Kelee Williams v. Robert Half International, Inc.

CourtDistrict Court, N.D. California
DecidedJanuary 31, 2023
Docket4:20-cv-03989
StatusUnknown

This text of Kelee Williams v. Robert Half International, Inc. (Kelee Williams v. Robert Half International, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kelee Williams v. Robert Half International, Inc., (N.D. Cal. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 KELEE WILLIAMS, Case No. 20-cv-03989-KAW

8 Plaintiff, PRETRIAL CONFERENCE 9 v. TENTATIVE RULINGS

10 ROBERT HALF INTERNATIONAL INC., Defendant. 11

12 13 I. MOTIONS IN LIMINE 14 Relevant evidence is any evidence that has any tendency to make a fact that is of 15 consequence to the determination of the action more or less probable than it would be without the 16 evidence. Fed. R. Evid. 401. The Court has discretion to “exclude relevant evidence if its 17 probative value is substantially outweighed by a danger of . . . unfair prejudice, confusing the 18 issue, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative 19 evidence.” 20 21 MIL Motion Ruling Reason/Explanation 22 Exclude fax from Ms. Plaintiff may introduce the fax into 23 Williams’ counselor, evidence to demonstrate that Plaintiff’s D1 Kathleen Alberts, to DENY therapist had submitted the form to 24 Broadspire dated show pretext. October 1, 2020 25 Exclude evidence of 26 actions by the Illinois The IDES Determination Letter may not 27 D2 Department of GRANT be used as evidence in this proceeding. Employment Security 820 Ill. Comp. Stat. 405/1900. 1 Defendant’s request is overbroad. Exclude evidence of Although Defendant characterizes these 2 communications communications between Plaintiff and a between Ms. Williams third-party as irrelevant, Plaintiff’s 3 D3 and RHI’s third party DENY allegations of Defendant’s improper 4 administrator, interference with her benefits request Broadspire make the communications relevant to 5 the remaining retaliation claims. 6 Discriminatory conduct occurring prior to the limitations period may be 7 considered as part of the continuing Exclude evidence of violations doctrine in support of a 8 whether RHI paid Ms. hostile work environment claim. Williams less than men 9 Plaintiff nowhere argues that differential D4 for similar work or GRANT pay amounted to harassing conduct, nor RHI’s compensation to 10 does she show that differential pay is a its employees prior to relevant consideration to the hostile 11 August 18, 2019 work environment assessment. 12 Evidence of differential pay prior to the limitations period is thus irrelevant. 13 The harassment of other women by 14 Plaintiff’s former direct supervisor is “relevant and probative” of the 15 supervisor’s hostility toward women. Exclude evidence of Heyne v. Caruso, 69 F.3d 1475, 1480– 16 D5 the reasons why Chris DENY 81 (9th Cir. 1995). Plaintiff’s admission Brinkman left RHI 17 that Brinkman did not harass her does not preclude consideration of his 18 maltreatment of other women in the Court’s hostile environment assessment. 19 The email correspondence does not 20 constitute confidential settlement 21 communications under Rule 408(a). Defendant’s counsel does not exhibit an 22 offer of valuable consideration in Exclude evidence of compromising or attempting to 23 settlement compromise the claim. Fed. R. Evid. communications 24 D6 between counsel Ellen DENY 408 (a)(1). Defense counsel emailed Plaintiff’s counsel “out of courtesy” Bronchetti and Seth 25 Rafkin (Bronchetti Decl., Ex. 5), not “during compromise negotiations about the 26 claim.” Fed. R. Evid. 408(a)(2). The Court does not rule, at this stage, on the 27 authentication of the email 1 This category of evidence is overbroad. Exclude evidence of But more importantly, Plaintiff still has 2 D7 alleged non-gender- DENY claims for retaliation which need not based bullying necessarily rely on gender-based 3 bullying. 4 Regarding the Scope of This is an improper motion in limine 5 D8 the Parties’ Non- DENY that requires the Court to interpret a Compete Provision contractual provision in a vacuum. 6 This evidence, in contrast to the 7 evidence excluded under Motion in Exclude evidence of Limine No. 4, is relevant to a remaining 8 Ms. Williams’ Verbal D9 Complaints as Not DENY claim. The evidence of Plaintiff’s 9 Protected Activities complaints, even verbal complaints, is relevant to her cause of action for 10 retaliation. 11 Plaintiff does not meaningfully argue that the failure to provide a mentor 12 demonstrates an adverse action, and that 13 category of evidence is accordingly Exclude evidence of excluded. Evidence of Plaintiff’s 14 being excluded from GRANT IN exclusion from meetings may be D10 meetings and not being PART, DENY introduced as an adverse action. 15 provided a mentor as IN PART Strother v. S. Cal. Permanente Med. adverse actions Group, 79 F.3d 859, 869 (9th Cir.1996) 16 (exclusion from meetings and seminars 17 that would have made plaintiff eligible for salary increases qualifies as adverse 18 employment action). 19 20 II. EVIDENTIARY ISSUES 21 A. Plaintiff’s Objections 22 23 Witness/Evidence Ruling Reason/Explanation 24 Abbey was not timely disclosed, and Defendant 25 Dawn Abbey SUSTAIN does not directly respond to Plaintiff’s objection to her testimony. 26 Andreesen was not timely disclosed, and 27 Tom Andreesen SUSTAIN Defendant does not establish that his testimony 1 Witness/Evidence Ruling Reason/Explanation 2 Cohoon was not timely disclosed, and 3 Gianne Cohoon SUSTAIN Defendant does not directly respond to Plaintiff’s objection to her testimony. 4 Daley was not timely disclosed, and Defendant 5 Kerry Daley SUSTAIN does not establish that her testimony will not result in prejudice. 6 Lampo was not timely disclosed, and Defendant 7 Kim Lampo SUSTAIN does not directly respond to Plaintiff’s objection 8 to her testimony. 9 Linotakis was not timely disclosed, and Fran Liontakis SUSTAIN Defendant does not directly respond to 10 Plaintiff’s objection to her testimony. 11 Tanaka George was not timely disclosed as a witness, Defendant does not establish that her 12 Colleen Tanaka George SUSTAIN testimony will not result in prejudice. 13 Additionally, her intended testimony appears redundant. 14 Though disclosed late, the identification of 15 Tinajero can hardly be surprising to Plaintiff. It appears Plaintiff was aware of Broadspire’s 16 Martha Tinajero OVERRULE relevance, particularly where Plaintiff 17 subpoenaed materials from Broadspire in April 2021 and Plaintiff’s counsel interacted with 18 Tinajero. See Dkt. 150-2 at 86. 19 Price was not timely disclosed. Although Defendant intends to ask only that he 20 authenticate certain documents, which might Todd Price SUSTAIN 21 not result in prejudice to Plaintiff, those documents were also disclosed well after the 22 close of discovery. 23 Rife was not timely disclosed, and Defendant Leslie Rife SUSTAIN does not establish that her testimony will not 24 result in prejudice. 25 Sweet was not timely disclosed, and Defendant 26 Stephanie Sweet SUSTAIN does not establish that her testimony will not result in prejudice. 27 1 Witness/Evidence Ruling Reason/Explanation 2 will not result in prejudice. 3 Thompson was not timely disclosed, and 4 Jill Thompson SUSTAIN Defendant does not establish that her testimony will not result in prejudice. 5 6 Plaintiff objects for lack of relevance, but the qualifications of other candidates for the 7 position she was denied are relevant to Exhibit A-28–32, 36–42 Defendant’s legitimate business reasons 8 (Applications for MBS – OVERRULE defense. The Court does not yet rule on the VP position) exhibits’ foundations and authenticity. 9 Disclosure of documents late within discovery 10 period (as opposed to after close of discovery) does not render disclosure untimely. 11 Exhibit A-98–100 12 (Personnel files of other Documents were not produced until December SUSTAIN applicants to MBS – VP 13, 2022, well after the close of discovery.

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Related

United States v. Cordero
18 F.3d 1248 (Fifth Circuit, 1994)
Heyne v. Caruso
69 F.3d 1475 (Ninth Circuit, 1995)

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Bluebook (online)
Kelee Williams v. Robert Half International, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/kelee-williams-v-robert-half-international-inc-cand-2023.