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Page 1 AMAA
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Mar-01-2012 12:13 pm
Case Number: CGC-11-513645
Filing Date: Mar-01-2012 12:13
Juke Box: 001 Image: 03515848
CASE MANAGEMENT STATEMENT
CYNTHIA SANDERS VS. AT&T et al
001003515848
instructions:
Please place this sheet on top of the document to be scanned.Page 2 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bay number, and adaress).
Katharine L. Ketllar (SBN 231586\¥Noah Levin (SBN 263069)
Mitler Law Group
111 Sutter Sireel, Suile 700
San Francisco, CA 94104
TELEPHONE NO. 815.464-4300 FAX NO. (Ophonait 415.464.4366
E-MAIL ADORESS (Oppona). kik@miltlerlawgroup.com; nal@millarlawgroup.com
ATTORNEY FOR (Namey: Defendants AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY
SUPERIOR COURT OF CALIFORNIA, COUNTY OF san FRANCISCO
STREET ADDRESS 400 McAllister Street
MAILING ADORESS
City AND ZIP CODE. San Francisco 94102
GRANCH NAME:
PLAINTIFF/PETITIONER: CYNTHIA SANDERS
DEFENDANTIRESPONDENT: AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY
CASE MANAGEMENT STATEMENT CASE NUMBER
(Check one): (7) UNLIMITED CASE () LIMITED CASE
(Amount demanded (Amount demanded is $25,000 CGC-11-513645
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCGE is scheduled as follows:
Date: March 16, 2012 Time: 2:00 p.m. Dept: 610 Div.: Room:
Address of court (if different from the address above):
[__] Netice of Intent to Appear by Telephone, by (namo);
INSTRUCTIONS: All applicable boxes must be checked, and the specified Information must be provided.
1. Party or parties (answer one):
a. [7] This statement is submitted by party (nama): Defendants AT&T Comp. and Pacific Bell Telephone Company
b. [“] This statement is submitted jointly by parties (names):
a. The complaint was filed on (date):
b. [7] The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintifis and cross-complainants only)
a C) an parties named in the complaint and cross-complaint have bean served, have appeared, or have been dismissed.
b. (2) The following parties named in the complaint or cross-complaint
(1) [] have not been served (specify names and explain why nol):
Complaint and cross-complalint (to be answered by plaintiffs and cross-complainants only)
(2) [2] have been served but have not appeared and have not been dismissed (specify names):
(3) [J] have had a default entered against them (specify names):
c. []) The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
Description of case
termination in vialation of public policy and intentional infliction of emotional disiress.
a. Typeofcasein [¥} complaint [0] cross-compiaint (Describe, including causes of action):
Plaintiff alleges causes of action for race discrimination, disability discrimination, retaliation, fallure to engage in the inleractive process, wrongful
Pago tots
S< Form Adora fs Mandatory Use CASE MANAGEMENT STATEMENT Cay Rue of Cours
sq] CM-110 [Peev. judy 1, 2014} wit COUNTS. C8 Gor
www.accesslaw.comPage 3 CM-110
PLAINTIFF/PETITIONER: CYNTHIA SANDERS CASE NUMBER:
¢ CGC-11-513645
DEFENDANT/RESPONDENT: AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY
4. b. Provide a brief statement of the case, including any damages. (/f personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date findicate source and amount], estimated future medical expenses, last
samings to date, and estimated future iost earings. if equitable ralief is sought, describe the nature of the relief)
Please see altachmant 4{b).
C7] (if more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party of parties request (7) a jury trial C_) a nonjury trial. {#f more than one party, provide the name of aach party
requasting a jury trial):
6. Trial date
a. (_] The trial has been set for (date):
b. CZ) No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint {if
nol, explain): Thie case will net be ready for trial within 12 months as the proper Defendant entity has nol been named or served and no
discovery has been conducted.
c. Dates on which parties or attomeys will not be available for trial (specify dates and explain reasons for unavailability):
5/1/12 - 8/22/12 (trials and vacation): 8/27/12-9/7/12 (trial); 9/24/12-10/5/1 2itrial); 11/9/12-12/14/12 (trials);
1114/13-1731/13 (ital): 4/1 1/13-3/22/13 (trial)
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [Y) days (specify number): 7 days
b. [__] hours (short causes) (specify):
6. Trial representation (io be answered for each party)
The party or parties will be represented at trial [7] by the attorney or party listed in the caption [__] by the following:
a. Attomey:
b. Firm:
c. Address:
d. Telephone number: f Fax number.
6. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
9. Preference
([7] This case is entitled to praferance (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in differant 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 counse!: Counsel G7) tas [-) 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 L_] has [_} has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if availabie).
(1) [£2] This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 oF to civil action
mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2} ((_] Plaintiff elacts to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) (42) This case is sxempt from judicial arbitration under rule 3.811 of the Califomia Rules of Courtor from clvil action
mediation under Code of Civil Procedure section 1775 et seq. (Specify exemption): Rule 3.611(b}(8)
CTO fae ay 7 20 CASE MANAGEMENT STATEMENT Pane 2oftPage 4 CM-110
PLAINTIFF/PETITIONER: CYNTHIA SANDERS
EFENDANT/RESPONDENT: AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY
CASE NUMBER:
CGC-11-513645
10. c. Indicate the ADR process cr processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check aif that apply and provide the specified information):
The party or parlies completing
this form are willing to
participate in the following ADR
processes (check ail 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 (atlach a copy of the parties‘ AOR
Stipulation):
(1) Mediation
wa
OW
Mediation session not yet scheduled
Mediation session scheduted for (date):
Agreed to complate mediation by (dasa):
Mediation completed on (dale):
(2) Settlement
conference
Settlement conference nol yet scheduled
Settlement conference scheduled for (date):
Agreed to complete settlement conferance by (date):
Settlement conference completed on (date):
(3) Neutral evaluation
Neutral evaluation not yet scheduled
Neutral evaiuation scheduled for (data):
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (daia):
(4) Nonbinding judicial
arbitration
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date);
Agreed to complete judicial arbitration by (data):
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):
(8) Other (specify):
UUUO;/OU0O;O000;O000/o000]o0
ADR session not yet scheduled
ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 Rev, duty 1.2019}
CASE MANAGEMENT STATEMENT
Page Sof 6Page 5 CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: CYNTHIA SANDERS
CGC-11-513645
DEFENDANTIRESPONDENT: AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY
17. Insurance
a. (_] Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: {__] Yes ([_] No
c. (C_] 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.
(__] Bankruptcy [_} Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. [_] There ara companion, underlying, or related cases.
(1) Name of case:
(2) Narne of court:
(3) Gase number:
(4) Status:
[—] Additionat cases are described in Attachment 13a.
b. [-)Amotionto (7_) consolidate [[_] coordinate will be filed by (name party):
14, Bifurcation
[¥] The party or parties intend to file a motion for an order difurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
Defendants may move to bifurcate discovery, with the Initial phase dedicated to delermining the identity of Plaintiffs employer. Oefendants may
also move to bifurcate issues relating to liability and damages, if necessary,
15. Other motions
L7) The party or parties expact to file the following motions before tial (specify moving party, type of motion, and issues):
if Ptaintiff will not voluntarily dismiss Defendants AT&T Carp. and Pacific Bail Talephone Company, they will file dispositive motions on the
ground thal they did not employ Plaintiff. Additional motions are anticipated if tha proper employing enlity is added to the case.
16. Discovery
a. (__] The party or parties have completed all discovery.
b. G7) The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendants Discovery of evidence supporting Plaintiff's claim that Defendants employed her = April 2012
c. [42] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Additional discovery will be necessary if the proper employing entity is added to the case, including the Plaintiff's deposition, Request for
Production of Documents, and Interrogatories. Defendants will also seek a stipulated protective order.
CM-110 (Rew. Ausy 1, 2007)
CASE MANAGEMENT STATEMENT Page 4016Page 6 CM-110
PLAINTIFF/PETITIONER: CYNTHIA SANDERS CASE NUMBER.
— CGC-11-513845
DEFENDANT/RESPONDENT: AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY
17. Economic litigation
a. [_] This is a limited civil case (i.e., tha amount demanded is $25,000 or less) and the economic litigation procedures in Coda
of Civit Procedure sections 90-96 will apply to this case.
b. (__] 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 (#/ checked, expiain specifically why economic litigation procedures reiating to discovery or trial
should not apply to this case):
18. Other issues
C_] 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. [7] The party or parties have met and conferred with all parties on al! subjects required by rule 3.724 of the Califomia Rules
of Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the partias 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 resotution,
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: march 1, 2012
Noah Levin >
{TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY}
b
(TYPE OR PRINT NAME) (SIGNATURE CF PARTY OR ATTORNEY)
[1] Additional signatures are attached.
M90 ew ty 3.7017 CASE MANAGEMENT STATEMENT Page borsPage 7 MC-025
CASE NUMBER:
CGC-11-513645
ATTACHMENT (Number): 4(b)
(This Atachmeni may be used with any Judicial Council form.)
Plaintiff alleges the above-referenced causes of actions against Defendants AT&T Corp. and Pacific Bell
Telephone Company, neither of whom employed Plaintiff. Both further deny that they treated Plaintiff
unlawfully in any way and deny that Plaintiff is entitled to damages, in any amount, or at all. Counsel for
Defendants has repeatedly spoken with and provided evidence to Plaintiff's counsel demonstrating the identity
of Plaintiff's employer, but Plaintiff has not amended her Complaint to dismiss the improper parties or to
reflect the proper Defendant entity.
SHORT TITLE:
~~ Sanders v. AT&T, et al.
(if the itam that this Atachment concems is made under penalty of perjury, all statements in this Page of
Attachment are made under penalty of perjury.) (aad pages as a requiea) | ;
reason Cowen ot cairn ATTACHMENT wer antl ca gow
J
MC-O25 [Rev. aly 1, 2008) to Judicial Council FormPage 8 MILLER Law Groce
A PROFESSION AL Corona TEN
SAN FRANCISCO CALIFORNEA
oO a nN DP oO FF WwW KH =a
wy NM MW BY HM NM KM KD wD = =o mw Se ol UlUlcelUlUlUrlCl
ao vy PF A FF ONY B= FC DO DAN OAK DH BAS
ao
MP
PROOF OF SERVICE
I, Pamela A. Leonard, declare that | am employed at Miller Law Group, A
Professional Corporation, whose address is 111 Sutter Street, Suite 700, San Francisco, CA
94104; | am over the age of eighteen (18) years and am not a party to this action. On the
below date, by the method noted below, | served the following document(s):
DEFENDANTS AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY'S CASE
MANAGEMENT CONFERENCE STATEMENT
on the interested parties in this action by placing a true and correct copy thereof, enclosed
in a sealed envelope addressed as follows:
Spencer F. Smith, Esq. Attorney for Plaintiff: Cynthia Sanders
Dow W. Patten, Esq.
Law Offices of Spencer F. Smith
353 Sacramento Street, Suite 1120
San Francisco, CA 94111
Tel: (415) 520-6950
Fax: (415) 520-0104
() BY MAIL: By placing a true copy thereof enclosed in a sealed envelope with
postage thereon fully prepaid, in the ordinary course of business for collection and
mailing on this date at Miller Law Group, 111 Sutter Street, San Francisco, California.
| declare that | am readily familiar with the business practice of Miller Law Group for
collection and processing of correspondence for mailing with the United States Postal
Service and that the correspondence would be deposited with the United States
Postal Service that same day in the ordinary course of business.
XX) [State] | declare under penalty of perjury under the laws of the State of California that
the foregoing is true and correct.
Executed on March 1, 2012 at San Francisco, California.
go A. eid ,
1
PROOF OF SERVICE
San Francisco County Court Case No. CGC-11-513645
PDF Page 1
PlainSite Cover Page
PDF Page 2
AMAA
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Mar-01-2012 12:13 pm
Case Number: CGC-11-513645
Filing Date: Mar-01-2012 12:13
Juke Box: 001 Image: 03515848
CASE MANAGEMENT STATEMENT
CYNTHIA SANDERS VS. AT&T et al
001003515848
instructions:
Please place this sheet on top of the document to be scanned.
PDF Page 3
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bay number, and adaress).
Katharine L. Ketllar (SBN 231586\¥Noah Levin (SBN 263069)
Mitler Law Group
111 Sutter Sireel, Suile 700
San Francisco, CA 94104
TELEPHONE NO. 815.464-4300 FAX NO. (Ophonait 415.464.4366
E-MAIL ADORESS (Oppona). kik@miltlerlawgroup.com; nal@millarlawgroup.com
ATTORNEY FOR (Namey: Defendants AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY
SUPERIOR COURT OF CALIFORNIA, COUNTY OF san FRANCISCO
STREET ADDRESS 400 McAllister Street
MAILING ADORESS
City AND ZIP CODE. San Francisco 94102
GRANCH NAME:
PLAINTIFF/PETITIONER: CYNTHIA SANDERS
DEFENDANTIRESPONDENT: AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY
CASE MANAGEMENT STATEMENT CASE NUMBER
(Check one): (7) UNLIMITED CASE () LIMITED CASE
(Amount demanded (Amount demanded is $25,000 CGC-11-513645
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCGE is scheduled as follows:
Date: March 16, 2012 Time: 2:00 p.m. Dept: 610 Div.: Room:
Address of court (if different from the address above):
[__] Netice of Intent to Appear by Telephone, by (namo);
INSTRUCTIONS: All applicable boxes must be checked, and the specified Information must be provided.
1. Party or parties (answer one):
a. [7] This statement is submitted by party (nama): Defendants AT&T Comp. and Pacific Bell Telephone Company
b. [“] This statement is submitted jointly by parties (names):
a. The complaint was filed on (date):
b. [7] The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintifis and cross-complainants only)
a C) an parties named in the complaint and cross-complaint have bean served, have appeared, or have been dismissed.
b. (2) The following parties named in the complaint or cross-complaint
(1) [] have not been served (specify names and explain why nol):
Complaint and cross-complalint (to be answered by plaintiffs and cross-complainants only)
(2) [2] have been served but have not appeared and have not been dismissed (specify names):
(3) [J] have had a default entered against them (specify names):
c. []) The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
Description of case
termination in vialation of public policy and intentional infliction of emotional disiress.
a. Typeofcasein [¥} complaint [0] cross-compiaint (Describe, including causes of action):
Plaintiff alleges causes of action for race discrimination, disability discrimination, retaliation, fallure to engage in the inleractive process, wrongful
Pago tots
S< Form Adora fs Mandatory Use CASE MANAGEMENT STATEMENT Cay Rue of Cours
sq] CM-110 [Peev. judy 1, 2014} wit COUNTS. C8 Gor
www.accesslaw.com
PDF Page 4
CM-110
PLAINTIFF/PETITIONER: CYNTHIA SANDERS CASE NUMBER:
¢ CGC-11-513645
DEFENDANT/RESPONDENT: AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY
4. b. Provide a brief statement of the case, including any damages. (/f personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date findicate source and amount], estimated future medical expenses, last
samings to date, and estimated future iost earings. if equitable ralief is sought, describe the nature of the relief)
Please see altachmant 4{b).
C7] (if more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party of parties request (7) a jury trial C_) a nonjury trial. {#f more than one party, provide the name of aach party
requasting a jury trial):
6. Trial date
a. (_] The trial has been set for (date):
b. CZ) No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint {if
nol, explain): Thie case will net be ready for trial within 12 months as the proper Defendant entity has nol been named or served and no
discovery has been conducted.
c. Dates on which parties or attomeys will not be available for trial (specify dates and explain reasons for unavailability):
5/1/12 - 8/22/12 (trials and vacation): 8/27/12-9/7/12 (trial); 9/24/12-10/5/1 2itrial); 11/9/12-12/14/12 (trials);
1114/13-1731/13 (ital): 4/1 1/13-3/22/13 (trial)
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [Y) days (specify number): 7 days
b. [__] hours (short causes) (specify):
6. Trial representation (io be answered for each party)
The party or parties will be represented at trial [7] by the attorney or party listed in the caption [__] by the following:
a. Attomey:
b. Firm:
c. Address:
d. Telephone number: f Fax number.
6. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
9. Preference
([7] This case is entitled to praferance (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in differant 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 counse!: Counsel G7) tas [-) 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 L_] has [_} has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if availabie).
(1) [£2] This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 oF to civil action
mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2} ((_] Plaintiff elacts to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) (42) This case is sxempt from judicial arbitration under rule 3.811 of the Califomia Rules of Courtor from clvil action
mediation under Code of Civil Procedure section 1775 et seq. (Specify exemption):
Rule 3.611(b}(8)
CTO fae ay 7 20 CASE MANAGEMENT STATEMENT Pane 2oft
PDF Page 5
CM-110
PLAINTIFF/PETITIONER: CYNTHIA SANDERS
EFENDANT/RESPONDENT: AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY
CASE NUMBER:
CGC-11-513645
10. c. Indicate the ADR process cr processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check aif that apply and provide the specified information):
The party or parlies completing
this form are willing to
participate in the following ADR
processes (check ail 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 (atlach a copy of the parties‘ AOR
Stipulation):
(1) Mediation
wa
OW
Mediation session not yet scheduled
Mediation session scheduted for (date):
Agreed to complate mediation by (dasa):
Mediation completed on (dale):
(2) Settlement
conference
Settlement conference nol yet scheduled
Settlement conference scheduled for (date):
Agreed to complete settlement conferance by (date):
Settlement conference completed on (date):
(3) Neutral evaluation
Neutral evaluation not yet scheduled
Neutral evaiuation scheduled for (data):
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (daia):
(4) Nonbinding judicial
arbitration
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date);
Agreed to complete judicial arbitration by (data):
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):
(8) Other (specify):
UUUO;/OU0O;O000;O000/o000]o0
ADR session not yet scheduled
ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 Rev, duty 1.2019}
CASE MANAGEMENT STATEMENT
Page Sof 6
PDF Page 6
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: CYNTHIA SANDERS
CGC-11-513645
DEFENDANTIRESPONDENT: AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY
17. Insurance
a. (_] Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: {__] Yes ([_] No
c. (C_] 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.
(__] Bankruptcy [_} Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. [_] There ara companion, underlying, or related cases.
(1) Name of case:
(2) Narne of court:
(3) Gase number:
(4) Status:
[—] Additionat cases are described in Attachment 13a.
b. [-)Amotionto (7_) consolidate [[_] coordinate will be filed by (name party):
14, Bifurcation
[¥] The party or parties intend to file a motion for an order difurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
Defendants may move to bifurcate discovery, with the Initial phase dedicated to delermining the identity of Plaintiffs employer. Oefendants may
also move to bifurcate issues relating to liability and damages, if necessary,
15. Other motions
L7) The party or parties expact to file the following motions before tial (specify moving party, type of motion, and issues):
if Ptaintiff will not voluntarily dismiss Defendants AT&T Carp. and Pacific Bail Talephone Company, they will file dispositive motions on the
ground thal they did not employ Plaintiff. Additional motions are anticipated if tha proper employing enlity is added to the case.
16. Discovery
a. (__] The party or parties have completed all discovery.
b. G7) The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendants Discovery of evidence supporting Plaintiff's claim that Defendants employed her = April 2012
c. [42] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Additional discovery will be necessary if the proper employing entity is added to the case, including the Plaintiff's deposition, Request for
Production of Documents, and Interrogatories. Defendants will also seek a stipulated protective order.
CM-110 (Rew. Ausy 1, 2007)
CASE MANAGEMENT STATEMENT Page 4016
PDF Page 7
CM-110
PLAINTIFF/PETITIONER: CYNTHIA SANDERS CASE NUMBER.
— CGC-11-513845
DEFENDANT/RESPONDENT: AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY
17. Economic litigation
a. [_] This is a limited civil case (i.e., tha amount demanded is $25,000 or less) and the economic litigation procedures in Coda
of Civit Procedure sections 90-96 will apply to this case.
b. (__] 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 (#/ checked, expiain specifically why economic litigation procedures reiating to discovery or trial
should not apply to this case):
18. Other issues
C_] 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. [7] The party or parties have met and conferred with all parties on al! subjects required by rule 3.724 of the Califomia Rules
of Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the partias 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 resotution,
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: march 1, 2012
Noah Levin >
{TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY}
b
(TYPE OR PRINT NAME) (SIGNATURE CF PARTY OR ATTORNEY)
[1] Additional signatures are attached.
M90 ew ty 3.7017 CASE MANAGEMENT STATEMENT Page bors
PDF Page 8
MC-025
CASE NUMBER:
CGC-11-513645
ATTACHMENT (Number): 4(b)
(This Atachmeni may be used with any Judicial Council form.)
Plaintiff alleges the above-referenced causes of actions against Defendants AT&T Corp. and Pacific Bell
Telephone Company, neither of whom employed Plaintiff. Both further deny that they treated Plaintiff
unlawfully in any way and deny that Plaintiff is entitled to damages, in any amount, or at all. Counsel for
Defendants has repeatedly spoken with and provided evidence to Plaintiff's counsel demonstrating the identity
of Plaintiff's employer, but Plaintiff has not amended her Complaint to dismiss the improper parties or to
reflect the proper Defendant entity.
SHORT TITLE:
~~ Sanders v. AT&T, et al.
(if the itam that this Atachment concems is made under penalty of perjury, all statements in this Page of
Attachment are made under penalty of perjury.) (aad pages as a requiea) | ;
reason Cowen ot cairn ATTACHMENT wer antl ca gow
J
MC-O25 [Rev. aly 1, 2008) to Judicial Council Form
PDF Page 9
MILLER Law Groce
A PROFESSION AL Corona TEN
SAN FRANCISCO CALIFORNEA
oO a nN DP oO FF WwW KH =a
wy NM MW BY HM NM KM KD wD = =o mw Se ol UlUlcelUlUlUrlCl
ao vy PF A FF ONY B= FC DO DAN OAK DH BAS
ao
MP
PROOF OF SERVICE
I, Pamela A. Leonard, declare that | am employed at Miller Law Group, A
Professional Corporation, whose address is 111 Sutter Street, Suite 700, San Francisco, CA
94104; | am over the age of eighteen (18) years and am not a party to this action. On the
below date, by the method noted below, | served the following document(s):
DEFENDANTS AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY'S CASE
MANAGEMENT CONFERENCE STATEMENT
on the interested parties in this action by placing a true and correct copy thereof, enclosed
in a sealed envelope addressed as follows:
Spencer F. Smith, Esq. Attorney for Plaintiff: Cynthia Sanders
Dow W. Patten, Esq.
Law Offices of Spencer F. Smith
353 Sacramento Street, Suite 1120
San Francisco, CA 94111
Tel: (415) 520-6950
Fax: (415) 520-0104
() BY MAIL: By placing a true copy thereof enclosed in a sealed envelope with
postage thereon fully prepaid, in the ordinary course of business for collection and
mailing on this date at Miller Law Group, 111 Sutter Street, San Francisco, California.
| declare that | am readily familiar with the business practice of Miller Law Group for
collection and processing of correspondence for mailing with the United States Postal
Service and that the correspondence would be deposited with the United States
Postal Service that same day in the ordinary course of business.
XX) [State] | declare under penalty of perjury under the laws of the State of California that
the foregoing is true and correct.
Executed on March 1, 2012 at San Francisco, California.
go A. eid ,
1
PROOF OF SERVICE
San Francisco County Court Case No. CGC-11-513645
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