MOTION to Stay All Proceedings filed by Tesla, Inc.. Motion Hearing set for 2/1/2024 10:00 AM in San Francisco, Courtroom 08, 19th Floor before Judge Jacqueline Scott Corley. Responses due by 12/28/2023. Replies due by 1/4/2024. DEFENDANT TESLA, INC.'S NOTICE OF MOTION AND MOTION TO STAY ALL PROCEEDINGS IN LIGHT OF LONG-RUNNING, CURRENTLY PENDING AND VIRTUALLY IDENTICAL STATE COURT LITIGATION; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF (Attachments: # (1) Declaration of Sara Begley ISO, # (2) Declaration of Tiffany Hart ISO, # (3) Declaration of Thomas Hill ISO, # (4) Declaration of Jessica Quon-Vaili ISO, # (5) Request for Judicial Notice ISO, # (6) Exhibit List, # (7) Exhibit A, # (8) Exhibit B, # (9) Exhibit C, # (10) Exhibit D, # (11) Exhibit E, # (12) Exhibit F, # (13) Exhibit G, # (14) Exhibit H, # (15) Exhibit I, # (16) Exhibit J, # (17) Exhibit K, # (18) Exhibit L, # (19) Exhibit M, # (20) Exhibit N, # (21) Exhibit O, # (22) Exhibit P, # (23) Exhibit Q, # (24) Exhibit R, # (25) Exhibit S, # (26) Proposed Order)(Hill, Thomas) (Filed on 12/18/2023) Modified Text on 12/19/2023 (krp, COURT STAFF).
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Exhibit
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Case 2:21-Oad’ 6823 3F04884-Serubeot GEM 22124 1EABYAL/IBAGS IRaig> Aaige ID #:1003
EXHIBIT
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U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Los Angeles District Office 255 E. Temple Street, 4th Floor Los Angeles, CA 90012 Intake Information Group: (800) 669-4000 Intake Information Group TTY: (800) 669-6820 Los Angeles Direct Dial: (213) 785-3090 FAX (213) 894-1118 Website: www.eeoc.gov
July 12, 2021 SENT VIA ELECTRONIC MAIL Elena R Baca Paul Hastings, LLP Employment Law Dept.
515 South Flower Street Twenty-Fifth Floor Los Angeles, Ca 90071 elenabaca@paulhastings.com Re: Feldblum v. Activision Blizzard, Inc., EEOC Charge No. 480-2018-05212 Dear Ms. Baca:
This letter serves to follow up on the matter regarding Feldblum v. Activision Blizzard, Inc., EEOC Charge No. 480-2018-05212 (Commissioners Charge) and Kish v. Blizzard Entertainment, et al., DFEH Case No. 201810-03875512, EEOC Charge No. 37A-2019-00053-C (Directors Complaint).
As you are aware, the United States Equal Employment Opportunity Commission (EEOC or Commission) filed a Commissioners Charge against Respondents on September 26, 2018. The California Department of Fair Employment and Housing (DFEH) filed a Directors Complaint on October 12, 2018 (later amended on October 29, 2018) with similar and overlapping allegations.
It is my understanding that you were asked by DFEH to reach out to me to discuss the matter. Specifically, you asked about interrelationship between the EEOCs Commissioners Charge and the DFEH Directors Charge which cover the same claims, bases and issues. You have reasonably asked the two agencies to coordinate and to respond to your question. As discussed, where there are duplicate charges filed with our respective agencies, typically the agency that first receives the charge handles the investigation. We also discussed that this was an unusual circumstance, involving an EEOC Commissioners Charge and a DFEH Directors Complaint. Pursuant to discussions between the EEOC and DFEH regarding how to handle the overlapping Commissioners Charge and Directors Complaint, our agencies agreed that pursuant to the EEOC-DFEH Worksharing Agreement and past practices, and in the spirit of cooperation, it would be in the best interest of both agencies to conduct a joint investigation of the case.
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The two agencies did agree to address the duplication of effort raised in these two investigations in the following manner: The EEOC and DFEH agreed that the EEOC would investigate the harassment allegations and related claims and DFEH would investigate allegations of pay, promotion, hiring assignment, transfer, training demotion, and termination. DFEH specifically agreed not to investigate the sexual harassment related claims. As our Letter of Determination indicates, we have proceeded on the sexual harassment related claims. It is our understanding that DFEH had already disclosed the arrangement between the agencies early in the investigation.
We have reached out to DFEH and we will continue to do so to coordinate efforts. We hope to get some further clarity from the DFEH and expect to have a response soon.
Sincerely,
Rosa M. Viramontes District Director EEOC Los Angeles District Office
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 3:23-cv-04984-JSC Document 22-23 Filed 12/18/23 Page 1 of 4
Exhibit
PDF Page 3
Case 2:21-Oad’ 6823 3F04884-Serubeot GEM 22124 1EABYAL/IBAGS IRaig> Aaige ID #:1003
EXHIBIT
PDF Page 4
Case 3:23-cv-04984-JSC Document 22-23 Filed 12/18/23 Page 3 of 4
U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Los Angeles District Office
255 E. Temple Street, 4th Floor
Los Angeles, CA 90012
Intake Information Group: (800) 669-4000
Intake Information Group TTY: (800) 669-6820
Los Angeles Direct Dial: (213) 785-3090
FAX (213) 894-1118
Website: www.eeoc.gov
July 12, 2021
SENT VIA ELECTRONIC MAIL
Elena R Baca
Paul Hastings, LLP Employment Law Dept.
515 South Flower Street
Twenty-Fifth Floor
Los Angeles, Ca 90071
elenabaca@paulhastings.com
Re: Feldblum v. Activision Blizzard, Inc., EEOC Charge No. 480-2018-05212
Dear Ms. Baca:
This letter serves to follow up on the matter regarding Feldblum v. Activision Blizzard,
Inc., EEOC Charge No. 480-2018-05212 (Commissioners Charge) and Kish v. Blizzard
Entertainment, et al., DFEH Case No. 201810-03875512, EEOC Charge No. 37A-2019-00053-C
(Directors Complaint).
As you are aware, the United States Equal Employment Opportunity Commission
(EEOC or Commission) filed a Commissioners Charge against Respondents on September
26, 2018. The California Department of Fair Employment and Housing (DFEH) filed a
Directors Complaint on October 12, 2018 (later amended on October 29, 2018) with similar and
overlapping allegations.
It is my understanding that you were asked by DFEH to reach out to me to discuss the
matter. Specifically, you asked about interrelationship between the EEOCs Commissioners
Charge and the DFEH Directors Charge which cover the same claims, bases and issues. You
have reasonably asked the two agencies to coordinate and to respond to your question.
As discussed, where there are duplicate charges filed with our respective agencies,
typically the agency that first receives the charge handles the investigation. We also discussed
that this was an unusual circumstance, involving an EEOC Commissioners Charge and a DFEH
Directors Complaint. Pursuant to discussions between the EEOC and DFEH regarding how to
handle the overlapping Commissioners Charge and Directors Complaint, our agencies agreed
that pursuant to the EEOC-DFEH Worksharing Agreement and past practices, and in the spirit of
cooperation, it would be in the best interest of both agencies to conduct a joint investigation of
the case.
PDF Page 5
Case 3:23-cv-04984-JSC Document 22-23 Filed 12/18/23 Page 4 of 4
The two agencies did agree to address the duplication of effort raised in these two
investigations in the following manner: The EEOC and DFEH agreed that the EEOC would
investigate the harassment allegations and related claims and DFEH would investigate
allegations of pay, promotion, hiring assignment, transfer, training demotion, and termination.
DFEH specifically agreed not to investigate the sexual harassment related claims. As our Letter
of Determination indicates, we have proceeded on the sexual harassment related claims. It is our
understanding that DFEH had already disclosed the arrangement between the agencies early in
the investigation.
We have reached out to DFEH and we will continue to do so to coordinate efforts. We
hope to get some further clarity from the DFEH and expect to have a response soon.
Sincerely,
Rosa M. Viramontes
District Director
EEOC Los Angeles District Office
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