Geodel Shiela Nelson v. Victorias Secret Stores, LLC

I. BACKGROUND

The complaint relates to injuries Nelson sustained while visiting one of Victoria’s Secret’s stores. Dkt. No. 1. Nelson first filed suit on April 27, 2021, but did not serve Victoria’s Secret at that time. Shinder Aff. ¶ 3. Michael Hernandez (“Hernandez”), counsel for Nelson, and Michael Lenkov (“Lenkov”), counsel for Victoria’s Secret, exchanged a number of e- mails related to whether Lenkov would accept service on Victoria’s Secret’s behalf. Dkt. No. 16-2. For example, Hernandez sent Lenkov an e-mail on May 18, 2021, inquiring as to service and attaching the complaint. Id. Hernandez followed up on the same on May 25, 2021, when Lenkov informed Hernandez that he had named an improper party and included an improper claim. Dkt. No. 16-3. The parties also engaged in significant correspondence prior to removal. Lenkov emailed Hernandez, concerning the possibility of a demand on May 30, 2021. Hernandez

CENTRAL DISTRICT OF CALIFORNIA

CIVIL MINUTES - GENERAL

Case No. 5:21-cv-01275-JVS-SHKx Date Sept. 15, 2021 Title Geodel Shiela Nelson v. Victorias Secret Stores, LLC et al $250,000 and that the adjuster offered far less, only $13,000, which…