Cynthia Sanders v. At&t et al Document 8: Case Management Statement

Filed January 12, 2012

Back to Cynthia Sanders v. At&t et al, Superior Court of California, County of San Francisco Case No. CGC-11-513645

Case Management Statement Filed By Defendant Pacific Bell Telephone Company At&t Corp Estimated Time For Trial: 7.0 Days

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Page 1 AMUN
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Jan-12-2012 10:49 am

Case Number: CGC-11-513645
Filing Date: Jan-12-2012 10:48
Juke Box: 001 Image: 03450261
CASE MANAGEMENT STATEMENT
Pre ree en a ce one tee

CYNTHIA SANDERS VS. AT&T et al
001003450261
Instructions:
Piease place this sheet on top of the document to be scanned.

Page 2 “FO
be
ot
J
4
ees.
CM-110

ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
Katherine L. Kettler (SBN 231586)/Noah Levin (SBN 263069)
Miller Law Group
411 Sutter Street, Suite 700
San Francisco, CA 94104
TELEPHONE NO.: 415-464-4300 FAX NO, (Optional): 44 5.464-4366
E-Mail ADDRESS (Options: kik @millerlawgroup.com; nal@millerlawgroup.com
ATTORNEY FOR (Name): Defendants AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY
F |

SUPERIOR COURT OF CALIFORNIA, COUNTY OF saw FRANCISCO
STREET ADDRESS: 400 McAllister Street
MAILING ADDRESS:
CITY AND 2iP COOE: San Francisco 94102
BRANCH NAME:
CLERK
BY:

PLAINTIFF/PETITIONER: CYNTHIA SANDERS
DEFENDANT/RESPONDENT: AT&T; AT&T CORP.; PACIFIC BELL TELEPHONE COMPANY
San Francisco County Scparion Scr
JAN En?

FOR COURT USE ONLY
wy
= agit Baa?
THE COURT
Diouty car

CASE MANAGEMENT STATEMENT
C7] UNLIMITED CASE L_] LIMITED CASE
{Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
(Check one):
CASE NUMBER:

CGC-11-513645

A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Time: 9-90 a.m. Dept.: g10
Address of court (if different from the address above):
Date: January 27, 2012
[__] Notice of intent to Appear by Telephone, by (name):
Dw.
Room:

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): Defendants AT&T Corp. and Pacific Bell Telephone Gampany
b. [__] This statement is submitted jointly by parties (names):
a. The complaint was filed on (date):
b. L_] The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
Complaint and cross-complaint (fo be answered by plaintiffs and cross-complainants only)
a. C_] al parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [__] The following parties named in the complaint or cross-complaint
(1) (1 have not been served (specify names and explain why not):
(2) [_] have been served but have not appeared and have not been dismissed (specify names):
(3) [_] have nad a default entered against them (specify names):
c. L_] 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. Typeofcasein [¥] complaint [__] cross-complaint
(Describe, incgiuding causes of action):
Plaintiff alleges causes of action for race discrimination, disability discrimination, retaliation, failure to engage in the interactive process, wrongful
termination in violation of public policy and intentional infliction of emotional distress.

CM-110 Rav. July 1, 2044]
Page tof 5
Foam {rcaptedt for Manaalory Use CASE MANAGEMENT STATEMENT Cay Rules of Court
www.courls.c@. gov
www.accessiaw.com

Page 3 CM-110

PLAINTIFF/PETITIONER: CYNTHIA SANDERS CASE NUMBER:
DEFENDANT/RESPONDENT. atat; AT&T CORP.: PACIFIC BELL TELEPHONE COMPANY
CGC-11-513645

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 amount], estimated future medical expenses, fost
earings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief)
Please see attachment 4(b).
LY] (ifmore space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request La jury trial [Ja nonjury trial. (if more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. [__] The trial has been set for (date):
b. [4] 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
not, explain}: This case will not be ready for trial within 12 months as the proper Defendant entity has not been named or served and no
discovery has been conducted,
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
5/412 - 7/31/12 (mulliple trials and vacation); 8/27/12-9/7/12 (trial); 9/24/12-10/5/12 (trial): 11/9/12-12/14/12 (trials); and 4/14/13-1/31/13 (trial)
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a Lv] days (specify number): 7 days
b. [_] hours (short causes} (specify):
8. Trial representation (to be answered for each party}
The party or parties will be represented at tral LY] by the attorney or party listed in the caption [__] by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number.
e. E-mail address: g. Party represented:
[__] Additional representation is described in Attachment 8.
9. Preference
i__] 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 [¥7 has CL] hasnot 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 LJ 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) (__] 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 Procadure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(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 1141.11.
(3) [G7] 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):
Rule 3.81 1(b)(8)
CM-110 [Rey July 1.2044] CASE MANAGEMENT STATEMENT Page 2018

Page 4 f
CM-110

PLAINTIFF/PETITIONER: CYNTHIA SANDERS
DEFENDANT/RESPONDENT: AT&T; AT&T CORP.; PACIFIC BELL TELEPHONE COMPANY

CASE NUMBER.
CGC-11-513645

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 aif that apply and provide the specified information):

The party or parties 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 (atfach 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 evaiuation
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):

UUOUU;)UOOUU;/O000;/OO000;/O000 0008
AOR session not yet scheduled
ADR session scheduled for (dafe):
Agreed to complete ADR session by (date):
ADR completed on (date):

CM-110 (Rev. July 1, 2011]
Page 3of 6
CASE MANAGEMENT STATEMENT

Page 5 CM-110

PLAINTIFF/PETITIONER: CYNTHIA SANDERS CASE NUMBER
DEFENDANT/RESPONDENT: AT&T: AT&T CORP.; PACIFIC BELL TELEPHONE COMPANY
CGC-11-513645

11. Insurance
a. [__] Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: CL] Yes [__] No
c. [__] Coverage issues will significantly affect resolutian of this case (expiain):
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 are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
[__] Additional cases are described in Attachment 13a.
b. [Ll Amotionto [_] consolidate [__] coordinate will be filed by (name party):
14. Bifurcation
[v1 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):
Defendants may move to bifurcate discovery, with the initial phase dedicated lo determining the identity of Plaintiffs employer. Defendants may
also move to bifurcate issues relating to liability and damages, if necessary.
15. Other motions
[7] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues).
if Plaintiff will not voluntarity dismiss Defendants AT&T Corp. and Pacific Bell Telephone Company they will file dispositive motions on the
ground that they did not employ Plaintiff, Additional motions are anticipated if the proper employing entity is added to the case.
16. Discovery
a. [_"] The party or parties have completed all discovery.
b. [7] The following discovery will be completed by the date specified (describe ail anticipated discovery):
Party Desegriptign Date
Defendants Discovery of evidence supporting Plaintiff's claim thal Defendants employed ber = March 2012
c. [2] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Additionat discovery will ba necassary if the proper employing entity is added to the case, including the Plaintiffs deposition, Request for
Production of Documents, and interrogatories. Defendants will also seek a stipulated protective order.

C110 Rev. Jay 1. 2041) CASE MANAGEMENT STATEMENT Page dors

Page 6 CM-110

PLAINTIFF/PETITIONER: CYNTHIA SANDERS CASE NUMBER:
~ CGC-11-513645
DEFENDANT/RESPONDENT: AT&T, AT&T CORP.; PACIFIC BELL TELEPHONE COMPANY

17. Economic litigation
a. __] 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. L_] 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
(] The party or parties request that the following additionat matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a. Ly] 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 ruie 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any): 1
lam completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as weil as oiher issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case Wiz) conference, including the written authority of the party where reqyired,.
Date: \2/20 f2.

—
(TYPE OR PRINT NAME} [ (SIGNATURE OF PARTY GR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
[__] Additional signatures are attached.

CM N10 few dy 1 2014 CASE MANAGEMENT STATEMENT Page Sor

Page 7 MC-025

SHORT TITLE: CASE NUMBER:
' Sanders v. AT&T, et al. CGC-11-513645
ATTACHMENT (Number): 4(b)
(This Attachment may be used with any Judicial! Council form.)
Plaintiff alleges the above referenced causes of actions against Defendants AT&T Corp. and Pacific Beil
Telephone Company, neither of whom employed Plaintiff. Both further deny that they treated Plainuff
unlawfully in anyway 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.

(if the item thal this Aflachment concems is made under penalty of perjury, all statements in this Page of
Attachment are made under penalty of perjury.) .
(Add pages as required)
"emcee Bana ATTACHMENT rn i cae
MC-025 [Rew Juty 1, 2009] te Judicial Council Form

Page 8 MULLER Law Groupe
A PROFESSLON 41 CORPORATION
San PRANGISCO, CALIFORNIA
Oo @©om NAN Dm FO FF &D NH =
NM NM AO fh OUNlUNMhlUNDlUlUNDlUlUNDll Sl Sl eee ea a ea ei ks
oO NN OO om FB GO HB = OF Ob ON Do BF HD | = GS
PROOF OF SERVICE
|, Natalie Young, 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):
CASE MANAGEMENT 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 January 12, 2012 at San Francisco, California.
“h). YOLUI
Natalie Young C)

1

PROOF OF SERVICE
San Francisco County Court Case No. CGC-11-513645

PDF Page 1	PlainSite Cover Page

PDF Page 2	AMUN SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Jan-12-2012 10:49 am Case Number: CGC-11-513645 Filing Date: Jan-12-2012 10:48 Juke Box: 001 Image: 03450261 CASE MANAGEMENT STATEMENT Pre ree en a ce one tee CYNTHIA SANDERS VS. AT&T et al 001003450261 Instructions: Piease place this sheet on top of the document to be scanned.

PDF Page 3	“FO be ot J 4 ees. CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Katherine L. Kettler (SBN 231586)/Noah Levin (SBN 263069) Miller Law Group 411 Sutter Street, Suite 700 San Francisco, CA 94104 TELEPHONE NO.: 415-464-4300 FAX NO, (Optional): 44 5.464-4366 E-Mail ADDRESS (Options: kik @millerlawgroup.com; nal@millerlawgroup.com ATTORNEY FOR (Name): Defendants AT&T CORP. and PACIFIC BELL TELEPHONE COMPANY F \| SUPERIOR COURT OF CALIFORNIA, COUNTY OF saw FRANCISCO STREET ADDRESS: 400 McAllister Street MAILING ADDRESS: CITY AND 2iP COOE: San Francisco 94102 BRANCH NAME: CLERK BY: PLAINTIFF/PETITIONER: CYNTHIA SANDERS DEFENDANT/RESPONDENT: AT&T; AT&T CORP.; PACIFIC BELL TELEPHONE COMPANY San Francisco County Scparion Scr JAN En? FOR COURT USE ONLY wy = agit Baa? THE COURT Diouty car CASE MANAGEMENT STATEMENT C7] UNLIMITED CASE L_] LIMITED CASE {Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) (Check one): CASE NUMBER: CGC-11-513645 A CASE MANAGEMENT CONFERENCE is scheduled as follows: Time: 9-90 a.m. Dept.: g10 Address of court (if different from the address above): Date: January 27, 2012 [__] Notice of intent to Appear by Telephone, by (name): Dw. Room: 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): Defendants AT&T Corp. and Pacific Bell Telephone Gampany b. [__] This statement is submitted jointly by parties (names): a. The complaint was filed on (date): b. L_] The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) Complaint and cross-complaint (fo be answered by plaintiffs and cross-complainants only) a. C_] al parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [__] The following parties named in the complaint or cross-complaint (1) (1 have not been served (specify names and explain why not): (2) [_] have been served but have not appeared and have not been dismissed (specify names): (3) [_] have nad a default entered against them (specify names): c. L_] 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. Typeofcasein [¥] complaint [__] cross-complaint (Describe, incgiuding causes of action): Plaintiff alleges causes of action for race discrimination, disability discrimination, retaliation, failure to engage in the interactive process, wrongful termination in violation of public policy and intentional infliction of emotional distress. CM-110 Rav. July 1, 2044] Page tof 5 Foam {rcaptedt for Manaalory Use CASE MANAGEMENT STATEMENT Cay Rules of Court www.courls.c@. gov www.accessiaw.com

PDF Page 4	CM-110 PLAINTIFF/PETITIONER: CYNTHIA SANDERS CASE NUMBER: DEFENDANT/RESPONDENT. atat; AT&T CORP.: PACIFIC BELL TELEPHONE COMPANY CGC-11-513645 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 amount], estimated future medical expenses, fost earings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief) Please see attachment 4(b). LY] (ifmore space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request La jury trial [Ja nonjury trial. (if more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. [__] The trial has been set for (date): b. [4] 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 not, explain}: This case will not be ready for trial within 12 months as the proper Defendant entity has not been named or served and no discovery has been conducted, c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 5/412 - 7/31/12 (mulliple trials and vacation); 8/27/12-9/7/12 (trial); 9/24/12-10/5/12 (trial): 11/9/12-12/14/12 (trials); and 4/14/13-1/31/13 (trial) 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a Lv] days (specify number): 7 days b. [_] hours (short causes} (specify): 8. Trial representation (to be answered for each party} The party or parties will be represented at tral LY] by the attorney or party listed in the caption [__] by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number. e. E-mail address: g. Party represented: [__] Additional representation is described in Attachment 8. 9. Preference i__] 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 [¥7 has CL] hasnot 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 LJ 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) (__] 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 Procadure section 1775.3 because the amount in controversy does not exceed the statutory limit. (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 1141.11. (3) [G7] 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): Rule 3.81 1(b)(8) CM-110 [Rey July 1.2044] CASE MANAGEMENT STATEMENT Page 2018

PDF Page 5	f CM-110 PLAINTIFF/PETITIONER: CYNTHIA SANDERS DEFENDANT/RESPONDENT: AT&T; AT&T CORP.; PACIFIC BELL TELEPHONE COMPANY CASE NUMBER. CGC-11-513645 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 aif that apply and provide the specified information): The party or parties 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 (atfach 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 evaiuation 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): UUOUU;)UOOUU;/O000;/OO000;/O000 0008 AOR session not yet scheduled ADR session scheduled for (dafe): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 (Rev. July 1, 2011] Page 3of 6 CASE MANAGEMENT STATEMENT

PDF Page 6	CM-110 PLAINTIFF/PETITIONER: CYNTHIA SANDERS CASE NUMBER DEFENDANT/RESPONDENT: AT&T: AT&T CORP.; PACIFIC BELL TELEPHONE COMPANY CGC-11-513645 11. Insurance a. [__] Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: CL] Yes [__] No c. [__] Coverage issues will significantly affect resolutian of this case (expiain): 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 are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: [__] Additional cases are described in Attachment 13a. b. [Ll Amotionto [_] consolidate [__] coordinate will be filed by (name party): 14. Bifurcation [v1 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): Defendants may move to bifurcate discovery, with the initial phase dedicated lo determining the identity of Plaintiffs employer. Defendants may also move to bifurcate issues relating to liability and damages, if necessary. 15. Other motions [7] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues). if Plaintiff will not voluntarity dismiss Defendants AT&T Corp. and Pacific Bell Telephone Company they will file dispositive motions on the ground that they did not employ Plaintiff, Additional motions are anticipated if the proper employing entity is added to the case. 16. Discovery a. [_"] The party or parties have completed all discovery. b. [7] The following discovery will be completed by the date specified (describe ail anticipated discovery): Party Desegriptign Date Defendants Discovery of evidence supporting Plaintiff's claim thal Defendants employed ber = March 2012 c. [2] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): Additionat discovery will ba necassary if the proper employing entity is added to the case, including the Plaintiffs deposition, Request for Production of Documents, and interrogatories. Defendants will also seek a stipulated protective order. C110 Rev. Jay 1. 2041) CASE MANAGEMENT STATEMENT Page dors

PDF Page 7	CM-110 PLAINTIFF/PETITIONER: CYNTHIA SANDERS CASE NUMBER: ~ CGC-11-513645 DEFENDANT/RESPONDENT: AT&T, AT&T CORP.; PACIFIC BELL TELEPHONE COMPANY 17. Economic litigation a. __] 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. L_] 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 (] The party or parties request that the following additionat matters be considered or determined at the case management conference (specify): 19. Meet and confer a. Ly] 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 ruie 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 1 lam completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as weil as oiher issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case Wiz) conference, including the written authority of the party where reqyired,. Date: \2/20 f2. — (TYPE OR PRINT NAME} [ (SIGNATURE OF PARTY GR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) [__] Additional signatures are attached. CM N10 few dy 1 2014 CASE MANAGEMENT STATEMENT Page Sor

PDF Page 8	MC-025 SHORT TITLE: CASE NUMBER: ' Sanders v. AT&T, et al. CGC-11-513645 ATTACHMENT (Number): 4(b) (This Attachment may be used with any Judicial! Council form.) Plaintiff alleges the above referenced causes of actions against Defendants AT&T Corp. and Pacific Beil Telephone Company, neither of whom employed Plaintiff. Both further deny that they treated Plainuff unlawfully in anyway 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. (if the item thal this Aflachment concems is made under penalty of perjury, all statements in this Page of Attachment are made under penalty of perjury.) . (Add pages as required) "emcee Bana ATTACHMENT rn i cae MC-025 [Rew Juty 1, 2009] te Judicial Council Form

PDF Page 9	MULLER Law Groupe A PROFESSLON 41 CORPORATION San PRANGISCO, CALIFORNIA Oo @©om NAN Dm FO FF &D NH = NM NM AO fh OUNlUNMhlUNDlUlUNDlUlUNDll Sl Sl eee ea a ea ei ks oO NN OO om FB GO HB = OF Ob ON Do BF HD \| = GS PROOF OF SERVICE \|, Natalie Young, 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): CASE MANAGEMENT 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 January 12, 2012 at San Francisco, California. “h). YOLUI Natalie Young C) 1 PROOF OF SERVICE San Francisco County Court Case No. CGC-11-513645


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