Preview
F11E0/E!^D0F:SE0
1 JOSHUA S. FALAKASSA (SBN: 295045)
FALAKASSA LAW, P.C.
2 1901 Avenue ofthe Stars Suite # 450 AUG 0 h 2022
3 Los Angeles, Califomia 90067 By: 'Vui.o-'i'jid
Tel.: (818) 456-6168; Fax: (888) 505-0868
4 Email: josh@falakassalaw.com
5 ARASH S. KHOSROWSHAHI (SBN: 293246)
6 LIBERTY MAN LAW, P.C.
1010 F Street, Ste. 300
7 Sacramento, Califomia 95814
Tel.: (916) 573-0469; Fax: (866) 700-0787
8 Email: ash@libertymanlaw.com
9
Attomeys for Plaintiff,
10 SAJIDA ZAMAN
11 SUPERIOR COURT OF CALIFORNIA
12
COUNTY OF SACRAMENTO BY FAX
13
14
SAJIDA ZAMAN, CASE NO.: 34-2019-00252121
15
Plaintiff, DECLARATION OF ARASH S.
16 KHOSROWSHAHI IN SUPPORT OF EX
vs.
PARTE APPLICATION FOR ORDER (1)
17 SPECIALLY SETTING HEARINGS ON
LIQUI-BOX CORPORATION, and DOES 1
18 through 20, inclusive. DISCOVERY MOTIONS; (2)
CONTINUING MOTION FOR
19 Defendants. SUMMARY JUDGMENT/SUMMARY
ADJUDICATION HEARING; AND (3)
20 FOR LEAVE TO FILE ADDITIONAL
EVIDENCE IN OPPOSITION TO
21
DEFENDANT'S MOTION FOR
22 SUMMARY JUDGMENT/SUMMARY
ADJUDICATION
23
Date: August 5,2022
24 Time: 9:00am
25 Dept.: 53
Trial Date: September 12,2022
26
27
28
DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
1 of 8
1 I, ARASH KHOSROWSHAHI, declare as follows:
2 1. I am an attomey licensed to practice law in the State of Califomia. My State Bar Numbei
3 is 293246.
4 2. I represent Plaintiff Sajida Zaman ("Plaintiff') in the above-entitled action. I have
5 knowledge of the facts stated herein and can testify competently thereto.
6 3. Defendant at the eleventh hour on May 18, 2022 sought ex parte relief to set a hearing
7 date of August 10, 2022 for its MSJ. After this Court granted relief, the MSJ was then
8 served at the last possible minute on May 27, 2022, providing exactly 75 days' notice to
9 Plaintiff, and giving her only the minimalttmeto file an opposition by the July 27, 2022
10 deadline.
11 4. After Plaintiff requested Defendant's OSHA logs via letter. Defendant's counsel delayed
12 production by several days, only producing documents relevant to Plaintiffs employment,
13 rather than all "current or stored" logs Defendant has in its possession, custody, or control.
14 5. Plaintiff thereafter served her Requests for Production of Documents, Set Four, on or
15 about May 18, 2022, asking for all documents compromising Defendant's (1) OSHA 300
16 (Request for Production of Documents, Set Four, No. 1), (2) OSHA 300a (Id., No. 2), and
17 (3) OSHA 301 (Id., No.3) at its Sacramento facility where Plainttff worked. (Attached as
18 Exhibit A is a tme and correct copy of Plaintiff Sajida Zaman's Requests for Production
19 of Documents to Defendant LiquiBox, Inc., Set Four (4).)
20 6. Plaintiff that same day also served her Special Interrogatories, Set Three, on or about May
21 18, 2022, asking (1) identtfying information of persons responsible for drafting OSHA
22 300, 300a, and 301 logs ("OSHA logs") at Defendant's Sacramento facility (Special
23 Interrogatory, Set Three, No. 30); (2) identifying information of persons responsible for
24 storing OSHA logs at Defendant's Sacramento facility (Id., No. 31); (3) identifying
25 information of persons with knowledge of Defendant's procedures relating to the drafting
26 and storing of the OSHA logs at the Sacramento facility (Id., No. 32); and (4) to describe
27 where the OSHA logs are stored at the Sacramento facility (Id., No. 33). (Attached as
28
DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
2 of 8
1 Exhibit B is a tme and correct copy of Plaintiff Sajida Zaman's Special Interrogatories to
2 Defendant Liqui-Box Corporation (Set Three).)
3 7. On or about June 21, 2022, rather than provided responses. Defendant continued its
4 obstmction by serving only meritless, boilerplate objections to Plaintiffs requests for
5 documents and interrogatories. Plaintiff met and conferred as to the objections in attempts
6 to obtain responses/documents and informally resolve the issues, but Defendant never
7 provided responses or documents.
8 8. Plaintiff thereafter filed her motions to compel on Special Interrogatories, Set Three (Res.
9 ID: 2664201) and Requests for Production of Documents, Set Four (Res. ID: 2664202) to
10 be heard on October 18, 2022.
11 9. On or about May 24, 2022, Plaintiff propounded her fifth set of Requests for Production
12 of Documents to Defendant. (Declaration of Arash S. Khosrowshahi in Support ["Khos.
13 Decl."], I 3; attached as Exhibit C is a tme and correct copy of Plaintiff Sajida Zaman's
14 Requests for the Inspection and Production of Documents and Other Things to Defendant
15 Liqui-Box Corporation (Set Five).) Notably, Request for Production No. 1 (the only
16 propounded request in the set) asked for: "All documents YOU identified in YOUR
17 responses to Plaintiff Sajida Zaman's Special Interrogatories to Defendant Liqui-Box
18 Corporation Set Four (4)." (See Exhibit C.)
19 10. The referenced Special Interrogatories, Set Four, were also served that same day,
20 and in sum ask forthe following information: (1) the identifying information of employees
21 who worked at Defendant's Sacramento facility who (a) Defendant contends violated the
22 CSB Policy in the last 10 years (Special hiterrogatory. Set 4, No. 34); (b) Defendant
23 reprimanded for violating the CSB policy in the last 10 years (Id., No. 35); (c) Defendant
24 terminated for violating the CSB policy in the last 10 years (Id., No. 36); (2)(a) identifying
25 information of each person with knowledge of each reprimand (Id., No. 37); (b) all facts
26 which supported each reprimand (Id., No. 38); (c) all documents containing information
27 Defendant relied on in the decision to reprimand (Id., No. 39); (3)(a) identifying
28 information of each person with knowledge of each termination (Id., No. 40); (b) all facts
DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
3 of 8
1 which supported each termination (Id., No. 41); (c) all documents containing information
2 Defendant relied on in the decision to termination (Id., No. 42). (Attached as Exhibit D
3 is a tme and correct copy of Plaintiff Sajida Zaman's Special Interrogatories to Defendant
4 Liqui-Box Corporation (Set Four).)
5 11. Rather than respond, on or about June 27, 2022 Defendant provided only
6 boilerplate objections to the requests as well as the interrogatories. Plaintiff met and
7 conferred as to the objections in attempts to obtain responses/documents, and informally
8 resolve the issues, but Defendant never provided responses or documents.
9 12. Plaintiff thereafter filed her motions to compel on Special Interrogatories, Set Four (Res.
10 ID: 2664199) and Requests for Production of Documents, Set Five (Res. ID: 2664198) to
11 be heard on October 18, 2022.
12 13. On May 27, 2022 Plaintiff served her fifth set of Special Interrogatories propounded
13 against Defendant via email. (Attached as Exhibit E is a tme and correct copy of Plaintiff
14 Sajida Zaman's Special Interrogatories to Defendant Liqui-Box Corporation (Set Five).)
15 14. The Special Interrogatories contained 22 separate interrogatories in relevant part asking
16 for: (1) safetyttainingsDefendant contends it provided Plaintiff and when they occurred
17 (Special Interrogatories, Nos. 45-46); (2) all steps Defendant took to evaluate modified
18 work duties to accommodate Plaintiff (Id., No. 48); (3) the date Plaintiffs injury was first
19 identified (Id., No. 49); (4) the percentage of employees who missed work due to
20 cumulative ttauma injuries or not in the last five years (Id., Nos. 50-51.); (5) all
21 facts/witnesses/documents in support of Defendant's contention that defective ttolleys
22 Plaintiff worked on were repaired (Id., No. 52-54); (6) all facts/documents in support of
23 the contention that Defendantttainedemployees to identify disease, condition or injury
24 from their signs and symptoms (Id., Nos. 56-57); (7) all facts/witnesses/document in
25 support of the contention that Plaintiff was diagnosed with a left knee and hamstring pain
26 in relation to her 4 Panel EHS Disciplinary Review. (Id. Nos. 58-59); (8) whether
27 Defendant contends Plaintiff injuries were caused by her failure to follow Defendant's
28 instmctions provided in her training on proper operation of mega tote carts, and all
DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
4 of 8
1 supporting facts (Id., Nos. 60-61); (9) whether attendance for such mega tote cart ttainings
2 were mandatory (Id., No. 62); (10) the identities of all persons present for mega tote cart
3 trainings, as well as all documents reflecting the matters presented at the ttainings (Id.,
4 Nos. 63-64); and (11) all facts supporting Defendant's contention that Plaintiffs actions
5 leading to her injuries were inconsistent with anyttainingsprovided. (Id., No. 65.) (See
6 Exhibit E.)
7 15. However, Defendant never served any objections or responses to the Special
8 Interrogatories. Plaintiff thereafterfiledher motions to compel on Special Interrogatories,
9 Set Five (Res. ID: 2664200) to be heard on October 18, 2022.
10 16. On May 27, 2022 Plaintiff served her second set of Form Interrogatories—General
11 propounded against Defendant via email. (Attached as Exhibit F is a tme and correct copy
12 of Plaintiff Sajida Zaman's Form Interrogatories—General, Set Two.) The interrogatories
13 were concurrently served with Plaintiffs Requests for Admissions to Defendant Liqui-
14 Box Corporation (Set One) (Attached as Exhibit G is a tme and correct copy of Plaintiff
15 Sajida Zaman's Requests for Admissions, Set One), and contained a single interrogatory,
16 No. 17.1, which required the Defendant to provide all facts, witnesses, and documents in
17 support of any denial or qualified admission to the Requests for Admissions. (See Exhibit
18 F.)
19 17. The Requests for Admissions themselves in relevant part asked Defendant to admit
20 information regarding: (1) Plaintiff not beingttainedon the CSB immediate reporting
21 requirement; (2) not being trained on recognizing signs of cumulativettaumainjuries or
22 gradually worsening symptoms such as her sttained knee/hamstting muscle; (3) that
23 Plaintiffs injury was cumulative in nature caused by repeated trauma over time and not
24 caused by a single event accident; (4) that Plaintiffs injury was not diagnosed sooner than
25 January 3, 2019; (5) that Defendant never discussed PiaintifFsrightsunder the FEHA
26 during her alleged late reporting; (6) that Plaintiffs work restrictions did not prohibit her
27 from performing all ofher essential job functions; (7) that the CSB policy does not require
28 employees to immediately report all physical pain until they leam their pain is connected
DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
5 of 8
1 to an injury; and (8) Plaintiff never beingttainedon distinguishing bodily sensations such
2 as soreness due to fatigue, from workplace injuries. (See Exhibit G, Requests for
3 Admissions Nos. 1 through 23.)
4 18. Because Defendant did not timely serve responses or objections. Plaintiff thereafter filed
5 her motion to compel on Form Interrogatories—General, Set Two (Res. ID: 2656706) and
6 motion to deem admitted the Requests for Admissions, Set One (Res. ID: 2656705) to be
7 heard on September 1 2022.
8 19. After having filed her Opposition to Defendant's MSJ on July 27,2022, Defendant finally
9 served its responses to Plaintiffs Requests for Admissions, Set 1 on August 1, 2022.
10 (Attached as Exhibit H is a tme and correct copy of Defendant's Responses to Requests
11 for Admissions, Set 1.) Of course. Plaintiff never had the opportunity to rely on this
12 discovery when drafting her opposition to the MSJ. This is despite the fact that Defendant
13 verified these responses on July 25,2022, two whole days before PlaintifPs opposition
14 was due. (See verification to Exhibit H.)
15 20. Plaintiffhas never sought prior continuances on the MSJ hearing date and has yet to have
16 sought ex parte relief in this matter.
17 21. After Plaintiff reported her knee pain on January 3, 2019, Defendant had Plaintiff
18 complete an AS 1059 investigation report. (Attached as Exhibit I is a tme and correct copy
19 of Plaintiffs AS 1059 investigation report.) Subsequently, Defendant's Manager of
20 Human Resources Janene Whitney, along with Chief Operating Officer Andrew
21 McLeland, Chief Human Resources Officer Angela Kenyon, and Supervisor Ken Villani,
22 all emailed one another about how PlaintifTs injury would be an OSHA recordable injury
23 for 2018, and how they would push back against Plaintiffs workers compensation claim,
24 as they were claiming Plaintiffs injury was first known to Plaintiff December 3, 2018,
25 not January 3, 2019. (Attached as Exhibit J is a tme and correct copy ofthe January 3,
26 2019 emails between Defendant's management discussing Plaintiffs work-related
27 injury.) Defendants then used their intemal "4 Panel EHS Disciplinary Review'" to claim
28 Plaintiff was diagnosed with a knee and hamstring sprain, and to claim Plaintiff reported
DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
6 of 8
1 her injury late, as pretextual justification for terminating her employment for not reporting
2 her injury immediately per the CSB policy. (Attached as Exhibit K is a tme and correct
3 copy ofPlaintiffs 4 Panel EHS Disciplinary Report.)
4 22. Attached as Exhibit L is a tme and correct copy of Plaintiffs workers compensation
5 medical records dated January 3, 2019 diagnosing her with sttain, not sprain, injuries;
6 compare with Exhibit K characterizing the injury as a sprain.)
7 23. Defendant made verified denials that their CSB policy (1) "did not require Plaintiff to
8 report pain unless and until Plaintiff identified her pain as connected to a workplace
9 injury." (Response to Requests for Admissions, Set 1, No. 13) and (2) did not require
10 employees to "immediately report all physical pain, unless and until the employee leams
11 that the pain is connected to an actual injury." (Id., No. 12) (See Exhibit H.)
12 24. Defendant admits it "neverttained"employees that they "must" report injuries regardless
13 of her knowledge of them. (Response to Requests for Admissions, Set 1, No. 2) (See
14 Exhibit H.)
15 25. Defendant now admits it never trained employees in how to recognize early signs of such
16 cumulative trauma injuries such as a sttained knee or a sttained hamstring muscle.
17 (Response to Requests for Admissions, Set 1, No. 3). (See Exhibit H.)
18 26. All ofPlaintiffs aforementioned discovery motions have been filed and timely served
19 upon Defendant.
20 27.1 called Defendant's counsel Mr. James Jones at Jackson Lewis, P.C. at 8:37am Thursday
21 August 4, 2022, given him ex parte notice that Plaintiff was seeking to specially set her
22 discovery motions for on or before September 1, 2022; that Plaintiff was seeking a 60 day
23 continuance on the MSJ hearing date; that Plaintiff sought leave to provide a supplemental
24 brief in opposition to the MSJ after the discovery motions were heard; and that in the
25 altemative Plaintiff sought to specially set her discovery motions for September 1, 2022.
26 I informed Mr. Jones the hearing was scheduled for August 5, 2022, at 9:00am in
27 Department 53. Mr. Jones did not indicate that he would oppose the ex parte application,
28 though he wished to participate in setting dates.
DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
7 of 8
1 I declare under penalty of perjury under the laws of the State of Califomia that the
2 foregoing is tme and correct.
3 Dated: August 4, 2022
4
5 By:
Arash S. Khosrowshahi
6 Attomey for Plaintiff Sajida Zaman
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
8 of 8
EXHIBIT A
1FALAKASSA LAW, P.C.
Joshua S. Falakassa (SBN: 295045)
2 1901 Ave. ofthe Stars, Suite #450
3 Los Angeles, Califomia 90067
Tel.: (818) 456-6168; Fax:
4 Email: josh@falakassalaw.com
5 LIBERTY MAN LAW, P.C.
6 Arash S. Khosrowshahi (SBN: 293246)
1010 F Stteet, Ste. 300
7 Sacramento, Califomia 95814
Tel.: (916) 573-0469; Fax: (866) 700-0787
8 Email: ash@libertymanlaw.com
9
Attomeys for Plaintiff,
10 SAJIDA ZAMAN
11 SUPERIOR COURT OF CALIFORNIA
12
COUNTY OF SACRAMENTO
13
14 SAJIDA ZAMAN, an individual. Case No.: 34-2019-00252121
15 Plaintiff,
16 vs. PLAINTIFF SAJIDA ZAMAN'S
REQUESTS FOR PRODUCTION OF
17 LIQUI-BOX CORPORATION, and DOES 1 DOCUMENTS TO DEFENDANT
through 20, inclusive. LIQUIBOX, INC., SET FOUR (4)
18
19 Defendants
20
21
22
23
PROPOUNDING PARTY PLAINTIFF, SAJIDA ZAMAN
24
RESPONDING PARTY DEFENDANT, LIQUI-BOX CORPORATION
25
SET NUMBER FOUR (4)
26
27
28
1 of 4
1
TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEYS OF
2
RECORD:
3
Plaintiff requests pursuant to Code ofCivil Procedure §§ 2031.010, e^je^. that within thirty
4
(30) days of service of this demand for production of documents, the above-named Defendani
5
serve a written statement addressing each demand to the effect that it will comply, it lacks the
6
ability to comply, or it finds a particular demand objectionable. However, in accordance with
7
Code of Civil Procedure §§ 2031.010, et seq., if a response contains an objection, it must identify
8
with particularity any document falling within the demand to which the objection is being made.
9
Plaintiff also requests, pursuant to Code of Civil Procedure §§ 2031.010, et seq., that within
10
thirty (30) days of service of this demand for production of documents, the above-named
11
Defendant produce the writings, documents, items, and things herein below listed which are
12
believed to be in its custody, possession, and conttol, for inspection and copying by Plaintiff and
13
his counsels at LIBERTY MAN LAW, P.C, 1010 F Street, Ste. 300, Sacramento, Califomia
14
15 95814, and FALAKASSA LAW, P.C, 1901 Avenue ofthe Stars, Suite #450, Los Angeles
16 Califomia 90067. Said writings, documents, items, and things are non-privileged and are
17 reasonably calculated to lead to the discovery of admissible evidence.
18 A personal appearance by said Defendant or its counsel is not required if said Defendani
19 will submit copies of the documents described below with verification, executed under penalty of
20 perjury, that the documents provided are tme, correct, and complete duplicates of the original
21 documents requested and that the copies provided are tme, correct, and complete copies of the
22 records requested.
23 DEFINITIONS
24 Words that are in CAPITALS are defined as follows:
25 (a) "LIQUI-BOX", "YOU" or "YOUR" as used herein, includes, describes and refers
26 to Defendant LIQUI-BOX CORPORATION, its subsidiaries, its parent/holding companies, its
27 agents, representatives, investigators, employees, conttactors, govemmental entities, insurance
28
2 of 4
1
companies, their agents, their employees, their investigators, their representatives and anyone else
2
acting on Defendant LIQUI-BOX CORPORATION behalf except its herein attomeys.
3
(b) "DOCUMENT(S)", as used herein, shall refer to, mean and include any tangible
4
thing upon which any expression, communication or representation has been recorded by any
5
means, including, but not limited to, all writings, as defined in Evidence Code § 250, including the
6
original or a copy of handwriting,typewriting,printing, photostating, photographing, electtonic
7
and/or all other means of recording upon any tangible or electtonic medium and/or thing as well
8
as all forms of communication or representation, including letters, words, pictures, sounds oi
9
symbols, or any combination thereof.
10
(c) "COMMUNICATION" or "COMMUNICATIONS" as used herein shall mean
11
and refer to any written, oral, or telephonic communication including thettansmissionor exchange
12
of any kind of DOCUMENT or DOCUMENTS as those terms are previously defined, including,
13
14 without limitation, face-to-face conversations, meetings, telephone conversations, voice mail
15 messages, electronic mail, messages stored on the intemet, inquiries, representations, discussions,
16 negotiations, agreements, understandings, letters, notes, telegrams, interviews, or any othei
17 method of communication.
18 REQUESTS FOR THE INSPECTION AND PRODUCTION OF DOCUMENTS AND
19 OTHER THINGS
20 REOUEST FOR PRODUCTION NO. 1
21 All DOCUMENTS comprising OSHA 300 logs detailing any injury/illness at YOUR
22 Sacramento facility. (The phrase "Sacramento facility" shall herein mean the business at 5000
23 Warehouse Way Sacramento, CA 95826 USA.)
24 REOUEST FOR PRODUCTION NO. 2
25 All DOCUMENTS comprising OSHA 300a logs detailing any injury/illness at YOUR
26 Sacramento facility.
27 ///
28 ///
3 of 4
1
REOUEST FOR PRODUCTION NO. 3
2
All DOCUMENTS comprising OSHA 301 logs detailing any injury/illness at YOUR
3
Sacramento facility.
4
5
Dated: May 18, 2022 FALAKASSA LAW, P.C.
6 LIBERTY MAN LAW, P.C.
7
8
BY:
9
10
JOSHUA S. FALAKASSA
11 ARASH KHOSROWSHAHI
Attomeys for Plaintiff SAJIDA ZAMAN
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4 of 4
EXHIBIT B
1 JOSHUA S. FALAKASSA (SBN: 295045)
FALAKASSA LAW, P.C.
2 1901 Avenue ofthe Stars Suite #450
Los Angeles, Califomia 90067
3 Tel.: (818) 456-6168
4 Fax:(888)505-0868
Email: josh@falakassalaw.com
5
LIBERTY MAN LAW, P.C.
6 ARASH S. KHOSROWSHAHI (SBN: 293246)
1010 F Stteet, Ste. 300
7
Sacramento, Califomia 95814
8 Tel.: (916) 573-0469
Fax: (866) 700-0787
9 Email: ash@libertymanlaw.com
10
Attomeys for Plaintiff
11 SAJIDA ZAMAN
12
SUPERIOR COURT OF CALIFORNIA
13
COUNTY OF SACRAMENTO
14
15
SAJIDA ZAMAN, an individual. CASENO.: 34-2019-00252121
16
PLAINTIFF SAJIDA ZAMAN'S SPECIAL
17 Plaintiff, INTERROGATORIES TO DEFENDANT
vs. LIQUI-BOX CORPORATION (SET
18 THREE)
LIQUI-BOX CORPORATION, and DOES 1
19 through 20, inclusive.
20 Defendants.
21
22
23
24
25 PROPOUNDING PARTY SAJIDA ZAMAN
26 RESPONDING PARTY LIQUI-BOX CORPORATION
27 SET NUMBER THREE (3)
28
PLAINTIFF SAJIDA ZAMAN'S SPECL\L INTERROGATORIES TO DEFENDANT LIQUI-
BOX CORPORATION (SET THREE)
1
TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD:
2
Plaintiff SAJIDA ZAMAN hereby requests that Defendant LIQUI-BOX
3
CORPORATION answer under oath within thirty (30) days, pursuant to Califomia Code of Civil
4
Procedure §§ 2030.010 et seq., the following interrogatories.
5
In answering these interrogatories please fumish such information as is available to you,
6
and not merely that which you know of your personal knowledge. This means that you are to
7
fiimish information which is available to you or is within the knowledge of your attomeys, or
8
their agents, employees, investigators or experts. (See Code of Civil Procedure §§ 2030.010 et
9
seq.)
10
If any of these interrogatories cannot be answered in full, you are required to answer to
11
the extent possible, specifying the reason for your inability to answer the remainder and stating
12
whatever information or knowledge you have conceming the unanswered portion.
13
DEFINITIONS
14
Words that are in CAPITALS are defined as follows:
15
(a) "LIQUI-BOX", "YOU" or "YOUR" as used herein, includes, describes and refers
16
to Defendant LIQUI-BOX CORPORATION, its subsidiaries, its parent/holding companies, its
17
agents, representatives, investigators, employees, conttactors, govemmental entities, insurance
18
companies, their agents, their employees, their investigators, their representatives and anyone else
19
acting on Defendant LIQUI-BOX CORPORATION behalf except its herein attomeys.
20
21 (b) PERSON includes a natural person, firm, association, organization, partnership,
22 business, tmst, limited liability company, corporation, or public entity.
23 SPECIAL INTERROGATORIES
24 SPECIAL INTERROGATORY NO. 30:
25 Please identify, by name, address and telephone number the PERSON(S) responsible for
26 drafting OSHA logs (including but not limited to OSHA 300, 300a, and 301 logs) at LIQUI-
27 BOX CORPORATION'S Sacramento facility. (The phrase "Sacramento facility" shall herein
28 mean the business at 5000 Warehouse Way Sacramento, CA 95826 USA.)
PLAINTIFF SAJIDA ZAMAN'S SPECLAL INTERROGATORIES TO DEFENDANT LIQUI-
BOX CORPORATION (SET THREE)
1
SPECIAL INTERROGATORY NO. 31:
2
Please identify, by name, address and telephone number the PERSON(S) responsible
3
for storing OSHA logs (including but not limited to OSHA 300, 300a, and 301 logs) at LIQUI-
4
BOX CORPORATION'S Sacramento facility.
5
SPECIAL INTERROGATORY NO. 32:
6
Please identify, by name, address and telephone number any PERSON(S) with
7
knowledge of LIQUI-BOX CORPORATION'S procedures relating tottiedrafting and storing
8
of OSHA logs at LIQUI-BOX CORPORATION'S Sacramento facility.
9
SPECIAL INTERROGATORY NO. 33:
10
11 Please describe where the OSHA logs (including but not limited to OSHA 300, 300a,
12 and 301 logs) are stored at LIQUI-BOX CORPORATION'S Sacramento facility.
13
14 Dated: May 18, 2022 FALAKASSA LAW, P.C.
LIBERTY MAN LAW, P.C.
15
16
17 BY:
18
19 JOSHUA S. FALAKASSA
ARASH KHOSROWSHAHI
20 Attomeys for Plaintiff SAHDA ZAMAN
21
22
23
24
25
26
27
28
PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI-
BOX CORPORATION (SET THREE)
EXHIBIT C
JOSHUA S. FALAKASSA (SBN: 295045)
1 FALAKASSA LAW, P.C.
2 1901 Avenue ofttieStars Suite # 450
Los Angeles, Califomia 90067
3 Tel.: (818) 456-6168
4 Fax:(888) 505-0868
Email: josh@falakassalaw.com
5
6 LIBERTY MAN LAW, P.C.
ARASH S. KHOSROWSHAHI (SBN: 293246)
7 1010 F Street, Ste. 300
Sacramento, Cahfomia 95814
8 Tel.: (916)573-0469
9 Fax: (866) 700-0787
Email: ash@libertymanlaw.com
10
11 Attomeys for Plainttff
SAJIDA ZAMAN
12
13 SUPERIOR COURT OF CALIFORNIA
14 COUNTY OF SACRAMENTO
15
16
SAJIDA ZAMAN, an individual, CASENO.: 34-2019-00252121
17
PLAINTIFF SAJIDA ZAMAN'S
18 Plaintiff, REQUESTS FOR THE INSPECTION ANI
19 vs. PRODUCTION OF DOCUMENTS AND
LIQUI-BOX CORPORATION, and DOES 1 OTHER THINGS TO DEFENDANT
20 through 20, inclusive. LIQUI-BOX CORPORATION (SET FIVE)
21
Defendants.
22
23
24
25
26 PROPOUNDING PARTY : SAJIDA ZAMAN
27 RESPONDING PARTY : LIQUI-BOX CORPORATION
28
SET NUMBER : FIVE (5)
PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI-
BOX CORPORATION (SET FOUR)
TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD:
1
2 Plaintiff requests pursuant to Code of Civil Procedure § 2031.010, et seq. that within thirty
3 (30) days of service of this demand for production of documents, the above-named Defendant
4
serve a written statement addressing each demand to the effect that it will comply, it lacks the
5
6 ability to comply, or it finds a particular demand objecttonable. However, in accordance with
7 Code of Civil Procedure §2031.010, et seq., if a response contains an objection, it must identify
8 with particularity any document falling within the demand to which the objection is being made.
9
Plaintiff also requests, pursuant to Code of Civil Procedure §2031.010, etseq., that within
10
11 thirty (30) days of service of this demand for production of documents, the above-named
12 Defendant produce the writings, documents, items, and things herein below listed which are
13 believed to be in its custody, possession, and conttol, for inspection and copying by Plaintiff at
14
FALAKASSA LAW, P.C. located at 1901 Ave of tiie Stars, Ste # 450 Los Angeles, CA 90067,
15
16 and LIBERTY MAN LAW, P.C, located at 1010 F Stteet, Ste. 300, Sacramento, CA 95814. Said
17 writings, documents, items and things are non-privileged and are reasonably calculated to lead to
18 the discovery of admissible evidence.
19
A personal appearance by said Defendant or its counsel is not required if said Defendant
20
21 will submit copies of the documents described below with verification, executed under penalty of
22 perjury, that the documents provided are tme, correct, and complete duplicates of the original
23 documents requested and that the copies provided eu-e tme, correct, and complete copies of the
24
records requested.
25
26 DEFINITIONS
27 Words that are in CAPITALS are defined as follows:
28
PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI-
BOX CORPORATION (SET FOUR)
(a) DOCUMENT(S), as used herein, shall refer to, mean, and include any tangible
1
2 thing upon which any expression, communication or representation has been recorded by any
3 means, including, but not limited to, any and all writings, as defined in Evidence Code § 250
4
including the original or a copy of handwriting,typewriting,printing, photostating, photographing,
5
6 electtonic and/or each and evety other means of recording upon any tangible or electtonic medium
7 and/or thing as well as any and all forms of communication or representation, including letters,
8 words, pictures, sounds or symbols, or any combination thereof
9
(b) LIQUI-BOX CORPORATION as used herein, includes, describes and refers to
10
11 Defendant LIQUI-BOX CORPORATION, its subsidiaries, its parent/holding companies, its
12 agents, representatives, investigators, employees, conttactors, insurance companies, their agents
13
their employees, their investtgators, their representatives and anyone else acting on LIQUI-BOX
14
CORPORATION'S behalf except its herein attomeys.
15
16 DOCUMENT REOUEST
17 The writings to be produced are:
18
REOUEST FOR PRODUCTION NO. 1
19
All documents YOU identified in YOUR responses to Plaintiff Sajida Zaman's Special
20
21 Interrogatories to Defendant Liqui-Box Corporation Set Four (4).
22 Dated: May 24, 2022 FALAKASSA LAW, P.C.
23 LIBERTY MAN LAW, P.C.
24
25
BY: Isi Joshua Falakassa
26
27
JOSHUA S. FALAKASSA
28
ARASH KHOSROWSHAHI
Attomeys for Plamttff SAJIDA ZAMAN
PLAINTIFF SAHDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI-
BOX CORPORATION (SET FOUR)
EXHIBIT D
JOSHUA S. FALAKASSA (SBN: 295045)
1
FALAKASSA LAW, P.C.
2 1901 Avenue ofthe Stars Suite # 450
Los Angeles, Califomia 90067
3 Tel.: (818) 456-6168
4 Fax:(888)505-0868
Email: josh@falakassalaw.com
5
6 LIBERTY MAN LAW, P.C.
ARASH S. KHOSROWSHAHI (SBN: 293246)
7 1010 F Street, Ste. 300
Sacramento, Califomia 95814
8
Tel.: (916) 573-0469
9 Fax: (866) 700-0787
Email: ash@libertymanlaw.com
10
11 Attomeys for Plaintiff
SAJIDA ZAMAN
12
13 SUPERIOR COURT OF CALIFORNIA
14
COUNTY OF SACRAMENTO
15
16
SAJIDA ZAMAN, an individual. CASE NO.: 34-2019-00252121
17
PLAINTIFF SAJIDA ZAMAN'S SPECIAL
18 Plaintiff,
INTERROGATORIES TO DEFENDANT
vs. LIQUI-BOX CORPORATION (SET
19
LIQUI-BOX CORPORATION, and DOES 1 FOUR)
20 through 20, inclusive.
21
Defendants.
22
23
24
25
26 PROPOUNDING PARTY SAJIDA ZAMAN
27 LIQUI-BOX CORPORATION
RESPONDING PARTY
28
SET NUMBER FOUR (4)
PLAINTIFF SAJIDA ZAMAN'S SPECLM. INTERROGATORIES TO DEFENDANT LIQUI-
BOX CORPORATION (SET FOUR)
1 TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD:
2 Plaintiff SAJIDA ZAMAN hereby requests that Defendant LIQUI-BOX CORPORATION
3 answer under oath within thirty (30) days, pursuant to Califomia Code of Civil Procedure §§
4 2030.010 et seq., the following interrogatories.
5 In answering these interrogatories please fumish such information as is available to you,
6 and not merely that which you know of your personal knowledge. This means that you are to
7 fumish information which is available to you or is within the knowledge ofyour attomeys, or their
8 agents, employees, investigators or experts. (See Code of Civil Procedure §§ 2030.010 et seq.)
9 If any of these interrogatories cannot be answered in fiill, you are required to answer to the
10 extent possible, specifying the reason for your inability to answer the remainder and stating
11 whatever information or knowledge you have conceming the unanswered portion.
12 DEFINITIONS
13 Words that are in CAPITALS are defined as follows:
14 (a) "LIQUI-BOX", "YOU" or "YOUR" as used herein, includes, describes and refers
15 to Defendant LIQUI-BOX CORPORATION, its subsidiaries, its parent/holding companies, its
16 agents, representatives, investigators, employees, conttactors, govemmental entities, insurance
17 companies, their agents, their employees, their investigators, their representatives and anyone else
18 acting on Defendant LIQUI-BOX CORPORATION behalf except its herein attomeys.
19 (b) PERSON includes a natural person, firm, association, organization, partnership,
20 business, tmst, limited liability company, corporation, or public entity.
21 (c) "REPRIMAND" or "REPRIMANDED" as used herein means any punishment
22 suspension, demotion, loss of pay, failure or refusal to promote, failure or refusal to hire, or any
23 other action or failure to act that adversely affects the employee's rights or interests.
24 SPECIAL INTERROGATORIES
25 SPECIAL INTERROGATORY NO. 34;
26 Please identify, by name, address and telephone number the PERSON(S) who worked at
27 LIQUI-BOX CORPORATION'S Sacramento facility who YOU contend violated YOUR
28 Critical Safety Behaviors Policy during the last ten (10) years. (The phrase "Sacramento facility
shall herein mean the business at 5000 Warehouse Way Sacramento, CA 95826 USA.)
PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI-
BOX CORPORATION (SET FOUR)
1 SPECIAL INTERROGATORY NO. 35:
2 Please identify, by name, address and telephone number the PERSON(S) who worked at
3 LIQUI-BOX CORPORATION'S Sacramento facility who YOU REPRIMANDED for
4 violating YOUR Critical Safety Behaviors Policy during the last ten (10) years.
5 SPECIAL INTERROGATORY NO. 36:
6 Please identify, by name, address and telephone number the PERSON(S) who worked at
7 LIQUI-BOX CORPORATION'S Sacramento facility who YOU terminated for violating
8 YOUR Critical Safety Behaviors Policy during the last ten (10) years.
9 SPECIAL INTERROGATORY NO. 37:
10 For each employee who was reprimanded for a violation of YOUR Critical Safety
11 Behaviors Policy at YOUR Sacramento facility during the last ten (10) years, please identify, by
12 name, address and telephone number all PERSON(S) with knowledge of the REPRIMAND.
13 SPECIAL INTERROGATORY NO. 38:
14 For each employee who was REPRIMANDED for a violation of YOUR Critical Safety
15 Behaviors Policy at YOUR Sacramento facility during the last ten (10) years, please state all facts
16 which support YOUR decision to REPRIMAND the employee.
17 SPECIAL INTERROGATORY NO. 39:
18 For each employee who was REPRIMANDED for a violation of YOUR Critical Safety
19 Behaviors Policy at YOUR Sacramento facility during the last ten (10) years, please identify all
20 documents containing information YOU relied upon in YOUR decision to REPRIMAND the
21 employee.
22 SPECIAL INTERROGATORY NO. 40:
23 For each employee who was terminated for a violation of YOUR Critical Safety
24 Behaviors Policy at YOUR Sacramento facility during the last ten (10) years, please identify, by
25 name, address and telephone number all PERSON(S) with knowledge of each employee YOU
26 terminated.
27 ///
28 ///
///
PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI-
BOX CORPORATION (SET FOUR)
1 SPECIAL INTERROGATORY NO. 41:
2 For each employee who was terminated for a violation of YOUR Critical Safety
3 Behaviors Policy at YOUR Sacramento facility during the past ten (10) years, please state all
4 facts upon which YOU supported YOUR termination of each employee.
5 SPECIAL INTERROGATORY NO. 42:
6 For each employee who was terminated for a violation of YOUR Critical Safety
7 Behaviors Policy at YOUR Sacramento facility during the past ten (10) years, please identify all
8 documents containing information YOU relied upon in YOUR decision to terminate each
9 employee.
10
11 Dated: May 24, 2022 FALAKASSA LAW, P.C.
12 LIBERTY MAN LAW, P.C.
13
14
BY: /s/ Joshua Falakassa
15
16
JOSHUA S. FALAKASSA
17 ARASH KHOSROWSHAHI
18 Attomeys for Plaintiff SAJIDA ZAMAN
19
20
21
22
23
24
25
26
27
28
PLAINTIFF SAJIDA ZAMAN'S SPECL\L INTERROGATORIES TO DEFENDANT LIQUI-
BOX CORPORATION (SET FOUR)
1 JOSHUA S. FALAKASSA (SBN: 295045)
FALAKASSA LAW, P.C.
2 1901 Avenue of ttie Stars Suite # 450
Los Angeles, Califomia 90067
3 Tel.: (818) 456-6168
Fax:(888)505-0868
4 Email: josh@falakassalaw.com
5
LIBERTY MAN LAW, P.C.
6 ARASH S. KHOSROWSHAHI (SBN: 293246)
1010 F Street, Ste. 300
7 Sacramento, Califomia 95814
Tel.: (916) 573-0469
8 Fax: (866) 700-0787
9 Email: ash@libertymanlaw.com
10 Attomeys for Plaintiff
SAJIDA ZAMAN
11
12
SUPERIOR COURT OF CALIFORNIA
13
COUNTY OF SACRAMENTO
14
15 SAJIDA ZAMAN, an individual. CASENO.: 34-2019-00252121
16 Plaintiff, DECLARATION OF JOSHUA
FALAKASSA REGARDING THE NEED
vs. FOR ADDITIONAL SPECIAL
17
LIQUI-BOX CORPORATION, and DOES 1 INTERROGATORIES TO DEFENDANT
18 through 20, inclusive.
[Served Concurrently with Plaintiffs Special
19 Interrogatories, Set Four]
20 Defendants.
21
22
23
24
25
26
27
28
1
DECLARATION OF JOSHUA FALAKASSA REGARDING THE NEED FOR ADDITIONAL SPECIAL
INTERROGATORIES TO DEFENDANT
1 DECLARATION OF JOSHUA FALAKASSA
2 I, Joshua Falakassa, declare and state as follows:
3 1. I am presently the attomey for plaintiff Sajida Zaman ("Plaintiff), a party to this
4 action.
5 2. I am propoimding to defendant Liqui-Box Corporatton ("Defendant") the attached
6 Special Interrogatories, Set Number Four (4).
7 3. This set of interrogatories will cause the total number of specially prepared
8 interrogatories propounded to the party to whom they are directed to exceed the number of
9 specially prepared interrogatories permitted by Section 2030.030 of the Code of Civil Procedure.
10 4. I have previously propounded a total of thirty-three (33) specially prepared
11 interrogatories to this party.
12 5. This set of interrogatories contains a total of nine (9) specially prepared
13 interrogatories.
14 6. I am familiar with the issues and the previous discovery conducted by all of the
IS parttes to this case.
16 7. I have personally examined each of the questions in this set of interrogatories.
17 8. This number of questions is warranted under Section 2030.040 of the Code of Civil
18 Procedure because of the quantity and nature of the existing and potential issues involved, and the
19 expedience and benefit to each of the parties that will result in using this form of discovery to
20 obtain certain information about Defendant's positions, argxunents and defenses.
21 9. None of the questions in this set of interrogatories is being propounded for any
22 improper purpose, such as to harass the party or the attomey for the party to whom it is directed or
23 to cause uimecessary delay or needless increase in the cost of litigation.
24 I declare under penalty of perjury imder the laws of the State of Califomia that the
25 foregoing is tme and correct, and that this declaration was executed on May 24, 2022, at Los
26 Angeles, Califomia.
27
/s/Joshua Falakassa
28
Joshua Falakassa
2
DECLARATION OF JOSHUA FALAKASSA REGARDING THE NEED FOR ADDITIONAL SPECIAL
INTERROGATORIES TO DEFENDANT
EXHIBIT E
JOSHUA S. FALAKASSA (SBN: 295045)
FALAKASSA LAW, P.C.
1901 Avenue ofthe Stars Suite # 450
3 Los Angeles, Califomia 90067
Tel.: (818) 456-6168
Fax: (888) 505-0868
4 Email: josh@falakassalaw.com
5 LIBERTY MAN LAW, P.C.
ARASH S. KHOSROWSHAHI (SBN; 293246)
6 1010 F Stteet, Ste. 300
Sacramento, Califomia 95814
7 Tel.: (916) 573-0469
Fax: (866) 700-0787
S Email: ash@libertymanlaw.com
Attomeys for Plaintiff
SAHDA ZAMAN
10
SUPERIOR COURT OF CALIFORNLA
II
COUNTY OF SACRAMENTO
12
13
SAJIDA ZAMAN, an individual, CASENO.: 34-2019-00252121
14 Plaintiff,
PLAINTIFF SAJIDA ZAMAN'S SPECIAL
INTERROGATORIES TO DEFENDANT
15 vs. LIQUI-BOX CORPORATION (SET FIVE)
LIQUI-BOX CORPORATION, and DOES 1
IC> through 20, inclusive,
17 Defendants.
18
19
20
PROPOUNDING PARTY SAJIDA ZAMAN
21
RESPONDING PARTY LIQUI-BOX CORPORATION
22 SET NUMBER FIVE (5)
23
PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT
LIQUI-BOX CORPORATION (SET FOUR)
TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD:
3
Plaintiff SAJIDA ZAMAN hereby requests that Defendant LIQUI-BOX
4 CORPORATION answer under oath within thirty (30) days, pursuant to Califomia Code of Civil
5 Procedure §§ 2030.010 etseq., the following interrogatories.
6 In answering these interrogatories please fumish such information as is available to you,
7 and not merely that which you know of your personal knowledge. This means that you are to
8 fiiraish information which is available to you or is within the knowledge of your attorneys, or
their agents, employees, investigators or experts. (See Code of Civil Procedure §§ 2030.010 et
9
seq.)
10
If any of these interrogatories cannot be answered in full, you are required to answer to
11
the extent possible, specifying the reason for your inability to answer the remainder and stating
12
whatever information or knowledge you have conceming the unanswered portion.
13 DEFINITIONS
14 Words that are in CAPITALS are defined as follows:
15 (a) "LIQUI-BOX", "YOU" or "YOUR" as used herein, includes, describes and
16 refers to Defendant LIQUI-BOX CORPORATION, its subsidiaries, its parent/holding companies
17 (including LB Hold Co.), its agents, representatives, investigators, employees, contractors,
IX govemmental entities, insurance companies, their agents, their employees, their investigators,
)9 their representatives and anyone else acting on Defendant LIQUI-BOX CORPORATION behalf
except its herein attomeys.
20
(b) PERSON includes a natural person, firm, association, organization, partnership,
21
business, tmst,
Preview
F11E0/E!^D0F:SE0 1 JOSHUA S. FALAKASSA (SBN: 295045) FALAKASSA LAW, P.C. 2 1901 Avenue ofthe Stars Suite # 450 AUG 0 h 2022 3 Los Angeles, Califomia 90067 By: 'Vui.o-'i'jid Tel.: (818) 456-6168; Fax: (888) 505-0868 4 Email: josh@falakassalaw.com 5 ARASH S. KHOSROWSHAHI (SBN: 293246) 6 LIBERTY MAN LAW, P.C. 1010 F Street, Ste. 300 7 Sacramento, Califomia 95814 Tel.: (916) 573-0469; Fax: (866) 700-0787 8 Email: ash@libertymanlaw.com 9 Attomeys for Plaintiff, 10 SAJIDA ZAMAN 11 SUPERIOR COURT OF CALIFORNIA 12 COUNTY OF SACRAMENTO BY FAX 13 14 SAJIDA ZAMAN, CASE NO.: 34-2019-00252121 15 Plaintiff, DECLARATION OF ARASH S. 16 KHOSROWSHAHI IN SUPPORT OF EX vs. PARTE APPLICATION FOR ORDER (1) 17 SPECIALLY SETTING HEARINGS ON LIQUI-BOX CORPORATION, and DOES 1 18 through 20, inclusive. DISCOVERY MOTIONS; (2) CONTINUING MOTION FOR 19 Defendants. SUMMARY JUDGMENT/SUMMARY ADJUDICATION HEARING; AND (3) 20 FOR LEAVE TO FILE ADDITIONAL EVIDENCE IN OPPOSITION TO 21 DEFENDANT'S MOTION FOR 22 SUMMARY JUDGMENT/SUMMARY ADJUDICATION 23 Date: August 5,2022 24 Time: 9:00am 25 Dept.: 53 Trial Date: September 12,2022 26 27 28 DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 1 of 8 1 I, ARASH KHOSROWSHAHI, declare as follows: 2 1. I am an attomey licensed to practice law in the State of Califomia. My State Bar Numbei 3 is 293246. 4 2. I represent Plaintiff Sajida Zaman ("Plaintiff') in the above-entitled action. I have 5 knowledge of the facts stated herein and can testify competently thereto. 6 3. Defendant at the eleventh hour on May 18, 2022 sought ex parte relief to set a hearing 7 date of August 10, 2022 for its MSJ. After this Court granted relief, the MSJ was then 8 served at the last possible minute on May 27, 2022, providing exactly 75 days' notice to 9 Plaintiff, and giving her only the minimalttmeto file an opposition by the July 27, 2022 10 deadline. 11 4. After Plaintiff requested Defendant's OSHA logs via letter. Defendant's counsel delayed 12 production by several days, only producing documents relevant to Plaintiffs employment, 13 rather than all "current or stored" logs Defendant has in its possession, custody, or control. 14 5. Plaintiff thereafter served her Requests for Production of Documents, Set Four, on or 15 about May 18, 2022, asking for all documents compromising Defendant's (1) OSHA 300 16 (Request for Production of Documents, Set Four, No. 1), (2) OSHA 300a (Id., No. 2), and 17 (3) OSHA 301 (Id., No.3) at its Sacramento facility where Plainttff worked. (Attached as 18 Exhibit A is a tme and correct copy of Plaintiff Sajida Zaman's Requests for Production 19 of Documents to Defendant LiquiBox, Inc., Set Four (4).) 20 6. Plaintiff that same day also served her Special Interrogatories, Set Three, on or about May 21 18, 2022, asking (1) identtfying information of persons responsible for drafting OSHA 22 300, 300a, and 301 logs ("OSHA logs") at Defendant's Sacramento facility (Special 23 Interrogatory, Set Three, No. 30); (2) identifying information of persons responsible for 24 storing OSHA logs at Defendant's Sacramento facility (Id., No. 31); (3) identifying 25 information of persons with knowledge of Defendant's procedures relating to the drafting 26 and storing of the OSHA logs at the Sacramento facility (Id., No. 32); and (4) to describe 27 where the OSHA logs are stored at the Sacramento facility (Id., No. 33). (Attached as 28 DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 2 of 8 1 Exhibit B is a tme and correct copy of Plaintiff Sajida Zaman's Special Interrogatories to 2 Defendant Liqui-Box Corporation (Set Three).) 3 7. On or about June 21, 2022, rather than provided responses. Defendant continued its 4 obstmction by serving only meritless, boilerplate objections to Plaintiffs requests for 5 documents and interrogatories. Plaintiff met and conferred as to the objections in attempts 6 to obtain responses/documents and informally resolve the issues, but Defendant never 7 provided responses or documents. 8 8. Plaintiff thereafter filed her motions to compel on Special Interrogatories, Set Three (Res. 9 ID: 2664201) and Requests for Production of Documents, Set Four (Res. ID: 2664202) to 10 be heard on October 18, 2022. 11 9. On or about May 24, 2022, Plaintiff propounded her fifth set of Requests for Production 12 of Documents to Defendant. (Declaration of Arash S. Khosrowshahi in Support ["Khos. 13 Decl."], I 3; attached as Exhibit C is a tme and correct copy of Plaintiff Sajida Zaman's 14 Requests for the Inspection and Production of Documents and Other Things to Defendant 15 Liqui-Box Corporation (Set Five).) Notably, Request for Production No. 1 (the only 16 propounded request in the set) asked for: "All documents YOU identified in YOUR 17 responses to Plaintiff Sajida Zaman's Special Interrogatories to Defendant Liqui-Box 18 Corporation Set Four (4)." (See Exhibit C.) 19 10. The referenced Special Interrogatories, Set Four, were also served that same day, 20 and in sum ask forthe following information: (1) the identifying information of employees 21 who worked at Defendant's Sacramento facility who (a) Defendant contends violated the 22 CSB Policy in the last 10 years (Special hiterrogatory. Set 4, No. 34); (b) Defendant 23 reprimanded for violating the CSB policy in the last 10 years (Id., No. 35); (c) Defendant 24 terminated for violating the CSB policy in the last 10 years (Id., No. 36); (2)(a) identifying 25 information of each person with knowledge of each reprimand (Id., No. 37); (b) all facts 26 which supported each reprimand (Id., No. 38); (c) all documents containing information 27 Defendant relied on in the decision to reprimand (Id., No. 39); (3)(a) identifying 28 information of each person with knowledge of each termination (Id., No. 40); (b) all facts DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 3 of 8 1 which supported each termination (Id., No. 41); (c) all documents containing information 2 Defendant relied on in the decision to termination (Id., No. 42). (Attached as Exhibit D 3 is a tme and correct copy of Plaintiff Sajida Zaman's Special Interrogatories to Defendant 4 Liqui-Box Corporation (Set Four).) 5 11. Rather than respond, on or about June 27, 2022 Defendant provided only 6 boilerplate objections to the requests as well as the interrogatories. Plaintiff met and 7 conferred as to the objections in attempts to obtain responses/documents, and informally 8 resolve the issues, but Defendant never provided responses or documents. 9 12. Plaintiff thereafter filed her motions to compel on Special Interrogatories, Set Four (Res. 10 ID: 2664199) and Requests for Production of Documents, Set Five (Res. ID: 2664198) to 11 be heard on October 18, 2022. 12 13. On May 27, 2022 Plaintiff served her fifth set of Special Interrogatories propounded 13 against Defendant via email. (Attached as Exhibit E is a tme and correct copy of Plaintiff 14 Sajida Zaman's Special Interrogatories to Defendant Liqui-Box Corporation (Set Five).) 15 14. The Special Interrogatories contained 22 separate interrogatories in relevant part asking 16 for: (1) safetyttainingsDefendant contends it provided Plaintiff and when they occurred 17 (Special Interrogatories, Nos. 45-46); (2) all steps Defendant took to evaluate modified 18 work duties to accommodate Plaintiff (Id., No. 48); (3) the date Plaintiffs injury was first 19 identified (Id., No. 49); (4) the percentage of employees who missed work due to 20 cumulative ttauma injuries or not in the last five years (Id., Nos. 50-51.); (5) all 21 facts/witnesses/documents in support of Defendant's contention that defective ttolleys 22 Plaintiff worked on were repaired (Id., No. 52-54); (6) all facts/documents in support of 23 the contention that Defendantttainedemployees to identify disease, condition or injury 24 from their signs and symptoms (Id., Nos. 56-57); (7) all facts/witnesses/document in 25 support of the contention that Plaintiff was diagnosed with a left knee and hamstring pain 26 in relation to her 4 Panel EHS Disciplinary Review. (Id. Nos. 58-59); (8) whether 27 Defendant contends Plaintiff injuries were caused by her failure to follow Defendant's 28 instmctions provided in her training on proper operation of mega tote carts, and all DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 4 of 8 1 supporting facts (Id., Nos. 60-61); (9) whether attendance for such mega tote cart ttainings 2 were mandatory (Id., No. 62); (10) the identities of all persons present for mega tote cart 3 trainings, as well as all documents reflecting the matters presented at the ttainings (Id., 4 Nos. 63-64); and (11) all facts supporting Defendant's contention that Plaintiffs actions 5 leading to her injuries were inconsistent with anyttainingsprovided. (Id., No. 65.) (See 6 Exhibit E.) 7 15. However, Defendant never served any objections or responses to the Special 8 Interrogatories. Plaintiff thereafterfiledher motions to compel on Special Interrogatories, 9 Set Five (Res. ID: 2664200) to be heard on October 18, 2022. 10 16. On May 27, 2022 Plaintiff served her second set of Form Interrogatories—General 11 propounded against Defendant via email. (Attached as Exhibit F is a tme and correct copy 12 of Plaintiff Sajida Zaman's Form Interrogatories—General, Set Two.) The interrogatories 13 were concurrently served with Plaintiffs Requests for Admissions to Defendant Liqui- 14 Box Corporation (Set One) (Attached as Exhibit G is a tme and correct copy of Plaintiff 15 Sajida Zaman's Requests for Admissions, Set One), and contained a single interrogatory, 16 No. 17.1, which required the Defendant to provide all facts, witnesses, and documents in 17 support of any denial or qualified admission to the Requests for Admissions. (See Exhibit 18 F.) 19 17. The Requests for Admissions themselves in relevant part asked Defendant to admit 20 information regarding: (1) Plaintiff not beingttainedon the CSB immediate reporting 21 requirement; (2) not being trained on recognizing signs of cumulativettaumainjuries or 22 gradually worsening symptoms such as her sttained knee/hamstting muscle; (3) that 23 Plaintiffs injury was cumulative in nature caused by repeated trauma over time and not 24 caused by a single event accident; (4) that Plaintiffs injury was not diagnosed sooner than 25 January 3, 2019; (5) that Defendant never discussed PiaintifFsrightsunder the FEHA 26 during her alleged late reporting; (6) that Plaintiffs work restrictions did not prohibit her 27 from performing all ofher essential job functions; (7) that the CSB policy does not require 28 employees to immediately report all physical pain until they leam their pain is connected DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 5 of 8 1 to an injury; and (8) Plaintiff never beingttainedon distinguishing bodily sensations such 2 as soreness due to fatigue, from workplace injuries. (See Exhibit G, Requests for 3 Admissions Nos. 1 through 23.) 4 18. Because Defendant did not timely serve responses or objections. Plaintiff thereafter filed 5 her motion to compel on Form Interrogatories—General, Set Two (Res. ID: 2656706) and 6 motion to deem admitted the Requests for Admissions, Set One (Res. ID: 2656705) to be 7 heard on September 1 2022. 8 19. After having filed her Opposition to Defendant's MSJ on July 27,2022, Defendant finally 9 served its responses to Plaintiffs Requests for Admissions, Set 1 on August 1, 2022. 10 (Attached as Exhibit H is a tme and correct copy of Defendant's Responses to Requests 11 for Admissions, Set 1.) Of course. Plaintiff never had the opportunity to rely on this 12 discovery when drafting her opposition to the MSJ. This is despite the fact that Defendant 13 verified these responses on July 25,2022, two whole days before PlaintifPs opposition 14 was due. (See verification to Exhibit H.) 15 20. Plaintiffhas never sought prior continuances on the MSJ hearing date and has yet to have 16 sought ex parte relief in this matter. 17 21. After Plaintiff reported her knee pain on January 3, 2019, Defendant had Plaintiff 18 complete an AS 1059 investigation report. (Attached as Exhibit I is a tme and correct copy 19 of Plaintiffs AS 1059 investigation report.) Subsequently, Defendant's Manager of 20 Human Resources Janene Whitney, along with Chief Operating Officer Andrew 21 McLeland, Chief Human Resources Officer Angela Kenyon, and Supervisor Ken Villani, 22 all emailed one another about how PlaintifTs injury would be an OSHA recordable injury 23 for 2018, and how they would push back against Plaintiffs workers compensation claim, 24 as they were claiming Plaintiffs injury was first known to Plaintiff December 3, 2018, 25 not January 3, 2019. (Attached as Exhibit J is a tme and correct copy ofthe January 3, 26 2019 emails between Defendant's management discussing Plaintiffs work-related 27 injury.) Defendants then used their intemal "4 Panel EHS Disciplinary Review'" to claim 28 Plaintiff was diagnosed with a knee and hamstring sprain, and to claim Plaintiff reported DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 6 of 8 1 her injury late, as pretextual justification for terminating her employment for not reporting 2 her injury immediately per the CSB policy. (Attached as Exhibit K is a tme and correct 3 copy ofPlaintiffs 4 Panel EHS Disciplinary Report.) 4 22. Attached as Exhibit L is a tme and correct copy of Plaintiffs workers compensation 5 medical records dated January 3, 2019 diagnosing her with sttain, not sprain, injuries; 6 compare with Exhibit K characterizing the injury as a sprain.) 7 23. Defendant made verified denials that their CSB policy (1) "did not require Plaintiff to 8 report pain unless and until Plaintiff identified her pain as connected to a workplace 9 injury." (Response to Requests for Admissions, Set 1, No. 13) and (2) did not require 10 employees to "immediately report all physical pain, unless and until the employee leams 11 that the pain is connected to an actual injury." (Id., No. 12) (See Exhibit H.) 12 24. Defendant admits it "neverttained"employees that they "must" report injuries regardless 13 of her knowledge of them. (Response to Requests for Admissions, Set 1, No. 2) (See 14 Exhibit H.) 15 25. Defendant now admits it never trained employees in how to recognize early signs of such 16 cumulative trauma injuries such as a sttained knee or a sttained hamstring muscle. 17 (Response to Requests for Admissions, Set 1, No. 3). (See Exhibit H.) 18 26. All ofPlaintiffs aforementioned discovery motions have been filed and timely served 19 upon Defendant. 20 27.1 called Defendant's counsel Mr. James Jones at Jackson Lewis, P.C. at 8:37am Thursday 21 August 4, 2022, given him ex parte notice that Plaintiff was seeking to specially set her 22 discovery motions for on or before September 1, 2022; that Plaintiff was seeking a 60 day 23 continuance on the MSJ hearing date; that Plaintiff sought leave to provide a supplemental 24 brief in opposition to the MSJ after the discovery motions were heard; and that in the 25 altemative Plaintiff sought to specially set her discovery motions for September 1, 2022. 26 I informed Mr. Jones the hearing was scheduled for August 5, 2022, at 9:00am in 27 Department 53. Mr. Jones did not indicate that he would oppose the ex parte application, 28 though he wished to participate in setting dates. DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 7 of 8 1 I declare under penalty of perjury under the laws of the State of Califomia that the 2 foregoing is tme and correct. 3 Dated: August 4, 2022 4 5 By: Arash S. Khosrowshahi 6 Attomey for Plaintiff Sajida Zaman 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 8 of 8 EXHIBIT A 1FALAKASSA LAW, P.C. Joshua S. Falakassa (SBN: 295045) 2 1901 Ave. ofthe Stars, Suite #450 3 Los Angeles, Califomia 90067 Tel.: (818) 456-6168; Fax: 4 Email: josh@falakassalaw.com 5 LIBERTY MAN LAW, P.C. 6 Arash S. Khosrowshahi (SBN: 293246) 1010 F Stteet, Ste. 300 7 Sacramento, Califomia 95814 Tel.: (916) 573-0469; Fax: (866) 700-0787 8 Email: ash@libertymanlaw.com 9 Attomeys for Plaintiff, 10 SAJIDA ZAMAN 11 SUPERIOR COURT OF CALIFORNIA 12 COUNTY OF SACRAMENTO 13 14 SAJIDA ZAMAN, an individual. Case No.: 34-2019-00252121 15 Plaintiff, 16 vs. PLAINTIFF SAJIDA ZAMAN'S REQUESTS FOR PRODUCTION OF 17 LIQUI-BOX CORPORATION, and DOES 1 DOCUMENTS TO DEFENDANT through 20, inclusive. LIQUIBOX, INC., SET FOUR (4) 18 19 Defendants 20 21 22 23 PROPOUNDING PARTY PLAINTIFF, SAJIDA ZAMAN 24 RESPONDING PARTY DEFENDANT, LIQUI-BOX CORPORATION 25 SET NUMBER FOUR (4) 26 27 28 1 of 4 1 TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEYS OF 2 RECORD: 3 Plaintiff requests pursuant to Code ofCivil Procedure §§ 2031.010, e^je^. that within thirty 4 (30) days of service of this demand for production of documents, the above-named Defendani 5 serve a written statement addressing each demand to the effect that it will comply, it lacks the 6 ability to comply, or it finds a particular demand objectionable. However, in accordance with 7 Code of Civil Procedure §§ 2031.010, et seq., if a response contains an objection, it must identify 8 with particularity any document falling within the demand to which the objection is being made. 9 Plaintiff also requests, pursuant to Code of Civil Procedure §§ 2031.010, et seq., that within 10 thirty (30) days of service of this demand for production of documents, the above-named 11 Defendant produce the writings, documents, items, and things herein below listed which are 12 believed to be in its custody, possession, and conttol, for inspection and copying by Plaintiff and 13 his counsels at LIBERTY MAN LAW, P.C, 1010 F Street, Ste. 300, Sacramento, Califomia 14 15 95814, and FALAKASSA LAW, P.C, 1901 Avenue ofthe Stars, Suite #450, Los Angeles 16 Califomia 90067. Said writings, documents, items, and things are non-privileged and are 17 reasonably calculated to lead to the discovery of admissible evidence. 18 A personal appearance by said Defendant or its counsel is not required if said Defendani 19 will submit copies of the documents described below with verification, executed under penalty of 20 perjury, that the documents provided are tme, correct, and complete duplicates of the original 21 documents requested and that the copies provided are tme, correct, and complete copies of the 22 records requested. 23 DEFINITIONS 24 Words that are in CAPITALS are defined as follows: 25 (a) "LIQUI-BOX", "YOU" or "YOUR" as used herein, includes, describes and refers 26 to Defendant LIQUI-BOX CORPORATION, its subsidiaries, its parent/holding companies, its 27 agents, representatives, investigators, employees, conttactors, govemmental entities, insurance 28 2 of 4 1 companies, their agents, their employees, their investigators, their representatives and anyone else 2 acting on Defendant LIQUI-BOX CORPORATION behalf except its herein attomeys. 3 (b) "DOCUMENT(S)", as used herein, shall refer to, mean and include any tangible 4 thing upon which any expression, communication or representation has been recorded by any 5 means, including, but not limited to, all writings, as defined in Evidence Code § 250, including the 6 original or a copy of handwriting,typewriting,printing, photostating, photographing, electtonic 7 and/or all other means of recording upon any tangible or electtonic medium and/or thing as well 8 as all forms of communication or representation, including letters, words, pictures, sounds oi 9 symbols, or any combination thereof. 10 (c) "COMMUNICATION" or "COMMUNICATIONS" as used herein shall mean 11 and refer to any written, oral, or telephonic communication including thettansmissionor exchange 12 of any kind of DOCUMENT or DOCUMENTS as those terms are previously defined, including, 13 14 without limitation, face-to-face conversations, meetings, telephone conversations, voice mail 15 messages, electronic mail, messages stored on the intemet, inquiries, representations, discussions, 16 negotiations, agreements, understandings, letters, notes, telegrams, interviews, or any othei 17 method of communication. 18 REQUESTS FOR THE INSPECTION AND PRODUCTION OF DOCUMENTS AND 19 OTHER THINGS 20 REOUEST FOR PRODUCTION NO. 1 21 All DOCUMENTS comprising OSHA 300 logs detailing any injury/illness at YOUR 22 Sacramento facility. (The phrase "Sacramento facility" shall herein mean the business at 5000 23 Warehouse Way Sacramento, CA 95826 USA.) 24 REOUEST FOR PRODUCTION NO. 2 25 All DOCUMENTS comprising OSHA 300a logs detailing any injury/illness at YOUR 26 Sacramento facility. 27 /// 28 /// 3 of 4 1 REOUEST FOR PRODUCTION NO. 3 2 All DOCUMENTS comprising OSHA 301 logs detailing any injury/illness at YOUR 3 Sacramento facility. 4 5 Dated: May 18, 2022 FALAKASSA LAW, P.C. 6 LIBERTY MAN LAW, P.C. 7 8 BY: 9 10 JOSHUA S. FALAKASSA 11 ARASH KHOSROWSHAHI Attomeys for Plaintiff SAJIDA ZAMAN 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 of 4 EXHIBIT B 1 JOSHUA S. FALAKASSA (SBN: 295045) FALAKASSA LAW, P.C. 2 1901 Avenue ofthe Stars Suite #450 Los Angeles, Califomia 90067 3 Tel.: (818) 456-6168 4 Fax:(888)505-0868 Email: josh@falakassalaw.com 5 LIBERTY MAN LAW, P.C. 6 ARASH S. KHOSROWSHAHI (SBN: 293246) 1010 F Stteet, Ste. 300 7 Sacramento, Califomia 95814 8 Tel.: (916) 573-0469 Fax: (866) 700-0787 9 Email: ash@libertymanlaw.com 10 Attomeys for Plaintiff 11 SAJIDA ZAMAN 12 SUPERIOR COURT OF CALIFORNIA 13 COUNTY OF SACRAMENTO 14 15 SAJIDA ZAMAN, an individual. CASENO.: 34-2019-00252121 16 PLAINTIFF SAJIDA ZAMAN'S SPECIAL 17 Plaintiff, INTERROGATORIES TO DEFENDANT vs. LIQUI-BOX CORPORATION (SET 18 THREE) LIQUI-BOX CORPORATION, and DOES 1 19 through 20, inclusive. 20 Defendants. 21 22 23 24 25 PROPOUNDING PARTY SAJIDA ZAMAN 26 RESPONDING PARTY LIQUI-BOX CORPORATION 27 SET NUMBER THREE (3) 28 PLAINTIFF SAJIDA ZAMAN'S SPECL\L INTERROGATORIES TO DEFENDANT LIQUI- BOX CORPORATION (SET THREE) 1 TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD: 2 Plaintiff SAJIDA ZAMAN hereby requests that Defendant LIQUI-BOX 3 CORPORATION answer under oath within thirty (30) days, pursuant to Califomia Code of Civil 4 Procedure §§ 2030.010 et seq., the following interrogatories. 5 In answering these interrogatories please fumish such information as is available to you, 6 and not merely that which you know of your personal knowledge. This means that you are to 7 fiimish information which is available to you or is within the knowledge of your attomeys, or 8 their agents, employees, investigators or experts. (See Code of Civil Procedure §§ 2030.010 et 9 seq.) 10 If any of these interrogatories cannot be answered in full, you are required to answer to 11 the extent possible, specifying the reason for your inability to answer the remainder and stating 12 whatever information or knowledge you have conceming the unanswered portion. 13 DEFINITIONS 14 Words that are in CAPITALS are defined as follows: 15 (a) "LIQUI-BOX", "YOU" or "YOUR" as used herein, includes, describes and refers 16 to Defendant LIQUI-BOX CORPORATION, its subsidiaries, its parent/holding companies, its 17 agents, representatives, investigators, employees, conttactors, govemmental entities, insurance 18 companies, their agents, their employees, their investigators, their representatives and anyone else 19 acting on Defendant LIQUI-BOX CORPORATION behalf except its herein attomeys. 20 21 (b) PERSON includes a natural person, firm, association, organization, partnership, 22 business, tmst, limited liability company, corporation, or public entity. 23 SPECIAL INTERROGATORIES 24 SPECIAL INTERROGATORY NO. 30: 25 Please identify, by name, address and telephone number the PERSON(S) responsible for 26 drafting OSHA logs (including but not limited to OSHA 300, 300a, and 301 logs) at LIQUI- 27 BOX CORPORATION'S Sacramento facility. (The phrase "Sacramento facility" shall herein 28 mean the business at 5000 Warehouse Way Sacramento, CA 95826 USA.) PLAINTIFF SAJIDA ZAMAN'S SPECLAL INTERROGATORIES TO DEFENDANT LIQUI- BOX CORPORATION (SET THREE) 1 SPECIAL INTERROGATORY NO. 31: 2 Please identify, by name, address and telephone number the PERSON(S) responsible 3 for storing OSHA logs (including but not limited to OSHA 300, 300a, and 301 logs) at LIQUI- 4 BOX CORPORATION'S Sacramento facility. 5 SPECIAL INTERROGATORY NO. 32: 6 Please identify, by name, address and telephone number any PERSON(S) with 7 knowledge of LIQUI-BOX CORPORATION'S procedures relating tottiedrafting and storing 8 of OSHA logs at LIQUI-BOX CORPORATION'S Sacramento facility. 9 SPECIAL INTERROGATORY NO. 33: 10 11 Please describe where the OSHA logs (including but not limited to OSHA 300, 300a, 12 and 301 logs) are stored at LIQUI-BOX CORPORATION'S Sacramento facility. 13 14 Dated: May 18, 2022 FALAKASSA LAW, P.C. LIBERTY MAN LAW, P.C. 15 16 17 BY: 18 19 JOSHUA S. FALAKASSA ARASH KHOSROWSHAHI 20 Attomeys for Plaintiff SAHDA ZAMAN 21 22 23 24 25 26 27 28 PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI- BOX CORPORATION (SET THREE) EXHIBIT C JOSHUA S. FALAKASSA (SBN: 295045) 1 FALAKASSA LAW, P.C. 2 1901 Avenue ofttieStars Suite # 450 Los Angeles, Califomia 90067 3 Tel.: (818) 456-6168 4 Fax:(888) 505-0868 Email: josh@falakassalaw.com 5 6 LIBERTY MAN LAW, P.C. ARASH S. KHOSROWSHAHI (SBN: 293246) 7 1010 F Street, Ste. 300 Sacramento, Cahfomia 95814 8 Tel.: (916)573-0469 9 Fax: (866) 700-0787 Email: ash@libertymanlaw.com 10 11 Attomeys for Plainttff SAJIDA ZAMAN 12 13 SUPERIOR COURT OF CALIFORNIA 14 COUNTY OF SACRAMENTO 15 16 SAJIDA ZAMAN, an individual, CASENO.: 34-2019-00252121 17 PLAINTIFF SAJIDA ZAMAN'S 18 Plaintiff, REQUESTS FOR THE INSPECTION ANI 19 vs. PRODUCTION OF DOCUMENTS AND LIQUI-BOX CORPORATION, and DOES 1 OTHER THINGS TO DEFENDANT 20 through 20, inclusive. LIQUI-BOX CORPORATION (SET FIVE) 21 Defendants. 22 23 24 25 26 PROPOUNDING PARTY : SAJIDA ZAMAN 27 RESPONDING PARTY : LIQUI-BOX CORPORATION 28 SET NUMBER : FIVE (5) PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI- BOX CORPORATION (SET FOUR) TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD: 1 2 Plaintiff requests pursuant to Code of Civil Procedure § 2031.010, et seq. that within thirty 3 (30) days of service of this demand for production of documents, the above-named Defendant 4 serve a written statement addressing each demand to the effect that it will comply, it lacks the 5 6 ability to comply, or it finds a particular demand objecttonable. However, in accordance with 7 Code of Civil Procedure §2031.010, et seq., if a response contains an objection, it must identify 8 with particularity any document falling within the demand to which the objection is being made. 9 Plaintiff also requests, pursuant to Code of Civil Procedure §2031.010, etseq., that within 10 11 thirty (30) days of service of this demand for production of documents, the above-named 12 Defendant produce the writings, documents, items, and things herein below listed which are 13 believed to be in its custody, possession, and conttol, for inspection and copying by Plaintiff at 14 FALAKASSA LAW, P.C. located at 1901 Ave of tiie Stars, Ste # 450 Los Angeles, CA 90067, 15 16 and LIBERTY MAN LAW, P.C, located at 1010 F Stteet, Ste. 300, Sacramento, CA 95814. Said 17 writings, documents, items and things are non-privileged and are reasonably calculated to lead to 18 the discovery of admissible evidence. 19 A personal appearance by said Defendant or its counsel is not required if said Defendant 20 21 will submit copies of the documents described below with verification, executed under penalty of 22 perjury, that the documents provided are tme, correct, and complete duplicates of the original 23 documents requested and that the copies provided eu-e tme, correct, and complete copies of the 24 records requested. 25 26 DEFINITIONS 27 Words that are in CAPITALS are defined as follows: 28 PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI- BOX CORPORATION (SET FOUR) (a) DOCUMENT(S), as used herein, shall refer to, mean, and include any tangible 1 2 thing upon which any expression, communication or representation has been recorded by any 3 means, including, but not limited to, any and all writings, as defined in Evidence Code § 250 4 including the original or a copy of handwriting,typewriting,printing, photostating, photographing, 5 6 electtonic and/or each and evety other means of recording upon any tangible or electtonic medium 7 and/or thing as well as any and all forms of communication or representation, including letters, 8 words, pictures, sounds or symbols, or any combination thereof 9 (b) LIQUI-BOX CORPORATION as used herein, includes, describes and refers to 10 11 Defendant LIQUI-BOX CORPORATION, its subsidiaries, its parent/holding companies, its 12 agents, representatives, investigators, employees, conttactors, insurance companies, their agents 13 their employees, their investtgators, their representatives and anyone else acting on LIQUI-BOX 14 CORPORATION'S behalf except its herein attomeys. 15 16 DOCUMENT REOUEST 17 The writings to be produced are: 18 REOUEST FOR PRODUCTION NO. 1 19 All documents YOU identified in YOUR responses to Plaintiff Sajida Zaman's Special 20 21 Interrogatories to Defendant Liqui-Box Corporation Set Four (4). 22 Dated: May 24, 2022 FALAKASSA LAW, P.C. 23 LIBERTY MAN LAW, P.C. 24 25 BY: Isi Joshua Falakassa 26 27 JOSHUA S. FALAKASSA 28 ARASH KHOSROWSHAHI Attomeys for Plamttff SAJIDA ZAMAN PLAINTIFF SAHDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI- BOX CORPORATION (SET FOUR) EXHIBIT D JOSHUA S. FALAKASSA (SBN: 295045) 1 FALAKASSA LAW, P.C. 2 1901 Avenue ofthe Stars Suite # 450 Los Angeles, Califomia 90067 3 Tel.: (818) 456-6168 4 Fax:(888)505-0868 Email: josh@falakassalaw.com 5 6 LIBERTY MAN LAW, P.C. ARASH S. KHOSROWSHAHI (SBN: 293246) 7 1010 F Street, Ste. 300 Sacramento, Califomia 95814 8 Tel.: (916) 573-0469 9 Fax: (866) 700-0787 Email: ash@libertymanlaw.com 10 11 Attomeys for Plaintiff SAJIDA ZAMAN 12 13 SUPERIOR COURT OF CALIFORNIA 14 COUNTY OF SACRAMENTO 15 16 SAJIDA ZAMAN, an individual. CASE NO.: 34-2019-00252121 17 PLAINTIFF SAJIDA ZAMAN'S SPECIAL 18 Plaintiff, INTERROGATORIES TO DEFENDANT vs. LIQUI-BOX CORPORATION (SET 19 LIQUI-BOX CORPORATION, and DOES 1 FOUR) 20 through 20, inclusive. 21 Defendants. 22 23 24 25 26 PROPOUNDING PARTY SAJIDA ZAMAN 27 LIQUI-BOX CORPORATION RESPONDING PARTY 28 SET NUMBER FOUR (4) PLAINTIFF SAJIDA ZAMAN'S SPECLM. INTERROGATORIES TO DEFENDANT LIQUI- BOX CORPORATION (SET FOUR) 1 TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD: 2 Plaintiff SAJIDA ZAMAN hereby requests that Defendant LIQUI-BOX CORPORATION 3 answer under oath within thirty (30) days, pursuant to Califomia Code of Civil Procedure §§ 4 2030.010 et seq., the following interrogatories. 5 In answering these interrogatories please fumish such information as is available to you, 6 and not merely that which you know of your personal knowledge. This means that you are to 7 fumish information which is available to you or is within the knowledge ofyour attomeys, or their 8 agents, employees, investigators or experts. (See Code of Civil Procedure §§ 2030.010 et seq.) 9 If any of these interrogatories cannot be answered in fiill, you are required to answer to the 10 extent possible, specifying the reason for your inability to answer the remainder and stating 11 whatever information or knowledge you have conceming the unanswered portion. 12 DEFINITIONS 13 Words that are in CAPITALS are defined as follows: 14 (a) "LIQUI-BOX", "YOU" or "YOUR" as used herein, includes, describes and refers 15 to Defendant LIQUI-BOX CORPORATION, its subsidiaries, its parent/holding companies, its 16 agents, representatives, investigators, employees, conttactors, govemmental entities, insurance 17 companies, their agents, their employees, their investigators, their representatives and anyone else 18 acting on Defendant LIQUI-BOX CORPORATION behalf except its herein attomeys. 19 (b) PERSON includes a natural person, firm, association, organization, partnership, 20 business, tmst, limited liability company, corporation, or public entity. 21 (c) "REPRIMAND" or "REPRIMANDED" as used herein means any punishment 22 suspension, demotion, loss of pay, failure or refusal to promote, failure or refusal to hire, or any 23 other action or failure to act that adversely affects the employee's rights or interests. 24 SPECIAL INTERROGATORIES 25 SPECIAL INTERROGATORY NO. 34; 26 Please identify, by name, address and telephone number the PERSON(S) who worked at 27 LIQUI-BOX CORPORATION'S Sacramento facility who YOU contend violated YOUR 28 Critical Safety Behaviors Policy during the last ten (10) years. (The phrase "Sacramento facility shall herein mean the business at 5000 Warehouse Way Sacramento, CA 95826 USA.) PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI- BOX CORPORATION (SET FOUR) 1 SPECIAL INTERROGATORY NO. 35: 2 Please identify, by name, address and telephone number the PERSON(S) who worked at 3 LIQUI-BOX CORPORATION'S Sacramento facility who YOU REPRIMANDED for 4 violating YOUR Critical Safety Behaviors Policy during the last ten (10) years. 5 SPECIAL INTERROGATORY NO. 36: 6 Please identify, by name, address and telephone number the PERSON(S) who worked at 7 LIQUI-BOX CORPORATION'S Sacramento facility who YOU terminated for violating 8 YOUR Critical Safety Behaviors Policy during the last ten (10) years. 9 SPECIAL INTERROGATORY NO. 37: 10 For each employee who was reprimanded for a violation of YOUR Critical Safety 11 Behaviors Policy at YOUR Sacramento facility during the last ten (10) years, please identify, by 12 name, address and telephone number all PERSON(S) with knowledge of the REPRIMAND. 13 SPECIAL INTERROGATORY NO. 38: 14 For each employee who was REPRIMANDED for a violation of YOUR Critical Safety 15 Behaviors Policy at YOUR Sacramento facility during the last ten (10) years, please state all facts 16 which support YOUR decision to REPRIMAND the employee. 17 SPECIAL INTERROGATORY NO. 39: 18 For each employee who was REPRIMANDED for a violation of YOUR Critical Safety 19 Behaviors Policy at YOUR Sacramento facility during the last ten (10) years, please identify all 20 documents containing information YOU relied upon in YOUR decision to REPRIMAND the 21 employee. 22 SPECIAL INTERROGATORY NO. 40: 23 For each employee who was terminated for a violation of YOUR Critical Safety 24 Behaviors Policy at YOUR Sacramento facility during the last ten (10) years, please identify, by 25 name, address and telephone number all PERSON(S) with knowledge of each employee YOU 26 terminated. 27 /// 28 /// /// PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI- BOX CORPORATION (SET FOUR) 1 SPECIAL INTERROGATORY NO. 41: 2 For each employee who was terminated for a violation of YOUR Critical Safety 3 Behaviors Policy at YOUR Sacramento facility during the past ten (10) years, please state all 4 facts upon which YOU supported YOUR termination of each employee. 5 SPECIAL INTERROGATORY NO. 42: 6 For each employee who was terminated for a violation of YOUR Critical Safety 7 Behaviors Policy at YOUR Sacramento facility during the past ten (10) years, please identify all 8 documents containing information YOU relied upon in YOUR decision to terminate each 9 employee. 10 11 Dated: May 24, 2022 FALAKASSA LAW, P.C. 12 LIBERTY MAN LAW, P.C. 13 14 BY: /s/ Joshua Falakassa 15 16 JOSHUA S. FALAKASSA 17 ARASH KHOSROWSHAHI 18 Attomeys for Plaintiff SAJIDA ZAMAN 19 20 21 22 23 24 25 26 27 28 PLAINTIFF SAJIDA ZAMAN'S SPECL\L INTERROGATORIES TO DEFENDANT LIQUI- BOX CORPORATION (SET FOUR) 1 JOSHUA S. FALAKASSA (SBN: 295045) FALAKASSA LAW, P.C. 2 1901 Avenue of ttie Stars Suite # 450 Los Angeles, Califomia 90067 3 Tel.: (818) 456-6168 Fax:(888)505-0868 4 Email: josh@falakassalaw.com 5 LIBERTY MAN LAW, P.C. 6 ARASH S. KHOSROWSHAHI (SBN: 293246) 1010 F Street, Ste. 300 7 Sacramento, Califomia 95814 Tel.: (916) 573-0469 8 Fax: (866) 700-0787 9 Email: ash@libertymanlaw.com 10 Attomeys for Plaintiff SAJIDA ZAMAN 11 12 SUPERIOR COURT OF CALIFORNIA 13 COUNTY OF SACRAMENTO 14 15 SAJIDA ZAMAN, an individual. CASENO.: 34-2019-00252121 16 Plaintiff, DECLARATION OF JOSHUA FALAKASSA REGARDING THE NEED vs. FOR ADDITIONAL SPECIAL 17 LIQUI-BOX CORPORATION, and DOES 1 INTERROGATORIES TO DEFENDANT 18 through 20, inclusive. [Served Concurrently with Plaintiffs Special 19 Interrogatories, Set Four] 20 Defendants. 21 22 23 24 25 26 27 28 1 DECLARATION OF JOSHUA FALAKASSA REGARDING THE NEED FOR ADDITIONAL SPECIAL INTERROGATORIES TO DEFENDANT 1 DECLARATION OF JOSHUA FALAKASSA 2 I, Joshua Falakassa, declare and state as follows: 3 1. I am presently the attomey for plaintiff Sajida Zaman ("Plaintiff), a party to this 4 action. 5 2. I am propoimding to defendant Liqui-Box Corporatton ("Defendant") the attached 6 Special Interrogatories, Set Number Four (4). 7 3. This set of interrogatories will cause the total number of specially prepared 8 interrogatories propounded to the party to whom they are directed to exceed the number of 9 specially prepared interrogatories permitted by Section 2030.030 of the Code of Civil Procedure. 10 4. I have previously propounded a total of thirty-three (33) specially prepared 11 interrogatories to this party. 12 5. This set of interrogatories contains a total of nine (9) specially prepared 13 interrogatories. 14 6. I am familiar with the issues and the previous discovery conducted by all of the IS parttes to this case. 16 7. I have personally examined each of the questions in this set of interrogatories. 17 8. This number of questions is warranted under Section 2030.040 of the Code of Civil 18 Procedure because of the quantity and nature of the existing and potential issues involved, and the 19 expedience and benefit to each of the parties that will result in using this form of discovery to 20 obtain certain information about Defendant's positions, argxunents and defenses. 21 9. None of the questions in this set of interrogatories is being propounded for any 22 improper purpose, such as to harass the party or the attomey for the party to whom it is directed or 23 to cause uimecessary delay or needless increase in the cost of litigation. 24 I declare under penalty of perjury imder the laws of the State of Califomia that the 25 foregoing is tme and correct, and that this declaration was executed on May 24, 2022, at Los 26 Angeles, Califomia. 27 /s/Joshua Falakassa 28 Joshua Falakassa 2 DECLARATION OF JOSHUA FALAKASSA REGARDING THE NEED FOR ADDITIONAL SPECIAL INTERROGATORIES TO DEFENDANT EXHIBIT E JOSHUA S. FALAKASSA (SBN: 295045) FALAKASSA LAW, P.C. 1901 Avenue ofthe Stars Suite # 450 3 Los Angeles, Califomia 90067 Tel.: (818) 456-6168 Fax: (888) 505-0868 4 Email: josh@falakassalaw.com 5 LIBERTY MAN LAW, P.C. ARASH S. KHOSROWSHAHI (SBN; 293246) 6 1010 F Stteet, Ste. 300 Sacramento, Califomia 95814 7 Tel.: (916) 573-0469 Fax: (866) 700-0787 S Email: ash@libertymanlaw.com Attomeys for Plaintiff SAHDA ZAMAN 10 SUPERIOR COURT OF CALIFORNLA II COUNTY OF SACRAMENTO 12 13 SAJIDA ZAMAN, an individual, CASENO.: 34-2019-00252121 14 Plaintiff, PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT 15 vs. LIQUI-BOX CORPORATION (SET FIVE) LIQUI-BOX CORPORATION, and DOES 1 IC> through 20, inclusive, 17 Defendants. 18 19 20 PROPOUNDING PARTY SAJIDA ZAMAN 21 RESPONDING PARTY LIQUI-BOX CORPORATION 22 SET NUMBER FIVE (5) 23 PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI-BOX CORPORATION (SET FOUR) TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD: 3 Plaintiff SAJIDA ZAMAN hereby requests that Defendant LIQUI-BOX 4 CORPORATION answer under oath within thirty (30) days, pursuant to Califomia Code of Civil 5 Procedure §§ 2030.010 etseq., the following interrogatories. 6 In answering these interrogatories please fumish such information as is available to you, 7 and not merely that which you know of your personal knowledge. This means that you are to 8 fiiraish information which is available to you or is within the knowledge of your attorneys, or their agents, employees, investigators or experts. (See Code of Civil Procedure §§ 2030.010 et 9 seq.) 10 If any of these interrogatories cannot be answered in full, you are required to answer to 11 the extent possible, specifying the reason for your inability to answer the remainder and stating 12 whatever information or knowledge you have conceming the unanswered portion. 13 DEFINITIONS 14 Words that are in CAPITALS are defined as follows: 15 (a) "LIQUI-BOX", "YOU" or "YOUR" as used herein, includes, describes and 16 refers to Defendant LIQUI-BOX CORPORATION, its subsidiaries, its parent/holding companies 17 (including LB Hold Co.), its agents, representatives, investigators, employees, contractors, IX govemmental entities, insurance companies, their agents, their employees, their investigators, )9 their representatives and anyone else acting on Defendant LIQUI-BOX CORPORATION behalf except its herein attomeys. 20 (b) PERSON includes a natural person, firm, association, organization, partnership, 21 business, tmst,