On October 15, 2019 a
Conference
was filed
involving a dispute between
Brianna Flores,
Estremera, Tania,
Hansen, Dexter Norman,
and
Biscomerica Corp., A California Corporation,
Does 1-100,
for Employment - Complex
in the District Court of San Bernardino County.
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CIfUA L
1 Richard D Marca State Bar 127365 d
3uPERIOR COURT oF CA FORNiH
Jeff T Olsen State Bar 283249 OUPITY OF SAN B RN RDtlVO
TR cT
2 VARNER BRANDT LLP saN a
3750 University Avenue Suite 610
3 Riverside California 92501 0
Telephone 951 274 7777
4 Facsimile 951 274 7770 o n
Y 4
T
5 N C E r N
Attorneys for Defendant
6 BISCOMERICA CORP a
California corporation
7
SUPERIOR COURT OF CALIFORNIA
8
COUNTY OF SAN BERNARDINO
9
BRIANNA FLORES individually and on CASE NO CIVDS 1930814
10 behalf of other members of the general public Assigned for aIl purposes to
situated
similarly Hon David Cohn Dept S26
11
a
0 12 Plaintiff
a n DECLARATION OF JEFF T OLSEN IN
13 v
SUPPORT OF AUT011 IATIC THIRTY
b h 30 DAY EXTENSIOI 1 OF TIME FOR
BISCOMERICA CORP California DEFENDANT TO RE POND TO
14 a
m corporation and DOES 1 through 100 PLAINTIFF S COMPLAINT PURSUANT
inclusive TO CODE OF CIVIL PROCEDURE
15
SECTION 430 41 A 3 i
16 r y
17
Defendants
j c
rt i L C
i r
18
Complaint Filed October 15 2019
19
20
21
22
23
24 lI
25
26 Il
27
28
1
DECLARATION OF JEFF T OLSEN
1 I Jeff T Qlsen deciare as follows
2 1
I am an attorney licensed to practice before this Court I am an attorney at the law
3 firzn of Varner Brandt LLP attorn ys af record for Defendant BISCC MERICA CORP a
4 California corporation Defendant I give this decIaratian in support of Defendant s automatic
5 thirty 30 day extension of time to respond to the Complaint filed by Plaintiff BRIA NNA
6 FLQRES Plaintif together with Defendant herein after the Parties pursuant to Code of
7 Civil Procedure section 430 41 a 3 I have personal knowledge ofthe facts set forth herein If
8 called to do so I could and would competently testify to these facts under oath
9 2 On or about October 1 S 2019 Plaintiff filed her Complaint against Defendant in
10 the Superior Court af California County of San Bernardino On ar about October 30 2019
I1 Plazntiff served Defendant with the Complaint
12 3 Defendant has recently retain d my firm for purposes of defending this litigation
a N
13 Defendant has received and reviewed the Complaint and is contemplating the merits of a
w
o 14 demurrer which would challenge the entire complaint on multiple grounds
t5 4 Based on my firm s recent retention as counsel however Plaintiff s caunsel and I
v
v
1b have not been able as c fthe time of this filing tc substantively and realistieally speak to tl e merits
l7 af Defendarit s prc pased responsive pleadings including a potential demurrer hefore the prigr
18 respansive
pleading deadline which is also stayed pursuant to the Court s Complex Litigation
19 Program Initial Case Management Conference Order
20 5 There ore out of an abundance of caution Defendant is filing this declaration for
21 an autorrzatic 30 day extension far Defendant to fi1e its respective responsive pleadings in
22 accordance with Ca1 Civ Proc 430 41 which wi11 hopefizlly allow the Parties the requisite time
23 to properly and fully rneet and confer on the issues of respansive pleadings and avoid any
24 unnecessary motions in hopes that counsel for both Parties can meet and confer pursuant to the
25 Initiat Case Management Conference Order and submit a jaint stipulation ahead afthe initial Case
26 Mazzagement Conference scheduled for December 17 2019 Assuming the stay is lifted and that
27 Defendant s calculatians are cc rrect tl te c zrrent 30 day extension under Cal Civ Proc 430 41
Z
2
DECLARATIUN OF JEFF I OLSEN
Document Filed Date
December 02, 2019
Case Filing Date
October 15, 2019
Category
Employment - Complex
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CIfUA L 1 Richard D Marca State Bar 127365 d 3uPERIOR COURT oF CA FORNiH Jeff T Olsen State Bar 283249 OUPITY OF SAN B RN RDtlVO TR cT 2 VARNER BRANDT LLP saN a 3750 University Avenue Suite 610 3 Riverside California 92501 0 Telephone 951 274 7777 4 Facsimile 951 274 7770 o n Y 4 T 5 N C E r N Attorneys for Defendant 6 BISCOMERICA CORP a California corporation 7 SUPERIOR COURT OF CALIFORNIA 8 COUNTY OF SAN BERNARDINO 9 BRIANNA FLORES individually and on CASE NO CIVDS 1930814 10 behalf of other members of the general public Assigned for aIl purposes to situated similarly Hon David Cohn Dept S26 11 a 0 12 Plaintiff a n DECLARATION OF JEFF T OLSEN IN 13 v SUPPORT OF AUT011 IATIC THIRTY b h 30 DAY EXTENSIOI 1 OF TIME FOR BISCOMERICA CORP California DEFENDANT TO RE POND TO 14 a m corporation and DOES 1 through 100 PLAINTIFF S COMPLAINT PURSUANT inclusive TO CODE OF CIVIL PROCEDURE 15 SECTION 430 41 A 3 i 16 r y 17 Defendants j c rt i L C i r 18 Complaint Filed October 15 2019 19 20 21 22 23 24 lI 25 26 Il 27 28 1 DECLARATION OF JEFF T OLSEN 1 I Jeff T Qlsen deciare as follows 2 1 I am an attorney licensed to practice before this Court I am an attorney at the law 3 firzn of Varner Brandt LLP attorn ys af record for Defendant BISCC MERICA CORP a 4 California corporation Defendant I give this decIaratian in support of Defendant s automatic 5 thirty 30 day extension of time to respond to the Complaint filed by Plaintiff BRIA NNA 6 FLQRES Plaintif together with Defendant herein after the Parties pursuant to Code of 7 Civil Procedure section 430 41 a 3 I have personal knowledge ofthe facts set forth herein If 8 called to do so I could and would competently testify to these facts under oath 9 2 On or about October 1 S 2019 Plaintiff filed her Complaint against Defendant in 10 the Superior Court af California County of San Bernardino On ar about October 30 2019 I1 Plazntiff served Defendant with the Complaint 12 3 Defendant has recently retain d my firm for purposes of defending this litigation a N 13 Defendant has received and reviewed the Complaint and is contemplating the merits of a w o 14 demurrer which would challenge the entire complaint on multiple grounds t5 4 Based on my firm s recent retention as counsel however Plaintiff s caunsel and I v v 1b have not been able as c fthe time of this filing tc substantively and realistieally speak to tl e merits l7 af Defendarit s prc pased responsive pleadings including a potential demurrer hefore the prigr 18 respansive pleading deadline which is also stayed pursuant to the Court s Complex Litigation 19 Program Initial Case Management Conference Order 20 5 There ore out of an abundance of caution Defendant is filing this declaration for 21 an autorrzatic 30 day extension far Defendant to fi1e its respective responsive pleadings in 22 accordance with Ca1 Civ Proc 430 41 which wi11 hopefizlly allow the Parties the requisite time 23 to properly and fully rneet and confer on the issues of respansive pleadings and avoid any 24 unnecessary motions in hopes that counsel for both Parties can meet and confer pursuant to the 25 Initiat Case Management Conference Order and submit a jaint stipulation ahead afthe initial Case 26 Mazzagement Conference scheduled for December 17 2019 Assuming the stay is lifted and that 27 Defendant s calculatians are cc rrect tl te c zrrent 30 day extension under Cal Civ Proc 430 41 Z 2 DECLARATIUN OF JEFF I OLSEN