Declaration

Cal. Super. - 6th Dist.July 18, 2017

1 DECLARATION OF SHAILENDRA SINGH IN SUPPORT OF HIS OPPOSITION TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Larry W. Lee, Esq. SBN 228175 DIVERSITY LAW GROUP, P.C. 515 S. Figueroa St., Suite 1250 Los Angeles, CA 90071 Telephone: (213) 488-6555 Facsimile: (213) 488-6554 Attorneys for Plaintiff (Additional counsel on following page) SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA CLARA SHAILENDRA SINGH, as an individual and on behalf of all others similarly situated, Plaintiffs, vs. INTER-CON SECURITY SYSTEMS, INC., a Corporation, and DOES 1 through 50, inclusive, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 17CV313202 Assigned for All Purposes to Honorable Brian C. Walsh in Department 1 DECLARATION OF SHAILENDRA SINGH’S IN SUPPORT OF HIS OPPOSITION TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION OF ISSUES Date: January 25, 2019 Time: 9:00 a.m. Dept: 1 Electronically Filed by Superior Court of CA, County of Santa Clara, on 12/14/2018 11:05 AM Reviewed By: R. Walker Case #17CV313202 Envelope: 2278889 17CV313202 Santa Clara - Civil 2 DECLARATION OF SHAILENDRA SINGH IN SUPPORT OF HIS OPPOSITION TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dennis S. Hyun (State Bar No. 224240) HYUN LEGAL, APC 515 S. Figueroa St., Suite 1250 Los Angeles, CA 90071 (213) 488-6555 (213) 488-6554 facsimile Edward W. Choi, State Bar No. 211334 Paul M. Yi, Esq. SBN 207867 LAW OFFICES OF CHOI & ASSOCIATES, APLC 515 S. Figueroa St. Suite 1250 Los Angeles, CA 90010 Telephone: (213) 381-1515 Facsimile: (213) 465-4885 William L. Marder, Esq. (SSN 170131) POLARIS LAW GROUP 501 San Benito Street, Suite 200 Hollister, CA 95023 Telephone: (831) 531-4214 Facsimile: (831) 634-0333 Attorneys for Plaintiff 3 DECLARATION OF SHAILENDRA SINGH IN SUPPORT OF HIS OPPOSITION TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, SHAILENDRA SINGH, declare under penalty of perjury as follows: DECLARATION OF SHAILENDRA SINGH 1. I am an individual over the age of 18. I am the named Plaintiff in the above- referenced action. I have personal knowledge of the facts set forth below and if called to testify I could and would do so competently. 2. I was formerly employed by Defendant INTER-CON SECURITY SYSTEMS, INC., (“Inter-Con”) from March 3, 2015 to May 19, 2017 as a security guard. 3. During my employment with Inter-Con I was assigned to work at the Department of Motor Vehicles (“DMV”) located in San Jose, California. Due to an unsubstantiated complaint by a DMV customer, I was suspended by Inter-Con and taken off of the DMV assignment. 4. After I was removed from the San Jose DMV assignment, Inter-Con reassigned me to work for a different client in Visalia. However, I could not work at that location because it was 204 miles from my house. As such, my employment was terminated. 5. Thereafter, I filed an unemployment insurance claim. 6. Inter-Con contested my unemployment insurance claim on the basis that I refused to accept the reassignment in Visalia, California. 7. I ultimately prevailed in my unemployment insurance claim. I declare under penalty of perjury and the laws of the State of California that the foregoing is true and correct and that this declaration was executed on this 14th day of December 2018 at Los Angeles, California. SHAILENDRA SINGH