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1 THOMAS DIMITRE, ATTORNEY AT LAW L.L.C. EXEMPT
State Bar No. 276924 Gov. Code § 6103
2 P.O. Box 801
Ashland, OR 97520
3 Telephone: (541) 890-5022
E-mail: dimitre@mind.net
4 Attorneys for Plaintiff 8/18/2021
Teresa Randolph
5
6 ROB BONTA
Attorney General of California
7 PETER D. HALLORAN
Supervising Deputy Attorney General
8 JERRY J. DESCHLER
Deputy Attorney General
9 State Bar No. 215691
1300 I Street, Suite 125
10 P.O. Box 944255
Sacramento, CA 94244-2550
11 Telephone: (916) 210-7871
Fax: (916) 324-5567
12 E-mail: Jerry.Deschler@doj.ca.gov
Attorneys for Defendants
13 Board of Trustees of the California State University,
which is the State of California acting in its higher
14 education capacity (erroneously sued as “Trustees
of the California State University, State of
15 California”), Cynthia Daley, and Debra Larson
16 SUPERIOR COURT OF THE STATE OF CALIFORNIA
17 COUNTY OF BUTTE
18 CIVIL DIVISION
19
20
TERESA RANDOLPH, Case No. 19CV01226
21
Plaintiff, STIPULATION TO VACATE TRIAL
22 DATE AND RELATED DATES
v.
23
24 TRUSTEES OF THE CALIFORNIA
STATE UNIVERSITY, STATE OF Judge: The Honorable Stephen E.
25 CALIFORNIA, AND CYNTHIA DALEY, Benson
AN INDIVIDUAL, AND DEBRA LARSON, Trial Date: December 6, 2021
26 AN INDIVIDUAL, Action Filed: April 24, 2019
27 Defendants.
28
1
Stipulation To Vacate Trial Date and Related Dates (19CV01226)
1 Plaintiff Teresa Randolph (“Randolph”) and Defendants Cynthia Daley and Board of
2 Trustees of the California State University, which is the State of California acting in its higher
3 education capacity (erroneously sued as “Trustees of the California State University, State of
4 California,” hereinafter referred to as “CSU”) stipulate as follows:
5 WHEREAS, The parties have engaged in extensive written discovery and discovery
6 motions, and motions attacking the pleadings, which were only recently resolved by the Court’s
7 most recent order on March 3, 2021; and
8 WHEREAS, the parties need and expect extensive additional discovery to narrow the issues
9 for trial. Specifically, Defendants intend to depose Randolph over a period of several days, and
10 Randolph has recently indicated an intent to conduct at least another thirteen depositions. The
11 depositions are likely to result in the need for additional discovery to fully prepare for trial. The
12 need for such extensive discovery and the delays in completing discovery are due, in part, to the
13 fact that the case is factually complex in that the Third Amended Complaint alleges ten causes of
14 action against two defendants, contains 153 paragraphs of factual allegations spanning
15 approximately thirteen years of Randolph’s employment with the CSU from 2006 to 2019, and
16 contains allegations that name or implicate dozens of fact witnesses; and
17 WHEREAS Randolph agrees to the request to vacate the December 6, 2021 trial date,
18 December 2, 2021 trial readiness conference, and November 1, 2021 mandatory settlement
19 conference, and associated dates.
20 IT IS HEREBY STIPULATED that the trial date now scheduled for December 6, 2021,
21 trial readiness conference scheduled for December 2, 2021, and mandatory settlement conference
22 scheduled for November 1, 2021, and all associated dates be vacated; and
23 IT IS STIPULATED that the Court schedule a status conference in approximately six
24 months, or as soon thereafter as the Court deems appropriate.
25
26
27
28
2
Stipulation To Vacate Trial Date and Related Dates (19CV01226)
1 Dated: August 17, 2021 Respectfully submitted,
2 THOMAS DIMITRE, ATTORNEY AT LAW L.L.C.
3
4
/s/ Thomas Dimitre
5 THOMAS DIMITRE
Attorneys for Plaintiff
6 Teresa Randolph
7
8
Dated: August 17, 2021 Respectfully submitted,
9
ROB BONTA
10 Attorney General of California
PETER D. HALLORAN
11 Supervising Deputy Attorney General
12
13
14 JERRY J. DESCHLER
Deputy Attorney General
15 Attorneys for Defendants
Board of Trustees of the California State
16 University, which is the State of California
acting in its higher education capacity
17 (erroneously sued as “Trustees of the
California State University, State of
18 California”), Cynthia Daley, and Debra
Larson
19
SA2019102196
20 35378129.docx
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Stipulation To Vacate Trial Date and Related Dates (19CV01226)
DECLARATION OF SERVICE BY U.S. MAIL
Case Name: Teresa Randolph v. Trustees of the California State University, et al.
Case No.: 19CV01226
I declare:
I am employed in the Office of the Attorney General, which is the office of a member of the
California State Bar, at which member's direction this service is made. I am 18 years of age or
older and not a party to this matter. I am familiar with the business practice at the Office of the
Attorney General for collection and processing of correspondence for mailing with the United
States Postal Service. In accordance with that practice, correspondence placed in the internal
mail collection system at the Office of the Attorney General is deposited with the United States
Postal Service with postage thereon fully prepaid that same day in the ordinary course of
business.
On August 18, 2021, I served the attached STIPULATION TO VACATE TRIAL DATE-
AND RELATED DATES by placing a true copy thereof enclosed in a sealed envelope in the
internal mail collection system at the Office of the Attorney General at 1300 I Street, Suite 125,
P.O. Box 944255, Sacramento, CA 94244-2550, addressed as follows:
Thomas Dimitre
PO Box 801
Ashland, OR 97520
Attorney for Plaintiff
I declare under penalty of perjury under the laws of the State of California and the United States
of America the foregoing is true and correct and that this declaration was executed on August 18,
2021, at Sacramento, California. ·
Sondra R. Bushey
Declarant
SA2019102196
35385578.docx
Preview
1 THOMAS DIMITRE, ATTORNEY AT LAW L.L.C. EXEMPT State Bar No. 276924 Gov. Code § 6103 2 P.O. Box 801 Ashland, OR 97520 3 Telephone: (541) 890-5022 E-mail: dimitre@mind.net 4 Attorneys for Plaintiff 8/18/2021 Teresa Randolph 5 6 ROB BONTA Attorney General of California 7 PETER D. HALLORAN Supervising Deputy Attorney General 8 JERRY J. DESCHLER Deputy Attorney General 9 State Bar No. 215691 1300 I Street, Suite 125 10 P.O. Box 944255 Sacramento, CA 94244-2550 11 Telephone: (916) 210-7871 Fax: (916) 324-5567 12 E-mail: Jerry.Deschler@doj.ca.gov Attorneys for Defendants 13 Board of Trustees of the California State University, which is the State of California acting in its higher 14 education capacity (erroneously sued as “Trustees of the California State University, State of 15 California”), Cynthia Daley, and Debra Larson 16 SUPERIOR COURT OF THE STATE OF CALIFORNIA 17 COUNTY OF BUTTE 18 CIVIL DIVISION 19 20 TERESA RANDOLPH, Case No. 19CV01226 21 Plaintiff, STIPULATION TO VACATE TRIAL 22 DATE AND RELATED DATES v. 23 24 TRUSTEES OF THE CALIFORNIA STATE UNIVERSITY, STATE OF Judge: The Honorable Stephen E. 25 CALIFORNIA, AND CYNTHIA DALEY, Benson AN INDIVIDUAL, AND DEBRA LARSON, Trial Date: December 6, 2021 26 AN INDIVIDUAL, Action Filed: April 24, 2019 27 Defendants. 28 1 Stipulation To Vacate Trial Date and Related Dates (19CV01226) 1 Plaintiff Teresa Randolph (“Randolph”) and Defendants Cynthia Daley and Board of 2 Trustees of the California State University, which is the State of California acting in its higher 3 education capacity (erroneously sued as “Trustees of the California State University, State of 4 California,” hereinafter referred to as “CSU”) stipulate as follows: 5 WHEREAS, The parties have engaged in extensive written discovery and discovery 6 motions, and motions attacking the pleadings, which were only recently resolved by the Court’s 7 most recent order on March 3, 2021; and 8 WHEREAS, the parties need and expect extensive additional discovery to narrow the issues 9 for trial. Specifically, Defendants intend to depose Randolph over a period of several days, and 10 Randolph has recently indicated an intent to conduct at least another thirteen depositions. The 11 depositions are likely to result in the need for additional discovery to fully prepare for trial. The 12 need for such extensive discovery and the delays in completing discovery are due, in part, to the 13 fact that the case is factually complex in that the Third Amended Complaint alleges ten causes of 14 action against two defendants, contains 153 paragraphs of factual allegations spanning 15 approximately thirteen years of Randolph’s employment with the CSU from 2006 to 2019, and 16 contains allegations that name or implicate dozens of fact witnesses; and 17 WHEREAS Randolph agrees to the request to vacate the December 6, 2021 trial date, 18 December 2, 2021 trial readiness conference, and November 1, 2021 mandatory settlement 19 conference, and associated dates. 20 IT IS HEREBY STIPULATED that the trial date now scheduled for December 6, 2021, 21 trial readiness conference scheduled for December 2, 2021, and mandatory settlement conference 22 scheduled for November 1, 2021, and all associated dates be vacated; and 23 IT IS STIPULATED that the Court schedule a status conference in approximately six 24 months, or as soon thereafter as the Court deems appropriate. 25 26 27 28 2 Stipulation To Vacate Trial Date and Related Dates (19CV01226) 1 Dated: August 17, 2021 Respectfully submitted, 2 THOMAS DIMITRE, ATTORNEY AT LAW L.L.C. 3 4 /s/ Thomas Dimitre 5 THOMAS DIMITRE Attorneys for Plaintiff 6 Teresa Randolph 7 8 Dated: August 17, 2021 Respectfully submitted, 9 ROB BONTA 10 Attorney General of California PETER D. HALLORAN 11 Supervising Deputy Attorney General 12 13 14 JERRY J. DESCHLER Deputy Attorney General 15 Attorneys for Defendants Board of Trustees of the California State 16 University, which is the State of California acting in its higher education capacity 17 (erroneously sued as “Trustees of the California State University, State of 18 California”), Cynthia Daley, and Debra Larson 19 SA2019102196 20 35378129.docx 21 22 23 24 25 26 27 28 3 Stipulation To Vacate Trial Date and Related Dates (19CV01226) DECLARATION OF SERVICE BY U.S. MAIL Case Name: Teresa Randolph v. Trustees of the California State University, et al. Case No.: 19CV01226 I declare: I am employed in the Office of the Attorney General, which is the office of a member of the California State Bar, at which member's direction this service is made. I am 18 years of age or older and not a party to this matter. I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service. In accordance with that practice, correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service with postage thereon fully prepaid that same day in the ordinary course of business. On August 18, 2021, I served the attached STIPULATION TO VACATE TRIAL DATE- AND RELATED DATES by placing a true copy thereof enclosed in a sealed envelope in the internal mail collection system at the Office of the Attorney General at 1300 I Street, Suite 125, P.O. Box 944255, Sacramento, CA 94244-2550, addressed as follows: Thomas Dimitre PO Box 801 Ashland, OR 97520 Attorney for Plaintiff I declare under penalty of perjury under the laws of the State of California and the United States of America the foregoing is true and correct and that this declaration was executed on August 18, 2021, at Sacramento, California. · Sondra R. Bushey Declarant SA2019102196 35385578.docx