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According to the allegations of the complaint, plaintiff Stuti Kochhar (“Plaintiff”) is a tutor for students at Stanford University, and in 2017, Plaintiff began to tutor defendant Mikaela Berkeley (“Mikaela”) at a rate of $105 per hour from April-December 31, 2017 and at a rate of $135 per hour from January 1, 2019 until June 20, 2020. (See complaint, ¶ 5.) In mid-2017, Mikaela informed Plaintiff that she had problems paying Plaintiff because she was unable to process payments using her international bank and was unable to write checks through her bank account in the United States. (See complaint, ¶ 7.) At that point, Mikaela’s mother, defendant Meruert Berkalieva (“Meruert”) began paying for the tutoring services. (See complaint, ¶ 8.) Meruert urged Plaintiff to invoice her quarterly because Meruert was incurring high flat fees for international banking currency transfers. (See complaint, ¶ 9.) Despite personal assurances from Meruert, starting in winter quarter of 2019, invoices
Hearing Date
December 17, 2020
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According to the allegations of the complaint, plaintiff Stuti Kochhar (“Plaintiff”) is a tutor for students at Stanford University, and in 2017, Plaintiff began to tutor defendant Mikaela Berkeley (“Mikaela”) at a rate of $105 per hour from April-December 31, 2017 and at a rate of $135 per hour from January 1, 2019 until June 20, 2020. (See complaint, ¶ 5.) In mid-2017, Mikaela informed Plaintiff that she had problems paying Plaintiff because she was unable to process payments using her international bank and was unable to write checks through her bank account in the United States. (See complaint, ¶ 7.) At that point, Mikaela’s mother, defendant Meruert Berkalieva (“Meruert”) began paying for the tutoring services. (See complaint, ¶ 8.) Meruert urged Plaintiff to invoice her quarterly because Meruert was incurring high flat fees for international banking currency transfers. (See complaint, ¶ 9.) Despite personal assurances from Meruert, starting in winter quarter of 2019, invoices