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  • Coulombe, Julie vs Butte County Probation(15) Unlimited Other Employment document preview
  • Coulombe, Julie vs Butte County Probation(15) Unlimited Other Employment document preview
  • Coulombe, Julie vs Butte County Probation(15) Unlimited Other Employment document preview
  • Coulombe, Julie vs Butte County Probation(15) Unlimited Other Employment document preview
  • Coulombe, Julie vs Butte County Probation(15) Unlimited Other Employment document preview
  • Coulombe, Julie vs Butte County Probation(15) Unlimited Other Employment document preview
  • Coulombe, Julie vs Butte County Probation(15) Unlimited Other Employment document preview
  • Coulombe, Julie vs Butte County Probation(15) Unlimited Other Employment document preview
						
                                

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CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY William E Carny, SBN 291397 PORTER SCOTT 350 University Avenue, Suite 200, Sacramento, CA 95825 (916) 929-1481 TELEPHONE NO.: FAX NO. (Optional): 3/17/2022 shoran@porterscott.com; wcamy@porterscott.com E-MAIL ADDRESS (Optional): ATTORNEY FOR (Name): Defendant COUNTY OF BUTTE SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE STREET ADDRESS: 1775 Concord Ave MAILING ADDRESS: 1775 Concord Ave CITY AND ZIP CODE: Chico, CA 95928 BRANCH NAME: Civil PLAINTIFF/PETITIONER: Julie Coulombe DEFENDANT/RESPONDENT: County of Butte CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): w UNLIMITED CASE D LIMITED CASE 18CV02884 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: April 1, 2022 Time: 1:30 pm Dept.: TBD Div.: Room: Address of court (if different from the address above): w Notice of Intent to Appear by Telephone, by (name): William E. Carny INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. [ZJ This statement is submitted by party (name): County of Butte b. D This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. D The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. D All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. D The following parties named in the complaint or cross-complaint (1) D have not been served (specify names and explain why not): (2) D have been served but have not appeared and have not been dismissed (specify names): (3) D have had a default entered against them (specify names): c. D 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. Type of case in complaint D cross-complaint (Describe, including causes of action): Plaintiff alleges causes of action under the FEHA for discrimination, harassment, retaliation, and failure to prevent. Page 1 of 5 Form Adopted for Mandatory Use Judicial Council of California CASE MANAGEMENT STATEMENT Cal. Rules of Court, rules 3.720–3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Julie Coulombe 18CV02884 DEFENDANT/RESPONDENT: County of Butte 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, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff was a probation officer for Defendant. She alleges a co-worker harassed her due to her gender. She alleges she complained to Defendant about an incident involving harassment and Defendant retaliated against her by not giving her promotions or other job opportunities. Defendant denies her claims. D (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request [ZJ a jury triaI D a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. D The trial has been set for (date): b. [L] 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): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 5/2/22; 5/18/2022/5/21/22; 5/23/22; 6/26/22; 7/1-8/22; 8/11-14/22; 8/29/22; 9/26/22; 11/7/22; 11/14/22; 1/9/23; 1/23/23; 2/27/23; 4/3/23; 4/10/23, 8/1-9/23 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [ZJ days (specify number): 8-10 days b. D hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the captionD by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: D Additional representation is described in Attachment 8. 9. Preference D 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 w has D 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: PartyD has D has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) D 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 Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) D 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) D This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Julie Coulombe - 18CV02884 DEFENDANT/RESPONDENT: County of Butte 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 all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): CJ Mediation session not yet scheduled [Z] [Z] Mediation session scheduled for (date): June 29, 2022 (1) Mediation CJ Agreed to complete mediation by (date): CJ Mediation completed on (date): [Z] Settlement conference not yet scheduled (2) Settlement [Z] CJ Settlement conference scheduled for (date): conference CJ Agreed to complete settlement conference by (date): CJ Settlement conference completed on (date): CJ Neutral evaluation not yet scheduled CJ CJ Neutral evaluation scheduled for (date): (3) Neutral evaluation CJ Agreed to complete neutral evaluation by (date): CJ Neutral evaluation completed on (date): CJ Judicial arbitration not yet scheduled (4) Nonbinding judicial CJ CJ Judicial arbitration scheduled for (date): arbitration CJ Agreed to complete judicial arbitration by (date): CJ Judicial arbitration completed on (date): CJ Private arbitration not yet scheduled (5) Binding private CJ CJ Private arbitration scheduled for (date): arbitration CJ Agreed to complete private arbitration by (date): CJ Private arbitration completed on (date): CJ ADR session not yet scheduled CJ CJ ADR session scheduled for (date): (6) Other (specify): CJ Agreed to complete ADR session by (date): CJ ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Julie Coulombe 18CV02884 DEFENDANT/RESPONDENT: County of Butte 11. Insurance a. D Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: D Yes D No c. D 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. D Bankruptcy D Other (specify): Status: 13. Related cases, consolidation, and coordination a. D There are companion, underlying, or related cases. (1) Name of case: Julie Coulombe v. County of Butte, PSI, adm. by York Risk Services Group (2) Name of court: Workers' Compensation Appeals Board of the State of California (3) Case number: ADJ11176324 (4) Status: Believed to be closed D Additional cases are described in Attachment 13a. b. D A motion to D consolidate D coordinate wiII be filed by (name party): 14. Bifurcation D 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): 15. Other motions [ZJ The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Defendant filed a Motion for Summary Judgment which is pending the Court's ruling. 16. Discovery a. D The party or parties have completed all discovery. b. m The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendants Written Discovery July 2022 Defendants Depositions October 2022 Defendants Expert Discovery Per Code c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Julie Coulombe 18CV02884 DEFENDANT/RESPONDENT: County of Butte 17. Economic litigation a.D 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. D 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 m The party or parties request that the following additional matters be considered or determined at the case management conference (specify): The Court heard Defendant's MSJ/MSA on March 4, 2022. As of the filing of this statement, the Court has not yet issued its ruling but the Court requested the parties submit additional exhibits by March 24 and the matter would be deemed submitted on March 28, 2022. Defendant requests the Court continue the CMC to be completed after the Court has issued its ruling on the pending Motion. 19. Meet and confer a.m 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 rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 1 I 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 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 17, 2022 William E . Carny (TYPE OR PRINT NAME) ► w (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) ► (SIGNATURE OF PARTY OR ATTORNEY) D Additional signatures are attached. CM-110 [Rev. July 1, 2011] Page 5 of 5 CASE MANAGEMENT STATEMENT CASE NAME: Coulombe v. Butte County Probation 1 CASE NO.: 18CV02884 2 PROOF OF SERVICE 3 At the time of service, I was over 18 years of age and not a party to this action. My business address 4 is 350 University Avenue, Suite 200, Sacramento, California 95825. 5 On the date below, I served the following document: 6 CASE MANAGEMENT STATEMENT 7 BY MAIL: I placed the envelope for collection and mailing, following our ordinary business practices.I 8 am readily familiar with this business’ practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary 9 course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid. □ Certified Mail/Return Receipt Requested, Article # 10 BY PERSONAL SERVICE: I caused such document to be personally delivered to the person(s) addressed below. (1) For a party represented by an attorney, delivery was made to the attorney or at the 11 attorney’s office by leaving the documents, in an envelope or package clearly labeled to identify the attorney being served, with a receptionist or an individual in charge of the office, between the hours of 12 nine in the morning and five in the evening. (2) For a party, delivery was made to the party or by leaving the documents at the party’s residence with some person not younger than 18 years of age between the 13 hours of eight in the morning and six in the evening. BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided by an 14 overnight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package for collection and overnight delivery at my office or a regularly utilized drop box of the overnight delivery 15 carrier. BY FAX TRANSMISSION: Based on an agreement of the parties to accept service by fax transmission, 16 I faxed the documents to the persons at the fax numbers listed below. No error was reported by the fax machine that I used. A copy of the record of the fax transmission, which I printed out, is attached 17 XX BY ELECTRONIC SERVICE: Based on a court order or an agreement of the parties to accept service by electronic transmission, I caused the documents to be sent to the persons at the electronic notification 18 address listed below. 19 Addressed as follows: 20 Wendy E. Musell 21 THE LAW OFFICES OF WENDY MUSELL 22 180 Grand Avenue, Suite 1300 Oakland, CA 94612 23 wmusell@wendymuselllaw.com hhayame@wendymuselllaw.com 24 mwillits@wendymuselllaw.com 25 I declare under penalty of perjury under the laws of the State of California that the foregoing is true 26 and correct. Executed at Sacramento, California on March 17, 2022. 27 28 Kriste11a Cha111pti11 __________________________ Kristena Champlin 1 {02650606.DOCX}