Taylor v. City and County of San Francisco

Filing 32

ORDER Allowing Parties to File Discovery Letter Regarding Production of City Documents and Identification of City Employees Receiving Public Assistance Re: 31 Stipulated Motion for Administrative Relief filed by City and County of San Francisco. Signed by Judge Charles R. Breyer on 2/3/2015. (mklS, COURT STAFF) (Filed on 2/3/2015)

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DENNIS J. HERRERA, State Bar #139669
City Attorney
ELIZABETH S. SALVESON, State Bar #83788
Chief Labor Attorney
ERIK A. RAPOPORT, State Bar #187059
Deputy City Attorney
Fox Plaza
1390 Market Street, 5th Floor
San Francisco, California 94102-5408
Telephone:
[phone]
Facsimile:
[phone]
E-Mail:
[e-mail]

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Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO
RACHEL LANGSTON, State Bar #257950
LEGAL AID SOCIETY
EMPLOYMENT LAW CENTER
180 Montgomery Street, Suite 600
San Francisco, California 94104
Attorneys for Plaintiff
KUIANA TAYLOR

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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KUIANA TAYLOR,

Case No. CV 14 3555 CRB

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Plaintiff,
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vs.
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CITY AND COUNTY OF SAN
FRANCISCO,

STIPULATED MOTION FOR
ADMINISTRATIVE RELIEF; AND
[PROPOSED] ORDER ALLOWING PARTIES
TO FILE DISCOVERY LETTER REGARDING
PRODUCTION OF CITY DOCUMENTS AND
IDENTIFICATION OF CITY EMPLOYEES
RECEIVING PUBLIC ASSISTANCE

Defendant.
Civ. Local Rules 7-11 and 7-12

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Plaintiff Kuiana Taylor and Defendant City and County of San Francisco (collectively, “the

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parties”) hereby move this Court for an order allowing the parties to file a letter brief setting forth the

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parties' respective positions regarding the production of City documents and identification of City

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employees in the City’s Jobs Now program, the job program in which Plaintiff participated. In order

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to qualify for the Jobs Now program, individuals must have received public assistance in the past. It is
Stipulated Motion for Admin. Relief
CASE NO. CV 14 3555 CRB

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the City’s position that information identifying employees who are receiving public assistance is

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protected by California Welfare and Institutions Code section 10850 which makes the disclosure of

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such information a misdemeanor under California law. It is Plaintiff’s position that this information is

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highly relevant and necessary for Plaintiff to litigate her discrimination and harassment claims against

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the City because a number of these individuals were witnesses to Plaintiff’s alleged harassment and/or

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alleged similar claims of harassment against Plaintiff’s supervisor.

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The Parties hereby make this Stipulated Motion for Administrative Relief in order to timely

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resolve this discovery dispute so that documents can be produced and an initial round of depositions

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can occur before the Court ordered mediation, currently set for May 20, 2015, takes place. Waiting 35

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days to resolve this dispute through formal motion procedures would needlessly delay the process and

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possibly prevent the parties from adequately preparing for the mediation. Moreover, filing a single

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letter outlining the parties respective positions will reduce the attorney time spent resolving this

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dispute.

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Dated: January 28, 2015

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LEGAL AID SOCIETY
By: /s/Rachael Langston
RACHAEL LANGSTON

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Attorney for Plaintiff
KUIANA TAYLOR

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dated: January 28, 2015

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DENNIS J. HERRERA
City Attorney
ELIZABETH SALVESON
Chief Labor Attorney
ERIK A. RAPOPORT
Deputy City Attorney

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By: /s/Erik A. Rapoport
ERIK A. RAPOPORT
Attorney for Defendant

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CITY AND COUNTY OF SAN FRANCISCO

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Stipulated Motion for Admin. Relief
CASE NO. CV 14 3555 CRB

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[Proposed] ORDER

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The Court has reviewed the Parties Stipulated Motion for Administrative Relief. Good cause
appearing, and PURSUANT TO STIPULATION, IT IS SO ORDERED – The Parties may file a single

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letter outlining their respective positions regarding the City’s production of documents and

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identification of City employees receiving public assistance.

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Bre

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Judge C

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________________________
O ORD
IT IS S
CHARLES R. BREYER
United States District Judge
yer

February 3, 2015
Dated: ________________

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Stipulated Motion for Admin. Relief
CASE NO. CV 14 3555 CRB

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