Glynn v. City of Stockton

Filing 60

FINAL PRETRIAL ORDER signed by District Judge Kimberly J. Mueller on 9/21/16 ORDERING that the parties shall submit to the court by 10/21/2016, a stipulation andproposed order addressing any supplementation by Mr. Enos. A Settlement Conference is SET for 11/8/2016 at 09:30 AM in Courtroom 24 (CKD) before Magistrate Judge Carolyn K. Delaney. The court shall hear arguments regarding any of the above motions the parties wish decided before trial on 10/7/2016. Any motion a party wants heard on that day shall be briefed in a maximum of five pages per motion, filed by 9/28/2016. Any opposition shall be filed by 10/4/2016, with replies argued at hearing. Jury Trial is SET for 1/30/2017 at 09:00 AM in Courtroom 3 (KJM) before District Jud ge Kimberly J. Mueller. Trial briefs are due on 1/13/2017. Plaintiff's motion for sanctions and attorney's fees is scheduled for hearing on 10/7/2016. Each party is granted 14 days from the date of this order to file objections to the same. (Kastilahn, A)

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JESSICA GLYNN,
Plaintiff,

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v.

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Civ. No. 2:15-cv-00529-KJM-DB

FINAL PRETRIAL ORDER

CITY OF STOCKTON,
Defendant.

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On September 9, 2016, the court conducted a final pretrial conference. Nancy L. McCoy

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and Gary Basham appeared for plaintiff Jessica Glynn; Jesse Maddox appeared for defendant City

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of Stockton.
After hearing, and good cause appearing, the court makes the following findings and

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orders:

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JURISDICTION/VENUE

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Jurisdiction is predicated on 28 U.S.C. § 1331 because this civil action arises in part under

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the laws of the United States. Plaintiff seeks redress for alleged violations of her rights pursuant

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to Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e et seq., as amended (“Title VII”),

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the California Fair Employment and Housing Act, California Government Code sections 12900

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et seq. (“FEHA”), and California Labor Code section 1102.5 (“Section 1102.5”), based on

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unlawful discrimination and retaliation in employment. The court has personal jurisdiction of
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defendant City of Stockton, as defendant is located in this Judicial District, and venue is proper

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pursuant to 28 U.S.C. § 1391(b) because the alleged wrongful conduct of Defendant and the

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events giving rise to plaintiff’s claims arose in this District. Jurisdiction and venue are not

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contested.

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JURY/NON-JURY

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Plaintiff has demanded a jury. Plaintiff has requested six (6) jurors. Defendant requested

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nine (9) jurors. The court shall empanel eight (8) jurors.

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UNDISPUTED FACTS

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1.

The City of Stockton is an incorporated city in the State of California, County of

San Joaquin, and a governmental agency.

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2.

The City of Stockton City Manager’s Office created the new Office of Violence

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Prevention (“OVP”) in or about 2014. The mission of the OVP is to significantly reduce violence

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in Stockton through the implementation of violence prevention and reduction programs and

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strategies.

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3.

The OVP Manager position was created in or about May 2014.

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4.

Defendant City of Stockton offered the position of OVP Manager to plaintiff

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Jessica Glynn on or about September 26, 2014.

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5.

Plaintiff Jessica Glynn signed defendant’s written September 26, 2014 offer of

employment for the OVP Manager position on October 8, 2014.

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6.

Plaintiff began working at the City as the OVP Manager on October 16, 2014.

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7.

Defendant City of Stockton terminated plaintiff’s employment on February 13,

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8.

Plaintiff is a female individual.

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9.

Defendant City of Stockton provided plaintiff a letter on February 13, 2015 that

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2015.

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stated her employment status was “at will” and she was being separated based upon “an

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incompatible management style.”

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DISPUTED FACTUAL ISSUES AND MIXED QUESTIONS OF LAW AND FACT

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1.

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Stockton.

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2.

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Whether plaintiff Jessica Glynn was an at-will employee with defendant City of

Whether plaintiff Jessica Glynn’s employment as defendant’s OVP Manager was

terminated by defendant City of Stockton for legitimate business reasons.

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3.

Whether defendant City of Stockton unlawfully discriminated against plaintiff

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Jessica Glynn on the basis of gender and/or pregnancy in violation of California law (FEHA)

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when it terminated her employment on February 13, 2015.

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4.

Whether defendant City of Stockton unlawfully discriminated against plaintiff

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Jessica Glynn on the basis of gender and/or pregnancy in violation of Federal law (Title VII)

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when it terminated her employment on February 13, 2015.

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5.

Whether the City would have taken the same action to terminate plaintiff’s

employment regardless of her membership in a protected category (female/pregnant).

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6.

Whether plaintiff engaged in activity protected by Labor Code section 1102.5.

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7.

Whether a causal connection exists between plaintiff’s alleged protected activity

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and her termination from the City.

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8.

Whether defendant City of Stockton unlawfully retaliated against plaintiff Jessica

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Glynn in violation of California Labor Code section 1102.5 when defendant terminated plaintiff’s

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employment as OVP Manager on February 13, 2015.

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Assuming defendant City of Stockton is found liable for unlawful retaliation in

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violation of California Labor Code section 1102.5 when it terminated plaintiff’s employment on

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February 13, 2015, whether defendant can prove by clear and convincing evidence that the

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termination would have occurred for legitimate, independent reasons even if the plaintiff had not

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engaged in activities protected by section 1102.5.

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10.

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Whether plaintiff suffered damages as a result of her termination.

future.

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The nature and extent of plaintiff Jessica Glynn’s non-economic damages, past and

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12.

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termination of employment.

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14.

The nature and extent of Jessica Glynn’s efforts to mitigate her damages.

SPECIAL FACTUAL INFORMATION

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Whether plaintiff Jessica Glynn has adequately mitigated her damages following

future.

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The nature and extent of plaintiff Jessica Glynn’s economic damages, past and

None applicable.
DISPUTED EVIDENTIARY ISSUES

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Disputed evidentiary issues have been articulated in motions in limine, as described

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below.

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STIPULATIONS/AGREED STATEMENTS

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The parties stipulate to the following:

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1.

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All witnesses, who are not party representatives, shall be excluded from the

Courtroom until being excused as a witness in this case.
2.

Neither party shall mention, or introduce evidence or solicit testimony regarding

the existence or extent of defendant City of Stockton’s Liability Insurance.

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3.

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originals, at trial.

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RELIEF SOUGHT

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1.

The parties may use and introduce true and correct copies of exhibits, rather than

Plaintiff seeks non-economic damages for emotional distress, past and future, in an

amount to be determined at trial.
2.

Plaintiff seeks economic damages for wage loss and employment benefits, past

and future, in an amount to be determined at trial.
3.

Plaintiff seeks economic damages for certain out of pocket economic losses, to be

determined at trial.

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4.

For pre-judgment and post-judgment interest.

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5.

For declaratory relief including but not limited to a judicial declaration of

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defendant’s wrongdoing in violation of Title VII, FEHA, and Labor Code section 1102.5, and
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injunctive relief requiring defendant to institute and enforce appropriate and lawful policies and

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practices.

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6. For recovery of attorney’s fees and costs as permitted by:

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a. Title VII (42 U.S.C. § 2000e-5(k));

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b. FEHA (Cal. Gov’t Code section 12965(b); and

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c. California Code of Civil Procedure section 1021.5.

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POINTS OF LAW
The parties shall alert the court to disputes about the applicable law and legal standards.
Trial briefs addressing these points more completely shall be filed with this court no later than

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seven days prior to the date of trial in accordance with Local Rule 285.

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ABANDONED ISSUES

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None.

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WITNESSES

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Plaintiff’s witnesses are listed as Attachment B.

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Defendant’s witnesses are listed as Attachment C.

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Each party may call any witnesses designated by the other.

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A.

The court will not permit any other witness to testify unless:

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(1) The party offering the witness demonstrates that the witness is for the purpose

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of rebutting evidence that could not be reasonably anticipated at the pretrial

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conference, or

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(2) The witness was discovered after the pretrial conference and the proffering

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party makes the showing required in “B,” below.

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B.

Upon the post pretrial discovery of any witness a party wishes to present at trial,

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the party shall promptly inform the court and opposing parties of the existence of the unlisted

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witnesses so the court may consider whether the witnesses shall be permitted to testify at trial.

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The witnesses will not be permitted unless:

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(1) The witness could not reasonably have been discovered prior to the discovery

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cutoff;
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(2) The court and opposing parties were promptly notified upon discovery of the

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witness;

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(3) If time permitted, the party proffered the witness for deposition; and

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(4) If time did not permit, a reasonable summary of the witness’s testimony was

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provided to opposing parties.

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EXHIBITS, SCHEDULES AND SUMMARIES
Parties’ joint exhibits are identified on Attachment A. Joint Exhibits shall be identified as
JX and listed numerically, e.g., JX-1, JX-2.
Plaintiff’s exhibits are identified on Attachment D. At trial, plaintiff’s exhibits shall be
listed numerically.
Defendant’s exhibits are identified on Attachment E. At trial, defendant’s exhibits shall
be listed alphabetically, first A, B, C, etc., then AA, BB, CC, etc., and so on.

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All exhibits must be premarked.

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The parties must prepare exhibit binders for use by the court at trial, with a side tab

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identifying each exhibit in accordance with the specifications above. Each binder shall have an

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identification label on the front and spine.

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The parties must exchange exhibits no later than twenty-eight days before trial. Any
objections to exhibits are due no later than fourteen days before trial.
A. The court will not admit exhibits other than those identified on the exhibit lists
referenced above unless:
1. The party proffering the exhibit demonstrates that the exhibit is for the purpose of
rebutting evidence that could not have been reasonably anticipated, or
2. The exhibit was discovered after the issuance of this order and the proffering party
makes the showing required in Paragraph “B,” below.
B. Upon the discovery of exhibits after the discovery cutoff, a party shall promptly

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inform the court and opposing parties of the existence of such exhibits so that the court may

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consider their admissibility at trial. The exhibits will not be received unless the proffering party

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demonstrates:
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1. The exhibits could not reasonably have been discovered earlier;

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2. The court and the opposing parties were promptly informed of their existence;

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3. The proffering party forwarded a copy of the exhibits (if physically possible) to the

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opposing party. If the exhibits may not be copied the proffering party must show that it has made

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the exhibits reasonably available for inspection by the opposing parties.

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DEPOSITION TRANSCRIPTS

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Counsel must lodge the sealed original copy of any deposition transcript to be used at trial

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with the Clerk of the Court on the first day of trial.

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FURTHER DISCOVERY OR MOTIONS

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In the parties’ joint pretrial statement, plaintiff requested that the court modify its pre-trial

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order to permit her to file and serve a supplemental expert report by Craig Enos, and to allow

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defendant to depose Mr. Enos on any new matters, should defendant desire. ECF No. 49 at 10.

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At the September 9, 2016 hearing, plaintiff indicated circumstances had changed such that she

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may no longer wish to proceed with this request. The parties shall meet and confer to determine

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how they wish to proceed and submit to the court by October 21, 2016, a stipulation and

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proposed order addressing any supplementation by Mr. Enos. If the parties are unable to agree on

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a proposal, they shall submit their respective positions in a joint statement by the same date.

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SETTLEMENT

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The court as is its practice refers the case for a court-convened settlement conference.

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Magistrate Judge Carolyn K. Delaney has been randomly selected. A settlement conference is

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scheduled before Judge Delaney for November 8, 2016 at 9:30 a.m. in Courtroom No. 24, 8th

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Floor.

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The parties are directed to submit their confidential settlement conference statements to

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the Court using the following email address: [e-mail]. If a party desires to

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share additional confidential information with the Court, they may do so pursuant to the

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provisions of Local Rule 270(d) and (e). Statements are due at least 7 days prior to the Settlement

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Conference. Each party is reminded of the requirement that it be represented in person at the

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settlement conference by a person able to dispose of the case or fully authorized to settle the

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matter at the settlement conference on any terms. See Local Rule 270.

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Additionally, the parties are instructed to consult Judge Delaney’s standing order for

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settlement information found on the court’s website at www.caed.uscourts.gov.

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MOTIONS

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Plaintiff filed a Motion for Leave to file a First Amended Complaint on March 31, 2016,

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which Defendant did not oppose. The motion was granted, and the First Amended Complaint was

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filed on May 3, 2016. Defendant City of Stockton answered the First Amended Complaint on or

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about June 1, 2016.

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Defendant City of Stockton filed a Motion for Summary Judgment/Adjudication, which

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was heard by the Court on July 1, 2016. The Court issued an order on July 26, 2016, partially

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granting and partially denying the motion. The Court granted the motion with respect to claims

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three and four, but denied the motion with respect to the other three claims, which are proceeding

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to trial.

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MOTIONS IN LIMINE

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The following motions are presently pending before the court:

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A. Plaintiff’s Motions in Limine

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Plaintiff will file the following motions in limine:

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1.

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To exclude Defendant’s introduction of evidence (information or witnesses) that

Defendant failed to provide in discovery;
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To exclude evidence that was either not provided at the appropriate Defendant

PMQ depositions, or is contrary to the Defendant PMQ witnesses’ testimony;
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For an order binding Defendant City of Stockton to the answers given in

deposition because their PMQ designees testified and spoke on behalf of the Defendant entity;
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To exclude any references or suggestions that Plaintiff was practicing law without

the proper bar license.

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B.

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Defendant City of Stockton will file motions in limine:

Defendant’s Disputed Evidentiary Issues and Motions in Limine

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To exclude all testimony and/or opinion from non-City employees concerning

Plaintiff’s work performance;
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To exclude expert testimony and evidence not included in Plaintiff’s expert

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disclosures, including any and all medical testimony about Plaintiff’s alleged emotional or

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physical distress;

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3.

To exclude testimony and/or evidence about Christian Clegg’s religious beliefs;

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4.

To exclude all evidence and testimony about alleged racist comments made by

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Plaintiff’s subordinates.
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To exclude all testimony and/or evidence about Plaintiff’s previously dismissed

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Third and Fourth Causes of Action, and the City’s previously filed Motion for Summary

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Judgment.

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6.

To exclude all evidence or testimony regarding other allegations and complaints

against the City and specifically to exclude the testimony of Michael Lam and Maria Alcazar.
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To exclude any evidence or testimony that Plaintiff’s employment status was

anything other than “at will.”
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The court shall hear arguments regarding any of the above motions the parties wish

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decided before trial on October 7, 2016. Any motion a party wants heard on that day shall be

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briefed in a maximum of five pages per motion, filed by September 28, 2016. Any opposition

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shall be filed by October 4, 2016, with replies argued at hearing.

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Each of the court’s rulings on a motion in limine will be made without prejudice and will

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be subject to proper renewal, in whole or in part, during trial. If a party wishes to contest a pretrial

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ruling, it must do so through a proper motion or objection, or otherwise forfeit appeal on such

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grounds. See FED. R. EVID. 103(a); Tennison v. Circus Circus Enters., Inc., 244 F.3d 684, 689

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(9th Cir. 2001) (“Where a district court makes a tentative in limine ruling excluding evidence, the

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exclusion of that evidence may only be challenged on appeal if the aggrieved party attempts to

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offer such evidence at trial.”) (alteration, citation and quotation omitted). In addition, challenges

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to expert testimony under Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993)
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are denied without prejudice. Should a party wish to renew a Daubert challenge at trial, it should

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alert the court, at which point the court may grant limited voir dire before such expert may be

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called to testify.

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JOINT STATEMENT OF THE CASE

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Defendant City of Stockton offered plaintiff Jessica Glynn the position of Manager of its

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Office of Violence Prevention on September 26, 2014. Plaintiff accepted the position on October

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8, 2014 and started work on October 16, 2014. Plaintiff was terminated on February 13, 2015.

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Plaintiff contends she was almost nine months pregnant at the time, and asserts that her protected

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status as a pregnant woman substantially motivated defendant’s decision to terminate her

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employment. Plaintiff also asserts she made several protected complaints not long before her

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termination, and that these protected complaints motivated defendant’s decision to terminate her

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employment.

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Plaintiff contends defendant City of Stockton’s actions violated federal and state laws

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prohibiting discrimination and state law prohibiting retaliation, and claims: (1) Gender and

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Pregnancy Discrimination in Violation of Title VII; 2) Gender and Pregnancy Discrimination in

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Violation of FEHA; and 3) Retaliation in Violation of Labor Code section 1102.5. Defendant

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denies all allegations, and asserts it terminated plaintiff’s employment for legitimate, non-

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discriminatory, business reasons.

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SEPARATE TRIAL OF ISSUES

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Plaintiff and Defendant do not anticipate the need for a separate trial of any of the issues

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in this matter.

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IMPARTIAL EXPERTS/LIMITATION OF EXPERTS

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Parties agree that there is no need for an impartial expert witness.
ATTORNEYS' FEES

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Plaintiff will be seeking attorney’s fees as prevailing party by post-trial motion, pursuant
to Local Rule 293 and Federal Rules of Civil Procedure 54(d).

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Defendant is not seeking attorneys’ fees at this time.
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ESTIMATED TIME OF TRIAL/TRIAL DATE

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Jury trial is set for January 30, 2017 at 9:00 a.m. in Courtroom Three before the

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Honorable Kimberly J. Mueller. Trial is anticipated to last seven (7) to ten (10) days. The parties

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are directed to Judge Mueller’s trial schedule outlined on her web page on the court’s website.

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Trial briefs are due on January 13, 2017.
PROPOSED JURY VOIR DIRE AND PROPOSED JURY INSTRUCTIONS

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The parties shall file any proposed jury voir dire seven days before trial. Each party will
be limited to ten minutes of jury voir dire.

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The court directs counsel to meet and confer in an attempt to generate a joint set of jury

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instructions and verdicts. The parties shall file any such joint set of instructions fourteen days

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before trial, identified as “Jury Instructions and Verdicts Without Objection.” To the extent the

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parties are unable to agree on all or some instructions and verdicts, their respective proposed

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instructions are due fourteen days before trial.

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Counsel shall e-mail a copy of all proposed jury instructions and verdicts, whether agreed

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or disputed, as a word document to [e-mail] no later than fourteen days

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before trial; all blanks in form instructions should be completed and all brackets removed.

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Objections to proposed jury instructions must be filed seven days before trial; each

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objection shall identify the challenged instruction and shall provide a concise explanation of the

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basis for the objection along with citation of authority. When applicable, the objecting party

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shall submit an alternative proposed instruction on the issue or identify which of his or her own

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proposed instructions covers the subject.

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TRIAL PROTECTIVE ORDER

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Defendant has indicated that it may seek a protective order regarding confidential and

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private personnel information of non-party City employees. Parties shall meet and confer so that

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defendant may determine if it is necessary to file a motion requesting a protective order, or if its

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concerns can be otherwise addressed.

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MISCELLANEOUS
Plaintiff filed a notice of motion for sanctions and attorney’s fees. The motion hearing is

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scheduled for October 7, 2016.

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OBJECTIONS TO PRETRIAL ORDER

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Each party is granted fourteen days from the date of this order to file objections to the

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same. If no objections are filed, the order will become final without further order of this court.

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DATED: September 21, 2016.

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UNITED STATES DISTRICT JUDGE

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Joint
Exh.
No.

Attachment A: Joint Exhibits
Document Description
Bates-Stamp No.

City of Stockton, California, City Manager
1. Administrative Directive- HR - 15 Discrimination and Harassment Policy, (March,
2010)

Exhibit 13 to Plaintiff Jessica
Glynn’s Deposition (Not BatesStamped)

Operation Peacekeeper Program Policies and
2. Procedures (Created January 2008 (4th Revision
Effective May 15, 2013)

008473-008484

Comprehensive Summary of City of Stockton
3. Unrepresented Management/Confidential and
Law Employees Compensation Plan (July 1,
2014)

000082-000113

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Witness Name And
Address

Attachment B: Plaintiff’s Witness List
Brief Statement Of The Nature Of The Testimony
To Be Proffered.

Testimony
Form – In
Person/ By
Deposition;
Expert/Non
1. Jessica Glynn Plaintiff Jessica Glynn is expected to testify about her Non-expert; In
skills and qualifications; job duties, job history, job person.
performance and separation of employment with
Defendant City of Stockton (“Defendant”); her
interactions and communications with Christian Clegg,
Kurt Wilson, Ken Praegitzer, other managers,
coworkers, program partners, and third parties in
connection with her work for Defendant City of
Stockton; and facts and events supporting her legal
claims and theories in this action.
Plaintiff is also expected to testify regarding her job
search efforts and mitigation and damages issues.

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2. Christian
Clegg/City of
Stockton,
Assistant to
City Manager

Christian Clegg, the Assistant to the City Manager for
Defendant, and Plaintiff’s former supervisor and
decision maker, is expected to testify about the
creation, development, staffing and structure of
Defendant’s Office of Violence Prevention (“OVP”).
Christian Clegg is also expected to testify as to the
recruitment, interview, screening and selection process
for Defendant’s OVP Manager in 2015; and
Defendant’s job offer to Plaintiff.
Christian Clegg is also expected to testify as to
Plaintiff’s job performance during her employment
with Defendant, including appraisals/ evaluations/
feedback; lack of discipline, warnings, counseling or
negative feedback; his related communications with
third persons; Plaintiff and Christian Clegg’s October
8, 2014 meeting and the February 13, 2015 termination
meeting.
Christian Clegg is also expected to testify as to
Defendant’s plan, intent and decision to terminate
Plaintiff’s employment, and the reasons therefore.
Christian Clegg is also expected to testify about
communications with the OVP staff as to the reasons
for Plaintiff's separation of employment, including
statements made at a staff meeting on or about
February 17, 2015.

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Non-expert; In
person and by
deposition
(PMQ
deposition
testimony
excerpts)

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Christian Clegg is also expected to testify about
Defendant’s policies, practices and procedures
regarding payment of overtime to its Peacekeepers,
Youth Outreach Workers and/or Outreach Workers.
This includes any changes or modifications to
Defendant’s policies, practices and procedures
regarding payment of overtime for its Peacekeepers,
Youth Outreach Workers and/or Outreach Workers.

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Christian Clegg is also expected to testify about
concerns and complaints to Defendant concerning
FLSA/wage and hour compliance issues of the
Peacekeepers; Defendant’s failure to properly
compensate Peacekeepers for overtime; and
remedial/corrective steps by Defendant to address
violations.

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Christian Clegg is also expected to testify about
concerns and complaints to Defendant concerning
potential constitutional due process violations arising
from Defendant’s information sharing practices and
procedures between Defendant’s Police Department
and Peacekeeper staff.

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Christian Clegg is also expected to testify about his
communications regarding Plaintiff’s pregnancy,
anticipated pregnancy disability leave, maternity leave
and plans to cover Plaintiff’s job duties while she was
on leave.

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Christian Clegg is also expected to testify about
Defendant’s policies, practices and procedures
regarding employee use of personal cell phones, text
messages and email for business/work use.

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3. Kurt Wilson,
City of
Stockton,
City Manager

Kurt Wilson is expected to testify regarding: Wilson’s
job interview with Plaintiff on or about September 25,
2014; Wilson’s verbal and written communications
with Plaintiff on September 26, 2014; Wilson’s
meeting with Plaintiff on or about October 2, 2014;
Defendant’s selection of Plaintiff for the OVP Manager
position; Wilson’s meeting with Plaintiff and Christian
Clegg on or about October 21, 2014; Defendant’s
decision to terminate Plaintiff’s employment and
Defendant’s termination meeting with Plaintiff on
February 13, 2015.

Non-expert; In
person and by
deposition
(PMQ
deposition
testimony
excerpts)

4. Laurie
Montes/City
of Stockton,
Deputy City
Manager

Laurie Montes is expected to testify regarding
Defendant’s policies, practices and procedures
regarding timekeeping and compensation of its
Peacekeepers, Youth Outreach Workers and Outreach
Workers; including the calculation of payment of

Non-expert; In
person and by
deposition
(PMQ
deposition

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overtime or “Comp. Time;” and Defendant’s “Flex
Time” compensation practice.

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Laurie Montes is also expected to testify regarding
communications between Plaintiff and Laurie Montes
regarding Defendant’s timekeeping and compensation
practices of the peacekeepers; prior FLSA noncompliant pay practices under former Program
manager Ralph Womack and Plaintiff’s concerns and
complaints regarding non-compliant FLSA/wage and
hour practices.

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Laurie Montes is also expected to testify regarding her
one meeting with Plaintiff that occurred on or about
December 4, 2014.

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testimony
excerpts)

5. Ken
Praegitzer,/
City of
Stockton,
former
Program
Manager,
Operation
Peacekeeper

Ken Praegitzer is expected to testify regarding
Defendant’s Operation Peacekeepers Program policies,
procedures and practices.
Ken Praegitzer is also expected to testify regarding
Defendant’s policies, practices and procedures
regarding timekeeping and compensation of its
Peacekeepers, Youth Outreach Workers and Outreach
Workers; including the calculation of payment of
overtime or “Comp. Time;” and Defendant’s “Flex
Time” compensation practice.
Ken Praegitzer is also expected to testify regarding
expectations and requirements of the Peacekeepers
with regard to working outside of scheduled hours,
including being on call.
Ken Praegitzer is also expected to testify regarding the
FLSA non-compliant compensation practices of the
Peacekeepers under his management.
Ken Praegitzer is also expected to testify regarding
regular “Core Group” meetings which included the
Peacekeepers and City of Stockton Police Officers/
Gang Unit detectives; and the information sharing
policies and practices between the two groups; and
Plaintiff’s directives to halt the Core Group meetings in
about November, 2014 light of her legal concerns.
Ken Praegitzer is also expected to testify regarding
communications with Plaintiff and other persons
16

Non-expert; In
person and by
deposition
(PMQ
deposition
testimony
excerpts)

1

regarding Plaintiff’s inquiries, concerns and complaints
regarding Peacekeeper timekeeping and compensation
practices.

2
3

Ken Praegitzer is also expected to testify regarding
communications with Plaintiff and other persons
regarding Plaintiff’s inquiries, concerns and complaints
regarding information sharing policies and practices
between Defendant’s Police Department and the
Peacekeepers/Outreach Workers.

4
5
6
7

Ken Praegitzer is also expected to testify regarding the
history of , and his observations of, Peacekeeper team
dynamics, including supervisor Jose Gomez skills,
abilities, weaknesses and job performance; and
Praegitzer’s opinions and recommendations.

8
9
10

Ken Praegitzer’s plans and intentions regarding
retirement/departure from his job as Defendant’s
Peacekeeper Program Manager and communications
with other persons as to same.

11
12
13
14
15
16
17
18

6. Trevor
Womack,
City of
Stockton
Police
Department,
Deputy Chief
of Police

Trevor Womack is expected to testify regarding the
regular “Core Group” meetings which included the
Peacekeepers and Defendant’s Police Officers/ Gang
Unit detectives; and the information sharing policies
and practices between the two groups; and Plaintiff’s
directives to halt the Core Group meetings in light of
her legal concerns.

Non-expert; In
person and by
deposition
(PMQ
deposition
testimony
excerpts)

Trevor Womack is also expected to testify regarding
communications with Plaintiff and other persons
regarding Plaintiff’s inquiries, concerns and complaints
regarding information sharing policies and practices
between Defendant’s Police Department and the
Peacekeepers/Outreach Workers; and Plaintiff’s
concerns or complaints to concerning these practices
might constitute constitutional/ due process violations.

19
20
21
22
23

Trevor Womack is also expected to testify regarding
his verbal communications with Plaintiff about Alicia
Duer made at the February 12, 2015 Cease Fire call in.

24
25
26
27
28

7. Marci
Arredondo/
City of
Stockton,

Attorney Arredondo is expected to testify about
Non-expert; In
Plaintiff’s expressed concerns and complaints about
person.
Defendant’s wage and hour and compensation practices
of the Peacekeepers; and communications with Plaintiff
17

1
2
3
4
5
6
7
8
9
10
11
12
13
14

Deputy City
Attorney
8. Neal
Lutterman,
former City
of Stockton,
Deputy City
Attorney

and others regarding same.

Attorney Lutterman is expected to testify about
Plaintiff’s expressed concerns and complaints about
legal/ constitutional due process and wage and hourrelated concerns/complaints; and communications with
Plaintiff and others regarding same.

Non-expert; in
person

DeAnna Solina is expected to testify regarding
Defendant’s policies, practices and procedures
regarding timekeeping and compensation of its
Peacekeepers, Youth Outreach Workers and Outreach
Workers; including the calculation of payment of
overtime or “Comp. Time;” and Defendant’s “Flex
Time” compensation practice.

Non-expert; In
person and by
deposition
(PMQ
deposition
testimony
excerpts)

Wilke Fleury
400 Capitol
Mall, 22nd Fl.
Sacramento
CA 95814
916.441.2430
9. DeAnna
Solina/City
of Stockton,
Director of
Human
Resources

15
DeAnna Solina is expected to testify regarding
communications and meetings with Plaintiff and other
persons regarding Plaintiff’s inquiries, concerns and
complaints regarding Defendant’s timekeeping and
compensation practices, and other wage and hourrelated issues, for its Peacekeepers, Youth Outreach
Workers and Outreach Workers.

16
17
18
19
20

DeAnna Solina is also expected to testify regarding
changes to Defendant’s policies, practices and
procedures regarding timekeeping and compensation of
its Peacekeepers, Youth Outreach Workers and
Outreach Workers; including the calculation of
payment of overtime or “Comp. Time;” and
Defendant’s “Flex Time” compensation practice.

21
22
23
24
25
26
27
28

10. Stephanie
van Steyn,
City of
Stockton,
Supervising
Human

Stephanie van Steyn is expected to testify regarding
Defendant’s policies, practices and procedures
regarding employee discipline; and employee
performance monitoring or improvement.
Stephanie van Steyn is expected to testify regarding
18

In person; nonexpert

1
2
3
4
5
6

Resources
Analyst at
City of
Stockton

Defendant’s policies, practices and procedures
regarding “comp time” for the time period January 1,
2012 to present. This includes any changes or
modifications to Defendant’s policies, practices or
procedures regarding “comp time” for the time period
January 1, 2012 to present.
Stephanie van Steyn is also expected to testify
regarding documentation related to the termination of
Plaintiff's employment.

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
19

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22

11. Jaime
Constantino,
City of
Stockton
/Youth
Outreach
Worker

Jaime Constantino is expected to testify regarding the
implementation and history of the Operation
Peacekeeper; and its program policies, procedures, and
practices.
Jaime Constantino is also expected to testify regarding
City of Stockton Peacekeeper/police information
sharing practices; and complaints and concerns raised
by regarding information sharing practices.
Jaime Constantino is also expected to testify regarding
City of Stockton Peacekeeper program team history –
tension, morale and team dynamic; and further as to the
OVP staffing structure, organization, changes and
potential changes; and discussions with Plaintiff Jessica
Glynn as to same.
Jaime Constantino is also expected to testify regarding
events of November 20, 2014 including the staff
meeting in which then-supervisor Jose Gomez went
ballistic.
Jaime Constantino is also expected to testify regarding
Jose Gomez’s and Jaime Constantino complaints about
Plaintiff; and about other claims of harassment,
discrimination and/or retaliation, and wage and hour
compliance issues among the Peacekeepers.
Jaime Constantino is also expected to testify regarding
Plaintiff Jessica Glynn’s concerns and legal issues
(including her constitutional due process concerns with
the information sharing practices between the
Peacekeepers and police officers/gang unit detectives,
including the practice of regular “Core Group
meetings” OVP/Ceasefire model; and
Plaintiff’s concerns and legal issues relating to wage
and hour issues, including Flex time, Comp. time,
overtime, timekeeping and recordkeeping procedures.

23
24
25

Jaime Constantino is also expected to testify regarding
the history and changes to Flex Time, Overtime, and
Comp time pay policies, practices and procedures of
Peacekeepers.

26
27
28
20

In person; nonexpert

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

12. Pheakday
Youn/ City
of Stockton
/former
Youth
Outreach
Worker

Pheakday Youn is expected to testify regarding the
implementation and history of the Operation
Peacekeeper; and its program policies, procedures, and
practices.
Pheakday Youn is also expected to testify regarding
City of Stockton Peacekeeper/police information
sharing practices; and complaints and concerns raised
by City of Stockton Peacekeepers regarding
information sharing practices.
Pheakday Youn is also expected to testify regarding
City of Stockton Peacekeeper program team history –
tension, morale and team dynamic; and further as to the
OVP staffing structure, organization, changes and
potential changes; and discussions with Plaintiff Jessica
Glynn as to same.
Pheakday Youn is also expected to testify regarding
events of November 20, 2014 including the staff
meeting in which Supervisor Jose Gomez went
ballistic.
Pheakday Youn is also expected to testify regarding
other claims of harassment, discrimination, retaliation,
and bullying among the Peacekeepers.

16
17
18
19
20
21
22
23
24
25
26
27

Pheakday Youn is also expected to testify regarding
Plaintiff Jessica Glynn’s duties, management style, and
job performance as the OVP Manager.
Pheakday Youn is also expected to testify regarding
Plaintiff Jessica Glynn’s concerns and legal issues
(including her constitutional due process concerns with
the information sharing practices between the
Peacekeepers and police officers/gang unit detectives,
including the practice of regular “Gore Group
meetings” OVP/Ceasefire model; and
Plaintiff’s concerns and legal issues relating to wage
and hour issues, including Flex time, Comp. time,
overtime, timekeeping and recordkeeping procedures.
Pheakday Youn is also expected to testify regarding the
history and changes to Flex Time, Overtime, and Comp
time pay policies, practices and procedures of
Peacekeepers.

28
21

In person; nonexpert

1

Pheakday Youn is also expected to testify regarding
Defendant Peacekeepers’ reputation as snitches in
Stockton communities; and Peacekeepers Jose Gomez
and Jaime Constantino’s specific reputations as
snitches in Stockton communities.

2
3
4

Pheakday Youn is also expected to testify regarding
communications by Christian Clegg regarding reasons
for Plaintiff Jessica Glynn’s separation of employment.

5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23

13. Stanley
Thomas City
of Stockton
/Youth
Outreach
Worker

Stanley Thomas is expected to testify regarding the
implementation and history of the Operation
Peacekeeper; and its program policies, procedures, and
practices.
Stanley Thomas is also expected to testify regarding
City of Stockton Peacekeeper/police information
sharing practices; and complaints and concerns raised
by City of Stockton Peacekeepers regarding
information sharing practices.
Stanley Thomas is also expected to testify regarding
City of Stockton Peacekeeper program team history –
tension, morale and team dynamic; and further as to the
OVP staffing structure, organization, changes and
potential changes; and discussions with Plaintiff Jessica
Glynn as to same.
Stanley Thomas is also expected to testify regarding
events of November 20, 2014 including the staff
meeting in which Supervisor Jose Gomez went
ballistic.
Stanley Thomas is also expected to testify regarding
other claims of harassment, discrimination, retaliation,
and bullying among the Peacekeepers.
Stanley Thomas is also expected to testify regarding
Plaintiff Jessica Glynn’s duties, management style, and
job performance as the OVP Manager.

24
25
26
27
28

Stanley Thomas is also expected to testify regarding
Plaintiff Jessica Glynn’s concerns and legal issues
(including her constitutional due process concerns with
the information sharing practices between the
Peacekeepers and police officers/gang unit detectives,
including the practice of regular “Core Group
22

In person; nonexpert

1

meetings” OVP/Ceasefire model; and
Plaintiff’s concerns and legal issues relating to wage
and hour issues, including Flex time, Comp. time,
overtime, timekeeping and recordkeeping procedures.

2
3

Stanley Thomas is also expected to testify regarding
the history and changes to Flex Time, Overtime, and
Comp time pay policies, practices and procedures of
Peacekeepers.

4
5
6

Stanley Thomas is also expected to testify regarding
Defendant Peacekeepers’ reputation as snitches in
Stockton communities; and Peacekeepers Jose Gomez
and Jaime Constantino’s specific reputations as
snitches in Stockton communities

7
8
9
10

Stanley Thomas is also expected to testify regarding
communications by Christian Clegg regarding reasons
for Plaintiff Jessica Glynn’s separation of employment.

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

14. Jose Gomez,
City of
Stockton
/Youth
Outreach
Worker

Jose Gomez is expected to testify regarding the
implementation and history of the Operation
Peacekeeper; and its program policies, procedures, and
practices.
Jose Gomez is also expected to testify regarding City
of Stockton Peacekeeper/police information sharing
practices; and complaints and concerns raised by City
of Stockton Peacekeepers regarding information
sharing practices.
Jose Gomez is also expected to testify regarding City
of Stockton Peacekeeper program team history –
tension, morale and team dynamic; and further as to the
OVP staffing structure, organization, changes and
potential changes; and discussions with Plaintiff Jessica
Glynn as to same.
Jose Gomez is also expected to testify regarding events
of November 20, 2014 including the staff meeting in
which Jose Gomez went ballistic.
Jose Gomez is also expected to testify regarding Jose
Gomez’s and Jose Gomez complaints about Plaintiff;
and about other claims of harassment, discrimination
and/or retaliation, and wage and hour compliance
issues among the Peacekeepers.
23

In person; nonexpert

1
Jose Gomez is also expected to testify regarding
Plaintiff Jessica Glynn’s duties, management style, and
job performance as the OVP Manager; and about the
reasons communicated to the Peacekeepers by
Christian Clegg for Plaintiff Jessica Glynn’s separation
of employment.

2
3
4
5

Jose Gomez is also expected to testify regarding OVP
staffing structure, organization, changes and potential
changes; and discussions with Plaintiff Jessica Glynn
as to same.

6
7
8

Jose Gomez is also expected to testify regarding
Plaintiff’s concerns and legal issues relating to wage
and hour issues, including Flex time, Comp. time,
overtime, timekeeping and recordkeeping procedures;
and communications with City of Stockton including
Human Resources regarding unpaid wages issues, and
changes to Peacekeeper timekeeping and pay practices
including abolishing “Flex Time” and implementing
Comp. time pay practices.

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

15. Ernest Bass/
City of
Stockton
/Youth
Outreach
Worker

Ernest Bass is expected to testify regarding the
implementation and history of the Operation
Peacekeeper; and its program policies, procedures, and
practices.
Ernest Bass is also expected to testify regarding City of
Stockton Peacekeeper/police information sharing
practices; and complaints and concerns raised by City
of Stockton Peacekeepers regarding information
sharing practices.
Ernest Bass is also expected to testify regarding City of
Stockton Peacekeeper program team history – tension,
morale and team dynamic; and further as to the OVP
staffing structure, organization, changes and potential
changes; and discussions with Plaintiff Jessica Glynn
as to same.
Ernest Bass is also expected to testify regarding events
of November 20, 2014 including the staff meeting in
which Jose Gomez went ballistic.

26
27
28

Ernest Bass is also expected to testify regarding other
claims of harassment, discrimination, retaliation, and
bullying among the Peacekeepers.
24

In person; nonexpert

1
Ernest Bass is also expected to testify regarding
Plaintiff Jessica Glynn’s duties, management style, and
job performance as the OVP Manager.

2
3

Ernest Bass is also expected to testify regarding
Plaintiff Jessica Glynn’s concerns and legal issues
(including her constitutional due process concerns with
the information sharing practices between the
Peacekeepers and police officers/gang unit detectives,
including the practice of regular “core group meetings”
OVP/Ceasefire model; and Plaintiff’s concerns and
legal issues relating to wage and hour issues, including
Flex time, Comp. time, overtime, timekeeping and
recordkeeping procedures.

4
5
6
7
8
9
10

Ernest Bass is also expected to testify regarding the
history and changes to Flex Time, Overtime, and Comp
time pay policies, practices and procedures of
Peacekeepers.

11
12
13

Ernest Bass is also expected to testify regarding
Defendant Peacekeepers’ reputation as snitches in
Stockton communities; and Peacekeepers Jose Gomez
and Jaime Constantino’s specific reputations as
snitches in Stockton communities.

14
15
16

Ernest Bass is also expected to testify regarding
communications by Christian Clegg regarding reasons
for Plaintiff Jessica Glynn’s separation of employment.

17
18
19
20
21
22
23
24
25
26

16. Matt Lam
City of
Stockton
/former
Youth
Outreach
Worker

Matt Lam is expected to testify regarding the
implementation and history of the Operation
Peacekeeper; and its program policies, procedures, and
practices.
Matt Lam is also expected to testify regarding City of
Stockton Peacekeeper/police information sharing
practices; and complaints and concerns raised by City
of Stockton Peacekeepers regarding information
sharing practices.
Matt Lam is also expected to testify regarding City of
Stockton Peacekeeper program team history – tension,
morale and team dynamic.

27
28

Matt Lam is also expected to testify regarding other
25

By deposition
transcript; nonexpert

1

claims of harassment, discrimination, retaliation,
bullying; including his own concerns and complaints
about information sharing expectations, bullying and
retaliation.

2
3

Matt Lam is also expected to testify regarding his
concerns and complaints about the information sharing
practices between the Peacekeepers and police
officers/gang unit detectives, including the practice of
regular “core group meetings”; and the expectations of
his supervisors Jose Gomez and Ralph Womack as to
same.

4
5
6
7
8

Matt Lam is also expected to testify regarding
Defendant Peacekeepers’ reputation as snitches in
Stockton communities; and Peacekeepers Jose Gomez
and Jaime Constantino’s specific reputations as
snitches in Stockton communities

9
10
11
12
13
14
15
16
17
18

17. Savong
Lam/Former
Director,
Neighborhoo
d-based
programs, of
Community
Partnership
For Families
Of San
Joaquin.

Savong Lam is expected to testify regarding her
interactions and observations of Jessica Glynn during
Plaintiff’s employment with Defendant.

18. Karen Costa,
City of
Stockton,
Executive
Assistant to
City Manager

Ms. Costa is expected to testify regarding
communications with Plaintiff, City Manager Kurt
Wilson, and Human Resources Director DeAnna
Solina regarding Plaintiff’s requested appointments,
meetings and calls.

19. Alicia Duer,
Program
Manager III
at City of
Stockton

Alicia Duer is expected to testify regarding her role and In person; nonresponsibilities regarding grants generally, and with expert
regard to grants related to the Peacekeeper program
specifically; and as to Florence Low’s role and
responsibilities regarding grants generally, and with
regard to grants related to the Peacekeeper program.

19

By deposition
transcript; nonexpert

She is also expected to testify regarding the
Peacekeeper program generally, and Jose Gomez’
reputation specifically, as snitches.
Ms. Lam is also expected to testify about concerns over
the safety of her husband/former Peacekeeper Matt
Lam and their four children, arising from the
inappropriate information sharing practices and
community perception of Defendant’s Peacekeepers as
mere snitches.

20
21
22
23

In person; nonexpert

24
25
26
27
28

26

1
Alicia Duer is also expected to testify regarding her
communications with Plaintiff regarding concerns
about Peacekeeper compensation practices.

2
3

Alicia Duer is also expected to testify regarding her
communications with Plaintiff on October 21, 2014.

4
5

Alicia Duer is expected to testify regarding
the BHS grant history; communications about the BHS
grant application process and changes thereto,
including communications with Frances Hutchins,
Florence Low, Christian Clegg, Ken Praegitzer and
Plaintiff.

6
7
8
9
10

20. Florence
Low

11
12

Florence Low is also expected to testify regarding her
communications with Plaintiff and others regarding
BHS grant application issues.

13
14
15
16
17
18
19
20
21
22
23
24

Florence Low is expected to testify regarding her role In person; nonand responsibilities regarding grants generally, and expert
with regard to grants related to the Peacekeeper
program specifically.

21. San Joaquin
County
Board of
Supervisors,
Custodian of
Records

A San Joaquin County Board of Supervisors, Custodian In person; nonof Records witness is expected to testify regarding the
expert
San Joaquin County Board of Supervisors Resolution;
and authentication of the new Three Year MHSA Plan.

22. Tom AmatoExecutive
Director of
PACT

Tom Amato is expected to testify regarding his
interactions and experiences with Jessica Glynn during
her employment; and communications with Defendant
following Plaintiff’s termination.

23. Gretchen
Newby/
Friends
Outside
Executive
Director

Gretchen Newby is expected to testify regarding her
In person; noninteractions and experiences with Jessica Glynn during expert
her employment; and communications with Plaintiff’s
termination before and after Plaintiff’s termination; and
as to Ms. Newby’s own observations and feedback
regarding Plaintiff’s preparation, organization and
performance at the February 11, 2015 Call-In rehearsal
and February 12, 2015 Call-In event.

24. Robina
Asghar,
Community

Robina Asghar is expected to testify regarding her
interactions and experiences with Jessica Glynn during
her employment; and communications with Plaintiff’s

25

In person; nonexpert

26
27
28

27

In person; nonexpert

1
2
3
4
5

Partnership
For Families
Of San
Joaquin,
Executive
Director

before termination.
She is also expected to testify regarding the
Peacekeeper program generally, and Jose Gomez’
reputation specifically, as snitches.

25. Michael
Tubbs,
former
Stockton City
Councilman
and Mayor
candidate

Michael Tubbs is expected to testify regarding
Plaintiff’s job duties, job performance and separation
of employment with Defendant; interactions and
communications with Plaintiff and others including
Christian Clegg, Kurt Wilson, Ken Praegitzer, other
City of Stockton managers, coworkers, program
partners, and other third parties in connection with
Plaintiff’s work for Defendant.

26. Debra Glynn,
Plaintiff’s
mother

Debra Glynn is expected to testify regarding her
In person; noninteractions and observations of Plaintiff Jessica Glynn; expert
and as to Plaintiff’s damages.
Santiago Salinas is expected to testify regarding his
observations of Plaintiff Jessica Glynn; and as to
Plaintiff’s damages.

In person; nonexpert

15

27. Santiago
Salinas,
Plaintiff’s
husband

16

28. Craig Enos

Mr. Enos is a forensic accountant, and will be
providing expert testimony regarding Plaintiff’s
economic damages and wage loss.

In-person;
expert

6
7
8
9
10
11

In person; nonexpert

12
13
14

17
18
19
20
21
22
23
24
25
26
27
28

28

1

Attachment C: Defendant’s Witness List

2

1.

3

Plaintiff’s hiring, work performance, and ultimate termination. Wilson will testify about the

4

City’s process in hiring and terminating management-level employees. Wilson may also testify

5

about creation of the Office of Violence and Prevention (“OVP”), creation of the OVP Manager

6

position, and the process of hiring a new Manager for the OVP.

7

2.

8

directly supervised Plaintiff and will testify about his communications with her during her

9

employment. Clegg will testify about Plaintiff’s hiring, work performance, and ultimate

Kurt Wilson: Wilson is City of Stockton City Manager. Wilson will testify about

Christian Clegg: Clegg is the Assistant to the City Manager/Deputy City Manager. He

10

termination. Clegg may also testify about the OVP, its mission, goals, and duties. Clegg may also

11

testify about the City’s Operation Peacekeeper and Ceasefire programs.

12

3.

13

duties and work performance. Gomez will also testify about his interactions with Plaintiff during

14

her employment as well as Plaintiff’s interactions with other City employees.

15

4.

16

her interactions with Plaintiff and the City’s grants programs. She may also testify about her

17

experiences as a female employee in the City Manager’s Office and obtaining grant funding.

18

5.

19

Plaintiff. Praegitzer may also testify about the mission, goals, and duties of the OVP, Operation

20

Peacekeeper, and Operation Ceasefire.

21

6.

22

experiences and communications with Plaintiff. Constantino may also testify about the

23

responsibilities of the City’s Peacekeepers/Outreach Workers.

24

7.

25

her communications with Plaintiff and about the City’s grants program. She may also testify

26

about her experiences as a female employee in the City Manager’s Office.

27

8.

28

testify about the City’s hiring and recruitment process as well as the creation of new City

Jose Gomez: Gomez was one of Plaintiff’s direct reports. He will testify about Plaintiff’s

Alicia Duer: Duer was an employee in the City Manager’s Office. She will testify about

Ken Praegitzer: Praegitzer will testify about his interactions and experiences with

Jaime Constantino: Constantino is an employee in the OVP. He will testify about his

Florence Low: Low is an employee in the City Manager’s Office. She will testify about

Debbie Shipp: Shipp is an employee in the City’s Human Resources Office. She will

29

1

positions. Shipp will also testify about the City’s civil service and classification rules. Shipp will

2

also testify about her communications and interactions with the Plaintiff during her employment.

3

9.

4

Operation Ceasefire as well as his communications and interactions with the Plaintiff during her

5

employment with the City.

6

10.

7

interactions and communications with Plaintiff during her employment with the City.

8

11.

9

Operation Peacekeeper and Operation Ceasefire programs as well as his communications and

Chief of Police Eric Jones: Chief Jones will testify about Operation Peacekeeper and

City Council Member Moses Zapian: Councilmember Zapian will testify about his

Deputy Chief of Police Trevor Womack: Deputy Chief Womack will testify about the

10

interactions with the Plaintiff.

11

12.

12

Department. She will testify about the City’s Civil Service and classification rules, and her

13

communications and interactions with Plaintiff during her employment with the City. Van Steyn

14

may also testify about the City’s personnel rules and policies.

15

13.

16

about her communications and interactions with Plaintiff during her employment with the City.

17

Solina may also testify the City’s practices, training, and hiring and separation procedures, as well

18

as the City’s civil service and classification rules and the City’s personnel rules and policies.

19

Solina may also testify regarding the City’s practice with respect to, and history of,

20

accommodating pregnant employees.

21

14.

22

Manager. Montes will testify about her communications and interactions with Plaintiff while she

23

was employed by the City. Montes may also testify about the City’s civil service and

24

classification rules as well as the City’s personnel rules and policies. She may also testify about

25

her experiences as a female employee in the City Manager’s Office, her experience with wage

26

and hour practices of Peacekeepers, and experience with grant funding at the City.

27

15.

28

about his interactions and communications with Plaintiff while she was employed with the City.

Stephanie Van Steyn: Van Steyn is an employee in the City’s Human Resources

DeAnna Solina: Solina is the Director of Human Resources for the City. Solina will testify

Laurie Montes: Montes is the Executive Assistant to the City Manager/Deputy City

Earnest Bass: Bass is an employee of the Office of Violence Prevention. He may testify

30

1

16.

2

testify about his interactions and communications with Plaintiff while she employed with the

3

City.

4

17.

5

about her interactions and communications with Plaintiff while she employed with the City.

6

18.

7

communications and interactions with Plaintiff while she was employed by the City.

8

19.

9

about her communications and interactions with Plaintiff while she was employed with the City.

Stanley Thomas: Thomas is an employee of the Office of Violence Prevention. He may

Latoya Simmons: Simmons was Plaintiff’s Administrative Assistant. Simmons will testify

City Councilman Michael Tubbs: Councilmember Tubbs may testify about his

Connie Cochran: Cochran is the City’s Public Information Officer. Cochran may testify

10

She may also testify about her experiences as a female employee at the City.

11

20.

12

Safe Communities. Wakeling may testify about Plaintiff’s hiring and his communications and

13

interactions with her after she was hired. Wakeling may also testify about his communications

14

with Christian Clegg about Plaintiff and goals of the OVP.

15

21.

16

First Amended Complaint, alleged damages and mitigation of such damages.

17

22.

18

expected to testify regarding what Plaintiff said during a meeting involving a discussion of

19

Peacekeeper timekeeping.

20

23.

21

and may testify regarding what he heard Plaintiff say regarding communications between

22

Peacekeepers and the Stockton Police Department.

23

24.

24

regarding what he heard Plaintiff say regarding communications between Peacekeepers and the

25

Stockton Police Department.

26

25.

27

may testify regarding what she heard Plaintiff say regarding communications between

28

Peacekeepers and the Stockton Police Department.

Stewart Wakeling: Wakeling is the Executive Director of the Community Partnership for

Plaintiff Jessica Glynn: Defendant expects her to testify regarding the allegations in her

Marci Arredondo: Arredondo is a Deputy City Attorney for the City of Stockton. She is

Neal Lutterman: Lutterman is a former Deputy City Attorney with the City of Stockton

John Luebberke: Luebberke is the City Attorney for the City of Stockton. He may testify

Susana Alcala Wood: Wood is the Assistant City Attorney for the City of Stockton. She

31

1

26.

2

alleged damages.

3

27.

4

alleged damages.

Jubin Merati: Dr. Merati is an expert witness, expected to testify regarding Plaintiff’s

Joanne Latham: Latham is an expert witness, expected to testify regarding Plaintiff’s

5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
32

1
2

Exhibit
No.

3

1.

Bates No.

Printout of webpage/copy of August 11, 2009 memorandum
prepared by “Alicia Duer, Grants Manager” for Deputy City
Manager Laurie Montes, concerning a Juvenile Accountability
Block Grant, pursued by Ms. Montes and Ms. Duer as part of the
grant funding for Peacekeepers in 2009.

JG 000712JG 000716

2.

City of Stockton, California, City Manager Administrative
Directive- HR – 15 - Discrimination and Harassment Policy,
(March, 2010)

000114-000125

3.

City of Stockton, California, City Manager Administrative
Directive- HR – 13- “Employee Performance Evaluation” policy
(4/18/11)

Exhibit 20 to
Van Steyn
Depo

4.

Operation Peacekeeper Program Policies and Procedures (Created
January 2008 (4th Revision Effective May 15, 2013)

005072-005083

4
5
6
7

Attachment D: Plaintiff’s Exhibit List
Document Description

8
9
10
11
12
13

5.

14

6.

15
16

Email between Laurie Montes and Ralph Womack dated January
29, 2013 re: “FLSA training”
Email correspondence exchanged between Ralph Womack, Laurie
Montes, Deanna Solina etc. re: “Possible FLSA training-possible
overtime issue.”

007810
007809

7.

Email between Laurie Montes and Ralph Womack dated February
13, 2013 entitled “meeting.”

8.

January 5, 2014 - Stockton Ceasefire One-Year Implementation
Update California Partnership for Safe Communities.

9.

April 2014 email correspondence from Frances Hutchins of BHS to
Alicia Duer and Ken Praegitzer regarding new MHSA plan,
regulations and end of current BHS funding program.

004005-004006

10.

May 20, 2014- Job Description for City of Stockton OVP Manager
position

000073-000075

11.

Comprehensive Summary of City of Stockton Unrepresented
Management/Confidential and Law Employees Compensation Plan
(July 1, 2014)

000082-000113

12.

Stockton Municipal Code, Charter, and Civil Service Rules,
Section 1201 (“City Manager shall appoint all officers and
employees of the City of Stockton)

17
18
19
20
21

007811
Exhibit Q to
Declaration of
Jessica Glynn

22
23
24
25
26
27
28

33

1
13.

San Joaquin MHSA Three-Year Program and Expenditure Plan 2014-15 – 2016-17 – February 24, 2014 Presentation to Steering
Committee

JG000717JG 000738

14.

San Joaquin County Behavioral Health Services Prevention and
Early Intervention Evaluation Report – Fiscal Year 2012/2013
(Prepared June, 2014)

JG000861JG 000978

15.

San Joaquin County Behavioral Health Services Mental Health
Services Act (MHSA) Three Year Program and Expenditure Plan2014-2017 (September, 2014)

JG000739JG000860

16.

City of Stockton’s September 26, 2014 Job Offer letter to Jessica
Glynn for OVP Manager position

000008

17.

2

Christian Clegg’s October 6, 2014 email to David Bennett re:
Office of Violence Prevention: “We have hired a very qualified
candidate to head up the office.”

000883

18.

Kurt Wilson’s October 8, 2014 memorandum to Teresia Zadroga
Haase, Human Resources Director, re: Office of Violence
Prevention Manager-Step 6.

000063

19.

Email correspondence between Plaintiff and Christian Clegg dated
October 9, 2014 entitled “Couple of items”

000315

3
4
5
6
7
8
9
10
11
12
13
14
15
16

21.

Plaintiff’s September 26, 2014 job offer letter signed October 8,
2014.
Ken Praegitzer October 8, 2014 memorandum to Peacekeepers re:
Operation Peacekeeper Core Objectives

008468-008470

22.

Email chain between Jessica Glynn and Christian Clegg dated
October 9, 2014 at 9:24 AM entitled” Couple of items”

JG 000012JG 000013

Defendant City of Stockton Human Resources (Mary Johnson,
Human Resources Technician) confirming Jessica Glynn’s
appointment to OVP Manager position, and attaching October 10,
2014 correspondence from Deanna Solina) re: confirmation of
approval of Glynn’s appointment to OVP Manager position.

JG 000274JG 000281

October 20, 2014 email correspondence between Plaintiff and
Karen Costa regarding setting up an appointment for Plaintiff with
City Manager Kurt Wilson
October 21, 2014 2:03 pm email correspondence between
Plaintiff and Karen Costa

006937

17

20.

18

000008

19
20
21
22

23.

23
24
25

24.

26
27

25.

28
34

006903

1

26.

2
3

27.

4
5
6

28.

October 21, 2014 2:17 pm email correspondence between
Plaintiff and Karen Costa

006904

October 21, 2014 2:19 pm email correspondence between
Plaintiff and Karen Costa regarding scheduling appointment for
Plaintiff and Director of Human Resources DeAnna Solina, and
request for Plaintiff to immediately call Ms. Solina.

006905

October 24, 2014 email correspondence from Stewart Wakeling,
CPSC re: new OVP “Director,” Jessica Glynn.

000384

7

30.

October 24, 2014 email correspondence from Christian Clegg to
Jessica Glynn re: “On the phone with IT”
November 7, 2014.email correspondence from Stewart Wakeling,
CPSC re: new OVP “Director, Jessica Glynn.”

000385

31.

Plaintiff’s November 7, 2014 email correspondence to
Peacekeepers re: Youth Outreach Coordinator Position Vacancy

0006761

32.

November 10, 2014 email correspondence from Plaintiff to
Christian Clegg re: follow up on scheduling a further “Meeting with 001006
Kurt re: legal and safety concerns of Peacekeepers.”

33.

November 10, 11 and 12 email correspondence from Stewart
Wakeling of CPSC regarding CalGrip grant application rejection.

34.

November 11, 2014 email correspondence from Ken Praegitzer to
Robina Asghar, Executive Director of CPFSJ re: OVP “Director,
Jessica Glynn.”

006726

35.

Jaime Constantino’s November 12, 2014 email to Plaintiff with his
application for the Supervisor position.

005254

8

29.

9
10
11
12
13

000461

14
15
16
17
18
19
20
21

36.

22
23
24
25
26
27

CPSC 11621163; CPSC
1262-1265

November 13, 2014 email correspondence where Plaintiff directed
006706
Operation Peacekeeper Program Manager Ken Praegitzer, to
postpone the scheduled November 19, 2014 “Core Group” meeting,
in light of the Peacekeeper information sharing and legal issues
Plaintiff had recently raised.

37.

Plaintiff’s November 19, 2014 emails regarding scheduling of
internal staff interviews

006662-006664

38.

November 17, 2014 email correspondence from Plaintiff to Alicia
Duer, Christian Clegg and Ken Praegitzer re: BHS Proposal and
MOU

006684;

28
35

006687

1

39.

November 18, 2014 email correspondence from Florence Low to
Plaintiff re: Staff Report and Reso for the BHS Grant 2014-15

005084-005090

40.

November 19, 2014 email correspondence from Plaintiff in follow
up to request for scheduling meeting with city Manager, City
attorneys and Police chief regarding Plaintiff’s legal concerns.

006652

41.

November 20, 2014 memorandum from Jessica Glynn to Jose
Gomez and Ken Praegitzer re: Youth Outreach Coordinator
Transition

006200

42.

December 18, 2014 email from Frances Hutchins of BHS, that a
new Request for Proposal would be issued “in early 2015.”

009610

43.

January 5, 2015 email correspondence from Jose Gomez to Sammy
Nunez, Executive Director of Father & Families, re: Jessica Glynn
as new OVP Director.

005341-005342

2
3
4
5
6
7
8
9
10
11
12

44.

13
14
15
16

January 13, 2015 email correspondence from Florence Low to
Plaintiff, Alicia Duer and Ken Praegitzer re: PEI Funding for
Operation Peacekeepers, with embedded emails of (1) December
18, 2014 from Frances Hutchins to Alicia Duer and Ken Praegitzer
and (2) April 11, 2014 from Frances Hutchins to Alicia Duer and
other recipients regarding PEI meetings; “Thank you for attending
yesterday..”

004005-004006
004384-4385

45.

Email Chain between Florence Low, Jessica Glynn, Ken Praegitzer,
009040-009042
Alicia Duer, and Frances Hutchins dated January 14, 2015 at 2:13
PM entitled “Re: Fwd: PEI funding for Operation Peacekeepers.”

46.

January 16, 2015 email correspondence from Plaintiff to Alicia
Duer requesting a meeting to discuss the letter of intent process for
the BHS grant, and asking for Ms. Duer’s help.

009044

47.

January 16, 2015 auto-reply from Ms. Duer’s email to Plaintiff,
indicating Ms. Duer was out of the office from January 16, 2015
until Tuesday January 20, 2015.

003588

48.

January 26, 2015 email from Plaintiff to Alicia Duer re: Letter of
Intent advice.

009043

49.

January 26, 2015 email from Alicia Duer to Plaintiff stating “City
offices are closed Friday January 23, 2015.

004796

50.

Jose Gomez’s January 28, 2015 memorandum to Christian Clegg
re: “Bias treatment of Employees and Hostile Work Environment.”

002699-002702

17
18
19
20
21
22
23
24
25
26
27
28

36

1

51.

January 29, 2015 email correspondence from Ken Praegitzer Judy
at Heritage Eye Skin & Laser Center, dated January 29, 2015 re:
Jessica Glynn/new OVP Director.

005057

52.

January 30, 2015 email correspondence from Michael Tubbs re:
“Intro” to New Director Jessica Glynn.”

007802

53.

Christian Clegg notes re: investigation/ interviews Constantino and
Gomez

02703-002705

54.

Christian Clegg 2/15 notes re: ”Summary of Key Issues –
Management style and fit of Jessica Glynn as OVP Manager.”

002706-2707

55.

Christian Clegg 2/15 notes re: “Notes re: Concerns related to
Jessica Glynn’s management style and performance.”

002711-002719

56.

February 4, 2015 email correspondence from Alicia Duer to
Frances Hutchins at BHS re: “PEI Funding for Operation
Peacekeepers.”

007262

57.

February 4, 2015 email correspondence from Frances Hutchins at
BHS to Alicia Duer

007262

58.

February 5, 2015 email from Alicia Duer to Plaintiff, forwarding
Frances Hutchins email and stating “I guess we may have missed it.
Still going to research to be sure.”

007231

59.

February 5, 2015 email from Alicia Duer to Plaintiff re: PEI
Funding for Operation Peacekeepers, stating “Let me know what I
can do to assist.”

005529

60.

February 10, 2015 email correspondence from Plaintiff to various
Ceasefire partners with Call-In rehearsal agenda.

000386-000387

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21

61.

22
23
24

February 11, 2015 email correspondence from Gretchen Newby/
Executive Director of Friends Outside to Plaintiff
Jessica Glynn right after the February 11, 2015 Call-in rehearsal
ended.

005335-005336

62.

February 11 - 12, 2015 email correspondence between Plaintiff and
Billy Olpin of BHS.

005327

63.

February 13, 2015 email from Karen Heil of Mule Creek Prison to
Plaintiff re: Call In success.

005306

64.

Text messages exchanged between Plaintiff Jessica Glynn and City
Councilman Michael Tubbs on February 13- 14, 2015.

JG 000361JG 000362

25
26
27
28

37

1
2

65.

February 13, 2015 Correspondence from Kurt Wilson to Plaintiff
re: termination of employment, with attachments.

000006-000007

66.

March 10, 2015 correspondence from Tom. Amato and Rev. Ernest
Williams’ to City Manager Kurt Wilson, with copies to the Mayor,
City Council, Police Chief Eric Jones and Jessica Glynn.

JG 000077 –
JG 000078

67.

Operation Peacekeeper Program Policies and Procedures (Created
January 2008)(6th Revision effective August 15, 2015)

3
4
5
6
7
8

68.

Plaintiff Jessica Glynn’s Calendar (10/14 – 2/15)

008446-008455

9
10

69.

11
12
13

70.

71.

Plaintiff Jessica Glynn’s moleskin notebook (10/14 – 2/15)

JG 00079- JG
000140

Declaration of Kurt Wilson dated May 10, 2016

JG 000932JG 000967

Declaration of Pheakday Youn dated June 17, 2016.

JG 000973JG 000974

Declaration of Florence Low dated May 9, 2016

JG 000928JG 000931

Declaration of Christian Clegg dated May 10, 2016

JG 000968JG 000969

Declaration of Florence Low dated June 23, 2016.

JG 000970JG 000972

Declaration of Jaime Constantino dated May 6, 2016

JG 000926JG 000927

Declaration of Ken Praegitzer dated May 9, 2016

JG 000924JG 000925

Printout from www.GovCB.com re: BHS Grant RFP

JG 000921

Printout from www.californiabids.com re: BHS Grant RFP

JG 000922JG 000923

Printout from www.usaopps.com re: BHS Grant RFP

JG 000922-JG
000923

14
15

72.

16
17

73.

18
19
20

74.

75.

21
22

76.

23
24

77.

25

78.

26
27

79.

28
38

1

Printout from NAPC web site re: BHS Grant RFP

JG 000917- JG
000918

81.

2016 Printout from City of Stockton’s current website re: Alicia
Duer “Grant Manager” and point of contact.

JG 000709JG 000711

82.

12/26/14 email from Starr Leasing Department to Jessica Glynn
regarding inquiry for 144 Walnut house lease

JG 000632

83.

12/31/14 Email exchanges between Jessica Glynn and Debra Glynn
regarding 144 E. Walnut Street, Stockton house lease

JG 000631

84.

1/6/15 email correspondence exchanged between Jessica Glynn and JG 000633
Eric Sotelo/Realtor re: 144 E. Walnut Street, Stockton house lease

85.

1/7/15 email correspondence exchanged between Jessica Glynn and JG 000634
Eric Sotelo/Realtor re: 144 E. Walnut Street, Stockton house lease

86.

1/7/15 Email exchanges between Jessica Glynn and Debra Glynn
regarding 144 E. Walnut Street, Stockton house lease

JG 000635

87.

1/14/15 email correspondence exchanged between Jessica Glynn
and Eric Sotelo/Realtor re: 144 E. Walnut Street, Stockton house
lease

JG 000636

88.

Residential Lease – One year term – Jessica Glynn/Santiago
Salinas for 144 E. Walnut Street, Stockton house lease executed
1/16/15

JG 000638JG 000643

89.

1/24/15 email correspondence exchanged between Jessica Glynn
and Eric Sotelo/Realtor re: 144 E. Walnut Street, Stockton house
lease –move in date

JG 000637

80.

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22

90.
91.

23
92.
24

Craig Enos - Defense Expert Report – March 30, 2016 and exhibits
thereto
June 2, 2016 email chain between Jessica Glynn, and Rebecca
Zaras and Kathy Brown of YWCA re: Meeting with Sherriff
June 2-6, 2016 email chain between Jessica Glynn, and Grace
Lubwama, Rebecca Zaras and Kathy Brown of YWCA re: Meeting
with Kalamazoo prosecuting attorney

ECF # 17
JG 000644
JG 000645 –
JG 000649

25
26

93.

June 16, 2016 Article – Local Coalition Working to Stop Violence

JG 000 651-655

27
28

94.

Plaintiff/YWCA $5K Contract and invoice
39

JG 000656-

1

JG 0006661

2
3
4

95.

July 6, 2016 email from Sarah Baker re: Violence Prevention Task
Force meeting

96.

July 8, 2016 email from William re: Human Trafficking Task Force JG 000667meeting
JG 000668

97.

July 11, 2016 email from Jessica Glynn re: Human Trafficking
Task Force meeting

JG 000669JG 000670

July 12, 2016 email from Sarah Baker re: Violence Prevention

JG 000671JG 000672

99.

July 13, 2016 email from Sarah Baker to William re: Human
Trafficking Task Force meeting

JG 000673JG 000674

100.

July 14, 2016 email from Grace Lubwama/CEO of YWCA
Kalamazoo re: grant opportunities

JG 000675JG 000679

101.

July 14, 2016 email from Sarah Baker re: Human Trafficking Task
Force meeting

JG 000680JG 000681

102.

July 18, 2016 email from Jessica Glynn re: Human Trafficking
Task Force-Protocol Working Group

JG 000682JG 000683

103.

July 21, 2016 email from Jessica Glynn re: Human Trafficking
Task Force-Protocol Working Group

JG 000684JG 000685

104.

July 29, 2016 email from Sarah Baker re: Opportunities to support
Violence Prevention and Build a Healthier community

JG 000686JG 000687

August, 2016 YWCA Kalamazoo/Jessica Glynn job offer letter

5
6

JG 000662JG000666

7
8

98.

9
10
11
12
13
14
15
16
17
18
19
20

105.

21

106.

August 9, 2016 email from Danielle Sielatycki re: Kalamazoo
Violence Prevention Task Force Reminder 8.11.16

JG 000689JG 000690
JG 000691JG 000692

107.

July 21, 2016 Article Re: Operation Ceasefire effort in Kalamazoo,
MI.

JG 000696JG 000706

108.

October 11, 2012 Article re: Kalamazoo commitment to Ceasefire
initiative.

JG 000707JG 000708

Jessica Glynn updated resume, August 2016.

JG 000974JG 000975

22
23
24
25
26
109.
27
28
40

1
2

Exhibit
A (1-3)

3
4

B

City of Stockton Offer of
000008
Employment to Jessica Glynn
dated September 26, 2014 and
signed by Glynn on October 8,
2014

C

Email between Clegg, E.
Jones, and Wakeling dated
October 7, 2014 entitled
“October 22nd – meeting with
OVP director and community
engagement lead”

001337

D

Memorandum between Kurt
Wilson and Teresia ZadrogaHaase dated October 8, 2014
entitled “Office of Violence
Prevention Manager – Hire at
Step 6”

000063

E (1-2)

Email chain between Jessica
000315
Glynn and Christian Clegg
dated October 9, 2014 at 9:24
AM entitled” Couple of items”

F (1-3)

Press Release dated October
10, 2014 “Stockton
Announces Two Key
Positions Filled: Director
Community Services and
Office of Violence Prevention
Manager Selected”

001815-1817

G

Correspondence between
Jessica Glynn and Deanna
Solina dated October 10, 2014
entitled “Office of Violence
Prevention Manager”

000028

H (1-3)

Email chain between Christian JG000014-0000016
Clegg, Jessica Glynn, and
Connie Cochran dated
October 14, 2014 between
11:43 AM and 10:00 PM

I

Email chain between Jessica
Glynn and Karen Costa dated
October 21, 2014 between
12:38 PM and 2:17 PM

5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Attachment E: Defendant’s Exhibit List
Description
Bates-stamp
Office of Violence Prevention 000073-000075
Manager Job Description

41

006904

1
2

entitled “Meetings with HR”
J (1-2)

Email chain between Jessica
Glynn and JoAnne Montanez
dated October 23, 2014 at
10:39 AM entitled “Re:
Privilege for communications
between Peacekeepers and
clients”

K

Email between Jessica Glynn
006831
and Jose Gomez dated
October 30, 2014 at 10:45 AM
entitled “Non-Exempt”

L (1-12)

Operation Peacekeeper
Program Policies and
Procedures – Created January
2008, 4th revision effective
May 15, 2013

005072-005083

M (1-4)

Inter-Office Memorandum
between Jose Gomez to
Christian Clegg dated January
28, 2015 entitled “Bias
Treatment of Employees and
Hostile Work Environment

002699-002701

N (1-3)

Clegg notes from 2/2 of
meeting between he and Jose
Gomez regarding claim of
hostile work environment
Christian Clegg’s type-written
notes entitled “OVP Notes”

002703-002705

Christian Clegg’s type-written
notes entitled “Summary of
key Issues – Management
Style and fit of Jessica Glynn
as OVP Manager”
Email between Glynn, Alicia
Duer, Christian Clegg, and
Ken Praegitzer dated
November 17, 2014 at 10:32
AM entitled “BHS proposal
and MOU”
Email between Plaintiff,
Alicia Duer, Florence Low,
Christian Clegg, and Ken
Praegitzer dated November
17, 2014 at 12:02 PM entitled
“Re: BHS proposal and
MOU”
Email between Florence Low

002706-2707

3
4
5
6
7
8
9
10
11
12
13
14
15
16
17

O (1-9)

18
19

P (1-2)

20
21
Q
22
23
24
R
25
26
27
28

S (1-3)

42

006882-006883

002711-002719

006684

006687

005084-005085; 005090

1
2
3
T (1-2)
4
5
6
7

U (1-4)

8
9
10
11

V

12
13

and Jessica Glynn dated
November 18, 2014 at 4:31
PM entitled “Staff Report and
Reso for the BHS Grant 201415”
Email chain between Florence 004384-4385
Low, Jessica Glynn, Ken
Praegitzer, Alicia Duer, and
Frances Hutchins dated
January 13, 2015 at 3:38 PM
entitled “Fwd: PEI funding for
Operation Peacekeepers”
Email Chain between Florence 009040-00942
Low, Jessica Glynn, Ken
Praegitzer, Alicia Duer, and
Frances Hutchins dated
January 14, 2014 at 2:13 PM
entitled “Re: Fwd: PEI
funding for Operation
Peacekeepers”
Email between Alicia Duer
003588
and Jessica Glynn dated
January 16, 2015 at 2:41 PM
entitled “Re: Letter of intent
advice (OUT OF OFFICE)”

14
15

W

Email between Alicia Duer
and Jessica Glynn dated
January 26, 2015 at 3:02 PM
entitled “Re: Letter of Intent
advice”

004796

X

Email chain between Frances
Hutchins and Alicia Duer
dated February 4, 2015 at 1:42
PM and 1:52 PM entitled
“Fwd: PEI funding for
Operation Peacekeepers”
Email chain between Alicia
Duer and Jessica Glynn dated
February 4, 2015 at 5:33 PM
entitled “Fwd: RE: PEI
funding for Operation
Peacekeepers”
Email chain between Alicia
Duer and Jessica Glynn dated
February 5, 2015 at 9:57 AM
entitled “Re: PEI funding for
Operation Peacekeepers”
Email chain between Jessica
Glynn and Karen Costa dated
November 24, 2014 at 10:07
AM entitled “Office assistant

007262

16
17
18
19
20
21

Y

22
23
24

Z

25
26
27
28

AA

43

007276

007231

006213

1
BB
2
3
4
5
6

CC (1-3)

7
8
9
10
11

DD

Email chain between Jessica
Glynn, Debbie Shipp, and
Mary Johnson dated
December 9, 2014 between
3:46 PM and December 10,
2014 at 11:58 AM entitled
“Update re Interviews next
Tuesday, Dec. 9, for Office
Assistant – OVP”

002072

EE (1-2)

Email chain between Jessica
Glynn, Mary Johnson, Debbie
Shipp, and Christian Clegg
dated December 15, 2014
between 2:44 PM and 3:35
PM entitled “Re: Latoya
Simmons”
Email chain between Jessica
Glynn and Christian Clegg
dated November 5, 2014 at
4:55 PM and January 2, 2015
at 11:28 AM entitled “Two
items”
Email between Laurie Montes
and Ralph Womack dated
January 29, 2013 at 7:24 PM
entitled “FLSA training”
Email chain between Ralph
Womack, Tami Matuska,
Laurie Montes, and DeAnna
Solina dated January 30, 2013
at 10:12 AM and 10:19 AM
entitled “Re: Possible FLSA
training – possible issue
regarding overtime”

000565-566

12
13
14
15
16
17
18
19

FF

20
21
22

GG

23
24
25
26
27
28

candidates”
Email chain between Jessica
002091
Glynn, Christian Clegg, and
Debbie Shipp dated November
24, 2015 between 10:59 AM
and 5:11 PM entitled “Re:
Interview Schedule for
Tuesday, Nov. 25—Office
Asst II – OPV”
Email chain between Jessica
006388-6389;006394
Glynn, Debbie Shipp, Karen
Costa, and Florence Low
dated December 5, 2014 at
3:20 PM through December 9,
2014 at 4:02 PM entitled
“Update re Interviews next
Tuesday, Dec. 9, for Office
Assistant – OVP”

HH

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006630

007810

007809

1

II

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3

JJ (1-2)

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5

KK

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LL (1-2)

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11

MM (1-19)

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13

NN (1-17)

14

OO (1-17)

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16

PP

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QQ
RR

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21

SS

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TT

Email between Laurie Montes
and Ralph Womack dated
February 13, 2013 at 4:04 PM
entitled “meeting”
Instant Message Chain
between Jessica Glynn and
Michael Tubbs dated February
13, 2015 at 8:27 PM
Email between Jessica Glynn
and Christian Clegg dated
October 24, 2014 between
8:41 AM and 12:18 PM
entitled “Re: On the phone
with IT”
Email chain from Christian
Clegg and Jessica Glynn dated
October 14, 2014 at 10:09 PM
and October 15, 2015 at 9:23
AM entitled “Re: Thursday”
Jessica Glynn’s June 17, 2016
declaration in support of her
Opposition to the City’s
Motion for Summary
Judgment
Expert Report of Jubin Merati,
Ph.D., and attached exhibits
Expert Report of Joanne
Latham, M.A., CRC, MFT,
CCM, ABVE/D, CLCP and
attached exhibits
City of Stockton
Hire/Personnel Action Form
dated October 10, 2014
City of Stockton Employment
Categories
Email chain between Jessica
Glynn and Christian Clegg
dated October 29 and 30, 2014
at 9:23 AM and 12:03 PM
entitled “My schedule today”
Plaintiff produced
approximately three hundred
additional documents
regarding her damages on
August 9, 2016. The City has
not been able to review the
entire production. The City
reserves the right to use any of
Plaintiff’s production Batesstamped 000644-000976.
Email chain between Trevor
Womack and Christian Clegg
dated January 13, 2015 at 2:08
PM entitled “FW: Ceasefire
45

7811

JG000361-000362

006875

JG000019-000020

Not Bates-Stamped: will be
marked KK -1 through KK19.
ECF Doc. 18 filed April 4,
2016
ECF Doc. 18 filed April 4,
2016
000011
000080
000547

000309

1

re-entry call-in workshop
confirmation for 1/15 at 1pm”

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UU
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5

VV (1-5)

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11

WW (1-2)
XX (1-2)

Email chain between Christian
Clegg and Glenn Shields and
Jose Rodriguez dated October
9, 2014 at 9:42 AM entitled
“Jose and Pastor Shields”
City of Stockton Invitation for
Applications for Office of
Violence Prevention Manager
Resume of Jessica Glynn to
City of Stockton
Email chain between Jessica
Glynn and Alicia Duer dated
January 16, 2015 at 2:41 PM;
January 20, 2015 at 2:18 PM;
and January 26, 2015 at 11:02
PM entitled “Letter of intent
advice”

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46

000320

000359-000360; 002151-2153
000039-000040
009042-009043

1

Attachment F: Plaintiff’s Discovery Documents Plaintiff Intends to Use at Trial

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4

1.

5

2.

6

3.

7

4.

DISCOV ERY DOCUMENT NAME
Defendant City of Stockton’s Amended Initial Disclosures
Defendant City of Stockton’s responses to RFPD, Set One
Defendant City of Stockton’s Supplemental Responses to RFPD, Set One
Defendant City of Stockton’s Supplemental Responses to RFPD, Set One –
Privilege Log

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9

5.

10

6.

11

7.

12

8.

13
14
15

9.
10.

Defendant City of Stockton’s Responses to RFPD, Set Two
Defendant City of Stockton’s Responses to RFPD, Set Three
Defendant City of Stockton’s Responses to RFPD, Set Four
Defendant City of Stockton’s Responses to RFPD, Set Five
Defendant City of Stockton’s responses to Special Interrogatories, Set One
Defendant City of Stockton’s Supplemental Responses to Special Interrogatories,
Set One

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25
26
27
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47

1

Attachment G: Deposition Transcripts Plaintiff Intends to Use at Trial
DEPOSITION TRANSCRIPT
PORTIONS FOR USE AT TRIAL

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1.

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5

Deposition transcript of Defendant, City of
Stockton Person Most Qualified (PMQ)
Designee, Christian Clegg, Volume I, taken
on October 27, 2015.

Page/line: 19:14-20:3; 36:10-38:5;
38:20-22; 39:19-43:8; 44:21-45:13;
46:6-61:25; 61:6; 63:1-25; 64:1-4;
65:4-9; 73:3-13; 83:19-85:14; 86:791:18; 97:12-98:1; 99:14-100:12;
120:4-12; 121:5-13; 122:5-8;
123:12-17; 125:3-19; 128:10133:12; 136:15-137:-10; 148:5-8;
151:2-169.19; 171:15-175:1;
174:17-175:2; 175:11-183:2;
186:20-22; 190:16-197:18; 197:19202:6; 202:14-209:25; 210:9226:7; 226:9-230:13; 235:12236:14; 240:1-14; 241:3-12;
241:24-242:14; 243:13-18; 243:25244:20; 249:8-12; 254:2-256:5;
Exh. 3 (pages 2606-2607); Exh. 11.

Deposition transcript of Defendant, City of
Stockton Person Most Qualified (PMQ)
Designee, Christian Clegg, Volume II, taken
on October 28, 2015.

Page/line: 236:20-22; 267:2274:25; 278:13-280:3; 281:6282:4; 284:25- 287:3; 287:4-288:6;
289:18-297:25; 299:17-300:20;
301:2-5; 304:25-305:19; 305:7-10;
308:15-311:5; 312:12-19; 336:15337:11; 337:22-25; 338:3-11;
343:15-344:2; 345:2-7; 345:17-24;
352:16-25; 353:1-359:4; 359:17360:1; 397:11-401:14; 415:22416:17; 418:21-425:8; 426:25444:19; 446:6-11; 455:15-456:7;
485:23-487:11; 494:11-496:22.

Deposition transcript of Defendant, City of
Stockton Person Most Qualified (PMQ)
Designee Kurt Wilson, taken on October 29,
2015.

Page/line: 4:13-21; 9:17-11:2;
12:4-13:3; 16:5-18:12; 22:2126:21; 28:4-8; 29:11-23; 32:17-20;
35:5-21; 42:21-25; 50:9-14; 53:354:6; 58:5-12; 60:17-61:16; 62:2163:16; 63:19-24; 64:12-16; 64:2266:4; 66:18-69:22; 70:12-21;
71:11-71:25; 72:15-18; Exh. 14;
Exh. 15;

Deposition transcript of Defendant, City of

Page/line: 6:1-15; 10:6-18; 11:14-

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14

2.

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20
21
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23

3.

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25
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27
28

4.

48

1

Stockton Person Most Qualified (PMQ)
Designee Ken Praegitzer, taken on
November 9, 2015.

2

16:1; 13:1-9; 17:11-19:3; 19:1521:11; 20:1-22:21; 23:17-24:4;
25:20-27:17; 28:4-30:10; 32:9-14;
33:7-35:25; 33:20-35:6; 36:4-9;
37:6-22; 38:16-39:11; 39:24-41:8;
41:22-43:7; 43:16-45:6; 46:747:14; 48:18-49:24; 49:1-22;
53:15-56:12; 61:3-62:4; 63:1-11;
73:23-74:12

Deposition transcript of Defendant, City of
Stockton Person Most Qualified (PMQ)
Designee Deanna Solina, taken on
November 9, 2015.

Page/line: 4:13-16; 5:3-6:11; 8:1813:2; 13:15-14:24; 15:13-15:24;
16:22-18:23; 19:3-22:17; 23:2424:4; 24:18-27:12; 27:22-29:7;
29:19-24; 30:6-33:19; 33:25-35:9;
35:11-41:9; Exh. 32

Deposition transcript of Defendant, City of
Stockton Person Most Qualified (PMQ)
Designee Stephanie Van Steyn, taken on
October 29, 2015.

Page/line: 4:13-5:16; 8:3-16; 9:1411:19; 13:6-14:1; 14:2-25; 15:1719:3; 20:21-21:20; 22:5-24:19;
24:23-26:25; 28:1-29:11; 29:1430:19-31:7; 40:6-42:22; 43:2451:5; 55:23-57:3; 59:9-15; 60:962:17; 64:7-14; 65:2-5; 65:1966:16; 74:23-76:3; 76:4-11; 76:578:1 76:24-77:18; 79:9-81:7;
81:23-98:12; Exhs. 16; 17; 23; 24;
25; 26.

Deposition transcript of Defendant, City of
Stockton Person Most Qualified (PMQ)
Designee Trevor Womack, taken on
November 20, 2015.

Page/line: 4:13-17; 5:6-12; 7:198:3; 9:11-10:19; 11:1-14:3; 15:1416:25; 18:3-19:15; 21:3-25:18;
25:23-31:6; 31:18-36:5; 36:1738:15; 39:1-45:11; 46:4-47:9;
47:13-17; 48:5-49:13; 49:21-51:12;
52:1-56:11; 57:17-24; 59:1-6;
60:22-61:14; 63:23-65:8; 66:7-15;
75:19-77:10; 78:13-25; Exh. 34.

Deposition transcript of Defendant, City of
Stockton Person Most Qualified (PMQ)
Designee Laurie Montes, taken on October
29, 2015.

Page/line: 4:22-25; 11:5-13:16;
13:23-20:25; 21:11-16; 21:22-22:8;
22:24-31:15; 31:20-33:2-36:23;
49:24-50:12.

Deposition transcript of Savong Lam, taken
on February 17, 2016.

Page/line: 6:16-8:18; 10:19-11:25;
40:6-41:3. 32:20-35:7; 44:1445:22; 55:6-57:13; 57:17-58:20.

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5.

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6.

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18

7.

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8.

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25
26

9.

27
28
49

1
2

10.

Deposition transcript of Matthew Lam, taken
on February 29, 2016.

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Page/line: 4:3-18; 9:9 – 12; 10:24 –
12:19; 14:17 – 17:1; 20:10 – 21;
21:2-24:23; 33:23-34:17; 38:2241:1; 3:12-21; 42:23-25; 43:1246:20; 47:9 – 51:14; 52:19- 53:12;
54:9 – 24; 55:20 – 60:8; 65:4 – 12;
70:20 – 73:23; 74:22-77:10; 78:22
– 80:12; 83:5- 88:23 - 89:22; 91:694:1; 94:9 – 95:13; 114:25 –
115:13.

1

Attachment H: Defendant’s List of Deposition Transcripts and Discovery Responses

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3
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5
6
7
8
9

Deposition Transcripts:
1.
Plaintiff Jessica Glynn
2.
Michael Lam
3.
Robina Asghar
4.
Savong Lam
5.
Jose Gomez
6.
Ken Praegitzer
7.
Moses Zapien
8.
Santiago Salinas
9.
Debra Glynn
10.
Craig Enos
11.
Gene Acevedo

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11
12

Discovery Responses:
1.
Plaintiff’s Expert Disclosures
2.
Plaintiff’s Responses to City’s Special Interrogatories, Set One

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