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Demurrer to the Second Amended Complaint and Motion to Compel Further Responses to Special Interrogatories, Form Interrogatories, and Requests for Production and Request for Monetary Sanctions by Defendants Foothill-De Anza Community College District, Patricia Buchner, Anita Muthy Ala-Kandula and Lorrie Ranck

Factual and Procedural Background

This is an action for age discrimination. In 2016, plaintiff Gregory Steshenko (“Plaintiff”) (self-represented), 55 years old, completed a phlebotomy training program and obtained a phlebotomist state license, the prerequisite for admission to the Medical Laboratory Technician (“MLT”) program. (See Second Amended Complaint [“SAC”] at ¶ 10.) Plaintiff thereafter enrolled in the MLT program at De Anza College. (Ibid.)

After Plaintiff started the program, defendant Patricia Buchner (“Buchner”) notified him that he needed to complete an “externship” at a clinical agency in order to graduate from the program. (SAC at ¶ 12.) T