ul 2 1B 14 15 16 7 18 19 20 2 22 23 24 25 26 27 28, DIGRIGINAL J, FELIX DE LA TORRE, Bar No. 204282 General Counsel WENDIL. ROSS, Bar No. 141030 Deputy General Counsel BRENDAN P. WHITE, Bar No. 264640, Regional Attorney PUBLIC EMPLOYMENT RELATIONS BOARD 1031 18th Street Sacramento, CA 95811-4174 Telephone: (916) 322-3198 Facsimile: (916) 327-6377 Attorneys for State of California, PUBLIC EMPLOYMENT RELATIONS BOARD FILED SUPERIOR COURT OF CALFORNA SUNY OF ANCRSIOE MAY 18 2018 E. Rodriguez IN THE SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF RIVERSIDE PUBLIC EMPLOYMENT RELATIONS case No: FRE BOARD, COMPLAINT Plaintiff, RELIEF v. COUNTY OF RIVERSIDE, Defendant, SERVICE EMPLOYEES. INTERNATIONAL UNION, LOCAL 721, Real Party in Interest. ic 1809250 FOR INJUNCTIVE Exempt from Fees (Gov. Code, § 6103) ‘Complaint for Injunctive Relief Al go, NZIS AN BSSearxanu u 12 13 14 15 16 7 18 19 20 2 2 23 25 26 27 28 TO THE HONORABLE COURT, CLERK OF THE COURT, AND ALL PARTIES: ‘Comes now Plaintiff California Public Employment Relations Board (PERB or Board), and alleges as follows: Parties 1, PERB is now and at all times mentioned herein has been an administrative agency| created by Government Code section 3541,” for the purpose of, inter alia, promoting the development of harmonious and cooperative labor relations between California’s public-sector employers and their employees. This includes California’s local-government employers and their employees, who are subject to the Meyers-Milias-Brown Act. (§ 3500 et seq. [MMBA].) 2. PERB has the power to petition the Superior Court for injunctive relief upon suance of a complaint charging that an employer or employee organization has engaged or is, engaging in an unfair practice, pursuant to sections 3509, subdivision (a), and 3541.3, subdivision (j). (See also, Cal. Code Regs., tit. 8, § 32450 et seq.)” = As a public agency, PERB is not required to file a bond or undertaking (Cal. Code| Civ. Proc., § 529, subd. (b)(3)) when requesting injunctive relief. 4. Asa public agency, PERB is not required to pay a filing fee. (§ 6103.) 5. Defendant County of Riverside (County) is and at all times mentioned herein has ‘been a public agency in the State of California within the meaning of section 3501, subdivision (©) and the employer of appropriate units of employees, including those in the Registered Nurse, Supervisory, Para-Professional, and Professional bargaining units of the County. (PERB Regulation 32016, subd. (b).) 6. Real Party in Interest, Service Employees International Union Local 721 (SEIU Local 721), is and at all times mentioned herein has been an employee organization in the State of California within the meaning of section 3501, subdivision (a). SEIU is the recognized ion (b), exclusive representative, within the meaning of Government Code section 3501, subdi " All further references to statutes are to the Government Code unless otherwise stated. 2 All further citations to provisions of the California Code of Regulations, title 8, will use| the shorthand “PERB Regulation,” followed by section and subsection numbers as appropriate. 1 Complaint for injunctive Reliefwer aweun 10 u 2 B 14 16 7 18 19 20 21 2 23 24 25 26 27 28 of the employees in the following bargaining units in the County of Riverside (County): Registered Nurse Unit, Supervisory Unit, Para-Professional Unit, and Professional Unit. (Cal. Code Regs.. including in Riverside, Lancaster, Los. Angeles, Santa Maria, Palm Springs, Santa Ana, and t. 8, § 32016, subd. (b).) SEIU operates offices at various locations in California, Ventura, 7. SEIU Local 721 and the County have been parties to a number of Memoranda of Understanding (MOU), the most recent of which having a term from July 2013 to November 2016. 8. From October 2016 through the present, SEIU and the County have been engaged in negotiations for a successor MOU. Since that time, SEIU has filed numerous unfair practice charges with PERB alleging that the County has failed and refused to bargain in good faith, erfered with protected activities, retaliated against employees for engaging in strike activi and unlawfully moved to impose new terms and conditions of employment, as more fully detailed below. ion of the subject matter of this action pursuant to Code 1. This Court has jurisdi of Civil Procedure sections 526 and 527, and the specific relief sought herein is authorized by Government Code sections 3509, subdivision (a), 3541.3, subdivision (j), and PERB Regulation 32450 et seq. 2. Venue in Riverside County Superior Court is proper because it is the Court of first resort with the power to grant relief to PERB, and because SEIU and the County either have offices and/or do business within the County of Riverside. Bargaining History 3. SEIU and the County (collectively referred to as “parties”) were parties to a ‘memorandum of understanding (MOU) that governed the SEIU-represented bargaining units, which expired on November 30, 2016. 4, The parties began negotiating for a successor MOU in September 2016. The parties have met 40 times in negotiating a successor MOU. 2 Complaint for Injunctive Reliefwok ww Seer.a u 12 13 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 5. On July 19, 2017, the parties held a bargaining session at which the County presented SEIU with its Last, Best, and Final Offer (LBFO). On or about July 26, 2017, the parties held a bargaining session at which SETU presented its counter-proposal to the County’s LBFO. 6. On August 29, 2017, SEIU gave notice that it intended to go on strike on ‘September 6 and 7, 2017, to protest the County’s unfair practices. The noticed strike involved approximately 6,000 employees at nearly all of the County's facilities, including Riverside University Health System’s (RUHS) medical centers and clinics. 7. The following day, the County declared impasse, and filed an unfair practice charge with an accompanying request for injunctive relief to enjoin essential employees from striking (PERB Case No. LA-CO-222-M). 8. PERB authorized its Office of General Counsel to seek a temporary restraining order (TRO), which the Superior Court of the County of Riverside issued on September 5, 2017 (Case No: RIC 1716450, Hon. John Vineyard presiding). The TRO enjoined over 1,000 ‘SEIU-represented members from striking, over 400 of who worked at RUHS. 9. After the September strike, the parties participated in the post-impasse factfinding process provided for in Government Code section 3505.4. ‘The factfinding process included six days of hearings. On April 9, 2018, the cl irperson of the factfinding panel issued his report and recommended resolution of the bargaining dispute. The County filed its, dissent to the chairperson’ report and recommendation on April 16, 2018. 10. On May 8, 2018, the County’s elected Board of Supervisors conducted a public hearing conceming the faetfinding report. At that public hearing, the County's chief negotiator and labor attorney, Ed Zappia, urged the Board of Supervisors to implement the County's July 2017 LBEO. At the conclusion of the public hearing, the County's Board of Supervisors took the matter under submission. On information and belief, the County's Board of Supervisors could vote to impose the LBFO at its next regularly scheduled meeting on May 22, 2018, or sooner if it calls a special meeting for that purpose. Mt 3 ‘Complaint for Injunctive ReliefBR wR 10 ul 12 13 4 15 16 7 18 19 20 21 22 23 25 26 27 28 History of Pre-Strike Bad-Faith Bargaining and Interference Complaints 11. As of the time of the September 2017 strike, SEIU had filed more than a dozen Unfair Practice Charges (UPCs) against the County. As to those UPCs, PERB has issued the following complaints, listed by case number: LA-CE-1168-M (surveillance); LA-CE-1174-M (surveillance); LA-CE-1188-M (harassment! intimidation/discriminatory application of dress code policy); LA CE-1191-M (unilateral changes to call off policy at RUHS); LA-CE-1192- M (access; harassment/intimidation; surveillance); LA-CE-1198-M (access); LA-CE-1199-M (unlawful restriction on display of Union logo at workplace); LA-CE-1207-M (access); LA~ CE-1208-M (unlawful restriction on display of Union logo at different worksite); LA-CE- 1209-M (bad faith bargaining — shifting negotiators); LA-CE-1212-M (bad faith bargaining —- surface bargaining); LA-CE-1213-M (bad faith bargaining — regressive bargaining); LA- CE-1214-M (bad faith bargaining — surface bargaining); LA-CE-1220-M (failure to fumish information); LA-CE-1222-M (bad faith bargaining — refusal to schedule bargaining sessions); LA-CE-1224-M (surveillance/interference); LA-CE-1239-M (bad faith bargaining—premature declaration of impasse); LA-CE-1240-M (unilateral change, interference, and discrimination); LA-CE-1242-M (unlawful restrictions on union-related literature in workplace). These complaints are scheduled to be heard in July 2018, before a Strike Interference Complaint Related to County’s Use of Strike Replacements 12. Onor about January 23, 2018, SEIU filed a UPC against the County (PERB Case No, LA-CE-1274-M) alleging the following: After the September 2017 strike, SEIU discovered that the County had entered into a contract with a company, Nurse Bridge, that specialized in providing strike replacement healthcare workers. Additional evidence further revealed that the County had ordered approximately 60 nurse replacements, which Nurse Bridge provided during the strike. These facts were not disclosed to PERB, SEIU, or the Court prior to the issuance of a TRO enjoining over 400 healthcare workers from striking. Instead, the County stated in declarations and in open court that it could not obtain any nurse replacements for the strike, The County concealed the Nurse Bridge contract from PERB and 4 Complaint for injunctive Reliefu 12 13 14 1s 16 7 18 19 20 21 22 23 24 25 26 27 28 the Court in order to interfere with the employees’ right to strike and retaliate against 13. Upon request from SEIU, PERB expedited the investigation of Case No. LA~ CE-1274-M and issued a complaint on or about February 26, 2018. The matter has been in June 2018, assigned to an ALJ for a hearing to begi ‘Termination of Mary Carcillar, RN, for Participating in SEIU’s September 2017 Strike 14, On or about December 22, 2017, SEIU filed a UPC against the County (PERB Case No. LA-CE-1270-M) alleging the following: On October 31, 2017, the County summoned Mary Carcillar, a Registered Nurse at RUHS, to an investigatory interview where it coercively interrogated her about her strike participation and other protected activities. The County asserted that its hired process server had served the TRO on Carcillar before the beginning of the September strike, but that she had willfully refused to report to work as ordered by the Court. Carcillar denied receiving a copy of the TRO until after the strike had ended. Nevertheless, the County determined that Carcillar was lying, that her conduct constituted a violation of the TRO, and that she endangered RUHS’ reputation and patients by striking. On this basis, the County fired Carcillar on or about November 30, 2017. 15. Upon SEIU’s request, PERB’s Office of General Counsel expedited the investigation of Case No. LA-CE-1270-M and issued a complaint on or about January 10, 2018. The matter proceeded to a hearing before an ALJ and the record was closed in April 2018. Presently, the parties are awaiting the ALJ’s proposed decision. Facts Alleged in SEIU’s Most Recent UPC 16. On May 2, 2018, SEIU filed its latest UPC against the County, PERB Case No. LA-CE-1306-M, alleging that the County has systematically interrogated nurses about their protected strike activities, fired two more nurses because of they participated in the strike, and is moving to implement its LBFO when no legal, good faith impasse is possible because of the existence of unremedied UPCs. SEIU also requested that PERB seek injunctive relief in this matter to preserve the status quo ante pending resolution of the administrative process. a 5 ‘Complaint for Injunctive ReliefSee ye u 12 B 4 15 16 7 18 19 20 21 2 23 24 25 26 27 28 Coercive Interrogations 17, Beginning on or about October 31, 2017, and continuing on various dates thereafter, the County’s Human Resources department and other managers interrogated the following Registered Nurses, and others, about their participation in a strike and/or other protected activities: Karina Cover (Cover), Shari Sagastume (Sagastume), Pilar Ham, Pamela Ligera, Loren LiCayan, Marie Josie Sanchez, Cindy Rivera, and Maria Mendoza. 18 SEIU alleges that these interrogations were coercive and for the purpose of interfering with the protected right to strike. ‘Termination of RN Cover 19. On or about April 13, 2018, the County fired Cover because she participated in SEIU’s September 2017 strike. According to the County, its hired process server had served Cover with a copy of the TRO, but Cover did not report to work as ordered. Cover, however, denies having been served andlor states that she was not aware she was subject to the TRO. Termination of RN Sagastume 20. On or about April 26, 2018, the County fired Sagastume because participated in a SEIU’s September 2017 strike. According to the County, its hired process server had served Sagastume with a copy of the TRO, but Sagastume did not report to work as ordered. Sagastume, however, denied having been served and/or states that she was not aware she was subject to the TRO. 21. SEIU alleges that these terminations were in retaliation for the employees’ participation in protected strike activities and were designed to chill the bargaining unit's desire to engage in future strikes, Allegations of Chill and Disaffection 22. In support of its request for injunctive relief, SEIU provided swom. declarations concerning the chilling effect of the County's unremedied UPCs. This evidence including the following summarized statements: ‘© Workers are terrified that the County will retaliate against those who engage in concerted| activities. More importantly, the bargaining units members’ faith in the collective 6 ‘Complaint for Injunctive Reliefbargaining process and in their MMBA-rights erodes with the County’s every unlawful act. If workers do not believe that PERB will uphold their ts, their disillusionment leads to disaffection the Union as well because it makes the Union appear ineffectual. [Josie Mooney, Assistant to President of SEIU, (White Decl. Exh. 14..] In recent months, Local 721°s members have expressed a general sense of hopelessness in the collective bargaining process. They have noticed that despite [the strike and UPCS}, the County refuses to bargain in good faith and continues to commit unfair labor practices... have noticed steady decrease in attendance at worksite meetings... many workers have indicated that they are aware that some other members were terminated. Because of these terminations, my co-workers have expressed fear that they too could be targeted by the County because of their union activity. [Alton Carswell, Clinical Therapist, job steward (White Decl. Exh. 3).] ‘Members are no longer interested in getting updates about the pending UPCs and are convinced that they cannot rely on anyone or any institution to protect their labor rights from the County. Pronounced decrease in attendance at Local 721’s general meetings and worksite meetings. Members have expressed fear based on the terminations that they| t00 will be fired if they participate in u mn activities. New hires stopped appearing at Union meet-and-greet meetings for fear of being targeted. [Arturo Hemandez, Program Specialist, job steward (White Decl. Exh. 4.).] Members feel cheated by the UPC process because there has been no resolution and the County continues to commit unfair practices. Members believe no institution can stop the County from breaking the law. Members at worksites outside of RUHS have heard about the terminations and are aware that the County has suffered no repercussion. Members no longer want to meet in the breakroom for fear management will identify and target them as Union supporters. [Donald Doran, Medi-Cal Eligibility Supervisor (White Decl. Exh. 5.).] ‘More than any other unfair practice, the termination of Mary Carcillar had the greatest chilling effect on workers? support for the contract campaign. Prior to the termination, Conaplait for Ijuncive ReetCer an ren 10 u 12 13, 14 15 16 7 18 19 20 2 23 24 25 26 27 28 hundreds of members held rallies outside RUHS and wore stickers supporting the Union. After the termination, only six members from RUHS attended a rally. Members no longer want to discuss the status of negotiations. [Heidi Holliday, SEIU staff (White Decl. Exh. 6.)] Land several other Local 721’s members are convinced that the nurses were terminated because of their participation in the strike. I know the Union is trying to get their jobs back but so far nothing has happened. Members have expressed to me that they are hopeless and they simply feel like this isa battle with the County to be treated fairly that, they cannot win. [Johnny Ortega, Correctional Food Services Supervisor, job steward (White Decl. Exh. 7,).] Members have told me they believe filing a UPC against the County for recent treatment is useless. In addition, whenever the idea of a future strike comes up in conversations with other members, some of them express fear...they have pointed out that nurses who participated in the last strike were fired for doing so and they do not want to suffer the same fate... Members are reluctant to meet and more and more are expressing disaffection, with the entire collective bargaining process and the feeling that they are powerless in the| face of the County's unfair labor practices. [Mark Slaughter, LVN II (White Decl. Exh, 10,).] Thave personally observed a demoralizing decrease in attendance at Local 721’s general meetings... The fact that there has been a lack of progress on {SEIU’s] non-frivolous UPCs before PERB has convinced many of them that the County is becoming even less afraid of committing unfair labor practices....On or about February 26, 2018, I attended a] rally outside (RUHS]. Based on my past observation of rallies at this site, I was expecting to see at least 50 members... counted only about ten members in attendance.....Several members reported to me that they did not attend the rally because they leamed that the County had fired a nurse who participated in the strike. [Camille Sohm, Victim Service Advocate, member of SEIU’s Executive Board (White Decl. Exh. 17) 8 (Complaint for Injunctive Relief+ Tam aware that there have been County employees terminated due to their participation in the strike. Iam now concemed that the County can punish my colleagues and me... and no one will hold the County accountable. [Regina Hamilton, Administrative Service Assistant (White Decl. Exh. 19.).] ‘© My colleagues and I have heard that the County fired nurses in retaliation for participating in union activities. Though my colleagues and I did not work with these nurses...we understood that the County was sending a clear message that it will punish anyone who speaks up. In the light of the nurses firing, I have heard from several colleagues at my worksite that they feel that if they support the union and take part in union activities, the County will retaliate against them in some way. [Retha Smith, Senior Development Specialist (White Decl. Exh. 20.).] Allegation Concerning Unlawful Implementation of the County’s LBFO 23. Additionally, in its latest charge, SEIU alleges that the County is taking conerete actions in preparation to impose its LBFO. As noted above, the County's Board of Supervisors received the recommendation of the County’s chief negotiator to implement the LBFO and could vote to do so as early as May 22, 2018, if not sooner. According to SEIU, the County’s history of bad faith bargaining conduct, coupled withthe retaliatory terminations of striking employees, precludes the possibility of good faith impasse. SEIU contends that these unremedied UPCs have had a chilling effect on the bargaining unit and are causing the kind of disaffection that prevents employees from engaging in collective bargaining and other protected activities for their mutual aid and protection. On this evidence, SEIU contends that the County has no right to impose its LBFO or any other changes to existing terms and conditions of employment. 24. On May 4, 2018, the County filed its response to Case No. LA-CE-1306-M and SEIU’s request for injunctive relief. PERB investigated the matter and, on May 8, 2018, sued the underlying administrative complaint in this case. On May 10, 2018, PERB notified the parties that it had approved SEIU’s request for injunctive relief. M 9 Complaint for Injunctive ReliefCaowraunun 10 ul 2 2B 4 15 16 7 18 19 20 2 2 24 25 26 27 28 FIRST CAUSE OF ACTION Injunctive Relief (Code Civ. Proc., §§ 526 & 527; Gov. Code, § 3541.3; Cal. Code Regs. § 32450 et seq.) 25. _ PERB incorporates all preceding paragraphs as though fully set forth herein. 26. By this Complaint and Petition, PERB contends that, beginning in October 2017 and continuing, the County has taken various actions in violation of the MMBA and that this Court should immediately direct the County to restore and maintain the status quo that existed before the County committed these violations of the MMBA, and enjoin and restrain the County and order from engaging in this unlawful conduct under the standards established in Public Employment Relations Board v. Modesto County Schools District (1982) 136 Cal.App.34 881. 27. Under the Modesto standards, the Board has determined that there is reasonable cause to believe the County has committed numerous unfair labor practices, based on sworn allegations and evidence in SEIU Local 721’s UPC indicating that the County’s conduet— including coercively interrogating employees; firing employees for engaging in strike activities; refusing to bargain in good faith; and moving to implement its LBFO—violates numerous provisions of the MMBA (§§ 3502, 3503, 3505, 3506, 3506.5(a) - (c), 3507(c), 3509(b)), and PERB Regulation 32603(a), (b), (c), (d), and (g).) 28. Under the Modesto standards, the Board has further determined that injunctive relief is just and proper because, absent such relief to restore and maintain the status quo ante with respect to the County’s collective bargaining relationship with Real Party in Interest SEIU Local 721 as and to the same extent it existed before it engaged in these unfair practices, the objectives of the MMBA will be frustrated, the efficacy of any final order issued by the Board will be nullified, and PERB’s administrative proceedings will be impeded. WHEREFORE, Plaintiff prays for judgment as follows: 1. That Defendant County, its agents, employees, representatives, officers, and all corporations, unincorporated associations, and natural persons acting in concert and participation| with any of them, until a hearing or trial on a preliminary injunction, be specifically enjoined and| restrained from: 10 ‘Complaint for Injunctive Relie?Cownunn en 10 ul 12 13, 14 15 16 7 18 19 20 21 22 23 24 25 27 28 ce and further, an order directing the County immediately to: f 2. That the County, and its agents, employees, representatives, officers, and all corporations, unincorporated associations, and natural persons acting in concert and participation| with any of them, until a hearing or trial on an Order to Show Cause re: preliminary injunetion, be enjoined and restrained from doing or attempting to do, directly or indirectly, by any means, interrogating its employees concerning their activities and sympathies protected under the Meyers-Milias Brown Act, (Gov. Code, § 3500 et seq[MMBA]); terminating or otherwise disciplining employees because of their participation in SEIU Local 721’s September 2017 strike; engaging in unilateral enforcement of the court’s temporary restraining order issued on September 5, 2017; failing or refusing to meet and confer with SEIU Local 721 in good faith for a successor MOU, and for any other lawful purpose that SEIU Local 721 may request in its capacity as exclusive representative of the bargaining units regarding matters within the scope of representation under the MMBA; unilaterally implementing its LBFO or otherwise failing or refusing to maintain the existing terms and conditions contained in the most recent MOU; offer Mary Carcillar, Karina Cover, and Shari Sagastume, and all other employees} who were terminated because they participated in SEIU’s September 2017 strike reinstatement, on an interim basis, to their former positions or, if those positions xno longer exist, fo substantially equivalent positions without prejudice to their seniority or any other rights and privileges previously enjoyed, and displacing, if necessary, any employee who has been hired or reassigned to replace them; restore and maintain the status quo ante with respect to the existing terms and conditions contained in its most recent MOU with Real Party in Interest SEIU Local 721; Post a copy of the Court’s order in all locations where communications to members of SEIU’s bargaining units are customarily posted. u ‘Complaint for Injunctive Reliefee a aww wD 10 uN 2 1B 14 15 16 7 18 19 20 21 2 23 24 25 26 27 28 method, or device whatsoever, any of the acts enjoined in paragraph 1 of this prayer, and each subdivision thereof, during the duration of this action. 3. That upon the hearing of said Order to Show Cause, a Preliminary Injunction be granted herein enjoining and restraining Defendant County and its agents, employees, representatives, officers, and all persons acting in concert with them or any of them, from failing to comply with the directives in paragraph 1 of this prayer, and each subdivision thereof, until PERB?s administrative proceedings have been completed and a final Board decision has issued. 5. That a permanent injunction pursuant to Code of Civil Procedure sections 526 and 527) be issued and directed to the County, its agents, employees, representatives, officers, and officials, and aay other person acting in concert or participation with any of them, enjoining and restraining them, and all persons acting in concert with them or any of them, from failing to comply with the directives in paragraph 1 of this prayer and each subdivision thereof. 6. Forits cost of suit herein incurred. 7. For such other and further relief as may be just and proper. Dated: May 18, 2018 Respectfully submitted, J. FELIX DE LA TORRE, General Counsel WENDIL. ROSS, Deputy General Counsel By. f Ah Zi ENDAN P. WHITE, Regional Attomey Attorneys for Plaintiff PUBLIC EMPLOYMENT RELATIONS BOARD 12, ‘Complaint for Injunctive Relief= u CM-0141 PUN Be ts tare ses Wea Rae ae Tena TT Brenden Wine 382680 Public Eployineat Relations Boar TORT oe Besar Sanamenty, CA Bsa11 4124 reLEenowe KO: (24g) 322-3198 raxno: (916) 327-6377 _ATTORNEY FOR ublic Employment Relations Board [SUPERIOR COURT OF CALIFORNIA, COUNTY OF RIVERSIDE swine aooress: 4050 Main Street caryawoameove: Riverside, CA 92501 aranounave: Riverside Historic Courthouse CASE Nae Public Employment Relations Board v. County of Riverside CIVIL CASE COVER SHEET Complex Case Designation gr 1809250 __| 2) untimited = [_} Limited oO o Untiie fer Counter ender FIC torrente Gerendedis | Fed fret ppearnce by detent exceeds 825.000) S25 000 orlss)| "(Ga Rules of Cour tla $02) | oer iN ‘tems 1-6 below must be completed (see instructions on page 2). * F-ck one Do blo Torte case pe ta best doctbes is case q= ‘Aut Tort Contract Provisonally Complex Civil Litigation (ly (1 aso 22) [ET seeoch of contacivarranty (06) (Cal. Rules of Court, rues 3400-3402) > Uninsured metrit () TE] aes 740 eatecions(0s) 2] nts repuaton (03) a Other PURDIMD (PersonaltniuryPropery [=] Other cen (05) [contacto dec (10) de ‘DamegeMrongtu Death Tor TE nsiranee coverage (18) [E niaws tor (4) lz “Acbocoe (04) otter contact 37) soos tigation (28) Product ably (24) Real Property’ [) environmentavToric txt (30) TE) Medial mabractice (45) (1 Eminent comaivnnverse 5) tnsurance coverage dims arising tom the aa Soweto) succes to Non-PUPDIWD (Other) Tort 2) Wrong eviction (33) ‘ypes (41) ‘usieas fortune business pratce (97) L—]. Other ral prenery (28) Enforcement of Judgment Sy cis (08) Uniavful Detainee Ey Enorcoment of egent (20) A Defamation (19) A conmarciat(31) Miscellaneous Chil Complaint Free) fe) EF coven TE) intettectast property (12) ‘Other compaint (not specitied above) (42) [E) Preessiona notigenca (25) ‘iiootinoous Chl Potion TF other non PPD tort (25) KH Asset froture (05) Patinarship and corporate govern (21) Enpoyment Patton atten ard (1) ee = TE] Wironatt emination 98) I witotmancate 02) [oer aon tepid abv), [7] other employment (15) [} other judiciat review (39) 2 Thiscase Lis [YTisnot — complex under rule 3.400 ofthe Calforria Rules of Cour. ifthe case is complex, mark the factors requiing exceptional judiéal management: a.) Large number of separately represented parties d. [_] Large number of witnesses: b.L_] Extensive motion practice raising dificult or novel. [_] Coordination with related actions pending in one or more courts [sues that wil be time-consuming o resolve im other counties, states, or countries, or ina federal court ¢. (7) Substantial amount of documentary evidence +. [7] substantial postjudgment judicial supervision 3. Remedies sought (check all that apply): e[_] monetary b.[Y7] nonmonetery; declaratory or injunctive relief 0. [_]punitive 4 Number of causes of action (spect: One 5. This case [lis isnot a cless action suit 6. If thece are any known related cose, le and serve a nati of related esse. (You may uso form Ci-016,) Date: May 18, 2018 Brendan P. White mae TPE OR TROT T TOR ATOR RRR Notice + Palntif must fie this cover sheet wth the fst paper fled in tne action or preceeding (except smal claims cases or cases fled under the Probate Code, Family Code, or Welfare end Inettutions Code). (Cel. Rules of Court, rule 3.220.) Failure to fle may result in sanctions * Flo this cover shoot in addiion to any cover sheet required by local cour rule, * if this case is complex under rule 3.400 ot seq. of the Calfoinia Rules of Court, you must serve a copy ofthis cover sheet on al, ‘other parties tothe action or proceeding, + Unless this is a collecions case under rule 3.740 ora complex caso, this cover shot wil be used fr stalistical purposes on See CIVIC CASE COVER SHEET Sea anaes es tnINSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET To Plaintiffs and Others Filing First Papers._ if you are fling a fist paper (for example, a complaint) in a cvl case, you must complete and file, slong with your fst paper, the Civ! Case Cover Shoot contalned on page 1, This information wil be vsed to comple slatises about the types and numbers of cases fled. You mast complote items 1 through 6 on the sheet. In tem 1, you must check ‘one box forthe case type that bast describes the case. ifthe case fis both a general and a more specific typeof case listed In tam 1, check the more spectfic one, Ifthe case has mulple causes of action, check the box that best Incioates the primary cause of action ‘To assist you In comploting tho shoat, examples of the eases that belong under each caso type in ler 1 are provided below. A cover shoot must be fled only with your inal paper. Failure to fle a cover sheet with the first paper fled in civil case mey subject a party, lis counsel, or both to sanctions under rues 2.30 and 3.220 of the Calforia Rules of Cour. To Parties in Rule 3.740 Collections Cases. “collections case" under rule 3.740 is defined as an action for recovery of money ‘owed in a sum stated to be certain that Is not more than $26,000, exclusive of interest and attorneys foes, arising from a transaction in ‘which property, services, o money was acquired on credit. A collections case does not include an action seeking the folowing: (1) tort damages, (2) punitive damages, (2) recovery of real property (4) recovery of personal property. or (5) a prejudgment wit of attachment. The Identification of a case as a rule 3.740 collections case on this form means that ft willbe exempt from the general time-forservice requirements and case management rules, unless a defendant fies a responsive pleading, A rue 3.740 collections case wil be subject tothe requirements for service and obtaining a judgment in rule 3.740. To Parties in Complex Cases. in complex cases only, parties must also use the Givi! Case Cover Sheet to designate whothor the ‘case is complex. If plaintiff belioves the case 's complex under rule 3.400 of tho California Rules of Cour, this must be Indicated by ‘compieting the appropriate baxes In items 1 and 2. Ifa plant designatos a case es complex, the cover sheet must bo served with the ‘complaint on all parties to the action. A defendant may fle and serve no leter than the time of its frst appearance a jolnder in the plaints designation, @ counter-designation thatthe case is not complex, o,f the plant has made no designation, a designation that the case is complex. (CASE TYPES AND EXAMPLES. cuo10 Auto Tort Const Provisionly Compox Cl Ligation (Ca "is (22) Peso nryPropety Srna of Contactar (8) Fs of Goer Rs 3400-340) ‘amegetrrgt Caan ‘reach Renae tt rade Reston (09) Unsure ates a2) “Soa ne ened tne Saratclen Bots (10) ‘ease involves en uninsured ‘Glas Invoiving Mass Tort (40) Toto jot Sonus Ugaten 8) tile these tm Pat rt Fu erento) torent Tes Tt (0) ena Aso) ogi teach of Coca insurance Coverage Cae ther PIPDIWD (Personal Injury on TY 0 . {area kom proeonety comer To eerie Coteedons (og noney ened. open Enforcement of Judgment besen 0h) epee exert of aren (20) 5 rape Danage Coles Gao Sefer at ‘init uproot Prema taty Sth tania Nototecone a) samara Soe Cees Juigrant(on- Pred Lay (no aos or ‘surance Gevenge (et ronal ciaecteracion) yo eba ‘on (1) sist Segre od ea ‘to Scrat ‘emilee sonny Aver ‘Medical Malpractice Othor Coverage {not unpaid taxes) Phys & Spoons ther Coast 7) Pelli ot Eno Othor Professional Health Care ‘Contractual Fraud Judgment on Unpaid Taxes: alprece, (thor Gontact Dispute (the Enforeamant of usgrnont Ones IONE ay eS earns ee ‘and fall) ® ‘Condemnation (14) RICO (27) Intentional Body Injury/POIWD ‘Wrongful Eviction (33) Oe oan (not spoctiod ‘eo, mhvaalon) ter Ral Proper 0, dt) (2) orl ton of WitotFoseeden of fea Prost Declare Ory ‘Emotonal Distress Norigage Forecosure Ianto Robe Ci on Nealges lon of ‘et Tite eerie al Docs Stor Roel Povey (a oinnt . ter FPO derma endartnan or a Commer ompint Non-PUPOMD (Other Tort ‘orecoure} one rmrnercomots) Busnors Tour unos Unlawtt Detainee et Get Corsa Practice (07) ‘Commercial (31) Miscellaneous Civil Potton om Ria dctnnatn, eso 2) nop an Crore tals are (nlc rage Gb (ie cas vate toga! ‘Goemanco Tras) (8) Giger his for coer, Ctr Pele apoctod veto fo. adr, ba) ‘apes Sommer Retota) wor) () 3) tail Review BaF ent Freud 1) ent Fert (05) Watelane Vturco tetas Popa (1) Potton Anton rd (1) eons Freedona Nogigonee 2) Wt andaa oa)? EeegDepensert Adit ipa acs ‘id Si rele Manaus ee ‘Sfx Proeesoral Mabractes Wit Mardares on iio Gout Cec Cited {et medical or ioae) Cape Mattor Potion for Reval From Late 3 ctr Kor Pon To Writ Other Limited Court Case ‘Gain melo et er Paton gh Teminaton 6) ry er Cro Ofer emeioent (1) Tin oll Sar Ordr Nate of pa Labor Someone Apple Baar a CIVIL CASE COVER SHEET‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF RIVERSIDE 4050 Main Street Riverside, CA 92501 www tiverside cour ov NOTICE OF CASE MANAGEMENT CONFERENCE PUBLIC EMPLOYMENT RELATIONS VS COUNTY OF RIVERSIDE CASE NO. RIC1809250 ‘The Case Conference is scheduled for 11/14/18 at 8:30 in Department 01. No later than 1S .calendar days before the date set for the case management conference cr review, each party must file a case management statement and serve it on all other parties in the case. CRC, Rule 3.725 The piainticross-complainant shall serve a copy of this notice on all defendants/cross-defendants who are named or added to the complaint and file proof of service. ‘Any disqualification pursuant to CCP Section 170.6 shall be filed in accordance with that section Requests for accommodations can be made by submitting Judicial Council form MC-410 no fewer than five court days before the hearing, See Califomia Rules of Court, rule 4.100. CERTIFICATE OF MAILING | certify that 1 am currently employed by the Superior Court of Califomia, County of Riverside, and that | am not a party to this action or proceeding. In my capacity, | am familiar with the practices and procedures used in connection with the mailing of ‘correspondence, Such correspondence is deposited in the outgoing mail of the Superior Court. Outgoing mail is delivered to and mailed by the United States Postal Service, postage prepaid, the same day in the ordinary course of business. | certify that | served ‘ copy of the foregoing NOTICE on this date, by depositing said copy as stated above. coun Egy once Ye Date: osen8 i by: JRIGUEZ , Deputy Clerk‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF RIVERSIDE 4050 Main Street Riverside, CA 92601 www riverside, courts.ca.gov, NOTICE OF DEPARTMENT ASSIGNMENT PUBLIC EMPLOYMENT RELATIONS VS COUNT CASE NO. RIC1809250 This case is assigned to the HONORABLE Judge Randall S Stamen in Department 07 for Law and Motion purposes only, ‘The case is assigned to Honorable Judge John Vineyard in Department 1 for case management hearings (Case Management Conferences, Order to Show Causes, Status Conferences and Trial Setting Conferences) and trial assignment purposes. ‘Any disqualification pursuant to CCP section 170.6 shall be filed in accordance with that section. The court follows California Rules of Court, Rule 3.1308(a)(1) for tentative rulings (see Riverside ‘Superior Court Local Rule 3316). Tentative Rulings for each law and motion matter are posted on the Internet by 3:00pm on the court day immediately before the hearing at . if you do not have internet access, you may ‘obtain the tentative ruling by telephone at (760) 904-5722. To request oral argument, you must (1) notify the judicial secretary at (760) 904-6722 and (2) inform all other parties, no later than 4:30 pm the court day before the hearing. if no request for oral argument is made by 4:30 pm, the tentative ruling will become the final ruling on the matter effective the date of the hearing ‘The fling party shall serve a copy of this notice on all parties. Requests for accommodations can be made by submitting Judicial Council form MC-410no fewer than five court days before the hearing, See California Rules of Court, rule 1.100. CERTIFICATE OF MAILING | certify that | am currently employed by the Superior Court of Califomia, County of Riverside, and that | ‘am not a party to this action or proceeding. In my capacity, | am familiar with the practices and procedures used in connection with the mailing of correspondence. Such correspondence is deposited in the outgoing mail of the Superior Court. Outgoing mail is delivered to and mailed by the United States Postal Service, postage prepaid, the same day in the ordinary course of business. | certify that | served a copy of the foregoing NOTICE on this date, by depositing said copy as stated above. Date: 05/18/18 by: ELIZETH RODRIGUEZ, Deputy Clerk