Preview
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ce CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar humaber, and address). ‘FOR COURT USE ONLY G
Sharona Eslamboly Hakim, Esq. SBN: 180998
Law Offices of Sharona Eslamboly Hakim : =
18730 Wilshire Bivd., Suite 500 F | LE D
Beverly Hills CA 90211
TELEPHONE NO: (310) 289-9100 FAX NO. (Optiona): (310) 289-9101
E-MAIL ADDRESS (Optona): narek@sehlawfirm.com
ATTORNEY FoR (Namey: SANDRA GARCIA
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Joaquin
STREET aDoREss: 180 E. Weber Avenue
Mains appress: 180 E. Weber Avenue
city ann zip cove: Stockton 95202
srancu name: Stockton Courthouse
“qm MUG 13 AY Ve OB
PLAINTIFF/PETITIONER: SANDRA GARCIA.
DEFENDANT/RESPONDENT: CITY OF LODI, ET AL.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): [7] UNLIMITED CASE [= ume case STK-CV-UPI-2021-0002445
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: September 15, 2021 Time: 8:45 a.m. Dept.: 10B Div.: Room:
Address of court (if different from the address above):
[¥] Notice of intent to Appear by Telephone, by (name): Narek Postajian
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. [¥] This statement is submitted by party (name): SANDRA GARCIA
b. [] This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): March 19, 2021
b. (2) The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a [J al Parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. Cw The following parties named in the complaint or cross-complaint
(1) [271 have not been served (specify names and explain why not):
All Defendants - Service in Progress
(2) [1 _ have been served but have not appeared and have not been dismissed (specify names):
(3) [1 have had a default entered against them (specify names):
c. [7] The tollowing additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a Typeofcasein [¥] complaint [1 cross-complaint (Describe, including causes of action):
GN-1, Prem.L-1, Prem.L-2, Prem.L-3, Prem.L-4, Prem.L-5.
Page 1 of S
Fo ence eee CASE MANAGEMENT STATEMENT Cal es of Coun,
‘CM-140 (Rev. July 4, 2013)
FILE BY FAX SatCM-110
CASE NUMBER:
i R:
PLAINTIFF/PETITIONER: SANDRA GARCIA STK-CV-UPI-2021-0002445
DEFENDANT/RESPONDENT: CITY OF LODI, ET AL.
4. b, Provide a brief statement of the case, including any damages. (if personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date {indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff's past and future medical specials, loss of earnings, loss of earning capacity and pain and suffering
damages have yet to be determined. In all, Plaintiff's damages far exceed $25,000.00
[1 (fmore space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury of nonjury trial
The party or parties request. [27] ajurytrial L__] anonjury trial. (if more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. [__] The trial has been set for (date):
b. (71 No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
c. Dates on which patties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
7. Estimated length of trial
‘The party or parties estimate that the trial will take (check one):
a. [37] days (specify number): 5-7
b, [_] hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial [__] by the attorney or party listed in the caption [__] by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
[1 Additional representation is described in Attachment 8.
9. Preference
[-) This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel [7] has [-_] has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party [J has [1 has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(14) (] This matter is subject to mandatory judicial! arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) [] Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) [4] This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
Amount in Controversy Exceeds the Statutory Threshold.
CHAO Rev. ey 3, 200) CASE MANAGEMENT STATEMENT Pago zatCM-110
PLAINTIFF/PETITIONER: SANDRA GARCIA
DEFENDANT/RESPONDENT:CITY OF LODI, ET AL.
CASE NUMBER:
STK-CV-UPI-2021-0002445
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check aif that apply and provide the specified information):
The party or parties completing
this form are willing to
participate in the following ADR
processes (check ail that apply):
if the party or parties completing this form in the case have agreed to
participate in or have already completed an ADR process or processes,
indicate the status of the processes (attach a copy of the parties' ADR
stipulation):
wa
(1) Mediation
Mediation session not yet scheduled
Mediation session scheduled for (date):
Agreed to complete mediation by (date):
Mediation completed on (date):
(2) Settlement
conference
Settlement conference not yet scheduled
Settlement conference scheduled far (date):
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
(3) Neutral evaluation
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
(4) Nonbinding judicial
arbitration
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date):
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
(5) Binding private
arbitration
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
(6) Other (specify):
HOOO|}OOO0;/O000;/O000}O008;O0Us
ADR session not yet scheduled
ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 (Rev. July 1, 2011}
CASE MANAGEMENT STATEMENT
Page SofCM-110
PLAINTIFF/PETITIONER: SANDRA GARCIA (CASE NUMBER:
L STK-CV-UPI-2021-0002445
DEFENDANT/RESPONDENT: CITY OF LODI, ET AL.
11, Insurance
a. [] Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: [-_] yes [_] No
ce. [_] Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
[-] Bankruptey [—] other (specify):
Status:
13. Related cases, consolidation, and coordination
a. [__] There are companion, underlying, or related cases.
(3) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
[) Additional cases are described in Attachment 13a.
b. L_]Amotionto [_] consolidate [_] coordinate will be filed by (name party):
14, Bifurcation
[) The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the failowing issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
[1] the party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. [1] The party or parties have completed all discovery.
b. [¥] The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiff Written Discovery 90 Days
Plaintiff Depositions 180 Days
Plaintiff Expert Discovery Per Code
c, [_] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
HALO [Rev uy, 201 CASE MANAGEMENT STATEMENT Page $015CM-110
PLAINTIFF/PETITIONER: CASE NUMBER:
\_ SANDRA GARCIA STK-CV-UPI-2021-0002445
DEFENDANT/RESPONDENT: CITY OF LODI, ET AL.
17. Economic litigation
a. [__] This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. [] This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
[1] The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a. 7] The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules
of Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any):
Tam completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: August 12, 2021 >
4
Narek Postajian, Esq. > ~ A
x
(TYPE OR PRINT NAME) (sia E OF PARTY OR ATTORNEY)
»
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
[_] Additional signatures are attached.
Cue 110 Rev, Jy, 20134 CASE MANAGEMENT STATEMENT age Sot
Preview
oR ce CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar humaber, and address). ‘FOR COURT USE ONLY G Sharona Eslamboly Hakim, Esq. SBN: 180998 Law Offices of Sharona Eslamboly Hakim : = 18730 Wilshire Bivd., Suite 500 F | LE D Beverly Hills CA 90211 TELEPHONE NO: (310) 289-9100 FAX NO. (Optiona): (310) 289-9101 E-MAIL ADDRESS (Optona): narek@sehlawfirm.com ATTORNEY FoR (Namey: SANDRA GARCIA SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Joaquin STREET aDoREss: 180 E. Weber Avenue Mains appress: 180 E. Weber Avenue city ann zip cove: Stockton 95202 srancu name: Stockton Courthouse “qm MUG 13 AY Ve OB PLAINTIFF/PETITIONER: SANDRA GARCIA. DEFENDANT/RESPONDENT: CITY OF LODI, ET AL. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): [7] UNLIMITED CASE [= ume case STK-CV-UPI-2021-0002445 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: September 15, 2021 Time: 8:45 a.m. Dept.: 10B Div.: Room: Address of court (if different from the address above): [¥] Notice of intent to Appear by Telephone, by (name): Narek Postajian INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. [¥] This statement is submitted by party (name): SANDRA GARCIA b. [] This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): March 19, 2021 b. (2) The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a [J al Parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. Cw The following parties named in the complaint or cross-complaint (1) [271 have not been served (specify names and explain why not): All Defendants - Service in Progress (2) [1 _ have been served but have not appeared and have not been dismissed (specify names): (3) [1 have had a default entered against them (specify names): c. [7] The tollowing additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a Typeofcasein [¥] complaint [1 cross-complaint (Describe, including causes of action): GN-1, Prem.L-1, Prem.L-2, Prem.L-3, Prem.L-4, Prem.L-5. Page 1 of S Fo ence eee CASE MANAGEMENT STATEMENT Cal es of Coun, ‘CM-140 (Rev. July 4, 2013) FILE BY FAX SatCM-110 CASE NUMBER: i R: PLAINTIFF/PETITIONER: SANDRA GARCIA STK-CV-UPI-2021-0002445 DEFENDANT/RESPONDENT: CITY OF LODI, ET AL. 4. b, Provide a brief statement of the case, including any damages. (if personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date {indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff's past and future medical specials, loss of earnings, loss of earning capacity and pain and suffering damages have yet to be determined. In all, Plaintiff's damages far exceed $25,000.00 [1 (fmore space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury of nonjury trial The party or parties request. [27] ajurytrial L__] anonjury trial. (if more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. [__] The trial has been set for (date): b. (71 No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which patties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of trial ‘The party or parties estimate that the trial will take (check one): a. [37] days (specify number): 5-7 b, [_] hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial [__] by the attorney or party listed in the caption [__] by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: [1 Additional representation is described in Attachment 8. 9. Preference [-) This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel [7] has [-_] has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party [J has [1 has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (14) (] This matter is subject to mandatory judicial! arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) [] Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) [4] This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): Amount in Controversy Exceeds the Statutory Threshold. CHAO Rev. ey 3, 200) CASE MANAGEMENT STATEMENT Pago zatCM-110 PLAINTIFF/PETITIONER: SANDRA GARCIA DEFENDANT/RESPONDENT:CITY OF LODI, ET AL. CASE NUMBER: STK-CV-UPI-2021-0002445 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check aif that apply and provide the specified information): The party or parties completing this form are willing to participate in the following ADR processes (check ail that apply): if the party or parties completing this form in the case have agreed to participate in or have already completed an ADR process or processes, indicate the status of the processes (attach a copy of the parties' ADR stipulation): wa (1) Mediation Mediation session not yet scheduled Mediation session scheduled for (date): Agreed to complete mediation by (date): Mediation completed on (date): (2) Settlement conference Settlement conference not yet scheduled Settlement conference scheduled far (date): Agreed to complete settlement conference by (date): Settlement conference completed on (date): (3) Neutral evaluation Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): (4) Nonbinding judicial arbitration Judicial arbitration not yet scheduled Judicial arbitration scheduled for (date): Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): (5) Binding private arbitration Private arbitration not yet scheduled Private arbitration scheduled for (date): Agreed to complete private arbitration by (date): Private arbitration completed on (date): (6) Other (specify): HOOO|}OOO0;/O000;/O000}O008;O0Us ADR session not yet scheduled ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 (Rev. July 1, 2011} CASE MANAGEMENT STATEMENT Page SofCM-110 PLAINTIFF/PETITIONER: SANDRA GARCIA (CASE NUMBER: L STK-CV-UPI-2021-0002445 DEFENDANT/RESPONDENT: CITY OF LODI, ET AL. 11, Insurance a. [] Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: [-_] yes [_] No ce. [_] Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. [-] Bankruptey [—] other (specify): Status: 13. Related cases, consolidation, and coordination a. [__] There are companion, underlying, or related cases. (3) Name of case: (2) Name of court: (3) Case number: (4) Status: [) Additional cases are described in Attachment 13a. b. L_]Amotionto [_] consolidate [_] coordinate will be filed by (name party): 14, Bifurcation [) The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the failowing issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions [1] the party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. [1] The party or parties have completed all discovery. b. [¥] The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Plaintiff Written Discovery 90 Days Plaintiff Depositions 180 Days Plaintiff Expert Discovery Per Code c, [_] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): HALO [Rev uy, 201 CASE MANAGEMENT STATEMENT Page $015CM-110 PLAINTIFF/PETITIONER: CASE NUMBER: \_ SANDRA GARCIA STK-CV-UPI-2021-0002445 DEFENDANT/RESPONDENT: CITY OF LODI, ET AL. 17. Economic litigation a. [__] This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. [] This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues [1] The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. 7] The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): Tam completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: August 12, 2021 > 4 Narek Postajian, Esq. > ~ A x (TYPE OR PRINT NAME) (sia E OF PARTY OR ATTORNEY) » (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) [_] Additional signatures are attached. Cue 110 Rev, Jy, 20134 CASE MANAGEMENT STATEMENT age Sot