On March 26, 2019 a
Motion-Secondary
was filed
involving a dispute between
Huisar, Sulin,
and
Applied Behavior Consultants, Inc A Corporation,
Does 1-20,
for Employment - Complex
in the District Court of San Bernardino County.
Preview
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VACHE A. THOMASSIAN (SB. #289053)
vache@kjtlawgr0up.com
CASPARJIVALAGIAN (S.B. #282818)
caspar@kjtlawgroup.com
KJT LAW GROUP LLP. SUPE FI L
COU’zgyROcFoURT OF
230 N. Maryland Ave., Sulte 306
‘
SAN CA
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BERNALIIQFDOIRNM
Glendale, CA 91206 DIS :c‘T'O
©WNO§NA
Telephone: 818.507.8525 JUL 0 a
2021
CHRISTOPHER A. ADAMS (8.13. #266440)
ca@AdamsEmploymentCounsel.com
ADAMS EMPLOYMENT COUNSEL
230 N. Malyland Ave., Suite 306
Glendale, CA 91206
Telephone: 818.425.1437
Attorneys for Plaintiff Sulin Huisar, 011 behalf 0f
GB_IH
herself and all others similarly situated
m SUPERIOR COURT OF THE STATE OF CALIFORNIA
P 306
COUNTY OF SAN BERNARDINO A8
Rou Suite
Avc‘
91206
SULIN HUISAR, individually and 011 behalf 0f Case No.: CIV-D81909249 XV:|
all others similarly situated,
Maryland
CA
KJTLAWG
. Assigned For All Purposes To:
Pl am”.ff ’
N. Glendale, Judge: David Cohn
230
V.
Dept: 8-26
APPLIED BEHAVIOR CONSULTANTS, DECLARATION OF CHRISTOPHER A.
INC., a corporation; and DOES 1-20, inclusive,
ADAMS IN SUPPORT OF PLAINTIFFIS
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MOTION FOR FINAL APPROVAL OF
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CLASS AND COLLECTIVE ACTION
Defendants.
SETTLEMENT
Hearing Information:
Location: Dept. 8-26
Date: July 29, 2021
Time: 10:00 a.m.
Action Filed: March 26, 2019
Trial Date: None Set
1
DECLARATION OF CHRISTOPHER A. ADAMS IN SUPPORT OF MOTION FOR FINAL APPROVAL OF
CLASS ACTION SETTLEMENT
DECLARATION OF CHRISTOPHER A. ADAMS
I, Christopher A. Adams, declare as follows:
1. I am an attorney duly licensed t0 practice law before all courts in the State 0f
California. I am an attorney with the law practice 0f Adams Employment Counsel and I, along With
©mVO§U1¥00NA
co—counsel, KJT Law Group LLP, represent Plaintiff Sulin Huisar (collectively, “Plaintiff”) in this
action against Defendant Applied Behavior Consultants, Inc. (“Defendant”). I have personal
knowledge 0f the facts set forth herein and, if called and sworn in as a witness, could and would
testify competently thereto. I submit this declaration in support 0f Plaintiffs Motion for Final
Approval 0f Class Action Settlement.
2. Defendant Applied Behavior Consultants, Inc. provides services for individuals with
autism and other developmental disabilities.
m
P 3. KJT Law Group LLP and Adams Employment Counsel have prosecuted this
u 306
Suite
R0 litigation solely 011 a contingent-fee basis, and have been completely at risk that it would not receive
Ave.
91206
any compensation for prosecuting Claims against Defendant. While KJT Law Group LLP and
Maryland
CA
KJTLAWG Adams Employment Counsel devoted its time and resources t0 this matter, they have foregone
N. Glendale,
other legal work for which they would have been compensated.
230
4. My office and KJT Law Group LLP are qualified t0 handle this litigation because we
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are experienced in litigating Labor Code violations in both individual and Class action cases,
mem¥wonflomNo3m
Document Filed Date
July 08, 2021
Case Filing Date
March 26, 2019
Category
Employment - Complex
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Preview
\v f". r V OR‘ G N iwL R \ VACHE A. THOMASSIAN (SB. #289053) vache@kjtlawgr0up.com CASPARJIVALAGIAN (S.B. #282818) caspar@kjtlawgroup.com KJT LAW GROUP LLP. SUPE FI L COU’zgyROcFoURT OF 230 N. Maryland Ave., Sulte 306 ‘ SAN CA gsflmigy”0 BERNALIIQFDOIRNM Glendale, CA 91206 DIS :c‘T'O ©WNO§NA Telephone: 818.507.8525 JUL 0 a 2021 CHRISTOPHER A. ADAMS (8.13. #266440) ca@AdamsEmploymentCounsel.com ADAMS EMPLOYMENT COUNSEL 230 N. Malyland Ave., Suite 306 Glendale, CA 91206 Telephone: 818.425.1437 Attorneys for Plaintiff Sulin Huisar, 011 behalf 0f GB_IH herself and all others similarly situated m SUPERIOR COURT OF THE STATE OF CALIFORNIA P 306 COUNTY OF SAN BERNARDINO A8 Rou Suite Avc‘ 91206 SULIN HUISAR, individually and 011 behalf 0f Case No.: CIV-D81909249 XV:| all others similarly situated, Maryland CA KJTLAWG . Assigned For All Purposes To: Pl am”.ff ’ N. Glendale, Judge: David Cohn 230 V. Dept: 8-26 APPLIED BEHAVIOR CONSULTANTS, DECLARATION OF CHRISTOPHER A. INC., a corporation; and DOES 1-20, inclusive, ADAMS IN SUPPORT OF PLAINTIFFIS NNNNNNNNNAAAAAAAAAA MOTION FOR FINAL APPROVAL OF mVOfim-fiwwdommflmthNAo CLASS AND COLLECTIVE ACTION Defendants. SETTLEMENT Hearing Information: Location: Dept. 8-26 Date: July 29, 2021 Time: 10:00 a.m. Action Filed: March 26, 2019 Trial Date: None Set 1 DECLARATION OF CHRISTOPHER A. ADAMS IN SUPPORT OF MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT DECLARATION OF CHRISTOPHER A. ADAMS I, Christopher A. Adams, declare as follows: 1. I am an attorney duly licensed t0 practice law before all courts in the State 0f California. I am an attorney with the law practice 0f Adams Employment Counsel and I, along With ©mVO§U1¥00NA co—counsel, KJT Law Group LLP, represent Plaintiff Sulin Huisar (collectively, “Plaintiff”) in this action against Defendant Applied Behavior Consultants, Inc. (“Defendant”). I have personal knowledge 0f the facts set forth herein and, if called and sworn in as a witness, could and would testify competently thereto. I submit this declaration in support 0f Plaintiffs Motion for Final Approval 0f Class Action Settlement. 2. Defendant Applied Behavior Consultants, Inc. provides services for individuals with autism and other developmental disabilities. m P 3. KJT Law Group LLP and Adams Employment Counsel have prosecuted this u 306 Suite R0 litigation solely 011 a contingent-fee basis, and have been completely at risk that it would not receive Ave. 91206 any compensation for prosecuting Claims against Defendant. While KJT Law Group LLP and Maryland CA KJTLAWG Adams Employment Counsel devoted its time and resources t0 this matter, they have foregone N. Glendale, other legal work for which they would have been compensated. 230 4. My office and KJT Law Group LLP are qualified t0 handle this litigation because we NNNNNMNNNAAAAAAAAA-x are experienced in litigating Labor Code violations in both individual and Class action cases, mem¥wonflomNo3m