On February 11, 2020 a
Party Statement
was filed
involving a dispute between
Smith, Jasmine,
and
Dls Events, Llc, A California Limited Liability Company,
for Employment - Complex
in the District Court of San Bernardino County.
Preview
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Edwin Aiwazian (SBN 232943) F I L E D
SUPERIOR COURT 0F CALuFORNIA
Arby Aiwazian (SBN 269827) COUNTY 0F SAN BERNARDINO
N Tara Zabehi (SBN 3 14706) SAN BERNARmNQ DISTRICT
Travis J. Maher (SBN 327206)
LAWYERSfor JUSTICE, PC DEC 2 4 2020
410 West Arden Avenue, Suite 203
Glendale, California 9 1 203
Tel: (818) 265-1020 / Fax: (818) 265—1021 BY
AL IE CERVANTES, DEPUTV
Attorneysfor Plaintiff
\OOOfloklthJ
John T. Egley (SBN 232545)
Jegley@calljensen.com
Ellen C. Cohen (SBN 276458)
Ecohen@calljensen.com
CALL & JENSEN
610 Newport Center Drive, Suite 700
Newport Beach, CA 92660
10 Tel: (949) 717-3000 / Fax: (949) 717—3100
11 Attorneysfor Defendant DLS EVENTS, LLC
12
13
SUPERIOR COURT OF THE STATE OF CALIFORNIA
14
FOR THE COUNTY OF SAN BERNARDINO
15
JASMINE SMITH, individually, and on behalf Case No.2 CIVDSZOO39OO
16 of other members of the general public similarly
situated;
'
CLASS ACTION
17
Plaintiff, Honorable David Cohn
18 Department S26
VS.
19 JOINT STATEMENT RE: FURTHER
DLS EVENTS, LLC, an unknown business CASE MANAGEMENT CONFERENCE
20 entity; and DOES 1 through 100, inclusive,
Date: December 31, 2020 i/
21 Defendants. Time: 10:00 a.m.
Dept: S-26
22
Complaint Filed: February 11, 2020
23 FAC Filed: July 22, 2020
Jury Trial Date: None Set
24
25
26
v" “ho
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N
27
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28 1'6»
JOINT STATEMENT RE: FURTHER CASE MANAGEMENT CONFERENCE
”
\r \r
TO THE HONORABLE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF
RECORD: I
AWN Plaintiff Jasmine Smith (“Plaintiff”) individually, and on behalf of other members 0f the
general public similarly situated and on behalf of other aggrieved employees pursuant to the
California Private Attorneys General Act (“PAGA”), and Defendant DLS Events, LLC
(“Defendant”) hereby submit the following Joint Statement in advance 0f the Further Case
OWNQUI
Management Conference scheduled for December 3 1, 2020 at 10:00 a.m.
I. PLAINTIFF’S STATEMENT
At the July 14, 2020 Initial Status Conference, the Court continued the stay on discovery,
10 and instructed the parties that a potential lift 0n the stay of discovery would be addressed at the
11 next status conference. At the October 14, 2020 Case Management Conference, the Court
12 continued the stay on discovery, and reserved December 31, 2020 to hear Defendant’s Motion to
13 continue the stay on discovery.
14 Prior t0 the discovery cut-off, Plaintiff anticipates propounding Form Interrogatories,
15 Requests for Production of Documents, Special Interrogatories, and Requests for Admission.
16 Plaintiff also anticipates taking depositions of Defendant’s person most knowledgeable, putative
17 class members who file declarations in opposition to Plaintiff‘s motion for class certification,
18 and depositions 0f other percipient witnesses. Plaintiff’s discovery will be narrowly tailored to
19 class certification issues, but Plaintiff anticipates that there will be some merits-based discovery
20 propounded where such discovery intersects and cannot be bifurcated from class certification
21 issues.
22 Plaintiff will request the class contact information from Defendant. Plaintiff agrees to
23 an “opt-out” notice process (as approved in Belaire-West Landscape, Inc. v. Superior Court
24 (2007) 149 Cal.App.4th 554, 561) with a neutral third—party administrator t0 precede delivery
25 ofthe class contact information t0 Plaintiff” s counsel. Plaintiff is amenable to splitting the costs
26 of the notice process 50/50 with Defendant.
27 Plaintiff is amenable to private mediation after receipt of the class data required for
28 valuation/preparation 0f damage calculations.
1
JOINT STATEMENT RE: FURTHER CASE MANAGEMENT CONFERENCE
Document Filed Date
December 24, 2020
Case Filing Date
February 11, 2020
Category
Employment - Complex
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' \r Edwin Aiwazian (SBN 232943) F I L E D SUPERIOR COURT 0F CALuFORNIA Arby Aiwazian (SBN 269827) COUNTY 0F SAN BERNARDINO N Tara Zabehi (SBN 3 14706) SAN BERNARmNQ DISTRICT Travis J. Maher (SBN 327206) LAWYERSfor JUSTICE, PC DEC 2 4 2020 410 West Arden Avenue, Suite 203 Glendale, California 9 1 203 Tel: (818) 265-1020 / Fax: (818) 265—1021 BY AL IE CERVANTES, DEPUTV Attorneysfor Plaintiff \OOOfloklthJ John T. Egley (SBN 232545) Jegley@calljensen.com Ellen C. Cohen (SBN 276458) Ecohen@calljensen.com CALL & JENSEN 610 Newport Center Drive, Suite 700 Newport Beach, CA 92660 10 Tel: (949) 717-3000 / Fax: (949) 717—3100 11 Attorneysfor Defendant DLS EVENTS, LLC 12 13 SUPERIOR COURT OF THE STATE OF CALIFORNIA 14 FOR THE COUNTY OF SAN BERNARDINO 15 JASMINE SMITH, individually, and on behalf Case No.2 CIVDSZOO39OO 16 of other members of the general public similarly situated; ' CLASS ACTION 17 Plaintiff, Honorable David Cohn 18 Department S26 VS. 19 JOINT STATEMENT RE: FURTHER DLS EVENTS, LLC, an unknown business CASE MANAGEMENT CONFERENCE 20 entity; and DOES 1 through 100, inclusive, Date: December 31, 2020 i/ 21 Defendants. Time: 10:00 a.m. Dept: S-26 22 Complaint Filed: February 11, 2020 23 FAC Filed: July 22, 2020 Jury Trial Date: None Set 24 25 26 v" “ho \ N 27 \‘f’xza 28 1'6» JOINT STATEMENT RE: FURTHER CASE MANAGEMENT CONFERENCE ” \r \r TO THE HONORABLE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD: I AWN Plaintiff Jasmine Smith (“Plaintiff”) individually, and on behalf of other members 0f the general public similarly situated and on behalf of other aggrieved employees pursuant to the California Private Attorneys General Act (“PAGA”), and Defendant DLS Events, LLC (“Defendant”) hereby submit the following Joint Statement in advance 0f the Further Case OWNQUI Management Conference scheduled for December 3 1, 2020 at 10:00 a.m. I. PLAINTIFF’S STATEMENT At the July 14, 2020 Initial Status Conference, the Court continued the stay on discovery, 10 and instructed the parties that a potential lift 0n the stay of discovery would be addressed at the 11 next status conference. At the October 14, 2020 Case Management Conference, the Court 12 continued the stay on discovery, and reserved December 31, 2020 to hear Defendant’s Motion to 13 continue the stay on discovery. 14 Prior t0 the discovery cut-off, Plaintiff anticipates propounding Form Interrogatories, 15 Requests for Production of Documents, Special Interrogatories, and Requests for Admission. 16 Plaintiff also anticipates taking depositions of Defendant’s person most knowledgeable, putative 17 class members who file declarations in opposition to Plaintiff‘s motion for class certification, 18 and depositions 0f other percipient witnesses. Plaintiff’s discovery will be narrowly tailored to 19 class certification issues, but Plaintiff anticipates that there will be some merits-based discovery 20 propounded where such discovery intersects and cannot be bifurcated from class certification 21 issues. 22 Plaintiff will request the class contact information from Defendant. Plaintiff agrees to 23 an “opt-out” notice process (as approved in Belaire-West Landscape, Inc. v. Superior Court 24 (2007) 149 Cal.App.4th 554, 561) with a neutral third—party administrator t0 precede delivery 25 ofthe class contact information t0 Plaintiff” s counsel. Plaintiff is amenable to splitting the costs 26 of the notice process 50/50 with Defendant. 27 Plaintiff is amenable to private mediation after receipt of the class data required for 28 valuation/preparation 0f damage calculations. 1 JOINT STATEMENT RE: FURTHER CASE MANAGEMENT CONFERENCE