On March 06, 2019 a
Motion-Secondary
was filed
involving a dispute between
Murray, Abraham,
and
Simplified Labor Staffing Solutions, Inc.,
Simplified Staffing Labor Solutions,Llc,
Simplified Staffing Labor Solutions-Ontario,
for Wrongful Termination
in the District Court of San Bernardino County.
Preview
DocuSign Envelope ID: 5605A069-DFOB-433D-B674-6C8C9725DB40
V
c—s.
F.
RICHARD E QUINTILONE, II (SBN 200995) SUPERIOR c W
JEFFREY T GREEN (SBN 330065) COUNTY 0’
SAN BER
KYLE J GALLEGO (PL-513245)
QUINTILONE & ASSOCLATES AUG 3 O 4122
22974 EL TORo ROAD, SUITE 100
LAKE FOREST, CA 92630
TELEPHONE: (949) 458-9675 ~/éu£1.:, C({cc_mufi,_3
.Ilc‘ro J_I; N x M. r“
FACSMLE: (949) 458-9679 T {Tyfigng
®OOQONUI$U3NH
EMAIL: REO@QUINTLAW. COM; JTG@QUINTLAW COM; KJGQDQUINTLAW. COM
Attorneys for Defendants, SIMPLIFIED STAFFING LABOR SOLUTIONS— ONTARIO;
SIMPLIFIED STAFFING LABOR SOLUTIONS, LLC; SIMPLIFIED STAFFING LABOR
SOLUTIONS, INC.
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
ABRAHAM MURRAY, CASE NO.: CIVDSl907075
Plaintiff, Assigned for All Purposes to:
Hon. Wilfred J. Schneider
V. Dept: S32
SIMPLIFIED STAFFING LABOR SOLUTIONS
— ONTARIO; SIMPLIFIED STAFFING LABOR DECLARATION OF ASH WAHI IN
SOLUTIONS, LLC; and DOES 1 t0 20, SUPPORT OF DEFENDANTS’ EX PARTE
APPLICATION FOR ORDER
Defendants. CONTINUING TRIAL AND REOPENING
NNNNNNNNNr—twt—dt—IHHHHr—r—
DISCOVERY
OONONM-PWNHOOOOQONM-bUJNr—to
[Filed concurrently with Ex Parte
Application; [Proposed] Order; Dec of KJG
ISO Ex Parte]
Date: August 31, 2022
Time: 8:30 a.m.
Dept: S32
Complaint Filed: March 6, 2019
FAC Filed: January 15, 2020
Trial date: September 19, 2022
-1-
DECLARATION OF ASH WAHI ISO DEFENDANTS’ EX PARTE APPLICATION FOR ORDER CONTINUING
TRIAL
DocuSign Envelope ID: 56C5A069-DFOB-433D-B674-608097ZSDB40
V \J
DECLARATION OF ASH WAHI
I, Ash Wahi, hereby declare as follows:
1. I am the Chief Executive Officer 0f Defendant SIMPLIFIED STAFFING LABOR
SOLUTIONS, INC., Ihave personal knowledge of the facts set forth herein and if called upon to testify, I
could and would do so competently under oath.
\DWQQMAWNH
2. I understand and am aware that Plaintiff Abraham Murray filed a Complaint against
Defendants 0n March 6, 2019, alleging (1) Discrimination; (2) Retaliation; (3) Failure to Prevent
Retaliation/Discrimination; Failure to Supervise and Train; (4) Failure to Accommodate; (5) Failure to
Engage in Good Faith Interactive Process; (6) Wrongful Termination in Violation of Public Policy; (7)
Breach of Oral/Implied Contract; and (8) Intentional Infliction 0f Emotional Distress. The Complaint
was amended on January 15, 2020, alleging the same causes of action.
3. I retained Rick Martin of Angel City Law Firm to handle this matter on August 4, 2020.
4. I understand and became aware in August 0f 2022, that my prior retained counsel failed
to litigate this matter by not propounding or responding to discovery, providing updates on the status
of the case, or pursuing settlement opportunities.
5. I immediately retained new counsel and substituted in Quintilone & Associates on
NNNNNNNNNHr—tp—tt—Ar—tr—tr—dr—tr—‘t—
August 24, 2022.
6. I became aware of the trial date of September 19, 2022, by my new counsel in August
mflQm-PWNHOKDWQONMAWNHO
of 2022.
7. I understand and am aware that if the trial is not continued I along With the named
Defendants Will suffer irreparable harm as my new counsel will not have adequate time to prepare for
trial.
8. I respectfully ask the Court to issue a brief continue of the trial so I can adequately
prepare for trial with my newly retained counsel.
///
///
///
///
_2_
DECLARATION OF ASH WAHI ISO DEFENDANTS’ EX PARTE APPLICATION FOR ORDER CONTINUING
TRIAL
Document Filed Date
August 30, 2022
Case Filing Date
March 06, 2019
Category
Wrongful Termination
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
DocuSign Envelope ID: 5605A069-DFOB-433D-B674-6C8C9725DB40 V c—s. F. RICHARD E QUINTILONE, II (SBN 200995) SUPERIOR c W JEFFREY T GREEN (SBN 330065) COUNTY 0’ SAN BER KYLE J GALLEGO (PL-513245) QUINTILONE & ASSOCLATES AUG 3 O 4122 22974 EL TORo ROAD, SUITE 100 LAKE FOREST, CA 92630 TELEPHONE: (949) 458-9675 ~/éu£1.:, C({cc_mufi,_3 .Ilc‘ro J_I; N x M. r“ FACSMLE: (949) 458-9679 T {Tyfigng ®OOQONUI$U3NH EMAIL: REO@QUINTLAW. COM; JTG@QUINTLAW COM; KJGQDQUINTLAW. COM Attorneys for Defendants, SIMPLIFIED STAFFING LABOR SOLUTIONS— ONTARIO; SIMPLIFIED STAFFING LABOR SOLUTIONS, LLC; SIMPLIFIED STAFFING LABOR SOLUTIONS, INC. SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO ABRAHAM MURRAY, CASE NO.: CIVDSl907075 Plaintiff, Assigned for All Purposes to: Hon. Wilfred J. Schneider V. Dept: S32 SIMPLIFIED STAFFING LABOR SOLUTIONS — ONTARIO; SIMPLIFIED STAFFING LABOR DECLARATION OF ASH WAHI IN SOLUTIONS, LLC; and DOES 1 t0 20, SUPPORT OF DEFENDANTS’ EX PARTE APPLICATION FOR ORDER Defendants. CONTINUING TRIAL AND REOPENING NNNNNNNNNr—twt—dt—IHHHHr—r— DISCOVERY OONONM-PWNHOOOOQONM-bUJNr—to [Filed concurrently with Ex Parte Application; [Proposed] Order; Dec of KJG ISO Ex Parte] Date: August 31, 2022 Time: 8:30 a.m. Dept: S32 Complaint Filed: March 6, 2019 FAC Filed: January 15, 2020 Trial date: September 19, 2022 -1- DECLARATION OF ASH WAHI ISO DEFENDANTS’ EX PARTE APPLICATION FOR ORDER CONTINUING TRIAL DocuSign Envelope ID: 56C5A069-DFOB-433D-B674-608097ZSDB40 V \J DECLARATION OF ASH WAHI I, Ash Wahi, hereby declare as follows: 1. I am the Chief Executive Officer 0f Defendant SIMPLIFIED STAFFING LABOR SOLUTIONS, INC., Ihave personal knowledge of the facts set forth herein and if called upon to testify, I could and would do so competently under oath. \DWQQMAWNH 2. I understand and am aware that Plaintiff Abraham Murray filed a Complaint against Defendants 0n March 6, 2019, alleging (1) Discrimination; (2) Retaliation; (3) Failure to Prevent Retaliation/Discrimination; Failure to Supervise and Train; (4) Failure to Accommodate; (5) Failure to Engage in Good Faith Interactive Process; (6) Wrongful Termination in Violation of Public Policy; (7) Breach of Oral/Implied Contract; and (8) Intentional Infliction 0f Emotional Distress. The Complaint was amended on January 15, 2020, alleging the same causes of action. 3. I retained Rick Martin of Angel City Law Firm to handle this matter on August 4, 2020. 4. I understand and became aware in August 0f 2022, that my prior retained counsel failed to litigate this matter by not propounding or responding to discovery, providing updates on the status of the case, or pursuing settlement opportunities. 5. I immediately retained new counsel and substituted in Quintilone & Associates on NNNNNNNNNHr—tp—tt—Ar—tr—tr—dr—tr—‘t— August 24, 2022. 6. I became aware of the trial date of September 19, 2022, by my new counsel in August mflQm-PWNHOKDWQONMAWNHO of 2022. 7. I understand and am aware that if the trial is not continued I along With the named Defendants Will suffer irreparable harm as my new counsel will not have adequate time to prepare for trial. 8. I respectfully ask the Court to issue a brief continue of the trial so I can adequately prepare for trial with my newly retained counsel. /// /// /// /// _2_ DECLARATION OF ASH WAHI ISO DEFENDANTS’ EX PARTE APPLICATION FOR ORDER CONTINUING TRIAL