Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Lisa Lin Garcia, SBN 260582 | Francesca M. Lanpher, SBN 299318 9 Fl L E D
Littler Mendelson, P.C. 7
333 Bush Street - Floor 34 .
San Francisco, CA 94104 2020 JAN 24 PM I: 38
TELEPHONE NO. 415-433-1940 FAX NO. (Options): 415-399-8490
EMAL ADDRESS (Qptonay: IIgarcia@littler.com | flanpher@liittler.com ROSA PINQUERO, CLERK
ATTORNEY FOR (Name: United Parcel Service, Inc.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Joaquin
street aporess: 180 E Weber Avenue
MAILING ADDRESS:
city anpzipcone: Stockton, CA 95202
BRANCH NAME:
PLAINTIFF/PETITIONER: Shaun Medina
DEFENDANT/RESPONDENT: United Parcel Service, Inc.
CASE MANAGEMENT STATEMENT ETLE BY FAX | CASNuMeER:
(Check one): [J UNLIMITED CASE Osuimitep case STK-CV-UWT-2019-0010877
(Amount demanded (Amount'demanded Is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: February 10, 2020 Time: 8:45 a.m, Dept.: 10A Div.: Room:
Address of court (if different from the address above):
] Notice of Intent to Appear by Telephone, by (name): Francesca M. Lanpher
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one);
a. 1X This statement is submitted by party (name): Defendant United Parcel Service, Inc.
b. (1 This statement is submitted jointly by parties (names):
2. Complaint and cross-compliaint (to be answered by piaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. [1 The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. (1 Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [1 The following parties named in the complaint or cross-complaint
(1) oO have not been served (specify names and explain why not):
(2) [1 have been served but have not appeared and have not been dismissed (specify names):
(3) (1 have had a default entered against them (specify names):
ec. (1 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. Typeofcase in DX] complaint 1 cross-complaint (Describe, including causes of action):
See attachment A.
Pege 1 of 5
Fos a Neem CASE MANAGEMENT STATEMENT Cal Rules of Cour.
CM-110 (Rev. Juy 1,2011] wiww.cours.ca.gov
American LegalNet, In
setae Forms WorkBoweamCM-110
PETITIONER: i CASE NUMBER:
| PLAINTIFF/ R: Shaun Medina STK-CV_UWT-2019-0010377
DEFENDANT/RESPONDENT: United Parcel Service, Inc.
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 eamings. if equitable relief is sought, describe the nature of the relief)
Plaintiffs Complaint arises out of Plaintiff's employment with Defendant United Parcel Service, Inc. ("UPS").
Plaintiff alleges that UPS discriminated, harassed, retaliated against him, and wrongfully terminated him based on
his age, race, national origin, ancestry, and disability. Plaintiff also alleges that UPS failed to accommodate and
failed to engage in the interactive process regarding his alleged disability during his employment. UPS denies the
allegations.
(C(t 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 (7) ajurytrial Dd anonjury trial. (if more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. [1 The trial has been set for (date):
b. EX] 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, expiain): Plaintiff's counsel informed UPS that a new counsel for Plaintiff will be substituting in. The
parties have also been engaging in early resolution discussions so have not engaged in full discovery.
¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
May 4-15 (trial); June 22-26 (trial); August 5-Sept. 15 (trial); Nov. 2-13 (trial)
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [X] days (specify number): 5 days
b. (1 hours {short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial OX] by the attorney or party listed in the caption 21 by the following:
a. Attomey:
b. Firm:
c, Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
C1 Additional representation is described in Attachment 8.
9. Preference
(1 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 D] has 1 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 (] 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) oO 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) (1 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) This case is exempt from judicial arbitration under rule 3.814 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
Rule 3.811(b)(8) (multiple causes of action); case value
Cus 10{Rov. dy 4, 2014 CASE MANAGEMENT STATEMENT Page 20f 8
senor Fam WorkFlow comCM-110
PLAINTIFF/PETITIONER: Shaun Medina CASE NUMBER:
[— STK-CV-UWT-2019-0010377
IDEFENDANT/RESPONDENT: United Parcel Service, Inc.
10. ¢. 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 (atfach a copy of the parties‘ ADR
Processes (check ail that apply): | stipulation):
{J Mediation session not yet scheduled
Mediation session scheduled for (data):
(1) Mediation ix
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference Agreed to complete settlement conference by (date) :
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation Oo
Agreed to complete neutral evaluation by (date):
Neutral evaluation compteted on (date):
Judicial arbitration not yet scheduled
(4) Nonbinding judicial g Judicial arbitration scheduled for (date):
arbitration Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
“ Private arbitration scheduled for (date):
(5) Binding private g
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
(8) Other (specify): og
Agreed to complete ADR session by (date);
DOOOJOOOOJOOOUOJOOODO;/OOOB8soOo00O
ADR completed on (date):
Cur Re Jy 42017 CASE MANAGEMENT STATEMENT Page’ ot 6
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‘soy FonmsWorkFlov.comCM-110
DEFENDANT/RESPONDENT: United Parcel Service, Inc.
PLAIN : i ‘CASE NUMBER:
LAINTIFF/PETITIONER: Shaun Medina STK-CV-UWT-2019-0010377
4.
414,
15.
Insurance
a. [1 Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: (] Yes 0 No
c. [Coverage issues will significantly affect resolution of this case (explain):
. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
(1 Bankruptcy [] Other (specify):
Status:
. Related cases, consolidation, and coordination
a. [1 There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
[1 Additional cases are described in Attachment 13a.
b. 1 Amotionto [ consolidate [J coordinate will be filed by (name party):
Bifurcation
(1 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):
Other motions
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motion for Summary Judgment and/or Adjudication; discovery motion (if needed).
16. Discovery
a. [] The party or parties have completed all discovery.
b BX The following discovery will be completed by the date specified (describe ail anticipated discovery):
Party i Date
Defendant Written Discovery August 2020
Defendant Plaintiff's Deposition August 2020
Defendant Third Party Depositions October 2020
Defendant Expert Discovery December 2020
c. [1 The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 (Rev. July 1, 2071) CASE MANAGEMENT STATEMENT Page 4016
seww.FormsWorkFlow.comCM-110
‘CASE NUMBER:
PLAINTIFF/PETITIONER: Shaun Medina STKCCV-UWT-2019-0010377
| DEFENDANT/RESPONDENT: United Parcel Service, Inc.
17. Economic litigation
a. C1 Thisisa 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. C1 Thisis 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 additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a. [XJ The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the Califomia Rules of
Court (if not, explain): On January 23, 2020, Plaintiff's counsel informed UPS that Plaintiff will have new counsel
and that they will file a notice of substitution of counsel.
b. After meeting and conferring as required by rule 3.724 of the Califomia Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any): 1
| 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: January 24, 2020
Francesca M. Lanpher =| b
(TYPE OR PRINT NAME) (SIGNATURE ‘OF PARTY OR ATTORNEY)
»
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
( Additional signatures are attached.
Page 6 of §
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CuH110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENTAttachment A to Defendant United Parcel Service, Inc.’s Case Management Statement
January 24, 2020
On February 13, 2019, Plaintiff filed the instant action against Defendants United Parcel Service,
Inc. (“UPS”) and “Vivian Doe” in Alameda Superior Court.
Plaintiff's Complaint asserts fourteen causes of action: (1) discrimination on the bases of age, rage,
national origin, ancestry, and disability in violation of FEHA; (2) harassment on the bases of age,
rage, national origin, ancestry, and disability in violation of FEHA; (3) wrongful termination in
violation of public policy; (4) failure to provide reasonable accommodation in violation of FEHA;
(5) failure to engage in the interactive process in violation of FEHA; (6) failure to prevent
discrimination and harassment and retaliation in violation of FEHA; (7) retaliation for taking
CFRA leave in violation of FEHA; (8) retaliation for engaging in protected activity in violation of
FEHA; (9) breach of express oral contract not to terminate employment without good cause; (10)
breach of implied-in-fact contract not to terminate employment without good cause; (11) negligent
hiring, supervision and retention; (12) intentional infliction of emotional distress; (13) violation of
Labor Code § 1102.5; and (14) violation of Labor Code § 6310.
On May 24, 2019, Plaintiff and Defendant UPS (the “Parties’) stipulated to transfer the action to
the proper venue of San Joaquin Superior Court.
On May 31, 2019, Alameda Superior Court granted the Parties” stipulation and ordered the action
transferred to San Joaquin Superior Court.
On September 19, 2019, Plaintiff and UPS filed a Joint Stipulation in which they agreed that
“Vivian Doe” identified in Plaintiff's Complaint was Vivian Joshua, and agreed to dismiss
individually named Defendant Vivian Joshua without prejudice.
On September 23, 2019, this Court granted the Parties’ Stipulation and dismissed individual
Defendant Vivian Joshua from this action without prejudice.
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Lisa Lin Garcia, SBN 260582 | Francesca M. Lanpher, SBN 299318 9 Fl L E D Littler Mendelson, P.C. 7 333 Bush Street - Floor 34 . San Francisco, CA 94104 2020 JAN 24 PM I: 38 TELEPHONE NO. 415-433-1940 FAX NO. (Options): 415-399-8490 EMAL ADDRESS (Qptonay: IIgarcia@littler.com | flanpher@liittler.com ROSA PINQUERO, CLERK ATTORNEY FOR (Name: United Parcel Service, Inc. SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Joaquin street aporess: 180 E Weber Avenue MAILING ADDRESS: city anpzipcone: Stockton, CA 95202 BRANCH NAME: PLAINTIFF/PETITIONER: Shaun Medina DEFENDANT/RESPONDENT: United Parcel Service, Inc. CASE MANAGEMENT STATEMENT ETLE BY FAX | CASNuMeER: (Check one): [J UNLIMITED CASE Osuimitep case STK-CV-UWT-2019-0010877 (Amount demanded (Amount'demanded Is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: February 10, 2020 Time: 8:45 a.m, Dept.: 10A Div.: Room: Address of court (if different from the address above): ] Notice of Intent to Appear by Telephone, by (name): Francesca M. Lanpher INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one); a. 1X This statement is submitted by party (name): Defendant United Parcel Service, Inc. b. (1 This statement is submitted jointly by parties (names): 2. Complaint and cross-compliaint (to be answered by piaintiffs and cross-complainants only) a. The complaint was filed on (date): b. [1 The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. (1 Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [1 The following parties named in the complaint or cross-complaint (1) oO have not been served (specify names and explain why not): (2) [1 have been served but have not appeared and have not been dismissed (specify names): (3) (1 have had a default entered against them (specify names): ec. (1 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. Typeofcase in DX] complaint 1 cross-complaint (Describe, including causes of action): See attachment A. Pege 1 of 5 Fos a Neem CASE MANAGEMENT STATEMENT Cal Rules of Cour. CM-110 (Rev. Juy 1,2011] wiww.cours.ca.gov American LegalNet, In setae Forms WorkBoweamCM-110 PETITIONER: i CASE NUMBER: | PLAINTIFF/ R: Shaun Medina STK-CV_UWT-2019-0010377 DEFENDANT/RESPONDENT: United Parcel Service, Inc. 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 eamings. if equitable relief is sought, describe the nature of the relief) Plaintiffs Complaint arises out of Plaintiff's employment with Defendant United Parcel Service, Inc. ("UPS"). Plaintiff alleges that UPS discriminated, harassed, retaliated against him, and wrongfully terminated him based on his age, race, national origin, ancestry, and disability. Plaintiff also alleges that UPS failed to accommodate and failed to engage in the interactive process regarding his alleged disability during his employment. UPS denies the allegations. (C(t 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 (7) ajurytrial Dd anonjury trial. (if more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. [1 The trial has been set for (date): b. EX] 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, expiain): Plaintiff's counsel informed UPS that a new counsel for Plaintiff will be substituting in. The parties have also been engaging in early resolution discussions so have not engaged in full discovery. ¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): May 4-15 (trial); June 22-26 (trial); August 5-Sept. 15 (trial); Nov. 2-13 (trial) 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [X] days (specify number): 5 days b. (1 hours {short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial OX] by the attorney or party listed in the caption 21 by the following: a. Attomey: b. Firm: c, Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: C1 Additional representation is described in Attachment 8. 9. Preference (1 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 D] has 1 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 (] 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) oO 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) (1 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) This case is exempt from judicial arbitration under rule 3.814 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): Rule 3.811(b)(8) (multiple causes of action); case value Cus 10{Rov. dy 4, 2014 CASE MANAGEMENT STATEMENT Page 20f 8 senor Fam WorkFlow comCM-110 PLAINTIFF/PETITIONER: Shaun Medina CASE NUMBER: [— STK-CV-UWT-2019-0010377 IDEFENDANT/RESPONDENT: United Parcel Service, Inc. 10. ¢. 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 (atfach a copy of the parties‘ ADR Processes (check ail that apply): | stipulation): {J Mediation session not yet scheduled Mediation session scheduled for (data): (1) Mediation ix Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date) : Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Oo Agreed to complete neutral evaluation by (date): Neutral evaluation compteted on (date): Judicial arbitration not yet scheduled (4) Nonbinding judicial g Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled “ Private arbitration scheduled for (date): (5) Binding private g arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (date): (8) Other (specify): og Agreed to complete ADR session by (date); DOOOJOOOOJOOOUOJOOODO;/OOOB8soOo00O ADR completed on (date): Cur Re Jy 42017 CASE MANAGEMENT STATEMENT Page’ ot 6 Ammerteen LegalNet ‘soy FonmsWorkFlov.comCM-110 DEFENDANT/RESPONDENT: United Parcel Service, Inc. PLAIN : i ‘CASE NUMBER: LAINTIFF/PETITIONER: Shaun Medina STK-CV-UWT-2019-0010377 4. 414, 15. Insurance a. [1 Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: (] Yes 0 No c. [Coverage issues will significantly affect resolution of this case (explain): . Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. (1 Bankruptcy [] Other (specify): Status: . Related cases, consolidation, and coordination a. [1 There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: [1 Additional cases are described in Attachment 13a. b. 1 Amotionto [ consolidate [J coordinate will be filed by (name party): Bifurcation (1 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): Other motions The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Motion for Summary Judgment and/or Adjudication; discovery motion (if needed). 16. Discovery a. [] The party or parties have completed all discovery. b BX The following discovery will be completed by the date specified (describe ail anticipated discovery): Party i Date Defendant Written Discovery August 2020 Defendant Plaintiff's Deposition August 2020 Defendant Third Party Depositions October 2020 Defendant Expert Discovery December 2020 c. [1 The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 (Rev. July 1, 2071) CASE MANAGEMENT STATEMENT Page 4016 seww.FormsWorkFlow.comCM-110 ‘CASE NUMBER: PLAINTIFF/PETITIONER: Shaun Medina STKCCV-UWT-2019-0010377 | DEFENDANT/RESPONDENT: United Parcel Service, Inc. 17. Economic litigation a. C1 Thisisa 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. C1 Thisis 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 additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. [XJ The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the Califomia Rules of Court (if not, explain): On January 23, 2020, Plaintiff's counsel informed UPS that Plaintiff will have new counsel and that they will file a notice of substitution of counsel. b. After meeting and conferring as required by rule 3.724 of the Califomia Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 1 | 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: January 24, 2020 Francesca M. Lanpher =| b (TYPE OR PRINT NAME) (SIGNATURE ‘OF PARTY OR ATTORNEY) » (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) ( Additional signatures are attached. Page 6 of § ‘American LegalNet, won FormsWorkFlow.com CuH110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENTAttachment A to Defendant United Parcel Service, Inc.’s Case Management Statement January 24, 2020 On February 13, 2019, Plaintiff filed the instant action against Defendants United Parcel Service, Inc. (“UPS”) and “Vivian Doe” in Alameda Superior Court. Plaintiff's Complaint asserts fourteen causes of action: (1) discrimination on the bases of age, rage, national origin, ancestry, and disability in violation of FEHA; (2) harassment on the bases of age, rage, national origin, ancestry, and disability in violation of FEHA; (3) wrongful termination in violation of public policy; (4) failure to provide reasonable accommodation in violation of FEHA; (5) failure to engage in the interactive process in violation of FEHA; (6) failure to prevent discrimination and harassment and retaliation in violation of FEHA; (7) retaliation for taking CFRA leave in violation of FEHA; (8) retaliation for engaging in protected activity in violation of FEHA; (9) breach of express oral contract not to terminate employment without good cause; (10) breach of implied-in-fact contract not to terminate employment without good cause; (11) negligent hiring, supervision and retention; (12) intentional infliction of emotional distress; (13) violation of Labor Code § 1102.5; and (14) violation of Labor Code § 6310. On May 24, 2019, Plaintiff and Defendant UPS (the “Parties’) stipulated to transfer the action to the proper venue of San Joaquin Superior Court. On May 31, 2019, Alameda Superior Court granted the Parties” stipulation and ordered the action transferred to San Joaquin Superior Court. On September 19, 2019, Plaintiff and UPS filed a Joint Stipulation in which they agreed that “Vivian Doe” identified in Plaintiff's Complaint was Vivian Joshua, and agreed to dismiss individually named Defendant Vivian Joshua without prejudice. On September 23, 2019, this Court granted the Parties’ Stipulation and dismissed individual Defendant Vivian Joshua from this action without prejudice.