Order: RACHEL MONIZ vs ADECCO USA, INC.

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                                SAN MATEO COUNTY


                                                                                                           AUG          2018




                 WWII
                                              SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                                                COUNTY OF SAN MATEO

                                                             COMPLEX CIVIL LITIGATION

                           RACHEL MONIZ, on behalf of the                             Case No.    17CIV01736
                           State of California and aggrieved                          REPRESENTATIVE ACTION
                           employees,
                                                                                      Assigned for All Purposes to
                                    Plaintiffs,                                       Hon.   Marie S. Weiner, Dept. 2

                           vs.                          -
                                                                                      CASE MANAGEMENT ORDER #6

                           ADECCO USA, INC., and DOES                1-50,
                           inclusive,

                                    Defendants.




                                    On August     1, 2018, a Discovery Conference was held in Department 2                of this

                           Court before the Honorable Marie S. Weiner.             Kyle Bates    of Schneider Wallace Cottrell

                           Konecky Wotkyns LLP appeared on behalf of Plaintiff Moniz;                  and Steven Blackburn of

                           Epstein Becker     & Green PC appeared on behalf of Defendant Adecco USA Inc.

                                    The discovery disputes regarding Defendant’s PMK deposition were discussed.

                                    The Court made the following rulings at the Conference, which are set forth

                           herein as the formal order      of this Court.
                                    IT IS HEREBY ORDERED               as follows:

                                    Plaintiffs’ request that the Court compel a further PMK deposition by requiring

                           Adecco to present Vanessa Hodgerson,            its Associated General Counsel, who the

                           previously deposed PMK (Debra Duffield) identified as a person who was more

                           knowledgeable as to certain identified categories,           specifically Subject Matter nos. 2, 3, 6,

                           10, 11,  12 and 15 is   DENIED      as  to Subject Matter Nos. 3, 6,      10,  11, 12, and   15, for the

                           reasons stated on the record at the Conference.          As to Subject Matter No. 2, the only

                           portion for which Plaintiffs need further information or confirmation is any actions

                           actually taken by Adecco to “enforce” confidentiality provisions against any Adecco

                           employee in regard to salary, benefits, compensation, and working conditions.                   Counsel

                           for the parties shall meet and confer, and present (directly to Department 2) by

                           August 10, 2018 a stipulated proposed order in regard to satisfying               Subject Matter No.2;

                           for example, by Hodgerson providing a declaration or offer of proof, or Adecco

                           providing a fiirther other PMK who is more knowledgeable than Hodgerson on this

                           particular point, etc.    [The Court notes, as set forth in CMC order #5, “in response to

                           CMC Order #4, Defendant          . .. disclosed that zero employees were subjected to

                           reprimands or other disciplinary action or warnings by Defendant based upon breach or




                                             August    1,2018
                                                                                         W/
                           alleged breach of the confidentiality provision of the employment agreement.”]

                           DATED:

                                                                                 HON. MARiE s. WEINER
                                                                                 JUDGE OF THE SUPERIOR COURT