Judge: Elaine Lu, Case: 24STCV30397, Date: 2025-03-07 Tentative Ruling

Case Number: 24STCV30397    Hearing Date: March 7, 2025    Dept: 9

 

The Court hereby distributes a tentative ruling for the Case Management Order.  The parties are welcome to provide input and propose modification(s) to any aspect of the CMO at the Initial Status Conference.  If all parties submit on the tentative CMO prior to the commencement of the March 7, 2025 ISC, the Court will adopt the tentative CMO, and the parties need not appear. 

 

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

 

Ruth Martin v Unilever United States, Inc. dba www.Breyers.com

 

24STCV30397

 

                                            [TENTATIVE] CASE MANAGEMENT ORDER

 

 

            This action has been designated as complex pursuant to CRC 3.400(a), and thus requires exceptional judicial management. All provisions of this CMO are deemed necessary to carry out the purposes of Rule 3.400(a), and to promote effective decision-making by the Court. They are based upon individual consideration of this complex action, including the Status Conference Reports previously filed by the parties.

 

 

1.               Defendant states that the Breyer’s website at issue is governed by Terms of Use containing a mandatory arbitration provision and class action waiver. See https://www.unileverus.com/terms/termsofuse.html#20 (Terms of Use, Section 20.B).  However, it does not appear that Defendant intends to move to compel arbitration pursuant to this arbitration provision.  Instead, Defendant will file a motion to quash service for lack of personal jurisdiction, and if that motion is unsuccessful, a demurrer.  The parties should note that litigation of multiple motions prior to bringing a motion to compel arbitration may, under certain circumstances, be deemed a waiver of arbitration.

 

2.               Defendant does not believe that mediation will be productive at this time.

 

3.               Defendant states that it has been erroneously named as it is only a holding company and is not the legal entity that operates the website at issue.  The parties are to meet and confer and to attempt to resolve the identity of the proper defendants, including if appropriate through a voluntary exchange of informal discovery and/or declarations.  If the parties are able to reach an agreement, they may file a stipulation and proposed order regarding dismissal of the currently named defendant and amendment of the complaint to delete the current named defendant and to name instead the correct defendant.  If the parties are unable to reach an agreement, Defendants may have to file a dispositive motion to resolve the issue.

 

 

4.               The Court hereby lifts the stay to permit Defendant to file and serve a Motion to Quash Service of Summons for Lack of Personal Jurisdiction.  Defendant must file and serve its anticipated Motion to Quash Service of Summons for Lack of Personal Jurisdiction by no later than April 7, 2025.  Before filing any demurrer or other motion, the moving party must contact the Court Staff in Department 9 to obtain a hearing date and a briefing schedule.  The Court sets a Non-Appearance Case Review Re: Filing and Serving of Defendant’s Responsive Pleading for April 14, 2025, 8:30 AM, Department 9.  If the Court denies Defendant’s anticipated Motion to Quash Service of Summons for Lack of Personal Jurisdiction, the Court will set a due date for Defendant’s anticipated demurrer approximately 30 days from the court’s ruling on Defendant’s Motion to Quash Service of Summons for Lack of Personal Jurisdiction.

 

5.               Phased Discovery. Discovery shall be phased.  Discovery will be phased with the stay lifted once Defendant files and serves an answer or, if applicable, after the Court rules on any pleading challenge. At that time, the Court will permit class certification discovery only.  Informal discovery is permitted.  Merits-based discovery will be allowed after a successful class certification motion. If there is a dispute concerning whether a given discovery request is certification or merits-based, the parties are to set up a telephonic conference with the court pursuant to the instructions herein.

 

6.               Class list discovery.  The decision in In Re Insurance Installment Fee cases (2012) 211 Cal.App.4th 1395, 1426-1429, held that the notice procedure prescribed by the trial court and followed by the defendant was necessary to protect privacy rights under the California Constitution.  Therefore, upon the Court’s lifting of the stay on class certification discovery, the parties shall use the procedure described in Belaire-West Landscape v Superior Court (2008) 149 Cal.App.4th 554 to notify putative class members, as described in the applicable paragraph of the currently operative complaint, giving them the opportunity to opt out.  The parties must share the cost of the procedure equally.

 

a.         Plaintiff is to take the lead and prepare a proposed letter to be sent out by the agreed-upon third party administrator.  The parties must discuss and settle upon a final version.

 

b.         The letter must be written using the administrator’s letterhead, not that of any party.

 

c.         The defense must turn over the contact information consisting of name, address, phone number, and email address (if available) to the third-party administrator.

 

d.         In the event the putative class list is greater than 400 people, the administrator must randomly select a sample of no more than 400.   The contact information for those persons who did not opt out must be turned over to the plaintiff.

 

7.               Protective Order.  Parties are alerted that model protective orders may be found at Los Angeles Superior Court website at http://www.lacourt.org/division/civil/CI0043.aspx.  The parties are encouraged to use these model orders as shown, or if modified, as a template for the modified order.  A redlined courtesy copy must be posted on the e-service bulletin board and lodged with the court at the time of filing. The parties must use the redlined version to identify any changes proposed to the model order.

 

8.               E-service & E-filing.  Electronic service is not the same as electronic filing.  The parties have agreed, and the Court has signed an order authorizing Case Anywhere as the e-service to be used in this case.  Argument must not be posted on the bulletin board.  For information on electronic filing in the Complex Courts, please refer to https://www.lacourt.org/division/efiling/efiling2.aspx and  http://www.lacourt.org/division/efiling/pdf/ComplexefilingFAQs.pdf.

 

9.               Class Certification Motion.    The Court will set a deadline for filing and serving the Class Certification Motion after ruling on the anticipated Motion to Quash Service and anticipated Demurrer.  If no party files a Motion to Quash Service or Demurrer, then the Court will set a deadline for filing and serving the Class Certification Motion upon the filing of Defendant’s answer.

 

10.            Telephonic conferences.  The Court handles discovery motions informally, using telephonic conferences and LA CourtConnect. Counsel must post a message via their Electronic Service Provider to request any informal discovery conference or other conference. The Court will either reply to the message or issue a Minute Order setting the conference.  The telephonic conference will automatically be taken off calendar if all relevant parties have not scheduled the telephonic conference with LA CourtConnect.  Parties must file and serve a 5-page joint brief two days before the conference. Since these conferences are informal, no court reporter or audio recording is permitted.

 

11.            Potential Related Cases.  Counsel are ordered to file and serve a Notice of Related Case for any potentially related cases pursuant California Rule of court Rule 3.300, civil case involving the same representative plaintiff.  This is a continuing obligation on both plaintiffs and defendants while this case is pending.

 

Plaintiff is ordered to download the instant signed order from the Court’s website, to give formal notice to all other parties, and to file proof of service of such within five (5) days.

 

IT IS SO ORDERED.

 

DATED:          March 7, 2025

 

                                                                                    __________________________

                                                                                    ELAINE LU

                                                                                    Judge of the Superior Court