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Michele Ballard Miller (SBN 104198)
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Mary L. Guilfoyle (SBN 143308) ALAMEDA COUNTY
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Gregory F. Fortescue (SBN 249133) FEB 17 2012
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MILLER LAW GROUP CLERK OF THE SUPERI
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Attorneys for Defendants KAISER
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— PLEASE TAKE NOTICE that on January 31, 2012, the Court entered itsOrder
on Protective Order Regarding Defendants’ Production of Privileged Documents, in the
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NOTICE OF ENTRY OF ORDER OF PROTECTIVE ORDER REGARDING DEFENDANTS’
PRODUCTION OF PRIVILEGED DOCUMENTS - Case No.: RG10495979
J&n 30 4% 09:48a THE ROSA tA@rour . Qis27-9425
Andrea Rosa (SBN 122658) 2. RAIL
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THE ROSA LAW GROUP ALAMEDA COUNTY
5050 Laguna Blvd., Suite 112-580 ;
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Elk Grove, CA 95758 a JAN © 1 2012
Tel: (918) 647-9425
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Fax: (916) 647-9425 , CLERK py THE fSUPERIOR couRr
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Marylon M. Boyd (SBN 139642) “ Deputy
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Attorneys for PlaintiffROBIN BONGON
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Michele Ballard Miller (SBN 104198) _
10 mbm@millerlawgroup.com
Mary L. Gullfoyle (SBN 143308)-
41 miq@millerlawgroup.com
Gregory F. Fortescue (SBN 249133)
12 gu@millerawgroup,com
MILLER LAW GROUP
13||A Professional Corporation
111 Sutter Street, Suite 700
14 || San Francisco, CA 94104
-|| Tel. (44 2} 464-4300
15 ||Fax (415) 464-4336
16 || Attorneys for Defendants
FOUNDATION HOSPITALS, INC.,
17 || KAISER FOUNDATION HEALTH PLAN, ING.,
48 And RON NAVARRA
49 SUPERIOR COURT OF CALIFORNIA
20 COUNTY OF ALAMEDA
of ROBIN BONGON, ~— - . Case No.: RG10495979
ASSIGNED FOR ALL PURPOSES TO
22 Plaintiff, JUDGE John M. True, Ill
DEPARTMENT 512
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24 STIPULATION REGARDING .
KAISER FOUNDATION HOSPITAL, INC.; DEFENDANTS’ PRODUCTION OF
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KAISER PERMANENTE, INC.; RON [PROPO OTECTIVE ORDER
26 || NAVARRA; and DOES 1 THROUGH 10,
27 Complaint filed: January 27, 2010
Defendanis. .
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STIPULATION PROTECTIVE ORDER REGARDING DEFENDANT KAISER'S
PRODUCTION OF PRIVILEGED DOCUMENTS
Case No,; RG10495975
Jan 30 12 09:48a THE ROSA LAW GROUP 916-647-9425 p.4
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“WHEREAS, Defendant KAISER FOUNDATION HOSPITALS ("Kaiser”} has
taken the position inthe course of discovery that the following two documents are protected
from disclosure by attorney-client privilege and/or attorney work product doctrine: {1) a
memorandum dated July 1, 2009 from Patia Dial, a third-party investigator, to
representatives in Kalser Permanente’s California Workers’ Compensation Department
regarding her investigation into Plaintiff's workers’ compensation claim for emotional
distress stemming from alleged sexual harassment; and (2) aCase Summary memorandum
dated July 9, 2009 by Sharon Burton, an investigator in Kaiser's EEO Investigations Unit, to
representatives inKaiser's legal department regarding Plaintiff'sintemal complaint of sexual
harassment (collectively, the "Memoranda’”);
WHEREAS, Plaintiff disputes Kaiser's claim of privilege regarding these two
documents and seeks their disclosure;
_ WHEREAS, Kaiser wishes to disclose these two documents voluntarily with
the express understanding that Its production of these documents does not waive the
attorney work-product doctrine or attorney-client privilege as to any other communication
with counsel relevant to this litigation:
WHEREFORE, Plaintiff and Kaiser, through their respective undersigned
counsel! of record, hereby stipulate and agree as follows:
1, Kaiser willproduce copies of the Memoranda within five (5) calendar
days following receipt of the entry of the Court's order deeming that such disclosure does
not waive Kaiser's rightto assert attorney work-product doctrine or attorney-client privilege
as to any other communication with counsel relevant to this litigation, including but not
Jimited to written and/or oral communications with counsel in the course of the investigations
1
STIPULATED PROTECTIVE ORDER REGARDING DEFENDANT KAISER’S
PRODUCTION OF PRIVILEGED DOCUMENTS
Case No.:34-2008-000-25804
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Jan 30 12 09:48a THE ROSA LAW GROUP 916-647-9425 p.5
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conducted by Ms. Burton or Ms. Dial.
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2. Plaintiff agrees not to argue or take the position in the course of this
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3, This stipulation is entered into pursuant to Code of Civil Procedure
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STIPULATED PROTECTIVE ORDER REGARDING DEFENDANT KAISER'S
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Case No.: 34-2008-000-25804
Jan 30 12 09:49a THE ROSA LAW GROUP 916-647-9425 p7
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Case name: Robin Bongon v. Kaiser Foundation Hospitals,Inc., etal.
Case No.; RG10-495969
DECLARATION OF SERVICE
(CCP, § 1013(a), 2915)
Tam a citizenof the United States and employed inSacramento County, California;[am over
the age of 18 years,and not a partyto the within action. My business address is5050 Laguna
Blvd. Suite 112-580, Elk Grove, CA 95758.
On the date below, I served the following documents:
Stipulation Regarding Defendant's Production ofPrivileged Documents and
[PROPOSED] Protective Order
at thefollowing address:
Gregory F. Fortescue Attorneys for
Defendant
10
MillerLaw Group Kaiser Foundation Hospitals, Inc.,etal.
111 Sutter Street,Suite 700
11
San Francisco, CA 94104
12
BK By United States Mail. [ enclosed the document in asealed envelope or package
- addzessed tothe person(s) atthe address listedabove and deposited such envelope with
postage thereon fullyprepaid with the United States Postal Service.
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Personal
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Service.
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I caused
above.
such document tobe delivered
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by hand to the officeof
[] By Overnight Delivery. Icaused such document to be delivered by overnight
delivery to theoffice of the person(s) listedabove.
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O By Facsimile. I cansed such document tobe transmitted by facsimilemachine to the
officeof the person(s) listedabove.
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[] By Email. I caused such document to be transmitted by email tothe office of the
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person(s) listedabove.
21
J declare under penalty of perjury that the foregoing istrue and correct and was executed on
22
January 26,2012 atElk Grove, California.
23 Meese
24
AliciaJackson”
25
THE ROSA LAW GROUP
Declaration of Service
Superior Court of California, County of Alameda
Hayward Hail of Justice
Case Number: RG10495979
Order of 01/31/2012
DECLARATION OF SERVICE BY MAIL
i certifythat |am not a party to thiscause and that a true and correct copy of the
foregoing document was mailed firstclass, postage prepaid, in a sealed envelope,
‘addressed as shown on the foregoing document or on the attached, and that the
mailing of the foregoing and execution ofthis certificate occurred at
24405 Amador Street, Hayward, California.
Executed on 01/31/2012.
Executive Officer / Clerk of the Superior Court
By jig Opie.
Deputy Clerk
= PROOF OF SERVICE
1,Cheryl Bower, declare that |! am employed at Miller Law Group, A Professional
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Corporation, whose address is 111 Sutter Street, Suite 700, San Francisco, CA 94104; |am
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over the age of eighteen (18) years and am not a party to this action. On the below date, by
the method noted below, | served the following document(s):
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NOTICE OF ENTRY OF ORDER OF PROTECTIVE ORDER REGARDING
DEFENDANTS’ PRODUCTION OF PRIVILEGED DOCUMENTS
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on the interested parties in this action by placing a true and correct copy thereof, enclosed
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in a sealed envelope addressed as follows:
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Marylon M. Boyd, Esq. Andrea Rosa, Esq.
LAW OFFICES OF MARYLON M. BOYD THE ROSA LAW GROUP
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2201 Broadway Street, Suite 815 5050 Laguna Bivd., Suite 112-580
Oakland, CA 94612 Elk Grove, CA 95758
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Tel: (510) 663-8772 Tel: (916) 647-9425
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Fax: (510) 663-8781 Fax: (916) 647-9425
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Email: fawofficeofmarylonboyd@yahoo.com Email: andrea.rosa@therosalawgroup.com
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Attorney for Plaintiff: Robin Bongon Attorney for Plaintiff: Robin Bongon
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XI BY OVERNIGHT DELIVERY: By placing the document(s) listed above in a sealed
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CORPORATION
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envelope(s) and consigning it/them to an express mail or overnight courier for
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guaranteed delivery on the next business day following the date of consignment to
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the address(es) set forth above. A copy of the consignment slip is attached to the
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last page of this proof of service.
MILLER
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BY MAIL: By placing a true copy thereof enclosed in a sealed envelope with
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postage thereon fully prepaid, in the ordinary course of business for collection and
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mailing on this date at Miller Law Group, 111 Sutter Street, San Francisco, California.
| declare that | am readily familiar with the business practice of Miller Law Group for
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collection and processing of correspondence for mailing with the United States Postal
Service and that the correspondence would be deposited with the United States
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Postal Service that same day in the ordinary course of business.
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| declare under penalty of perjury under the laws of the State of California that the
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foregoing is true and correct.
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Executed on February 17, 2012 at San Francisco, California.
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PROOF OF SERVICE
Case No. RG10495979
Preview
oe. A = Michele Ballard Miller (SBN 104198) mbm@millerlawgroup.com CLIETS Mary L. Guilfoyle (SBN 143308) ALAMEDA COUNTY NO mig@millerlawgroup.com Gregory F. Fortescue (SBN 249133) FEB 17 2012 WO gff@millelawgroup.com MILLER LAW GROUP CLERK OF THE SUPERI RIOR ORT FP A Professional Corporation By 2 Lecet 111 Sutter Street, Suite 700 oO San Francisco, CA 94104 Tel. (415) 464-4300 OO Fax (415) 464-4336 nN Attorneys for Defendants KAISER FOUNDATION HOSPITALS, INC., wa KAISER FOUNDATION HEALTH PLAN, INC., And RON NAVARRA oO lek OC =| lle £ SUPERIOR COURT OF CALIFORNIA LHP PNY CORPORATION IN AND FOR THE COUNTY OF ALAMEDA CALIFORNIA WH Group om ls Fk er LAW IRANCISCO, ee PROFESSIONAL ROBIN BONGON, Case No.: RG10495979 Oo ed MILLER ae oo ASSIGNED FOR ALL PURPOSES TO ih DMD SAN Plaintiff, JUDGE John M. True, Ill A DEPARTMENT 512 or ON NOTICE OF ENTRY OF ORDER OF = PROTECTIVE ORDER REGARDING KAISER FOUNDATION HOSPITAL, INC.; DEFENDANTS’ PRODUCTION OF &=& ODO KAISER FOUNDATION HEALTH PLAN, INC.; PRIVILEGED DOCUMENTS KAISER PERMANENTE, IJNC.; RON CO PF NAVARRA; and DOES 1 THROUGH 10, = PO Complaint filed: January 27, 2010 Defendants. NY KN WO PO FR HF oO PD OD RP NAN bo oOo Dh NOTICE OF ENTRY OF ORDER OF PROTECTIVE ORDER REGARDING DEFENDANTS’ PRODUCTION OF PRIVILEGED DOCUMENTS - Case No.: RG10495979 — PLEASE TAKE NOTICE that on January 31, 2012, the Court entered itsOrder on Protective Order Regarding Defendants’ Production of Privileged Documents, in the PP above-referenced case. A true and correct copy of that Order is attached hereto as Exhibit DW A. BR oO Dated: February 17, 2012 MILLER LAW GROUP OO A Professional Corporation nN oO By: Co SS oO Gregory F. Fortescue Attorneys for Defendants on KAISER FOUNDATION HOSPITAL, INC., KAISER FOUNDATION HEALTH PLAN, edUrmedhUum INC., and RON NAVARRA © 0) CORPORATION CALIFORNIA GRouP em Law FRANCISCO, 0) PROFESSIONAI. 4820-8916-4558,v. 1 em MILLER SAN oe > A 2 © © = | © PO NM © HM >) NH CO KH PO ©) ©> NM SE nm Coo hw 1 NOTICE OF ENTRY OF ORDER OF PROTECTIVE ORDER REGARDING DEFENDANTS’ PRODUCTION OF PRIVILEGED DOCUMENTS - Case No.: RG10495979 J&n 30 4% 09:48a THE ROSA tA@rour . Qis27-9425 Andrea Rosa (SBN 122658) 2. RAIL -— THE ROSA LAW GROUP ALAMEDA COUNTY 5050 Laguna Blvd., Suite 112-580 ; N Elk Grove, CA 95758 a JAN © 1 2012 Tel: (918) 647-9425 WO Fax: (916) 647-9425 , CLERK py THE fSUPERIOR couRr F&F Marylon M. Boyd (SBN 139642) “ Deputy Law Offices of Maryion M. Boyd om 2201 Broadway Street, Suite 315 coe Oakland, CA 94612 DO Tek 61 0) 663-8772 Fax: (510) 663-8781 NN Attorneys for PlaintiffROBIN BONGON wa oO Michele Ballard Miller (SBN 104198) _ 10 mbm@millerlawgroup.com Mary L. Gullfoyle (SBN 143308)- 41 miq@millerlawgroup.com Gregory F. Fortescue (SBN 249133) 12 gu@millerawgroup,com MILLER LAW GROUP 13||A Professional Corporation 111 Sutter Street, Suite 700 14 || San Francisco, CA 94104 -|| Tel. (44 2} 464-4300 15 ||Fax (415) 464-4336 16 || Attorneys for Defendants FOUNDATION HOSPITALS, INC., 17 || KAISER FOUNDATION HEALTH PLAN, ING., 48 And RON NAVARRA 49 SUPERIOR COURT OF CALIFORNIA 20 COUNTY OF ALAMEDA of ROBIN BONGON, ~— - . Case No.: RG10495979 ASSIGNED FOR ALL PURPOSES TO 22 Plaintiff, JUDGE John M. True, Ill DEPARTMENT 512 * 23 Nl¥. 24 STIPULATION REGARDING . KAISER FOUNDATION HOSPITAL, INC.; DEFENDANTS’ PRODUCTION OF 25 || KAISER FOUNDATION HEALTH PLAN, iNG.; PRIVILEGED DOCUMENTS AND KAISER PERMANENTE, INC.; RON [PROPO OTECTIVE ORDER 26 || NAVARRA; and DOES 1 THROUGH 10, 27 Complaint filed: January 27, 2010 Defendanis. . 28 - | STIPULATION PROTECTIVE ORDER REGARDING DEFENDANT KAISER'S PRODUCTION OF PRIVILEGED DOCUMENTS Case No,; RG10495975 Jan 30 12 09:48a THE ROSA LAW GROUP 916-647-9425 p.4 “~ “WHEREAS, Defendant KAISER FOUNDATION HOSPITALS ("Kaiser”} has taken the position inthe course of discovery that the following two documents are protected from disclosure by attorney-client privilege and/or attorney work product doctrine: {1) a memorandum dated July 1, 2009 from Patia Dial, a third-party investigator, to representatives in Kalser Permanente’s California Workers’ Compensation Department regarding her investigation into Plaintiff's workers’ compensation claim for emotional distress stemming from alleged sexual harassment; and (2) aCase Summary memorandum dated July 9, 2009 by Sharon Burton, an investigator in Kaiser's EEO Investigations Unit, to representatives inKaiser's legal department regarding Plaintiff'sintemal complaint of sexual harassment (collectively, the "Memoranda’”); WHEREAS, Plaintiff disputes Kaiser's claim of privilege regarding these two documents and seeks their disclosure; _ WHEREAS, Kaiser wishes to disclose these two documents voluntarily with the express understanding that Its production of these documents does not waive the attorney work-product doctrine or attorney-client privilege as to any other communication with counsel relevant to this litigation: WHEREFORE, Plaintiff and Kaiser, through their respective undersigned counsel! of record, hereby stipulate and agree as follows: 1, Kaiser willproduce copies of the Memoranda within five (5) calendar days following receipt of the entry of the Court's order deeming that such disclosure does not waive Kaiser's rightto assert attorney work-product doctrine or attorney-client privilege as to any other communication with counsel relevant to this litigation, including but not Jimited to written and/or oral communications with counsel in the course of the investigations 1 STIPULATED PROTECTIVE ORDER REGARDING DEFENDANT KAISER’S PRODUCTION OF PRIVILEGED DOCUMENTS Case No.:34-2008-000-25804 @ Jan 30 12 09:48a THE ROSA LAW GROUP 916-647-9425 p.5 ‘ conducted by Ms. Burton or Ms. Dial. —_ WD 2. Plaintiff agrees not to argue or take the position in the course of this W litigationthat Kaisers disclosure of the Memoranda constituted a waiver of Kaiser’s rightto HR assert attorney work-product doctrine or attorney-client privilege as to any other HW communication with counsel relevant to this litigation.- Oo ON 3, This stipulation is entered into pursuant to Code of Civil Procedure sections 2031.060 and all other applicable provisions of the Code of CivilProcedure. oO OC Ok IT1S SO STIPULATED. + lll NY Dated: May .-—— THE ROSAJLAW GROUP DO ie &® me B ——» os, BW OT Andrea Rosa , _ Attorney for Plaintiff DW wm ROBIN BONGON Van. 23, 2Op2. or LON M, BOYD DN Dated: Mey 2041 - THE LAW/OFFICES OF =| ODO = By: io oe /Marylon M. Boyd’ Na AD OO Attorney for Plaintiff ROBIN BONGON RP = NM fT Dated: May ,2071 MILLER LAW GROUP MH O A Professional Corporation FF PF OA By: C o> WM Gregory F. Fortescue Oo DY Attorney for Defendants KAISER FOUNDATION HOSPITALS, Mw ant INC., KAISER FOUNDATION HEALTH PLAN, INC., and RON NAVARRA mM 2 STIPULATED PROTECTIVE ORDER REGARDING DEFENDANT KAISER'S PRODUCTION OF PRIVILEGED DOCUMENTS Case No.:34-2008-000-25804 @ ® _dan 30 12 09:49a THE ROSA LAW GROUP ‘ '916-647-9425 D6 PROTECTIVE ORDER —s | N ITISSO ORDERED. . , Wwe WH & | Dated: In Ble [Le Hon. ohn M. ridge} a Superior Court Judge DW Alameda County . 4824-3839-7193, v.1 N OD o ek OO + ak NY WD fF Re Oo ee DW HS AN we eo OF CO DR LK = HD PR WO BD fF KN oO BH ®m PR PO an hm 3 STIPULATED PROTECTIVE ORDER REGARDING DEFENDANT KAISER'S . PRODUCTION OF PRIVILEGED DOGUMENTS Case No.: 34-2008-000-25804 Jan 30 12 09:49a THE ROSA LAW GROUP 916-647-9425 p7 a Case name: Robin Bongon v. Kaiser Foundation Hospitals,Inc., etal. Case No.; RG10-495969 DECLARATION OF SERVICE (CCP, § 1013(a), 2915) Tam a citizenof the United States and employed inSacramento County, California;[am over the age of 18 years,and not a partyto the within action. My business address is5050 Laguna Blvd. Suite 112-580, Elk Grove, CA 95758. On the date below, I served the following documents: Stipulation Regarding Defendant's Production ofPrivileged Documents and [PROPOSED] Protective Order at thefollowing address: Gregory F. Fortescue Attorneys for Defendant 10 MillerLaw Group Kaiser Foundation Hospitals, Inc.,etal. 111 Sutter Street,Suite 700 11 San Francisco, CA 94104 12 BK By United States Mail. [ enclosed the document in asealed envelope or package - addzessed tothe person(s) atthe address listedabove and deposited such envelope with postage thereon fullyprepaid with the United States Postal Service. i) By the Personal person(s) Service. listed I caused above. such document tobe delivered . by hand to the officeof [] By Overnight Delivery. Icaused such document to be delivered by overnight delivery to theoffice of the person(s) listedabove. 18 O By Facsimile. I cansed such document tobe transmitted by facsimilemachine to the officeof the person(s) listedabove. 19 [] By Email. I caused such document to be transmitted by email tothe office of the 20 person(s) listedabove. 21 J declare under penalty of perjury that the foregoing istrue and correct and was executed on 22 January 26,2012 atElk Grove, California. 23 Meese 24 AliciaJackson” 25 THE ROSA LAW GROUP Declaration of Service Superior Court of California, County of Alameda Hayward Hail of Justice Case Number: RG10495979 Order of 01/31/2012 DECLARATION OF SERVICE BY MAIL i certifythat |am not a party to thiscause and that a true and correct copy of the foregoing document was mailed firstclass, postage prepaid, in a sealed envelope, ‘addressed as shown on the foregoing document or on the attached, and that the mailing of the foregoing and execution ofthis certificate occurred at 24405 Amador Street, Hayward, California. Executed on 01/31/2012. Executive Officer / Clerk of the Superior Court By jig Opie. Deputy Clerk = PROOF OF SERVICE 1,Cheryl Bower, declare that |! am employed at Miller Law Group, A Professional NYO Corporation, whose address is 111 Sutter Street, Suite 700, San Francisco, CA 94104; |am WO over the age of eighteen (18) years and am not a party to this action. On the below date, by the method noted below, | served the following document(s): FF NOTICE OF ENTRY OF ORDER OF PROTECTIVE ORDER REGARDING DEFENDANTS’ PRODUCTION OF PRIVILEGED DOCUMENTS oo on the interested parties in this action by placing a true and correct copy thereof, enclosed ODO in a sealed envelope addressed as follows: N Oo Marylon M. Boyd, Esq. Andrea Rosa, Esq. LAW OFFICES OF MARYLON M. BOYD THE ROSA LAW GROUP oO 2201 Broadway Street, Suite 815 5050 Laguna Bivd., Suite 112-580 Oakland, CA 94612 Elk Grove, CA 95758 OO Tel: (510) 663-8772 Tel: (916) 647-9425 oe Fax: (510) 663-8781 Fax: (916) 647-9425 |= Email: fawofficeofmarylonboyd@yahoo.com Email: andrea.rosa@therosalawgroup.com Re DB Attorney for Plaintiff: Robin Bongon Attorney for Plaintiff: Robin Bongon WO ee XI BY OVERNIGHT DELIVERY: By placing the document(s) listed above in a sealed HR CORPORATION CALIFORNIA envelope(s) and consigning it/them to an express mail or overnight courier for Group Bw guaranteed delivery on the next business day following the date of consignment to OO the address(es) set forth above. A copy of the consignment slip is attached to the Law FRANCISCO, DO PROFESSIONAL me last page of this proof of service. MILLER Bw NN BY MAIL: By placing a true copy thereof enclosed in a sealed envelope with SAN postage thereon fully prepaid, in the ordinary course of business for collection and A Bm DH mailing on this date at Miller Law Group, 111 Sutter Street, San Francisco, California. | declare that | am readily familiar with the business practice of Miller Law Group for 0O© | collection and processing of correspondence for mailing with the United States Postal Service and that the correspondence would be deposited with the United States OO PP Postal Service that same day in the ordinary course of business. |= DO | declare under penalty of perjury under the laws of the State of California that the HO foregoing is true and correct. PD DH NY Executed on February 17, 2012 at San Francisco, California. F&F DN hay plLI VAN nM DP oOo HN Cheryl Royler PN on NB PROOF OF SERVICE Case No. RG10495979