Document 48-3
Filed 04/14/2008
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WILLIAM R. TAMAYO - #084965 (CA) DAVID OFFEN-BROWN -- #63321 (CA LINDA S. ORDONIO-DIXON - #172830 (CA) EQUAL EMPLOYMENT OPPORTUNITY COMMISSION San Francisco District Office 350 The Embarcadero, Suite 500 San Francisco, CA 94105-1687 Telephone No. (415) 625-5654 Fax No. (415) 625-5657
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
EQUAL EMPLOYMENT OPPORTUNITY ) COMMISSION, ) ) Plaintiff ) ) v. ) ) GEORGIA-PACIFIC CORRUGATED, ) LLC, ) ) Defendant. ) __________________________________ )
CIVIL ACTION NO. C-07-3944 (SBA) ORDONIO-DIXON DECLARATION 3, 3rd Fl. (Oakland) Hon. Saundra B. Armstrong
Courtroom: Judge:
I, LINDA ORDONIO-DIXON declare that I am a person over the age of eighteen, competent to testify to the following matters within my personal knowledge: 1. I am an attorney for plaintiff United States Equal Employment Opportunity Commission (EEOC), and in that capacity I am charged with the litigation of the instant suit. As such, I am personally familiar with the events and documents associated with the litigation of this case. //
Ordonio-Dixon Decl. Civil Action No. C-07-3944 (SBA)
1
Case 4:07-cv-03944-SBA
Document 48-3
Filed 04/14/2008
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2.
On the morning of April 4, 2008, I read an email from Margaret Hart Edwards, counsel for Defendant Georgia Pacific Corrugated, proposing that the April 7, 2008 deposition of Charging Party Janet Stege be postponed. The email indicates it was sent at 3:54 p.m. on April 3, 2008. A true and correct copy of this email is contained in the attachment to this declaration.
3.
The same morning, I responded to Ms. Edwards' email and indicated that if Ms. Stege's deposition was to be taken before the April 24, 2008, mediation "we need to go forward" with Ms. Stege's April 7, 2008 deposition. A true and correct copy of this email is contained in the attachment to this declaration.
4.
On the morning of Saturday, April 5, 2008, I learned via an email from Ms. Edwards that the deposition on Monday, April 7, 2008, had been cancelled. The email indicates it was sent at 9:10 p.m. on April 4, 2008. A true and correct copy of this email is contained in the attachment to this declaration.
I declare under penalty of perjury, under the laws of the State of California, that the foregoing is true and correct, and that this Declaration was executed on April 14, 2008, at San Francisco, California.
//s// LINDA S. ORDONIO-DIXON
Ordonio-Dixon Decl. Civil Action No. C-07-3944 (SBA)
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Case 4:07-cv-03944-SBA
Document 48-3
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Attachment
Case 4:07-cv-03944-SBA L1NDA ORDONIO-DIXON - RE: Stege Deposition
Document 48-3
Filed 04/14/2008
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From: To: Date: Subject:
"Edwards, Margaret"
"LINDA ORDONIO-DIXON"
4/4/20089:10:46 PM
RE: Stege Deposition
We are not willing to go forward without knowing Ms. Stege's status, and
it does make a difference. Nor do we agree that Ms. Dickson has the
same status, when Ms. Stege is not a plaintiff. The deposition will not
go forward on Monday. Please give me alternate dates later in April or
in May.
I do not know yet whether we will have to seek a postponement of the
mediation, but that seems a distinct possibility.
Margaret
Margaret Hart Edwards, Esq.
Senior Shareholder'
Littler Mendelson PC
650 California Street, 20th Floor
San Francisco, California 94108
Direct Phone: 415.288.6678
Direct Fax: 415.743.6641
General Office Phone: 415.433.1940
General Office Fax: 415.399.8490
Assistant: Yvonne Catig 415.288.6337
Email: [email protected]
www.littler.com <.http://www.littler.com/>
From: LINDA ORDONIO-DIXON [mailto:[email protected]]
Sent: Friday, April 04, 2008 10:46 AM
To: Edwards, Margaret
Cc: [email protected]
Subject: Re: Stege Deposition
Hi Margaret, I don't believe the Court's ruling ruling makes a
difference as to the taking of Janet's deposition. Janet's state claims
arise out of the same set of facts as the federal claims in this case
and Kathy, as Janet's private attorney, has the right to attend the
depo. In any event, I am not available on the 21st or 22nd and there
are no days in the week of April 14th on which Kathy and I are both
available. If Janet's depo is to be taken before the mediation on the
24th, we need to go forward on Monday. Please let us know what you
decide as soon as possible. Thanks, Linda
>>> "Edwards, Margaret"
Dear Linda,
Case 4:07-cv-03944-SBA L1NDA ORDONIO-DIXON - RE: Stege Deposition
Document 48-3
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As the court has taken the motion to intervene under submission, and we
have no ruling, we believe that it would be premature to proceed with
the deposition of Ms. Stege on Monday and Tuesday of next week. I'd
like to propose that we try to reschedule the deposition for April 21
and 22, in the hope that we have a ruling by then, one way or the other,
and we can get the deposition before the mediation on April 24, 2008.
Will those dates work for you? If not, please give me alternative
dates.
I assume that you will coordinate with Ms. Dickson, as Stege is not
formally a plaintiff in the case.
Margaret Hart Edwards, Esq.
Senior Shareholder
Littler Mendelson PC
650 California Street, 20th Floor
San Francisco, California 94108
Direct Phone: 415.288.6678
Direct Fax: 415.743.6641
General Office Phone: 415.433.1940
General Office Fax: 415.399.8490
Assistant: Yvonne Catig 415.288.6337
Email: [email protected]
www.littler.com
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Case 4:07-cv-03944-SBA L1NDA ORDONIO-DIXON - RE: Stege Deposition
Document 48-3
Filed 04/14/2008
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To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this document (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. This email may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply email and delete all copies of this message. To reply to our email administrator directly, send an email [email protected] Littler Mendelson, P.C. http://www.littler.com
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