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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Larry W. Lee (SBN. 228175); Max W. Gavron (SBN 291697)
DIVERSITY LAW GROUP
515 South Figueroa Street, Suite 1250 ELECTRONICALLY FILED
Los Angeles, CA 90071 Superior Court of California
TELEPHONE NO.: (213) 488-6555 FAX NO. (Optional): (213) 488-6554 County of Santa Barbara
E-MAIL ADDRESS (Optional):
Darrel E. Parker, Executive Officer
Plaintiff Victoria Tice
ATTORNEY FOR (Name): 9/29/2022 12:14 PM
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA By: Terri Chavez , Deputy
STREET ADDRESS:1100 Anacapa Street
P.O. Box 21107
MAILING ADDRESS:
Santa Barbara, CA 93121
CITY AND ZIP CODE:
BRANCH NAME:Anacapa Division
PLAINTIFF/PETITIONER: Victoria Tice
DEFENDANT/RESPONDENT: Trader Joe's Company
CASE MANAGEMENT STATEMENT CASE NUMBER:
20CV00892
(Check one): UNLIMITED CASE LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: October 14, 2022 Time: 8:30 a.m. Dept.: 3 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Max W. Gavron
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. This statement is submitted by party (name): Plaintiff Victoria Tice
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): February 14, 2020
b. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. The following parties named in the complaint or cross-complaint
(1) have not been served (specify names and explain why not):
(2) have been served but have not appeared and have not been dismissed (specify names):
(3) have had a default entered against them (specify names):
c. The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of case in complaint cross-complaint (Describe, including causes of action):
This is a wage and hour action. Plaintiff asserted class wide claims for violation of Labor Code sections 201-203.
Plaintiff also seeks civil penalties pursuant to California Labor Code Section 2698, et seq. The Court denied Plaintiff’ s
Motion for Class Certification on September 21, 2021. Plaintiff continues to prosecute her claim under the PAGA.
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California
CASE MANAGEMENT STATEMENT rules 3.720–3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Victoria Tice
20CV00892
DEFENDANT/RESPONDENT: Trader Joe's Company
4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, including medical
expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is
Plaintiff seeks penalties, pursuant to Labor Code Sections 201-203, for Defendant’s
sought, describe the nature of the relief.)
failure to pay putative class members all wages due and owing upon separation from employment in
circumstances where Defendant paid employees their final wages on pay cards without prior authorization.
Plaintiff also seeks civil penalties as set forth in California Labor Code Section 2698, et seq, attorneys’ fees, and
costs.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request a jury triaI a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. The trial has been set for (date): 2/14/23
b. No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): because
of previously scheduled trials:
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 3-4
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption by the following:
a. Attorney: William L. Marder
b. Firm: Polaris Law Group LLP
c. Address: 501 San Benito Street, Suite 200
d. Telephone number: (831) 531-4214 f. Fax number: (831) 634-0333
e. E-mail address: bill@polarislawgroup.cpom g. Party represented: Plaintiff
Additional representation is described in Attachment 8.
9. Preference
This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel has has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM-110 [Rev. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Victoria Tice
20CV00892
DEFENDANT/RESPONDENT: Trader Joe's Company
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date): 11/17/20
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date) :
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
arbitration
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Victoria Tice 20CV00892
DEFENDANT/RESPONDENT: Trader Joe's Company
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes No
c. Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
Bankruptcy Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate wiII be filed by (name party):
14. Bifurcation
The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. The party or parties have completed all discovery.
b The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiff Written discovery Per Code
Plaintiff Depositions of parties and witnesses Per Code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
On August 31, 2022, the Court granted Defendant’s Motion to Quash a subpoena issued by Plaintiff. Plaintiff
recently reissued the subpoena to the third-party pay card provider seeking information regarding fees
incurred by the aggrieved employees and served notices to consumer.
CM-110 [Rev. July 1, 2011] Page 4 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Victoria Tice
20CV00892
DEFENDANT/RESPONDENT: Trader Joe's Company
17. Economic litigation
a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of
Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any):
I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: September 29, 2022
Max W. Gavron
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev. July 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
1 PROOF OF SERVICE
2 (Code of Civil Procedure Sections 1013a, 2015.5)
3
STATE OF CALIFORNIA ]
4 ]ss.
COUNTY OF LOS ANGELES ]
5
6 I am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action; my business address is 515 S. Figueroa Street, Suite 1250,
7 Los Angeles, California 90071.
8 On September 29, 2022, I served the following document(s) described as: CASE
9 MANAGEMENT STATEMENT on the interested parties in this action as follows:
10 Helene Wasserman hwasserman@littler.com
Shannon R. Boyce sboyce@littler.com
11 Melissa Velez mvelez@littler.com
12 Carolyn Ward cward@littler.com
Littler Mendelson, P.C.
13 2049 Century Park East, 5th Floor
Los Angeles, CA 90067
14 Attorneys for Defendant Trader Joe’s
15 Company
16 X BY ELECTRONIC SERVICE: Based on a court order I caused the above-
entitled document(s) to be served through the Odyssey eFileCA E-Filing System at the website
17 www.california.tylerhost.net, addressed to all parties appearing on the electronic service list for
18 the above-entitled case. The service transmission was reported as complete and a copy of the
filing receipt/confirmation will be filed, deposited, or maintained with the original document(s)
19 in this office.
20 I declare under penalty of perjury under the laws of the State of California that the above
21 is true and correct. Executed on September 29, 2022, at Los Angeles, California.
22
_________________________________
23 Erika Mejia
24
25
26
27
28
PROOF OF SERVICE
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Larry W. Lee (SBN. 228175); Max W. Gavron (SBN 291697) DIVERSITY LAW GROUP 515 South Figueroa Street, Suite 1250 ELECTRONICALLY FILED Los Angeles, CA 90071 Superior Court of California TELEPHONE NO.: (213) 488-6555 FAX NO. (Optional): (213) 488-6554 County of Santa Barbara E-MAIL ADDRESS (Optional): Darrel E. Parker, Executive Officer Plaintiff Victoria Tice ATTORNEY FOR (Name): 9/29/2022 12:14 PM SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA By: Terri Chavez , Deputy STREET ADDRESS:1100 Anacapa Street P.O. Box 21107 MAILING ADDRESS: Santa Barbara, CA 93121 CITY AND ZIP CODE: BRANCH NAME:Anacapa Division PLAINTIFF/PETITIONER: Victoria Tice DEFENDANT/RESPONDENT: Trader Joe's Company CASE MANAGEMENT STATEMENT CASE NUMBER: 20CV00892 (Check one): UNLIMITED CASE LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: October 14, 2022 Time: 8:30 a.m. Dept.: 3 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Max W. Gavron INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): Plaintiff Victoria Tice b. This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): February 14, 2020 b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. The following parties named in the complaint or cross-complaint (1) have not been served (specify names and explain why not): (2) have been served but have not appeared and have not been dismissed (specify names): (3) have had a default entered against them (specify names): c. The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type of case in complaint cross-complaint (Describe, including causes of action): This is a wage and hour action. Plaintiff asserted class wide claims for violation of Labor Code sections 201-203. Plaintiff also seeks civil penalties pursuant to California Labor Code Section 2698, et seq. The Court denied Plaintiff’ s Motion for Class Certification on September 21, 2021. Plaintiff continues to prosecute her claim under the PAGA. Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Victoria Tice 20CV00892 DEFENDANT/RESPONDENT: Trader Joe's Company 4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is Plaintiff seeks penalties, pursuant to Labor Code Sections 201-203, for Defendant’s sought, describe the nature of the relief.) failure to pay putative class members all wages due and owing upon separation from employment in circumstances where Defendant paid employees their final wages on pay cards without prior authorization. Plaintiff also seeks civil penalties as set forth in California Labor Code Section 2698, et seq, attorneys’ fees, and costs. (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request a jury triaI a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. The trial has been set for (date): 2/14/23 b. No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): because of previously scheduled trials: 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 3-4 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption by the following: a. Attorney: William L. Marder b. Firm: Polaris Law Group LLP c. Address: 501 San Benito Street, Suite 200 d. Telephone number: (831) 531-4214 f. Fax number: (831) 634-0333 e. E-mail address: bill@polarislawgroup.cpom g. Party represented: Plaintiff Additional representation is described in Attachment 8. 9. Preference This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel has has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Victoria Tice 20CV00892 DEFENDANT/RESPONDENT: Trader Joe's Company 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): 11/17/20 Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date) : Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Victoria Tice 20CV00892 DEFENDANT/RESPONDENT: Trader Joe's Company 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes No c. Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Bankruptcy Other (specify): Status: 13. Related cases, consolidation, and coordination a. There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: Additional cases are described in Attachment 13a. b. A motion to consolidate coordinate wiII be filed by (name party): 14. Bifurcation The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. The party or parties have completed all discovery. b The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Plaintiff Written discovery Per Code Plaintiff Depositions of parties and witnesses Per Code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): On August 31, 2022, the Court granted Defendant’s Motion to Quash a subpoena issued by Plaintiff. Plaintiff recently reissued the subpoena to the third-party pay card provider seeking information regarding fees incurred by the aggrieved employees and served notices to consumer. CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Victoria Tice 20CV00892 DEFENDANT/RESPONDENT: Trader Joe's Company 17. Economic litigation a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: September 29, 2022 Max W. Gavron (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. July 1, 2011] Page 5 of 5 CASE MANAGEMENT STATEMENT American LegalNet, Inc. www.FormsWorkFlow.com 1 PROOF OF SERVICE 2 (Code of Civil Procedure Sections 1013a, 2015.5) 3 STATE OF CALIFORNIA ] 4 ]ss. COUNTY OF LOS ANGELES ] 5 6 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is 515 S. Figueroa Street, Suite 1250, 7 Los Angeles, California 90071. 8 On September 29, 2022, I served the following document(s) described as: CASE 9 MANAGEMENT STATEMENT on the interested parties in this action as follows: 10 Helene Wasserman hwasserman@littler.com Shannon R. Boyce sboyce@littler.com 11 Melissa Velez mvelez@littler.com 12 Carolyn Ward cward@littler.com Littler Mendelson, P.C. 13 2049 Century Park East, 5th Floor Los Angeles, CA 90067 14 Attorneys for Defendant Trader Joe’s 15 Company 16 X BY ELECTRONIC SERVICE: Based on a court order I caused the above- entitled document(s) to be served through the Odyssey eFileCA E-Filing System at the website 17 www.california.tylerhost.net, addressed to all parties appearing on the electronic service list for 18 the above-entitled case. The service transmission was reported as complete and a copy of the filing receipt/confirmation will be filed, deposited, or maintained with the original document(s) 19 in this office. 20 I declare under penalty of perjury under the laws of the State of California that the above 21 is true and correct. Executed on September 29, 2022, at Los Angeles, California. 22 _________________________________ 23 Erika Mejia 24 25 26 27 28 PROOF OF SERVICE