On May 02, 2019 a
Party Statement
was filed
involving a dispute between
Mark Tirman,
Tirman, Mark,
and
Passport Health Holdings, Llc,
Pph Franchise Holdings, Llc,
for Unlimited Civil
in the District Court of Alameda County.
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AANA
___.___ 22705717.
Scott Edward Cole, Esq. (S.B. #160744)
Laura Grace Van Note, Esq. (S.B. #310160)
SCOTT COLE & ASSOCIATES, APC
YO
555 12" Street, Suite 1725
Oakland, California 94607
WD
Telephone: (510) 891-9800
Facsimile: (510) 891-7030
BR
Email: scole@scalaw.com
Email: lvannote@scalaw.com
HW
Web: www.scalaw.com
DR
Attorneys for Representative Plaintiff,
Aggrieved Employees and the Plaintiff Class
SN
Diana Estrada, Esq. (S.B. # 212702)
Oo
Brianna S. Wilson, Esq. (S.B. # 316730)
WILSON, ELSER, MOSKOWITZ,
So
EDELMAN & DICKER LLP
555 South Flower Street, Suite 2900
Los Angeles, California 90071
ons
Telephone: (213) 443-5100
Facsimile: (213) 443-5101
Email: diana.Estrada@wilsonelser.com
SCOTT COLE & ASSOCIATES, APC
Email: brianna.wilson@wilsonelser.com
555 12™ STREET, SUITE 1725
OAKLAND, CA 94607
ATTORNEYS AT LAW
TEL: (510) 891-9800
Attorneys for Defendants
PPH FRANCHISE HOLDINGS, LLC, and
rniaaar
PASSPORT HEALTH HOLDINGS, LLC
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF ALAMEDA
Cue
MARK TIRMAN, individually, and on Case No. RG19017399
behalf of all others similarly situated,
F&F
Assigned for All Purposes To:
Plaintiff, Judge: Brad Seligman
F&F
vs. Dept: 23
PPH FRANCHISE HOLDINGS, LLC; UPDATED JOINT COMPLEX CASE
BH
PASSPORT HEALTH HOLDINGS, LLC; MANAGEMENT CONFERENCE
and DOES | through 100, inclusive, STATEMENT
F
Defendants. Date: April 14, 2020
Time: 3:00 p.m.
&
Dept: 23
AXED
kB
Action Filed: May 2, 2019
BSS
-[-
Joint Complex Case Management Conference Statement
3612774v.1
Defendants PPH FRANCHISE HOLDINGS, LLC and PASSPORT HEALTH
=|
HOLDINGS, LLC (“Defendant”) and Plaintiff Mark Tirman (‘Plaintiff’), by and through their
WN
respective counsel, hereby submit the following Updated Joint Complex Case Management
Conference Statement.
eR
FACTUAL BACKGROUND
NW
Plaintiff's Statement: Plaintiff and the putative class members are non-exempt nurses
DO
employed within California. Plaintiff alleges Defendant had a consistent policy whereby it failed
NY
to provide legally compliant meal and rest periods, failed to provide accurate wage statements,
Oo
failed to pay all wages due on termination, and engaged in unfair business practices in violation of
0
the Unfair Competition Act. The basis for these claims is that Defendant schéduled patient
S
eet
appointments without allocating time for class members to take breaks.
BHA
5 The parties are meeting and conferring on outstanding discovery, and will submit a joint
Ro
IDC statement if it becomes necessary.
SsEe8
= tS
Supae
age Defendant’s Statement: Plaintiff alleges to be a member of a class alleging causes of
rWAaADRE
agEce
mee
Document Filed Date
April 30, 2020
Case Filing Date
May 02, 2019
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AANA ___.___ 22705717. Scott Edward Cole, Esq. (S.B. #160744) Laura Grace Van Note, Esq. (S.B. #310160) SCOTT COLE & ASSOCIATES, APC YO 555 12" Street, Suite 1725 Oakland, California 94607 WD Telephone: (510) 891-9800 Facsimile: (510) 891-7030 BR Email: scole@scalaw.com Email: lvannote@scalaw.com HW Web: www.scalaw.com DR Attorneys for Representative Plaintiff, Aggrieved Employees and the Plaintiff Class SN Diana Estrada, Esq. (S.B. # 212702) Oo Brianna S. Wilson, Esq. (S.B. # 316730) WILSON, ELSER, MOSKOWITZ, So EDELMAN & DICKER LLP 555 South Flower Street, Suite 2900 Los Angeles, California 90071 ons Telephone: (213) 443-5100 Facsimile: (213) 443-5101 Email: diana.Estrada@wilsonelser.com SCOTT COLE & ASSOCIATES, APC Email: brianna.wilson@wilsonelser.com 555 12™ STREET, SUITE 1725 OAKLAND, CA 94607 ATTORNEYS AT LAW TEL: (510) 891-9800 Attorneys for Defendants PPH FRANCHISE HOLDINGS, LLC, and rniaaar PASSPORT HEALTH HOLDINGS, LLC IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF ALAMEDA Cue MARK TIRMAN, individually, and on Case No. RG19017399 behalf of all others similarly situated, F&F Assigned for All Purposes To: Plaintiff, Judge: Brad Seligman F&F vs. Dept: 23 PPH FRANCHISE HOLDINGS, LLC; UPDATED JOINT COMPLEX CASE BH PASSPORT HEALTH HOLDINGS, LLC; MANAGEMENT CONFERENCE and DOES | through 100, inclusive, STATEMENT F Defendants. Date: April 14, 2020 Time: 3:00 p.m. & Dept: 23 AXED kB Action Filed: May 2, 2019 BSS -[- Joint Complex Case Management Conference Statement 3612774v.1 Defendants PPH FRANCHISE HOLDINGS, LLC and PASSPORT HEALTH =| HOLDINGS, LLC (“Defendant”) and Plaintiff Mark Tirman (‘Plaintiff’), by and through their WN respective counsel, hereby submit the following Updated Joint Complex Case Management Conference Statement. eR FACTUAL BACKGROUND NW Plaintiff's Statement: Plaintiff and the putative class members are non-exempt nurses DO employed within California. Plaintiff alleges Defendant had a consistent policy whereby it failed NY to provide legally compliant meal and rest periods, failed to provide accurate wage statements, Oo failed to pay all wages due on termination, and engaged in unfair business practices in violation of 0 the Unfair Competition Act. The basis for these claims is that Defendant schéduled patient S eet appointments without allocating time for class members to take breaks. BHA 5 The parties are meeting and conferring on outstanding discovery, and will submit a joint Ro IDC statement if it becomes necessary. SsEe8 = tS Supae age Defendant’s Statement: Plaintiff alleges to be a member of a class alleging causes of rWAaADRE agEce mee