DeclarationCal. Super. - 6th Dist.April 2, 202110 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 21 CV379043 Santa Clara - Civil AEGIS LAW FIRM, PC KASHIF HAQUE, State Bar No. 218672 SAMUEL A. WONG, State Bar No. 217 1 04 JESSICA L. CAMPBELL, State Bar No. 280626 KRISTY R. CONNOLLY, State Bar 328477 9811 Irvine Center Drive, Suite 100 Irvine, California 92618 Telephone: (949) 379-6250 Facsimile: (949) 379-6251 Email: kconnolly@aegislawfirm.com Attorneys for Plaintiff Jason AmyX, individually, and on behalf of all others similarly situated. Electronically Filed by Superior Court of CA, County of Santa Clara, on 2/1 6/2022 12:34 PM Reviewed By: R. Walker Case #21 CV379043 Envelope: 8304830 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA CLARA JASON AMYX, individually and 0n behalf Case N0. 21CV379043 of all others similarly situated, Assigned For All Purposes T0: Plaintiff, Hon. Sunil R. Kulkarni V. Department I DECLARATION OF KRISTY R. BOARDWALK AUTO CENTER, INc_; CONNOLLY IN SUPPORT OF PLAINTIFF’S and DOES 1 through 20, inclusive, REQUEST FOR DISMISSAL OF ENTIRE Defendants. ACTION WITHOUT PREJUDICE Complaint Filed: April 2, 2021 Trial Date: None DECLARATION OF KRISTY R. CONNOLLY 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, Kristy R. Connolly, declare that: 1. I am an attorney at law, duly licensed and entitled to practice in the State of California. I am an associate at Aegis Law Firm, PC, attorney of record for Plaintiff Jason Amyx (“Plaintiff”). As such, I have personal knowledge 0f the matters set forth herein and, if called as a witness, could and would competently testify thereto under oath. 2. This action was filed on April 2, 2021, as a proposed class action against defendant Boardwalk Auto Center, Inc (“Defendant”). Plaintiff then requested t0 dismiss his individual and class action claims Without prejudice, Which the Court granted on July 23, 2021. 3. Plaintiff filed his First Amended Complaint 0n July 26, 2021 Which alleges a single cause 0f action for Violation 0f the California Labor Code Private Attorneys General Act (“PAGA”). 4. Unfortunately, Plaintiff has passed away and can n0 longer pursue the PAGA action. 5. N0 consideration is being provided in exchange for the dismissal 0f this action without prejudice. 6. Pursuant to California Rule of Court 3.770(0), notice of the dismissal need not be provided t0 the potentially aggrieved employees because n0 notice of pendency of this action has been provided t0 the potentially aggrieved employees. I am not aware of any aggrieved employees Who are foregoing filing their own claims in reliance 0n this case. Therefore, I believe the PAGA claim may be dismissed Without notice to potentially aggrieved employees. I declare under penalty of perjury of the laws of the State of California, that the foregoing is true and correct. Executed 0n February 16, 2022, at Irvine, California. _44@% Kristy R. Connolly -2- DECLARATION OF KRISTY R. CONNOLLY