FELEI Superior Court of California EUGENE SHVETSKY, Esq. (#301075) County of Los Angeles Law Of?ce of Eugene A. Shvetsky - I 25422 Trabuco Road, Suite 105-314 JUN 8 21117 Lake Forest, CA 92630 Sh Telephone: (657) 3 40- 5 46 5 Byam i. garter, E?gutive Officer/Clerk Deputy Attorney for Plaintiff MILES BERNAL Ma Moran SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES 7 ,2 11;: 8.11.: 8le it; if? MILES BERNAL 8 Case No: 3 166721e4 COMPLAINT: "2 Plaintiff, 1. Failure to Pay Wages (including Labor Code 201, 202 203, 204, 210, 218, 218.5, 218.6, 558,1194,1199) Vs. . Failure to Provide Rest Periods and Meal Periods or Compensation in Lieu Thereof (including Labor Code 226.7, 512; IWC Order(s); Cal Code Regs: Title 8, 11040) OCEAN VIEW DRIVE, IA .IIA YUETING dba OCEAN VIEW DRIVE, DENG CHAOYIN DENG CHAOYING dba OCEAN VIEW DRIVE, DENG DENG WEI dba OCEAN VIEW DRIVE, and Does 1-50, inclusive OJ . Failure to Pay Wages or Provide Employee Records to Terminated Employee (including Labor Code 201-203, 432, 1198.5, 1199) A . Intentional Failure to Comply with Itemized Employee Wage Statement Provisions (including Labor Code 226) VI . Private Attorney General Act Ch . Wrongful Discharge in Violation of Public Policy Defendants x) . Breach of Contract 00 . Conversion FOR RL A1113 0 Judge \0 . Violations of the Cal. Business Code (including? 17200? 17208) 10. Violations of California Department. OfFair 53:; Employment and Housing Act (1nclud1ng ??12940) Date Complaint Filed: 151:; i" 1:23 Assigned for all purposes to the Hon. Judge Dept: 11: 1i DEMAND EXCEEDS $25,000.00 BUT LESS THAN $5,000,000.00 COMPLAINT -HUJnAjanggLCOMPLAINT Plaintiff MILES BERNAL hereby alleges as follows: PARTIES 1. Plaintiff Miles Bernal (?Bernal?) is and at all times herein mentioned was an individual residing in the County of Los Angeles, State of California. 2 Defendant Ocean View Drive, Inc. has its principal place of business in Rancho Palos Verdes, California. The principal place of business is located at 7 Marguerite Drive, Rancho Palos Verdes, CA 90275. Attached as ?Exhibit is the registration with the Secretary of State. 3. Defendant Ocean View Drive is licensed in California as a corporation, identi?ed by corporation number C370478 1 within the City of Rancho Palos Verdes. 4. Defendant Deng Chaoying is a resident of Gardena, California, and was at all times mentioned herein an individual residing in the County of Los Angeles, California. 5. Defendant Deng Wei is a resident of Rancho Palos Verdes, and was at all times mentioned herein an individual residing in the County of Los Angeles, California. 6. Defendant Jia Yueting, on information and belief, is a resident of Rancho Palos Verdes, and was at all times mentioned herein an individual residing in the County of Los Angeles,? Califomia. 7. Defendants Deng Chaoying dba Ocean View Drive, Inc., Deng Wei dba Ocean View Drive, Inc., and Jia Yueting dba Ocean View Drive, Inc., are individuals operating Ocean View Drive, Inc. as owners. 8. Defendants are collectively referenced herein as ?Defendants.? 9. Defendants are in the business of purchasing real estate property, upgrading said property, providing guest lodging, and hosting social events on such property. Defendants also provide exterior property maintenance, repair, landscaping, exterior and interior design for the purchased properties. . 10. Within the three months preceding Plaintiffs termination, Defendants, and each of them, consistently failed to pay wages due to Plaintiff pursuant to California state wage and hour laws. 2 COMPLAINT 11. During the LIABILITY PERIOD, Defendants, and each of them, had a consistent policy of unlawfully deducting amounts from non-exempt employee?s wages. Defendants also maintained a consistent policy of failing to indemnify employee for necessary and conditional losses. 12. During the LIABILITY PERIOD, Defendants, and each of them, had a consistent policy of unlaw?illy failing to provide rest periods and meal periods, or compensation in lieu thereof, in violation of California state labor and wage laws (including, but not limited to, California Labor Code 226.7, 512, IWC Wage Order(s), Cal. Code Regs, Title 8, 11040). During the LIABILITY PERIOD, the Defendants maintained a consistent policy of failing to provide Plaintiff with rest periods of at least ten (10) minutes per four (4) hours of work or major fraction thereof, and failed to pay Plaintiff one (1) hour of pay at Plaintiff?s regular rate of compensation for each workday the rest period is not provided. When meal breaks were provided, Plaintiff was instructed as to what non?work activities he was permitted to do or where he could go, and remained under Defendants? control despite without compensation. l3. Defendants? failed to pay wages to terminated Plaintiff, in violation of California wage and labor law (including Labor Code 201?203, 204, 210, 225.5, and 1199). Defendants? further failed to provide Plaintiff?s wage documentation and employee ?le upon request. 14. During the LIABILITY PERIOD, Defendants?, and each of them, have had a consistent policy of unlawfully failing to comply with California wage and labor law in regards to employee time sheet documentation (including, but not limited to, Labor Code 226, 1174, 1175). This unlawful conduct included the intentional and willful denial to provide Employee time cards and wage documentation. 15. During the LIABILITY PERIOD, Defendants? and each of them, have had a consistent policy of failing to compensate Plaintiff for travel time and travel expenses in violation of California wage and labor law (including Industrial Welfare Commission Wage Order No 14- 80,Cal. Code Regs, Title 8, 11140). 16. Plaintiff was unlawfully terminated on or about November 1, 2015. 17. The above?described allegations, in addition to the statutory penalties proscribed by 3 COMPLAINT Ln. ware? @00le law, also constitute a breach of contract between Plaintiff and each Defendant. 18. The above-described allegations, in addition to the statutory penalties proscribed by law, establish that Defendants, and each of them, wrongfully converted property and/or monies rightfully belonging to Plaintiff and/or similarly situated staff members. 19. Plaintiff brings this action pursuant to Labor Code sections 204, 210, 2116, 218.5, 218.6, 221, 225.5, 1194, 1199, and 2802 along with any other appropriate California authority and seeks unpaid wages, penalties, injunctive and other equitable relief, and reasonable attorneys' fees and costs, in addition to any other penalties available by law. Pursuant to Business and Professions section 17200-17208, Plaintiff also seeks injunctive relief, restitution, and disgorgement of all bene?ts Defendants? enjoyed from their failure to pay lawfully due wages. 20. The aggregate of all damages and relief sought is in excess of twenty-five thousand dollars. II. VENUE AND JURISDICTION 21. Plaintiff hereby incorporates paragraphs 1-20, above, as though set forth in full herein. 22. Venue and jurisdiction as to each Defendant are proper in this judicial district, pursuant to Code of Civil Procedure section 395. 23. The true names and capacities, whether individual, corporate, associate, or otherwise, of defendants sued herein as DOES 1-100, inclusive, are currently unknown to Plaintiff, who therefore sue by such ?ctitious names under Code of Civil Procedure section 474. Plaintiff is informed and believes, and based thereon alleges, that each of the defendants designated herein as a DOE is legally responsible in some manner for the unlawful acts referenced herein. 24. Plaintiff will seek leave of Court to amend this Complaint to re?ect the true names and capacities of the defendants designated hereinafter as DOES when such identities become known. 25. Plaintiff is informed and believes, and based thereon alleges, that each defendant acted in all respects pertinent to this action as the agent of the other defendants, carried out a joint 4 COMPLAINT rer- L9 210scheme, business plan, or policy in all respects pertinent to the misfeasance alleged herein, and the acts of each defendant are legally attributable to the other defendants. GENERAL ALLEGATIONS 26. Plaintiff hereby incorporates paragraphs 1-25, above, as though set forth in full herein. 27. Plaintiff is informed and believes, and thereon alleges, that Defendants Deng Chaoying, Deng Wei, and Jia Yueting dominated the executive decision-making and ?nancial arrangements of Ocean View Drive, Inc. A unity of interest and ownership existed at all relevant times such that the separate identities of the corporation and the individuals no longer existed, to the extent that if the acts of Deng Chaoying, Deng Wei, and ia Yueting were treated as the acts of the corporation alone this would promote and lead to an inequitable and unjust result. 28. Plaintiff is informed and believes, and thereon alleges, that defendants Deng Chaoying, Deng Wei, and Jia Yueting: Comrningled funds and treated company assets as their own, including but not limited to the personal use of the company vehicles and corporate funds; Used of?ce or business locations and employees for both corporate and personal functions; (0) Used Ocean View Drive, Inc. to engage in illegal and improper activities, including the wrongful employment practices described herein; Disregarded legal formalities, including but not limited to: keeping corporate minutes and maintaining separate corporate records; Diverted assets to themselves while maintaining liability in Ocean View Drive, Inc.; Deliberately under-funded Ocean View Drive, Inc. Held themselves personally responsible and were parties to the contracts entered into by Ocean View Drive, Inc. 29. Plaintiff alleges that defendants, and each of them, maintained illegal and/or 5 COMPLAINT improper workplace policies during the LIABILITY PERIOD. Plaintiff was subjected to the improper, illegal, or otherwise wrongful workplace policies. 30. Defendants maintained a consistent policy of failing to pay wages for hours worked due to being misclassifled as an ?exempt? employee. 31. Plaintiff, at all relevant times pertinent hereto, was a non-exempt employee within the meaning of the California Labor Code and within the scope of the rules and regulations of the IWC California Wage Orders. Plaintiff is a non?exempt employee as he: Did not manage an enterprise or a customarily recognized department or subdivision; Did not regularly direct the work of two or more subordinate employees, and did not spend 50% or more of his time supervising or directing any employees; (0) Did not have authority to hire, ?re, set pay scales; Did not discipline employees; At all relevant times, the arrangement was "at-will" 32. During the LIABILITY PERIOD, Plaintiff worked for the defendants, and each of them, and was paid a ?at rate. 33. Defendants are, and at all relevant times were, aware that they were not in compliance with California law. 34. Defendants? unlawful practices constitute a breach of their duties to Plaintiff and were deliberate and in callous disregard of Plaintiff?s rights. 35. Defendants? consistent policy of failing to my legal wages was willful and intentional. Defendants? maintained a workplace policy of failing to compensate employees for hours worked. i 36. Defendants also failed to provide reimbursement for expenses accumulated during Plaintiff?s tenure. Ill 6 COMPLAINT FIRST ACTION FAILURE TO PAY WAGES As Against all Defendants 37. Plaintiff hereby incorporates paragraphs 1-3 6, above, as though set forth in full herein. 38. During the LIABILITY PERIOD, defendants, and each of them, consistently failed to pay wages due to Plaintiff. Plaintiff did not receive wages in compliance with California state wage and hour laws, (including Lab. Code sections 204, 210, 211, 216, 218.5, 218.6, 221, 225.5, 1194, 1199, 2802). Statutory damages are available to Plaintiff. 39. Despite knowing that their conduct was unlawful, defendants, and each of them, acted willfully, maliciously, and oppressively to under?compensate Plaintiff for time worked. Furthermore, each Defendant rati?ed, authorized, or was aware of the unlawful conduct of each other defendant, such that an award of exemplary/punitive damages is warranted. As a result of the unlawful acts of defendants, and each of them, Plaintiff seeks wages in amounts to be determined at trial, and are entitled to recovery of such amounts, plus interest and penalties thereon as available, attorney? fees, and costs, pursuant to the California Labor Code and other relevant provisions of California law. v. SECOND CAUSE OF ACTION FAILURE TO PROVIDE REST PERIODS AND MEAL PERIODS OR COMPENSATION IN LIEU THEREOF As Against all Defendants 40. Plaintiff hereby incorporates paragraphs 1-39, above, as though set forth in full herein. 41. During the LIABILITY PERIOD, Defendants, and each of them, have had a consistent policy of unlawfully failing to provide to Plaintiff rest periods and meal periods, or compensation in lieu thereof, in violation of California state labor and wage laws (including, but not limited to, California Lab. Code sections 226.7, 512, IWC Wage Order(s), Cal. Code Regs, Title 8, section 11040). 42. During the LIABILITY PERIOD the Defendants maintained a consistent policy of 7 COMPLAINT failing to provide Plaintiff rest periods of at least ten (10) minutes per four (4) hours worked or major fraction thereof, and failed to pay Plaintiff one (1) hour of pay at Plaintiff?s regular rate of compensation for each workday the rest period is not provided. 43. Despite knowing that their conduct was unlawful, Defendants, and each of them, acted willfully, maliciously, and oppressively. Furthermore, each Defendant rati?ed, authorized, or was aware of the unlawful conduct of each other defendant, such that an award of exemplary/punitive damages is warranted. As a result of the unlawful acts of Defendants, Plaintiff seeks wages in amounts to be determined at trial, and is entitled to recovery of such amounts, plus interest and penalties thereon as available, attorney? fees, and costs, pursuant to the California Lm Code and other relevant provisions of California law. THIRD OF ACTION FAILURE TO PAY WAGES OR PROVIDE EMPLOYEE RECORDS TO TERMNATED EMPLOYEE As Against all Defendants 44. Plaintiff hereby incorporates paragraphs 1?43, above, as though set forth in full herein. 45. Upon Defendants? termination of Plaintiff?s employment all wages earned and unpaid were due and payable within seventy?two (72) hours of termination of employment. Defendants failed to make such payment upon Plaintiffs? termination of employment, in violation of California wage and labor laws (including Lab. Code sections 201-203, 1199). Plaintiff did not receive all wages to which he was entitled. 46. Upon Plaintiff 5 request to inspect or copy records, Defendants were required to provide such records no later than 21 calendar days from the date of the request. Plaintiff requested such records on or around December 15, 2016 via regular mail, and Defendants have failed to comply with said request. Plaintiff?s request for records and con?rmation of receipt is attached as "Exhibit 47. Despite knowing that their conduct was unlawful, Defendants, and each of them, acted willfully, maliciously, and oppressively. Furthermore, each Defendant ratified, authorized, or 8 COMPLAINT was aware of the unlawful conduct of each other Defendant, such that an award of exemplary/punitive damages is warranted. As a result of the unlawful acts of Defendants, Plaintiff seeks unpaid wages in an amount to be determined at trial, and is entitled to the recovery of such amount, plus interest and penalties thereon as available, attorney fees, and costs, pursuant to .the California Labor Code and other relevant provisions of California law. Pursuant to Lab. Code section 203, Plaintiff is entitled to up to thirty (30) days of wages for each day that Defendants, and each of them, failed to timely pay wages due. VII. FOURTH CAUSE OF ACTION INTENTIONAL FAILURE TO COMPLY WITH ITEMIZED EMPLOYEE WAGE STATEMENT PROVISIONS As Against all Defendants 48.4 Plaintiff hereby incorporates paragraphs 1?47, above, as fully set forth herein. 49. During the LIABILITY PERIOD, Defendants, and each of them, have had a consistent policy of failing to provide, or at the time of payment of wages, an accurate itemized statement in writing showing: Gross wages earned; Total hours worked by the employee; (0) All deductions; Net wages earned; The inclusive dates of the period for which the employee is paid. 50. Despite knowing that their conduct was unlawful, Defendants, and each of them, acted willfully, maliciously, and oppressively to deny Plaintiff with itemized wage statements. Furthennore, each Defendant rati?ed, authorized, or was aware of the unlawful conduct of each other defendant, such that an award of exemplary/punitive damages is warranted. As a result of the unlawful acts of Defendant, Plaintiff seeks wages in an amount to be determined at trial, and is entitled to recovery of such amounts, plus interest and penalties thereon as available, attorneys? fees, and costs, pursuant to California Labor Code and other relevant provisions of California law. mi 9 COMPLAINT FIFTH ACTION PRIVATE ATTORNEY GENERAL ACT As Against all Defendants 51. Plaintiff hereby incorporates paragraphs 1-50 as though fully set forth herein. 52. Defendants have committed several Labor Code violations against Plaintiff and similarly situated employees. 53. Plaintiff, as an ?aggrieved employee,? within the meaning of Labor Code section 2698, et seq., acting on behalf of himself and other similarly aggrieved employees, bring this representative action against Defendants to recover the civil penalties due to Plaintiff and members of the Plaintiff Class. These damages are sought according to proof pursuant to Labor Code section 2699(a) and including but not limited to $100.00 for each initial violation and $200.00 for each subsequent violation per employee per pay period for Labor Code violations, including but not limited to Labor Code 204 and 1194. Plaintiff seeks damages on behalf of himself and on behalf of other employees forthe conduct of Defendants set forth herein. 54. On or about February 22, 2017, Plaintiff noti?ed Defendants Ocean View Drive, Inc., ia Yueting, Chaoying Deng and Deng Wei, and the California Labor and Workforce Development Agency via certi?ed mail, of Defendants? violations of provisions of the California Labor Code as set forth herein. These letters and con?rmation of receipt are attached as "Exhibit Plaintiff informed Defendants and the LWDA that he intended to bring a claim for civil penalties under Labor Code section 2698, et seq. Plaintiff will have exhausted Plaintiff?s pre??ling requirements under Labor Code section 2698, et seq. as of the time of the ?ling of this Complaint. 55. Plaintiff was compelled to retain the services of counsel to ?le this court action to protect his interests and that of other employees, and to assess and collect the civil penalties owed by Defendants. Plaintiff has incurred attorneys? fees and costs which he is entitled to recover under Labor Code section 2699. 10 COMPLAINT \icncn SIXTH ACTION WRONGFUL DISCHARGE IN VIOLATION OF PUBLIC POLICY As Against all Defendants 56. Plaintiff hereby incorporates paragraphs 1-55 as though fully set forth herein. 57. Plaintiff?s employment was terminated, invviolation of fundamental public policies of the State of California, with respect to retaliation for reporting to of Defendants the labor and wage violations alleged herein. 58. Plaintiff?s termination was wrongful and in violation of the fundamental principles of the public policy of the State of California as re?ected in its law, objective, and policies. The conduct that violated said policies is stated in this Complaint. 59. Among the statutory and judicial public policy violated by Defendants? conduct are California Code of Civil Procedure section 527.8, Labor Code section 6400 et seq, and Labor Code section 6310. 60. As a result of said employment relationship, Defendants were obligated to restrain from discharging Plaintiff, or any other employee, for reasons which violate or circumvent said poliCy, law, or the objectives which underlie each and not to compound their illegal conduct by retaliating against Plaintiff. 61. As a direct and foreseeable result of the aforementioned acts of Defendants and/or their agents, Plaintiff lost and will continue to lose income in an amount to be proven at trial. Plaintiff has also incurred attorney fees. Plaintiff claims such amount as damages together with pre- judgment interest pursuant to Civil Code section 3287 and/or any other applicable provision of the law. X. SEVENTH CAUSE OF ACTION BREACH OF CONTRACT As Against all Defendants 62. Plaintiff hereby incorporates paragraphs 1?61 as though set forth in full herein. 63. Plaintiff and defendants entered into a contract whereby Plaintiff agreed to perform duties as a Club House Business Manager for Defendants. ll COMPLAINT 64. Plaintiff complied with all conditions precedent and the conditions for performance upon defendants occurred. 65. Defendants materially failed to comply with the terms of the contract, including a breach of the covenant of good faith and fair dealing. 66. As a proximate result of Defendant's material breaches of the contract, Plaintiff sustained damages. XI. EIGHTH CAUSE OF ACTION CONVERSION As Against all Defendants 67. Plaintiff hereby incorporates paragraphs 1?66 as though set forth herein. 68. Plaintiff has been denied monies to which he is entitled, owed, or has a right to possess, due to Defendants? wrongful withholding of earned wages. 69. The Defendant?s aforementioned conduct constitutes a willful, intentional, and malicious and oppressive attempt to avoid transferring such monies to Plaintiff such that an award of general, special, and punitive/exemplary damages is warranted. XII. NINTH CAUSE OF ACTION VIOLATIONS OF CALIFORNIA BUSINESS PROFESSIONS CODE (17200-17208) As Against all Defendants 70. Plaintiff hereby incorporates paragraphs 1?69, above, as though set forth in full herein. 71. The above?described violations of California law, including but not limited to the failure to comply with the speci?ed statutes, constitute one or more unlawful practices and activities as de?ned by Business and Professions Code section 17200, et seq. 72. The actions of defendants, as alleged within this Complaint, constitute false, fraudulent, unlawful, unfair, and deceptive business practices within the meaning of Business and Professions Code section 17200, et seq. 12 COMPLAINT result of their unlawful acts, defendants have reaped, and continue to reap, unfair benefits and unlawful pro?ts. Defendants should be enjoined from this activity and made to disgorge these ill-gotten gains to plaintiff. 74. As a direct and proximate result of the unfair business practices of defendants, Plaintiff is entitled to equitable and injunctive relief, including full restitution and disgorgement of all wages which have been unlawfully withheld from Plaintiff. 75. The unlawful conduct alleged herein is continuing, and there is no indication that defendants will not continue such activity into the future. 76. Plaintiff ?thher request that the Court issue a preliminary and permanent injunction as necessary. TENTH CAUSE OF ACTION VIOLATIONS OF CALIFORNIA DEPARTMENT OF FAIR EMPLOYMENT AND HOUSING ACT (INCLUDING 12940) As Against all Defendants 77. Plaintiff hereby incorporates paragraphs 1-76 as though ?illy set forth herein. 78. Under California Fair Employment and Housing Act, Gov. Code ?12940(a), it is an unlawful employment practice for an employer to discharge an employee due to Ancestry or National Origin. 79. Defendant Ocean View Drive, Inc. is a private employer subject to suit under the California Fair Employment and Housing Act (FEHA) (Gov. Code 12900 et. Seq.). - 80. On or around October 28, 2016, Defendant Ocean View Drive, Inc. wrongfully terminated Plaintiff based on discrimination and retaliation due to Ancestry and National Origin, including language use restrictions. 81. Plaintiff?s termination based on Ancestry and National Origin was wrongful and against California law and public policy. 82. Plaintiff has ful?lled the notice requirements of the Department of Fair Employment and Housing in accordance with Code 12960 and 12962. Plaintiff was issued a ?right to sue? letter on or around January 20, 2017. This letter is attached as "Exhibit 3 COMPLAINT ?XIV. PRAYER Wherefore, Plaintiff prays as follows: 1. 10. 11. 12. For compensatory damages in an amount according to proof with interest thereon; For economic and/or special damages in an amount according to proof with interest thereon; For premium pay and penalties pursuant to the applicable provisions of the California Labor Code; For premium wages pursuant to the Califo?mia Labor Code; For punitive/exemplary damages; For attorneys? fees, interest on wages and penalties as available by law, and cost of suit; That DEFENDANTS be found to have engaged in unfair competition in violation of section 17200 of the California Business and Professions Code; That DEF ENDANTS be ordered and enjoined to make restitution due to their unfair competition, including disgorgement of wrong?illy- obtained . revenues, earnings, pro?ts, compensation, and bene?ts, pursuant to California Business and Professions Code sections 17200, et seq.; For such other and further relief as the Court deems just and improper, including the imposition of injunctive relief upon DEFENDANTS. Prejudgment interest on all due and unpaid wages (Labor Code section 218.6 and Civil Code sections 3287 and 3289); For general damages; Interest on compensatory damages at the legal rate from the date of injury or pursuant to Code of Civil Procedure section 3291; 14 COMPLAINT DATED: 06/02/2017 LAW OFFICE OF EUGENE A. SHVETSKY EUGENE Attorney for Plaintiff BY: 15 COMPLAINT EXHIBIT A EXHIBIT A In (A Passer->1? State of California 3 Secretary of State Statement of Information FC36648 (Domestic Stock and Agricultural Cooperative Corporations) FEES (Filing and Disclosure): $25.00. - If this is an amendment, see instructions. Fl IMPORTANT READ INSTRUCTIONS BEFORE COMPLETING THIS FORM In the of?ce of the Secretary of State 1. CORPORATE NAME of the State of California OCEAN VIEW DRIVE, INC. MAR-04 2016 2. CALIFORNIA CORPORATE NUMBER i C3704781 This Space for Filing Use Only No ChangeiStatement (Not applicable if agent address of record is a P.O. Box address. See instructions.) 3' If there have been any changes to the information contained in the last Statement of Information filed with the California Secretary of State' 'or no statement of information has been previously filed. this form must be completed in its entirety. If there has been no change in any of the information contained in the last Statement of Information ?led with the California Secretary of State, check the box and proceed to Item 17. Complete A'ddresses for the Following (DO not abbreviate the name Of the city. Items 4 and 5 cannot be P.0. Boxes.) 4. STREET ADDRESS OF PRINCIPAL EXECUTIVE OFFICE CITY STATE ZIP CODE 7 MARGUERITE DRIVE, RANCHO PALOS VERDES, CA 90275 5. STREET ADDRESS OF PRINCIPAL BUSINESS OFFICE IN CALIFORNIA. IF ANY CITY STATE ZIP CODE 7 MARGUERITE DRIVE, RANCHO PALOS VERDES, CA 90275 a. MAILING ADDRESS OF CORPORATION. IF DIFFERENT THAN ITEM 4 CITY STATE ZIP CODE Names and Complete Addresses of the Following Officers (The corporation must list these three of?cers. A comparable title for the Speci?c of?cer may be added; however, the preprinted titles on this form must not be altered.) 7. CHIEF EXECUTIVE ADDRESS CITY STATE ZIP CODE YUETING JIA 7 MARGUERITE DRIVE, RANCHO PALOS VERDES, CA 90275 a. SECRETARY ADDRESS CITY STATE ZIP CODE CHAOYING DENG 7 MARGUERITE DRIVE, RANCHO PALOS VERDES, CA 90275 9. CHIEF FINANCIAL ADDRESS CITY STATE ZIP CODE CHAOYING DENG 7 MARGUERITE DRIVE, FIANCHO PALOS VERDES, CA 90275 Names and Complete Addresses of All Directors, Including Directors Who are Also Officers (The corporation must have at least one director. Attach additional pages, if necessary.) I 10. NAME . ADDRESS CITY STATE ZIP CODE CHAOYING DENG 18455 FIGUEROA ST, GARDENA, CA 90243 11. NAME . ADDRESS CITY STATE ZIP CODE WEI DENG 7 MARGUERITE DRIVE, RANCHO PALOS VERDES, CA 90275 12. NAME ADDRESS CITY STATE ZIP CODE 13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS. IF ANY: Agent for Service of Process If the agent is an individual. the agent must reside in California and Item 15 must be completed with a California street address, a PD. Box address is not acceptable. If the agent ls another corporation, the agent must have on ?le with the California Secretary of State a certi?cate pursuant to California Corporations Code section 1505 and Item 15 must be left blank. 14. NAME OF FOR SERVICE OF PROCESS is Viz-1,- Rain-.5 Ire:"gzg. 31-.1- .iE. -. are . CHAOYING DENG - 15. STREET ADDRESS OF AGENT FOR SERVICE OF-PROCESS IN CALIFORNIA. IF AN INDIVIDUAL CITY STATE ZIP CODE 7 MARGUERITE DRIVE, RANCHO PALOS VERDES, CA 90275 Type of Business 15. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION CORPORATE . 17. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE. THE CORPORATION CERTIFIES THE INFORMATION CONTAINED HEREIN. INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT. 03/04/2016 MEGHA GORE PAYROLL MANAGER DATE TYPEIPRINT NAME OF PERSON COMPLETING FORM TITLE SIGNATURE SI-200 (REV 0112013) Page 1 Of 1 APPROVED BY SECRETARY OF STATE EXHIBIT EXHIBIT UPS: Tracking Proof of Delivery 0113,53 Dear Customer. notice serves as praaf of daltvary for rm:- shipment {Israd below. Tracking Number: 123F1V960171291 [103 Service: UPS Next Day AEND Weight .10 [b On: 131412016 Delivered On: 13152016 10:03 AM. Delivered To: PALOS VERDES PENINSULA. CA. US Left At: Other - released Thank you for glving us :his serve you. Since-yew. UPS results provided by 0511212017 .109 PM. ET EXHIBIT EXHIBIT Tracking umber: 70163010000040328513 Delivered Product Tracking Information See Available Actions Postal Product: Features: Ceni?ed Mair" iffxianTlME'? W. ii'EM I - Ltm?ilC-N February 21, 201 T, 1:47. pm Delivered, Le? with Individual SACRAMENTO, CA 95814 February21, 2017, 6:21 am In Transit lo Destination February 20, 2017, 5:36 am Departed USPS Facility WEST SACRAMENTO, CA 95799 February 19, 2017, 7:50 pm in Transil io Desiinalion Tracking Number: 70163010000040328520 Delivered Product Tracking Information See Avaiiable Actions Postal Product: Features: Certi?ed Mail" mama "lug. emu: [ram Lemar. February 22. 2017. 10:57 am Delivered, Left with Individual RAMCHO VERDES. CA 90275 Cir-arm's. February 22. 2017. 9:22 am In Transit to Desiinatlon February 21. 20i 7, 9:22 am Arrived at USPS LOS ANGELES, CA 90052 February 13. 2017, 6:58 am In Transit to Desllnallon EXHIBIT EXHIBIT llau?wwug'w?? if? ?13? 7747' - luau- {v all. DEPARTMENT OF FAIR EMPLOYMENT HOUSING ?ll-Kg: 431%; 2213 Kausen Drive. Suite 100 I Elk Grove CAI 95753 300-700-2320 . email: contact.center@dleh.ca.gov January 20. 2017 Miles Bernal . California RE: 'Notice of Case Closure and Right to Sue DFEH Matter Number: 849889-271514 Right to Sue: Berna] I Chaoying Deng Ocean View Drive. Inc Dear Miles Bernal. This letter informs you that the above-referenced complaint was filed with the Department of Fair Employment and Housing (DFEH) has been closed effective January 20. 2017 because an immediate Right to Sue notice was requested. DFEH will take no further action on the complaint. This letter is also your Right to Sue notice. According to Government Code section 12965. subdivision a civil action may be brought under the provisions of the Fair Employment and Housing Act against the person. employer. labor organization or employment agency named in the above-referenced complaint. The civil action must be filed within one year from the date of this letter. To obtain a federal Right to Sue notice, you must visit the U5. Equal Employment Opportunity Commission (EEOC) to file a complaint within 30 days of receipt of this DFEH Notice of Case Closure or within 300 days of the alleged discriminatory act. whichever is earlier. Sincerely. Department of Fair Employment and Housing