Case #BC660653 · California Superior Court, Los Angeles County

Rueda v. CE OPCO LLC et al

Filed May 08, 2017 Judge Judge Elizabeth Allen White
Closed CE OPCO, LLC d/b/a Combs Enterprises, LLC Combs Enterprises, LLC 207 Anderson, LLC Sean John Combs
Contains Sexual Harassment · Hostile Work Environment · Retaliation · Defamation
Parties
Cindy Rueda Plaintiff
CE OPCO, LLC d/b/a Combs Enterprises, LLC A business entity conducting business in Los Angeles County, California, operating as Combs Enterprises, LLC.
Combs Enterprises, LLC A corporation registered with the Secretary of State of New York, conducting business in Los Angeles County, California, in conjunction with CE OPCO.
207 Anderson, LLC A business entity serving as the record employer for payroll purposes during Plaintiff's employment in Los Angeles County, California.
Sean John Combs Individual and supervisor, owner/founder of Combs Enterprises, residing in Los Angeles County, California, for whom Plaintiff worked as a personal chef.
Factual Allegations
Disclaimer: allegations as pled by the plaintiff, summarized by Grok.

Cindy Rueda began working as a chef for Defendants at Sean Combs' residence in Los Angeles County, California, in January 2015, initially on weekends from 9:00 a.m. to midnight or 2:00 a.m., paid a flat rate of $150 per day. In May 2015, she was asked to work six days a week with the same hours and pay, which she accepted. In June 2015, she declined a full-time offer due to unreasonable hours and pay, continuing her weekend schedule. On or around September 27, 2015, she accepted a full-time position as an exempt employee chef, working daily from 9:00 a.m. to midnight or 2:30 a.m., and was required to travel with Combs for events outside Los Angeles. She received no additional pay for extended hours or travel, despite complaints in October and December 2015 to Stacy Friend, Combs' estate director, and Christina Khorram, his personal assistant. Plaintiff was instructed to track her hours but was still paid as an exempt employee at the flat rate. She faced inappropriate conduct, including being summoned to serve meals to Combs and guests during or after sexual activities, with Combs making explicit comments about his body on one occasion. Plaintiff complained about harassment and pay issues to Stacy Friend, but no corrective action was taken. On or around May 8, 2016, after receiving a watch, she was accused of theft and fired, allegedly as a pretext for her prior complaints about overtime pay and harassment.

Prayer for Relief

Plaintiff seeks past and future economic and non-economic damages, including lost earnings, pain and suffering, special damages, actual damages, nominal damages, punitive damages under Civil Code § 3294, damages for unpaid wages, overtime, and double time wages, penalties for inaccurate wage statements, unpaid penalty wages, restitution under Business and Professions Code § 17203, pre-judgment interest, costs, reasonable attorneys' fees, and preliminary and permanent injunctions to prevent further violations of the California Labor Code and unfair business practices.

Causes of Action
FIRST CAUSE OF ACTION Sexual Harassment California Fair Employment and Housing Act (Defendants and Does)
SECOND CAUSE OF ACTION Quid Pro Quo Sexual Harassment California Fair Employment and Housing Act (Defendants and Does)
THIRD CAUSE OF ACTION Hostile Work Environment California Fair Employment and Housing Act (Defendants and Does)
FOURTH CAUSE OF ACTION Failure to Prevent Harassment and Retaliation California Fair Employment and Housing Act (Defendants and Does)
FIFTH CAUSE OF ACTION Violation of Whistleblower Protection California Labor Code § 1102.5 (Defendants and Does)
SIXTH CAUSE OF ACTION Wrongful Discharge in Violation of Public Policy Common Law (Defendants and Does)
SEVENTH CAUSE OF ACTION Retaliation California Labor Code § 1102.5(b) (Defendants and Does)
EIGHTH CAUSE OF ACTION Defamation Common Law (Defendants and Does)
NINTH CAUSE OF ACTION Intentional Infliction of Emotional Distress Common Law (Defendants and Does)
TENTH CAUSE OF ACTION Negligent Infliction of Emotional Distress Common Law (Defendants and Does)
ELEVENTH CAUSE OF ACTION Failure to Pay Overtime Wages California Labor Code § 1194 (Defendants and Does)
TWELFTH CAUSE OF ACTION Knowing and Intentional Failure to Comply with Itemized Employee Wage Statement Provisions California Labor Code § 226(a) (Defendants and Does)
THIRTEENTH CAUSE OF ACTION Failure to Pay Wages of Terminated or Resigned Employee California Labor Code §§ 201, 202, 203 (Defendants and Does)
FOURTEENTH CAUSE OF ACTION Violation of Unfair Competition Law California Business and Professions Code § 17200 et seq. (Defendants and Does)
Disposition
Voluntary Request for Dismissal — April 25, 2019

Dismissal pursuant to settlement.

Docket
Date No. Description
May 8, 2017 1 SUMMONS No document
May 8, 2017 2 Complaint. Filed by Cindy Rueda (Plaintiff) No document
May 8, 2017 3 COMPLAINT FOR: 1. SEXUAL HARASSMENT;ETC No document
May 17, 2017 4 Summons Issued. Filed by Cindy Rueda (Plaintiff) No document
May 17, 2017 5 First Amended Complaint. Filed by Cindy Rueda (Plaintiff) No document
May 17, 2017 6 FIRST AMENDED SUMMONS No document
May 17, 2017 7 FIRST AMENDED COMPLAINT FOR: 1. SEXUAL HARASSMENT; ETC No document
May 17, 2017 8 Complaint (1st). Filed by Cindy Rueda (Plaintiff) No document
May 22, 2017 9 Notice of Case Management Conference. Filed by Clerk No document
May 22, 2017 10 NOTICE OF CASE MANAGEMENT CONFERENCE No document
May 22, 2017 11 NOTICE OF CASE MANAGEMENT CONFERENCE No document
Jun 29, 2017 12 Proof of Service (not Summons and Complaint). Filed by CE OPCO, LLC (Defendant); Combs Enterprises, LLC (Defendant); Combs Entrerprises, LLC (Defendant) et al. No document
Jun 29, 2017 13 Petition. Filed by CE OPCO, LLC (Defendant); Combs Enterprises, LLC (Defendant); Combs Entrerprises, LLC (Defendant) et al. No document
Jun 29, 2017 14 Declaration. Filed by CE OPCO, LLC (Defendant); Combs Enterprises, LLC (Defendant); Combs Entrerprises, LLC (Defendant) et al. No document
Jun 29, 2017 15 Declaration. Filed by CE OPCO, LLC (Defendant); Combs Enterprises, LLC (Defendant); Combs Entrerprises, LLC (Defendant) et al. No document
Jun 29, 2017 16 DEFENDANTS' NOTICE OF PETITION AND PETITION TO COMPEL ARBITRATION ETC. No document
Jun 29, 2017 17 DECLARATION OF RYAN APPLEBY IN SUPPORT OF DEFENDANTS' PETITION TO COMPEL ARBITRATION ETC. No document
Jun 29, 2017 18 DECLARATION OF KIMBERLY SULLIVAN IN SUPPORT OF DEFENDANTS PETITION TO COMPEL ARBITRATION ETC. No document
Jun 29, 2017 19 CERTIFICATE OF SERVICE No document
Aug 4, 2017 20 PLAINTIFF'S OPPOSITION TO DEFENDANTS' PETITION TO COMPEL ARBITRATION; AND DECLARATION OF CINDY RUEDA No document
Aug 4, 2017 21 Opposition Document. Filed by Cindy Rueda (Plaintiff) No document
Aug 4, 2017 22 Declaration. Filed by Cindy Rueda (Plaintiff) No document
Aug 4, 2017 23 DECLARATION OF CINDY RUEDA IN SUPPORT OF HER OPPOSITION TO DEFENDANTS' PETITION TO COMPEL ARBITRATION No document
Aug 10, 2017 24 Reply/Response. Filed by CE OPCO, LLC (Defendant); Combs Enterprises, LLC (Defendant); Combs Entrerprises, LLC (Defendant) et al. No document
Aug 10, 2017 25 REPLY IN SUPPORT OF DEFENDANTS' PETITION TO COMPEL ARBITRATION AND STAY FURTHER PROCEEDINGS No document
Aug 10, 2017 26 Notice. Filed by CE OPCO, LLC (Defendant); Combs Enterprises, LLC (Defendant); Combs Entrerprises, LLC (Defendant) et al. No document
Aug 10, 2017 27 NOTICE OF ERRATA TO PETITION TO COMPEL ARBITRATION AND TO STAY FURTHER PROCEEDINGS No document
Aug 17, 2017 28 RULING MOTION TO COMPEL ARBITRAT1ON No document
Aug 17, 2017 29 Order Appointing Court Approved Reporter as Official Reporter Pro Tempore. Filed by Defendant/Respondent No document
Aug 17, 2017 30 Order. Filed by Court No document
Aug 17, 2017 31 ORDER APPOINTING COURT APPROVED REPORTER AS OFFICIAL REPORTER PRO TEMPORE No document
Aug 17, 2017 32 Minute order entered: 2017-08-17 00:00:00. Filed by Clerk No document
Aug 17, 2017 33 Minute Order No document
Aug 31, 2017 34 Order. Filed by CE OPCO, LLC (Defendant); Combs Enterprises, LLC (Defendant); Combs Entrerprises, LLC (Defendant) et al. No document
Aug 31, 2017 35 ORDER GRANTING DEFENDANTS' PETITION TO COMPEL ARBITRATION AND TO STAY FURTHER PROCEEDINGS No document
Oct 19, 2017 36 Minute order entered: 2017-10-19 00:00:00. Filed by Clerk No document
Feb 1, 2018 37 Notice of Change of Address or Other Contact Information. Filed by Cindy Rueda (Plaintiff) No document
Feb 1, 2018 38 Notice of Change of Address No document
Aug 17, 2018 39 Minute order entered: 2018-08-17 00:00:00. Filed by Clerk No document
Aug 17, 2018 40 Minute Order No document
Feb 19, 2019 41 Minute Order (Status Conference Regarding Arbitration). Filed by Clerk No document
Apr 22, 2019 42 Minute Order (Order to Show Cause Re: Dismissal Pursuant to Settlement). Filed by Clerk No document
Apr 25, 2019 43 Request for Dismissal. Filed by Cindy Rueda (Plaintiff) No document
Attorneys
James E. Blancarte
Blancarte Law
Plaintiff
Cristal L. Cabrera
Law Office of Cristal L. Cabrera
Plaintiff