Preview
To: Page3of9 2020-08-28 17:59:47 (GMT) 15102253600 From: Oakland City Attorney Office
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FILED BY E-DELIVE Ryo
BARBARA J. PARKER, City Attorney - SBN 069722 ALAMEDA COUNTY
MARIA BEE, Chief Assistant City Attormey - SBN 167716 August 28, 2020
DAVID PEREDA, Special Counsel - SBN 237982 CLERK OF
TeLerHone no. (510) 238-6520 FAX NO. (Optional: (510) 238-6500 THE SUPERIOR COURT
E-MAIL. ADDRESS (Optionay: DPereda@oaklandcityattorney.org By Antoinette Jackson, Deputy
ATTORNEY FOR (Name): CITY OF OAKLAND CASE NUMBER:
SUPERIOR COURT OF CALIFORNIA, COUNTY OF ALAMEDA RG19007799
sTREET appress: 1225 Fallon Street
MAILING ADDRESS
CITY AND ZIP CODE: Oakland, CA 94612
BRANCH NAME: Rene’ C. Davidson Courthouse
PLAINTIFF/PETITIONER: MILDRED OLIVER
DEFENDANT/RESPONDENT: CITY OF OAKLAND
CASE MANAGEMENT STATEMENT CASE NUMBER
(Check one): UNLIMITED CASE [“) uimirep case RG19007799
(Amountdemanded (Amount demanded is $25,000
exceeds $25,000) or less}
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 09-8-2020 Time: 9:00 a.m. Dept.: 25 Div. Room:
Address of court (if different from the address above):
1221 Oak Street, Oakland California 94612
Notice of Intent to Appear by Telephone, by (name): David Pereda
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): Defendant City of Oakland
b. [_] This statement is submitted Jointly by parties (names):
2. Complaintandcross-complaint (fo be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. CI The cross-compiaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a LC] alt parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [__] The following parties named in the complaint or cross-complaint
{1) [C1] have not been served {specify names and explain why nop:
(2) [~_] have been served but have not appeared and have not been dismissed (specify names):
{3} [1 have had a default entered against them (specify names):
ec. LC] 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 complaint [1 cross-compiaint (Describe, including causes of action):
Plaintiff asserts claims for alleged discrimination--based on race and gender--and retaliation under FEHA and
the state's whistleblower statute.
Page 1 of §
Form Adopted for Mandatory Use Cal, Rutes of Court,
Judicial Council of California CASE MANAGEMENT STATEMENT rules 3,720-3.730
CM-110 [Rev. July 1, 2014} www. cours.ca.gov
To: Page4of9 2020-08-28 17:59:47 (GMT) 15102253600 From: Oakland City Attorney Office
CM-110
PLAINTIFF/PETITIONER: MILDRED OLIVER CASE NUMBER:
-_ RG19007799
DEFENDANT/RESPONDENT: CITY OF OAKLAND
4. b. Provide a brief statement of the case, including any damages. (/f personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. {f equitable relief is sought, describe the nature of the relief.)
Plaintiff claims that she endured discrimination, a hostile work environment, and retaliation before she retired
from the Oakland Police Department. The City denies her claims. While Plaintiff was assigned to the Internal
Affairs Division, she investigated a disturbing sexual-misconduct scandal. Due to deficiencies in the
investigation, it was reassigned. In a separate, unrelated matter, Plaintiff received discipline pursuant to policy.
L__] dfmore space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request [_] a jury trial @ nonjury trial. (if more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. CO The trial has been set for (date):
b. 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):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 10 court days
b. [] hours (short causes) (specify):
8. Trial representation (fo be answered for each party)
The party or parties will be represented at trial [[y_] by the attorney or party listed inthe caption [____] by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
L__] 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 [1 has not provided the ADR information package identified
in rule 3.2271 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party C_] has CJ 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) ["7] 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) 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):
Alleged damages exceed statutory limit.
CMO fRev, July 1, 2014} CASE MANAGEMENT STATEMENT Page
2 of 5
To: Page 5of 9 2020-08-28 17:59:47 (GMT) 15102253600 From: Oakland City Attorney Office
CM-110
| PLAINTIFF/PETITIONER: MILDRED OLIVER CASE NUMBER:
RG19007799
DEFENDANT/RESPONDENT: CITY OF OAKLAND
10. c. 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 all that apply and provide the specified information):
The party or parties completing lf 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 aif that apply): stipulation):
Mediation session not yet scheduled
OOOU;OO00/0CO00;/OO00;CUuU;UuUs
Mediation session scheduled for (date):
(1) Mediation
Agreed tc complete mediation by (dafe):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed an (date):
Judicial arbitration not yet scheduled
(4) Nenbinding judicial
Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
(5) Binding private
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (dafe}:
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
CN-110 (Rev. July 1, 2017) Page 3 of 5
CASE MANAGEMENT STATEMENT
To: Page6of9 2020-08-28 17:59:47 (GMT) 15102253600 From: Oakland City Attorney Office
PLAINTIFF/PETITIONER: MILDRED OLIVER CASE NUNBER:
F DEFENDANT/RESPONDENT: CITY OF OAKLAND
RG19007799
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.
[C7] Bankruptey [*) Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. [C_] There are companion, underlying, or related cases.
{1} Name of case:
(2) Name of court:
{3) Case number:
(4) Status:
[J Additional cases are described in Attachment 13a.
b. [_]Amotionto [__] consolidate [J 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
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
The City may file a summary judgment motion.
16. Discovery
a. [_] The party or parties have completed all discovery.
b. [7] The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
City of Oakland Initial written discovery August 2021
City of Oakland Depositions August 2021
City of Oakland Follow-up written discovery October 2021
City of Oakland Expert discovery Per C.C.P.
c. [_] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2014}
CASE MANAGEMENT STATEMENT Page
4 of 5
To: Page7of9 2020-08-28 17:59:47 (GMT) 15102253600 From: Oakland City Attorney Office
CM-110
PLAINTIFF/PETITIONER: MILDRED OLIVER CASE NUMBER
— RG19007799
DEFENDANT/RESPONDENT: CITY OF OAKLAND
17. Economic litigation
a. [_] This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. (__] 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 fifigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
C__] The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meetand 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 nat, 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):
20. Total number of pages attached (if any): 0
| 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 25, 2020
David Pereda /s/ >
(TYPE OR PRINT NAME) {SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME}
» (SIGNATURE OF PARTY OR ATTORNEY)
[) Additional signatures are attached.
OM-110 [Rev Jufy 1, 2044) CASE MANAGEMENT STATEMENT Page § of &
To: Page 8 of 9 2020-08-28 17:59:47 (GMT) 15102253600 From: Oakland City Attorney Office
PROOF OF SERVICE
Mildred L. Oliver v. City of Oakland, Oakland Police Department, and Does1-25, inclusive
Alameda County Superior Court Case No. RG 19007799
lama resident of the State of California, over the age of cighteen years, and not a party to
the within action. My business address is City Hall, One Frank H. Ogawa Plaza, 6th Floor,
Oakland, California 94612. On the date set forth below I served the within documents:
DEFENDANT CITY OF OAKLAND’S CASE MANAGEMENT STATEMENT
oO By United States mail. I enclosed the documents in a sealed envelope or package
addressed to the persons at the address(s)es listed below and (specify one):
O)Deposited the sealed envelope with the United States Postal Service, with the
postage fully prepaid.
Placed the sealed envelope for collection and mailing, following our ordinary
business practices. | am readily familiar with the City of Oakland’s practice for
collecting and processing correspondence for mailing. On the same day that
correspondence is placed for collection and mailing, it is deposited in the ordinary
course of business with the United States Postal Service, with postage fully
prepaid.
oO By messenger service. I served the documents by placing them in an envelope or
package addressed to the persons at the address(es) listed below and providing them to
the professional messenger service for service.
Oo By overnight delivery. I enclosed the documents in an envelope or package provided
by an overnight delivery carrier and addressed to the persons at the address(es) listed
below. I placed the envelope or package for collection and overnight delivery at an
office or a regularly utilized drop box of the overnight delivery carrier.
oO By fax transmission. Based on an agreement of the parties to accept service by fax
transmission, I faxed the documents to the persons at the fax numbers listed below.
There was no error reported by the fax machine that I used. Attached is a copy of the
record of the fax transmission.
oO By e-mail transmission. Based on an agreement of the parties to accept service by
electronic transmission, | emailed the documents in PDF format to the persons at the
email address(es) listed below. No error was reported sent by email.
Oo By personal delivery. | personally delivered the document(s) to the person(s) at the
address(es) listed below.
22
John Houston Scott Pamela Y. Price
23 Scott Law Firm P.O. Box. 5843
1388 Sutter Street, Suite 715 Oakland, CA 94605
24 San Francisco, CA 94109 Telephone: (510) 452-0292
Telephone: (415) 561-9600 Email: pamela@pypesq.com
25 Fax: (415) 561-6909
Email: john@scottlawfirm
net Attorney for Plaintify
26
Attorney for Plaintiff
28
PROOF OF SERVICE RG19007799
To: Page9of9 2020-08-28 17:59:47 (GMT) 15102253600 From: Oakland City Attorney Office
1 I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.
Executed on August 28, 2020 at Oakland, California.
Cte (het
Carma Carden
22
23
24
25
26
28
PROOF OF SERVICE RG19007799
Preview
To: Page3of9 2020-08-28 17:59:47 (GMT) 15102253600 From: Oakland City Attorney Office ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FILED BY E-DELIVE Ryo BARBARA J. PARKER, City Attorney - SBN 069722 ALAMEDA COUNTY MARIA BEE, Chief Assistant City Attormey - SBN 167716 August 28, 2020 DAVID PEREDA, Special Counsel - SBN 237982 CLERK OF TeLerHone no. (510) 238-6520 FAX NO. (Optional: (510) 238-6500 THE SUPERIOR COURT E-MAIL. ADDRESS (Optionay: DPereda@oaklandcityattorney.org By Antoinette Jackson, Deputy ATTORNEY FOR (Name): CITY OF OAKLAND CASE NUMBER: SUPERIOR COURT OF CALIFORNIA, COUNTY OF ALAMEDA RG19007799 sTREET appress: 1225 Fallon Street MAILING ADDRESS CITY AND ZIP CODE: Oakland, CA 94612 BRANCH NAME: Rene’ C. Davidson Courthouse PLAINTIFF/PETITIONER: MILDRED OLIVER DEFENDANT/RESPONDENT: CITY OF OAKLAND CASE MANAGEMENT STATEMENT CASE NUMBER (Check one): UNLIMITED CASE [“) uimirep case RG19007799 (Amountdemanded (Amount demanded is $25,000 exceeds $25,000) or less} A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 09-8-2020 Time: 9:00 a.m. Dept.: 25 Div. Room: Address of court (if different from the address above): 1221 Oak Street, Oakland California 94612 Notice of Intent to Appear by Telephone, by (name): David Pereda 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): Defendant City of Oakland b. [_] This statement is submitted Jointly by parties (names): 2. Complaintandcross-complaint (fo be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. CI The cross-compiaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a LC] alt parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [__] The following parties named in the complaint or cross-complaint {1) [C1] have not been served {specify names and explain why nop: (2) [~_] have been served but have not appeared and have not been dismissed (specify names): {3} [1 have had a default entered against them (specify names): ec. LC] 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 complaint [1 cross-compiaint (Describe, including causes of action): Plaintiff asserts claims for alleged discrimination--based on race and gender--and retaliation under FEHA and the state's whistleblower statute. Page 1 of § Form Adopted for Mandatory Use Cal, Rutes of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3,720-3.730 CM-110 [Rev. July 1, 2014} www. cours.ca.gov To: Page4of9 2020-08-28 17:59:47 (GMT) 15102253600 From: Oakland City Attorney Office CM-110 PLAINTIFF/PETITIONER: MILDRED OLIVER CASE NUMBER: -_ RG19007799 DEFENDANT/RESPONDENT: CITY OF OAKLAND 4. b. Provide a brief statement of the case, including any damages. (/f personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. {f equitable relief is sought, describe the nature of the relief.) Plaintiff claims that she endured discrimination, a hostile work environment, and retaliation before she retired from the Oakland Police Department. The City denies her claims. While Plaintiff was assigned to the Internal Affairs Division, she investigated a disturbing sexual-misconduct scandal. Due to deficiencies in the investigation, it was reassigned. In a separate, unrelated matter, Plaintiff received discipline pursuant to policy. L__] dfmore space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request [_] a jury trial @ nonjury trial. (if more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. CO The trial has been set for (date): b. 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): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 10 court days b. [] hours (short causes) (specify): 8. Trial representation (fo be answered for each party) The party or parties will be represented at trial [[y_] by the attorney or party listed inthe caption [____] by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: L__] 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 [1 has not provided the ADR information package identified in rule 3.2271 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party C_] has CJ 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) ["7] 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) 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): Alleged damages exceed statutory limit. CMO fRev, July 1, 2014} CASE MANAGEMENT STATEMENT Page 2 of 5 To: Page 5of 9 2020-08-28 17:59:47 (GMT) 15102253600 From: Oakland City Attorney Office CM-110 | PLAINTIFF/PETITIONER: MILDRED OLIVER CASE NUMBER: RG19007799 DEFENDANT/RESPONDENT: CITY OF OAKLAND 10. c. 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 all that apply and provide the specified information): The party or parties completing lf 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 aif that apply): stipulation): Mediation session not yet scheduled OOOU;OO00/0CO00;/OO00;CUuU;UuUs Mediation session scheduled for (date): (1) Mediation Agreed tc complete mediation by (dafe): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed an (date): Judicial arbitration not yet scheduled (4) Nenbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled Private arbitration scheduled for (date): (5) Binding private arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (dafe}: (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CN-110 (Rev. July 1, 2017) Page 3 of 5 CASE MANAGEMENT STATEMENT To: Page6of9 2020-08-28 17:59:47 (GMT) 15102253600 From: Oakland City Attorney Office PLAINTIFF/PETITIONER: MILDRED OLIVER CASE NUNBER: F DEFENDANT/RESPONDENT: CITY OF OAKLAND RG19007799 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. [C7] Bankruptey [*) Other (specify): Status: 13. Related cases, consolidation, and coordination a. [C_] There are companion, underlying, or related cases. {1} Name of case: (2) Name of court: {3) Case number: (4) Status: [J Additional cases are described in Attachment 13a. b. [_]Amotionto [__] consolidate [J 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 The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): The City may file a summary judgment motion. 16. Discovery a. [_] The party or parties have completed all discovery. b. [7] The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date City of Oakland Initial written discovery August 2021 City of Oakland Depositions August 2021 City of Oakland Follow-up written discovery October 2021 City of Oakland Expert discovery Per C.C.P. c. [_] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2014} CASE MANAGEMENT STATEMENT Page 4 of 5 To: Page7of9 2020-08-28 17:59:47 (GMT) 15102253600 From: Oakland City Attorney Office CM-110 PLAINTIFF/PETITIONER: MILDRED OLIVER CASE NUMBER — RG19007799 DEFENDANT/RESPONDENT: CITY OF OAKLAND 17. Economic litigation a. [_] This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. (__] 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 fifigation procedures relating to discovery or trial should not apply to this case): 18. Other issues C__] The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meetand 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 nat, 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): 20. Total number of pages attached (if any): 0 | 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 25, 2020 David Pereda /s/ > (TYPE OR PRINT NAME) {SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME} » (SIGNATURE OF PARTY OR ATTORNEY) [) Additional signatures are attached. OM-110 [Rev Jufy 1, 2044) CASE MANAGEMENT STATEMENT Page § of & To: Page 8 of 9 2020-08-28 17:59:47 (GMT) 15102253600 From: Oakland City Attorney Office PROOF OF SERVICE Mildred L. Oliver v. City of Oakland, Oakland Police Department, and Does1-25, inclusive Alameda County Superior Court Case No. RG 19007799 lama resident of the State of California, over the age of cighteen years, and not a party to the within action. My business address is City Hall, One Frank H. Ogawa Plaza, 6th Floor, Oakland, California 94612. On the date set forth below I served the within documents: DEFENDANT CITY OF OAKLAND’S CASE MANAGEMENT STATEMENT oO By United States mail. I enclosed the documents in a sealed envelope or package addressed to the persons at the address(s)es listed below and (specify one): O)Deposited the sealed envelope with the United States Postal Service, with the postage fully prepaid. Placed the sealed envelope for collection and mailing, following our ordinary business practices. | am readily familiar with the City of Oakland’s practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service, with postage fully prepaid. oO By messenger service. I served the documents by placing them in an envelope or package addressed to the persons at the address(es) listed below and providing them to the professional messenger service for service. Oo By overnight delivery. I enclosed the documents in an envelope or package provided by an overnight delivery carrier and addressed to the persons at the address(es) listed below. I placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier. oO By fax transmission. Based on an agreement of the parties to accept service by fax transmission, I faxed the documents to the persons at the fax numbers listed below. There was no error reported by the fax machine that I used. Attached is a copy of the record of the fax transmission. oO By e-mail transmission. Based on an agreement of the parties to accept service by electronic transmission, | emailed the documents in PDF format to the persons at the email address(es) listed below. No error was reported sent by email. Oo By personal delivery. | personally delivered the document(s) to the person(s) at the address(es) listed below. 22 John Houston Scott Pamela Y. Price 23 Scott Law Firm P.O. Box. 5843 1388 Sutter Street, Suite 715 Oakland, CA 94605 24 San Francisco, CA 94109 Telephone: (510) 452-0292 Telephone: (415) 561-9600 Email: pamela@pypesq.com 25 Fax: (415) 561-6909 Email: john@scottlawfirm net Attorney for Plaintify 26 Attorney for Plaintiff 28 PROOF OF SERVICE RG19007799 To: Page9of9 2020-08-28 17:59:47 (GMT) 15102253600 From: Oakland City Attorney Office 1 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on August 28, 2020 at Oakland, California. Cte (het Carma Carden 22 23 24 25 26 28 PROOF OF SERVICE RG19007799