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Jonathan M. Gcnish (State Bar No. 25903 1)
F
SUPERIOR COJR‘. H
I L ED I
A1 IFORNIA
COUNTV‘ OF 5A5 ’ V.‘ £ "(TWO
jgenish@blackstonepc.com SAN BERNARDIN’
é
; Um (HICT
Miriam Schimmel (State Bar No. 185089)
mschimmel@blackstonepc.com NOV OJ 2.23
Joana Fang (State Bar No. 309623)
jfang@blackstonepc.com ’
BY
BLACKSTONE LAW, APC J
JObiii-‘AH Hip,-
Ju...» \
8383 Wilshire Boulevard, Suite 745 «Armifdu my
Beverly Hills, California 9021 1
Telephone: (3 10) 622-4278
OO\IO\
Attorneys for Plaintiff
JUAN MANUEL MUNOZ
\O Allison S. Wallin, Bar N0. 313185
awallin@littlcr.com
10 Brooke S. Hammond, Bar No. 264305
bhammond@littler.com
11 Andrea Oguntula, Bar No. 327587
aoguntula@littler.com
12 LITTLER MENDELSON P.C.
2049 Century Park East
13 5th Floor
Los Angeles, California 90067.3107
l4 Telephone: 310.553.0308
Fax No.: 800.715.1330
15
Attorneys for Defendant
16 MGA ENTERTAINMENT, INC.
l7 SUPERIOR COURT 0F CALIFORNIA
m
l8 COUNTY OF SAN BERNARDINO
19 JUAN MANUEL MUNOZ, individually, and Case N0. CIVSBZ312322
on behalf of Aggrieved Employees pursuant
20 to the California Private Attorneys General JOINT STIPULATION AND
Act, ORDER T0 CONTINUE
21 NOVEMBER 28, 2023 TRIAL SETTING
Plaintiff, CONFERENCE
22 v.
ASSIGNED FOR ALL PURPOSES TO
23 MGA ENTERTAINMENT, INC., a JUDGE DONALD ALVAREZ, DEPT. S-14
California nonprofit corporation; and DOES 1
24 through 25, inclusive, Trial Date: None Set
Complaint Filed: June l, 2023
25 Defendants.
26
27
28
JOINT STIPULATION AND m ORDER To CONTINUE NOVEMBER 28,
CONFERENCE
2023 TRIAL SETTING
\a \a
Plaintiff JUAN MANUEL MUNOZ (“Plaintiff") and Defendant MGA ENTERTAINMENT,
INC. (“Defendant”) hereto, by and through their respective counsel, hereby stipulate and request the
Court t0 order as follows:
WHEREAS, on or about March 22, 2023, Plaintiff filed a Class Action Complaint in Los
Angeles County Superior Court, Case Number 23STCV06386, against Defendant alleging the
following causes of action: (1) Violation of Cal. Labor Code §§ 5 10 and 1 198 (Unpaid Overtime); (2)
Violation 0f Cal. Labor Code §§ l 194, 1 197 and 1197.1 (Unpaid Minimum Wages); (3) Violation of
Cal. Labor Code §§ 226.7 and 512(a) (Unpaid Meal Period Premiums); (4) Violation of Cal. Labor
Code § 226.7 (Unpaid Rest Period Premiums); (5) Violation of Cal. Labor Code § 226(a) (Failure to
10 Provide Accurate Wage Statements); (6) Violation of Cal. Labor Code §§ 201, 202 and 203 (Final
11 Wages Not Timely Paid); (7) Violation of Cal. Labor Code §§ 2800 and 2802 (Failure to Rcimburse
12 Necessary Business Expenses); and (8) Violation of Cal. Business & Professions Code § 17200, et
13 seq.;
14 WHEREAS, on or about June 1, 2023, Plaintiff filed a separate Complaint against Defendant
15 pursuant to the California Private Attorneys General Act in San Bemardino County Superior Court,
16 Case Number CIVSB2312322 for civil penalties stemming from the same allegations from the Class
17 Action Complaint;
18 WHEREAS, the Patties have agreed to a private mediation scheduled for January 22, 2024,
19 with Gig Kyriacou, Esq.;
20 WHEREAS, the Parties have agreed to an informal exchange of information and documents at
21 least 60 days prior t0 the mediation to facilitate a meaningful mediation;
22 WHEREAS, the Trial Setting Conference in this matter is currently set for November 28, 2023,
23 at 8:30 a.m. in Department S-14 of the above-cntitlcd Court;
24 WHEREAS, in the interest of efficiency, the Parties agree that it would conserve the Court's
25 and the Parties’ time and resources to continue the Trial Setting Conference to a date after their
26 scheduled mediation;
27 NOW THEREFORE, it is hereby request and agreed by the Parties, by and through their
28 respective counsel undersigned below, that die Trial Setting Conference, currently noticed for
JOINT STIPULATION AND fl] ORDER TO CONTFNUE NOVEMBER 28,
CONFERENCE
2023 TRIAL SETTING
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Jonathan M. Gcnish (State Bar No. 25903 1) F SUPERIOR COJR‘. H I L ED I A1 IFORNIA COUNTV‘ OF 5A5 ’ V.‘ £ "(TWO jgenish@blackstonepc.com SAN BERNARDIN’ é ; Um (HICT Miriam Schimmel (State Bar No. 185089) mschimmel@blackstonepc.com NOV OJ 2.23 Joana Fang (State Bar No. 309623) jfang@blackstonepc.com ’ BY BLACKSTONE LAW, APC J JObiii-‘AH Hip,- Ju...» \ 8383 Wilshire Boulevard, Suite 745 «Armifdu my Beverly Hills, California 9021 1 Telephone: (3 10) 622-4278 OO\IO\ Attorneys for Plaintiff JUAN MANUEL MUNOZ \O Allison S. Wallin, Bar N0. 313185 awallin@littlcr.com 10 Brooke S. Hammond, Bar No. 264305 bhammond@littler.com 11 Andrea Oguntula, Bar No. 327587 aoguntula@littler.com 12 LITTLER MENDELSON P.C. 2049 Century Park East 13 5th Floor Los Angeles, California 90067.3107 l4 Telephone: 310.553.0308 Fax No.: 800.715.1330 15 Attorneys for Defendant 16 MGA ENTERTAINMENT, INC. l7 SUPERIOR COURT 0F CALIFORNIA m l8 COUNTY OF SAN BERNARDINO 19 JUAN MANUEL MUNOZ, individually, and Case N0. CIVSBZ312322 on behalf of Aggrieved Employees pursuant 20 to the California Private Attorneys General JOINT STIPULATION AND Act, ORDER T0 CONTINUE 21 NOVEMBER 28, 2023 TRIAL SETTING Plaintiff, CONFERENCE 22 v. ASSIGNED FOR ALL PURPOSES TO 23 MGA ENTERTAINMENT, INC., a JUDGE DONALD ALVAREZ, DEPT. S-14 California nonprofit corporation; and DOES 1 24 through 25, inclusive, Trial Date: None Set Complaint Filed: June l, 2023 25 Defendants. 26 27 28 JOINT STIPULATION AND m ORDER To CONTINUE NOVEMBER 28, CONFERENCE 2023 TRIAL SETTING \a \a Plaintiff JUAN MANUEL MUNOZ (“Plaintiff") and Defendant MGA ENTERTAINMENT, INC. (“Defendant”) hereto, by and through their respective counsel, hereby stipulate and request the Court t0 order as follows: WHEREAS, on or about March 22, 2023, Plaintiff filed a Class Action Complaint in Los Angeles County Superior Court, Case Number 23STCV06386, against Defendant alleging the following causes of action: (1) Violation of Cal. Labor Code §§ 5 10 and 1 198 (Unpaid Overtime); (2) Violation 0f Cal. Labor Code §§ l 194, 1 197 and 1197.1 (Unpaid Minimum Wages); (3) Violation of Cal. Labor Code §§ 226.7 and 512(a) (Unpaid Meal Period Premiums); (4) Violation of Cal. Labor Code § 226.7 (Unpaid Rest Period Premiums); (5) Violation of Cal. Labor Code § 226(a) (Failure to 10 Provide Accurate Wage Statements); (6) Violation of Cal. Labor Code §§ 201, 202 and 203 (Final 11 Wages Not Timely Paid); (7) Violation of Cal. Labor Code §§ 2800 and 2802 (Failure to Rcimburse 12 Necessary Business Expenses); and (8) Violation of Cal. Business & Professions Code § 17200, et 13 seq.; 14 WHEREAS, on or about June 1, 2023, Plaintiff filed a separate Complaint against Defendant 15 pursuant to the California Private Attorneys General Act in San Bemardino County Superior Court, 16 Case Number CIVSB2312322 for civil penalties stemming from the same allegations from the Class 17 Action Complaint; 18 WHEREAS, the Patties have agreed to a private mediation scheduled for January 22, 2024, 19 with Gig Kyriacou, Esq.; 20 WHEREAS, the Parties have agreed to an informal exchange of information and documents at 21 least 60 days prior t0 the mediation to facilitate a meaningful mediation; 22 WHEREAS, the Trial Setting Conference in this matter is currently set for November 28, 2023, 23 at 8:30 a.m. in Department S-14 of the above-cntitlcd Court; 24 WHEREAS, in the interest of efficiency, the Parties agree that it would conserve the Court's 25 and the Parties’ time and resources to continue the Trial Setting Conference to a date after their 26 scheduled mediation; 27 NOW THEREFORE, it is hereby request and agreed by the Parties, by and through their 28 respective counsel undersigned below, that die Trial Setting Conference, currently noticed for JOINT STIPULATION AND fl] ORDER TO CONTFNUE NOVEMBER 28, CONFERENCE 2023 TRIAL SETTING