Contract analysis
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Contract analysis / draft-answer-fuentes.docx
draft-answer-fuentes.docx
High · 1
Medium · 0
Standard · 0
1. That Plaintiff take nothing by reason of the Complaint, and that each and every cause
1. That Plaintiff take nothing by reason of the Complaint, and that each and every cause of action therein be dismissed with prejudice;
2. That judgment be entered in favor of Defendant and against Plaintiff on all causes of
2. That judgment be entered in favor of Defendant and against Plaintiff on all causes of action;
3. That Plaintiff's request for class certification be denied;
3. That Plaintiff's request for class certification be denied;
4. That Plaintiff's PAGA claims be dismissed for lack of standing or, in the alternative,
High
⚑ Penalty / liquidated damages
4. That Plaintiff's PAGA claims be dismissed for lack of standing or, in the alternative, that any PAGA penalties be reduced in the Court's discretion;
5. That Defendant be awarded its costs of suit incurred herein; and
5. That Defendant be awarded its costs of suit incurred herein; and
6. For such other and further relief as this Court deems just and proper.
6. For such other and further relief as this Court deems just and proper. Dated: ___, 2022 CALDERWOOD & HARKNESS LLP By: ________ Renata Vasquez (SBN XXXXXX) Devon Archer (SBN XXXXXX) 777 South Flower Street, Suite 4200 Los Angeles, California 90017 Telephone: (213) 555-7200 Attorneys for Defendant AURELIUS MEDIA AMERICAS INC. [DRAFT — pending client review and filing. Expected filing date: February 17, 2023, followi