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CMCP Diversity Matters Summer 2015 Newsletter


Summer 2015 1

CMCP Diversity Matters

2015 eNewsletter Committee Members


Tambry L. Bradford (Co-Chair) Special Counsel Pepper Hamilton LLP

Cassandra Mougin (Co-Chair) Shareholder Pettit Kohn Ingrassia & Lutz, PC

Michael Chung Of Counsel Willenken Wilson Loh & Delgado LLP

Karen A. Henry Counsel Davis Wright Tremaine LLP

Noah Perez-Silverman Associate Caldwell Leslie & Proctor, PC

Kelly Perigoe Associate Caldwell Leslie & Proctor, PC

David Shimkin Member Cozen O’Connor

Jonathan M. Turner Partner Epstein Turner Weiss

Summer 2015 Newsletter

Table of Contents page 3

Meet Your New CMCP Board Members – Attorney Spotlights Series Spotlight: Camilo Echavarria

page 4

A Tale Of Two Public Entities: What Employers Can Learn About The Feha Accommodation Process

page 7

Business Development Series: Is it Time for a Mid-Year Correction?

page 9

125 Years Later, CA Supreme Court Grants Membership Posthumously to First Chinese-American Lawyer

page 11

Women@the Table Panel 1: “Hit or Miss? Women Lawyers’ Litigation and Trial Strategies”

page 14

Trend to Limit ADA and FEHA Definitions of Disability Attributed to Behavioral Disorders Affecting Work Relations?

page 15

Diversity Calendar Mark Your Calendars for Upcoming Diversity Events


CMCP Diversity Matters



CAMILO ECHAVARRIA – Partner, Davis Wright Tremaine LLP By: Karen A. Henry, Counsel, Davis Wright Tremaine LLP

In this short interview, CMCP eNewsletter Committee Member Karen A. Henry of Davis Wright Tremaine, introduces the CMCP membership to one of the new members of CMCP’s Board of Directors: Camilo Echavarria, a partner at Davis Wright Tremaine LLP.

This video will open a new webpage.

Karen Henry is an attorney in Davis Wright Tremaine LLP’s Los Angeles office. She maintains a broad and diverse practice, focusing primarily on media, IP, and entertainment law. For more info about Karen, click here.


Summer 2015 Newsletter

A Tale Of Two Public Entities:

What Employers Can Learn About The FEHA Accommodation Process By: Andrew I. Chung, Associate, Pettit Kohn Ingrassia & Lutz, PC

Finding the right accommodation

for a disabled employee can be a difficult task under the Fair Employment and Housing Act (“FEHA”). An employer’s accommodation obligations are broad, and litigation can ensue when there is a breakdown in the accommodation process. Two recent appellate decisions involving public entities, however, provide employers with guidance on how to better approach an employee’s request for accommodation.

Where The Employer’s Accommodation Efforts Fall Short In Swanson v. Morongo Unified School District (2014) 232 Cal. App.4th 954, as modified on denial of reh’g (Dec. 23, 2014), a teacher sued a public school district (“District”) alleging that her employment contract was not renewed because of her breast cancer and related medical leaves.

After the Plaintiff-teacher was diagnosed with cancer, the District afforded her a prolonged leave of absence to care for her condition. Upon her return from leave, the District and Plaintiff discussed an appropriate classroom assignment. The District recommended an assignment to a 5th grade class, while Plaintiff requested to teach the 2nd grade because she had taught that level before and was familiar with the curriculum.


CMCP Diversity Matters Plaintiff expressed that she was concerned that her cancer treatments would inhibit her ability to prepare and plan lessons for a new assignment. The District ultimately assigned Plaintiff to teach kindergarten. After another short medical leave and return to work, the District evaluated Plaintiff’s in-class instruction as part of its annual review of all teachers. Plaintiff’s performance was rated poor, and her contract was not renewed because of the unfavorable evaluation. Plaintiff sued the District under FEHA, alleging that the District discriminated against and failed to accommodate her. Relying on Raine v. City of Burbank (2006) 135 Cal.App.4th 1215, 1222–1223, the trial court held that the District’s accommodation efforts were sufficient because the District had no obligation to choose either the best accommodation for Plaintiff or the specific accommodation that she sought. The Fourth Appellate District disagreed, however, holding that the law imposes an affirmative duty on employers to reassign a disabled employee to an already funded, vacant position at the same level. Swanson, supra, 232 Cal. App.4th at p. 970 (citing Spitzer v. The Good Guys, Inc. (2000) 80 Cal.App.4th 1376, 1389). The Court found it significant that the 2nd grade position that Plaintiff requested was vacant at the time of her request. Moreover, the


Court held that the District should have afforded Plaintiff preferential consideration when considering her request to teach the 2nd grade. Swanson, supra, 232 Cal. App.4th at p. 970 (citing Jensen v. Wells Fargo Bank (2000) 85 Cal. App.4th 245, 265).

Where The Employer’s Accommodation Efforts Are Sufficient Contrary to the result in Swanson, the Second Appellate District affirmed summary judgment for an employer in Nealy v. City of Santa Monica (2015) 234 Cal. App.4th 359. Similar to Swanson, Nealy involved a lawsuit where the plaintiff alleged disability discrimination and failure to accommodate. The employee in Nealy worked for the City of Santa Monica (“City”) as a solid waste equipment operator. After he endured an on-the-job knee injury, Plaintiff underwent multiple periods of disability and leaves of absence. Initially, the City reassigned Plaintiff to a groundskeeper position as an accommodation. After a second industrial injury, Plaintiff was returned to work on “light duty,” which restricted him from several physical activities, including kneeling and heavy lifting. Pursuant to his restrictions, Plaintiff requested that the City return him to the solid waste equipment operator position

with modifications to the job. The City conducted several meetings with Plaintiff and hired a disability consulting firm to determine whether Plaintiff could perform the essential functions of that role. The City concluded that Plaintiff’s restrictions precluded him from performing that job without eliminating certain essential functions. After initially[?] declining to do so [slightly unclear as to what the City declined to do], the City considered reassigning Plaintiff to a lateral, vacant position. Plaintiff could not be reassigned, however, because he was not qualified for the lone lateral position that was available. Unable to find an accommodation for Plaintiff, the District effectively separated Plaintiff’s employment. The Second Appellate District concluded that the City’s actions were lawful. Notably, the Court rejected Plaintiff’s argument that the City could have restructured his former position so that he would not have to kneel or lift heavy objects. Because kneeling and lifting heavy objects were essential functions of the job, the City was not required to eliminate those functions as an accommodation. Id. at p. 359. As to reassignment, the Court held that the law does not require employers to provide an indefinite leave of absence to await possible future vacancies. Id.

Summer 2015 Newsletter

The Takeaway From Swanson And Nealy The employers in Swanson and Nealy both denied the accommodation sought by the employee, but the respective courts notably reached opposite conclusions on their accommodation efforts. Although the District’s accommodation efforts in Swanson were not necessarily poor, summary judgment could not be affirmed in that case because the District did not have a viable reason for denying the teacher’s request for a 2nd grade assignment. That assignment was vacant and available, and the District did not give sufficient consideration to the teacher’s medical concerns.

By contrast, the City in Nealy had a well-reasoned basis to deny its employee’s reassignment request. The City hired a disability consulting firm to evaluate the employee’s essential job functions, communicated with the employee on multiple occasions to discuss the employee’s restrictions, and explored all lateral vacancies before deciding that the employee was not qualified for any vacant positions. Employers who are contemplating an accommodation request should be mindful of the results in Swanson and Nealy. At a minimum, employers should (1) carefully evaluate the employee’s essential job functions in view of any work restrictions, and (2) communicate with the employee

about the accommodations that are being explored and the alternatives available to the employee. It is important that employers afford their employees an opportunity to actively participate in the accommodation process. Employers should also consult with a medical professional or a disability consultant where feasible to find accommodations that are compatible with an employee’s work restrictions and limitations. Although a perfect accommodation may not exist, closely mirroring the employer’s actions in Nealy will put employers in a better position to accommodate employees with disabilities and avoid litigation.

Andrew I. Chung is an Associate at Pettit Kohn Ingrassia & Lutz PC in Los Angeles. He can be reached at achung@pettitkohn.com or (310)-417-1147. For more info about Andrew, click here.


CMCP Diversity Matters

Business Development Series:

Is it Time for a Mid-Year Correction? By: Martha Sullivan, Principal, Thornton Marketing

Somehow, the year is half over. Have you completed

50% of the business development tasks you planned on for 2015? Or have you been focused only on billable hours? If you are like most of my coaching clients, you probably have a long list of calls you meant to make, meetings you need to schedule and events you should attend. Some people might call this a “time management” issue, but more often, I find that my clients don’t take action because they don’t feel confident about the outcome. They compare themselves to the rainmakers they know and are sure that other lawyers have biz dev figured out, or that the process is simply easier for others. I can assure you that it’s not easier. The difference is that rainmakers have a biz dev plan in place, and they are committed to taking action. If you read my last CMCP blawg, you may remember that one of the most effective ways to increase your confidence is by taking action. In April, when I wrote about the book “The Confidence Code,” I didn’t realize that it would be an important part of the conversation at the third annual “From


Having it All to Leaning In” event sponsored by the Santa Clara County Bar Association on June 10. The attendees were encouraged to read the book before the event. I was a co-presenter for the rainmaking session with Heidi Keefe, a partner at Cooley. Heidi and I discussed ways to engage in business development and she shared stories of her own success at landing clients because she maintained long-term relationships with a large network of contacts. She also talked about the importance of being herself and she encouraged the attendees to be authentic. In the words of Oscar Wilde, “Be yourself. Everyone else is already taken.”

Taking Action As I said above, confidence is about taking action. By a fortuitous coincidence, biz dev is also about taking action. More accurately, it’s about taking many actions every year over the course of your career and being diligent about following up with your contacts. Perhaps you can keep these tasks in your head, but

Summer 2015 Newsletter

my coaching clients have found that it’s easier and more effective to capture them in a written marketing plan. (Yes, I know I keep saying that you have to have a plan. Trust me. I’m right about this). You might be thinking that the summer months are a bad time for biz dev because so many people are on vacation. Let’s be realistic. Not everyone will be taking vacation, and those that do will probably only be gone for two weeks. Even if you can’t schedule all the meetings you want to have right now, you can start setting up your September calendar, and start planning the rest of this year. It is not too soon to add the CMCP Annual Business Conference to your calendar (Oct. 22-23 in Los Angeles). If you have attended previous conferences, you already know that this is one of the best networking opportunities you will have all year.

Committing to Your Plan If you are ready to get started and need a framework for your biz dev plans, email me (marthasullivan@ earthlink.net) and I will send you the Personal Marketing Plan template that my coaching clients use. Some sections may not be relevant to your practice. Focus on the ones that make sense for you, and commit to completing at least one biz dev task every week. If you develop a weekly habit, you will quickly realize that every month of the year is a great time to be engaged in your biz dev practice. And a year from now, you will be far more confident about your ability to generate business.

Martha Sullivan is Principal of Thornton Marketing in San Rafael, CA. marthasullivan@earthlink.net; 415.472.7126; www.thorntonmarketing.com


CMCP Diversity Matters

125 Years Later, CA Supreme Court Grants Membership Posthumously to First Chinese-American Lawyer By: Michael Chung, Of Counsel, Willenken Wilson Loh & Delgado LLP

On March 16, 2015, the California

Supreme Court corrected an 1890 decision that denied Hong Yen Chang admission to the California State Bar because of his Chinese heritage. It took a team composed of Chang’s descendants and law students from the University of California, Davis School of Law to finally get the Court to admit Chang to the Bar. In a nine-page opinion the Court noted: “Even if we cannot undo history, we can acknowledge it and, in so doing, accord a full measure of recognition to Chang’s pathbreaking efforts to become the first lawyer of Chinese descent in the United States.” In re Hong Yen Chang on Admission, California Supreme Court Case Number S223736 at 8.


Chang was born in China and moved to the U.S. in 1872 as part of a Chinese government-sponsored program to teach Chinese youth about Western culture. He attended schools on the East Coast—graduating from Phillips Academy, Yale University and Columbia Law School. When Chang moved to California in 1890, he had already been admitted to the New York Bar two years earlier. In doing so, he became the country’s first Chinese-American attorney. Chang’s journey to gain admission in New York was not without difficulties, however. New York’s highest court first denied Chang admission because he was not a citizen, but later admitted him after

a New York judge issued Chang a certificate of naturalization. Yet, in spite of this fact, the California Supreme Court rejected Chang’s application because it did not consider Chang a citizen. It held that the certificate of naturalization issued in New York was void because the federal Chinese Exclusion Act prohibited courts from issuing certificates of naturalization to any native of China and it being conceded that Chang was a “person of Mongolian nativity.” It would not be until March 26, 1923, when You Chung Hong was admitted to the Bar, that California would allow Chinese-Americans to practice law in this state.

Summer 2015 Newsletter

Photo: Courtesy of Wikimedia

“A candid reckoning with a sordid chapter of our state and national history.” In overturning the 1890 decision, the California Supreme Court recounted California’s sad but pivotal role in persuading Congress to pass the Chinese Exclusion Act and how racism against Chinese immigrants formed the foundation for the California Constitutional Convention of 1879. The 1879

Constitution denied those with Chinese ancestry the right to vote along with any “idiot, insane person, or person convicted” of various crimes and directed the Legislature to discourage Chinese “immigration by all means within its power.” Given this historical background, the Court concluded that “the discriminatory exclusion of Chang from the State Bar of California was a grievous wrong” and that Chang had been denied the equal protection of the laws. Id. at 8.

Although Chang was unable to practice law in California and serve the Chinese community in San Francisco as he originally planned, he had a successful career in banking, academics and diplomacy. Nonetheless, Chang’s posthumous admission is bittersweet when considering the contributions he could have made to the legal community in California had he been afforded the privileges he had duly earned.

Michael Chung, Of Counsel, Willenken Wilson Loh & Delgado LLP. He can be reach at michaelchung@willenken.com or 213-694-3697.


CMCP Diversity Matters

Women@theTable Panel:

“Hit or Miss? Women Lawyers’ Litigation and Trial Strategies” Featuring Hon. Holly Fujie, Hon. Rex Heeseman, and Hon. Teresa Sanchez-Gordon By: Jennifer Weidinger, Associate, Pettit Kohn Ingrassia & Lutz, PC

On May 6, 2015, CMCP member law firm Lim, Ruger

& Kim LLP hosted the first of a three-panel seriesl intended to explore women in the law. The panel discussed effective advocacy and strategies to curtail bias in the courtroom. The moderators asked speakers to elaborate on personal experiences, provide insights, suggestions, and approaches for women lawyers, and address questions from the audience. The first panel featured Hon. Holly Fujie, Hon. Rex Heeseman (Ret.), and Hon. Teresa Sanchez-Gordon, and was moderated by Lisa Yang and George Busu of Lim, Ruger & Kim LLP.

Women in litigation and trial. Hon. Heeseman noted that in 1971 the average law school classroom was comprised of approximately 7% women. Now in 2015, that number is almost up to 50%. What a difference 45 years makes and the judges acknowledged the accomplishments women have made in litigation and trial practice during that time, from increasing numbers of women partners and trial lawyers, to the number of women appointed to the bench. Women have successfully earned their positions at the “table,” yet biases, whether obvious or not, still exist in the profession.


Have judges observed gender inequities in the courtroom? All three panelists concurred most lawyers (both male and female) attempt to present their most professional self to the judges in open court. However there are instances where tactics range from mere puffery to intimidation and even bullying. The best remedy in these situations is to rise above the fray, and regardless of experience, age, or gender, focus in on the potency of the factual or legal argument. Hon. Fujie emphasized the importance of using one’s own strengths to overcome intimidation tactics. A lawyer may be soft spoken, yet present a cogent analysis of a case that will leave her opponent without a counter argument. She need not even raise her voice to become the clear victor in the eyes of the court.

Summer 2015 Newsletter

would not let this intimidate them, it can derail even an experienced attorney. Intimidation tactics are best countered by attorneys who direct their energy to the legal arguments or cross examination, those who swiftly redirect attention to their own points, and seamlessly recapture the interest of the judge and jury.

The judges remarked that some male attorneys tend to believe they are more prepared than they actually are at trial, while female attorneys will believe they are not prepared enough, thus downplaying their strengths. The judges have observed women defer to male attorneys without basis during argument, playing into that gender stereotype. This is ineffective argument and a result of lack of confidence rather than lack of skill. All three panelists encouraged women to thoroughly prepare and be confident in that preparation during any presentation, whether it be a motion or examination at trial. Hon. Heeseman recognized there is still evidence of the macho attitude exhibited by some male attorneys in the courtroom. It is often a cover for lack of preparedness, and though many women attorneys

All three judges noted that their clerks often told them of comments made or looks exchanged, before the judge had taken the bench. A lack of respect between counsel (outside the judge’s presence) does not go unnoticed in the courtroom, and there is a clear line between advocacy and disrespectfulness. Credibility is a fundamental trait in any successful attorney, male or female, therefore the judges recommend selfawareness at all times during practice. Career goals are seldom enhanced by disrespect, and almost always propelled by a mutual respect between counsel.

Have the judges themselves experienced gender bias in their own careers? Hon. Fujie recalled an incident as a presiding judge where a male attorney, amidst arguing a motion, referred to her as “honey.” The reference was quickly withdrawn by the attorney, but a germane example Continued on next page…


CMCP Diversity Matters of gender bias towards even a presiding judge. Such a casual term would likely never be applied to a male judge. She noted that her career has been fueled by a passion to succeed and to encourage diversity in the legal profession, and she recalled clearly when one individual told her she would never become a judge. After her time as a partner of her law firm, then as the first Asian American to serve as the president of the State Bar of California, and now as a presiding judge, appointed in 2011, Hon. Fujie encouraged young women lawyers to continue to succeed, and to continue to broaden diversity as women and minorities in the profession. After all, Hon. Fujie noted, winning on your merit is the best revenge.

What suggestions do the judges have for women in the courtroom? Be prepared. This was the prominent recommendation provided by all three panelists. Hon. Sanchez-Gordon noted that regardless of age, experience, gender, whether the lawyer was from a big firm or small firm, at the end of the day, the attorney most prepared wins the argument. This is the overriding principle and key for women and minority lawyers, who often feel disadvantaged from the start. True preparation includes a mastery of the facts of the case, any applicable case law, and a mastery of your opponents’ potential arguments. Even if an attorney appears on behalf of someone

else from their firm, they should have taken the time to familiarize themselves with the case to be able to speak meaningfully and anticipate some questioning from the judge. She recommended women lawyers maintain their professionalism in the courtroom, from attire to demeanor, as it makes an impact on the judges, who may be meeting you for the first time. Hon. Reeseman suggested “practice makes perfect” and that lawyers can and should be practicing their oral arguments (for a motion or for trial) many times prior to the final hearing. Practice in front of other associates, in front of partners, and take criticisms with improvement in mind. Take positives and negatives and apply them to your own practice and behavior. Also, observing other lawyers is an excellent way to hone your own style, and to stay current. Maintain credibility. All agreed that establishing credibility in the courtroom is essential. For example Hon. Fujie recalled an attorney who claimed a specific case supported his argument, when in actuality it did not. This completely destroyed his credibility and created distrust. All lawyers, regardless of gender, should value their own credibility and aim to present a reasonable position to the court. The panel agreed that exaggerating the record occurs all too often in their courtrooms, and is not well taken. Exhibiting reasonableness in the face of disagreement allows the court to place trust in that attorney, and carries forward to future cases. Whether it means opening up the conversation to compromise, or standing firm in a position, a lawyer’s ability to gauge the argument and context, and adapt accordingly, flows to their ultimate credibility with the judges. Upcoming panels include: “The Woman Factor- How Women at the Top Impact Organizations” (June 25, 2015); and “Gender Stereotypes at the Bargaining Table” (August 20, 2015).

Jennifer Weidinger is an Associate at Pettit Kohn Ingrassia & Lutz’s Los Angeles office. Ms. Weidinger’s practice focuses primarily on premises liability and employment litigation. For more info about Jennifer, click here. 13

Summer 2015 Newsletter

Trend to Limit ADA and FEHA Definitions of Disability Attributed to Behavioral Disorders Affecting Work Relations? By: Jonathan M. Turner, Partner, Epstein Turner Weiss

Could there be a trend starting

among the courts to put restraints on the reach of the disability discrimination laws when it comes to mental impairments affecting an employee’s ability to get along with others in the workplace? Maybe. In December of this past year, the Ninth Circuit put the brakes on its own precedent by reversing a jury finding that the employer violated the Americans with Disabilities Act (“ADA”) when it terminated an employee because of behavioral issues attributed to a mental disorder. In Weaving v. City of Hillsboro, 763 F.3d 1106 (9th Cir. 2014), an employee diagnosed with attention deficit hyperactivity disorder (“ADHD”) was terminated because of “recurring interpersonal problems” that caused workplace conflicts with the employee’s supervisors, co-workers and subordinates. Although the employee’s disruptive behavior was allegedly attributable to his ADHD, the Ninth Circuit held that his termination did not violate the ADA because the employee’s mental disorder, while making it more difficult for him to “get along”

with others, “d[id] not amount to a substantial impairment of his ability to interact with others within the meaning of the ADA.” Id., at 1113. On May 26, 2015, a California court addressed a similar issue arising out of an order granting summary judgment in favor an employer. In Higgins-Williams v. Sutter Medical Foundation, __ Cal. Rptr.3d __, No. C073677, 2015 WL 3451590 (Cal. Ct. App. May 26, 2015), an employee who was diagnosed with a mental disorder (adjustment disorder with anxiety) alleged that because of his disorder he could not work for a particular supervisor who reportedly was abusive to the employee. Although the employee argued that under the California Fair Employment and Housing Act (“FEHA”) he was entitled to a reasonable accommodation for his disorder, the California Court of Appeal was not persuaded. The court held that the inability to work for a particular supervisor “because of anxiety and stress related to that supervisor’s standard oversight of the

employee’s job performance d[id] not constitute a mental disability under FEHA.” Id., at *3. In both of these cases, the court concluded that the mental disorder in question did not satisfy the definition of a disability under the governing law because the disorder did not rise to a level so as to “limit a major life activity.” The major life activity at issue in Weaving was the ability to engage in social interaction, while the major life activity at issue in Higgins-Williams was the ability to work. Although a different legal analysis was applied in each case when denying relief to the employee, it would appear from these cases that the state and federal courts are starting to recognize limits to the protections afforded under the disability discrimination laws when the alleged disability amounts to a behavioral disorder that impairs the plaintiff’s ability to relate to others in the workplace.

Jonathan M. Turner is founding partner at Epstein Turner Weiss in Los Angeles. Jonathan represents management in all aspects of labor and employment law. For more information about Jonathan, click here 14

CMCP Diversity Matters

Diversity Calendar July 10, 2015

July 15, 2015

July 18-23, 2015

Professionals Mixer Benefiting Nepal

5th Anniversary Party

90th Annual Conventions and Exhibits

Asian Pacific American Bar Association Los Angeles

Orange County Lavender Bar Association

California Association of Black Lawyers

Mad Ave - LA

The Sky Garden at the Michelson Building - Irvine

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6:00pm - 2:00am (next day 7/11/2015)

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The Westin Bonaventure Hotel - LA

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July 23, 2015

July 23, 2015

July 27, 2015

ACBA Summer Reception 2015

BHBA Summer Mixer at Trader Vic’s Lounge

Annual SFLRLA Summer Picnic!

5:30pm - 7:30pm

6:00pm - 8:00pm

Alameda County Bar Association

10:00am - 5:00pm

Beverly Hills Bar Association

San Francisco La Raza Lawyers Association

The Beverly Hilton - Beverly Hills

Ceja Winery - Napa

Read more

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July 29, 2015

July 30, 2015

September 12, 2015

In-House Counsel Diversity Awards Reception

Judges’ Dinner

Hollywood Bowl - B-52s & Psych Furs Concert - Space is Limited

Bar Association of San Francisco

Marines Memorials Club - SF

Bocanova - Oakland Read more

5:30pm - 7:30pm

5:30pm - 8:30pm

Schiff Hardin - SF

Queen’s Bench Bar Association Read more

Read more


Lesbian & Gay Lawyers Association of L.A. Hollywood Bowl - LA Read more

September 15, 2015

September 16-19, 2015

September 24, 2015

The 2015 OCWLA Gala

NAMWOLF 2015 Annual Meeting

Orange County Women Lawyers Association

The National Association of Minority & Women Owned Law Firms

Filipino Community Night at Petco Park (Filipino Inspired Pre-Game Entertainment)

Irvine Marriott - Irvine

Loews Hollywood Hotel - LA

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Read more

5:00pm - 9:00pm


4:30pm - 6:10pm

Filipino American Lawyers of San Diego Petco Park - San Diego Read more


CMCP Diversity Matters

Summer 2015 Newsletter

Summer 2015 Newsletter


Summer 2015

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