Statement Case Management ConferenceCal. Super. - 6th Dist.March 18, 2021CM-110 A'nORNEY OR PARTY WITHOUT ATTORNEY (Name, Scare Bar number, and address) Aidin D. Ghavimi, Esq. (SBN 305808) ST ARPOINT, ALC 1801 Century Park East, Ste 2400, Los Angeles, CA 90067 TELEPHONE NO 310-556-9627 FAX NO (oprionag.424-255-4035 e-vuu_uooaesstoprronar> aidin@starpointlaw.com ATTORNEY FOR : Plaintiff, Jayli Bachman FOR COURT USE ONLY SUPERIOR COURT OF CALIFORNIA, COUNTY OF STREETADDRESS 191 N. F!rStStreet MAILING ADDRESS 191 N. First Street CITY AND zip CODE. 8Byl JOSei CA 95113 'NCH NAME Downtown Superior Court (DTS) PLAINTIFF/PETITIONER: JAYLI BACHMAN DEFENDANT/RESPONDENT: STANFORD HEALTH CARE, et al. CASE MANAGEMENT STATEMENT (chechone): [Z] UNLIMITEDCASE [3 LIMITEDCASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) CASE NUMBER: 21 CV380603 A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: June 27, 2021 Time: l:30pm Dept.: 2 Div.: Room: Address of court (if different from the address above): [Z] Notice of Intent to Appear by Telephone, by (name): Qjdill (,5Byjyj INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. [2] This statement is submitted by party (name): Jayli Bachman b, 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): b. [2 The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. [Z] All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b, [3 The following parties named in the complaint or cross-complaint (1) havenotbeenserved(specifynamesandexplainwhynot): (2) [1 have been served but have not appeared and have not been dismissed (specify names): (3) [HI have had a default entered against them (specify names): c. The following additional parties may be added (specify names, nature ofinvolvementin case, and date by which they may be served): 4. Description of case a. Type of case in [Z] complaint [2 cross-complaint (Describe, includingcausesofaction): Complaint for gender and gender identity discrimination, harassment, failure to prevent harassment, retaliation, and constructive termination. Form Adopted for Mandatoiy Use Judicial Council of California CM"l'lO[Rev Julyl20l1] CASE MANAGEMENT ST ATEMENT Page 1 of 5 Cal Rules of Court, rules 3.720-3.730 www courls ca.gov Electronically Filed by Superior Court of CA, County of Santa Clara, on 7/27/2021 11:09 AM Reviewed By: System System Case #21CV380603 Envelope: 6930814 21CV380603 Santa Clara - Civil System System CM-110 PLAINTIFF/PETITIONER: JAYLI BACHMAN DEFENDANT/RESPONDENT: STANFORD HEALTH CARE, et al. CASE NUMBER 21 CV380603 4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amountl, estimated future medical expenses, lost eamings to date, and estimated future lost eamings. /f equitable relief is sought, describe the nature of the relief.) Defendant by and through a supervisor discriminated and harassed Plaintiff based on her gender and gender identity. When Plaintiff complained, Defendant retaliated and constructively terminated Plaintiff's employment. [ (lf more space is needed, check this box and attach a page designated asAttachment4b.) 5. Jury or nonjury trial Thepartyorpartiesrequest [Z] ajurytrial anonjurytrial. requesting a jury trial): (If more than one party, provide the name of each party 6. Trial date a. [2 The trial has been set for (date): b. [Z] No trial date has been set. This case will be ready fortrial within 12 months ofthe date of the filing ofthe complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 2021 : 11 /12 - 26, 1 2/14 - 1 /04 2022: 5/16 - 25, 11 /05 - 12 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [ days (specify number): 7 DADS b. [2] hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial [Z] by the attorney or party listed in the caption a. Attorney: b. Firm: c. Address: d. Telephone number: e. E-mail address: [] Additional representation is described in Attachment 8. 9. Preference [ This case is entitled to preference (specify code section): f. Fax number: g. Party represented: 10. Alternative dispute resolution (ADR) [2 by the following: 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 3.2:)1 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel has [2 has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (:) For self-represented parties: Party [5 has € has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) Tmheids.lmatpl0tnteurnisdesu!eocdtetoOfmCalVn.ld, aPtro0ry ejduudricei sleacrtbl0itnra1t7io7n5u3ndbeercaCuosdeethofeCaimviol Punrot?nedcuornetrsOevcetrisoyndl01e4sl.nl01toerxtcoeceidvitlhaection statutory limit. (2) [2 Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 4141.14. (3) [HI 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 1 775 et seq. (specify exemption): CM-110 (Rev July 12011 ] CASE MANAGEMENT ST ATEMENT Page 2 of 5 CM-110 PLAINTIFF/PETITIONER: JAYLI BACHMAN DEFENDANT/RESPONDENT: STANFORD HEALTH CARE, et al. CASE NUMBER 21 CV380603 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 a// 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 [Z] [Z] Mediation session not yet scheduled 0 Mediation session scheduled for (date): 0 Agreed to complete mediation by (date).' 0 Mediation completed on (date): (2) Settlement conference € [3 Settlement conference not yet scheduled 0 Settlement conference scheduled for (date): € Agreed to complete settlement conference by (date): 0 Settlement conference completed on (date): (3) Neutral evaluation € 0 Neutral evaluation not yet scheduled 0 Neutral evaluation scheduled for (date): € Agreed to complete neutral evaluation by (date): 0 Neutral evaluation completed on (date): (4) Nonbinding judicial arbitration [IIJ 0 Judicial arbitration not yet scheduled € Judicial arbitration scheduled for (date): 0 Agreed to complete judicial arbitration by (date): 0 Judicial arbitration completed on (date): (5) Binding private arbitration € 0 Private arbitration not yet scheduled 0 Private arbitration scheduled for (date): 0 Agreed to complete private arbitration by (date): 0 Private arbitration completed on (date): (6) Other (specify): € 0 ADR session not yet scheduled 0 ADR session scheduled for (date): 0 Agreed to complete ADR session by (date): 0 ADR completed on (date): CM-'I 10 [Rev July 1201 j ] CASE MANAGEMENT STATEMENT Page 3 of 5 cu*"l'ln PLAINTIFF/PETITIONER: JAYLI BACHMAN DEFENDANT/RESPONDENT: STANFORD HEALTH CARE, et at. CASE NUMBER 21 CV380603 11. Insurance a. [2 Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes [ No c. [3 Coverage issues will significantly affect resolution ofthis case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Status: 13. Related cases, consolidation, and coordination B, [2 There are companion, underlying, or related cases. (1 ) Name of case: (2) Name of court: (3) Case number: (4) Status: [2 Additional cases are described in Attachment 13a. b. [2 A motion to [I] consolidate [2 coordinate will be filed by (name party): 14. Bifurcation 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 of motion, and reasons): 15. Other motions [1 The party or parties expect to file the following motions before trial (specifymovingparty, type ofmotion, andissues).' 16. Discovery a. [1 The parl or parties have completed all discovery. b. [3 The following discovery will be completed by the date specified (describe all anticipated discovery) Plaintiff Plaintiff Plaintiff Written discovery Fact depositions Expert depositions Per code Per code Per code C, The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-1SO [Rev July j, 201 j ] CASE MANAGEMENT STATEMENT Page 4 of 5 (.M-l'lfl PLAINTIFF/PETITIONER: JAYLI BACHMAN DEFENDANT/RESPONDENT: STANFORD HEALTH CARE, ei al. CASE NUMBER 21 CV380603 17. Economiclitigation B, [2 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. 5, [3 This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues [2 The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. [Z] 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 (ifnot, 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): 0 I 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 will 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: July 23, 2021 Aidin Ghavimi, Esq. (TYPE OR PRINT NAME) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) [2 Additional signatures are attached. CM-'I 10 [Rev July I 2011 ] CASE MANAGEMENT STATEMENT Page 6 of 6 \quaUIhU-DNH NNNNNNNNNHHHHHHHHHH WQQUIhUJNHCCmQGUIhMNHC PROOF 0F SERVICE (CCP §§ 1013(a) and 2015.5; FRCP 5) STATE OF CALIFORNIA, COUNTY OF SANTA CLARA I am employed in the County 0fLos Angeles, State 0f California. I am over the age of 18 and not a party to the within action; my business address is: 1801 Century Park East, 24th Floor, Los Angeles, CA 90067. On July 26, 2021, I served the foregoing documents described as: PLAINTIFF’S CASE MANAGEMENT STATMENT 0n the interested parties in this matter ofBachman v. Stanford Health Care, et al. SEE SERVICE LIST ( ) BY FIRST CLASS MAIL: By placing copies thereof enclosed in sealed envelopes addressed t0 the interested parties and depositing such envelope(s) in the mail at LOS ANGELES, California. The envelopes were mailed with postage thereon fully prepaid. I am "readily familiar" with the firm's practice 0f collection and processing correspondence for mailing. Under that practice, it would be deposited With U.S. Postal Service on the same day in the ordinary course of business. I am aware on motion 0f the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after the date 0f deposit for mailing in affidavit. ( ) OVERNIGHT DELIVERY: () UPS () FedEx: I enclosed the documents in an envelope or package and addresses to the persons at the address stated in the SERVICE LIST. I placed the envelope or package for collection and overnight delivery at an office or a regular utilized drop box of the overnight delivery carrier. ( ) UPS / FEDEX DELIVERY: I enclosed the documents in an envelope or package and addresses to the persons at the address stated in the SERVICE LIST. Iplaced the envelope or package for collection and delivery at an office 0r a regular utilized drop box 0f the delivery carrier. ( ) FACSIMILE: I faxed the documents to the persons at the numbers listed in the SERVICE LIST. N0 error was reported by the fax system that I used. A copy 0f the record 0f the fax transmission can be provided upon request. (XX) EMAIL/ELECTRONIC TRANSMISSION: Based on California Rule of Court 2.25 1(c)(3), a court order 0r an agreement of the parties t0 accept service by email 0r electronic transmission, I caused the documents t0 be sent t0 the person at the email addressed listed in the SERVICE LIST. I did not receive, Within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. (XX) STATE - I declare under penalty ofpeljury under the laws of the State 0f California that the above is true and correct. ( ) FEDERAL - I declare that I am employed in the office 0f a member 0f the bar of this court at Whose direction the service was made. I declare under penalty ofpeljury under the laws of the United States that the above is true and correct. EXECUTED on July 26, 2021, in Los Angeles, Califo ©W\IO\UIKOJNH NNNNNNNNNHHHHHHHHHH ®\IO\UIhWN#©\G®\IQUIhWNH© SERVICE LIST ALYSON S. CABRERA, ESQ. acabrera@grsm.com JENNIFER M. LYNCH, ESQ. jlynch@grsm.com NICHOLAS A. DEMING, ESQ. ndeming@grsm.com GORDON REES SCULLY MANSUKHANI, LLP 275 Battery Street, Suite 2000 San Francisco, CA 941 11 Telephone: (415) 986-5900 Facsimile: (415) 986-8054 Counsel for Defendant, Stanford Health Care