Motion,Ex Parte: JAIME LIMON vs HERLINE GOUTAMA

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                                1 T.P. Skinner (SBN: 297710)
   SKINNER LAW GROUP APC
 2 1654 The Alameda, Suite 100
   San Jose, CA 95126
 3 Telephone: 408.813.9240
   tom@skinnerlawgroupca.com
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   Huy Tran (SBN 288196)                                                     2/16/2023
 5 Justice at Work Law Group, LLP
   1550 The Alameda, Suite 302
 6 San Jose, CA 95126
   Telephone: (408) 317-1100
 7 Facsimile: (408) 351-0105
   Huy@Jawlawgroup.com
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   Attorneys for Plaintiffs
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                   IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                             IN AND FOR THE COUNTY OF SAN MATEO
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                                                      Case No. 22-CIV-01527
      JAIME CALDERON LIMON, an
14    individual, and EDWIN HERRERA, an               NOTICE OF MOTION TO APPROVE
      individual, on behalf of the State of
15                                                    PAGA SETTLEMENT
      California and other aggrieved
      persons,
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17                   Plaintiffs,
                                                      Hearing Date: June 15, 2023
18                                                    Time: 9:00 am
             vs.                                      Location: Department 22
19                                                    Judge: Hon. Danny Y. Chou

20    HERLINE GOUTAMA, an individual,
      FC HEAVENLY ENTERPRISES, INC.
21    dba Let's Stage It, a California
      corporation, and Does 1 through 25,
22    inclusive,
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                     Defendants
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            TO DEFENDANTS AND THEIR COUNSEL OF RECORD:
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            PLEASE TAKE NOTICE THAT ON JUNE 15, 2023, at 9am or as soon thereafter as may
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     be heard by the complex division of the Superior Court of the State of California, County of San
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     Mateo, located at 800 N. Humboldt St., San Mateo, CA 94401, Plaintiffs JAIME CALDERON
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                NOTICE OF MOTION TO APPROVE PAGA SETTLEMENT; 22-CIV-01527
 1   LIMON and EDWIN HERRERA (together, “Plaintiffs”) will move for court approval of the

 2   PAGA settlement they executed with Defendants.

 3          This Motion is unopposed by Defendants.

 4          This Motion is based on the accompanying Memorandum of Points and Authorities, the

 5   Declarations of Huy Tran and Thomas P. Skinner, and pleadings on file, and any other such matters

 6   that the complex division of the San Mateo County Superior Court may consider in its

 7   determination that this matter should be designated as complex.

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     DATED: February 16, 2023                                   SKINNER LAW GROUP APC
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11                                                              /s/ T.P. Skinner______
                                                                Thomas P. Skinner
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                NOTICE OF MOTION TO APPROVE PAGA SETTLEMENT; 22-CIV-01527
                                              PROOF OF SERVICE
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                             STATE OF CALIFORNIA, SANTA CLARA COUNTY
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 3            I, Arely Alas, am a resident of Santa Clara County. I am over the age of eighteen years and not a
     party to the within-entitled action; my business address is 1654 The Alameda, Suite 100, San Jose Ca, 95126.
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 5           On 2/16/2023, I served the within:

 6           1)   Notice of Posting of Complex Fees
             2)   Notice of Motion to Approve PAGA Settlement
 7           3)   Memorandum of Points and Authorities ISO Motion to Approve PAGA Settlement
             4)   Declaration of Thomas P. Skinner ISO Motion to Approve PAGA Settlement
 8           5)   Declaration of Huy Tran Motion to Approve PAGA Settlement

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11   [X] BY ELECTRONIC MAIL: On February 16, 2023, by use of electronic “email” address
12   arely@skinnerlawgroupca.com, I served the above-named document[s] on the party[ies] named
     below, in the above referenced matter, by transmitting by electronic mail to each party’s electronic
13   “email” address listed below.
14   Attorneys for Defendants:

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                     Na Rae Kim
16                   NaRae.Kim@lewisbrisbois.com
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                     Robert Lockwood
18                   Robert.Lockwood@lewisbrisbois.com
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                     Joseph Lordan
20                   Joseph.Lordan@lewisbrisbois.com

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             Executed on 2/16/2023 at San Jose, California.
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                                                                     /s/ Arely Alas
23                                                                   Arely Alas

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                  NOTICE OF MOTION TO APPROVE PAGA SETTLEMENT; 22-CIV-01527