On August 4, 2026, the Honorable Carolyn B. Kuhl of the Los Angeles Superior Court dismissed the class and representative PAGA claims in Wang v. Yuejie Inc., et al. (Case No. 25STCV01728), a putative wage-and-hour class action against LTL client Yuejie Inc., a California logistics company. The dismissal followed the court’s March 26, 2026 ruling denying a motion by the named plaintiff’s former lawyers for precertification discovery – an order that would have required Yuejie to release its employees’ names and contact information, through a third-party administrator, so that those lawyers could search for a new class representative.
The case was filed in January 2025 as a class and PAGA action in the name of a single former employee. Months later, she discharged her lawyers, began representing herself, and asked the court to remove her from the case, declaring under penalty of perjury that she had retained counsel “solely for an individual wage claim, not a class action nor a PAGA representative action.” Her former lawyers disputed that account and moved for leave to send a Belaire-West opt-out notice to Yuejie’s current and former employees to find someone to take her place.
When a named plaintiff drops out of a putative class action, California courts often allow plaintiff’s counsel to obtain putative class members’ contact information so the case can continue with a substitute representative. But precertification discovery “is not a matter of right,” and the court must weigh the potential for abuse of the class action procedure against the benefits of disclosure. The leading decisions in this area involve named plaintiffs who chose to bring class claims and later settled, turned out to lack standing, or were disqualified. LTL argued that this case was different in kind: the request came from lawyers whose own client had discharged them and disavowed the representative claims filed in her name.
The court agreed that the balance weighed against disclosure. Without resolving the dispute between the plaintiff and her former lawyers, the court concluded that “there exists a risk that an attorney could abuse the class action procedure by improperly filing class and PAGA claims on an employee’s behalf.” Quoting LTL’s opposition, the court explained that former counsel’s position amounted to the principle that “[a]ny attorney in California can file unauthorized class and PAGA claims in a client’s name, use that person as a placeholder, get discharged when the client discovers what happened, and then obtain court-ordered Belaire-West discovery to mine the defendant’s employee records for a willing replacement.” The court noted that former counsel had cited no case granting a former lawyer’s precertification discovery motion in these circumstances, and that it was “at least possible” the case was more akin to one in which “strangers to the litigation” embark on a “fishing expedition” for a class representative after filing suit.
On the other side of the scale, the court found little to gain from disclosure. Unlike the secret call monitoring at issue in CashCall, Inc. v. Superior Court, former counsel had not shown that employees would be unable to discover potential wage-and-hour violations on their own; counsel had not shown a significant investment of work that dismissal would waste; and counsel had not shown that American Pipe tolling would fail to protect putative class members’ claims. The court denied the motion and gave former counsel 90 days to find a new representative through informal efforts, after which any party could seek dismissal of the class allegations.
No substitute representative came forward. After the 90-day period expired, former counsel confirmed that Yuejie should proceed with dismissal, and on August 4 the court dismissed the class claims and the representative PAGA claims without prejudice, leaving only the former employee’s individual claims. Had the motion been granted, Yuejie would have been required to open its workforce to outreach in search of a plaintiff willing to continue a class action its own named plaintiff had disavowed. LTL’s Caleb Liang and Kevin Kelly represent Yuejie Inc.
Court’s Ruling (March 26, 2026)
Court’s Order (August 4, 2026)