Preview
Case Number: 21-CIV-04310
SUPERIOR COURT OF SAN MATEO COUNTY
400 County Center 1050 Mission Road
Redwood City, CA 94063 South San Francisco, CA 94080
www.sanmateocourt.org
Minute Order
Monika Chopra vs. Natera, Inc, a Delaware corporation, et al 21-CIV-04310
02/03/2022 3:00 PM
Informal Discovery Conference
Hearing Result: Held
Judicial Officer: Halperin, Ernst A. Location: Courtroom P
Courtroom Clerk: Eresmia Ouranitsas Courtroom Reporter:
Parties Present
Exhibits
Minutes
Journals
- Conference held from 3:02 p.m. to 4:03 p.m.
Gary S. Brotman for Plaintiff Monika Chopra
Harold Jones for Defendant Natera, Inc.
The parties have agreed that the Entity Deposition of Defendant Natera, Inc. will take place between
March 7 and March 16 on mutually agreeable dates.
Defendant agrees to serve, no later than February 24, 2022 at 5:00 p.m., verified supplemental
responses and responsive documents to:
Plaintiff s FROGs 3.7, 4.1, 200.1, 200.3, 200.4, 201.1, 201.7, 204.7, 211.1 and 214.1.
SROGs Nos. 3, 11, 12, 13, 14, 17, 23, 25, 26, 27, 29, 30. In responding to the special interrogatories 27,
28, 29, and 30, Defendant agrees to provide a supplemental response to the extent the information is
available to Defendant.
RFA Nos. 16, 18, 20, 24, 26, and 29 and FROG 17.1 with respect to those RFAs.
RFP. 36, 52, 53, 55,
For any verified supplemental responses not served by the above-date, either party may make a
discovery motion without asking for another conference.
Plaintiff agrees to withdraw RFA Nos. 8, 30 and issue new RFAs incorporating the definition of negative
performance review proposed in Plaintiff s meet-and-confer letter and a time limitation with respect to
RFA No. 30 limited to the time both Plaintiff and the other employee were employed by Defendant.
Defendant agrees to respond with more than an objection.
The parties are unable to agree on:
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Case Number: 21-CIV-04310
whether Defendant will supplement its response to FROG 209.2;
whether Defendant will supplement its response to SROG No. 8, 9, 10, 15.
whether Defendant will respond with more than objections to RFA No. 9. Counsel have agreed to meet-
and-confer one more time on Plaintiff s proposal to limit RFA No. 9 to only the employees at Plaintiff s
office from January 1, 2017 to the present.
Whether Defendant will supplement its responses to RFA Nos. 46-47.
whether Defendant will provide supplemental responses to RFP Nos. 29, 30, 32, 33, 35, 59-62, 65-69
(Plaintiff s counsel agrees to send Defense counsel an email specifying how Plaintiff would be willing to
narrow, and what documents Plaintiff would be willing to accept for 65-69.
Either party may make a discovery motion with respect to the FROGs, SROGs, and RFAs on which they
cannot agree without asking for another conference. The parties agree that any motion with respect to
the discovery identified in these minutes will be considered timely if filed on or before March 28, 2022.
Counsel agree to exchange an email confirming their agreement about the motion deadline.
Case Events
- Party appeared by audio and/or video; Gary S. Brotman for Plaintiff Monika Chopra & Harold Jones for
Defendant Natera, Inc.
Others
Comments:
Future Hearings and Vacated Hearings
March 30, 2022 1:30 PM Order to Show Cause Re: Failed to File Stip and Order to ADR
Courtroom P
Halperin, Ernst A.
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Preview
Case Number: 21-CIV-04310 SUPERIOR COURT OF SAN MATEO COUNTY 400 County Center 1050 Mission Road Redwood City, CA 94063 South San Francisco, CA 94080 www.sanmateocourt.org Minute Order Monika Chopra vs. Natera, Inc, a Delaware corporation, et al 21-CIV-04310 02/03/2022 3:00 PM Informal Discovery Conference Hearing Result: Held Judicial Officer: Halperin, Ernst A. Location: Courtroom P Courtroom Clerk: Eresmia Ouranitsas Courtroom Reporter: Parties Present Exhibits Minutes Journals - Conference held from 3:02 p.m. to 4:03 p.m. Gary S. Brotman for Plaintiff Monika Chopra Harold Jones for Defendant Natera, Inc. The parties have agreed that the Entity Deposition of Defendant Natera, Inc. will take place between March 7 and March 16 on mutually agreeable dates. Defendant agrees to serve, no later than February 24, 2022 at 5:00 p.m., verified supplemental responses and responsive documents to: Plaintiff s FROGs 3.7, 4.1, 200.1, 200.3, 200.4, 201.1, 201.7, 204.7, 211.1 and 214.1. SROGs Nos. 3, 11, 12, 13, 14, 17, 23, 25, 26, 27, 29, 30. In responding to the special interrogatories 27, 28, 29, and 30, Defendant agrees to provide a supplemental response to the extent the information is available to Defendant. RFA Nos. 16, 18, 20, 24, 26, and 29 and FROG 17.1 with respect to those RFAs. RFP. 36, 52, 53, 55, For any verified supplemental responses not served by the above-date, either party may make a discovery motion without asking for another conference. Plaintiff agrees to withdraw RFA Nos. 8, 30 and issue new RFAs incorporating the definition of negative performance review proposed in Plaintiff s meet-and-confer letter and a time limitation with respect to RFA No. 30 limited to the time both Plaintiff and the other employee were employed by Defendant. Defendant agrees to respond with more than an objection. The parties are unable to agree on: 1 Case Number: 21-CIV-04310 whether Defendant will supplement its response to FROG 209.2; whether Defendant will supplement its response to SROG No. 8, 9, 10, 15. whether Defendant will respond with more than objections to RFA No. 9. Counsel have agreed to meet- and-confer one more time on Plaintiff s proposal to limit RFA No. 9 to only the employees at Plaintiff s office from January 1, 2017 to the present. Whether Defendant will supplement its responses to RFA Nos. 46-47. whether Defendant will provide supplemental responses to RFP Nos. 29, 30, 32, 33, 35, 59-62, 65-69 (Plaintiff s counsel agrees to send Defense counsel an email specifying how Plaintiff would be willing to narrow, and what documents Plaintiff would be willing to accept for 65-69. Either party may make a discovery motion with respect to the FROGs, SROGs, and RFAs on which they cannot agree without asking for another conference. The parties agree that any motion with respect to the discovery identified in these minutes will be considered timely if filed on or before March 28, 2022. Counsel agree to exchange an email confirming their agreement about the motion deadline. Case Events - Party appeared by audio and/or video; Gary S. Brotman for Plaintiff Monika Chopra & Harold Jones for Defendant Natera, Inc. Others Comments: Future Hearings and Vacated Hearings March 30, 2022 1:30 PM Order to Show Cause Re: Failed to File Stip and Order to ADR Courtroom P Halperin, Ernst A. 2