Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Helene Wasserman BN130134 Shannon R. Boyce BN229041 Melissa Velez
Melissa Velez BN316714
LITTLER MENDELSON, P.C.
2049 Century Park East, 5th Floor, Los Angeles, CA 90067.3107 ELECTRONICALLY FILED
TELEPHONE NO.: 310.553.0308 FAX NO. (Optional): 310.553.5583 Superior Court of California
E-MAIL ADDRESS (Optional): hwasserman@littler.com; sboyce@littler.com
County of Santa Barbara
ATTORNEY FOR (Name): TRADER JOE’S COMPANY
Darrel E. Parker, Executive Officer
10/12/2022 12:17 PM
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Barbara
By: Leili Hejazi , Deputy
STREET ADDRESS: 1100 Anacapa Street
MAILING ADDRESS: 1100 Anacapa Street
CITY AND ZIP CODE: Santa Barbara 93101
BRANCH NAME: Anacapa
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): Melissa Velez
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): Trader Joe's Company
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):
PAGA complaint pursuant to Labor Code §§ 201-203 and 2698, et seq.
Page 1 of 5
Form Adopted for Mandatory Use
Judicial Council of California
CASE MANAGEMENT STATEMENT Cal. Rules of Court,
rules 3.720–3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
PLAINTIFF/PETITIONER: VICTORIA TICE CASE NUMBER:
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 sought, describe the nature of the relief.)
Plaintiff alleges Defendant violated Labor Code §§ 201-203 by issuing final wages through paycards without
authorization and for which aggrieved employees allegedly incurred fees. Defendant denies the claims and
denies that Plaintiff, or other current or former employees, are entitled to any recovery. Defendant further denies
that this matter is suitable for representative treatment.
(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): Feberuary 14, 2023
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):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 15 days on a representative basis.
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:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
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):
This is a class action (CA Rule of Court, Rule 3.811(b)(2)).
CM-110 [Rev. July 1, 2011]
CASE MANAGEMENT STATEMENT Page 2 of 5
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
PLAINTIFF/PETITIONER: VICTORIA TICE CASE NUMBER:
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):
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]
CASE MANAGEMENT STATEMENT Page 3 of 5
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
PLAINTIFF/PETITIONER: VICTORIA TICE CASE NUMBER:
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):
Defendant intends to file a motion for summary judgment.
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
Defendant Written Discovery Per Code
Defendant Deposition(s) of fact witnesses Per Code
Defendant Expert Discovery Per Code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011]
CASE MANAGEMENT STATEMENT Page 4 of 5
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
PLAINTIFF/PETITIONER: VICTORIA TICE CASE NUMBER:
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): Defendant seeks to move for summary adjudication, on the theory that because the paycard
program provided means by which former crew members would not incur fees the program was lawful. It would
decrease trial time and significantly increase the likelihood of settlement if the Court addressed this issue
summarily. Plaintiff refused to stipulate to permit summary adjudication briefing pursuant to subdivision (t) of
California Code of Civil Procedure 437c. Accordingly, Defendant respectfully requests that the Court authorize
briefing on this issue for summary adjudication.
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: October 12, 2022
Melissa Velez
(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]
CASE MANAGEMENT STATEMENT Page 5 of 5
American LegalNet, Inc.
www.FormsWorkFlow.com
1 PROOF OF SERVICE
2
At the time of service, I was over 18 years of age and not a party to this action. I am
3
employed in the County of Los Angeles, State of California. My business address is 633 West 5th
4
Street, 63rd Floor, Los Angeles, CA 90071.
5
6 On October 12, 2022, I served true copies of the following document(s) described as
7 CASE MANAGEMENT STATEMENT
8 the interested parties in this action as follows:
9 Larry W Lee William L. Marder
Max W. Gavron Polaris Law Group LLP
10 Diversity Law Group 501 San Benito St., Suite 200
11 515 S. Figueroa St., Suite 1250 Hollister, CA 95023
Los Angeles, CA 90071 Telephone: (831) 531-4214
12 Telephone: (213) 488-6555 Facsimile: (831) 634-0333
Facsimile: (213) 488-6554 Email: bill@polarislawgroup.com
13 lwlee@diversitylaw.com
mgavron@diversitylaw.com
14 Olympia@diversitylaw.com
15 Erika@diversitylaw.com
16
VIA ELECTRONIC SERVICE: Based on a court order or an agreement of the
17 parties to accept electronic service, including pursuant to Code of Civil Procedure
section 1010.6, which allows for service by e-mail or electronic transmission, I
18 caused the documents to be sent to the persons at the electronic service addresses
listed herein. My email address is mmorelli@littler.com.
19
20 I declare under penalty of perjury under the laws of the State of California that the
21 above is true and correct. Executed on October 12, 2022, at Los Angeles, California.
22
23
Michele Morelli
24
25
26
27 4867-9332-7657.1 / 071820-1075
28
LITTLER MEND ELSO N P.C.
2049 C entury Park East
5th Floor
Los Angeles, CA 90067.3107
310.553.0308
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Helene Wasserman BN130134 Shannon R. Boyce BN229041 Melissa Velez Melissa Velez BN316714 LITTLER MENDELSON, P.C. 2049 Century Park East, 5th Floor, Los Angeles, CA 90067.3107 ELECTRONICALLY FILED TELEPHONE NO.: 310.553.0308 FAX NO. (Optional): 310.553.5583 Superior Court of California E-MAIL ADDRESS (Optional): hwasserman@littler.com; sboyce@littler.com County of Santa Barbara ATTORNEY FOR (Name): TRADER JOE’S COMPANY Darrel E. Parker, Executive Officer 10/12/2022 12:17 PM SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Barbara By: Leili Hejazi , Deputy STREET ADDRESS: 1100 Anacapa Street MAILING ADDRESS: 1100 Anacapa Street CITY AND ZIP CODE: Santa Barbara 93101 BRANCH NAME: Anacapa 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): Melissa Velez 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): Trader Joe's Company 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): PAGA complaint pursuant to Labor Code §§ 201-203 and 2698, et seq. Page 1 of 5 Form Adopted for Mandatory Use Judicial Council of California CASE MANAGEMENT STATEMENT Cal. Rules of Court, rules 3.720–3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov American LegalNet, Inc. www.FormsWorkFlow.com CM-110 PLAINTIFF/PETITIONER: VICTORIA TICE CASE NUMBER: 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 sought, describe the nature of the relief.) Plaintiff alleges Defendant violated Labor Code §§ 201-203 by issuing final wages through paycards without authorization and for which aggrieved employees allegedly incurred fees. Defendant denies the claims and denies that Plaintiff, or other current or former employees, are entitled to any recovery. Defendant further denies that this matter is suitable for representative treatment. (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): Feberuary 14, 2023 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): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 15 days on a representative basis. 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: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: 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): This is a class action (CA Rule of Court, Rule 3.811(b)(2)). CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 of 5 American LegalNet, Inc. www.FormsWorkFlow.com CM-110 PLAINTIFF/PETITIONER: VICTORIA TICE CASE NUMBER: 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): 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] CASE MANAGEMENT STATEMENT Page 3 of 5 American LegalNet, Inc. www.FormsWorkFlow.com CM-110 PLAINTIFF/PETITIONER: VICTORIA TICE CASE NUMBER: 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): Defendant intends to file a motion for summary judgment. 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 Defendant Written Discovery Per Code Defendant Deposition(s) of fact witnesses Per Code Defendant Expert Discovery Per Code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5 American LegalNet, Inc. www.FormsWorkFlow.com CM-110 PLAINTIFF/PETITIONER: VICTORIA TICE CASE NUMBER: 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): Defendant seeks to move for summary adjudication, on the theory that because the paycard program provided means by which former crew members would not incur fees the program was lawful. It would decrease trial time and significantly increase the likelihood of settlement if the Court addressed this issue summarily. Plaintiff refused to stipulate to permit summary adjudication briefing pursuant to subdivision (t) of California Code of Civil Procedure 437c. Accordingly, Defendant respectfully requests that the Court authorize briefing on this issue for summary adjudication. 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: October 12, 2022 Melissa Velez (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] CASE MANAGEMENT STATEMENT Page 5 of 5 American LegalNet, Inc. www.FormsWorkFlow.com 1 PROOF OF SERVICE 2 At the time of service, I was over 18 years of age and not a party to this action. I am 3 employed in the County of Los Angeles, State of California. My business address is 633 West 5th 4 Street, 63rd Floor, Los Angeles, CA 90071. 5 6 On October 12, 2022, I served true copies of the following document(s) described as 7 CASE MANAGEMENT STATEMENT 8 the interested parties in this action as follows: 9 Larry W Lee William L. Marder Max W. Gavron Polaris Law Group LLP 10 Diversity Law Group 501 San Benito St., Suite 200 11 515 S. Figueroa St., Suite 1250 Hollister, CA 95023 Los Angeles, CA 90071 Telephone: (831) 531-4214 12 Telephone: (213) 488-6555 Facsimile: (831) 634-0333 Facsimile: (213) 488-6554 Email: bill@polarislawgroup.com 13 lwlee@diversitylaw.com mgavron@diversitylaw.com 14 Olympia@diversitylaw.com 15 Erika@diversitylaw.com 16 VIA ELECTRONIC SERVICE: Based on a court order or an agreement of the 17 parties to accept electronic service, including pursuant to Code of Civil Procedure section 1010.6, which allows for service by e-mail or electronic transmission, I 18 caused the documents to be sent to the persons at the electronic service addresses listed herein. My email address is mmorelli@littler.com. 19 20 I declare under penalty of perjury under the laws of the State of California that the 21 above is true and correct. Executed on October 12, 2022, at Los Angeles, California. 22 23 Michele Morelli 24 25 26 27 4867-9332-7657.1 / 071820-1075 28 LITTLER MEND ELSO N P.C. 2049 C entury Park East 5th Floor Los Angeles, CA 90067.3107 310.553.0308