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SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Feb-19-2013 10:37 am
Case Number: CGC-12-524871
Filing Date: Feb-19-2013 10:36
Filed by: WESLEY G. RAMIREZ
Juke Box: 001 Image: 03946955
CASE MANAGEMENT STATEMENT
SHELLEY KRAMER VS. KAUFMAN DOLOWICH VOLUCK & GONZO LLP, A
LIMITED et al
001003946955
Instructions:
Please place this sheet on top of the document to be scanned.CM-110
"ATTORNEY OR PARTY WITHOUT ATTORNEY (Wome, State Bar number and address) FOR COURT USE ONLY |
$)
BOGAARDS LAW OFFICES SBN: 107803 i
PIETER BOGAARDS i
103 E. Blithedale Ave, Suite 10
MILL VALLEY, CA 94941 I
TevepHone No: 415.381-5002 AX NO. (Optional; 415,38 1-5009 F fi
EMAIL ADDRESS (Optonap. pieter@bogaards.com SyisBrlar dock of
ATTORNEY FOR (vemey Shelley Kramer asin of Man Prancle
SUPERIOR COURT OF CALIFORNIA, COUNTY OFSAN FRANCISCO 4g |
srnecr Aooness 400 McAllister Street FEB 19 erg |
maitine Aporess 400 McAllister Street Cc
cary anozie cove San Francisco, 94102 By. LERK
BRANCH NAME: Civic Center Courthouse .
PLAINTIFF/PETITIONER: Shelley Kramer
OEFENDANT/RESPONDENT: Kaufman Dolowich Voluck & Gonzo, LLP
CASE MANAGEMENT STATEMENT CASE NUMBER: i
(Check one): [XC] UNLIMITED CASE [1 umiteo case CGC 12-524871 |
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
a LX)
b. This statement is submitted jointly by parties (names)
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) RB ¥
A CASE MANAGEMENT CONFERENCE is scheduled as follows: |
Date:March 6, 2013 Time: 10:30 a.m. Dept.: Div.: Room: 61
Address of court (if different from the address above):
[XX] Notice of Intent to Appear by Telephone, by (name):Pieter Bogaards
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provi ed.
1. Party or parties (answer one):
This statement is submitted by party (name): Plaintiff Shelley Kramer :
a. The complaint was filed on (date): October 2, 2012
b. () The cross-complaint, if any, was filed on (date):
a. (2X1 Ali parties named in the complaint and cross-complaint have been served, have appeared, or have been
b. The following parties named in the complaint or cross-complaint
(1) (21 have not been served (specify names and explain why not): /
3. Service (to be answered by plaintiffs and cross-complainants only) 4.
(2) [1 have been served but have not appeared and have not been dismissed (specify names): |
(3) have had a default entered against them (specify names):
they may be served):
c. [1] The following additional parties may be added (specify names, nature of involvement in case, and date by pen
|
4. Description of case
issed.
a. Typeofcasein [X] complaint [77] cross-complaint (Describe, including causes of action): Wrobgful
Termination. Disabilty Discrimination/Harassment/Retaliation
Forma Adopted fof Mandatory Use CASE MANAGEMENT STATEMENT
'CM-110 fRev. July 1, 2011]fs
“CASE NUMBER:
PLAINTIFF/PETITIONER: Shelley Ki
LAINTIFEI eney Samer CGC 12-524871
JEFENDANT/RESPONDENT: Kaufman Dolowich Voluck & Gonzo, LLP
b, Provide a brief statement of the case, including any damages. (/f personal injury damages are sought, specify the hi and
4
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expénses, lost
earings to date, and estimated future lost earnings. if equitable relief is sought, describe the nature of the relief) |
Plaintiff was an attorney working for defendant. She suffered a seizure and a brain tumor was discovered and rempved. Two
months later she was terminated by Defednants due th her perceived disability. She has suffered lost income in excess of $150K.
to date, with future lost earnings anticiapted to be $150K p/a. Plaintiff seeks declaratory and injunctive relief to bat Defendants
discriminatrory actions and policies. i
[1 (ttmore space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial |
The party or parties request [7X] a jury trial [7] anonjury trial, (if more than one party, provide the name of each party
requesting a jury trial): i
6. Trial date
(2) The trial! has been set for (date): |
b. [2X] Notrial date has been set. This case will be ready for trial within 12 months of the date of the filing of the corbpiaint (if
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons “ranaecinny:
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [2%] days (specify number): 15
b. [_] hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial [X] by the attorney or party listed in the caption [[_] by the followi 9:
a. Attorney:
b. Firm: {
c. Address:
d. Telephone number: f. Fax number: i
e. E-mail address: g. Party represented:
[] 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 commibnities; read
the ADR information package provided by the court under rule 3.221 for information about the processes availablé through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel (X] has [—] has not provided the ADR information pack§ge identified
in rule 3.221 to the client and reviewed ADR options with the dient.
(2) For self-represented parties: Party [—_] has [_] has not reviewed the ADR information package identifiedjn rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or fo civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exbeed the
statutory limit.
(2) [] 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) [2%] This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civillaction
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): Amount at issue - sdeks
injunctive relief
CM-110 fRev. Juty 4, 2019) CASE MANAGEMENT STATEMENTPLAINTIFF/PETITIONER: Shelley Kramer ‘NUMBER: i
DEFENDANT/RESPONDENT: Kaufman Dolowich Voluck & Gonzo, LLP CGC 12-524871
10. ¢. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participa
have already participated in (check all that apply and provide the specified information):
(2) Settlement
conference
The party or parties completing
this form are willing to
participate in the following ADR
processes (check all that apply):
If the party or parties completing this form in the case have a
participate in or have already completed an ADR process or
indicate the status of the processes (attach a copy of the pai
stipulation): j
Mediation session not yet scheduled
Mediation session scheduled for (date):April 30, 20
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
Settlement conference scheduled for (date):
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
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (data):
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date):
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date).
(4) Nonbinding judicial
arbitration
Private arbitration not yet scheduled
(6) Binding private Private arbitration scheduled for (date):
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
AOR session not yet scheduled
AOR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
OOOO;O000;0000/0000/0000)0080
ADR completed on (date):
GHEO ow dy 120011 CASE MANAGEMENT STATEMENTPLAINTIFF/PETITIONERShelley Kramer (CASE NUMBER:
[— CGC 12-524871
DEFENDANT/RESPONDENTKaufman Dolowich Voluck & Gonzo, LLP
11. Insurance
a. (J Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: ~] Yes [J] No
c. [J 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.
Bankruptcy [—] Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. [_] There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court
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(3) Case number:
(4) Status:
[] Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate will be filed by (name party):
14, Bifurcation
[1 The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues
action (specify moving party, type of motion, and reasons):
15. Other motions
[5X1 The pany or parties expect to file the following motions before trial (specify moving party, type of motion, and iss
Motion to Amend to add COA for Failure to Accommodate and Prayer for Injunctive and Declaratory Relief fc
Disabiity Discrimination.
16. Discovery
a. The party or parties have completed all discovery.
b. (0) The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiff Subpoena of Third Parties August 30, 201
Plaintiff Written Discovery June 30, 2013
Plaintiff Depositions July 30, 2013
c. [XX] The following discovery issues, including issues regarding the discovery of electronically stored information,
anticipated (specify): Plaintiff has Motions to Compel and for a Protective order are pending and to be he
February 21, 2013. Judge Pro Tem recommendation granted Plaintiff's motions, and denied Defendants.
Further MTC for the second and third set of discovery requests are anticipated to be filed based on Defend:
inadequate repsonses and failure to produce.
‘CM-110 Rev. July 1, 2019] CASE MANAGEMENT STATEMENTi
PLAINTIFF/PETITIONER: Shelley Kramer ‘CASE NUMBER. |
Ty CGC 12-524871 |
DEFENDANT/RESPONDENT: Kaufman Dolowich Voluck & Gonzo, LLP
17. Economic litigation |
a. 7] This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedufes in Code
of Civil Procedure sections 90-98 will apply to this case. .
b. [] 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
[1 The party or parties request that the following additional matters be considered or determined at the case mana
conference (specify):
19, Meet and confer
a. LX] The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the Calif
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 fc
(specify):
20. Total number of pages attached (if any): 0
| am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues
the case management conference, including the written authority of the party where required.
Date: February 18, 2013
‘
BOGAARDS LAW OFFICES » Ve
(TYPE OR PRINT NAME) {sic \TURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
‘CME110 Rev. duly 1, 2011) CASE MANAGEMENT STATEMENTwon
n wo
PIETER BOGAARDS (#107803)
Attorney at Law
103 E. Blithedale Avenue, Suite 10
Mill Valley, CA 94941
(415) 381-5002
FAX (415) 381-5009
pieter@bogaards.com
Attorney for Plaintiff
Shelley Kramer
SUPERIOR COURT OF THE STATE OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO
SHELLEY KRAMER, Case No. CGC-12-524871
Plaintiff,
)
) PROOF OF SERVICE
vs. }
KAUFMAN DOLOWICH VOLUCK & )
GONZO LLP, a Limited Liability )
Partnership registered with the California )
State Bar (No. 54084), KATHERINE )
CATLOS, an individual, and DOES | - )
20, inclusive, )
)
)
Defendants.
PROOF OF SERVICE
-i-q
|
lam a citizen of the United States and employed in the County of Marin; I am over the age of eighteen
years and not a party to the within action; my business address is 103 E. Blithedte} Ste. 10, Mill’
Valley, CA 94941.
On February 18, 2013 I served the following document(s): i
CASE MANAGEMENT STATEMENT
Addressed as follows: |
Nancy McCarthy
1000 Drakes Landing Road i
Greenbrae, CA 94904
Tel: 415.485-1220 t
Fax: 415.454-9633 i !
E-mail: Maczord@aol.com i
By depositing a true copy thereof in the United States mail at Mill Valley, California, in a’
sealed envelope, with first-class postage thereon fully prepaid, to the address indicated above.
X___By hand service to the address indicated above.
By depositing a true copy thereof in a depository for FEDERAL EXPRESS k, overnight
courier service to the address indicated above.
By depositing a true copy thereof in the United States Postal Service for ove Express
Mail delivery service to the address indicated above.
I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct.
Dated: February 18, 2013 LAW OFFICES OF PIETER BOGAARDS
By: *
PIETER BOGMARDS, ESQ.
Attorney for Plaintiff Shelley Kramer
PROOF OF SERVICE -1-