Free Memorandum in Opposition - District Court of California - California

Case 4:07-cv-03944-SBA

Document 48-4

Filed 04/14/2008

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KATHRYN BURKETT DICKSON, State Bar No. 70636 DICKSON - ROSS LLP 1970 Broadway, Suite 1045 Oakland, CA 94612 Phone: 510-268-1999 Fax: 510-268-3627 E-mail: [email protected] Attorneys for Plaintiff/Intervenor JANET STEGE

UNTIED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 14 15 16 17 18 19 20 21 22 23 I, Kathryn Burkett Dickson, declare as follows: 24 1. 25 Court, and am counsel of record for Plaintiff Intervenor Janet Stege. I submit this Declaration in 26 Support of Plaintiff/Intervenor Stege's and Plaintiff EEOC's Opposition to Motion to Extend 27 Deadline to Complete Mediation. I have personal knowledge of the facts set forth in this 28
Declaration of Kathryn Dickson in Support of Plaintiff/Intervenor Stege's and Plaintiff EEOC's Opposition to Motion to Extend Deadline to Complete Mediation Civil Action No. C-07-3944 (SBA) 1

EQUAL EMPLOYMENT OPPORTUNITY ) COMMISSION, ) ) Plaintiff, ) ) JANET STEGE, ) ) Plaintiff/Intervenor, ) ) v. ) ) GEORGIA-PACIFIC CORRUGATED, ) LLC, ) ) Defendant. ) __________________________________ )

CIVIL ACTION NO. C-07-3944 (SBA) DECLARATION OF KATHRYN BURKETT DICKSON IN SUPPORT OF PLAINTIFF/INTERVENOR STEGE'S AND PLAINTIFF EEOC'S OPPOSITION TO MOTION TO EXTEND DEADLINE TO COMPLETE MEDIATION Courtroom: Judge: 3, 3rd Fl. (Oakland) Hon. Saundra B. Armstrong

I am an attorney licensed to practice in the State of California and before this

Case 4:07-cv-03944-SBA

Document 48-4

Filed 04/14/2008

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declaration and am competent to testify to them. 2. I have been provided with and have reviewed a copy of the documents the EEOC

produced in response to a document request submitted by Defendant Georgia-Pacific (G-P). Among those documents were extensive medical records ­ which had already been in the company's possession and which the company provided to the EEOC during the agency's investigation of Ms. Stege's administrative complaint. These include documents Bates-Stamped EEOC 108 - 281, among others. 3. The documents produced by the EEOC also included detailed notes of witness

interviews conducted by the EEOC during its investigation.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that I authorized the electronic signature on this Declaration on April 14, 2008 in Oakland, California.

/s/ Kathryn Burkett Dickson Kathryn Burkett Dickson

Declaration of Kathryn Dickson in Support of Plaintiff/Intervenor Stege's Opposition to Motion to Extend Deadline to Complete Mediation Civil Action No. C-07-3944 (SBA) 2