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”$22;
SCALLI RASUSSEN, PC
Halbert B. Rasumussen, Esq. (108566)
Dana R. Cohn, Esq. (302974)
F I L E
2 ;
800 Wilshire Boulevard, Ste. 400 SUPERIOR COURT 0F CALIFORNm
Los Angeles, CA 90017 0853“” OF; fifiNfiEENARDINO
‘ BEW‘A“ ""4” “STR'CT
Te1.: (213)239-5622
Fax: (213) 239-5623
MAY 26 2021
Attorneysfor Defendant QUAID HARLEY—DA VIDSON, INC.
PESTOTNIK LLP BY 1dr“?
ROSS H Hyslop (149358) foFAEL HERNANDEZ, DEPUTY
5
501 W. Broadway, Suite 1025
San Diego, California 92101
Tel: 619.237.3000
Fax: 619.342.8020
Attorneysfor PlaintiffLISA HILL, 0n behalfofherselfi the
proposed class,all others similarly situated, and 0n behalfof
the generalpublic
THE SUPERIOR COURT FOR THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
LISA HILL, an individual, on behalf ofherself, Case No. CIV DSl 826573
the proposed c1ass(es), all others similarly
situated, and on behalf ofthe general public, CLASS ACTION
Plaintiff, JOINT STATUS REPORT FOR JUNE
1, 2021 STATUS CONFERENCE
V'
Date: June 1, 2021
Time: 9:00 a.m.
QUAID HARLEY-DAVIDSON, INC., a
Judge: Hon. Wilfred J. Schneider
DOES through
California corporation; and 1 10,
Location: Department S32
inclusive,
San Bernardino Superior Court
Defendants.
247 West Third Street
San Bernardino, CA 92415-0201
Unlimited Civil Case
Complaint Filed: 10/05/20] 8
FAC Filed: 3/4/2019
SAC Filed: 5/22/20] 9
Assigned for all purposes to the Honorable
Wilfred J. Schneider
002393893 - l
-
JOINT STATUS REPORT FOR JUNE 1, 202] STATUS CONFERENCE
PlaintiffLisa Hill (“Plaintiff’ or “Hill”) and Defendant Quaid Harley-Davidson, Inc.
(“Defendant” or “QHD”) hereby submit the followingjoint status report for purposes ofthe June
1, 2021 status conference.
UNLESS OTHERWISE INDICATED, THE FOLLOWING STATEMENTS,
REPRESENTATIONS, POSITIONS, AND/OR CONTENTIONS ARE JOINT IN
NATURE, SUBMITTED BY PLAINTIFF AND OHD:
1. The last status conference was held 0n March l, 2021.
2. The June 1, 2021 status conference coincides with the hearing on Plaintiffs motion
for class certification. As such, the outcome ofthat motion will drive the remainder ofthe
10 scheduling issues.
11 3. As the Court knows, the relevant rules relating to the management of class actions
12 are contained in California Rules of Court (“CRC”), rules 3.760-3.771, and (for CLRA actions
13 like this one) Civil Code § 178]. The parties agree that, ifclass certification is granted, the class
14 will need to be given some form of notice and an opportunity to opt-out, per CRC 3.766, before
15 any merits-based issues can be decided.
16 4. If the Court certifies the case as a class action, the following issues will need t0 be
17 addressed at some point:
18 a) The method and manner ofissuing notice to the class.
19 b) Who will pay for the cost ofproviding notice to the class.
20 c) Whether QHD or a qualified third-party administrator will issue class notice.
21 d) The setting ofa schedule and/or deadlines for:
22 1) preparation ofa class list by QHD, and a decision on what information the class
23 list should contain;
24 2) determing the proper form/content of class notice, including a deadline for the
25 parties to submit a proposed class notice for approval to the Court;
26 3) ifthe parties are unable to agree on an acceptable form of class notice, a date by
27 which the parties present their competing proposals to the Court;
28
- -
002393893 2
JOINT STATUS REPORT FOR JUNE l, 2021 STATUS CONFERENCE
Preview
A8 ”$22; SCALLI RASUSSEN, PC Halbert B. Rasumussen, Esq. (108566) Dana R. Cohn, Esq. (302974) F I L E 2 ; 800 Wilshire Boulevard, Ste. 400 SUPERIOR COURT 0F CALIFORNm Los Angeles, CA 90017 0853“” OF; fifiNfiEENARDINO ‘ BEW‘A“ ""4” “STR'CT Te1.: (213)239-5622 Fax: (213) 239-5623 MAY 26 2021 Attorneysfor Defendant QUAID HARLEY—DA VIDSON, INC. PESTOTNIK LLP BY 1dr“? ROSS H Hyslop (149358) foFAEL HERNANDEZ, DEPUTY 5 501 W. Broadway, Suite 1025 San Diego, California 92101 Tel: 619.237.3000 Fax: 619.342.8020 Attorneysfor PlaintiffLISA HILL, 0n behalfofherselfi the proposed class,all others similarly situated, and 0n behalfof the generalpublic THE SUPERIOR COURT FOR THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO LISA HILL, an individual, on behalf ofherself, Case No. CIV DSl 826573 the proposed c1ass(es), all others similarly situated, and on behalf ofthe general public, CLASS ACTION Plaintiff, JOINT STATUS REPORT FOR JUNE 1, 2021 STATUS CONFERENCE V' Date: June 1, 2021 Time: 9:00 a.m. QUAID HARLEY-DAVIDSON, INC., a Judge: Hon. Wilfred J. Schneider DOES through California corporation; and 1 10, Location: Department S32 inclusive, San Bernardino Superior Court Defendants. 247 West Third Street San Bernardino, CA 92415-0201 Unlimited Civil Case Complaint Filed: 10/05/20] 8 FAC Filed: 3/4/2019 SAC Filed: 5/22/20] 9 Assigned for all purposes to the Honorable Wilfred J. Schneider 002393893 - l - JOINT STATUS REPORT FOR JUNE 1, 202] STATUS CONFERENCE PlaintiffLisa Hill (“Plaintiff’ or “Hill”) and Defendant Quaid Harley-Davidson, Inc. (“Defendant” or “QHD”) hereby submit the followingjoint status report for purposes ofthe June 1, 2021 status conference. UNLESS OTHERWISE INDICATED, THE FOLLOWING STATEMENTS, REPRESENTATIONS, POSITIONS, AND/OR CONTENTIONS ARE JOINT IN NATURE, SUBMITTED BY PLAINTIFF AND OHD: 1. The last status conference was held 0n March l, 2021. 2. The June 1, 2021 status conference coincides with the hearing on Plaintiffs motion for class certification. As such, the outcome ofthat motion will drive the remainder ofthe 10 scheduling issues. 11 3. As the Court knows, the relevant rules relating to the management of class actions 12 are contained in California Rules of Court (“CRC”), rules 3.760-3.771, and (for CLRA actions 13 like this one) Civil Code § 178]. The parties agree that, ifclass certification is granted, the class 14 will need to be given some form of notice and an opportunity to opt-out, per CRC 3.766, before 15 any merits-based issues can be decided. 16 4. If the Court certifies the case as a class action, the following issues will need t0 be 17 addressed at some point: 18 a) The method and manner ofissuing notice to the class. 19 b) Who will pay for the cost ofproviding notice to the class. 20 c) Whether QHD or a qualified third-party administrator will issue class notice. 21 d) The setting ofa schedule and/or deadlines for: 22 1) preparation ofa class list by QHD, and a decision on what information the class 23 list should contain; 24 2) determing the proper form/content of class notice, including a deadline for the 25 parties to submit a proposed class notice for approval to the Court; 26 3) ifthe parties are unable to agree on an acceptable form of class notice, a date by 27 which the parties present their competing proposals to the Court; 28 - - 002393893 2 JOINT STATUS REPORT FOR JUNE l, 2021 STATUS CONFERENCE