Tyler Kem v. Strike Advisory, LLC

I. INTRODUCTION

On July 17, 2023, plaintiff Tyler Kem (“Kem”) filed an action against Defendants Strike Advisory, LLC, Ventive, LLC, Jonathan Cardella, and Does 1-50 in the Superior Court of California for the County of Ventura. Dkt. 1. Plaintiff brings claims for (1) breach of contract; (2) breach of the implied covenant of good faith and fair dealing: (3) unjust enrichment; (4) unfair competition in violation of Business and Professions Code §§ 17200 Et Seq.: (5) retaliation in violation of Labor Code § 1102.5; (6) violation of Labor Code § 98.6 regarding retaliation; (7) wrongful termination in violation of public policy; (8) defamation per se; (9) failure to provide written commission agreement in violation of Labor Code § 2751: (10) failure to timely pay earned commissions in violation of Labor Code § 204: and (11) failure to timely pay final wages upon termination of employment and waiting penalties due to willful delay. Dkt. 1-2 (“Compl.”) 41-165. On September 8, 2023, defendants removed the case to this court based on diversity jurisdiction. Dkt. 1. On September 15, 2023, defendants filed this motion to transfer the case to Idaho. Dkt. 9 (“MTT”). On…