Superior Court of the State of California County of Los Angeles
Case No. BC651992
IMPORTANT NOTICE REGARDING YOUR PRIVACY RIGHTS AND DISCLOSURE OF YOUR PERSONAL CONTACT INFORMATION
Re: Privacy Notice Regarding the Disclosure of Your Contact Information in Alexandra Escamilla, et al. v. Ono Hawaiian BBQ, Inc., et al.
A proposed class action lawsuit has been filed by Plaintiffs Alexandra Escamilla, Mireya Corona, and Steven Rivera (“Plaintiffs”) against Ono Hawaiian BBQ, Inc.; Apelila and J, LLC; Culver City Sepulveda, LLC; Santa Monica Bundy, LLC; Alhambra Valley Restaurant, LLC; C & S Stockton, LLC; Colma Serramonte Restaurant, LLC; LA Sunset, LLC; Malaki and J, LLC; Hayward Hesperian Restaurant, LLC; Las Tunas Enterprise, LLC; Manteca Airport Restaurant, LLC; Mira Loma PR, LLC; Moreno Beach Express, Inc.; Morgan Cochrane, LLC; OHB Holding I, LLC; Perris Case, LLC; Puente Hills Restaurant, LLC; Riverside CSP Restaurant, LLC; Rosemead Marshall Restaurant, LLC; S & F Hawaiian BBQ, LLC; S & H Hayward, LLC; J & U Hawaiian BBQ, LLC; San Leandro Palma, LLC; Walnut Florence, LLC; Alameda Compton, LLC; Culver City Jefferson, LLC; Fontana Summit, LLC; Hollywood Sunset, LLC; Turlock Countryside Restaurant, LLC; Stockton Pacific Restaurant, LLC; San Pedro Gaffey Investments, LLC; WH Garden Marketplace, LLC; and Ono Management, LLC (collectively, “Defendants”). Plaintiffs seek to represent all individuals who worked for Defendants as a non-exempt employee in the State of California at any time from February 27, 2013 to the present. Plaintiffs primarily allege that Defendants failed to pay overtime and minimum wages, failed to provide meal and rest breaks, failed to reimburse for necessary business expenditures, failed to provide proper itemized wage statements, and failed to timely pay all wages due upon separation of employment. Plaintiffs are seeking recovery of unpaid wages, penalties, and interest on behalf of themselves and all potential class members.
Defendants deny Plaintiffs’ claims and maintain that they have complied with all applicable laws and regulations. The Court has not made any decision on the merits of Plaintiffs’ claims or whether this case will proceed as a class action.
You are receiving this notice because Defendants’ records indicate that you worked for one of the Defendants as a non-exempt employee at some point during the period of February 27, 2013 to the present and, therefore, you may be a member of the proposed class. Plaintiffs’ lawyers have requested your name, address, email address, and telephone number so that they may contact you about the lawsuit and ask you questions about your employment with Defendants. Defendants believe this information is private and have not given Plaintiffs’ attorneys your contact information at this point. To protect your privacy rights, the parties have agreed to follow the procedure outlined in this letter.
You are NOT required to share your contact information with Plaintiffs’ attorneys, but if you do NOTHING after receiving this letter, Defendants will provide Plaintiffs’ attorneys with your name and most recent contact information from their records.
You should be receiving this notice by U.S. Mail, email, and text message. You may opt-out from Plaintiffs’ attorneys receiving your personal contact information from any of these methods as described below.
PROCEDURE FOR DISCLOSURE OR NON-DISCLOSURE OF CONTACT INFORMATION
If you do not want Defendants to disclose your name, address, telephone number, and personal e-mail address to Plaintiffs and their attorneys, you must request that your information not be disclosed by doing any of the following by June 20, 2020:
Text message: You can text “Opt out” along with your name to the following phone number: 1-(949) 266-9922.
Email: Replying to the email message stating “Opt out”. If you did not receive an email message with this information, you can send an email message stating “Opt out” and your name to the following email address: EscamillaVOnoHawaiian@cptgroup.com.
U.S. Mail: Filling out, signing, and mailing the pre-addressed opt-out postcard.
|DISCLOSURE||If you want Defendants to disclose your name, address, telephone number, and personal e-mail address to Plaintiffs and their attorneys, you do not need to do anything.|
Your rights regarding this lawsuit will not be affected in any way whether you choose to opt out of disclosing your contact information or not. You are not required to release information or to discuss this matter with either side. California law prohibits your employer from retaliating against you in any way for providing or refusing to provide any information.
If you have any questions about this notice, you may seek independent legal counsel at your own expense or you may contact any of the attorneys representing the parties in this case at the addresses and telephone numbers listed below. Their contact information is listed below.
|Attorneys for Plaintiffs||Attorneys for Defendants|
MATERN LAW GROUP, PC
Matthew J. Matern, Esq.
Matthew W. Gordon, Esq.
Vanessa M. Rodriguez, Esq.
1230 Rosecrans Avenue, Suite 200
Manhattan Beach, CA 90266
Telephone: (310) 531-1900
SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
Richard J. Simmons, Esq.
Jason W. Kearnaghan, Esq.
Hilary A. Habib, Esq.
Ryan J. Krueger, Esq.
Allison Cheffer, Esq.
333 South Hope Street, 43rd Floor
Los Angeles, California 90071-1422
Telephone: (213) 620-1780