Preview
os | @ @ FILED. BY FAX
GM-110
ATTORNEY OR PARTY WITHOUT, ATTORNEY thlame, State Bar aumber, and eddrass): FOR COURT USE ON}
Elizabeth Staggs Wilson, Bar No. 183160; Shannon R. Boyce, Bar No. 229041 MILE Py
LITTLER MENDELSON, P.c. 5
633 W. 5” Street, 63" Floor WH? 27 p Py
Los Angeles, GA 90071 , PHS 13
Teeprone Na: (213) 443-4300 FAX NO. (Optional (213) 443-4299 Pe HE
E-MAIL ADDRESS (Gptinaly EStAQgS-Wilson@littler.com; shoyce@littler.com @ Chea y
ArronverFon eons: Defendants DOCTORS HOSPITAL OF. MANTECA ING. _f| witha
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN
streer anoress: 222 E. Weber Avenue
maine anpress: PO, Box 201022
cryanpzpcone: Stockton, CA 95201
erancHwame: Stockton Branch
PLAINTIFF/PETITIONER: REGINALD LYLE
DEFENDANT/RESPONDENT: DOCTORS HOSPITAL OF MANTECA, INC., ET AL.
CASE MANAGEMENT STATEMENT
LA
. CASE NUMBER:
(Check one): [J UNLIMITED CASE OO (uimnep case STK-GV-UEO-2016-6523
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
ACASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: April 3, 2017 Time: 8:45 a.m. Dept.: 22 Div.:
Address of court (if different from the address above):
Room:
EX Notice of Intent to Appear by Telephone, by (name): Shannon R. Boyce
INSTRUCTIONS: All applicable boxes must be checked, and the specified Information must be provided.
i
1, Party or partles (answer ane):
a. BQ This staternentis submitted by party (name): Defendants DOCTORS HOSPITAL OF MANTECA ING., ET AL,
b. [This statement is submitted Jointly by parties (names):
2. Complaint and crass-complaint ({o be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. (1 Thecross-complaint, if any, was filed on (date):
3. Service (to be answered, by plaintiffs and cross-complainants only)
0 Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. O The following parties named in the complaint or eross-complaint
a O ' have not been served (specify names and explain why nol):
|
(2) o | have been served but have not appeared and have not bean dismissed (specify names):
g O | have had a default entered against them (specify names):
:
i
c. [1 The following additional parties may be added (specify names, nature of involvement in case, and dale by which
they may ° served):
4. Deséription of case
a. Type of case in| &) complaint ( cross-complaint (Describe, including causes of aclfon):
Putative class action alleging failure to pravide meal and rest breaks, failure to pay minimum hourly and overtime
wages, fallure, fo pay wages at termination, failure to provide accurate wage statements, and unfair competition.
Page Lots
Fon A CASE MANAGEMENT STATEMENT Tan Reon cf Court,
raloa 3720-3 730
OM-110 [Figv. July 1, 2011) |‘ FG ® @ .
CM-116
PLAINTIFF/PETITIONER: REGINALD LYLE, et al. CASE NUMBER:
LL ie etal STK-CV-UEO-2016-6523
DEFENDANT/RESPONDENT: DOCTORS HOSPITAL OF MANTECA ING., et at
4. b, Provide.a brief statement of the case, Including any damages: (/f personal injury damages are sought, specify the injury.and
damages claimed, including medical expenses to-date [indicate source and amount}, estimated future. medical expenses, Jost
eamings to date, and estimated future lost eamings. if equitable reliefis sought, describe the nature of the relief.)
Plaintiff brings this putative class action on behalf of-himself.and all.others similarly situated for failure to provide
meal and rest breaks, failure to pay minimum hourly and overtime wages, failure to pay wages at termination, and
failure to provide accurate wage statemerits Uinder the Labor Code. Plaintiff also alleges unfair competition under
the Business & Professions Code. Defendants deny the-entirety. of-Plaintiffs. allegations and deny that Plaintiff's
claims are suitable for class treatment. ’
0 ttmore space is néeded, check this box and attach a page designaled'as Attachment 4b.)
§. Jury or nanjury tal
‘The party or parties request Oa jury trial Ha nonjury trial. (If more than one party, provide the name of each.party
requesting a jury trial): : .
6. Teal date:
oO The trial has been set for (dafe}:
.. 4X] 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): Plaintiff will have to move for class certification before the parties can proceed to trial
i
c. Dates on which parties or altomeys will not be available for trial (specify dates and explain reasons for unavailability):
1
7. Estimated length of trial
The party or parties estimate that the trial will take (check one): The estimated od length wil! be unknown until a decision on
class certification i is made,
a C1 days (specity number:
b. [1 hours (short causes) (specify):
8. Trial representation (fo be answered for each patty) a
The party or patties will be represented at trial [XJ bythe atiomey ar patty listed in-the caption 11 by the following:
a. Altomey: : .
b. Firm: i
c. “Address:
d. Telephone number: 4... Fax number:
e. Email address: | g. Party represented:
L_- Additional representation i is described In Attachment 8.
9. Preference i
This case is antitied to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR# informatian package. Please note that different ADR processes are available in different courts and communitias; 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 D l-has (1 hasnot. provided the ADR information package id identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-1 -represented parties: Party (1 has © (7) has not reviewed the ADR information package identified in.rule 3.221,
b. Referral to Judicial arbitration or civil action mediation (if available).
(1) 6 This matter is subject to mandatory judicial arbitration under Code of Civil Pracedure 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 [i fimit.
(2) O Plaintitt elects to refer this case to judicial arbitration and agrees to:limit recovery to-the amount specified in Cade of
Civil Procedure section 1141.11.
@ 1 This case is exempt from judicial esbitration under rufe 3.811 of the Califomia Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et-seq. (specify exemption):
This is a class action (CA Rule of Court, Rule 3.814(6)(2)).
a CASE MANAGEMENT STATEMENT Pagozets
sous FonnaWorkFton, comcm-ti0
PLAINTIFPPETTIONER: REGINALD LYLE, etal.
Derepantnssrowmen DOCTORS HOSPITAL OF MANTECA ING. etal.
CASE NUMBER:
STK- Cv. UEO-2016-6823
40. G Indicate the ADR | cco or processes that the party or partles. are wil to participate! ‘in, have. agreed to participate in, or:
. have. je aacty pariipated 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 all that apply):
ifthe party or parties completing this form inthe case have agreed to:
‘participate in or have already completed an ADR process or processes,
‘indicate the status. of ihe Processes (attach a-copy. of the parties‘ADR
stipulation):
“(ly Mediation Ri.
Mediation cas not yet scheduled . ”
Mediation session scheduled for (date):
‘Agréed. to-complete mediation by (date):
Mediation: completed-an (date): .
* (2) Settlement | ;
conference ‘ Oo
Settlement conference not yet scheduled
Settlement ‘conference scheduled for (date):
Agread to | complete settlement conference by (date) :
- Settlement sonferenca completed on (date): .
(3) Neutral evaluation ‘ ao
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 g
arbitration .
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (datey:
Agreed to complete judicial ‘arbitration by (date):
Judicial arbitration conipleted on (date):
) Binding private | oO
“ abiirion
: Private arbitration not ‘yet scheduled .
Private arbitration scheduled for (date):: .
Agreed to complete private arbitration by (date):
Private arbitration completed on (dale):
-() Otter (speci: yoo
coog}ocaa coon oono}ooo0o0;o00R8
ADR session not yet scheduled :
ADR session scheduled for (date); .
Agreed to'compiete.ADR session by (cate):
(2) ADR completed on (date):
CASE MANAGEMENT STATEMENT
| American LegatWet, a.
nae ForraWou ow com
-Page 3 of §e e 4
CM-110
PLANTIFFPETTIONER: REGINALD LYLE, etal. Tease nouer.
4 STK-CV-UEO-2016-652:
[ DereNoaNTmEsPONDENT: DOCTORS HOSPITAL OF MANTECA ING., etal. 3
11. Insurance
a. LE) Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights; C] Yes 1 No
« O Coverage issues will significantly affect resolution of this case (explain):
i 5
|
412. Jurisdiction '
Indicate any matters that may affect the court's jurisdiction c or processing of this case and describe ihe status.
01 Bankruptey a Other (specify):
Status;.
|
13. Related cases, consolidation, and coordination |
- a @ There are companion, underlying, or related cases.
(1). Name of case: See Notice of Related Cases, filed concurrently herewith
(2) Name of court: -
(3) Case number:
@) Status: |
C2 Additional cases are described in Attachment 13a.
b, o Amotion to © consotidate 1 coordinate will be filed by (name party):
|
14; Bifurcation
1 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):
15. Other motions. |
The party or parties ‘@xpect to file the follewing motions before trial (specify moving party, type of motion, and issues):
Defendants anticipate opposing Plaintiff's expected motion for class certification, filing a motion for
decertification! and-possibly a motion for summary Judgment.
16. Discovery © |
a. [J The party ot parties have completed all discovery.
b _The following discovery. will be completed by the date specified (desttibe ait anticipated discovery):
Description - Date
Defendants Written Discovery TBD
t
Defendants i Plaintiffs Deposition - : TBD
: . :
|
|
cG The following discovery issues, Including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Defendants request that discovery be bifurcated, with the initial phase focusing only on issues related to
class certification.
‘wn Formalverktlow com
|
H
a a CASE MANAGEMENT STATEMENT " Pea ats
|
I
f. |
| | @ e
chi-110
PLAINTIFEPETITIONER: REGINALD LYLE, etal.
| DEFENDANT/RESPONDENT: DOCTORS HOSPITAL OF MANTECA INC., et al;
1
1
17, Economic litigation |
a. [1 This isa limited civil case (Le., the amount demanded is $25,060 or fess) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. [1 This isa timited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will ba filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
STK-CV-UEO-2016-6523
18, Other Issues ‘
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify): The parties met and conferred regarding class certification, and request that the Court set a
further status conference in 90 days to set a class certification deadline. The parties are currently meeting and
conferting rgarding discovery in this matter, which will dictate the timing for Plaintiff's anticipated motion for class
certification.
19. Meet and confer
a, The party or parties have met and conferred with ail partias 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 Califomia Rules of Court, the parties agree on the following
(specify): .
'
1
|
i
{
20. Total number of pages attached (if any):
Jam completely familiar ith 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 inta stipulations on these issues at the time of
the case management conference, including the written authority of the parly where required.
Date: March 27,:2017
Shannon R. Boyce
(TYPE OR PRINT NAME) © (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME). . {SIGNATURE OF PARTY OR ATTORNEY)
C Additional signatures are attached,
i
‘
i
‘
cH FR. 1, 2098 CASE MANAGEMENT STATEMENT Page sts
vem FoomWerkFlow commeee
NRRBRBRE BS GSN RHE REEOKR SE GS
28
USTTLER manDEL SCH
i tic Sapen tar
tessa eh Seger sat
wow on ou FWY
ee .
' F ERVICE
l Tam a resident of the State of Callfornia, over the age of eighteen years, and not a
party to the within action. My business address is 2049 Century Park East, 5th Floor, Los Angeles,
caer 9§0067.3107. On March 27, 2017, I served the within document(s):
DEFENDANT'S CASE MANAGEMENT STATEMENT
by placing a true copy of the document(s) listed above for collection and mailing
: Ex] following the firm’s ordinary business practice in a sealed envelope with postage
| thereon fully prepaid for deposit in the United States mail at Los Angeles,
|
California addressed as set forth below.
. Joseph Lavi, Esq.
. Vincent C. Granberry, Esq.
‘ LAVI & EBRAHIMIAN, LLP
8889 W. Olympic Boulevard
Suite 200
, Beverly Hills, CA 90211
: : Telephone: 310.432.0000
’ Facsimile: 310.432.0001
' | atoleys for Plaintiff Reginald Lyle
'
| I am readily familiar with the firm's practice of collection and processing
correspondence for mailing and for shipping via overnight delivery service. Under that practice it
would be deposited with the U.S. Postal Service or if an overnight delivery service shipment,
; deposited in an overnight delivery service pick-up box or office on the same day with postage or
i
fees thereon fully prepaid In the ordinary course of business.
' I declare under penalty of perjury under the laws of the State of California that the
above is true and correct, Executed on March 27, 2027, 2
i
Firmwvide:142979786.1 052845,1344
PROOF OF SERVICE
Preview
os | @ @ FILED. BY FAX GM-110 ATTORNEY OR PARTY WITHOUT, ATTORNEY thlame, State Bar aumber, and eddrass): FOR COURT USE ON} Elizabeth Staggs Wilson, Bar No. 183160; Shannon R. Boyce, Bar No. 229041 MILE Py LITTLER MENDELSON, P.c. 5 633 W. 5” Street, 63" Floor WH? 27 p Py Los Angeles, GA 90071 , PHS 13 Teeprone Na: (213) 443-4300 FAX NO. (Optional (213) 443-4299 Pe HE E-MAIL ADDRESS (Gptinaly EStAQgS-Wilson@littler.com; shoyce@littler.com @ Chea y ArronverFon eons: Defendants DOCTORS HOSPITAL OF. MANTECA ING. _f| witha SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN streer anoress: 222 E. Weber Avenue maine anpress: PO, Box 201022 cryanpzpcone: Stockton, CA 95201 erancHwame: Stockton Branch PLAINTIFF/PETITIONER: REGINALD LYLE DEFENDANT/RESPONDENT: DOCTORS HOSPITAL OF MANTECA, INC., ET AL. CASE MANAGEMENT STATEMENT LA . CASE NUMBER: (Check one): [J UNLIMITED CASE OO (uimnep case STK-GV-UEO-2016-6523 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) ACASE MANAGEMENT CONFERENCE is scheduled as follows: Date: April 3, 2017 Time: 8:45 a.m. Dept.: 22 Div.: Address of court (if different from the address above): Room: EX Notice of Intent to Appear by Telephone, by (name): Shannon R. Boyce INSTRUCTIONS: All applicable boxes must be checked, and the specified Information must be provided. i 1, Party or partles (answer ane): a. BQ This staternentis submitted by party (name): Defendants DOCTORS HOSPITAL OF MANTECA ING., ET AL, b. [This statement is submitted Jointly by parties (names): 2. Complaint and crass-complaint ({o be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. (1 Thecross-complaint, if any, was filed on (date): 3. Service (to be answered, by plaintiffs and cross-complainants only) 0 Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. O The following parties named in the complaint or eross-complaint a O ' have not been served (specify names and explain why nol): | (2) o | have been served but have not appeared and have not bean dismissed (specify names): g O | have had a default entered against them (specify names): : i c. [1 The following additional parties may be added (specify names, nature of involvement in case, and dale by which they may ° served): 4. Deséription of case a. Type of case in| &) complaint ( cross-complaint (Describe, including causes of aclfon): Putative class action alleging failure to pravide meal and rest breaks, failure to pay minimum hourly and overtime wages, fallure, fo pay wages at termination, failure to provide accurate wage statements, and unfair competition. Page Lots Fon A CASE MANAGEMENT STATEMENT Tan Reon cf Court, raloa 3720-3 730 OM-110 [Figv. July 1, 2011) |‘ FG ® @ . CM-116 PLAINTIFF/PETITIONER: REGINALD LYLE, et al. CASE NUMBER: LL ie etal STK-CV-UEO-2016-6523 DEFENDANT/RESPONDENT: DOCTORS HOSPITAL OF MANTECA ING., et at 4. b, Provide.a brief statement of the case, Including any damages: (/f personal injury damages are sought, specify the injury.and damages claimed, including medical expenses to-date [indicate source and amount}, estimated future. medical expenses, Jost eamings to date, and estimated future lost eamings. if equitable reliefis sought, describe the nature of the relief.) Plaintiff brings this putative class action on behalf of-himself.and all.others similarly situated for failure to provide meal and rest breaks, failure to pay minimum hourly and overtime wages, failure to pay wages at termination, and failure to provide accurate wage statemerits Uinder the Labor Code. Plaintiff also alleges unfair competition under the Business & Professions Code. Defendants deny the-entirety. of-Plaintiffs. allegations and deny that Plaintiff's claims are suitable for class treatment. ’ 0 ttmore space is néeded, check this box and attach a page designaled'as Attachment 4b.) §. Jury or nanjury tal ‘The party or parties request Oa jury trial Ha nonjury trial. (If more than one party, provide the name of each.party requesting a jury trial): : . 6. Teal date: oO The trial has been set for (dafe}: .. 4X] 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): Plaintiff will have to move for class certification before the parties can proceed to trial i c. Dates on which parties or altomeys will not be available for trial (specify dates and explain reasons for unavailability): 1 7. Estimated length of trial The party or parties estimate that the trial will take (check one): The estimated od length wil! be unknown until a decision on class certification i is made, a C1 days (specity number: b. [1 hours (short causes) (specify): 8. Trial representation (fo be answered for each patty) a The party or patties will be represented at trial [XJ bythe atiomey ar patty listed in-the caption 11 by the following: a. Altomey: : . b. Firm: i c. “Address: d. Telephone number: 4... Fax number: e. Email address: | g. Party represented: L_- Additional representation i is described In Attachment 8. 9. Preference i This case is antitied to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR# informatian package. Please note that different ADR processes are available in different courts and communitias; 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 D l-has (1 hasnot. provided the ADR information package id identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-1 -represented parties: Party (1 has © (7) has not reviewed the ADR information package identified in.rule 3.221, b. Referral to Judicial arbitration or civil action mediation (if available). (1) 6 This matter is subject to mandatory judicial arbitration under Code of Civil Pracedure 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 [i fimit. (2) O Plaintitt elects to refer this case to judicial arbitration and agrees to:limit recovery to-the amount specified in Cade of Civil Procedure section 1141.11. @ 1 This case is exempt from judicial esbitration under rufe 3.811 of the Califomia Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et-seq. (specify exemption): This is a class action (CA Rule of Court, Rule 3.814(6)(2)). a CASE MANAGEMENT STATEMENT Pagozets sous FonnaWorkFton, comcm-ti0 PLAINTIFPPETTIONER: REGINALD LYLE, etal. Derepantnssrowmen DOCTORS HOSPITAL OF MANTECA ING. etal. CASE NUMBER: STK- Cv. UEO-2016-6823 40. G Indicate the ADR | cco or processes that the party or partles. are wil to participate! ‘in, have. agreed to participate in, or: . have. je aacty pariipated 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 all that apply): ifthe party or parties completing this form inthe case have agreed to: ‘participate in or have already completed an ADR process or processes, ‘indicate the status. of ihe Processes (attach a-copy. of the parties‘ADR stipulation): “(ly Mediation Ri. Mediation cas not yet scheduled . ” Mediation session scheduled for (date): ‘Agréed. to-complete mediation by (date): Mediation: completed-an (date): . * (2) Settlement | ; conference ‘ Oo Settlement conference not yet scheduled Settlement ‘conference scheduled for (date): Agread to | complete settlement conference by (date) : - Settlement sonferenca completed on (date): . (3) Neutral evaluation ‘ ao 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 g arbitration . Judicial arbitration not yet scheduled Judicial arbitration scheduled for (datey: Agreed to complete judicial ‘arbitration by (date): Judicial arbitration conipleted on (date): ) Binding private | oO “ abiirion : Private arbitration not ‘yet scheduled . Private arbitration scheduled for (date):: . Agreed to complete private arbitration by (date): Private arbitration completed on (dale): -() Otter (speci: yoo coog}ocaa coon oono}ooo0o0;o00R8 ADR session not yet scheduled : ADR session scheduled for (date); . Agreed to'compiete.ADR session by (cate): (2) ADR completed on (date): CASE MANAGEMENT STATEMENT | American LegatWet, a. nae ForraWou ow com -Page 3 of §e e 4 CM-110 PLANTIFFPETTIONER: REGINALD LYLE, etal. Tease nouer. 4 STK-CV-UEO-2016-652: [ DereNoaNTmEsPONDENT: DOCTORS HOSPITAL OF MANTECA ING., etal. 3 11. Insurance a. LE) Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights; C] Yes 1 No « O Coverage issues will significantly affect resolution of this case (explain): i 5 | 412. Jurisdiction ' Indicate any matters that may affect the court's jurisdiction c or processing of this case and describe ihe status. 01 Bankruptey a Other (specify): Status;. | 13. Related cases, consolidation, and coordination | - a @ There are companion, underlying, or related cases. (1). Name of case: See Notice of Related Cases, filed concurrently herewith (2) Name of court: - (3) Case number: @) Status: | C2 Additional cases are described in Attachment 13a. b, o Amotion to © consotidate 1 coordinate will be filed by (name party): | 14; Bifurcation 1 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): 15. Other motions. | The party or parties ‘@xpect to file the follewing motions before trial (specify moving party, type of motion, and issues): Defendants anticipate opposing Plaintiff's expected motion for class certification, filing a motion for decertification! and-possibly a motion for summary Judgment. 16. Discovery © | a. [J The party ot parties have completed all discovery. b _The following discovery. will be completed by the date specified (desttibe ait anticipated discovery): Description - Date Defendants Written Discovery TBD t Defendants i Plaintiffs Deposition - : TBD : . : | | cG The following discovery issues, Including issues regarding the discovery of electronically stored information, are anticipated (specify): Defendants request that discovery be bifurcated, with the initial phase focusing only on issues related to class certification. ‘wn Formalverktlow com | H a a CASE MANAGEMENT STATEMENT " Pea ats | I f. | | | @ e chi-110 PLAINTIFEPETITIONER: REGINALD LYLE, etal. | DEFENDANT/RESPONDENT: DOCTORS HOSPITAL OF MANTECA INC., et al; 1 1 17, Economic litigation | a. [1 This isa limited civil case (Le., the amount demanded is $25,060 or fess) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. [1 This isa timited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will ba filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): STK-CV-UEO-2016-6523 18, Other Issues ‘ The party or parties request that the following additional matters be considered or determined at the case management conference (specify): The parties met and conferred regarding class certification, and request that the Court set a further status conference in 90 days to set a class certification deadline. The parties are currently meeting and conferting rgarding discovery in this matter, which will dictate the timing for Plaintiff's anticipated motion for class certification. 19. Meet and confer a, The party or parties have met and conferred with ail partias 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 Califomia Rules of Court, the parties agree on the following (specify): . ' 1 | i { 20. Total number of pages attached (if any): Jam completely familiar ith 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 inta stipulations on these issues at the time of the case management conference, including the written authority of the parly where required. Date: March 27,:2017 Shannon R. Boyce (TYPE OR PRINT NAME) © (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME). . {SIGNATURE OF PARTY OR ATTORNEY) C Additional signatures are attached, i ‘ i ‘ cH FR. 1, 2098 CASE MANAGEMENT STATEMENT Page sts vem FoomWerkFlow commeee NRRBRBRE BS GSN RHE REEOKR SE GS 28 USTTLER manDEL SCH i tic Sapen tar tessa eh Seger sat wow on ou FWY ee . ' F ERVICE l Tam a resident of the State of Callfornia, over the age of eighteen years, and not a party to the within action. My business address is 2049 Century Park East, 5th Floor, Los Angeles, caer 9§0067.3107. On March 27, 2017, I served the within document(s): DEFENDANT'S CASE MANAGEMENT STATEMENT by placing a true copy of the document(s) listed above for collection and mailing : Ex] following the firm’s ordinary business practice in a sealed envelope with postage | thereon fully prepaid for deposit in the United States mail at Los Angeles, | California addressed as set forth below. . Joseph Lavi, Esq. . Vincent C. Granberry, Esq. ‘ LAVI & EBRAHIMIAN, LLP 8889 W. Olympic Boulevard Suite 200 , Beverly Hills, CA 90211 : : Telephone: 310.432.0000 ’ Facsimile: 310.432.0001 ' | atoleys for Plaintiff Reginald Lyle ' | I am readily familiar with the firm's practice of collection and processing correspondence for mailing and for shipping via overnight delivery service. Under that practice it would be deposited with the U.S. Postal Service or if an overnight delivery service shipment, ; deposited in an overnight delivery service pick-up box or office on the same day with postage or i fees thereon fully prepaid In the ordinary course of business. ' I declare under penalty of perjury under the laws of the State of California that the above is true and correct, Executed on March 27, 2027, 2 i Firmwvide:142979786.1 052845,1344 PROOF OF SERVICE