Preview
1 Rafael Gonzalez, SBN 210202
rgonzalez@mullenlaw.com
2 Brian T. Daly, SBN 298731
bdaly@mullenlaw.com
3 MULLEN & HENZELL L.L.P.
112 East Victoria Street
4 Post Office Drawer 789
Santa Barbara, CA 93102-0789
5 Telephone: (805) 966-1501
Facsimile: (805) 966-9204
6
Attorneys for Defendant
7 FRESH VENTURE FOODS, LLC
8
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 FOR THE COUNTY OF SANTA BARBARA
11 COOK DIVISION
12
13 SICILIA MENDOZA, individually, on ) Case No. 18CV04448
behalf of themselves and all others )
14 similarly situated, )
) STIPULATION RE: MEDIATION
15 Plaintiffs, )
) Dept.: SM2
16 v. ) Trial Judge: James F. Rigali
) MSC Judge: Timothy J. Staffel
17 FRESH VENTURE FOODS, LLC, a )
California limited liability corporation, ) Complaint Filed: September 7, 2018
18 CENTRAL CITY LABOR [Form )
Unknown], MARISOL GARCIA ) Trial Date: n/a
19 SANDOVAL, individually; and DOES 1 )
through 20, inclusive, )
20 )
Defendants. )
21 )
22
23 It is hereby stipulated and agreed by and between Plaintiff Sicilia Mendoza
24 (“Plaintiff”), on the one hand, and Defendants Fresh Venture Foods, LLC, Central City Labor,
25 and Marisol Garcia Sandoval, (collectively, “Defendants”), on the other hand, by and through
26 their counsel of record, as follows:
27 ///
28 ///
-1-
STIPULATION RE: MEDIATION
1 RECITALS
2 WHEREAS, Plaintiff has filed an action alleging wrongful termination in violation of
3 public policy; and
4 WHEREAS, the parties desire to preserve party and judicial resources by making a
5 good faith effort prior to trial to resolve the claims through private mediation; and
6 WHEREAS, the parties have agreed to privately mediate this action before the Hon.
7 Louise LaMothe on January 17, 2023; and
8 WHEREAS, on November 7, 2022, the Hon. Timothy J. Staffel ordered that the trial
9 confirmation conference in this action on 12/19/22 be vacated, and that the jury trial date on
10 1/17/23 be vacated, and that the parties appear at a case management conference on 2/7/23, and
11 that the parties submit a written stipulation re: mediation.
12 THEREFORE, it is hereby stipulated and agreed by and between the undersigned
13 parties, through their respective counsel, as follows:
14 1. The parties agree to mediate this action before the Hon. Louise LaMothe on January
15 17, 2023.
16
17 IT IS SO STIPULATED.
18
19 (Signatures on next page)
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-2-
STIPULATION RE: MEDIATION
17
1 PROOF OF SERVICE
(Code Civ. Proc. §§ 1013a & 2015.5)
2
3 I am employed in the County of Santa Barbara, State of California. I am over 18 years
4 of age and not a party to the within action. My business address is 112 East Victoria Street,
5 Santa Barbara, California 93101.
6 On November 21, 2022, I caused to be served STIPULATION RE: MEDIATION on
7 the interested party(ies) in this action, addressed as follows:
8
Service List Attached
9
10 BY MAIL: I am readily familiar with the Mullen & Henzell L.L.P. practice for
collection and processing of correspondence for mailing with the United States Postal
11 Service (USPS). The correspondence indicated above would be deposited with the
USPS the same date as this declaration in the ordinary course of business. The
12 correspondence was placed for deposit with the USPS at the offices of Mullen &
Henzell L.L.P., 112 East Victoria Street, Santa Barbara, California. The envelope(s)
13 was/were sealed with postage fully prepaid on this date and placed for collection and
mailing following ordinary business practices and addressed as indicated above.
14
15 BY FEDERAL EXPRESS (FedEx) / UNITED PARCEL SERVICE (UPS) / OTHER
(Specify) OVERNIGHT DELIVERY: I left the above-referenced document(s) for
16 delivery at a FedEx / UPS / Other (Specify) drop off location in a sealed envelope
addressed as indicated above, with fees for delivery fully prepaid.
17
BY PERSONAL SERVICE: I caused the above-referenced document(s) to be hand
18 delivered to the party(ies) at the address(es) indicated above.
19 BY ELECTRONIC SERVICE: I caused the above-referenced document(s) to be
electronically served to the parties at the addresses indicated above.
20
21 I declare under penalty of perjury under the laws of the State of California that the
22 foregoing is true and correct, and that this declaration was executed on November 21, 2022, at
23 Santa Barbara, California.
24
25
Laura J. Sire
26
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Mendoza v. Fresh Venture Foods, LLC, et al.
Case No. 18CV04448
SERVICE LIST
1
2 ATTORNEY(S) FOR PLAINTIFF(S):
3 STAN S. MALLISON, ESQ.
HECTOR R. MARTINEZ, ESQ.
4 HEATHER M. HAMILTON, ESQ.
MALLISON & MARTINEZ
5 1939 HARRISON STREET, SUITE 730
OAKLAND, CA 94612-3547
6 TEL: (510)832-9999
FAX: (510) 832-1101
7 STANM@THEMMLAWFIRM.COM
HECTORM@THEMMLAWFIRM.COM
8 HHAMILTON@THEMMLAWFIRM.COM
ARODRIGUEZ@THEMMLAWFIRM.COM
9
PARALEGALS:
10 DANIEL ARJONA DARJONA@THEMMLAWFIRM.COM
LOGAN BOWIE LBOWIE@THEMMLAWFIRM.COM
11 PAULINA MALDONADO PMALDONADO@THEMMLAWFIRM.COM
12
13 ATTORNEY FOR CO-DEFENDANT:
14 CHARLEY M. STOLL, ESQ.
CHARLEY M. STOLL, A PROFESSIONAL CORPORATION
15 340 ROSEWOOD AVENUE, SUITE K
CAMARILLO, CA 93010
16 TEL: (805) 389-5296
FAX: (805) 389-5288
17 CSTOLL@CMSAPC.COM
18 PARALEGAL:
DANA M. LAVENANT DLAVENANT@CMSAPC.COM
19
4870-8452-0253, v. 1
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28
Mendoza v. Fresh Venture Foods, LLC, et al.
Case No. 18CV04448
Preview
1 Rafael Gonzalez, SBN 210202 rgonzalez@mullenlaw.com 2 Brian T. Daly, SBN 298731 bdaly@mullenlaw.com 3 MULLEN & HENZELL L.L.P. 112 East Victoria Street 4 Post Office Drawer 789 Santa Barbara, CA 93102-0789 5 Telephone: (805) 966-1501 Facsimile: (805) 966-9204 6 Attorneys for Defendant 7 FRESH VENTURE FOODS, LLC 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SANTA BARBARA 11 COOK DIVISION 12 13 SICILIA MENDOZA, individually, on ) Case No. 18CV04448 behalf of themselves and all others ) 14 similarly situated, ) ) STIPULATION RE: MEDIATION 15 Plaintiffs, ) ) Dept.: SM2 16 v. ) Trial Judge: James F. Rigali ) MSC Judge: Timothy J. Staffel 17 FRESH VENTURE FOODS, LLC, a ) California limited liability corporation, ) Complaint Filed: September 7, 2018 18 CENTRAL CITY LABOR [Form ) Unknown], MARISOL GARCIA ) Trial Date: n/a 19 SANDOVAL, individually; and DOES 1 ) through 20, inclusive, ) 20 ) Defendants. ) 21 ) 22 23 It is hereby stipulated and agreed by and between Plaintiff Sicilia Mendoza 24 (“Plaintiff”), on the one hand, and Defendants Fresh Venture Foods, LLC, Central City Labor, 25 and Marisol Garcia Sandoval, (collectively, “Defendants”), on the other hand, by and through 26 their counsel of record, as follows: 27 /// 28 /// -1- STIPULATION RE: MEDIATION 1 RECITALS 2 WHEREAS, Plaintiff has filed an action alleging wrongful termination in violation of 3 public policy; and 4 WHEREAS, the parties desire to preserve party and judicial resources by making a 5 good faith effort prior to trial to resolve the claims through private mediation; and 6 WHEREAS, the parties have agreed to privately mediate this action before the Hon. 7 Louise LaMothe on January 17, 2023; and 8 WHEREAS, on November 7, 2022, the Hon. Timothy J. Staffel ordered that the trial 9 confirmation conference in this action on 12/19/22 be vacated, and that the jury trial date on 10 1/17/23 be vacated, and that the parties appear at a case management conference on 2/7/23, and 11 that the parties submit a written stipulation re: mediation. 12 THEREFORE, it is hereby stipulated and agreed by and between the undersigned 13 parties, through their respective counsel, as follows: 14 1. The parties agree to mediate this action before the Hon. Louise LaMothe on January 15 17, 2023. 16 17 IT IS SO STIPULATED. 18 19 (Signatures on next page) 20 21 22 23 24 25 26 27 28 -2- STIPULATION RE: MEDIATION 17 1 PROOF OF SERVICE (Code Civ. Proc. §§ 1013a & 2015.5) 2 3 I am employed in the County of Santa Barbara, State of California. I am over 18 years 4 of age and not a party to the within action. My business address is 112 East Victoria Street, 5 Santa Barbara, California 93101. 6 On November 21, 2022, I caused to be served STIPULATION RE: MEDIATION on 7 the interested party(ies) in this action, addressed as follows: 8 Service List Attached 9 10 BY MAIL: I am readily familiar with the Mullen & Henzell L.L.P. practice for collection and processing of correspondence for mailing with the United States Postal 11 Service (USPS). The correspondence indicated above would be deposited with the USPS the same date as this declaration in the ordinary course of business. The 12 correspondence was placed for deposit with the USPS at the offices of Mullen & Henzell L.L.P., 112 East Victoria Street, Santa Barbara, California. The envelope(s) 13 was/were sealed with postage fully prepaid on this date and placed for collection and mailing following ordinary business practices and addressed as indicated above. 14 15 BY FEDERAL EXPRESS (FedEx) / UNITED PARCEL SERVICE (UPS) / OTHER (Specify) OVERNIGHT DELIVERY: I left the above-referenced document(s) for 16 delivery at a FedEx / UPS / Other (Specify) drop off location in a sealed envelope addressed as indicated above, with fees for delivery fully prepaid. 17 BY PERSONAL SERVICE: I caused the above-referenced document(s) to be hand 18 delivered to the party(ies) at the address(es) indicated above. 19 BY ELECTRONIC SERVICE: I caused the above-referenced document(s) to be electronically served to the parties at the addresses indicated above. 20 21 I declare under penalty of perjury under the laws of the State of California that the 22 foregoing is true and correct, and that this declaration was executed on November 21, 2022, at 23 Santa Barbara, California. 24 25 Laura J. Sire 26 27 28 Mendoza v. Fresh Venture Foods, LLC, et al. Case No. 18CV04448 SERVICE LIST 1 2 ATTORNEY(S) FOR PLAINTIFF(S): 3 STAN S. MALLISON, ESQ. HECTOR R. MARTINEZ, ESQ. 4 HEATHER M. HAMILTON, ESQ. MALLISON & MARTINEZ 5 1939 HARRISON STREET, SUITE 730 OAKLAND, CA 94612-3547 6 TEL: (510)832-9999 FAX: (510) 832-1101 7 STANM@THEMMLAWFIRM.COM HECTORM@THEMMLAWFIRM.COM 8 HHAMILTON@THEMMLAWFIRM.COM ARODRIGUEZ@THEMMLAWFIRM.COM 9 PARALEGALS: 10 DANIEL ARJONA DARJONA@THEMMLAWFIRM.COM LOGAN BOWIE LBOWIE@THEMMLAWFIRM.COM 11 PAULINA MALDONADO PMALDONADO@THEMMLAWFIRM.COM 12 13 ATTORNEY FOR CO-DEFENDANT: 14 CHARLEY M. STOLL, ESQ. CHARLEY M. STOLL, A PROFESSIONAL CORPORATION 15 340 ROSEWOOD AVENUE, SUITE K CAMARILLO, CA 93010 16 TEL: (805) 389-5296 FAX: (805) 389-5288 17 CSTOLL@CMSAPC.COM 18 PARALEGAL: DANA M. LAVENANT DLAVENANT@CMSAPC.COM 19 4870-8452-0253, v. 1 20 21 22 23 24 25 26 27 28 Mendoza v. Fresh Venture Foods, LLC, et al. Case No. 18CV04448