Statement Case Management ConferenceCal. Super. - 6th Dist.November 24, 2020200V373984 Santa Clara - Civil QMeMQ/stem ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Tanya Gomerman (SBN 271834), Michael Brooks (SBN 272053) Electronically Filed Law Offices of Tanya Gomerman, PC by superior court of CA, 825 Van Ness Ave, Ste. 502, San Francisco, CA 94109 county of Santa Clara, TELEPHONE No.: 415-545-8608 FAX No. (0ptiona/):855-545-8608 on 8/30/2021 12:02 PM E-MAIL ADDRESS(0ptionaI): tanya@attorneytanya.com, michael@attorneytanya.com Reviewed By; System System ATTORNEY FOR (Name): Plaintiff Jane Doe case #20CV373984 SUPERIOR COURT 0F CALIIFORNIA, COUNTY 0F Santa Clara Envelope: 71 66057 STREETADDRESS: 191 N. FlrSt Street MAILING ADDRESS: CITY AND ZIP CODE: San Jose 951 13 BRANCH NAME: PLAINTIFF/PETITIONER: Jane Doe DEFENDANT/RESPONDENT: Rural/Metro of California, Inc. et al CASE MANAGEMENT STATEMENT CASE NUMBER (Check one): UNLIMITED CASE E LIMITED CASE 200V373984 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: September 14, 2021 Time: 10:00 am Dept: 19 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Michael Brooks INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): Jane Doe b. E This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): November 24, 2020 b. E The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. A|| parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. E The following parties named in the complaint or cross-complaint (1) E have not been served (specify names and explain why not): (2) E have been served but have not appeared and have not been dismissed (specify names): (3) E have had a default entered against them (specify names): c. E The following additional parties may be added (specify names, nature ofinvolvement in case, and date by which they may be served): 4. Description of ca_se 3- Type 0f case In complaint E cross-complaint (Describe, including causes of action): See attachment Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3720-3130 CM-1 10 [Rev. July 1, 201 1] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: Jane Doe CASE NUMBER: . . ZOCV373984 DEFENDANT/RESPONDENT: Rural/Metro of California, Inc. et al 4. b. Provide a brief statement of the case, including any damages. (prersonal injury damages are sought, specify the injwy and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable reliefis sought, describe the nature of the relief.) Plaintiff was raped by supervising co-worker Defendant Chavez. Plaintiff‘s employer (AMR) knew of Defendant Chavez's propensity for harassment prior to the rape but failed to act. Later, after Plaintiff complained to AMR about Defendant Chavez and subsequently other AMR managers regarding harassment, including Defendant Garvin, she was targeted for discipline and terminated. Plaintiff seeks compensatory and exemplary damages.E (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request a jury trial E a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. E The trial has been set for (date): b. No trial date has been set. This case will be ready fortrial within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 11/01/21-03/25/22; 04/1 1/22-06/03/22; 06/1 3/22-06/26/22; 07/1 8/22-07/29/22; 08/08/22-08/20/22; 09/12/22-09/16/22; 10/03/22-10/14/22; 12/09/22-12/23/22; 02/03/23-02/17/23 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 10'1 5 b. E hou rs (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption E by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented:E Additional representation is described in Attachment 8. 9. PreferenceE This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel has E has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: PartyE has E has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) E This matter is subject to mandatoryjudicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) E Plaintiff elects to referthis case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) E This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-“OIReV- Ju'y 1' 20“] CASE MANAGEMENT STATEMENT ”962°” CM-110 DEFENDANT/RESPONDENTZ Rural/Metro of California, Inc. et al PLAINTIFF/PETITIONER: Jane Doe CASE NUMBER: ZOCV373984 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing this form are willing to participate in the following ADR processes (check all that apply): If the party or parties completing this form in the case have agreed to participate in or have already completed an ADR process or processes, indicate the status of the processes (attach a copy of the parties'ADR stipulation): (1) Mediation DDDI Mediation session not yet scheduled Mediation session scheduled for (date): Agreed to complete mediation by (date): Mediation completed on (date): (2) Settlement conference Settlement conference not yet scheduled Settlement conference scheduled for (date): Agreed to complete settlement conference by (date): Settlement conference completed on (date): (3) Neutral evaluation Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): (4) Nonbinding judicial arbitration Judicial arbitration not yet scheduled Judicial arbitration scheduled for (date): Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): (5) Binding private Private arbitration not yet scheduled Private arbitration scheduled for (date): DUDE DUDE DUDE DUDE DUDE arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled E ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CMflJfl PLAINTIFF/PETITIONER: Jane Doe CASE NUMBER: 2 V 7 4 DEFENDANT/RESPONDENT: Rural/Metro of California, Inc. etal OC 3 398 11. Insurance a. E Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: E Yes E No c. E Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.E Bankruptcy E Other (specify): Status: 13. Related cases, consolidation, and coordination a_ E There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status:E Additional cases are described in Attachment 13a. b. E A motion to E COHSOlidate E coordinate will be filed by (name party): 14. Bifu rcationE The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type ofmotion, and reasons): 15. Other motionsE The party or parties expect to file the following motions before trial (specify moving party, type ofmotion, and issues): 16. Discovery a. E The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovely): Pady Description Date Plaintiff Written Discovery 1/31/2022 Plaintiff Depositions of Percipient Witnesses 3/31/2022 Plaintiff Depositions of Experts per code c_ E The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-1 10 [Rev. July 1, 201 1] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: Jane Doe CASE NUMBER:- 20CV373984 DEFENDANT/RESPONDENT: RU ral/Metro Of california, Inc. et al 17. Economic litigation a.E This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b.E This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery wi|| be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issuesE The party or parties request that the following additional matters be considered 0r determined at the case management conference (specify): 19. Meet and confer a. V The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 1 | am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and wi|| possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: August 30, 2021 . m r,k Michael Brooks ’ (TYPE 0R PRINT NAME) (SIGNATURE 0F PARTY 0R A'I'I'ORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR A'I'I'ORNEY)E Additional signatures are attached. CM-“OIRev-Ju'v 1v 2°11] CASE MANAGEMENT STATEMENT Pases°f5 SHORT TITLE: Jane Doe V. Rural/Metro of California, Inc. CASE "UMBER: _ 20-CV-373984 1 2 Attachment 3 Description of Case: 4. a. 4 For Damages: Sexual Battery; Violation of Rights to Freedom from Sexual Violence; Gender 5 Violence; Assault and Battery; Intentional Infliction of Emotional Distress; Negligent Hiring, 6 Supervision and Retention; Negligence; Employment Discrimination Based on Sex and Disability; Hostile Work Environmental Harassment; Retaliation in Violation 0f the Fair Employment and 7 Housing Act; Failure to Accommodate Disability; Failure to Prevent Harassment, Discrimination and Retaliation; Whistle-blower Retaliation in Violation 0f Labor Code Sections 98.6 and 1102.5; 8 Wrongful Discharge in Violation of Public Policy 9 1 0 1 1 12 1 3 14 1 5 1 6 1 7 1 8 1 9 20 21 22 23 24 25 26 (Required for verified pleading) The items on this page stated on information and belief are (spechj/ item numbers, not line numbers): 27 This page may be used with any Judicial Council form or any other paper filed with the court. Page 6 Form Approved by the ADDITIONAL PAGE Judicifi Come“ O‘Cam'amia Attach to Judicial Council Form or Other Court Paper CR0 201. 501 M0020 [New January 1. 1987] QONUIAUJN 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CERTIFICATE OF SERVICE I am a resident of the United States and employed in the County 0f San Francisco, over the age of eighteen years and not a party to the within action or proceeding. My business address is 825 Van Ness Avenue, Suite 502, San Francisco, CA 94109. My electronic service address is salma@attorneytanya.com. On the date stated below, I served the foregoing documents described as: CASE MANAGEMENT STATEMENT [X] BY ELECTRONIC MAIL: The document listed was transmitted Via email to the email address(es) listed below. Tyler A. Brown Edward A. Kraus Kate L. Brown Kathryn E. Barrett Jackson Lewis P.C. Silicon Valley Law Group 50 California Street, 9th Floor One North Market Street, Ste. 200 San Francisco, CA 941 11 San Jose, CA 95 1 13 Email: Tyler.Brown@jacksonlewis.com Email: eak@svlg.com Kate.Brown@jacksonlewis.com keb@svlg.com Larry.Nels0n@jacksonlewis.com edn@svlg.com mvn@svlg.com Attorneys for Defendants Rural/Metro 0f California, Inc. Attorneys for Defendant Albert J. Chavez American Medical Response West American Medical Response, Inc. and Christopher Garvin Pursuant to Code of Civil Procedure section 1010.6, this document Will only be served electronically to the persons at the electronic notification address listed above. I am readily familiar with the business practice for filing electronically, and the document would be electronically served that same day in the ordinary course 0f business following ordinary business practices. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed 0n August 30, 2021 at Sunnyvale, California. fl . Salmeuleyman -1- CERTIFICATE OF SERVICE
