Statement Case Management ConferenceCal. Super. - 6th Dist.March 26, 202121 CV381402 Santa Clara - Civil WerlflQ/stem ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY JAMES R. WILLIAMS, County Counsel (S.B. #271253) _ . JENNIFER s WANG, Deputy County Counsel (SB. #233155) Electronlfzally Flled OFFICE 0F THE COUNTY COUNSEL by Superlor Court 0f CA, 7o w. Hedding Street, East Wing, 9th Floor, San Jose, CA 951 10 County of Santa Clara, TELEPHONE No.: (408)299-5900 FAX No. (Optional): (408)292-7240 on 7/26/2021 10.35 AM E-MAIL ADDREsswptional): iennifer.wanq@CCO.SCCGOV.0rq Reviewed By: System System A1TORNEY FOR (Name): Defendant County Of Santa Clara case #21 cv381402 SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F SANTA CLARA Envelope: 6920863 STREET ADDRESS: 191 N. First Street MAILINGADDRESS: (same aS above) CITY AND ZIP CODE: San Jose, CA 951 13 BRANCH NAME: Downtown Superior Court PLAINTIFF/PETITIONER; PATRICIA HALFMAN DEFENDANT/RESPONDENT: SANTA CLARA COUNTY, et al. CASE MANAGEMENT STATEMENT EqSEQ/Uggfiioz (Check one): g UNLIMITED CASE D LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE STATUS REVIEW HEARING is scheduled as follows: Date: August 10, 2021 Time: 3:00 p.m. Dept: 20 Div.: Room: Address of court (if different from the address above): E Notice of Intent to Appear by Telephone, by (name): JENNIFER WANG, Deputy County Counsel INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. g This statement is submitted by party (name): Defendant County of Santa Clara b. D 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. D The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. D A|| parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. D The following parties named in the complaint or cross-complaint (1) D have not been served (specify names and explain why not): (2) D have been served but have not appeared and have not been dismissed (special names): (3) D have had a default entered against them (specify names): c. D The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type of case in E complaint D cross-complaint (Describe, including causes of action): Alleged discrimination, harassment, retaliation, failure to prevent discrimination, and violation of Labor Code section 1102.5. Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 312073.730 CM-1 10 [Rev. July 1, 201 1] www.courts.ca‘gov American LegalNet, Inc. www.FormsWorkFlow.c0m _ CM-110 EEFENDANT/RESPONDENT: SANTA CLARA COUNTY, et al. I CASE NUMBER:PLAI NTI FF/PETITIONER. PATRICIA HALFMAN 21 CV381 402 4. b. Provide a brief statement of the case, including any damages. (prersonal injury damages are sought, specify the injury 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 relief is sought, describe the nature of the relief.) Plaintiff is a former employee of St. Louise Regional Hospital (SLRH). Plaintiff claims that she did not receive a permanent position at SLRH after the hospital was acquired by Santa Clara County because of discrimination and retaliation. She further claims harassment by her former manager. Plaintiff seeks unspecified economic and non- economic damages. The County denies plaintiff’s claims and asserts that all decisions made and actions taken were for legitimate, non-discriminatory and non-retaliatory reasons. D (Ifmore space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request g a jury trial D a nonjury trial. (Ifmore than one party, provide the name of each party requesting a jury trial): Trial date a. D The trial has been set for (date): b. g No trial date has been set. This case wi|| be ready for trial within 12 months of the date of the filing ofthe complaint (if not, explain): Defendant anticipates that this case wi|| be ready for trial in August 2022. The Complaint was filed on March 26, 2021, but there was a 2.5 month delay in service ofthe Complaint on defendant. c. Dates on which parties or attorneys wi|| n_ot be available for trial (specify dates and explain reasons for unavailability): Feb. 21-25 (family trip); March 28-April 1 (possible family reunion). Estimated length of trial The party or parties estimate that the trial will take (check one): a. E days (specify number): 5 b. D hours (short causes) (specify): Trial representation (to be answered for each pafiy) The party or parties will be represented at trial E by the attorney or party listed in the caption D by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: D Additional representation is described in Attachment 8. Preference D 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 E has D 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: Party D has D has not reviewed the ADR information package identified in rule 3.221. b. Referral tojudicial arbitration or civil action mediation (if available). (1) D This matter is subject to mandatory judicial 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) D Plaintiff elects to refer this case tojudicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141 .11. (3) D This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-“OIRev- JUIWM CASE MANAGEMENT STATEMENT WW American LegaINet, Inc. www.FormsWorkFlow.com . CM-110 PLAINTIFF/PETITIONER: PATRICIA HALFMAN D-EFENDANT/RESPONDENT: SANTA CLARA COUNTY, et al. CASE NUMBER: 21 CV381 402 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 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 arbitration Private arbitration not yet scheduled Private arbitration scheduled for (date): Agreed to complete private arbitration by (date): Private arbitration completed on (date): (6) Other (specify): DUDE DUDE DUDE DUDE DUDE DUDE ADR session not yet scheduled ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-1 10 [Rev. July 1, 201 1] CASE MANAGEMENT STATEMENT Page 3 of 5 American LegalNet, Inc. www.FonnsWorkFlow.coma CM-110 - CASE NUMBER: _ PLAINTIFF/PETITIONER. PATRICIA HALFMAN 21CV381402 DEFENDANT/RESPONDENT: SANTA CLARA COUNTY, et al. 11. Insurance a. g Insurance carrier, if any, for pany filing this statement (name): self-insured b. Reservation of rights: D Yes D No c. D 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. D Bankruptcy D Other (specify): Status: 13. Related cases, consolidation, and coordination a. D There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: D Additional cases are described in Attachment 13a. b. D A motion to D consolidate D coordinate wi|| be filed by (name party): 14. Bifurcation D 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 E The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Defendant anticipates filing a motion for summaryjudgment. 16. Discovery a. D The party or parties have completed all discovery. b E The following discovery wi|| be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant Written Discovery November 2021 Defendant Depositions February 2021 c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-“OIReV- Ju'mom CASE MANAGEMENT STATEMENT Pagan” American LegalNet, Inc. www.FormsWorkFlow.00m . CM-110 . CASE NUMBER: _ PLAINTIFF/PETITIONER. PATRICIA HALFMAN 21 CV381402 DEFENDANT/RESPONDENT: SANTA CLARA COUNTY, et al. 17. Economic litigation a. D 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. D 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 D 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. E The party or parties have met and conferred with all parties on all subjects required by rule 3.724 ofthe California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 0f the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 0 | 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 26, 2021 JENNIFER WANG, Deputy County Counsel > /s/ Jennifer S Wang (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) D Additional signatures are attached. CM-“OIRev- Ju'mom CASE MANAGEMENT STATEMENT Pages“ American LegaINet, Inc. www.FormsWorkFlow.com V. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA PROOF OF SERVICE BY ELECTRONIC MAIL Patricia Halfinan v. Santa Clara County, et al. No. 21CV381402 I, Anna Marie B. Espiritu, declare: I am now and at all times herein mentioned have been over the age 0f eighteen years, employed in Santa Clara County, California, and not a party to the within action or cause; that my business address is 70 West Hedding Street, 9th Floor, San Jose, California 951 10-1770. My electronic service address is: anna.espiritu@cco.sccgov.org. On July 26, 2021, I electronically served a copy 0f CASE MANAGEMENT STATEMENT to the person listed below at the following electronic service address: Harper & Burns LLP Alexandra M. Halfman Email: amhalfinan@h§gperbums.com I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was executed on July 26, 2021. Anna Marie B. Espiritu Proof of Service by Electronic Mail Case Number: 21CV381402
