Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar num�r. and oddross): FOR COURT USE ONLY
Thomas Dimitre SBN 276924
PO Box 801
Ashland, OR 97520
TELEPHONE NO.; 5418905022 FAX NO. (Optional): 5414884601
E-MAIL ADDRESS 1op1ionaQ: dimitre@mind.net
. ATTORNEY FOR /Name): Teresa Randolph
SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE 3/12/2024
srREET ADDREss· 1775 Concord Ave
MAILING ADDRESS•
cITYANDzIPcooe, Chico, CA 95928
BRANCH NAME:
PLAINTIFF/PETITIONER: Teresa Randolph
DEFENDANT/RESPONDENT: Trustees of the Calif State Univ, State of Calif, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER·
(Check one): m UNLIMITED CASE
(Amount demanded
D LIMITED CASE
(Amount demanded is $25,000
19CV01226
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: mar 27, 2024 Time: 10:30 Dept.: 2 Div.: Room:
am Address of court (if
different from the address above):
[ZJ Notice of Intent to Appear by Telephone, by (name): Thomas Dimitre
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. W This statement is submitted by party (name): Teresa Randolph
b. D This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): 4/19/19
b. D The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. W All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. D The following parties named in the complaint or cross-complaint
(1) D have not been served (specify names and explain why not):
(2) D have been served but have not appeared and have not been dismissed (specify names):
( 3) D have had a default entered against them (specify names):
c. D The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be seNed):
4. Description of case
a. Type of case in W complaint D cross-complaint (Describe, including causes of action):
Employment discrimination and constructive discharge case
Pa o1ot5
Form Ad<)pted lo, Mandalo,y Use
Judicial Council of Caliromia
CASE MANAGEMENT STATEMENT Cal. Rules of Coun,
NKlS 3.720-3.730
CM-110(Rav. July 1, 20111 www.courls.ca.gov
CM-110
- PLAINTIFF/PETITIONER: Teresa Randolph
DEFENDANT/RESPONDENT: Trustees of the Calif State Univ, State of Calif, et al.
CASE NUMBER
19CV01226
4. b. Provide a brief statement of the case. Including any damages. (If 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 earning�. If equitable relief Is sought, describe the nature of the relief.)
Plaintiff was discriminated against due to her disability, already agreed upon accommodations unilaterally
removed, no interactive process or reasonable accommodations. Plaintiff was constructtvely discharged when
her physician recommended that she not return to worl< due to the unwillingness of Defendants to comply with the
FEHA. Damages $750,000 of which approx $350k is lost wages/retirement and $400k Is pain and suffering.
x (If more space is needed, check this box and attach a page designated as Attachment 4b.)
D
m
5. Jury or nonjury trial
The party or parties request a jury trial D a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. D The trial has been set for (date):
b. [ZJ 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, exp/am):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
See attached.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [lJ days (specify number): 7
b. D hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial [2J by the attorney or party listed in the caption D by the foilOWlng:
a. Attorney:
b. Firm:
C. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
D Additional representation is described in Attachment 8.
9. Preference
D 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 [ZJ has Dhas 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 D has D has not reviewed the ADR Information package identified In rule 3.221.
b. Referral to judicial arbitration or clvll action mediation (If available).
(1) D This matter Is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) D 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) [2J This case Is exempt from Judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM,110lfl-Y -Uyl.2011)
CASE MANAGEMENT STATEMENT
CM-110
CASC NUMBER·
PLAINTIFF/PETITIONER: Teresa Randolph
_
19CV01226
DEFENDANT/RESPONDENT: Trustees of the Calif State Univ, State of Calif, 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):
m Mediation session not yet scheduled
(1) Mediation IT] D Mediation session scheduled for (date):
D Agreed to complete mediation by (date):
D Mediation completed on (date):
m Settlement conference not yet scheduled
(2) Settlement D Settlement conference scheduled for (date):
conference
D Agreed to complete settlement conference by (dale):
D Settlement conference completed on (date):
D Neutral evaluation not yet scheduled
D D Neutral evaluation scheduled for (date):
(3) Neutral evaluation
D Agreed to complete neutral evaluation by (date):
D Neutral evaluation completed on (dale):
D Judicial arbitration not yet scheduled
(4) Nonbinding judicial D D Judicial arbitration scheduled for (date):
arbitration
D Agreed to complete judicial arbitration by (dale):
D Judicial arbitration completed on (date):
D Private arbitration not yet scheduled
(5) Binding private D D Private arbitration scheduled for (date):
arbitration
D Agreed to complete private arbitration by (date):
D Private arbitration completed on (date):
D ADR session not yet scheduled
D D ADR session scheduled for (date):
(6) O ther (specify):
D Agreed to complete ADR session by (date):
D ADR completed on (dale):
CM-110 [Rev. July 1. 2011) P190 3 ol 5
CASE MANAGEMENT STATEMENT
CM-110
CASE NUMBER;
PLAINTIFF/PETITIONER: Teresa Randolph
- 19CV01226
DEFENDANT/RESPONDENT: Trustees of the Calif State Univ, State of Calif, et al.
11. Insurance
a. D Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: D Yes D No
c. D 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.
D Bankruptcy D Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. D There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
D Additional cases are described in Attachment 13a.
b. D A motion to D consolidate D coordinate will be filed by (name party):
14. Bifurcation
D 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):
15. Other motions
[L] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Plaintiff, MSJ
.
16. Discovery
a. D
The party or parties have completed all discovery.
b. W
The following discovery will be completed by the date specified (describe all anticipated discovery):
� Description Date
Plaintiff Defendant has refused to provide discovery documents which Unknown
may necessitate a motion to compel.
.
c . 1Z] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
See above.
Pago 4 of 5
CM-110 (Rev. July 1, 20111
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Teresa Randolph "55 "UMBER:
1QCV01226
DEFENDANT/RESPONDENT: Trustees Of the Calif State Univ, State Of Calif. et al.
17. Economic litigation
a. I:I
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. :I 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):
Setting of a settlement conference.
19. Meet and confer
a. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the Califomia Rules
of Court (if not, explain):
Not applicable at this time.
b. After meeting and conferring as required by rule 3.724 of the Caiifomia Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (it any):
Iam 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: March 10, 2024 '.
I'r
Thomas Drmrtre
(TYPE OR PRINT NAME)
' ,1
,
\'
(SIGNA'I'GRE OF PARTYXR ATTORNEY)
(TYPE 0R PRlNT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
E] Additional signatures are attached.
CM" '° ["3" "V '- 2°"! CASE MANAGEMENT STATEMENT "9' 5°' 5
Attachment:
6. Trial Date. Plaintiff and Plaintiff’s counsel are not available for trail during the following
dates:
March 30, 2024 - December 31, 2024
The Court should set a trial date for early 2025.
16. Discovery. The Court should set a deadline for discovery, as Defendants are abusing the
discovery process. Otherwise, Plaintiff will file for a protective order, to limit and set a deadline
for Defendants’ frivolous discovery requests. This case was set to go to trial in August 2023.
Since that time, Defendants have propounded numerous frivolous and meritless discovery
including, but not limited to:
a) another day of deposition of Plaintiff (Defendant has already taken 2 days of Plaintiff’s
deposition), b) Subpoenas, c) Mental Examination of Plaintiff, Depositions of Third Party
witnesses. We would expect that the Calif. DOJ would have it together and would have
propounded discovery in a timely manner. Continuing to propound discovery – that all could
have been done years ago – in a timely manner – is unnecessarily extending this case, and
keeping it out of a trial setting mode.
Plaintiff has responded to all of the multiple discovery requests made by Defendant, and as of the
date of Plaintiff filing out this CMC statement, no objections have been raised to Plaintiff by
Defendant.
1 Thomas Dimitre, Attorney at Law L.L.C.
CSB # 276924
2 dimitre@mind.net
3
PO Box 801
Ashland, OR 97520
4 Telephone: 541-890-5022
Attorney for Plaintiff
5
6
STATE OF CALIFORNIA
7
COUNTY OF BUTTE
8
9
10
TERESA RANDOLPH, an individual Case No. 19CV01226
11
Plaintiff
12
CERTIFICATE OF SERVICE
13 v.
14 TRUSTEES OF THE CALIFORNIA
STATE UNIVERSITY, STATE OF
15
CALIFORNIA, AND CYNTHIA DALEY,
16 AN INDIVIDUAL, AND DEBRA
LARSON, AN INDIVIDUAL
17
Defendants
18
19
20
21
22
23
24
25
26
27
28
1
2
I, Thomas Dimitre, declare as follows:
3
I am an employee of Thomas Dimitre, Attorney at Law, over the age of eighteen
4
years and not a party to this action. My business address is PO BOX 801, Ashland,
5
Oregon 97520. My business telephone number is (541) 890-5022, and my fax number is
6
(541) 488-4601.
7
8 On March 12, 2024 I served the foregoing document(s) described as:
9 1. CMC Statement, by placing true copies thereof in sealed envelopes with
10 postage thereon fully prepaid, in the United States mail at ASHLAND, OR
11 addressed as shown below:
12
Jerry Deschler Jr.
13 Deputy Attorney General IV
14
1300 I Street
Sacramento, CA 95814
15
16
I declare, under penalty of perjury under the a s of the State of California, that
the foregoing is true and correct
17
Executed on March 12, 2024
18
19
TH
20
Attorney for Plaintiff,
21 Teresa Randolph
22
23
24
25
26
27
28
2
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar num�r. and oddross): FOR COURT USE ONLY Thomas Dimitre SBN 276924 PO Box 801 Ashland, OR 97520 TELEPHONE NO.; 5418905022 FAX NO. (Optional): 5414884601 E-MAIL ADDRESS 1op1ionaQ: dimitre@mind.net . ATTORNEY FOR /Name): Teresa Randolph SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE 3/12/2024 srREET ADDREss· 1775 Concord Ave MAILING ADDRESS• cITYANDzIPcooe, Chico, CA 95928 BRANCH NAME: PLAINTIFF/PETITIONER: Teresa Randolph DEFENDANT/RESPONDENT: Trustees of the Calif State Univ, State of Calif, et al. CASE MANAGEMENT STATEMENT CASE NUMBER· (Check one): m UNLIMITED CASE (Amount demanded D LIMITED CASE (Amount demanded is $25,000 19CV01226 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: mar 27, 2024 Time: 10:30 Dept.: 2 Div.: Room: am Address of court (if different from the address above): [ZJ Notice of Intent to Appear by Telephone, by (name): Thomas Dimitre INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. W This statement is submitted by party (name): Teresa Randolph b. D This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): 4/19/19 b. D The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. W All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. D The following parties named in the complaint or cross-complaint (1) D have not been served (specify names and explain why not): (2) D have been served but have not appeared and have not been dismissed (specify names): ( 3) D have had a default entered against them (specify names): c. D The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be seNed): 4. Description of case a. Type of case in W complaint D cross-complaint (Describe, including causes of action): Employment discrimination and constructive discharge case Pa o1ot5 Form Ad<)pted lo, Mandalo,y Use Judicial Council of Caliromia CASE MANAGEMENT STATEMENT Cal. Rules of Coun, NKlS 3.720-3.730 CM-110(Rav. July 1, 20111 www.courls.ca.gov CM-110 - PLAINTIFF/PETITIONER: Teresa Randolph DEFENDANT/RESPONDENT: Trustees of the Calif State Univ, State of Calif, et al. CASE NUMBER 19CV01226 4. b. Provide a brief statement of the case. Including any damages. (If 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 earning�. If equitable relief Is sought, describe the nature of the relief.) Plaintiff was discriminated against due to her disability, already agreed upon accommodations unilaterally removed, no interactive process or reasonable accommodations. Plaintiff was constructtvely discharged when her physician recommended that she not return to worl< due to the unwillingness of Defendants to comply with the FEHA. Damages $750,000 of which approx $350k is lost wages/retirement and $400k Is pain and suffering. x (If more space is needed, check this box and attach a page designated as Attachment 4b.) D m 5. Jury or nonjury trial The party or parties request a jury trial D a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. D The trial has been set for (date): b. [ZJ 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, exp/am): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): See attached. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [lJ days (specify number): 7 b. D hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial [2J by the attorney or party listed in the caption D by the foilOWlng: a. Attorney: b. Firm: C. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: D Additional representation is described in Attachment 8. 9. Preference D 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 [ZJ has Dhas 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 D has D has not reviewed the ADR Information package identified In rule 3.221. b. Referral to judicial arbitration or clvll action mediation (If available). (1) D This matter Is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) D 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) [2J This case Is exempt from Judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM,110lfl-Y -Uyl.2011) CASE MANAGEMENT STATEMENT CM-110 CASC NUMBER· PLAINTIFF/PETITIONER: Teresa Randolph _ 19CV01226 DEFENDANT/RESPONDENT: Trustees of the Calif State Univ, State of Calif, 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): m Mediation session not yet scheduled (1) Mediation IT] D Mediation session scheduled for (date): D Agreed to complete mediation by (date): D Mediation completed on (date): m Settlement conference not yet scheduled (2) Settlement D Settlement conference scheduled for (date): conference D Agreed to complete settlement conference by (dale): D Settlement conference completed on (date): D Neutral evaluation not yet scheduled D D Neutral evaluation scheduled for (date): (3) Neutral evaluation D Agreed to complete neutral evaluation by (date): D Neutral evaluation completed on (dale): D Judicial arbitration not yet scheduled (4) Nonbinding judicial D D Judicial arbitration scheduled for (date): arbitration D Agreed to complete judicial arbitration by (dale): D Judicial arbitration completed on (date): D Private arbitration not yet scheduled (5) Binding private D D Private arbitration scheduled for (date): arbitration D Agreed to complete private arbitration by (date): D Private arbitration completed on (date): D ADR session not yet scheduled D D ADR session scheduled for (date): (6) O ther (specify): D Agreed to complete ADR session by (date): D ADR completed on (dale): CM-110 [Rev. July 1. 2011) P190 3 ol 5 CASE MANAGEMENT STATEMENT CM-110 CASE NUMBER; PLAINTIFF/PETITIONER: Teresa Randolph - 19CV01226 DEFENDANT/RESPONDENT: Trustees of the Calif State Univ, State of Calif, et al. 11. Insurance a. D Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: D Yes D No c. D 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. D Bankruptcy D Other (specify): Status: 13. Related cases, consolidation, and coordination a. D There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: D Additional cases are described in Attachment 13a. b. D A motion to D consolidate D coordinate will be filed by (name party): 14. Bifurcation D 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): 15. Other motions [L] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Plaintiff, MSJ . 16. Discovery a. D The party or parties have completed all discovery. b. W The following discovery will be completed by the date specified (describe all anticipated discovery): � Description Date Plaintiff Defendant has refused to provide discovery documents which Unknown may necessitate a motion to compel. . c . 1Z] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): See above. Pago 4 of 5 CM-110 (Rev. July 1, 20111 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Teresa Randolph "55 "UMBER: 1QCV01226 DEFENDANT/RESPONDENT: Trustees Of the Calif State Univ, State Of Calif. et al. 17. Economic litigation a. I:I 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. :I 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): Setting of a settlement conference. 19. Meet and confer a. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the Califomia Rules of Court (if not, explain): Not applicable at this time. b. After meeting and conferring as required by rule 3.724 of the Caiifomia Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (it any): Iam 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: March 10, 2024 '. I'r Thomas Drmrtre (TYPE OR PRINT NAME) ' ,1 , \' (SIGNA'I'GRE OF PARTYXR ATTORNEY) (TYPE 0R PRlNT NAME) (SIGNATURE OF PARTY OR ATTORNEY) E] Additional signatures are attached. CM" '° ["3" "V '- 2°"! CASE MANAGEMENT STATEMENT "9' 5°' 5 Attachment: 6. Trial Date. Plaintiff and Plaintiff’s counsel are not available for trail during the following dates: March 30, 2024 - December 31, 2024 The Court should set a trial date for early 2025. 16. Discovery. The Court should set a deadline for discovery, as Defendants are abusing the discovery process. Otherwise, Plaintiff will file for a protective order, to limit and set a deadline for Defendants’ frivolous discovery requests. This case was set to go to trial in August 2023. Since that time, Defendants have propounded numerous frivolous and meritless discovery including, but not limited to: a) another day of deposition of Plaintiff (Defendant has already taken 2 days of Plaintiff’s deposition), b) Subpoenas, c) Mental Examination of Plaintiff, Depositions of Third Party witnesses. We would expect that the Calif. DOJ would have it together and would have propounded discovery in a timely manner. Continuing to propound discovery – that all could have been done years ago – in a timely manner – is unnecessarily extending this case, and keeping it out of a trial setting mode. Plaintiff has responded to all of the multiple discovery requests made by Defendant, and as of the date of Plaintiff filing out this CMC statement, no objections have been raised to Plaintiff by Defendant. 1 Thomas Dimitre, Attorney at Law L.L.C. CSB # 276924 2 dimitre@mind.net 3 PO Box 801 Ashland, OR 97520 4 Telephone: 541-890-5022 Attorney for Plaintiff 5 6 STATE OF CALIFORNIA 7 COUNTY OF BUTTE 8 9 10 TERESA RANDOLPH, an individual Case No. 19CV01226 11 Plaintiff 12 CERTIFICATE OF SERVICE 13 v. 14 TRUSTEES OF THE CALIFORNIA STATE UNIVERSITY, STATE OF 15 CALIFORNIA, AND CYNTHIA DALEY, 16 AN INDIVIDUAL, AND DEBRA LARSON, AN INDIVIDUAL 17 Defendants 18 19 20 21 22 23 24 25 26 27 28 1 2 I, Thomas Dimitre, declare as follows: 3 I am an employee of Thomas Dimitre, Attorney at Law, over the age of eighteen 4 years and not a party to this action. My business address is PO BOX 801, Ashland, 5 Oregon 97520. My business telephone number is (541) 890-5022, and my fax number is 6 (541) 488-4601. 7 8 On March 12, 2024 I served the foregoing document(s) described as: 9 1. CMC Statement, by placing true copies thereof in sealed envelopes with 10 postage thereon fully prepaid, in the United States mail at ASHLAND, OR 11 addressed as shown below: 12 Jerry Deschler Jr. 13 Deputy Attorney General IV 14 1300 I Street Sacramento, CA 95814 15 16 I declare, under penalty of perjury under the a s of the State of California, that the foregoing is true and correct 17 Executed on March 12, 2024 18 19 TH 20 Attorney for Plaintiff, 21 Teresa Randolph 22 23 24 25 26 27 28 2