**Court Filing Reveals Allegations of Unlawful Retaliation and Wrongful Termination Against Prominent Event Venue**
On September 13, 2024, a complaint was filed by Trent Warren, Amanda Olshever, and Nicole Olshever in the Superior Court of California for Ventura County against Hummingbird Nest, LLC and its managing member Kieu Hoang. The plaintiffs allege multiple violations of California labor laws, including unlawful retaliation, wrongful termination, and failure to pay wages.
The lawsuit details that Hummingbird Nest Ranch in Simi Valley is owned and operated by Kieu Hoang, who purchased the venue in 2015. The plaintiffs were employed in various sales roles at the venue: Nicole Olshever as Director of Sales & Marketing and Deputy General Manager since September 2019; Trent Warren as Director of Sales & Marketing since May 2019; and Amanda Olshever as a Sales Representative since June 2023. Despite their significant contributions to the business, including securing substantial revenue through event bookings, they claim they were subjected to unfair labor practices.
The plaintiffs assert that they were improperly classified as salaried employees exempt from overtime pay. They allege that this misclassification resulted in unpaid overtime work—approximately 20 hours per week for Nicole and 7.5 hours per week for Trent. Furthermore, they contend that they were not provided with proper meal and rest breaks and were often required to remain responsive to clients during these periods.
In a series of communications detailed in the complaint, it is evident that the plaintiffs repeatedly raised concerns about delayed commission payments. For instance, on January 2 and January 15, 2024, Nicole texted Hoang stating "We can’t afford to work and not be paid," while Warren highlighted "Your personal debts do not justify illegally withholding employee pay." Despite these complaints, Hoang allegedly continued to delay payments citing his financial difficulties.
Tensions escalated during a meeting on May 1, 2024, where the plaintiffs confronted Hoang about unpaid commissions amidst his introduction of new staff members intended to assist with sales efforts. The situation deteriorated further when payroll was missed twice in May 2024. By early June 2024, after several unresolved requests for payment documented through emails between June 2-6 (Exhibits D-F), Hoang indicated that their employment would soon end due to financial constraints.
On July 17, 2024, formal termination letters were sent via email by Hoang. Although outstanding commissions were eventually paid upon termination along with severance offers—which the plaintiffs did not accept—the lawsuit claims this sequence of events constitutes unlawful retaliation under Labor Code §§98.6 and §1102.5 for their protected activities of complaining about wage violations.
The plaintiffs seek compensatory economic damages for lost wages (past and future), noneconomic damages for emotional distress caused by wrongful termination under public policy (Tameny Claim), punitive damages for willful misconduct by defendants including civil penalties up to $10k per violation under relevant labor codes along with reasonable attorney fees pursuant various statutory provisions cited within their nine causes action outlined within complaint document filed court records dated September11th represented legal counsel firm Caskey Holzman attorneys Marshall A Caskey Daniel M Holzman N Cory Barari case number identified CU GE03-0623 presiding judge Brenda L Connick