Shara Hannah v. Paris Henriksen et al

Filing 27

FINAL JUDGMENT BY CONSENT by Judge Jesus G. Bernal. Related to: Stipulation for Judgment 26 . Any of the Defendants failure to fully comply with one or more terms provided for in the Settlement Agreement will result in immediate and irreparable harm to Plaintiff. All matters having been resolved between the Parties, all of Plaintiffs claims against Defendants are dismissed without prejudice. SEE DOCUMENT FOR FURTHER INFORMATION. ( MD JS-6. Case Terminated ) (twdb)

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JS-6

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA, EASTERN DIVISION

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11 SHARA HANNAH, an individual,

Plaintiff,

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Case No. 5:21-CV-00232-JGB-SHKx
FINAL JUDGMENT BY CONSENT

vs.

14 PARIS HENRIKSEN, an individual;

FEEL IT PRODUCTIONS LLC, a

15 California limited liability company;

HENRIKSEN PRODUCTIONS, an
16 entity of unknown form and origin;
HENRIKSEN INDUSTRIES, an entity
17 of unknown form and origin; and DOES
1 through 10, inclusive,
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Defendants.
Trial Date:

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FINAL JUDGMENT BY CONSENT

None

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This Consent Judgment is entered into by and between Plaintiff Shara

2 Hannah (“Plaintiff”), on one hand, and Defendants Paris Henriksen (“Henriksen”),
3 Feel It Productions LLC (“FIP”), Henriksen Productions (“HP”), and Henriksen
4 Industries (“HI”) (collectively, “Defendants”) on the other hand, through their
5 respective counsel of record.
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2.

Plaintiff is an individual residing in Riverside County, California.

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Henriksen is an individual residing in Orange County, California.

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FIP is a limited liability company, organized under the laws of the State

9 of California, with its principal place of business in Los Angeles, California.
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HP is an entity of unknown form and origin with its principal place of

11 business in Los Angeles, California.
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HI is an entity of unknown form and origin with its principal place of

13 business in Los Angeles, California.
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Plaintiff filed her Complaint on February 9, 2021, against Defendants

15 alleging causes of action for: (1) intentional misrepresentation; (2) promissory fraud;
16 (3) negligent misrepresentation; (4) rescission and restitution; (5) breach of written
17 contract; (6) breach of oral contract; (7) breach of the implied covenant of good faith
18 and fair dealing; (8) declaratory relief; (9) breach of employment contract; (10)
19 failure to pay minimum wages in violation of Cal. Labor Code §§ 1194 and 1197;
20 (11) violation of Cal. Labor Code § 1194.2; (12) willful failure to pay wages in
21 violation of Cal. Labor Code §§ 201 and 203; (13) failure to provide itemized wages
22 in violation of Cal. Labor Code §§ 226 and 1174; (14) violation of Cal. Bus. & Prof.
23 Code § 17200; (15) failure to pay out vacation pay at termination in violation of Cal.
24 Labor Code § 227.3; (16) failure to reimburse Plaintiff for expenditures in violation
25 of Cal. Labor Code § 2802; and (17) failure to pay all wages owed in violation of
26 Cal. Labor Code § 210 (the “Litigation” or “Action”). See Docket (“Dkt.”) No. 1,
27 Complaint.
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4658736.1

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FINAL JUDGMENT BY CONSENT

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8.

A First Amended Complaint was subsequently filed in the Action on

2 February 24, 2021 against Defendants alleging the same causes of action in the
3 original. See Dkt. No. 13.
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Plaintiff and Defendants (collectively, the “Parties”) now wish to effect

5 a complete resolution and settlement of all claims, disputes, and controversies
6 relating to the allegations made by Plaintiff against Defendants in the Action and to
7 resolve their differences and disputes by settling this Action for a confidential
8 monetary amount agreed to by the Parties (the “Settlement Amount”) and other
9 terms and conditions as fully set forth in the Settlement Agreement and Mutual
10 General Release executed between the Parties (the “Settlement Agreement”).
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NOW, THEREFORE, IT IS HEREBY ORDERED, ADJUDGED AND

13 DECREED THAT:
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1.

This Court has jurisdiction over the subject matter of this action and

15 over all of the Parties;
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2.

Defendants acknowledge and agree that the agreed-upon Settlement

17 Amount does not precisely reflect the amount of actual monetary damages suffered
18 by Plaintiff in connection with Defendants’ conduct. Accordingly, the Settlement
19 Amount only represents the Parties’ agreement to informally resolve all of the
20 purported controversies, claims, causes of action and disputes, both real and
21 potential, between Plaintiff and Defendants as set forth in the First Amended
22 Complaint to avoid further litigation and consumption of resources attendant
23 thereto. Any of the Defendants’ failure to fully comply with one or more terms
24 provided for in the Settlement Agreement will result in immediate and irreparable
25 harm to Plaintiff. Defendants agree and admit that there is no adequate remedy at
26 law for such failure, and Defendants agree that in the event of such failure,
27 Defendants shall be jointly and severally liable to Plaintiff in the amount of
28 $278,222.52, representing the entire amount alleged in Plaintiff’s First Amended
4658736.1

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FINAL JUDGMENT BY CONSENT

1 Complaint;
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The Settlement Amount shall remain confidential between the Parties

3 and all of their respective parents, subsidiaries and each of their respective owners,
4 officers, directors, partners, representatives, attorneys, predecessors, successors,
5 heirs, and assigns;
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This Court shall retain jurisdiction to construe, enforce, and implement

7 the Settlement Agreement and Final Judgment by Consent; and
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All matters having been resolved between the Parties, all of Plaintiff’s

9 claims against Defendants are dismissed without prejudice.
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IT IS SO ORDERED.

11 DATED: July 13, 2021
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The Honorable Jesus G. Bernal
United States District Judge

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4658736.1

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FINAL JUDGMENT BY CONSENT