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 172 |
Filed: 9/22/2020, Entered: 9/22/2020 |
Request For Dismissal |
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With Prejudice AS TO COMPLAINT ONLY AS TO DEFENDANT JONATHAN TEO AND EXCLUDING ALL PAGA CLAIMS
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 Request |
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| 171 |
Filed: 9/21/2020, Entered: 9/21/2020 |
Proof of Service - ELECTRONIC of |
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REQUEST FOR DISMISSAL WITH PREJUDICE BY PLAINTIFF; ETC served on SEE SERVICE LIST
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Request |
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| 170 |
Filed: 9/21/2020, Entered: 9/21/2020 |
Request For Dismissal |
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With Prejudice COMPLAINT AGAINST ALL DEFENDANTS EXCEPT TEO AND EXCLUDING ALL PAGA CLAIMS
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Request |
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| 169 |
Filed: 9/21/2020, Entered: 9/21/2020 |
Request For Dismissal |
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With Prejudice CROSS COMPLAINT BINARY CAPITAL MANAGEMENT, LLC
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Request |
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| 168 |
Filed: 9/1/2020, Entered: 9/1/2020 |
Proof Of Service By Mail |
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NOTICE OF ENTRY OF ORDER APPROVING PAGA SETTLEMENT AGREEMENT AND AWARD OF FEES AND COSTS
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Request |
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| 167 |
Filed: 9/1/2020, Entered: 9/1/2020 |
Notice of Entry of Order |
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APPROVING PAGA SETTLEMENT AGREEMENT AND AWARD OF FEES AND COSTS
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Request |
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| 166 |
Filed: 8/31/2020, Entered: 8/31/2020 |
Order |
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Type: APPROVING PAGA SETTLMENT AGREEMENT AND AWRD OF FEES AND COSTS Signed by: JUDGE FINEMAN Date Signed: 08/31/20.
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Request |
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| 165 |
Filed: 8/28/2020, Entered: 8/28/2020 |
Tentative ruling adopted and becomes order: |
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PLAINTIFF ANN LAI'S AND DEFENDANT(S) BINARY CAPITAL'S MOTION FOR APPROVAL OF PAGA SETTLEMENT, AND (2) PLAINTIFF ANN LAI'S MOTION FOR FEES AND COSTS FROM THE COMMON FUND PAGA SETTLEMENT Plaintiff's Unopposed Motion for Approval of PAGA settlement and for fees and costs is GRANTED. Pursuant to Labor Code 2699(l), the Court has reviewed the moving and supplemental briefs, which supplemental brief responded to the Court's questions about certain aspects of the settlement, and all supporting documentation before granting the motion. Settlement Approval Standards: For class action settlements, there is an established body of law setting forth the standards for approval. For PAGA claims, there is less guidance. The Legislature's express command that PAGA settlements be approved by the court necessarily implies that there is some substantive dimension to the review. (Labor Code 2699(l).) There appears to be no California precedent to guide trial court judges. Federal precedent is helpful. In O'Connor v. Uber Techs, Inc. (N.D. Cal. 2016) 201 F.Supp.3d 1110, 1133, for example, the court denied approval of class action settlements that included PAGA claims in part because the plaintiffs' claims added up to as much as $1 billion in PAGA penalties but parties settled those claims for $1 million, or 0.1% of their alleged maximum value. As Judge Edward Chen stated, "where plaintiffs bring a PAGA representative claim, they take on a special responsibility to their fellow aggrieved workers who are effectively bound by any judgment. [citation omitted] Such a plaintiff also owes responsibility to the public at large; they act, as the statute's name suggests, as a private attorney general, and 75% of the penalties go to the LWDA 'for enforcement of labor laws . . . and for education of employers and employees about their rights and responsibilities under this code.'" (Id., at 1134.) In that case, the Labor Workforce and Development Agency ("LWDA") itself filed a brief stating that "[i]t is thus important that when a PAGA claim is settled, the relief provided for under the PAGA be genuine and meaningful, consistent with the underlying purpose of the statute to benefit the pubic and, in the context of a class action, the court evaluate whether the settlement meets the standards of being 'fundamentally fair, reasonable, and adequate' with reference to the public policies underlying the PAGA." (Id., at 1133.) Judge Chen noted that "a court may reduce the penalty when 'to do otherwise would result in an award that is unjust, arbitrary and oppressive, or confiscatory.'" (Id., at 1134, citing Labor Code 2699(e)(2).) California law provides some general guidance concerning judicial approval of any settlement. First, public policy generally favors settlement. (Neary v. Regents of University of California (1992) 3 Cal.4th 273.) Nonetheless, the court should not approve an agreement contrary to law or public policy. (Bechtel Corp. v. Superior Court (1973) 33 Cal.App.3d 405, 412; Timney v. Lin (2003) 106 Cal.App.4th 1121, 1127.) Moreover, "[t]he court cannot surrender its duty to see that the judgment to be entered is a just one, nor is the court to act as a mere puppet in the matter." (California State Auto. Assn. Inter-Ins. Bureau v. Superior Court (1990) 50 Cal.3d 658, 664.) As a result, courts have specifically noted that Neary does not always apply, because "[w]here the rights of the public are implicated, the additional safeguard of judicial review, though more cumbersome to the settlement process, serves a salutatory purpose." (Consumer Advocacy Group, Inc. v. Kintetsu Enterprises of America (2006) 141 Cal.App.4th 48, 63.) Other statutory schemes also provide some guidance. In California False Claims Act (CFCA), the court may consider "the best interests of the parties involved and the public purposes behind the act" (Govt. Code 12652(c)(1), as well as whether the settlement is "fair, adequate, and reasonable under all the circumstances." (Govt. Code 12652(e)(2)(B).) Similarly, under Prop 65, a court may consider whether a settlement is just and serves the public interest. (Consumer Advocacy, 6 Cal.App.4th at 61-62.) The primary purpose of PAGA is "to achieve maximum compliance with state labor laws" and "to ensure an effective disincentive for employers to engage in unlawful and anticompetitive business practices." (2003 Cal. Legis. Serv. Ch. 906 1(a).) The Legislature further found that, while self-policing efforts have had some success, "in other cases the only meaningful deterrent to unlawful conduct is the vigorous assessment and collection of civil penalties as provided in the Labor Code." (Id., at 1(b).) Terms and Background of the Settlement: The gravamen of the complaint is that Defendants, contrary to California law, impermissibly imposed non-disclosure ("NDA"), non-disparagement and confidentiality provisions in agreements with its employees. According to Plaintiff, after she left her employment, Binary Capital improperly warned Plaintiff about violating these provisions. On June 28, 2017, Plaintiff filed her initial complaint and the parties have engaged in motion practice and discovery. The parties were unsuccessful in settlement discussions in 2017, but were able to resolve the action in 2019. Plaintiff has also settled her individual claims with an individual defendant, Jonathan Teo and a Binary entity and shared the individual settlements with the LWDA PAGA unit. She receives monetary amounts and an indirect equity interest in a Binary entity in her individual settlement. The terms of this settlement are that the Binary Capital Entity Defendants have agreed to pay $60,800 to resolve the PAGA claims arising from its mandatory non-disclosure/non-disparagement agreements. According to Plaintiff, Binary Capital had nine employees and there are 125 pay periods at issue. Plaintiff calculates that Binary Capital is paying close to $500 per pay period or more than $6,750 per employee. Specifically, the common fund settlement will be distributed as follows: (1) Plaintiff's counsel will be entitled to an award of fees and costs from the common fund, to be determined by the Court (Settlement III.E); (2) $18,000 of the remaining amount will be allocated to the Labor Code 1102.5 PAGA claim, with each employee receiving 25% of a $2000 per-employee penalty amount (or $500 per employee), and the State receiving 75% (or $1500 per employee) (See Settlement III.F-G); and (3) the remainder of the common fund will be distributed as follows: 23 75% of the remainder to the State, and 25% of the remainder to the employees on a pro-rated per-24 pay-period basis. (Id.) In addition, a settlement term is that Binary Capital and its principles (Justin Caldbeck and Teo) will be prohibited by Court order from taking any steps to enforce the NDA provisions against the PAGA Group members, who will receive notice of this injunctive relief and other terms of the settlement. The settlement is not with defendants Teo or Caldbeck, who were sued under an alter ego theory because Plaintiff determined their signature was not necessary to obtain penalties and injunctive relief. Plaintiff represents that she will pursue the individual defendants under an alter ego theory if the Binary Capital Entity Defendants do not pay the settlement amounts. There is no general release. The settlement agreement provides that the State and Plaintiff will enter into the following release: "All claims asserted in the Action under PAGA, based upon the factual allegations set forth in the Second Amended Complaint, including but not limited to all PAGA claims arising from any non-disclosure or non-disparagement provisions in any agreement signed by any Binary Capital employee (Excluding Jonathan Teo and Justin Caldbeck) at issue in the Complaint during the 'Covered Period.'" The Binary Capital Defendants deny all liability. They have joined in this motion for approval of settlement. Analysis of the Settlement: The Court finds that there has been proper notice given of the settlement and this hearing, including to the LAWDA. Plaintiff calculates that the maximum exposure in this case is $234,000 based upon (1) liability; (2) "stacking" of penalties; (3) a $10,000 per-employee penalty for the Labor Code 1102.5 violations; (4) a $200 per-pay-period/per-employee penalty for all violations but the "initial" violation; (5) a per-pay-period (as opposed to per-signature) penalty for the Labor Code 432.5 violations; and (6) no discretionary reduction in penalties under Labor Code 2699(e)(1). The Binary Capital Defendants dispute liability and can be expected to fully litigate the issues. There are issues regarding liability since NDAs can be appropriate. Additionally, there are issues of whether a court will award the maximum penalties and whether Defendants can be liable based upon a "subsequent violation" defense. Even if liability is established at a trial, Plaintiff might only receive 20% of the maximum exposure. Taking into account the time and expense of litigation, the uncertainty of litigation, the policy favoring settlement, the Court, in exercising its discretion after review of the pleadings and evidence, finds that the settlement amount is fair and reasonable. The Court finds as additional support for this conclusion because the settlement has the additional benefit of the injunction. The value of an injunction cannot be monetized, but provides significant benefits for the employees. Based upon all of the circumstances and in exercising its discretion, the Court concludes that the settlement is genuine and meaningful, and consistent with the underlying purpose of the statute to benefit the pubic. There is no request for any incentive payments for the Plaintiff and no evidence of fraud or collusion in the settlement negotiations. The Court finds the Release narrowly tailored to the claims in the case and reasonable, and that the notice to the employees fairly apprises them of the settlement. Plaintiff's counsel is to provide mail notice to the employees. Attorney fees: Plaintiff seeks attorneys' fees in the amount of $20,064 (33% of the common fund) and costs in the amount of $4,345.38 to be paid out of the settlement amount as fees, relying on the "common fund" theory. While a common fund fee is appropriate here, even a proper common fund-based fee award should be reviewed through a lodestar cross-check. In Lafitte v. Robert Half International (2016) 1 Cal.5th 480, 503, the Supreme Court endorsed the use of a lodestar cross-check as a way to determine whether the percentage allocated is reasonable. The Supreme Court stated: "If the multiplier calculated by means of a lodestar cross-check is extraordinarily high or low, the trial court should consider whether the percentage used should be adjusted so as to bring the imputed multiplier within a justifiable range, but the court is not necessarily required to make such an adjustment." (Id., at 505.) Plaintiff's counsel, Chris Baker, submits a declaration setting forth his experience and that of the other attorneys who worked on the case. The hourly rates they charge their hourly paying clients range from $640-$875 per hour. He represents that the amount requested far exceeds the lodestar amount, but does not provide that figure or any billing statements. The declaration does detail the work on the case including preparing the complaint and subsequent complaint, demurrers, discovery, arbitration motions, and the settlement negotiations. He provides other examples where state court judges have awarded his firm or other firms in PAGA cases a 33% award. The Court finds the amount of attorneys' fees and costs fair and reasonable and grants the request. Even though Plaintiff's counsel does not provide billing statements, the work performed clearly exceeded the amount of fees requested even if the Court were to calculate fees at $500 per hour. Since the case was taken on a contingency, Plaintiff could have requested a multiplier. (Ketchum v. Moses (2001) 24 Cal.4th 1122, 1132.) Plaintiff could have also requested fees based upon the value of the injunction, but did not. This Court may use its own experience to determine the value of attorneys' fees. (Spencer v. Collins (1909) 156 Cal. 298, 306 ("The value of attorney's services is a matter with which a judge must necessarily be familiar. When the court is informed of the extent and nature of such services, its own experience furnishes it with every element necessary to fix their value.") ."); Reynolds v. Ford Motor Company (2020) 47 Cal.App.5th 1105, 1113-14 ("The trial court acted well within its discretion in using 'the prevailing market value in the community for similar legal services' relying on its personal knowledge and familiarity with the area legal services, as the 'touchstone' for determination" of the reasonable hourly rates.'" (citations omitted).) This Court had extensive experience in class action and other common fund cases while an attorney and has made decisions about attorneys' fees and costs frequently during her time as a judicial officer. Given that this is a "common fund" fee, and the lodestar analysis is only for purposes of the "cross check" required by Lafitte, the Court finds that no adjustment is necessary, and the requested fee is approved. The costs are also reasonable and compensable. If the tentative ruling is uncontested, it shall become the order of the Court. Thereafter, counsel for Plaintiff shall prepare a written order consistent with the Court's ruling and including the relevant information included in her May 27, 2020 proposed order for the Court's signature, pursuant to California Rules of Court, Rule 3.1312, and provide written notice of the ruling to all parties who have appeared in the action, as required by law and the California Rules of Court.
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Request |
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| 164 |
Filed: 8/28/2020, Entered: 8/28/2020 |
Motion for Approval |
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JOINT MOTION FOR APPROVAL OF PAGA SETTLEMENT AND PLAINTIFF'S MOTION FOR FEES AND COSTS
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Request |
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| 163 |
Filed: 8/10/2020, Entered: 8/10/2020 |
Jury Trial |
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JURY TRIAL TIME ESTIMATE 7 DAYS
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Request |
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| 162 |
Filed: 8/7/2020, Entered: 8/7/2020 |
Notice |
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OF NEW HEARING DATE AND TIME FOR JOINT MOTION FOR APPROVAL OF PAGA SETTLEMENT AND PLAINTIFF'S MOTION FOR FEES AND COSTS
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Request |
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| 161 |
Filed: 7/28/2020, Entered: 7/28/2020 |
Motion for order |
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FOR FEES AND COSTS
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Request |
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| 160 |
Filed: 7/28/2020, Entered: 7/28/2020 |
Motion for Approval |
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OF PAGA SETTLEMENT
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Request |
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| 159 |
Filed: 7/27/2020, Entered: 7/27/2020 |
Mandatory Settlement Conference |
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Hearing Time: 1:30 PM
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Request |
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| 158 |
Filed: 7/22/2020, Entered: 7/22/2020 |
Supplemental |
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PLAINTIFF ANN LAI'S SUPPLEMENTAL BRIEF IN SUPPORT OF MOTION FOR SETTLEMENT APPROVAL
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Request |
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| 157 |
Filed: 7/13/2020, Entered: 7/13/2020 |
Proof Of Service By Mail |
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PAGA SETTLEMENT AGREEMENT; ETC
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Request |
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| 156 |
Filed: 7/10/2020, Entered: 7/10/2020 |
Proof Of Service By Mail |
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CASE MANAGEMENT ORDER NO.1 BY JUDGE FINEMAN
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Request |
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| 155 |
Filed: 7/10/2020, Entered: 7/10/2020 |
Affidavit of Mailing |
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CASE MANAGEMENT ORDER NO. 1 BY JUDGE FINEMAN
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Request |
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| 154 |
Filed: 7/10/2020, Entered: 7/10/2020 |
Order |
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CASE MANAGEMENT ORDER NO. 1 BY JUDGE FINEMAN
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Request |
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| 153 |
Filed: 7/8/2020, Entered: 7/8/2020 |
Order Granting Challenge Request against Judicial Officer |
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Pursuant to CCP Section 170.6
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Request |
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| 152 |
Filed: 7/6/2020, Entered: 7/6/2020 |
Peremptory Challenge Pursuant to CCP 170.6 Against |
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Judicial Officer; SENT TO DEPT. 20, COPY TO DEPT 2
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Request |
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| 151 |
Filed: 6/30/2020, Entered: 6/30/2020 |
Affidavit of Mailing |
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Order Designating As Complex Case and Assigning Judge For All Purposes
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Request |
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| 150 |
Filed: 6/30/2020, Entered: 6/30/2020 |
Affidavit of Mailing |
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CMO #1
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Request |
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| 149 |
Filed: 6/30/2020, Entered: 6/30/2020 |
Case Management Order |
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CMO #1
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Request |
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| 148 |
Filed: 6/29/2020, Entered: 6/29/2020 |
Order |
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Designating As Complex Case and Assigning Judge For All Purposes
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Request |
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| 147 |
Filed: 6/9/2020, Entered: 6/9/2020 |
Proof Of Service By Mail |
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Notice of New Hearing Date, Time and Department for Joint Motion for Approval of PAGA Settlement and Plaintiff???s Motion for Fees and Costs;ETC served on SEE SERVICE LIST
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Request |
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| 146 |
Filed: 6/9/2020, Entered: 6/9/2020 |
Notice |
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Notice of New Hearing Date, Time and Department for Joint Motion for Approval of PAGA Settlement and Plaintiff's Motion for Fees and Costs
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Request |
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| 145 |
Filed: 5/27/2020, Entered: 5/27/2020 |
Proof Of Service By Mail |
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PLAINTIFF'S NOTICE OF MOTION AND MOTION FOR APPROVAL OF PAGA SETTLEMENT; ETC...
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Request |
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| 144 |
Filed: 5/27/2020, Entered: 5/27/2020 |
Motion |
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FOR FEES AND COSTS
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Request |
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| 143 |
Filed: 5/27/2020, Entered: 5/27/2020 |
Proposed Order Received |
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APPROVING PAGA SETTLEMENT
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Request |
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| 142 |
Filed: 5/27/2020, Entered: 5/27/2020 |
Declaration in Support |
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OF MOTION FOR APPROVAL OF PAGA SETTLEMENT
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Request |
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| 141 |
Filed: 5/27/2020, Entered: 5/27/2020 |
Memorandum of Points and Authorities in Support |
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OF JOINT NOTICE FOR MOTION FOR APPROVAL OF PAGA SETTLEMENT
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Request |
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| 140 |
Filed: 5/27/2020, Entered: 5/27/2020 |
Motion |
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FOR APPROVAL OF PAGA SETTLEMENT
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Request |
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| 139 |
Filed: 9/16/2019, Entered: 9/16/2019 |
Stipulation and Proposed Order received & forwarded to Dept |
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25, STIPULATION & ORDER TO ADR
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Request |
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| 138 |
Filed: 8/28/2019, Entered: 8/28/2019 |
ADR Referral |
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Order to ADR within 21 days
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Request |
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| 137 |
Filed: 8/13/2019, Entered: 8/13/2019 |
Case Management Statement |
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CMC 8/28/19
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Request |
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| 136 |
Filed: 7/17/2019, Entered: 7/17/2019 |
Answer |
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to DEFENDANT BINARY CAPITAL MTGP I, L.P.'S CROSS-COMPLAINT
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Request |
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| 135 |
Filed: 6/19/2019, Entered: 6/19/2019 |
Answer |
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Answer to Plaintiff's Second Amended Complaint by Defendants Binary Capital, a General Partnership, Binary Capital Management, LLC, Binary Capital MTGP I, LP, Binary Capital TTGP, Ltd., and Binary Capital MTGP II, LP
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Request |
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| 134 |
Filed: 6/10/2019, Entered: 6/10/2019 |
Case Management Statement |
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CMC 6/26
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Request |
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| 133 |
Filed: 5/23/2019, Entered: 5/23/2019 |
Notice of Entry of Order |
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OVERRULING BINARY DEFENDANTS' DEMURRER TO PLAINTIFF'S 15TH CAUSE OF ACTION.
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Request |
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| 132 |
Filed: 5/14/2019, Entered: 5/14/2019 |
Order |
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Type: OVERRULING BINARY DEFENDANTS' DEMURRER TO PLAINTIFF'S 15TH CAUSE OF ACTION Signed by: JUDGE FINEMAN Date Signed: 5-13-19
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Request |
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| 131 |
Filed: 5/2/2019, Entered: 5/2/2019 |
Order sent for signature to Judicial Officer |
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#3 OVERRULING BINARY DEFENDANTS DEMURRER TO PLAINTIFF'S 15TH CAUSE OF ACTION
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Request |
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| 130 |
Filed: 4/24/2019, Entered: 4/24/2019 |
Hearing on Demurrer |
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TO PLAINTIFF'S FIFTEENTH CAUSE OF ACTION
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Request |
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| 129 |
Filed: 4/18/2019, Entered: 4/18/2019 |
Proof of Service by OVERNIGHT DELIVERY of |
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REPLY BRIEF IN SUPPORT OF DEMURRER TO PLAINTIFF'S FIFTEENTH CAUSE OF ACTION FOR FAILURE TO PAY WAGES DUE UPON SEPARATION BY BINARY CAPITAL DEFENDANTS; ETC... served on SEE SERVICE LIST
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Request |
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| 128 |
Filed: 4/17/2019, Entered: 4/17/2019 |
Memorandum of Points and Authorities in Reply |
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BRIEF IN SUPPORT OF DEMURRER TO PLAINTIFF'S FIFTEENTH CAUSE OF ACTION FOR FAILURE TO PAY WAGES DUE UPON SEPARATION BY BINARY CAPITAL DEFENDANTS
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Request |
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| 127 |
Filed: 4/17/2019, Entered: 4/17/2019 |
Memorandum of Points and Authorities in Opposition |
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TO PLAINTIFF ANN LAI'S REQUEST FOR JUDICIAL NOTICE
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Request |
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| 126 |
Filed: 4/16/2019, Entered: 4/16/2019 |
Proof of Service by PERSONAL SERVICE of |
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PLAINTIFF ANN LAI'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO DEMURRER TO THE FIFTEENTH CAUSE OF ACTION; ETC... served on SEE SERVICE LIST
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Request |
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| 125 |
Filed: 4/15/2019, Entered: 4/15/2019 |
Notice of Case Management Conference |
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CMC 6/26/19
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Request |
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| 124 |
Filed: 4/11/2019, Entered: 4/11/2019 |
Memorandum of Points and Authorities in Opposition |
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PLAINTIFF ANN LAI'S TO DEMURRER TO THE FIFTEENTH CAUSE OF ACTIONS
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Request |
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| 123 |
Filed: 4/11/2019, Entered: 4/11/2019 |
Request For Judicial Notice |
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IN SUPPORT OF PLAINTIFF ANN LAI'S OPPOSITION TO DEMURRER TO THE FIFTEENTH CAUSE OF ACTION
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Request |
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| 122 |
Filed: 4/10/2019, Entered: 4/10/2019 |
Motion to Deem Facts as Admitted |
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Hearing Time: 9:00 AM
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Request |
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| 121 |
Filed: 4/9/2019, Entered: 4/9/2019 |
Case Management Statement |
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CMC 4/24
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Request |
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| 120 |
Filed: 4/3/2019, Entered: 4/3/2019 |
Proof of Service by PERSONAL SERVICE of |
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ANN LAI'S REPLY IN SUPPORT OF HER MOTION TO HAVE REQUESTS DEEMED ADMITTED AND TO COMPEL FURTHER DISCOVERY RESPONSES AGAINST BINARY CAPITAL MANAGEMENT LLC AND REQUEST FOR SANCTIONS, ETC served on SEE SERVICE LIST
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Request |
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| 119 |
Filed: 4/3/2019, Entered: 4/3/2019 |
Proposed Order Received |
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GRANTING PLAINTIFF ANN LAI'S MOTION TO HAVE RESPONSES DEEMED ADMITTED, TO COMPEL FURTHER DISCOVERY, AND FOR SANCTIONS
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Request |
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| 118 |
Filed: 4/3/2019, Entered: 4/3/2019 |
Declaration in Reply |
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SCHWARTZ DECLARATION IN SUPPORT OF LAI'S MOTION TO HAVE REQUEST DEEMED ADMITTED AND TO COMPEL FURTHER DISCOVERY RESPONSES AGAINST BINARY CAPITAL MANAGEMENT LLC AND REQUEST FOR SANCTIONS
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Request |
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| 117 |
Filed: 4/3/2019, Entered: 4/3/2019 |
Memorandum of Points and Authorities in Reply |
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IN SUPPORT OF HER MOTION TO HAVE REQUESTS DEEMED ADMITTED AND TO COMPEL FURTHER DISCOVERY RESPONSES AGAINST BINARY CAPITAL MANAGEMENT LLC AND REQUEST FOR SANCTIONS
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Request |
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| 116 |
Filed: 3/27/2019, Entered: 3/27/2019 |
Proof of Service by OVERNIGHT DELIVERY of |
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DEFENDANT BINARY CAPITAL MANAGMENT LLC'S MEMOARNDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO MOTION TO HAVE REQUESTS DEEMED ADMITTED AND TO COMPE FURTHER DISCOVERY RESPONSES, ETC served on SEE SERVICE LIST
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Request |
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| 115 |
Filed: 3/27/2019, Entered: 3/27/2019 |
Declaration in Opposition |
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OF JONATHAN TEO OF DEFENDANT BINARY CAPTIAL MANAGEMENT LLC'S MOTION TO HAVE REQUESTS DEEMED ADMITTED AND TO COMPEL FURTHER DISCOVERY RESPONSES
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Request |
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| 114 |
Filed: 3/27/2019, Entered: 3/27/2019 |
Memorandum of Points and Authorities in Opposition |
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DEFENDANT BINARY CAPITAL MANAGEMENT LLC'S TO MOTION TO HAVE REQUESTS DEEMED ADMITTED ANT TO COMPEL FURTHER DISCOVERY RESPONSES
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Request |
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| 113 |
Filed: 3/27/2019, Entered: 3/27/2019 |
Declaration in Opposition |
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OF MARK R. CONRAD OF DEFENDANT BINARY CAPITAL MANAGEMENT LLC'S TO MOTION TO HAVE REQUESTS DEEMED ADMITTED AND TO COMPEL FURTHER DISCOVERY RESPONSES
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Request |
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| 112 |
Filed: 3/22/2019, Entered: 3/22/2019 |
Proof of Service by PERSONAL SERVICE of |
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NOTICE OF MOTION AND MOTION TO HAVE REQUESTS DEEMED ADMITTED AND TO COMPEL FURTHER DISCOVERY RESPONSES, ETC... served on SEE SERVICE LIST
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Request |
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| 111 |
Filed: 3/22/2019, Entered: 3/22/2019 |
Notice |
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OF APPEARANCE OF JAY RAPAPORT
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Request |
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| 110 |
Filed: 3/18/2019, Entered: 3/18/2019 |
Proof of Service |
|
VIA EMAIL AND US MAIL served on SEE SERVICE LIST with a service date of 03/18/2019
|
|
Request |
|
|
|
| 109 |
Filed: 3/18/2019, Entered: 3/18/2019 |
Notice |
|
OF NEW HEARING DATE FOR DEMURRER TO PLAINTIFF'S FIFTEENTH CAUSE OF ACTION FOR FAILURE TO PAY WAGES DUE UPON SEPARATION BY BINARY CAPITAL DEFENDANTS
|
|
Request |
|
|
|
| 108 |
Filed: 3/15/2019, Entered: 3/15/2019 |
Proof Of Service By Mail |
|
NOTICE OF DEMURRER AND DEMURRER TO PLAINTIFF'S FIFTEENTH CAUSE OF ACTION FOR FAILURE TO PAY WAGES DUE UPON SEPARATION ETC... served on SEE SERVICE LIST
|
|
Request |
|
|
|
| 107 |
Filed: 3/15/2019, Entered: 3/15/2019 |
Proposed Order Received |
|
GRANTING THE DEMURRER TO PLAINTIFF'S FIFTEENTH CAUSE OF ACTION FOR FAILURE TO PAY WAGES DUE UPON SEPARATION
|
|
Request |
|
|
|
| 106 |
Filed: 3/15/2019, Entered: 3/15/2019 |
Declaration in Support |
|
OF DEMURRER TO PLAINTIFF'S FIFTEENTH CAUSE OF ACTION ETC...
|
|
Request |
|
|
|
| 105 |
Filed: 3/15/2019, Entered: 3/15/2019 |
Demurrer to |
|
TO PLAINTIFF'S FIFTEENTH CAUSE OF ACTION FOR FAILURE TO PAY WAGES DUE UPON SEPARATION BY BINARY CAPITAL DEFENDANTS; ETC...
|
|
Request |
|
|
|
| 104 |
Filed: 3/14/2019, Entered: 3/14/2019 |
Notice of Related Case |
|
CGC-19-573412
|
|
Request |
|
|
|
 103 |
Filed: 3/13/2019, Entered: 3/13/2019 |
Declaration in Support |
|
OF PLAINTIFF ANN LAI'S MOTION TO HAVE REQUESTS DEEMED ADMITTED, TO COMPEL FURTHER DISCOVERY RESPONSES AGAINST BINARY CAPITAL MANAGEMENT LLC, AND REQUEST FOR SANCTIONS
|
|
|
|
|
|
| 102 |
Filed: 3/13/2019, Entered: 3/13/2019 |
Notice of Motion and Motion to Deem Matters Admitted |
|
AND TO COMPEL FURTHER DISCOVERY RESPONSES AGAINST BINARY CAPITAL MANAGEMENT LLC; REQUEST FOR SANCTIONS; MEMORANDUM OF POINTS AND AUTHORITIES
|
|
Request |
|
|
|
| 101 |
Filed: 3/6/2019, Entered: 3/6/2019 |
Order |
|
Type: FOR EXTENSION OF TIME FOR BINARY CAPITAL DEFENDANTS TO ANSWER TO THE COMPLAINT Signed by: V. RAYMOND SWOPE Date Signed: 03/05/2019
|
|
Request |
|
|
|
| 100 |
Filed: 3/4/2019, Entered: 3/4/2019 |
Order sent for signature to Judicial Officer |
|
23; SWOPE; JOINT STIPULATION AND ORDER FOR EXTENSION OF TIME FOR BINARY CAPITAL DEFENDANTS TO ANSWER OF OTHERWISE RESPOND TO COMPLAINT
|
|
Request |
|
|
|
| 99 |
Filed: 3/4/2019, Entered: 3/4/2019 |
Proof Of Service By Mail |
|
JOINT STIPULATION AND ORDER FOR EXTENSION OF TIME FOR BINARY CAPITAL DEFENDANTS TO ANSWER OF OTHERWISE RESPOND TO COMPLAINT
|
|
Request |
|
|
|
| 98 |
Filed: 2/26/2019, Entered: 2/26/2019 |
Notice of Entry of Order |
|
STIPULATED PROTECTIVE ORDER BETWEEN P[LAINTIFF ANN LAI AND JUSTIN CALDBECK, IN HIS INDIVIDUAL CAPACITY, AND STANDISH MANAGEMENT
|
|
Request |
|
|
|
| 97 |
Filed: 2/21/2019, Entered: 2/21/2019 |
Answer |
|
TO SECOND AMENDED COMPLAINT; DEMAND FOR JURY TRIAL
|
|
Request |
|
|
|
| 96 |
Filed: 2/19/2019, Entered: 2/19/2019 |
Stipulation and Order |
|
Type: STIPULATED PROTECTIVE ORDER WITH JUSTIN CALDBECK, IN HIS INDIVIDUAL CAPACITY, AND STANDISH MANAGEMENT Signed by: JUDGE GEORGE A. MIRAM Date Signed: 02/13/2019
|
|
Request |
|
|
|
| 95 |
Filed: 2/19/2019, Entered: 2/19/2019 |
Notice of Entry of Order |
|
GRANTING PLAINTIFF'S STIPULATED PROTECTIVE ORDER WITH LOS ANGELES COUNTY EMPLOYEES RETIREMENT ASSOCIATION
|
|
Request |
|
|
|
| 94 |
Filed: 2/7/2019, Entered: 2/7/2019 |
Proof Of Service By Mail |
|
CASE MANAGEMENT STATEMENT; NOTICE OF APPEARANCE BY MARK R CONRAD
|
|
Request |
|
|
|
| 93 |
Filed: 2/7/2019, Entered: 2/7/2019 |
Notice |
|
of APPEARANCE BY MARK R. CONRAD
|
|
Request |
|
|
|
| 92 |
Filed: 2/7/2019, Entered: 2/7/2019 |
Proof of Service - ELECTRONIC of |
|
COMPLAINT, SUMMONS ON DEFENDANTS VIA TWITTER SECOND AMENDED COMPLAINT; SUMMONS; ORDER GRANTING PUBLICATION OF SUMMONS
|
|
Request |
|
|
|
| 91 |
Filed: 2/6/2019, Entered: 2/6/2019 |
Stipulation and Order |
|
Type: PROTECTIVE ORDER WITH LOS ANGELES COUNTY EMPLOYEES RETIREMENT ASSOCIATION Signed by: JUDGE MIRAM Date Signed: 02/06/19
|
|
Request |
|
|
|
| 90 |
Filed: 2/6/2019, Entered: 2/6/2019 |
Notice |
|
of APPEARANCE OF ELLIOT R PETERS
|
|
Request |
|
|
|
| 89 |
Filed: 2/6/2019, Entered: 2/6/2019 |
Notice |
|
of APPEARANCE OF ANJALI SRINIVASAN
|
|
Request |
|
|
|
| 88 |
Filed: 2/6/2019, Entered: 2/6/2019 |
Notice |
|
of APPEARANCE OF ELIZABETH K MCCLOSKEY
|
|
Request |
|
|
|
| 87 |
Filed: 2/6/2019, Entered: 2/6/2019 |
Stipulation and Proposed Order received & forwarded to Dept |
|
DEPARTMENT 28
|
|
Request |
|
|
|
| 86 |
Filed: 2/4/2019, Entered: 2/4/2019 |
Stipulation and Proposed Order received & forwarded to Dept |
|
28 - PROTECTIVE ORDER WITH LOS ANGELES COUNTY EMPLOYEES RETIREMENT ASSOCIATION
|
|
Request |
|
|
|
| 85 |
Filed: 1/31/2019, Entered: 1/31/2019 |
Notice |
|
OF ENTRY OF DISMISSAL OF CALDBECK
|
|
Request |
|
|
|
| 84 |
Filed: 1/22/2019, Entered: 1/22/2019 |
Proof of Service by PUBLICATION of |
|
SUMMONS ON SECOND AMENDED COMPLAINT
|
|
Request |
|
|
|
| 83 |
Filed: 1/9/2019, Entered: 1/9/2019 |
Notice of Case Management Conference |
|
CMC 2/22/19
|
|
Request |
|
|
|
| 82 |
Filed: 12/26/2018, Entered: 12/26/2018 |
Notice of Entry of Order |
|
NOTICE OF ENTRY OF ORDER GRANTING PLAINTIFF AN LAI'S EX PARTE APPLICATION FOR ORDER OF PUBLICATION OF SUMMONS
|
|
Request |
|
|
|
| 81 |
Filed: 12/26/2018, Entered: 12/26/2018 |
Request For Dismissal |
|
With Prejudice
|
|
Request |
|
|
|
| 80 |
Filed: 12/20/2018, Entered: 12/20/2018 |
Order |
|
Type: GRANTING PLAINTIFF ANN LAI'S EX PARTE APPLICATION FOR ORDER OF PUBLICATION OF SUMMONS Signed by: JUDGE GREENBERG Date Signed: 12/20/18
|
|
Request |
|
|
|
| 79 |
Filed: 12/20/2018, Entered: 12/20/2018 |
Ex-Parte Application |
|
FOR ORDER OF PUBLICATION OF SUMMONS, ETC
|
|
Request |
|
|
|
| 78 |
Filed: 11/20/2018, Entered: 11/20/2018 |
Notice of Case Management Conference |
|
CMC 1/23/19
|
|
Request |
|
|
|
| 77 |
Filed: 10/25/2018, Entered: 10/25/2018 |
Notice of Case Management Conference |
|
CMC 12/12/18
|
|
Request |
|
|
|
| 76 |
Filed: 10/18/2018, Entered: 10/18/2018 |
Answer |
|
TO SECOND AMENDED COMPLAINT
|
|
Request |
|
|
|
| 75 |
Filed: 10/9/2018, Entered: 10/9/2018 |
Proof of Service |
|
PERSONAL SERVICE IS QUESTIONABLE, SEPARATE PROOF OF SERVICE IS REQUIRED FOR EACH PARTY
|
|
Request |
|
|
|
| 74 |
Filed: 10/1/2018, Entered: 10/1/2018 |
Notice of Entry of Order |
|
GRANTING PLAINTIFF'S MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT.
|
|
Request |
|
|
|
| 73 |
Filed: 9/24/2018, Entered: 9/24/2018 |
Order |
|
Type: GRANTING PLAINTIFF'S MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT Signed by: JUDGE GREENBERG Date Signed: 09/20/18
|
|
Request |
|
|
|
| Save 25% on a pre-paid one year subscription. |
|
|
| 72 |
Filed: 9/24/2018, Entered: 9/24/2018 |
Proof Of Service By Mail |
|
SECOND AMENDED COMPLAINT, SUMMONS
|
|
Request |
|
|
|
| 71 |
Filed: 9/24/2018, Entered: 9/24/2018 |
Proof of Service on CORPORATION, LLC, etc |
|
SUMMONS, SECON AMENDED COMPLAINT, SERVED ON BECKY DEGEORGE - CSC - PERSON AUTHORIZED TO ACCEPT SERVICE
|
|
Request |
|
|
|
| 70 |
Filed: 9/17/2018, Entered: 9/17/2018 |
Summons: Issued/Filed |
|
2ND AMENDED
|
|
|
|
|
|
| 69 |
Filed: 9/13/2018, Entered: 9/13/2018 |
Mail returned undelivered |
|
Notice of CMC set on 9/13/18
|
|
Request |
|
|
|
| 68 |
Filed: 9/11/2018, Entered: 9/11/2018 |
Notice |
|
OF REPRESENTATION
|
|
Request |
|
|
|
| 67 |
Filed: 9/10/2018, Entered: 9/10/2018 |
Motion for Leave to File Amended Complaint/Answer |
|
Hearing Time: 9:00 AM
|
|
Request |
|
|
|
| 66 |
Filed: 8/31/2018, Entered: 8/31/2018 |
Proof Of Service By Mail |
|
PLAINTIFF ANN LAI'S REPLY served on SEE SERVICE LIST
|
|
Request |
|
|
|
| 65 |
Filed: 8/31/2018, Entered: 8/31/2018 |
Memorandum of Points and Authorities in Support |
|
PLAINTIFF ANN LAI'S REPLY IN SUPPORT OF MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT
|
|
Request |
|
|
|
| 64 |
Filed: 8/28/2018, Entered: 8/28/2018 |
Opposition |
|
TO PLAINTIFF LAI'S MOTION TO FILE SECOND AMENDED COMPLAINT
|
|
Request |
|
|
|
| 63 |
Filed: 8/27/2018, Entered: 8/27/2018 |
Notice of Case Management Conference |
|
CMC set for 11/1/18
|
|
Request |
|
|
|
| 62 |
Filed: 8/14/2018, Entered: 8/14/2018 |
Proof Of Service By Mail |
|
PLAINTIFF ANN LAI'S NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT, ETC served on SEE SERVICE LIST CORRECTED PROOF OF SERVICE RE PLAINTIFF ANN LAI'S MOTION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT
|
|
Request |
|
|
|
| 61 |
Filed: 8/8/2018, Entered: 8/8/2018 |
Declaration in Support |
|
DECLARATION OF CHRIS BAKER IN SUPPORT OF PLAINTIFF ANN LAI'S MOTION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT
|
|
Request |
|
|
|
| 60 |
Filed: 8/8/2018, Entered: 8/8/2018 |
Proof Of Service By Mail |
|
PLAINTIFF ANN LAI'S NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT, ETC served on SEE SERVICE LIST
|
|
Request |
|
|
|
| 59 |
Filed: 8/8/2018, Entered: 8/8/2018 |
Notice of Motion and Motion for Leave to Amend |
|
PLAINTIFF ANN LAI'S NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF
|
|
Request |
|
|
|
| 58 |
Filed: 7/31/2018, Entered: 7/31/2018 |
Motion to Lift Stay |
|
Hearing Time: 9:00 AM
|
|
Request |
|
|
|
| 57 |
Filed: 7/23/2018, Entered: 7/23/2018 |
Memorandum of Points and Authorities in Reply |
|
BRIEF RE: MOTION TO LIFT STAY
|
|
Request |
|
|
|
| 56 |
Filed: 7/18/2018, Entered: 7/18/2018 |
Memorandum of Points and Authorities in Opposition |
|
DEFENDANT JUSTIN CALDBECK'S OPPOSITION TO PLAINTIFF'S MOTION TO LIFT STAY AND PETITION TO RESUME ARBITRATON AS PREVIOUSLY ORDERED BY COURT
|
|
Request |
|
|
|
| 55 |
Filed: 6/28/2018, Entered: 6/28/2018 |
Notice of Court Hearing |
|
Notice of CMC set for 9/13/18
|
|
Request |
|
|
|
| 54 |
Filed: 6/25/2018, Entered: 6/25/2018 |
Proof Of Service By Mail |
|
PLAINTIFF ANN LAI'S NOTICE OF MOTION AND MOTION TO LIFT STAY; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT, ETC served on SEE SERVICE LIST
|
|
Request |
|
|
|
| 53 |
Filed: 6/20/2018, Entered: 6/20/2018 |
Proposed Order Received |
|
GRANTING PLAINTIFF ANN LAI'S MOTION TO LIFT STAY
|
|
Request |
|
|
|
| 52 |
Filed: 6/20/2018, Entered: 6/20/2018 |
Declaration in Support |
|
OF CHRIS BAKER OF PLAINTIFF ANN LAI'S MOTION TO LIFT STAY
|
|
Request |
|
|
|
| 51 |
Filed: 6/20/2018, Entered: 6/20/2018 |
Motion |
|
AND MOTION TO LIFT STAY, ETC
|
|
Request |
|
|
|
| 50 |
Filed: 5/9/2018, Entered: 5/9/2018 |
Motion for leave |
|
TO FILE A SECOND AMENDED COMPLAINT
|
|
Request |
|
|
|
| 49 |
Filed: 5/8/2018, Entered: 5/8/2018 |
Proof of Service by OVERNIGHT DELIVERY of |
|
DEFENDANT AND CROSS-COMPLAINANT TORA HOLDINGS, INC.'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE , SUMMARY ADJUDICATION, ETC served on SEE SERVICE LIST
|
|
Request |
|
|
|
| 48 |
Filed: 5/8/2018, Entered: 5/8/2018 |
Proof Of Service By Mail |
|
PLAINTIFF ANN LAI'S REPLY IN SUPPORT OF HER MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT, ETC served on JONATHAN TEO
|
|
Request |
|
|
|
| 47 |
Filed: 5/2/2018, Entered: 5/2/2018 |
Proof of Service by PERSONAL SERVICE of |
|
PLAINTIFF ANN LAI'S REPLY IN SUPPORT OF HER MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT served on DONNA M. RUTTER, ESQ
|
|
Request |
|
|
|
| 46 |
Filed: 5/2/2018, Entered: 5/2/2018 |
Declaration in Reply |
|
IN SUPPORT OF PLAINTIFF'S MOTION TO FILE A SECOND AMENDED COMPLAINT
|
|
Request |
|
|
|
| 45 |
Filed: 5/2/2018, Entered: 5/2/2018 |
Memorandum of Points and Authorities in Reply |
|
IN SUPPORT OF HER MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT
|
|
Request |
|
|
|
| 44 |
Filed: 4/27/2018, Entered: 4/27/2018 |
Opposition |
|
TO PLAINTIFFS' MOTION TO FILE SECOND AMENDED COMPLAINT
|
|
Request |
|
|
|
| 43 |
Filed: 4/27/2018, Entered: 4/27/2018 |
Declaration |
|
OF DONNA M. RUTTER IN SUPPORT OF MOTION TO FILE A SECOND AMENDED COMPLAINT
|
|
Request |
|
|
|
| 42 |
Filed: 4/25/2018, Entered: 4/25/2018 |
Order |
|
Type: GRANTING ATTORNEY'S MOTION TO BE RELIEVED AS COUNSEL Signed by: JUDGE GREENBERG Date Signed: 04/24/18
|
|
Request |
|
|
|
| 41 |
Filed: 4/24/2018, Entered: 4/24/2018 |
Proof of Service by PERSONAL SERVICE of |
|
PLAINTIFF ANN LAI'S NOTICE OF MOTION AND MOTION TO FILE A SECOND AMENDED COMPLAINT, ETC
|
|
Request |
|
|
|
| 40 |
Filed: 4/24/2018, Entered: 4/24/2018 |
Proof of Service by PERSONAL SERVICE of |
|
PLAINTIFF ANN LAI'S NOTICE OF MOTION AND MOTION TO FILE A SECOND AMENDED COMPLAINT, ETC served on DONNA M. RUTTER
|
|
Request |
|
|
|
| 39 |
Filed: 4/23/2018, Entered: 4/23/2018 |
Order sent for signature to Judicial Officer |
|
TO DEPT. 3 ORDER AFTER HEARING
|
|
Request |
|
|
|
| 38 |
Filed: 4/18/2018, Entered: 4/18/2018 |
Notice of Court Hearing |
|
Notice of CMC: 7/11/18
|
|
Request |
|
|
|
| 37 |
Filed: 4/17/2018, Entered: 4/17/2018 |
Proposed Order Received |
|
GRANTING MOTION TO FILE A SECOND AMENDED COMPLAINT
|
|
Request |
|
|
|
| 36 |
Filed: 4/17/2018, Entered: 4/17/2018 |
Declaration in Support |
|
OF PLAINTIFF'S ANN LAI'S NOTICE OF MOTION AND MOTION TO FILE A SECOND AMENDED COMPLAINT
|
|
Request |
|
|
|
| 35 |
Filed: 4/17/2018, Entered: 4/17/2018 |
Motion |
|
NOTICE OF MOTION AND MOTION TO FILE A SECOND AMENDED COMPLAINT
|
|
Request |
|
|
|
| 34 |
Filed: 4/11/2018, Entered: 4/11/2018 |
Motion To Be Relieved As Counsel |
|
Hearing Time: 9:00 AM
|
|
Request |
|
|
|
| 33 |
Filed: 3/16/2018, Entered: 3/16/2018 |
Proof of Service - ELECTRONIC of |
|
NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL ETC.. served on JONATHAN TEO
|
|
Request |
|
|
|
| 32 |
Filed: 3/14/2018, Entered: 3/14/2018 |
Proof of Service by OVERNIGHT DELIVERY of |
|
NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL served on SEE SERVICE LIST
|
|
Request |
|
|
|
| 31 |
Filed: 3/14/2018, Entered: 3/14/2018 |
Declaration |
|
IN SUPPORT OF ATTORNEYS' MOTION TO BE RELIEVED AS COUNSEL
|
|
Request |
|
|
|
| 30 |
Filed: 3/14/2018, Entered: 3/14/2018 |
Proposed Order Received |
|
GRANTING ATTORNEY'S MOTION TO BE RELIEVED AS COUNSEL
|
|
Request |
|
|
|
| 29 |
Filed: 3/14/2018, Entered: 3/14/2018 |
Motion |
|
AND MOTION TO BE RELIEVED AS COUNSEL
|
|
Request |
|
|
|
| 28 |
Filed: 2/2/2018, Entered: 2/2/2018 |
Motion to Seal |
|
Hearing Time: 9:00 AM
|
|
Request |
|
|
|
| 27 |
Filed: 12/20/2017, Entered: 12/20/2017 |
Other Hearing |
|
Hearing Time: 02:00 PM
|
|
Request |
|
|
|
| 26 |
Filed: 12/13/2017, Entered: 12/13/2017 |
Joinder |
|
TO MOTION TO COMPEL ARBITRATION AND STAY, ETC
|
|
Request |
|
|
|
| 25 |
Filed: 12/13/2017, Entered: 12/13/2017 |
Motion to Compel Arbitration and to Stay |
|
Hearing Time: 9:00 AM
|
|
Request |
|
|
|
| 24 |
Filed: 12/11/2017, Entered: 12/11/2017 |
Proof Of Service By Mail |
|
DEFENDANT BINARY CAPITAL MANAGEMENT, LLC'S NOTICE OF MOTION AND MOTION TO SEAL....
|
|
Request |
|
|
|
| 23 |
Filed: 12/11/2017, Entered: 12/11/2017 |
Proposed Order Received |
|
GRANTING DEFENDANT BINARY CAPITAL MANAGMENT, LLC'S MOTION TO SEAL....
|
|
Request |
|
|
|
| 22 |
Filed: 12/11/2017, Entered: 12/11/2017 |
Declaration |
|
OF April SUN IN SUPPORT OF DEFENDANT BINARY CAPITAL MANAGEMENT, LLC'S MOTION TO SEAL....
|
|
Request |
|
|
|
| 21 |
Filed: 12/11/2017, Entered: 12/11/2017 |
Motion |
|
AND MOTION TO SEAL, ETC
|
|
Request |
|
|
|
| 20 |
Filed: 12/6/2017, Entered: 12/6/2017 |
Proof of Service by OVERNIGHT DELIVERY of |
|
REPLY MEMORANDUM IN SUPPORT OF ITS MOTION TO COMPEL ARBITRATION AND FOR IMMEDIATE STAY OF JUDICIAL PROCEEDINGS, ETC
|
|
Request |
|
|
|
| 19 |
Filed: 12/6/2017, Entered: 12/6/2017 |
Declaration |
|
OF April SUN IN SUPPORT OF REPLY MEMORANDUM IN SUPPORT OF ITS MOTION TO COMPEL ARBITRATION OF PLAINTIFF ANN LAI'S CLAIMS AND FOR IMMEDIATE STAY OF JUDICIAL PROCEEDINGS
|
|
Request |
|
|
|
| 18 |
Filed: 12/6/2017, Entered: 12/6/2017 |
Declaration in Support |
|
OF REPLY MEMORANDUM IN SUPPORT OF MOTION TO COMPEL ARBITRATION OF PLAINTIFF ANN LAI'S CLAIMS AND FOR IMMEDIATE STAY OF JUDICIAL PROCEEDINGS
|
|
Request |
|
|
|
| 17 |
Filed: 12/6/2017, Entered: 12/6/2017 |
Memorandum Of Points And Authorities; |
|
IN SUPPORT OF ITS MOTION TO COMPEL ARBITRATION AND FOR IMMEDIATE STAY OF JUDICIAL PROCEEDINGS
|
|
Request |
|
|
|
| 16 |
Filed: 12/5/2017, Entered: 12/5/2017 |
Proof of Service by PERSONAL SERVICE of |
|
PLAINTIFF ANN LAI'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO DEFENDANT'S MOTION TO COMPEL ARBITRATION served on SEE SERVICE LIST
|
|
Request |
|
|
|
| 15 |
Filed: 12/5/2017, Entered: 12/5/2017 |
Documents Lodged Conditionally Under Seal |
|
Document(s): EXHIBITS A AN B TO PLAINTIFF ANN LAI'S DECLARATION IN SUPPORT OF OPPOSITION TO DEFENDANTS' MOTION TO COMPEL ARBITRATION
|
|
Request |
|
|
|
| 14 |
Filed: 12/5/2017, Entered: 12/5/2017 |
Documents Lodged Conditionally Under Seal |
|
Document(s): UNREDACTED VERSION OF PLAINTIFF ANN LAI'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO DEFENDANTS' MOTION TO COMPEL ARBITRATION
|
|
Request |
|
|
|
| 13 |
Filed: 11/30/2017, Entered: 11/30/2017 |
Declaration |
|
IN SUPPORT OF OPPOSITION TO MOTION TO COMPEL ARBITRATION
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Request |
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| 12 |
Filed: 11/30/2017, Entered: 11/30/2017 |
Memorandum of Points and Authorities in Opposition |
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TO MOTION TO COMPEL ARBITRATION
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Request |
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| 11 |
Filed: 11/21/2017, Entered: 11/21/2017 |
Proof of Service by MESSENGER SERVICE of |
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DEFENDANT JUSTIN CALDEBECK'S NOTICE OF JOINDER OF BINARY CAPITAL MANAGEMENT, LLC'S NOTICE OF MOTION AND MOTION TO COMPEL ARBITRATION, ETC served on SEE SERVICE LIST
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Request |
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| 10 |
Filed: 11/21/2017, Entered: 11/21/2017 |
Proof of Service by MESSENGER SERVICE of |
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DEFENDANT BINARY CAPITAL MANAGEMENT, LLC'S NOTICE OF MOTION AND MOTION TO COMPEL ARBITRATION, ETC served on SEE SERVICE LIST
|
|
Request |
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|
|
| 9 |
Filed: 11/17/2017, Entered: 11/17/2017 |
Proof of Service by MESSENGER SERVICE of |
|
DEFENDANTS BINARY CAPITAL MANAGEMENT, LLC'S NOTICE OF MOTION AND MOTION TO COMPEL ARBITRATION, ETC served on SEE SERVICE LIST
|
|
Request |
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|
|
| 8 |
Filed: 11/17/2017, Entered: 11/17/2017 |
Proposed Order Received |
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GRANTING MOTION TO COMPEL ARBITRATION, ETC
|
|
Request |
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|
|
| 7 |
Filed: 11/17/2017, Entered: 11/17/2017 |
Declaration |
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OF JONATHAN TEO IN SUPPORT OF MOTION TO COMPEL ARBITRATION, ETC
|
|
Request |
|
|
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| 6 |
Filed: 11/17/2017, Entered: 11/17/2017 |
Notice |
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OF JOINDER OF MOTION TO COMPEL ARBITRATION OF PLAINTIFF ANN LAI'S CLAIMS AND FOR IMMEDIATE STAY, ETC
|
|
Request |
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|
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| 5 |
Filed: 11/17/2017, Entered: 11/17/2017 |
Motion |
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TO COMPEL ARBITRATION OF PLAINTIFF ANN LAI'S CLAIMS AND FOR IMMEDIATE STAY OF JUDICIAL PROCEEDINGS, ETC
|
|
Request |
|
|
|
| 4 |
Filed: 10/26/2017, Entered: 10/26/2017 |
Case Management Conference |
|
Hearing Time: 9:00 AM
|
|
Request |
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|
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| 3 |
Filed: 9/20/2017, Entered: 9/20/2017 |
Stipulation and Order |
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TO EXTEND TIME FOR PLAINTIFF TO FILE AMENDED COMPLAINT AND FOR DEFENDANTS TO RESPOND SIGNED BY JUDGE CRETAN
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|
Request |
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| 2 |
Filed: 9/11/2017, Entered: 9/11/2017 |
Stipulation and Proposed Order received & forwarded to Dept |
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DEPT 6, STIP AND ORDER TO EXTEND TIME TO FILE AMENDED COMPLAINT AND FOR DEFENDANTS TO RESPOND
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Request |
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| 1 |
Filed: 8/21/2017, Entered: 8/21/2017 |
Notice & Acknowledgment of Receipt of |
|
SUMMONS & COMPLAINT, NOTICE OF CMC
|
|
Request |
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