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RYAN H. CROSNER, CA Bar No. 27841 8
ryan.crosner@ogletree.com
CATHERINE L. BRACKETT, CA Bar No. 33291 8
catherine.brackett@ogletree.com
F i
SngRIOR Co J55;
OGLETREE, DEAKINS, NASH, SMOAK & OUNTY or CALIFORN
SAN HERNAggrrnEnERNARDmo'A
STEWART, P.C. D!STR!CT
400 South Hope Street, Suite 1200
Los Angeles, CA 90071 FEB 14
2023
Telephone: 213-239-9800
Facsimile: 21 3-239-9045 BY ‘x
NICOLE
Attorneys for Defendant o'uwvsn.
DEPUTY
FCA US, LLC
OKOOONQ
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
11 NICOLE SALAZAR, individually, and on behalf Case N0. CIVSB 2126538
of other members 0f the general public similarly
12 situated, DECLARATION OF RYAN H. CROSNER
IN SUPPORT OF DEFENDANT’S
13 Plaintiff, MOTION TO STAY ACTION
14 VS. Date: May 2, 2023
Time: 10:00 A.M.
15 FCA US, LLC, a Delaware limited liability Place: Dept. Sl7
company; and DOES through 100, inclusive,
1 Judge: Hon. Joseph T. Ortiz
16 [Assigned for all purposes]
Defendants.
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Action Filed: August 10, 2021
18 Trial Date: None
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DECLARATION OF RYAN H. CROSNER IN SUPPORT OF DEFENDANT’S MOTION TO STAY ACTION
DECLARATION OF RYAN H. CROSNER
I, Ryan H. Crosner, declare and state as follows:
1. I am an attorney licensed to practice law before all courts of the State 0f California.
I am an attorney at the law firm Ogletree, Deakins, Nash, Smoak and Stewart, P.C., counsel for
defendant FCA US, LLC (“Defendant”). I make this declaration in support 0f Defendant’s Notice
of Motion and Motion to Stay the Action (“Motion”) filed by plaintiffNicole Salazar (“Salazar”).
The facts set forth herein are true of my own personal knowledge, and if called upon t0 testify
OCOONO
thereto, I could and would competently do so under oath.
2. On December 5, 2019, plaintiff Aaron Hallum (“Hallum”) filed a class action
Complaint against Defendant. A true and correct copy 0fthe Complaint is attached hereto as
11 Exhibit 1.
12 3. On February 13, 2020, Hallum filed a representative action complaint against
13 Defendant, seeking civil penalties under the Private Attorneys General Act of 2004, Labor Code
14 section 2698 et seq. (“PAGA”). A true and correct copy ofthis complaint is attached hereto as
15 Exhibit 2.
16 4. On January 21 , 2020, Defendant and Hallum filed a Joint Stipulation to Continue
17 the Initial Case Management Conference. In the Joint Stipulation, the parties noticed Hallum had
18 effectuated service 0f the Complaint on December 17, 2019. The parties asked the Court to
19 continue the Initial Case Management Conference from February 10, 2020 to March 16, 2020. The
20 Court granted this Joint Stipulation, continuing the parties’ Initial Case Management Conference to
21 March 16, 2020. A true and correct copy of this Joint Stipulation is attached hereto as Exhibit 3.
22 5. On March 3, 2020, Defendant and Hallum filed a Joint Case Management
23 Conference Statement. In the Statement, the parties advised the Court that they were in the process
24 of selecting a neutral t0 conduct a private mediation. The parties asked the Court t0 stay formal
25 discovery pending mediation. The parties also requested that the Court refrain from setting any
26 case deadlines and that it continue the Case Management Conference until the week of July 27,
27 2020, t0 give the parties an opportunity to schedule, prepare for, and participate in a mediation. In
28 response, the Court continued the Case Management Conference to July 28, 2020. A true and
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DECLARATION OF RYAN H. CROSNER IN SUPPORT OF DEFENDANT’S MOTION TO STAY ACTION
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RYAN H. CROSNER, CA Bar No. 27841 8 ryan.crosner@ogletree.com CATHERINE L. BRACKETT, CA Bar No. 33291 8 catherine.brackett@ogletree.com F i SngRIOR Co J55; OGLETREE, DEAKINS, NASH, SMOAK & OUNTY or CALIFORN SAN HERNAggrrnEnERNARDmo'A STEWART, P.C. D!STR!CT 400 South Hope Street, Suite 1200 Los Angeles, CA 90071 FEB 14 2023 Telephone: 213-239-9800 Facsimile: 21 3-239-9045 BY ‘x NICOLE Attorneys for Defendant o'uwvsn. DEPUTY FCA US, LLC OKOOONQ SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO 11 NICOLE SALAZAR, individually, and on behalf Case N0. CIVSB 2126538 of other members 0f the general public similarly 12 situated, DECLARATION OF RYAN H. CROSNER IN SUPPORT OF DEFENDANT’S 13 Plaintiff, MOTION TO STAY ACTION 14 VS. Date: May 2, 2023 Time: 10:00 A.M. 15 FCA US, LLC, a Delaware limited liability Place: Dept. Sl7 company; and DOES through 100, inclusive, 1 Judge: Hon. Joseph T. Ortiz 16 [Assigned for all purposes] Defendants. 17 Action Filed: August 10, 2021 18 Trial Date: None 19 20 21 22 23 24 25 26 27 28 1 DECLARATION OF RYAN H. CROSNER IN SUPPORT OF DEFENDANT’S MOTION TO STAY ACTION DECLARATION OF RYAN H. CROSNER I, Ryan H. Crosner, declare and state as follows: 1. I am an attorney licensed to practice law before all courts of the State 0f California. I am an attorney at the law firm Ogletree, Deakins, Nash, Smoak and Stewart, P.C., counsel for defendant FCA US, LLC (“Defendant”). I make this declaration in support 0f Defendant’s Notice of Motion and Motion to Stay the Action (“Motion”) filed by plaintiffNicole Salazar (“Salazar”). The facts set forth herein are true of my own personal knowledge, and if called upon t0 testify OCOONO thereto, I could and would competently do so under oath. 2. On December 5, 2019, plaintiff Aaron Hallum (“Hallum”) filed a class action Complaint against Defendant. A true and correct copy 0fthe Complaint is attached hereto as 11 Exhibit 1. 12 3. On February 13, 2020, Hallum filed a representative action complaint against 13 Defendant, seeking civil penalties under the Private Attorneys General Act of 2004, Labor Code 14 section 2698 et seq. (“PAGA”). A true and correct copy ofthis complaint is attached hereto as 15 Exhibit 2. 16 4. On January 21 , 2020, Defendant and Hallum filed a Joint Stipulation to Continue 17 the Initial Case Management Conference. In the Joint Stipulation, the parties noticed Hallum had 18 effectuated service 0f the Complaint on December 17, 2019. The parties asked the Court to 19 continue the Initial Case Management Conference from February 10, 2020 to March 16, 2020. The 20 Court granted this Joint Stipulation, continuing the parties’ Initial Case Management Conference to 21 March 16, 2020. A true and correct copy of this Joint Stipulation is attached hereto as Exhibit 3. 22 5. On March 3, 2020, Defendant and Hallum filed a Joint Case Management 23 Conference Statement. In the Statement, the parties advised the Court that they were in the process 24 of selecting a neutral t0 conduct a private mediation. The parties asked the Court t0 stay formal 25 discovery pending mediation. The parties also requested that the Court refrain from setting any 26 case deadlines and that it continue the Case Management Conference until the week of July 27, 27 2020, t0 give the parties an opportunity to schedule, prepare for, and participate in a mediation. In 28 response, the Court continued the Case Management Conference to July 28, 2020. A true and 2 DECLARATION OF RYAN H. CROSNER IN SUPPORT OF DEFENDANT’S MOTION TO STAY ACTION