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
\y {ORIGINAE
LAW OFFICE OF SCOTT ERNEST WHEELER
Scott Ernest Wheeler (SBN 187998)
Justin A. Wheeler (SBN 342226)
250 West First Street, Suite 216
Claremont, California 9171
Telephone: (909) 621-4988
1
SUPERIQfigo’UgT E D
COUNTo TF0
ALIFORN
.b Facsimile: (909) 621—4622 3“” BFBNAfifiINEgRNAHDI N0“
Email: sew@scottwheelerlawoffice.com
jaw@scottwheeler1awoffice.com
Attorneyfor Plaintiffand the Putative Class
\OOOQONUI
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 FOR THE COUNTY OF SAN BERNARDINO
12 SAN BERNARDINO DISTRICT
13
MARIA VILLEGAS, individually, and 0n Case N0.: CIVDSZOZO848
14 behalf 0f all others similarly situated,
DECLARATION OF JUSTIN A.
15 Plaintiff, WHEELER IN SUPPORT OF
PLAINTIFF’S MOTION FOR FINAL
16 V.
APPROVAL OF CLASS ACTION
17 MYOJO USA, INC., a corporation; SETTLEMENT
SQUARE ONE STAFFING; and DOES 1
18 through 50, inclusive, Date: May 15, 2023
Time: 9:00 a.m.
19 Defendants. Dept: S-26
20
Action Filed: September 25, 2020
21 Trial Date: None Set
22
23
24
25
26
27
28
-1-
DECLARATION OF JUSTIN A. WHEELER ISO PLAINTIFF’S MOTION FOR FINAL APPROVAL
OF CLASS ACTION SETTLEMENT
\y \1
I, JUSTIN A. WHEELER, hereby declare as follows:
1. I am an attorney at law, licensed to practice in the State of California. I am
ADJN
an associate of the Law Offices 0f Scott E. Wheeler which is the attorney of record for Plaintiff
Maria Villegas in the above-entitled action Maria Villegas Myojo USA,
v. Inc. et. al. (Case No.
CIVDS2020848). I make this declaration on the basis of personal firsthand knowledge unless
another source of information or belief clearly appears from the
context, and as to all such
OOOOVOUI
matters, I believe them to be true. If called as a witness, I could and would readily and
competently testify to all matters stated within.
2. I make this declaration in support 0f Plaintiff’s Motion for Final Approval of Class
Action Settlement Filed on behalf of Plaintiff, Maria Villegas.
Qualifications Of Counsel
12 3. I received a B.S. in Psychology from Texas Christian University in 2018. I
13 received my J.D. from the University of La Verne, College of Law in 2021. I became an Active
14 Member of the State -Bar of California on December 2, 2021, and have been an Active Member
15 in good standing continuously since then.
16 4. In January of 2022, became an associate at the Law Office
I 0f Scott Ernest
17 Wheeler in Claremont, California, and I have been continuously involved in employment
18 litigation matters, including active wage and hour litigation in individual, representative and class
19 actions.
20 5. My recent experience includes Victor Chavez Mata v. Preferred Pallets, Ina, San
21 Bernardino Superior Court, Case Number: CIVSB21 1 5694, an action pursuant t0 the Private
22 Attorneys General Act (“PAGA”), and Rosa Ornelas v. Mastercorp Commercial Services, LLC,
23 San Bernardino Superior Court, Case Number: CIVSB21 14590, a wage and hour class action.
24 6. I am currently litigating several other class actions and PAGA suits in state courts
25 throughout California.
26 ///
27 ///
28 ///
-2-
DECLARATION OF JUSTIN A. WHEELER ISO PLAINTIFF’S 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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Preview
\y {ORIGINAE LAW OFFICE OF SCOTT ERNEST WHEELER Scott Ernest Wheeler (SBN 187998) Justin A. Wheeler (SBN 342226) 250 West First Street, Suite 216 Claremont, California 9171 Telephone: (909) 621-4988 1 SUPERIQfigo’UgT E D COUNTo TF0 ALIFORN .b Facsimile: (909) 621—4622 3“” BFBNAfifiINEgRNAHDI N0“ Email: sew@scottwheelerlawoffice.com jaw@scottwheeler1awoffice.com Attorneyfor Plaintiffand the Putative Class \OOOQONUI 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 FOR THE COUNTY OF SAN BERNARDINO 12 SAN BERNARDINO DISTRICT 13 MARIA VILLEGAS, individually, and 0n Case N0.: CIVDSZOZO848 14 behalf 0f all others similarly situated, DECLARATION OF JUSTIN A. 15 Plaintiff, WHEELER IN SUPPORT OF PLAINTIFF’S MOTION FOR FINAL 16 V. APPROVAL OF CLASS ACTION 17 MYOJO USA, INC., a corporation; SETTLEMENT SQUARE ONE STAFFING; and DOES 1 18 through 50, inclusive, Date: May 15, 2023 Time: 9:00 a.m. 19 Defendants. Dept: S-26 20 Action Filed: September 25, 2020 21 Trial Date: None Set 22 23 24 25 26 27 28 -1- DECLARATION OF JUSTIN A. WHEELER ISO PLAINTIFF’S MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT \y \1 I, JUSTIN A. WHEELER, hereby declare as follows: 1. I am an attorney at law, licensed to practice in the State of California. I am ADJN an associate of the Law Offices 0f Scott E. Wheeler which is the attorney of record for Plaintiff Maria Villegas in the above-entitled action Maria Villegas Myojo USA, v. Inc. et. al. (Case No. CIVDS2020848). I make this declaration on the basis of personal firsthand knowledge unless another source of information or belief clearly appears from the context, and as to all such OOOOVOUI matters, I believe them to be true. If called as a witness, I could and would readily and competently testify to all matters stated within. 2. I make this declaration in support 0f Plaintiff’s Motion for Final Approval of Class Action Settlement Filed on behalf of Plaintiff, Maria Villegas. Qualifications Of Counsel 12 3. I received a B.S. in Psychology from Texas Christian University in 2018. I 13 received my J.D. from the University of La Verne, College of Law in 2021. I became an Active 14 Member of the State -Bar of California on December 2, 2021, and have been an Active Member 15 in good standing continuously since then. 16 4. In January of 2022, became an associate at the Law Office I 0f Scott Ernest 17 Wheeler in Claremont, California, and I have been continuously involved in employment 18 litigation matters, including active wage and hour litigation in individual, representative and class 19 actions. 20 5. My recent experience includes Victor Chavez Mata v. Preferred Pallets, Ina, San 21 Bernardino Superior Court, Case Number: CIVSB21 1 5694, an action pursuant t0 the Private 22 Attorneys General Act (“PAGA”), and Rosa Ornelas v. Mastercorp Commercial Services, LLC, 23 San Bernardino Superior Court, Case Number: CIVSB21 14590, a wage and hour class action. 24 6. I am currently litigating several other class actions and PAGA suits in state courts 25 throughout California. 26 /// 27 /// 28 /// -2- DECLARATION OF JUSTIN A. WHEELER ISO PLAINTIFF’S MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT