On February 14, 2020 a
Party Notice
was filed
involving a dispute between
Tice, Victoria,
and
Trader Joe'S Company,
for Unlimited Other Employment (15)
in the District Court of Santa Barbara County.
Preview
1 Larry W. Lee, Bar No. 228175
Max W. Gavron, Bar No. 291697
2 DIVERSITY LAW GROUP
515 S. Figueroa St., Suite 1250
3 Los Angeles, CA 90071
Telephone: (213) 488-6555
4 Facsimile: (213) 488-6554
5 Attorneys for Plaintiff
VICTORIA TICE
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9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 FOR THE COUNTY OF SANTA BARBARA
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12 VICTORIA TICE, as an individual and on Case No. 20CV00892
behalf of all others similarly situated,
13 NOTICE OF SETTLEMENT
Plaintiff,
14
v.
15 Trial Date: February 14, 2023
TRADER JOE’S COMPANY, a California Complaint Filed: February 14, 2021
16 corporation; and DOES 1 through 50, inclusive,
17 Defendant.
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NOTICE OF SETTLEMENT
1 The Parties have arrived at a proposed resolution with the assistance of a mediator and
2 have executed a memorandum of understanding. The Parties anticipate drafting and executing a
3 longform settlement agreement within the next 30 days after which Plaintiff will move for
4 preliminary approval. The Parties wish to notify the Court and request that the Court vacate all
5 dates and deadlines in anticipation of Plaintiff moving for approval of the proposed settlement.
6
7 Dated: December 20, 2022
8 Larry W. Lee
Max W. Gavron
9 DIVERSITY LAW GROUP
Attorneys for Plaintiffs
10 VICTORIA TICE
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NOTICE OF SETTLEMENT
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 December 20, 2022, I served the following document(s) described as: NOTICE OF
9 SETTLEMENT 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 December 20, 2022, at Los Angeles, California.
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_________________________________
23 Olympia Pena
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PROOF OF SERVICE
Document Filed Date
December 20, 2022
Case Filing Date
February 14, 2020
Category
Unlimited Other Employment (15)
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1 Larry W. Lee, Bar No. 228175 Max W. Gavron, Bar No. 291697 2 DIVERSITY LAW GROUP 515 S. Figueroa St., Suite 1250 3 Los Angeles, CA 90071 Telephone: (213) 488-6555 4 Facsimile: (213) 488-6554 5 Attorneys for Plaintiff VICTORIA TICE 6 7 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SANTA BARBARA 11 12 VICTORIA TICE, as an individual and on Case No. 20CV00892 behalf of all others similarly situated, 13 NOTICE OF SETTLEMENT Plaintiff, 14 v. 15 Trial Date: February 14, 2023 TRADER JOE’S COMPANY, a California Complaint Filed: February 14, 2021 16 corporation; and DOES 1 through 50, inclusive, 17 Defendant. 18 19 20 21 22 23 24 25 26 27 28 1 NOTICE OF SETTLEMENT 1 The Parties have arrived at a proposed resolution with the assistance of a mediator and 2 have executed a memorandum of understanding. The Parties anticipate drafting and executing a 3 longform settlement agreement within the next 30 days after which Plaintiff will move for 4 preliminary approval. The Parties wish to notify the Court and request that the Court vacate all 5 dates and deadlines in anticipation of Plaintiff moving for approval of the proposed settlement. 6 7 Dated: December 20, 2022 8 Larry W. Lee Max W. Gavron 9 DIVERSITY LAW GROUP Attorneys for Plaintiffs 10 VICTORIA TICE 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 NOTICE OF SETTLEMENT 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 December 20, 2022, I served the following document(s) described as: NOTICE OF 9 SETTLEMENT 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 December 20, 2022, at Los Angeles, California. 22 _________________________________ 23 Olympia Pena 24 25 26 27 28 PROOF OF SERVICE