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govinfo:USCOURTS-caed-1_26-cv-00315-1

U.S. District Court for the Eastern District of California · 2026-09-30

· GavelSight synced 2026-11-10 16:05:51

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 JOINT STIPULATION TO REMAND ACTION TO STATE COURT; [PROPOSED] ORDER 
 
LAWYERS for JUSTICE, PC 
450 North Brand Boulevard, Suite 900 
Glendale, California 91203 
 
 
Daniel Bass (Cal. State Bar No. 287466)  
 d.bass@calljustice.com  
Brian J. St. John (Cal. State Bar No. 304112)  
 brian@calljustice.com  
LAWYERS for JUSTICE, PC  
450 North Brand Blvd., Suite 900  
Glendale, California 91203  
Telephone: (818) 265-1020 
Facsimile: (818) 265-1021 
  
Attorneys for Plaintiff  
 
Additional Attorneys on Following Page 
  
UNITED STATES DISTRICT COURT  
EASTERN DISTRICT OF CALIFORNIA 
 
MARVELL HILL, individually, and 
on behalf of other members of the 
general public similarly situated ; 
   
                   Plaintiff, 
 
 vs. 
 
TRINITY SERVICES GROUP, 
INC., a 
Florida corporation; KEEFE 
GROUP, LLC, a Missouri limited 
liability company; TKC HOLDINGS, 
INC., an unknown business entity; 
COURTESY PRODUCTS, L.L.C., a 
Missouri limited liability company ; 
and DOES 1 through 100, inclusive,  
 
  Defendants. 
Case No.: 1:26-cv-00315-KES-HBK 
 
Honorable Helena M. Barch-Kuchta 
U.S. Magistrate Judge  
 
[Removed from Fresno Superior Court, 
Case No. 25CECG05247] 
 
 
JOINT STIPULATION TO REMAND 
ACTION TO STATE COURT; ORDER 
 
 
 
Date: September 4, 2026 
 Time: N/A 
 Courtroom: 2 
 
  
 
Complaint Filed: 
 
November 6, 2025 
Trial Date: Not Set 
 
 
Case 1:26-cv-00315-KES-HBK     Document 25     Filed 09/30/26     Page 1 of 5
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1 
 JOINT STIPULATION TO REMAND ACTION TO STATE COURT; [PROPOSED] ORDER 
 
 
LAWYERS for JUSTICE, PC 
450 North Brand Boulevard, Suite 900 
Glendale, California 91203 
 
 
Yvonne Arvanitis-Fossati (Cal. State Bar No. 161764) 
     yvonne.fossati@jacksonlewis.com 
JACKSON LEWIS P.C. 
725 South Figueroa Street, Suite 2500 
Los Angeles, California 90017-5408 
Telephone: (213) 689-0404 
Facsimile: (213) 689-0430 
 
Hazel U. Poei (Cal. State Bar No. 214928) 
     hazel.poei@jacksonlewis.com 
Sheereen Javadizadeh (Cal. State Bar No. 288141) 
     sheereen.javadizadeh@jacksonlewis.com 
JACKSON LEWIS P.C. 
200 Spectrum Center Drive, Suite 500 
Irvine, California 92618 
Telephone: (949) 885-1360 
Facsimile: (949) 885-1380 
  
  
Attorneys for Defendants 
TRINITY SERVICES GROUP, INC., KEEFE GROUP, LLC, 
TKC HOLDINGS, INC., and COURTESY PRODUCTS, L.L.C. 
 
Case 1:26-cv-00315-KES-HBK     Document 25     Filed 09/30/26     Page 2 of 5
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2 
 JOINT STIPULATION TO REMAND ACTION TO STATE COURT; ORDER 
 
 
LAWYERS for JUSTICE, PC 
450 North Brand Boulevard, Suite 900 
Glendale, California 91203 
 
 
JOINT STIPULATION 
IT IS HEREBY STIPULATED , by and between Plaintiff Marvell Hill 
("Plaintiff") and Defendants Trinity Services Group, Inc., Keefe Group, LLC, TKC 
Holdings, Inc., and Courtesy Products, L.L.C. (collectively, "Defendants"), b y and 
through their respective counsel of record, as follows: 
WHEREAS, on November 6, 2026, Plaintiff filed a Class Action Complaint 
for Damages in the Superior Court of California, County of Fresno, alleging wage -
and-hour violations; 
WHEREAS, on January 15, 2026, Defendants removed this action to the 
United States District Court for the Eastern District of California; 
WHEREAS, on February 13, 2026, Plaintiff filed a Motion to Remand 
pursuant to 28 U.S.C. § 1447, which was submitted to the Court without ora l 
argument on April 2, 2026; 
WHEREAS, a related PAGA action, Hill v. Trinity Services Group, Inc., et 
al. (Fresno Superior Court Case No. 26CECG00167), remains pending in state 
court before the Honorable D. Tyler Tharpe; 
WHEREAS, the Parties held a global, private mediation session with well-
regarded mediator Tagore Subramaniam, Esq. on May 1, 2026; 
WHEREAS, following mediation the Parties  reached a class and PAGA 
settlement that, if approved, will resolve the above-captioned action and the related 
PAGA Action in their entirety; 
WHEREAS, on August 14, 2026 the Parties filed a Joint Notice of 
Settlement in the above-captioned action; 
WHEREAS, the Parties are finalizing a long form settlement agreement and 
have stipulated that the appropriate jurisdiction for approval of the settlement in 
this Action is the Superior Court for the State of California, County of Fresno and 
that remand of this action is in the interest of judicial efficiency and cost savings; 
Case 1:26-cv-00315-KES-HBK     Document 25     Filed 09/30/26     Page 3 of 5
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3 
 JOINT STIPULATION TO REMAND ACTION TO STATE COURT; ORDER 
 
 
LAWYERS for JUSTICE, PC 
450 North Brand Boulevard, Suite 900 
Glendale, California 91203 
 
 
WHEREAS, in light of the foregoing, the Parties agree t here is good cause 
to vacate all future dates and deadlines and to remand this action back to the 
Superior Court for the State of California, County of Fresno; 
WHEREAS, it is the Parties’ intention, following remand, to consolidate 
this Action with the PAGA Action and file a Motion for Preliminary Approval 
thereafter; 
THEREFORE, and subject to this Court’s approval, THE PARTIES 
HEREBY STIPULATE that the Action shall be remanded to the Superior Court 
for the State of California, County of Sacramento  rendering the necessity of any 
future dates herein moot. 
 
DATED: September 29, 2026 JACKSON LEWIS P.C. 
 
 
By:  /s/ Hazel U. Poei  (as authorized on           
September 29, 2026)____________              
  YVONNE ARVANITIS-FOSSATI 
HAZEL U. POEI 
SHEEREEN JAVADIZADEH 
 
Attorneys for Defendants 
TRINITY SERVICES GROUP, INC., 
KEEFE GROUP, LLC, TKC 
HOLDINGS, INC., AND COURTESY 
PRODUCTS, L.L.C. 
  
DATED: September 29, 2026 LAWYERS FOR JUSTICE, PC 
 
 
By:  /s/ Daniel Bass                   
DANIEL BASS 
 
Attorneys for Plaintiff 
MARVELL HILL 
Case 1:26-cv-00315-KES-HBK     Document 25     Filed 09/30/26     Page 4 of 5
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4 
 JOINT STIPULATION TO REMAND ACTION TO STATE COURT; ORDER 
 
 
LAWYERS for JUSTICE, PC 
450 North Brand Boulevard, Suite 900 
Glendale, California 91203 
 
 
ORDER 
The Court, having received and reviewed the Parties' Joint Stipulation to 
Remand Action to State Court, and good cause appearing, hereby GRANTS the 
Parties’ joint request and ORDERS the following:  
This action, Eastern District of California Case No.  1:26-cv-00315-KES-
HBK, is hereby the remanded to the Superior Court of California, County of 
Fresno, Case No. 25CECG05247; and  
In the event the Fresno Superior Court does not enter a judgment and order 
granting final approval of the Parties’ settlement and the Parties file a stipulation to 
remove the case again to this Court, the Court shall reopen the current case. 
The Clerk of the Court is directed to terminate any pending motions and 
close this case. 
The Clerk of the Court shall serve a c opy of this order on the Clerk of the 
Superior Court of California, County of Fresno. 
 
 
IT IS SO ORDERED. 
 
 Dated:     September 30, 2026       
     UNITED STATES DISTRICT JUDGE 
 
 
Case 1:26-cv-00315-KES-HBK     Document 25     Filed 09/30/26     Page 5 of 5

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