Corpus: 543,329 opinions ·
3,179 judges ·
newest 2026-11-02 · expanding
Coverage ↗
Opinion
govinfo:USCOURTS-caed-1_26-cv-00315-1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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