Party Discovery: Tanya Abella vs. GHC of Sac-SNF LLC

• 
• 
• 
• 

						
                                
Preview
                                1   GRAHAMHOLLIS APC
               Graham S.P. Hollis (SBN 120577)
           2   ghollis@grahamhollis.com
               Vilmarie Cordero (SBN 268860)
           3   vcordero@grahamhollis.com
               Hali M. Anderson (SBN 261816)
                                                                               FILED/ENDORSED
           4   handerson@grahamhollis.com
               3555 Fifth Avenue, Suite 200                                           AUG - 5 2021
           5   San Diego, California 92103
               Telephone: 619.692.0800                                        By:       H. PFIWpi.TON
           6   Facsimile: 619.692.0822                                                   Deputy Clerk

           7   Attorneys for Plaintiff Tanya Abella
           8                         SUPERIOR COURT OF THE STATE OF CALIFORNIA
           9                                      COUNTY OF SACRAMENTO
          10   TANYA ABELLA, individually and on behalf          Case No.:   34-2018-00245953
               of all similarly situated and aggrieved
          11   employees of DEFENDANTS in the State of
  oo                                                             PLAINTIFF'S NOTICE OF MOTION TO
               California,
          12                                                     APPROVE PRIVATE ATTORNEYS
eub<
                              Plaintiff,                         GENERAL ACT SETTLEMENT
          13
                       V.
                                                                 RESERVATION # 2574817
iSw'::^   14
                                                                 Date:       September 1, 2021
li -      15
          16
               GHC OF SAC-SNF LLC; LIFE
               GENERATIONS HEALTHCARE LLC; and
               DOES 1 THROUGH 100, inclusive,
                                                                 Time:
                                                                 Dept:
                                                                 Judge:
                                                                             1:30p.m.
                                                                             53
                                                                             Hon. Shama H. Mesiwala
  >nz
  in <
  men     17                  Defendants.
                                                                 Complaint Filed: December 6, 2018
          18                                                     First Amended Complaint Filed: September 22,
                                                                 2020
          19
          20 TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
          21      PLEASE TAKE NOTICE that on September 1, 2021, at 1:30 p.m. or as soon thereafter as the

          22 matter may be heard in Department 53 in the above-entitled court, before the Honorable Shama H.
          23 Mesiwala, Plaintiff Tanya Abella will and hereby does, pursuant to California Code of Civil
          24 Procedure sections 2699(1) move this Court for an Order granting Plaintiffs Motion to Approve PAGA
          25 Settlement.
          26          This Motion is made pursuant to the instant Notice of Motion, and the Memorandum of Points and

          27 Authorities, the Declarations of Hali M. Anderson and Plaintiff Tanya Abella, and Proposed
          28 Order concurrently filed herewith, as well as the pleadings and the records on file in this action, and
               upon such oral and other documentary evidence as may be presented at the time of hearing.
                        PLAINTIFF'S NOTICE OF MOTION TO APPROVE PRIVATE ATTORNEYS GENERAL ACT
                                                      SETTLEMENT
           1 Respectfully submitted.
           2   Dated: Augusts, 2021                    GRAHAMHOLLIS APC
           3
           4                                     By:
                                                       GRAHAM S.P. HOLLIS
           5                                           VILMARIE CORDERO
                                                       HALI M. ANDERSON
           6                                           Attorneys for Plaintiff
           7
           8
           9
          10
          11
 §S

          13
3go
J 5
Ofi3 14
          15
aE^;Q 16
 m Z
 in   <




          18
          19
          20
          21
          22
          23
          24
          25
          26
          27
          28

                      PLAINTIFF'S NOTICE OF MOTION TO APPROVE PRIVATE ATTORNEVS GENERAL ACT
                                                    SETTLEMENT