Summons and Complaint

AO 440 (Rev 1209) Summons in a Civil Action

UNITED STATES DISTRICT COURT for the

Northern District of California

HOSETTA ZERTUCHE )

Plaintiff ) v ) Civil Action No

COUNTY OF SANTA CLARA JAMES )GLEASON SANDRA EOVINO and KIMBERLY

)

CVII-03691)MARUFFI )

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Defondant

SUMMONS IN A CIVIL ACTION

To (Defondants name and address)

COUNTY OF SANTA CLARA 70 West Hedding Street San Jose CA 95110 JAMES GLEASON 373 West Julian Street San Jose CA 95110 SANDRA EOVINO 70 West Hedding Street San Jose CA 95110 KIMBERLY MARUFFI 373 West Julian Street San Jose CA 95110

A lawsuit has been filed against you

Within 21 days after service of this summons on you (not counting the day you received it) - or 60 days if you are the United States or a United States agency or an officer or employee of the United States described in Fed R Civ P 12 (a)(2) or (3) - you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure The answer or motion must be served on the plaintiff or plaintiffs attorney whose name and address are MICHAEL E ADAMS LA W OFFICES OF MICHAEL E ADAMS 702 Marshall Street Suite 300 Redwood City CA 94063

Ifyou fail to respond judgment by default will be entered against you for the relief demanded in the complaint You also must file your answer or motion with the court

LERK F COURT

JUl 27 2Btt jJ~Date ~ --~OiClDPUtyCle---middotshy

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111 MICHAEL E ADAMS (SBN 47278) LAW OFFICES OF MICHAEL E ADAMS

2 II 702 Marshall Street Suite 300 Redwood City CA 94063

3 II Telephone (650) 599-9463 Fax (650) 599-9785

4 ~0 20 UAttorney for PlaintiffHOSETIA ZERTUCHE 0 omiddot vmiddot iJt~ i1 ~iSk gt let rjCt IngqLI0 Of CoI-~IJ~Jrt

crnaUNITED STATES DISTRICT COURT6

NORTHERN DISTRICT OF CALIFORNIA7

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II HOSETTA ZERTUCHE

11 II Plaintiff

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1311 v

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COUNTY OF SANTA CLARA JAMES GLEASON SANDRA EOVINO and

1611 KIMBERLY MARUFFI

17 Defendants

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19 Plaintiff alleges

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CG 11 - 0 3 6 9 1

COMPLAINT FOR FEDERAL CIVIL RIGHTS VIOLATIONAND JURy DEMAND

JURISDICTION AND VENUE 22

Jurisdiction of this court is invoked pursuant to 28 USCS sect1331 and sect1343 in 23

order to secure protection of and to redress deprivation of civil rights secured by Title 2411

42 USCS sect1983 and the United States Constitution Venue lies with this court within

the meaning of28 USCS sect1391 in that one or more of the Defendants reside or are 26

located in the Northern District of California and most or all of the events or omissions 27

giving rise to the claims herein occurred in said District 28

LAW OFFICES OF

MICHAEL E ADAMS II 1702 MARSHALL ST 11300 REDWOOD CITY CA 94063 ~=~=-=~r1=~~~W~rT~~---~~-----

(650)599-9463 Complamt for Federal CivIl Rights VlOlauon and Jury Demand

1II FACT ALLEGATIONS

211 I PlaintiffHosetta Zertuche is an adult female residing in Redwood City CA

311 2 Defendant Santa Clara County (County) is a governmental entity and its

4 II main offices are located in San Jose CA

5 3 At all times herein involved Defendant James Gleason (Gleason) was and is

6 an attorney employed by the County as Special Assistant to the County Counsel and as

7 II Director of its Independent Defense Counsel Office (IDO)

811 4 At all times herein involved Defendant Sandra Eovino (Eovino) was

9 II employed by the County as Executive Administrative Manager in the Office of County

10 II Counsel

11 II 5 At all times herein involved Defendant Kimberly Maruffi (Maruffi) was

12 II employed by the County as a supervising paralegal in the Office of County Counsel

13 II 6 Each Defendant was the agent and employee of every other Defendant and in

14 II acting as herein alleged acted within the course and scope of said agency and

15 II employment

16 7 Each Defendant was a co-conspirator with every other Defendant and in acting

17 II as herein alleged acted pursuant to their conspiracy to implement the improper purposes

18 thereof

19 8 At all relevant times the IDO administered and continues to administer the

20 II provision of defenses to indigent criminal defendants in the County who could not be

21 II defended by the County Public Defender (PD) because the PD had determined that

22 II conflicts of interest existed between said criminal defendants (conflicts defendants) and

23 II other indigent criminal defendants who were being represented by the PD The IDO

24 II provided defenses to the conflicts defendants by assigning them to private criminal

25 II defense attorneys by paying such attorneys for representing the conflicts defendants and

26 II by providing such attorneys with investigation and other support services to assist them as

27 II needed in representing the conflicts defendants

28 9 At all times herein involved the IDO was and remains a function ofthe Office

LAW OFFICES OF MICHAEL E ADAMS

70Z MARSHALLSTN300 2 REDWOOD CITY CA 94063

(650) 599-9463 Complaint for Federal CiVil Rights VIOlation and Jury Demand

1 II ofCounty CounseL The Office of County Counsel carried out other functions such as

2 II providing legal representation to the Public Guardian in conservatorship proceedings and

311 providing legal representation to sheriffs deputies being sued for alleged misconduct

4 II that created actual or apparent conflicts of interest for the Office of County Counsel in

5 relation to the activities of the IDO Accordingly when the IDO was created the County

611 adopted a formal policy establishing an ethical wall between the IDO and all other

711 functions of the Office of County Counsel (Ethical Wall Policy) The Ethical Wall

8 Policy bars all non-IDO employees ofthe Office of County Counsel from receiving any

9 information concerning IDO activity including the funding and development of defenses

10 for any of the indigent criminal defendants being represented through the IDO

1111 10 At all times herein involved Plaintiff Hosetta Zertuche (Zertuche) was

12 employed by the County as a legal secretary in the IDO In said capacity Zertuches

13 duties were to provide legal and administrative support to Gleason as well as legal

1411 support to IDO staff attorneys Gleason was Zertuches work supervisor and Kimberly

15 Maruffi (Maruffi) was her administrative supervisor

1611 11 Ngoc Lam (Lam) worked as a paralegal in the IDO from approximately

17 November 2009 to April 2010 during which she worked closely with Gleason on IDO

18 II matters In or about April 2010 Lam was reassigned to work as a paralegal in another

19 unit of the Office of County County that pursued contempt proceedings for nonpayment

20 ofchild support and she remains so assigned Despite her reassignment Lam continued

2111 to work closely with Gleason on IDO matters including administrative tasks of the sort

22 that Gleason had previously assigned to Zertuche

2311 12 From April 2010 onward Zertuche became increasingly concerned that

24 Lams continued IDO work constituted a significant breach ofthe Ethical Wall Policy

25 given Lams reassignment to the conservatorship unit Zertuche repeatedly complained to

26 II Gleason but he was gave no consideration to her complaints

2711 13 Zertuche nonetheless persisted with her complaints to superiors about Lams

2811 continued IDO work In late October 2010 Zertuche indicated to Lams supervisor

LAw OFFICES OF MICHAEL E ADAMS

701 MARSHALL ST 11300 3 REDWOOD CITY CA 94063 Complamt for Federal CIvil Rights Violation and Jury Demand(650) 599-9463

111 Barbara Dowdy-Stimac that the Ethical Wall Policy was implicated by the considerable

211 time that Lam was spending in the IDO area In early November 2010 Zertuche

311 informed Maruffi her own administrative supervisor that Lams continued IDa work

411 breached the Ethical Wall Policy Zertuches complaints immediately resulted in an

511 investigation by the County Administrator Sandy Eovino (Eovino) into Lams

611 continued IDO work Eovino interrogated Gleason in late November 2010 about the IDa

711 work that Lam had been doing following her transfer out ofIDO

8 II 14 Immediately following his interrogation by Eovino Gleason retaliated against

9 II Zertuche because she had made the ethical wall complaint concerning his activities with

10 II Lam Gleason initially did so by treating Zertuche in a consistently angry and harsh

11 II manner that contrasted starkly with the consistently genial manner with which he had

1211 previously interacted with her Following said interrogation of Gleason Eovino

13 II compromised her investigation and joined in retaliating against Zertuche because ofher

14 II ethical wall complaint During December 2010 Gleason and Maruffi further retaliated

15 II against Zertuche by giving her an improvement needed rating in the work relations

16 II category of the annual job performance evaluation (JPE) issued to Zertuche on or about

17 II December 20 2011 and Eovino joined Maruffi in defending and refusing to change the

1811 improvement needed rating Said rating was unprecedented in that the JPEs issued

1911 during her previous six years ofCounty employment had always given her above-standard

20 II ratings in the work relations category and had never rated her as less than satisfactory

21 II in any category The improvement needed rating was furthermore unfounded in that

22 II as during her previous years of County employment Zertuche was consistently cordial

23 II and responsive in her relations with other County employees

2411 15 Zertuche who suffers from an anxiety disorder was deeply shaken and upset

2511 by said retaliatory actions Consequently on or about December 232010 Zertuche took

26 II a medical leave from her employment During her medical leave Zertuche was

27 II reassigned from the IDa to a different unit of the Office of County Counsel effective

2811 upon her return to work Pursuant to instructions from her health care provider Zertuche

LAw OFFICES OF MICHAEL E ADAMS 4701 MARSHALL STlOG

REDWOOD CITY CA 94063 Complamt for Federal eml Rights VIOlation and Jury Demand(650) 5999463

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1 I did not return to work until approximately March 21 2011

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311 FIRST CLAIM

411 (Free speech retaliation in violation of 42 USC sect1983)

II 16 Plaintiffrealleges Paragraphs 1 through 15 hereinabove of this Complaint

6 II and each and every allegation thereof as though fully set forth herein

7 II 17 Plaintiffs complaints alleged in Paragraphs 9 and 10 were made outside the

811 scope of her job duties were expressed in a courteous and noninflammatory manner and

9 I involved as issue ofpublic concern namely whether the County was operating the IDO in

II a proper and ethical manner

1111 18 Defendants Gleason Eovino and Maruffi retaliated against Plaintiff for her

121 expression of the above alleged complaints Said retaliation included Gleason treating

1311 Plaintiff in a rude and angry manner Gleason and Maruffi downgrading to improvement

14 II needed the rating in her JPE for the work relations category and Eovino ratifying said

II downgraded rating Gleason Maruffi and Eovino and each of them possessed final

16 I policymaking authority to act on behalf ofthe County in exercising control over

17 Plaintiffs working conditions and evaluating her job performance

1811 19 As the proximate result thereof Plaintiff lost earnings while on medical leave

19 II 20 As the further proximate result thereof Plaintiff has suffered anxiety

II humiliation depression and emotional distress

21 II 21 Defendants Gleason Maruffi and Eivino acted as hereinabove alleged in

2211 reckless disregard for Plaintiffs rights thereby entitling Plaintiff to awards ofpunitive

2311 damages against each of them

2411 22 Pursuant to 42 USC sect1985 Plaintiff is entitled to her reasonable attorneys

fees

26 WHEREFORE Plaintiff prays for relief as follows

2711 1 For general and special damages against all Defendants in the sum of

2811 $15000000

LAw OFFICES 0 MICHA EL E ADAMS

702 MARSHALL ST 1t300 5 REDWOOD CITY CA 94063

(650) 599middot9463 Complamt for Feaeral CIVil Rights VIOlatlon and Jury Demand

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1 II 2 For punitive damages against Defendants Gleason Maruffl Eovino and each

211 of them in the sum of $30000000

3 II 3 For reasonable attorneys fees

4 4 For costs of suit

5 For such other and further relief as this court deems just and proper

6 DATED July 272011

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9 Attorney for Plaintiff HOSETTA ZERTUCHE

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12 JURY DEMAND 13 1 Plaintiff hereby demands a trial jy jury as to all issues raised in the complaint

1411 DATED July 27 2011

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17 HOSETTA ZERTUCHE

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702 MARSHALL ST 11300 6 REDWOOD CITV CA 94063

(650) 599middot9463 Complaint for Federal Civtl Rights VIolation and Jury Demand

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ORIGINAL FiLED

HOSETTA ZERTUCHE

Plaintiff (s) v

COUNTY OF SANTA CLARA ET AL Defendant( s)

JUL 272011 Richard W Wleklng

Olerk US Distriot Court Northem District of CaliforniaNo C 11-03691 HRL San Jose

ORDER SETTING INITIAL CASE MANAGEMENT CONFERENCE AND ADR DEADLINES

IT IS HEREBY ORDERED that this action is assigned to the Honorable Howard R Lloyd When serving the complaint or notice of removal the plaintiff or removing defendant must serve on all other parties a copy of this order the Notice of Assignment of Case to a United States Magistrate Judge for Trial and all other documents specified in Civil Local Rule 4-2 Counsel must comply with the case schedule listed below unless the Court otherwise orders

IT IS FURTHER ORDERED that this action is assigned to the Alternative Dispute Resolution (ADR) Multi-Option Program governed by ADR Local Rule 3 Counsel and clients shall familiarize themselves with that rule and with the material entitled Dispute Resolution Procedures in the Northern District of California on the Court ADR Internet site at wwwadrcanduscourtsgovAlimited number of printed copies are available from the Clerks Office for parties in cases not subject to the courts Electronic Case Filing program (ECF)

IT IS FURTHER ORDERED that plaintiff or removing defendant serve upon all parties the brochure entitled Consenting To A Magistrate Judges Jurisdiction In The Northern District Of California additional copies of which can be downloaded from the following Internet site httpwwwcanduscourtsgov

CASE SCHEDULE -ADR MULTI-OPTION PROGRAM

Date Event Governing Rule

72712011 Complaint filed

9202011 Last day to FRCivP 26(f) amp ADR meet and confer re initial disclosures early LR3-S settlement ADR process selection and discovery plan

file ADR Certification signed by Parties and Counsel Civil LR 16-8 (b) amp (form available at httpwwwcanduscourtsgov) ADR LR 3-S(b

file either Stipulation to ADR Process or Notice of Civil LR 16-8 (c) amp Need for ADR Phone Conference (form available at ADR LR 3-S(b amp httpwwwcanduscourtsgov) Q

1042011 Last day to file Rule 26(t) Report complete initial disclosures or state objection in Rule 26(t) Report and file Case Management Statement per attached Standing Order re Contents of Joint Case Management Statement (also available at httpwwwcanduscourtsgov)

FRCivP 26(a) (I) Civil LR 16-9

1011112011 INITIAL CASE MANAGEMENT CONFERENCE Civil LR 16-10

(CMC) in Courtroom 2 5th Floor SJ at 1 30 PM

If the Initial Case Management Conference is continued the other deadlines are continued accordingly

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

MAGISTRATE JUDGE HOWARD R LLOYD

STANDING ORDER RE INITIAL CASE MANAGEMENT

1 In cases that are randomly assigned to Judge Lloyd for all purposes the parties are requested to file their written consent to the assignment of a US Magistrate Judge for all purposes or their written declination of consent as soon as possible

2 The civil motion calendar is heard on Tuesdays at 1000 am The criminal motion calendar is heard on Thursdays at 930 am Motions may be noticed for hearing pursuant to Civil LR 7 Counsel need not reserve a hearing date in advance for civil motions although noticed dates may be reset as the Courts calendar requires HOWEVER do not notice a motion over a civil discovery dispute Instead follow this courts Standing Order re Civil Discovery Disputes

3 Parties with questions regarding scheduling (excluding settlement conferences) should contact Judge Lloyds Administrative Law Clerk at (408) 535-5411

4 A Case Management Conference will be held on the date and time specified in the Order Setting Initial Case Management Conference in Courtroom 2 United States Courthouse 280 South First Street San Jose California This conference may be continued only by Court Order pursuant to Civil LR 16-2e) Parties may not stipulate to continue a Case Management Conference without Court approval

5 Pursuant to Civil LR 16-9 no later than seven (7) days before the Case Management Conference the parties shall file a Joint Case Management Statement For the required format and contents of this filing follow the Standing Order for All Judges of the Northem District of California Contents of Joint Case Management Statement If preparation of a joint statement would cause undue hardship the parties may serve and file separate statements which shall include a description of the undue hardship

6 Plaintiff or removing Defendant shall serve a copy of this Standing Order on all parties to this action and on all parties subsequently joined in accordance with FedRCivP 4 and 5 Following service Plaintiff shall file a certificate of service in accordance with Civil LR 5-6

IT IS SO ORDERED

Dated August 22 2002 Amended February 26 2007 Amended June 3 2011

HOWARD R LLOYD United States Magistrate Judge



STANDING ORDER RE CIVIL DISCOVERY DISPUTES

1 Effect of Delay on Discovery Disputes

The parties and counsel are cautioned not to allow discovery disagreements to drag on unresolved until some important looming deadline forces them into action Because of the press of its other business the court may not be able to give the dispute its attention with the same celerity that some or all of the parties think is necessary

2 Resolving Discovery Disputes

In order for this court to efficiently and flexibly respond to discovery disputes and accounting both for (1) parties and counsels obligation to diligently strive to resolve such disputes without court involvement and (2) the limitations on available judicial resources effective immediately this court adopts a new procedure for resolving discovery disputes

A Absent leave of court formal noticed discovery motions may no longer be filed and if filed contrary to this order will not be heard

B Instead parties (and non-parties involved in a discovery dispute) will first use the customary convenient means of communication - telephone e-mail correspondence person to person talks between members of opposing litigation teams shyto try to reach agreement

C If that fails to lead to complete agreement then LEAD COUNSEL (and any unrepresented person) accompanied by anyone else whose presence is needed to fully explore resolution shall meet IN PERSON for as long as and as often as is needed to reach full agreement

i Unjustified delay in arranging the meeting especially where the dispute is time sensitive or refusal to attend or to partiCipate meaningfully will be grounds for sanctions andor for entry of an order in favor of the other side Except in extreme circumstances excuses such as press of business inconvenience or cost will not suffice

ii Hopefully the parties can agree on a site for the in-person meeting of lead counsel The most sensible way would probably be for the party advancing the dispute to pick the place for the first meeting the other party pick the site for the second and alternating thereafter If the parties cannot agree then the court requires lead counsel meet at a location approximately half way between their offices

D If the meeting(s) between lead counsel do not resolve the dispute then within 5 business days after conclusion of the session(s) (or 5 days after reaching impasse as to a particular issue) the parties shall file on pleading paper a Discovery Dispute Joint Report _ (Joint Report) In no event maya Joint Report be fried later than 7 days after the discovery cut-off date(s) as prescribed in Civif loR 37-3 As usual a chambers copy should also be submitted

i The Joint Reports cover page will contain the case caption a one sentence identification of the issue it covers the date place and length of time of the jOint meeting the close of discovery and any other date that is relevant and the attestations of lead counsel that they complied with this Standing Order

ii To avoid needless complexity and unwieldiness the Joint Report should deal with only one issue (or at most a few inextricably related issues)

iii The Joint Report including the cover page shall not exceed 11 pages It should describe the dispute and the facts essential to understanding it Then in a format that allows ready comparison it should give each partys position (with brief citation to important authority) and - finally - each partys final and most reasonable proposal for how the court should decide

iv The only exhibit permitted to the Joint Report is an exact copy of the discovery request(s) in issue and the response(s) (if any) to it (ie requests for documents interrogatories privilege log non-party subpoena etc) If it consists of more than just a few pages the exhibit shall be indexed

v A single lead-counsel-in-person session may produce more than one Joint Report but the court would look with disfavor on any attempt to use multiple Joint Reports to skirt the page limitation

vi Unjustified delay or refusal to participate meaningfully in the preparation of the Joint Report is grounds for imposition of sanctions or entry of an order sought by the other side

E Upon receipt of the Joint Report the court will decide what further proceedings if any are appropriate If the issue is clearly presented and ripe for decision it may simply issue a ruling Alternatively other options include scheduling a telephone conference calling for further briefing or rarely holding a hearing

F Any party seeking an award of attorney fees or other expenses in connection with a discovery dispute shall file a noticed motion pursuant to the Northern District Local Rules It would ordinarily be presumptuous to file such a motion before the court has ruled on the dispute

G When the parties have become or expect to become engaged in a succession of discovery disputes or otherwise require the ongoing assistance of a neutral decision maker the court recommends they consider appointment of a Special Master

IT IS SO ORDERED

Dated June 3 2011


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middotC ~ 0 fIl bullbull 5 ~ ~ fIl Cl QJ 5 ~euro 0rnZ 0-5QJ bullbull amp

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IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

NOTICE OF ASSIGNMENT OF CASE

TO A UNITED STATES MAGISTRATE JUDGE FOR TRIAL

Pursuant to General Order 44 the Assignment Plan of the United States District Court for

the Northern District of California this case has been randomly assigned to Magistrate Judge

Howard R Lloyd

Pursuant to Title 28 US C sect 636(c) with written consent of all parties a magistrate judge

may conduct all proceedings in the case Attached is a form to complete if you consent to proceed

before the assigned magistrate judge and a form to complete if you decline to proceed before the

assigned magistrate judge Electronic versions of both forms are also available at the Courts

Internet site httpwwwcanduscourtsgovClick on Forms-Civil A party is free to withhold

consent without adverse consequences If a party declines to consent the case will be randomly

reassigned to a district judge and a case management conference will be scheduled on the district

judges calendar as close as possible to the date presently scheduled before the magistrate judge

You must file your consent or declination by the deadline for filing the initial case

management statement

The plaintiff or removing party shall serve a copy of this notice and all attachments upon all

other parties in the action pursuant to Federal Rules of Civil Procedure 4 and 5

FOR THE COURT

RICHARD W WIEKING CLERK

~~ By Deputy Clerk

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UNITED STATES DISTRICT COURT


No C

Plaintiff(s) CONSENT TO PROCEED BEFORE A UNITED STATES MAGISTRATE JUDGE

v

Defendant( s)

CONSENT TO PROCEED BEFORE A UNITED STATES MAGISTRATE JUDGE

In accordance with the provisions ofTitle 28 USC Section 636(c) the undersigned party

hereby voluntarily consents to have a United States Magistrate Judge conduct any and all further

proceedings in the case including trial and order the entry of a final judgment Appeal from the

judgment shall be taken directly to the United States Court ofAppeals for the Ninth Circuit

Dated ------------~------- Signature

Counsel for ------c---~--

(Plaintiff Defendant or indicateipro sel)

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No C

Plaintiff( s) DECLINATION TO PROCEED BEFORE A MAGISTRATE JUDGE

v AND REQUEST FOR REASSIGNMENT TO A UNITED STATES DISTRICT JUDGE

Defendant( s)

REQUEST FOR REASSIGNMENT TO A UNITED STATES DISTRICT JUDGE

The undersigned party hereby declines to consent to the assignment of this case to a United

States Magistrate Judge for trial and disposition and hereby requests the reassignment of this case to

a United States District Judge

Dated Signature_____________

Counsel for ~--c--~-~__-~-

(Plaintiff Defendant or indicate pro se)

STANDING ORDER FOR ALL JUDGES OF THE NORTHERN DISTRICT OF CALIFORNIA

CONTENTS OF JOINT CASE MANAGEMENT STATEMENT

Commencing March 12007 aU judges of the Northern District of California will require the identical infonnation in Joint Case Management Statements filed pursuant to Civil Local Rule 16-9 The parties must include the following infonnation in their statement which except in unusually complex cases should not exceed ten pages

1 Jurisdiction and Service The basis for the courts subject matter jurisdiction over plaintiffs claims and defendants counterclaims whether any issues exist regarding personal jurisdiction or venue whether any parties remain to be served and if any parties remain to be served a proposed deadline for service

2 Facts A brief chronology ofthe facts and a statement of the principal factual issues in dispute

3 Legal Issues A brief statement without extended legal argument of the disputed points oflaw including reference to specific statutes and decisions

4 Motions All prior and pending motions their current status and any anticipated motions

5 Amendment of Pleadings The extent to which parties claims or defenses are expected to be added or dismissed and a proposed deadline for amending the pleadings

6 Evidence Preservation Steps taken to preserve evidence relevant to the issues reasonably evident in this action including interdiction of any document-destruction program and any ongoing erasures of e-mails voice mails and other electronically-recorded material

7 Disclosures Whether there has been full and timely compliance with the initial disclosure requirements of Fed R Civ P 26 and a description of the disclosures made

8 Discovery Discovery taken to date if any the scope of anticipated discovery any proposed limitations or modifications of the discovery rules and a proposed discovery plan pursuant to Fed R Civ P 26(f)

9 Class Actions If a class action a proposal for how and when the class will be certified

10 Related Cases Any related cases or proceedings pending before another judge of this court or before another court or administrative body

II Relief All relief sought through complaint or counterclaim including the amount of any

-1shy

damages sought and a description of the bases on which damages are calculated In addition any party from whom damages are sought must describe the bases on which it contends damages should be calculated if liability is established

12 Settlement and ADR Prospects for settlement ADR efforts to date and a specific ADR plan for the case including compliance with ADR LR 3-5 and a description ofkey discovery or motions necessary to position the parties to negotiate a resolution

13 Consent to Magistrate Judge For All Purposes Whether all parties will consent to have a magistrate judge conduct all further proceedings including trial and entry ofjudgment

14 Other References Whether the case is suitable for reference to binding arbitration a special master or the Judicial Panel on Multidistrict Litigation

15 Narrowing ofIssues Issues that can be narrowed by agreement or by motion suggestions to expedite the presentation of evidence at trial (eg through summaries or stipulated facts) and any request to bifurcate issues claims or defenses

16 Expedited Schedule Whether this is the type of case that can be handled on an expedited basis with streamlined procedures

17 Scheduling Proposed dates for designation of experts discovery cutoff hearing of dispositive motions pretrial conference and trial

18 Trial Whether the case will be tried to a jury or to the court and the expected length of the trial

19 Disclosure of Non-party Interested Entities or Persons Whether each party has filed the Certification of Interested Entities or Persons required by Civil Local Rule 3-16 In addition each party must restate in the case management statement the contents of its certification by identifying any persons firms partnerships corporations (including parent corporations) or other entities known by the party to have either (i) a financial interest in the subject matter in controversy or in a party to the proceeding or (ii) any other kind of interest that could be substantially affected by the outcome of the proceeding

20 Such other matters as may facilitate the just speedy and inexpensive disposition ofthis matter

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

SAN JOSE DIVISION

STANDING ORDER REGARDING

CASE MANAGEMENT IN CIVIL CASES

10 II This order sets forth requirements for initial case management in all civil matters assigned to

t 11 District Judges Ronald M Whyte Jeremy Fogel Lucy H Koh and Edward J Davila and

6u ~ 12 Magistrate Judges Howard R Lloyd and Paul S Grewal All papers filed must include the case u - u 13 number of the action followed by the initials of the assigned district judge or magistrate judge and if ~ 0 til ~ bullc S 1411 applicable the initials of the magistrate judge to whom the action is referred for discovery or other ~ ~~ til 0 ~ E 15 II pretrial activity -- ~S oo~ 16 I Plaintiff shall serve a copy of this Standing Order on all parties to this action and on all 0 s ~ l5 17 II parties subsequently joined in accordance with FedRCivP 4 and 5 Following service plaintiff u

5 18 II shall file a certificate of service in accordance with Civil LR 5-6(a)

19 II All disclosure or discovery disputes in cases assigned to district judges are referred to the

201 assigned magistrate judge for determination pursuant to FedRCivP 72(a) Magistrate judges

2111 themselves handle disclosure and discovery disputes in the cases assigned to them

2211 Before select1ng a hearing-dare-fer a metien-befof8 anyofth~ judges of the San Jose

23 II Division counsel must confer with opposing counsel to determine that the proposed hearing date

24 II will not cause undue prejudice

25 II Civil motions under Civil LR 7-2 in cases assigned to Judge Whyte may be noticed for

26 II hearing on any Friday at 900 am

2711 Civil motions under Civil LR 7-2 in cases assigned to Judge Fogel may be noticed for

28 II hearing only after contacting Judge Fogels administrative law clerk Christian Delaney at

408-535-5426 and obtaining an available date

111 Civil motions under Civil LR 7-2 in cases assigned to Judge Koh may be noticed for

2 II hearing only after contacting Judge Kohs Courtroom Deputy Martha Parker Brown at 408-535shy

3 II 5346 and obtaining an available date

41 Civil motions under Civil LR 7-2 in cases assigned to Judge Davila may be noticed for

5 I hearing only after contacting Judge Davilas Courtroom Deputy Elizabeth Garcia at 408-535-5356

61 Civil motions under Civil LR 7-2 in cases assigned to Magistrate Judge Lloyd may be

7 noticed for hearing on any Tuesday at 1000 am

8 Civil motions under Civil LR 7-2 in cases assigned to Magistrate Judge Grewal may be


10 Pursuant to FedRCivP 16 and 26 and Civil LR 16-10(a) a Case Management Conference

1 11 I will be held on at at the United States

5 8 1211 Courthouse 280 South First Street San Jose California This conference may be continued only by U ~

Col U 1311 court order pursuant to Civil LR 16-2(e) Parties may not stipulate to continue a Case Management ~

0

~ l 1411 Conference without court approval ~ S rIl 0 QI s 151 Pursuant to Civil LR 16-3 in advance of the Case Management Conference counsel shall

1U ~ S rn Z 161 confer with their respective clients and opposing counsel for the purposes specified in FedRCivP

~0 ~ S 1711 26(f) Civil LR 16-8 and 16-9 and in patent cases Patent LR 3-1 through 3-6 A meaningful meet Ilo

~ 1811 and confer process prior to the Case Management Conference and good faith compliance with the

191 requirements of this Order are essential elements of effective case management Failure to meet and

20 II confer to be prepared for the Case Management Conference or to file a Joint Case Management

2111 Conference Statement may result in sanctions Parties may but are not required to attend the Case

22fl Management Conference

23 II In all E-filing cases when filing papers in connection with any motion for determination by

24 II a judge the parties shall in addition to filing papers electronically lodge with chambers a printed

2511 copy of the papers by the close of the next court day following the day the papers are filed

2611 electronically These printed copies shall be marked Chambers Copy and shall be submitted to the

2711 Clerks Office in an envelope clearly marked with the Judges name case number and E-filing

28 2

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111 Chambers Copy Parties shall not file a paper copy of any document with the Clerks Office that

2 I has already been filed electronically

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1 11 s Q -iii 12U g () u 13 0

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J= 18

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IT IS SO ORDERED

Dated April 25 2011

~ RonaldM ~ bull ~ United St~t~hDYte lSt11etre

iamptJ ~ _ ohLucyH United States District Judge

l~Smiddot ~Paul S Grewal United States Magistrate Judge

SAN JOSE DIVISION 2811 STANDING ORDER REGARDING CASE MANAGEMENT IN CIVIL CASES

5

10

15

20

25

111 MICHAEL E ADAMS (SBN 47278) LAW OFFICES OF MICHAEL E ADAMS

2 II 702 Marshall Street Suite 300 Redwood City CA 94063

3 II Telephone (650) 599-9463 Fax (650) 599-9785

4 ~0 20 UAttorney for PlaintiffHOSETIA ZERTUCHE 0 omiddot vmiddot iJt~ i1 ~iSk gt let rjCt IngqLI0 Of CoI-~IJ~Jrt

crnaUNITED STATES DISTRICT COURT6

NORTHERN DISTRICT OF CALIFORNIA7

5 J Ii VL 1 il I1iJ

8

9

II HOSETTA ZERTUCHE

11 II Plaintiff

1211

1311 v

14

COUNTY OF SANTA CLARA JAMES GLEASON SANDRA EOVINO and

1611 KIMBERLY MARUFFI

17 Defendants

18

19 Plaintiff alleges

21

CG 11 - 0 3 6 9 1

COMPLAINT FOR FEDERAL CIVIL RIGHTS VIOLATIONAND JURy DEMAND

JURISDICTION AND VENUE 22

Jurisdiction of this court is invoked pursuant to 28 USCS sect1331 and sect1343 in 23

order to secure protection of and to redress deprivation of civil rights secured by Title 2411

42 USCS sect1983 and the United States Constitution Venue lies with this court within

the meaning of28 USCS sect1391 in that one or more of the Defendants reside or are 26

located in the Northern District of California and most or all of the events or omissions 27

giving rise to the claims herein occurred in said District 28

LAW OFFICES OF

MICHAEL E ADAMS II 1702 MARSHALL ST 11300 REDWOOD CITY CA 94063 ~=~=-=~r1=~~~W~rT~~---~~-----

(650)599-9463 Complamt for Federal CivIl Rights VlOlauon and Jury Demand










10 II Counsel





15 II employment



18 thereof










































































5

10

15

20

25


2

311 FIRST CLAIM






















fees



2811 $15000000




5

10

15

20

25






6 DATED July 272011

7

8


11


1411 DATED July 27 2011

~


17 HOSETTA ZERTUCHE

18

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28





HOSETTA ZERTUCHE

Plaintiff (s) v




























IT IS SO ORDERED

























IT IS SO ORDERED

Dated June 3 2011


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1

UQ=

5

ltE ~


= ~~







Howard R Lloyd













FOR THE COURT


~~ By Deputy Clerk

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No C


v

Defendant( s)






Dated ------------~------- Signature



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-------



No C



Defendant( s)






















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

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20

25



3

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9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

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~-22

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27

IT IS SO ORDERED

Dated April 25 2011














10 II Counsel





15 II employment



18 thereof










































































5

10

15

20

25


2

311 FIRST CLAIM






















fees



2811 $15000000




5

10

15

20

25






6 DATED July 272011

7

8


11


1411 DATED July 27 2011

~


17 HOSETTA ZERTUCHE

18

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28





HOSETTA ZERTUCHE

Plaintiff (s) v




























IT IS SO ORDERED

























IT IS SO ORDERED

Dated June 3 2011


1

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1

UQ=

5

ltE ~


= ~~







Howard R Lloyd













FOR THE COURT


~~ By Deputy Clerk

1

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No C


v

Defendant( s)






Dated ------------~------- Signature



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-------



No C



Defendant( s)






















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

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20

25



3

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8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

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~-22

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27

IT IS SO ORDERED

Dated April 25 2011

































































5

10

15

20

25


2

311 FIRST CLAIM






















fees



2811 $15000000




5

10

15

20

25






6 DATED July 272011

7

8


11


1411 DATED July 27 2011

~


17 HOSETTA ZERTUCHE

18

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28





HOSETTA ZERTUCHE

Plaintiff (s) v




























IT IS SO ORDERED

























IT IS SO ORDERED

Dated June 3 2011


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1

UQ=

5

ltE ~


= ~~







Howard R Lloyd













FOR THE COURT


~~ By Deputy Clerk

1

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No C


v

Defendant( s)






Dated ------------~------- Signature



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-------



No C



Defendant( s)






















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

10

15

20

25



3

4

6

7

8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

21

~-22

23

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27

IT IS SO ORDERED

Dated April 25 2011



































5

10

15

20

25


2

311 FIRST CLAIM






















fees



2811 $15000000




5

10

15

20

25






6 DATED July 272011

7

8


11


1411 DATED July 27 2011

~


17 HOSETTA ZERTUCHE

18

19

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24

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28





HOSETTA ZERTUCHE

Plaintiff (s) v




























IT IS SO ORDERED

























IT IS SO ORDERED

Dated June 3 2011


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1

UQ=

5

ltE ~


= ~~







Howard R Lloyd













FOR THE COURT


~~ By Deputy Clerk

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No C


v

Defendant( s)






Dated ------------~------- Signature



1

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-------



No C



Defendant( s)






















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

10

15

20

25



3

4

6

7

8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

21

~-22

23

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27

IT IS SO ORDERED

Dated April 25 2011





5

10

15

20

25


2

311 FIRST CLAIM






















fees



2811 $15000000




5

10

15

20

25






6 DATED July 272011

7

8


11


1411 DATED July 27 2011

~


17 HOSETTA ZERTUCHE

18

19

21

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23

24

26

27

28





HOSETTA ZERTUCHE

Plaintiff (s) v




























IT IS SO ORDERED

























IT IS SO ORDERED

Dated June 3 2011


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1

UQ=

5

ltE ~


= ~~







Howard R Lloyd













FOR THE COURT


~~ By Deputy Clerk

1

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No C


v

Defendant( s)






Dated ------------~------- Signature



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-------



No C



Defendant( s)






















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

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20

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3

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8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

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~-22

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27

IT IS SO ORDERED

Dated April 25 2011





5

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6 DATED July 272011

7

8


11


1411 DATED July 27 2011

~


17 HOSETTA ZERTUCHE

18

19

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28





HOSETTA ZERTUCHE

Plaintiff (s) v




























IT IS SO ORDERED

























IT IS SO ORDERED

Dated June 3 2011


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1

UQ=

5

ltE ~


= ~~







Howard R Lloyd













FOR THE COURT


~~ By Deputy Clerk

1

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No C


v

Defendant( s)






Dated ------------~------- Signature



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-------



No C



Defendant( s)






















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

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3

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9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

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~-22

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IT IS SO ORDERED

Dated April 25 2011






HOSETTA ZERTUCHE

Plaintiff (s) v




























IT IS SO ORDERED

























IT IS SO ORDERED

Dated June 3 2011


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1

UQ=

5

ltE ~


= ~~







Howard R Lloyd













FOR THE COURT


~~ By Deputy Clerk

1

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No C


v

Defendant( s)






Dated ------------~------- Signature



1

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-------



No C



Defendant( s)






















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

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20

25



3

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8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

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IT IS SO ORDERED

Dated April 25 2011



















IT IS SO ORDERED

























IT IS SO ORDERED

Dated June 3 2011


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1

UQ=

5

ltE ~


= ~~







Howard R Lloyd













FOR THE COURT


~~ By Deputy Clerk

1

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No C


v

Defendant( s)






Dated ------------~------- Signature



1

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-------



No C



Defendant( s)






















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

10

15

20

25



3

4

6

7

8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

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IT IS SO ORDERED

Dated April 25 2011














IT IS SO ORDERED

























IT IS SO ORDERED

Dated June 3 2011


1

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1

UQ=

5

ltE ~


= ~~







Howard R Lloyd













FOR THE COURT


~~ By Deputy Clerk

1

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No C


v

Defendant( s)






Dated ------------~------- Signature



1

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-------



No C



Defendant( s)






















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

10

15

20

25



3

4

6

7

8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

21

~-22

23

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26

27

IT IS SO ORDERED

Dated April 25 2011



























IT IS SO ORDERED

Dated June 3 2011


1

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28

1

UQ=

5

ltE ~


= ~~







Howard R Lloyd













FOR THE COURT


~~ By Deputy Clerk

1

2

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28



No C


v

Defendant( s)






Dated ------------~------- Signature



1

2

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24

25

26

27

28

-------



No C



Defendant( s)






















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

10

15

20

25



3

4

6

7

8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

21

~-22

23

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26

27

IT IS SO ORDERED

Dated April 25 2011














IT IS SO ORDERED

Dated June 3 2011


1

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28

1

UQ=

5

ltE ~


= ~~







Howard R Lloyd













FOR THE COURT


~~ By Deputy Clerk

1

2

3

4

5

6

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9

10

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12

13

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28



No C


v

Defendant( s)






Dated ------------~------- Signature



1

2

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4

5

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12

13

14

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18

19

20

21

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23

24

25

26

27

28

-------



No C



Defendant( s)






















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

10

15

20

25



3

4

6

7

8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

21

~-22

23

24

26

27

IT IS SO ORDERED

Dated April 25 2011





1

2

3

4

5

6

7

8

9

10

11

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16

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18

19

20

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23

24

25

26

27

28

1

UQ=

5

ltE ~


= ~~







Howard R Lloyd













FOR THE COURT


~~ By Deputy Clerk

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

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18

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20

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25

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27

28



No C


v

Defendant( s)






Dated ------------~------- Signature



1

2

3

4

5

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8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

-------



No C



Defendant( s)






















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

10

15

20

25



3

4

6

7

8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

21

~-22

23

24

26

27

IT IS SO ORDERED

Dated April 25 2011





1

2

3

4

5

6

7

8

9

10

11

12

13

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28



No C


v

Defendant( s)






Dated ------------~------- Signature



1

2

3

4

5

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9

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26

27

28

-------



No C



Defendant( s)






















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

10

15

20

25



3

4

6

7

8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

21

~-22

23

24

26

27

IT IS SO ORDERED

Dated April 25 2011





1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

-------



No C



Defendant( s)






















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

10

15

20

25



3

4

6

7

8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

21

~-22

23

24

26

27

IT IS SO ORDERED

Dated April 25 2011



















-1shy











-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

10

15

20

25



3

4

6

7

8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

21

~-22

23

24

26

27

IT IS SO ORDERED

Dated April 25 2011















-2shy

----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

10

15

20

25



3

4

6

7

8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

21

~-22

23

24

26

27

IT IS SO ORDERED

Dated April 25 2011





----------------

I

2

3

4

5

611 Case No

7

8

9



SAN JOSE DIVISION































0














28 2

5

10

15

20

25



3

4

6

7

8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

21

~-22

23

24

26

27

IT IS SO ORDERED

Dated April 25 2011


















0














28 2

5

10

15

20

25



3

4

6

7

8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

21

~-22

23

24

26

27

IT IS SO ORDERED

Dated April 25 2011





5

10

15

20

25



3

4

6

7

8

9

1 11 s Q -iii 12U g () u 13 0

~ ~ 14~l5 Il E

~ ~ 0 rJ)Z 16 CI l) 5 ~ u 17

J= 18

19

21

~-22

23

24

26

27

IT IS SO ORDERED

Dated April 25 2011





Documents

Summons and Complaint