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Nakamura Lozano & Pratt LLP
Finance & Banking
Document types detected
Analysis / memo5
Pleading / procedure4
Correspondence1
Engagement letter1
Other1
Parties across the matter
Client Vantage Mobility Systems CorpCounsel Vantage Mobility Systems CorpDefendant Vantage Mobility Systems CorpHARKNESS LLPHarkness LLPNew Westvale Partners LLCOF CALIFORNIA COUNTY OF SAPratt LLPVantage Mobility Systems CorpVeltrano Analytics LLCWHITFIELD GARZA LLPWhitfield Garza LLP
Chronology
2025-09-11 · insurance-coverage-analysis-memo.docx
… and applicable service rules, Vantage's responsive pleading is due on September 11, 2025. Calderwood & Harkness LLP was engaged as lead defense counsel effective August 4, 2025, …
2025-09-11 · preliminary-case-assessment-memo.docx
… 818 West Seventh Street, Suite 930, Sacramento, California 95814. • September 11, 2025: Responsive pleading deadline (30 days from date of service). C&H intends to file a demur …
2025-09-11 · removal-analysis-memo.docx
… urrer/motion to strike in San Bernardino County Superior Court by the September 11, 2025 responsive pleading deadline, while monitoring developments that could warrant revisiting …
2025-09-11 · settlement-strategy-memo.docx
… Agents, Inc. Accordingly, VMS's responsive pleading deadline falls on September 11, 2025. The matter was opened at C&H on August 4, 2025, and a litigation hold was issued to all …
2025-09-11 · client-status-update-memo-august-2025.docx
… Inc., in Sacramento, California. The responsive pleading deadline is September 11, 2025. The complaint sets forth seven causes of action: (1) meal period violations under Califo …
2025-09-11 · letter-to-ridgeway-defense-cost-reporting.docx
… nia), VMS's registered agent for service of process in California. • September 11, 2025: Deadline for VMS to file a responsive pleading (answer, demurrer, or motion to strike). …
2025-09-11 · engagement-letter-reyes-v-vms.docx
… ing is due 30 days following service, which establishes a deadline of September 11, 2025. C&H will work with your office to determine the most appropriate initial responsive plea …
2025-09-11 · demurrer-motion-to-strike-draft.docx
… ornia 92415. Respectfully submitted, CALDERWOOD & HARKNESS LLP Dated: September 11, 2025 CALDERWOOD & HARKNESS LLP By: ________ Renata Vasquez (SBN 247831) Attorneys for Defendan …
2025-09-05 · removal-analysis-memo.docx
… equest Renata Vasquez's approval of this recommendation no later than September 5, 2025, to allow adequate time for the responsive pleading team to finalize the state court fili …
2025-09-02 · class-cert-opposition-outline.docx
… Vasquez, Responsible Partner, Labor & Employment Practice Group Date: September 2, 2025 Addressees: Internal Working Document — Calderwood & Harkness LLP Litigation Team Client: …
2025-08-29 · client-status-update-memo-august-2025.docx
… Facsimile: (213) 555-8201 www.calderwoodharkness.com MEMORANDUM Date: August 29, 2025 To: Priya Nandakumar, General Counsel, Vantage Mobility Systems Corp. Catherine Hsu, Oper …
2025-08-27 · settlement-strategy-memo.docx
… est Fifth Street, Suite 4400 Los Angeles, California 90071 MEMORANDUM August 27, 2025 FROM: Renata Vasquez, Responsible Partner, Labor & Employment Practice Group, Calderwood …
2025-08-27 · expert-retention-letter-proulx.docx
… : (213) 555-7200 Facsimile: (213) 555-7201 www.calderwoodharkness.com August 27, 2025 VIA ELECTRONIC MAIL AND FIRST CLASS MAIL Dr. Kenneth Proulx, Ph.D. Veltrano Analytics LLC …
2025-08-25 · letter-to-ridgeway-defense-cost-reporting.docx
… 7200 Facsimile: (213) 488-7201 Email: rvasquez@calderwoodharkness.com August 25, 2025 Via Email and U.S. Mail Neil Pemberton, AVP – Complex Claims Ridgeway National Insurance …
2025-08-25 · engagement-letter-reyes-v-vms.docx
… providing our recommended responsive-pleading strategy no later than August 25, 2025. 3. Scope of Representation Matters Included. C&H's engagement is limited to the defense …
2025-08-22 · insurance-coverage-analysis-memo.docx
… Partner, and Devon Archer, Associate, Calderwood & Harkness LLP DATE: August 22, 2025 RE: Insurance Coverage Analysis — Ridgeway National Insurance Company Reservation of Righ …
2025-08-22 · client-status-update-memo-august-2025.docx
… mes Underwood and Devon Archer, and circulated to Priya Nandakumar on August 22, 2025. That memorandum, which is protected by the attorney-client privilege and the work produc …
2025-08-21 · expert-retention-letter-proulx.docx
… : Thank you for meeting with me and members of our litigation team on August 21, 2025 to discuss your potential engagement as a testifying expert in the above-referenced matte …
2025-08-20 · removal-analysis-memo.docx
… , Lead Associate, Labor & Employment, Calderwood & Harkness LLP DATE: August 20, 2025 RE: Removal Analysis — Gloria Reyes, individually and on behalf of all others similarly s …
2025-08-18 · insurance-coverage-analysis-memo.docx
… idgeway National Insurance Company Reservation of Rights Letter Dated August 18, 2025; EPL Policy No. EPL-VMS-2024-07821; Gloria Reyes, individually and on behalf of all other …
2025-08-18 · preliminary-case-assessment-memo.docx
… Vasquez, Responsible Partner, Labor & Employment Practice Group DATE: August 18, 2025 RE: Preliminary Case Assessment — Gloria Reyes, individually and on behalf of all others …
2025-08-18 · letter-to-ridgeway-defense-cost-reporting.docx
… "Ridgeway" or "Ridgeway National") Reservation of Rights letter dated August 18, 2025, pursuant to which Ridgeway has agreed to fund defense costs in the above-captioned matte …
2025-08-15 · insurance-coverage-analysis-memo.docx
… minary Case Assessment Memorandum transmitted under separate cover on August 15, 2025, the maximum theoretical exposure for all statutory categories exceeds $65 million. This …
2025-08-12 · insurance-coverage-analysis-memo.docx
… August 1, 2025. Vantage was served with the summons and complaint on August 12, 2025 via its registered agent for service of process, CT Agents, Inc., in Sacramento, Californ …
2025-08-12 · preliminary-case-assessment-memo.docx
… s. The litigation hold is discussed further in Section IX.B below. • August 12, 2025: Vantage was served with the summons and complaint through its registered agent for servi …
2025-08-12 · removal-analysis-memo.docx
… adline: The 30-day removal window under 28 U.S.C. § 1446(b) runs from August 12, 2025, the date on which VMS was served via its California registered agent, CT Agents, Inc. Th …
2025-08-12 · settlement-strategy-memo.docx
… of California, County of San Bernardino, and service was completed on August 12, 2025, via CT Agents, Inc. Accordingly, VMS's responsive pleading deadline falls on September 1 …
2025-08-12 · litigation-hold-memorandum.docx
… Fontana Plant"). Vantage was served with the summons and complaint on August 12, 2025, via its registered agent, CT Agents, Inc., in Sacramento, California. The purpose of thi …
2025-08-12 · client-status-update-memo-august-2025.docx
… Tran as co-counsel. Service of the complaint was perfected on VMS on August 12, 2025 through its registered agent, CT Agents, Inc., in Sacramento, California. The responsive …
2025-08-12 · letter-to-ridgeway-defense-cost-reporting.docx
… nia, County of San Bernardino, assigned Case No. CIVSB-2025-04781. • August 12, 2025: VMS served with the Summons and Complaint via CT Agents, Inc. (Sacramento, California), …
2025-08-12 · engagement-letter-reyes-v-vms.docx
… sponsive-Pleading Deadline. Service of the Complaint was completed on August 12, 2025, via VMS's agent for service of process, CT Agents, Inc., located at 818 West Seventh Str …
2025-08-12 · answer-to-complaint-draft.docx
… laintiff") in this action on August 1, 2025, and served on Vantage on August 12, 2025. Vantage responds to each and every allegation of the Complaint as specifically set forth …
2025-08-12 · demurrer-motion-to-strike-draft.docx
… er CIVSB-2025-04781. VMS was served with the Summons and Complaint on August 12, 2025 through CT Agents, Inc., its registered agent for service of process in California, locat …
2025-08-08 · litigation-hold-memorandum.docx
… es at any time from August 4, 2021 through the present, no later than August 8, 2025. 5. All HR department staff at the Fontana Plant responsible for timekeeping administrat …
2025-08-05 · preliminary-case-assessment-memo.docx
… preliminary review of the complaint and available client records. • August 5, 2025: A comprehensive litigation hold notice was issued to Vantage through Priya Nandakumar, G …
2025-08-05 · settlement-strategy-memo.docx
… 5, and a litigation hold was issued to all relevant VMS custodians on August 5, 2025. The named plaintiff, Gloria Reyes, is a former Production Associate who worked on Trim L …
2025-08-05 · litigation-hold-memorandum.docx
… utierrez, Fontana Plant Manager, Vantage Mobility Systems Corp. DATE: August 5, 2025 RE: Litigation Hold Notice — Gloria Reyes, individually and on behalf of all others simil …
2025-08-05 · client-status-update-memo-august-2025.docx
… icable litigation management guidelines. B. Litigation Hold Issued On August 5, 2025, James Underwood prepared and issued a privileged litigation hold memorandum directed to …
2025-08-05 · letter-to-ridgeway-defense-cost-reporting.docx
… ion for class certification. • August 4, 2025: C&H matter opened. • August 5, 2025: Litigation hold notice issued to VMS management, IT department, and relevant custodians …
2025-08-04 · insurance-coverage-analysis-memo.docx
… lderwood & Harkness LLP was engaged as lead defense counsel effective August 4, 2025, following Vantage's receipt of an advance courtesy copy of the complaint from plaintiff' …