Plaintiff's Motion for Final Approval
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administrator’s revised bid.
4. An enhancement of $15,000 to Plaintiff. In making this award, the Court has considered only the factors discussed in Golba v. Dick’s Sporting Goods, Inc. (2015) 238 Cal.App.4th 1251 and Clark v. Am. Residential Servs. LLC (2009) 175 Cal.App.4th 785.
5. The amount remaining is to be distributed 75% to the LWDA and 25% to the aggrieved employees as required by the version of PAGA in effect when the case was filed.
Please submit a revised proposed order for the Court’s signature that conforms to the foregoing. 3 Dehkordi vs. Modern Creation Inc
2025-01473144
Plaintiff's Motion for Final Approval The motion for approval of PAGA settlement is CONTINUED to July 31, 2026 at 9:00 a.m. in Department CX101 to permit the parties to respond to the following items of concern. Any supplemental briefing shall be filed on or before July 21, 2026. If a revised settlement agreement and/or proposed notice is submitted, a redline version showing all changes, deletions and additions must be submitted as well. In addition, Plaintiff must provide proof of service of any revised settlement agreement and supplemental papers on the LWDA.
The moving papers and supporting declaration aren’t internally tabbed or bookmarked as required by the Rules of Court. Please be advised that failure to follow the Rules of Court in future filings may result in hearing continuances and orders to follow the Rules.
As to the settlement:
1. Are there any other cases, whether individual, class, or PAGA (including in the pre-filing LWDA stage) that may be affected by this settlement?
2. What is the actual number of aggrieved employees and pay periods worked? Is the escalator triggered?
3. The “Released Parties” include a laundry list of parents, subsidiaries, etc., but also refers to Defendant’s “related entities” in several places. Please delete references to “related entities,” as this term is too vague for the scope of the release to be understood.
4. Has Plaintiff separately settled his individual claims? If so, please provide a copy of the individual settlement agreement. All agreements between the parties are relevant to the Court’s fairness analysis.
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Examples: “Why did the court rule this way?” · “What were the procedural grounds?” · “Is appearance required?”
5. What documents and information did Defendant turn over prior to mediation? For example, did Defendant provide Plaintiff’s personnel records? Copies of relevant policy documents? Time and pay records for the aggrieved employees? If time and pay records were turned over, were they all records, or were they a representative sample? If a sample, how large (e.g., 10%)?
6. Did counsel interview anyone other than Plaintiff to value the non-record claims?
7. As to the rest break claim, Defendant would raise standard defenses about its obligation being merely to provide breaks (rather than ensure they’re taken) and the difficulty of proving the claim on an aggregate basis. How are these defenses responsive to counsel’s allegation that Defendant had no rest break policy at all?
8. As to the reimbursement claim, Plaintiff claimed he was required to use his own vehicle for work-related travel, purchase fuel at his own expense, and purchase safety equipment and tools at his own expense. Defendant would contend that it provided company vehicles for travel, company credit cards for fuel purchases, and all necessary safety equipment and tools. What did the evidence show? Did Defendant indeed provide company vehicles, company credit cards, and all necessary equipment?
9. As to the waiting time claim, Plaintiff alleges not only a derivative waiting time claim, but the substantive failure to pay him at all for his last three days of work. As to the substantive claim, what did the evidence show? Did Defendant pay Plaintiff for his last three days or not?
10. Plaintiff’s pre-filing letter to the LWDA mentions seating violations. These do not appear to be discussed in counsel’s valuation. Since seating violations will be released by this settlement, they must be valued.
11. Please provide contemporaneously made billing records for lodestar cross-check purposes. In the event such records are unavailable, please provide a time-and-task chart that identifies all timekeepers and their claimed billing rates.
12. The notice attached to counsel’s declaration is from a different case. Please provide a notice for this case.
Does notice need to be given in any languages other than English?
4 RENTERIA vs. NEWLIGHT TECHNOLOGIES, INC.
2021-01215778
Plaintiff’s Motion for Approval of Paga Settlement
The Court has reviewed the supplemental briefing filed in response to the prior minute order. The motion for approval of the parties’ PAGA settlement is GRANTED. The Court finds the parties’ settlement is “fair, reasonable, and adequate in view of PAGA’s purposes to remediate present labor law violations, deter future ones, and to maximize enforcement of state labor laws.” (Moniz v. Adecco USA, Inc. (2021) 72 Cal.App.5th 56, 72.) The Court approves the following distributions:
1. Attorneys’ fees in the amount of $34,500, or 30% of the GSA. The Court finds this amount to be a reasonable result in light of the quality of the result obtained, the work performed by counsel, and the estimated lodestar. In approving this amount, the Court is not approving any particular hourly billing rates proposed by counsel.
2. Litigation costs in the amount of $15,000, representing the full amount sought.
3. Administration costs in the amount of $2,950, per the administrator’s bid.
4. The amount remaining is to be distributed 75% to the LWDA and 25% to the aggrieved employees as required by the version of PAGA in effect when the case was filed.
The Court declines to award an incentive payment to Plaintiff. The settlement agreement in Plaintiff’s companion FEHA action provides that approval of this PAGA settlement is a condition precedent to Defendant’s payment obligations in the FEHA settlement. In effect, the two actions have been settled together in a single, unified settlement. The amount Plaintiff will receive