Contract analysis

I. IDENTIFICATION OF PARTIES AND COUNSEL Plaintiff Marisol Fuentes is an individual residing in the County of Los Angeles, State of California, who brings this action individually and on behalf of all others similarly situated. Plaintiff Fuentes appears by and through her attorneys of record, Castellano Byrne & Salas LLP (Marco Castellano, State Bar No. 198422; Diane Salas), 11755 Wilshire Boulevard, Suite 900, Los A

II. RECITALS A. The Fuentes Action. On November 1, 2022, Plaintiff Marisol Fuentes filed a putative class action complaint in the Superior Court of the State of California, County of Los Angeles, styled Marisol Fuentes v. Aurelius Media Americas Inc., Case No. 22STCV38214 (the "Fuentes Action"). The Fuentes Action alleges wage-and-hour violations under the California Labor Code, including, without limitation, claims

I. Notice of Related Case. On November 28, 2022, Defendant Aurelius Media Americas Inc. filed a Notice of Related Case in Case No. 22STCV38214, identifying Case No. 22STCV39501 (Halloran v. Aurelius Media Americas Inc.) as a related case within the meaning of California Rules of Court, Rule 3.300. The Notice of Related Case established that both actions involve the same parties, arise from the same or substantially i

III. STIPULATED TERMS Based upon the foregoing recitals, which are incorporated herein by this reference, the parties hereby stipulate and agree as follows:

1. Lead Case. Case No. 22STCV38214 (Fuentes v. Aurelius Media Americas Inc.) shall be designated the lead case for all purposes in connection with the consolidated action.

2. Consolidation. Case No. 22STCV39501 (Halloran v. Aurelius Media Americas Inc.) shall be consolidated with Case No. 22STCV38214 (Fuentes v. Aurelius Media Americas Inc.) for all purposes, including, without limitation, discovery, law and motion practice, class certification proceedings, trial, and any settlement proceedings. The consolidation shall be complete; that is, the two actions shall be merged into a single

3. Future Filings. Following entry of the order granting consolidation, all future filings in the consolidated action shall be made exclusively in Case No. 22STCV38214. No further filings shall be made in Case No. 22STCV39501, except as may be necessary to effectuate the consolidation (including, without limitation, the filing of a notice of consolidation or clerk's transfer order in the Halloran Action file) or as o

4. Caption. Following consolidation, all pleadings, motions, briefs, declarations, discovery requests and responses, correspondence with the Court, and other papers filed in the consolidated action shall bear the caption of Case No. 22STCV38214, with the following named plaintiffs listed in the caption: Marisol Fuentes, Derek Halloran, and Yesenia Padilla. The caption shall reflect that each named plaintiff brings th

5. Consolidated Amended Complaint. Within twenty (20) calendar days of the Court's entry of the order granting consolidation, Plaintiffs' counsel shall file a Consolidated Amended Complaint in Case No. 22STCV38214. The Consolidated Amended Complaint shall name Marisol Fuentes, Derek Halloran, and Yesenia Padilla as named plaintiffs and shall assert all claims from both the Fuentes Action complaint and the Halloran Ac

6. Responsive Pleading. Defendant Aurelius Media Americas Inc. shall have thirty (30) calendar days from service of the Consolidated Amended Complaint to file its responsive pleading, which may include an answer, demurrer, motion to strike, or other responsive pleading permitted under the California Code of Civil Procedure. This deadline shall be calculated in accordance with the applicable provisions of the Code of

7. Assignment. The parties respectfully request that the consolidated action be assigned for all purposes to the department of the Superior Court to which Case No. 22STCV38214 is currently assigned. The parties understand that Case No. 22STCV38214 is currently assigned to the Honorable Raymond Escobedo in Department 34 of the Los Angeles Superior Court, Stanley Mosk Courthouse, and respectfully request that the conso

8. Preservation of Rights. This Stipulation is entered into solely for the purpose of promoting judicial economy and the efficient resolution of these related actions. Nothing in this Stipulation is intended to, nor shall it be construed to, waive, limit, modify, or otherwise affect any party's rights, claims, defenses, or remedies in this litigation, whether arising under statute, common law, or equity. Without limi

9. No Admission. This Stipulation, and the consolidation of the Fuentes Action and the Halloran Action, shall not be construed as an admission by any party regarding the merits of any claim or defense asserted or to be asserted in either action. The parties enter into this Stipulation without prejudice to their respective positions on any issue in this litigation.

IV. SIGNATURES Dated: January 27, 2023 FOR PLAINTIFFS MARISOL FUENTES, DEREK HALLORAN, AND YESENIA PADILLA: CASTELLANO BYRNE & SALAS LLP By: ________ Marco Castellano (SBN 198422) 11755 Wilshire Boulevard, Suite 900 Los Angeles, California 90025 Telephone: (310) 555-4210 Facsimile: (310) 555-4211 Attorneys for Plaintiffs Marisol Fuentes, Derek Halloran, and Yesenia Padilla FOR DEFENDANT AURELIUS MEDIA AMERICAS INC.:

1. Case No. 22STCV39501 (Derek Halloran v. Aurelius Media Americas Inc.) is hereby consolidated with Case No. 22STCV38214 (Marisol Fuentes v. Aurelius Media Americas Inc.) for all purposes, including, without limitation, discovery, law and motion practice, class certification proceedings, trial, and any settlement proceedings.

2. Case No. 22STCV38214 (Fuentes v. Aurelius Media Americas Inc.) shall be and hereby is designated the lead case. All future filings in the consolidated action shall be made in Case No. 22STCV38214. The Clerk of the Court is directed to note the consolidation in the case management system for both Case No. 22STCV38214 and Case No. 22STCV39501.

3. Plaintiffs shall file a Consolidated Amended Complaint in Case No. 22STCV38214 within twenty (20) calendar days of the date of this Order. The Consolidated Amended Complaint shall name Marisol Fuentes, Derek Halloran, and Yesenia Padilla as named plaintiffs and shall assert all claims from both the Fuentes Action and the Halloran Action in a single pleading.

4. Defendant Aurelius Media Americas Inc. shall have thirty (30) calendar days from service of the Consolidated Amended Complaint to file its responsive pleading, including any answer, demurrer, motion to strike, or other responsive pleading.

5. This matter is assigned for all purposes to the Honorable Raymond Escobedo, Department 34, Stanley Mosk Courthouse, 111 North Hill Street, Los Angeles, California 90012. Dated: February 3, 2023 ________________________________________ HON. RAYMOND ESCOBEDO Judge of the Superior Court This Order was entered by the Court on February 3, 2023. A court-stamped, filed copy of this Order is retained in the matter file of