On August 22, 2022 a
Motion-Secondary
was filed
involving a dispute between
Anzora, Joseph,
and
Does 1 Through 100, Inclusive,
Inland Behavioral And Health Services, Inc.,
for Complex Civil Unlimited
in the District Court of San Bernardino County.
Preview
Maria C. Roberts, SBN 137907
mroberts@greeneroberts.com
Dessi N. Day, SBN 207699
dday@greeneroberts.com
Noel J. Meza, SBN 331 169
nmeza@greeneroberts.com
GREENE & ROBERTS
402 West Broadway, Suite 1025
San Diego, CA 92101
Telephone: (619) 398-3400
FAX Facsimile: (619) 330-4907 V ne Taylor,
Dam),
BY Attorneys for Defendant Inland Behavioral and Health Services, Inc.,
a California corporation
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
10
JOSEPH ANZORA, as an aggrieved Case No. CIVSB2218375
11 employee, and on behalf of all other Judge: Hon. David Cohn
aggrieved employees under the Labor Code Action Date: August 22, 2022
12 Private Attomeys’ General Act of 2004, Trial Date: Not Yet Set
13 Plaintiff, MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT OF
14 V. MOTION BY DEFENDANT INLAND
BEHAVIORAL AND HEALTH SERVICES,
15 INLAND BEHAVIORAL AND HEALTH INC. TO STAY CASE PENDING
SERVICES, INC. a California corporation 3
OUTCOME OF EARLIER FILED AND
16 and DOES 1 through 100, inclusive, RELATED CASE
17 Defendants. SUPPORTING DOCUMENTS:
NOTICE OF MOTION AND MOTION TO
18 STAY; DECLARATION OF MARIA C.
ROBERTS; REQUEST FOR JUDICIAL
19 NOTICE
20 Date: April 10, 2023
Time: 10:00 a.m.
21 Dept: $26
22
23
24
25
26
27
28
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT’S MOTION TO STAY
I.
INTRODUCTION
This case, filed by JOSEPH ANZORA, is one 0f four duplicative wage and hour lawsuits
filed against Inland Behavioral and Health Services, Inc (IBHS) and its Chief Executive Officer,
Temetry Ann Lindsey, since June of 2021. A11 four cases were filed by the Bibiyan Law Group
on behalf of various former IBHS employees and arise out of the same facts and allegations. The
following is a summary of the cases filed:
\OOO\IO\
l. On June 24, 2021, Bibiyan filed thefirst case against IBHS and Dr. Lindsey on
behalf of Plaintiff, Edith Franco, alleging various wage and hour violations and
asserting these claims individually and 0n a putative class basis (“First Case”). (Exh.
10 1.)
11 2. On October 1, 2021, Bibiyan filed the second case against IBHS and Dr. Lindsey 0n
behalf of Plaintiffs Edith Franco and Monica Alfaro, alleging a single claim for
12
alleged violations of the Private Attorney General Act (“PAGA”), (“Second Case”).
13 This case is based on the same facts and allegations as the First Case. (Exh. 2.)
14 3. On January 4, IBHS and Dr. Lindsey on
2022, Bibiyan filed the third case against
behalf of Plaintiff Gloria Acuna, also alleging a single claim for alleged Violations of
15 the Private Attorney General Act (“PAGA”), (“Third Case”). All claims pled in this
case are included in those pled in the Second Case and this case is based on the same
16
facts and allegations as the First and Second Cases. (Exh. 3.)
17
4. On August 22, 2022, Bibiyan filed this case, thefourth case against IBHS and Dr.
18 Lindsey on behalf of Plaintiff JOSEPH ANZORA, also alleging a single claim for
alleged violations of the Private Attorney General Act (“PAGA”), (“Fourth Case”).
19 A11 claims pled in this case are included in those pled in the Second Case and this case
is based on the same facts and allegations as the First, Second and Third Cases. (Exh.
20
4.)
21 The four complaints filed by the Bibiyan firm are Virtually identical and contain the same facts,
22 legal theories and alleged Labor Code Violations. All four cases are subject to a Case
23 Management Order and all are now assigned to the Complex Department, Dept. 826, before the
24 Hon. David Cohn.
25 ///
26 ///
27 ///
28 ///
1
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT’S MOTION TO STAY
Document Filed Date
December 14, 2022
Case Filing Date
August 22, 2022
Category
Complex Civil Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Maria C. Roberts, SBN 137907 mroberts@greeneroberts.com Dessi N. Day, SBN 207699 dday@greeneroberts.com Noel J. Meza, SBN 331 169 nmeza@greeneroberts.com GREENE & ROBERTS 402 West Broadway, Suite 1025 San Diego, CA 92101 Telephone: (619) 398-3400 FAX Facsimile: (619) 330-4907 V ne Taylor, Dam), BY Attorneys for Defendant Inland Behavioral and Health Services, Inc., a California corporation SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO 10 JOSEPH ANZORA, as an aggrieved Case No. CIVSB2218375 11 employee, and on behalf of all other Judge: Hon. David Cohn aggrieved employees under the Labor Code Action Date: August 22, 2022 12 Private Attomeys’ General Act of 2004, Trial Date: Not Yet Set 13 Plaintiff, MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF 14 V. MOTION BY DEFENDANT INLAND BEHAVIORAL AND HEALTH SERVICES, 15 INLAND BEHAVIORAL AND HEALTH INC. TO STAY CASE PENDING SERVICES, INC. a California corporation 3 OUTCOME OF EARLIER FILED AND 16 and DOES 1 through 100, inclusive, RELATED CASE 17 Defendants. SUPPORTING DOCUMENTS: NOTICE OF MOTION AND MOTION TO 18 STAY; DECLARATION OF MARIA C. ROBERTS; REQUEST FOR JUDICIAL 19 NOTICE 20 Date: April 10, 2023 Time: 10:00 a.m. 21 Dept: $26 22 23 24 25 26 27 28 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT’S MOTION TO STAY I. INTRODUCTION This case, filed by JOSEPH ANZORA, is one 0f four duplicative wage and hour lawsuits filed against Inland Behavioral and Health Services, Inc (IBHS) and its Chief Executive Officer, Temetry Ann Lindsey, since June of 2021. A11 four cases were filed by the Bibiyan Law Group on behalf of various former IBHS employees and arise out of the same facts and allegations. The following is a summary of the cases filed: \OOO\IO\ l. On June 24, 2021, Bibiyan filed thefirst case against IBHS and Dr. Lindsey on behalf of Plaintiff, Edith Franco, alleging various wage and hour violations and asserting these claims individually and 0n a putative class basis (“First Case”). (Exh. 10 1.) 11 2. On October 1, 2021, Bibiyan filed the second case against IBHS and Dr. Lindsey 0n behalf of Plaintiffs Edith Franco and Monica Alfaro, alleging a single claim for 12 alleged violations of the Private Attorney General Act (“PAGA”), (“Second Case”). 13 This case is based on the same facts and allegations as the First Case. (Exh. 2.) 14 3. On January 4, IBHS and Dr. Lindsey on 2022, Bibiyan filed the third case against behalf of Plaintiff Gloria Acuna, also alleging a single claim for alleged Violations of 15 the Private Attorney General Act (“PAGA”), (“Third Case”). All claims pled in this case are included in those pled in the Second Case and this case is based on the same 16 facts and allegations as the First and Second Cases. (Exh. 3.) 17 4. On August 22, 2022, Bibiyan filed this case, thefourth case against IBHS and Dr. 18 Lindsey on behalf of Plaintiff JOSEPH ANZORA, also alleging a single claim for alleged violations of the Private Attorney General Act (“PAGA”), (“Fourth Case”). 19 A11 claims pled in this case are included in those pled in the Second Case and this case is based on the same facts and allegations as the First, Second and Third Cases. (Exh. 20 4.) 21 The four complaints filed by the Bibiyan firm are Virtually identical and contain the same facts, 22 legal theories and alleged Labor Code Violations. All four cases are subject to a Case 23 Management Order and all are now assigned to the Complex Department, Dept. 826, before the 24 Hon. David Cohn. 25 /// 26 /// 27 /// 28 /// 1 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT’S MOTION TO STAY