Marcia Marsh vs. Vacasa LLC

Opposition

Cal. Super. - 4th Dist.May 9, 2017

Oo X N n R W N N O N N O N N O N O N N N = e m e m e m p m e e e e E e 0 0 ~ 1 O&O Wn BA WwW N = Oo O e N S N Wn Rs W N = O AEGIS LAW FIRM, PC KASHIF HAQUE, State Bar No. 218672 SAMUEL A. WONG, State Bar No. 217104 JESSICA L. CAMPBELL, State Bar No. 280626 ALI S. CARLSEN, State Bar No. 289964 9811 Irvine Center Drive, Suite 100 Irvine, California 92618 Telephone: (949) 379-6250 Facsimile: (949) 379-6251 Attorneys for Plaintiff MARCIA MARSH ELECTRONICALLY FILED Superior Court of California, County of Orange 09/01/2017 at 01:24:00 Pi Clerk of the Superior Court By & Clerk, Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE MARCIA MARSH, individually and on behalf of all others similarly situated Plaintiffs, VS. VACASA LLC, an Oregon limited liability company; and DOES 1 through 20, inclusive, Defendants. Case No. 30-2017-00919110-CU-OE-CXC Assigned for all purposes to Hon. Glenda Sanders, Dept. CX101 PLAINTIFF’S STATEMENT OF NON- OPPOSITION TO DEFENDANT’S MOTION TO STRIKE PLAINTIFFS REQUEST FOR A JURY TRIAL | PURSUANT TO THE PAGA Date: September 15, 2017 Time: 1:30 p.m. Dept.: CX101 PLAINTIFF'S STATEMENT OF NON-OPPOSITION wn Rs W N O e 1 DN 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 Plaintiff MARCIA MARSH (“Plaintiff”) respectfully submits this Statement of Non- Opposition to Defendant VACASA LLC’s (“Defendant”) Motion to Strike Plaintiff's Request for a Jury Trial Pursuant to the PAGA (“Motion”). Plaintiff had already agreed to stipulate to not seek a jury trial before Defendant filed its Motion. See Exhibit C to Declaration of Carlos Jimenez In Support of Defendant’s Motion to Strike Plaintiff’s Request for a Jury Trial Pursuant to the PAGA, p. 2. DATED: September 1, 2017 AEGIS LAW FIRM, PC Ali S. Carlsen Attorneys for Plaintiff MARCIA MARSH 1. PLAINTIFF'S STATEMENT OF NON-OPPOSITION N O O0 2 1 O N nn BA W N ) 0 ~~ O N nh Bs WwW ND ee O N D Y n R W ND = O CERTIFICATE OF SERVICE I, the undersigned, am employed in the County of Orange, State of California. I am over the age of 18 and not a party to 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 September 1, 2017, I served the foregoing document entitled: o PLAINTIFF'S STATEMENT OF NON-OPPOSITION TO DEFENDANT'S MOTION TO STRIKE PLAINTIFF'S REQUEST FOR A JURY TRIAL PURSUANT TO THE PAGA on all the appearing and/or interested parties in this action by placing [_} the original [X] a true copy thereof enclosed in sealed envelope(s) addressed as follows: LITTLER MENDELSON, P.C. Carlos Jimenez cajimenez@littler.com Radha D.S. Kulkarni rkulkarni@littler.com Attorneys for Defendant: Vacasa, LLC [1] (BY MAIL) I am readily familiar with the firm’s practice of collection and processing correspondence for matling. 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 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 of deposit for mailing this affidavit. (Cal Code Civ. Proc. § 1013(a); Fed. R. Civ. Proc. 5(a); Fed. R. Civ. Proc. 5(c).) [1] (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 to be deposited for delivery to a facility regularly maintained Federal Express for overnight delivery. (Cal Code Civ. Proc. § 1013(c); Fed. R. Civ. Proc. 5(c).) X (BY ELECTRONIC TRANSMISSION) I caused said document(s) to be served via electronic transmission to the addressee(s) listed above 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).) ] (BY PERSONAL SERVICE) 1 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).) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on September 1, 2017, at Irvine, California. od 7 IN Kathyan Alvarez CERTIFICATE OF SERVICE