Rueda v. CE OPCO LLC et al
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.
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.
Dismissal pursuant to settlement.
| 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 |