On June 21, 2023 a
Motion-Secondary
was filed
involving a dispute between
Frias, Norma,
and
Does 1-20,
Himnel Usa Incorporated,
for Wrongful Termination Unlimited
in the District Court of San Bernardino County.
Preview
Elyza P. Heraldez, Esq. (State Bar N0. 293395)
HERALDEZ LAW PC ELECTRONICALLY FILED
8280 Aspen Street, Suite 120 SUPERIOR COURT OF CALIFORNIA
Rancho Cucamonga, CA 91730 COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
Office: (909) 942—9992
Email: Elyza.Heraldez@Heraldezlaw.com 4/17/2024 4:01 PM
Attorneys for Plaintiffs NORMA FRIAS, By: Leslie Zepeda, DEPUTY
VERONICA HERNANDEZ, and YESENIA ROBLES
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
10
11 NORMA FRIAS, CASE NO.: CIVSB2314042
(Consolidated With CIVSB23 14471 and
12 Plaintiff, CIVSB23 14929)
13 VS. Assigned t0 Hon. Michael A. Sachs, Dept. S28
14 HIMNEL USA INCORPORATED, a California DECLARATION OF ELYZA P. HERALDEZ
Corporation, HIMNEL USA INCORPORATED IN SUPPORT OF PLAINTIFF YESENIA
15 DBA ST. MARY’S MONTESSORI SCHOOL, a ROBLES’S MOTION FOR LEAVE TO FILE
California Corporation, and DOES 1-20, SECOND AMENDED COMPLAINT
16 Inclusive,
[Filed concurrently with Notice ofMotion and
17 Defendants. Motionfor Leave t0 File Second Amended
Complaint, Memorandum ofPoints and Authorities;
18 [Proposed] Order]
19 VERONICA HERNANDEZ
Date: August 6, 2024
20 Plaintiff, Time: 8:30 a.m.
Dept: $28
21 vs.
22 HIMNEL USA INCORPORATED, etc., et a1,
23 Defendants.
24 YESENIA ROBLES,
25 Plaintiff,
26 vs.
27 HIMNEL USA INCORPORATED, etc., et a1,
28 Defendants.
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DECLARATION OF ELYZA P. HERALDEZ IN SUPPORT OF PLAINTIFF YESENIA ROBLES’S
MOTION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT
DECLARATION OF ELYZA P. HERALDEZ
I, Elyza Heraldez, declare as follows:
1. I am an attorney licensed to practice law in the state of California and am counsel 0f record
for Plaintiff Kayla Mann in the above-entitled action. I have personal knowledge of the facts set forth
herein, and if called as a witness, I could and would competently testify thereto.
2. I make this declaration in support of Yesenia Robles’s (“Plaintiff”) Motion for Leave t0
File Second Amended Complaint as t0 Defendant Himnel USA Incorporated dba St. Mary’s Montessori
School (“Defendant”).
3. A true and correct copy of Plaintiff s First Amended Complaint filed on or about November
10 9, 2023, is attached hereto as Exhibit “A.”
11 4. A true and correct copy of the proposed Second Amended Complaint is attached hereto as
12 Exhibit “B.”
13 I hereby declare under penalty ofperjury under the laws 0fthe State of California that the foregoing
14 is true and correct.
15 Executed this 16th day of April, 2024 at Rancho Cucamonga, California.
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_g% Elyza P. Hefraldez
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DECLARATION OF ELYZA P. HERALDEZ IN SUPPORT OF PLAINTIFF YESENIA ROBLES’S
MOTION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT
Document Filed Date
April 17, 2024
Case Filing Date
June 21, 2023
Category
Wrongful Termination Unlimited
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