On July 05, 2019 a
Conference
was filed
involving a dispute between
Maddies, Jeffrey,
and
Goliath Financial, Inc.,
for Employment - Complex
in the District Court of San Bernardino County.
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Joseph Lavi, Esq, (SBN 209776) ELECTRONICALLY FILED (Auto)
Vincent C. Granberry, Esq. (SBN 276483) SUPERIOR COURT OF CALIFORNIIA
Elizabeth L. Harrier, Esq. (SBN 3 19550) COUNTY OF SAN BERNARDINO
LAVI & EBRAHIMIAN, LLP 11/3/2023 4:39 PM
8889 W. Olympic Blvd., Suite 200
Beverly Hills, California 90211
Telephone: (3 10) 432-0000
Facsimile: (3 10) 432-0001
Emails: ilavi@lelawfirm.com
V ranberrv@lelawfirm.com
eharrier@lelawfinn.com
WHT1@lelawfirm.com
Attorneys for PLAINTIFF JEFFREY MADDIES,
on behalf of himself and others similarly situated.
Brenan T. Sapien, Esq. (SBN 274247)
Brendan.Sapien@DaughertyLordan.com
10
DAUGHERTYLORDAN LLP
550 S. Hope Street, Suite 2400
Los Angeles, CA 90071
11
Telephone: 2 1 3 .423 .6027
12 Attorneys for DEFENDANT GOLIATH FINANCIAL,
INC. -
13
SUPERIOR COURT OF THE STATE OF CALIFORNIA
14 '
FOR THE COUNTY OF SAN BERNARDINO
15
16
JEFFREY MADDIES, on behalf of himself and Case No; CIVDS 1 919776
others similarly situated,
17
CLASS ACTION
PLAINTIFF,
18
[Assignedfor all purposes t0 the Hon. David
VS I
19 Cohn; Dept. S—26]
20 and DOES JOINT STATEMENT IN ADVANCE 0F
?(?)LmlpggigiNANaAL’ INC"
.
1 t0
THE TRIAL SETTING CONFERENCE
21
Trial Setting Conference:
DEFENDANT
22 Date: November 6, 2023
Time: 8:30AM
23 Dept. S-26
24 Plaintiff JEFFREY MADDIES (“Plaintiff”) and Defendant GOLIATH FINANCIAL, INC.
25 (“Defendant”) (collectively, “Parties”), by and through their respective counsel of record, hereby
26 submit the following joint report in advance of the Trial Setting Conference on November 6, 2023:
27 Based on Defendant’s alleged financial hardship, Plaintiff has attempted to negotiate an
28 individual settlement. During telephonic meet and confers, Defendant informed Plaintiff that it would
1
JOINT STATEMENT IN ADVANCE OF THE TRIAL SETTING CONFERENCE
produce the requested financial documents. Plaintiff has been following up regularly to obtain these
documents, as well as to begin negotiations on an individual settlement. To date, there has been no
progress on the production of financial records 0r individual settlement discussions.
Defendant recently spoke with opposing counsel to discuss individual settlement negotiations
and anticipate getting Plaintiff an individual offer by Monday or Tuesday of next week. Additionally,
Defense counsel in this matter has been embroiled in the very public departure of defense attorneys
from Lewis Brisbois Bisgaard and Smith to Barber Ranen. In the wake of that exodus and the
implosion of Barber Ranen, defense counsel in this matter has been transitioning to a different firm —
which has been the source of the delay in this matter.
10 Further, it was a result of this transition that Defense Counsel inadvertently failed to appear
11 at the last status conference in this matter. Defense Counsel apologizes to both the Court and
12 Plaintiff’s Counsel for this error and will ensure it does not happen again.
13
Dated: November 3, 2023 Respectfully submitted,
14
LAVI & EBRAHIMIAN, LLP
15
l6 By: /s/ Elizabeth L. Harrier
Joseph Lavi, Esq.
17
Vincent C. Granberry, Esq.
Elizabeth L. Harrier, Esq.
18
l9 Attorneys for Plaintiff JEFFREY MADDIES
and Other Class Members
20
Dated: November 3, 2023 Respectfully submitted,
21
DAUGHERTYLORDAN LLP
22
23
By: /S/ Brendan Sapien
24 Brendan Sapien, Esq.
25
Attorneys for Defendant
26
GOLIATH FINANCIAL, INC.
27
28
2
JOINT STATEMENT IN ADVANCE OF THE TRIAL SETTING CONFERENCE
Document Filed Date
November 03, 2023
Case Filing Date
July 05, 2019
Category
Employment - Complex
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Joseph Lavi, Esq, (SBN 209776) ELECTRONICALLY FILED (Auto) Vincent C. Granberry, Esq. (SBN 276483) SUPERIOR COURT OF CALIFORNIIA Elizabeth L. Harrier, Esq. (SBN 3 19550) COUNTY OF SAN BERNARDINO LAVI & EBRAHIMIAN, LLP 11/3/2023 4:39 PM 8889 W. Olympic Blvd., Suite 200 Beverly Hills, California 90211 Telephone: (3 10) 432-0000 Facsimile: (3 10) 432-0001 Emails: ilavi@lelawfirm.com V ranberrv@lelawfirm.com eharrier@lelawfinn.com WHT1@lelawfirm.com Attorneys for PLAINTIFF JEFFREY MADDIES, on behalf of himself and others similarly situated. Brenan T. Sapien, Esq. (SBN 274247) Brendan.Sapien@DaughertyLordan.com 10 DAUGHERTYLORDAN LLP 550 S. Hope Street, Suite 2400 Los Angeles, CA 90071 11 Telephone: 2 1 3 .423 .6027 12 Attorneys for DEFENDANT GOLIATH FINANCIAL, INC. - 13 SUPERIOR COURT OF THE STATE OF CALIFORNIA 14 ' FOR THE COUNTY OF SAN BERNARDINO 15 16 JEFFREY MADDIES, on behalf of himself and Case No; CIVDS 1 919776 others similarly situated, 17 CLASS ACTION PLAINTIFF, 18 [Assignedfor all purposes t0 the Hon. David VS I 19 Cohn; Dept. S—26] 20 and DOES JOINT STATEMENT IN ADVANCE 0F ?(?)LmlpggigiNANaAL’ INC" . 1 t0 THE TRIAL SETTING CONFERENCE 21 Trial Setting Conference: DEFENDANT 22 Date: November 6, 2023 Time: 8:30AM 23 Dept. S-26 24 Plaintiff JEFFREY MADDIES (“Plaintiff”) and Defendant GOLIATH FINANCIAL, INC. 25 (“Defendant”) (collectively, “Parties”), by and through their respective counsel of record, hereby 26 submit the following joint report in advance of the Trial Setting Conference on November 6, 2023: 27 Based on Defendant’s alleged financial hardship, Plaintiff has attempted to negotiate an 28 individual settlement. During telephonic meet and confers, Defendant informed Plaintiff that it would 1 JOINT STATEMENT IN ADVANCE OF THE TRIAL SETTING CONFERENCE produce the requested financial documents. Plaintiff has been following up regularly to obtain these documents, as well as to begin negotiations on an individual settlement. To date, there has been no progress on the production of financial records 0r individual settlement discussions. Defendant recently spoke with opposing counsel to discuss individual settlement negotiations and anticipate getting Plaintiff an individual offer by Monday or Tuesday of next week. Additionally, Defense counsel in this matter has been embroiled in the very public departure of defense attorneys from Lewis Brisbois Bisgaard and Smith to Barber Ranen. In the wake of that exodus and the implosion of Barber Ranen, defense counsel in this matter has been transitioning to a different firm — which has been the source of the delay in this matter. 10 Further, it was a result of this transition that Defense Counsel inadvertently failed to appear 11 at the last status conference in this matter. Defense Counsel apologizes to both the Court and 12 Plaintiff’s Counsel for this error and will ensure it does not happen again. 13 Dated: November 3, 2023 Respectfully submitted, 14 LAVI & EBRAHIMIAN, LLP 15 l6 By: /s/ Elizabeth L. Harrier Joseph Lavi, Esq. 17 Vincent C. Granberry, Esq. Elizabeth L. Harrier, Esq. 18 l9 Attorneys for Plaintiff JEFFREY MADDIES and Other Class Members 20 Dated: November 3, 2023 Respectfully submitted, 21 DAUGHERTYLORDAN LLP 22 23 By: /S/ Brendan Sapien 24 Brendan Sapien, Esq. 25 Attorneys for Defendant 26 GOLIATH FINANCIAL, INC. 27 28 2 JOINT STATEMENT IN ADVANCE OF THE TRIAL SETTING CONFERENCE