Jan Hubner BC 591877

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Keith A. Fink, Bar No. 146841

Sarah E. Hernandez, Bar No. 206305
Jennifer H. Yeung, Bar No. 280819
FINK & STEINBERG
Attorneys at Law
11500 Olympic Boulevard, Suite 316
Los Angeles, California 90064
Telephone: (310) 268-0780
Facsimile: (310) 268-0790
CO1FORIvIj 1.
OF ORIGINAL FILED
To Ancl
ini-r (.t
AUG 1 9 2015
Shorn R. Carter, Executive Officer/Clerk
By: Moses Soto, Deputy
Attorneys for Plaintiff

JAN WILLEM HUBNER
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
10 JAN WILLEM HUBNER, an individual;

Plaintiff,
11
CASE NO.
AMERICAN APPAREL, INC., a

14 Delaware corporation; AMERICAN
APPAREL RETAIL, INC., a California
15 corporation; AMERICAN APPAREL
(USA), LLC, a California limited liability
16 company; AMERICAN APPAREL
MANUFACTURING, INC., a California
17 corporation; AMERICAN APPAREL
GROUP, a Delaware corporation;
18 AMERICAN APPAREL
CORPORATION, a Delaware
19 corporation; and DOES 1 to 100, inclusive,
Defendants.
21
BC 591 8 7 7
1.
WRONGFUL TERMINATION IN
VIOLATION OF PUBLIC POLICY
2.
VIOLATION OF LABOR CODE
13
20
CENTRAL DISTRICT
COMPLAINT FOR DAMAGES FOR:
vs.
12
3.
4.
5.
1102.5
VIOLATION OF LABOR CODE 201, ET SEQ.
VIOLATION OF LABOR CODE 203, ET SEQ
VIOLATION OF LABOR CODE 204(A),
ET SEQ.
6.
7.
VIOLATION OF BUSINESS & PROFESSIONS

CODE 17200, ET SEQ.
226
[JURY TRIAL DEMANDED]
22
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PlaintiffJAN WILLEM HUBNER hereby alleges as follows:

VENUE AND PARTIES
24
25
1.
relevant hereto was, a resident of the County of Los Angeles, State of California.
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27
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Plaintiff JAN WILLEM HUBNER (PLAINTIFF and/or HUBNER) is, and at all times
2.
PLAINTIFF is informed and believes, and thereon alleges, that Defendant AMERICAN
APPAREL, INC. (AMERICAN APPAREL and/or DEFENDANTS) is, and at all times
1
PLAINTIFFS COMPLAINT FOR DAMAGES
1.
relevant hereto was, a Delaware corporation doing substantial business in the County of Los
Angeles, State of California.
3.
PLAINTIFF is informed and believes, and thereon alleges that Defendant AMERICAN
APPAREL RETAIL, INC. (AMERICAN APPAREL and/or DEFENDANTS) is, and at
all times relevant hereto was, a California corporation, doing substantial business in the County
of Los Angeles, State of California.
4.
APPAREL (USA), LLC (AMERICAN APPAREL and/or DEFENDANTS) is, and at all
times relevant hereto was, a California limited liability company, doing substantial business in the
County of Los Angeles, State of California.
10
11
5.
12
APPAREL
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DEFENDANTS) is, and at all times relevant hereto was, a California corporation, doing
14
substantial business in the County of Los Angeles, State of California.
15
6.
MANUFACTURING,
INC.
(AMERICAN
APPAREL
and/or
PLAINTIFF is informed and believes, and thereon alleges that Defendant AIVIERICAN
16
APPAREL GROUP (AMERICAN APPAREL and/or DEFENDANTS) is, and at all
17
times relevant hereto was, a Delaware corporation, doing substantial business in the County of
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Los Angeles, State of California.
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7.
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APPAREL CORPORATION (AMERICAN APPAREL and/or DEFENDANTS) is, and
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at all times relevant hereto was, a Delaware corporation, doing substantial business in the
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County of Los Angeles, State of California.
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8.
PLAINTIFF is informed and believes, and thereon alleges that AMERICAN APPAREL, INC.,
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AMERICAN APPAREL RETAIL, INC., AMERICAN APPAREL (USA), LLC, AMERICAN
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APPAREL MANUFACTURING, INC., AMERICAN APPAREL GROUP, and AMERICAN
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APPAREL CORPORATION were joint employers of PLAINTIFF. AMERICAN APPAREL,
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INC., AMERICAN APPAREL RETAIL, INC., AMERICAN APPAREL (USA), LLC,
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AMERICAN APPAREL MANUFACTURING, INC., AMERICAN APPAREL GROUP, and

2
AMERICAN APPAREL CORPORATION hired employees jointly, including PLAINTIFF,
controlled PLAINTIFFS and other employees work assignments, and paid PLAINTIFFS
and other employees wages. Therefore, these entities were at all times joint employers of
PLAINTIFF.
9.
PLAINTIFF is unaware of the true names and capacities, whether individual, corporate,
associated or otherwise,
DEFENDANT DOE) inclusive, and therefore sues said Does by such fictitious names.
PLAINTIFF will seek leave of Court to amend this Complaint to show the true names and
capacities of such DOES when the same has been ascertained. PLAINTIFF is informed and
10
believes, and thereon alleges that each of the fictitiously named Defendants is responsible to
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PLAINTIFF for the injuries suffered and alleged herein, or is subject to the jurisdiction of the
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Court as a necessary party for the relief herein requested.
13
10.
of Defendants
DOES 1 through
100
(DOES
and/or
PLAINTIFF is informed and believes, and thereon alleges that AMERICAN APPAREL, INC.,
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AMERICAN APPAREL RETAIL, INC., AMERICAN APPAREL (USA), LLC, AMERICAN
15
APPAREL MANUFACTURING, INC., AMERICAN APPAREL GROUP, and AMERICAN
16
APPAREL CORPORATION are alter-egos of one another because there is such a unity of
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interest and ownership that their separate corporate personalities are merged so that one
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corporation is a mere adjunct of another and the companies form a single enterprise.
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PLAINTIFF further alleges that AMERICAN APPAREL, INC., AMERICAN APPAREL
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RETAIL,
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MANUFACTURING, INC., AMERICAN APPAREL GROUP, and AMERICAN APPAREL
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CORPORATION commingled their finds and other assets, failed to segregate the funds of the
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separate entities, allowed the diversion of corporate funds or assets to non-corporate uses,
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failed to maintain corporate minutes, failed to maintain adequate corporate records, failed to
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adhere to corporate formalities, failed to conduct transactions by and between one another at
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arms length, used the same offices and/or business locations, employed the same or largely the
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same employees, and/or failed to adequately capitalize some or all of the corporations.
INC.,
AMERICAN
APPAREL
(USA),
LLC,
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3
AMERICAN
APPAREL
11.
PLAINTIFF is informed, believes, and thereon alleges that each DEFENDANT and DOE is
now, and was at all times mentioned herein, the agent, principal, partner, officer, joint
venturer, employee or alter ego of the remaining DEFENDANTS and DOES, and that all of
the acts and conduct alleged herein were performed within the course and scope and in the
furtherance of such agency, partnership, joint venture, employment or alter ego relationship.
12.
Venue is properly laid in this Court in that the claims and injuries occurred in the County of
Los Angeles.
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GENERAL ALLEGATIONS
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13.
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HUBNER re-alleges and incorporates herein by reference, as though set forth in full herein,
and every allegation contained in Paragraphs 1 through 12, inclusive.
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Hubner s Excellent Job Performance

14.
In or around January 2006, HUBNER was hired by AMERICAN APPAREL as a Sales
15
Associate for one of its European stores. During his tenure in Europe, HUBNER excelled at
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his position and earned a promotion to the position of Merchandiser. HUBNER also worked
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as a Store Manager for A1VIERICAN APPAREL, and his duties eventually included
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overseeing the opening of new AMERICAN APPAREL stores throughout Europe.
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15.
Due to HUBNERS stellar performance and significant contributions, in or around
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16.
August 2009, AMERICAN APPAREL promoted him to Brand Manager and relocated him
to the United States.
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17.
As Brand Manager, HUBNER reported directly to the Chief Executive Officer
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18.
(CEO), DOV CHARNEY (CHARNEY), and was responsible for, but not limited to,
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overseeing the brand practices for AMERICAN APPAREL, as well as merchandising,
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hiring/recruiting, brand visuals and looks, and product development.
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19.
In or around April 2011, again due to his excellent job performance, HUBNER received
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another promotion to the position of Director of Retail Standards and Store Compliance
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(Director) which entailed him overseeing two hundred fifty stores (250) stores
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internationally to ensure compliance of AMERICAN APPARELS then high standards for
their merchandise and physical stores.
Hubners Compensation
20.
HUBNER, as Director, was to receive a One Hundred Thousand Dollar ($100,000.00) salary
per year, and entitled to yearly bonuses, some of which would be awarded in stock packages. He
also was entitled to three (3) weeks of paid vacation per year.
21.
performance for each of the years he was in that position.
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As Director, HUBNER excelled at his position and was awarded bonuses due to his
22.
AMERICAN APPARELS practices and policies, involved grossing up the amount of bonus
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monies awarded to an employee, including HUBNER, so that his or her net bonus would be an
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exact amount.
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23.
Due to his exemplary performance, in or around January 2014, HUBNER was awarded a
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grossed up bonus that was to result in a bonus in the net amount of Twenty Five Thousand
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Dollars ($25,000) in the form of a stock package. However, HUBNER never received this
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package.
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24.
In or around April 2014, HUBNER was awarded another grossed up bonus that was to result in
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a net amount of Fifty Thousand Dollars ($50,000) in the form of a stock package, which again
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he never received.
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Hubners Wrongful Termination
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25.
On or around, March 19, 2015, HUBNER complained to PAULA SCHNEIDER
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(SCHNEIDER), the then newly instituted Chief Executive Officer (CEO) of
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AMERICAN APPAREL, that he had not been paid his bonus monies and/or stock packages.
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26.
Despite HUBNERS complaint regarding his unpaid earned bonus monies and/or stock
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packages, SCHNEIDER did not take any action to arrange for the payment of HUBNERS
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delinquent bonus monies and/or stock packages.
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27.
On or about April 10, 2015, a mere twenty-two (22) days after he complained to SCHNEIDER
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regarding his unpaid bonus monies and/or stock packages with SCHNEIDER, HUBNER was
terminated without cause and without any warning, despite a lack of any previous discipline
throughout his approximately nine (9) years of employment, and in retaliation for his
complaints and/or to avoid payment of his earned wages. SCHNEIDER, to whom HUBNER
had directly reported, refused to confer with HUBNER regarding his abrupt termination.
28.
During his employment, HUBNER only took one (1) week of vacation in or around April 2014,
from the time he was first promoted to Brand Manager in 2009 until the time of his
termination.
29.
10
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At the time of HUBNERS termination, HUBNER was not compensated for his vested unused
vacation.
30.
Upon information and belief, SCHNEIDER, CRAIG SIMMONS (SIMMONS), the Chief
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Human Resources Manager, and others, are fully aware of AMERICAN APPARELS written
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policy to pay out unused accrued vacation time, but have purposefully engaged in a pattern and
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practice of failing to, and refusing to compensate for unused vacation time, pursuant to the
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company policy.
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FIRST CAUSE OF ACTION
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WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY
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(Against All DEFENDANTS and DOES 1 to 100)
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31.
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32.
It is the well-established policy of the State of California by and through its statutory and
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common laws, including but not limited to: the California Constitution, Article I,
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and Professions Code
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identified herein, that it is intolerable and unlawful for an employer to bar or to discharge a
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person from employment or to discriminate against the person in compensation and/or in
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terms, conditions, or privileges of employment in retaliation for opposing an unlawful practice
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or participating in a protected activity. California also has a fundamental, substantial, and
17200, et
and Civil Code
1770, et
8, Business
and Labor Code as
well-established public policy against retaliating against an employee for internally raising
concerns related to unlawful activities, including failure to pay earned bonuses and/or wages.
(See, e.g., Labor Code
33.
1102.5).
In contravention of these policies, HUBNER is informed, believes and thereon alleges that
DEFENDANTS retaliated against him, and terminated him because of his complaint(s)
regarding AMERICAN APPARELS failure to pay his earned bonus monies and/or stock
packages, and/or in order to avoid payment of his earned wages.
34.
DEFENDANTS actions described herein above were in violation of established public policy
against termination for participating in a protected activity, such as complaining about
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DEFENDANTS failure to properly and timely compensate him pursuant to the law and their
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own policies.
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35.
The conduct, statements and acts described herein were an ongoing part of a continuing
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scheme and course of conduct. DEFENDANTS were aware of the substance of the
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above-described facts and circumstances and ratified the wrongs and injuries mentioned herein
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when it was their ability to prevent, remedy and/or correct these wrongs.
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36.
DEFENDANTS have continued to ratifr and have refused to remedy or correct the
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aforementioned conduct during and/or since HUBNERS employment, notwithstanding the
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fact that they knew or reasonably should have known of the conduct and its unlawfulness.
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37.
As a direct and proximate result of the aforementioned violations of statute and public policy,
HUBNER has suffered and will continue to suffer:
a. A substantial reduction in past and current income, and future income
potential in sums as may be shown according to proof;
b. A substantial injury and damage to his occupation and professional reputation
in a sum as may be shown according to proof;
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c. A substantial reduction in loss of work-related benefits; and
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d. Extreme humiliation, embarrassment, depression, sleeplessness, emotional
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pain, emotional distress which culminated in physical injury and bodily injury,
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suffering, mental anguish, inconvenience, loss of enjoyment of life, and other

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losses from the date of said acts all to HUBNERS damage in a sum as may be
shown according to proof.
38.
The amount of HUBNERS damages is not presently known but he will seek leave of Court to
amend this Complaint when the exact amount of such damages has been ascertained or will
prove the same at trial.
39.
The above-recited actions of DEFENDANTS were done with malice, fraud, or oppression, and
reckless disregard of HUBNER S rights. DEFENDANTS engaged in their offensive conduct
despite their awareness of the effect on HUBNER. As a result of these and other actions,
HUBNER is entitled to an award of punitive damages.
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II
SECOND CAUSE OF ACTION
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(Against ALL DEFENDANTS AND DOES 1 TO 100)

40.
15
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1102.5
41.
California Labor Code
1102.5 provides, in part, that an employer may not retaliate against an
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employee for disclosing information, or because the employer believes that the employee
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disclosed or may disclose information, to a government or law enforcement agency, to a person
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with authority over the employee or another employee who has the authority to investigate,
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discover, or correct the violation or noncompliance...
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42.
HUBNER reasonably believed in, and complained of DEFENDANTS illegal failure to pay his
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earned bonus monies and/or stock packages to SCHNEIDER, his direct supervisor, and CEO
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of AMERICAN APPAREL.
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43.
HUBNER is informed and believes and thereon alleges that DEFENDANTS did willfully
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retaliate against him for engaging in the acts alleged herein by terminating his employment, due
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to their belief that he would report DEFENDANTS to governmental agencies.
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44.
DEFENDANTS termination of HUBNER has caused him economic and noneconomic harm
in an amount to be proven at trial, but which are in excess of the minimum jurisdiction of this
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1
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court. HUBNER S damages include, but are not limited to, loss of earnings and benefits.
45.
3
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DEFENDANTS violations subject them to civil penalties of Ten Thousand Dollars ($10,000)
per violation.
46.
HUBNER will seek attorneys fees and costs to the extent permitted by any applicable statutes
and provisions of the Labor Code.
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THIRD CAUSE OF ACTION
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(Against ALL DEFENDANTS and DOES 1-100)

47.
11
12
201, et q
48.
When DEFENDANTS unlawfully terminated HUBNERS employment on April 10, 2015
13
they failed to pay him all wages due and owing at the time of his termination, including but not
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necessarily limited to compensation for his earned, unused vacation time, and earned bonus
15
monies and/or stock packages.
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49.
Pursuant to Labor Code
201, it is unlawful for an employer to willfully fail to pay an employee
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earned wages and/or bonuses, vacation pay, and benefits due and unpaid at the time of
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termination. DEFENDANTS failed to pay HUBNER his wages and/or bonuses and vacation
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pay, and/or benefits earned and unpaid at the time of his termination.
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50.
HUBNER will seek attorneys fees incurred in prosecuting this action under Labor Code
203, 218.5, and/or 1194, et
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or any other applicable sections.
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FOURTH CAUSE OF ACTION

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51.
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203, et q
52.
DEFENDANTS failed to pay HUBNER all of his wages due and owing at the time of his
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termination. Pursuant to Labor Code
203, if an employer willfully fails to pay an employee
who is discharged his or her wages then the wages of the employee shall continue as a penalty
from the due date thereof at the same rate until paid...
53.
DEFENDANTS have continuously and willfully failed to pay HUBNER his due and unpaid
wages. More than thirty (30) days have past since HUBNER was terminated by
DEFENDANTS, yet all of his wages have still not been paid to him.
54.
As a consequence of DEFENDANTS willful conduct in not paying HUBNER all wages due
upon termination, he is entitled to thirty (30) days of wages as penalty wages under Labor Code
203, together with interest thereon.
10
55.
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203, 218.5, and/or 1194, et
or any other applicable sections.
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FIFTH CAUSE OF ACTION
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204(a)
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[Failure to Pay Earned Bonus]
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56.
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57.
DEFENDANTS conduct is in violation of Labor Code
204(a) which provides that all wages
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earned by a person during their employment are due and payable twice a month on the regular
21
paydays as designated in advance by the employer, and such wages include bonuses.
22
58.
During HUBNERS employment with DEFENDANTS, he earned monetary bonuses based on
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his job performance. Plaintiff performed all duties necessary to earning this bonus, and
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DEFENDANTS terminated him prior to paying HUBNER all of his earned bonus monies,
25
despite his previous requests for said payment. Upon information and belief, DEFENDANTS
26
terminated HUBNER, in retaliation for engaging in protected activity and also to avoid paying
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earned bonuses.
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59.
The exact amount of bonus monies earned by HUBNER is unknown, but is a minimum of
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Seventy Five Thousand Dollars ($75,000.00) of net bonus monies and/or stock packages.
HUBNER will seek leave of the Court to include such monies in his damages calculation, and
to amend this Complaint, as necessary.
60.
As such, HUBNER is entitled to receive from DEFENDANTS the full amount of any earned
bonus monies, and well as interest until paid in full.
6
7
SIXTH CAUSE OF ACTION
10
61.
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226 Ct g
62.
Pursuant to Labor Code
226 et
an employer is required to provide accurate wage
13
statements in writing, which includes a wage statement reflecting HUBNERS earned bonus
14
monies which were never paid, and accrued and earned vacation pay.
15
63.
16
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During his employment with DEFENDANTS, they failed to provide an accurate accounting of
HUBNERS earned monies and failed to pay same.
64.
As a result of the conduct of DEFENDANTS and DOES, HUBNER sustained damages and is
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entitled to additional pay in an amount to be determined and presented at the time of trial, and
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at a minimum in a combined excess of the jurisdiction of the Superior Court and Plaintiff is
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entitled to damages pursuant to Labor Code
21
65.
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226.7.
1194 et
and any other applicable code sections.
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SEVENTH CAUSE OF ACTION

VIOLATION OF BUSINESS & PROFESSIONS CODE
25
26
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17200, et q

66.
11
67.
California Business and Professions Code
17200, et q, provides that unfair competition
shall mean and include all unlawful, unfair or fraudulent business act or practices and unfair,
deceptive, untrue or misleading advertising.
68.
PLAINTIFF is informed and believe and thereon alleges that DEFENDANTS have engaged in
unfair competition in violation of California Business and Professions Code
maintaining a workplace rife with retaliation and violations of established California public
policy including but not limited to the following: California Constitution, Article I,
Code
maintenance of such unfair business practices allows DEFENDANTS to maintain an unfair
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advantage over other companies that comply with established California laws and the public
11
policy of the state of California, and personally harmed and injured monetarily or otherwise,
12
PLAINTIFF.
69.
13
14
70.
8, Civil
and the above-referenced California Labor Code provisions. The
DEFENDANTS fall within the definition of person as set forth at Business and Professions
Code
15
1770, et
17200, et q, by
17203 and 17506.
The unlawful, unfair, and fraudulent business practices of DEFENDANTS described above
16
present a continuing threat to members of the public in that DEFENDANTS have or will soon
17
engage in the conduct described above and members of the public are likely to be deceived
18
when they pursue or gain employment with DEFENDANTS. Pursuant to California Business
19
and Professions Code
20
71.
Provides injunctive and declaratory relief finding that DEFENDANTS have violated the
provisions of California Business and Professions Code
21
22
17203, PLAINTIFF seeks an order from this Court that:
72.
17200, et q; and
For an order enjoining DEFENDANTS and their respective successors, agents, servants,
23
officers, directors, employees, and all other persons acting in concert with them, directly or
24
indirectly, from engaging in conduct which violates California Business and Professions Code
25
17200,etq
26
27
28
/
12
PRAYER FOR RELIEF
2
3
WHEREFORE, PLAINTIFF prays for judgment against DEFENDANTS, and each of them,
as follows:
1.
For general, special, actual, compensatory and/or nominal damages, including prejudgment
interest, in an amount to be determined at trial, but no less than five hundred thousand
dollars ($500,000.00);
2.
For lost salary, both front and back pay, unpaid wages, bonuses, stock entitlements,
vacation pay, severance pay and any other benefits to which PLAINTIFF would have
been entitled to by reason of his employment with defendants, according to proof, but no
10
11
less than five hundred thousand dollars ($500,000.00);

3.
For punitive damages in an amount to be determined at trial sufficient to punish penalize
12
and/or deter DEFENDANTS, and each of them, from further engaging in the conduct
13
described herein, and to deter others from engaging in the same or similar acts;
14
4.
For appropriate civil and statutory penalties;
15
5.
For restitution and/or disgorgement of all ill-gotten gains (on the Seventh Cause of Action
16
17
only);
6.
For preliminary and permanent injunction against DEFENDANTS from the acts of unfair
competition as described in the Seventh Cause of Action;
18
19
7.
For reasonable costs and attorneys fees where appropriate;
20
8.
For pre- and postjudgment interest on all damages and other relief awarded herein from all
entities against whom such relief may be properly awarded; and
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9.
For all such other relief as this Court deems just and appropriate.
23
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Dated: August 19, 2015
FINK & STEINBERG
25
26
7 4
By:
Keith A. Fink
Sarah E. Hernandez
Jennifer H. Yeung
Attorneys for Plaintiff
JAN WILLEM HUBNER
27
28
13
CM-O1 0
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address).
FOR COURT USE ONLY
Jennifer H. Yeung SBN 280819

Fink & Steinberg
11500 Olympic Boulevard, Suite 316
(310) 268-078Q
FAX NO. (310) 268-0790
1aintiff Jan Willem Hubner
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles
STREET ADDRESS: 111 North Hill
Street
MAIUNG ADDRESS: 111 North Hill Street
C1TYANDZIPCODE: Los Angeles, California 90012
BRANCH NAME: Central District
CONFORN1iij
TELEPHONE NO..
ATTORNEY FOR (Name):
ur i
OF ORIGINAL FILED
nc
\ncepIm
AUG1 92015
Shorn H. Carter, Executive Officer/Clerk
By: Moses Soto, Deputy
CASE NAME:
Hubner v. American Apparel, Inc., et al.

CIVIL CASE COVER SHEET
Unlimited
El
CASE NUMBER:
Complex Case Designation
Limited
El
BC 5 9 1 8 7 7
El
Counter
Joinder
(Amount
JUDGE
demanded is
Filed with first appearance by defendant
$25,000 or less)
(Cal. Rules of Court, rule 3402)
DEPT:
Items 16 below must be completed (see instructions on page 2).
1 Check one box below for the case type that best describes this case:
Auto Tort
Contract
Provisionally Complex Civil Litigation
(Cal. Rules of Court, rules 3.4003.403)
Auto (22)
Breach of contract/warranty (06)
Uninsured motorist (46)
Rule 3.740 collections (09)
Antitrust/Trade regulation (03)
Other Pl/PDIWD (Personal InjurylProperty
Other collections (09)
Construction defect (10)
DamagelWrongful Death) Tort
Insurance coverage (18)
Mass tort (40)
Asbestos (04)
Other contract (37)
Securities litigation (28)
Product liability (24)
Real Property
Environmental/Toxic tort (30)
Medical malpractice (45)
Eminent domain/Inverse
Insurance coverage claims arising from the
condemnation (14)
Other PI/PDIrND (23)
above listed provisionally complex case
types (41)
Wrongful eviction (33)
Non-PIIPD/WD (Other) Tort
Other real property (26)
Enforcement of Judgment
Business tort/unfair business practice (07)
Civil rights (08)
Unlawful Detainer
Enforcement of judgment (20)
Defamation (13)
Commercial (31)
Miscellaneous Civil Complaint
Fraud (16)
Residential (32)
RICO (27)
Intellectual property (19)
Drugs (38)
Other complaint (not specified above) (42)
Professional negligence (25)
Judicial Review
Miscellaneous Civil Petition
Other non-PI/PD/WD tort (35)
Asset forfeiture (05)
Partnership and corporate govemance (21)
Employment
Petition re: arbitration award (11)
Other petition (not spec/fled above) (43)
Wrongful termination (36)
Writ of mandate (02)
Other employment (15)
Other judicial review (39)
2. This case
is
is not
complex under rule 3.400 of the California Rules of Court. If the case is complex, mark
the
factors requiring exceptional judicial management:
Large number of separately represented parties
a.
d.
Large number of witnesses
b.
Extensive motion practice raising difficult or novel
e.
Coordination with related actions pending in one or more courts
issues that will be time-consuming to resolve
in other counties, states, or countries, or in a federal court
Substantial amount of documentary evidence
c.
f.
Substantial postjudgment judicial supervision
(Amount
demanded
exceeds $25000)
El
El
El
El
El
El
El
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5.
6.
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a.LZI
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b. EZI nonmonetary; declaratory or injunctive relief
Remedies sought (check all that apply):

monetary
Number of causes of action (specify): Seven (7)
This case
is
is not
a class action suit.
If there are any known related cases, file and serve a notice of related case. (You may use form CM-015.)
El
C.
L71 punitive
ELI
Date: August 19, 2015

Jennifer H. Yeung, SBN 280819
(TYPE OR PRINT NAME)
NOTICE
(SIGNATURE OF PARTY O ATTORNEY OR PARTY)
Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or
cases filed
under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to
file may result
in sanctions.
File this cover sheet in addition to any cover sheet required by local court rule.
If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover
sheet on all
other parties to the action or proceeding.
Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes
only.
Form Adopted for Mandatory Use
Judicial Council of California
CM-010 [Rev July 1, 2007)
CIVIL CASE COVER S H EET
Page 1 012
Cal Rules of Court, rules 2.30, 3220. 3.4003.403, 3740;
Cal Standards of Judicial Administration, std 3.10
www.courtinfo.ca.gov
CM-O10
INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET
To Plaintiffs and Others Filing First Papers. If you are filing a first paper (for example, a complaint) in a civil case, you must
complete and file, along with your first paper, the Civil Case Cover Sheet contained on page 1. This information will be used to compile
statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1, you must check
one box for the case type that best describes the case. If the case fits both a general and a more specific type of case listed in item 1,
check the more specific one. If the case has multiple causes of action, check the box that best indicates the primary cause of action.
To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 are provided below. A cover
sheet must be filed only with your initial paper Failure to file a cover sheet with the first paper filed in a civil case may subject a party,
its counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court.
To Parties in Rule 3.740 Collections Cases. A collections case under rule 3.740 is defined as an action for recovery of money
owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorneys fees, arising from a transaction in
which property, services, or money was acquired on credit. A collections case does not include an action seeking the following: (1) tort
damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of
attachment. The identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general
time-for-service requirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections
case will be subject to the requirements for service and obtaining a judgment in rule 3.740,
To Parties in Complex Cases. In complex cases only, parties must also use the Civil Case Cover Sheet to designate whether the
case is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by
completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover sheet must be served with the
complaint on all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in the
plaintiffs designation, a counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation that
the case is complex.
CASE TYPES AND EXAMPLES
Auto Tort
Auto (22)Personal Injury/Property
Damage/Wrongful Death
Uninsured Motorist (46) (if the
case involves an uninsured
motorist claim subject to

arbitration, check this item
instead of Auto)
Other PIIPDIWD (Personal lnjuryl
Property DamagelWrongful Death)
Tort
Asbestos (04)
Asbestos Property Damage
Asbestos Personal lnjury/
Wrongful Death
Product Liability (not asbestos or
toxic/environmental) (24)
Medical Malpractice (45)
Medical Malpractice
Physicians & Surgeons
Other Professional Health Care
Malpractice
Other Pl/PDAND (23)
Premises Liability (e.g.. slip
and fall)
Intentional Bodily lnjury/PDNVD
(e.g., assault, vandalism)
Intentional Infliction of
Emotional Distress
Negligent Infliction of
Emotional Distress
Other Pl/PDIWD
Non-Pl/POIWD (Other) Tort
Business Tort/Unfair Business

Practice (07)
Civil Rights (e.g., discrimination,
false arrest) (not civil
harassment) (08)
Defamation (e.g., slander, libel)
(13)
Fraud (16)
Intellectual Property (19)
Professional Negligence (25)
Legal Malpractice
Other Professional Malpractice
(not medical or legal)

Other Non-Pl/PDJIND Tort (35)
Employment
Wrongful Termination (36)
Other Employment (15)
cM-O1o [Rev. July 1, 2007]
Contract
Breach of Contract/Warranty (06)
Breach of Rental/Lease
Contract (not unlawful detainer

or wrongful eviction)
Contract/Warranty BreachSeller
Plaintiff (not fraud or negligence)

Negligent Breach of Contract/
Warranty
Other Breach of ContractNVarranty
Collections (e.g., money owed, open
book accounts) (09)
Collection CaseSeller Plaintiff
Other Promissory Note/Collections
Case
Insurance Coverage (not provisionally
complex) (18)
Auto Subrogation
Other Coverage
Other Contract (37)
Contractual Fraud
Other Contract Dispute
Real Property
Eminent Domain/Inverse
Condemnation (14)
Wrongful Eviction (33)
Other Real Property (e.g.. quiet title) (26)
Writ of Possession of Real Property
Mortgage Foreclosure
Quiet Title
Other Real Property (not eminent
domain, landlord/tenant, or
foreclosure)
Unlawful Detainer
Commercial (31)
Residential (32)
Drugs (38) (if the case involves illegal

drugs, check this item: othe,wise,
report as Commercial or Residential)
Judicial Review
Asset Forfeiture (05)
Petition Re: Arbitration Award (11)
Writ of Mandate (02)
WritAdministrative Mandamus
WritMandamus on Limited Court
Case Matter
WritOther Limited Court Case
Review
Other Judicial Review (39)
Review of Health Officer Order
Notice of AppealLabor
Commissioner Aooeals
CIVIL CASE COVER SHEET
Provisionally Complex Civil Litigation (Cal.

Rules of Court Rules 34003.403)
Antitrust/Trade Regulation (03)
Construction Defect (10)
Claims Involving Mass Tort (40)
Securities Litigation (28)
Environmental/Toxic Tort (30)
Insurance Coverage Claims
(arising from provisionally complex

case type listed above) (41)
Enforcement of Judgment
Enforcement of Judgment (20)
Abstract of Judgment (Out of
County)
Confession of Judgment (non-
domestic relations)
Sister State Judgment

Administrative Agency Award
(not unpaid taxes)

Petition/Certification of Entry of
Judgment on Unpaid Taxes
Other Enforcement of Judgment
Case
Miscellaneous Civil Complaint
RICO (27)
Other Complaint (not specified
above) (42)
Declaratory Relief Only

Injunctive Relief Only (non-
harassment)
Mechanics Lien
Other Commercial Complaint
Case (non-tort/non-complex)
Other Civil Complaint
(non-tort/non-complex)
Miscellaneous Civil Petition
Partnership and Corporate
Governance (21)
Other Petition (not specified
above) (43)
Civil Harassment
Workplace Violence
Elder/Dependent Adult
Abuse
Election Contest
Petition for Name Change
Petition for Relief From Late
Claim
Other Civil Petition
Page 2 of 2
rsH0RTTTLE:
CASE NUMSER
CIVIL CASE COVER SHEET ADDENDUM AND

STATEMENT OF LOCATION
(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)
This form is required pursuant to Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court.
Item I. Check the types of hearing and fill in the estimated length of hearing expected for this case:
JURYTRIAL?
YES
CSSACTION?
YES LIMITEDCASE?
DYES
Item II. Indicate the correct district and courthouse location (4 steps
D HOURS/H DAYS
7
6
TIMEESTIMATEDFORTRIAL
If you checked Limited Case, skip to Item Ill, Pg. 4):
Step 1: After first completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your
case in the left margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected.
Step 2: Check one Superior Court type of action in Column B below which best describes the nature of this case.
Step 3: In Column C, circle the reason for the court location choice that applies to the type of action you have
checked. For any exception to the court location, see Local Rule 2.0.
Applicable Reasons for Choosing Courthouse Location (see Column C below)

1.
2.
3.
4.
5.
Class actions must be filed in the Stanley Mosk Courthouse, central district.
May be filed in central (other county, or no bodily injury/property damage).
Location where cause of action arose.
Location where bodily injury, death or damage occurred.
Location where performance required or defendant resides.
6.
7.
8.
9.
10.
Location
Location
Location
Location
Location
of property or permanently garaged vehicle.

where petitioner resides.
wherein defendant/respondent functions wholly.
where one or more of the parties reside.
of Labor Commissioner Office
Step 4: Fill in the information requested on page 4 in Item Ill; complete Item IV. Sign
A
Civil Case Cover Sheet

Category No.
Type of Action
(Check only one)
Auto (22)
.s.t
<I
Uninsured Motorist (46)
Asbestos (04)
>
Product Liability (24)
C
Applicable Reasons
See Step 3 Above
Personal Injury/Property Damage/Wrongful Death
A71 10 Personal Injury/Property Damagef\Nrongful Death
Uninsured Motorist
C A6070 Asbestos Property Damage

A7221 Asbestos
1., 2., 4.
Personal Injury/Wrongful Death
El A7260 Product Liability (not asbestos or toxic/environmental)
1., 2., 4.
2.
2.
1., 2., 3.. 4., 8.
C)
Medical Malpractice (45)
El
A7210 Medical Malpractice
Physicians & Surgeons
El A7240 Other Professional Health Care Malpractice
C)
El
El
0
C)
0-I
El A7100 Motor Vehicle
the declaration.
El A7250 Premises Liability (e.g., slip and fall)
C)
cl)E
Persinjury
Property Damage
Wrongful Death
(23)
LACIV 109 (Rev. 03/11)

LASC Approved 03-04
El
A7230 Intentional Bodily Injury/Property Damage/Wrongful Death (e.g.,

assault, vandalism, etc.)
1., 4.
1., 4.
1
4.
1. 4
El A7270 Intentional Infliction of Emotional Distress
1., 3.
El
A7220 Other Personal Injury/Property Damage/Wrongful Death
CIVIL CASE COVER SHEET ADDENDUM

AND STATEMENT OF LOCATION
Local Rule 2.0
Page 1 of 4
rsH0RTT1TLE

Category No.
Type of Action
(Check only one)
Business Tort (07)

1;;
Hubner v. American Apparel, Inc., etal.
El
C
Applicable Reasons
See Step 3 Above
A6029 Other Commercial/Business Tort (not fraud/breach of contract)
1. 3.
ci)
Civil Rights (08)
El A6005 Civil Rights/Discrimination
1., 2.. 3.
Defamation (13)
El
A6010 Defamation (slander/libel)
1., 2., 3.
Fraud (16)
El
A6013 Fraud (no contract)
1., 2.. 3.
2.0)
0
ci)
Q cci
El
A6017 Legal Malpractice
1., 2., 3.
El
A6050 Other Professional Malpractice (not medical or legal)
1., 2., 3.
Other (35)
El
A6025 Other Non-Personal Injury/Property Damage tort
2.3.
Wrongful Termination (36)
ll
A6037 Wrongful Termination
El
A8024 Other Employment Complaint Case
1.. 2., 3.
El
A6109 Labor Commissioner Appeals
10.
El
A6004 Breach of Rental/Lease Contract (not unlawful detainer or wrongful

eviction)
Professional Negligence (25)
occi
ci)
>
0
0
Other Employment (15)
LU
Breach of Contract! Warranty

(06)
(not insurance)
2 5
A6008 Contract/Warranty Breach -Seller Plaintiff (no fraud/negligence)
El
A601 9 Negligent Breach of Contract/Warranty (no fraud)
1., 2., 5.
El
A6028 Other Breach of Contract/Warranty (not fraud or negligence)
1., 2., 5.
El
A6002 Collections Case-Seller Plaintiff
2., 5., 6.
El
A6012 Other Promissory Note/Collections Case
2.. 5.
El
A6015 Insurance Coverage (not complex)
1,, 2,, 5.. 8.
El
A6009 Contractual Fraud
1., 2., 3., 5.
El
A6031 Tortious Interference
1., 2., 3., 5.
El
A6027 Other Contract Dispute(not breach/insurance/fraud/negligence)
1., 2., 3.. 8.
Eminent Domain/Inverse
Condemnation (14)
El
A7300 Eminent Domain/Condemnation
2.
Wrongful Eviction (33)
El
A6023 Wrongful Eviction Case
El
A6018 Mortgage Foreclosure
2.. 6.
El
A6032 Quiet Title
2.. 6.
El
A6060 Other Real Property (not eminent domain, landlord/tenant, foreclosure)
2.. 6.
El
A6021
Unlawful Detainer-Commercial (not drugs or wrongful eviction)
2., 6.
El
A6020 Unlawful Detainer-Residential (not drugs or wrongful eviction)
2. 6.
Unlawful DetainerPost-Foreclosure (34)
El
A6020F Unlawful Detainer-Post-Foreclosure
2., 6.
Unlawful Defamer-Drugs (38)
El
A6022 Unlawful Detainer-Drugs
2., 6.
ci
El
Collections (09)
0
C.)
Insurance Coverage (18)
Other Contract (37)
a)
.J 3.
Number of parcels______
2., 6.
0
ci
ci)
Other Real Property (26)
Unlawful Deti;,r-Commercial
ci)
cci
a)
Unlawful Detainer-Residential
cci
=
LACIV 109 (Rev. 03/11)

LASC Approved 03-04

Local Rule
2.0
Page 2 of 4
SHORT TITLE:
CASE NUMBER

Category No.
Type of Action
(Check only one)
Applicable Reasons
See Step 3 Above
Asset Forfeiture (05)

Petition re Arbitration (11)
Writ of Mandate (02)
-o
-)
Other Judicial Review (39)

Antitrust/Trade Regulation (03)
2
2
Construction Defect (1 0)
Claims lnvoMng Mass Tort
El A6108 Asset Forfeiture Case
2., 6.
0 A61 15 Petition to Compel/ConfirmNacate Arbitration
2., 5.
El
A6151 Writ-Administrative Mandamus
2., 8.
El
A6152 Writ
2.
El
A61 53 Writ Other Limited Court Case Review
2.
El
A6150 Other Writ /Judicial Review
2., 8.
Mandamus on Limited Court Case Matter
El A6003 Antitrust/Trade Regulation
1., 2.. 8.
El
1., 2., 3.
A6007 Construction Defect
El A6006 Claims Involving Mass Tort
1., 2., 8.
El A6035 Securities Litigation Case
1., 2., 8.
Toxic Tort
Environmental (30)
El
A6036 Toxic Tort/Environmental
1., 2., 3., 8.
Insurance Coverage Claims

from Complex Case (41)
El
A6014 Insurance Coverage/Subrogation (complex case only)
1., 2., 5., 8.
0
C-,
Securities Litigation (28)
:
>
EE
0,
LU
Enforcement
of Judgment (20)
RICO (27)
r1
U)
SC-)
Other Complaints
(Not Specified Above) (42)
C-.,
Partnership Corporation
Governance (21)
In
2., 9.
El
A6160 Abstract of Judgment
2., 6.
El
A6107 Confession of Judgment (non-domestic relations)
..
>
Other Petitions
(Not Specified Above)
(43)
2., 9.
El A6140 Administrative Agency Award (not unpaid taxes)
2., 8.
El
A6114 Petition/Certificate for Entry of Judgment on Unpaid Tax
2., 8.
El
A61 12 Other Enforcement of Judgment Case
2., 8., 9.
El
A6033 Racketeering (RICO) Case
1.. 2., 8.
El
A6030 Declaratory Relief Only
1., 2.. 8.
A6040 Injunctive Relief Only (not domestic/harassment)
2.. 8.
A601 1 Other Commercial Complaint Case (non-tort/non-complex)
1.. 2., 8.
El
A6000 Other Civil Complaint (non-tort/non-complex)
1., 2., 8.
El
A61 13 Partnership and Corporate Governance Case
2.. 8.
A6121 Civil Harassment
2.. 3., 9.
El
A6123 Workplace Harassment
2.. 3., 9.
El
A6124 Elder/DependentAdultAbuseCase
2., 3., 9.
El
A6190 Election Contest
2.
El
A61 10 Petition for Change of Name
2.. 7.
El
A6170 Petition for Relief from Late Claim Law
2., 3., 4.. 8.
A6100 Other Civil Petition
2., 9.
In
U)
El A6141 Sister State Judgment
LACIV 109 (Rev. 03/11)
LASC Approved 03-04
Local Rule 2.0

Page 3 of 4
SHORT 11TLE:
CASE NUMBER
Item III. Statementof Location: Entertheaddressoftheaccident, partys residenceorplaceof business, performance, orother
circumstance indicated in Item II. Step 3 on Page 1, as the proper reason for filing in the court location you selected.
ADDRESS:
REASON: Check the appropriate boxes for the numbers shown

under Column C for the type of action that you have selected for
this case.
747 Warehouse St.
[11. [12. [13. [14. [15. [16. [17. [18. [19. [110.
CITY
STATE
Los Angeles
CA
Item IV. Declaration of Assignment I declare under
ZIP CODE
90021
penalty of perjury under the laws of the State of California that the foregoing is true
and correct and that the above-entitled matter is properly filed for assignment to the Stanley Mosk
Central
District of the Superior Court of California, County of Los Angeles [Code Civ. Proc.,
Rule 2.0, subds. (b), (c) and (d)j.
courthouse in the
392 et seq., and Local
/)
Dated: August 19, 2015
(SIGNAPURE OF 6
ATTORNEYIFILING
ARTY)
PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY
COMMENCE YOUR NEW COURT CASE:
1.
Original Complaint or Petition.
2.
If filing a Complaint, a Completed Summons form for issuance by the Clerk.
3.
Civil Case Cover Sheet, Judicial Council form CM-010.
4.
Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev.
03/11).
5.
Payment in full of the filing fee, unless fees have been waived.
6.
A signed order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plaintiff or petitioner is a
minor under 18 years of age will be required by Court in order to issue a summons.
7.
Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum
must be served along with the summons and complaint, or other initiating pleading in the case.
LACIV 109 (Rev. 03/11)

LASC Approved 03-04

Local Rule 2.0

Page 4 of 4
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

NOTICE OF CASE ASSIGNMENT UNLIMITED CIVIL CASE (NON-CLASS ACTION)
Case Number
-
BC5 9187?
THIS FORM IS TO BE SERVED WITH THE SUMMONS AND COMPLAINT

Your case is assigned for all purposes to the judge indicated below.
There is more information on the reverse side of this form.
ASSIGNED JUDGE
DEPT
ROOM
ASSIGNED JUDGE
DEPT
ROOM
Hon. Elizabeth Allen White
48
506
636
Lion. Deirdre Hill
49
509
14
300
Hon. John L. Segal
50
508
Hon. Richard Fruin
15
307
lion. Mitchell L. Heckloff
51
511
Hon. Rita Miller
16
306
Hon. Susan Bryant-Deason
52
510
Hon. Richard E. Rico
17
309
Hon. Steven J. Klemfield
53
513
Hon. Stephanie Bowick
19
311
Hon. Ernest M. Hiroshige
54
512
Hon. Dalila Corral Lyons
20
310
Hon. Malcolm H. Mackey
55
515
Hon. Robert L.Hess
24
314
Hon. Michael Johnson
56
514
Hon. Yvette M. Palazuelos
28
318
Hon. Rolf M. Tree
58
516
Hon. Barbara Scheper
30
400
Hon. Gregory Keosian
61
732
Hon. Samantha Jessner
31
407
Hon. Michael L. Stern
62
600
Hon. Mary H. Strobel
32
406
Hon. Mark Mooney
68
617
Hon. Michael P. Linfleld
34
408
Hon. William F. Fahey
69
621
Hon. Gregory Alarcon
36
410
Hon. Suzanne G. Bruguera
71
729
Hon. Marc Marmaro
37
413
Hon. Ruth Ann Kwan
72
731
Hon. Maureen Daffy-LewIs
38
412
Hon. Rafael Ongkeko
73
733
Hon. Elizabeth Fetter
39
415
Hon. Teresa Sanchez-Gordon
74
735
Hon. Michelle R. Rosenblatt
40
414
Hon. Gall Ruderman Feuer
78
730
Hon. Holly E. Kendig
42
416
Hon. Mel Red Recana
45
529
Hon. Emile H. Ellas
324
CCW
*provbionaily Complex
Non-class Action Cases
Assignment is Pending
Complex Determination
324
CCW
Hon. Kevin C. Brazile
534
Hon. Barbara A. Meiers
12
Hon. Terry A. Green
Hon. Frederick C. Sheller
46
500
Hon. Debre K. Weintraub
47
507
*ComDiex
All non-class action cases designated as provisionally complex are forwarded
to the Supervising Judge of the Complex Litigation Program
located in the Central Civil West Courthouse (600 S. Commonwealth
Ave., Los Angeles 90005), for complexlnon-complex determination
pursuant to Local Rule 3.3(k). ThIs procedure is for the purpose of
assessing whether or not the case Is complex within the meaning of
California Rules of Court, rule 3.400. Depending on the outcome of
that assessment, the case may be reassigned to one of the judges of the
Complex Litigation Program or reassigned randomly to a court in the
Central District
Given to the Plalntiff/Cross-ComplainantlAttorney of Record
on
SHEFIRI R. CAc1TER
LACIV CCH 190 (Rev. 04115)
LASC Approved 05-06
SHERRI R. CARTER, Executive OfficeriClerk
M. Soto
By
NOTICE OF CASE ASSIGNMENT

UNLIMITED CIVIL CASE
Deputy Clerk
Page I of 2
INSTRUCTIONS FOR HANDLING UNLIMITED CIVIL CASES

The following critical provisions of the Chapter Three Rules, as applicable in the Central District, are summarized
for your assistance.
APPLICATION
The Chapter Three Rules were effective January 1, 1994. They apply to all general civil cases.
PRIORITY OVER OTHER RULES

The Chapter Three Rules shall have priority over all other Local Rules to the extent the others are inconsistent.
CHALLENGE TO ASSIGNED JUDGE
A challenge under Code of Civil Procedure section 170.6 must be made within 15 days after notice of assignment for
all purposes to
judge, or if a party has not yet appeared, within 15 days of the first appearance.
TIME STANDARDS
Cases assigned to the Individual Calendaring Court will be subject to processing under the following time standards:
COMPLAINTS: All complaints shall be served within 60 days of filing and proof of service shall be filed within 90 days
of filing.
CROSS-COMPLAINTS: Without leave of court first being obtained, no cross-complaint may be filed by any party after
their answer i
filed. Cross-complaints shall be served within 30 days of the filing date and a proof of service filed within 60 days of the filing
date.
A Status Conference will be scheduled by the assigned Independent Calendar Judge no later than 270 days after the
filing of the complaint
Counsel must be fully prepared to discuss the following issues: alternative dispute resolution, bifurcation, settlement,
trial date, and exper
witnesses.
FINAL STATUS CONPERENCE
The Court will require the parties at a status conference not more than 10 days before the trial to have timely filed and
served all motiom
in limine, bifurcation motions, statements of major evidentiary issues, dispositive motions, requested jury instructions,
and special jury
instructions and special jury verdicts. These matters may be heard and resolved at this conference. At least
5 days before this conference
counsel must also have exchanged lists of exhibits and witnesses and have submitted to the court a brief statement
of the case to be read to
the jury panel as required by Chapter Eight of the Los Angeles Superior Court RuLes.
SANCTIONS
The court will impose appropriate sanctions for the failure or refusal to comply with Chapter Three Rules, orders made
by the Court, and
time standards or deadlines established by the Court or by the Chapter Three Rules. Such sanctions may be on party
a
or if appropriate on
counsel for the party.
This is not a complete delineation of the Chapter Three Rules, and adherence only to the above provisions
is therefore not a
guarantee against the Imposition of sanctions under Trial Court Delay Reduction. Careful reading
and compliance with the
actual Chapter Rules I absolutely Imperative.
LACIV CCH 190 (Rev. 04115)

LASC Approved 05-06
NOTICE OF CASE ASSIGNMENT

UNLIMITED CML CASE
Page 2 of 2
VOLUNTARY EFFICIENT LITIGATIO STi

N
PULATIONS
Supedor Cau,t of California

County of ias Angeles
Lou Mgi.s County

SAouodlon
S.cUun
Los AngeI County
B Msodlon Labor id
The Early Organizational Meeting Stipulation Disc

overy
.
Resolution Stipulation, and Motions in Limine Stip
ulation are
voluntary stipulations entered into by the parties
. The parties
may enter into one, two, or all three of
the stipulations;
however, they may not alter the stipulat
ions as written,
because the Court wants to ensure uniformity
of application.
These stipulations are meant to encour
age cooperation
between the parties and to assist in resolvin
g issues in a
manner that promotes economic case reso
lution and judicial
efficiency.
6;;
II
, .11
Caouu
Munclon of 1.oi MgiIs
14ibs C.II..Ja
The following organizations endorse the goal of

promoting efficiency in litigation and ask
that counsel
consider using these stipulations as a volunt
aiy way to
promote communications and procedures amo
ng counsel
and with the court to fairly resoWe issues in thei cas
r
es.
Los Angeles County Bar Association Litigati
on Sectlofl
tc
J_
1
Los Angeles County Bar Association

Labor and Employment Law Sectlon
Ausodon of
BihwosTiW Loueiu
Consumer Attorneys Association of Los Ang
eles
Southem California Defense Counsel

Assoclation of Business Trial Lawyers
Califomla Employment Lawyers AssoclatIon
LP4N 230 QE
fWyed 4-11
\haEAMAooPEss OF AttOY
OR PMTY VdfliOUt A1IORNEY:
1?iEPI-iONE NO.:
EUP$L ADDRESS (Ocni):
ATTORNEY FOR (Nap.):
STATE SN tS*ISEN
R$Id
F. 2
FAX NO. (OpIoa):
SUPERIOR COURT OF CALIFORNIA, CO

UNTY OF LOS ANGELES
[COURThOUSE ADDRESS:
\_PJJNT1FF:
ptrqu,vs I;
STIPULATION
CASEffiE
DISCOVERY RESOLUTION
This stipulation Is Intended to provide

a fast and Informal resolution of discove
ry Issues
through limited paperwork and an
Informal conference with the Court
to aid In the
resolution of the Issues.
The parties agree that
1, Prior to the discovery cut-off in this acti
on,
the moving party first makes a written req no discovery motion shall be flied Or heard unless
uest for an Informal Discovery Conference
to the temis of this stipulation.
pursuant
V
2. At the Informal Discovery Conference

the
and determine whether it ca be resolved Court will consider the dispute presented by parties
party from maldng a record at the con informally. Nothing set forth herein will preclude a
clusion of an Informal Discovery Confere
orally orlnwrlling.
nce, either
3. Following a reasonable and good faith

atte
presented, a party may request an Info mpt at an informal resolution of each issue to be
rmal Discovery Conference pursuant to
procedures:
the following
a. The party requesting the Informal
Dis
covery Conference will:

V
I.
File a Request for Infonnal Discov

ery
approved form (copy attached) and Coflference with the clerWs office on the
deliver a courtesy onformed copy to the
goed dspa
V
ii.
Indude a brief summary of the dispute

and spe
cify the relief requested; and
ill.
Serve the opposing party pursuant

that ensures that the opposing par to any authorized or agreed method of service
ty receives the Request for Informal Discov
ery
Conference no later than the next cou
rt day following the lWng.
b. Any Answer to a Request for Informa
l Discovery Conference must
I. Also be filed on the approved farm
(copy attached);
ii.
Indude a brief summary of why the

requested
LM3NO3SSWI
LASC pimd 04111
FrOpIa.U.e
STIPULATION
rehef should be denied;
DiSCOVERY RESOLUTiON
P1ct3
FnftE
iii.
iv.
Be filed within two (2) court days of receipt of

the Request: and
Be served on the opposing party pursuant
to any authorized or agreed upon
method of service that ensures that the
opposing party receives the Answer no
later than the next court day following the filin
g.
c. No other pleadings, including but not limited

to exhibits, dedarations, or attachments, will
be accepted.
d. If the Court has not granted or denied the
Request for Informal Discovery Conference
within ten (10) days following the filing of
the Request, then it shall be deemed to have
been denied., If the Court acts on the Req
uest, the parties will be notified whether the
Request for informal Discovery Conference
has been granted or denied and, if granted.
the date and time of the Informal Discovery
Con1erence which must be within twenty (20)
days of the filing of the Request for Informal
Discovery Conference.
e. If the conference Is not held Within twenty
Informal Discovery Conference, unless exte (20) days of the filing of the Request for
nded by agreement of the parties and the
Court, then the Request for the Informal
Discovery Conference shall be.deemed to have
been denied at that time.
4. If (a) the Court has denied a conference
or (b)
without the Court having acted or (c) the Infor one of the time deadlines above has expired
mal Discovery Conference Is conduded without
resolving the dispute, then a party may file a
discovery motion to address unresolved issues.
5. The parties hereby further agree that the time
for maldng a motion to compel or other
discovery motion Is tolled from the date of
filing of the Request for Informal Discovery
Conference qntll (a) the request is denied or
dee
filing of the Request for Informal Discovery Con med denied or (b) twenty (20) days after the
ference, whichever is earlier, unless extended
byOrderoftheCourt
It Is the understanding and intent of the parti
es
dispute to which It applies, constitute a writi that this stipulation shall, for each discovery
ng memorializing a spedftc later date to which
the p opounding tor demanding or requestlngj
party and the responding party have agreed In.
wdtlng, wiUdn the meanlAg of Code CMI Pro
cedure sections 2030300(c), 2031.320(c), and
2033.290(c).
6. NothIng herein will preclude any party from
applying ex paite for appropriate relief, including
an order Shortening time for a motion to be hea
rd concerning discovery.
7. Any party may terminate this stipulation by

giving twenty-one (21) days notice of Inten to
t
terminate the stipulation.
8. References to days mean calendar days, unl
ess
any act pursuant to this stipulation falls on a Sat othenwise noted. It thedate for performing
urday, Sunday or Court holiday, then the time
for performing that act Shall be extended to the nex
t Court day.
AO4fl1
FarIanLJ..
STIPULATION DISCOVERY RESOLUTION

-
The following parties stipulate:

Date:
Date:
Date:
Date:
Date:
Oste:
Date:
>
(TYPE OR PEINT NAME)
(MTORNEY FOR PLAINTIFF)
(TYPE CR PRINT NAME)
FOR DEFENOANT)
npjy FOR
(TYPE CR PRINT NAI)
J4DT)
(ATTORNEY FOR DEFENDAN1)
(TYPE OR PRWrNAIIE)
ynjpy pn_____________
ny FOR_____
_________
P44WQ4I11
FcrCpIandLbI
STIPULATION
ynpjy .j.
DISCOVERY RESOLUTION
P.g.3a13
ATTCV C PPT WT)UT A1TY:
TELEPHONE NO.:
E-MAIL ADDRESS (Op*on):
ATTORNEY FOR (Name):
rA1a.PmIJ.Iem
V. Fl. 5b.
FAX NO. (OpUo):
SUPERIOR COURT OF CALIFORNIA, COUNTY OF

LOS ANGELES
OURTHOUSE ADDRESS:
PLAINTWF:
OEFENDANT:
STIPULATION
EARLY ORGANIZATIONAL MEETING

V
CA Me
This stipulation Is IfltOflded to OI)COWa9 cooP

eration among the parties at an early stage In
the litigation and to assist the parties In efficient
case resolution.
The parties agree that:
1. The parties commit to conduct, an Initial conferen
ce (In-person or via teleconference or da
videoconference) wIthin 15 days from the date
this stipulation Is signed, to dlsuss and consider
whether the,e can be agreement on the Miowlng
a. Are motions to challenge the pleadings nece
amendment as of right, or if the Court wou ssary? If the Issue can be resolved by
ld allow leave to amend could an amended
complaint resolve most or all of the issues a
demurrer might otherwise raise? If so. the parties
agree to work through pleading Issues so that
resolve. Is the issue that the defendant seeks a demurrer need only raise issues th8y cannot
to raise amenable to resolution on demurrer, or
Would 501115 ottiei t
YPe of motion be preferable? Could a volunlaiy targe
ted exchange of
documents or inImiatIon by any party cure
an uncertainty In the pleadings?
b. Initial mutual exchanges of documents at the
employment case, the employment records, scoW of the litigation. (For example, In an
personnel file and documents relating to the
conduct hi question could be considered core
. In a personal injury case, an incident or
police report, medical records, and repair
or maintenance records could be considered
.
c. Exchange of names and contact Information of
witnesses;
d. Any Insurance agreement that may be available

to satisfy part or all of a judgment, or to
Indemnify or reimburse (Or payments made to
satisfy a judgment
e. Exchange of any other infcnnstlon that might be
or resolution of the case in a manner that preserv helpfUl to facilitate understanding, handing,
es objections or privileges by agreement
f. Controlling. Issues of law that, If resolved early,
will, promote efficiency and economy In other
phases of tile case. Also, when and how such
issues can be presented to the Court;
g. Miether or when the case should be schedule
d with a settlement officer, what discovery or
court ruling on legal issues is reasonably requ
ired to make settlement discussions meanlngM,
and whether the parties wish to use a sitting
judge or a private mediator or other options as
04111
FarO*niU.
STIPULATION - EARLY ORGANIZAT
IONAL MEETING
P.u.1at2
Tm.E
discussed in the Alternative Dispute Resolutio

n (ADR) information Package served with the
complaint;
h. Computation of damages, Induding documents,

not privdeged or protected from disclosure, on
wtch such computation is based;
t.
2.
3.
Whether the case is suitable for the Expe

dited
&asuieAoscourt.orr, under CMI and then Jury Trial procedures (see information at
under General Information).
The time for a defending party to respond to acom
plaint or cross-complaint will be extended
to
for the complaint, and
(SISERT OA1
for the cross
(INSERT DAIS)
complaint, which Is comprised of the 30 days to
respo
and the 30 days permitted by Code of Civil Proc nd under Government Code 68616(b),
edure sectIon 1054(a), good cause having
been found by the Clvii Supervising Judge due
to the case management benefits provided by
this Stipulation. A copy of the General Order can
be found at wviw.laauDerioIcowLom under
clidr, click on rGeneral Information, then click
on Voluntaiy Efficient Litigation Stipulations.
The parties v.IU prepare a Joint report tided Join
t Status Report Pursuant to Initial Conference
and Early Organizational Meeting Stipulation,
and If desired, a proposed aider summarizing
results of their meet and confer and advising
the
efildent conduct or resolution of the case. The Court of any way It may assist the parties
parti
the Ca5e Management Conference statement, es shall attach the Joint Status Report to
and file the documents wtien the CMC
statement Is due.
.
ReferenceS to days mean calendar days unl

ess ottieiwise noted. if the date for performing
any act pursuant to this stipulation falls on a Satu
rday
for performing that act shall be extended to the next , Sunday or Court holiday, then the time
Court day
me tosowing parties stipulate:
4.
0
Oak:
0
0
(A1TORNEY FOR PLAIHTIH)
(A1TORNEY FOR DEFENDANT)
(ATTORNEY FOR DEFENDANT)
YPE OR PRINT NAME)
(ATTORNEY FOR DEFENDANT)
D-
0:
(TYPE OR PRINTNAME)
(ATTORNEY FOR_______________
(ATTORNEY FOR______________
(ATTORNEY FOR______________
__
LIVm (new)
LASC 04111
STIPULATION- EARLY ORGANIZAT
IONAL MEETING
Pan. 2 at 2
I
II
Iii
jj
Ill
S3
1001111
11
iii
NM RIO S3 OFATTOIOYIPRI1Y MTNOUT A1TY
1EL.EPHONE NO.:
5VAI BAR MIOAR
FAX NO. (Oon):
E-MAfl. ADDRESS (Opcid).

ATTORNEY FOR (Nne)
UPER1OR COURT OF CALIFORNIA, COUNTY OF

LOS ANGELES
OURTHOUSE ADDRESS:
tfiJNTIFF:
STIPULATION AND ORDER
MOTIONS IN LIMINE
CASE
This stipulation Is Intended to provld fast and

informal resolution of evidentlary
Issues through diligent efforts to define and disc
uss such Issues and limit paperwork.
The parties agree that
1. At least___ days before the final status confere
parties with a list containing a one paragraph explnce, each party will provide aft other
Umine; Each one paragraph explanation must iden anation of each proposed motion in
tify
motion in lknlne and the grounds for tjie proposed motithe substance of a single proposed
on.
2. The parties thereafter wW. meet and confer, eith

er in person or via teleconference or
videoconference, concerning aft proposed
motions in limine. In that meet and confer, the
parties will determine:
a. Vftether the parties can stipulate to any of the
proposed motions. If the parties so
stipulate, they may flea stipulation and propos
ed.order with the Court
b. Wiether any of the proposed motions can be brief
ed and submitted by means of a
short joint statement of issues. For each moti
on which can be addressed by a short
joint statement of Issues, a short joint stateme
nt of issues must be filed with the Court
10 days prior to the final status conference
.
statement of issues may not exceed three pag Each sides portion of the short joint
es. The parties will meet and confer to
agree on a date and manner for exchanging
the
shod joint statement of issues and the process forparties respective portions of the
filing the short joint statement of
3. Al proposed motions in limine that are not either the sub

ject of a stipulation or briefed via
a short joint statement of issues will be briefed and flied
in accoidancewith the California
Rules of Court and the Los Angeles Superior Cou
rt Rules.
sO411I
Farar.dLJI
STIPULATION AND ORDER
MOTIONS IN LIMINE
PIUI1&2
0.
I
I-
C.
U.
10
LI.
Jil.
L.
IQ
lu.
Iz
10
I0
0 I
r
.
A
iS
a.
0.
ii
LI
I
SUM-I 00
SUMMONS
FOR COURT USE ONLY

(SOLO PARA USO bE LA CORTE)
(CITA CION JUDICIAL)

NOTICE TO DEFENDANT:
(AVISO AL DEMANDADO):
AMERICAN APPAREL, INC., a Delaware corporation;

Additional Parties Attachment form is attached.
COJL.UI
Los AnoelFc nprfn,.
YOU ARE BEING SUED BY PLAINTIFF:

(LO ESTA DEMANDANDO EL DEMANDANTE):
1
Sherri R. Carter, Executive Officer/Clerk
Moses Soto, Deputy
JAN WILLEM HUBNER, an individual,

Plaintiff.
NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the information
below.
You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy
served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your
case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts
Online Self-Help Center (www.courtinfoca.gov/selfhelp), your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask
the court clerk for a fee waiver form, If you do not file your response on time, you may lose the case by default, and your wages, money, and property
may be taken without further warning from the court.
There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to call an attorney
referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate
these nonprofit groups at the California Legal Services Web site (www.lawhelpcalifornia.org), the California Courts Online Self-Help Center
(vvvvw.courtinfo.ca.gov/selfhelp), or by contacting your local court or county bar association. NOTE: The court has a statutory lien for waived fees and
costs on any settlement or arbitration award of $10,000 or more in a civil case. The courts lien must be paid before the court will dismiss the case.
AVISO! Lo han demandado. Si no responde dentro de 30 dias, Ia code puedo decidir en su contra sin escuchar su versiOn. Lea Ia informacin a
1
continuacin.
Tiene 30 DIAS DE CALENDARIO despus de que 10 entreguen esta citaciOn y papeles 10gales para presentar una respuesta por escrito en esta
code y hacer que se entregue una copia a! demandante. Una carta o una liamada telefOnica no lo protegen. Su respuesta por escrito tiene quo estar
en forrnato legal correcto si desea que procesen su caso en Ia corte. Es posible que haya un formulario que usted pueda usar para su respuesta.
Puede encontrar estos formularios do Ia corte y ms informacin en el Centro de Ayuda do las Cortes de California (www.sucorte.ca.gov), en Ia
biblioteca do feyes de su condado o on Ia code quo le quode ms cerca. Si no puede pagar Ia cuota do presonfaciOn, pida al secretario do Ia code
que le d un form ulario de exenciOn do pago do cuotas. Si no prosenta su respuesta a tiempo, puede perder 01 caso por incumplimiento y a code le
podr quitar su sueldo, dinero y bienes sin ms advedencia.
Hay otros requisitos legales. Es recomendable que flame a un abogado inmediatamente. Si no conoce a un abogado, puede Ilamar a un servicio de
remisin a abogados. Si no puede pagar a un abogado, es posthle quo cumpla con los requisitos para obtenor seivicios legaies gratuitos de un
programa de servicios legales sin tines de lucro. Puede encontrar estos grupos sin fines de lucro en el sitlo web de California Legal Seniices,
(www.lawhelpcalifomia.org), en of Centro do Ayuda do las Codes do California, (www.sucorte.ca.gov) o ponindose en contacto con Ia code o el
colegio de abogados locales. A VISO: Por fey, a code tieno derecho a reclamar las cuotas y los costos exontos por imponer un gravamen sobre
cualquier recuperaciOn do $10,000 mOs do valor recibida modiante un acuerdo 0 una concosiOn de arbitraje en un caso de derecho civil. Tiene que
pagar el gravamen do Ia code antes do quo Ia code pueda desochar et caso.
The name and address of the court is:

(Elnombre ydireccidn de Ia corte es):
Los Angeles Superior Court
fl(
CASE NUMBER;
(NdmerodelCaso)p
U 4!
I
.
l1
111 North Hill Street

The name, address, and telephone number of plaintiffs attorney, or plaintiff without an attorney, is:
(El nombre, Ia direcciOn y of nUmero do telfono del abogado del demandante, o del demandante que no tiene abogado, es):
Jennifer H. Yeung, SBN 280819, Fink & Steinberg, 11500 Olympic Blvd., Ste. 316, Los Angeles, CA 90064
(1O2 2(-O7O
DATE:
Clerk, by
(Fecha)
(Secretarlo)
(For proof of service of this summons,

ummons (form POS-O1 0).)
(Para pruoba do entrega do esta citation use of formulario Proof of Service of Summons, (POS-Olo)).
NOTICE TO THE PERSON SERVED: You are served
I5]
1
as an individual defendant.
2.
as the person sued under the fictitious name of (specify):
M. $t
Deputy
(Adjunto)
E1
on behalf of (specify):
under:
CCP 416.10 (corporation)

CCP 416.20 (defunct corporation)
CCP 416.40 (association or partnership)
CCP 416.60 (minor)

CCP 416.70 (conservatee)
CCP 416.90 (authorized person)
other (specify):
4.
by personal delivery on (date):

Page 1 of 1

5UM-100 ]Rev July 1,2009]
SUMMONS
Code of CMI Procedure
412.20. 465
www.couiliiifo cagov
SUM-200(A)
SHORT TITLE:
CASE NUMBER.

INSTRUCTIONS FOR USE
-
This form may be used as an attachment to any summons if space does not permit the listing of all parties on the summons.
If this attachment is used, insert the following statement in the plaintiff or defendant box on the summons: Additional Parties
Attachment form is attached.
List additional parties (Check only one box. Use a separate page for each type of party.):
Plaintiff
Defendant
Cross-Complainant
Cross-Defendant
AMERICAN APPAREL RETAIL, INC., a California corporation; AMERICAN APPAREL (USA), LLC, a
California limited liability company; AMERICAN APPAREL MANUFACTURING, INC., a California
corporation, AMERICAN APPAREL GROUP, a Delaware corporation; AMERICAN APPAREL
CORPORATION, a Delaware corporation; and DOES ito 100, inclusive,
Defendants.
Page
of
I
Page 1 of 1

SUM-200(A) [Rev. January 1. 2007[
ADDITIONAL PARTIES ATTACHMENT

Attachment to Summons

Jan Hubner BC 591877

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Jan Hubner BC 591877

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1

Keith A. Fink, Bar No. 146841

Attorneys for Plaintiff

COUNTY OF LOS ANGELES

10 JAN WILLEM HUBNER, an individual;

AMERICAN APPAREL, INC., a

VIOLATION OF LABOR CODE

COMPLAINT FOR DAMAGES FOR:

VIOLATION OF LABOR CODE

VIOLATION OF BUSINESS & PROFESSIONS

[JURY TRIAL DEMANDED]

PlaintiffJAN WILLEM HUBNER hereby alleges as follows:

PLAINTIFFS COMPLAINT FOR DAMAGES

Angeles, State of California.

APPAREL RETAIL, INC. (AMERICAN APPAREL and/or DEFENDANTS) is, and at

of Los Angeles, State of California.

substantial business in the County of Los Angeles, State of California.

APPAREL GROUP (AMERICAN APPAREL and/or DEFENDANTS) is, and at all

Los Angeles, State of California.

APPAREL CORPORATION (AMERICAN APPAREL and/or DEFENDANTS) is, and

County of Los Angeles, State of California.

AMERICAN APPAREL RETAIL, INC., AMERICAN APPAREL (USA), LLC, AMERICAN

APPAREL MANUFACTURING, INC., AMERICAN APPAREL GROUP, and AMERICAN

APPAREL CORPORATION were joint employers of PLAINTIFF. AMERICAN APPAREL,

INC., AMERICAN APPAREL RETAIL, INC., AMERICAN APPAREL (USA), LLC,

AMERICAN APPAREL MANUFACTURING, INC., AMERICAN APPAREL GROUP, and

PLAINTIFFS COMPLAINT FOR DAMAGES

AMERICAN APPAREL CORPORATION hired employees jointly, including PLAINTIFF,

Court as a necessary party for the relief herein requested.

AMERICAN APPAREL RETAIL, INC., AMERICAN APPAREL (USA), LLC, AMERICAN

APPAREL MANUFACTURING, INC., AMERICAN APPAREL GROUP, and AMERICAN

PLAINTIFF further alleges that AMERICAN APPAREL, INC., AMERICAN APPAREL

MANUFACTURING, INC., AMERICAN APPAREL GROUP, and AMERICAN APPAREL

PLAINTIFFS COMPLAINT FOR DAMAGES

and every allegation contained in Paragraphs 1 through 12, inclusive.

Hubner s Excellent Job Performance

In or around January 2006, HUBNER was hired by AMERICAN APPAREL as a Sales

overseeing the opening of new AMERICAN APPAREL stores throughout Europe.

Due to HUBNERS stellar performance and significant contributions, in or around

As Brand Manager, HUBNER reported directly to the Chief Executive Officer

overseeing the brand practices for AMERICAN APPAREL, as well as merchandising,

hiring/recruiting, brand visuals and looks, and product development.

PLAINTIFFS COMPLAINT FOR DAMAGES

internationally to ensure compliance of AMERICAN APPARELS then high standards for

their merchandise and physical stores.

performance for each of the years he was in that position.

Hubners Wrongful Termination

On or around, March 19, 2015, HUBNER complained to PAULA SCHNEIDER

(SCHNEIDER), the then newly instituted Chief Executive Officer (CEO) of

delinquent bonus monies and/or stock packages.

PLAINTIFFS COMPLAINT FOR DAMAGES

FIRST CAUSE OF ACTION

WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY

(Against All DEFENDANTS and DOES 1 to 100)

and Professions Code

person from employment or to discriminate against the person in compensation and/or in

terms, conditions, or privileges of employment in retaliation for opposing an unlawful practice

or participating in a protected activity. California also has a fundamental, substantial, and

and Civil Code

PLAINTIFFS COMPLAINT FOR DAMAGES

and Labor Code as

(See, e.g., Labor Code

packages, and/or in order to avoid payment of his earned wages.