Motion to Compel Discovery with Sanctions in MARGARITA HERRERA VS. CITY AND COUNTY OF SAN FRANCISCO ET AL| Trellis.Law

On July 30, 2019 a Party Discovery was filed involving a dispute between Herrera, Margarita, and City And County Of San Francisco, Does 1 Through 15, for OTHER NON EXEMPT COMPLAINTS in the District Court of San Francisco County.

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1 DENNIS J. HERRERA, State Bar #139669
City Attorney
2 KATHARINE HOBIN PORTER, State Bar #173180 ELECTRONICALLY
Chief Labor Attorney F I L E D
3 ERIN KUKA, State Bar #275042 Superior Court of California,
County of San Francisco
Deputy City Attorney
4 Fox Plaza 06/17/2020
1390 Market Street, 5th Floor Clerk of the Court
BY: RONNIE OTERO
5 San Francisco, California 94102-5408 Deputy Clerk
Telephone: (415) 554-4229
6 Facsimile: (415) 554-4248
E-Mail: erin.kuka@sfcityatty.org
7

8 Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO
9

10 SUPERIOR COURT OF THE STATE OF CALIFORNIA

11 COUNTY OF SAN FRANCISCO

12 UNLIMITED JURISDICTION

13 MARGARITA HERRERA, Case No. CGC-19-578026

14 Plaintiff, DISCOVERY

15 vs. DECLARATION OF ERIN KUKA IN
SUPPORT OF DEFENDANT CITY AND
16 CITY AND COUNTY OF SAN COUNTY OF SAN FRANCISCO’S
FRANCISCO, OPPOSITION TO PLAINTIFF’S MOTION TO
17 COMPEL FURTHER RESPONSES TO
Defendant. PLAINTIFF’S FIRST SET OF REQUESTS FOR
18 PRODUCTION OF DOCUMENTS, FIRST SET
OF REQUESTS FOR ADMISSION AND FORM
19 INTERROGATORIES – EMPLOYMENT (SET
ONE) AND FOR AN AWARD OF A
20 MONETARY SANCTION AGAINST
DEFENDANT IN THE AMOUNT OF $2,597.50
21
Hearing Date: June 30, 2020
22 Hearing Judge: Hon. Ethan P. Schulman
Time: 9:00 a.m.
23 Place: Dept. 302

24 Date Action Filed: July 30, 2019
Trial Date: January 25, 2021
25

28 1
KUKA DECL ISO CCSF’S OPPOSITION TO MOTION TO COMPEL n:\labor\li2019\200243\01453781.docx
CASE NO. CGC-19-578026
1 I, ERIN KUKA, declare as follows:

2 1. I am a Deputy City Attorney and represent Defendant City and County of San

3 Francisco in this action. I have personal knowledge of the facts set forth in this declaration and, if

4 called to testify, I could and would testify competently to the following.

5 2. On October 8, 2019, I emailed Plaintiff’s counsel, Deborah Kochan. A true and correct

6 copy of the email is attached as Exhibit 1.

7 3. On February 12, 2020, I emailed Plaintiff’s counsel, Deborah Kochan responding to

8 Plaintiff’s February 11, 2020 email. A true and correct copy of the email is attached as Exhibit 2.

9 4. On March 4, 2020, I emailed Plaintiff’s counsel, Deborah Kochan responding to

10 Plaintiff’s March 4, 2020 email. A true and correct copy of the email is attached as Exhibit 3.

11 5. On March 5, 2020, I emailed Plaintiff’s counsel, Deborah Kochan responding to

12 Plaintiff’s March 5, 2020 email. A true and correct copy of the email is attached as Exhibit 4.

13 6. In early March, Deborah Kochan and I exchanged several emails about the timing of

14 further meet and confer. A true and correct copy of the email chain is attached as Exhibit 5.

15 7. On May 6, 2020, I emailed Plaintiff’s counsel, Deborah Kochan responding to her

16 email. A true and correct copy of the email is attached as Exhibit 6.

17 8. On May 19, 2020, I emailed Plaintiff’s counsel, Deborah Kochan regarding Plaintiff’s

18 forthcoming motion. A true and correct copy of the email is attached as Exhibit 7.

19 9. On and around February 13, 2020, I emailed Plaintiff’s counsel, Deborah Kochan about

20 a requested extension to Plaintiff’s deadline for discovery responses. A true and correct copy of the

21 February email chain attached as Exhibit 8, with confidential, irrelevant matters redacted.

22 10. A true and correct copy of Calcor Space Facility, Inc. v. Superior Court of Orange

23 County, 53 Cal.App.4th 216 (1997) is attached for convenience as Exhibit 9.

24 11. A true and correct copy of Obregon v. Superior Court, 67 Cal.App.4th 424 (1998) is

25 attached for convenience as Exhibit 10.

26 12. A true and correct copy of Mills v. U.S. Bank, 166 Cal.App.4th 871 (2008) is attached

27 for convenience as Exhibit 11.

28 2
KUKA DECL ISO CCSF’S OPPOSITION TO MOTION TO COMPEL n:\labor\li2018\171593\01387818.docx
CASE NO. CGC-19-578026
1 13. A true and correct copy of Deyo v. Kilbourne, 84 Cal.App.3d 771 (1978) is attached for

2 convenience as Exhibit 12.

3 14. I worked in excess of 12 hours on the City’s Opposition Memorandum of Points and

4 Authorities, the three SSUFs, and this declaration. The City calculates the fair market value of an

5 attorney with my experience to be $400 per hour. Accordingly, the City seeks sanctions up to $4,800

6 for the preparation of this opposition.

7 I declare under penalty of perjury that the foregoing is true and correct. Executed June 17,

8 2020 at San Francisco, California.

11
ERIN KUKA
12

19
20

28 3
KUKA DECL ISO CCSF’S OPPOSITION TO MOTION TO COMPEL n:\labor\li2018\171593\01387818.docx
CASE NO. CGC-19-578026
EXHIBIT 1

EXHIBIT 1
From: Kuka, Erin (CAT)
To: "dkochan@kochanstephenson.net"
Subject: Herrera v. CCSF
Date: Tuesday, October 8, 2019 12:02:20 PM

Hello Ms. Kochan,

I am representing the City in Ms. Herrera’s lawsuit. I have received the discovery served on
the Mayor’s Office, apparently on October 1. (It took a few days for the mail to be routed to
me; please see below for my direct contact info.) I am writing to request a 60-day extension
on your RFP, RFA, and Form Rogs. I will be taking some intermittent leave in the coming
month and will be out of the office from October 12th through the 20th, October 31st through
November 5th, and November 15th through the 19th. 60 additional days should be sufficient
to gather the requested documents and respond. Please let me know if you will agree to that
timeline.

I am also writing to meet and confer regarding the PMK deposition because I will be out on
the date you selected. My preference would be to reset the deposition for after the
document production is completed because the depo notice requests the same docs as the
RFP and, given my calendar, I will need the extra time to gather everything. Are you agreeable
to that?

Thank you,
Erin

Erin Kuka
Deputy City Attorney
Office of City Attorney Dennis Herrera
1390 Market Street, 7th Floor
San Francisco, CA 94102
(415) 554-4229 Direct
www.sfcityattorney.org

This message may be subject to the attorney-client privilege and/or may contain
confidential attorney work product. If you have received this message in error, please
delete it immediately and notify the sender.
EXHIBIT 2

EXHIBIT 2
From: Kuka, Erin (CAT)
To: "Deborah Kochan"
Cc: Mathew Stephenson; Eliana Greenberg
Subject: RE: Herrera v. CCSF - m &C and mtn compel deadline
Date: Wednesday, February 12, 2020 4:16:52 PM

Hello Deborah,

I have no problem extending the motion to compel deadline to March 10th. I will await your
M&C letter. Regarding the stipulation: having not yet received your M&C letter, I do not know
what the “dispute about the propriety of certain objections” is. Accordingly, I have to decline
to enter into any sort of stipulation as to how that “dispute” should be handled. I remain
hopeful that any dispute can be resolved through the M&C process.

Best,
Erin

Erin Kuka
Deputy City Attorney
San Francisco City Attorney’s Office
(415) 554-4229 Direct
www.sfcityattorney.org

From: Deborah Kochan
Sent: Tuesday, February 11, 2020 8:22 AM
To: Kuka, Erin (CAT)
Cc: Mathew Stephenson ; Eliana Greenberg

Subject: Herrera v. CCSF - m &C and mtn compel deadline

Erin,

I write to initiate the meet and confer process and to request an extension of the motion to compel
deadline to March 10th. One of the several areas of concern we have with Defendant’s responses is
the insertion of boilerplate objections in response to each and every request for production, request
for admission, and special interrogatory. We will write under separate cover to address our
remaining concerns but in the meantime wanted to get the process going in that such boilerplate
objections are improper and not permitted by the Discovery Act in that, among other things, they
render any commitment to produce documents and/or information ambiguous, at best.

In order to address such problems and avoid the need of a discovery motion as to the objections
we’ve developed a stipulation that we’ve used many times over the years. This stipulation has been
endorsed by many defense counsel as a means of clearing up any ambiguity created by the
interjection of objections. Please let us know if you have any questions. I’ve attached the document
in Word so that you can suggest changes. If you do, please track them.

Thank you,
Deborah

Deborah Kochan
Kochan & Stephenson
1680 Shattuck Avenue
Berkeley, CA 94709
Tel: (510) 649-1130
Fax: (510) 649-1131
dkochan@kochanstephenson.net
www.kochanstephenson.com
EXHIBIT 3

EXHIBIT 3
From: Kuka, Erin (CAT)
To: "Deborah Kochan"
Cc: Mathew Stephenson; Eliana Greenberg
Subject: RE: Herrera v. CCSF - m &C and mtn compel deadline
Date: Wednesday, March 4, 2020 9:08:45 AM

Thanks for the reminder – I’ve been jammed up. I’m slammed today but will have a response
for you tomorrow. I am sure we can work it out without motion practice.

Best,
Erin

Erin Kuka
Deputy City Attorney
San Francisco City Attorney’s Office
(415) 554-4229 Direct
www.sfcityattorney.org

From: Deborah Kochan
Sent: Wednesday, March 4, 2020 6:47 AM
To: Kuka, Erin (CAT)
Cc: Mathew Stephenson ; Eliana Greenberg

Subject: Fwd: Herrera v. CCSF - m &C and mtn compel deadline

Good Morning Erin - I’m following up on the below email I sent last Friday. While we hope we can
resolve these issues informally, if we cannot we need to get going on preparing Plaintiff’s motion to
compel given next Tuesday’s deadline.

Thanks,
Deborah

Deborah Kochan
Kochan & Stephenson
1680 Shattuck Avenue
Berkeley, California 94709
(510) 649-1130
www.kochanstephenson.com
dkochan@kochanstephenson.net
Begin forwarded message:

From: Deborah Kochan
Date: February 28, 2020 at 10:50:16 AM PST
To: "Kuka, Erin (CAT)"
Cc: Mathew Stephenson , Eliana Greenberg

Subject: FW: Herrera v. CCSF - m &C and mtn compel deadline

Erin,

I’m writing as a follow up to my previous email about Plaintiff concerns about
Defendant’s deficient discovery responses. As you know, earlier this month I
forwarded you a proposed stipulation to address Defendant’s insertion of boilerplate
objections in response to each and every request for production, request for
admission, and special interrogatory. As I explained, in order to address such problems
and avoid the need of a discovery motion as to the objections we’ve developed a
stipulation that we’ve used many times over the years. This stipulation has been
endorsed by many defense counsel as a means of clearing up any ambiguity created by
the interjection of objections. General objections to the entire set of discovery are
unauthorized, constitute discovery abuse and can subject the objecting party to
sanctions. See Korea Data Systems Co. Ltd. V. Sup.Ct. (Amazing Technologies
Corp.) (1997) 51 CA4th 1513; 1516. That is because in interjecting boilerplate
objections and making each response subject to those objections, the responding party
is not providing a clear communication as to the information/documents it will and will
not provide. Indeed, such objections allow the responding party to withhold
information and documents subject to those objections and the receiving party has no
way of knowing whether information and documents have been withheld, much less
the reasons why such information and/or documents were withheld. The proposed
stipulation works to remove any such ambiguity.

Requests for Production

In addition to the interjection of boilerplate, improper objections Defendant’s qualified
responses to most of the requests for production is improper. I will address those
issues in the order they appear in Defendant’s responses. With respect to Request
Nos. 2-3, Defendant limits it production to the communications it itemizes between
Plaintiff and Karen Cohn/Haroon Ahmad. But as you know, Plaintiff’s demand was not
limited to just those communications itemized by Defendant. Rather, Plaintiff asked for
all communications for a specific reason. Plaintiff is alleging that Ms. Cohn (and by
proxy her subordinate Haroon Ahmad), treated her in a different manner and handled
virtually each and every issue with Plaintiff differently because of her protected status
and previous lawsuit. Thus, all of the communications between the Ms. Herrera and
Cohn as well as all communications between Plaintiff and Ahmad are relevant and may
lead to the discovery of admissible evidence.
With respect to Request Nos. 4-6, Defendant has also improperly qualified its
response. Plaintiff is entitled to all communications as between Cohn and Ahmad as
well as between Cohn and DPH and Ahmad and DPH in that that all of these
communications that relate to Ms. Herrera are relevant and may lead to the discovery
of admissible evidence.

Defendant’s responses to Request Nos. 8-10 are problematic for the same reasons as
the above referenced responses. That is, Defendant does not commit itself to
producing all non-privileged responsive documents and instead qualifies its response
despite the fact that Plaintiff’s work performance, complaints she made, and any
complaints made about her are at issue is this case.

With respect to Defendant’s responses to Request Nos. 13-18, as above Defendant
qualifies its responses and does not commit to producing all responsive documents.
The documents sought in response to each request could not be more centrally
relevant to Plaintiff’s claims and Defendant’s failure and/or refusal to provide an
unqualified commitment to produce all non-privileged documents is unacceptable.

Employment Form Interrogatories

In addition to the interjection of boilerplate, improper objections Defendant also failed
to provide proper, substantive responses to Plaintiff’s Form Interrogatories, despite the
fact that Plaintiff granted Defendant’s request for a lengthy extension of time within
which to respond. I will address those issues in the order they appear in Defendant’s
responses. With respect to Interrogatory Nos. 204.3, 204.6, 204.7, 207.1, and 207.2,
rather than respond to the specific questions posed Defendant improperly refers
Plaintiff to the entire set of documents Defendant produced and leaves it to Plaintiff to
figure out the specific communications, person and documents that answer the
questions posed. This is clearly improper in that it is not really an answer at all. As you
may know, the Discovery Act requires that the answer be “as complete and
straightforward as the information reasonably available to the responding party
permits.” CCP 2030.220. “Parties must state the truth, the whole truth, and nothing
but the truth in answering interrogatories.” Scheiding v. Dinwiddie Const. Co. (1999) 69
Cal.App.4th 64, 76. Moreover, it is not proper to answer by reference to other
documents. If the question requires reference to some other document, it should be
identified and its contents summarized so that the answer by itself is fully responsive to
the interrogatory. Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 783-784.

With respect to Interrogatory Nos. 215.1 and 215.2, Defendant fails to state whether or
not it interviewed any witnesses and/or obtained statements other than to state it
won’t provide information regarding any investigation the City Attorney’s office did.
But of course the interrogatories are not limited to just any investigations the City
Attorney’s office may have done thus the responses will need to be amended to either
state that no investigation was conducted other than that conducted by the City
Attorney’s office or Defendant will have to provide the information regarding any other
investigations it did.

With respect to Interrogatory No. 217.1, Defendant fails to provide any substantive
response whatsoever, despite the fact that it denied all of Plaintiff’s requests for
admission. As you may know, the purpose of Plaintiff requests for admission and
corresponding employment form interrogatories was to see if the issues could be
narrowed and to potentially streamline the deposition discovery which is to commence
shortly. But Defendant has obstructed Plaintiff’s legitimate discovery claiming, among
other things, that Plaintiff’s discovery is premature because discovery has just
commenced. Such statements ignore the fact that virtually all of the witnesses and
documents necessary to formulate a response are within Defendant’s control, and that
Plaintiff provided Defendant two additional months within which to respond.
Moreover, as explained above, it is not proper to answer by reference to other
documents. If the question requires reference to some other document, it should be
identified and its contents summarized so that the answer by itself is fully responsive to
the interrogatory. Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 783-784.

Please let us know whether you would like to set up time to meet and confer about the
above by phone or in person. We need to get all of the above resolved in order to keep
this case on track.

Thank you,
Deborah

Deborah Kochan
Kochan & Stephenson
1680 Shattuck Avenue
Berkeley, CA 94709
Telephone: (510) 649-1130
Facsimile: (510) 649-1131
dkochan@kochanstephenson.net
www.kochanstephenson.com

From: Deborah Kochan
Date: Tuesday, February 11, 2020 at 8:21 AM
To: "Kuka, Erin (CAT)"
Cc: Mathew Stephenson , Eliana
Greenberg
Subject: Herrera v. CCSF - m &C and mtn compel deadline

Erin,
I write to initiate the meet and confer process and to request an extension of the
motion to compel deadline to March 10th. One of the several areas of concern we
have with Defendant’s responses is the insertion of boilerplate objections in response
to each and every request for production, request for admission, and special
interrogatory. We will write under separate cover to address our remaining concerns
but in the meantime wanted to get the process going in that such boilerplate
objections are improper and not permitted by the Discovery Act in that, among other
things, they render any commitment to produce documents and/or information
ambiguous, at best.

In order to address such problems and avoid the need of a discovery motion as to the
objections we’ve developed a stipulation that we’ve used many times over the years.
This stipulation has been endorsed by many defense counsel as a means of clearing up
any ambiguity created by the interjection of objections. Please let us know if you have
any questions. I’ve attached the document in Word so that you can suggest changes.
If you do, please track them.

Thank you,
Deborah

Deborah Kochan
Kochan & Stephenson
1680 Shattuck Avenue
Berkeley, CA 94709
Tel: (510) 649-1130
Fax: (510) 649-1131
dkochan@kochanstephenson.net
www.kochanstephenson.com
EXHIBIT 4

EXHIBIT 4
From: Kuka, Erin (CAT)
To: "Deborah Kochan"
Cc: Mathew Stephenson; Eliana Greenberg
Subject: RE: Herrera v. CCSF - m &C and mtn compel deadline
Date: Thursday, March 5, 2020 3:38:35 PM

Hi,

Thanks for your message. I’m sorry to report that I’m not feeling well, and I’m going to be out
tomorrow attending some necessary appointments. Let’s extend your deadline a week to the
17th, which will give us time to connect early next week.

Thanks,
Erin

Erin Kuka
Deputy City Attorney
San Francisco City Attorney’s Office
(415) 554-4229 Direct
www.sfcityattorney.org

From: Deborah Kochan
Sent: Thursday, March 5, 2020 2:38 PM
To: Kuka, Erin (CAT)
Cc: Mathew Stephenson ; Eliana Greenberg

Subject: Re: Herrera v. CCSF - m &C and mtn compel deadline
Importance: High

Erin,

Thank you for getting back to me. While I too am hopeful we can work this out so as to avoid the
need for a motion, even if your client agrees to amend its responses to cure the defects we’ve
itemized, in the interim we’re going to need an extension on the motion to compel deadline. Please
confirm an extension of that deadline today otherwise we’re going to need to begin to prepare our
motion tomorrow.

Thanks,
Deborah
Deborah Kochan
Kochan & Stephenson
1680 Shattuck Avenue
Berkeley, CA 94709
Telephone: (510) 649-1130
Facsimile: (510) 649-1131
dkochan@kochanstephenson.net
www.kochanstephenson.com

From: "Kuka, Erin (CAT)"
Date: Wednesday, March 4, 2020 at 9:08 AM
To: Deborah Kochan
Cc: Mathew Stephenson , Eliana Greenberg

Subject: RE: Herrera v. CCSF - m &C and mtn compel deadline

Thanks for the reminder – I’ve been jammed up. I’m slammed today but will have a response
for you tomorrow. I am sure we can work it out without motion practice.

Best,
Erin

Erin Kuka
Deputy City Attorney
San Francisco City Attorney’s Office
(415) 554-4229 Direct
www.sfcityattorney.org

From: Deborah Kochan
Sent: Wednesday, March 4, 2020 6:47 AM
To: Kuka, Erin (CAT)
Cc: Mathew Stephenson ; Eliana Greenberg

Subject: Fwd: Herrera v. CCSF - m &C and mtn compel deadline
Good Morning Erin - I’m following up on the below email I sent last Friday. While we hope we can
resolve these issues informally, if we cannot we need to get going on preparing Plaintiff’s motion to
compel given next Tuesday’s deadline.

Thanks,
Deborah

Deborah Kochan
Kochan & Stephenson
1680 Shattuck Avenue
Berkeley, California 94709
(510) 649-1130
www.kochanstephenson.com
dkochan@kochanstephenson.net

Begin forwarded message:

From: Deborah Kochan
Date: February 28, 2020 at 10:50:16 AM PST
To: "Kuka, Erin (CAT)"
Cc: Mathew Stephenson , Eliana Greenberg

Subject: FW: Herrera v. CCSF - m &C and mtn compel deadline

Erin,

With respect to Request Nos. 4-6, Defendant has also improperly qualified its
response. Plaintiff is entitled to all communications as between Cohn and Ahmad as
well as between Cohn and DPH and Ahmad and DPH in that that all of these
communications that relate to Ms. Herrera are relevant and may lead to the discovery
of admissible evidence.

Employment Form Interrogatories

Please let us know whether you would like to set up time to meet and confer about the
above by phone or in person. We need to get all of the above resolved in order to keep
this case on track.

Thank you,
Deborah

Deborah Kochan
Kochan & Stephenson
1680 Shattuck Avenue
Berkeley, CA 94709
Telephone: (510) 649-1130
Facsimile: (510) 649-1131
dkochan@kochanstephenson.net
www.kochanstephenson.com

From: Deborah Kochan
Date: Tuesday, February 11, 2020 at 8:21 AM
To: "Kuka, Erin (CAT)"
Cc: Mathew Stephenson , Eliana
Greenberg
Subject: Herrera v. CCSF - m &C and mtn compel deadline

Erin,

I write to initiate the meet and confer process and to request an extension of the
motion to compel deadline to March 10th. One of the several areas of concern we
have with Defendant’s responses is the insertion of boilerplate objections in response
to each and every request for production, request for admission, and special
interrogatory. We will write under separate cover to address our remaining concerns
but in the meantime wanted to get the process going in that such boilerplate
objections are improper and not permitted by the Discovery Act in that, among other
things, they render any commitment to produce documents and/or information
ambiguous, at best.

In order to address such problems and avoid the need of a discovery motion as to the
objections we’ve developed a stipulation that we’ve used many times over the years.
This stipulation has been endorsed by many defense counsel as a means of clearing up
any ambiguity created by the interjection of objections. Please let us know if you have
any questions. I’ve attached the document in Word so that you can suggest changes.
If you do, please track them.

Thank you,
Deborah

Deborah Kochan
Kochan & Stephenson
1680 Shattuck Avenue
Berkeley, CA 94709
Tel: (510) 649-1130
Fax: (510) 649-1131
dkochan@kochanstephenson.net
www.kochanstephenson.com
EXHIBIT 5

EXHIBIT 5
From: Kuka, Erin (CAT)
To: "Deborah Kochan"
Cc: "Mathew Stephenson"; "Eliana Greenberg"
Subject: RE: Herrera v. CCSF - m &C and mtn compel deadline
Date: Monday, March 16, 2020 3:51:46 PM

Hi again Deborah,

Just writing with an update. SF declared a shelter in place today and that’s taken me away from my
usual work, so I haven’t had a chance to get back to the Herrera case. I anticipate that things will
calm down in a few days. Meanwhile, thank you for your patience; I simply have to prioritize that
work right now over civil discovery. I will be in touch tomorrow or Wednesday at the latest with an
update. Thank you for understanding.

Erin

From: Kuka, Erin (CAT)
Sent: Friday, March 13, 2020 5:52 PM
To: 'Deborah Kochan'
Cc: 'Mathew Stephenson' ; 'Eliana Greenberg'

Case Info

Judge

Samuel K. Feng Track Judge’s New Case

Case No.

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Document Filed Date

June 17, 2020

Case Filing Date

July 30, 2019

County

Parties

CITY AND COUNTY OF SAN FRANCISCO Defendant
DOES 1 THROUGH 15 Defendant
FRENZEN, AMY P. Attorney for the Defendant
HERRERA, MARGARITA Plaintiff
KOCHAN, DEBORAH MARIE Attorney for the Plaintiff
KUKA, ERIN Attorney for the Defendant
ROLNICK, JONATHAN C Attorney for the Defendant
YAN, MATTHEW Attorney for the Defendant
Mathew Stephenson Attorneys for Plaintiffs
Dennis Herrera Attorneys for Defendants
Katharine Porter Attorneys for Defendants
David Chiu Attorneys for Defendants

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Party Discovery: MARGARITA HERRERA VS. CITY AND COUNTY OF SAN FRANCISCO ET AL

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