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1 MARCIE ISOM FITZSHVIMONS
ANIBER A.EKLOF (SBN: 305750)
(SBN: 226906)
GORDON REES SCULLY MANSUKHANI, LLP
275 Battery Street, Suite 2000 I E w
COUNTY
-
San Francisco, CA 941 11 SAN MATFG
Telephone: (415) 875—4131 ,
— .1
2018
OCT
~
Facsimile: (415) 986—8054
misom@orsm.com '
.
u“
aeklof@gbrsm.com Upam'
mark
Attorneys for Defendant
TRUSTEES OF THE LELAND
By IW W
STANFORD JUNIOR UNIVERSITY, erroneously sued as
THE LELAND STANFORD JUNIOR UNIVERSITY
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN MATEO
94 ALI TAGHAVI, an individual, CASE NO. 17CIV04570
p—J
p-J
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Plaintiff,
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Suite vs. RESPONSE TO PLAINTIFF’S
= CA SUPPLEMENTAL BRIEF
g Street,
THE LELAND STANFORD JUNIOR SUPPORTING MOTION FOR
Z: UNIVERSITY, a California nonprofit PROTECTIVE ORDER
7:?
mo
Francisco,
corporation, doing business as STANFORD REGARDING DEPOSITION
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v Battery UNIVERSITY; ALTICOR, INC, a Michigan TRANSCRIPT OF ALI TAGHAVI
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corporation; and DOES 1-10, inclusive,
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Defendants. Date: October 9, 2018
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o Time: 9:00 AM
VVVVVVVVVVVVVVVVVVVVVVVV
Dept: Law and Motion
Trial Date: December 17, 201 8
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STANFORD’S RESPONSE TO PLAINTIFF’S SUPPLENIENTALzBfiliE'F ”SUPPORTING '
MOTION FOR PROTECTIVE ORDER '
I. Stanford’s Response t0 Plaintiff’s Basis for Confidentiality/Volume I
PLAINTIFF’S STANFORD’S OBJECTION
DESIGNATION
1, Work History This relates to Plaintiffs employment at Stanford, Which Plaintiff
16:1-20225 put at issue in his publically filed Complaint. Plaintiff’s Complaint
also addresses his employment at Stanford and he has waived any
right to privacy directly relevant to his claims. (Davis v. Super. Ct.
(1992) 7 Cal. App. 4th 1008, 1014-16.)
2, Marital; Medical No obj ection to this designation.
24:1-2426; 24:7—
26:23
\OOOVON
3, Work History; Plaintiff” semployment history is not private or subj ect to a
Employment confidential designation. Plaintiff publically lists his prior employers
Personnel and experience on LinkedIn, gave Stanford permission to contact his
27:10-30:22 prior employers, and has sent his resume containing as much to
dozens of employers. (Sirota v. Penske Truck Leasing Corp. (ND.
Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7)
10
4. Medical; Plaintiff s employment history is not private or subj ect to a
Employment confidential designation. Plaintiff publically lists his prior employers
11
LLP Personnel; Work and experience on Linkedln, gave Stanford permission to contact his
History prior employers, and has sent his resume containing as much to
12
2000
30:23:1—40223 dozens of employers. (Sirota v. Penske Truck Leasing Corp. (ND.
Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7)
94111
Mansuklmni,
Suite 13
5, Work History; This testimony is not about Plaintiff’s “employment history” as
CA
Employment characterized. It pertains to Plaintiffs feelings regarding his
14
Street,
Personnel separation from TOWn 0f Pofiola Valley, Which are not confidential
Scully
Francisco, 41:18-42:15 or private.
15
Battery
6, Work History Plaintiff s employment history is not private or subject to a
Rees
16 43:1-45:1 confidential designation. Plaintiff publically lists his prior employers
San and experience on LinkedIn, gave Stanford permission to contact his
275
prior employers, and has sent his resume containing as much to
Gordon
17
dozens of employers. (Sirota v. Penske Truck Leasing Corp. (ND.
18 Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7)
7. Work History; Plaintiff’s employment history is not private or subject to a
19 Employment confidential designation. Plaintiff publically lists his prior employers
Personnel and experience on Linkedln, gave Stanford permission to contact his
20 45:2-58:2 prior employers, and has sent his resume containing as much to
dozens of employers. (Sirota v. Penske Truck Leasing Corp. (N.D.
21 Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7)
8. Work History; This relates to Plaintiff s employment at Stanford, which Plaintiff
22 Employment put at issue in his publically filed Complaint. Plaintiff s Complaint
Personnel; also addresses his employment at Stanford and he has waived any
23 Financial right to privacy directly relevant to his claims. (Davis v. Super. Ct.
58:23-59z9; 60:9— (1992) 7 Cal. App. 4th 1008, 1014-16.)
24 64:2
9. Work History This relates to Plaintiff s employment at Stanford, Which Plaintiff
25 64:2-6723 put at issue in his publically filed Complaint. Plaintiff’s Complaint
also addresses his employment at Stanford and he has waived any
26 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
(1992) 7 Cal. App. 4th 1008, 1014-16.)
27 10, Work History This relates to Plaintiff s employment at Stanford, Which Plaintiff
67:4—70:4 put at issue in his publically filed Complaint. Plaintiff’s Complaint
28 also addresses his employment at Stanford and he has waived any
-1-
STANFORD’S RESPONSE TO PLAINTIFF’S SUPPLEMENTAL BRIEF SUPPORTING
MOTION FOR PROTECTIVE ORDER
PLAINTIFF’S STANFORD’S OBJECTION
DESIGNATION
right to privacy directly relevant t0 his claims. (Davis v. Super. Ct.
(1992) 7 Cal. App. 4th 1008, 1014-16.)
11. Work History; This relates to Plaintiffs employment at Stanford, which Plaintiff
Employment put at issue in his publically filed Complaint. Plaintiff‘s Complaint
Personnel also addresses his employment at Stanford and he has waived any
80:2-91 :25 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
(1992) 7 Cal. App. 4th 1008, 1014-16.)
12. Work History; This relates to Plaintiff’s employment at Stanford, which Plaintiff
Employment put at issue in his publically filed Complaint. Plaintiff’s Complaint
Personnel also addresses his employment at Stanford and he has waived any
92:21-104:1 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
\OOONQ
(1992) 7 Cal. App. 4th 1008, 1014-16.)
13. Work History; This relates to Plaintiffs employment at Stanford, which Plaintiff
‘
Employment put at issue in his publically filed Complaint. Plaintiffs Complaint
Personnel also addresses his employment at Stanford and he has waived any
10 10412-105 :2 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
(1992) 7 Cal. App. 4th 1008, 1014-16.)
11 14. Work History; This relates to Plaintiff s employment at Stanford, Which Plaintiff
LLP
Employment put at issue in his publically filed Complaint. Plaintiff s Complaint
12 Personnel also addresses his employment at Stanford and he has waived any
2000
94111
106:1-109:1 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
Mansukhani,
Suite 13 (1992) 7 Cal. App. 4th 1008, 1014—16.)
CA 15. Work History This relates t0 Plaintiff s employment at Stanford, Which Plaintiff
Street,
14 114:23—1 15 :13 put at issue in his publically filed Complaint. Plaintiffs Complaint
also addresses his employment at Stanford and he has waived any
Scully
Francisco,
15 right t0 privacy directly relevant to his claims. (Davis v. Super. Ct.
Battery (1992) 7 Cal. App. 4th 1008, 1014—16.)
Rees
San
16 16. Work History; This relates to Plaintiff’s employment at Stanford, Which Plaintiff
275
Employment put at issue in his publically filed Complaint. Plaintifs Complaint
Gordon
17 Personnel also addresses his employment at Stanford and he has waived any
119220—128z6 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
18 (1992) 7 Cal. App. 4th 1008, 1014-16.)
17. Work History; This relates to Plaintiff s employment at Stanford, which Plaintiff
19 Employment put at issue in his publically filed Complaint. Plaintiff’ s Complaint
Personnel also addresses his employment at Stanford and he has waived any
20 12827—147224 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
(1992) 7 Cal. App. 4th 1008, 1014-16.)
21 18. Work History; This relates to Plaintiffs employment at Stanford, Which Plaintiff
Employment put at issue in his publically filed Complaint. Plaintiffs Complaint
22 Personnel also addresses his employment at Stanford and he has waived any
148:1—160:15 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
23 (1992) 7 Cal. App. 4th 1008, 1014-16.)
19. Work History; This relates t0 Plaintiffs employment at Stanford, Which Plaintiff
24 Employment put at issue in his publically filed Complaint. Plaintiff s Complaint
Personnel also addresses his employment at Stanford and he has waived any
25 168:24—1 80:23 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
(1992) 7 Cal. App. 4th 1008, 1014—16.)
26 20, Work History; This relates t0 Plaintiff s employment at Stanford, Which Plaintiff
Employment put at issue in his publically filed Complaint. Plaintiff s Complaint
27 Personnel also addresses his employment at Stanford and he has waived any
180:24-1 83 :25 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
28 (1992) 7 Cal. App. 4th 1008, 1014—16.)
-2-
STANFORD’S RESPONSE TO PLAINTIFF’S SUPPLEMENTAL BRIEF SUPPORTING
MOTION FOR PROTECTIVE ORDER
PLAINTIFF’S STANFORD’S OBJECTION
DESIGNATION
21. Work History; This relates to Plaintiff s employment at Stanford, Which Plaintiff
Employment put at issue in his publically filed Complaint. Plaintiffs Complaint
Personnel also addresses his employment at Stanford and he has waived any
186:1-194:25 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
(1992) 7 Cal. App. 4th 1008, 1014-16.)
22, Work History; This relates t0 Plaintiff” s employment at Stanford, Which Plaintiff
Employment put at issue in his publically filed Complaint. Plaintiff s Complaint
Personnel also addresses his employment at Stanford and he has waived any
19821-20219 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
(1992) 7 Cal. App. 4th 1008, 1014-16.)
23. Work History; This relates to Plaintiff’s employment at Stanford, Which Plaintiff
\OOOVQ
Employment put at issue in his publically filed Complaint. Plaintiff s Complaint
Personnel also addresses his employment at Stanford and he has waived any
20426-21 1 :25 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
(1992) 7 Cal. App. 4th 1008, 1014-16.)
10
11 II. Stanford’s Response t0 Plaintiff’s Basis for Confidentiality/Volume II
LLP
12
2000
PLAINTIFF’S STANFORD’S OBJECTION
94111
DESIGNATION
Mansukhani,
Suite 13
CA 24. Work History; This relates to Plaintiffs employment at Stanford, Which Plaintiff
Street,
14 Employment put at issue in his publically filed Complaint. Plaintiff’s Complaint
Personnel also addresses his employment at Stanford and he has waived any
Scully
224: 14-236z4
Francisco,
15 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
Battery (1992) 7 Cal. App. 4th 1008, 1014-16.)
Further, Plaintiffs employment history is not private or subj ect to a
Rees
16
San
confidential designation. Plaintiff publically lists his prior employers
275
Gordon
17 and experience on LinkedIn, gave Stanford permission to contact his
prior employers, and has sent his resume containing as much to
18 dozens of employers. (Sirota v. Penske Truck Leasing Corp. (N.D.
Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7)
19 25. Work History; This relates to Plaintiff’s employment at Stanford, Which Plaintiff
Employment put at issue in his publically filed Complaint. Plaintiff’s Complaint
20 Personnel also addresses his employment at Stanford and he has waived any
238:1—248zl right to privacy directly relevant to his claims. (Davis v. Super. Ct.
21 (1992) 7 Cal. App. 4th 1008, 1014-16.)
26. Work History; This relates t0 Plaintiff’s employment at Stanford, which Plaintiff
22 Employment put at issue in his publically filed Complaint. Plaintiff s Complaint
Personnel also addresses his employment at Stanford and he has waived any
23 253 :1 1-255 :15 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
(1992) 7 Cal. App. 4th 1008, 1014-16.)
24 27, Work History; This relates to Plaintiff s employment at Stanford, Which Plaintiff
Employment put at issue in his publically filed Complaint. Plaintiff s Complaint
25 Personnel -
-
Valso addresses his employment at Stanfordr-and he has waived any
265:25-26823 right to privacy directly relevant to his claims. (Davis v. Super. Ct.
26 (1992) 7 Cal. App. 4th 1008, 1014—16.)
28. Work History; This relates to Plaintiffs employment at Stanford, Which Plaintiff
27 Employment put at issue in his publically filed Complaint. Plaintiff s Complaint
Personnel also addresses his employment at Stanford and he has waived any
28 27021-279223 right t0 privacy directly relevant to his claims. (Davis v. Super. Ct.
_3_
STANFORD’S RESPONSE TO PLAINTIFF’S SUPPLEMENTAL BRIEF SUPPORTlNG
MOTION FOR PROTECTIVE ORDER
PLAINTIFF’S STANFORD’S OBJECTION
DESIGNATION
(1992) 7 Cal. App. 4th 1008, 1014-16.)
29. Work History; This relates to Plaintiff s employment at Stanford, Which Plaintiff
Employment put at issue in his publically filed Complaint. Plaintiff s Complaint
Personnel; also addresses his employment at Stanford and he has waived any
Medical right t0 privacy directly relevant to his claims. (Davis v. Super. Ct.
330:1-352z22 (1992) 7 Cal. App. 4th 1008, 1014—16.)
No obj ection to Plaintiff’s designation regarding medical related
testimony.
30. Work History; Plaintiff” semployment history is not private or subj ect to a
Employment confidential designation. Plaintiff publically lists his prior employers
\DOOQQ
Personnel and experience on LinkedIn, gave Stanford permission t0 contact his
35325-36825 prior employers, and has sent his resume containing as much to
dozens of employers. (Sirota v. Penske Truck Leasing Corp. (ND.
Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7)
10 3 1. Work History; Plaintiff s employment history is not private or subject t0 a
Employment confidential designation. Plaintiff publically lists his prior employers
11 Personnel and experience on Linkedln, gave Stanford permission to contact his
LLP 369:1—3 94:25 prior employers, and has sent his resume containing as much to
12 dozens 0f employers. (Sirota v. Penske Truck Leasing Corp. (ND.
2000
Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7)
94111
Mansukhnni,
Suite 13 32. Work History; Plaintiff s employment history is not private or subj ect t0 a
Employment confidential designation. Plaintiff publically lists his prior employers
CA
14 Personnel; and experience on Linkedln, gave Stanford permission to contact his
sent his resume containing as much t0
Street,
405:1—446zl7 prior employers, and has
Scully
Francisco,
15 dozens 0f employers. (Sirota v. Penske Truck Leasing Corp. (N.D.
Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7).
Battery
Rees
16
San
275
III. Stanford’s Response t0 Plaintiff’s Basis for Confidentiality/Volume III
Gordon
17
18
PLAINTIFF’S STANFORD’S OBJECTION
19 DESIGNATION
33, Work History; Plaintifi’ s employment history is not private or subj ect to a
20 Financial; confidential designation. Plaintiffpublically lists his prior employers
Employment and experience on LinkedIn, gave Stanford permission to contact his
21 Personnel prior employers, and has sent his resume containing as much to
547:23-565:12 dozens of employers. (Strata v. Penske Truck Leasing Corp. (ND.
22 Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7).
23
IV. Stanford’s Response t0 Plaintiff’s Basis for Confidentiality/Deposition Exhibits
24
25 EX. PLAINTIFF’S STANFORD’S OBJECTION
DESIGNATION
26
1-13 Work History; Plaintiff waived privacy and confidentiality in matters directly
Employment relevant to the lawsuit. (Davis v. Super. Ct. (1992) 7 Cal.App.4th
27
Personnel 1008, 1014-16.)
17 Work History Plaintiff publically lists his prior employers and experience on
28
LinkedIn and has sent his resume containing as much to dozens of
_4_
STANFORD’S RESPONSE TO PLAINTIFF’S SUPPLEMENTAL BRIEF SUPPORTING
MOTION FOR PROTECTIVE ORDER
EX. PLAINTIFF’ S STANFORD’S OBJECTION
DESIGNATION
employers. (Sirota v. Penske Truck Leasing Corp. (ND. Cal. March
16, 2006) 2006 U.S. Dist. LEXIS 15763, *7)
18 Employment Plaintiff redacted these records — a confidential designation is
Personnel unnecessary.
19 Privacy Plaintiff publically lists his prior employers and experience on
LinkedIn and has sent his resume containing as much to dozens of
employers. (Sirota v. Penske Truck Leasing Corp. (N.D. Cal. March
16, 2006) 2006 U.S. Dist. LEXIS 15763, *7)
20-21 Work History Plaintiff redacted these records —a confidential designation is
unnecessary.
\OOOQQ
27-28 Employment No objection.
Personnel
Dated: September 27, 2018 GORDON REES SCULLY MANSUKHANI,
WWW
10
11
LLP
12
2000
MARCIE ISOM FITZSIMMONS
94111
Mansukhani,
Suite 13 AMBER A. EKLOF
CA
TRUSTEES OF THE LELAND
14 STANFORD JUNIOR UNIVERSITY,
erroneously sued as TEE LELAND
Street,
Scully
Francisco,
15 STANFORD JUNIOR UNIVERSITY
Battery
Rees
16
San
275
Gordon
17
18
19
20
21
22
23
24
25.
26
27
28
-5-
STANFORD’S RESPONSE TO PLAINTIFF’S SUPPLEMENTAL BRIEF SUPPORTING
MOTION FOR PROTECTIVE ORDER
PROOF OF SERVICE
Ali Taghavi v. The Leland Stanford University
San Mateo Superior Court Case N0. I 7CIV045 70
I am a resident of the State of California, over the age of eighteen years, and not a party
to the within action. My business address is: Gordon Rees Scully Mansukhani, LLP 275 Battery
Street, Suite 2000, San Francisco, CA 941 1 1. On the date below, I served the within documents:
RESPONSE TO PLAINTIFF’S SUPPLEMENTAL BRIEF SUPPORTING MOTION FOR
PROTECTIVE ORDER REGARDING DEPOSITION TRANSCRIPT OF ALI TAGHAVI
OOVONUl-P
l Via Electronic Transmission: By transmitting Via
above to the e—mail address(es) set forth below.
electronic mail the document(s) listed
\O
Fredrick A. Hagen
BERDING & WEIL LLP
2175 N. California Blvd, Suite 500
10
Walnut Creek, California 94596
Telephone: 925-838-2090
11
LLI’ Facsimile: 925—820—5592
fllagen@berdingweil.com
2000
12
94111
Plaintiff’s Counsel
Mansukhani,
Suite 13
CA
David P. Zins Karen J. Kubin
14
Street,
Morrison & Foerster LLP Morrison & Foerster LLP
Scully
Francisco,
707 Wilshire Blvd., Suite 6000 425 Market Street
15
Los Angeles, CA 94105 San Francisco, CA 94105
Battery
Rees
Telephone: 213—892-5200 Telephone: 415-268-7000
16
San Facsimile: 213-892—5454 Facsimile: 415—268-7522
275 dzins@mofo.com 1d
Preview
w \J ~ 1 MARCIE ISOM FITZSHVIMONS ANIBER A.EKLOF (SBN: 305750) (SBN: 226906) GORDON REES SCULLY MANSUKHANI, LLP 275 Battery Street, Suite 2000 I E w COUNTY - San Francisco, CA 941 11 SAN MATFG Telephone: (415) 875—4131 , — .1 2018 OCT ~ Facsimile: (415) 986—8054 misom@orsm.com ' . u“ aeklof@gbrsm.com Upam' mark Attorneys for Defendant TRUSTEES OF THE LELAND By IW W STANFORD JUNIOR UNIVERSITY, erroneously sued as THE LELAND STANFORD JUNIOR UNIVERSITY SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN MATEO 94 ALI TAGHAVI, an individual, CASE NO. 17CIV04570 p—J p-J 'E 2000 Plaintiff, G .3: 94111 .2 = w Suite vs. RESPONSE TO PLAINTIFF’S = CA SUPPLEMENTAL BRIEF g Street, THE LELAND STANFORD JUNIOR SUPPORTING MOTION FOR Z: UNIVERSITY, a California nonprofit PROTECTIVE ORDER 7:? mo Francisco, corporation, doing business as STANFORD REGARDING DEPOSITION w v Battery UNIVERSITY; ALTICOR, INC, a Michigan TRANSCRIPT OF ALI TAGHAVI m G3 San corporation; and DOES 1-10, inclusive, E o ”U 275 l- Defendants. Date: October 9, 2018 O o Time: 9:00 AM VVVVVVVVVVVVVVVVVVVVVVVV Dept: Law and Motion Trial Date: December 17, 201 8 ”1 ‘ “ 7~ cw‘ ~ "‘ x ~‘ \\_\ ‘K / 0457a MPAR Memora "du'" ,' 0' Paints 1414795 an d Authorities inRepl ;\.///_/\///_//////l/////l//////[///////////// STANFORD’S RESPONSE TO PLAINTIFF’S SUPPLENIENTALzBfiliE'F ”SUPPORTING ' MOTION FOR PROTECTIVE ORDER ' I. Stanford’s Response t0 Plaintiff’s Basis for Confidentiality/Volume I PLAINTIFF’S STANFORD’S OBJECTION DESIGNATION 1, Work History This relates to Plaintiffs employment at Stanford, Which Plaintiff 16:1-20225 put at issue in his publically filed Complaint. Plaintiff’s Complaint also addresses his employment at Stanford and he has waived any right to privacy directly relevant to his claims. (Davis v. Super. Ct. (1992) 7 Cal. App. 4th 1008, 1014-16.) 2, Marital; Medical No obj ection to this designation. 24:1-2426; 24:7— 26:23 \OOOVON 3, Work History; Plaintiff” semployment history is not private or subj ect to a Employment confidential designation. Plaintiff publically lists his prior employers Personnel and experience on LinkedIn, gave Stanford permission to contact his 27:10-30:22 prior employers, and has sent his resume containing as much to dozens of employers. (Sirota v. Penske Truck Leasing Corp. (ND. Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7) 10 4. Medical; Plaintiff s employment history is not private or subj ect to a Employment confidential designation. Plaintiff publically lists his prior employers 11 LLP Personnel; Work and experience on Linkedln, gave Stanford permission to contact his History prior employers, and has sent his resume containing as much to 12 2000 30:23:1—40223 dozens of employers. (Sirota v. Penske Truck Leasing Corp. (ND. Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7) 94111 Mansuklmni, Suite 13 5, Work History; This testimony is not about Plaintiff’s “employment history” as CA Employment characterized. It pertains to Plaintiffs feelings regarding his 14 Street, Personnel separation from TOWn 0f Pofiola Valley, Which are not confidential Scully Francisco, 41:18-42:15 or private. 15 Battery 6, Work History Plaintiff s employment history is not private or subject to a Rees 16 43:1-45:1 confidential designation. Plaintiff publically lists his prior employers San and experience on LinkedIn, gave Stanford permission to contact his 275 prior employers, and has sent his resume containing as much to Gordon 17 dozens of employers. (Sirota v. Penske Truck Leasing Corp. (ND. 18 Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7) 7. Work History; Plaintiff’s employment history is not private or subject to a 19 Employment confidential designation. Plaintiff publically lists his prior employers Personnel and experience on Linkedln, gave Stanford permission to contact his 20 45:2-58:2 prior employers, and has sent his resume containing as much to dozens of employers. (Sirota v. Penske Truck Leasing Corp. (N.D. 21 Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7) 8. Work History; This relates to Plaintiff s employment at Stanford, which Plaintiff 22 Employment put at issue in his publically filed Complaint. Plaintiff s Complaint Personnel; also addresses his employment at Stanford and he has waived any 23 Financial right to privacy directly relevant to his claims. (Davis v. Super. Ct. 58:23-59z9; 60:9— (1992) 7 Cal. App. 4th 1008, 1014-16.) 24 64:2 9. Work History This relates to Plaintiff s employment at Stanford, Which Plaintiff 25 64:2-6723 put at issue in his publically filed Complaint. Plaintiff’s Complaint also addresses his employment at Stanford and he has waived any 26 right to privacy directly relevant to his claims. (Davis v. Super. Ct. (1992) 7 Cal. App. 4th 1008, 1014-16.) 27 10, Work History This relates to Plaintiff s employment at Stanford, Which Plaintiff 67:4—70:4 put at issue in his publically filed Complaint. Plaintiff’s Complaint 28 also addresses his employment at Stanford and he has waived any -1- STANFORD’S RESPONSE TO PLAINTIFF’S SUPPLEMENTAL BRIEF SUPPORTING MOTION FOR PROTECTIVE ORDER PLAINTIFF’S STANFORD’S OBJECTION DESIGNATION right to privacy directly relevant t0 his claims. (Davis v. Super. Ct. (1992) 7 Cal. App. 4th 1008, 1014-16.) 11. Work History; This relates to Plaintiffs employment at Stanford, which Plaintiff Employment put at issue in his publically filed Complaint. Plaintiff‘s Complaint Personnel also addresses his employment at Stanford and he has waived any 80:2-91 :25 right to privacy directly relevant to his claims. (Davis v. Super. Ct. (1992) 7 Cal. App. 4th 1008, 1014-16.) 12. Work History; This relates to Plaintiff’s employment at Stanford, which Plaintiff Employment put at issue in his publically filed Complaint. Plaintiff’s Complaint Personnel also addresses his employment at Stanford and he has waived any 92:21-104:1 right to privacy directly relevant to his claims. (Davis v. Super. Ct. \OOONQ (1992) 7 Cal. App. 4th 1008, 1014-16.) 13. Work History; This relates to Plaintiffs employment at Stanford, which Plaintiff ‘ Employment put at issue in his publically filed Complaint. Plaintiffs Complaint Personnel also addresses his employment at Stanford and he has waived any 10 10412-105 :2 right to privacy directly relevant to his claims. (Davis v. Super. Ct. (1992) 7 Cal. App. 4th 1008, 1014-16.) 11 14. Work History; This relates to Plaintiff s employment at Stanford, Which Plaintiff LLP Employment put at issue in his publically filed Complaint. Plaintiff s Complaint 12 Personnel also addresses his employment at Stanford and he has waived any 2000 94111 106:1-109:1 right to privacy directly relevant to his claims. (Davis v. Super. Ct. Mansukhani, Suite 13 (1992) 7 Cal. App. 4th 1008, 1014—16.) CA 15. Work History This relates t0 Plaintiff s employment at Stanford, Which Plaintiff Street, 14 114:23—1 15 :13 put at issue in his publically filed Complaint. Plaintiffs Complaint also addresses his employment at Stanford and he has waived any Scully Francisco, 15 right t0 privacy directly relevant to his claims. (Davis v. Super. Ct. Battery (1992) 7 Cal. App. 4th 1008, 1014—16.) Rees San 16 16. Work History; This relates to Plaintiff’s employment at Stanford, Which Plaintiff 275 Employment put at issue in his publically filed Complaint. Plaintifs Complaint Gordon 17 Personnel also addresses his employment at Stanford and he has waived any 119220—128z6 right to privacy directly relevant to his claims. (Davis v. Super. Ct. 18 (1992) 7 Cal. App. 4th 1008, 1014-16.) 17. Work History; This relates to Plaintiff s employment at Stanford, which Plaintiff 19 Employment put at issue in his publically filed Complaint. Plaintiff’ s Complaint Personnel also addresses his employment at Stanford and he has waived any 20 12827—147224 right to privacy directly relevant to his claims. (Davis v. Super. Ct. (1992) 7 Cal. App. 4th 1008, 1014-16.) 21 18. Work History; This relates to Plaintiffs employment at Stanford, Which Plaintiff Employment put at issue in his publically filed Complaint. Plaintiffs Complaint 22 Personnel also addresses his employment at Stanford and he has waived any 148:1—160:15 right to privacy directly relevant to his claims. (Davis v. Super. Ct. 23 (1992) 7 Cal. App. 4th 1008, 1014-16.) 19. Work History; This relates t0 Plaintiffs employment at Stanford, Which Plaintiff 24 Employment put at issue in his publically filed Complaint. Plaintiff s Complaint Personnel also addresses his employment at Stanford and he has waived any 25 168:24—1 80:23 right to privacy directly relevant to his claims. (Davis v. Super. Ct. (1992) 7 Cal. App. 4th 1008, 1014—16.) 26 20, Work History; This relates t0 Plaintiff s employment at Stanford, Which Plaintiff Employment put at issue in his publically filed Complaint. Plaintiff s Complaint 27 Personnel also addresses his employment at Stanford and he has waived any 180:24-1 83 :25 right to privacy directly relevant to his claims. (Davis v. Super. Ct. 28 (1992) 7 Cal. App. 4th 1008, 1014—16.) -2- STANFORD’S RESPONSE TO PLAINTIFF’S SUPPLEMENTAL BRIEF SUPPORTING MOTION FOR PROTECTIVE ORDER PLAINTIFF’S STANFORD’S OBJECTION DESIGNATION 21. Work History; This relates to Plaintiff s employment at Stanford, Which Plaintiff Employment put at issue in his publically filed Complaint. Plaintiffs Complaint Personnel also addresses his employment at Stanford and he has waived any 186:1-194:25 right to privacy directly relevant to his claims. (Davis v. Super. Ct. (1992) 7 Cal. App. 4th 1008, 1014-16.) 22, Work History; This relates t0 Plaintiff” s employment at Stanford, Which Plaintiff Employment put at issue in his publically filed Complaint. Plaintiff s Complaint Personnel also addresses his employment at Stanford and he has waived any 19821-20219 right to privacy directly relevant to his claims. (Davis v. Super. Ct. (1992) 7 Cal. App. 4th 1008, 1014-16.) 23. Work History; This relates to Plaintiff’s employment at Stanford, Which Plaintiff \OOOVQ Employment put at issue in his publically filed Complaint. Plaintiff s Complaint Personnel also addresses his employment at Stanford and he has waived any 20426-21 1 :25 right to privacy directly relevant to his claims. (Davis v. Super. Ct. (1992) 7 Cal. App. 4th 1008, 1014-16.) 10 11 II. Stanford’s Response t0 Plaintiff’s Basis for Confidentiality/Volume II LLP 12 2000 PLAINTIFF’S STANFORD’S OBJECTION 94111 DESIGNATION Mansukhani, Suite 13 CA 24. Work History; This relates to Plaintiffs employment at Stanford, Which Plaintiff Street, 14 Employment put at issue in his publically filed Complaint. Plaintiff’s Complaint Personnel also addresses his employment at Stanford and he has waived any Scully 224: 14-236z4 Francisco, 15 right to privacy directly relevant to his claims. (Davis v. Super. Ct. Battery (1992) 7 Cal. App. 4th 1008, 1014-16.) Further, Plaintiffs employment history is not private or subj ect to a Rees 16 San confidential designation. Plaintiff publically lists his prior employers 275 Gordon 17 and experience on LinkedIn, gave Stanford permission to contact his prior employers, and has sent his resume containing as much to 18 dozens of employers. (Sirota v. Penske Truck Leasing Corp. (N.D. Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7) 19 25. Work History; This relates to Plaintiff’s employment at Stanford, Which Plaintiff Employment put at issue in his publically filed Complaint. Plaintiff’s Complaint 20 Personnel also addresses his employment at Stanford and he has waived any 238:1—248zl right to privacy directly relevant to his claims. (Davis v. Super. Ct. 21 (1992) 7 Cal. App. 4th 1008, 1014-16.) 26. Work History; This relates t0 Plaintiff’s employment at Stanford, which Plaintiff 22 Employment put at issue in his publically filed Complaint. Plaintiff s Complaint Personnel also addresses his employment at Stanford and he has waived any 23 253 :1 1-255 :15 right to privacy directly relevant to his claims. (Davis v. Super. Ct. (1992) 7 Cal. App. 4th 1008, 1014-16.) 24 27, Work History; This relates to Plaintiff s employment at Stanford, Which Plaintiff Employment put at issue in his publically filed Complaint. Plaintiff s Complaint 25 Personnel - - Valso addresses his employment at Stanfordr-and he has waived any 265:25-26823 right to privacy directly relevant to his claims. (Davis v. Super. Ct. 26 (1992) 7 Cal. App. 4th 1008, 1014—16.) 28. Work History; This relates to Plaintiffs employment at Stanford, Which Plaintiff 27 Employment put at issue in his publically filed Complaint. Plaintiff s Complaint Personnel also addresses his employment at Stanford and he has waived any 28 27021-279223 right t0 privacy directly relevant to his claims. (Davis v. Super. Ct. _3_ STANFORD’S RESPONSE TO PLAINTIFF’S SUPPLEMENTAL BRIEF SUPPORTlNG MOTION FOR PROTECTIVE ORDER PLAINTIFF’S STANFORD’S OBJECTION DESIGNATION (1992) 7 Cal. App. 4th 1008, 1014-16.) 29. Work History; This relates to Plaintiff s employment at Stanford, Which Plaintiff Employment put at issue in his publically filed Complaint. Plaintiff s Complaint Personnel; also addresses his employment at Stanford and he has waived any Medical right t0 privacy directly relevant to his claims. (Davis v. Super. Ct. 330:1-352z22 (1992) 7 Cal. App. 4th 1008, 1014—16.) No obj ection to Plaintiff’s designation regarding medical related testimony. 30. Work History; Plaintiff” semployment history is not private or subj ect to a Employment confidential designation. Plaintiff publically lists his prior employers \DOOQQ Personnel and experience on LinkedIn, gave Stanford permission t0 contact his 35325-36825 prior employers, and has sent his resume containing as much to dozens of employers. (Sirota v. Penske Truck Leasing Corp. (ND. Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7) 10 3 1. Work History; Plaintiff s employment history is not private or subject t0 a Employment confidential designation. Plaintiff publically lists his prior employers 11 Personnel and experience on Linkedln, gave Stanford permission to contact his LLP 369:1—3 94:25 prior employers, and has sent his resume containing as much to 12 dozens 0f employers. (Sirota v. Penske Truck Leasing Corp. (ND. 2000 Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7) 94111 Mansukhnni, Suite 13 32. Work History; Plaintiff s employment history is not private or subj ect t0 a Employment confidential designation. Plaintiff publically lists his prior employers CA 14 Personnel; and experience on Linkedln, gave Stanford permission to contact his sent his resume containing as much t0 Street, 405:1—446zl7 prior employers, and has Scully Francisco, 15 dozens 0f employers. (Sirota v. Penske Truck Leasing Corp. (N.D. Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7). Battery Rees 16 San 275 III. Stanford’s Response t0 Plaintiff’s Basis for Confidentiality/Volume III Gordon 17 18 PLAINTIFF’S STANFORD’S OBJECTION 19 DESIGNATION 33, Work History; Plaintifi’ s employment history is not private or subj ect to a 20 Financial; confidential designation. Plaintiffpublically lists his prior employers Employment and experience on LinkedIn, gave Stanford permission to contact his 21 Personnel prior employers, and has sent his resume containing as much to 547:23-565:12 dozens of employers. (Strata v. Penske Truck Leasing Corp. (ND. 22 Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7). 23 IV. Stanford’s Response t0 Plaintiff’s Basis for Confidentiality/Deposition Exhibits 24 25 EX. PLAINTIFF’S STANFORD’S OBJECTION DESIGNATION 26 1-13 Work History; Plaintiff waived privacy and confidentiality in matters directly Employment relevant to the lawsuit. (Davis v. Super. Ct. (1992) 7 Cal.App.4th 27 Personnel 1008, 1014-16.) 17 Work History Plaintiff publically lists his prior employers and experience on 28 LinkedIn and has sent his resume containing as much to dozens of _4_ STANFORD’S RESPONSE TO PLAINTIFF’S SUPPLEMENTAL BRIEF SUPPORTING MOTION FOR PROTECTIVE ORDER EX. PLAINTIFF’ S STANFORD’S OBJECTION DESIGNATION employers. (Sirota v. Penske Truck Leasing Corp. (ND. Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7) 18 Employment Plaintiff redacted these records — a confidential designation is Personnel unnecessary. 19 Privacy Plaintiff publically lists his prior employers and experience on LinkedIn and has sent his resume containing as much to dozens of employers. (Sirota v. Penske Truck Leasing Corp. (N.D. Cal. March 16, 2006) 2006 U.S. Dist. LEXIS 15763, *7) 20-21 Work History Plaintiff redacted these records —a confidential designation is unnecessary. \OOOQQ 27-28 Employment No objection. Personnel Dated: September 27, 2018 GORDON REES SCULLY MANSUKHANI, WWW 10 11 LLP 12 2000 MARCIE ISOM FITZSIMMONS 94111 Mansukhani, Suite 13 AMBER A. EKLOF CA TRUSTEES OF THE LELAND 14 STANFORD JUNIOR UNIVERSITY, erroneously sued as TEE LELAND Street, Scully Francisco, 15 STANFORD JUNIOR UNIVERSITY Battery Rees 16 San 275 Gordon 17 18 19 20 21 22 23 24 25. 26 27 28 -5- STANFORD’S RESPONSE TO PLAINTIFF’S SUPPLEMENTAL BRIEF SUPPORTING MOTION FOR PROTECTIVE ORDER PROOF OF SERVICE Ali Taghavi v. The Leland Stanford University San Mateo Superior Court Case N0. I 7CIV045 70 I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is: Gordon Rees Scully Mansukhani, LLP 275 Battery Street, Suite 2000, San Francisco, CA 941 1 1. On the date below, I served the within documents: RESPONSE TO PLAINTIFF’S SUPPLEMENTAL BRIEF SUPPORTING MOTION FOR PROTECTIVE ORDER REGARDING DEPOSITION TRANSCRIPT OF ALI TAGHAVI OOVONUl-P l Via Electronic Transmission: By transmitting Via above to the e—mail address(es) set forth below. electronic mail the document(s) listed \O Fredrick A. Hagen BERDING & WEIL LLP 2175 N. California Blvd, Suite 500 10 Walnut Creek, California 94596 Telephone: 925-838-2090 11 LLI’ Facsimile: 925—820—5592 fllagen@berdingweil.com 2000 12 94111 Plaintiff’s Counsel Mansukhani, Suite 13 CA David P. Zins Karen J. Kubin 14 Street, Morrison & Foerster LLP Morrison & Foerster LLP Scully Francisco, 707 Wilshire Blvd., Suite 6000 425 Market Street 15 Los Angeles, CA 94105 San Francisco, CA 94105 Battery Rees Telephone: 213—892-5200 Telephone: 415-268-7000 16 San Facsimile: 213-892—5454 Facsimile: 415—268-7522 275 dzins@mofo.com 1d