On September 25, 2020 a
Motion-Secondary
was filed
involving a dispute between
Villegas, Maria,
and
Does 1-50,
Myojo Usa, Inc.,
Square One Staffing,
for Employment - Complex
in the District Court of San Bernardino County.
Preview
i ‘I
.
DocuSign Envelope ID: 943A1 acc-o747-4A5E-Avv 1BD1 CA5EVBR‘G‘NAL
LAW OFFICE OF SCOTT ERNEST WHEELER
Scott Ernest Wheeler (SBN 187998)
Justin A.Wheeler (SBN 342226)
250 West First Street, Suite 216
Claremont, California 91711
Telephone: (909) 621-4988
F L
I
SUPERIOR COURTEFQAUFO
Facsimile: (909) 621 -4622 cggmv 0F SAN asnmnoflg"
N BERNARD‘NO
Email: sew@scottwheelerlawoffice.com DISTRICT
jaw@sc0ttwheelerlawoffice.com
OOOOQONUI-PMN—n
APR 2 1 2023
Attorneysfor Plaintiffand the Putative Class
i
5 .
Jasmin
menus. Deputy
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
MARIA VILLEGAS, individually, and CASE NO. CIVD82020848
on behalf 0f all others similarly situated,
, , [Hon. David Cohn, Dept. S-26]
Plamtlff,
V.
DECLARATION OF PLAINTIFF MARIA
VILLEGAS IN SUPPORT OF MOTION
NNNNNNNNNHH—‘flt—tt—v—Ib—A—t—
MYOJO USA, fNC,, a corporation; FOR FINAL APPROVAL OF CLASS
SQUARE ONE STAFFING; and DOES 1 ACTION SETTLEMENT
through 50, inclusive,
WQQLII$WNflO¥OOONONMJ>UJNH
Date: May 15, 2023
Defendants.
Time: 9:00 a.m.
Dept: S-26
Action Filed: September 25, 2020
Trial Date: None Set
-1-
DECLARATION OF MARIA VILLEGAS IN SUPPORT OF MOTION FOR
FINAL APPROVAL OF CLASS ACTION SETTLENIENT
DocuSign Envelope'lb: 943A1acc-o747-4AsE-Ac ‘BD1 CA5E7A63
DECLARATION OF MARIA VILLEGAS
I, Maria Villegas, hereby declare as follows:
1. I am the named plaintiff in the above-entitled action for settlement purposes only.
l make this declaration 0n the basis of personal firsthand knowledge, except as to those matters
£11th
stated on information and belief. If called as a witness, I could and would readily and
competently testify t0 all matters stated within.
2. I make this declaration in support of Plaintiff’s Motion for Final Approval of Class
OOOOVQ
Action Settlement.
3. Before the formal commencement of this litigation, and throughout the course 0f
the lawsuit, I cooperated with my attorney, Scott Ernest Wheeler 0f the Law Office of Scott
12
Ernest Wheeler, and took actions to protect the interests of the other Class Members. I spent a
13
significant amount of time consulting with my attorney in person and by phone, providing my
14
attorney with relevant documents, reviewing relevant documents with my attorney, assisting my
15
attorney in preparation of pleadings, participating in mediation and settlement discussions and
16
17 other important decisions concerning the case, and keeping myself informed 0f the developments
18 in the case even after a settlement was reached.
19
4. I estimate that I spent the following amount of time actively involved in this
20
action:
21
0 Preliminary in-person meetings with my attorney prior to and
22
filing: 6.50 hours
23
o Review PAGA Notice and Class Action Complaint: 2.00 hours
24
0 Conferences and telephone conversations with my attorney after filing
25
the Complaint: 3.50 hours
26
0 Telephone meetings with my attorney regarding other litigation
27
matters: 4.50 hours
28
-2-
DECLARATION OF MARIA VILLEGAS IN SUPPORT OF MOTION FOR
FINAL APPROVAL OF CLASS ACTION SETTLEMENT
Document Filed Date
April 21, 2023
Case Filing Date
September 25, 2020
Category
Employment - Complex
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i ‘I . DocuSign Envelope ID: 943A1 acc-o747-4A5E-Avv 1BD1 CA5EVBR‘G‘NAL LAW OFFICE OF SCOTT ERNEST WHEELER Scott Ernest Wheeler (SBN 187998) Justin A.Wheeler (SBN 342226) 250 West First Street, Suite 216 Claremont, California 91711 Telephone: (909) 621-4988 F L I SUPERIOR COURTEFQAUFO Facsimile: (909) 621 -4622 cggmv 0F SAN asnmnoflg" N BERNARD‘NO Email: sew@scottwheelerlawoffice.com DISTRICT jaw@sc0ttwheelerlawoffice.com OOOOQONUI-PMN—n APR 2 1 2023 Attorneysfor Plaintiffand the Putative Class i 5 . Jasmin menus. Deputy SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT MARIA VILLEGAS, individually, and CASE NO. CIVD82020848 on behalf 0f all others similarly situated, , , [Hon. David Cohn, Dept. S-26] Plamtlff, V. DECLARATION OF PLAINTIFF MARIA VILLEGAS IN SUPPORT OF MOTION NNNNNNNNNHH—‘flt—tt—v—Ib—A—t— MYOJO USA, fNC,, a corporation; FOR FINAL APPROVAL OF CLASS SQUARE ONE STAFFING; and DOES 1 ACTION SETTLEMENT through 50, inclusive, WQQLII$WNflO¥OOONONMJ>UJNH Date: May 15, 2023 Defendants. Time: 9:00 a.m. Dept: S-26 Action Filed: September 25, 2020 Trial Date: None Set -1- DECLARATION OF MARIA VILLEGAS IN SUPPORT OF MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLENIENT DocuSign Envelope'lb: 943A1acc-o747-4AsE-Ac ‘BD1 CA5E7A63 DECLARATION OF MARIA VILLEGAS I, Maria Villegas, hereby declare as follows: 1. I am the named plaintiff in the above-entitled action for settlement purposes only. l make this declaration 0n the basis of personal firsthand knowledge, except as to those matters £11th stated on information and belief. If called as a witness, I could and would readily and competently testify t0 all matters stated within. 2. I make this declaration in support of Plaintiff’s Motion for Final Approval of Class OOOOVQ Action Settlement. 3. Before the formal commencement of this litigation, and throughout the course 0f the lawsuit, I cooperated with my attorney, Scott Ernest Wheeler 0f the Law Office of Scott 12 Ernest Wheeler, and took actions to protect the interests of the other Class Members. I spent a 13 significant amount of time consulting with my attorney in person and by phone, providing my 14 attorney with relevant documents, reviewing relevant documents with my attorney, assisting my 15 attorney in preparation of pleadings, participating in mediation and settlement discussions and 16 17 other important decisions concerning the case, and keeping myself informed 0f the developments 18 in the case even after a settlement was reached. 19 4. I estimate that I spent the following amount of time actively involved in this 20 action: 21 0 Preliminary in-person meetings with my attorney prior to and 22 filing: 6.50 hours 23 o Review PAGA Notice and Class Action Complaint: 2.00 hours 24 0 Conferences and telephone conversations with my attorney after filing 25 the Complaint: 3.50 hours 26 0 Telephone meetings with my attorney regarding other litigation 27 matters: 4.50 hours 28 -2- DECLARATION OF MARIA VILLEGAS IN SUPPORT OF MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT