Stipulation and OrderCal. Super. - 6th Dist.March 19, 2020w p-dr-AHMHF-As-AHHH \DOOQONM-{kaNP-‘O \oooucx‘m-szzww Envelope: 4588606 AEGIS LAW FIRM,'PC KASHIF HAQUE, State Bar No; 21 8672 SAMUEL A. WQNG, State Bar No. 217104 JESSICA L. CAKZPB'ELL, State Bar No. 280626 9811 Irvine Centér' Drive, Suite! 100 Irvine, California 9261 8 Telephone: (949) 379-6250 Facsimile: (949) 379-625 I _ Email: JCampBell@aegislawfirm.com I Attorneys for PlaintiffFrank Ayon, individually and on behalf of all others similarly situated FILED _ July 13, 2020 g Clerk of The Court Superior Court of CA i County of Santa Clara ZOCV365255 By: rwalker SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY 0F SANTA CLARA FRANK AYON, individually and on behalf of ail others similarly situated Plaintiff, vs. RED COLLAR PET FOODS, 1N0; and DOES 1 through 20, inclusive, Defendants. JOINT STIPULATION AND [PROPOSED] ORDER TO TRANSFER ACTION _ Case N0. 20CV365255 JOINT STIPULATION AND [PRGPGSEB] ORDER T0 TRANSFER ACTION T0 THE SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F SAN BERNARDINO ‘ DEPT: JUDGE: 1 1 Brian C. Walsh " i! U! < b) wmflm Ix.) This Joint Stipulation is submitted by PlaintiffFRANK AYON (“P1aintiff’), ,and Defendant RED COLILAR PET'FOQDS, INC. (“Defendant”) (éollectively the “Parties”), by and through their respective attorneys of record. The Parties stipulate and agree as follows: 1. RECITALS 1. Plaintiff filed his Covinplaint 0n March 19, 2020, in Santa Clara County. In that pleading, Plaintiff asserts claimé for various wage and hour claims 0n behalf of himself and all non-exempt employees who worked for Defendant in the State 0f California. 2. Defendant contends venue is proper in San Bernardino County because its principal placa 0f business is in San Bemardino. 3. The Parties agree that this action should be transferred to San Bemardino County. II. STIPULATION Based on the foregoing recitals, Which are incorporated harem by reference, the Parties hereby stipulate, agree, and jointly request that the Court transfer this action for all purposes to the Superior Court ofthe State of California in and for the County of San Bernardino. It is further stipulated and agreed that Plaintiff shall post the clerk’s costs and fees associated with processing a change ofvenue concurrently With the filing of this Stipulation. IT IS SO STIPULATED. DATED: July 8, 2020 AEGES LAW FIRM BszEygfl Z»MCA L. CAMPBELL Attorneys for Plaintiff Frank Ayon 2 JOINT STIPULATION AND [PROPOSED] ORDER TO TRANSFER ACTION U1 L») \OOO\J© DATED: July 8, 2020 KING CHENG MILLER & JEN, LLP v By: "- ’ , DAVID P. KING g , Attorneys for Red Collar et Foods, Inc. n. 3‘ JOINT STIPULATION AND [PROPOSED] ORDER TO TRANSFER ACTION U1 A U) [\J \DOOQO\ IWI- ORDER The Court, having reviewed. the Parties’ stipulation, and finding good cause therefore, GRANTS the Parties’ reqfiest. This action shall be transferred to the San Bernardino County Superior Court for all purposes effective immediately. The Clerk of the Court is directed t0 process the change of venue effective as ofthe date of this order and promptly transfer the file to the Clerk for the Superior Court 0f California in and for the County of San Bernardino. Dated: IT IS SO ORDERED. Julv13,2020 K P C' 09L HON. JUDGE BRIAN C. WALSH - JUDGE OF THE SUPERIOR COURT 4 JOINT STIPULATION AND [PROPOSED] ORDER TO TRANSFER. ACTION \OOOQONUI-PUJNH NNNNNNNNNt-I-Ht-I-Ht-I-Ht- OONQM$UJNHOKOOOQONMJ>WNHO CERTIFICATE OF SERVICE I, the undersigned, am employed in the County 0f Orange, State 0f California. I am over the age of 18 and not a party t0 the Within action; am employed With Aegis Law Firm PC and my business address is 9811 Irvine Center Drive, Suite 100, Irvine, California 92618. On July 13, 2020, I served the foregoing document entitled: 0 JOINT STIPULATION AND [PROPOSED] ORDER TO TRANSFER ACTION TO THE SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO on all the appearing and/or interested parties in this action by deliveringD the original g a true copy thereof on the party(ies) addressed below as follows: Laura Bailey Gallagher, esq. HARMON & DAVIES, P.C. 2306 Columbia Avenue Lancaster, PA 17603 Telephone: 717.291 .2236 Facsimile: 717.291.5739 lgallagher@h-dlaw.com Attorneys For Defendant: RED COLLAR PET FOODS, INC. D (BY MAIL) I am readily familiar With the firm’s practice 0f collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service 0n that same day with postage thereon fully prepaid at Irvine, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postage cancellation date or postage meter date is more than one day after date 0f deposit for mailing this affidavit. (Cal Code Civ. Proc. § 1013(a); Fed. R. Civ. Proc. 5(a); Fed. R. Civ. Proc. 5(c).) D (BY OVERNIGHT MAIL) I am personally and readily familiar with the business practice of Aegis Law Firm PC for collaction and processing correspondence for overnight delivery, and I caused such document(s) described herein t0 be deposited for delivery t0 a facility regularly maintained Federal Express for overnight delivery. (Cal Code Civ. Proc. § 1013(0); Fed. R. Civ. Proc. 5(c).) g (BY ELECTRONIC TRANSMISSION) I caused said document(s) to be served Via electronic transmission Via the above listed email addresses 0n the date below. (Cal. Code Civ. Proc. § 1010.6(6); Fed. R. Civ. Proc. 5(b)(2)(E); Fed. R. Civ. Proc. 5(b)(3).) D (BY PERSONAL SERVICE) I delivered the foregoing document by hand delivery to the addressed named above. (Cal Code Civ. Proc. § 1011; Fed. R. Civ. Proc. 5(b)(2)(A)-) /// /// /// /// CERTIFICATE 0F SERVICE \OOOQONUI-PUJNH NNNNNNNNNt-I-Ht-I-Ht-I-Ht- OONQM$UJNHOKOOOQONMJ>WNHO I declare under penalty of peljury under the laws 0f the State of California that the foregoing is true and correct. Executed on July 13, 2020, at Irvine, California. Andrea Drocco -2- CERTIFICATE OF SERVICE