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  • Oliver VS City of Oakland Civil Unlimited (Civil Rights/Discrimination) document preview
  • Oliver VS City of Oakland Civil Unlimited (Civil Rights/Discrimination) document preview
  • Oliver VS City of Oakland Civil Unlimited (Civil Rights/Discrimination) document preview
  • Oliver VS City of Oakland Civil Unlimited (Civil Rights/Discrimination) document preview
  • Oliver VS City of Oakland Civil Unlimited (Civil Rights/Discrimination) document preview
  • Oliver VS City of Oakland Civil Unlimited (Civil Rights/Discrimination) document preview
  • Oliver VS City of Oakland Civil Unlimited (Civil Rights/Discrimination) document preview
  • Oliver VS City of Oakland Civil Unlimited (Civil Rights/Discrimination) document preview
						
                                

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From: 08/24/2020 15:05 #112 P.002/007 FILED BY E-DELIVERY ALAMEDA COUNTY CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY August 24, 2020 John Houston Scott, SBN 72578 CLERK OF Scott Law Firm THE SUPERIOR COURT 1388 Sutter Street, Suite 715, San Francisco, CA 94109 By Catherine Green, Deputy TELEPHONE NO. 415-561-9603 FAX NO. (Optional): 415-561-9609 CASE NUMBER: E-MAIL ADDRESS (Option): john@scottlawfirm.net RG 1 9007799 ATTORNEY FOR (Name: Plaintiff MILDRED OLIVER SUPERIOR COURT OF CALIFORNIA, COUNTY OF Alameda street appress: 1225 Fallon Street MAILING ADDRESS CITY AND ZIP CODE: Oakland, CA 94612 BRANCH NAME, PLAINTIFF/PETITIONER: Mildred Oliver DEFENDANT/RESPONDENT: City of Oakland, Oakland Police Department, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): (] UNLIMITED CASE [1 umrrep CASE RG19007799 {Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: September 8, 2020 Time: 9:00 a.m. Dept.: 25 Div.: Room: Address of court (if different from the address above): 1221 Oak Street, Oakland, CA 94612 Notice of Intent to Appear by Telephone, by (name): John Houston Scott INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): Mildred Oliver, Plaintiff b. C4 This statement is submitted jointly by parties (names): 2. ¢ taint and cr plaint (to be answered by plaintiffs and cross-complainants only} a. The complaint was filed on (date): February 21, 2019 b. [1] The cross-complaint, if any, was filed on (date): 3. Service (fo be answered by plaintiffs and cross-complainants only) a. All parties named in the compiaint and cross-complaint have been served, have appeared, or have been dismissed. b. [2] The fatlowing parties named in the complaint or cross-complaint (1) [1 have not been served (specify names and explain why not): (2) [1 have been served but have not appeared and have not been dismissed (specify names): {3) (--] have had a default entered against them (specify names): c CC] The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type of case in comptaint [2] cross-compiaint (Describe, including causes of action): Gender Discrimination; Race Discrimination; Hostile-Work Environment; FEHA Retaliation; Whistleblower Retaliation Page 1 of 5 Fe ord ibted for Mandatory \datory gee U: CASE MANAGEMENT STATEMENT at Rules Cal. Rule ofof Cour,Court, CM-110 [Rev. July 1, 2011] www. courts.ca.gov From: 08/24/2020 15:06 #112 P.003/007 CM-110 CASE NUMBER PLAINTIFF/PETITIONER: Mildred Oliver RG19007799 DEFENDANT/RESPONDENT: City of Oakland, Oakland Police Department, et al. 4. b. Provide a brief statement of the case, including any damages. (if personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, fost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff Mildred Oliver is suing her former employer, the Oakland Police Department, after she suffered discrimination and retaliation for reporting and attempting to initiate prosecution of criminal allegations against her peers. (if more space is needed, check this box and attach a page designated as Attachment 4b.) §. Jury or nonjury trial The party or parties request a jury trial Co a nonjury trial. (if more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. [_] The trial has been set for (date): b. [2] No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): March 2, 2021, March 15, 2121; March 29, 2021, April 19, 2021, September 20, 2021, and November 15, 2021 7. Estimated length of trial The party or parties estimate that the tria! will take (check one): a. [LZ] days (specify number): 12 days b. C4 hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial [Y] by the attorney or party listed in the caption [__] by the following: a, Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number. e. E-mail address: g. Party represented: [7] Additional representation is described in Attachment 8. 9, Preference ((“] This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel has [J has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. {2) For self-represented parties: Party (7) has [J has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) [[=] This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) [[_] Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141,11. (3) [7] This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): MATT Rev July 4.2611 CASE MANAGEMENT STATEMENT Page 2of8 From: 08/24/2020 15:06 #112 P.004/007 CM-110 PLAINTIFF/PETITIONER: Mildred Oliver ICASE NUMBER Le : ; RG19007799 DEFENDANT/RESPONDENT: City of Oakland, Oakland Police Department, et al. 10. ¢. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check ail that apply and provide the specified information): The party or parties completing | if the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR | indicate the status of the processes (attach a copy of the parties’ ADR processes (check ail that apply): | stipulation): ra | Mediation session not yet scheduled wa Co Mediation session scheduled for (date): (1) Mediation Cc] Agreed to complete mediation by (date): [£1] Mediation completed on (date): (41 settlement conf ettiement conference not t yet yet schedule scheduled (2) Settlement ara] CI Settlement conference scheduled for (date): conference Cy Agreed toe complete settlement conference by (date): [-] Settlement conference completed on (date): [J Neutral evaluation not yet scheduled ; co | aa | Neutral evaluation scheduled for (date): (3) Neutral evaluation CI Agreed to complete neutral evaluation by (date): (J Neutral evaluation completed on (date): CI Judicial arbitration not yet scheduled (4) Nonbinding judicial co [2] Judicial arbitration scheduled for (date): arbitration co Agreed to complete judicial arbitration by (date): [7] Judicia! arbitration completed on (date): C7) pritivate arbitration roitrati heduled not yet schedule (5) Binding private cl Cc] Private arbitration scheduled for (date): arbitration [1 Agreed to compiete private arbitration by (date): [J Private arbitration completed on (date): Coy ADR session not yet scheduled co | | ADR session scheduled for (date): (6) Other (specify): | Agreed to complete ADR session by (date): [-] ADR completed on (date): Page 3 of CMO [Rev daly 4, 20771 CASE MANAGEMENT STATEMENT From: 08/24/2020 15:07 #112 P.0O5/007 PLAINTIFF/PETITIONER: Mildred Oliver CASE NUMBER: - . . RG19007799 DEFENDANT/RESPONDENT: City of Oakland, Oakland Police Department, et al. 11. Insurance a. [_] Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights) [[_] Yes [7] No c. [_] Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status [__] Bankruptcy [7] other (specify): Status: 13. Related cases, cor , and coordination a. [_] There are companion, underlying, or related cases. {1) Name of case: (2) Name of court: (3) Case number: (4) Status: [["] Additional cases are described in Attachment 13a. b. CJ) Amotionto [77 consolidate [—_] coordinate will be filed by (name party): 14. Bifurcation The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions [J The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues). 16. Discovery a. [] The party or parties have completed all discovery. b. The following discovery will be compieted by the date specified (describe all anticipated discovery): Party Description Date Plaintiff Written discovery to defendant/third parties March, 2121 Plaintiff Non-expert depositions/discovery March, 2121 Plaintiff Expert discovery March, 2121 c. [_] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011) CASE MANAGEMENT STATEMENT Page 4 of § From: 08/24/2020 15:07 #112 P.0O6/007 CM-110 PLAINTIFF/PETITIONER: Mildred Oliver CASE NUMBER —~ RG190077: DEFENDANT/RESPONDENT: City of Oakland, Oakland Police Department, et al. 9007799 17. Economic titigation a. (_] This is a fimited civil case (i.e., the amount demanded is $25,000 or tess) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. [7] This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues [7] the party or parties request that the following additional matters be considered or determined at the case management conference (specify}: 19, Meet and confer a. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): It is premature to narrow issues but the parties' counsel are hopeful they will continue to explore that possibility. 20. Total number of pages attached (if any): | am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: August 24, 2020 John Houston Scott br Lh shy Sabie a {TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Z (TYPE OR PRINT NAME) {SIGNATURE OF PARTY OR ATTORNEY) [-] Additional signatures are attached. OM-110 fRev. July1, 2041 CASE MANAGEMENT STATEMENT Page 8 of From: 08/24/2020 15:07 #112 P.007/007 PROOF OF SERVICE (Mildred Oliver v. City of Oakland, et al., Case No. RG19007799) I, Sherry Alhawwash, declare as follows: I am a citizen of the United States, over the age of eighteen years and not a party to the within entitled action. My business address is 1388 Sutter Street, Suite 715, San Francisco, California 94109. On August 24 2020, I served the attached: PLAINTIFF’S CASE MANAGEMENT STATEMENT the interested party(ies) named below: Michael J. Quirk, Deputy City Attorney David A, Pereda, Special Counsel Oakland City Attorney’s Office One Frank H. Ogawa Plaza, 6" Floor Oakland, CA 94612 I served the attached document(s) in the manner indicated below: X BY MAIL: I caused true and correct copy(ies) of the above documents to be placed and sealed in envelope(s) addressed to the addressee(s) named above and, following ordinary business practices, placed said envelope(s) at 1388 Sutter Street, Suite 715, San Francisco, CA 94109, for collection and mailing with the United States Postal Service and there is delivery by the United States Post Office at said address(es). In the ordinary course of business, correspondence placed for collection on a particular day is deposited with the United States Postal Service that same day. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed August 24, 2020 at San Francisco, California. Sherry Al ash PROOF OF SERVICE