Howell Management Services v. Vashisht-Rota CA4/1

I.

BACKGROUND

A. Parties and Relationships Howell Management Services, LLC (HMS), is a Utah entity with its principal place of business in Utah. HMS contracts with colleges and universities to recruit mostly international students for enrollment. Its managing member is Christopher N. Howell. Rota is a resident of San Diego County. She was the managing member of August Education Group, LLC (AEG), a California entity that provided consulting services. Beginning in 2015, HMS and AEG entered into a series of four agreements by which AEG agreed to perform services for HMS as an independent contractor. Rota, on behalf of AEG, repudiated the fourth agreement in May 2017. B. Utah Litigation In November 2017, after Rota and AEG made several demands for compensation, HMS sued them in the First Judicial District Court of the State of Utah (the Utah court) for breach of contract. HMS sought a declaration it owed Rota and AEG no money and an injunction to enforce posttermination obligations of the third agreement. Rota filed a complaint against HMS and Howell in the Utah court for unpaid wages and harassment. She filed numerous frivolous motions and papers that contained disrespectful…