Party Notice: *MF**COMPLEX** Reyes -v- Imperial Imports Print

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                                ~ ORIGINAL
     JCL LAW        FIRM, APC
     Jean-Claude Lapuyade (State Bar #248676)
     Sydney Castillo Johnson (State Bar #343881)
     Monnett De La Torre (State Bar #272884)                                                  Fie    D
                                                                                   SUPERIOR COURT OF CALIFORNIA
     5440 Morehouse Drive, Suite 3600                                               COUNTY  OF
     San Diego, CA 92121                                                             SAN BERNARDINO: OISTRICT
     Telephone: (619) 599-8292
     Facsimile: (619) 599-8291                                                            SEP 13 2023
     jlapuyade@jcl-lawfirm.com
     scastillo@jcl-lawfirm.com
     mdelatorre@jcl-lawfirm.com
                                                                                 v»—OR
     ZAKAY      LAW      GROUP, APLC
     Shani O. Zakay (State Bar #277924)
     5440 Morehouse Drive, Suite 3600
     San Diego, CA 92121
     Telephone: (619) 255-9047
     Facsimile: (858) 404-9203
10   shani@zakaylaw.com

1    Attorneys for INTERVENOR

12                           SUPERIOR COURT OF THE STATE OF CALIFORNIA

13                                 FOR THE COUNTY                  OF SAN BERNARDINO
14
     ALEX GONZALEZ            on behalf
                                      of all aggrieved              | CASE NO: CIVSB2320530
15   employees,                                                       [CASE NO: CIVSB2304458 (Reyes)]

16       Plaintiffs,                                                Assigned to the Hon. Donald Alvarez
                                                                    Department S23 - SBJC
17       Vv
                                                                     NOTICE OF MOTION FOR LEAVE                   TO
18
     IMPERIAL           IMPORTS,    INC.,    a    California         INTERVENE IN PENDING ACTION
19   corporation;      SAN   BERNARDINO           MOTORS,
     INC.,    a California corporation;     and    DOES        |     Date:   October 19, 2023
     through 25, inclusive,                                          Time:   8:30 a.m.

21       Defendants.
                                                                     Judge: Hon. Donald Alvarez
                                                                     Dept: S23
22
     NORMA REYES, an individual, on behalf of
23   herself and on behalf of all persons similarly
     situated,
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          Intervenor.
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                          NOTICE OF MOTION       FOR LEAVE          O INTE       E IN PENDING   ACTION,
PLEASE TAKE NOTICE         that on October 19, 2023, at 8:30am, or as soon thereafter as may

        be heard, in Department $23, before the Honorable           Donald   Alvarez of the above-entitled Court,

    3   Proposed Plaintiff in Intervention Norma       Reyes (“Intervenor™) will and hereby does, move for an

        order to intervene in this Action (the “Motion”).     Intervenor seeks to intervene in order to protect and

        pursue her claim for civil penalties on behalf of fellow aggrieved employees and the State of

    6   California against Defendants under the Private Attorneys General Act of 2004, Labor Code § 2698,

        ef seq.    The motion will be made pursuant to Code of Civil Procedure § 387(d)(1) on the grounds

        that the proposed Intervenor (1) has an unconditional right to intervene conferred by law and/or (2)

        claims an interest relating to the property that is the subject matter of the action and she is so situated

10      that the disposition of the action may as a practical matter impair or impede her ability to protect that

i       interest that is not and cannot be adequately represented by the existing parties.          The motion is
12      alternatively made pursuant to Code of Civil Procedure § 387(d)(2) on the grounds that the proposed

13      Intervenor has an interest in the matter in litigation.

14                The motion will be based on this notice of motion, the Declaration of Jean-Claude Lapuyade,

15      the Declaration of Shani O. Zakay, and the supporting memorandum served and filed herewith, the

16      records and file herein, and such evidence and argument as may be presented at the hearing of the

17      motion.

18                Respectfully submitted,

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        Dated:    September 13, 2023                     JCL LAW FIRM, APC
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                                                         By
22                                                            Jean-            uyade.
                                                              Attorneys for Plaintiff-Intervenor
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                           NOTICE   OF MOTION   FOR   LEAVE   TO INTERVENE    IN PENDING   ACTION