Motion-Secondary: VICTOR FARDANESH VS HEALTHCARE SERVICES GROUP, INC., ET AL.

• 
• 

						
                                
Preview
                                Aimneny
                                                soiid
                                                   dwee od


     KENNETH D. SULZER (SBN 120253)
     ksulzer@constangy.com                                                            FILE
                                                                                    ior Court of California
     MATTHEW SCHOLL (SBN 301560)                                                     inty of Los Angeles
     mscholl@constangy.com
     CONSTANGY, BROOKS, SMITH & PROPHETE, LLP                                       DEC 31 2020
     2029 Century Park East, Suite 1100                                 Sherri
                                                                                           ve Officer/Clerk of Court
     Los Angeles, CA 90067                                               By,
     Telephone: (310) 909-7775                                                                             Deputy
     Facsimile: (424) 276-7410



                                                                               Ir
     Attorneys for Defendants                                                                   ic
                                                                                       \LA\ [
     HEALTHCARE SERVICES GROUP, INC. and                                                  ==
     HCSG WEST LLC

                         THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

10                                  FOR THE COUNTY OF LOS ANGELES

ll    VICTOR FARDANESH, individually,               Case No.: 20STCV33872
      and on behalf of other members of the
12    general public similarly situated,             [Case Assigned to Hon. Elihu M. Berle, Dept. 6]
13
                               Plaintiff,           DECLARATION OF TAMI FORD IN
14                                                  SUPPORT OF DEFENDANTS’ MOTION TO
                 VS.                                COMPEL ARBITRATION
15
                                                    Filed concurrently with:
      HEALTHCARE SERVICES GROUP,                            Notice of Motion and Motion to Compel
16    INC., an unknown business entity; HCSG                Arbitration
17    WEST LLC, an unknown business entity;                 Declaration of Matthew Scholl in Support of
      915 QUALITY BUSINESS                                  Defendants’ Motion to Compel
18    SOLUTIONS, INC., and DOES 1 through                    [Proposed] Order
      100, inclusive,                                       Proof of Service
19
                                                    Date:   February 10, 2021
                               Defendants.          Time:   9:00 a.m.
20
                                                    Dept.   6
21

22

23
24          I, Tami Ford, declare as follows:

25           1          I have been employed   by Healthcare Services Group, Inc. (“Healthcare Services

26 || Group”) since March 2013.      Healthcare Services Group is the parent company of HCSG West LLC

27   (together, “HCSG”).     With the exception of the period from June 2019 through early-December 2019,

28   I have been employed by Healthcare Services Group as the California Human Resources Director

                                          1
            DECLARATION OF TAMI FORD ISO MOTION TO COMPEL ARBITRATION