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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar number, and adqreS5) [SBN] 945691] FOR COURT USE ONLY
Jerry J. Deschler, Deputy Attorney General
California Department of Justice, Office of the Attorney General
1300 | Street, Ste. 125, Sacramento, CA 95814
Superior Court of California
TevepHone no: (916) 210-7871 FAX NO. (Optional: (916) 324-5567
County of Butte
F
E-MAIL ADDRESS (Optional): jerry.deschler@doj.ca.gov
ATTORNEY FOR (Name): Defendants
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Butte
10/17/2023
street appress: 1775 Concord Ave.
MAILING ADDRESS: Sharif Elmaitah, 2 D
CITY AND ZIP CODE: Chico, CA 95928 => Deputy
BRANCH NAME: ‘Clectronicaily FILED
PLAINTIFF/PETITIONER: Teresa Randolph
DEFENDANT/RESPONDENT: California State University, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE [) timrtep case 19CV01226
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: Nov. 1, 2023 Time: 10:30 Dept.: 2 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Defendants
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. [_] This statement is submitted by party (name):
This statement is submitted jointly by parties (names): All named defendants (see attached)
Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a The complaint was filed on (date):
b. [_] The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
a. Co al parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [_] The following parties named in the complaint or cross-complaint
(1) [1 have not been served (specify names and explain why not):
(2) [1 have been served but have not appeared and have not been dismissed (specify names):
(3) [1 have had a default entered against them (specify names):
c. Co) The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
Description of case
a Type of case in complaint Co cross-complaint (Describe, including causes of action):
Employment discrimination, harassment, retaliation, failure to accommodate/interactive process, pursuant to
California Fair Employment and Housing Act; violation of public policy; defamation; invasion of privacy.
Page 1 of 5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California rules 3.720-3.730
(CM-110 (Rev. July 1, 2011] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: Teresa Randolph
‘CASE NUMBER:
19CV01226
DEFENDANT/RESPONDENT: California State University, et al.
4. b. Provide a brief statement of the case, including any damages. (/f personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff cannot prove a prima facie case for any of her employment causes of action. She was not harassed or
discriminated against based on any protected characteristic and was not subjected to any adverse employment
action. Any actions taken by the Defendants were for legitimate business reasons. Defendants granted
reasonable accommodations. Defendants took reasonable steps to prevent harassment.
[=] (fmore space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request [5 a jury trial [4 a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial).
Trial date
a. [1 The trial has been set for (date).
b. [7] No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain).
Trial date has been vacated. Parties are scheduling depositions and completing discovery. See attached
©. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability).
See attached.
Estimated length of ti I
The party or parties estimate that the trial will take (check one).
days (specify number): 12-15 court days
. [1 hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial [7] by the attorney or party listed in the caption [] by the following
a. Attorney:
b. Firm:
c. Address:
d Telephone number: f Fax number:
E-mail address: g. Party represented
ro Additional representation is described in Attachment 8.
Preference
[1] This case is entitled to preference (specify code section)
10. Alternative dispute resolution (ADR)
a ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel [-1 thas [21 has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party [1 has [1] has not reviewed the ADR information package identified in rule 3.221
b. Referral to judicial arbitration or civil action mediation (if available).
4) C3
d
This matter is subj ject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
2) CO Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11
3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption).
3.811(b)(7)
(CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 of 5
CM-110
PLAINTIFF/PETITIONER: Teresa Randolph [CASE NUMBER:
19CV01226
DEFENDANT/RESPONDENT: California State University, et al.
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):
Oo Mediation session not yet scheduled
Oo Mediation session scheduled for (date):
(1) Mediation
Oo Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date):
Settlement conference completed on (date): 6/28/23
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
arbitration
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
(CM-110 [Rev. July 1, 2011] Page 3 ofS
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER:
CASE NUMBER:
L Teresa Randolph
19CV01226
DEFENDANT/RESPONDENT: California State University, et al.
11. Insurance
a [1 insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: [7] Yes No
c. [1 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.
[1 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:
(3) Case number:
(4) Status:
[] Additional cases are described in Attachment 13a.
b. [-_] Amotion to [5 consolidate [-) coordinate will be filed by (name party):
14. Bifurcation
The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
Defendants may file a motion to bifurcate damages from liability.
15. Other motions
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Defendants are preparing a motion for summary adjudication and motion for sanctions as to some causes of
action. Defendants will later file a motion for summary judgment/adjudication as to remaining causes of action.
16. Discovery
a. [_] The party or parties have completed all discovery.
The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Descriptio Date
Defendant Initial written discovery complete
Defendant Plaintiff's deposition Feb. 2024
Defendant Subpoenas TBD
Defendant Mental examination of Plaintiff Feb. 2024
Defendant Depositions of third party witnesses May 2024
The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
The parties engaged in extensive written discovery and document production, and required motion work to
resolve discovery disputes. The Covid pandemic initially prevented the parties from completing depositions
(at least some of which should be conducted in person because the case is document-intensive). The parties
scheduled depositions of plaintiff and over a dozen percipient and "persons most knowledgeable" witnesses.
Several are complete. Some witnesses are avoiding service. As set forth in attachment 6.b., Defendants will
move to compel a mental examination of Plaintiff and expect further discovery motions.
(CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5
CM-110
PLAINTIFF/PETITIONER: Teresa Randolph CASE NUMBER;
| 19CV01226
DEFENDANT/RESPONDENT: California State University, et al.
17. Economic litigation
a. [_] This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. [_] 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 management
conference (specify):
19. Meet and confer
a. L¥_] The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules
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 following
(specify):
20. Total number of pages attached (if any): 3
| am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: October 17, 2023
Jerry J. Deschler » SSS
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME)
» (SIGNATURE OF PARTY OR ATTORNEY)
[] Additional signatures are attached.
(CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5
Attachment 1.b.
This statement is being submitted jointly by all named defendants. Specifically:
° Defendant Board of Trustees of the California State University (erroneously sued as
“Trustees of the California State University, State of California”) is the State of
California acting in its higher education capacity. California State University, Chico is
one of the twenty three campuses that comprise the California State University system.
Cynthia Daley
Individual defendant Debra Larson was dismissed from the case.
Attachment 6.b.
The parties are still engaging in additional depositions and written discovery. Some key third-
party witnesses have been evading service of deposition subpoenas and have not yet been
deposed.
Defendants sent a demand letter to Plaintiff regarding a requested mental examination to
determine the nature and extent of her emotional distress damages, if any, and the causation of
such damages, pursuant to Code of Civil Procedure sections 2032.020, et seq. Defendants expect
to file a motion to compel the examination, which is expected to be filed and served shortly.
Based on admissions from Plaintiff during the first two days of her deposition establishing that
she has no evidentiary basis for some of the eleven causes of action in her Third Amended
Complaint, Defendants met and conferred with Plaintiff orally and in writing on June 15, 2023 to
request voluntary dismissal of some of those causes of action that admittedly had no evidentiary
basis, as dismissal would streamline the issues for trial and would ultimately reduce the time and
expense needed by all parties to bring the case to trial. Plaintiff refused. Consequently,
Defendants are in the process of preparing a motion for summary adjudication of some of
Plaintiff's causes of action, and a motion for sanctions pursuant to Code of Civil Procedure
sections 128.5 and 128.7 for continuing to prosecute and refusal to withdraw meritless claims.
Once discovery is complete, including the above-referenced depositions and discovery motions,
and defendants complete their additional written discovery, Defendants will move for summary
adjudication of Plaintiff's remaining causes of action.
Attachment 6.c.
Defense counsel is unavailable for trial on the following dates:
March 18, 2024 — April 12, 2024
June 17, 2024 — June 21, 2024
November 27, 2024 — November 29, 2024
December 24, 2024 — January 3, 2025
DECLARATION OF SERVICE BY E-MAIL
Case Name: Teresa Randolph v. Trustees of the California State University, et al.
No.: 19CV01226
I declare:
Iam employed in the Office of the Attorney General, which is the office of a member of the
California State Bar, at which member's direction this service is made. I am 18 years of age or
older and not a party to this matter.
On October 17, 2023, I served the attached CASE MANAGE T STATEMENT by
transmitting a true copy via electronic mail addressed as follows:
Thomas Dimitre
Thomas Dimitre Attorney at Law LLC
E-mail Address: dimitre@mind.net
I declare under penalty of perjury under the laws of the State of California and the United States
of America the foregoing is true and correct and that this declaration was executed on October
17, 2023, at Sacramento, California.
Christopher R. Irby S/ Christopher R. Irby
Declarant Signature
$A2019102196
37597264.docx
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar number, and adqreS5) [SBN] 945691] FOR COURT USE ONLY Jerry J. Deschler, Deputy Attorney General California Department of Justice, Office of the Attorney General 1300 | Street, Ste. 125, Sacramento, CA 95814 Superior Court of California TevepHone no: (916) 210-7871 FAX NO. (Optional: (916) 324-5567 County of Butte F E-MAIL ADDRESS (Optional): jerry.deschler@doj.ca.gov ATTORNEY FOR (Name): Defendants SUPERIOR COURT OF CALIFORNIA, COUNTY OF Butte 10/17/2023 street appress: 1775 Concord Ave. MAILING ADDRESS: Sharif Elmaitah, 2 D CITY AND ZIP CODE: Chico, CA 95928 => Deputy BRANCH NAME: ‘Clectronicaily FILED PLAINTIFF/PETITIONER: Teresa Randolph DEFENDANT/RESPONDENT: California State University, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE [) timrtep case 19CV01226 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: Nov. 1, 2023 Time: 10:30 Dept.: 2 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Defendants INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. [_] This statement is submitted by party (name): This statement is submitted jointly by parties (names): All named defendants (see attached) Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a The complaint was filed on (date): b. [_] The cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) a. Co al parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [_] The following parties named in the complaint or cross-complaint (1) [1 have not been served (specify names and explain why not): (2) [1 have been served but have not appeared and have not been dismissed (specify names): (3) [1 have had a default entered against them (specify names): c. Co) The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): Description of case a Type of case in complaint Co cross-complaint (Describe, including causes of action): Employment discrimination, harassment, retaliation, failure to accommodate/interactive process, pursuant to California Fair Employment and Housing Act; violation of public policy; defamation; invasion of privacy. Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California rules 3.720-3.730 (CM-110 (Rev. July 1, 2011] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: Teresa Randolph ‘CASE NUMBER: 19CV01226 DEFENDANT/RESPONDENT: California State University, et al. 4. b. Provide a brief statement of the case, including any damages. (/f personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff cannot prove a prima facie case for any of her employment causes of action. She was not harassed or discriminated against based on any protected characteristic and was not subjected to any adverse employment action. Any actions taken by the Defendants were for legitimate business reasons. Defendants granted reasonable accommodations. Defendants took reasonable steps to prevent harassment. [=] (fmore space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request [5 a jury trial [4 a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial). Trial date a. [1 The trial has been set for (date). b. [7] No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain). Trial date has been vacated. Parties are scheduling depositions and completing discovery. See attached ©. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability). See attached. Estimated length of ti I The party or parties estimate that the trial will take (check one). days (specify number): 12-15 court days . [1 hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial [7] by the attorney or party listed in the caption [] by the following a. Attorney: b. Firm: c. Address: d Telephone number: f Fax number: E-mail address: g. Party represented ro Additional representation is described in Attachment 8. Preference [1] This case is entitled to preference (specify code section) 10. Alternative dispute resolution (ADR) a ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel [-1 thas [21 has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party [1 has [1] has not reviewed the ADR information package identified in rule 3.221 b. Referral to judicial arbitration or civil action mediation (if available). 4) C3 d This matter is subj ject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. 2) CO Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11 3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption). 3.811(b)(7) (CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 of 5 CM-110 PLAINTIFF/PETITIONER: Teresa Randolph [CASE NUMBER: 19CV01226 DEFENDANT/RESPONDENT: California State University, et al. 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): Oo Mediation session not yet scheduled Oo Mediation session scheduled for (date): (1) Mediation Oo Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): 6/28/23 Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): (CM-110 [Rev. July 1, 2011] Page 3 ofS CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: CASE NUMBER: L Teresa Randolph 19CV01226 DEFENDANT/RESPONDENT: California State University, et al. 11. Insurance a [1 insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: [7] Yes No c. [1 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. [1 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: (3) Case number: (4) Status: [] Additional cases are described in Attachment 13a. b. [-_] Amotion to [5 consolidate [-) coordinate will be filed by (name party): 14. Bifurcation The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): Defendants may file a motion to bifurcate damages from liability. 15. Other motions The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Defendants are preparing a motion for summary adjudication and motion for sanctions as to some causes of action. Defendants will later file a motion for summary judgment/adjudication as to remaining causes of action. 16. Discovery a. [_] The party or parties have completed all discovery. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Descriptio Date Defendant Initial written discovery complete Defendant Plaintiff's deposition Feb. 2024 Defendant Subpoenas TBD Defendant Mental examination of Plaintiff Feb. 2024 Defendant Depositions of third party witnesses May 2024 The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): The parties engaged in extensive written discovery and document production, and required motion work to resolve discovery disputes. The Covid pandemic initially prevented the parties from completing depositions (at least some of which should be conducted in person because the case is document-intensive). The parties scheduled depositions of plaintiff and over a dozen percipient and "persons most knowledgeable" witnesses. Several are complete. Some witnesses are avoiding service. As set forth in attachment 6.b., Defendants will move to compel a mental examination of Plaintiff and expect further discovery motions. (CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: Teresa Randolph CASE NUMBER; | 19CV01226 DEFENDANT/RESPONDENT: California State University, et al. 17. Economic litigation a. [_] This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. [_] 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 management conference (specify): 19. Meet and confer a. L¥_] The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules 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 following (specify): 20. Total number of pages attached (if any): 3 | am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: October 17, 2023 Jerry J. Deschler » SSS (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) » (SIGNATURE OF PARTY OR ATTORNEY) [] Additional signatures are attached. (CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5 Attachment 1.b. This statement is being submitted jointly by all named defendants. Specifically: ° Defendant Board of Trustees of the California State University (erroneously sued as “Trustees of the California State University, State of California”) is the State of California acting in its higher education capacity. California State University, Chico is one of the twenty three campuses that comprise the California State University system. Cynthia Daley Individual defendant Debra Larson was dismissed from the case. Attachment 6.b. The parties are still engaging in additional depositions and written discovery. Some key third- party witnesses have been evading service of deposition subpoenas and have not yet been deposed. Defendants sent a demand letter to Plaintiff regarding a requested mental examination to determine the nature and extent of her emotional distress damages, if any, and the causation of such damages, pursuant to Code of Civil Procedure sections 2032.020, et seq. Defendants expect to file a motion to compel the examination, which is expected to be filed and served shortly. Based on admissions from Plaintiff during the first two days of her deposition establishing that she has no evidentiary basis for some of the eleven causes of action in her Third Amended Complaint, Defendants met and conferred with Plaintiff orally and in writing on June 15, 2023 to request voluntary dismissal of some of those causes of action that admittedly had no evidentiary basis, as dismissal would streamline the issues for trial and would ultimately reduce the time and expense needed by all parties to bring the case to trial. Plaintiff refused. Consequently, Defendants are in the process of preparing a motion for summary adjudication of some of Plaintiff's causes of action, and a motion for sanctions pursuant to Code of Civil Procedure sections 128.5 and 128.7 for continuing to prosecute and refusal to withdraw meritless claims. Once discovery is complete, including the above-referenced depositions and discovery motions, and defendants complete their additional written discovery, Defendants will move for summary adjudication of Plaintiff's remaining causes of action. Attachment 6.c. Defense counsel is unavailable for trial on the following dates: March 18, 2024 — April 12, 2024 June 17, 2024 — June 21, 2024 November 27, 2024 — November 29, 2024 December 24, 2024 — January 3, 2025 DECLARATION OF SERVICE BY E-MAIL Case Name: Teresa Randolph v. Trustees of the California State University, et al. No.: 19CV01226 I declare: Iam employed in the Office of the Attorney General, which is the office of a member of the California State Bar, at which member's direction this service is made. I am 18 years of age or older and not a party to this matter. On October 17, 2023, I served the attached CASE MANAGE T STATEMENT by transmitting a true copy via electronic mail addressed as follows: Thomas Dimitre Thomas Dimitre Attorney at Law LLC E-mail Address: dimitre@mind.net I declare under penalty of perjury under the laws of the State of California and the United States of America the foregoing is true and correct and that this declaration was executed on October 17, 2023, at Sacramento, California. Christopher R. Irby S/ Christopher R. Irby Declarant Signature $A2019102196 37597264.docx