Statement Case Management Conference

Cal. Super. - 6th Dist.March 30, 2021

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 21 CV381 526 Santa Clara - Civil Mark A. Ozzello (SBN 1 16595) Mark.Ozzello@capstonelawyers.com Brandon Brouillette (SBN 273 156) Brandon.Brouillette@capstonelawyers.com Joseph Hakakian (SBN 32301 1) J0seph.Hakakian@capstonelawyers.com Capstone Law APC 1875 Century Park East, Suite 1000 Los Angeles, California 90067 Telephone: (3 10) 556-481 1 Facsimile: (3 10) 943-0396 Attorneys for Plaintiff Matilde Joven ROGER M. MASON, ESQ. (107486) KURT E. WESON, ESQ. (121 163) RACHAEL E. BROWN, ESQ. (286634) SWEENEY MASON LLP 983 UniversityA venue, Suite 104C Los Gatos, CA 95032-7637 Telephone: (408) 356-3000 rmason@smwb.com kwilson@smwb.c0m reb@smwb.com Attorneys for Defendant Impec Group, Inc. System Syst Electronically Filed by Superior Court of CA, County of Santa Clara, on 8/13/2021 10:28 AM Reviewed By: System System Case #21 CV381 526 Envelope: 7057353 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA CLARA MATILDE JOVEN, individually, and 0n behalf of other members 0f the general public similarly situated, Plaintiff, VS. IMPEC GROUP, INC., a California corporation; and DOES 1 through 10, inclusive, Defendants. Case N0. 21CV381526 [ASSIGNED FOR ALL PURPOSES TO HON. SUNIL R. KULKARNI-DEPT. 1] JOINT CASE MANAGEMENT STATEMENT Dept: 01 Date: August 15, 2021 Time: 2:30 pm. Complaint Filed: March 30, 2021 JOINT CASE MANAGEMENT STATEMENT 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Following meet and confer efforts, and pursuant to the Court’s directive at the Initial CMC, Plaintiff Matilde Joven (“Plaintiff”) and Defendant Impec Group, Inc. (“Defendant”) (collectively, the “Parties”), by and through their respective counsel of record, submit this Joint Case Management Statement in the above-entitled action for the further Case Management Conference hearing (“CMC”), set for August 19, 2021, at 2:30 pm. in Department 1, Santa Clara Superior Court, 191 N. First Street, San Jose, CA 951 13-1090. 1. EARLY MEDIATION The Parties have agreed t0 proceed to early mediation. The Parties are meeting and conferring regarding mediators and would apprise the Court that most of the more main stream mediators d0 not have availability until early 2022. 2. FORMAL v. INFORMAL DISCOVERY The Parties have agreed t0 proceed with informal discovery. Plaintiff has provided Defendant With a list 0f the information required for early mediation and the Parties are meeting and conferring regarding discovery issues. Regarding the Class/Aggrieved employee contact information, the Parties have agreed t0 enter into a Protective Order t0 be entered by the Court, and then proceed through the Belaire- West notice process, with the Parties equally sharing the cost 0f the Notice. A Protective Order Will be submitted for the Court’s approval in short order. 2 JOINT CASE MANAGEMENT STATEMENT A QQUI 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: August 12, 2021 Dated: August 12, 2021 3 CAPSTONE LAW APC By: l i Mar t A. Ozzello Brandon Brouillette Joseph Hakakian Attorneys for Plaintiff Matilde Joven SWEENEYMASON LLP By: ROGER M. MASON KURT E. WILSON RACHAEL E. BROWN Attorneys for Defendant Impec Group, Inc. JOINT CASE MANAGEMENT STATEMENT 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the State of California, County ofLos Angeles. I am over the age of 18 and not a party t0 the Within suit; my business address is 1875 Century Park East, Suite 1000, Los Angeles, California 90067. My electronic address is matthew.krout@capstonelawyers.com. On August 13, 2021, I served the documents described as: JOINT INITIAL CASE MANAGEMENT STATEMENT 0n the interested parties in this action by sending [ ] the original [0r] [V] a true copy thereof [V] to interested parties as follows [0r] [ ] as stated on the attached service list: ROGER M. MASON, ESQ. (1 07486) KURT E. WILSON, ESQ. (121 163) RACHAEL E. BROWN, ESQ. (286634) SWEENEY MASON LLP 983 University Avenue, Suite 104C Los Gatos, CA 95032-7637 Telephone: (408) 356-3000 rmason@smwb.com kwilson@smwb.com reb@smwb.com Attorneys for Defendant Impec Group, Inc. [ ] BY MAIL (ENCLOSED IN A SEALED ENVELOPE): Ideposited the envelope(s) for mailing in the ordinary course ofbusiness at Los Angeles, California. I am “readily familiar” with this film’s practice ofcollection and processing correspondence for mailing. Under that practice, sealed envelopes are deposited with the U.S. Postal Service that same day in the ordinary course ofbusiness with postage thereon fillly prepaid at Los Angeles, California. [J] BY ELECTRONIC FILE & SERVE: A true and correct copy ofthe above-referenced document(s) was electronically served on counsel 0frecord by means ofuploading the document t0 One Legal Court Filing website portal in accordance With the Court’s Order. [ ] BY PERSONAL SERVICE: Icaused DDS Legal t0 deliver the document, enclosed in a sealed envelope, by hand to the offices ofthe addressee(s) named herein. [ ] BY OVERNIGHT DELIVERY: I am “readily familiar” With this film’s practice 0f collection and processing correspondence for overnight delivery. Under that practice, overnight packages are enclosed in a sealed envelope with a packing slip attached thereto fully prepaid. The packages are picked up by the carrier at our offices 0r delivered by our office t0 a designated collection site. I declare under penalty ofpeljury under the laws ofthe State ofCalifornia that the foregoing is true and correct. Executed this 13th Day ofAugust, 2021 at Los Angeles, California. Matthew Krout m .734% Name Signa’t‘ure V v f PROOF OF SERVICE