Judge Teresa A. Beaudet, Case Number: 23STCV03269, Date: 2024-01-09 Tentative Ruling

HECTOR M. BARRAZA-BENITEZ, individually, and on behalf of all other aggrieved employees,

Plaintiff,

vs.

DMCG, INC., et al.

Defendants.

Case No.:

23STCV03269

Hearing Date:

January 9, 2024

Hearing Time: 10:00 a.m.

[TENTATIVE] ORDER RE:

DEFENDANTS DMCG, INC.’S AND BAIL HOTLINE BAIL BONDS, INC.’S MOTION TO COMPEL ARBITRATION AND STAY PROCEEDINGS

On February 14, 2023, Plaintiff Hector M. Barraza-Benitez, individually, and on behalf of all other aggrieved employees (“Plaintiff”) filed the instant PAGA Representative Action Complaint Pursuant to the Private Attorneys General Act against Defendants DMCG, Inc. (“DMCG”) and Bail Hotline Bail Bonds, Inc. (“Bail Hotline”) (jointly, “Defendants”). The Complaint alleges claims under the Private Attorneys General Act.

Defendants now move for an order compelling Plaintiff “to participate in arbitration of his individual claims under the Private Attorney General Act (‘PAGA’) and stay the representative PAGA claims pending the resolution of the claims at arbitration.” Plaintiff opposes.

The Court rules on Defendants’ evidentiary objections to the Declaration of Daniel J. Bass as follows:

The Court rules on Defendants’ evidentiary objections to the Declaration of Hector M. Barraza-Benitez as follows:

In a motion to compel arbitration, the moving party must prove by a preponderance of evidence the existence of the arbitration agreement and that the dispute is covered by the agreement. The burden then shifts to the resisting party to prove by a preponderance of evidence a ground for denial (e.g., fraud, unconscionability, etc.). ((Rosenthal v. Great Western Fin. Securities Corp. (1996) 14 Cal.4th 394, 413-414.)

Generally, on a petition to compel arbitration, the court must grant the petition unless it finds either (1) no written agreement to arbitrate exists; (2) the right to compel arbitration has been waived; (3) grounds exist for revocation of the agreement; or (4) litigation is pending that may render the arbitration unnecessary or create conflicting rulings on common issues. ((Code Civ. Proc., § 1281.2); (Condee v. Longwood Management Corp. (2001) 88 Cal.App.4th 215, 218-219.)

“California has a strong public policy in favor of arbitration and any doubts regarding the arbitrability of a dispute are resolved in favor of arbitration.” ((Coast Plaza Doctors Hospital v. Blue Cross of California (2000) 83 Cal.App.4th 677, 686.) “This strong policy has resulted in the general rule that arbitration should be upheld unless it can be said with assurance that an arbitration clause is not susceptible to an interpretation covering the asserted dispute.” ((Ibid. [internal quotations omitted].) This is in accord with the liberal federal policy favoring arbitration agreements under the Federal Arbitration Act (“FAA”), which governs all agreements to arbitrate in contracts “involving interstate commerce.” (9 U.S.C. § 2, et seq.; (Higgins v. Superior Court (2006) 140 Cal.App.4th 1238, 1247.)

In the Complaint, Plaintiff alleges that he “was employed as a bail agent at Defendants’ South Broadway location in Los Angeles and Valley Boulevard location in El Monte.” (Compl., ¶ 19.) Defendants provide evidence that Bail Hotline is a subsidiary of DMCG. (Maglanque Decl., ¶ 2.) Defendants state that Plaintiff was employed by DMCG. (Maglanque Decl., ¶ 2.) Plaintiff was hired around June 27, 2019, as a bail assistant at one of DMCG’s Los Angeles offices (referred to internally as the 77^th Office). (Maglanque Decl., ¶ 5.)

Defendants submit the Declaration of Sheryl Maglanque, the Human Resources Manager of DMCG. (Maglanque Decl., ¶ 1.) Ms. Maglanque states that “[o]n or about June 27, 2019, I was provided Plaintiffs information by Gilbert McGuire, one of DMCG’ s Directors, and I called Plaintiff on June 27, 2019. 1 verbally made the offer and when he accepted, I explained that he would receive the Employment Packet via DocuSign. I went over everything in the packet, including the Arbitration Agreement, asked if he had any questions, and obtained his email address. I then emailed the Employment Packet around 4:27 pm on June 27, 2019.” (Maglanque Decl., ¶ 11.)

Ms. Maglanque states that “[f]rom the DocuSign’s certificate of completion, it appears that Plaintiff reviewed and signed the various documents between June 27 and June 28.” (Maglanque Decl., ¶ 12.) She further states that “[a] true and correct copy of the Arbitration Agreement that Plaintiff and I executed is attached as Exhibit B to Adreani Decl.” (Maglanque Decl., ¶ 12.) Exhibit “B” to the Declaration of Michael B. Adreani is a document titled “Mediation and Arbitration Agreement.” (Adreani Decl., ¶ 5, Ex. B.) The Mediation and Arbitration Agreement provides, inter alia, as follows:

“The parties agree that all references to the ‘Employer’ in this Agreement shall include and all of its subsidiary and affiliated entities, including all former, current and future officers, directors and employees of all such entities, in their capacity as such or otherwise; all benefit plans and their sponsors, fiduciaries, administrators, affiliates and agents, in their capacity as such and otherwise; and all successors and assigns of any of them. Except as otherwise provided in this Agreement, the Employer and the Employee hereby consent to the resolution by binding arbitration of all claims or controversies for which a federal or state court or other dispute resolution body otherwise would be authorized to grant relief, whether or not arising out of, relating to or associated with the Employee’s employment or wages with the Company, that the Employee may have against the Company or that the Company may have against the Employee.

Claims covered by this Agreement include, but are not limited to, claims for wages or other compensation due; claims for breach of any contract or covenant, express or implied; tort claims; claims for discrimination or harassment on bases which include but are not limited to race, sex, sexual orientation, religion, national origin, age, marital status, disability or medical condition; claims for benefits, except as excluded in paragraph 6; and claims for violation of any federal, state or other governmental constitution, statute, ordinance, regulation, or public policy including but not limited to any laws, codes, or acts and their California equivalents. The purpose and effect of this Agreement is to substitute arbitration as the forum for resolution of the Claims; all responsibilities of the parties under the statutes applicable to the Claims shall be enforced. We both understand and agree that we are entering into this Agreement voluntarily, and that this Agreement provides for the waiver of our respective rights to a trial by jury on the claims covered by this Agreement.” (Adreani Decl., ¶ 5, Ex. B, § 2.)

As set forth above, Defendants state that Bail Hotline is a subsidiary of DMCG. (Maglanque Decl., ¶ 2.) Defendants state that Plaintiff “was not hired by, nor did he work for Bail Hotline. He was employed by DMCG.” (Maglanque Decl., ¶ 2.) Defendants assert that “[t]o the extent Bail Hotline is consider [sic] to be Plaintiff’s employer, it is a third-party beneficiary of the Arbitration Agreement, as term ‘Employer’ includes subsidiaries of DMCG.” (Mot. at p. 1, fn. 2., citing Adreani Decl., ¶ 5, Ex. B, § 2.) Plaintiff does not dispute this point in the opposition.

In the opposition, Plaintiff does not appear to argue that he did not sign the subject Mediation and Arbitration Agreement. Plaintiff also does not dispute that the Mediation and Arbitration Agreement covers the claims alleged against Defendants in the Complaint. Therefore, the burden now shifts to Plaintiff to prove a ground for denial.

Plaintiff asserts that “even if Plaintiff signed the arbitration clause, the purported agreement is unconscionable.” (Opp’n at p. 8:23-24.)

Plaintiff contends that the “arbitration provision” is procedurally unconscionable. Plaintiff asserts that “the documents Plaintiff supposedly signed are given to prospective employees of Defendants on a take it or leave it basis with no potential for negotiation. Indeed, Defendants’ own Declarant confirms that the process of signing the documents occurs before an employee even begins working for Defendants.” (Opp’n at p. 10:9-12.)

Plaintiff points to the Declaration of Sheryl Maglanque, in which she states, inter alia, that “[o]nce a decision is made to hire [sic] candidate, his or her information is then forwarded to the HR Department.” (Maglanque Decl., ¶ 6.) Ms. Maglanque states that “I or another staff member from the HR Department contacts the candidate on the telephone and an offer is verbally made along with a tentative start date. The staff member explains the positions, the pay, and all the documents that the candidate needs to sign. If the candidate accepts the offer verbally, we will instruct them to complete and send us an application if one had not been submitted prior to the interview. In addition to the application, the candidate will receive an Employment Packet. The Employment Packet consists of the Summary of Compensation and Benefits, California Meal Breaks & Penalties, Non-Disclosure and Non-Compete Agreement, Mediation and Arbitration Agreement (‘Arbitration Agreement’), and Authorization to run a background check. The staff member explains each of these documents to the candidate on the initial call.” (Maglanque Decl., ¶ 7.) Ms. Maglanque states that “[d]uring that initial call, the staff member from the HR Department instructs the candidate to read all the documents, inquires whether the candidate requires additional time to review the documents, inquires whether the candidate has any questions, and requests the candidate’s email address. After the initial call concludes, the HR Department emails the Employment Packet along with an application, if necessary, via DocuSign to the candidate.” (Maglanque Decl., ¶ 8.) Ms. Maglanque indicates that “[o]nce DMCG receives the application and Employment Packet from the candidate, I sign all the necessary agreements and acknowledgments via DocuSign, and initiates [sic] the background check. When the background check is cleared, we confirm the start date with the candidate.” (Maglanque Decl., ¶ 9.)

Plaintiff also asserts that “there is no indication that Plaintiff was free to reject any documents and work for Defendants.” (Opp’n at p. 10:14-15.) In his supporting declaration, Plaintiff states that “to begin my work for Defendants I was required to sign a package of documents sent to me electronically. I have reviewed the declarations submitted by Defendants in support of its Motion as well as the exhibits attached thereto. Though I do not recall signing these documents specifically, I do remember being required to electronically sign a packet of documents electronically to begin my work. These documents were not explained to me either before being sent or when I began work as Defendants’ declarations claim. Rather I was told to sign them to start work and that my copies of them would be the electronic versions I signed.” (Barraza-Benitez Decl., ¶ 5.) Plaintiff further states that “[f]rom what I recall of the electronic signature process Defendants utilized I was not able to pick and choose what I signed, but instead I was required to approve signing each document in the packet of documents on an all or nothing basis. Moreover, I was never given the opportunity to negotiate the terms of the documents presented to me, I was simply required to sign them, as is, to work for the Defendants.” (Barraza-Benitez Decl., ¶ 6.)

Defendants assert that the subject Mediation and Arbitration Agreement is not procedurally unconscionable. They point to the Declaration of Sheryl Maglanque, in which she states that “[d]uring that initial call, the staff member from the HR Department instructs the candidate to read all the documents, inquires whether the candidate requires additional time to review the documents, inquires whether the candidate has any questions, and requests the candidate’s email address.” (Maglanque Decl., ¶ 8.)

Defendants assert that “Plaintiff does not claim that he wanted to negotiate the Arbitration Agreement or that he would have rejected the position because of the Arbitration Agreement. In fact, he had a copy of the Arbitration Agreement and received a few days to review the agreement at his leisure and signed it a day after receiving the employment packet.” (Reply at p. 1:18-22.) Ms. Maglanque states that “I called Plaintiff on June 27, 2019. 1 verbally made the offer and when he accepted, I explained that he would receive the Employment Packet via DocuSign.” (Maglanque Decl., ¶ 11.) Ms. Maglanque further states that “[f]rom the DocuSign’s certificate of completion, it appears that Plaintiff reviewed and signed the various documents between June 27 and June 28.” (Maglanque Decl., ¶ 12.)

The Court also notes that “[w]hen … there is no other indication of oppression or surprise, ‘the degree of procedural unconscionability of an adhesion agreement is low, and the agreement will be enforceable unless the degree of substantive unconscionability is high.’¿” (Serpa ¿v. California Surety Investigations, Inc. (2013) 215 Cal.App.4th 695, 704¿¿¿.)¿¿Based on the foregoing, the Court finds that there is a low level of procedural unconscionability.¿¿

Plaintiff also asserts that the “arbitration provision” is substantively unconscionable. “Substantive unconscionability pertains to the fairness of an agreement’s actual terms and to assessments of whether they are overly harsh or one-sided. A contract term is not substantively unconscionable when it merely gives one side a greater benefit; rather, the term must be so one-sided as to shock the conscience.” (Carmona v. Lincoln Millennium Car Wash, Inc., supra, 226 Cal.App.4th at p. 85 [internal quotations and citation omitted].)

Plaintiff cites to Alberto v. Cambrian Homecare (2023) 91 Cal.App.5th 482, 485-486, where “Jennifer Playu Alberto, the respondent, is a former employee of appellant Cambrian Homecare. When she was hired, Alberto signed a written arbitration agreement. Alberto brought wage-and-hour claims against Cambrian. Cambrian petitioned for arbitration. The trial court denied the petition. The trial court found that even if the parties had formed an arbitration agreement, the agreement had unconscionable terms, terms that so permeated the agreement they could not be severed.” The Court of Appeal affirmed.

“Cambrian hired Alberto on or about September 17, 2019. That same day, as part of her orientation, a Cambrian representative gave her agreements to sign. Three of those agreements relate to resolution of potential disputes: a ‘Dispute Resolution Process—Arbitration Agreement’ (Arbitration Agreement), a ‘Confidentiality Agreement,’ and a ‘Confidentiality Agreement Addendum’ (Addendum).” ((Id. at p. 486.) The Court concluded that “the Arbitration Agreement and the Confidentiality Agreement should be read together. They were executed on the same day. They were both separate aspects of a single primary transaction—Alberto’s hiring. They both governed, ultimately, the same issue—how to resolve disputes arising between Alberto and Cambrian arising from Alberto’s employment. Failing to read them together artificially segments the parties’ contractual relationship.” ((Id. at pp. 490-491.)

The Alberto Court concluded, inter alia, that “[h]ere, the trial court found the Confidentiality Agreement’s injunction provisions made the parties’ agreement to arbitrate insufficiently mutual. The Arbitration Agreement required Alberto to arbitrate all of her claims against Cambrian. But the Confidentiality Agreement allowed Cambrian to obtain—outside of arbitration—an ‘immediate’ injunction for Alberto’s breach of Cambrian’s confidentiality requirements…The trial court’s finding was well supported by California law.” (Alberto v. Cambrian Homecare, supra, 91 Cal.App.5th at p. 492.)

Plaintiff asserts that here, “just as in Alberto, Defendants’ confidentiality agreement allows for Defendants to seek injunctive relief in a court rather than arbitration.” (Opp’n at p. 12:4-5.) In his supporting declaration, Plaintiff’s counsel states that “[w]hen Defendants produced Plaintiff’s personnel file it included what appears to be the entirety of the ‘Employment Packet’ described by Defendants’ declarant Sheryl Maglanque. This Employment packet includes a document entitled ‘Non-Disclosure and Non-Compete Agreement’ and several other documents allegedly signed concurrently with Defendants’ purported Arbitration Agreement. A true and correct copy of the ‘Non-Disclosure and Non-Compete Agreement’ produced by Defendants is attached hereto as ‘Exhibit A.’” (Bass Decl., ¶ 4, Ex. A.) Section 8 of the subject Non-Disclosure and Non-Compete Agreement provides, inter alia, that “[t]he Employee acknowledges that disclosure of any Confidential Information or breach of any of the non-competitive covenants or agreements contained herein will give rise to irreparable injury to Company or clients of Company, inadequately compensable in damages. Accordingly, Company or, where appropriate a client of Company, may seek and obtain injunctive relief against the breach or threatened breach of the foregoing undertakings, in addition to any other legal remedies which may be available.” (Bass Decl., ¶ 4, Ex. A, § 8.)

In the reply, Defendants assert that “[e]ven though the NDA only provides the right to injunctive relief to Defendant and its clients, there is no prohibition on Plaintiff seeking injunctive relief. Further, the NDA seeks to protect Defendant and its client’s trade secrets, therefore, under the NDA, only Defendant would need to seek injunctive relief.” (Reply at p. 4:15-18.) Defendants also note that Section 7 of the Mediation and Arbitration Agreement provides, inter alia, that “[t]his Agreement does not apply to…claims for injunctive and/or other equitable relief for intellectual property violations, unfair competition and/or the use and/or unauthorized disclosure of trade secrets or confidential information…” (Adreani Decl., ¶ 5, Ex. B, § 7.)

Plaintiff notes that the Court of Appeal in Alberto also noted that “[t]he trial court found the Confidentiality Agreement’s prohibition on discussing wages unconscionable. As we describe above, the Confidentiality Agreement treated ‘compensation and salary data and other employee information’ as a supposed ‘trade secret’ that Alberto could be enjoined from discussing.” (Alberto v. Cambrian Homecare, supra, 91 Cal.App.5th at p. 493.) The Court of Appeal noted that “[t]he Labor Code provides that ‘No employer may do any of the following:…(a) Require, as a condition of employment, that an employee refrain from disclosing the amount of his or her wages…(b) Require an employee to sign a waiver or other document that purports to deny the employee the right to disclose the amount of his or her wages…(c) Discharge, formally discipline, or otherwise discriminate against an employee who discloses the amount of his or her wages.’ (Lab. Code, § 232.) The Confidentiality Agreement on its face violated the Labor Code. A facially illegal provision, in direct contravention of the Labor Code, is unconscionable.” (Ibid.)

Plaintiff contends that here, “just like in Alberto, the confidentiality agreement uses sweeping definitions of ‘trade secrets’ to include even greater categories of information that [sic] the ‘compensation and salary data and other employee information’ in contravention of Labor Code section 232.’” (Opp’n at p. 12:9-12.) Plaintiff notes that Section 1 of the Non-Disclosure and Non-Compete Agreement here provides, inter alia, that “[e]mployee recognizes and acknowledges that the systems which Company owns, plans or develops, whether for its own use or for use by its clients, are confidential and are the property of Company…All communications, including but not limited to any meetings, conferences and all written correspondence or verbal communication regarding any type of company strategic or operational plans are covered under this agreement and deemed confidential.” (Bass Decl., ¶ 4, Ex. A, § 1.) But Plaintiff does not appear to point to any provision in the Non-Disclosure and Non-Compete Agreement containing a prohibition on discussing wages.

Further, in Alberto, “[t]he Arbitration Agreement provided that ‘no form of class, collective, or representative action’ would be maintained without the parties’ mutual consent. Citing Iskanian, the trial court found this provision unconscionable because it required Alberto to waive her PAGA claims.” (Alberto v. Cambrian Homecare, supra, 91 Cal.App.5th at p. 494.) The Court of Appeal found that “[b]oth before and after Viking River Cruises, blanket waivers of PAGA claims are unconscionable. Therefore, the trial court’s ruling on this issue was correct.” (Id. at p. 495.) Here, however, Plaintiff does not point to any provision in the subject documents containing a waiver of PAGA claims.

Plaintiff also asserts that “the venue selected in the arbitration clause is unreasonable and highly inconvenient for Plaintiff.” (Opp’n at p. 13:18-19.) The Court notes that Section 4 of the Mediation and Arbitration Agreement provides that “[a]ll arbitrations covered by this Agreement shall be adjudicated in accordance with the state or federal law that would be applied by an Arbitrator sitting at a venue local to Riverside, California chosen pursuant to Employment Rules for Arbitration set by the American Arbitration Association.” (Adreani Decl., ¶ 5, Ex. B, § 4.) Plaintiff states in his supporting declaration that “I live and work in the County of Los Angeles. All of the work I performed for Defendants was in their offices and surrounding courthouses in Los Angeles County. If I am required to arbitrate in Riverside, California it will cost me additional inconvenience, time and expense that I would not be required to endure with litigating in the Los Angeles Superior Court.” (Barraza-Benitez Decl., ¶ 10.)

In the reply, Defendants counter that “Plaintiff [sic] argument that arbitrating in Riverside County is a burden for him is also without merit. Riverside County adjoins Los Angeles County, and the distance between the El Monte office, where Plaintiff worked, and the City of Riverside is approximately forty miles.” (Reply at p. 3:6-8.) In his supporting declaration, Plaintiff states that he “worked completely alone at the El Monte office from about 10 a.m. to 7 or 8 p.m.” (Barraza-Benitez Decl., ¶ 8.) Defendants also state that they are “agreeable to Los Angeles County as the venue for the arbitration.” (Reply at p. 3:12-13.)

Based on the foregoing, the Court finds that Plaintiff has not demonstrated a high level of substantive unconscionability. In light of the finding of only a low level of procedural unconscionability, the Court finds that Plaintiff has not met his burden of demonstrating that the subject Mediation and Arbitration Agreement is unenforceable due to unconscionability.

As set forth above, Defendants move for an order compelling Plaintiff to “to participate in arbitration of his individual claims under the Private Attorney General Act…and stay the representative PAGA claims pending the resolution of the claims at arbitration.” (Notice of Motion at p. ii:7-9.)

“In Viking River Cruises, Inc. v. Moriana (2022) 596 U.S. ___ [213 L. Ed. 2d 179, 142 S.Ct. 1906] (Viking River), the United States Supreme Court considered a predispute employment contract with an arbitration provision specifying that ‘in any arbitral proceeding, the parties could not bring any dispute as a class, collective, or representative PAGA action. It also contained a severability clause specifying that if the waiver was found invalid, any class, collective, representative, or PAGA action would presumptively be litigated in court. But under that severability clause, if any ‘portion’ of the waiver remained valid, it would be ‘enforced in arbitration.’ (Id. at p. ___ [142 S.Ct. at p. 1916].) In light of our state law rule prohibiting wholesale waiver of PAGA claims (Iskanian, supra, 59 Cal.4th at p. 383), the high court construed the severability clause to reflect the parties’ agreement to arbitrate any alleged Labor Code violations personally sustained by a PAGA plaintiff—so-called ‘individual’ claims—and held that the Federal Arbitration Act (FAA) (9 U.S.C. § 1 et seq.) compels enforcement of this agreement. (Viking River, at p. ___ [142 S.Ct. at pp. 1922–1925].) In so holding, the high court declared that the FAA ‘preempted’ a separate state law rule that ‘PAGA actions cannot be divided into individual and non-individual claims’ where the parties have agreed to arbitrate individual claims. (Viking River, at p. ___ [142 S.Ct. at p. 1913].) For consistency, we use the terms ‘individual’ and ‘non-individual’ claims in accordance with the high court’s usage in Viking River.”

The Adolph Court found that “[t]he question here is whether an aggrieved employee who has been compelled to arbitrate claims under PAGA that are ‘premised on Labor Code violations actually sustained by’ the plaintiff maintains statutory standing to pursue ‘PAGA claims arising out of events involving other employees’ in court. We hold that the answer is yes. To have PAGA standing, a plaintiff must be an ‘aggrieved employee’—that is, (1) ‘someone ‘who was employed by the alleged violator’ and (2) ‘against whom one or more of the alleged violations was committed.’ Where a plaintiff has brought a PAGA action comprising individual and non-individual claims, an order compelling arbitration of the individual claims does not strip the plaintiff of standing as an aggrieved employee to litigate claims on behalf of other employees under PAGA.” ((Adolph v. Uber Technologies, Inc., supra, 14 Cal.5th at p. 1114 [internal quotations omitted].)

The Adolph Court further noted that “[n]othing in PAGA or any other relevant statute suggests that arbitrating individual claims effects a severance. When a case includes arbitrable and nonarbitrable issues, the issues may be adjudicated in different forums while remaining part of the same action. Code of Civil Procedure section 1281.4 states that upon ‘order[ing] arbitration of a controversy which is an issue involved in an action,’ the court should ‘stay the action.’ It further provides that ‘[i]f the issue which is the controversy subject to arbitration is severable, the stay may be with respect to that issue only.’ Section 1281.4 does not contemplate that the compelled arbitration of an issue in controversy in the action is a separate action. The statute makes clear that the cause remains one action, parts of which may be stayed pending completion of the arbitration.” ((Adolph v. Uber Technologies, Inc. (2023) 14 Cal.5th 1104, 1124-1125.)

The Court finds that a stay of the “non-individual” PAGA claims is warranted, particularly to avoid inconsistent rulings. Thus, the Court grants Defendants’ request to stay Plaintiff’s non-individual PAGA claims pending completion of arbitration of Plaintiff’s individual PAGA claims.

For the foregoing reasons, Defendants’ motion to compel arbitration is granted as to Plaintiff’s individual PAGA claims. Defendants’ motion is denied as to Plaintiff’s non-individual PAGA claims.

The action is stayed pending completion of arbitration of Plaintiff’s individual PAGA claims.

The Court sets an arbitration completion status conference on January 9, 2025, at 10:00 a.m. in Dept. 50. The parties are ordered to file a joint report regarding the status of the arbitration five court days prior to the status conference, with a courtesy copy delivered directly to Department 50.

Superior Court of California

County of Los Angeles

Department 50