Shanel Dickson v. Kenny Griffin et al Document 12: Statement: Case Management Conference

Superior Court of California, County of Santa Clara
Case No. 22CV393878
Filed June 13, 2022

HRG 6/21/22 Case Management Statement

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Page 1 220VSanta Clara —
Civil
CMRI flaming
0R PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
Joshua D. Boxer; Corey B. Bennett; Clare E. Moran (SBN:226712; 267816;340539)
Matern Law Group, PC
A'I'I'ORNEY
F°R
Electronically Filed
1230 Rosecrans Avenue Suite Manhattan Beach, CA
by SUpe rI o r court o f c A
County of Santa Clara,
on 6/1 3/2022 4:05 PM
Reviewed By: R. Fleming
-

TELEPH0NEN0.: (310)
E—MAILADDRESS:

531-
FAx Me.mptionao: (310)
531-
cmoran@maternIawgroup.com
ATTORNEY FOR(Name): Shanel Dickson
Case #22cv
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA
EnveloPe' .
STREETADDRESS: 191 North First Street
MAILING ADDRESS:
”WU“ °””
191 North First Street
CITY AND ZIP CODE:
San Jose 951 Downtown Superior Court
BRANCH NAME:
PLAINTIFF/PETITIONER: Shanel Dickson
DEFENDANT/RESPONDENT:
Tesla Energy Operations,
Inc. et al.
CASE MANAGEMENT STATEMENT
UNLIMITED CASE
(Amount demanded
(Check one):
|:|
exceeds $25,000)
Address of court
E
different
b.
b.
E
E
E
E
D
PM
Dept:
Room:
Div.:
All applicable
E.
Moran
boxes must be checked, and the specified information must be provided.
This statement
is
submitted by party (name): Shanel Dickson
This statement
is
submitted jointly by parties (names):
The complaint was
The
b.
The
(1)
(2)
(3)
c.
on
cross-complaint,
E
following parties
E
E
E
be answered by plaintiffs and cross-complainants
only)
(date):
if
any,
was
filed
on
(date):
Type
named
in
have been served but have not appeared and have not been dismissed (specify names):
have had a default entered against them (specify names):
The
following additional parties
they
may be
of
Plaintiff
case
in
the complaint or cross-complaint
have not been served (specify names and explain why not):
Description of case
a.
filed
(to
(to be answered by plaintiffs and cross-complainants only)
All parties named in the complaint and cross-complaint have been sewed, have appeared, or have been dismissed.
Service
a.
4.
$25,
from the address above):
Complaint and cross-complaint
a.
3.
is
Party or parties (answer one):
a.
2.
220V
scheduled as follows:
Notice of Intent to Appear by Telephone, by (name): Clare
INSTRUCTIONS:
1.
is
Time: 2:
(if
LIMITED CASE
(Amount demanded
or less)
A CASE MANAGEMENT CONFERENCE
Date: 06/21/
CASE NUMBER:
may be added
(specify
names, nature of involvement
in case,
and date by which
served):
E
complaint
E
cross-complaint
(Describe, including causes ofaction):
alleges sexual and racial harassment, gender and race discrimination, retaliation, failure to take steps necessary to
prevent harassment, discrimination, and/or
and/or retention and constructive discharge
retaliation, Intentional Infliction of
in violation
emotional distress, negligent
hiring,
Supervision,
of public policy.
Page
Form Adopted
for
Mandatory Use
Judicial Council of California
CM-1
[Rev.
September
1,
2021]
CASE MANAGEMENT STATEM ENT

of
Cal. Rules of Court,
rules
3120—
www.couns.ca.gov
Page 2 CM-PLAINTIFF/PETITIONER:
Shanel Dickson
DEFENDANT/RESPONDENT:
4.
CASE NUMBER:
Tesla Energy Operations,
220V
Inc. et aI.
Provide a brief statement of the case, including any damages. (prersonal injury damages are sought, specify the injwy and
claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
b.
damages
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
This is an individual complaint for discrimination, harassment, and retaliation. Plaintiff alleges that Defendants retaliated against
Plaintiff
punitive
E
5.
(If
and failed to prevent harassment, discrimination and retaliation,
damages, civil penalties, injunctive relief, and attorneys' fees
more space
Jury or nonjury
The
a jury
party or parties request
Plaintiff
seeks monetary,
box and attach a page designated as Attachment 4b.)
E
trial
a nonjury
trial.
(Ifmore than one party, provide the
name
of each party
trial):
date
Trial
a.
this
trial
requesting a jury
6.
needed, check
is
emotional distress.
inflicting
E
The
No
b.
trial
trial
has been setfor
date has been
(date):
set.
This case
will
be ready
for
within
trial
months
of the date of the
filing
of the complaint
(if
not, explain):
will not be available for trial (specify dates and explain reasons for unavailability):
10/24/22-1 1/04/22(tria|); 12/12-12/16/22(tria|);12/23-12/26/22(office closed); 12/30/22-01/02/23(office closed)
Dates on which parties or attorneys
c.
7.
Estimated length of
The
a.
b-
8.
party or parties estimate that the
E
a.
trial will
take (check one):
days (specify number): 7-10 days
hours (short causes) (specify):
Trial representation (to
The
9.
trial
party or parties
will
be answered
for
be represented
at
each party)
by the attorney or party
trial
listed in
the caption
E
by the following:
Attorney:
b.
Firm:
c.
Address:
d.
Telephone number:
e.
E-mailaddress:
E
E
Additional representation
is
described
in
Attachment
f.
Fax number:
g.
Party represented:
8.
Preference
This case
10. Alternative
a.
is
entitled to
preference (specify code section):
dispute resolution (ADR)
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 of the California Rules of Court for information about the
processes available through the court and community programs
has
For parties represented by counsel: Counsel
rule 3.221 to the client and reviewed ADR options with the
(1)
in
For self—represented parties: Party
(2)
b.
has
(2)
(3)
[Rev.
This matter
is
Code
of Civil
is
exempt from
mediation under
1,
2021]
ADR
information package identified
ADR
information package identified
in rule
3.221.
available).
Code of Civil Procedure section 1141 .11 or to civil action
Procedure section 1775.3 because the amount in controversy does not exceed the
case to
Procedure section 1141.11.
This case
September
(if
provided the
limit.
Plaintiff elects to refer this
Civil
has not
client.
subject to mandatoryjudicial arbitration under
mediation under
statutory
E
case.
has not reviewed the
Referral to judicial arbitration or civil action mediation
(1)
CM-1
E
E
E
E E
in this
Code
judicial arbitration
judicial arbitration
and agrees
to limit
recovery to the amount specified
under rule 3.811 of the California Rules of Court or from
1775 et seq. (specify exemption):
civil
in
Code
of
action
of Civil Procedure section
CASE MANAGEMENT STATEMENT
Page 2 °f5
Page 3 CM-PLAINTIFF/PETITIONER:
DEFENDANT/RESPONDENT:
10. C.
Indicate the
ADR
ShaneIDickson
CASE NUMBER:
Tesla Energy Operations,
220V
Inc. et aI.
process or processes that the party or parties are willing to participate
in (check all that apply and provide the specified information):
in,
have agreed
to participate
in,
or
have already participated
The
this
party or parties completing
form are willing to
participate in the following
processes (check
(
1 )
(2)
M e d'la
-
t'
Ion
E
settlement
conference
_
(3) Neutral evaluatlon
(4)
Nonbindingjudicial
arbitration
(5)
Binding private
arbitration
(6)
CM-1
Other
[Rev.
(specify):
September
all
1,
2021]
E
E
E
E
ADR
that apply):
in the case have agreed to
have already completed an ADR process or processes,
indicate the status of the processes (attach a copy of the parties'ADR
If
the party or parties completing this form
participate in or
stipulation):
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
Mediation session not yet scheduled
Mediation session scheduled for (date):
Agreed
to
complete mediation by(date):
Mediation completed on (date):
Settlement conference not yet scheduled
Settlement conference scheduled for(date):
Agreed
to
complete settlement conference by(date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
I
Agreed
to
complete neutral evaluatlon by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet
Judicial arbitration
Agreed
to
scheduled
scheduled for (date):
completejudicial arbitration by (date):
Judicial arbitration
completed on (date):
Private arbitration not yet scheduled
Private arbitration scheduled for
Agreed
to
complete private
(date):
arbitration
by (date):
Private arbitration completed on (date):
ADR session
ADR seSSIon
not yet scheduled
'
Agreed
to
sc h edu ed for (date)
complete
ADR completed
.'
|
on
ADR session
by (date):
(date):
CASE MANAGEMENT STATEMENT
Page 3 °f5
Page 4 CM-PLAINTIFF/PETITIONER:
DEFENDANT/RESPONDENT:
11.
CASE NUMBER:
Shanel Dickson
Tesla Energy Operations,
220V
Inc. et aI.
Insurance
a.
b.
c.
E
E
Insurance
Reservation of
carrier,
if
any, for party
E
rights:
Coverage issues
filing this
E
Yes
statement (name):
No
will significantly affect
resolution of this
case
(explain):
12. Jurisdiction
any matters
Indicate
E
that
may
affect the court's jurisdiction or processing of this
case and describe the
status.
Other (specify): This matter has been removed to federal court.
Bankruptcy
Status:
13.
Related cases, consolidation, and coordination
a.
E
There are companion, underlying, or related cases.
(2)
Name
Name
(3)
Case number:
(1)
of case:
of court:
(4) Status:
E
E
E
Additional cases are described
A
b.
motion to
E
in
Attachment 13a.
E
consolidate
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
15.
16.
moving party, type of motion, and reasons):
Other motions
E
The
party or parties expect to
file
the following motions before
trial
(specify
moving
party, type of motion,
and issues):
Discovery
a.
b.
E
m
The
party or parties have completed
The
following discovery
will
all
discovery.
be completed by the date specified (describe
all
anticipated discovery):
Date
Description
Party
Plaintiff
Written Discovery
September
Plaintiff
Depositions
September
Plaintiff
Expert Discovery
Per Code
c.
CM‘“°
E
[Rev-
The
following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated
Septembe’
“202”
(specify):
CASE MANAGEMENT STATEMENT
Pag°4°f5
Page 5 CM-PLAINTIFF/PETITIONER:
DEFENDANT/RESPONDENT:
17.
Economic
a.
b.
18.
19.
E
E
CASE NUMBER:
Shanel Dickson
Tesla Energy Operations,
22CV
Inc. et aI.
litigation
This
a limited
is
civil
case
(i.e.,
the
of Civil Procedure sections 90-
amount demanded
will
apply to
this
is
$25,000 or less) and the economic
litigation
procedures
in
Code
case.
civil case and a motion to withdraw the case from the economic litigation procedures or for additional
be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
This
a limited
is
discovery
will
Other issues
E
party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
The
Meet and confer
The
a.
party or parties have
met and conferred
with
all
parties
on
all
subjects required by rule 3.724 of the California Rules
0f Court (ifnot, explain):
b.
E
20. Total
After meeting
and conferring as required by
rule
3.724 of the California Rules of Court, the parties agree on the following
(specify):
number
of
pages attached
(if
any):
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: June 13,
Clare E. Moran
(TYPE
0R PRINT NAME)
(TYPE
OR PRINT NAME)
(SIGNATURE 0F PARTY 0R ATTORNEY)
D
CM-1
[Rev.
September
1,
2021]
E
(SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CASE MANAGEMENT STATEMENT
Page 5 of
Page 6 PROOF OF SERVICE
I am employed in the County of Los Angeles, State of California.
I am over the age 0f
eighteen (18) years and not a party t0 the Within action.
business address is 1230 Rosecrans
Ave, Suite 200 Manhattan Beach, California 90266.
My
A
On June
13,

I
served the document described
as:
CASE MANAGEMENT STATEMENT
QONUI
g
ONLY BY ELECTRONIC TRANSMISSION:
Pursuant to Emergencv Rule 12. Ee-mail
mailing the document(s) to the persons at the
address(es) listed below. During the
Coronavirus (COVID-19) pandemic, this office will be primarily working remotely, unable
to send physical mail as usual, and is therefore using only electronic mail.
Will assume
our email service was successful on the date of transmission unless we receive an electronic
message or other indication that the transmission was not received on that date.
We

Kiran
S.
Attorney for Defendants
Lopez, Esq.
TESLA

Tesla, Inc.
ENERGY OPERATIONS,
And TESLA, INC.

901 Page Avenue
Fremont, CA 9453 Telephone: (5 1 0) 239- 1 4 1 Email: kirlopez@tesla.com

CC: William Nervis

Azadeh Allayee, Esq.
Hennigh Law Corporation
INC.
wnervis@tesla.com

Attorney for Defendant
KENNY GRIFFIN
700 South Flower Street, Suite Los Angeles, CA Telephone: (213) 277-Email: azadeh.allavee@hennighlaw.com

I

true
and
declare under penalty of perjury under the laws of the State of California that the above
is
correct.
Executed on June
13,

at
South San Francisco, California.
MM 71L.
Mariana Toledo

PROOF OF SERVICE
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