Party Discovery: Randolph, Teresa vs Trustees of the California State University et al

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                                5/26/2020



             1       Thomas Dimitre, Attorney at Law L.L.C.
                     CSB # 276924
             2       dimitre@mind.net
                     PO Box 801
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                     Ashland, OR 97520
             4       Telephone: 541-890-5022
                     Attorney for Plaintiff
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                                                             STATE OF CALIFORNIA
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             7                                                  COUNTY OF BUTTE

             8                                                     CIVIL DIVISION
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           11     TERESA RANDOLPH, an individual                           Case No. 19CV01226
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                        Plaintiff                                          [PROPOSED] ORDER
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                             v.
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                  TRUSTEES OF THE CALIFORNIA
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                  STATE UNIVERSITY, STATE OF
           16     CALIFORNIA, AND CYNTHIA DALEY,
                  AN INDIVIDUAL, AND DEBRA
           17     LARSON, AN INDIVIDUAL
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                        Defendants
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                           On September 9, 2019, Plaintiff, Teresa Randolph, filed a Motion to Compel Production
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                  of Documents in regards to her First Request for Production of Documents, from Defendants
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           25     State of California, Trustees of the California State University, Cynthia Daley and Debra Larson

           26     (collectively “Defendants”).
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             1             After multiple hearings and after considering the briefs of both parties on Plaintiff’s

             2    Motion to Compel Production of Documents – with appearances by Deputy Attorney General
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                  Jerry Deschler on behalf of Defendants Trustees of the California State University, State of
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                  California, Cynthia Daley and Debra Larson, and by Thomas Dimitre, on behalf of Plaintiff
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                  Teresa Randolph - Good Cause appearing, the Court rules as follows:
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             8    The Motion is GRANTED as to request nos. 81, 83, 84, and 86.
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                  The Motion is DENIED as to request nos. 33, 37, 63, 64, 67, 85 and 87.
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                  The parties’ requests for sanctions are DENIED.
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                  Supplemental/further responses are to be provided by Defendants within 20 days’ notice of the
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           13     Order.

           14     The Case Management Conference shall be set out to July 22, 2020 at 10:30 am.
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                  Case Management Conference Statements are to be timely filed and served.
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                  IT IS SO ORDERED
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           20     Dated:   _____________________               ______________________
                                                               Judge of the Superior Court
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                                                         CERTIFICATE OF SERVICE
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                           I, Thomas Dimitre, declare as follows:

             4             I am an employee of Thomas Dimitre, Attorney at Law, over the age of eighteen
             5    years and not a party to this action.          My business address is PO BOX 801, Ashland,
             6    Oregon 97520. My business telephone number is (541) 890-5022, and my fax number is
             7    (541) 488-4601.
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                           On May 24, 2020 I served the foregoing document(s) described as:
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                       1.   Proposed Order by placing true copies thereof in sealed envelopes with postage
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                           thereon fully prepaid, in the United States mail at ASHLAND, OR addressed as
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                           shown below:
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           13     Jerry Deschler Jr.
                  Deputy Attorney General IV
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                  1300 I Street
           15     Sacramento, CA 95814
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                           I declare, under penalty of perjury under the laws of the State of California, that
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                  the foregoing is true and correct.          Executed on May 24, 2020 at Ashland OR.
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                                                                        ___________________________
           20                                                           THOMAS DIMITRE
           21                                                           Attorney for Plaintiff,
                                                                        Teresa Randolph
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