Shanel Dickson v. Kenny Griffin et al Document 13: Statement: Case Management Conference

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

Case Management Statement

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Page 1 220VSanta Clara —
Civil
CMHWming
ATTORNEY 0R PARTY WITHOUT ATTORN EY

FOR COURT USE ONLY
(Name, State Bar number, and address):
Kiran S. Lopez (SBN 252467)
TESLA’ 'NC901 Page Avenue
Fremont, CA TELEPHONE
No.:
FAX
(510) 239-
E—MAILADDRESS(Optiona/)=
ATTORNEY FOR(Name):
Electronically Filed
by Superior Court of CA,
County of Santa Clara,
on 6/1 3/2022 2:14 PM
Reviewed By: R. Fleming
case #chv
No.(0ptiona/):
kirlopez@tesla.com
Tesla, |nc_
SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F
Santa Clara
Envelope: 92031
STREET ADDRESS: 191 North First Street
MAILING ADDRESS:
CITY AND ZIP CODE:
BRANCH NAME:
San Jose, CA 951 Downtown Superior Court
PLAINTIFF/PETITIONER:
SHANEL D|CKSON
DEFENDANT/RESPONDENT:
m
(Check one):
TESLA INC ET AL
CASE MANAGEMENT STATEMENT
E
UNLIMITED CASE
(Amount demanded
exceeds $25,000)
A CASE MANAGEMENT CONFERENCE
Date:
Address of court
m
(if
different
b.
Dept:
2:15PM
Notice of Intent to Appear by Telephone, by (name):
m
E
E
E
E
Service
a.
b.
Room:
Div.:

All applicable
Kiran S_ Lopez
boxes must be checked, and the specified information must be provided.
This statement
is
submitted by party (name): Tesla
This statement
is
submitted jointly by parties (names):
(to
The
A|| parties
The
(2)
(3)
c.
E
cross—complaint,
if
any,
was
filed
on
Energy Operations,
Inc.
named
E
E
E
in
only)
only)
named
in
the complaint or cross-complaint
have not been served (specify names and explain why
not):
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
Description of case
Type 0f case in
Inc.
the complaint and cross—complaint have been served, or have appeared, or have been dismissed.
following parties
3-
and Tesla,
(date):
be answered by plaintiffs and cross-complainants
(1)
4.
scheduled as follows:
is
Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants
The complaint was filed on (date):
a.
b.
3.
220V
$25,
Party or parties (answer one):
a.
2.
is
from the address above):
INSTRUCTIONS:
1.
LIMITED CASE
(Amount demanded
or less)
Time:
June 21,
CASE NUMBER
may be added
(specify
names, nature of involvement
in case,
and
the date
by which
served):
complaint
E
cross-complaint
(Describe, including causes of action):
alleges causes of action for (1) Sexual and Racial Harassment (FEHA); (2) Gender and Race Discrimination (FEHA);
Prevent (FEHA); (4) Retaliation (FEHA); (5) Intentional Infliction of Emotional Distress; (6) Negligent Hiring,
Supervision, and/or Retention; and (7) Constructive Discharge in Violation of Public Policy.
Plaintiff
(3) Failure to
Page
Form Adopted
for
Mandatory Use
Judicial Council of California
CM-
[Rev. January
1,
2009]
CASE MANAGEMENT STATEMENT

of
Cal. Rules of Court,
rules
3720—
www.courtinfo.ca.gov
American LegaINet,
Inc.
www.FormsWorkflow.com
Page 2 CM-PLAINTIFF/PETITIONER:
CASENUMBER:
SHANEL DICKSON
220V
_DEFENDANT/RESPONDENT: TESLA’ INC
4.
Provide a brief statement of the case, including any damages. (prersonal injury damages are sought, specify the injury and
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.)
b.
damages
Plaintiff
alleges various causes of action related to her
employment
with Tesla, Inc. ("Tesla"). Tesla denies
of Plaintiff's
all
allegations.
E
5.
(If
more space
Jury or nonjury
The
needed, check
is
E
trial
party or parties request
requesting a jury
E
m
Trial
a.
b.
The trial has been set for (date):
No trial date has been set. This case
N/A as
N/A as
Estimated length of
The
a.
b-
8.
this
this
trial.
(If
USDC
to the
E
E
will
be ready
case was removed
will
for
trial
to the
not be available for
case was removed
more than one party, provide
the
name
of each party
for the
Northern
District of
CA on
March
17,
2022.
to the
within
USDC
trial
months ofthe date
for the
Northern
(specify dates
USDC
for the
and
of the filing of the complaint
District of
CA on
March
(if
17, 2022.
explain reasons for unavailability):
Northern
District of
CA on
March
17,
2022.
District of
CA on
trial
party or parties estimate that the
trial will
take (check one):
days (specify number):
hours (Short causes)
Trial representation (to
The
a nonjury
case was removed
this
Dates on which parties or attorneys
c.
E
trial
date
”0t, explain}:
7.
a jury
4b.)
trial):
N/A as
6.
box and attach a page designated as Attachment
this
party or parties
will
(SPeCifY)-'
N/A as this case was removed
March 17, 2022.
to the
USDC
for the
Northern
be answered for each party)
be represented
at
by the attorney or party
trial
listed in the
caption
E
by the
following:
Attorney:
Firm:
Address:
Telephone number:
corhsvgovsv
Fax number:
E-mail address:
E
E
.
9.
Party represented:
Additional representation
Preference
This case
10. Alternative
a.
Counsel
c.
CM-1
E
E
entitled to
m
E
2009]
the
have agreed
The case has gone
1,
in
Attachment
8.
preference (specify code section):
ADR options with
AII parties
[Rev. January
described
Dispute Resolution (ADR)
has
has not
reviewed
b.
is
is
to
to
an
provided the
ADR
information package identified
in rule
3.221 to the client and has
client.
a form ofADR.
ADR
ADR will
be completed by
(date).-
process (indicate status):
CASE MANAGEMENT STATEMENT
Page 2 of 4
Page 3 CM-PLAINTIFF/PETITIONER:
CASE NUMBER:
SHANEL D|CKSON
220V
—DEFENDANT/RESPONDENT: TESLA, INC,
E
E
E
E
E
E
E
The
10. d.
party or parties are willing to participate
(1)
(2)
(3)
(4)
(5)
(6)
(7)
E
E
E
e.
f.
g.
11.
E
(check
all
that apply):
judicial arbitration under Code of Civil Procedure section 1141 .12 (discovery to close 15 days before
under Cal. Rules of Court, rule 3.822)
Nonbinding
arbitration
under Code of
Procedure section 1141 .12 (discovery
Nonbinding
judicial arbitration
before
order required under Cal. Rules of Court, rule 3.822)
trial;
Civil
to
remain open
until
30 days
Binding judicial arbitration
Binding private arbitration
Neutral case evaluation
Other
(specify).-
This matter
is
the statutory
subject to mandatoryjudicial arbitration because the
amount
in
controversy does not exceed
limit.
case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Procedure section 1141 .1 1.
This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court (specify exemption):
Plaintiff elects to refer this
Civil
Settlement conference
The
party or parties are willing to participate
N/A as
12.
in
Mediation
E
E
case was removed
this
to the
an early settlement conference (specify when):
in
USDC
for the
Northern
District of
CA on
March
17,
2022.
Insurance
a.
Insurance
carrier,
if
E
Reservation ofrights:
b.
c.
Coverage issues
any, for party
filing this
E
Yes
will significantly
statement (name):
No
affect resolution of this
case
(explain):
13. Jurisdiction
E
Indicate
E
any matters
that
Bankruptcy
may
affect the court's jurisdiction or processing of this case,
and describe the
status.
Other(specify):
Status:
14.
E
Related cases, consolidation, and coordination
a.
There are companion, underlying, or related cases.
(2)
Name
Name
(3)
Case number:
(1)
E
E
b.
E
of case:
of court:
(4) Status:
Additional cases are described
A
motion to
E
in
consolidate
Attachment 14a.
E
coordinate
will
be
filed
by (name party):
15. Bifu rcation
The
N/A as
16.
file a motion for an order bifurcating, severing, or coordinating the
moving party, type of motion, and reasons):
party or parties intend to
action (specify
this
case was removed
to the
USDC
for the Northern District of
CA on
March
17,
following issues or
causes
of
2022.
Other motions
E
The
party or parties expect to
N/A as
CM-1
[Rev. January
this
1,
file
case was removed
2009]
the following motions before
to the
USDC
for the
trial
Northern
(specify
moving
District of
CASE MANAGEMENT STATEMENT
CA on
party, type of motion,
March
17,
and issues):
2022.
Page 3 of 4
Page 4 CM-PLAINTIFF/PETITIONER:
CASE NUMBER:
SHAN EL DICKSON
22CV
BEFENDANT/RESPONDENT: TESLA, INC.
17.
E
E
Discovery
a.
b.
The
party or parties
The
following discovery
have completed
will
all
discovery.
be completed by the date specified (describe
c.
E
a.
b.
19.
E
E
Economic
Date
USDC
to the
for the
Northern
CA on
District of
March
17,
2022.
on March
17,
2022.
following discovery issues are anticipated (specify):
NIA as
18.
case was removed
this
The
anticipated discovery):
Description
Party
N/A as
all
case was removed
this
to the
USDC
for the
Northern
District of
CA
litigation
This
is
of Civil
a limited civil case (i.e., the amount demanded
Procedure sections 90 through 98 wi|| apply to
is
$25,000 or
this
less)
and the economic
litigation
procedures
Code
in
case.
a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
wi|| be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
This
is
discovery
Other issues
The
party or parties request that the following additional matters be considered or determined at the case
management
conference (specify):
Closure of Superior Court case
20.
E
Meet and confer
The party
a.
of Court
NIA as
b.
this
After meeting
or parties
(if
of removal to
in light
have met and conferred with
all
USDC
parties
for the
on
all
Northern
District of
CA on
March
17,
2022.
subjects required by rule 3.724 of the California Rules
not, explain):
case was removed
to the
USDC
and conferring as required by
rule
for the Northern District of
CA on
March
17,
2022.
3.724 of the California Rules of Court, the parties agree on the following
(specify):
21. Total
|
am
number
of
pages attached
completely familiar with
this
(if
any):
case and
will
be
fully
prepared to discuss the status of discovery and ADR, 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
conference, including the written authority of the party where required.
Date:
June
13,

CM-1
[Rev. January
1,
2009]
J
/
Kiran S. Lopez
management
\

(TYPE
OR PRINT NAM E)
(TYPE
OR PRINT NAME)
(SIGNATURE OF PARTY OR ATTORNEY)
E
(SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CASE MANAGEMENT STATEMENT
Page 4 of
Page 5 PROOF OF SERVICE
I
declare that
I
am employed in the County 0f Alameda,
age 0f eighteen years and not a party to the within cause;
On the
Avenue, Fremont, California 94538.
State of California.
my business address is
date set forth below,
I
I
am
over the
901 Page
served the attached:
CASE MANAGEMENT STATEMENT
on the following
OONON
interested party(s) in said cause:
Moran (cmoranéflmaternlawgroup.com);
Corey Benjamin Bennett (cbennett(a)maternlaw2r0up.com)
Matthew Maters (mmatern@maternlawgr0up.com)
Clare
Matern Law Group, PC
1330 Broadway Suite
\O

Oakland,
[
]
VIA MAIL -- CCP
By placing
on
CA §1013(a), 2015.5:
a true copy thereof enclosed in a sealed envelope(s), addressed as above, and placing each for collection and mailing
that date following ordinary business practices.
I
am readily
familiar with
my firm’s business practice of collection and
processing of correspondence for mailing with the United States Postal Service and correspondence placed for collection and

mailing would be deposited With the United States Postal Service
same day
in the ordinary course
at
Fremont, California, With postage thereon fully prepaid, that
of business.
[

]
VIA OVERNIGHT MAIL/COURIER -- CCP
By placing
mail service or overnight courier service.

§1013(c), 2015.5:
a true copy thereof enclosed in a sealed envelope(s), addressed as above, and placing each for collection by overnight
I
am readily familiar with my firm’s business practice
of collection and processing of
correspondence for overnight mail or overnight courier service, and any correspondence placed for collection for overnight
delivery would, in the ordinary course 0f business, be delivered to an authorized courier or driver authorized

carrier to receive

[X]
documents, With delivery fees paid or provided
VIA E—MAIL
for, that
same day,
for delivery
by the overnight mail
on the following business day.
0R ELECTRONIC TRANSMISSION -- CCP §§1010.6,
1013(e), 2015.5,
CRC 2008:
Based on a court order or an agreement 0f the
documents

to
be sent
to the
persons
at the
parties to accept service
by e-mail 0r
e-mail addresses listed above.
I
electronic transmission,
I
caused the
did not receive, within a reasonable time afier the
transmission, any electronic message or other indication that the transmission
was unsuccessfiJl.
I
am readily familiar with my
firm’s business practice 0f processing and transmitting documents Via e-mail or electronic transmissi0n(s) and any such

documents would be transmitted
in the ordinary course
of business.
I
declare under penalty of perjury that the foregoing
is
true
and correct and
declaration
was executed 0n June
13,
2022,
at
San Francisco,
California.

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