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FiLED
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Sfafe Barnumber, and address) SstmaasstSBONLY
Shane Singh (SBN 202733)/ Grace E. Mehta (SBN 327676)
06/23/2022
Lewis Brisbois Bisgaard & Smith, LLP
2020 West El Camino Avenue, Suite 700 ddonKIn
Sacramento, CA 95833 , Depijty
TELEPHONENO 916.564.5400 FAXNO (Opffona/; 916.564.5444 Case Humb^r.
E-MAIL ADDRESS (Optional)- Shane.Singh@lewisbrisbois.eom
ATTORNEY FOR (fvamej Defendant AsomBO Environmental Restoration Industry
34=2019-0026294$
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO
STREETADDRESS 720 Ninth Street
MAIUNG ADDRESS
CITY AND ZIP CODE Sacrsmento, CA 95814 i
BRANCH NAME
PLAINTIFF/PETITIONER: JAY ROBINSON, et al.
DEFENDANT/RESPONDENT: ASOMEO ENVIRONMENTAL RESTORATION INDUSTRY, et al.
C A S E MANAGEMENT STATEMENT CASE NUMBER
(Check one): M UNLIIUITED CASE • LiiVIITED CASE
34-2019-00262942-CU-OE-GDS
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: July 8,2022 Time: 8:30 a.m. Dept: 31 Div.: Room:
Address of court (ff different from the address above):
^ Notice of Intent to Appear by Telephone, by (name): Grace Mehta
INSTRUCTIONS: All applicable boxes must be checlced, and the specified information must be provided.
1. Party or parties (answer one):
a. ^ This statement is submitted by party (name): Defendant Asomeo Environmental Restoration Industry, LLC
b. CD This statement is submitted jointly by parties (names):
Complaint and cross-complaint (fo be answemd by plaintfffs and cross-complainants only) P3
a. The complaint was filed on (date):
b. CD The cross-complaint, if any, was filed on (date):
Service (fo be answered by plaintfffs and cross-complainants only)
a. CD All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. CD The following parties named in the complaint or cross-complaint
(1) •
(2) •
(3) •
CD The following additional parties may be added (specffy names, natum of involvement in case, and date by which
they may be served):
Description of case
a. Type of case in ^ complaint D cross-complaint (Describe, induding causes of action):
Class Action Complaint alleging various wage and hour violations, such as meal and rest periods, pay overtime
and minimum wages, reimburse for employment related expenses, and provide accurate wage statements.
Pane 1 of 5
Forni Adopted fbr Mandatoiy Use Cal Rules of Court,
Judicial Councll of California CASE MANAGEMENT STATEMENT mles 3.720-3 730
CM-110 [Rev julyl,2011] www courts ca.gov
American LegalNet, Inc.
www FomisWorkFlQw.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: JAY ROBINSON, et al.
34-2019-00262942-CU-OE-GDS
"DEFENDANT/RESPONDENT: ASOMEO ENVIRONMENTAL RESTORATION INDUSTRY, et al.
4. b. Provide a brief statement of the case, including any damages, (ff personal injury damages am sought specffy the injury and
damages claimed, including medical expenses to date [indicate source and amount] estimated future medical expenses, lost
eamings to date, and estimated futum lost eamings. ff equitable relief is sought describe the nature ofthe relief)
The Class Action Complaint alleges wage and hour violations based on Defendant's purported failure to provide
meal and rest periods, pay earned wages, reimburse for employment related expenses, and provide accurate
wage statements. Defendant contests Plaintiffs' claims and contentions.
CD (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 trial CD a nonjury trial. (ff more than one party, pmvide the name of each party
requesting a jury trial):
6. Trial date
a. CD The trial has been set for (date):.
b. KI 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 (ff
not explain): Pre-certification and post-certification procedures (if any) preclude trial within 12 months ofthe
filing of the complaint.
c. Dates on which parties or attomeys will not be available for trial (specffy dates and explain masons for unavailability):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. ! 3 days (specffy number): 5-7
b. CD hours (short causes) (specffy):
Trial representation (to be answemd for each party)
The party or parties will be represented at trial ^ by the attorney or party listed in the caption D by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f Fax number:
e. E-mail address: g. Party represented:
CD Additional representation is described in Attachment 8.
9. Preference
CD This case is entitled to preference (spedfy code section):
10. Altemative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR infbrmation package provided by the court under rule 3.221 fbr 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 D has D has not reviewed the ADR information package identified in mle 3.221.
b. Referral to judicial arbitration or civii action mediation (if available).
(1) CD 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) CD 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) ISI This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court orft-omcivil action
mediation under Code of Civil Procedure section 1775 et seq. (specffy exemption):
Rule 3.811 (b)(2) of the California Rules of Court.
CM-110 [Rev July 1,2011] Page 2 of 5
C A S E MANAGEMENT STATEMENT
American LegalNet, Inc.
www FormsWorkFlow com
CM-110
CASE NUMBER
PLAINTIFF/PETITIONER: JAY ROBINSON, et al.
34-2019-00262942-CU-OE-GDS
DEFENDANT/RESPONDENT: ASOMEO ENVIRONMENTAL RESTORATION INDUSTRY, et al.
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 pmvide the specffied information):
The party or parties completing If the party or parties completing this fomn 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 ofthe processes (attach a copy ofthe parties'ADR
processes (check all that apply): stipulation):
CD Mediation session not yet scheduled
CD Mediation session scheduled for (date):
(1) Mediation El
CD Agreed to complete mediation by (dafe);
CD Mediation completed on (dafe):
CD Settlement conference not yet scheduled
(2) Settlement CD Settlement conference scheduled for (dafe);
conference El
CD Agreed to complete settlement conference by (dafe);
CD Settlement conference completed on (dafe):
CD Neutral evaluation not yet scheduled
CD Neutral evaluation scheduled for (date):
(3) Neutral evaluation •
CD Agreed to complete neutral evaluation by (dafe);
CD Neutral evaluation completed on (dafe):
CD Judicial arbitration not yet scheduled
(4) Nonbinding judicial CD Judicial arbitration scheduled for (dafe);
arbitration •
CD Agreed to complete judicial arbitration by (dafe);
CD Judicial arbitration completed on (dafe):
CD Private artiitration not yet scheduled
(5) Binding private • Private artiitration scheduled for (dafe);
arbitration •
CD Agreed to complete private arbitration by (dafe);
n Private artiitration completed on (dafe):
n ADR session not yet scheduled
(6) Other (specify): • ADR session scheduled for (dafe);
•
• Agreed to complete ADR session by (dafe);
CD ADR completed on (dafe):
CM-110 [Rev July 1,2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc
www FonnsWorkFlow com
CM-110
CASE NUMBER
PLAINTIFF/PETITIONER: JAY R O B I N S O N , et al.
34-2019-00262942-CU-OE-GDS
"DEFENDANT/RESPONDENT: ASOMEO ENVIRONMENTAL RESTORATION INDUSTRY
11. Insurance
a. n Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: D Yes • No
c. CD 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 D Other (spec^;;
Status:
13. Related cases, consolidation, and coordination
a. CD There are companion, underiying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
• Additional cases are described in Attachment 13a.
• A motion to CD consolidate CD coordinate will be filed by (name parfy/'
14. Bifurcation
CD 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, fype of motion, and reasons):
15. Other motions
^ The party or parties expect tofilethe following motions before trial (specify moving parfy,fypeof motion, and issues):
Defendant's motion for class decertification in the event a prior motion for class certification is granted.
16. Discovery
a. CD The party or parties have completed all discovery.
b ^ The following discovery will be completed by the date specified (describe all anticipated discovery):
Partv Description Date
Defendant Document Inspection Demand TBD
Defendant Special Interrogatories TBD
Defendant Plaintiffs Deposition TBD
CD The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1,2011] Page 4 of 6
C A S E MANAGEMENT STATEMENT
American LegalNet, inc.
www FormsWorkFlow com
CM-110
CASE NUMBER.
PLAINTIFF/PETITIONER: JAY ROBINSON, et al.
34-2019-00262942-CU-OE-GDS
DEFENDANT/RESPONDENT: ASOMEO ENVIRONMENTAL RESTORATION INDUSTRY, et al.
17. Economic litigation
a. CD 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. CD This is a limited civil case and a motion to withdraw the caseft-omthe economic litigation procedures or for additional
discovery will be filed (ff checked, explain specifically why economic litigation procedums relating to discovery or trial
should not apply to this case):
18. Other issues
CD 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. CD The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the Califomia Rules of
Court (ffnot explain): The parties have informally met and conferred to stipulate to Plaintiffs' filing ofthe Second
Amended Complaint.
b. After meeting and conferring as required by rule 3.724 ofthe Califomia Rules of Court, the parties agree on the following
(specffy):
20. Total number of pages attached (ffany):
I am completely familiar with this case and will be fully prepared to discuss the status of discovery and altemative 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: June 23, 2022
Grace E. Mehta
(TYPE OR PRINT NAME) (SIGtWTURE OF RARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
n Additional signatures are attached.
CM-110 [Rev July 1,2011] Page 6 of 6
C A S E MANAGEMENT STATEMENT
American LegalNet, Inc
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1 CALIFORNIA STATE COURT PROOF OF SERVICE
Jay Robinson, et al. v. Asomeo Environmental Restoration Industry, LLC
2 34-2019-00262942-CU-OE-GDS
3 STATE OF CALIFORNIA, COUNTY OF SACRAMENTO
4 At the time of service, I was over 18 years of age and not a party to this action. My
business address is 2020 West El Camino Avenue, Suite 700, Sacramento, CA 95833.
5
On June 23, 2022,1 served true copies of the following document(s):
6
CASE MANAGEMENT STATEMENT
7
I served the documents on the following persons at the following addresses (including fax
8 numbers and e-mail addresses, if applicable):
9 Attornevs for Plaintiffs, Jay Robinson and Attornevs for Defendant, Phillips & Jordan,
Huso Pineda Inc
10 Patricia A. Savage Morgan P. Forsey
11 Savage, Lamb & Lunde, PC Victoria L. Tallman
1550 Humboldt Road, Suite 4 Amanda E. Beckwith
12 Chico, CA 95928 Sheppard, Mullin, Richter & Hampton LLP
Phone: 530.592.3861 Four Embarcadero Center, 17*^ Floor
13 Fax: 530.592.3865 San Francisco, CA 94111-4109
Email: psavesq@gmail.com Phone: 415.434.9100
14 Fax: 415.434.3947
Email: mforsey(^sheppardmullin.com
15 vtallman(@sheppardmullin.com
abeckwith (gsheppardmullin.com
16
17 The documents were served by the following means:
18 @ (BY U.S. MAIL) I enclosed the documents in a sealed envelope or package addressed to
the persons at the addresses listed above and:
19
• Deposited the sealed envelope or package with the U.S. Postal Service, with the
20 postage fully prepaid.
21 HI Placed the envelope or package for collection and mailing, following our ordinary
business practices. I am readily familiar with the firm's practice for collection and processing
22 correspondence for mailing. Under that practice, on the same day that correspondence is placed
for collection and mailing, it is deposited in the ordinary course of business with the U.S. Postal
23 Service, in a sealed envelope or package with the postage fully prepaid.
24 H (BY E-MAIL OR ELECTRONIC TRANSMISSION) Based on a court order or an
agreement ofthe parties to accept service by e-mail or electronic transmission, I caused the
25 documents to be sent from e-mail address anne.french@lewisbrisbois.com to the persons at
the e-mail addresses listed above. I did not receive, within a reasonable time after the
26 transmission, any electronic message or other indication that the transmission was
unsuccessful.
27
I declare under penalty of perjury under the laws of the State of Califomia that the
28 foregoing is true and correct.
4881-5415-2998.1 1
PROOF OF SERVICE
1 Executed on June 23, 2022, at Sacramento, Califomia.
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4881-5415-2998 1
PROOF OF SERVICE