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34-2022-00324254-CU-OE-GDS·sacramento·Civil·Wage-and-hour class action
Hearing almost 2 years agoDENIED WITHOUT PREJUDICE

Jaime Farias vs. Labor Resource Group, Inc

Motion for Preliminary Approval of Settlement

Hearing date
Oct 11, 2024
Department
22
Judge
Prevailing
N/A
Appearance
Not required

Motion type

Browse all Motion for Preliminary Approval of Class Settlement rulings statewide →

Causes of action

Monetary amounts referenced

$850,000$10,000$283,333.33$25,000$15,000$30,000$22,500$7,500

Parties

PlaintiffJaime Farias
DefendantLabor Resource Group, Inc
DefendantCEMCO, Inc.

Ruling

34-2022-00324254-CU-OE-GDS: Jaime Farias vs. Labor Resource Group, Inc 10/11/2024 Hearing on Motion for Preliminary Approval of Settlement in Department 22

Tentative Ruling

Plaintiff Jaime Farias’s (“Plaintiff”) motion for preliminary approval of the Parties’ class and Private Attorneys General Act (“PAGA”) settlement is UNOPPOSED, but DENIED WITHOUT PREJUDICE, for the reasons specified below.

Moving counsel’s Notice of Motion does not provide notice of the Court’s tentative ruling system, as required by Local Rule 1.06. Moving counsel is directed to contact opposing counsel and advise them of Local Rule 1.06, the Court’s tentative ruling procedure, and the manner to request a hearing.

The Court has provided specific direction on the information and argument the Court requires to grant a motion for preliminary and final approval of a class action settlement. The Parties shall carefully review the Checklist for Approval of Class Action Settlements and fully comply with each applicable item to ensure a prompt ruling from the Court.

Background

On July 26, 2022, Plaintiff filed a putative wage-and-hour class action complaint against Defendants Labor Resource Group, Inc. and CEMCO, Inc. (“Defendants”) for: (1) failure to pay minimum and straight time wages (Labor Code §§ 204, 1194, 1194.2, and 1197); (2) failure to pay overtime wages (Labor Code §§ 1194, and 1198); (3) failure to provide meal periods (Labor Code §§ 226.7 and 512); (4) failure to authorize and permit rest periods (Labor Code §§ 226.7 and 512); (5) failure to timely pay final wages at termination (Labor Code §§ 201-203); (6) failure to provide accurate itemized wage statements (Labor Code § 226); (7) failure to indemnify employees for expenditures (Labor Code § 2802); and (8) unfair business practices (Business and Professions Code 17200 et seq.). (Marquez Decl., ¶ 4.) On September 29, 2022, Plaintiff filed a separate action against Defendants for civil penalties under PAGA. (Ibid.)

Plaintiff sent a notice to Defendants and the California Labor & Workforce Development Agency (“LWDA”) alleging similar wage and hour violations pursuant to the PAGA on July 26, 2022. (Marquez Decl., ¶ 4.) On June 20, 2024, Plaintiff amended his LWDA notice for settlement purposes to include claims for the failure to pay vested vacation wages upon termination and the failure to pay sick leave. (Ibid.) Four days later, on June 24, 2024, Plaintiff filed a first amended complaint in the class action matter (“Class FAC”) adding causes of action for the failure to pay vested vacation wages upon termination and the failure to pay sick leave. (Ibid.)

On September 13, 2024, following the exhaustions of the 65-day statutory period in the PAGA action, the Parties submitted a stipulation, along with a redlined PAGA FAC and clean copy of the PAGA FAC for the Court’s review and approval. (Ibid.) The Court signed the Order granting Plaintiff leave to file the PAGA FAC on September 18, 2024. (9-18-24 Order.)

Plaintiff now moves for preliminary approval of the Parties’ Class Action and PAGA Settlement

34-2022-00324254-CU-OE-GDS: Jaime Farias vs. Labor Resource Group, Inc 10/11/2024 Hearing on Motion for Preliminary Approval of Settlement in Department 22

Agreement and Class Notice (“Settlement Agreement” or “Agreement”). (Marquez Decl., ¶ 8, Exh. 1 (“SA”).)

Legal Standard

The law favors the settlement of lawsuits, particularly in class actions and other complex cases where substantial resources can be conserved by avoiding the time, expense, and rigors of formal litigation. (See Neary v. Regents of Univ. of Cal (1992) 3 Cal.4th 273, 277-281; Lealao v. Beneficial California, Inc. (2000) 82 Cal.App.4th 19, 52.) However, a class action may not be dismissed, compromised, or settled without approval of the court, and the decision to approve or reject a proposed settlement is committed to the court’s sound discretion. (See Cal. Rules of Court, Rule 3.769; Wershba v. Apple Computer, Inc. (2001) 91 Cal.App.4th 224, 234-35 (Wershba).)

In determining whether to approve a class settlement, the court’s responsibility is to “prevent fraud, collusion or unfairness to the class” through settlement because the rights of the class members, including the named plaintiffs, “may not have been given due regard by the negotiating parties.” (Consumer Advocacy Group, Inc. v. Kintetsu Enters. of Am. (2006) 141 Cal.App.4th 46, 60.) The court must independently determine “whether the settlement is in the best interests of those whose claims will be extinguished” and “make an independent assessment of the reasonableness of the terms to which the parties have agreed.” (Kullar v.

Foot Locker Retail, Inc. (2008) 168 Cal.App.4th 116, 130, 133.) The burden of establishing the fairness and reasonableness of the settlement is on the proponent. (Wershba, supra, 91 Cal.App.4th at p. 245; see also 7-Eleven Owners for Fair Franchising v. Southland Corp. (2000) 85 Cal.App.4th 1135 1165-66.)

The Court does not rubber stamp these motions, but rather serves as a guardian of absent class members’ rights to ensure the settlement is fair. (Luckey v. Superior Court (2014) 228 Cal.App.4th 81, 95.) “Ultimately, the [trial] court’s determination is nothing more than ‘an amalgam of delicate balancing, gross approximations and rough justice.” (7-Eleven, supra, 85 Cal.App.4th at p. 1145.) “A settlement need not obtain 100 percent of the damages sought in order to be fair and reasonable. Compromise is inherent and necessary in the settlement process.

Thus, even if 'the relief afforded by the proposed settlement is substantially narrower than it would be if the suits were to be successfully litigated,' this is no bar to a class settlement because 'the public interest may indeed be served by a voluntary settlement in which each side gives ground in the interest of avoiding litigation.'” (Wershba, supra, 91 Cal.App.4th at p. 250, citations omitted.) The court’s primary objective for preliminary approval is to establish whether to direct notice of the proposed settlement to the class, invite the class’s reaction, and schedule a final fairness hearing. (Rubenstein et al., Newberg on Class Actions (6th ed. 2023) § 13:10.)

Summary of Agreement

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00324254-CU-OE-GDS: Jaime Farias vs. Labor Resource Group, Inc 10/11/2024 Hearing on Motion for Preliminary Approval of Settlement in Department 22

Under the terms of the Agreement, Defendants deny liability, but agree to pay a Gross Settlement Amount (“GSA”) of $850,000 to resolve Plaintiff’s claims. (SA, ¶¶ 1.21, 3.1.) Defendants will separately pay any and all employer payroll taxes owed on the wage portions of the Individual Class Payments. (Id., ¶ 3.1.) Participating Class Members and Aggrieved Employees will receive their share of the settlement without asking or requiring them to submit any claim and none of the GSA will revert to Defendants. (Ibid.)

Defendants shall fully fund the GSA in six equal quarterly payments made to the Settlement Administrator. (Id., ¶ 4.3.) The first quarterly payment will be due on February 29, 2024, with each additional payment due at the end of every third month thereafter. (Ibid.) Concurrent with the final payment, Defendants will also pay the amount necessary to pay Defendants’ share of employer payroll taxes. (Ibid.)

The following amounts will be paid from the GSA:  A Class Representative Service Payment to Plaintiff of not more than $10,000 (SA, ¶ 3.2.1);  A Class Counsel Fees Payment of not more than 33 1/3% (estimated to be $283,333.33) and a Class Counsel Litigation Expenses Payment of not more than $25,000 (id., ¶ 32.2);  An Administrator Expenses Payment not to exceed $15,000 (id., ¶ 3.2.3);  A PAGA Penalties payment of $30,000, with 75% allocated to the LWDA ($22,500) and 25% allocated to the Aggrieved Employees ($7,500) (id., ¶ 3.2.5).

The remaining amount – the Net Settlement Amount (“NSA”) – shall be distributed to the Participating Class Members as Individual Class Payments, calculated on a pro-rata basis. (SA, ¶¶ 1.22, 1.27, 3.2.4.) For tax purposes, 20% of each Individual Class Payment will be allocated to the settlement of wage claims and 80% allocated to the settlement of claims for interest and penalties. (Id., ¶ 3.2.4.1.) Similarly, the Aggrieved Employees’ portion of the PAGA Penalties shall be distributed on a pro-rata basis. (Id., ¶¶ 1.23, 3.2.5.1.)

Aggrieved Employees assume fully responsibility and liability for any taxes owed on their Individual PAGA Payments. (Id., ¶ 3.2.5.1.) Individual Class and PAGA Payment checks will remain valid for at least 180 days after the date of mailing. (Id., ¶ 4.4.1.) The Administrator will cancel all checks not cashed by the void date and the funds associated with any such checks will be transmitted to Legal Aid At Work, as a cy pres recipient. (Id., ¶¶ 4.4.1, 4.4.3.) Plaintiff and his Counsel attest that they have no interest in the proposed cy pres recipient. (Marquez Decl., ¶ 16; Farias Decl., ¶ 18.)

Within 15 days after the Court grants preliminary approval of the settlement, Defendants will deliver the Class Data to the Administrator. (SA, ¶ 4.2.) Using best efforts to perform as soon as possible, and in no event later than 14 days after receiving the Class Data, the Administrator will send to all Class Members identified in the Class Data, via first-class USPS mail, the Notice, with Spanish translation. (Id., ¶ 7.4.2.) Before mailing the Notices, the Administrator shall update Class Member addresses using the National Change of Address database. (Ibid.) No later than 3 business days after the Administrator’s receipt of any Notice returned as undeliverable, the Administrator shall re-mail the Notice using any forwarding address provided by the USPS. (Id., ¶ 7.4.3.) If no forwarding address is provided, the Administrator shall conduct an address

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00324254-CU-OE-GDS: Jaime Farias vs. Labor Resource Group, Inc 10/11/2024 Hearing on Motion for Preliminary Approval of Settlement in Department 22

search and re-mail the Notice to the most current address obtained. (Ibid.) Class Members will have 60 days to submit written objections, challenges to workweeks and/or pay periods, and requests for exclusion. (Id., ¶¶ 1.42, 7.5, 7.6, 7.7.) The deadline will be extended an additional 14 days beyond the 60 days otherwise provided in the Notice for all Class Members whose notice is re-mailed. (Id., ¶ 7.4.4.)

Issues of Concern:

On July 1, 2024, Local Rule 2.99.05 went into effect. The rule states the moving papers for a preliminary and final approval motion for a class action and/or PAGA settlement must “include a declaration that attests to the fact that: (1) counsel for the moving party has reviewed the settlement checklist; and (2) that the moving papers were prepared in compliance with the checklist.” (Local Rule 2.99.05(C).) The rule further provides that: “[f]ailure to provide this declaration will result in the denial of the approval motion without prejudice.” (Ibid.) The rule explains that the “[f]ailure to provide the required information stated in the checklist wastes judicial resources and imposes unnecessary burden on the parties and the Court.” (Id. at 2.99.05(D).)

Here, Moving Counsel’s declaration fails to include the attestation required by Local Rule 2.99.05. Further, the motion fails to comply with the checklist in the following ways.

1. LWDA Notices: Plaintiff must provide copies of his original July 26, 2022 notice letter and his June 20, 2024 amended notice letter.

2. Releases: Generally, in cases involving both class and PAGA claims, the settlement should include separate releases for the Class Members and the Aggrieved Employees. (Checklist, § I, ¶¶ 11, 14.) The class release must be fairly tailored to the claims that were or reasonably could be asserted in the lawsuit based on the facts alleged in the complaint. (See Amaro v. Anaheim Arena Management, LLC (2021) 69 Cal.App.5th 521, 538-539 [“Releases must be appropriately tethered to the complaint’s factual allegations;” “[A] court cannot release claims that are outside the scope of the allegations of the complaint.”].) The PAGA release must be tethered to the PAGA claims that were or reasonably could have been alleged based on the facts alleged in the LWDA Notice. (See id., at p. 541, fn. 5 and Uribe v. Crown Building Maintenance Co. (2021) 70 Cap.App.5th 986, 1005.)

Here, the Agreement has an unusual release structure that raises several concerns. Effective on the date when Defendants fully fund the entire GSA and all employer payroll taxes, Plaintiff, Class Members, and Class Counsel will release claims against all Released Parties as follows:  “Plaintiff’s and Class Members’ Release. Plaintiff, Class Members, and Class Counsel will release all Released Parties of all claims, both potential and actual, that were or may have been raised in the Class Action and the PAGA Action, including claims under Labor Code section 201, 202, 203, 204, 216, 218.5, 222, 223, 226, 226.3, 11 226.7,

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00324254-CU-OE-GDS: Jaime Farias vs. Labor Resource Group, Inc 10/11/2024 Hearing on Motion for Preliminary Approval of Settlement in Department 22

227.3, 245-248.5, 510, 512, 558, 1174, 1174.5, 1194, 1194.2, 1197, 1197.1, 1198, 2802, 2698, 2699, 2699.3, 2699.5, California Industrial Welfare Commission Wage Orders, Cal. Code Regs., tit. 8, sections 3395 and 11000, et seq., California Business and Professions Code section 17200, et seq, and all class claims, representative claims, aggrieved employee claims, sick pay claims, vacation pay claims, meal or rest and recovery period claims, meal or rest and recovery period premium claims, unpaid regular, overtime, and/or minimum wage claims, including but not limited to claims for failing to properly calculate the regular rate of pay for purposes of paying overtime, meal and rest period premium payments, failing to pay all minimum and overtime wages for hours worked, failure to pay all wages owed upon separation of employment, failure to indemnify employees for all necessary expenditures, failure to provide accurate itemized wage statements and complete payments of wages at separation or termination, failure to provide accurate and itemized wage statements, unfair competition based on the foregoing, unlawful business practices based on the foregoing, fraudulent business practices based on the foregoing, PAGA penalties based on the foregoing, waiting time penalties, civil penalties based on the foregoing, interest, fees, costs, and any other claims that may have been raised in Plaintiff’s Complaints filed in the Class Action and PAGA Actions or that reasonably relate to the allegations therein during the Class Period and PAGA Period as defined above (collectively the ‘Released Claims’).

The Release Period shall be the Class Period. Except as set forth in Section 5.4 of this Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.” (SA, ¶ 5.1.)  “Release by Participating Class Members Who Are Not Aggrieved Employees: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, release Released Parties from all claims, both potential and actual, that were or may have been raised in the Class Action, including claims under Labor Code section 201, 202, 203, 204, 216, 218.5, 222, 223, 226, 226.3, 226.7, 227.3, 245-248.5, 510, 512, 558, 1174, 1174.5, 1194, 1194.2, 1197, 1197.1, 1198, 2802, California Industrial Welfare Commission Wage Orders, Cal.

Code Regs., tit. 8, sections 3395 and 11000, et seq., California Business and Professions Code section 17200, et seq, and all class claims, sick pay claims, vacation pay claims, meal or rest and recovery period claims, 11 meal or rest and recovery period premium claims, unpaid regular, overtime, and/or minimum wage claims, including but not limited to claims for failing to properly calculate the regular rate of pay for purposes of paying overtime, meal and rest period premium payments, failing to pay all minimum and overtime wages for hours worked, failure to pay all wages owed upon separation of employment, failure to indemnify employees for all necessary expenditures, failure to provide accurate itemized wage statements and complete payments of wages at separation or termination, failure to provide accurate and itemized wage statements, unfair competition based on the foregoing, unlawful business

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00324254-CU-OE-GDS: Jaime Farias vs. Labor Resource Group, Inc 10/11/2024 Hearing on Motion for Preliminary Approval of Settlement in Department 22

practices based on the foregoing, fraudulent business practices based on the foregoing, waiting time penalties, civil penalties based on the foregoing, interest, fees, costs, and any other claims that may have been raised in Plaintiff’s Complaints filed in the Class Action or that reasonably relate to the allegations therein during the Class Period. The Release Period for the claims set forth in this paragraph shall be the Class Period.” (SA, ¶ 5.2.)  “Release by Non-Participating Class Members Who Are Aggrieved Employees: All Non-Participating Class Members who are Aggrieved Employees are deemed to release, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, the Released Parties from all claims for PAGA penalties that were alleged, or reasonably could have been alleged, based on the PAGA Period facts stated in the Operative Complaints and the PAGA Notice, including any and all claims involving any alleged failure to pay minimum wages or overtime, failure to provide meal and rest periods, failure to provide accurate wage statements, failure to pay all wages due at separation, and failure to reimburse business expenses, including Labor Code sections 201, 202, 203, 210, 216, 223, 225.5, 226, 226.3, 226.7, 227.3, 245-248.5, 256, 432, 432.5, 432.7, 510, 512, 558, 558.1, 1024.5, 1174, 1194, 1197, 1197.1, 1198, 1198.5, 1199, 2699, 2699.3, 2802, 2810.5, as well as all PAGA claims based upon the causes of action and Labor Code provisions set forth in paragraph 5.2 during the PAGA Period.

Aggrieved Employees only release these claims for the duration of the PAGA Period.” (SA, ¶ 5.3.)

While Counsel stresses that the Parties’ utilized the Los Angeles County Superior Court model agreement, the Parties made several revisions that render the releases overbroad. (Marquez Decl., ¶ 9, Exh. 2.) First, the Parties combined Plaintiff’s general release with the Class Members’ release. (Id., at ¶ 5.1.) Second, the combined Plaintiff and Class release includes both Class and PAGA claims. (Ibid.) Third, the combined Plaintiff and Class release is not properly limited in scope to those claims that were or reasonably could have been alleged based on the facts alleged in the Operative Complaint. (Ibid.)

Instead, the release includes “all claims, both potential and actual, that may have been raised in the Class Action,” including “any other claims that may have been raised in Plaintiff’s Complaints filed in the Class Action or that reasonably relate to the allegations therein during the Class Period,” without any regard to the facts alleged. Notably, the Parties removed that critical limiting language from the model agreement. (Id., ¶¶ 5.1, 5.2.) The Court notes that the Parties retained the “reasonably could have been alleged, based on the [] facts stated” language in the PAGA release. (Id., ¶ 5.3.)

Next, while the Court is aware that the Los Angeles Model Agreement provides for a “Release by Participating Class Members Who Are Not Aggrieved Employees” and a “Release by Non- Participating Class Members Who Are Aggrieved Employees,” the Court finds this structure confusing. As drafted, neither of these releases apply to Participating Class Members who are also Aggrieved Employees. The Court believes the better approach would be to: (1) revise paragraph 5.1 to apply to Plaintiff only; (2) revise paragraph 5.2 to remove the “Who Are Not

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00324254-CU-OE-GDS: Jaime Farias vs. Labor Resource Group, Inc 10/11/2024 Hearing on Motion for Preliminary Approval of Settlement in Department 22

Aggrieved Employees” language from the heading; and (3) revise paragraph 5.3 to remove the “Non-Participating Class Members Who Are” language from both the heading and the paragraph. This would create a general release for Plaintiff, a separate Class release for Participating Class Members, and a separate PAGA release for all Aggrieved Employees, consistent with the governing case law, and ensure that all Participating Class Members and all Aggrieved Employees are covered by a release. The Court notes that, notwithstanding the Agreement’s structure, the Parties’ proposed Class Notice describes a release applicable to all Aggrieved Employees. (SA, Notice, p. 7.)

3. Exposure Analysis: Counsel provides a sufficient exposure analysis for Plaintiff’s unpaid off-the-clock work, meal period, rest period, failure to reimburse, and derivative penalty claims. (Marquez Decl., ¶¶ 18-26.) However, Counsel fails to provide any discussion of the vested vacation and sick leave claims added to the Class and PAGA actions for settlement purposes. Counsel must explain how these claims were valued.

4. Proposed Class Notice: The notice to Class Members must fairly apprise the prospective members of the terms of the settlement without expressing an opinion on the merits of the settlement. (7-Eleven Owners for Fair Franchising v. Southland Corp. (2000) 85 Cal.App.4th 1135, 1164; see also Cal. Rule of Court, Rule 3.769.) “Whether a claimant would want to accept or reject the proposed settlement is a decision to be made by him independently and without influence or pressure from those competing parties who either favor or oppose the settlement.” (Phila. Hous. Auth. v. Am. Radiator & Std. Sanitary Corp. (E.D. Pa. 1970) 323 F.Supp. 364, 378.)

Here, the Notice includes the following language: “Plaintiff and Class Counsel strongly believe the Settlement is a good deal for you because they believe that: (1) Defendants have agreed to pay a fair, reasonable and adequate amount considering the strength of the claims and the risks and uncertainties of continued litigation; and (2) Settlement is in the best interests of the Class Members and Aggrieved Employees.” (SA, Notice, at p. 4.) The Court finds this language is unnecessary and may improperly discourage class members from objecting to the settlement. Accordingly, it must be removed.

Moreover, the Notice must be revised to accurately describe the releases, consistent with any amendments to the Agreement, as discussed above. (Notice, pp. 6-7.)

5. Class Counsel Fees: The Court will not make any rulings on the reasonableness of Counsel’s hourly rates until final approval. However, because Counsel has provided extensive discussion of his hourly rates in support of the instant motion (Marquez Decl., ¶¶ 50-53, Exhs. 4 and 5), the Court urges Counsel to carefully review the checklist and the Court’s prior orders in advance of a renewed motion for preliminary approval and subsequent motion for final approval. As the Court has previously explained and Counsel is well aware, the prevailing rates in Los Angeles, San Jose, San Francisco, and New York or those charged by select Big Law firms are

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00324254-CU-OE-GDS: Jaime Farias vs. Labor Resource Group, Inc 10/11/2024 Hearing on Motion for Preliminary Approval of Settlement in Department 22

not the prevailing rates in Sacramento. Moreover, Counsel is admonished for again misrepresenting this Court’s order granting final approval in Sunshine Retirement Wage and Hour Case, JCCP 5247. (See Marquez Decl., ¶ 50(c)(3).) While the Court ultimately approved the requested award, the Court concluded that the claimed hourly rates exceeded the prevailing rates in this region. (1-19-24 Minute Order in Sunshine Retirement Wage and Hour Case, JCCP 5247; see also 8-30-24 Minute Order in Aguilar v. American Pasteurization Company, LLC, Case No. 34-2021-00312027.) Counsel should avoid merely cutting and pasting from previous motions, particularly where the Court has already considered and rejected the argument.

Disposition

These issues render the Court unable to conclude that the Settlement is fair, adequate, and reasonable. Accordingly, Plaintiff’s motion is DENIED WITHOUT PREJUDICE.

The Court is not opposed to the Settlement on a high level, but requires the Parties to address the issues raised above before the Court can grant preliminary approval. The Court’s list above is not intended to state that no other issues exist with respect to this motion. The Parties are advised to review their entire motion and make any necessary changes to fully comply with the checklist before filing a renewed motion.

To request oral argument on this matter, you must call Department 22 at (916) 874-5762 by 4:00 p.m., the court day before this hearing and notification of oral argument must be made to the opposing party/counsel. If no call is made, the tentative ruling becomes the order of the court. (Local Rule 1.06.)

Parties requesting services of a court reporter may arrange for private court reporter services at their own expense, pursuant to Government code §68086 and California Rules of Court, Rule 2.956. Requirements for requesting a court reporter are listed in the Policy for Official Reporter Pro Tempore available on the Sacramento Superior Court website at https://www.saccourt.ca.gov/court-reporters/docs/crtrp-6a.pdf. The list of Court Approved Official Reporters Pro Tempore is available at https://www.saccourt.ca.gov/courtreporters/docs/crtrp-13.Pdf.

If you are not using a reporter from the Court’s Approved Official Reporter Pro Tempore list, a Stipulation and Appointment of Official Reporter Pro Tempore (CV/E-206) must be signed by each party, the private court reporter, and the Judge. The signed form must be filed with the clerk prior to the hearing.

If a litigant has been granted a fee waiver and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211). The form must be filed with the clerk at least 10 days prior to the hearing or at the time the hearing is scheduled if less

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

34-2022-00324254-CU-OE-GDS: Jaime Farias vs. Labor Resource Group, Inc 10/11/2024 Hearing on Motion for Preliminary Approval of Settlement in Department 22

than 10 days away. Once approved, the clerk will forward the form to the Court Reporter’s Office and an official reporter will be provided.

If oral argument is requested, the Parties are encouraged to appear via Zoom with the links below:

To join by Zoom link - https://saccourt-ca-gov.zoomgov.com/my/sscdept22 To join by phone dial (833) 568-8864 ID 16184738886

Counsel for Plaintiff is directed to notice all parties of this order.

Please note that the Complex Civil Case Department now provides information to assist you in managing your complex case on the Court website at https://www.saccourt.ca.gov/civil/complex-civil-cases.aspx. The Court strongly encourages parties to review this website regularly to stay abreast of the most recent complex civil case procedures. Please refer to the website before directly contacting the Court Clerk for information.

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