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MARCIEISOM FITZSIMMONS (SBN: 226906)
W" AMBER A.EKL0F (SBN: 305750)
2 GORDON REES
275 Battery
SCULLY MANSUKHANI, LLP
Suite 2000
I E1 E DNTY
3
Street,
San Francisco, CA 941 11 SAN MATEO CCU
875-4131
b
Telephone: (415) .
OCT 2 4 2018
4 Facsimile; (415) 986—8054
misom@grsm.com
mews
’
penor Court
5 aeklof@grsm.com
By
6 Attorneys for Defendant
MEPUW CLERK
TRUSTEES OF THE LELAND
7 STANFORD JUNIOR UNIVERSITY, erroneously sued as
THE LELAND STANFORD JUNIOR UNIVERSITY
8
9 SUPERIOR COURT OF CALIFORNM
10 COUNTY OF SAN MATEO
11 ALI TAGHAVI, an individual, ) CASE NO. 17CIV0457O
S
A )
2%.“ 12 Plaintiff,
)
DECLARATION OF AMBER EKLOF
2:: IN SUPPORT OF DEFENDANT
)
"Egg 13 vs. STANFORD’S OPPOSITION TO
)
Eras PLAINTIFF’S EX PARTE
EEO“ 14 THE LELAND STANFORD JUNIOR )
APPLICATION TO CONTINUE
53:3, UNIVERSITY, a California nonprofit )
TRIAL AND ALL SCHEDUELD
53.2 15 corporation, doing business as STANFORD ) HEARINGS
0);: UNIVERSITY; ALTICOR, INCL, a Michigan )
16 corporation; and DOES 1—10, inclusive,
:pw g
§~ 17 Defendants. )
O
U
18 A——-
7&3
- fl ’ '"F"\ )
)
Date: October 24, 2018
g;““’*° Time; 2:00 PM
)
19 Declaration in Support Dept: Presiding Law and Motion
l
)
1457728
L
)
20 *
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N\\|\IN“\\\\\\|\|\|\\\\l\\\W\\\\\ -'
21 _ , . . )
)
22
Amber A. Eklof, declare as follows:
mm
I,
23
24 1. I am an attorney at law licensed to practice before all courts 0f the State 0f
25 California and am an Associate in the law firm 0f Gordon Rees Scully Mansukhani, LLP,
m
a 26
27
attorneys for Defendant Trustees of the Leland Stanford Junior University (“Stanford”). Ihave
gé 28
-1-
DECLARATION OF AMBER EKLOF IN SUPPORT OF DEFENDANT STANFORD’S OPPOSITION TO
PLANTIFF ’S EX PARTE APPLICATION TO CONTINUE TRIAL AND ALL SCHEDUELD HEARINGS
personal knowledge 0f the matters contained in this declaration and if called to testify to them
could and would do so competently.
2. Plaintiff” Ali Taghavi (“Plaintiff”) filed a lawsuit in San Mateo County Superior
Court 0n October 4, 2017 19, 2016. On February 9, 2018 Plaintiff filed a First Amended
Complaint (“PAC”) alleging the following causes 0f action: (1) wrongful termination based on
age, race, national origin and religious discrimination in Violation of the Fair Employment and
OOVON
Housing Act (“FEHA”) against Stanford; (2) wrongful termination in Violation of the Federal
Food, Drug, and Cosmetic Act (“FFDCA”) against Stanford; and (3) intentional interference
\O With prospective economic advantage against Defendant Alticor, Inc.
10 3. Plaintiff mail served Requests for Production of Documents Set One and Form
11 Interrogatories — Employment Law on May 24, 201 8.
LLP
2000
12 4. Defendants have collectively produced more than 22,000 pages of documents in
94111
13 this case already.
Mansukhani,
Suite
CA
14 5. ‘
Plaintiff was deposed over a three-day period on July 30, 2018, July 31, 2018 and
Street,
Scully
Francisco,
15 August 8,201 8. My Partner, Marcie Isom Fitzsimmons took Plaintiff s deposition on July 30,
Battery
Rees
16 201 8, July 3 1, 201 8. Alticor’s counsel eXamined Plaintiff during a portion of the time on July 31
San
275
Gordon
17 and August 8,201 8.
'
18 6. Plaintiff mail served a Notice of Deposition for John Ioannidis on June 22, 201 8,
19 with a deposition date of July 17, 201 8. The deposition was moved. On July 18, 2018, Plaintiff
20 mail served an Amended Notice of Deposition for John Ioannidis With a deposition date of
21 August 21, 2018.
22 7. Plaintiff canceled the deposition of John Ioannidis on August 15, 2018 and mail
23 served an amended notice of deposition for September 18, 201 8.
24 8. On September 17, 2018, Plaintiff once again canceled the deposition 0f John
25 Ioannidis and mail served an amended notice 0f deposition for November 12, 201 8.
26 9. On September 17, 201 8, Plaintiff s counsel, Fred Hagen, requested deposition
27 dates for Dr. Sandra Winter. I responded the next day with Dr. Winter’s availability. That same
28
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DECLARATION OF AMBER EKLOF IN SUPPORT OF DEFENDANT STANFORD’S OPPOSITION TO
PLAINTIFF’S EX PARTE APPLICATION TO CONTNUE TRIAL AND ALL SCHEDUELD HEARINGS
day, Mr. Hagen requested dates for six witnesses. Isent Mr. Hagen an email response 0n
September 19, 2018, providing dates for four of the witnesses and indicating Ihad reached out to
the two remaining witnesses for dates.
10. On October 11, 201 8, Plaintiff filed a Motion to Compel against Stanford, despite
Stanford’s Willingness to continue to meet and confer on discovery and to conduct a search for
any additional documents With proposed search parameters. Plaintiff declined Stanford’s offer
and refused t0 provide any alternatives to Stanford’s efforts.
KOOOQON
11. On September 21 ,2018, Plaintiff filed a similar Motion t0 Compel against Alticor
Inc. On October 23, 201 8, this court denied Plaintiff s motion in itsentirety.
10 I declare under penalty of perjury under the laws 0f the State of California that the
11 foregoing is true and correct.
LLP
2000
12 Executed this 24th day 0f October 2018 at San Francisco, California.
94111
13
flp/M
Mahsukhani,
Suite
CA
Street,
14
Scully
Francisco,
15 Amber A. Eklof
Battery
Rees
16
San
275
Gordon
17
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DECLARATION OF AMBER EKLOF m SUPPORT OF DEFENDANT STANFORD’S OPPOSITION TO
PLANTIFF’S EX PARTE APPLICATION TO CONTINUE TRIAL AND ALL SCHEDUELD HEARINGS
Preview
MARCIEISOM FITZSIMMONS (SBN: 226906) W" AMBER A.EKL0F (SBN: 305750) 2 GORDON REES 275 Battery SCULLY MANSUKHANI, LLP Suite 2000 I E1 E DNTY 3 Street, San Francisco, CA 941 11 SAN MATEO CCU 875-4131 b Telephone: (415) . OCT 2 4 2018 4 Facsimile; (415) 986—8054 misom@grsm.com mews ’ penor Court 5 aeklof@grsm.com By 6 Attorneys for Defendant MEPUW CLERK TRUSTEES OF THE LELAND 7 STANFORD JUNIOR UNIVERSITY, erroneously sued as THE LELAND STANFORD JUNIOR UNIVERSITY 8 9 SUPERIOR COURT OF CALIFORNM 10 COUNTY OF SAN MATEO 11 ALI TAGHAVI, an individual, ) CASE NO. 17CIV0457O S A ) 2%.“ 12 Plaintiff, ) DECLARATION OF AMBER EKLOF 2:: IN SUPPORT OF DEFENDANT ) "Egg 13 vs. STANFORD’S OPPOSITION TO ) Eras PLAINTIFF’S EX PARTE EEO“ 14 THE LELAND STANFORD JUNIOR ) APPLICATION TO CONTINUE 53:3, UNIVERSITY, a California nonprofit ) TRIAL AND ALL SCHEDUELD 53.2 15 corporation, doing business as STANFORD ) HEARINGS 0);: UNIVERSITY; ALTICOR, INCL, a Michigan ) 16 corporation; and DOES 1—10, inclusive, :pw g §~ 17 Defendants. ) O U 18 A——- 7&3 - fl ’ '"F"\ ) ) Date: October 24, 2018 g;““’*° Time; 2:00 PM ) 19 Declaration in Support Dept: Presiding Law and Motion l ) 1457728 L ) 20 * > N\\|\IN“\\\\\\|\|\|\\\\l\\\W\\\\\ -' 21 _ , . . ) ) 22 Amber A. Eklof, declare as follows: mm I, 23 24 1. I am an attorney at law licensed to practice before all courts 0f the State 0f 25 California and am an Associate in the law firm 0f Gordon Rees Scully Mansukhani, LLP, m a 26 27 attorneys for Defendant Trustees of the Leland Stanford Junior University (“Stanford”). Ihave gé 28 -1- DECLARATION OF AMBER EKLOF IN SUPPORT OF DEFENDANT STANFORD’S OPPOSITION TO PLANTIFF ’S EX PARTE APPLICATION TO CONTINUE TRIAL AND ALL SCHEDUELD HEARINGS personal knowledge 0f the matters contained in this declaration and if called to testify to them could and would do so competently. 2. Plaintiff” Ali Taghavi (“Plaintiff”) filed a lawsuit in San Mateo County Superior Court 0n October 4, 2017 19, 2016. On February 9, 2018 Plaintiff filed a First Amended Complaint (“PAC”) alleging the following causes 0f action: (1) wrongful termination based on age, race, national origin and religious discrimination in Violation of the Fair Employment and OOVON Housing Act (“FEHA”) against Stanford; (2) wrongful termination in Violation of the Federal Food, Drug, and Cosmetic Act (“FFDCA”) against Stanford; and (3) intentional interference \O With prospective economic advantage against Defendant Alticor, Inc. 10 3. Plaintiff mail served Requests for Production of Documents Set One and Form 11 Interrogatories — Employment Law on May 24, 201 8. LLP 2000 12 4. Defendants have collectively produced more than 22,000 pages of documents in 94111 13 this case already. Mansukhani, Suite CA 14 5. ‘ Plaintiff was deposed over a three-day period on July 30, 2018, July 31, 2018 and Street, Scully Francisco, 15 August 8,201 8. My Partner, Marcie Isom Fitzsimmons took Plaintiff s deposition on July 30, Battery Rees 16 201 8, July 3 1, 201 8. Alticor’s counsel eXamined Plaintiff during a portion of the time on July 31 San 275 Gordon 17 and August 8,201 8. ' 18 6. Plaintiff mail served a Notice of Deposition for John Ioannidis on June 22, 201 8, 19 with a deposition date of July 17, 201 8. The deposition was moved. On July 18, 2018, Plaintiff 20 mail served an Amended Notice of Deposition for John Ioannidis With a deposition date of 21 August 21, 2018. 22 7. Plaintiff canceled the deposition of John Ioannidis on August 15, 2018 and mail 23 served an amended notice of deposition for September 18, 201 8. 24 8. On September 17, 2018, Plaintiff once again canceled the deposition 0f John 25 Ioannidis and mail served an amended notice 0f deposition for November 12, 201 8. 26 9. On September 17, 201 8, Plaintiff s counsel, Fred Hagen, requested deposition 27 dates for Dr. Sandra Winter. I responded the next day with Dr. Winter’s availability. That same 28 -2- DECLARATION OF AMBER EKLOF IN SUPPORT OF DEFENDANT STANFORD’S OPPOSITION TO PLAINTIFF’S EX PARTE APPLICATION TO CONTNUE TRIAL AND ALL SCHEDUELD HEARINGS day, Mr. Hagen requested dates for six witnesses. Isent Mr. Hagen an email response 0n September 19, 2018, providing dates for four of the witnesses and indicating Ihad reached out to the two remaining witnesses for dates. 10. On October 11, 201 8, Plaintiff filed a Motion to Compel against Stanford, despite Stanford’s Willingness to continue to meet and confer on discovery and to conduct a search for any additional documents With proposed search parameters. Plaintiff declined Stanford’s offer and refused t0 provide any alternatives to Stanford’s efforts. KOOOQON 11. On September 21 ,2018, Plaintiff filed a similar Motion t0 Compel against Alticor Inc. On October 23, 201 8, this court denied Plaintiff s motion in itsentirety. 10 I declare under penalty of perjury under the laws 0f the State of California that the 11 foregoing is true and correct. LLP 2000 12 Executed this 24th day 0f October 2018 at San Francisco, California. 94111 13 flp/M Mahsukhani, Suite CA Street, 14 Scully Francisco, 15 Amber A. Eklof Battery Rees 16 San 275 Gordon 17 18 19 20 21 22 23 24 25 26 27 28 -3- DECLARATION OF AMBER EKLOF m SUPPORT OF DEFENDANT STANFORD’S OPPOSITION TO PLANTIFF’S EX PARTE APPLICATION TO CONTINUE TRIAL AND ALL SCHEDUELD HEARINGS