In the Supreme Court of the State of California Michael Williams, an Individual, Plaintiff and Appellant, V. Superior Court of California for the County of Los Angeles, Respondent

Defense Counsel Journal, July 2016 | Go to article overview

In the Supreme Court of the State of California Michael Williams, an Individual, Plaintiff and Appellant, V. Superior Court of California for the County of Los Angeles, Respondent


Marshalls of CA, LLC, Real Party in Interest.

After a Decision by the Court of Appeal, Second Appellate District, Division One Case No. B259967

Los Angeles County Superior Court, Case No. BC503806, Judge William F. Highberger

APPLICATION FOR LEAVE TO FILE AMICUS CURIAE BRIEF AND AMICUS CURIAE BRIEF OF INTERNATIONAL ASSOCIATION OF DEFENSE COUNSEL IN SUPPORT OF REAL PARTY IN INTEREST MARSHALLS OF CA, LLC

* Mary-Christine Sungaila (#156795)

Martin M. Ellison (#292060)

HAYNES AND BOONE, LLP

600 Anton Boulevard, Suite 700

Costa Mesa, California 92626

Tel: 949-202-3000 * Fax: 949-202-3001

me. sungaila@hayne sboone .com

martin.ellison@haynesboone.com

Attorneys for Amicus Curiae International Association of Defense Counsel

TABLE OF CONTENTS

TABLE OF AUTHORITIES
APPLICATION FOR LEAVE TO FILE AMICUS CURIAE
BRIEF

  INTEREST OF AMICUS CURIAE; HOW THE AMICUS
  CURIAE BRIEF WILL ASSIST THE COURT

  NO PARTY OR COUNSEL FOR A PARTY AUTHORED
  OR CONTRIBUTED TO THIS BRIEF

  CONCLUSION

AMICUS CURIAE BRIEF

  INTRODUCTION
  BACKGROUND
  LEGAL DISCUSSION

  A. The Trial Court's Discovery Order Was a Proper
     Exercise of Its Inherent Authority to Control the
     Proceedings Before It

  B. By Structuring Discovery Proceedings as It Did,
     the Trial Court Aligned Itself with the
     Investigatory Practices That the State Itself
     Typically Implements

  C. The Incremental Discovery Process Ordered by the
     Trial Court Makes Good Policy Sense

CONCLUSION

CERTIFICATE OF WORD COUNT

PROOF OF SERVICE

TABLE OF AUTHORITIES

Cases

Cottle v. Super. Ct. (1992) 3 Cal.App.4th 1367

Craib v. Bulmash (1989) 49 Cal.3d 475

Dunlap v. Super. Ct. (2006) 142 Cal.App.4th 330

Exxon Mobil Corp. v. State of New Hampshire, U.S. Supreme Court Case No. 15-933

Greyhound Corp. u. Super. Ct. (1961) 56 Cal.2d 355

Iskanian v. CLS Transportation L.A., LLC (2014) 59 Cal.4th 348

John B. v. Super. Ct. (2006) 38 Cal.4th 1177

Obregon v. Super. Ct. (1998) 67 Cal.App.4th 424

The Procter & Gamble Co. v. Dino Rikos, U.S. Supreme Court Case No. 15-835

Rutherford u. Owens-Illinois, Inc. (1997) 16 Cal.4th 953

Statutes

Code Civ. Proc., [section] 128, subd. (a)

Code Civ. Proc., [section] 2017.020

Private Attorneys General Act of 2004 (Lab. Code, [section][section] 2698 et seq.)

Other Authorities

California Rules of Court, rule 8.520(f)

Bureau of Field Enforcement, Report a Labor Violation to the California Labor Commissioner's Bureau of Field Enforcement (June 2014)

Brittany Blackburn Koch, Dealing with the DOL (Department of Labor) at Your Door, Part II (Feb. 5, 2014) The National Law Review [as of Apr. 22, 2016]

State of Cal. Budget Change Proposal (Dec. 2015) Submitted by the Lab. and Workforce Development Agency and the Dept, of Industrial Relations, at p. 3, [as of Apr. 22, 2016]

S227228

IN THE SUPREME COURT OF THE STATE OF CALIFORNIA

Michael Williams, an individual,

Plaintiff and Appellant,

v.

Superior Court of California for the County of Los Angeles,

Respondent.

Marshalls of CA, LLC,

Real Party in Interest.

After a Decision by the Court of Appeal, Second Appellate District, Division One Case No. B259967

Los Angeles County Superior Court, Case No. BC503806, Judge William F. Highberger

APPLICATION FOR LEAVE TO FILE AMICUS CURIAE BRIEF

TO THE HONORABLE CHIEF JUSTICE:

Under rule 8.520(f) of the California Rules of Court, the International Association of Defense Counsel (IADC) requests permission to file the attached amicus curiae brief in support of real party in interest Marshalls of CA, LLC. …

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