On February 11, 2020 a
Stipulation,Agreement
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
F I L E
\U SUPERIOR COURT 0F CALIF
COUNTY or SAN BERNARtgmg
SAN BERNARDINO DISTRICT
Tara Zabehi (SBN 3 14706)
TravisMaher (SBN 327206)
J.
AUG - 4 2023
LAWYERSfor JUSTICE, PC
410 West Arden Avenue, Suite 203
Glendale, California 91203
Tel: (818) 265-1020 / Fax: (818) 265-1021 JES ICA GA "1&2, Epm‘
*
fittomeysfor Plaintiffiasminc Smith
John T. Egley (SBN 232545)
Ellen C. Cohen (SBN 276458)
CALL & JENSEN
61 0 Newport Center Drive, Suite 700
Newport Beach, CA 92660
Tel: (949) 717-3000 / Fax: (949) 717-3100
Attorneysfor Defendant DLS Events, LLC
10
SUPERIOR COURT OF THE STATE OF CALIFORNIA
11
12
FOR THE COUNTY OF SAN BERNARDINO
13 JASMINE SMITH. individually, and on behalf of Case No.: CIVDSZOO3900
other members of thegeneral public similarly
14 situated and on behalf of other aggrieved Honorable Joseph T. Ortiz
employees pursuant to the California Private Department S 1 7
15 Attorneys General Act;
CLASS ACTION
16 Plaintiff,
JOINT STIPULATION T0
vs.
17 CONTINUE THE DEADLINE FOR
DLS EVENTS, LLC,
MOTION FORELASS
PLAINTIFF’S
an unknown business
18 CERTIFICATION; [PROPOSED]
entity; and DOES 1 through 100, inclusive ORDER THEREON
19
Defendants.
[JOINr s TA TEMENT RE.- FUR THER CA SE
20 MA NA GEMENT CONFERENCE FIL ED
CONCURRENTL Y HERE WITH]
21
Complaint Filed: February 11, 2020
22 FAC Filed: July 22, 2020
Jury Trial Date: None Set
23
fi 7/0 507/073-— Bq Ola?
24
«*0 Egg!” "7;:
25
26
27
28
JOINT STIPULATION TO CONTINUE THE DEADL FOR PLAINTIFF’S MOTION FOR CLASS
CERTIFICATION; [PR ED] ORDER THEREON
\z \z
Plaintiff Jasmine Smith (“Plaintiff") and Defendant DLS Events, LLC (“Defendant”)
(collectively, “the Parties”). by and through their respective counsel of record. hcrcby stipulate
as follows:
WHEREAS, Plaintiff filed a Class Action Complaint for Damages on February 11,
2020. asserting ten causes 0f action for Defendant’s alleged violation 0f the California Labor
Code and Califomia Business & Professions Code §§ 17200, et seq.;
WHERAS. on February 19. 2020. this case was assigned to Judge David Cohn in the
Complex Litigation Program in Department S-26;
WHEREAS. 0n 0r about March 4. 2020, the State of California declared a state 0f
10 emergency in connection with the COVID-l 9 pandemic;
11 WHEREAS. at thc July 14. 2020 Initial Status Conference, duc t0 Defendant‘s financial
12 issues expressed t0 the Court by counsel for Defendant, as a direct result of the COVID-l9
l3 pandemic shuttering all music events in California and severely impacting Ihc music festival
l4 industry, the Court continued the stay 0n discovery, and instructed the Parties that a potential
15 lift on the stay ofdiscovery would be addressed at the next status conference;
l6 WHEREAS. 0n July 22. 2020. Plaintiff filed a First Amended Complaint which added
17 one cause ofaction, pursuant to California Labor Code §§ 2698 et seq. for enforcement under
18 the Private Attorneys Genera] Act (“PAGA”) for Defendant’s alleged California Labor Code
19 violations. Defendant timely filed an Answer on August 24, 202 l;
20 WHEREAS. due l0 the continuing effects of the COVID pandemic on Defendant‘s
21 business, discovery remained stayed until June 8, 202], at which time Plaintiff promptly
22 propoundcd written discovery requests and deposition notices;
23 WHEREAS. Defendant served responses t0 Plaintiff’s discovery‘ and the Parties
24 subsequently met and conferred regarding Defendant’s responses. In connection with those
25 meet-and-confer efforts, Defendant produced additional class data and information. The Parties
26 continue t0 meet and confer in good faith in hopes of resolving any remaining discovery issues
27 cooperatively and obviating the need for motion practice;
28 WHEREAS, both Parties have expressed an interest in exploring a negotiated resolution
2
JOINT STIPULATION T()CONTINUE THE DEADLINE FOR PLAINTIFF'S MOTION FOR CLASS
CERTIFICATION; [PROPOSED] ORDER THEREON
Document Filed Date
August 04, 2023
Case Filing Date
February 11, 2020
Category
Employment - Complex
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F I L E \U SUPERIOR COURT 0F CALIF COUNTY or SAN BERNARtgmg SAN BERNARDINO DISTRICT Tara Zabehi (SBN 3 14706) TravisMaher (SBN 327206) J. AUG - 4 2023 LAWYERSfor JUSTICE, PC 410 West Arden Avenue, Suite 203 Glendale, California 91203 Tel: (818) 265-1020 / Fax: (818) 265-1021 JES ICA GA "1&2, Epm‘ * fittomeysfor Plaintiffiasminc Smith John T. Egley (SBN 232545) Ellen C. Cohen (SBN 276458) CALL & JENSEN 61 0 Newport Center Drive, Suite 700 Newport Beach, CA 92660 Tel: (949) 717-3000 / Fax: (949) 717-3100 Attorneysfor Defendant DLS Events, LLC 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 12 FOR THE COUNTY OF SAN BERNARDINO 13 JASMINE SMITH. individually, and on behalf of Case No.: CIVDSZOO3900 other members of thegeneral public similarly 14 situated and on behalf of other aggrieved Honorable Joseph T. Ortiz employees pursuant to the California Private Department S 1 7 15 Attorneys General Act; CLASS ACTION 16 Plaintiff, JOINT STIPULATION T0 vs. 17 CONTINUE THE DEADLINE FOR DLS EVENTS, LLC, MOTION FORELASS PLAINTIFF’S an unknown business 18 CERTIFICATION; [PROPOSED] entity; and DOES 1 through 100, inclusive ORDER THEREON 19 Defendants. [JOINr s TA TEMENT RE.- FUR THER CA SE 20 MA NA GEMENT CONFERENCE FIL ED CONCURRENTL Y HERE WITH] 21 Complaint Filed: February 11, 2020 22 FAC Filed: July 22, 2020 Jury Trial Date: None Set 23 fi 7/0 507/073-— Bq Ola? 24 «*0 Egg!” "7;: 25 26 27 28 JOINT STIPULATION TO CONTINUE THE DEADL FOR PLAINTIFF’S MOTION FOR CLASS CERTIFICATION; [PR ED] ORDER THEREON \z \z Plaintiff Jasmine Smith (“Plaintiff") and Defendant DLS Events, LLC (“Defendant”) (collectively, “the Parties”). by and through their respective counsel of record. hcrcby stipulate as follows: WHEREAS, Plaintiff filed a Class Action Complaint for Damages on February 11, 2020. asserting ten causes 0f action for Defendant’s alleged violation 0f the California Labor Code and Califomia Business & Professions Code §§ 17200, et seq.; WHERAS. on February 19. 2020. this case was assigned to Judge David Cohn in the Complex Litigation Program in Department S-26; WHEREAS. 0n 0r about March 4. 2020, the State of California declared a state 0f 10 emergency in connection with the COVID-l 9 pandemic; 11 WHEREAS. at thc July 14. 2020 Initial Status Conference, duc t0 Defendant‘s financial 12 issues expressed t0 the Court by counsel for Defendant, as a direct result of the COVID-l9 l3 pandemic shuttering all music events in California and severely impacting Ihc music festival l4 industry, the Court continued the stay 0n discovery, and instructed the Parties that a potential 15 lift on the stay ofdiscovery would be addressed at the next status conference; l6 WHEREAS. 0n July 22. 2020. Plaintiff filed a First Amended Complaint which added 17 one cause ofaction, pursuant to California Labor Code §§ 2698 et seq. for enforcement under 18 the Private Attorneys Genera] Act (“PAGA”) for Defendant’s alleged California Labor Code 19 violations. Defendant timely filed an Answer on August 24, 202 l; 20 WHEREAS. due l0 the continuing effects of the COVID pandemic on Defendant‘s 21 business, discovery remained stayed until June 8, 202], at which time Plaintiff promptly 22 propoundcd written discovery requests and deposition notices; 23 WHEREAS. Defendant served responses t0 Plaintiff’s discovery‘ and the Parties 24 subsequently met and conferred regarding Defendant’s responses. In connection with those 25 meet-and-confer efforts, Defendant produced additional class data and information. The Parties 26 continue t0 meet and confer in good faith in hopes of resolving any remaining discovery issues 27 cooperatively and obviating the need for motion practice; 28 WHEREAS, both Parties have expressed an interest in exploring a negotiated resolution 2 JOINT STIPULATION T()CONTINUE THE DEADLINE FOR PLAINTIFF'S MOTION FOR CLASS CERTIFICATION; [PROPOSED] ORDER THEREON