On December 27, 2018 a
Party Discovery
was filed
involving a dispute between
Boudreau, John,
On Behalf Of All Others Similarly Situated,
and
Does 1-10,
Mcginness, Chris,
Primeritus Financial Services Inc,
for (Other Employment Complaint Case)
in the District Court of Sacramento County.
Preview
Alejandro P. Gutierrez, SBN 107688 FILED
1 agutierrez@hathawaylawfirm. com
Superior Court Of Califomia
2 HATHAWAY, PERRETT, WEBSTER, POWERS,
CHRISMAN & GUTIERREZ, APC OB/28/2021
3 5450 Telegraph Road, Suite 200 atumer4
Ventiu-a, CA 93006-3577
4 Telephone: (805) 644-7111 ISy , Deputy
Facsimile: (805) 644-8296 Castt Number:
5
Daniel J. Palay, SBN 159348 34-2018-00247272
6 djp(@calemploymentcounsel. com
Brian D. Hefelfinger, SBN 253054
7 bdh(^calemploymentcounsel. com
PALAY HEFELFINGER, APC
8 1746 S. Victoria Avenue, Suite 230
Venttira, Califomia 93003
9 Tel: (805) 628-8220
X Fax: (805) 765-8600
10
Attorneys for Plaintiffs JOHN BOUDREA U
11 and the Certified Class
12
O 13 SUPERIOR COURT OF THE STATE OF CALIFORNIA
14
FOR THE COUNTY OF SACRAMENTO (UNLIMITED)
15
JOHN BOUDREAU, an mdividual, on behalf of CASENO.: 34-2018-00247272
16 himself and all others similarly situated.
17 Complaint filed: Dec. 27,2018
Plaintiffs, Assigned to Dept. 41
18 vs.
DECLARATION R E PROOF OF
19 PRIMERITUS FINANCL\L SERVICES, INC., a SERVICE OF PLAINTIFF'S NOTICE
Delaware Corporation; CHRIS MCGUINNESS, OF MOTION AND UNOPPOSED
20 an individual; and DOES 1 through 10, inclusive, MOTION FOR PRELIMINARY
APPROVAL OF CLASS
21 Defendants. SETTLEMENT AND SUPPORTING
22 DOCUMENTS
23
24
25
I am employed in the Coimty of Ventura, State of CaUfornia. I am over the age of eighteen
26 (18) years and not a party to the within action. My business address is 5450 Telegraph Road, Suite
200, Venttu-a, Califomia 93003.
27
On the June 22,2021,1 caused to be served,tiieforegoing documents: PLAINTIFF'S
28 NOTICE AND MOTION AND UNOPPOSED MOTION FOR PRELIMINARY APPROVAL
1
DECLARATION RE PROOF OF SERVICE OF 2-26-21 TENTATIVE RULING CONTINUING CMC
OF CLASS SETTLEMENT; MEMORANDUM OF POINTS AND AUTHORITIES IN
1 SUPPORT THEREOF; DECLARATIONS OF JOHN BOUDREAU AND ALEJANDRO P.
2 GUTIERREZ IN SUPPORT THEREOF; AND PROPOSED ORDER on tiie interested parties in
said action by placing the tme copies thereof enclosed in sealed envelopes addressed as follows:
3
Keith A. Jacoby Attomeys for Defendants, Primeritus
4 Littler Mendelson, PC
2049 Centtiry Park East, 5* Floor Financial Services, et al.
5
Los Angeles, CA 90067-3107
6 Tel: (310) 553-0308 / Fax: (310) 553-5583
kjacoby@littler.com/bschwan@littler.com
7
Nathaniel H. Jenkins
8 Littler Mendelson, PC
9 500 Capitol Mall, Suite 2000
Sacramento, CA 95814
10 Tel: (916) 830-7200 / Fax: (916) 561-0828
njenkins@littler.com
11
[ ] BY M A I L : By placing a tme copy thereof enclosed in a sealed envelope addressed to
12 the addressee(s) listed above. I am "readily familiar" with the firm's practice of collection and
13 processing correspondence for mailing. Under that practice, it would be deposited with the U.S.
Postal Service on that same date with postage thereon fully prepaid at Ventura, Califonua, in the
14 ordinary course of business. I am aware that on motion of the party served, service is presumed
invalid if postal cancellation date or postage meter date is more than one day after date of deposit
15 for mailing in affidavit.
16 [ ] BY OVERNIGHT DELFVERY: By sending atioiecopy thereof by ovemight delivery service
17 to the addressee(s) listed above. The envelope was deposited in or with a facility regularly
maintained by the ovemight carrier with delivery fees paid or provided for.
18
[X ] ELECTRONIC MAIL: By elecfronically mailing the document(s) listed above to the e-mail
19 address(es) set forth below, or as stated on the attached service list per agreement.
20
I declare under penalty of perjury under the laws of the State of Califomia that the
21 foregoing is tme and correct. Executed on June 22,2021. atVentura, Califomia.
22 Edna Byerlv
Edna Byerly
23
24
25
26
27
28
DECLARATION RE PROOF OF SERVICE OF 2-26-21 TENTATIVE RULING CONTINUING CMC
Document Filed Date
June 28, 2021
Case Filing Date
December 27, 2018
Category
(Other Employment Complaint Case)
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