1   RIVERA & TSOU, APC
    Lena Tsou (SBN 318842)
2   4100 Newport Place, Suite 600
    Newport Beach, California 92660
3   Attorneys for Defendant
    CORALINE HOME HEALTH, INC.
4
5
6                        SUPERIOR COURT OF THE STATE OF CALIFORNIA
7                               FOR THE COUNTY OF ORANGE
8
9   JORDAN MARLOWE,                               Case No. 30-2026-01398812
10                Plaintiff,
                                                  DEFENDANT CORALINE HOME HEALTH, INC.'S
11       v.                                       RESPONSES TO PLAINTIFF'S SPECIAL
                                                  INTERROGATORIES, SET ONE
12  CORALINE HOME HEALTH, INC.; and DOES 1
    through 25,
13                Defendants.
14
15  PROPOUNDING PARTY:   Plaintiff JORDAN MARLOWE
16  RESPONDING PARTY:    Defendant CORALINE HOME HEALTH, INC.
17  SET NO.:             One
18
19                              PRELIMINARY STATEMENT
20       Responding Party has not completed its investigation of the facts relating to this case and
21  reserves the right to amend these responses. These responses are made without prejudice to
22  Responding Party's right to rely on subsequently discovered information.
23
24  SPECIAL INTERROGATORY NO. 1:
25       State the name and job title of each person who participated in the decision to terminate
26  Plaintiff's employment.
27  RESPONSE TO SPECIAL INTERROGATORY NO. 1:
28       Responding Party objects to this interrogatory as vague, ambiguous and overbroad.
1   Subject to and without waiving these objections, Responding Party responds as follows:
2   Hannah Ruiz, Regional Director of Clinical Operations; and Victor Adeyemi, Human Resources
3   Manager.
4
5   SPECIAL INTERROGATORY NO. 2:
6        State all facts supporting your contention, in your Third Affirmative Defense, that Plaintiff
7   was terminated for poor performance.
8   RESPONSE TO SPECIAL INTERROGATORY NO. 2:
9        Plaintiff's performance was poor, as reflected in Plaintiff's personnel file.
10
11  SPECIAL INTERROGATORY NO. 3:
12       Identify each written performance evaluation of Plaintiff from 2022 to the date of termination.
13  RESPONSE TO SPECIAL INTERROGATORY NO. 3:
14       Pursuant to Code of Civil Procedure section 2030.230, Responding Party refers Plaintiff to
15  the performance evaluations produced as CORALINE 000112 through CORALINE 000131, which are
16  the written evaluations of Plaintiff dated March 2022, March 2023, March 2024 and March 2025.
17
18  SPECIAL INTERROGATORY NO. 4:
19       State the number of complaints of disability discrimination made by employees of your
20  Orange County branch from January 1, 2021 to the present.
21  RESPONSE TO SPECIAL INTERROGATORY NO. 4:
22       Responding Party objects to this interrogatory as overly broad, unduly burdensome, and
23  invasive of the privacy rights of third parties.
24
25  SPECIAL INTERROGATORY NO. 5:
26       State the date on which you first learned that Plaintiff had requested a medical leave.
27  RESPONSE TO SPECIAL INTERROGATORY NO. 5:
28       Responding Party will supplement this response.
1
2   SPECIAL INTERROGATORY NO. 6:
3        Identify every person who reviewed Plaintiff's request for accommodation made on or about
4   August 12, 2025.
5   RESPONSE TO SPECIAL INTERROGATORY NO. 6:
6        Responding Party objects to this interrogatory to the extent it seeks information protected
7   by the attorney-client privilege and the attorney work product doctrine. Subject to and without
8   waiving these objections, Responding Party responds: Victor Adeyemi and Hannah Ruiz reviewed
9   the request. Responding Party's outside counsel was also consulted.
10
11  SPECIAL INTERROGATORY NO. 7:
12       State Plaintiff's rate of pay on the date of termination.
13  RESPONSE TO SPECIAL INTERROGATORY NO. 7:
14       $41.25 per hour.
15
16  SPECIAL INTERROGATORY NO. 8:
17       Identify all documents that support your contention that Plaintiff's position was eliminated
18  as part of a reorganization.
19  RESPONSE TO SPECIAL INTERROGATORY NO. 8:
20       Responding Party objects to this interrogatory on the ground that it calls for a legal
21  conclusion. Responding Party further objects that the interrogatory is not reasonably calculated
22  to lead to the discovery of admissible evidence. See documents produced.
23
24  Dated: April 20, 2026                    RIVERA & TSOU, APC
25
26                                           By: /s/ Lena Tsou
27                                               Lena Tsou
28                                           Attorneys for Defendant CORALINE HOME HEALTH, INC.
1
2                                  PROOF OF SERVICE
3        I am employed in the County of Orange, State of California. On April 20, 2026, I served the
4   foregoing DEFENDANT CORALINE HOME HEALTH, INC.'S RESPONSES TO PLAINTIFF'S SPECIAL
5   INTERROGATORIES, SET ONE on counsel for Plaintiff by placing a true copy in a sealed envelope
6   with postage fully prepaid in the United States mail at Newport Beach, California.
7        I declare under penalty of perjury under the laws of the State of California that the
8   foregoing is true and correct. Executed on April 20, 2026.
9                                            /s/ Ana Lucero
