39 minute read
WESTSIDE HAPPENINGS
Have an event for the calendar? Send it to kkirk@ timespublications.com
Disney+ Day Friday, Nov. 12
Disney+ is making its way to select cities around the globe for an interactive pop-up installation of larger-than-life inflatable balloons in celebration of Disney+ Day, which will be a celebration of the Disney+ global community. The uplifting stunt gives fans the opportunity to pose with their favorite characters and moments from the brand.
Santa Monica Pier, Santa Monica, Noon to 8 p.m.
“Word Salad, Fashionistas and Girlfriends” Book Signing Saturday, Nov. 13
Enjoy a special book signing and trunk show with Kathryn Pellman at Village Well Books & Coffee. “Word Salad, Fashionistas and Girlfriends” is her amusing book of found poems and literary collage. She will introduce the whimsical, playful, long-limbed and knobby-kneed Fashionistas, including the Awesome Sewists Wine & Fabric Collective, as they tell their stories, enjoy and navigate life, friends and romance, both real and imagined. Event is free, no ticket required.
9900 Culver Blvd., Culver City, 4 p.m.
On Sunday, Nov. 14 from 5 to 6:15 p.m., discover Santa Monica’s diverse stories through murals during Santa Monica WALL to WALL, a special webinar and self-guided tour.
only, limited to only 100 numbered copies. Get your copies signed by true Venice legends in person.
15 Washington Blvd., Venice, 5 to 7 p.m.
“Venice Stories Vol. 3” Book Release & Signing Party Saturday, Nov. 13
Celebrating 75 stories with the release of Jason Hill’s “Venice Stories Volume 3” at Hinano Café. The event will feature live music by the Venice Street Legends and the Brobots. Books will be available for $20 cash
Comedy & Cocktails Saturday, Nov. 13
Enjoy a stand-up comedy show including talent from Comedy Central, Netflix and HBO presented by Silicon Beach Social at Women’s Club of Playa del Rey. At 5 p.m. there will be a pizza pop-up and beverages followed by the 7 pm. show. A portion of proceeds will be donated to B.R.I.D.G.E., a charity focused on equality in education and mental health resources to help fight childhood adversity and trauma. Tickets cost $30 and are available through Eventbrite or at the door.
8039 West Manchester Ave.,
On Friday, Nov. 12 from noon to 8 p.m., Disney+ is hosting an interactive pop-up installation of larger-than-life inflatable balloons on the Santa Monica Pier to celebrate the Disney+ global community.
COURTESY OF DISNEY+
Dug Mug & The Thugs Saturday, Nov. 13
Check out a live performance at the Cinema Bar by Dug Mug and The Thugs – a blues band featuring Dug Mug Swanson of Nashville fame on bass with Bubba Blues on guitar/dobro, J.R. Lozano on drums and special guest Chef Denny on harmonica. No cover charge.
3967 Sepulveda Blvd., Culver City, 8 p.m.
Los Angeles Television, Script & Film Festival Nov. 13 & 14
27 films, 26 screenplays and one stage play. Screenings and Q&As with film directors, producers, actors and writers at Promenade Playhouse. Make new connections. It’s the perfect place to meet film and TV industry people. Single tickets are $10 per block. $30 passes for all films on Saturday, $30 passes for all films Sunday.
1404 3rd St. Promenade., Santa Monica, 1 p.m., latvsff.org
Santa Monica WALL to WALL Sunday, Nov. 14
Santa Monica is home to over 130 murals – each has a story to tell or an issue to air. Discover the social, historic and aesthetic significance of Santa Monica’s outdoor murals at this virtual fall event featuring a special webinar paired with a self-guided tour. Join Santa Monica College professor Elizabeth Dastin as she discusses the craft and messaging of street murals, key artworks in Santa Monica and the inherent preservation challenges faced by the medium, and meet three artists who have created colorful murals from Ocean Avenue to the Santa Monica Airport. Admission is $20 for Conservancy members and $30 for the general public. Registrants will receive a print and digital booklet after the webinar for the self-guided tour.
Webinar, Santa Monica, 5 p.m., smconservancy.org
Second Sunday Jazz Sunday, Nov. 14
Second Sunday Jazz is back at Mt. Olive Lutheran Church. After nearly 20 months, live jazz is back. Guest jazz musicians are the Christian Jacob Trio. $10 suggested donation at the door. Face masks and COVID vaccination required. Free parking. Everyone is welcome.
1343 Ocean Park Blvd., Santa Monica, 5 p.m.
The Story of Plastic Wednesday, Nov. 17
“The Story of Plastic” is a searing expose revealing the ugly truth behind plastic pollution and the false solution of plastic recycling. Different from every other plastic documentary you’ve seen, this presents a cohesive timeline of how we got to our current global plastic pollution crisis and how the oil and gas industry has successfully manipulated the narrative around it. From the extraction of fossil fuels and plastic disposal to the global resistance fighting back, “The Story of Plastic” is a life-changing film depicting one of the world’s most pressing environmental issues. Two lucky winners will receive a Zero Waste Kit. A panel discussion will follow the film. A link to the event will be sent the day of the event. Event is free but you must register online.
Online, 6 p.m., storyofplastic_sm.eventbrite.com
Holiday Boutique Saturday, Nov. 20
The Woman’s Club of Playa del Rey is hosting their annual Holiday Boutique, an exciting one-day shopping event of handcrafted, homemade, home baked, one-of-a-kind treasures made by local talent. There will be a canned food drive for LAX Pantry, food trucks and an opportunity drawing. The raffle benefits the Woman’s Club Scholarship Fund. Event will take place in the rear parking lot of the Woman’s Club. For more information, contact wcprdholidayboutique@gmail.com.
8039 W. Manchester Ave., Playa del Rey, 8 a.m. to 3 p.m., wcpdr.org
Send event information at least 10 days in advance to kkirk@ timespublications.com
Classifieds / Legals
DEADLINE: Monday at 11am for Thursdays CALL ANN: 626-584-8747 or EMAIL: ann@argonautnews.com
Fic. Business Name
FICTITIOUS BUSINESS NAME S T A T E M E N T F I L E N O . 2 0 2 1 2 1 8 5 4 1
The following person(s) is (are) doing business as: MAQUETTE. 507 N. Larchmont Boulevard Los Angeles, CA 90004. COUNTY: Los Angeles. REGISTERED OWNER(S) J. Latter Design LLC, 608 N. Edinburgh Avenue Los Angeles, CA 90048, Caitlin Scanlon, 443 ½ S. Norton Avenue Los Angeles, CA 90020 . State of Incorporation or LLC: California. THIS BUSINESS IS CONDUCTED BY Joint Venture. The date registrant commenced to transact business under the fictitious business name or names listed above on: N/A. I declare that all information in this statement is true and correct. (A registrant who declares as true any material matter pursuant to Section 17913 of the Business and Professions Code that the registrant know to be false is guilty of a misdemeanor punishable by a fine not to exceed one thousand dollars ($1,000)). REGISTRANT/CORP/LLC NAME: J. Latter Design LLC, Julie Goldman. TITLE: General Partner. This statement was filed with the LA County Clerk on: October 5, 2021. NOTICE – in accordance with subdivision (a) of Section 17920, a Fictitious Name statement generally expires at the end of five years from the date on which it was filed in the office of the county clerk, except, as provided in subdivision (b) of Section 17920, where it expires 40 days after any change in the facts set forth in the statement pursuant to Section 17913 other than a change in the residence address of a registered owner. a new Fictitious Business Name statement must be filed before the expiration. The filing of this statement does not of itself authorize the use in this state of a fictitious business name in violation of the rights of another under federal, state, or common law (see Section 14411 et seq., Business and Professions code). Publish: The Argonaut Newspaper. Dates: 10/28/21, 11/04/21, 11/11/21, 11/18/21
FICTITIOUS BUSINESS NAME S T A T E M E N T F I L E N O . 2 0 2 1 2 2 0 5 0 5
Type of Filing: Original. The following person(s) is (are) doing business as: LANGHE CUCINA LLC. 16711 Hawthorne Blvd., Lawndale, CA 90260. COUNTY: Los Angeles. REGISTERED OWNER(S) LANGHE CUCINA LLC, 16711 Hawthorne Blvd., Lawndale, CA 90260. State of Incorporation or LLC: California. THIS BUSINESS IS CONDUCTED BY a Limited Liability Company. The date registrant commenced to transact business under the fictitious business name or names listed above on: 08/2021. I declare that all information in this statement is true and correct. (A registrant who declares as true any material matter pursuant to Section 17913 of the Business and Professions Code that the registrant know to be false is guilty of a misdemeanor punishable by a fine not to exceed one thousand d o l l a r s ( $ 1 , 0 0 0 ) ) . REGISTRANT/CORP/LLC NAME: Pierpaolo Mattei. TITLE: President, Corp or LLC Name: LANGHE CUCINA LLC. This statement was filed with the LA County Clerk on: October 07, 2021. NOTICE – in accordance with subdivision (a) of Section 17920, a Fictitious Name statement generally expires at the end of five years from the date on which it was filed in the office of the county clerk, except, as provided in subdivision (b) of Section 17920, where it expires 40 days after any change in the facts set forth in the statement pursuant to Section 17913 other than a change in the residence address of a registered owner. a new Fictitious Business Name statement must be filed before the expiration. The filing of this statement does not of itself authorize the use in this state of a fictitious business name in violation of the rights of another under federal, state, or set forth in the statement pursuant to Section 17913 other than a change in the residence address of a registered owner. a new Fictitious Business Name statement must be filed before the expiration. The filing of this statement does not of itself authorize the use in this state of a fictitious business name in violation of the rights of another under federal, state, or common law (see Section 14411 et seq., Business and Professions code). Publish: The Argonaut Newspaper. Dates: 10/28/21, 11/04/21, 11/11/21, 11/18/21
FICTITIOUS BUSINESS NAME STATEMENT FILE NO. 2021227146
The following person(s) is (are) doing business as: POPULUSS. 800 N. Topanga Canyon Blvd. Topanga, CA 90290. COUNTY: Los Angeles. REGISTERED OWNER(S) New Rising Sun LLC, 800 N. Topanga Canyon Blvd. Topanga, CA 90290. State of Incorporation or LLC: California. THIS BUSINESS IS CONDUCTED BY a Limited Liability Company. The date registrant commenced to transact business under the fictitious business name or names listed above on: N/A. I declare that all information in this statement is true and correct. (A registrant who declares as true any material matter pursuant to Section 17913 of the Business and Professions Code that the registrant know to be false is guilty of a misdemeanor punishable by a fine not to exceed one thousand dollars ($1,000)). REGISTRANT/CORP/LLC NAME: Joseph Recsnik. TITLE: President, Corp or LLC Name: New Rising Sun LLC. This statement was filed with the LA County Clerk on: October 19, 2021. NOTICE –in accordance with subdivision (a) of Section 17920, a Fictitious Name statement generally expires at the end of five years from the date on which it was filed in the office of the county clerk, except, as provided in subdivision (b) of Section 17920, where it expires 40 days after any change in the facts set forth in the statement pursuant to Section 17913 other than a change in the residence address of a registered owner. a new Fictitious Business Name statement must be filed before the expiration. The filing of this statement does not of itself authorize the use in this state of a fictitious business name in violation of the rights of another under federal, state, or common law (see Section 14411 et seq., Business and Professions code). Publish: The Argonaut Newspaper. Dates: 11/11/21, 11/18/21, 11/25/21, 12/02/21 Name Change
AMENDMENT ORDER TO SHOW CAUSE FOR CHANGE OF NAME Case No. 21TRCP00366
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES. Petition of BY AND THRU HIS GUARDIAN ADLITEM OCTAVIO AND MARIANA SALAS, for Change of Name. TO ALL INTERESTED PERSONS: 1.) Petitioner: Octavio Brandon Salas III by and thru his guardian adlitem Mariana and Octavio Salas filed a petition with this court for a decree changing names as follows: a.) Octavio Brandon Salas III to Brandon Octavio Salas III 2.) THE COURT ORDERS that all persons interested in this matter appear before this court at the hearing indicated below to show cause, if any, why the petition for change of name should not be granted. Any person objecting to the name changes described above must file a written objection PAGE 20 THE ARGONAUT NOVEMBER 11, 2021that includes the reasons for the objection at least two court days before the matter is scheduled to be heard and must appear at the hearing to petition for change of name should not be granted. Any person objecting to the name changes described above must file a written objection that includes the reasons for the objection at least two court days before the matter is scheduled to be heard and must appear at the hearing to show cause why the petition should not be granted. If no written objection is timely filed, the court may grant the petition without a hearing. NOTICE OF HEARING: Date: 12/17/2021. Time: 9:00 AM. Dept.: M. The address of the court is 825 Maple Ave., Torrance, CA 90503-Torrance Courthouse. A copy of this Order to Show Cause shall be published at least once each week for four successive weeks prior to the date set for hearing on the petition in the following newspaper of general circulation, printed in this county: Los Angeles. Original filed: November 02, 2021. Deirdre Hill, Judge of the Superior Court. PUBLISH: The Argonaut Newspaper 11/04/21, 11/11/21, 11/18/21, 11/25/21
ORDER TO SHOW CAUSE
FOR CHANGE OF NAME
Case No. 21SMCP00632
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES. Petition of CHANDNI SINGH, for Change of Name. TO ALL INTERESTED PERSONS: 1.) Petitioner: Chandni Singh filed a petition with this court for a decree changing names as follows: a.) Chandni Singh to Chandni Singh Gallagher 2.) THE COURT ORDERS that all persons interested in this matter appear before this court at the hearing indicated below to show cause, if any, why the petition for change of name should not be granted. Any person objecting to the name changes described above must file a written objection that includes the reasons for the objection at least two court days before the matter is scheduled to be heard and must appear at the hearing to show cause why the petition should not be granted. If no written objection is timely filed, the court may grant the petition without a hearing. NOTICE OF HEARING: Date: 01/21/2022. Time: 8:30 AM. Dept.: K. The address of the court is 1725 Main Street Santa Monica, CA 90401Santa Monica Courthouse. A copy of this Order to Show Cause shall be published at least once each week for four successive weeks prior to the date set for hearing on the petition in the following newspaper of general circulation, printed in this county: Los Angeles. Original filed: November 03, 2021. Lawrence Cho, Judge of the Superior Court. PUBLISH: The Argonaut Newspaper 11/11/21, 11/18/21, 11/25/21, 12/02/21
Summons
SUMMONS (CITACION JUDICIAL) Case Number (Número del Caso): 21STCV22037
NOTICE TO DEFENDANT (AVISO AL DEMANDADO): HAZEL IMOGEN RALPH, an individual; and HELLO HAZIE, LLC, a California Limited Liability Company; DOES 1 through 10, inclusive; YOU ARE BEING SUED BY PLAINTIFF (LO ESTA DEMANDANDO EL DEMANDANTE): IMPACT NETWORKING, LLC, an Illinois Limited Liability Company; and IMPACT LA, LLC, a California Limited Liability Company NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the information below. You have 30 CALENDAR Liability Company; and IMPACT LA, LLC, a California Limited Liability Company NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the information below. You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts Online Self-Help Center (www.courtinfo.ca.gov/selfhelp), your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask the court clerk for a fee waiver form. If you do not file your response on time, you may lose the case by default, and your wages, money, and property may be taken without further warning from the court.There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to call an attorney referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate these nonprofit groups at the California Legal Serv i c e s W e b s i t e (www.lawhelpcalifornia.org), the California Courts Online S e l f - H e l p C e n t e r (www.courtinfo.ca.gov/selfhelp), or by contacting your local court or county bar association. Tiene 30 DÍAS DE CALENDARIO después de que le entreguen esta citación y papeles legales para presentar una respuesta por escrito en esta corte y hacer que se entregue una copia al demandante. Una carta o una llamada telefónica no lo protegen. Su respuesta por escrito tiene que estar en formato legal correcto si desea que procesen su caso en la corte. Es posible que haya un formulario que usted pueda usar para su respuesta. Puede encontrar estos formularios de la corte y más información en el Centro de Ayuda de las Cort e s d e C a l i f o r n i a (www.courtinfo.ca.gov/selfhelp/espanol/), en la biblioteca de leyes de su condado o en la corte que le quede más cerca. Si no puede pagar la cuota de presentación, pida al secretario de la corte que le dé un formulario de exención de pago de cuotas. Si no presenta su respuesta a tiempo, puede perder el caso por incumplimiento y la corte le podrá quitar su sueldo, dinero y bienes sin más advertencia. Hay otros requisitos legales. Es recomendable que llame a un abogado inmediatamente. Si no conoce a un abogado, puede llamar a un servicio de remisión a abogados. Si no puede pagar a un abogado, es posible que cumpla con los requisitos para obtener servicios legales gratuitos de un programa de servicios legales sin fines de lucro. Puede encontrar estos grupos sin fines de lucro en el sitio web de California Legal Services, (www.lawhelpcalifornia.org), en el Centro de Ayuda de las Cortes de C a l i f o r n i a , (www.courtinfo.ca.gov/selfhelp/espanol/) o poniéndose en contacto con la corte o el colegio de abogados locales. The name and address of the court is (El nombre y dirección de la corte es): Superior Court of the State of California, county of Los Angeles, Central Division, Stanley Mosk Courthouse help/espanol/) o poniéndose en contacto con la corte o el colegio de abogados locales. The name and address of the court is (El nombre y dirección de la corte es): Superior Court of the State of California, county of Los Angeles, Central Division, Stanley Mosk Courthouse, 111 N. Hill Street, Los Angeles, CA 90012. The name, address, and telephone number of plaintiff's attorney, or plaintiff without an attorney, is (El nombre, la dirección y el número de teléfono del abogado del demandante, o del demandante que no tiene abogado, es): Robert L. Rosenthal 9595 Wilshire Blvd., Suite 900 Beverly Hills, CA 90212 ; Tel: (702) 257-1483 DATE (Fecha): June 14, 2021; Sherri R. Carter, Clerk (Secretario), by C. Monroe, Deputy (Adjunto)
SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES, STANLEY MOSK COURTHOUSE Case No.: 21STCV22037
IMPACT NETWORKING, LLC, an Illinois Limited Liability Company; and IMPACT LA, LLC, a California Limited Liability Company,
vs.
Plaintiffs,
HAZEL IMOGEN RALPH, an individual; and HELLO HAZIE, LLC, a California Limited Liability Company; DOES 1 through 10, 17 inclusive, Defendants.
COMPLAINT FOR: 1. BREACH OF DUTY OF LOYALTY 2. UNFAIR COMPETITION (Cal. Bus. & Prof. Code§ 17200 et seq.) JURY TRIAL DEMANDED
Plaintiffs, IMPACT NETWORKING, LLC and IMPACT LA, LLC, for its Complaint against Defendants HAZEL IMOGEN RALPH and HELLO HAZIE, LLC, alleges as follows:
1. THE PARTIES Plaintiff, Impact Networking, LLC ("Impact Networking"), is an Illinois Limited Liability Company, which at all relevant times, has been duly licensed to conduct business in the State of California, and has had an office in Los Angeles County, California. 2. Plaintiff, Impact LA, LLC ("Impact LA"), is a California Limited Liability Company duly licensed to conduct business in California, has an office in Los Angeles County, California, and is a wholly owned subsidiary of lmpact Networking. (Collectively, Impact Networking and Impact LA shall be referred to herein as "Impact" .) 3. Defendant Hazel Imogen Ralph ("Ralph) is an individual residing in Los Angeles County, California. 4. Defendant, Hello Hazie, LLC ("Hello Hazie") is a California Limited Liability 5 Company located in Los Angeles County, California. 5. The true names and capacities, whether individual, corporate, associate or otherwise, of the defendants Does 1 through 10, inclusive, and each of them, are unknown to Plaintiffs, who therefore sue said Defendants by said fictitious names. When the identities and capacities of Does 1 through 10, 9 inclusive, become known to Plaintiffs, they will amend their Complaint. The term "Defendants, 6. This Court has jurisdiction over all causes of action asserted in this Complaint pursuant 13 to the California Constitution, Article VI, Section 10, California Business & Professions Code § 17204, 14 and California Code of Civil Procedure§ 410.10, by virtue of the fact that this is a civil action wherein 15 the matter in controversy, exclusive of interest, exceeds $25,000, and because this case is a cause not 16 given by statute to other trial courts. 7. Venue is proper in Los Angeles County under California Code of Civil Procedure § 395 18 because: (a) Defendant resides in Los Angeles County, California; (b) one or more of the acts, breaches, and other wrongful conduct giving rise to the causes of action asserted occurred or was to be performed in Los Angeles County, California; and (c) the obligations to be performed by Ralph at issue in this Complaint were to be performed in Los Angeles County, California.
GENERAL ALLEGATIONS
8. Impact own and operate integrated business technology companies that provide information technology services to individuals and businesses that include such things as website design, product design, cybersecurity, process optimization, marketing, and print services. 9. On April 23, 2018, Ralph began working as a Senior Art Director for Impact Networking at its office in Lake Forest, Illinois, and was paid an initial annual salary of $85,000, plus benefits. 10. On December 2, 2019, Impact Networking promoted Ralph to Associate Creative 3 Director, and her annual salary was increased to $105,000, plus benefits. 11. In or around August 2020, Ralph agreed to relocate from Lake Forest, Illinois to Los 5 Angeles, California and to work for Impact as Creative Director at its office in Los Angeles at an annual 6 salary of $131,250, plus benefits. 12. As part of Impact's and Ralph's agreement to relocate to Los Angeles, California, 8 Impact paid for Ralph's moving expenses in the amount of $5,996.72. 13. On August 10, 2020, Ralph officially began working as Creative Director at Impact's Los Angeles office. 14. As Creative Director, Ralph worked directly with Impact's customers to design their websites and products, and to create their advertisements, logos and branding. 15. On April 27, 2021, Ralph voluntarily resigned from Impact. 16. In or around May 2021, Impact discovered that, from at least November 20, 2020 until April 27, 2021, Ralph had owned and operated her own business, Hello Hazie, which directly competed with Impact. 17. Ralph never advised Impact, either during or after her employment at Impact, that she owned and operated a competing business. 18. Ralph never advised Impact, either during or after her employment at Impact, that she owned and operated Hello Hazie. 19. Plaintiffs incorporate by reference as though fully set forth herein all previous allegations in the Complaint. 20. An employer has the right to the undivided loyalty of its employees. The duty of loyalty is breached and may give rise to a tort cause of action on behalf of the employer when the employee 27 takes action inimical to the employer's best interests. See Stokes v. Dole Nut Co. (1995) 41 Cal.App.4th 28 285; Service Employees International Union, Local 250 v. Colcord (2008) 160 Cal.App.4th 362. 21. As a trusted employee of lmpact, Ralph owed Impact a duty ofloyalty and honesty, and 3 a duty to discharge her responsibilities in good faith, with the care an ordinary prudent person in a like 4 position would exercise, and in a manner she reasonably believed to be in Impact's best interests. 22. As Impact's Creative Director, Ralph was in a position of trust. 23. As Impact's Creative Director, Ralph had a duty to act with honesty and integrity in her dealings with Impact as well as the customer accounts she managed. 24. As Impact's Creative Director, Ralph had a duty not to act in her own self-interest and 9 not to act to the detriment of Impact. 25. Ralph breached her duty of loyalty to Impact by taking the following actions, all of which caused injury to Impact: ( a) for a period of at least six months before Ralph voluntarily resigned as Impact's Creative Director, Ralph owned and operated her own competing business, Hello Hazie, without Impact's knowledge or consent; (b) by owning and operating Hello Hazie for at least six months while still employed at Impact, Ralph failed to give Impact her undivided loyalty; and (c) upon information and belief, for at least six months, Ralph used Impact's time and resources to conduct business for her own self-interest by owning and operating her own competing business, Hello Hazie. 26. As a direct and proximate result of Ralph's breach of her duty of loyalty, Plaintiffs have been and will continue to be damaged in an amount that is in excess of this Court's minimum jurisdiction, which includes, among other things, actual damages, disgorgement of at least six months of Ralph's annual salary she was paid while employed at Impact (i.e., $65,625), and revenues received 21 by Hello Hazie. 27. At the time Ralph committed the above wrongful conduct in breach of her duty of loyalty, Ralph was guilty of malice, oppression, and a willful and conscious disregard for the rights of Plaintiffs. As a result, Ralph is liable for punitive damages in an amount to be proven at trial. SECOND CAUSE OF ACTION Unfair Competition in Violation of California Business & Professions Code§ 17200 et seq. (Against All Defendants)
28. Plaintiffs incorporate by reference as though fully set forth herein all previous allegations in the Complaint. 29. As alleged herein, Defendants have engaged in conduct that constitutes unlawful, unfair, and fraudulent business practices in violation of California Business & Professions Code § 1 7200 et seq. 30. Defendants have taken the actions alleged herein with the intent to injure Plaintiffs and to gain an unfair competitive advantage in the marketplace. 31. As a direct and proxim-
fendants have engaged in conduct that constitutes unlawful, unfair, and fraudulent business practices in violation of California Business & Pr et Summonsofessions Code § seq. 1 7200 30. Defendants have taken the actions alleged herein with the intent to injure Plaintiffs and to gain an unfair competitive advantage in the marketplace. 31. As a direct and proximate result of Defendants' unlawful conduct, Plaintiffs have suffered, and will continue to suffer, substantial actual losses for which they are entitled to restitution from Defendants that is in excess of this Court's minimum jurisdiction, which includes but is not limited to, actual damages, disgorgement of at least six months of Ralph's annual salary she was paid while employed at Impact (i.e., $65,625), and revenues received by Hello Hazie. 32. Unless enjoined by the Court, Defendants will continue to engage in the acts, conduct, and omissions set forth above, which have resulted, and will continue to result in irreparable injury to Plaintiffs. Plaintiffs have no adequate remedy at law for such acts and threatened acts. Therefore, Plaintiffs request, pursuant to California Business & Professions Code § 17203, that during the pendency of this action, the Court issue a preliminary injunction, and that after trial, the Court issue a permanent injunction, restraining and enjoining Defendants and their agents, employees, attorneys and representatives, and anyone acting at their direction or on their behalf, from engaging in further conduct constituting unfair competition. WHEREFORE, Plaintiffs pray for judgment against Defendants as follows: 1. For compensatory damages in amount to be proved at the time of trial, but believed to be in excess of $100,000; 2. For punitive damages in an amount to be proved at trial; 3. For injunctive relief prohibiting unfair competition; 4. For an award of attorneys' fees, to the extent provided by statute or contract; 5. For costs of suit; 6. For such other relief as this Court deems just and proper. Dated: June 14, 2021 By: David C. Van Dyke, Esq . Robert L. Rosenthal, Esq. 9595 Wilshire Blvd., Ste. 900 Beverly Hills, CA 90212 Attorneys for Defendants Impact LA, LLC and Impact Networking, LLC PUBLISHED: The Argonaut Newspaper 10/28/21, 11/04/21, 11/11/21, 11/18/21
SUMMONS (CITACION JUDICIAL) Case Number (Número del
Caso): 21STCV22037
NOTICE TO DEFENDANT (AVISO AL DEMANDADO): HAZEL IMOGEN RALPH, an individual; and HELLO HAZIE, LLC, a California Limited Liability Company; DOES 1 through 10, inclusive; YOU ARE BEING SUED BY PLAINTIFF (LO ESTA DEMANDANDO EL DEMANDANTE): IMPACT NETWORKING, LLC, an Illinois Limited Liability Company; and IMPACT LA, LLC, a California Limited Liability Company NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the information below. You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy served on the plaintiff. A letter or phone call will not ing heard unless you re spond within 30 days. Read the information below. You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts Online Self-Help Center (www.courtinfo.ca.gov/selfhelp), your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask the court clerk for a fee waiver form. If you do not file your response on time, you may lose the case by default, and your wages, money, and property may be taken without further warning from the court.There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to call an attorney referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate these nonprofit groups at the California Legal Serv i c e s W e b s i t e (www.lawhelpcalifornia.org), the California Courts Online S e l f - H e l p C e n t e r (www.courtinfo.ca.gov/selfhelp), or by contacting your local court or county bar association. Tiene 30 DÍAS DE CALENDARIO después de que le entreguen esta citación y papeles legales para presentar una respuesta por escrito en esta corte y hacer que se entregue una copia al demandante. Una carta o una llamada telefónica no lo protegen. Su respuesta por escrito tiene que estar en formato legal correcto si desea que procesen su caso en la corte. Es posible que haya un formulario que usted pueda usar para su respuesta. Puede encontrar estos formularios de la corte y más información en el Centro de Ayuda de las Cort e s d e C a l i f o r n i a (www.courtinfo.ca.gov/selfhelp/espanol/), en la biblioteca de leyes de su condado o en la corte que le quede más cerca. Si no puede pagar la cuota de presentación, pida al secretario de la corte que le dé un formulario de exención de pago de cuotas. Si no presenta su respuesta a tiempo, puede perder el caso por incumplimiento y la corte le podrá quitar su sueldo, dinero y bienes sin más advertencia. Hay otros requisitos legales. Es recomendable que llame a un abogado inmediatamente. Si no conoce a un abogado, puede llamar a un servicio de remisión a abogados. Si no puede pagar a un abogado, es posible que cumpla con los requisitos para obtener servicios legales gratuitos de un programa de servicios legales sin fines de lucro. Puede encontrar estos grupos sin fines de lucro en el sitio web de California Legal Services, (www.lawhelpcalifornia.org), en el Centro de Ayuda de las Cortes de C a l i f o r n i a , (www.courtinfo.ca.gov/selfhelp/espanol/) o poniéndose en contacto con la corte o el colegio de abogados locales. The name and address of the court is (El nombre y dirección de la corte es): Superior Court of the State of California, county of Los Angeles, Central Division, Stanley Mosk Courthouse, 111 N. Hill Street, Los Angeles, CA 90012. The name, address, and telephone number of plaintiff's attorney, or plaintiff without an attorney is (El nombre la Superior Court of the State of California, county of Los Angeles, Central Division, Stanley Mosk Courthouse, 111 N. Hill Street, Los Angeles, CA 90012. The name, address, and telephone number of plaintiff's attorney, or plaintiff without an attorney, is (El nombre, la dirección y el número de teléfono del abogado del demandante, o del demandante que no tiene abogado, es): Robert L. Rosenthal 9595 Wilshire Blvd., Suite 900 Beverly Hills, CA 90212 ; Tel: (702) 257-1483 DATE (Fecha): June 14, 2021; Sherri R. Carter, Clerk (Secretario), by C. Monroe, Deputy (Adjunto)
SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES, STANLEY MOSK COURTHOUSE Case No.: 21STCV22037
IMPACT NETWORKING, LLC, an Illinois Limited Liability Company; and IMPACT LA, LLC, a California Limited Liability Company,
vs.
Plaintiffs,
HAZEL IMOGEN RALPH, an individual; and HELLO HAZIE, LLC, a California Limited Liability Company; DOES 1 through 10, 17 inclusive, Defendants.
COMPLAINT FOR: 1. BREACH OF DUTY OF LOYALTY 2. UNFAIR COMPETITION (Cal. Bus. & Prof. Code§ 17200 et seq.) JURY TRIAL DEMANDED
Plaintiffs, IMPACT NETWORKING, LLC and IMPACT LA, LLC, for its Complaint against Defendants HAZEL IMOGEN RALPH and HELLO HAZIE, LLC, alleges as follows:
1. THE PARTIES Plaintiff, Impact Networking, LLC ("Impact Networking"), is an Illinois Limited Liability Company, which at all relevant times, has been duly licensed to conduct business in the State of California, and has had an office in Los Angeles County, California. 2. Plaintiff, Impact LA, LLC ("Impact LA"), is a California Limited Liability Company duly licensed to conduct business in California, has an office in Los Angeles County, California, and is a wholly owned subsidiary of lmpact Networking. (Collectively, Impact Networking and Impact LA shall be referred to herein as "Impact" .) 3. Defendant Hazel Imogen Ralph ("Ralph) is an individual residing in Los Angeles County, California. 4. Defendant, Hello Hazie, LLC ("Hello Hazie") is a California Limited Liability 5 Company located in Los Angeles County, California. 5. The true names and capacities, whether individual, corporate, associate or otherwise, of the defendants Does 1 through 10, inclusive, and each of them, are unknown to Plaintiffs, who therefore sue said Defendants by said fictitious names. When the identities and capacities of Does 1 through 10, 9 inclusive, become known to Plaintiffs, they will amend their Complaint. The term "Defendants, " as 1 O used herein, shall include each of said fictitiously named Defendants, Ralph and Hello Hazie. 6. This Court has jurisdiction over all causes of action asserted in this Complaint pursuant 13 to the California Constitution, Article VI, Section 10, California Business & Professions Code § 17204, 14 and California Code of Civil Procedure§ 410.10, by virtue of the fact that this is a civil action wherein 15 the matter in controversy, exclusive of interest, exceeds $25,000, and because this case is a cause not 16 given by statute to other trial courts. 7. Venue is proper in Los Angeles County under California Code of Civil Procedure § 395 18 because: (a) Defendant resides in Los Angeles County, California; (b) one or more of the acts, breaches, and other wrongful conduct giving rise to the causes of action asserted occurred or was to be performed in Los Angeles County, California; and (c) the obligations to be performed by Ralph at issue in this Complaint were to be performed in Los Angeles County, California.
GENERAL ALLEGATIONS
8. Impact own and operate integrated business technology companies that provide information technology services to individuals and businesses that include such things as website design, product design, cybersecurity, process optimization, marketing, and print services. 9. On April 23, 2018, Ralph began working as a Senior Art Director for Impact Networking at its office in Lake Forest, Illinois, and was paid an initial annual salary of $85,000, plus benefits. 10. On December 2, 2019, Impact Networking promoted Ralph to Associate Creative 3 Director, and her annual salary was increased to $105,000, plus benefits. 11. In or around August 2020, Ralph agreed to relocate from Lake Forest, Illinois to Los 5 Angeles, California and to work for Impact as Creative Director at its office in Los Angeles at an annual 6 salary of $131,250, plus benefits. 12. As part of Impact's and Ralph's agreement to relocate to Los Angeles, California, 8 Impact paid for Ralph's moving expenses in the amount of $5,996.72. 13. On August 10, 2020, Ralph officially began working as Creative Director at Impact's Los Angeles office. 14. As Creative Director, Ralph worked directly with Impact's customers to design their websites and products, and to create their advertisements, logos and branding. 15. On April 27, 2021, Ralph voluntarily resigned from Impact. 16. In or around May 2021, Impact discovered that, from at least November 20, 2020 until April 27, 2021, Ralph had owned and operated her own business, Hello Hazie, which directly competed with Impact. 17. Ralph never advised Impact, either during or after her employment at Impact, that she owned and operated a competing business. 18. Ralph never advised Impact, either during or after her employment at Impact, that she owned and operated Hello Hazie.
FIRST CAUSE OF ACTION Breach of the Duty of Loyalty (Against Ralph)
19. Plaintiffs incorporate by reference as though fully set forth herein all previous allegations in the Complaint. 20. An employer has the right to the undivided loyalty of its employees. The duty of loyalty is breached and may give rise to a tort cause of action on behalf of the employer when the employee 27 reference as though fully set forth herein all previous allegations in the Complaint. 20. An employer has the right to the undivided loyalty of its employees. The duty of loyalty is breached and may give rise to a tort cause of action on behalf of the employer when the employee 27 takes action inimical to the employer's best interests. See Stokes v. Dole Nut Co. (1995) 41 Cal.App.4th 28 285; Service Employees International Union, Local 250 v. Colcord (2008) 160 Cal.App.4th 362. 21. As a trusted employee of lmpact, Ralph owed Impact a duty ofloyalty and honesty, and 3 a duty to discharge her responsibilities in good faith, with the care an ordinary prudent person in a like 4 position would exercise, and in a manner she reasonably believed to be in Impact's best interests. 22. As Impact's Creative Director, Ralph was in a position of trust. 23. As Impact's Creative Director, Ralph had a duty to act with honesty and integrity in her dealings with Impact as well as the customer accounts she managed. 24. As Impact's Creative Director, Ralph had a duty not to act in her own self-interest and 9 not to act to the detriment of Impact. 25. Ralph breached her duty of loyalty to Impact by taking the following actions, all of which caused injury to Impact: ( a) for a period of at least six months before Ralph voluntarily resigned as Impact's Creative Director, Ralph owned and operated her own competing business, Hello Hazie, without Impact's knowledge or consent; (b) by owning and operating Hello Hazie for at least six months while still employed at Impact, Ralph failed to give Impact her undivided loyalty; and (c) upon information and belief, for at least six months, Ralph used Impact's time and resources to conduct business for her own self-interest by owning and operating her own competing business, Hello Hazie. 26. As a direct and proximate result of Ralph's breach of her duty of loyalty, Plaintiffs have been and will continue to be damaged in an amount that is in excess of this Court's minimum jurisdiction, which includes, among other things, actual damages, disgorgement of at least six months of Ralph's annual salary she was paid while employed at Impact (i.e., $65,625), and revenues received 21 by Hello Hazie. 27. At the time Ralph committed the above wrongful conduct in breach of her duty of loyalty, Ralph was guilty of malice, oppression, and a willful and conscious disregard for the rights of Plaintiffs. As a result, Ralph is liable for punitive damages in an amount to be proven at trial. SECOND CAUSE OF ACTION Unfair Competition in Violation of California Business & Professions Code§ 17200 et seq. (Against All Defendants)
28. Plaintiffs incorporate by reference as though fully set forth herein all previous allegations in the Complaint. 29. As alleged herein, Defendants have engaged in conduct that constitutes unlawful, unfair, and fraudulent business practices in violation of California Business & Professions Code § 1 7200 et seq. 30. Defendants have taken the actions alleged herein with the intent to injure Plaintiffs and to gain an unfair competitive advantage in the marketplace. 31. As a direct and proximate result of Defendants' unlawful conduct, Plaintiffs have suffered, and will continue to suffer, substantial actual losses for which they are entitled to restitution from De Plaintiffs and to gain an un fair competitive advantage in the marketplace. 31. As a direct and proximate result of Defendants' unlawful conduct, Plaintiffs have suffered, and will continue to suffer, substantial actual losses for which they are entitled to restitution from Defendants that is in excess of this Court's minimum jurisdiction, which includes but is not limited to, actual damages, disgorgement of at least six months of Ralph's annual salary she was paid while employed at Impact (i.e., $65,625), and revenues received by Hello Hazie. 32. Unless enjoined by the Court, Defendants will continue to engage in the acts, conduct, and omissions set forth above, which have resulted, and will continue to result in irreparable injury to Plaintiffs. Plaintiffs have no adequate remedy at law for such acts and threatened acts. Therefore, Plaintiffs request, pursuant to California Business & Professions Code § 17203, that during the pendency of this action, the Court issue a preliminary injunction, and that after trial, the Court issue a permanent injunction, restraining and enjoining Defendants and their agents, employees, attorneys and representatives, and anyone acting at their direction or on their behalf, from engaging in further conduct constituting unfair competition. WHEREFORE, Plaintiffs pray for judgment against Defendants as follows: 1. For compensatory damages in amount to be proved at the time of trial, but believed to be in excess of $100,000; 2. For punitive damages in an amount to be proved at trial; 3. For injunctive relief prohibiting unfair competition; 4. For an award of attorneys' fees, to the extent provided by statute or contract; 5. For costs of suit; 6. For such other relief as this Court deems just and proper.
Dated: June 14, 2021
By: David C. Van Dyke, Esq . Robert L. Rosenthal, Esq. 9595 Wilshire Blvd., Ste. 900 Beverly Hills, CA 90212 Attorneys for Defendants Impact LA, LLC and Impact Networking, LLC PUBLISHED: The Argonaut Newspaper 10/28/21, 11/04/21, 11/11/21, 11/18/21
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