Statement Case Management Conference

Cal. Super. - 6th Dist.June 23, 2021

flO‘xUI-RUJN 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 21 CV383516 Santa Clara - Civil AEGIS LAW FIRM, PC SAMUEL A. WONG, State Bar N0. 217 1 04 KASHIF HAQUE, State Bar N0. 218672 JESSICA L. CAMPBELL, State Bar No. 280626 9811 Irvine Center Drive, Suite 100 Irvine, California 92618 Telephone: (949) 379-6250 Facsimile: (949) 379-6251 Email: icampbell@aegislawfirm.com R. Fler Electronically Filed by Superior Court of CA, County of Santa Clara, on 10/14/2021 12:13 PM Reviewed By: R. Fleming Case #21 CV38351 6 Envelope: 7464754 Attorneys for Plaintiff Anthony Sanchez, individually, and on behalf of all others similarly situated. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA CLARA ANTHONY SANCHEZ, individually and on behalf 0f all others similarly situated, Plaintiffs, V. JSR MICRO, INC.; JSR NORTH AMERICA HOLDINGS, INC.; JSR LIFE SCIENCES, LLC; and DOES 1 through 20, inclusive, Defendants. Case No. 21CV383516 AssignedforAll Purposes t0: Hon. Sunil R. Kulkarni Dept. I JOINT INITIAL STATUS CONFERENCE STATEMENT Date: October 21, 2021 Time: 2:30 pm. Dept; 1 Complaint Filed: June 23, 2021 ning THE PARTIES’ JOINT INITIAL STATUS CONFERENCE STATEMENT C:\Users\mkelly\Documents\Sanchez - JSR - Inital JCMCS - 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff Anthony Sanchez (“Plaintiff”) and Defendants JSR Micro, Inc., JSR North America Holdings, Inc., and JSR Life Sciences, LLC (Collectively, “Defendants”) by and through their counsel 0f record, submit the following Joint Case Management Conference Statement in advance of the Initial Case Management Conference scheduled for October 21, 2021, at 2:30 pm. in Department 1. 1. A BRIEF OBJECTIVE SUMMARY OF THE CASE: This case is a class action involving claims for failure t0 pay minimum and overtime wages, failure t0 provide meal and rest breaks, failure to reimburse necessary business expenses, failure to provide accurate itemized wage statements, failure t0 pay all wages due upon separation 0f employment, and unfair business practices. 2. A SUMMARY OF ANY ORDERS FROM PRIOR CASE MANAGEMENT CONFERENCES AND THE PROGRESS OF THE PARTIES’ COMPLIANCE WITH SAID ORDERS: There have been n0 prior case management conferences in this matter. 3. SIGNIFICANT PROCEDURAL AND PRACTICAL PROBLEMS THAT MAY LIKELY BE ENCOUNTERED: None. 4. SUGGESTIONS FOR EFFICIENT MANAGEMENT, INCLUDING A PROPOSED TIMELINE OF KEY EVENTS: The parties are discussing private mediation. Plaintiff requests that the Court lift the stay on discovery. The parties suggest a further status conference in 90 days. After mediation, Plaintiff will be prepared t0 propose a deadline for filing a motion for class certification. 5. OTHER SPECIAL CONSIDERATION TO ASSIST THE COURT IN DETERMINING AN EFFECTIVE CASE MANAGEMENT PLAN: Plaintiff filed a separate PAGA case arising from the same Violations. The PAGA case is also pending in Santa Clara, with Case No. 21CV386334, in Department 3. The parties believe both cases should follow the same case management schedule in Department 1. Plaintiff does not believe consolidation is appropriate given the risk that the class action case Will be removed t0 2 THE PARTIES’ JOINT INITIAL STATUS CONFERENCE STATEMENT C:\Users\mkelly\Documents\Sanchez - JSR - Inital JCMCS - 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 federal court at some point in the future. Plaintiff is Willing to make the litigation of the two cases as efficient as possible, such as by serving discovery in only one case that can be used in both cases. Defendant agrees the cases should be managed in the same department and that discovery should be coordinated to avoid redundancy and inefficiency. Dated: October 14, 2021 AEGIS LAW FIRM, PC By: ,g’z‘M Jesfica L. Campbell Attorneys for Plaintiff Dated: October 14, 2021 SQUIRE PATTON BOGGS (US) LLPwaé% Michael W. Kelly Lilah J. Sutphen Attorneys for Defendants 3 THE PARTIES’ JOINT INITIAL STATUS CONFERENCE STATEMENT C:\Users\mkelly\Documents\Sanchez- JSR- InitaIJCMCS- \OOOQONUI-bUJNr-t NNNNNNNNNr-tv-lr-tr-tv-tr-tr-Av-np-tr-A OOQONUI-bUJNv-‘OKOOOQQUI-PWNHO CERTIFICATE OF SERVICE I, the undersigned, am employed in the County 0f Orange, State 0f California. I am over the age 0f 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 October 14, 2021, I served the foregoing document entitled: 0 JOINT INITIAL STATUS CONFERENCE STATEMENT 0n all the appearing and/or interested parties in this action by delivering D the originalg a true copy thereof on the party(ies) addressed below as follows: Michael W. Kelly Lilah J. Sutphen SQUIRE PATTON BOGGS (US) LLP 275 Battery Street, Suite 2600 San Francisco, California 941 11 Telephone: 415 954 0200 Facsimile: 415 393 9887 michael.kelly@squirepb.com lilah.sutphen@squirepb.com Attorneysfor Defendant: JSR MICRO, INC; JSR NORTH AMERICA HOLDINGS, INC.; JSR LIFE SCIENCES, LLC D (BY MAIL) I am readily familiar with the firm’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day With postage thereon fully prepaid at Irvine, California in the ordinary course 0f business. I am aware that 0n motion 0f 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(0).) D (BY OVERNIGHT MAIL) I am personally and readily familiar With the business practice of Aegis Law Firm PC for collection and processing correspondence for overnight delivery, and I caused such document(s) described herein t0 be deposited for delivery to a facility regularly maintained Federal Express for overnight delivery. (Cal Code Civ. Proc. § 1013(0); Fed. R. Civ. Proc. 5(0).) E (BY ELECTRONIC TRANSMISSION) I caused said document(s) t0 be served Via electronic transmission Via the above listed email addresses on 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. § 101 1; Fed. R. Civ. Proc. S(b)(2)(A).) /// /// /// /// CERTIFICATE OF SERVICE \OOOQONUI-bUJNr-t NNNNNNNNNr-tv-lr-tr-tv-tr-tr-Av-np-tr-A OOQONUI-bUJNv-‘OKOOOQQUI-PWNHO I declare under penalty 0f perjury under the laws 0f the State of California that the foregoing is true and correct. Executed 0n October 14, 2021, at Irvine, California. Delaney Graves -2- CERTIFICATE OF SERVICE