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ATTORNEY OR PARTY WITHOUTATTORNEY (Narre, State Bar nurber, and address): r IQROR COGRF ISR OMY y 4;
Lisa Lin Garcia, SBN 260582 | Nicholas W. McKinney, SBN 322792 _ wean bet
Littler Mendelson, P.C. a :
333 Bush Street - Floor 34 2821 HAR 1S PH ke 20
San Francisco, CA 94104 LEY CLEA
‘TELEPHONENO..415-433-1940 FAX NO. (Optional): 415-399-8480, OG if
E-MAILADDRESS (OpionapliQarcia@littler.com | nmckinney@littler.com Vita. 0
ATTORNEY FOR Ware):United Parcel Service, Inc. beet freer 7 ee
- beeury
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Joaquin
street aporess: 180 E Weber Avenue
MAILING ADDRESS:
crryano zip cove:Stockton, CA 95202
BRANCH NAME:
PLAINTIFF/PETITIONER: Shaun Medina
DEFENDANT/RESPONDENT: United Parcel Senice, Inc.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): [J UNLIMITED CASE O sumirep case STK-CV-UWT-2018-0010377
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: March 28, 2021 Time: 8:45 a.m. Dept: 10A
Address of court (if different from the address above):
EI Notice of Intent to Appear by Telephone, by (name): Nicholas W. McKinney
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. BJ This statement is submitted by party (name): Defendant United Parcel Senice, Inc.
b. [1 This statement is submitted jointly by parties (names):
Complaint and cross-complaint (to be answered by plaintiffs and cross-comptainants only)
a. The complaint was filed on (date):
b. C1 The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
a. C1 Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [1 The followingparties 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) (1 have hada default entered against them (specifynames):
c. [J The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
Description of case
a. Type of case in 2 complaint C1 cross-compiaint (Describe, including causes of action):
See attachment A
Page tof 5
Fe Cal Rt fer
“Tudeel Coscia Calera CASE MANAGEMENT STATEMENT Ries oat
CM-410 Rev. July 1, 2011] www.courts.ca gov
‘American LegaNet.th @
ww FormsWoriflow son!CM-110
7 Hi CASE NUMBER:
PLAINTIFF/PETITIONER, Shaun Medina STK-CV-UWT-2019-0010377
| DEFENDANT/RESPONDENT: United Parcel Senice, Inc.
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 (o date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiffs Complaint arises out of Plaintiffs employment with Defendant United Parcel Senice, Inc. ("UPS").
Plaintiff alleges that UPS discriminated, harassed, retaliated against him, and wrongfully terminated him based on
his age, race, national origin, ancestry, and disability. Plaintiff also alleges that UPS failed to accommodate and
failed to engage in the interactive process regarding his alleged disability during his employment. UPS denies the
allegations.
Ds (if more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury ornonjury trial
‘The party or parties request (1) ajury trial 22 a nonjury trial. (lf more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. C1 The trial has been set for (date):
b. EJ No trial date has been set. This case willbe 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):
See Attachment B
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. Ed days (specify number): 5 days ,
b. [1 _ hours (short causes) (specify):
8. Trial representation (tobe answered for each party)
The party or parties willbe represented at trial {by the attorney or party listed in the caption Oo by the follow ing:
a. Attorney:
b, Firm
c. Address:
d. Telephone number: f. Fax number:
e. Email address: g. Party represented:
O Additional representation is described in Attachment 8.
9. Preference
Os Miis case is entitled to preference (spscify code section):
10. Alternative dis pute 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 courtunder rule 3,221 for information about the processes available through the
courtand community programs in this case.
(1) For parties represented by counsel Counsel has 1) hasnot 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 [] has (1 has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) (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) C1 Aaintiff etects 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) I This case is exempt from judicial arbitration under rute 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specifyexemption):
Rule 3.811(b)(8) (multiple causes of action); case value
CMT Re. ys, 201) CASE MANAGEMENT STATEMENT / Page2ot§CM-110
PLAINTIFF/PETITIONER: Medi: CASE NUMBER:
|_ Shaun Medina STK-CV-UWT-2019-0010377
IDEFENDANT/RESPONDENT: United Parcel Service, Inc.
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 all that apply and provide the specified information):
The party or parties completing | ff the party or parties corrpleting 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 (atiach a copy of the parties’ ADR
processes (check all that apply): | stipulation):
0 Nediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation w
oa
Agreed to complete mediation by (date):
&
Mediation completed on (date): 8/26/2020
Settlement conference not yet scheduled
(2) Settlement R Settlement conference scheduled for (dafe).
conference Agreed to complete settlement conference by (date) :
OOO®w
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation oO
Agreed to complete neutral evaluation by (date):
oo0o0a
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
Foti B dini Judicial arbitration scheduled for (date):
(4) Nonbinding judicial g
arbitration Agreed to complete judicial arbitration by (date):
noada
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(8) Binding private oO Private arbitration scheduled for (date):
arbitration Agreed to complete private arbitration by (date):
ooo0
Private arbitration completed on (date):
ADR session not yet scheduled
(6) Other (specify: 4 ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ooad
ADR completed on (date):
CM-*10 (Rex Jy 4, 2911] CASE MANAGEMENT STATEMENTCM-110
PLAINTIFF/PETITIONER: Medi CASE NUMBER:
er Shaun ne . STK-CV-UWT-2019-0010377
DEFENDANT/RESPONDENT: United Parcel Senice, inc.
11. Insurance
a. 1 Insurance carrier, if any, for party filing this statement (name):
b, Reservation of rights: Cl Yes 0 No
c. [1 Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affectthe court's jurisdiction or processing of this case and describe the status.
O Bankruptey C1 Other (specify):
Status:
13. Related cases, consolidation, and coordination
a, O There are companion, underlying, or related cases.
(1) Name of casi
(2) Name of cou!
(3) Case number:
(4) Status:
O Additional cases are described in Attachment 13a.
b. O Anntion to (1 consolidate Os coordinate will be filed by (name party):
14. Bifurcation
O te 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, (ype of motion, and reasons):
15, Other motions
The party or parties expect to file the follow ing motions before trial (specify moving party, type of motion, and issues):
Motion for Summary Judgment and/or Adjudication; discovery motion (if needed).
16. Discovery
a O The party or parties have completed all discovery.
b BM The following discovery will be completed by the date specified (describe all anticipated discovery):
Party: Description Date
Defendant Written Discovery August 2024
Defendant Plaintiffs Deposition August 2021
Defendant Third Party Depositions October 2021
Defendant Expert Discovery December 2021
c. (1 The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
HO Re ay HF CASE MANAGEMENT STATEMENT Pogedors
American LegaNet
ie FormstvorkFlowCM-110
. i ‘CASE NUMBER:
PLAINTIFF/PETITIONER: Shaun Medina STK-CV.UWT.2019-0010377
| DEFENDANT/RESPONDENT: United Parcel Senice, Inc.
17. Economic litigation
a. (1 This is alimited 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. 01 This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery willbe filed (ifchecked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18, Otherissues
(1 The party or parties request that the follow ing additional matters be considered or determined at the case management
conference (specify):
19. Meetand confer
a. [El 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 (ifnot, expiain):
b. Aftermeeting 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 (ifany): 2
lam completely familiar w ith 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: March 15, 2020
Nicholas W. McKinney aE ee
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY ORATTORNEY)
»
(TYPE OR PRINT NAME) (SIGNATURE GF PARTY ORATTORNEY)
D1 Additional signatures are attached.
4812-2135-2416.1
CMa Ren dtyt, 207) CASE MANAGEMENT STATEMENT Page otsAttachment A to Defendant United Parcel Service, Inc.’s Case Manage ment Statement
March 29, 2021
4a
On February 13, 2019, Plaintiff filed the instant action against Defendants United Parcel Service,
Inc. (“UPS”) and “Vivian Doe” in Alameda Superior Court.
Plaintiff's Complaint asserts fourteen causes of action: ({) discrimination on the bases of age, rage,
national origin, ancestry, and disability in violation of FEHA; (2) harassment on the bases of age,
tage, national origin, ancestry, and disability in violation of FEHA; (3) wrongful termination in
violation of public policy; (4) failure to provide reasonable accommodation in violation of FEHA;
(5) failure to engage in the interactive process in violation of FEHA; (6) failure to prevent
discrimination and harassment and retaliation in violation of FEHA; (7) retaliation for taking
CFRA leave in violation of FEHA; (8) retaliation for engaging in protected activity in violation of
FEHA; (9) breach of express oral contract not to terminate employment without good cause; (10)
breach of implied-in-fact contract not to terminate employment without good cause; (11) negligent
hiring, supervision and retention; (12) intentional infliction of emotional distress; (13) violation of
Labor Code § 1102.5; and (14) violation of Labor Code § 6310.
On May 24, 2019, Plaintiff and Defendant UPS (the “Parties”) stipulated to transfer the action to
the proper venue of San Joaquin Superior Court.
On May 31, 2019, Alameda Superior Court granted the Parties’ stipulation and ordered the action
transferred to San Joaquin Superior Court.
On September 19, 2019, Plaintiff and UPS filed a Joint Stipulation in which they agreed that
“Vivian Doe” identified in Plaintiff's’ Complaint was Vivian Joshua, and agreed to dismiss
individua tly named Defendant Vivian Joshua without prejudice.
On September 23, 2019, this Court granted the Parties’ Stipulation and dismissed individual
Defendant Vivian Joshua from this action without prejudice.
4850-8096-4064,1 101661. 1006Attachment B to Defendant United Parcel Service, Inc.’s Case Management Statement
March 29, 2021
6.c
Defendant's attorneys will not be available for trial on the following dates:
» 4/22/21 - 4/23/21 (arbitration)
» 5/10-21/21 (trial)
© = 6/17/21-6/18/21 (arbitration)
© =7/12-15/21 (arbitration)
© 7/26/21 - 7/27/21 (arbitration)
« 8/30/21 — 9/2/21 (arbitration)
* 9/13-16/21 (arbitration)
© —9/28-10/1/21 (arbitration)
© =10/4/21-10/6/21 (arbitration)
© 11/5-19/21 (trial)
= 1/10/22 - 1/12/22 (arbitration)
«= 2/4-18/22 (trial)
Also: October through January is the busy season for UPS, so best not to have trial during these
months.
4828-9692-8993.1 101661, 1006PROOF OF SERVICE
I am a resident of the State of California, over the age of eighteen years, and not a
party to the within action. My business address is 500 Capitol Mall, Suite 2000, Sacramento,
California 95814. On March 15, 2021, 1 served the within document(s):
DEFENDANT'S CASE MANAGEMENT STATEMENT
o 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. No error was reported by the fax machine that I used. A copy of the record
of the fax transmission, which I printed out, is attached.
o By United States Mail. 1 enclosed the documents in a sealed envelope or
package addressed to the persons at the addresses below and (specify one):
deposited the sealed envelope with the United States Postal Service, with the
postage fully prepaid.
C Placed the envelope for collection and mailing, following our ordinary
business practices. I am readily familiar with this business'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, in a sealed
envelope with postage fully prepaid.
I am a resident or employed in the county where the mailing occurred. The
envelope or package was placed in the mail at: Sacramento, California.
o By Overnight Delivery. I deposited a true copy of the same enclosed in a sealed
envelope, with delivery fees provided for, in an overnight delivery service pick up
box or office designated for overnight delivery, and addressed as set forth below.
oO By Personal Delivery. I personally delivered the documents to the persons at the
addresses listed below. (1) For a party represented by an attorney, delivery was
made to the attorney or at the attorney's office by leaving the documents, in an
envelope or package clearly labeled to identify the attorney being served, with a
receptionist or an individual in charge of the office, between the hours of nine in
the morning and five in the evening. (2) For a party, delivery was made to the party
or by leaving the documents at the party's residence with some person not younger
than 18 years of age between the hours of eight in the morning and six in the
evening.
PROOF OF SERVICEBy Messenger Service. | served the documents by placing them in an envelope or
1
oO
package addressed to the persons at the addresses listed below and providing them
2 to a professional messenger service for service. (A declaration by the messenger
3 must accompany this Proof of Service or be contained in the Declaration of
Messenger below.)
4
rc] By Electronic Service. Based on a court order or an agreement of the parties to
5 accept electronic service, | caused the documents to be sent to the persons at the
6 electronic service addresses listed below.
Nazo Koulloukian Attorneys for Plaintiffs
7 nazo@koullaw.com SHAUN MEDINA
Christine Harmandayan
8 christine@koullaw.com
9 I declare under penalty of perjury under the laws of the State of California that the
10 || above is true and correct. Executed on March 15, 2021, at Sacramento, California.
Fpcentinictae
Lauren Michel
28
LITTLER MENDELSON P.C.4837-3476-6035.1 101661, 1006 2.
" PROOF OF SERVICE
Preview
Qa &, ce 8g . £4 .epwen cM-110 S > ATTORNEY OR PARTY WITHOUTATTORNEY (Narre, State Bar nurber, and address): r IQROR COGRF ISR OMY y 4; Lisa Lin Garcia, SBN 260582 | Nicholas W. McKinney, SBN 322792 _ wean bet Littler Mendelson, P.C. a : 333 Bush Street - Floor 34 2821 HAR 1S PH ke 20 San Francisco, CA 94104 LEY CLEA ‘TELEPHONENO..415-433-1940 FAX NO. (Optional): 415-399-8480, OG if E-MAILADDRESS (OpionapliQarcia@littler.com | nmckinney@littler.com Vita. 0 ATTORNEY FOR Ware):United Parcel Service, Inc. beet freer 7 ee - beeury SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Joaquin street aporess: 180 E Weber Avenue MAILING ADDRESS: crryano zip cove:Stockton, CA 95202 BRANCH NAME: PLAINTIFF/PETITIONER: Shaun Medina DEFENDANT/RESPONDENT: United Parcel Senice, Inc. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): [J UNLIMITED CASE O sumirep case STK-CV-UWT-2018-0010377 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: March 28, 2021 Time: 8:45 a.m. Dept: 10A Address of court (if different from the address above): EI Notice of Intent to Appear by Telephone, by (name): Nicholas W. McKinney INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. BJ This statement is submitted by party (name): Defendant United Parcel Senice, Inc. b. [1 This statement is submitted jointly by parties (names): Complaint and cross-complaint (to be answered by plaintiffs and cross-comptainants only) a. The complaint was filed on (date): b. C1 The cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) a. C1 Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [1 The followingparties 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) (1 have hada default entered against them (specifynames): c. [J The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): Description of case a. Type of case in 2 complaint C1 cross-compiaint (Describe, including causes of action): See attachment A Page tof 5 Fe Cal Rt fer “Tudeel Coscia Calera CASE MANAGEMENT STATEMENT Ries oat CM-410 Rev. July 1, 2011] www.courts.ca gov ‘American LegaNet.th @ ww FormsWoriflow son!CM-110 7 Hi CASE NUMBER: PLAINTIFF/PETITIONER, Shaun Medina STK-CV-UWT-2019-0010377 | DEFENDANT/RESPONDENT: United Parcel Senice, Inc. 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 (o date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiffs Complaint arises out of Plaintiffs employment with Defendant United Parcel Senice, Inc. ("UPS"). Plaintiff alleges that UPS discriminated, harassed, retaliated against him, and wrongfully terminated him based on his age, race, national origin, ancestry, and disability. Plaintiff also alleges that UPS failed to accommodate and failed to engage in the interactive process regarding his alleged disability during his employment. UPS denies the allegations. Ds (if more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury ornonjury trial ‘The party or parties request (1) ajury trial 22 a nonjury trial. (lf more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. C1 The trial has been set for (date): b. EJ No trial date has been set. This case willbe 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): See Attachment B 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. Ed days (specify number): 5 days , b. [1 _ hours (short causes) (specify): 8. Trial representation (tobe answered for each party) The party or parties willbe represented at trial {by the attorney or party listed in the caption Oo by the follow ing: a. Attorney: b, Firm c. Address: d. Telephone number: f. Fax number: e. Email address: g. Party represented: O Additional representation is described in Attachment 8. 9. Preference Os Miis case is entitled to preference (spscify code section): 10. Alternative dis pute 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 courtunder rule 3,221 for information about the processes available through the courtand community programs in this case. (1) For parties represented by counsel Counsel has 1) hasnot 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 [] has (1 has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) (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) C1 Aaintiff etects 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) I This case is exempt from judicial arbitration under rute 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specifyexemption): Rule 3.811(b)(8) (multiple causes of action); case value CMT Re. ys, 201) CASE MANAGEMENT STATEMENT / Page2ot§CM-110 PLAINTIFF/PETITIONER: Medi: CASE NUMBER: |_ Shaun Medina STK-CV-UWT-2019-0010377 IDEFENDANT/RESPONDENT: United Parcel Service, Inc. 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 all that apply and provide the specified information): The party or parties completing | ff the party or parties corrpleting 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 (atiach a copy of the parties’ ADR processes (check all that apply): | stipulation): 0 Nediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation w oa Agreed to complete mediation by (date): & Mediation completed on (date): 8/26/2020 Settlement conference not yet scheduled (2) Settlement R Settlement conference scheduled for (dafe). conference Agreed to complete settlement conference by (date) : OOO®w Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation oO Agreed to complete neutral evaluation by (date): oo0o0a Neutral evaluation completed on (date): Judicial arbitration not yet scheduled Foti B dini Judicial arbitration scheduled for (date): (4) Nonbinding judicial g arbitration Agreed to complete judicial arbitration by (date): noada Judicial arbitration completed on (date): Private arbitration not yet scheduled (8) Binding private oO Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): ooo0 Private arbitration completed on (date): ADR session not yet scheduled (6) Other (specify: 4 ADR session scheduled for (date): Agreed to complete ADR session by (date): ooad ADR completed on (date): CM-*10 (Rex Jy 4, 2911] CASE MANAGEMENT STATEMENTCM-110 PLAINTIFF/PETITIONER: Medi CASE NUMBER: er Shaun ne . STK-CV-UWT-2019-0010377 DEFENDANT/RESPONDENT: United Parcel Senice, inc. 11. Insurance a. 1 Insurance carrier, if any, for party filing this statement (name): b, Reservation of rights: Cl Yes 0 No c. [1 Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affectthe court's jurisdiction or processing of this case and describe the status. O Bankruptey C1 Other (specify): Status: 13. Related cases, consolidation, and coordination a, O There are companion, underlying, or related cases. (1) Name of casi (2) Name of cou! (3) Case number: (4) Status: O Additional cases are described in Attachment 13a. b. O Anntion to (1 consolidate Os coordinate will be filed by (name party): 14. Bifurcation O te 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, (ype of motion, and reasons): 15, Other motions The party or parties expect to file the follow ing motions before trial (specify moving party, type of motion, and issues): Motion for Summary Judgment and/or Adjudication; discovery motion (if needed). 16. Discovery a O The party or parties have completed all discovery. b BM The following discovery will be completed by the date specified (describe all anticipated discovery): Party: Description Date Defendant Written Discovery August 2024 Defendant Plaintiffs Deposition August 2021 Defendant Third Party Depositions October 2021 Defendant Expert Discovery December 2021 c. (1 The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): HO Re ay HF CASE MANAGEMENT STATEMENT Pogedors American LegaNet ie FormstvorkFlowCM-110 . i ‘CASE NUMBER: PLAINTIFF/PETITIONER: Shaun Medina STK-CV.UWT.2019-0010377 | DEFENDANT/RESPONDENT: United Parcel Senice, Inc. 17. Economic litigation a. (1 This is alimited 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. 01 This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery willbe filed (ifchecked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18, Otherissues (1 The party or parties request that the follow ing additional matters be considered or determined at the case management conference (specify): 19. Meetand confer a. [El 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 (ifnot, expiain): b. Aftermeeting 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 (ifany): 2 lam completely familiar w ith 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: March 15, 2020 Nicholas W. McKinney aE ee (TYPE OR PRINT NAME) (SIGNATURE OF PARTY ORATTORNEY) » (TYPE OR PRINT NAME) (SIGNATURE GF PARTY ORATTORNEY) D1 Additional signatures are attached. 4812-2135-2416.1 CMa Ren dtyt, 207) CASE MANAGEMENT STATEMENT Page otsAttachment A to Defendant United Parcel Service, Inc.’s Case Manage ment Statement March 29, 2021 4a On February 13, 2019, Plaintiff filed the instant action against Defendants United Parcel Service, Inc. (“UPS”) and “Vivian Doe” in Alameda Superior Court. Plaintiff's Complaint asserts fourteen causes of action: ({) discrimination on the bases of age, rage, national origin, ancestry, and disability in violation of FEHA; (2) harassment on the bases of age, tage, national origin, ancestry, and disability in violation of FEHA; (3) wrongful termination in violation of public policy; (4) failure to provide reasonable accommodation in violation of FEHA; (5) failure to engage in the interactive process in violation of FEHA; (6) failure to prevent discrimination and harassment and retaliation in violation of FEHA; (7) retaliation for taking CFRA leave in violation of FEHA; (8) retaliation for engaging in protected activity in violation of FEHA; (9) breach of express oral contract not to terminate employment without good cause; (10) breach of implied-in-fact contract not to terminate employment without good cause; (11) negligent hiring, supervision and retention; (12) intentional infliction of emotional distress; (13) violation of Labor Code § 1102.5; and (14) violation of Labor Code § 6310. On May 24, 2019, Plaintiff and Defendant UPS (the “Parties”) stipulated to transfer the action to the proper venue of San Joaquin Superior Court. On May 31, 2019, Alameda Superior Court granted the Parties’ stipulation and ordered the action transferred to San Joaquin Superior Court. On September 19, 2019, Plaintiff and UPS filed a Joint Stipulation in which they agreed that “Vivian Doe” identified in Plaintiff's’ Complaint was Vivian Joshua, and agreed to dismiss individua tly named Defendant Vivian Joshua without prejudice. On September 23, 2019, this Court granted the Parties’ Stipulation and dismissed individual Defendant Vivian Joshua from this action without prejudice. 4850-8096-4064,1 101661. 1006Attachment B to Defendant United Parcel Service, Inc.’s Case Management Statement March 29, 2021 6.c Defendant's attorneys will not be available for trial on the following dates: » 4/22/21 - 4/23/21 (arbitration) » 5/10-21/21 (trial) © = 6/17/21-6/18/21 (arbitration) © =7/12-15/21 (arbitration) © 7/26/21 - 7/27/21 (arbitration) « 8/30/21 — 9/2/21 (arbitration) * 9/13-16/21 (arbitration) © —9/28-10/1/21 (arbitration) © =10/4/21-10/6/21 (arbitration) © 11/5-19/21 (trial) = 1/10/22 - 1/12/22 (arbitration) «= 2/4-18/22 (trial) Also: October through January is the busy season for UPS, so best not to have trial during these months. 4828-9692-8993.1 101661, 1006PROOF OF SERVICE I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is 500 Capitol Mall, Suite 2000, Sacramento, California 95814. On March 15, 2021, 1 served the within document(s): DEFENDANT'S CASE MANAGEMENT STATEMENT o 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. No error was reported by the fax machine that I used. A copy of the record of the fax transmission, which I printed out, is attached. o By United States Mail. 1 enclosed the documents in a sealed envelope or package addressed to the persons at the addresses below and (specify one): deposited the sealed envelope with the United States Postal Service, with the postage fully prepaid. C Placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with this business'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, in a sealed envelope with postage fully prepaid. I am a resident or employed in the county where the mailing occurred. The envelope or package was placed in the mail at: Sacramento, California. o By Overnight Delivery. I deposited a true copy of the same enclosed in a sealed envelope, with delivery fees provided for, in an overnight delivery service pick up box or office designated for overnight delivery, and addressed as set forth below. oO By Personal Delivery. I personally delivered the documents to the persons at the addresses listed below. (1) For a party represented by an attorney, delivery was made to the attorney or at the attorney's office by leaving the documents, in an envelope or package clearly labeled to identify the attorney being served, with a receptionist or an individual in charge of the office, between the hours of nine in the morning and five in the evening. (2) For a party, delivery was made to the party or by leaving the documents at the party's residence with some person not younger than 18 years of age between the hours of eight in the morning and six in the evening. PROOF OF SERVICEBy Messenger Service. | served the documents by placing them in an envelope or 1 oO package addressed to the persons at the addresses listed below and providing them 2 to a professional messenger service for service. (A declaration by the messenger 3 must accompany this Proof of Service or be contained in the Declaration of Messenger below.) 4 rc] By Electronic Service. Based on a court order or an agreement of the parties to 5 accept electronic service, | caused the documents to be sent to the persons at the 6 electronic service addresses listed below. Nazo Koulloukian Attorneys for Plaintiffs 7 nazo@koullaw.com SHAUN MEDINA Christine Harmandayan 8 christine@koullaw.com 9 I declare under penalty of perjury under the laws of the State of California that the 10 || above is true and correct. Executed on March 15, 2021, at Sacramento, California. Fpcentinictae Lauren Michel 28 LITTLER MENDELSON P.C.4837-3476-6035.1 101661, 1006 2. " PROOF OF SERVICE