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ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Bar number, and address):
Bruce D. MacLeod, Esq. SBN: 130860
Willoughby, Stuart,| Bening & Cook OOO1 HAY il PH 3:19
{ g
50 W. San Fernando Street, Suite 400
na Cae Is
San Jose, California 95113
FItgiba
SUPERION CIES = SPECK TON
eerpHoneno: (408) 289-1972 Fax no.(optionay (408) 295-6375
E-MAIL ADDRESS (Optonay: DrUCe@wsbclawyers.com
ATTORNEY FOR (Nome): Defendant Jeffrey Loew
‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Joaquin
streeraponess: 333 E. Weber Avenue
MAILING ADDRESS:
omvanpzpcon: Stockton, CA 95201
orancHnave: Stockton Courthouse
PLAINTIFF/PETITIONER: Tracey B. Page, an individual
I
DEFENDANT/RESPONDENT: Lary Taylor, an individual; Jeffrey Loew,
an individual; et al. |
CASE MANAGEMENT STATEMENT ASE NUMBER:
(Check one): [KK] UNLIMITED|CASE () Limrreo case STK-CV-UF-2020-0010485
(Amount demanded (Amount demanded Is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 5/25/2021 Time: 8:45 am Dept: 10D Div.: Room:
Address of court (if different from the address above):
1
w Notice of Intent to Appear by Telephone, by (name); Bruce MacLeod, Counsel for' Jeffrey Loew
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
I
1. Party or parties (answer one):
a. (&) This statement is submitted by party (name): Jeffrey Loew
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):
b, () The cross-complaint, li any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. (2) Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [J] The following parties named in the complaint or cross-complaint
(1) [oy have not been served (specify names and explain why not):
Q) CD have beer coned but have not appeared and have not been dismissed (specify names):
(8) () have had a default entered against them (specify names):
i :
c. [) The following addi ional parties may be added (specify names, nature of involvement in case, and the date by which
they may be served):
4. Description of case
a, ..Typeofcasein [) complaint (2) cross-complaint (Describe, including causes of action):
Complaint for Breach of Contract, Conspiracy, Conversion, Lack of Mental Capacity
Undue Influence, Elder, Abuse, Fraud, Legal Malpractice, Negligence, Negligent
Infliction of Emotional Distress, Breach of Fiduciary Duty, Unfair Business
Practices, Breach| of the Implied Covenant of Good Faith and Fair Dealing
Page 1 of 5
Form Adopted for Mancatery Lise toe CASE MANAGEMENT STATEMENT Gal, Rules of Court
Ritimiacaa CEB Espen, tpt
| FILE BY FAX 1490.14002M - Page v. Lobw
hoCM-110
DEFENDANT/RESPONDENT: tarry Taylor, an individual; Jeffrey Loew,
an individual; et fal.
PLAINTIFF/PETITIONER: Tracey B. Page, an individual casenumscr:
STK-CV-UF-2020-0010485
4. ob
C] (if more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
Provide a brief statement dt 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.)
Defendant represented Plaintiff for a short period in an underlying trust action.
Plaintiff contends he improperly abandoned her claim, resulting in damage. Defendant
contends the Plaintiff was fully aware of all actions taken by the Defendants and
consented to then| and that any claims are barred by the Statute of Limitations.
The party or parties request wa ajury trial (2) anonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. (CJ) The trial has been set for (date):
b.
c.
7. Estimated length of trial .
The party or parties estimate that the trial will take (check one):
a
b. [L) hours (short causes) [(specity):
8. Trial representation (to be answered for each party)
The party or parties will be reptesented at trial (2) by the attorney or party listed in the caption (D2 by the foltowing:
e.
“LJ Additional representation is described in Attachment 8.
9. Preference |
(-) This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
aecp
[QQ 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):
Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
6/21-26/2021 - vacation; 9/7-10/2021 ~- Trial; 10/25-11/5/2021 - Trial
EX] days (specify number): Five
Altorney:
Firm:
Address:
Telephone number: f. Fax number:
E-mail address: g. Party represented:
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 [}has [C] has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For setlrepresented parts: Party [}has [J has not reviewed the ADR information package identified in rule 3.221.
Referral to judicial arbitration or civil action mediation (if available).
(1) (2) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civillaction
mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not oy the
statutory limit. |
(2) (CQ 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) Cy This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): |
(GM-110 (Rev. July 1, 2011} CASE MANAGEMENT STATEMENT Poge 2ots
ge
Essential
E\Forms:
1490.14002M - Page v. LoewcM-110
PLAINTIFF/PETITIONER:Tracey B.
an individual; et lal.
DEFENDANT/RESPONDENT: Larry Taylor, an individual; Jeffrey Loew,
Page, an individual | casenumscr:
STK-CV-UF-2020-0010485
10. oc. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, o
have already participated in (check ail that apply and provide the specified information):
The party or parties completing
this form are willing to
participate in the following ADR
processes (check aif that apply): | stipulation):
i
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 (atfach a copy of the parties' ADR
'
[2] Mediation session not yet scheduled
CO Mediation session scheduled for (date):
(1) Mediation , f
(1 Agreed to complete mediation by (date):
' (2) Mediation completed on (date):
1
|
' [J Settlement conference not yet scheduled
(2) Settlement : a (Settlement conference scheduled for (date):
conference (Agreed to complete settlement conference by (date):
{) Settlement conference completed on (date):
(1 Neutral evaluation not yet scheduled
(3) Neutral evaluation | a (2) Neutral evaluation scheduled for (date):
(2) Agreed to complete neutral evaluation by (date):
(2) Neutral evaluation completed on (date):
’
(2 Judicial arbitration not yet scheduled
(4) Nonbinding judicial a () Judicial arbitration scheduled for (date):
arbitration
() Agreed to complete judicial arbitration by (date):
(2) Judicial arbitration completed on (date):
[2] Private arbitration not yet scheduled
(5) Binding private : QO (2) Private arbitration scheduled for (date):
arbitration () Agreed to complete private arbitration by (date):
(C2 Private arbitration completed on (date):
[J ADR session not yet scheduled
(2) ADR session scheduled for (date):
() Agreed to complete ADR session by (date):
(2) ADR completed on (date):
(6) Other (specify): oO
CM-110 [Rev. July 1, 2012)
| Essential
cebaom | f=\Forms:
CASE MANAGEMENT STATEMENT
1490.14002M - Page v. Loew
Page 9 of SCM-110
PLAINTIFF/PETITIONER: Tracey B. Page, an individual CASE NUMBER:
STK-CV-UF-2020-0010485
DEFENDANT/RESPONDENT: Larry) Taylor, an individual; Jeffrey Loew,
an individual; et al.
11. Insurance
a. [&] Insurance carrier, if any, for party filing this statement (name): Arch Insurance Company
b. Reservation of rights: LC Yes [X} No
c. [] Coverage issues will significantly affect resolution of this case (explain):
1
12, Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case, and describe the status.
2 Bankruptcy (XQ Other (specify): The status of the underlying trust action is unknown.
Status: ,
i
13. Related cases, consolidation, and coordination
a. [2] There are companion, underlying, or related cases.
(1) Name of case: j
(2) Name of court: |
(3) Case number: |
{4) Status: '
(C] Additional cases aro described in Attachment 13a.
b. Cy Amotionto ([) consolidate [2] coordinate will be filed by (name party):
14. Bifurcation
(2) The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
. i
15. Other motions |
[X) The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Defendant Loew's Demurrer is set for May 25, 2021
16. Discovery
a. [C] The party or parties have completed all discovery.
b. [2] The following discovery will be completed by the date specified (describe ail anticipated discovery):
Party 4 Description Date
' None scheduled due to pending demurrer
c. [LQ The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
M-110 [Flow. July 1, 2011] CASE MANAGEMENT STATEMENT “Rage 4 of 5
CEB | Essential
cebeom | fa]Forms™ 1490.14002M - Page v. LoewCM-110
PLAINTIFF/PETITIONER: Tracey B. Page, an individual CASE NUMBER:
| STK-CV-UF-2020-0010485
DEFENDANT/RESPONDENT: Larry Taylor, an individual; Jeffrey Loew,
an_ individual; et lal.
T
17. Economic litigation '
a. [2] This isa limited civil dase (.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. (CC) This is a limited civil Gase 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
() 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. [2] The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of
Count (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 (ifany); Q
| am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolutior b
f
as well as other issues raised by ths statement, and will possess the authority to enter into stipulations on these issues at the time
the case management conference, including the written authority of the party where required.
Date: 5/10/2021
> Bue D. Wlaclwed
Bruce D. Macteod
7
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OF ATTORNEY)
| »
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(2) Additional signatures are attached.
M110 Rev. Juy 1, 2011) CASE MANAGEMENT STATEMENT Rage Sot 5
CEB | Essentiat
cchoom | fel Forms”
1490.14002mM - Page v. LoewBENING & COOK
STUART,
WILLOUGHBY,
Oo em ND
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Case Name: |Page v. Taylor (Jeffrey Loew)
Court: ‘San Joaquin County Superior Court
Case No. ‘SSTK-CV-UF-2020-0010485
Our File No. 1490.14002M
| PROOF OF SERVICE
i
STATE OF CALIFORNIA ]
i ] ss.
COUNTY.OF SANTA CLARA ]
Tama titizen of the United States and employed in the County of Santa Clara, State of]
California; I arn over the age of eighteen years and not a party to the within action; my busines:
address is 50 w. San Fernando Street, Suite 400, San Jose, CA 95113. On the date set forth
below I served'the document[s] described as:
CASE ee STATEMENT;
NOTICE OF DEPOSIT OF JURY FEES
e
on the following person[s] in this action as follows:
I
Jerome Anthony Clay, Jr. Counsel for Plaintiff, TRACY B. PAGE
LAW OFFICES OF JEROME A. CLAY
5250 Claremont Avenue, Suite 221
Stockton, CA 95207
209-603-9852
510-280-2841 ifax
J clay7@elaylaw. net
[] [BY u 's. MAIL] I caused the above referenced documents, addressed to the addressee|s],
to be placed for collection and mailing with the United States Postal Service, in a seale:
envelope with postage fully prepaid. I understand that service shall be presumed inval
upon motion of a party served if the postal cancellation date or postage date on the
envelope is more than one day after the date of deposit for mailing contained on the
affidavit.
ae
[ ] [BY PERSONAL SERVICE] I caused the document[s] to be delivered by hand to the
offices|of the addressee[s].
|
[ ] [BY ELECTRONIC FILING AND SERVICE] Pursuant to Code of Civil Procedure
1010.06, I electronically filed and served the document(s) described above on One Legal’s
electronic filing system. Notice of this filing will be sent by one Legal to all parties
indicated on the electronic filing receipt. Parties may access this filing through One
- Legal’s electronic filing system.
[ ] [BY FACSIMILE] I caused the document[s] to be transmitted by facsimile on this date to
the offices of addressee[s]. The facsimile machine complies with Rule 2003(3) of the
California Rules of Court and was reported as complete and without error at the time
specified on the transmission confirmation report and was properly issued by the
. transmitting facsimile machine operating at [408]295-6375.STUART & BENING
WILLOUGHBY,
oe NO
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[X] [BY ELECTRONIC MAIL] Pursuant to agreement of the parties for electronic service,
caused|a copy of the document{s] to be transmitted via an electronic mail account
maintained at the law office of Willoughby, Stuart, Bening & Cook to the email address as
listed. The transmission was reported as complete and without error.
[]
[X]
[]
[BY FEDERAL EXPRESS] | caused the envelope[s] to be placed for collection and
overnight delivery by Federal Express with delivery fees thereon fully prepaid or provided
for.
[STATE] I declare under penalty of perjury under the laws of the State of California that
the foregoing i is true and correct.
[FEDERAL] I declare that I am employed i in the office of a member of the bar of this
court at whose direction the service was made.
Executed on May 10, 2021 at Sunnyvale, California.
Sheila Smith
Sheila Smith
Preview
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Bar number, and address): Bruce D. MacLeod, Esq. SBN: 130860 Willoughby, Stuart,| Bening & Cook OOO1 HAY il PH 3:19 { g 50 W. San Fernando Street, Suite 400 na Cae Is San Jose, California 95113 FItgiba SUPERION CIES = SPECK TON eerpHoneno: (408) 289-1972 Fax no.(optionay (408) 295-6375 E-MAIL ADDRESS (Optonay: DrUCe@wsbclawyers.com ATTORNEY FOR (Nome): Defendant Jeffrey Loew ‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Joaquin streeraponess: 333 E. Weber Avenue MAILING ADDRESS: omvanpzpcon: Stockton, CA 95201 orancHnave: Stockton Courthouse PLAINTIFF/PETITIONER: Tracey B. Page, an individual I DEFENDANT/RESPONDENT: Lary Taylor, an individual; Jeffrey Loew, an individual; et al. | CASE MANAGEMENT STATEMENT ASE NUMBER: (Check one): [KK] UNLIMITED|CASE () Limrreo case STK-CV-UF-2020-0010485 (Amount demanded (Amount demanded Is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 5/25/2021 Time: 8:45 am Dept: 10D Div.: Room: Address of court (if different from the address above): 1 w Notice of Intent to Appear by Telephone, by (name); Bruce MacLeod, Counsel for' Jeffrey Loew INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. I 1. Party or parties (answer one): a. (&) This statement is submitted by party (name): Jeffrey Loew 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): b, () The cross-complaint, li any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. (2) Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [J] The following parties named in the complaint or cross-complaint (1) [oy have not been served (specify names and explain why not): Q) CD have beer coned but have not appeared and have not been dismissed (specify names): (8) () have had a default entered against them (specify names): i : c. [) The following addi ional parties may be added (specify names, nature of involvement in case, and the date by which they may be served): 4. Description of case a, ..Typeofcasein [) complaint (2) cross-complaint (Describe, including causes of action): Complaint for Breach of Contract, Conspiracy, Conversion, Lack of Mental Capacity Undue Influence, Elder, Abuse, Fraud, Legal Malpractice, Negligence, Negligent Infliction of Emotional Distress, Breach of Fiduciary Duty, Unfair Business Practices, Breach| of the Implied Covenant of Good Faith and Fair Dealing Page 1 of 5 Form Adopted for Mancatery Lise toe CASE MANAGEMENT STATEMENT Gal, Rules of Court Ritimiacaa CEB Espen, tpt | FILE BY FAX 1490.14002M - Page v. Lobw hoCM-110 DEFENDANT/RESPONDENT: tarry Taylor, an individual; Jeffrey Loew, an individual; et fal. PLAINTIFF/PETITIONER: Tracey B. Page, an individual casenumscr: STK-CV-UF-2020-0010485 4. ob C] (if more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial Provide a brief statement dt 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.) Defendant represented Plaintiff for a short period in an underlying trust action. Plaintiff contends he improperly abandoned her claim, resulting in damage. Defendant contends the Plaintiff was fully aware of all actions taken by the Defendants and consented to then| and that any claims are barred by the Statute of Limitations. The party or parties request wa ajury trial (2) anonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. (CJ) The trial has been set for (date): b. c. 7. Estimated length of trial . The party or parties estimate that the trial will take (check one): a b. [L) hours (short causes) [(specity): 8. Trial representation (to be answered for each party) The party or parties will be reptesented at trial (2) by the attorney or party listed in the caption (D2 by the foltowing: e. “LJ Additional representation is described in Attachment 8. 9. Preference | (-) This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) aecp [QQ 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): Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 6/21-26/2021 - vacation; 9/7-10/2021 ~- Trial; 10/25-11/5/2021 - Trial EX] days (specify number): Five Altorney: Firm: Address: Telephone number: f. Fax number: E-mail address: g. Party represented: 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 [}has [C] has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For setlrepresented parts: Party [}has [J has not reviewed the ADR information package identified in rule 3.221. Referral to judicial arbitration or civil action mediation (if available). (1) (2) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civillaction mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not oy the statutory limit. | (2) (CQ 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) Cy This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): | (GM-110 (Rev. July 1, 2011} CASE MANAGEMENT STATEMENT Poge 2ots ge Essential E\Forms: 1490.14002M - Page v. LoewcM-110 PLAINTIFF/PETITIONER:Tracey B. an individual; et lal. DEFENDANT/RESPONDENT: Larry Taylor, an individual; Jeffrey Loew, Page, an individual | casenumscr: STK-CV-UF-2020-0010485 10. oc. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, o have already participated in (check ail that apply and provide the specified information): The party or parties completing this form are willing to participate in the following ADR processes (check aif that apply): | stipulation): i 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 (atfach a copy of the parties' ADR ' [2] Mediation session not yet scheduled CO Mediation session scheduled for (date): (1) Mediation , f (1 Agreed to complete mediation by (date): ' (2) Mediation completed on (date): 1 | ' [J Settlement conference not yet scheduled (2) Settlement : a (Settlement conference scheduled for (date): conference (Agreed to complete settlement conference by (date): {) Settlement conference completed on (date): (1 Neutral evaluation not yet scheduled (3) Neutral evaluation | a (2) Neutral evaluation scheduled for (date): (2) Agreed to complete neutral evaluation by (date): (2) Neutral evaluation completed on (date): ’ (2 Judicial arbitration not yet scheduled (4) Nonbinding judicial a () Judicial arbitration scheduled for (date): arbitration () Agreed to complete judicial arbitration by (date): (2) Judicial arbitration completed on (date): [2] Private arbitration not yet scheduled (5) Binding private : QO (2) Private arbitration scheduled for (date): arbitration () Agreed to complete private arbitration by (date): (C2 Private arbitration completed on (date): [J ADR session not yet scheduled (2) ADR session scheduled for (date): () Agreed to complete ADR session by (date): (2) ADR completed on (date): (6) Other (specify): oO CM-110 [Rev. July 1, 2012) | Essential cebaom | f=\Forms: CASE MANAGEMENT STATEMENT 1490.14002M - Page v. Loew Page 9 of SCM-110 PLAINTIFF/PETITIONER: Tracey B. Page, an individual CASE NUMBER: STK-CV-UF-2020-0010485 DEFENDANT/RESPONDENT: Larry) Taylor, an individual; Jeffrey Loew, an individual; et al. 11. Insurance a. [&] Insurance carrier, if any, for party filing this statement (name): Arch Insurance Company b. Reservation of rights: LC Yes [X} No c. [] Coverage issues will significantly affect resolution of this case (explain): 1 12, Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case, and describe the status. 2 Bankruptcy (XQ Other (specify): The status of the underlying trust action is unknown. Status: , i 13. Related cases, consolidation, and coordination a. [2] There are companion, underlying, or related cases. (1) Name of case: j (2) Name of court: | (3) Case number: | {4) Status: ' (C] Additional cases aro described in Attachment 13a. b. Cy Amotionto ([) consolidate [2] coordinate will be filed by (name party): 14. Bifurcation (2) The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): . i 15. Other motions | [X) The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Defendant Loew's Demurrer is set for May 25, 2021 16. Discovery a. [C] The party or parties have completed all discovery. b. [2] The following discovery will be completed by the date specified (describe ail anticipated discovery): Party 4 Description Date ' None scheduled due to pending demurrer c. [LQ The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): M-110 [Flow. July 1, 2011] CASE MANAGEMENT STATEMENT “Rage 4 of 5 CEB | Essential cebeom | fa]Forms™ 1490.14002M - Page v. LoewCM-110 PLAINTIFF/PETITIONER: Tracey B. Page, an individual CASE NUMBER: | STK-CV-UF-2020-0010485 DEFENDANT/RESPONDENT: Larry Taylor, an individual; Jeffrey Loew, an_ individual; et lal. T 17. Economic litigation ' a. [2] This isa limited civil dase (.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. (CC) This is a limited civil Gase 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 () 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. [2] The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Count (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 (ifany); Q | am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolutior b f as well as other issues raised by ths statement, and will possess the authority to enter into stipulations on these issues at the time the case management conference, including the written authority of the party where required. Date: 5/10/2021 > Bue D. Wlaclwed Bruce D. Macteod 7 (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OF ATTORNEY) | » (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (2) Additional signatures are attached. M110 Rev. Juy 1, 2011) CASE MANAGEMENT STATEMENT Rage Sot 5 CEB | Essentiat cchoom | fel Forms” 1490.14002mM - Page v. LoewBENING & COOK STUART, WILLOUGHBY, Oo em ND 10 Il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case Name: |Page v. Taylor (Jeffrey Loew) Court: ‘San Joaquin County Superior Court Case No. ‘SSTK-CV-UF-2020-0010485 Our File No. 1490.14002M | PROOF OF SERVICE i STATE OF CALIFORNIA ] i ] ss. COUNTY.OF SANTA CLARA ] Tama titizen of the United States and employed in the County of Santa Clara, State of] California; I arn over the age of eighteen years and not a party to the within action; my busines: address is 50 w. San Fernando Street, Suite 400, San Jose, CA 95113. On the date set forth below I served'the document[s] described as: CASE ee STATEMENT; NOTICE OF DEPOSIT OF JURY FEES e on the following person[s] in this action as follows: I Jerome Anthony Clay, Jr. Counsel for Plaintiff, TRACY B. PAGE LAW OFFICES OF JEROME A. CLAY 5250 Claremont Avenue, Suite 221 Stockton, CA 95207 209-603-9852 510-280-2841 ifax J clay7@elaylaw. net [] [BY u 's. MAIL] I caused the above referenced documents, addressed to the addressee|s], to be placed for collection and mailing with the United States Postal Service, in a seale: envelope with postage fully prepaid. I understand that service shall be presumed inval upon motion of a party served if the postal cancellation date or postage date on the envelope is more than one day after the date of deposit for mailing contained on the affidavit. ae [ ] [BY PERSONAL SERVICE] I caused the document[s] to be delivered by hand to the offices|of the addressee[s]. | [ ] [BY ELECTRONIC FILING AND SERVICE] Pursuant to Code of Civil Procedure 1010.06, I electronically filed and served the document(s) described above on One Legal’s electronic filing system. Notice of this filing will be sent by one Legal to all parties indicated on the electronic filing receipt. Parties may access this filing through One - Legal’s electronic filing system. [ ] [BY FACSIMILE] I caused the document[s] to be transmitted by facsimile on this date to the offices of addressee[s]. The facsimile machine complies with Rule 2003(3) of the California Rules of Court and was reported as complete and without error at the time specified on the transmission confirmation report and was properly issued by the . transmitting facsimile machine operating at [408]295-6375.STUART & BENING WILLOUGHBY, oe NO 10 ie 12 13 14 16 17 18 20 21 22 23 24 25 26 27 28 [X] [BY ELECTRONIC MAIL] Pursuant to agreement of the parties for electronic service, caused|a copy of the document{s] to be transmitted via an electronic mail account maintained at the law office of Willoughby, Stuart, Bening & Cook to the email address as listed. The transmission was reported as complete and without error. [] [X] [] [BY FEDERAL EXPRESS] | caused the envelope[s] to be placed for collection and overnight delivery by Federal Express with delivery fees thereon fully prepaid or provided for. [STATE] I declare under penalty of perjury under the laws of the State of California that the foregoing i is true and correct. [FEDERAL] I declare that I am employed i in the office of a member of the bar of this court at whose direction the service was made. Executed on May 10, 2021 at Sunnyvale, California. Sheila Smith Sheila Smith