On October 01, 2020 a
Party Notice
was filed
involving a dispute between
Amaya, Jaime,
Bass, Ryne,
Gonzalez, Paula,
Jaime Amaya, On Behalf Of Themselves And All Others Similarly Situated,
Mazariegos, Alida,
Tello, Adriana,
Tello, Georgina,
and
Buddha Capital Corporation,
Does 1 Through 10, Inclusive,
Rr Franchising, Inc,
Vanguard Cleaning Systems, Inc,
Vanguard Cleaning Systems Of The Central Valley,
Wine Country Ventures, Inc.,
for Complex Civil Unlimited Class Action
in the District Court of San Mateo County.
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JESSICA RIGGIN (SBN 281712)
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jriggin@rukinhyland.com
2 VALERIE BRENDER (SBN 298224)
vbrender@rukinhyland.com
3 RUKIN HYLAND & RIGGIN LLP
1939 Harrison Street, Suite 290
4 Oakland, CA 94612 4/16/2021
5 Telephone: (415) 421-1800
Facsimile: (415) 421-1700
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MATTHEW C. HELLAND (SBN 250451)
7 helland@nka.com
DANIEL BROME (SBN 278915)
8 dbrome@nka.com
NICHOLS KASTER, LLP
9 235 Montgomery Street, Suite 810
San Francisco, CA 94104
10 Telephone: (415) 277-7235
Facsimile: (415) 277-7238
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Attorneys for Plaintiffs
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF SAN MATEO
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16 ALIDA MAZARIEGOS, PAULA CASE NO.: 20-CIV-04267
GONZALEZ, and JAIME AMAYA
17 NOTICE OF MINUTE ORDER
18 Plaintiffs, on behalf of themselves
and all others similarly situated, Judge: Hon. Nancy L. Fineman
Dept.: 04
19 v.
20 VANGUARD CLEANING SYSTEMS,
INC.; RR FRANCHISING, INC., D/B/A
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VANGUARD CLEANING SYSTEMS
22 OF SOUTHERN CALIFORNIA AND
D/B/A VANGUARD CLEANING
23 SYSTEMS OF NORTHERN
CALIFORNIA; BUDDHA CAPITAL
24 CORPORATION, D/B/A VANGUARD
CLEANING SYSTEMS OF
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SACRAMENTO, D/B/A VANGUARD
26 CLEANING SYSTEMS OF THE
CENTRAL VALLEY, AND D/B/A
27 VANGUARD CLEANING SYSTEMS
OF THE CENTRAL COAST; AND
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NOTICE OF MINUTE ORDER
WINE COUNTRY VENTURES, INC.
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D/B/A VANGUARD CLEANING
2 SYSTEMS OF THE NORTH BAY,
AND DOES 1 THROUGH 10,
3 INCLUSIVE,
4 Defendants.
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NOTICE OF MINUTE ORDER
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On April 6, 2021, the Court conducted a status conference in the above-captioned case, at
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which Plaintiffs Alida Mazariegos, Paula Gonzalez, and Jaime Amaya (“Plaintiffs”) and
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Defendants Vanguard Cleaning Systems, Inc. (“Vanguard”); RR Franchising, Inc., d/b/a
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Vanguard Cleaning Systems of Southern California and d/b/a Vanguard Cleaning Systems of
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Northern California (“RR Franchising”); Buddha Capital Corporation, d/b/a/ Vanguard Cleaning
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Systems of Sacramento, d/b/a Vanguard Cleaning Systems of the Central Valley, and d/b/a/
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Vanguard Cleaning Systems of the Central Coast (“Buddha Capital”); and Wine Country
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Ventures, Inc. d/b/a Vanguard Cleaning Systems of the North Bay (“Wine Country”)
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(“Defendants”) (collectively “the Parties”), appeared through their counsel of record. During the
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status conference, the Court issued the following orders:
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1. The Court will conduct an informal discovery conference with the Parties regarding a
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discovery dispute relating to a release between Plaintiff Mazariegos and Defendant
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Wine Country on April 15, 2021 at 9:00 a.m., with statements to be emailed to
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Department 4 by April 13, 2021. All other parties are welcome to attend, but are not
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required.
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2. The briefing schedule for Plaintiffs’ motion for class certification shall be as follows:
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a. Plaintiffs’ motion for class certification shall be filed by August 6, 2021.
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b. Defendants’ oppositions shall be filed by November 5, 2021.
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c. Plaintiffs’ reply shall be filed by November 19, 2021.
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d. The hearing date shall be December 7, 2021 at 8:30 a.m.
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3. There shall be a further case management conference on July 6, 2021 at 8:30 a.m. The
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Parties shall file a joint status conference statement by June 29, 2021.
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Prior to filing this Notice of Minute Order, counsel for Plaintiffs circulated the Notice among the
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Parties, and counsel for each party confirmed its accuracy.
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NOTICE OF MINUTE ORDER
1 IT SO ORDERED.
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Dated:
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4 THE HONORABLE NANCY L. FINEMAN
Judge of the Superior Court
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NOTICE OF MINUTE ORDER
1 PROOF OF SERVICE
2 I am employed in the County of Alameda, State of California; I am over the age of 18
years and not a party to the within entitled action; my business address is 1939 Harrison Street,
3 Suite 290, Oakland, California 94612.
4 On April 15, 2021, I served the foregoing document(s), described as: NOTICE OF
MINUTE ORDER on the interested parties to said action by the following means:
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6 (By Mail) By placing the document(s) listed above in a sealed envelope with
postage thereon fully prepaid, in the a United States Mail at Oakland, California
7 addressed as set forth below.
(By Overnight Delivery) By placing a true copy thereof, enclosed in a sealed
8 envelope, with delivery charges prepaid, to be sent by Federal Express, addressed
as shown below.
9 (By Electronic Service) By electronically transmitting the document(s) listed above,
addressed as set forth below.
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Philip Baldwin Fraser A. McAlpine
11 Damon Ott Adam Truong
Olivia Florio Roberts Adam Lounsbury
12 LITTLER MENDELSON P.C. JACKSON LEWIS P.C.
333 Bush Street 50 California Street
13 34th Floor 9th Floor
San Francisco, CA 94104 San Francisco, CA 94111
14 Email: PBaldwin@littler.com Email: adam.truong@jacksonlewis.com
DOtt@littler.com adam.lounsbury@jacksonlewis.com
15 OFlorioRoberts@litter.com fraser.mcalpine@jacksonlewis.com
16 Attorneys for VANGUARD Attorneys for RR FRANCHISING, INC.;
CLEANING SYSTEMS, INC. BUDDHA CAPITAL CORPORATION; AND
17 WINE COUNTRY VENTURES, INC.
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(State) I declare under penalty of perjury under the laws of the State of California
20 that the above is true and correct.
21 Executed on April 15, 2021 at Newport, California.
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Brigitte A. Butler
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NOTICE OF MINUTE ORDER
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JESSICA RIGGIN (SBN 281712) 1 jriggin@rukinhyland.com 2 VALERIE BRENDER (SBN 298224) vbrender@rukinhyland.com 3 RUKIN HYLAND & RIGGIN LLP 1939 Harrison Street, Suite 290 4 Oakland, CA 94612 4/16/2021 5 Telephone: (415) 421-1800 Facsimile: (415) 421-1700 6 MATTHEW C. HELLAND (SBN 250451) 7 helland@nka.com DANIEL BROME (SBN 278915) 8 dbrome@nka.com NICHOLS KASTER, LLP 9 235 Montgomery Street, Suite 810 San Francisco, CA 94104 10 Telephone: (415) 277-7235 Facsimile: (415) 277-7238 11 Attorneys for Plaintiffs 12 13 SUPERIOR COURT OF THE STATE OF CALIFORNIA 14 COUNTY OF SAN MATEO 15 16 ALIDA MAZARIEGOS, PAULA CASE NO.: 20-CIV-04267 GONZALEZ, and JAIME AMAYA 17 NOTICE OF MINUTE ORDER 18 Plaintiffs, on behalf of themselves and all others similarly situated, Judge: Hon. Nancy L. Fineman Dept.: 04 19 v. 20 VANGUARD CLEANING SYSTEMS, INC.; RR FRANCHISING, INC., D/B/A 21 VANGUARD CLEANING SYSTEMS 22 OF SOUTHERN CALIFORNIA AND D/B/A VANGUARD CLEANING 23 SYSTEMS OF NORTHERN CALIFORNIA; BUDDHA CAPITAL 24 CORPORATION, D/B/A VANGUARD CLEANING SYSTEMS OF 25 SACRAMENTO, D/B/A VANGUARD 26 CLEANING SYSTEMS OF THE CENTRAL VALLEY, AND D/B/A 27 VANGUARD CLEANING SYSTEMS OF THE CENTRAL COAST; AND 28 NOTICE OF MINUTE ORDER WINE COUNTRY VENTURES, INC. 1 D/B/A VANGUARD CLEANING 2 SYSTEMS OF THE NORTH BAY, AND DOES 1 THROUGH 10, 3 INCLUSIVE, 4 Defendants. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NOTICE OF MINUTE ORDER 1 On April 6, 2021, the Court conducted a status conference in the above-captioned case, at 2 which Plaintiffs Alida Mazariegos, Paula Gonzalez, and Jaime Amaya (“Plaintiffs”) and 3 Defendants Vanguard Cleaning Systems, Inc. (“Vanguard”); RR Franchising, Inc., d/b/a 4 Vanguard Cleaning Systems of Southern California and d/b/a Vanguard Cleaning Systems of 5 Northern California (“RR Franchising”); Buddha Capital Corporation, d/b/a/ Vanguard Cleaning 6 Systems of Sacramento, d/b/a Vanguard Cleaning Systems of the Central Valley, and d/b/a/ 7 Vanguard Cleaning Systems of the Central Coast (“Buddha Capital”); and Wine Country 8 Ventures, Inc. d/b/a Vanguard Cleaning Systems of the North Bay (“Wine Country”) 9 (“Defendants”) (collectively “the Parties”), appeared through their counsel of record. During the 10 status conference, the Court issued the following orders: 11 1. The Court will conduct an informal discovery conference with the Parties regarding a 12 discovery dispute relating to a release between Plaintiff Mazariegos and Defendant 13 Wine Country on April 15, 2021 at 9:00 a.m., with statements to be emailed to 14 Department 4 by April 13, 2021. All other parties are welcome to attend, but are not 15 required. 16 2. The briefing schedule for Plaintiffs’ motion for class certification shall be as follows: 17 a. Plaintiffs’ motion for class certification shall be filed by August 6, 2021. 18 b. Defendants’ oppositions shall be filed by November 5, 2021. 19 c. Plaintiffs’ reply shall be filed by November 19, 2021. 20 d. The hearing date shall be December 7, 2021 at 8:30 a.m. 21 3. There shall be a further case management conference on July 6, 2021 at 8:30 a.m. The 22 Parties shall file a joint status conference statement by June 29, 2021. 23 Prior to filing this Notice of Minute Order, counsel for Plaintiffs circulated the Notice among the 24 Parties, and counsel for each party confirmed its accuracy. 25 26 27 28 NOTICE OF MINUTE ORDER 1 IT SO ORDERED. 2 Dated: 3 4 THE HONORABLE NANCY L. FINEMAN Judge of the Superior Court 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 NOTICE OF MINUTE ORDER 1 PROOF OF SERVICE 2 I am employed in the County of Alameda, State of California; I am over the age of 18 years and not a party to the within entitled action; my business address is 1939 Harrison Street, 3 Suite 290, Oakland, California 94612. 4 On April 15, 2021, I served the foregoing document(s), described as: NOTICE OF MINUTE ORDER on the interested parties to said action by the following means: 5 6 (By Mail) By placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid, in the a United States Mail at Oakland, California 7 addressed as set forth below. (By Overnight Delivery) By placing a true copy thereof, enclosed in a sealed 8 envelope, with delivery charges prepaid, to be sent by Federal Express, addressed as shown below. 9 (By Electronic Service) By electronically transmitting the document(s) listed above, addressed as set forth below. 10 Philip Baldwin Fraser A. McAlpine 11 Damon Ott Adam Truong Olivia Florio Roberts Adam Lounsbury 12 LITTLER MENDELSON P.C. JACKSON LEWIS P.C. 333 Bush Street 50 California Street 13 34th Floor 9th Floor San Francisco, CA 94104 San Francisco, CA 94111 14 Email: PBaldwin@littler.com Email: adam.truong@jacksonlewis.com DOtt@littler.com adam.lounsbury@jacksonlewis.com 15 OFlorioRoberts@litter.com fraser.mcalpine@jacksonlewis.com 16 Attorneys for VANGUARD Attorneys for RR FRANCHISING, INC.; CLEANING SYSTEMS, INC. BUDDHA CAPITAL CORPORATION; AND 17 WINE COUNTRY VENTURES, INC. 18 19 (State) I declare under penalty of perjury under the laws of the State of California 20 that the above is true and correct. 21 Executed on April 15, 2021 at Newport, California. 22 23 Brigitte A. Butler 24 25 26 27 28 4 NOTICE OF MINUTE ORDER