Iris Alonzo Bc592105

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Keith A. Fink, Bar No. 146841

Sarah E. Hernandez, Bar No. 206305
Jennifer H. Yeung, Bar No. 280819
FINK & STEINBERG
Attorneys at Law
11500 Olympic Boulevard, Suite 316
Los Angeles, California 90064
Telephone: (310) 268-0780
Facsimile: (310) 268-0790
OF ORIGINAL FILED
)ns Ancelpc
AUG 202015
SherrJ H. Carter, Executive
OtficerICerk
By: Moses Soto, Deputy
Attorneys for Plaintiff

IRIS ALONZO
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES CENTRAL DISTRICT

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10 IRIS ALONZO, an individual;
CASE NO.
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COMPLAINT F(JAJGF)R:
Plaintiff,
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V.
13 AMERICAN APPAREL, INC., a Delaware

corporation; AMERICAN APPAREL
14 RETAIL, INC., a California corporation;
AMERICAN APPAREL (USA), LLC, a
15 California limited liability company;
AMERICAN APPAREL
16 MANUFACTURING, INC., a California
corporation; AMERICAN APPAREL
17 GROUP, a Delaware corporation;
AMERICAN APPAREL CORPORATION,
18 a Delaware corporation; and DOES 1 to 100,
inclusive,
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Defendants.
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1. WRONGFUL TERMINATION IN
VIOLATION OF PUBLIC POLICY;
2. BREACH OF CONTRACT ORAL;
3. BREACH OF CONTRACT WRITTEN;
4. BREACH OF THE COVENANT OF GOOD
FAITH AND FAIR DEALING;
5. VIOLATION OF LABOR CODE 201 &
203, ET SEQ.;
6. VIOLATION OF LABOR CODE 206
7. VIOLATION OF LABOR CODE 1102.5
8. VIOLATION OF LABOR CODE 1198.5
9. VIOLATION OF BUSINESS AND
PROFESSIONS CODE 17200, ET SEQ.
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[JURY TRIAL DEMANDED]
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Plaintiff IRIS ALONZO hereby alleges as follows:
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VENUE AND PARTIES
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1.
hereto was, a resident of the County of Los Angeles, State of California.
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Plaintiff IRIS ALONZO (ALONZO and/or PLAINTIFF) is, and at all

times relevant
2.
PLAINTIFF is informed and believes, and thereon alleges, that Defendant AMER
ICAN
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PLAINTIFFS COMPLAINT FOR DAMAGES
APPAREL, INC. (AMERICAN APPAREL and/or DEFENDANTS) is, and at all times
relevant hereto was, a Delaware corporation doing substantial business in the County of Los
Angeles, State of California.
3.
PLAINTIFF is informed and believes, and thereon alleges that Defendant AMERICAN
APPAREL RETAIL, INC. (AMERICAN APPAREL and/or DEFENDANTS) is, and at
all times relevant hereto was, a California corporation, doing substantial business in the County
of Los Angeles, State of California.
4.
APPAREL (USA), LLC (AMERICAN APPAREL and/or DEFENDANTS) is, and at all
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times relevant hereto was, a California limited liability company, doing substantial business in
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the County of Los Angeles, State of California.
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5.
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APPAREL
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DEFENDANTS) is, and at all times relevant hereto was, a California corporation, doing
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substantial business in the County of Los Angeles, State of California.
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6.
MANUFACTURING,
INC.
(AMERICAN
APPAREL
and/or
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APPAREL GROUP (AMERICAN APPAREL and/or DEFENDANTS) is, and at all times
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relevant hereto was, a Delaware corporation, doing substantial business in the County of Los
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7. PLAINTIFF is informed and believes, and thereon alleges that Defendant AMERICAN APPAREL
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CORPORATION (AMERICAN APPAREL and/or DEFENDANTS) is, and at all times
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relevant hereto was, a Delaware corporation, doing substantial business in the County of Los
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8.
PLAINTIFF is informed and believes, and thereon alleges that AMERICAN APPAREL, INC.,
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AMERICAN APPAREL RETAIL, INC., AMERICAN APPAREL (USA), LLC, AMERICAN
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APPAREL MANUFACTURING, INC., AMERICAN APPAREL GROUP, and AMERICAN
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APPAREL CORPORATION were joint employers of PLAINTIFF. AMERICAN APPAREL,
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INC., AMERICAN APPAREL RETAIL, INC., AMERICAN APPAREL (USA), LLC,

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AMERICAN APPAREL MANUFACTURING, INC., AMERICAN APPAREL GROUP, and
AMERICAN APPAREL CORPORATION hired employees jointly, including PLAINTIFF,
controlled PLAINTIFFS and other employees work assignments, and paid PLAINTIFF S and
other employees wages. Therefore, these entities were at all times joint employers of
PLAINTIFF.
9.
PLAINTIFF is unaware of the true names and capacities, whether individual, corporate,
associated or otherwise, ofDefendants DOES 1 through 100 (DOES and/or DEFENDANT
DOE) inclusive, and therefore sues said Does by such fictitious names. PLAINTIFF will seek
leave of Court to amend this Complaint to show the true names and capacities of such DOES
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when the same has been ascertained. PLAINTIFF is informed and believes, and thereon alleges
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that each of the fictitiously named Defendants is responsible to PLAINTIFF for the injuries
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suffered and alleged herein, or is subject to the jurisdiction of the Court as a necessary party for
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the relief herein requested.
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10.
PLAINTIFF is informed and believes, and thereon alleges that AMERICAN APPAREL, INC.,
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AMERICAN APPAREL RETAIL, INC., AMERICAN APPAREL (USA), LLC, AMERICAN
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APPAREL MANUFACTURING, INC., AMERICAN APPAREL GROUP, and AMERICAN
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APPAREL CORPORATION are alter-egos of one another because there is such a unity of
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interest and ownership that their separate corporate personalities are merged so that one
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corporation is a mere adjunct of another and the companies form a single enterprise. PLAINTIFF
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further alleges that AMERICAN APPAREL, INC., AMERICAN APPAREL RETAIL, INC.,
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AMERICAN APPAREL (USA), LLC, AMERICAN APPAREL MANUFACTURING, INC.,
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AMERICAN APPAREL GROUP, and AMERICAN APPAREL CORPORATION commingled
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their funds and other assets, failed to segregate the firnds of the separate entities, allowed the
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diversion of corporate funds or assets to non-corporate uses, failed to maintain corporate
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minutes, failed to maintain adequate corporate records, failed to adhere to corporate formalities,
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failed to conduct transactions by and between one another at arms length, used the same offices
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and/or business locations, employed the same or largely the same employees, and/or failed to
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adequately capitalize some or all of the corporations.

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11.
PLAINTIFF is informed, believes, and thereon alleges that each DEFENDANT and DOE is
now, and was at all times mentioned herein, the agent, principal, partner, officer, joint venturer,
employee or alter ego of the remaining DEFENDANTS and DOES, and that all of the acts and
conduct alleged herein were performed within the course and scope and in the furtherance of
such agency, partnership, joint venture, employment or alter ego relationship.
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Venue is properly laid in this Court in that the claims and injuries occurred in the County of Los
Angeles.
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GENERAL ALLEGATIONS
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every allegation contained in Paragraphs 1 through 12, inclusive.
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ALONZO was employed by AMERICAN APPAREL from February 16, 2004, through June 25,
2014, and then again from October 20, 2014, through February 19, 2015.
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PLAINTIFF re-alleges and incorporates herein by reference, as though set forth in full, each and
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During her eleven-year tenure with DEFENDANTS, ALONZO made many meaningful and
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tangible contributions to AMERICAN APPAREL in the areas of product design, retail
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development, and brand growth that resulted in over one billion dollars in sales and global
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recognition for the apparel company.
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In the area of product development, ALONZO was instrumental in the development and
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execution of the companys Tn-Blend Jersey fabric, which alone was responsible for
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approximately twenty five million dollars of sales annually since 2005, the Cotton Spandex
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Legging, a top seller since its launch, the now classic 3 stripe Tube Socks (2006), the Disco
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Pant (2007), the Deep V Neck (2007), the launch of the companys first Denim line
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(2010), the top selling Fisherman Sweater (2012), and hundreds of other products.
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In 2008, after the passing of Proposition 8 in California, ALONZO and her team were
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responsible for conceiving the groundbreaking and globally recognized Legalize Gay
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campaign and was an early supporter of partnering with innovative gay culture publications and
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organizations.
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ALONZO also stewarded important collaborations and relationships between the American
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Apparel brand and world-class art museums, international art groups, independent artists and
art non-profits, solidifying the brands place in the contemporary art sector.
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ALONZOS commitment to AMERICAN APPAREL and its success was undying since the
outset of her employment. Throughout her tenure with DEFENDANTS, ALONZOS job
performance was stellar and DEFENDANTS continually acknowledged her work product and
contributions to the company.
Exactly one weekfollowing the ousting ofFormer CEO Dov Charney,
Alonzo was terminated without severance or cause.
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PLAINTIFF is informed and believes that in or around 2013 and early to mid-2014,
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DEFENDANTS secretly looked for ways to fire CEO Dov Charney (Mr. Charney) and to
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compromise his control of stock in the company. On or about June 18, 2014, Mr. Charney was
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officially terminated as CEO of AMERICAN APPAREL.
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Exactly one week later on or aboutJune 25, 2014, ALONZO received a telephone call from
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AMERICAN APPARELS Interim CEOJohn Luttrell (Mr. Luttrell). During this call, Mr.
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Luttrell asked ALONZO if she had been speaking with Mr. Charney since his termination.
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ALONZO affirmed that she had been, but only because he was her friend. ALONZO also made
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clear to Mr. Luttrell that her job duties at AMERICAN APPAREL were her top priority and
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that she had been diligently performing all of her job responsibilities notwithstanding Mr.
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Charneys departure, as she had been for the ten years prior. In response, Mr. Luttrell told
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ALONZO, Ill have to think about how I feel about that.
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Approximately two (2) hours later, ALONZO received an email from Interim General Counsel,
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Tobias Keller (Mr. Keller), informing her that she was terminated, effective immediately.
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DEFENDANTS refused to provide ALONZO with a one-year severance as they had promised
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her, and as a condition of her employment. DEFENDANTS also provided no reason for her
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termination.
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Following this abrupt termination, ALONZO was forced to borrow money to supplement her
lost wages and to pay her bills, including rent and utilities. ALONZO was forced to take out a
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loan in the amount of $30,000.00 from Mr. Charney in order to survive.
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Due to the loss ofPlaintiffs creative leadership, the Interim CEO begs Plaintiffto
return to American Apparel to restore the company brand.
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On or about September 29, 20:14, Scott Brubaker (Mr. Brubaker) was hired as Interim CEO.
In the second week of October 2014, Mr. Brubaker requested a meeting with ALONZO. Over
the course of a three-hour dinner meeting, Mr. Brubaker told ALONZO that there was no
creative leadership at the company and pleaded for ALONZO to return to her position as
Senior Creative Director as soon as possible. Additionally, recognizing ALONZOS advertising
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talent as well, Mr. Brubaker told ALONZO he wanted her to fill the role of Interim Marketing
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Director as well as head of the E-commerce division at AMERICAN APPAREL to save the
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companys falling online sales.
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ALONZO agreed to return to the company as AMERICAN APPARELS Senior Creative

Director, without an increase in gross pay, on the following terms:
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(1) ALONZO would be reimbursed for the $30,000.00 loan she had borrowed from Mr.
Charney to supplement her lost wages over the summer of 2014;
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(2) ALONZO S employee stock plans, which were cancelled when she was terminated
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on June 25, 2014, would be reinstated and any shares of stocks that vested since her
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termination would be paid to her including taxes by AMERICAN APPAREL
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(ALONZO was promised two tranches that vested following her termination for 50,000
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shares and 53,333 shares, respectively, plus taxes); and
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(3) AMERICAN APPAREL promised ALONZO additional bonuses if she was able to
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improve the E-commerce sales, which were approximately 20% negative compared to
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the year prior, by the end of the 2014 fiscal calendar.
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DEFENDANTS and ALONZO agreed to the above terms and ALONZO was officially re
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hired by AMERICAN APPAREL on October 20, 2014. Mr. Brubaker acted as ALONZOS
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supervisor from the date of her rehire until a new Chief Executive Officer was appointed on or
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about January 5, 2015.

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27.
Following her rehire, ALONZO excelled in her three roles as Senior Creative Director, Interim
Marketing Director, and head of the E-commerce division. ALONZOS job duties, included
but were not limited to, the following:
Overseeing all print and digital advertising campaigns, email campaigns, and brand
collaborations;
Supervising all photo shoots and presiding over all charitable contributions made by
AMERICAN APPAREL;
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Designing and implementing billboard campaigns, product design, and store design;
Creating and managing DEFENDANTS first-ever marketing budget which totaled

approximately $12,000,000.00; and
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Reestablishing communication channels between various creative departments in an
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effort to recapture the original brand aesthetics, which had been neglected in her
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absence.
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Mr. Brubaker frequently praised ALONZOS stellar performance, including but not limited to:
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her efforts to increase online sales by twenty-two percent (22%) in approximately three months.
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Prior to ALONZOS rehire, the E-commerce division, which is responsible for online sales, was
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operating at a negative fifteen point three percent (-15.3%) year-to-date growth rate, primarily as
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a result of the chaos that ensued following Mr. Charneys and ALONZOs respective
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terminations. With the improvement brought about by ALONZO S strategic decisions and
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communication alignment, online sales were operating at a two percent (2%) year-to-date
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growth rate by December 31, 2014.
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On or about December 24, 2014, Mr. Brubaker sent an email to ALONZO praising her for her
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dedication and contributions to the growth of AMERICAN APPAREL stating, in part, Thank
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you for your undying dedication, positive energy and leadership throughout this year. I am so
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impressed with your abilities and your drive. Thank you for all that you do for American
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Apparel... A true and correct copy of this email is attached hereto as Exhibit A.
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II
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Defendantsfail to compensate Alonzo as promised and instead continue to delay
taking any action on what she is rightfully owed.
30.
In or around mid-December 2014, ALONZO sent an email to Mr. Brubaker inquiring about the
stock grants she lost when she was terminated on June 25, 2014, as well as the reimbursement
of $30,000.00 loan. Despite ALONZOS request for a resolution of these issues by year-end,
DEFENDANTS failed to issue payment.
31.
In or around mid-January 2015, ALONZO sent another email to Mr. Brubaker expressing her
concern that she still had not been paid the $30,000.00 pursuant to one of the conditions of her
rehire. ALONZO informed Mr. Brubaker that she was compelled to borrow $30,000.00 from
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her parents to pay back Mr. Charney for the loan and needed AMERICAN APPAREL to issue
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payment to her immediately. Mr. Brubaker responded that ALONZO should not have paid Mr.
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Charney back and assured her that Standard General, the controlling interest in AMERICAN
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APPAREL, would be issuing payment of $30,000.00 to Mr. Charney directly, an amount which
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was never paid, not even a fraction thereof.
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32. ALONZO made similar complaints to Standard General Partner David Glazek (Mr. Glazek)
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from November 2014 to January 2015, but again received no definitive response and/or
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resolution regarding the $30,000.00 or shares of stock owed, resulting in further delay. A true
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and correct copy of text messages exchanged between Mr. Glazek and ALONZO is attached
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hereto as Exhibit B.
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33.
On or about January 5, 2015, Paula Schneider (Ms. Schneider) became the new Chief
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Executive Officer of AMERICAN APPAREL. Throughout her employment under Ms.
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Schneider, ALONZO also received praise for her creativity, hard work, and tangible
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contributions to AMERICAN APPAREL.
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34.
On or about February 5, 2015, ALONZO sent an email to Ms. Schneider to address the still
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unpaid sum of $30,000.00 as well as her lost shares due to her termination. Ms. Schneider gave
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assurances to ALONZO that any amount owed to her would be forthcoming. However, as was
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the case with the Interim CEO and the Standard General Partner, Ms. Schneider also refused to
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pay ALONZO her wages.

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Alonzo is wrongfully terminated in retaliation for her retention ofan attorney to
resohe the issue ofher unpaid wages, which Defrndants still refuse to pay.
35.
Frustrated with DEFENDANTS refusal to pay in breach of their promises to ALONZO, and
realizing the Interim CEO, Standard General Partner, and new CEO had been stringing her
along with empty promises that she would be made whole on all monies she was owed,
ALONZO retained an attorney, Keith A. Fink, Esq. (Mr. Fink) of FINK & STEINBERG.
36.
On or about February 16, 2015, ALONZOS attorney Mr. Fink wrote an email to Chelsea A.
Grayson (Ms. Grayson), General Counsel for AMERICAN APPAREL, to advise her of his
representation of ALONZO and to formally request ALONZOS personnel file pursuant to
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Labor Code Section 1198.5. A true and correct copy of this email is attached hereto as Exhibit
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C.
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That same day, ALONZO also informed Ms. Schneider in writing of her decision to retain legal
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counsel. In her email, ALONZO told Ms. Schneider she did not want anything to get between
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herself and Ms. Schneider and ALONZO explained that she felt it would be best to have a
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lawyer address the issues surrounding her unpaid compensation.
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Less than seventy-two (72) hours later, on or about February 19, 2015 (erroneously dated
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February 19, 2014), DEFENDANTS terminated ALONZOS employment with AMERICAN
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APPAREL in retaliation for retaining an attorney and/or for demanding payment of her wages.
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At around 3:30 p.m. that day, Director of Asset Protection and Risk Management Blue Montez
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(Mr. Montez) and Chief Human Resources Officer Craig Simmons (Mr. Simmons)
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barged into a meeting ALONZO was conducting and instructed all other employees to
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evacuate the office, at which point ALONZO was presented with a termination letter.
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DEFENDANTS provided no reason for ALONZOS termination. Upon information and
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belief, DEFENDANTS made the decision to terminate ALONZO due to the complaint written
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by ALONZOS attorney Mr. Fink on her behalf just a few days prior. A true and correct copy of
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the termination letter is attached hereto as Exhibit D.
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39.
Instead of allowing ALONZO to leave her place of employment with respect and dignity, Mr.
Montez, together with a group of security guards, escorted ALONZO out of the building to her
vehicle like a common criminal.
40.
ALONZO is informed and believes that DEFENDANTS have a pattern and practice of firing
employees who retained legal counsel to complain of a host of unlawful practices by
DEFENDANTS and/or complaining of DEFENDANTS failure to pay their employees
rightfully owed monies, including but not limited to wages, reimbursements, and vested shares
of stock.
41.
On or about March 6, 2015, AMERICAN APPAREL produced ALONZOS personnel file, but
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it was incomplete. Tellingly several documents relative to her compensation, terms of her
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rehire, her requests to be compensated, and eventual firing were removed. Additionally,
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PLAINTIFF is informed and believes that AMERICAN APPAREL now has a practice of
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sanitizing illegally fired employees by stuffing personnel files with backdated memorandums
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that the employees were never shown while working at AMERICAN APPAREL and removing
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select documents from files that demonstrate illegal practices by the company.
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Defrndants unlawfully withheld vacation payfrom Alonzo.
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Pursuant to the terms of her employment with DEFENDANTS, ALONZO was entitled to
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three (3) weeks of vacation. However, from 2004 to 2011, ALONZO was unable to take time off
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for vacation due to her workload, which required her to work approximately ninety (90) to one
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hundred (100) hours per week. It was not until 2011, approximately seven years after her initial
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hire date, that ALONZO took a vacation.
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ALONZO is informed and believes that DEFENDANTS have a pattern and practice, under
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new management, of not paying out accrued and/or unused vacation. ALONZO is further
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informed and believes that this has been a pattern and practice established by Ms. Grayson and
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Ms. Schneider.
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44.
Upon termination, DEFENDANTS failed to pay ALONZO her accrued and/or unused
vacation.
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FIRST CAUSE OF ACTION
WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY
(Against All DEFENDANTS and DOES 1 to 100)
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46.
It is the well-established policy of the State of California by and through its statutory and common
laws, including but not limited to California Constitution, Article I,
Code
Complaint, that it is intolerable and unlawful for an employer to bar or to discharge a person from
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employment or to discriminate against the person in compensation or in terms, conditions, or
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privileges of employment in retaliation for opposing an unlawful and/or discriminatory practice
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and/or for participating in a protected activity and/or for requesting payment of wages.
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47.
8, Business and Professions
17200, etq, Civil Code 1770, etq, and the various Labor Code sections within this
In contravention of these policies, PLAINTIFF is informed, believes and thereupon alleges that
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DEFENDANTS retaliated against her, and terminated her because of her complaints ofunlawful
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practices, including but not limited to, DEFENDANTS failure to compensate PLAINTIFF
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pursuant to the terms of her rehire and because PLAINTIFF hired an attorney to address the issues
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surrounding the unpaid compensation and various Labor Code violations and/or to avoid payment
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of wages.
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48.
against termination for participating in a protected activity as alleged above.
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DEFENDANTS actions described herein above were in violation of established public policy
49.
The conduct, statements and acts described herein were an ongoing part of a continuing scheme
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and course of conduct. DEFENDANTS were aware ofthe substance of the above-described facts
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and circumstances and ratified the wrongs and injuries mentioned herein when it was their ability
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to prevent, remedy and/or correct these wrongs.
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50.
DEFENDANTS have continued to ratify and have refused to remedy or correct the
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aforementioned conduct during and since PLAINTIFFS employment, notwithstanding the fact
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that they knew or reasonably should have known of the conduct and its unlawfulness.
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51.
As a direct and proximate result of the aforementioned violations of statute and public policy,
PLAINTIFF has suffered and will continue to suffer:
a.
A substantial reduction in past and current income and future income potential in sums as
may be shown according to proof
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b.
A substantial injury and damage to her occupation and professional reputation in a sum as
may be shown according to proof;
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c.
A substantial reduction in loss of work-related benefits; and
d.
Extreme humiliation and embarrassment and other losses from the date of said acts all to
PLAINTIFFS damage, in a sum as may be shown according to proof.
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52.
The amount of PLAINTIFFS damages is not presently known but she will seek leave of Court
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to amend this Complaint when the exact amount of such damages has been ascertained or will
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prove the same at trial.
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53.
The above-recited actions of DEFENDANTS were done with malice, fraud, oppression, and/or
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reckless disregard of PLAINTIFFS rights. DEFENDANTS engaged in offensive conduct despite
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their awareness of the effect on PLAINTIFF. As a result ofthese and other actions, PLAINTIFF is
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entitled to an award of punitive damages.
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SECOND CAUSE OF ACTION
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BREACH OF CONTRACT ORAL
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54.
and every allegation contained in Paragraphs 1 through 53, inclusive.
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PLAINTIFF re-alleges and incorporates herein by reference, as though set forth in full, each
55.
In or around 2004, DEFENDANTS and PLAINTIFF entered into an employment contract.
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During her employment, Mr. Charney, acting on behalf of DEFENDANTS, verbally
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represented to PLAINTIFF that the terms of her employment would include one (1) year
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severance pay upon termination. During her employment, PLAINTIFF was also promised
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three (3) of vacation annually.
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56.
Following her initial termination, in or around mid-October 2014, ALONZO agreed to return to
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the company as AMERICAN APPARELS Senior Creative Director, without an increase in
gross pay, on the following terms:
(2) ALONZOS employee stock plans, which were cancelled when she was terminated
on June 25, 2014, would be reinstated and any shares of stocks that vested since her
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57.
hired by AMERICAN APPAREL on October 20, 2014.
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DEFENDANTS and ALONZO agreed to the above terms and ALONZO was officially re
58.
PLAINTIFF at all times performed her obligations under the employment contract.
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DEFENDANTS breached the employment contract by terminating PLAINTIFF without
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severance or cause, and by failing to pay accrued and/or unused vacation, the $30,000.00 she
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loaned from Mr. Charney, or her vested shares of stock, which amounted to a total of 103,333
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shares of stock.
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59.
severance, vacation pay, lost wages and stock entitlements.
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60.
DEFENDANTS refusal to perform on the employment agreement was undertaken without

stipulation, justification, or excuse.
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As a result of DEFENDANTS breach, PLAINTIFF was damaged, including but not limited to,
61.
PLAINTIFFS damages are a certain, foreseeable, and measurable consequence of
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DEFENDANTS breaches. As a direct and proximate result of said breaches, PLAINTIFF has
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been damaged in an amount to be proven at trial according to proof, which she believes to be in
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excess of five hundred thousand dollars ($500,000.00).
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//
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TIIIRI) CAUSE OF ACTION
BREACH OF CONTRACT WRITTEN
62.
and every allegation contained in Paragraphs 1 through 61, inclusive.
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PLAINTIFF re-alleges and incorporates herein by reference, as though set forth in full, each
63.
In or around 2004, DEFENDANTS and PLAINTIFF entered into an employment contract.
During her employment, Former CEO Mr. Charney, acting on behalf of DEFENDANTS,
represented in writing to PLAINTIFF that the terms of her employment would include one (1)
year severance pay upon termination. During her employment, PLAINTIFF was also promised
three (3) of vacation annually.
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64.
Following her initial termination, in or around mid-October 2014, ALONZO agreed to return to
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the company as AMERICAN APPARELS Senior Creative Director, without an increase in
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gross pay, on the following terms:
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(2) ALONZOS employee stock plans, which were cancelled when she was terminated
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onJune 25, 2014, would be reinstated and any shares of stocks that vested since her
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65.
DEFENDANTS and ALONZO agreed to the above terms which were documented in a series
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of email exchanges between Mr. Brubaker and ALONZO. ALONZO was officially re-hired by
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AMERICAN APPAREL on October 20, 2014.
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66.
PLAINTIFF at all times performed her obligations under the employment contract.
DEFENDANTS breached the employment contract by terminating PLAINTIFF without
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severance or cause, and by failing to pay accrued and/or unused vacation, the $30,000.00 she
loaned from Mr. Charney, or her vested shares of stock, which amounted to a total of 103,333
shares of stock.
67.
severance, vacation pay, lost wages and stock entitlements.
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68.
DEFENDANTS refusal to perform on the employment agreement was undertaken without

stipulation, justification, or excuse.
7
8
As a result of DEFENDANTS breach, PLAINTIFF was damaged, including but not limited to,
69.
PLAINTIFFS damages are a certain, foreseeable, and measurable consequence of
DEFENDANTS breaches. As a direct and proximate result of said breaches, PLAINTIFF has
10
been damaged in an amount to be proven at trial according to proof which she believes to be in
ii
excess of five hundred thousand dollars ($500,000.00).
12
FOURTH CAUSE OF ACTION
13
BREACH OF THE IMPLIED COVENANT OF GOOD FAITH AN]) FAIR DEALING
14
15
16
70.
17
18
PLAINTIFF re-alleges and incorporates herein by reference, as though set forth in frill, each and
71.
Implied in every California contract is a covenant of good faith and fair dealing. This implied
19
covenant prevents one party to a contract from acting in bad faith in the performance of its
20
contractual obligations and prevents it from intentionally depriving the other party of the
21
benefit he or she bargained for in the agreement.
22
72.
In or around October 2014, and through various representations, DEFENDANTS and
23
PLAINTIFF entered into oral and written contracts under which PLAINTIFF would be paid
24
$30,000.00 to make her whole on the $30,000.00 loan she had borrowed from Mr. Charney to
25
supplement her lost wages following her termination; payment of stock entitlements that had
26
vested since her termination, and additional incentives for increasing AMERICAN
27
APPAREL S online sales. This constituted a valid and binding contract, the terms of which are
28
certain and enforceable.

15
73.
PLAINTIFF at all times performed her obligations under the agreement. DEFENDANTS
breached the agreement by terminating PLAINTIFF without cause and in retaliation for her
protected complaints.
74.
PLAINTIFF has suffered damages.
5
6
As a result of DEFENDANTS breach of the covenant of good faith and fair dealing,
75.
PLAINTIFF has suffered and continues to suffer:

a.
A substantial reduction in past and current income and future income potential
in sums as may be shown according to proof;
8
b.
A substantial injury and damage to her occupation and professional reputation in

a sum as may be shown according to proof;
10
11
c.
A reduction in loss of work-related benefits; and
12
d.
Extreme humiliation, embarrassment, emotional pain, and distress, which
13
culminated in suffering, mental anguish, inconvenience, and other losses from the date of her
14
termination, all of PLAINTIFFS damages in a sum as may be shown according to proof.
15
76.
The amount ofPLAINTIFFS damages is not presently known, but she will seek leave of Court to
16
amend this Complaint when the exact amount of such damages has been ascertained and/or will
17
18
77.
19
reckless disregard of PLAINTIFFS rights. DEFENDANTS engaged in offensive conduct despite
20
their awareness of the effect on PLAINTIFF. As a result of these and other actions, PLAINTIFF is
21
22
23
FIFTH CAUSE OF ACTION
24
VIOLATION OF LABOR CODE 201 AN]) 203, et q
25
26
78.
27
28
79.
DEFENDANTS failed to pay PLAINTIFF her wages earned and unpaid upon termination,
16
including the $30,000.00, accrued and/or unused vacation, and vested shares of stock. Pursuant to
Labor Code
unpaid at the time of termination.
80.
201, it is unlawful for an employer to fail to pay an employee the wages earned and
As a consequence of DEFENDANTS willful conduct in not paying PLAINTIFF all wages due
and owing to her upon termination, PLAINTIFF is entitled to penalty wages under Labor Code
203, together with interest thereon. Pursuant to Labor Code 203, if an employer willfully
fails to pay any wages and benefits of an employee who is discharged or quit within specified
times, the wages of such employee shall continue to accrue from the date thereof at the same
rate until paid, or until an action is commenced, up to a maximum of thirty (30) days.
10
81.
PLAINTIFF will seek attorneys fees incurred in prosecuting this action under Labor Code
201, 202, 218.5, and/or 1194, et q

1
11
12
SIXTH CAUSE OF ACTION
13
VIOLATION OF LABOR CODE
14
15
16
82.
17
18
206, et q
83.
PLAINTIFF is owed unpaid wages, bonuses, stock entitlements, vacation pay, severance pay, and
19
other benefits to which PLAINTIFF was entitled to by reason of her employment with
20
DEFENDANTS;
21
84.
DEFENDANTS acknowledged orally and in writing that PLAINTIFF was entitled to payment of
22
$30,000.00 to make her whole on her $30,000.00 loan, payment of her vested shares of stock
23
(ALONZO was promised two tranches that vested following her termination for 50,000 shares and
24
53,333 shares, respectively, plus taxes), vacation pay, severance pay, and other bonuses for
25
improving AMERICAN APPARELS online sales by the end of 2014. However, DEFENDANTS
26
refused to issue payment.
27
28
85.
Labor Code
206 provides in pertinent part,
.. .
the employer shall pay, without condition and
within the time set by this article, all wages, or parts thereof, conceded by him to be due....
DEFENDANTS have not paid the aforementioned sums, which they acknowledged was rightfully
due to PLAINTIFF.
86.
statute for unpaid wages (over 10 days and over 30 days).
4
5
PLAINTIFF has not received payment and it has been over the applicable time period set by
87.
As a consequence of DEFENDANTS willful conduct in their failure to pay PLAINTIFF all
wages due upon termination, including stocks, bonuses, vacation pay, and severance pay,
PLAINTIFF is entitled to penalties and treble damages under Labor Code
interest thereon.
88.
206, together with
PLAINTIFF will seek attorneys fees incurred in prosecuting this action under Labor Code
218.5, and/or any other applicable Labor Code sections.
10
11
SEVENTH CAUSE OF ACTION
12
13
14
15
89.
16
17
1102.5
90.
Pursuant to Labor Code
1102.5, an employer may not retaliate against an employee for
18
disclosing information, or because the employer believes that the employee disclosed or may
19
disclose information, to a government or law enforcement agency, to a person with authority over
20
the employee or another employee who has the authority to investigate, discover, or correct the
21
violation or noncompliance... .
22
91.
PLAINTIFF reasonably believed and complained of DEFENDTS illegal failure to pay her
23
earned wages, stock entitlements, and vacation pay to many of DEFENDANTS employees,
24
agents, or officers, including but not limited to Scott Brubaker, David Glazek, Paula Schneider,
25
and Chelsea Grayson.
26
92.
PLAINTIFF is informed, believes, and thereon alleges that DEFENDANTS did willfully
27
retaliate against her for engaging in the acts alleged herein by terminating her employment, due to
28
the belief that she would report DEFENDANTS to governmental agencies.

18
93.
As a direct and proximate result ofDEFENDANTS conduct, PLAINTIFF has suffered and will
continue to suffer:
a.
A substantial reduction in past and current income and future income potential
in sums as may be shown according to proof;
4
b.
A substantial injury and damage to her occupation and professional reputation in

a sum as may be shown according to proof;
6
7
c.
A substantial reduction in loss of work-related benefits; and
d.
Extreme humiliation and embarrassment and other losses from the date of said
acts all to PLAINTIFFS damage, in a sum as may be shown according to proof.
9
10
94.
The amount of PLAINTIFFS damages is not presently known but she will seek leave of Court
12
13
95.
14
reckless disregard ofPLAINTIFFS rights. DEFENDANTS engaged in offensive conduct despite
15
their awareness of the effect on PLAINTIFF. As a result of these and other actions, PLAINTIFF is
16
17
96.
1102.5(f), DEFENDANTS violations also subject them to civil
penalties often thousand dollars ($10,000.00) for each violation of Labor Code
18
19
Pursuant to Labor Code
97.
1102.5.
PLAINTIFF will seek attorneys fees and costs to the extent permitted by any applicable statutes
and provisions of the Labor Code.
20
21
EIGHTH CAUSE OF ACTION
22
23
24
25
98.
28
every allegation contained in Paragraphs 1 through 97 inclusive.
26
27
1198.5
99.
Pursuant to Labor Code 1198.5, an employer who receives an employees request to inspect or
copy records ofthat employees file pursuant to subdivision (b) pertaining to a current or former
19
employee shall comply with the request as soon as practicable, but no later than 21 calendar days
from the date of the request. Additionally, pursuant to Labor Code
are allowed access to their personnel files and records that relate to their performance or to any
grievance concerning them.
1198.5, former employees
100. DEFENDANTS failed to comply with PLAINTIFFS written request for her employment file,
in violation of Labor Code 1198.5. Tellingly several documents relative to her compensation,
terms of her rehire, her requests to be compensated, and eventual firing were removed.
Additionally, PLAINTIFF is informed and believes that AMERICAN APPAREL now has a
practice of sanitizing illegally fired employees by stuffing personnel files with backdated
10
memorandums that the employees were never shown while working at AMERICAN APPAREL
ii
and removing select documents from files that demonstrate illegal practices by the company.
12
101. The amount of PLAINTIFFS damages is not presently known, but she will seek leave of Court
13
14
15
MNTH CAUSE OF ACTION
16
VIOLATION OF BUSINESS & PROFESSIONS CODE
17
18
19
20
21
17200, et
102. PLAINTIFF re-alleges and incorporates herein by reference, as though set forth in full, each and
103. California Business and Professions Code
17200, etq, provides that unfair competition shall
22
mean and include all unlawful, unfair or fraudulent business act or practices and unfair, deceptive,
23
untrue or misleading advertising.
24
104. PLAINTIFF is informed and believes and thereon alleges that DEFENDANTS have engaged
25
in unfair competition in violation of California Business and Professions Code
26
by maintaining a workplace rife with retaliation and violations of established California public
27
policy including but not limited to the following: California Constitution, Article I,
28
Code
17200, et
8 and Civil
1770, et g The continuation of such unfair business practices allows DEFENDANTS

20
to maintain an unfair advantage over other companies which comply with established California
laws and the public policy of the state of California.
105. DEFENDANTS falls within the definition of person as set forth in Business and Professions
Code
4
5
17203 and 17506.
106. The unlawful, unfair, and fraudulent business practices of DEFENDANTS described above
present a continuing threat to members of the public in that DEFENDANTS have or will soon
engage in the conduct described above, and members of the public are likely to be deceived
when they pursue or gain employment with DEFENDANTS. Pursuant to California Business
and Professions Code

a.
10
17203, PLAINTIFF seeks an order from this Court that:
Provides injunctive and declaratory relief finding that DEFENDANTS have violated
the provisions of California Business and Professions Code
11
b.
12
17200, et q; and
For an order enjoining DEFENDANTS and their respective successors, agents,
13
servants, officers, directors, employees, and all other persons acting in concert with
14
them, directly or indirectly, from engaging in conduct which violates California Business
15
and Professions Code
1
17200, et q
16
PRAYER FOR REUEF
17
18
WHEREFORE, PLAINTIFF prays for judgment against DEFENDANTS, and each of them, as
follows:
19
20
1.
For general, special, actual, compensatory and/or nominal damages, including prejudgment
21
interest, in an amount to be determined at trial, but no less than five hundred thousand dollars
22
($500,000.00);
23
2.
For lost salary, both front and back pay, unpaid wages, bonuses, stock entitlements, vacation
24
pay, severance pay, and any other benefits to which PLAINTIFF would have been entitled to
25
by reason of her employment with DEFENDANTS, according to proof, but no less than five
26
hundred thousand dollars ($500,000.00);
27
28
3.
For punitive damages in an amount to be determined at trial sufficient to punish penalize

and/or deter DEFENDANTS, and each of them, from further engaging in the conduct
21
described herein, and to deter others from engaging in the same or similar acts;
i
2
4.
For appropriate civil and statutory penalties;
5.
For restitution and/or disgorgement of all ill-gotten gains (on the Ninth Cause of Action only);
6.
For preliminary and permanent injunction against DEFENDANTS from the acts of unfair
competition as described in the Ninth Cause of Action;
7.
For reasonable costs and attorneys fees where appropriate;
8.
For pre- and postjudgment interest on all damages and other relief awarded herein from all
entities against whom such relief may be properly awarded; and
8
9
9.
For all such other relief as this Court deems just and appropriate.
10
DATED: August 19, 2015
FINK & STEINBERG

By:
13
14
15
(/iL--,)
/
KeifhA.Fink
Sarah E. Hernandez
Jennifer H. Yeung
Attorneys for Plaintiff
IRIS ALONZO
16
17
18
19
20
21
22
23
24
25
26
27
28
22
CM-OiO
ATTORNEY OR PARTY WiTHOUT ATTORNEY (Name, State Barnumber, and address):
Jennifer H. Yeung SBN 280819

Fink & Steinberg
11500 Olympic Boulevard, Suite 316
TELEPHONE NO.:
ATTORNEY FOR (Name):
L310) 268-0780
Plaintiff Iris Alonzo
SUPERIOR COURT OF CALIFORNIA, COUNTY OF

STREET ADDRESS:
MAILING ADDRESS:
CITY AND ZIP CODE
BRANCH NAME:
FAX NO.:
(310) 268-0790
COMORMEI) COP
OF ORIGINAL FILED
Los Angeles
T 4riaplc
111 North Hill Street

Los Angeies, California 90012
Central District
Shorn R. Carter, Executive Officer/Clerk

Alonzo v. American Apparel, Inc., et al.
CASE
Complex Case Designation
LEJ
,rnr(otirf
AUG20 2015
CASE NAME:
CIVIL CASE COVER SHEET

Unlimited
Limited
FORCOURTUSEOIVLY
NUMBC
El
El
5 92 105
Counter
Joinder
(Amount
JUDGE
demanded is
Filed with first appearance by defendant
$25,000 or less)
OEPT:
(Cal. Rules of Court, rule 3.402)
Items 16 below must be completed (see instructions on page 2).
1. Check one box below for the case type that best describes this case:
Auto Tort
Contract
Provisionally Complex Civil Litigation
(Cal. Rules of Court, rules 3.4003.403)
Breach of contract/warranty (06)
Auto (22)
Uninsured motorist (46)
Rule 3.740 collections (09)
Antitrust/Trade regulation (03)
Other Pl/PDIWD (Personal Injury/Property
Other collections (09)
Construction defect (10)
Damage/Wrongful Death) Tort
Insurance coverage (18)
Mass tort (40)
Asbestos (04)
Other contract (37)
Securities litigation (28)
Product liability (24)
Real Property
Environmental/Toxic tort (30)
Medical malpractice (45)
Eminent domain/Inverse
Insurance coverage claims arising from the
condemnation (14)
Other Pl/PDPND (23)
above listed provisionally complex case
types (41)
Wrongful eviction (33)
Non-PI/PDIWD (Other) Tort
Other real property (26)
Enforcement of Judgment
Business tort/unfair business practice (07)
Enforcement of judgment (20)
Civil rights (08)
Unlawful Detainer
Commercial (31)
Defamation (13)
Miscellaneous Civil Complaint
Residential (32)
Fraud (16)
RICO (27)
Intellectual property (19)
Drugs (38)
Other complaint (not specified above) (42)
Professional negligence (25)
Judicial Review
Miscellaneous Civil Petition
Asset forfeiture (05)
Other non-PIIPDAND tort (35)
Partnership and corporate governance (21)
Employment
Petition re: arbitration award (11)
Other petition (not specified above) (43)
Wrongful termination (36)
Writ of mandate (02)
Other employment (15)
Other judicial review (39)
2. This case
is
LU is not complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the
factors requiring exceptional judicial management:
Large number of separately represented parties
a.
Large number of witnesses
d.
(Amount
demanded
exceeds $25,000)
EEl
El
LZI
El
El
El
El
El
El
El
El
3.
4.
5.
6.
b.
El
El
c.
El
El
El
El
El
El
El
El
El
El
El
El
El
El
EZI
El
El
El
El
El
El
El
El
El
El
El
El
El
El
L._J
Extensive motion practice raising difficult or novel

issues that will be time-consuming to resolve
Substantial amount of documentary evidence
a.L1
El
El
e.
El
El Coordination with related actions pending in one or more courts
in other counties, states, or countries, or in a federal court
El Substantial postjudgment judicial supervision

b. EZ1 nonmonetary; declaratory or injunctive relief
f.
Remedies sought (check all that apply):

monetary
Number of causes of action (specify): Nine (9)
This case
is
is not
a class action suit.
If there are any known related cases, file and serve a notice of related case. (You may use form CM-015.)
c.
punitive
El
Date: August 19, 2015

Jennifer H. Yeung, SBN 280819
(TYPE OR PRINT NAME)
E OF PARTYR ATTOR
0
/ (SIGNAT
Y FOR PARTY)
NOTICE
Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed
under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
in sanctions.
File this cover sheet in addition to any cover sheet required by local court rule.
If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all
other parties to the action or proceeding.
Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only.
Foss Adopted (or Mandatory Use
Judicial Council of California
CM-O1O [Rev. July 1,20071
Page 1 of 2
Cal. Rules of Court, rules 2.30, 3.220, 3.4003.403, 3.740;
Cal. Standards 0
f Judicial Administration, std. 3.10
WWW.CoUitiflfo.ca.gov
INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET
CM-OW
To Plaintiffs and Others Filing First Papers. If you are filing a first paper (for example, a complaint)
in a civil case, you must
complete and file, along with your first paper, the Civil Case Cover Sheet contained on page 1. This
information will be used to compile
statistics about the types and numbers of cases filed. You must complete items I through 6 on the
sheet. In item 1,
one box for the case type that best describes the case. If the case fits both a general and a more specific type of case you must check
listed in item 1,
check the more specific one. If the case has multiple causes of action, check the box that best indicates
the primary cause of action.
To assist you in completing the sheet, examples of the cases that belong under each case type in item
1 are provided below. A cover
sheet must be filed only with your initial paper. Failure to file a cover sheet with the first paper filed
in a civil case may subject a party,
its counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court.
To Parties in Rule 3.740 Collections Cases. A collections case under rule 3.740 is defined as an action for recovery
of money
owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorneys
fees, arising from a transaction in
which property, services, or money was acquired on credit. A collections case does not include an
action seeking the following: (1) tort
damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property,
or (5) a prejudgment writ of
attachment. The identification of a case as a rule 3.740 collections case on this form means that will
it
be exempt from the general
time-for-service requirements and case management rules, unless a defendant files a responsive
pleading. A rule 3.740 collections
case will be subject to the requirements for service and obtaining a judgment in rule 3.740.
To Parties in Complex Cases. In complex cases only, parties must also use the Civil Case Cover Sheet to designate
whether the
case is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court,
this must be indicated by
completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover
sheet must be served with the
complaint on all parties to the action. A defendant may file and serve no later than the time of its first
appearance a joinder in the
plaintiffs designation, a counter-designation that the case is not complex, or, if the plaintiff has made
no designation, a designation that
the case is complex.
Auto Tort
Auto (22)Personal Injury/Property

Damage/Wrongful Death
Uninsured Motorist (46) (if the
case involves an uninsured
motorist claim subject to
arbitration, check this item
instead of Auto)
Other PI!PD/WD (Personal lnjuryl
Property DamagelWrongful Death)
Tort
Asbestos (04)
Asbestos Property Damage
Asbestos Personal Injuryl
Wrongful Death
Product Liability (not asbestos or
toxic/environmental) (24)
Medical Malpractice (45)
Medical Malpractice
Physicians & Surgeons
Other Professional Health Care
Malpractice
Other PI/PDIWD (23)
Premises Liability (e.g. slip
and fall)
Intentional Bodily Injury/PDIWD
(e.g., assault, vandalism)
Intentional Infliction of
Emotional Distress
Negligent Infliction of
Emotional Distress
Other Pl/PDIWD
Non-PIIPDIWD (Other) Tort
Business Tort/Unfair Business
Practice (07)
Civil Rights (e.g., discrimination,
false arrest) (not civil
harassment) (08)
Defamation (e.g.. slander, libel)

(13)
Fraud (16)
Intellectual Property (19)
Professional Negligence (25)
Legal Malpractice
Other Professional Malpractice
(not medical or legal)
Other Non-Pl/PDAND Tort (35)
Employment
Wrongful Termination (36)

Other Employment (15)
CM-ole ]Rev July 1,2007]
CASE TYPES AND EXAMPLES
Contract
Breach of Contract/Warranty (06)

Breach of Rental/Lease
Contract (not unlawful detainer
or wrongful eviction)
Contract/Warranty BreachSeller
Plaintiff (not fraud or negligence)
Negligent Breach of Contract/
Warranty
Other Breach of Contract/Warranty
Collections (e.g., money owed, open
book accounts) (09)
Collection CaseSeller Plaintiff
Other Promissory Note/Collections
Case
Insurance Coverage (not provisionally
complex) (18)
Auto Subrogation
Other Coverage
Other Contract (37)
Contractual Fraud
Other Contract Dispute
Real Property
Eminent Domain/Inverse
Condemnation (14)
Wrongful Eviction (33)
Other Real Property (e.g., quiet title) (26)
Writ of Possession of Real Property
Mortgage Foreclosure
Quiet Title
Other Real Property (not eminent
domain, landlordftenant, or
foreclosure)
Unlawful Detainer
Commercial (31)
Residential (32)
Drugs (38) (if the case involves illegal
drugs, check this item: othe,wise,
report as Commercial or Residential)
Judicial Review
Asset Forfeiture (05)

Petition Re: Arbitration Award (11)
Writ of Mandate (02)
WritAdministrative Mandamus
WritMandamus on Limited Court
Case Matter
WritOther Limited Court Case
Review
Other Judicial Review (39)
Review of Health Officer Order
Notice of AppealLabor
Commissioner Appeals
Provisionally Complex Civil Litigation (Cal.

Rules of Court Rules 3.4003.403)
Antitrust/Trade Regulation (03)

Construction Defect (10)
Claims Involving Mass Tort (40)
Securities Litigation (28)
Environmental/Toxic Tort (30)
Insurance Coverage Claims
(arising from provisionally complex
case type listed above) (41)
Enforcement of Judgment
Enforcement of Judgment (20)

Abstract of Judgment (Out of
County)
Confession of Judgment (nondomestic relations)
Sister State Judgment

Administrative Agency Award
(not unpaid taxes)
Petition/Certification of Entry of
Judgment on Unpaid Taxes
Other Enforcement of Judgment
Case
Miscellaneous Civil Complaint
RICO (27)
Other Complaint (not specified

above) (42)
Declaratory Relief Only
Injunctive Relief Only (nonharassment)
Mechanics Lien
Other Commercial Complaint
Case (non-tort/non-complex)
Other Civil Complaint
(non-tortfnon-complex)
Miscellaneous Civil Petition
Partnership and Corporate

Governance (21)
Other Petition (not specified
above) (43)
Civil Harassment
Workplace Violence
Elder/Dependent Adult
Abuse
Election Contest
Petition for Name Change
Petition for Relief From Late
Claim
Other Civil Petition
Page 2 of 2
SHORT TITLE:
CASE NUMBER
BC 5 9 2 1 0 5
CIVIL CASE COVER SHEET ADDENDUM AND

STATEMENT OF LOCATION
(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)
This form is required pursuant to Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court.
Item I. Check the types of hearing and fill in the estimated length of hearing expected for this case:
JURY TRIAL?
YES
CLASS ACTION?
El
YES LIMITED CASE?
El YES
Item II. Indicate the correct district and courthouse location (4 steps
TIME ESTIMATED FOR TRIAL 7-8
E HOURS/
DAYS
If you checked Limited Case, skip to Item Ill, Pg. 4):
Step 1: After first completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your
case in the left margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected.
Step 2: Check one Superior Court type of action in Column B below which best describes the nature of this case.
Step 3: In Column C, circle the reason for the court location choice that applies to the type of action you have
checked. For any exception to the court location, see Local Rule 2.0.
Applicable Reasons for Choosing Courthouse Location (see Column C below)
1.
2.
3.
4.
5.
Class actions must be filed in the Stanley Mosk Courthouse, central district.
May be filed in central (other county, or no bodily injury/property damage).
Location where cause of action arose.
Location where bodily injury, death or damage occurred.
Location where performance required or defendant resides.
6.
7.
8.
9.
10.
Location
Location
Location
Location
Location
of property or permanently garaged vehicle.

where petitioner resides.
wherein defendant/respondent functions wholly.
where one or more of the parties reside.
of Labor Commissioner Office
Step 4: Fill in the information requested on page 4 in Item Ill; complete Item IV. Sign the declaration.
=0
<I
Civil Case Cover Sheet

Category No.
Type of Action
(Check only one)
Applicable Reasons
See Step 3 Above
Auto (22)
LI
A71 00 Motor Vehicle
Uninsured Motorist (46)
LI
A71 10 Personal Injury/Property Damage/Wrongful Death
LI
A6070 Asbestos Property Damage
2.
LI
A7221 Asbestos
2.
A7260 Product Liability (not asbestos or toxic/environmental)
1., 2., 3.. 4., 8.
LI
A7210 Medical Malpractice Physicians & Surgeons
1., 4.
Asbestos (04)
0-I-
Product Liability (24)
1. 2., 4
Uninsured Motorist
Personal Injury/Wrongful Death
Ca
LI A7240 Other Professional Health Care Malpractice
aG)
.
Personal Injury/Property Damage/Wrongful Death
1., 2., 4.
a)
Medical Malpractice (45)
Personal injury
Property Damage
Wrongful Death
(23)
LACIV 109 (Rev. 03/11)

LASC Approved 03-04
1.. 4.
LI
A7250 Premises Liability (e.g., slip and fall)
LI
A7230 Intentional Bodily Injury/Property Damage/Wrongful Death (e.g.,

assault, vandalism, etc.)
1 4
LI
A7270 Intentional Infliction of Emotional Distress
1., 3.
LI
A7220 Other Personal Injury/Property Damage/Wrongful Death
CIVIL CASE COVER SHEET ADDENDUM

AND STATEMENT OF LOCATION
4.
Local Rule 2.0

Page 1 of 4
rSHORT TITLE:
Alonzo
CASE NUMBER
v. American Apparel, Inc., et al.

Category No.
Type of Action
(Check only one)
C
Applicable Reasons
See Step 3 Above
Business Tort (07)
El
A6029 Other Commercial/Business Tort (not fraud/breach of contract)
1., 3.
Civil Rights (08)
El
A6005 Civil Rights/Discrimination
1., 2., 3.
Defamation (13)
El
A6010 Defamation (slander/libel)
1., 2., 3.
Fraud (16)
El
A6013 Fraud (no contract)
1., 2., 3.
El
A6017 Legal Malpractice
1., 2., 3.
El
A6050 Other Professional Malpractice (not medical or legal)
1., 2. 3.
Other (35)
El
A6025 Other Non-Personal Injury/Property Damage tort
2.3.
Wrongful Termination (36)
A6037 Wrongful Termination
El
A6024 Other Employment Complaint Case
1., 2., 3.
El
A6109 Labor Commissioner Appeals
10.
El
A6004 Breach of Rental/Lease Contract (not unlawful detainer or wrongful

eviction)
-t
I-0
a
o
-=
zz
U,
Professional Negligence (25)
ocu
a)
E
0
Other Employment (15)
Ui
Breach of Contract! Warranty

(06)
(not insurance)
2 5
El
A6008 Contract/Warranty Breach -Seller Plaintiff (no fraudineghgence)
El
A601 9 Negligent Breach of Contract/Warranty (no fraud)
1., 2., 5.
El
A6028 Other Breach of Contract/Warranty (not fraud or negligence)
1., 2., 5.
El
A6002 Collections Case-Seller Plaintiff
2., 5., 6.
El
A6012 Other Promissory Note/Collections Case
2., 5.
El
A6015 Insurance Coverage (not complex)
1., 2., 5., 8.
El
A6009 Contractual Fraud
1., 2., 3., 5.
El
A6031
El
A6027 Other Contract Dispute(not breach/insurance/fraudlnegligence)
1., 2., 3., 8.
Eminent Domain/Inverse
Condemnation (14)
El
A7300 Eminent Domain/Condemnation
2.
Wrongful Eviction (33)
El
A6023 Wrongful Eviction Case
2., 6.
El
A6018 Mortgage Foreclosure
2., 6.
El
A6032 Ouiet Title
2., 6.
El
A6060 Other Real Property (not eminent domain, landlord/tenant, foreclosure)
2., 6.
El
A6021
2., 6.
El
A8020 Unlawful Detainer-Residential (not drugs or wrongful eviction)
2., 6.
Unlawful DetainerPost-Foreclosure (34)
El
A6020F Unlawful Detainer-Post-Foreclosure
2., 6.
Unlawful Detainer-Drugs (38)
El
A6022 Unlawful Detainer-Drugs
2., 6.
Collections (09)
C-,
Insurance Coverage (18)
Other Contract (37)
a)
0
3.
Tortious Interference
1., 2., 3., 5.
Number of parcels______
a
ci,
Other Real Property (26)
Unlawful Detaier-Commercial
Unlawful Detainer-Commercial (not drugs or wrongful eviction)
=
ci,
Unlawful Detaner-Residential
LACIV 109 (Rev. 03/11)
LASC Approved 03-04

Local Rule 2.0

Page 2 of 4
SHORT TITLE:
CASE NUMBER

Category No.
Type of Action
(Check only one)
Asset Forfeiture (05)

Petition re Arbitration (11)
0::
C.,
Writ of Mandate (02)
El A61 08 Asset Forfeiture Case
2., 6.
2., 5.
Antitrust/Trade Regulation (03)
0)
Construction Defect (10)
A61 15 Petition to Compel/ContirmNacate Arbitration
El A6151 Writ-Administrative Mandamus
2., 8.
0 A61 52 Writ
2,
El
Other Judicial Review (39)
C
Applicable Reasons
See Step 3 Above
Mandamus on Limited Court Case Matter
A61 53 Writ Other Limited Court Case Review

-
2.
El A61 50 Other Writ /Judicial Review
2., 8.
Li
1., 2., 8.
A6003 Antitrust/Trade Regulation
El A6007 Construction Defect
1., 2., 3.
-J
Claims lnvoMng Mass Tort

0
El
A6006 Claims Involving Mass Tort
1., 2., 8.
A6035 Securities Litigation Case
1., 2., 8.
C-)
>..
Securities Litigation (28)
Toxic Tort
Environmental (30)
(n
El A6036 Toxic Tort/Environmental
1., 2., 3., 8.
El
1., 2., 5., 8.
>
Insurance Coverage Claims

from Complex Case (41)
A6014 Insurance Coverage/Subrogation (complex case only)
Li A6141 Sister State Judgment

,
EE
C)
C,
Ui
0)
Enforcement
of Judgment (20)
RICO (27)
Cl)
0
(I)
c)
>
C-,
Other Complaints
(Not Specified Above) (42)
Partnership Corporation
Governance (21)
Cl)
2., 6.
El
2., 9.
A6107 Confession of Judgment (non-domestic relations)
El A6140 Administrative Agency Award (not unpaid taxes)
2., 8.
LI
A6114 Petition/Certificate for Entry of Judgment on Unpaid Tax
2.. 8.
El
A6112 Other Enforcement of Judgment Case
2., 8., 9.
El
A6033 Racketeering (RICO) Case
1., 2., 8.
El A6030 Declaratory Relief Only
1., 2., 8.
El
2.. 8.
A6040 Injunctive Relief Only (not domestic/harassment)
LI A601 1 Other Commercial Complaint Case (non-tort/non-complex)
1., 2.. 8.
LI
1., 2., 8.
A6000 Other Civil Complaint (non-tort/non-complex)
El A61 13 Partnership and Corporate Governance Case
2., 8.
LI A6121 Civil Harassment
2., 3., 9.
El
A6123 Workplace Harassment
2., 3.. 9.
El
A6124 Elder/Dependent Adult Abuse Case
2., 3., 9.
LI
A6190 Election Contest
2.
U)
C
C.)
U)>
c-)
Other Petitions
(Not Specified Above)
(43)
LACIV 109 (Rev. 03/11)

LASC Approved 03-04
2., 9.
0 A6160 Abstract of Judgment
El A61 10 Petition for Change of Name
2., 7.
El A6170 Petition for Relief from Late Claim Law
2., 3., 4., 8.
El
2., 9.
A6100 Other Civil Petition

Local Rule 2.0

Page 3 of 4
rsHoRT TITLE:
CASE NUMBER
Item III. Statement of Location: Enter the address of the accident, partys residence or place of business, performance, or other
circumstance indicated in Item II., Step 3 on Page 1, as the proper reason for filing in the court location you selected.
ADDRESS:
REASON: Check the appropriate boxes for the numbers shown

under Column C for the type of action that you have selected for
this case.
747 Warehouse St.
El. R12. E3. E14. E5. E6. E7. E8. E9. ElO.
CITY
STATE:
ZIP CODE:
Los Angeles
CA
90021
I declare under penalty of perjury under the laws of the State of California that the foregoing is true
above-entitled
matter is properly filed for assignment to the Stanley Mosk
courthouse in the
and correct and that the
Central
District of the Superior Court of California, County of Los Angeles [Code Civ. Proc., 392 et seq., and Local
Item IV. Declaration of Assignment:
Rule 2.0, subds. (b), (c) and (d)].
Dated: August 19, 2015

(SIGN(fURE OF ATTORNEY/FILIN
PARTY)
6
PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY
COMMENCE YOUR NEW COURT CASE:
1.
Original Complaint or Petition.
2.
If filing a Complaint, a completed Summons form for issuance by the Clerk.
3.
Civil Case Cover Sheet, Judicial Council form CM-010.
4.
Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev.
03/11).
5.
Payment in full of the filing fee, unless fees have been waived.
6.
A signed order appointing the Guardian ad Litem, Judicial Council form CIV-01 0, if the plaintiff or petitioner is a
minor under 18 years of age will be required by Court in order to issue a summons.
7.
Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum
must be served along with the summons and complaint, or other initiating pleading in the case.
LACIV 109 (Rev. 03/11)

LASC Approved 03-04

Local Rule 2.0

Page 4 of 4
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

NOTICE OF CASE ASSIGNMENT UNLIMITED CIVIL CASE (NON-CLASS ACTION)
Case Number
-
8C592 105
THIS FORM IS TO BE SERVED WITH THE SUMMONS AND COMPLAINT

Your case is assigned for all purposes to the judge indicated below.
There is more information on the reverse side of this form.
I ASSIGNED JUDGE
DEPT
ROOM
Hon. Kevin C. Brazile
534
Hon. Barbara A. Meiers
12
Hon. Terry A. Green
I ASSIGNED JUDGE
DEPT
ROOM
Hon. Elizabeth Allen White
48
506
636
Hon. Deirdre Hill
49
509
14
300
Hon. John L. Segal
50
508
Hon. Richard Fruin
15
307
Hon. Mitchell L. Beckloff
51
511
Hon. Rita Miller
16
306
Hon. Susan Bryant-Deason
52
510
Hon. Richard E. Rico
17
309
Hon. Steven J. Kleifleld
53
513
Hon. Stephanie Bowick
19
311
Hon. Ernest M. Hiroshige
54
512
Hon. Dalila Corral Lyons
20
310
Hon. Malcolm H. Mackey
55
515
Hon. Robert L.Hess
24
314
Hon. Michael Johnson
56
514
Hon. Yvette M. Palazueles
28
318
Hon. RoIf M. Treu
58
516
Hon. Barbara Scheper
30
400
Hon. Gregory Keosian
61
732
Hon. Samantha Jessner
31
407
Hon. Michael L. Stern
62
600
Hon. Mary H. Strobel
32
406
Hon. MsrkMooney
68
617
Hon. Michael P. Llnfield
34
408
Hon. William F. Fahey
69
621
Hon. Gregory Alarcon
36
410
Hon. Suzanne G. Bruguera
71
729
Hon. Marc Marmaro
37
413
Hon. Ruth Ann Kwan
72
731
Hon. Maureen Duffy-Lewis
38
412
Hon. Rafael Ongkeko
73
733
Hon. Elizabeth Feffer
39
415
Hon. Teresa Sanchez-Gordon
74
735
Hon. Michelle R. Rosenblatt
40
414
Hon. Gail Ruderman Feuer
78
730
Hon. Holly E. Kendlg
42
416
Hon. Mel Red Recana
45
529
324
CCW
Hon. Frederick C. Shaller
46
500
Hon. Debre K. Weintraub
47
507
324
CCW
--
Hon. Emile H. ElIas

*provbionally Complex
Non-class Action Cases
Assignment is Pending
Comniex Determination
*ComDlex
All non-class action cases designated as provisionally complex are
forwarded to the Supervising Judge of the Complex Litigation Program
located in the Central Civil West Courthouse (600 S. Commonwea
lth Ave., Los Angeles 90005), for complex/non-complex determination
pursuant to Local Rule 3.3(k). This procedure is for the purpose of
assessing whether or not the case Is complex within the meaning of
California Rules of Court, rule 3.400. DependIng on the outcome
of that assessment, the case may be reassigned to one of the judges of the
Complex Litigation Program or reassigned randomly to a court in the
Central District.
Given to the PlaintifflCross-ComplalnantlAttorney of Record
on
SI4ERRI R. CARTER
I.ACIVCCH 190 (Rev. 04115)
LASC Approved 05.06
SHERRI R. CARTER, Executive Officer/Clerk
U. SOIl)
By
NOTICE OF CASE ASSIGNMENT

UNLIMITED CML CASE
-,
De Pu,
I Clerk
Page I of 2
INSTRUCTIONS FOR HANDLING UNLIMITED CIVIL CASES

The following critical provisions of the Chapter Three Rules, as applicable in the Central District, are summarized
for your assistance.
APPLICATION
The Chapter Three Rules were effective January 1, 1994. They appLy to all general civil cases.
PRIORiTY OVER OTHER RULES

The Chapter Three Rules shall have priority over all other Local Rules to the extent the others are inconsistent.
CHALLENGE TO ASSIGNED JUDGE

A challenge under Code of Civil Procedure section 170.6 must be made within 15 days after notice of assignment
for all purposes to
judge, or if a party has not yet appeared, within 15 days of the first appearance.
TIME STANDARDS
Cases assigned to the Individual Calendaring Court will be subject to processing under the following time
standards:
COMPLAINTS: All complaints shall be served within 60 days of filing and proof of service shall
be filed within 90 days of filing.
CROSS-COMPLAINTS: Without leave of court first being obtained, no cross-complaint may be filed by any party after their
answer i
filed. Cross-complaints shall be served within 30 days of the filing date and a proof of service fiLed within
60 days of the filing date.
A Status Conference will be scheduled by the assigned Independent Calendar Judge no later than 270 days
after the filing of the complaint
Counsel must be fully prepared to discuss the following issues: alternative dispute resolution, bifurcation,
settlement, trial date, and exper
witnesses.
FINAL STATUS CONFERENCE
The Court will require the parties at a status conference not more than 10 days before the trial have timely
to
filed and served all motions
in limine, bifurcation motions, statements of major evidentiary issues, dispositive motions, requested
jury instructions, and special jury
instructions and special jury verdicts. These matters may be heard and resolved at this conference.
At least 5 days before this conference,
counsel must also have exchanged lists of exhibits and witnesses and have submitted to the court
a brief statement of the case to be read to
the jury panel as required by Chapter Eigit of the Los Angeles Superior Court Rules.
SANCTIONS
The court will impose appropriate sanctions for the failure or refusal to comply with Chapter Three
Rules, orders made by the Court, and
time standards or deadlines established by the Court or by the Chapter Three Rules. Such sanctions
may be on a party or if appropriate on
counsel for the party.
This is not a complete delineation of the Chapter Three Rules, and adherence only to the
above provisions is therefore not a
guarantee against the Imposition of sanctions under Trial Court Delay Reduction. Careful reading and
compliance with the
actual Chapter Rules Is absolutely Imperative.
LACIV CCH 190 (Rev. 04/15)

LASC Approved 05-08
NOTICE OF CASE ASSIGNMENT

UNLIMITED CIVIL CASE
Page 2 of 2
VOLUNTARY EFFICIENT LITIGATIO STI

N
PULATIONS
Supedor Court of California

County of Los Angeles
Los Angus Cow*y

S Aleoddlon
Los Angeles County
B Assoelellon Labor esd
Law Sson
II
:1 .11
Ca
Msocloo of Los Angeles
&iin C.IIla
OJi.u Cossl
The Early Organizational Meeting Stipulat

ion, Discovery
Resolution Stipulation, and Motions in Lim
ine Stipulation are
voluntary stipulations entered into by the par
ties. The parties
may enter into one, two, or all three
of the stipulations;
however, they may not alter the stipulat
ions as written,
because the Court wants to ensure uniformit
y of application.
These stipulations are meant to enc
ourage cooperation
between the parties and to assist in reso
lving issues in a
manner that promotes economic case reso
lution and judicial
efficiency.
The following organizations endorse the
goal of
promoting efficiency in litigation and
ask that counsel
consider using these stipulations as a vol
untary way to
promote communications and procedure
s among counsel
and with the court to fairly resolve issues in
their cases.
Los Angeles County Bar Association Liti
gation Sectlofl
Los Angeles County Bar Association

Labor and Employment Law Sectlon
Assoton of
Besle.iaTili Lawysra
Consumer Attorneys Association of Los Angeles
Southern California Defense Counsel

Associatlon of Business Trial LawyersO
C.I!.pluym.of
Calilornia Employment Lawyers Assoclatlon
LNW 230 QEW)

Atwoued4-1l
IEM
MTCEY Oft PMTY wnsr ATTO

ftIY
TELEPHONE NO.:
E-MAIL AOURESS (Oc):
aTATE8M Ie*6ER
,pIe
z,
FAX NO. (Opdond):
[SUPERIOR COURT OF CALIFORNIA

, COUNTY OF LOS ANGELES
[OURThQUSE AORESS:
PIJdN11FF:
i
STIPULATION
DISCOVERY RESOLUTION
This stipulation Is Intended to provid

e a fast and informal resolution of disc
overy issues
through limited paperwork and an
Informal conference with the Court to
aid In the
resolution of the Issues.
The parties agree that

1. Prior to the discovery cut-off in this action,
no discovery motion shall be filed or heard unl
the moving party first makes a written req
uest for an Informal Discovery Conference pur ess
to the temis of this stipulation.
suant
V
2. At the Informal Discovery Conference

the
and determine whether it can be resolvedCourt will consider the dispute presented by parties
informally. Nothing set forth herein will preclud
party from making a record at the con
ea
clusion of an Informal Discovery Confere
nce, either
orally or in writing.
V
3. FollowIng a reasonable and good faith

atte
presented, a party may request an Info mpt at an informal resolution of each issue to be
rmal Discovery Conference pursuant to the
foflowing
procedures
.
a. The party requesting the Informal

Dis
covery Conference will:

V
I.
File a Request for Informal Discov

ery Coliference with the c1erks office on
the
approved fomi (copy attached) and
deliver a courtesy onformed copy to the
ased depa
V
ii.
Indude a brief summary of the dispute

and spe
cify the relief requested; and
IL
Serve the opposing party pursuant to

that ensures that the opposing par any authorized or agreed method of service
ty receives the Request for Informal Discovery
Conference no later than the next cou
rt day following the filing.
b. My Answer to a Request for Informa
l Discovery Conference must
I. Also be filed on the approved farm
(copy attached);
IL Include a brief summary of why the
requested relief should be denied;
LFdIVO3
LASC P4Iowed 04011
STIPULATION DISCOVERY RESO
FIai UI.
LUTION
-
P I I3
MB
iii.
iv.
Be filed within two (2) court days of receipt

of the Request; and
Be served on the opposing party pur
suant to any authorized or agreed upon
method of service that ensures that the
opposing party receives the Answer no
later than the next court day following the
filing.
c. No other pleadings, indtgling but not limit

ed to exhibits, dedarations, or attachments, will
be accepted.
d. If the Court has not granted or denied the
Request for Informal Discovery Conference
within, ten (10) days following the filing of
the Request, then it shall be deemed to have
been denied.. If the Court acts on the Req
uest, the parties will be notified whether the
Request for lflformal Discovery Conference
has been granted or denied and, if granted,
the date and time of the Informal Discovery
Conference which must be within twenty (20)
days of the filing of the Request for Informal
Discovery Conference.
e. If the conference Is not held Within twen
ty
Informal Discovery Conference, unless exte (20) days of the filing of the Request for
nded by agreement of the parties and the
Cowl, then the Request for the Infomial Dis
covery Conference shall be.deemed to have
been dnisd at that time.
4. If (a) the Court has denied a conference or
(b)
without the Court having acted or (c) the Infor one of the time deadlines above has expired
mal Discovery Conference is conduded without
resolving the dispute, then a party may file a
discovery motion to address unresolved issues.
5. The parties hereby further agree that the tim
e for making a motion to compel or other
discovery fl)fl IS tolled from the data
of filing of the Request for Informal Discover
y
Conference untli (a) the request is denied
or deemed denied or (b) twenty (20) days after
the
Iding of the Request for Informal Discovery Con
ference, whichever is earlier, unless extended
byOrderoftheCourt
It I. the understanding and intent of the pas
ties
dispute to which It applies, constitute a writing that this stipulation shall, for each discovery
the p opounding [or demanding or requestIng memorializing a speciftc later date to which
pasty and the responding pasty have agreed In.
wdling, within the meaning of Code CMI Pro
cedure sections 2030300(c), 2031.30(c), and
2033.290(c).
6. NothIng herein wil preclude any party from
applying ax paite for appropriate relief, indudi
ng
an order Shortering time for a motion to be hea
rd concerning discovery.
7. Any party may terminate this stipulation by
gMng twenty-one (21) days notice of Iqten
t to
teminate the sidation.
8. References to days mean calendar days, unl
ess otherwise noted. If the date for performing
any act pursuant to this stipulation falls on a Sat
urday, Sunday or Court holiday, then the time
for performing that act Shall be exte ded to the
next Court day.
LAsc
04111
FcrandUi
STIPULATION
DISCOVERY
1cM
The following parties stipulate:

Date:
Date:
Date:
Date:
>
(TYPE OR PRINT NA)IE)
(ATTORNEY FOR PLAINTiFF)
(TYPE CR PRINT NAME)

jII I%flflT F$
>.
(TYPE CR PRINT NAME)
wr
(ATTORNEY FOR DEFENDANT)
>
r1w,, ,w,
Date:
i,

(TYPE
>
aaESfl
(ATTORNEY FOR_______________
Date:.
Date:
>
YPEORPRWTNAME)
(ATTORNEY FOR_______________
NCR PRWT
LAQVI
LASC PpO4fl1
F Opland U..
(ATTORNEY FOR
STIPULATION DISCOVERY RESOLUTION

-
Ps. 3 at3
STATISM MSmm
1ELEPHONE NO.:
EMAN. ADDRESS (Oplon):
Rv
OmV.S. .p
FAX NO. (Opdon):
SUPERIOR COURT OF CALIFORNIA, COUNTY

OF LOS ANGELES
JRTHOUSE ADORESS:
P4MNTIFF:
DEFENDANT:
STIPULATION
EARLY ORGANIZATIONAL MEETING
This stipulation Is Intended to encourage coo

peration among the parties at an early stage
In
the litigation and to assist the parties In efficien
t case resolution.
1. The parties commit to conduct, an Initial con
videoconference) wIthin 15 days from the date ference (in-person or via teleconference or via
this
whether there can be agreement on the following stipulation is signed, to dlsuss and consider
:
a. Are mOtions to challenge the pleadings nec

essary? It the Issue can be resolved
amendment as of right, or if the Court
would allow leave to amend, could an amendeby
d
complaint resolve most or all of the issues a
demurrer might otherwise raise? If so, the parti
es
agree t work through pleading lsues so that
resolve. Is Ih issue that the defendant seeks a demurrer need only raise Issues they cannot
would some Other type of motion be prefera to raise amenable to resolution on demurrer, or
ble? Could a voluntary targeted exchange of
documents or Information by any party cur
e an uncertainty In the pleadings?
b. Initial mutual exchanges of documents at the
score of the litigation. (For example, In an
employment case, the
oyment records, personnel file and doc
uments relating to the
conduct In question could be considered
core. In a personal injury case, an Incident
police report, medical records, and repair
or
or maintenance records could be considered
core.;
.
c. Exchange of names and contact Information of
witnesses;
d. Any Insurance agreement that may be availab

indemnify or reimburse for payments made to le to satisfy part or all of a judgment, or to
satisfy a judgment
e. Exchange of any other information that might
be helphi to facilitate understanding, handing,
or resolution of the case In a manner that pre
serves objections or privileges by agreement
f. Controlling. issues of law that, if resolved earl
phases of tie case. Also, when and how suc y, will promote efficiency and economy In other
h Issues can be presented to the Court;
g. Miether or when the case should be schedu
led
court ruling on legal issues Is reasonably require with a settlement officer, what discovery or
and Whether the parties wish to use a silting d to make settlement discussions meaningful,
judge or a private mediator or other options as
ou1i
FarOpIariUI
STIPULATION
EARLY ORGANIZATIONAL MEETI

NG
P.Q.1012
[iicHfnnE
discussed in the Alternative Dispute Resolution

(ADR) Information Package served with the
complaint;
h. Computation of damages, Induding documents,
not privileged or protected from dlsdosure, on
which such computation is based;
i.
2.
Whether the case is suitable for the Expe

dited Jury
rwwjasu,,eliorcourLom under Civil and then unde Trial procedures (see information at
r General Information).
The time for a defending party to respond to
a complaint or cross-complaint will be extended
to
for the complaint, and
ON8ERT1)
for Itie cross
complaint, which Is comprised of the 30 days
to respond under Government Code 66616(b),
and the 30 days permitted by Code of Civil Pro
cedure section 1054(a), good cause having
been found by the Civil Superi4skig Judge due
to the case management benefits provided by
this Stipulation. A copy of the General Order
can be found at wtw.lasuDeAorcourLom under
CIvIr, dick on General lnforn,alion then click
on Voluntaiy Efficient Utigatlon St4iulatlons.
The parties will prepare a joln report titled Join
t Status Report Pursuant to Initial Conference
and Early Organizational Meeting Stipulation,
and
If desired, a proposed order summarizing
meijfts of their meet and confer and advising
the Court of any way it may assist the parties
effldent conduct or resdufton of the case. The
parties shall attach the Joint Status Report to
the Ca8e Management Conference stateme
nt, and file the documentS when the CMC
statement Is due.
,
3.
ReferenceS to days mean calendar days, unl

ess othewlse noted. If the date for performing
any ad pursuant to this stIpulation falls on a Satu
rday, Sunday or Court holiday, then the time
for performing that act shall be extended to the
next Court day
The following parties stipulate:
4.
0
V
Ode:
(ATTORNEY FOR PLAIN1WF)
Od
(FYPE OR PRINT NAME)
Dab:

(TYPEORPRINTNAME)
(ATTORNEY FOR_______________
(ATTORNEY FOR______________
Lwm (-
LASC Fpd 04111
(ATTORNEY FOR
STIPULATiON EARLY ORGANIZAT
iONAL MEETING
Pag 20(2
I
II
I
I
I
11. .1
ls
C.
iii
4
V
I.
I. 1(111
ii
t.
iDdIl II
CiJ
ii
1
II!
III
j_,TATEeM
-
TELEPHONE NO.:
E-MAIL ADDRESS (Op*on):
ATTORNEY FOR (Ni1e).
P1.
FAX NO. (Opdoa):
SUPERIOR COURT OF CALIFORNIA, COUNTY OF

LOS ANGELES
OURThOUSE ADDRESS:
STIPULATION AND ORDER
CA MG
MOTIONS IN UMINE
This stipulation Is Intended to providO fast and

Informal resolution of evidentlary
issues through diligent efforts to define and disc
uss such issues and limit paperwork.
1. At least
days before the final Status conference,
each party will provide all other
parties with a list containing a one paragraph expl
anation of each proposed motion in
Umine; Each one paragraph explanation must iden
tify
motion In mime and the grounds for the proposed motithe substance of a single proposed
on.
2. The parties thereafter wil meet and confer, either in

person or via teleconference or
videoconference, concerning all proposed motions
in limine. In that meet and confer, the
parties will determine:
a. VWiether the parties can stipulate to any of Ue prop
osed motiw. fl ti parties so
stipulate, they may file a stipiation and proposed
.oider with the Court
b. Whether any of the proposed motions can be briefed
and submitted by means of a
short joint statement of issues. For each motion
which can be addressed by a short
joint statement of issues, a short joint stateme
nt of issues must be filed with the Court
10 days prior to the final status conference.
Each sides portion of the short joint
statement of issues may not exceed three
pages. The parties will meet and confer to
agree on a date and manner for exchanging the
parties respective portions of the
statement of issues and the process for
filing the short joint statement of
issues.
V
Vj
3. Al proposed motions in limine that are not either the subj

ect of a stipulation or briefed via
a short joint statement of issues will be briefed and ifled
in
accoidance with the California
Rules of Court and the Los Angeles Superior Court
Rules.
pqpO4I11
FaroplariUls
STIPULATION AND ORDER
MOTIONS IN LIMINE
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________________
SUM-100
SUMMONS
FOR COURT USE ONLY

(SOLO PARA USO DE LA CORTE)
(CITA CION JUDICIAL)

NOTICE TO DEFENDANT:
(AVISO AL DEMANDADO):
AMERICAN APPAREL INC., a Delaware corporation

Additional Parties Attachment form is attached.
COIFORN1N) UOI Y
YOU ARE BEING SUED BY PLAINTIFF:

(LOESTADEMANDANDOELDEMANDANTE):
AUG20 2015
IRIS ALONZO, an individual,

Plaintiff.
Shern R. Carter, Executive OfficerlClerk

NOTICE! You have been sued. The court may decide

against you without your being heard unless you respon
d 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 inform
ation 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 respon
se 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 service
s program. You can locate
these nonprofit groups at the California Legal Services Web site
(www.courtinfo.ca.gov/selfhelp), or by contacting your local court (www.lawhe!pcalifornia.org), the California Courts Online Self-Help Center
or county bar association. NOTE: The court has a statuto
ry lien for waived fees and
costs on any settlement or arbitration award of $10,000 or more
in a civil case. The courts lien must be paid before the
court will dismiss the case.
AVISO! Lo han demandado. Si no responde cientro de 30
1
dIas, Ia code puede
decidir en su Contra STh escuchar su version. Lea Ia

continuacidn.
infonriaciOn a
Tiene 30 DIAS DE CALENDARIO despus de que le entregu
en esta citacidn y papeles legates para presentar una
respuesta por escrito en esta
corte y hacer que se entregue una copia al demandante. Una
carta o una Ilamada telefOnica no /0 protegen. Su respue
sta por escrito tiene que estar
en form ato legal correcto Si desea que procesen su caso en
Ia code. Es posible que haya un formularlo que usted
pueda usar para su respuesta.
Puede encontrar estos form u/ar/os de Ia code y ms inform
aciOn en el Centro de Ayuda de las Codes de California
(www.sucorte.ca.gov), en Ia
biblioteca de leyes de su condado o en Ia code que le quede
ms cerca. Si no puede pagar Ia cuota de presen
taciOn, pida at secretario de Ia code
que le d un form ulario de exencibn de pago de cuotas. Si no presen
ta su respuesta a tiempo, puede perder el caso por
incumplimiento y Ia code le
podra quitar su sue/do, dinero y bienes sin ms advedencia.
Hay otros requisitos legates. Es recomendable que Ilame a un
abogado inmediatamenfe. Si no conoce a un abogad
o, puede Ilamar a un servicio de
remisiOn a abogados. Si no puede pagar a un abogado, es
posibie que cumpla con los requisitos para obtener servici
os legates gratuitas de un
programa de servicios legales sin fines de lucro. Puede encont
rar estos grupos sin fines de lucro en el sitio web de Califo
rnia Legal Sen,ices,
(www.lawhelpcalifornia.org), en el Centro de Ayuda de las Codes
de California, (www.sucorte.ca.gov) o ponindose en
contacto con Ia code o el
co!egio de abogados locales. A V/SO: Por fey, a code tiene
derecho a rectamar las cuotas ylos costos exentos
por imponer un gravamen sobre
cualquierrecuperaciOn de $10,000 0 ms de valor recibid
a med/ante un acuerdo o una concesiOn de arbifraje
en un caso de derecho civil. Tiene que
pagar el gravamen de Is code antes de que Ia code pueda desech
ar el caso.
The name and address of the court is:

(El nombre y direccin do Ia corte es):
Los Angeles Superior Court
CASE NUMBER:
(Ntimero del Caso).

BC 5 92 1 o
The name, address, and telephone number of plaintiffs attorney, or

plaintiff without an attorney, is:
(El nombre, Ia direcciOfl ye! nUmero
do telbfono del abogado del demandante, 0 del
Jennifer H. Yeung, SBN 280819, Fink & Steinberg, 11500 Olympic demandante quo no tiene abogado, es):
Blvd., Ste. 316, Los Angeles, CA 90064
DATE:
SiIERRLC
Clerk,
by
(Fecha)
(Secretarlo)
(For proof of service of this summons, use Proof of Service of Summ
ons (form POS-OlO).)
(Pars prueba de entrega de esta citatiOn LI.se el formulario Proof of Servic
e of Summons, (POS-01Q)).
[SEAL]
,Deputy
(Adjunto)
NOTICE TO THE PERSON SERVED: You are served

as an individual defendant.
2.
as the person sued under the fictitious name of (specify):
1.
3.
on behalf of (specify):
under:
4.
Form Adopted for Mandatory Use
Judicial Council of California
SUM-leO lRev. July 1.2009]
M.SOto
CCP 416,10 (corporation)

CCP 416.20 (defunct corporation)
CCP 416.40 (association or partnership)
CCP 416.60 (minor)

CCP 416.70 (conservatee)
CCP 416.90 (authorized person)
other (specify):
by personal delivery on (date):
SUMMONS
Code of Civil Procedure
41220.465
wwwcOurfinfo.ca.gov
SUM-200(A)
CASE NUMBER:
roRT TITLE:
jAlonzo v. American Apparel, Inc., et al.

INSTRUCTIONS FOR USE
-
This form may be used as an attachment to any summons if space does not permit the listing of all parties on the summons.
If this attachment is used, insert the following statement in the plaintiff or defendant box on the summons: Additional Parties
Attachment form is attached.
List additional parties (Check only one box. Use a separate page for each type of pany.):
Plaintiff
7J
Defendant
Cross-Complainant
Cross-Defendant
AMERICAN APPAREL RETAIL, INC., a California corporation; AMERICAN APPAREL (USA), LLC, a
California limited liability company; AMERICAN APPAREL MANUFACTURING, INC., a California
corporation, AMERICAN APPAREL GROUP, a Delaware corporation; AMERICAN APPAREL
CORPORATION, a Delaware corporation; and DOES ito 100, inclusive,
Defendants.
Page
of
1
Page 1 of I
Form Adopted for Mandatory Use

Judicial Council of Cailfornia
SUM-200(A) [Rev. January 1, 2007[
ADDITIONAL PARTIES ATTACHMENT

Attachment to Summons

Iris Alonzo Bc592105

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1

Keith A. Fink, Bar No. 146841

Attorneys for Plaintiff

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES CENTRAL DISTRICT

10 IRIS ALONZO, an individual;

13 AMERICAN APPAREL, INC., a Delaware

[JURY TRIAL DEMANDED]

Plaintiff IRIS ALONZO hereby alleges as follows:

VENUE AND PARTIES

hereto was, a resident of the County of Los Angeles, State of California.

Plaintiff IRIS ALONZO (ALONZO and/or PLAINTIFF) is, and at all

PLAINTIFFS COMPLAINT FOR DAMAGES

Angeles, State of California.

APPAREL RETAIL, INC. (AMERICAN APPAREL and/or DEFENDANTS) is, and at

of Los Angeles, State of California.

the County of Los Angeles, State of California.

substantial business in the County of Los Angeles, State of California.

Angeles, State of California.

CORPORATION (AMERICAN APPAREL and/or DEFENDANTS) is, and at all times

Angeles, State of California.

AMERICAN APPAREL RETAIL, INC., AMERICAN APPAREL (USA), LLC, AMERICAN

APPAREL MANUFACTURING, INC., AMERICAN APPAREL GROUP, and AMERICAN

APPAREL CORPORATION were joint employers of PLAINTIFF. AMERICAN APPAREL,

INC., AMERICAN APPAREL RETAIL, INC., AMERICAN APPAREL (USA), LLC,

PLAINTIFFS COMPLAINT FOR DAMAGES

AMERICAN APPAREL MANUFACTURING, INC., AMERICAN APPAREL GROUP, and

AMERICAN APPAREL CORPORATION hired employees jointly, including PLAINTIFF,

associated or otherwise, ofDefendants DOES 1 through 100 (DOES and/or DEFENDANT

the relief herein requested.

AMERICAN APPAREL RETAIL, INC., AMERICAN APPAREL (USA), LLC, AMERICAN

APPAREL MANUFACTURING, INC., AMERICAN APPAREL GROUP, and AMERICAN

AMERICAN APPAREL (USA), LLC, AMERICAN APPAREL MANUFACTURING, INC.,

AMERICAN APPAREL GROUP, and AMERICAN APPAREL CORPORATION commingled

diversion of corporate funds or assets to non-corporate uses, failed to maintain corporate

adequately capitalize some or all of the corporations.

PLAINTIFFS COMPLAINT FOR DAMAGES

such agency, partnership, joint venture, employment or alter ego relationship.

every allegation contained in Paragraphs 1 through 12, inclusive.

tangible contributions to AMERICAN APPAREL in the areas of product design, retail

recognition for the apparel company.

PLAINTIFFS COMPLAINT FOR DAMAGES

contributions to the company.

Exactly one weekfollowing the ousting ofFormer CEO Dov Charney,

Alonzo was terminated without severance or cause.

officially terminated as CEO of AMERICAN APPAREL.

ALONZO, Ill have to think about how I feel about that.

PLAINTIFFS COMPLAINT FOR DAMAGES

loan in the amount of $30,000.00 from Mr. Charney in order to survive.

return to American Apparel to restore the company brand.

Senior Creative Director as soon as possible. Additionally, recognizing ALONZOS advertising

companys falling online sales.

ALONZO agreed to return to the company as AMERICAN APPARELS Senior Creative

termination would be paid to her including taxes by AMERICAN APPAREL

shares and 53,333 shares, respectively, plus taxes); and

the year prior, by the end of the 2014 fiscal calendar.

about January 5, 2015.

PLAINTIFFS COMPLAINT FOR DAMAGES

but were not limited to, the following:

Creating and managing DEFENDANTS first-ever marketing budget which totaled

Reestablishing communication channels between various creative departments in an

growth rate by December 31, 2014.

PLAINTIFFS COMPLAINT FOR DAMAGES

Defendantsfail to compensate Alonzo as promised and instead continue to delay