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EXHIBIT A

Case 2:15-cv-02394-DSF-MAN Document 1-2 Filed 04/01/15 Page 1 of 75 Page ID #:7

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Service of ProcessTransmittal03/11/2015CT Log Number 526733593

TO: ami Fortier-GomezFox Group Legal2121 Avenue of the Stars, Suite 764Los Angeles, CA 90067

RE: rocess Served in California

FOR: 1st Century Fox America, Inc. (Domestic State: DE)

ENCLOSED ARE COPIES OF LEGAL PROCESS RECEIVED BY THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS:

TITLE OF ACTION: rian Jun, Pltf. vs. Fox Group, et al. including 21st Century Fox America Inc., Dfts.Name discrepancy noted

DOCUMENT S) SERVED: ummons, Case Cover Sheet(s), Instructions, Addendum(s) and Statement(s),Complaint, Demand(s), Notice(s), Stipulations, Conference(s), Stipulation(s) andOrder(s)

COURT/AGENCY: os Angeles County - Superior Court - Hill Street, CACase BC574646

NATURE OF ACTION: mployee Litigation - Wrongful Termination - February 12, 2014

ON WHOM PROCESS WAS SERVED: T Corporation System, Los Angeles, CA

DATE AND HOUR OF SERVICE: y Process Server on 03/11/2015 at 14:52

JURISDICTION SERVED : alifornia

APPEARANCE OR ANSWER DUE: ithin 10 days after service

ATTORNEY S) / SENDER S): dward YunYun ft Simonian, PC11175 Santa Monica Blvd.Suite 420Los Angeles, CA 90025310-651-9940

ACTION ITEMS: OP Papers with Transmittal, via Fed Ex 2 Day , 780333986452Image SOPEmail Notification, Janet Nova [email protected] Notification, Tami Fortier-Gomez [email protected] Notification, Randy Kender [email protected] Notification, Patrick Gillham [email protected]

SIGNED: T Corporation SystemADDRESS: 18 West Seventh Street

Los Angeles, CA 90017TELEPHONE: 13-337-4615

Page 1 of 1 / SS

Information displayed on this transmittal is for CT Corporation'srecord keeping purposes only and is provided to the recipient forquick reference. This information does not constitute a legalopinion as to the nature of action, the amount of damages, theanswer date, or any information contained in the documentsthemselves. Recipient is responsible for interpreting saiddocuments and for taking appropriate action. Signatures oncertified mail receipts confirm receipt of package only, notcontents.


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SUMMONS(CITACION JUDICIAL)

NOTICE TO DEFENDANT:(AVISO AL D EMANDA DO):Fox Group, New s Am erica Inc., 21st Century Fox America Inc., FoxEntertainment G roup, Inc., and DOE S 1 to 100, inclusive

YOU ARE B EING SUED BY PLAINTIFF:(LO ESTA DEMANDANDO EL DEMANDANTE):Brian Jun

SUM-100FOR COURT USE O NLY

(SOLO PARA US O DELA COFI TE)

CONFORMED COPYORIGINAL FILED

Superior Court of CaliforniaCounty of Los Angeles

M A R 0 5 2 0 1 5Sh erri R. Ca rter Executive Officer/Cler

By Myrna Bel tran Depu ty

NOTICE You have been sued. The court may decide against you without your being heard unless you respo nd within 30 days. Read the informationbelow.

You have 30 CALENDAR DAYS after this summ ons and legal pap ers are served on you to file a written response at this court and have a co pyserved on the p laintiff. A letter or phone call will not protect you. Your written response must be In proper legal form If you want the cou rt to hear youcase. There may be a court form that you can use for your respon se. You can find these court forms and m ore Information at the California CourtsOnline Self-Help Center(www.courtinfo.ca.goviselthelp).your county law library, or the courthouse nearest you. If you cannot pay the filing fee, askthe court clerk for a fee waiver form. If you do n ot file your response on time, you m ay lose the case by default, and your wag es, money, and propertmay be taken w ithout further warning from the court

There are other legal requirements. You m ay want to call an attorney right away. If you do not kn ow an attorney, you may w ant to call an attorneyreferral service. If you cannot afford an attorney, you ma y be eligible for free legal services from a nonprofit legal services program. You can locatethese nonprofit groups a t the California Legal Services Web site(wwwlawhelpcal ifomle.org), the California Courts Online Self-Help Center(www.couninfo.ca.goviselthelp),or by contacting your local co urt or county bar assod ation. NOTE: The court has a statutory lien for waived fees an dcosts on any settlement or arbitration award o f $10,000 or mo re In a civil case. The court's lien must be p aid before the court will dismiss the case.

Lo han demande d°. Si no responde d entro de 30 dies, la carte puede deddir en su con tra s in escuchar su vershin. Lea la inforrnacian acontinuacian.

T7ene 30 DIAS DE CA LEIVDA RIO despu6s de qua le enbeguen esta ut ter :16n y papeles legales para presenter una respuesta pot escri to en ecarte y ha cot quo se ent tegue una co pia al demendante. Una carte o una armada telef6nIca no to protegen. Su respuesia pot °sot to bene quo es ten format° legal correct° sI desea quo procesen su caso en la cone. Es posible quo haya on (wo rded° quo us ted puede u ser pars su respues ta.Puede encontrar estos fonnulartos de la cone y mas informed:5n en el Centro de Ayuda de las Cortes de California(wmv.sucorte.ca.gov), en lablbl ioteca de /eyes de su conclado o en la cone qu o le quede m as coma . S/no puede pager la cuo ta de presentacion, pida al secretarlo de la codequo le de un formula: to de exend6n de pago de cuotas. Si no presente su respuestaa tiempo, puede perder el caso pot Incumplimiento y la code lepodra guitar su sueldo, dinero y biertes s in más advertenda.

Hay obos requisi tos legates. Es recomendable quo nam e a un abogado Inmediatamente. Si no conoce a o n ebogado, puede &m ar a un servicioremision a abogados. Si no puede pa gera on abogado, es posibie qua cumpla con los requisrlos pare obtener servicios legates gratuitos de unprograma de serviclos logo/es s in f ines de ludo. Puede encontrar estos grupos sin f ines de ludo one si lk, web de California Legal Services,(rmwlawhelpcalifomia.org), en el Centro de Ayuda de las Cortes de California,(wwer.sucorte.ca.gov) o ponlandose en co ntact°con a code o elcolegio de abogados locales. AVISO : Pot ley, la cone done derecho a redama r las cuotas y los cost= exentos par imponer un gravam en sabrecualquier recuperacian de $10,000 6 mils de valor recibida mediente un acu erdo o un a concesion de arbi traje on u n caso de derecho civiL Tien° pager el gravamen de la code antes de qu a la carte pueda desechar el caso.

The name and address of the court is:

(El nombre y direccion de la carte es):Los Angeles Sup. Ct. - Stanley Mosk111 N H ill StreetLos Angeles 90012

The nam e, address , and te lephon e num ber of p la in t i ff s a t torney, or p la in t i ff wi thout an a t torney, i s :(El nombre, la direccion ye nOm em de telefono del abogado del demandante, o del demandante qua no Ilene abogado, es):Edward Yun, Yun & Simonian, PC, 11175 Santa Monica Blvd, Ste 420, Los Angeles, CA 90025, 310.651.994j

DATE: EM R.CARIER l e rk , by YRNA ELTRANDeputy

(Fecha) Secretarfo) Acfjunto)(For pluof of service of this summ ons, useP r o o f o f S e rv i c e o f S u m m o n s(form POS-010).)(Para prueba de entrega de esta citation use el formularioP r o o f o f S e r v ic e o f S u m m o n s ,(POS-010)).

NOTICE TO THE PERSON SERVED: You are served1. as an Indiv idual defendant .2. as the person sued under the fictitious name of (specify):

rejafAlme t NUMBER:

ts ' MAR 0 5 201

3, =1 on behalf of specify) 21 I S4 -

under CP 416.10 (corporation) Jn CCP 41620 (defunct corporation) IIE CCP 416.40 (association or partnership) F

EJ other (specify):4. 1-71 by personal delivery on (date):

mer; c4

CCP 416.60 (minor)CCP 416.70 (conservatee)

CCP 416.90 (authorized person)

Foos 1of iForm Adopted for 14andabay

Judidei Council of CefidcmiaSU14100 [Rev. July1. 20091

SUMMONS Code of MI Procedure §5 412.20,465vnow.courtinfo.cagev


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ATTORNEY OR PARTYEdward Yun

RYJO_UITAITTORNEY(Name. Sta te Bar number, and address) :— SBN 258245)

Yun & Simonian, PC11175 Santa Monica Boulevard, Suite 420Los Angeles, CA 90025

TELEPHONE NO.; 310.651.9940 AX NO.: 323.900.0660ATTORNEY FOR (Nam): Plaintiff Brian Jun

FOR COURT U SEONLY


Superior Court of Californiacounty Of Los Angeles

M A R 05 2 0 1 5

Sherri R. Carter, Executive Officer/CIEBy Myrna Beltran, Deputy

SUPERIOR COURT OF CALIFORNIA, COUNTY OFLos AngelesSTREET ADDRESS: 111 N Hill Street. . . . . . . . . .111 N Hill Street

crrrAND ZIP COOEI Los Angeles 90012BRANCH NAME: Stank} , mosk

CASE NAME:

Brian Jun v. Fox G roup, News A merica Inc., et al.CIVIL CASE COVER SHEET Complex Case Designation

CASE t 7 4 6 4 6nlimited mited(Amount Amountdemanded emanded isexceeds $25,000) 25,000 or less)

Counter oinder

Filed with first appearance by defendant(Cal. Rules of Court, rule 3.402)

JUDGE:

DEPT:

I tems 1 below m ust be com pleted (see Ins t ruct ions on page 2) .1 Check one box below for the case type that best describes this case:

Auto Tor t ontract rovisionally Complex Civil Litigation= Auto (22) l Breach o f contractiwa rranty (06) (Cal. Rules of Co urt. rules 3.400-3.463)

= Uninsured m otor is t (46) I Rule 3.740 collections (09) Antitrust/Trade regulation (03)Other PUPDMID (Personal Injury/Property Other collections (09) Cons truct ion defect (10)

DamagePNrongful Death) Tort Insurance coverage (18) Mass tort (40)=I Asbestos (04) D Other contract (37) =1 Securities litigation (28)E • oduct ilablRy (24) eal Property I Environmen tal/Toxic tort (30)I—I M• dical malpractice (45) Eminen t dom ain /Inve rse I nsurance coverage claims arising from theEl Other PI/PDNVD (23) ondemnation (14) bove listed provisionally complex caseNon-PI/PD/WD (Other) Tort 1 W rongful evic t ion (33) ypes (41)

ED Business tort/unfair bus iness practice (07) n Other real prope rty (26) nforcement of Judgment

= Civil righ ts (08) nlawful Detainer .:3 Enforcemen t of judgm ent (20)

CI D• famation (13) Commercial (31) iscellaneous Civil Complaint= Fraud (16) = 7 Residential (32). =1 RICO (27)= inte l lectual pm perly (19) Drugs (38) 1=1 Other complaint(not specified above) (42)I Professional negligence (25) udicial Review iscellaneous Civil Petition1 • her non-PI/PD/WD tort (35) l Asset fo rfe i ture (05) 1:::=1 Partnership and corp orate governan ce (21). Le loyment Petition re: arbitration award (11) = Other petition (not specified above) (43)1 Wrongfu l termination (36) --- Writ of m andate (02)ri • her employment (15) -1 O ther judicial review (39)

2. This case LI is LLI S not complex under rule 3.400 of the California Rules of Court. If the case Is complex, mark thefactors requiring exceptional judicial management

a = Large number of separately represented parties . ED Large number of witnesses

b. E] Extensive motion practice raising difficult or novel e. ED Coordination with related actions pending in one or more courtsissues that will be time-consuming to resolve n other counties, states, or countries, or in a federal court

c = Substantial amount of documentary evidence . CI Substantial postjudgment judicial supervision3. Remedies sought (check all that apply):a.M monetary b.M nonmonetary: declaratory or injunctive relief c. [If punitive4. Number of causes of action (specify): eight (8)5. This case I= is I= s no t a class action suit.6. If there are any known related cases, file and serve a notice of related case. (You may use form CM-015.)

Date: February 26,2015Edward Yun, Esq.

(TYPE OR PRINT NAME)SIGNATURE OF PARTY OR ATTORNEY FOR PARTY)

NOTICE• Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed

under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may resultIn sanctions.

• File this cover sheet in addition to any cover sheet required by local court rule.• If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all

other parties to the action or proceeding.• Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes on

Fags 1 of 2

Fonn Adopted for Mandalay UssJudicial Coma of CaLforriac e 4 - 0 1 0PUY. iL l2Y 1.70071

CIVIL CASE COVER SHEET Cal. Fades of Court, niers 2-30, 3.=0, 3.400-3.403.3.740;Cal. Standards dila:dial Adrrinistratkat, std. 3.10vnnv.ceurtbdo.cagov


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INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEETM-010

To Plaint i ffs and Others Fi l ing Firs t Papers . I f you are f i l ing a f i rs t paper (for exam ple, a com plaint) in a civi l case, youmustcom plete and file, along w ith your first paper, theCivil Case Cover Sheet contained on page 1. This information will be used to comp ilestatistics about the types and num bers of cases filed. You must complete items 1 through 6 on the sheet In item 1, you m ust checone bo x for the case type that best describes the case. If the case fits both a gen eral and a m ore specific type of case listed in item1,check the m ore specific one. if the case has m ultiple causes of action, check the bo x that best indicates the primary cause of actioTo assist you in completing the sheet, examp les of the cases that belong under each cas e type in item 1 are provided below. A covsheet m ust be filed only w ith your Initial paper. Failure to file a cover sheet with the first paper filed in a civil case m ay subject a p aits counse l, or both to sanction s und er rules 2.30 and 3.220 of the California Rules of Court.To Parties In Rule 3.740 Collections Cases. A 'collections case u nder rule 3.740 is defined as an action for recovery of mone yowed in a sum stated to be certain that Is not more than $25,000, exclusive of interest and attorneys fees, arising from a transaction which property, services, or money w as acquired on credit A collections case does n ot include an action seeking the following:(1) tortdam ages, (2) pun i t ive dam ages, (3) recovery of real property, (4) recovery of personal prop erty, or (5) a prejudg me nt wri tat tachment The ident i ficat ion of a case as a rule 3 .740 col lect ions (me on this form m eans that i t wi l l be exempt f rom the genetime-for-service requiremen ts and case m anagem ent rules, unless a defendant files a responsive pleading. A rule 3.740 collectiocase will be subject to the requireme nts for service and obtaining a judg men t in rule 3.740.To Parties In Complex Cases. In complex case s only, par t ies m ust a lso use theCM Case Cover Sheet to designate whether thecase is com plex. If a plaintiff believes the case Is com plex under rule 3.400 of the California Rules of Court, this must be indicatedcompleting the appropriate boxes in items1 and 2. If a plaintiff designates a case as complex, the cover sh eet must b e served w ith thecom plaint on all parties to the action. A defend ant ma y file and serve no later than the tim e of its first appeara nce a joinde r in tplaintiffs designation, a counter-designation tha t the case is not complex, or, if the plaintiff has made no design ation, a designation ththe case Is comp lex. ASE TYPES AND EXAMPLESAuto Tor t

Auto (22)-Personal Injury/PropertyDamage/Wron gful Death

Uninsured Motorist (46)(if thecase involves an uninsuredmotorist claim subject toarbitration, check this iteminstead of Auto)

Other PUPDAND (Persona l injury/Property Damage/Wrongful Death)Tort

Asbestos (04)Asbestos Property DamageAsbestos Personal Injury/

Wrongful DeathProduct Liability(not asbestos or

toxic/environmental)(24)Medical Malpractice (45)

Medical Malpractice-Physicians & Surgeons

Other Professional Health CareMalpractice

Other PI/PD/WD (23)Premises Liability (e.g., slipand fall)

Intentional Bodily Injury/PDAND(e.g., assault. vandalism)

Intentional Infliction ofEmotional Distress

Negligent Infliction ofEmotional Distress

Other PUPD/WDNon-PVPD/WD (Other) Tort

Business Tort/Unfalr BusinessPractice (07)

Civil Rights (e.g., discrimination,false arrest)(not civilharassment) (08)

Defamation (e.g.. slander, libel)(13)

Fraud (16)Intellectual Prop erty (19)Professional Negligen ce (25)

Legal MalpracticeOther Professional Malpractice

(not medical or legal)Other Non-PI/PD/WD Tort (35)

E m p l o y m e n tWrongful Termination (36)Other Employment (15)

ContractBreath of Con tract/Warranty (06)

Breath of Rental/Lease

Contract(not unlawful detaineror wrong ful eviction)Contract/Warranty Breath-Seller

Plaintiff(not fraud or negligence)Negligent Breach of Contract/

WarrantyOther Breach of Contract/Warranty

Collections (e.g., money owed , openbook acco unts) (09)Collection Cas e-Seller PlaintiffOther Promissory Note/Collections

CaseInsurance Coverage(not p rovisionally

complex) (18)Auto SubrogationOther Coverage

Other Contract (37)Contractual FraudOther Contract Dispute

Real PropertyEminent Domain/InverseCondemnation (14)

Wrongful Eviction (33)Other Real Property (e.g., q uiet title) (26)

Writ of Possession of Real PropertyMortgage ForeclosureQuiet TitleOther Real Property(not eminentdomain, landlord/tenant, orforeclosure)

Unlawful DetainerCommercial (31)Residential (32)Drugs (38)(if the case Wolves Illegal

drugs, check this Item; otherw ise,report as Commercial or Residential)

Judicial ReviewAsset Forfeiture (05)Petition Re: Arbitration Award (11)Writ of Mand ate (02)

Writ-Administrative MandamusWrit-Mandamu s on Um ited Court

Case MatterWrit-Other Limited Court Case

ReviewOther Judicial Review (39)

Review of Health Officer OrderNotice of Appeal-Labor

Commissioner Appeals

Provisionally Com plex Clvil l i t igation (Cal.Rules of Cou rt Rules 3A00-3.403)

Antitrustarade Regulation (03)

Construction Defect (10)Claims Involving Mass Tort (40)Securities Litigation (28)Environmental/Toxic Tort (30)Insurance Coverage Claims

(arising from provisionaly complexcase type listed above)(41)

Enforcement of JudgmentEnforcement of Judgm ent (20)

Abstract of.Judgment (Out ofCounty)

Confession of Judgment(non-domestic relations)

Sister State Judgm entAdministrative Agency Award

(not unpaid taxes)Petition/Certification of Entry of

Judgmen t on Unpaid TaxesOther Enforcement of Judgment

CaseMiscellaneous Civil Complaint

RICO (27)Other Complaint(not spec ified

above) (42)Dedaratory Relief OnlyInjunctive Re lief Only(non-

harassment)Mechanics LienOther Commercial Complaint

Case (non-tort/non-complex)Other Civil Complaint

(non-tort/non-complex)Miscellaneous Civil Petit ion

Partnership and CorporateGovernance (21)

Other Paton (not specifiedabove) (43)Civil HarassmentWorkplace Violence

Elder/Dependent AdultAbuseElection ContestPetition for Name ChangePetition for Relief From Late

ClaimOther CNit Petition

CIVIL CASE COVER SHEETPigs 2 of 2mmorrtmiuryr.2mm


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SHORT TITLE: ASE NUMBERJun v. Fox Group, News America Inc. et al.

6CIVIL CASE COVER SHEET ADDENDUM AND

STATEMENT OF LOCATION(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)

This form Is required pursuant to Local Rule 2.0 in all new CMI case filings In the Lo s Angeles Superior Court.

Item I. Check the types of hearing and fill In the estimated length of hearing expected for this case:

JURY TRIAL? ES CLASS ACTION? El YES LIMITED CASE? DYES TIME ESTIMATED FOR TRIAL 14 O HOURS/ DAYS

Item II. Indicate the correct district and courthouse location (4 steps — If you checked 'Limited Cases, skip to Item III, Pg. 4):

Step 1: After first completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for yourcase in the l eft margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected.

Step 2: Check one Superior Court type of action in Column B below which best describes the nature of this case.

Step 3: In Column C, circle the reason for the court location choice that applies to the type of action you havechecked. For any exception to the court location, see Local Rule 2.0.

Applicable Reasons for Choosing Courthouse Lo cation (see Column C below)

1. Class actions must be filed In the Stanley Mosk Courthouse. central district2. May be filed in central (other county, or no bodily Injury/property damage).3. Location where cause of action arose.4. Location where bodily injury, death or damage occurred.5. Location where performance required or defendant resides.

6. Location of property or permanently garaged vehicle.7. Location where petitioner resides.8. Location wherein defendant/respondent functions wholly.9. Lawton where one or more of the parties res ide.

10. Location of Labor Commissioner Office

Step 4: All in the Information requested on page 4 in Item III; complete Item IV. Sign the declaration.

• : .--A L -,.. '-'Civil Case Cover Sheet ' ;, 1

. ... •:: .-I • • • • . . .- • : . ' ; .. -: : - A-.- . 'B - -,, -- . _ . - •-• . . Tips of Action ..--; ..•.i. :- ,..- : ., .. ; , . (Check only one) , • .

Applicable Reasons -:See Step 3 Above,

Auto (22) 0 A7100 Motor Vehicle. Personal Injury/Property Damage/Wrongful Death 1., 2.. 4.

Uninsured Motorist (46) 0 A7110 Personal Injury/Property Damage/Wrongful Death — Uninsured Motorist 1., 2.. 4.

—

0 A6070 Asbestos Property Damage 2.Asbestos (04)

0 A7221 Asbestos - Personal Injury/Wrongful Death 2.

Product Liability (24) 0 A7260 Product Liability (not asbes tos or toxic/environmental) 1., 2., 3., 4., 8.

0 A7210 Medical Malpractice. Physicians 8 Surgeons 1.. 4.Medical Malpractice (45)

Ci A7240 Other Professional Health Care Malpractice 1., 4.

Other0 A7250 Premises Liability (e.g., slip and fall) 1., 4.

Personal InjuryProperty Damage

0 A7230 intentional Bodily Injury/Property Damage/Wrongful Death (e.g..assault, vandalism, etc.)

1., 4.

Wrongful Death(23)

0

0

A7270 Intentional Infliction of Emotional Distress

A7220 Other Personal Injury/Property Damage/Wrongful Death

1.,

1.,

3.

4.

LAM/ 109 (Rev. 03/11)

LASC Approved 03-04

CIVIL CASE COVER SHEET ADDENDUMAND STATEMENT OF LOCATION

Local Rule 2.0

Page 1 o14


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Unawfu

ean

SHORT TRIE:Jun v. Fox Group, News America Inc. et al.

CASE NUMBER

-,... Civil dise Cove r: Sheet :.• Category No. •:. •

• • • - :..:-= ._• • •• ' • .2- — : . • =•• • . Type of Athon s; . . -•.'',... ', ..'.:4- 1

. - , - • ; (Check only one) ; •

. 0 .Applicable Reasons -• See Step 3 Above .

Business Tort (07) CI A6029 Other C ommercial/Business Tort (not fraud/breach of contract) 1., 3.

CM R ights (08) 0 A6005 Civil Rights/Discrimination 1., 2.. 3.

Defamation (13) 0 A6010 Defamation (slander/libel) 1., 2.. 3.

Fraud (16) 0 A6013 Fraud (no contract) 1., 2., 3.

0 A6017 Legal Malpractice 1.. 2., 3.Professional Negligence (25)

0 A6050 Other Professional Malpractice (not medical or legal) 1., 2., 3.

Other (35) 0 A6025 Other Non-Personal Injury/Property Damage tort 2..3.

W rongful Termination (36) IZ A6037 W rongful Termination 1.@4).

0 A6024 Other Employment Comp laint Case 1., 2., 3.Other Employment (15)CI A6109 Labor C ommissioner Appeals 10.

0 A6004 B reach of Rental/Lease Contract (not unlawful detainer or wrongfuleviction) 2., 5.

Breath of Contract/ W arranty 2., 5.(06) 0 6008 Contract/W arranty Breach -Seller Plaintiff (no fraud/negligence)

(not insurance) CI A6019 Negligent Breach of Contract/Wa rranty (no fraud) 1., 2., 5.

0 A6028 Other Breach of C ontract/W arranty (not fraud or negligence) 1., 2., 5.

0 6002 C ollections Case-Seller Plaintiff 2., 5.. 6.Collections (09)

CI A6012 Other Promissory Note/Collections Case 2.. 5.

Insurance Coverage (18) 0 A6015 Insurance Coverage (not complex) 1.,2., 5.,8.

0 A6009 Contractual Fraud 1., 2., 3., 5.Other Contract (37) 0 A6031 Tortious Interference 1., 2., 3., 5.

CI A6027 Other Contract Dispute(not breach/insurance/fraud/negligence) 1.. 2., 3., 8.

Eminent Domain/InverseCondemnation (14) 0 A7300 Eminent Domain/Condemnation umber of parcels 2.

W rongful Eviction (33) 0 A6023 Wrongful Eviction Case 2., 6.

0 A6018 Mortgage Foreclosure 2.. 6.

Other Real Properly (26) 0 A6032 Quiet Tide 2.. 6.

0 6060 Other R eal Property (not eminent d omain, landlord/tenant, foreclosure) 2.. 6.

U nlawful Detainer-Commercial(31) 0 A6021 U nlawful Detainer-Com mercial (not drugs or wrongful eviction) 2.. 6.

U nlawful Detainer-Residential(32)

CI A6020 U nlawful Detainer-Residential (not drugs or wrongful eviction) 2., 6.

U nlawful Detainer-Post-Foreclosure (34) 0 A6020FU nlawful Detainer-Post-Foreclosure 2., 6.

U nlawful Detainer-Drugs (38) 0 A6022 U nlawful Detainer-Drugs 2., 6.

LAM/ 109 (R ev. 03/11) ML CASE COVER SHEET ADDENDUM ocal Rule 2.0LASC Approved 03-04 ND STATEMENT OF LOCATION age 2 of 4


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- - ..r. A r:'CMI Case Cover Sheet

.: . . . - - ., ategory No. f- "...,_ ' ,.

.....

• . •• . . Type of Mien' .4-....; .•: „ . -. . • . . .(Check only o ne) -"_” • .:"... ..:t., . . . . ; L ..

Applicable Reasons -.See Step 3 Abo ve' :

Asset Fo rfeiture (05) 0 A6108 Asse t Forfe i ture Case 2.6.

Petition re Arbitration (11) 0 A6115 Petit ion to Com pel/Confirm/Vacate Arbitrat ion 2., 5.

0 A6151 Writ - Administrat ive Mandamu s 2., 8.

Writ of Mandate (02) 0 A6152 Writ - Mandam us on Lim ited Court Case Matter 2.

0 A6153 Writ - Other Limited Cou rt Case Review 2.

Other Judicial Review (39) 0 A6150 Other Wri t / Judida t Review 2., 8.

AntitrustfTrade Reg ulation (03) 0 A6003 Antitrust /Trade Regu lation 1.. 2., 8.

Construction Defect (10) 0 A6007 Cons t ruc t ion Defec t 1., 2., 3.

Claims IrivoktIng Mass Tort 0 A6006 Claims Invo lving Mass Tort 1., 2.. 8.(40)

Securities Litigation (28) 0 A6035 Securit ies Lit igation Cas e 1., 2.. 8.

Toxic Tort 0 A6036 Toxic Tort/Environmental 1.,2., 3.,8.Environmental (30)

Insurance Coverage Claimsfrom Com plex Case (41) 0 A6014 Insurance Coverage/Subrogation (complex case only)

1., 2., 5., 8.

0 A6141 Sis te r S ta te Judgm ent 2., 9.

0 A6160 Abst rac t of Judgm ent 2., 6.

Enforcement 0 A6107 Confession o f Judgm ent (non-dom estic relations) 2.. 9.

of Judgment (20) 0 A6140 Adm inistrative Agency Aw ard (not unp aid taxes) 2.. 8.

0 A6114 Petit ion/Certif icate for Entry of Judgm ent on Unpaid Tax 2., 8.

0 A6112 Other Enforcemen t of Judgm ent Case 2.. 8.. 9.

RICO (27) 0 A6033 Racketeer ing (RICO) Case 1.. 2., 8.

0 A6030 Declara tory Rel ie f Only 1., 2., 8.

Other Complaints 0 A6040 Injunctive Relief Only (not dom estic/harassmen t)2., 8.

(Not Specified Abo ve) (42) 0 A6011 Other Comm ercial Complaint Case (non-tort /non-comp lex) 1., 2., 8.

0 A6000 Other Clvil Comp laint (non-tort /non-com plex) 1„ 2.. 8.

Partnership Corporation 0 A6113 Partnership and Corporate Gov ernance Case 2 - E LGovernance (21)

0 A6121 Civil Harassment 2., 3.. 9.

0 A 6 1 23 W o r k p l a c e H a r a s s m e n t 2„ 3., 9.

0 A6124 Elder/Dependen t Adult Abuse Case 2., 3., 9.Other Petitions

(Not Specified Above) 0 A8190 Election Contest 2(43) 0 A6110 Pe t it ion for Change of Nam e • 2., 7.

0 A6170 Peti t ion for Relief from Late Claim Law 2, 3., 4., 8.

0 6100 Other Civil Petition 2..9.

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SNORT TITLE:Jun v. Fox Grou p, News America Inc. et al .

CASE NUMBER

LACIV 109 (Rev. 03/11)

LASC Approved 03-04

CIVIL CASE COVER SHEET ADDENDUM •AND STATEMENT OF LOCATION

Local Rule 2.0

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SHORT TITLE:

Jun v. Fox Group, News America Inc. et al.CASE NUMBER

Item III. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or othercircumstance indicated in Item H., Step 3 on Page 1 , as the proper reason for filing in the court location you selected.

ADDRESS:

REASON: Check the appropriate boxes for the numbers shown 10201 W Pico Boulevardunder Colum n C for the type of action that you have selected forthis case.

01. 212. 123. 04. 05. 06. 07. 08. 09. 010.

CnY TATE: IP CODE:

LOS Angeles A 003.5

Item IV. Declaration of A ssignmenz:I declare under p enalty of perjury und er the laws of the State of California that the foregoing is true

and correct and that the above-entitled matter Is properly filed for assignment to the Stanley Mosk ourthouse In theCentral istrict of the Superior Court of California, County of Los Angeles (Code Civ. Proc., § 392 et seq., and Local

Rule 2.0, subds. (b), (c) and (d)].

Dated: February 26,2015(SIGNATURE OF ATTORNEY/FIUNG PARTY)

PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLYCOMMENCE YOUR NEW COURT CASE:

1. Original Complaint or Petition.

2. If filing a Complaint, a completed Summons form for issuance by the Clerk.

3. CMI Case Cover Sheet, Judicial Council form CM-010.

4. CMI Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev.03/11).

5. Payment in full of the filing fee, unless fees have been waived.

6. A signed order appointing the Guardian ad L item, Judicial Council form CIV-0l 0, if the plaintiff or petitioner is aminor under 18 years of age will be required by Court in order to issue a summons.

7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendummust be served along with the summons and complaint, or other initiating pleading in the case.

LACIV 1 09 (Rev. 03/11) IVIL CASE COVER SHEET ADDENDUMLASC Approved 03-04 ND STATEMENT OF LOCATION

Local Rule 2.0

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EDWARD YUN (SBN 258245)SEVAHN SIMONIAN (SBN 301881)YUN SIMONIAN, PC11175 Santa M onica Blvd., Suite 420Los Ang eles, California 90025

Telephone Num ber: (310) 651-9940

Attorney for Plaintiff Brian Jun

Brian Jun,

V.

Fox Grou p, News Am erica Inc., 21st CenturyFox Am erica Inc., Fox En tertainment G roup,Inc., and DO ES 1 to 100, inclusive,

Defendants.


Superior Court of CaliforniaCounty of Los Angeles

M A R0 5 2 0 1 5S h e r r i R. C a r t e r E x e c u t i v e O f fi c e r /C l e

By Myrna Beltran, Deputy

1) Unlawful Violation of the CaliforniaFam ily Rights Act

2) U nlawful Retaliation in Violation ofthe California Family Rights Act

3) U nlawful Violation of the FamilyMed ical Leave Act

4) U nlawful Retaliation in Violation ofthe Family Medical Leave Act

5) U nlawful A ssociational DisabilityDiscrimination in V iolation of the FaiHousing and Employment Act

6) U nlawful Associational PregnancyDiscrimination in Violation of the FaiHousing and Employment Act

7) Failure to Prevent D iscriminationand/or R etaliation in V iolation of theFair Housing and Employment Act

8) W rongful Termination in Violation ofPublic Policy

DEMAND FOR JU RY TRIAL

SUPERIOR COU RT STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

BCase Number:

5 74 6 46

COMPLAINT FOR DAMAG ES FOR:

Plaintiff Brian Jun hereby brings his complaint against Defendants Fox Group, News

COMPLAINT


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Am erica Inc., 21st Century Fox Am erica Inc., Fox Entertainment Group, Inc. (collectively " FO

and/or " DEF END ANT S" ), and Does 1 through 100, inclusive, and alleges as follows:

GENERAL ALLEGATIONS

1. The true names, identities, or capacities whether individual, corporate, associate,

otherwise, of Defendants Does 1 throu gh 100, inclusive, are unkn own to the Plaintiff, who there

sues said Defendan ts by such fictitious names. W hen the true nam es, identities or capacities of s

fictitiously designated Defendants are ascertained, Plaintiff will ask leave of this Court to amend

Com plaint and to insert said true nam es, identities, and capacities, together with the proper chargi

allegations.

2. Plaintiff is informed and believes and thereon alleges that each of the D efenda

sued herein as a Doe is responsible in some m anner an d liable herein for negligent, wanton, reckl

and tortious conduct, strict liability, and by such wrongful conduct, proximately caused the

Plaintiff's injuries and dam ages.

3. At all times mentioned herein; Plaintiff was an d is a resident of the County of

Angeles, State of C alifornia.

4. Defendants FOX and Does 1 through 50, were corporations, associations,

partnerships, joint ventures, or other business entities, organized and existing under the laws of t

State of California and at all times herein m entioned conducted business in the State of C aliforn

and throughout the County of Los Angeles.

5. Defenda nts Does 51 through 100, were individuals who were the agents, employ

members, volunteers, servants, partners, representatives, independent contractors, joint venturers

other participants with or of Defendants FOX, and Does 1 through 50, and in doing the things

hereinafter mentioned, were acting within the course and scope of said agency, employment,

mem bership or other relationship with said Defend ants. At all times herein mentioned, De fendan

Does 51 through 100 were employees of Defendants FOX and Does 1 through 50 who held

supervisory positions w ithin the com pany.

6. At all times herein m entioned, DEFE NDA NTS , whether or not specifically identi

2COMPLAINT

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or designated herein as a D oe, and each of them, were the a gents, employees, servants, partn

independen t contractors, joint venturers and participants with all other Defend ants, and with e

other, and in doing the things hereinafter m entioned, were agents, emp loyees, servants, partn

joint venturers, and with the consent and per mission of the co-Defenda nts, and each of them.

7. W henever in this Com plaint reference is made to DEF END ANT S, such allegatio

herein above alluded to, shall be deem ed to mean the acts or om issions of FOX an d Does 1 to

inclusive, herein acting jointly and/or severally.

FACTU AL ALLEGATIONS COMMON TO ALL CAU SES OF ACTION

8. Plaintiff Brian Jun was a dedicated and successful tax planning manager for

Defendan ts FOX for over a yea r. In fact, Plaintiff's supervisor Shelly Nahass, Senior Vice Presi

of Tax Planning, gave Mr. Jun an outstanding mid-year review along with a discretionary bonus.

9. In or around May 2013, Plaintiff Jun's wife was pregnant and gave birth to the

couple's child. Following the delivery, Plaintiffs wife began experiencing severe post-partum

depression an d related disabilities.

10. As of about A ugust 2013, Mr. Jun disclosed his need for reasonable accomm oda

to care for his wife and newborn child to FO X and supervisor Shelly Nahass. Plaintiff advised

Nahass that he wo uld be seeking a leave that qualified for protection und er the Fam ily Med

Leave Act ("FM LA" ) and the California Fam ily Rights Act (" CFR A" ) beginning in or aro

December 2013. Approximately a week after his conversation with Shelly Nahass, Plaintiff B

Jun submitted a formal request for a FML A/CFR A-qualifying leave.

11. FO X's V ice President of Tax Planning Shelly Nahass reacted negatively to Plain

Brian Ju n's familial situation and impen ding need to take a protected leave of absence. Ms. Na

began treating Mr. Jun d ifferently from other similarly situated employees who were no t prepar

to go on a leave of absence. For instance, Defendant Nahass gave Plaintiff Brian Jun written

warn ings for the same behavior exhibited by colleagues outside of his protected classifications

received no analogous discipline.

12. Despite Shelly Naha ss's harassing and discriminatory beha vior, Plaintiff began

3COMPLAINT


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FML A and CFR A-protected leave as of approximately December 2013.

13. Upon Plaintiff's return to work, Defendants FOX aggressively retaliated against

Brian Jun , culminating in the wrongful termination of Plaintiff Brian Jun o n or about Febru ary 1

2014, for no other reason than (a) in retaliation for having taken a leave of absence under FMLA a

CFR A to ca re for his disabled wife and child, and (b) discriminatorily due to his association with

recently pregnant and disabled spouse.'

14. Plaintiff has timely filed a complaint with the California Department of Fair

Em ployment and H ousing, has complied with all the administrative requirements of that agency. T

Department of Fair Employment and Housing issued Right-To-Sue Notices to Plaintiff on

February 3, 2015.

FIRST CAUSE OF ACTION

U NLAW FU L VIOLATION OF THE CALIFORNIA FAMILY RIGHTS ACT [Governme

Code §12945.2]

(Against Defendants Fox Group , News Am erica Inc., 21st Century Fo x Am erica Inc., Fox

Entertainment Group, Inc. and DOES 1 to 100, inclusive)

15. Plaintiff restates and incorporates by reference each and every allegation contained

paragra phs 1 through 1 5, inclusive, as though fully set forth herein.

16. The above described actions by DEFENDANTS FOX and DOES 1 through 100,

inclusive, and/or their agents/employees, constitute unlawful violation of the California Family

Rights Act, codified in Governm ent Code section 12945.2.

17. At all material times, Plaintiff was a qualified em ployee for all positions he held

applied for, and he performed ea ch and every m aterial covenant and con dition of said employee in

satisfactory manner.

18. Plaintiff is a member of the class of persons entitled to protected medical and/or

family leave under the California Family Rights Act, embodied in Government Code section

12945.2. Specifically, Plaintiff worked for more than one (1) year for Defendants FOX and work

in excess of one thousand two h undred a nd fifty hours (1,250) in the preceding twelve (12) mo

4COMPLAINT


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period prior to his requested and/or taken leav es. Further, Plaintiff qualified for fam ily care an

med ical leave due to the birth of his child and the serious health condition of his spouse.

19. Defendan ts FOX, business entities form unknow n, and DOE S 1 through 50 and ea

of them are employers covered by and subject to the California Family Rights Act because

DE FEN DA NT em ployed fifty (50) or more full- or part-time employees for each working day

each of the twenty (20) calendar weeks p receding and following the leave periods.

20. Defendan ts FOX and D OES 1 through 100 violated the California Family Rights A

by refusing to allow Plaintiff to take required leave and otherwise discouraging him from taki

require leave. Defendants comm itted the aforesaid unlawful emp loyment practices by, with

limitation: (a) discouraging Plaintiff from taking pr otected leave; (b) pressuring P laintiff to retur

early from his leave; (c) discriminating against Plaintiff for requesting and taking a protected leav

and (c) terminating Plaintiff because he took a leave.

21. Defendants FOX and DOES 1 through 100 took adverse action against Plaintiff

including, but not limited to, dem oting, suspending, providing both w ritten and verbal warning

failing to promote, decreasing job responsibilities, issuing poor performance reviews, decreasi

pay, denying benefits, disciplining, decreasing hours, and/or thereafter terminating his employme

because of his exercise of his right to fam ily care and m edical leave under the California Fam

Rights Act.

22. The foregoing conduct engaged in by Defendants FO X and D oes 1 through 100, a

each of the directors, officers, and/or managing agents, constitutes malice, fraud, and oppression a

was carried on with a conscious and w illful disregard of Plaintiff's right to work in an env ironme

free of discrimination based on the exercise of one's right to family care and m edical leave under

California Family Right Act, so as to entitle Plaintiff to punitive damages to punish and set an

exam ple of said Defenda nts.

23. As a direct and proximate result of the aforementioned acts and omissions o

DEFENDANTS, Plaintiff has sustained and will continue to suffer in an amount within the

jurisdiction of this Cou rt, the exact amoun t to be proven at trial. Such da ma ges include a) loss

salary and other valuable em ployment benefits; b) pre-judgment interest and interest on the sum

5COMPLAINT


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dam ages at the legal rate; c) consequential damages, including dam ages for sham e, humiliatio

mental anguish, and em otional distress caused by the conduct of D efendant; and d) other genera

damages.

24. As a proximate result of the foregoing conduct, which violated the provisions of

Govern ment C ode §12945.2, Plaintiff has been forced to and will incur attorney's fees and costs

the prosecution of this claim, in an am ount to be prov en at trial.

SECOND CAUSE OF ACTION

UNLAWFUL RETALIATION IN VIOLATION OF THE CALIFORNIA FAMILY RIGHTS

ACT [Government Code §12945.2]

(Against Defendants Fox Group, News America Inc., 21st Century Fox America Inc., Fox


25. Plaintiff restates and incorporates by reference each and every allegation contained i

paragraphs 1 through 15, inclusive, as though fully set forth herein.

26. The above described actions by Defendants FOX and DOE S 1 through 100, inclusiv

and/or their agents/employees, constitute unlawful violation of the C alifornia Fa mily R ights A

codified in Governm ent Code section 12945.2.27. At all material times, Plaintiff was a qualified employee for all positions he held

applied for, and he performed each and every m aterial covenant and con dition of said employee in

satisfactory manner.

28. Plaintiff is a member of the class of persons entitled to protected medical and/o r

family leave under the California Family Rights Act, embodied in Government Code section

12945.2. Specifically, Plaintiff worked for more than one (1) year for Defendan ts FOX and w orke

in excess of one thousand two hu ndred and fifty hours (1,250) in the preceding twelve (12) mon

period prior to his requested and/or taken leaves. Further, Plaintiff qualified for family care and

medical leave du e to the birth of his child and the serious health condition of his spouse.

29. Defendants FOX, business entities form Unknown, and DOES 1 through 50 and eac

of them are employers covered by and subject to the California Family Rights Act because

6COMPLAINT •


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DE FEN DA NT em ployed fifty (50) or more full- or part-time employees for each working day

each of the twenty (20) calendar weeks preced ing and following the leave periods.

30. Defend ants violated the California Fam ily Rights Act by retaliating against Plainti

because he sought to ex ercise and/or did exerc ise his rights under the C alifornia Family Rights Ac

In particular, Defendants FOX and Does 1 through 100 took adverse action against Plaintiff,

including, but not limited to, demoting, suspend ing, providing both written and verbal warn ings

failing to promote, decreasing job responsibilities, issuing poor performance reviews, decreasin

pay, denying be nefits, disciplining, decreasing hours, and/or thereafter terminating his employm en

because of his exercise of his right to fam ily care and m edical leave und er the California Fam

Rights A ct.

31. In engaging in the aforementioned conduct, DEFENDANTS, and each of them,

aided, abetted, incited, compelled, and/or coerced unlawful em ployment p ractices in violation of t

announced policy of this State against such practices.

32. The foregoing conduct engaged in by Defendants FOX and Does 1 through 100, an

each of the directors, officers, and/or managing agents, constitutes malice, fraud, and oppression an

was carried on W ith a conscious and willful disregard of Plaintiff's right to work in an environme nt

free of retaliation based on the exercise of on e's right to family care an d m edical leave under th

California Family Right Act, so as to entitle Plaintiff to punitive damages to punish and set an

example of said Defendants., so as to entitle Plaintiff to punitive damages to punish and set an

example of said Defendants.



jurisdiction of this Court, the exact amou nt to be proven at trial. Such damages include a) loss o

salary and other valuable emp loyment benefits; b) pre-judgment interest and interest on the sum o

dam ages at the legal rate; c) consequential damages, including dam ages for sham e, humiliatio

men tal anguish, and emotional distress caused by the conduct of Defenda nt; and d) other genera

damages.

34. As a proximate result of the foregoing conduct, which violated the provisions o

7COMPLAINT

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41. The foregoing conduct engaged in by Defendants FOX an d Does 1 through 100, a


was carried on w ith a conscious and willful disregard of Plaintiff's right to work in an en vironm e

free of discrimination based on the exercise of one's right to family care and m edical leave under t

Fam ily Medical Leave Act, so as to entitle Plaintiff to liquidated dam ages.

42. As a direct and proximate result of the aforementioned acts and omissions of


jurisdiction of this Cour t, the exact am ount to be proven at trial. Such dam ages include a) loss o

salary and other valuable employm ent benefits; b) pre-judgmen t interest and interest on thesum oI

damages at the legal rate; and c) other general damages.

43. As a proxim ate result of the foregoing conduct, Plaintiff has been forced to and w

incur attorney's fees and costs in the prosecution of this claim, in an am ount to be proven at tria

which are recoverable under 29 U .S.C. §2617(a)(3).

FOURTH CAUSE OF ACTION

U NLAW FU L RETALIATION IN VIOLATION OF THE FAMILY MEDICAL LEAVE AC

[29 U .S.C. §26151

(Against Defendants Fox Gro up, News A merica Inc., 21st Century Fo x Am erica Inc., Fox



paragr aphs 1 through 1 5, inclusive, as though fully set forth herein.

45. DEF EN DA NTS F OX and D oes 1 through 100, and/or their agents/employees, a

entities or individuals subject to suit under the C alifornia Fair Emp loyment an d Housing A ct, Gov

Cod e § 12940, et seq.

46. The above described actions by Defendants FOX an d Does 1 through 100, inclusiv

and/or their agents/employees, constitute unlawful FMLA discrimination and interference in

violation of the Fa mily and M edical Leave Act, codified in 29 U .S.C. §2615.

47. At all times herein m entioned, DEFEN DANT S were " employers" under the Fami

9COMPLAINT

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and Me dical Leave A ct and, specifically, 29 U.S.C . section 2611(4).

48. At all times herein mentioned, Plaintiff was an eligible employee under the F

and Me dical Leave A ct and, specifically, 29 U.S.C. section 2611(2).

49. DEFENDANTS violated the Family Medical Leave Act by retaliating against

Plaintiff because he sought to exercise and/or did exercise his rights under the Fam ily Medic

Act. In particular, Defendants FOX and Does 1 through 100 took adverse action against P

including, but not limited to, demoting, suspending, providing both written and verbal warnings,

failing to promote, decreasing job responsibilities, issuing poor performance reviews, decreasing

pay, denying benefits, disciplining, decreasing h ours, and/or thereafte r terminating his empl

because of his exercise of his right to family care and medical leave under the Fam ily Medica

Act.

50. The foregoing conduct engag ed in by Defendants FOX and Does 1 through 10

each of th e directors, officers, and/or managing ag ents, constitutes malice, fraud, and oppress

was carried on with a conscious and willful disregard of Plaintiff's right to work in an envir

free of retaliation based on the exercise of one's right to family care and medical leave under the

Family Me dical Leave Act, so as to entitle Plaintiff to liquidated damages.



jurisdiction of this Court, the exact amount to be proven at trial. Such damages include a) loss of

salary and other valuable employment benefits; b) pre-judgment interest and interest on the

damag es at the legal rate; and c) other general dama ges.

52. As a proxima te result of the foregoing c onduct, Plaintiff has been forced to an

incur attorney's fees and costs in the prosecution of this claim, in an amount to be proven at trial,

which are recoverable under 29 U.S.C. §2617(a)(3).

FIFTH CAUSE OF ACTION

U NLAW FUL ASSOCIATIONAL DISABILITY DISCRIMINATION IN VIOLATION OF

THE FAIR EM PLOYMENT AND HO U SING ACT [Government Code §§ 12926z

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12940, et seq.]

(Against Defendants Fox G roup, News A merica Inc., 21st Century Fox A merica Inc. , Fox


53. Plaintiff restates and incorporates by reference each and every allegation contained in

paragra phs 1 through 15, inclusive, as though fully set forth herein.

54. Defendant FO X and D oes 1 through 100, and/or their agents/employees, are entitie

or individuals subject to suit under the California Fair Emp loyment and Housing Act, Gov. Co de §

12926 and 1 2940, et seq.

55. At all ma terial times, Plaintiff was a qualified em ployee associated with a perso

namely his wife, who suffered from disabilities that limited one or more major life activities as

described herein or, alternatively, a person who DEFENDANTS regarded as suffering from a

disability or viewed as having a record of having a disability.

56. Plaintiff was at all times able to perform the essential functions of his job.

57. DE FEN DA NTS , and each of them, knew of Plaintiff's wife's disabilities and knew,

or should have known, that they fell within the definition of disability under Government Code

§12926. DEFE ND AN TS further knew , or should have known, that despite his wife's disabilitie

Plaintiff could perform the essential fturctions of her job with or without reasonable

accommodations.

58. Despite its knowledge of the foregoing, DEFENDANTS took adverse action agains

Plaintiff, including, but not limited to, dem oting, suspending, providing both w ritten an d verba

warnings, failing to prom ote, decreasing job responsibilities, issuing poor performa nce review

decreasing pay, den ying benefits, disciplining, decreasing hours, and/or thereafter term inating his

employment because of his association with a person, namely his wife, who suffered from

disabilities.

59. In engaging in the foregoing conduct, Defendants FOX and Does 1 through 100

aided, abetted, incited, participated. in, coerced and/or compelled unlawful emp loyment practices in

violation of C alifornia's Fair Em ployment and Housing Act.

60. The foregoing conduct engaged in by Defendants FO X and D oes 1 through 100, and

Ii

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each of the directors, officers, and/or m anaging agents, constitutes malice, fraud, and oppression an

was carried on with a conscious and w illful disregard of Plaintiff's right to work in a n environm e

free of discrimination based on his association with a person suffering from disabilities, so asentitle Plaintiff to punitive dam ages to punish and set an example of said D EFEN DAN TS.


Defendants, Plaintiff has sustained and w ill continue to suffer in an amount within the jurisdiction

this Court, the exact amoun t to be proven a t trial. Such dam ages include a) loss of salary and othe

valuable employment benefits; b) pre-judgment interest and interest on the sum of damages at th

legal rate; c) consequential damages, including damages for sham e, humiliation, mental anguish, an

emotional distress caused by the conduct of Defendant; and d) other general dam ages.


Governm ent Cod e §12940, et seq., Plaintiff has been forced to and w ill incur attorney's fees a

costs in the prosecution of this claim, in an amou nt to be proven at trial.

SIXTH CAUSE OF ACTION

U NLAW FU L ASSOCIATIONAL PREGNANCY DISCRIMINATION IN VIOLATION O

THE FAIR EMPLOYM ENT A ND HO SU ING AC T [Government Code §§ 12926 & 12940,seq.]]

(Against Defendants Fox Group , News Am erica Inc., 21st Century Fox A merica Inc., Fox



paragraphs 1 through 15, inclusive, as though fully set forth herein.

64. Defendan ts FOX and Does 1 through 100, and/or their agents/employees, are entiti

or individuals subject to suit under the California Fair Emp loyment and Housing Act, Gov. Cod e §

12926 and 12 940, et seq.

65. At all ma terial times, Plaintiff was a qu alified em ployee associated with a perso

namely his wife, who was pregnant as described herein or, alternatively, a person who

DEFE NDA NTS knew w as pregnant and/or had been pregnant.

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66. Plaintiff was at all times able to p erform the essential functions of his job.

67. DEF END ANT S, and each of them, knew of Plaintiff's wife's pregnancy.

68. Despite its knowledge of the foregoing, DEFE ND ANT S took adverse action againPlaintiff, including, but not limited to, demoting, suspending, providing both written and verb

warnings, failing to prom ote, decreasing job responsibilities, issuing poor performan ce review

decreasing pay, d enying benefits, disciplining, decreasing hours, and /or thereafter terminating his

employm ent because of his association with a person, nam ely his wife, who w as and/or had bee

pregnant.

69. In engaging in the foregoing conduct, Defendants FOX and Does 1 through 100

aided, abetted, incited, participated in, coerced and/or com pelled unlawful emp loyment practices iviolation of California's Fair Employmen t and Hou sing Act.

70. The foregoing conduct engaged in by Defendants FOX and Does 1 through 100, an


was carried on with a conscious and w illful disregard of Plaintiff's right to work in an environm en

free of discrimination based on his association with a person w ho was an d/or had been pregnant, s

as to entitle Plaintiff to punitive damages to punish and set an examp le of said DEFE NDA NTS.


Defend ants, Plaintiff has sustained and will continue to suffer in an am ount within the jurisdiction o

this Court, the exact amoun t to be proven at trial. Such dam ages include a) loss of salary and othe

valuable employment benefits; b) pre-judgment interest and interest on the sum of dam ages at the

legal rate; c) consequential dam ages, including damages for sham e, humiliation, mental anguish, an

emotional distress caused by the conduct of D efendant; and d) other general damages.


Governm ent Code §12940, et seq., Plaintiff has been forced to and w ill incur attorney's fees an

costs in the prosecution of this claim, in an amount to be proven at trial.

SEVENTH CAU SE OF ACTION

FAILURE TO TAKE ALL REASONABLE STEPS NECESSARY TO PREVENT

1 3COMPLAINT


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DISCRIMINATION AND/OR RETALIATION IN VIOLATION OF THE FA IR

EMPLO YMEN T AND HOU SING ACT [Government Code § 12940, et seq.]

(Against Defendants Fox G roup, News Am erica Inc., 21st Century Fo x America Inc., Fox

Entertainmen t Group, Inc. and DO ES 1 to 100, inclusive)

73. Plaintiff restates and incorporates by reference e ach a nd every allegation

contained in paragraphs 1 throug h 73, inclusive, as though fully set forth herein.

74. Defendants FOX and Does 1 through 100, and/or their agents/employees, failed to

take all reasonable steps necessary to preve nt discrimination and/or retaliation in employm

occurring. Further, said Defendants knew or should have known of the discrimination and/or

retaliation against Plaintiff described above, yet failed to condu ct an adequ ate, investigatio

nature and substance of the discrimination and/or retaliation, and failed to take immediate and

appropriate corrective action so as to discipline any of the offenders.

75. The response of Defendants FOX and Does 1 through 100, and/or their

agents/employees to that knowledge was so inadequate as to establish a deliberate indifferen

tacit authorization of, the alleged offensive practices, and an affirmative c ausal link existed

Defendants' inaction and action and th e injuries suffered by Plaintiff.

76. By failing to take all reasonable steps necessary to prevent discrimination and/or

retaliation, and by failing to properly investigate a nd reme dy the discrimina tion and/or re

that occurred, Defendants FOX and D oes 1 through 100 committed unlawful employment p

as described and prohibited in Governm ent Code §12940(k).

77. In engaging in the aforementioned conduct, DEFENDANTS, and each of them

aided, abetted, incited, compelled, and/or coerced unlawful employment practices in violati

announce d policy of this State against such practices.

78. As a direct and foreseeable result of the aforementioned acts and omissions o


jurisdiction of this Court, the exact amount to be proven at trial. Such damages include a) loss o

salary and other valuable em ployment benefits; b) pre-judgment interest and interest on th

damages at the legal rate; c) consequential damages, including damages for shame, humiliation

14COMPLAINT


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mental anguish, and emotional distress caused by the conduct of Defendant; and d) other gener

damages.

79. The above described acts of DEFENDANTS, by and through their managing agen

officers or directors, were engaged in w ith a d eliberate, cold, callous, fraudulent and intention

man ner in order to injure and dam age Plaintiff and/or with a conscious disregard of Plaintiff an

Plaintiff's rights. Such acts w ere despicable, and constitute malice, fraud and/or oppression with

the meaning of Civil Code §3294. Plaintiff requests an assessment of punitive damages agains

Defendants, in an amount to be proven at time of trial.

80. As a proximate result of the foregoing conduct, which violated the provisions o

Govern ment C ode §12940, et seq., Plaintiff has been forced to and w ill incur attorney's fees a

costs in the prosecution of this claim, in an am ount to be pr oven at trial.

EIGHTH CAUSE OF ACTION

WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY

(Against Defendants Fox Gro up, News A merica Inc., 21st Century Fo x Am erica Inc., Fox


81. Plaintiff restates and incorporates by reference each and every allegation contained

paragra phs 1 through 81, inclusive, as though fully set forth herein.

82. DEF END ANT S' termination of Plaintiff 's employment violates public policy as

forth in both state and federal laws, including Government Code § 12940, et seq., which prohib

discriminatory and retaliatory practices in the workplace.

83. The foregoing conduct engaged in by Defendants FOX and Does 1 through 100, a


was carried on w ith a conscious and willful disregard of Plaintiff's right to work in an en vironm e

free of discrimination and retaliation based on the (a) exercise of Plaintiff's rights to family care a

medical leave under the California Fam ily R ights Act, (b) exercise of Plaintiff 's reights to fam

care and m edical leave under the Fam ily Medical Leave Act, (c) association with a disabled perso

and (d) association with a p regnant person, so as to en title Plaintiff to punitive damag es to punis

15COMPLAINT


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and set an exam ple of said Defendants.


Defendants, Plaintiff has sustained and will continue to suffer in an am ount within the jurisdiction o

this Court, the exact amount to be p roven at trial. Such dama ges include (a) loss of salary and othe

valuable emp loyment ben efits; (b) pre-judgm ent interest and interest on the sum of da mage s at th

legal rate; (c) consequential damages, including dam ages for sham e, humiliation, mental anguish

and em otional distress caused by the conduct of D efendants; and (d) other general damages.

16COMPLAINT

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PRAYER FOR RELIEF

W HERE FOR E, Plaintiff Brian Jun prays judgment against the DEFEN DAN TS, and each of

them, as follows:

A. For general and special dam ages according to proof;

B. For loss of earnings and earning capacity and/or other econom ic damages, according

to proof;

C. For pre-judgment interest to the extent allowed by law ;

D. For punitive, exemplary, and/or liquidated damages in an amount to punish

Defenda nts or as otherwise allowed by law;

E. For attorney's fees in prosecuting this action (except on the E ighth Cause of A ction);

F. For perm anent injunctive relief to stop the illegal practices complained of above;

G. For costs of suit; and,

H. For such other and further relief as the C ourt deems just and proper.

DAT ED: March 4, 2015 espectfully Subm itted,YUN & SIMONIAN, PC

By:


17COMPLAINT


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10cp 1c • I

; 12R P Pi

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DEMAND FOR JU RY TRIAL

Plaintiff Brian Jun hereby demands trial by jury on all issues so triable in the Complaint.

DATED: March 4, 2015 espectfully Submitted,YU N & SIMONIAN, PC

By:


18COMPLAINT


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SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELESNOTICE OF CASE ASSIGNMENT - UNLIMITED CIVIL CASE (NON-CLASS ACTION)

Case Number

THIS FORM IS TO BE SERVED W ITH THE SUMMONS AND COM PLAINTfig. c k7 A 6 4 6our case is assigned for all pu rposes to the judicial officer indicated below . There is add itional information on the e si o hi form.ASSIGNED JU DGE DEPT ROOM ASSIGNED JU DGE DEPT ROOM

Hon. Kevin C. Brazile 1 534 Hon. Mitchell L. Beckloff 51 511

Hon. Barbara A. Meiers 12 636 Hon. Susan Bryant-Deason 52 510

. Hon. Terry A. Green 14 300 Hon. Steven J . Kleifield 53 513

Hon. Richard Fruin 15 307 Hon. Ernest M. Hiroshige 54 512

Hon. Rita Miller 16 306 Hon. Malcolm H. Mackey 55 515

Hon. Richard E. Rico 17 309 Hon. Michael Johnson 56 514

Hon. Stephanie Bowick 19 311 Hon Rolf M. Treu 58 516

Hon Dalila Corral Lyons 20 310 Hon. Michael L. Stern 62 600

Hon. Robert L. Hess 24 314 Hon. Mark Mooney 68 617

Hon. Yvette M. Palazuelos 28 318 Hon. W illiam F. Fahey 69 621

Hon. Barbara Scheper 30 400 Hon. Suzanne G. Bruguera

Hon. Samantha Jessner 31 407 Hon. Ruth Ann Kwan 731 4 2Hon. Mary H. Strobel 32 406 Hon. Rafael Ongkeko 73 733

Hon. M ichael P. Linfield 34 408 Hon. Teresa Sanchez-Gordon 74 735

Hon. Gregory Alarcon 36 410

Hon. Marc Marmaro 37 413

Hon. Maureen Duffy-Lewis 38 412 •

Hon. Elizabeth Feffer 39 415 .

Hon. Michelle R. R osenblatt 40 414

Hon. Holly E. Kendig 42 416

Hon. Mel Red Recana 45 529

Hon. Frederick C. Shaller 46 500 Hon. Em ilie H. Elias 324 CCW

Hon. Debre Katz W eintraub 47 507*Provisionally ComplexNon-Class Action Cases

Hon. Elizabeth Allen W hite 48 506Assignment is Pending

ComplexDetermination324 CCW

Hon. Deirdre Hill 49 509

Hon. John L. Segal 50 508

*ComplexAll non-class action cases designated as provislona ly complex are forwarded to the Supervising Judge of the Complex Litigation Program located in the Central CivilW est Courthouse (600 S. Commonwealth Ave., Los Angeles 90005), for complexInon-complex determination pursuant to Local Rule 3.3(k). This procedure is for thepurpose of assessing whether or not the case is complex within the meaning of California Rules of Court, rule 3.400. Depending on the outcome of that assessment, thcase may be reassigned to one of the judges of the Complex Litigation Program or reassigned randomly to a court in the Central District.Given to the Plaintiff/Cross-Complainant/Attorney of Record on SHERRI R. CARTER, Executive Officer/Clerk

By Deputy ClerkLACIV CC H 190 (Rev05/14) OTICE OF CASE ASSIGNMENT — age 1 of 2LASC Approved 05-06For Optional Use

NLIMITED CIVIL CASE


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INSTRUCTIONS FOR HANDLING U NLIMITED CIVIL CASES

The following critical provisions of the Chapter Three Rules, as applicable in the Central District, are summarized for your assistance.

APPLICATION

The Chapter Three Rules were effective January 1, 1994.* They apply to all general civil cases.

PRIORITY OVER OTHER RULES

The Chapter Three Rules shall have priority over all other Local Rules to the extent the others are inconsistent.

CHALLENGE TO ASSIGNED JUDGE

A challenge under Code of Civil Procedure section 170.6 must be made within 15 days after notice of assignment for all purposes toa judge, or if a party has not yet appeared, within 15 days of the first appearance.

TIME STANDARDS

Cases assigned to the Individual Calendaring Court will be subject to processing under the following time standards:

COMPLAINTS: All complaints shall -be served i thin 60 days of fi l ing and-proof of service. shall be fi led within 90 days o

CROSS-COMPLAINTS: Without leave of court first being obtained, no cross-complaint may be filed by any party after their

answer is filed. Cross-complaints shall be served within 30 days of the filing date and a proof of service filed within 60 days of tfiling date.

A Status Conference will be scheduled by the assigned Independent Calendar Judge no later than 270 days after the filing of thecomplaint. Counsel must be fully prepared to discuss the following issues: alternative dispute resolution, bifurcation, settlement,trial date, and expert witnesses.

FINAL STATUS CONFERENCE

The Court will require the parties at a status conference not more than 10 days before the trial to have timely filed and served allmotions in limine, bifurcation motions, statements of major evidentiary issues, dispositive motions, requested jury instructions, andspecial jury instructions and special jury verdicts. These matters may be heard and resolved at this conference. At least 5 daysbefore this conference, counsel must also have exchanged lists of exhibits and witnesses and have submitted to the court a brief

statement of the case to be read to the jury panel as required by Chapter Eight of the Los Angeles Superior Court Rules.

SANCTIONS

The court will impose appropriate sanctions for the failure or refusal to comply with Ch apter Three R ules, orders made byand time standards or deadlines established by the Court or by the Chapter Three Rules. Such sanctions may be on a party or ifappropriate on counsel for the party.

This is not a complete delineation of the Chapter Three Rules, and adherence only to the above provisions is thereforenot a guarantee against the imposition of sanctions under Trial Court Delay Reduction. Careful reading andcompliance with the actual Chapter Rules is absolutely-imperative.

LACIV CCH 19 0 (Rev05/14) OTICE OF CASE ASSIGNMENT — age 2 of LASC Approv ed 05-06For Opt ional Use NLIMITED CIVIL CASE


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Super ior Court o f Cal i forniaCoun ty o f Los Ange le s

Los Angeles-CountyBar Associa t ionMil:Odom Section .

Los Ange le s Coun ty. •Bar Assoda t ion Labor and

EmploymenitawBection

VOLUNTARY EFFICIENT LITIGATION STIPULATIONS

The Early Organ izat ional Meet ing St ipulat ion , Disco very

Reso lution Stipulation, and Mo tions in Limine Stipulation arevoluntary stipulations entered into by the p arties. The parties

may enter into one, two, or all three of the stipulations;

-however, they may not alter the stipulations as written,

becau se the Court W ants to ensure un iform ity of appl icat ion.

These stipulations are meant to. encourage cooperation

betw een the p ar t ies an d to ass i s t in reso lv ing i ssues in a

m anner that promotes-ecortom ic_cate resolution and judicialefficiency.

Consumer At torneysAssocia t ion of Los Angeles

• • • • - • •• •

Southern Cal i forniaDefense Counsel

1/...A1110

Associa t ion ofBusiness Tr ia l Lawyers

California Employment •Lawyers Associa t ion

LACIV 230 (NEW)LASC Approved 4-11For Optional Use

The following organizations endorse the goal of

promoting efficiency in litigation and ask that counsel

consider using these stipulations as a voluntary way to

ptumote com mu nica tions and p rocedures amon g counse l

and with the co urt to fairly resolve issues in their cases.

*Los Angeles County Bar Association Litigation Section*

• Los Angeles Coun ty Bar Association

Labor and Em ployment Law Section*

*Consumer Attorneys Association of Los Angeles*

*Southern' California Defense Counsel*

+Association of Business Trial Lawyers*

*California Employm ent Lawyers Association+


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Ftirserrod tar Clerk's no StampAME AND ADDRESS OF ATTORNEY OR PARTY WITHOUT ATTORNEY: TATE BAR NUMBER

TELEPHONE NO.:E-MAIL ADDRESS (Optional):

ATTORNEY FOR (Name):

FAX NO. (Optional):

SUPERIOR COURT OF CA LIFORNIA, COUNTY OF LOS ANG ELESCOURTHOUSE ADDRESS:

PLAINTIFF:

DEFENDANT:

CASE NUMBER:

STIPULATION — DISCOVERY RESO LUTION-

This stipulation is - intended to provide a fast and informal resolution of discovery issuesthrough limited paperwork and an informal conference with the Court to aid in theresolution of the issues.

The parties agree that:

1, Prior to the discovery cut-off in this action, no discovery m otion shall be filed or heard u nlessthe moving party first makes a written request for an Informal Discovery Conference pursuantto the terrris of this stipulation.

2. At the Informal D iscovery Conference theCourt will-consider the dispute Presented by partiesand determ ine whether it can be resolved inform ally. Nothing set forth herein will preclude aparty from m aking a record at the conclusion of an Inform al Discovery Conference, eitherorally or in writing.

3. Following a reasonable and good faith attempt at an inform al resolution of each issue to bepresented, a party may request an Informa l Discovery Conference pu rsuant to the followingprocedures:-

a. The party requesting the Informal D iscovery Conference will:

i. File a Request for Informal D iscovery Conferen ce with the clerk's office on theapprov ed form (copy 'attached) and deliver a courtesy, Conform ed copy to theassigned department; •

ii. Include a brief summary of the dispute and specify the relief requested; and

• i i i . erve the opposing party pursuant to any authorized or agreed method of servicethat ensures that the opposing pa rty receives the Request for Informal D iscoveryConference no later than the next court day following the filing.

b. Any Answ er to a Request for Informal Discovery Conference must:

i. Also be filed on the approved form (copy attached);

ii. Include a brief summary of why the requested relief should be'denied;LACIV 036 (new)LASC Approved 04/11For Optional Use

STIPU LATION — DISCOVERY RESOLU TIONPegs 1 of 3


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SHORT TITLE, CASE NUMBER:

iii. e fi led w ithin two (2) court days of receipt of the Reque st; and

• v. e served on the opposing party pursuant to any authorized or agreed uponm ethod of se rv ice tha t ensures tha t the oppos ing par ty rece ives the Answ er nolater than the next co urt day follow ing the filing.

c. No other p leadings, including bu t not l im ited to exhibits, declarations, or attachm ents, willbe accepted.

d. I fthe Cour t has no t g ran ted or den ied the R eque s t fo r In form al Discov ery Conference :within ten (10) days fol lowing the f i ling of the Reque st , then i t shal l be de em ed to hav ebeen den ied . I f the Cour t ac t s on the Requ es t , the p ar t ies w i ll be no t if ied w hether theReque st for Informa l Discove ry Conference has b een granted o r denied-and, if granted,the date and t im e of the Informal Discovery Conference, which m ust be w i thin twenty (20)days o f the-fi ling of the Req uest for Informal Discovery Co nference.

e. if the conference is not held Within twenty (20) days of the filing of the Request forIn form al Discovery Con ference , un less ex tended by ag reemen t o f the par t i es and theCourt , then the Req uest for the Informal Discovery Conference -shal l be dee m ed to havebeen d enied a t that time.

4. If (a) the Cou rt has denied a co nference o r (b) one o f the t ime d eadl ines abo ve ha s expiredwithout the Cou rt having acted or (c) the Informal Discovery Conference is con cluded w ithoutresolving the dispute, then a pa rty may fi le a discovery m otion to address un resolved issues.

5. The parties hereby further agree that the time for making a motion to compel or otherdiscov ery 'mot ion i s to l led f rom the da te o f f i ling of the Req ues t fo r In form al Discovery

Conference u nt i l (a) the requ est i s denied or de em ed de nied or (b) twenty (20) days af ter thefiling of the Requ est for Inform al Discovery Conference, wh ichever is earlier, unless extendedby Order of the Cou rt .

I t is the unde rs tanding and intent of the p ar t ies that th is s t ipula t iorrshal l, for each discoverydispute to w hich i t appl ies , const i tu te a w rit ing m em oria lizing a "specif ic la ter date to w hichthe propounding [or dem anding or request ing] par ty and the responding par ty have agreed inwri t ing," w i thin the m eaning of Co de C ivil Procedure sect ions 2030:300(c) , 2031.320(c), and2033.290(c).

6. Nothing herein wi l l preclude any par ty f rom applyingex par te for approp riate relief, includingan order shortening t ime for a m otion to be heard con cerning discovery.

7. Any pa r ty may terminate this s t ipulat ion by g iving twenty-one (21) days not ice of intent toterminate the stipulation.

8. References to "days" m ean calendar days , unless o therwise noted. If the date for performingany act pu rsuant to this st ipulation falls on a Saturday, Sund ay or Court holiday, then the t imefor performing that act Shall be extended to the next Cou rt day.

' LACIV 036 (new)' LASC Approved 04/11

For Optional Use-

STIPULATION — DISCOVERY RESOLUTIONPage 2 of 3


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NAME AND ADDRESS OF ATTORNEY OR PARTY VOTTROUT ATTORNEY:

TELEPHONE NO.: AX NO. (Optional):

E-MAIL ADDRESS (Optional):ATTORNEY FOR (Name ):

STATE BAR NUMBER Reserved for Clerieo He Siornp

•

•

SUPERIOR COU RT OF CALIFORNIA, COUNTY OF LOS A NGELESCOURTHOUSE ADDRESS:

._PLAINTIFF:

DEFENDANT:

.

STIPULATION— EARLY ORG ANIZATIONAL M EETINGC A S E N U M B E R :

This stipulationi s in t ended to enco urage cooPe ra t ion_am ong the p a r t ie s a t an ea r ly s t ags in

the l i tigat ion and to ass is t_ th e pa r t ies ineff ic ient cas e resolut ion.The parties agree that:

1. The parties commit to conduct, an initial conference (in-person or via teleconference or viavideocon ference) within 15 days from the date this st ipulat ion is signed,to d iseuss an d cons iderwhether there can be ag reement on the fo l lowing:

a. Are motions to challenge the pleadings necessary?- If the issue can be resolved byamendment as of right, or if the Court would allow leave to amend, could an amendedcom plaint resolve mos t or al l of the issues a d em urrer might otherwise raise? If so, the part iesagree to work through pleading i ssues so tha t a demurrer need only ra ise i ssues they cannotresolve. Is the issue that the defendant seeks to raise am enable to resolution on d em urrer, or

wo uld som e o the r type o f m ot ion b e p re fe rab le? Cou ld a vo lun ta ry t a rge ted exchang e o fdocum ents or informa tion by any party cure an unce rtainty in the pleadings?

b. Ini tia l m utual excha nge s of docu m ents a t the "core" of the li t igat ion. (For exam ple , in anem ployment case , the em ployment r ecords , pe r sonne l fi le and docum ents r e la t ing to thecond uct in quest ion could be co nsidered "co re ." In a person al in jury case , an incident orpolice report, medical records, and repair or maintenance records could be considered"core.");

c. Exchange of nam es and contac t informat ion of w i tnesses ;

d. Any insurance agreement that may be available to satisfy part or all of a judgment, or toindemn ify or reimb urse for paym ents mad e to sat isfy a judgm ent;

e. Exchan ge of any other informa tion that m igh

Brian Jun

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