JOHN CHRISTNER TRUCKING, LLC and THREE DIAMOND LEASING, LLC, Defendants. "'[A] party challenging enforcement of a forum selection clause may not base its challenge on choice of law analysis.'" See Atl. Iskanian v. CLS Transp. But after fuel. Case Details Parties Documents Dockets Case Details Case Number: 21-5025 Filing Date: [21-5025] [Entered: 03/11/2021 03:45 PM]. ECF No. Plaintiff and the Class Members are represented by the following attorneys acting as Class Counsel: Carolyn H. CottrellDavid C. LeimbachMichelle S. LimSCHNEIDER WALLACECOTTRELL KONECKY LLP2000 Powell Street, Suite 1400Emeryville, CA 94608Telephone: (800) 689-0024Facsimile: (415) 421-7105ccottrell@schneiderwallace.comDLeimbach@schneiderwallace.commlim@schneiderwallace.com, Robert S. BoulterLAW OFFICES OF ROBERT S. BOULTER1101 Fifth Avenue, Suite 310San Rafael, California 94901Telephone: (415) 233-7100rsb@boulter-law.com. Also, every "owner-operator" completes an orientation at those headquarters. [21-5025] [Entered: 03/11/2021 03:45 PM], Dallas County Texas Courts | Personal Injury | Management. The settlement administrator will total the number of settlement shares for all Class Participants; the resulting sum will be divided into the Net Settlement Amount to reach a per share dollar figure. There are two kinds of personal jurisdiction that a court may exercise over an out-of-state defendant. [21-5025]--[Edited 03/12/2021 by JM PDF removed filed by the court on 3/12/21.] Response date set to 04/14/2021 for Carolyn H. Cottrell. . John Christner Trucking serves customers in the United States and is headquartered in Sapulpa, Oklahoma. ICOA 23. "The proper question is whether the defendant's conduct connects him to the forum in a meaningful way." Manner of Service: email. Driver Resources | John Christner Trucking Driver Resources Welcome JCT Drivers This page is dedicated to keeping you up to date with the latest JCT info. All Rights Reserved. This is an estimate of what your fixed expenses and variable expenses may be. The Court is unpersuaded that transferring this case to the Northern District of Oklahoma would serve to extinguish Huddleston's California state law claims. [21-5025] [Entered: 04/19/2021 04:25 PM], Docket[10822480] Attorney Ms. Michelle S. Lim for Thomas Huddleston admitted to the bar of this court. Because document collection is now mostly an exercise in electronic discovery, the presence of corporate documents in Oklahoma does not weigh heavily in favor of finding that jurisdiction in California would be unreasonable. Arising Out Of Forum-Related Activities. The policies at issue may have their origin in Oklahoma, but JCT's decision to purposefully direct its activities toward California and apply those policies in this forum give rise to specific personal jurisdiction. Levine v. Entrust Grp., Inc., No. See Fed. John Christner Trucking is Seeking Lease Purchase Drivers and Owner Operators Solos Start at to $1.20 per Mile Teams Start at $1.25 per Mile John Christner Trucking Benefits: Solos Starts at to $1.20 per Mile Teams Start at $1.25 per Mile Fuel Surcharge paid on all miles - loaded and empty C 14-01372 LB, 2014 WL 4477349, at *7 (N.D. Cal. Id. ." The general rule is that each plaintiff in a class action must individually satisfy venue, so the venue determination is "based on the plaintiffs in the class actionnot absent class members." JCT has not made a sufficient showing that the exercise of personal jurisdiction is unreasonable. Overall. 2:13-CV-00161-JAM-AC, 2015 WL 1530510, at *3 (E.D. The Court begins its analysis with JCT's challenge to personal jurisdiction. 3:21-CV-01669 | 2021-07-20, Dallas County District Courts | Personal Injury | The Crowley declaration includes as an exhibit a copy of the "Independent Contractor Operating Agreement" ("ICOA") that Huddleston signed. 17-cv-02081-RS ("Huddleston I"), slip op. Cal. [21-5025] [Entered: 03/15/2021 12:22 PM], [10815141] Admissions letter sent. Fill out the form below to receive a free and confidential initial consultation. Id. John Christner Trucking asked the court to deny certification because Huddleston has failed to demonstrate that Californias wage and hour laws apply to him or any other putative class member.. This message tells you what trips have. Huddleston's claims arise out of JCT's forum-related activities, and the second requirement is satisfied. Defendant has agreed to pay $9,250,000.00 to settle this lawsuit (Gross Settlement Amount). Huddleston argues that just as the EEOC was not bound by an agreement to which it was not a party, the PAGA claims here belong to the state of California and therefore fall outside the ambit of the forum-selection clause. OF INTERESTED PARTIES: n. Served on 03/12/2021. ECF No. The Court applies federal law to the interpretation and enforcement of a forum-selection clause. Apr. John Christner Trucking Case Summary On 03/11/2021 Huddleston filed a Labor - Labor Standard lawsuit against John Christner Trucking. (Text Only - No Attachment). "We are impressed with the customized technical . The mediation contact form must be completed and returned to the Mediation Office within four days of the date of this notice. In EEOC v. Waffle House, Inc., 534 U.S. 279 (2002), the Supreme Court held that a governmental agency was not bound by an employee's arbitration agreement such that it was barred from pursuing judicial relief in an enforcement action. at *3-*4 and thus had broader reach than the choice-of-law provision in the ICOA here. OF INTERESTED PARTIES: y. App. 10 ("Opp. A former safety manager for a California company has been sentenced to probation for a conspiracy involving the illegal repair of cargo tanks. 2006)). If you were a lease driver for JCT and/or have questions about the lawsuit, please contact Robert S. Boulter. 2011). 2012 WL 393614, at *1 (emphasis supplied). (internal quotation marks omitted)). Reply at 3. (Text Only - No Attachment) [21-5025] [Entered: 03/25/2021 04:25 PM], [10817929] Acknowledgment of transcript order filed by Thomas Huddleston. 752, et seq. This lawsuit seeks recovery of unpaid wages, statutory damages, civil penalties, restitution, interest, attorneys fees and costs. 12. UniCourt uses cookies to improve your online experience, for more information please see our Privacy Policy. CIVF 07-1321 AWI SMS, 2007 WL 3341389, at *7 (E.D. Mark Schremmer, senior editor, joined Land Line in 2015. When a case concerns enforcement of a forum-selection clause, 1404(a) provides a mechanism for its enforcement and "a proper application of section 1404(a) requires that a forum-selection clause be given controlling weight in all but the most exceptional cases." ECF No. The plaintiff need only make a prima facie showing of jurisdiction to defeat the motion to dismiss, but "may not simply rest on the bare allegations of the complaint." According to court documents, John Christner Trucking is a for-hire motor carrier that provides trucking services nationwide and relies, in part, on drivers who operate trucks leased from its company, Three Diamond Leasing. See, e.g., Brandi v. Belger Cartage Serv., Inc., 842 F. Supp. John Christner Trucking LLC is an active DOT registered motor carrier operating under USDOT Number 273897 and MC Number 192518. A "valid forum-selection clause [should be] given controlling weight in all but the most exceptional cases." 3d at 1206 n.5 (holding that a representative PAGA claim could be litigated in Arizona federal courts); see also id. PAGA cases "function[] as a substitute for an action brought by the government itself." Huddleston has submitted no evidence of court congestion particular to Oklahoma as opposed to California. C. 28 U.S.C. How will the Attorneys for the Class Members be paid? It is thus not Huddleston's personal choice to live in California which drives the jurisdictional analysis, but JCT's choice to dispatch deliveries to and from California which does." Id. Id. at 581-82. [a] forum [selection] clause should control absent a strong showing that it should be set aside." As such, the Class Participants understand and agree that they are providing the Released Parties with a full and complete release with respect to the Released Claims. Huddleston seeks to represent other "owner-operators" in a collective action under the Fair Labor Standards Act ("FLSA") and class actions under California and Oklahoma law. Am., Inc., 485 F.3d 450, 457 (9th Cir. [21-5025] [Entered: 04/27/2021 08:32 AM], Docket[10823665] Minute order filed - Notice due that record is complete by 04/27/2021 for Mark C. McCartt, Clerk of Court (oclk). Co., 417 F.3d at 357. The opinion in Waffle House was fairly narrow and distinguishable from the facts here. [Please open the Notice for important information.] Response date set to 04/14/2021 for Michelle S. Lim. The most common ethnicity at John Christner Trucking is White (66%), followed by Hispanic or Latino (11%) and Black or African American (10%). Served on 03/24/2021. Transcript ordered: Motion Hearing Re: Class Certification 10/24/2019 and Scheduling Conference held 12/9/2020. Id. And the best part of all, documents in their CrowdSourced Library are FREE! My experience working at John Christner Trucking was a good experience. First, the forum-selection clause in Ronlake provided that the agreement "and all issues regarding the rights and obligations of the Members, the construction, enforcement and interpretation hereof . This class action case was initiated by Robert Boulter and co-counsel in 2017 on behalf of driver Thomas Huddleston against Oklahoma based trucking giant John Christner Trucking (JCT) and arises out of its lease purchase (Oklahoma Class Period). Yahoo! The California resident claims he routinely. John Christner Trucking Dec 2010 - Jun 2013 2 years 7 months Invoiced customers for our service, large and small based upon their requests and requirements and on a timely basis. John Christner was great at first and then milege saving came to be the normal no matter the load and route drivers lose 100+ miles per load sometimes as high as 200. Id. Murphy v. Schneider Nat'l, Inc., 362 F.3d 1133, 1140 (9th Cir. Each Class Participant (as described in Section 3) will receive a pro rata share of the Net Settlement Amount based on settlement shares assigned to them as described below. It is well established that the Fourteenth Amendment's Due Process Clause limits the power of a court to exercise jurisdiction over out-of-state defendants who do not consent to jurisdiction. "[U]ncontroverted allegations must be taken as true, and conflicts between parties over statements contained in affidavits must be resolved in the plaintiff's favor." The touchstone for asserting specific jurisdiction over a nonresident defendant is "the relationship among the defendant, the forum, and the litigation." Weekly Settlement Deduction with JCT (John Christner Trucking) 4,877 views Jan 20, 2020 64 Dislike Share Save Trucking with Miss Tee 1.95K subscribers Deduction that will come out of your. The Ninth Circuit has outlined three situations in which enforcement of a forum-selection clause would be unreasonable: "(1) if the inclusion of the clause in the agreement was the product of fraud or overreaching; (2) if the party wishing to repudiate the clause would effectively be deprived of his day in court were the clause enforced; and (3) if enforcement would contravene a strong public policy of the forum in which suit is brought." The 19 causes of action in the lawsuit: Feb. 6, 2012). Public Records Policy. John Christner Trucking, L.L.C. Adjust the GREEN FIELDS below. The general venue statute does not authorize venue in a single district in which the most substantial part of the events or omissions giving rise to the claim occurred. Marine, 134 S. Ct. at 583. CV 05-4928-NM EX, 2006 WL 8074721, at *3 (C.D. The purposeful-direction requirement is satisfied. 410.10 (2004). 2015) (construing similar contract and holding that "while Plaintiffs' misclassification claims 'relate to' the ICOA (and thus trigger the forum-selection clause) they would likely not be governed by Arizona law, as only 'the agreement' itself is governed by such law"). The Supreme Court has commanded that "[i]n the light of present-day commercial realities and expanding international trade[,] . This case was filed in U.S. Courts Of Appeals, U.S. Court Of Appeals, Tenth Circuit. Unless you present convincing evidence proving you worked more workweeks than shown by Defendants records, your Individual Settlement Amount will be determined based on Defendants records. The settlement administrator will determine all Individual Settlement Amounts based on Defendants records of the weeks worked by Class Members. The state of California may have an interest in the outcome of this dispute, but that interest is not so overwhelming or unusual that this should be an exception to the general rule that a valid forum-selection clause should be honored. Docketing statement, transcript order form and notice of appearance due on 03/25/2021 for Thomas Huddleston; notice of appearance due on 03-25-2021 for John Christner Trucking, LLC. Huddleston has submitted an affidavit outlining the "prohibitive" financial hardship associated with litigating this case in Oklahoma, Huddleston Decl. Our . If you fail to keep your address current, you may not receive your Individual Settlement Amount. Defendant is represented by the following attorneys: Christopher J. EckhartAngela S. CashKaren B. ReisingerSCOPELITIS, GARVIN, LIGHT,HANSON & FEARY, P.C.10 West Market Street, Suite 1400Indianapolis, IN 46204Telephone: (317) 637-1777Facsimile: (317) 687-2414, Bobby L. Latham, Jr.James L. ColvinLATHAM WAGNER STEELE LEHMAN1515E. First brief on cross-appeal and appendix due 06/07/2021 for John Christner Trucking, LLC. John Christner Trucking was facing a driver misclassification lawsuit that was granted class action status in Feburary 2020. JCT leases facilities in Phoenix, Arizona, and Oklahoma City, Oklahoma. Gulf Oil Corp. v. Gilbert, 330 U.S. 501, 508 (1947) (superseded on other grounds). See Leroy v. Great W. United Corp., 443 U.S. 173, 180 (1979) ("The question of personal jurisdiction, which goes to the court's power to exercise control over the parties, is typically decided in advance of venue, which is primarily a matter of choosing a convenient forum."). The lawsuit was filed in 2017. Federal judges approved separate class certifications for divers in Oklahoma and California. 5:22-CV-00848 | 2022-09-21, U.S. District Courts | Civil Right | 12, which he asserts is substantial enough that he "may not be able to maintain his claim if forced to do so in Oklahoma," Opp. Relators John Christner Trucking, LLC and Stephen Sprague have filed an unopposed motion to dismiss this original proceeding. September 24, 2022| Opt-out/Objection/Challenge Postmark Date, October 31, 2022 @ 10:30 a.m.| Final Approval Hearing. Show more Link John Christner Trucking website Learn more Jobs We were not able to detect your location. See Burger King Corp. v. Rudzewicz, 471 U.S. 462, 464 (1985). Thus, this factor is not at issue. 5:15CV81, 2016 WL 1559176, at *5 (W.D. M/S Bremen v. Zapata Off-Shore Co., 407 U.S. 1, 10 (1972). Updated May 4, 2022. Gulf Ins. at 294. Preliminary record filed. No. The Court held that an arbitration agreement to which the EEOC was not a party could not limit the remedies otherwise granted to the EEOC by statute, which not only had the authority to pursue independent actions in court for Title VII violations but, in the context of the suit, also had "exclusive authority over the choice of forum and the prayer for relief once a charge has been filed." The following persons will be considered Class Members and be eligible to receive an Individual Settlement Amount from the Net Settlement Amount: Plaintiff and persons who meet the requirements of one or more of the following class or collective definitions: California Class All current and former individuals, to the extent they perform(ed) transportation services for Defendant within California from April 12, 2013 to June 21, 2022. Id. Any disputes must be postmarked by Saturday, September 24, 2022, and should be mailed to Huddleston v. JCT Settlement Administrator, P.O. . In other words, while the "in connection with" language is broad enough to encompass Huddleston's misclassification claims and bring them under the umbrella of the forum-selection clause, the ICOA provides that Oklahoma law applies only to interpretation of the ICOA itself. He further testifies that litigating this case in Oklahoma would impose a prohibitive economic hardship on him due to the cost of travel and time away from work, problems that he would not experience if the case were to remain in California. The deal will form one of the biggest temperature-controlled fleets in the nation at more than 3,000 trucks (800 at JCT), 5,000 trailers and total revenue exceeding $1 billion. JCT argues that the centerpiece of Huddleston's complaint is the Fair Labor Standards Act ("FLSA"), which set nationwide standards, and because Huddleston performed long-haul truck-driving services throughout the country, the FLSA claims "could have arisen whether he was a resident of California, Connecticut, Colorado, or any other state in the country." Cal. The test's first prong encompasses both purposeful direction and purposeful availment. The Court concludes that the forum selection clause of the ICOA is valid and enforceable. 2004). ROBERTO BALDERRAMA vs. JOHN CHRISTNER TRUCKING, JACQUELINE BRADFORD, Ordosgoitti v. Werner Enterprises, Inc. et al, Chandler et al v. Craters & Freighters Franchise Company, Beissel et al v. Western Flyer Express, LLC, Board of Education of Yukon Oklahoma Public Schools v. SYSCO USA II, LLC, Seay et al v. Oklahoma Board of Dentistry et al, Seay, et al v. Oklahoma Board of Dentistry, et al. Mahoney v. Depuy Orthopaedics, Inc., No. CollegeSource, Inc. v. AcademyOne, Inc., 653 F.3d 1066, 1080 (9th Cir. Huddleston Decl. COMPLAINT with Jury Demand against John Christner Trucking, LLC by Thomas Huddleston. According to court documents, John Christner Trucking is a for-hire motor carrier that provides trucking services nationwide and relies, in part, on drivers who operate trucks leased from its company, Three Diamond Leasing. This second prong of the specific jurisdiction test is satisfied if the plaintiff would not have been injured "but for" the defendant's forum-related contacts. Opp. Both groups are considered Class Members in this Notice. If you are a Class Member, you may be entitled to receive money from a Settlement in this case, as described below. "'Overreaching' is a ground 'short of fraud,' and a mere showing of 'non-negotiability and power difference' does not render a forum selection clause unenforceable." 10-1, Huddleston Decl. The classes consist of more than 3,000 truck drivers in the California Work Class and the Oklahoma class. "Although a FLSA claim for relief ostensibly arises from an employment contract, courts have likened FLSA claims to tort claims and have applied the purposeful direction standard." $246.4 M. Employees. at 24. If a defendant challenges the existence of personal jurisdiction, the plaintiff bears the burden of establishing the district court's personal jurisdiction over the defendant. So basically they give you older trucks with almost 500k miles. JCT restricts all routes accross I-90 but if driver does not say anything about added miles to avoid JCT WILL NOT Pay them same as using I-70 west of Denver in winter. Hirschbach Motor Lines today announced the completion of the acquisition of Sapulpa, Oklahoma-based refrigerated carrier John Christner Trucking. Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. Select SOLO DRIVER or TEAM DRIVER. 7. John Christner Trucking has an overall rating of 3.3 out of 5, based on over 41 reviews left anonymously by employees. Oct. 5, 2010)); Hernandez v. Martinez, No. Specifically, he says that a significant portion of his drop-offs and pick-ups were located in Tulare, Stockton, Fresno, Newman, Turlock, Modesto, Merced, Madera, and Livingston (all located within the Eastern District of California) and that the vast majority of his total driving miles were related to either a pick-up or drop-off in California. [21-5025]--[Edited 03/24/2021 by KLP to delete the attachment; entry filed.] CERT. 28 U.S.C 1404(a) provides that "[f]or the convenience of parties and witnesses, in the interest of justice, a district court may transfer any civil action to any other district or division where it might have been brought or to any district or division to which all parties have consented." Forum-selection clauses are also scrutinized for "fundamental fairness," and may be deemed unfair if inclusion of the clause was motivated by bad faith, or if the party had no notice of the forum provision. "By orchestrating deliveries to and from California and applying the allegedly unlawful employment practices to persons performing those transportation services, [JCT] targets California." John Christner Trucking 19007 W Hwy 33 Internet United States of America. Copyright 2023 Land Line Magazine & Land Line Now. at 17. Popular Searches. Opp. Instead, the federal circuit courts appear to agree that venue may be proper in multiple districts if a "substantial part" of the underlying events took place in each of those districts. Good lease to make money. Feb 17, 2022. "No one factor is dispositive; a court must balance all seven." . We can transport your goods at temperatures ranging anywhere from minus 20 degrees Fahrenheit to plus 90 degrees Fahrenheit and hold them at the temperature you specify. Mot. After deductions of these amounts, what remains of the Gross Settlement Amount, or the Net Settlement Amount, will be available to pay monetary Individual Settlement Amounts to (i) Plaintiff; and (ii) Class Members who do not opt out of the Settlement (collectively, Class Participants). 1998). 5:20-CV-00915 | 2020-09-11, U.S. Courts Of Appeals | Civil Right | Being primarily a FLSA case, JCT contends, "[i]t cannot be said that JCT's California operations made the FLSA claim (or Oklahoma state claims) uniquely possible." Code Ann. The Court cannot find on this record that honoring the forum-selection clause would mean that Huddleston "will for all practical purposes be deprived of his day in court." Huddleston argues that his claims brought pursuant to the Private Attorney General Act ("PAGA") are of such a strong local nature that they should be litigated in California. Huddleston v. John Christner Trucking is a putative class action pending in the Northern District of Oklahoma (Case No. Served on 03/24/2021. Why one international organization is joining the fight. See also Kia Motors Am., Inc. v. MPA Autoworks, No. 2015); Robles, 2015 WL 1530510, at *4. Core-Vent Corp. v. Nobel Indus. Web: www.johnchristner.com. Inc. v. La Ligue Contre Le Racisme Et L'Antisemitisme, 433 F.3d 1199 (9th Cir. 1988), having to obtain or present evidence from JCT's personnel in Oklahoma will not impose an unreasonable burden on JCT. CERT. [21-5023, 21-5025] [Entered: 03/25/2021 08:56 AM], Docket[10817559] Entry of appearance filed by Adam Carl Smedstad, James Anthony Eckhart, Mrs. Angela Stemle Cashand Christopher Eckhart for John Christner Trucking, LLC. 1:13-CV-00712-AWI, 2013 WL 3730391, at *2 (E.D. A forum-selection clause is "not unreasonable merely because of the parties' unequal bargaining power: it is enforceable if there is reasonable communication of the clause." 4:20-CV-00638 | 2020-12-07, U.S. District Courts | Contract | A trucker has been awarded $500,000 after being unlawfully detained while making a 2019 delivery in California. JCT does not target any advertising specifically to California and, since at least 2013, only 10- 12% of its total nationwide miles have been logged in California. Ronlake v. US-Reports, Inc., No. JCT is big enough to offer all you need to be successful but we're small enough to know you by name. Huddleston does not exclusively bring California claims; the Complaint also contains four causes of action under Oklahoma law, and in any case, "federal judges routinely apply the law of a State other than the State in which they sit." Plaintiff Thomas Huddleston brings this wage-and-hour putative class action lawsuit against defendant John Christner Trucking, LLC ("JCT"). Whether JCT violated the California Labor Code and Wage Orders will be answered not by looking to the ICOA but instead by the statutes and regulations governing Huddleston's claims. That test requires showing that the defendant (1) has committed an intentional act; (2) expressly aimed at the forum state; (3) causing harm that the defendant knows is likely to be suffered in the forum state. Los Angeles, LLC, 59 Cal. As to the ICOA, he testifies that when he was in Oklahoma for orientation, he was told that the ICOA was nonnegotiable, was told that it was offered on a take-it-or-leave-it basis, and that the forum-selection clause and its effects were never explained to him. 2015). Served on 03/12/2021. The first, known as "general jurisdiction," exists if the defendant's contacts with the forum are "so substantial and of such a nature as to justify suit against it on causes of action arising from dealings entirely distinct from those activities." Opp. Oklahoma Class All current and former individuals who provide(d) transportation services for Defendant within the United States, who (1) entered into an Independent Contractor Operating Agreement with Defendant, and (2) entered into a Lease Agreement with Defendant or Three Diamond Leasing, LLC, from April 12, 2014 to June 21, 2022. Preliminary record filed. Hirschbach acquiring John Christner Trucking, creating reefer giant. Id. In support of its motion to dismiss, JCT submits, inter alia, a declaration from Shannon Crowley, Vice President of Risk Management. CERT. Id. [21-5025] [Entered: 03/15/2021 11:58 AM], [10814928] Entry of appearance filed by Michael J Blaschke, Mr. Robert S. Boulter, Ms. Carolyn H. Cottrell, Mr. David C. Leimbach, Ms. Michelle S. Lim and Ms. Rachel Lawrence Mor for Thomas Huddleston. 74] of the defendant, John Christner Trucking, LLC ("JCT"). If you were a lease driver for JCT and/or have questions about the lawsuit, please contact Robert S. Boulter. By clicking "Submit", I agree to be contacted by John Christner Trucking, or on behalf of John Christner Trucking, with the information provided above. To be heard at the Final Approval Hearing you must also not opt out of the Settlement. You may also withdraw your objection in writing by mailing a withdrawal statement to the Court and counsel for the parties postmarked no later than Monday, October 17, 2022, orally at the Final Approval Hearing, or as otherwise ordered by the Court. See also Narayan, 616 F.3d at 899; Quinonez v. Empire Today, LLC, No. Atl. Although it is not mandatory, courts considering a challenge to both personal jurisdiction and venue generally decide the issue of personal jurisdiction first. Parts Coordinator. 206, et seq. 2021-11-03, U.S. District Courts | Personal Injury | A review of the distirct court docket shows transcripts ordered were already on file. Hirschbach Motor Lines recently agreed to acquire John Christner Trucking (JCT), a refrigerated carrier based in Sapulpa, Oklahoma. After the first two prongs of the test have been met, the defendant has the burden of showing that the Court's jurisdiction would be unreasonable. While the Court is sensitive to the potential financial strain involved in litigating this case in Oklahoma, serving as the named plaintiff in a class action is unlikely to carry with it the requirement that Huddleston travel to Oklahoma with much frequency, and Huddleston has failed to explain why litigating in Oklahoma would require substantially more time away from work than litigating in California such that he would be denied the ability to bring the case. Click UPDATE at the bottom of the calculator. See Narayan v. EGL, Inc., 616 F.3d 895, 899 (9th Cir. 1404 And Forum-Selection Clause. LaCross, 95 F. Supp. Bancroft & Masters, Inc. v. Augusta Nat.