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Wau
Fredrick A. Hagen, California Bar.No. 196220.
BERDING & WEIL LLP
2175 N. California Blvd, Suite 500 FILED
Walnut Creck,.California 94596
Telephone: 925-838-2090
SAN MATEO COUNTY
Facsimile: 925-820-5592 NOV 0-8 2018
fhagen@berdingweil.com
kpinco@berdingweil:com Clerkof r Gourt
Attomeys for Plaintiff Ciel
ALI TAGHAVI
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eee
47-WV—04570
SUPERIOR COURT OF THE STATE OF CALIFORNIA
jimmy =
EVID 1
Evidence
447!
u ALI TAGHAVI, an individual, No. 17CIV04570 1
oa
12 Plaintiff, LODGED — CONDITIONALLY UNDER
SEAL
13 VS.
INDEX OF EVIDENCE IN SUPPORT OF 1
14 THE LELAND STANFORD JUNIOR PLAINTIFF ALI TAGHAVI’S
UNIVERSITY, a California nonprofit OPPOSITION TO STANFORD’S
15 corporation, doing business as STANFORD UNTIMELY MOTION FOR SUMMARY
UNIVERSITY; ALTICOR, INC.; a Michigan JUDGMENT/ADJUDICATION
16 corporation; and DOES 1-10, inclusive,
Date: November 16, 2018
17 Defendants. Time: 9:00 a.m.
Dept.: Law and Motion
18
Complaint Filed: October 4, 2017
19 Trial Date: December 17, 2018
/
20
Pursuant to rule.3.1350, subdivisions (c) and (g) of the California Rules of Court, Plaintiff
21
Ali Taghavi hereby submits the following declaration, with related ‘exhibits; in support of its
22
Opposition to Motion for Summary Judgmient/Adjudication!.
23
Mt
24
ut
25
26.
27 1 The Deelatation(s) filed- concurrently herewith, attach excerpts and exhibits from
Plaintiffs deposition as well as.a mimber of other dociiments served in discovery in the above-
28 captioned action, as Plaintiff's deposition testimony has been designated confidential.
-1-
BERDING
& WEIL iLe INDEX OF EVIDENCE IN SUPPORT OF PLAINTIFF ALI TAGHAVIS OPPOSITION 10 DEFENDANT
Been tind daneee
STANFORD’S UNTIMELY MOTION FOR SUMMARY JUDGMENT/ADJUDICATION
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| | RETACHUMENT / DESCRIPTION .
2 1 Declaration of Ali Taghavi
3 2 Declaration of Fred A. Hagen
4 3 Declaration of Scott Bates
4 Declaration of Andrew T. Stevenson
5
Stanford’s offer of employment to Plaintiff Ali Taghavi, dated and executed
Exhibit A
6 on June 12, 2015.
Defendant Alticor, Inc,’s Gift Agreement with Defendant Board of Trustees
Exhibit B of The Leland Stanford Junior University, dated August 15, 2014 and
executed on. August 13, 2014 and August 14, 2014,
Emails between Defendant Alticor, Inc. and’ Plaintiff Ali Taghavi and
Exhibit C
WELL Project guidelines.
10 Email string between Plaintiff and Defendants regarding non-approval of
Exhibit D
11 requested new proposed WELL Project guidelines
Exhibit E Monthly Stanford Prevention Research Center newsletter and related email
12
Exhibit F Email exchange between Sandra Winters and Stanford Development Office
13
Exhibit G Email from Elsie Wang to Plaintiff re “action items”
14 Email from Plaintiff to Elsie Wang containing the. PR and Marketing plan
Exhibit H
15 for the WELL Project
Exhibit I Email from Plaintiff to Stanford employee John Ioannidis re concerns
16
Email. from Plaintiff io Elsie Wang re “follow up items” and containing the
17 Exhibit J
PR and Marketing plan for the WELL Project
18 Email from Elsie Wang to other Stanford employees informing of
Exhibit K
Plaintiff's termination from Stanford.
19
Email from Mike Cazer to Amway Region Presidents, produced by Alticor,
Exhibit L
20 Inc. as ALTO002200
Email from Keith Randolph to Audra Davies, Produced by Alticor, Inc. as
21 Exhibit M
ALT0002318-2319
22 Timeline of WELL Project events produced by Allticor, Inc. as
Exhibit N
ALT0002469-2472
23
Email from Amway’s Todd Woodward, responding to Ali Taghavi’s refusal
24 Exhibit ° to alter publicity. limitations, produced by Alticor, Inc. as ALT0014114-
14116
25
Email from Sam Rehnborg to John Farquar, dated March 16, 2016 and
26 Exhibit P
produced by Alticor, Inc. as ALT0002930-2931
27 Meeting notes indicating Alticor Inc.’s dissatisfaction with the lack of
Exhibit Q
publicity, produced by Alticor, Inc. as ALT0002453
28
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INDEX OF EVIDENCE IN SUPPORT OF PLAINTIFF ALI TAGHAVI’S OPPOSITION TO DEFENDANT
‘alot Cree, Car 6596
STANFORD'S UNTIMELY MOTION FOR SUMMARY JUDGMENT/ADJUDICATION
Email string between Stanford and Alticor, Inc. re dissatisfaction with
Exhibit R
publicity video, produced by Allticor, Inc. as ALT0016617
Exhibit § Plaintiff's deposition testimony
Email from Keith Randolph critically describing facilitation of WELL
Exhibit T Project and Stanford employees involved, produced by Alticor, Inc. as
ALT0005997
June 6, 2016 Alticor, Inc. emails regarding Plaintiff's termination produced
Exhibit U
by Alticor, Inc. as ALT0013096
Exhibit V Deposition testimony of Catherine Heaney
Exhibit W Email from counsel for Stanford regarding failure to effectuate service
Date: November 2, 2018 BERDIN WEIL LLP
10
11
AI
Fredrick A. Hagen
Attomey for Plaintiff
12 ALI TAGHAVI
13 X:AWdocs\823619 |\PLD\00964034.DOCX
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3.
BERDING & WEILL? INDEX OF EVIDENCE IN SUPPORT OF PLAINTIFF ALI TAGHAVI'S OPPOSITION TO DEFENDANT
cee
STANFORD’S UNTIMELY MOTION FOR SUMMARY JUDGMENT/ADIJUDICATION
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Wau Fredrick A. Hagen, California Bar.No. 196220. BERDING & WEIL LLP 2175 N. California Blvd, Suite 500 FILED Walnut Creck,.California 94596 Telephone: 925-838-2090 SAN MATEO COUNTY Facsimile: 925-820-5592 NOV 0-8 2018 fhagen@berdingweil.com kpinco@berdingweil:com Clerkof r Gourt Attomeys for Plaintiff Ciel ALI TAGHAVI > eee 47-WV—04570 SUPERIOR COURT OF THE STATE OF CALIFORNIA jimmy = EVID 1 Evidence 447! u ALI TAGHAVI, an individual, No. 17CIV04570 1 oa 12 Plaintiff, LODGED — CONDITIONALLY UNDER SEAL 13 VS. INDEX OF EVIDENCE IN SUPPORT OF 1 14 THE LELAND STANFORD JUNIOR PLAINTIFF ALI TAGHAVI’S UNIVERSITY, a California nonprofit OPPOSITION TO STANFORD’S 15 corporation, doing business as STANFORD UNTIMELY MOTION FOR SUMMARY UNIVERSITY; ALTICOR, INC.; a Michigan JUDGMENT/ADJUDICATION 16 corporation; and DOES 1-10, inclusive, Date: November 16, 2018 17 Defendants. Time: 9:00 a.m. Dept.: Law and Motion 18 Complaint Filed: October 4, 2017 19 Trial Date: December 17, 2018 / 20 Pursuant to rule.3.1350, subdivisions (c) and (g) of the California Rules of Court, Plaintiff 21 Ali Taghavi hereby submits the following declaration, with related ‘exhibits; in support of its 22 Opposition to Motion for Summary Judgmient/Adjudication!. 23 Mt 24 ut 25 26. 27 1 The Deelatation(s) filed- concurrently herewith, attach excerpts and exhibits from Plaintiffs deposition as well as.a mimber of other dociiments served in discovery in the above- 28 captioned action, as Plaintiff's deposition testimony has been designated confidential. -1- BERDING & WEIL iLe INDEX OF EVIDENCE IN SUPPORT OF PLAINTIFF ALI TAGHAVIS OPPOSITION 10 DEFENDANT Been tind daneee STANFORD’S UNTIMELY MOTION FOR SUMMARY JUDGMENT/ADJUDICATION Me, a RD mo, s: Ss: <; + Sout | | RETACHUMENT / DESCRIPTION . 2 1 Declaration of Ali Taghavi 3 2 Declaration of Fred A. Hagen 4 3 Declaration of Scott Bates 4 Declaration of Andrew T. Stevenson 5 Stanford’s offer of employment to Plaintiff Ali Taghavi, dated and executed Exhibit A 6 on June 12, 2015. Defendant Alticor, Inc,’s Gift Agreement with Defendant Board of Trustees Exhibit B of The Leland Stanford Junior University, dated August 15, 2014 and executed on. August 13, 2014 and August 14, 2014, Emails between Defendant Alticor, Inc. and’ Plaintiff Ali Taghavi and Exhibit C WELL Project guidelines. 10 Email string between Plaintiff and Defendants regarding non-approval of Exhibit D 11 requested new proposed WELL Project guidelines Exhibit E Monthly Stanford Prevention Research Center newsletter and related email 12 Exhibit F Email exchange between Sandra Winters and Stanford Development Office 13 Exhibit G Email from Elsie Wang to Plaintiff re “action items” 14 Email from Plaintiff to Elsie Wang containing the. PR and Marketing plan Exhibit H 15 for the WELL Project Exhibit I Email from Plaintiff to Stanford employee John Ioannidis re concerns 16 Email. from Plaintiff io Elsie Wang re “follow up items” and containing the 17 Exhibit J PR and Marketing plan for the WELL Project 18 Email from Elsie Wang to other Stanford employees informing of Exhibit K Plaintiff's termination from Stanford. 19 Email from Mike Cazer to Amway Region Presidents, produced by Alticor, Exhibit L 20 Inc. as ALTO002200 Email from Keith Randolph to Audra Davies, Produced by Alticor, Inc. as 21 Exhibit M ALT0002318-2319 22 Timeline of WELL Project events produced by Allticor, Inc. as Exhibit N ALT0002469-2472 23 Email from Amway’s Todd Woodward, responding to Ali Taghavi’s refusal 24 Exhibit ° to alter publicity. limitations, produced by Alticor, Inc. as ALT0014114- 14116 25 Email from Sam Rehnborg to John Farquar, dated March 16, 2016 and 26 Exhibit P produced by Alticor, Inc. as ALT0002930-2931 27 Meeting notes indicating Alticor Inc.’s dissatisfaction with the lack of Exhibit Q publicity, produced by Alticor, Inc. as ALT0002453 28 2- INDEX OF EVIDENCE IN SUPPORT OF PLAINTIFF ALI TAGHAVI’S OPPOSITION TO DEFENDANT ‘alot Cree, Car 6596 STANFORD'S UNTIMELY MOTION FOR SUMMARY JUDGMENT/ADJUDICATION Email string between Stanford and Alticor, Inc. re dissatisfaction with Exhibit R publicity video, produced by Allticor, Inc. as ALT0016617 Exhibit § Plaintiff's deposition testimony Email from Keith Randolph critically describing facilitation of WELL Exhibit T Project and Stanford employees involved, produced by Alticor, Inc. as ALT0005997 June 6, 2016 Alticor, Inc. emails regarding Plaintiff's termination produced Exhibit U by Alticor, Inc. as ALT0013096 Exhibit V Deposition testimony of Catherine Heaney Exhibit W Email from counsel for Stanford regarding failure to effectuate service Date: November 2, 2018 BERDIN WEIL LLP 10 11 AI Fredrick A. Hagen Attomey for Plaintiff 12 ALI TAGHAVI 13 X:AWdocs\823619 |\PLD\00964034.DOCX 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3. BERDING & WEILL? INDEX OF EVIDENCE IN SUPPORT OF PLAINTIFF ALI TAGHAVI'S OPPOSITION TO DEFENDANT cee STANFORD’S UNTIMELY MOTION FOR SUMMARY JUDGMENT/ADIJUDICATION