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  • Jane Doe vs BIG BROTHERS BIG SISTERS OF AMERICA, a California corporation, et al.Other PI/PD/WD Unlimited (23) document preview
  • Jane Doe vs BIG BROTHERS BIG SISTERS OF AMERICA, a California corporation, et al.Other PI/PD/WD Unlimited (23) document preview
  • Jane Doe vs BIG BROTHERS BIG SISTERS OF AMERICA, a California corporation, et al.Other PI/PD/WD Unlimited (23) document preview
  • Jane Doe vs BIG BROTHERS BIG SISTERS OF AMERICA, a California corporation, et al.Other PI/PD/WD Unlimited (23) document preview
  • Jane Doe vs BIG BROTHERS BIG SISTERS OF AMERICA, a California corporation, et al.Other PI/PD/WD Unlimited (23) document preview
  • Jane Doe vs BIG BROTHERS BIG SISTERS OF AMERICA, a California corporation, et al.Other PI/PD/WD Unlimited (23) document preview
  • Jane Doe vs BIG BROTHERS BIG SISTERS OF AMERICA, a California corporation, et al.Other PI/PD/WD Unlimited (23) document preview
  • Jane Doe vs BIG BROTHERS BIG SISTERS OF AMERICA, a California corporation, et al.Other PI/PD/WD Unlimited (23) document preview
						
                                

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CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Paul Caleo (SBN 153925) Mark Heisey (SBN 300141) Gordon Rees Scully Mansukhani. LLP 1111 Broadway, Suite 1700 Oakland, California94607 TELEPHONE NO.: (510) 463-8600 (510) 984-1721 FAX NO. (Optional): E-MAIL ADDRESS (Optional): pcaleo@grsm.com; mheisey@grsm.com ATTORNEY FOR (Name): Defendant BOYS & GIRLS CLUB OF MONTEREY COUNTY SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY STREET ADDRESS:1200 Aguajito Road MAILING ADDRESS: Monterey, CA 93940 CITY AND ZIP CODE: BRANCH NAME: PLAINTIFF/PETITIONER: JANE BE DOE DEFENDANT/RESPONDENT: BIG BROTHERS BIG SISTERS OF AMERICA, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE (Amount demanded (Amount demanded is $25,000 21CV000805 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 17, 2022 Time: 10:00 a.m. Dept.: 15 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Mark J. Heisey 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): Defendant BOYS & GIRLS CLUB OF MONTEREY COUNTY 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, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. The following parties named in the complaint or cross-complaint (1) have not been served (specify names and explain why not): (2) have been served but have not appeared and have not been dismissed (specify names): (3) have had a default entered against them (specify names): c. The following 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. Type of case in complaint cross-complaint (Describe, including causes of action): Plaintiff alleges emotional distress, negligence, breach of duty, fraud and sexual harassment Page 1 of 5 Form Adopted for Mandatory Use Judicial Council of California CASE MANAGEMENT STATEMENT Cal. Rules of Court, rules 3.720–3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov www.CalCourtForms.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: JANE BE DOE DEFENDANT/RESPONDENT: BIG BROTHERS BIG SISTERS OF AMERICA, et al. 21CV000805 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 alleges she was sexually abused as a minor. BGCMC defers to Plaintiff's description of the specific damages alleged. (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request a jury triaI a nonjury 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. 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 parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): See attachment. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 5-7 days 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: 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 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 has has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) 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) 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): CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT www.CalCourtForms.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: JANE BE DOE DEFENDANT/RESPONDENT: BIG BROTHERS BIG SISTERS OF AMERICA, et al. 21CV000805 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 all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled Settlement conference scheduled for (date): (2) Settlement conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled Judicial arbitration scheduled for (date): (4) Nonbinding judicial arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled Private arbitration scheduled for (date): (5) Binding private arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT www.CalCourtForms.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: JANE BE DOE DEFENDANT/RESPONDENT: BIG BROTHERS BIG SISTERS OF AMERICA, et al. 21CV000805 11. Insurance a. Great American Insurance Group Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes No c. 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. Bankruptcy Other (specify): Status: 13. Related cases, consolidation, and coordination a. There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: Additional cases are described in Attachment 13a. b. A motion to consolidate coordinate wiII be filed by (name party): 14. Bifurcation 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 expect to file the following motions before trial (specify moving party, type of motion, and issues): Motion for Summary Judgment 16. Discovery a. 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 Defendant Written Discovery July 2022 Defendant Expert Discovery Per Code Defendant Depositions August 2022 c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT www.CalCourtForms.com Trial List Case Management Statement Attachment No. Case & Venue Trial MSC Date Misc. Date 1. O'Kane, Thomas and Sharon v. Walgreen's 4/20/22 San Francisco County 2. Morales, Francisca Raygoza v Dollar Tree 5/2/22 3/21/22 TRC: 4/20/22 CASE SETTLED 3. Weigandt-Thompson, Patricia v Sacramento 5/3/22 3/28/22 Sacramento County 4. Naji, Razzak v Albertsons Companies, LLC 6/3/22 Sonoma County 5. Robles v. ACCWC 6/20/22 Alameda County 6. Paul Caleo, Esq. – Out of Office 6/27/22 to 7/1/22 7. Chi Chi Beignet, Inc., et al. v. Jack in the Box 6/29/22 San Francisco County 8. Caldwell v De Oliveira, Marcelo 7/18/22 Issues Conf.: 7/7/22 Contra Costa County 9. Ross, Ray v. Walgreens Co. dba Walgreens 8/8/22 San Francisco County 10. Grubbs, Helen v Walgreen Co., et al. 8/29/22 8/8/21 San Joaquin County 11. Bland, Jack v. Lorne Manly and PV Holding Corp. 9/2/22 Sonoma County 12. Thompson, Bobbie v Family Dollar Stores 9/19/22 SC.: 9/6/22 Los Angeles County 13. Jamerson, Tyra v. Starbucks Corporation 9/26/22 TRC.: 9/19/22 Humboldt County 14. Haycraft, Shaman v. Starbucks Corp. 10/3/22 8/18/22 PTC: 9/16/22 San Mateo County 15. Strong, Jack v. Starbucks 10/24/22 San Francisco County 16. White, Edward v. Walgreen Co. 10/25/22 10/10/22 Stanislaus County 17. Jorge Najera-Ceja v. Walgreen Co. 10/31/22 Alameda County 18. Keitel, Todd v Specialized Bicycle Compo 10/31/22 Alameda County 19. Green, Erica v Sutter Health, Inc. 10/31/22 PTC: 10/21/22 Alameda County Trial List Case Management Statement Attachment 20. McCracken v. City of Riverside 11/4/22 TRC: 10/28/22 River Side County 21. Lague, Marybeth v. Property Management 415, Inc. 11/7/22 San Francisco County 22. Franzino v Washington Outpatient Surgery Center 11/7/22 Alameda County 23. Vagenas, Linda v. Dollar Tree Stores 11/15/22 10/17/22 Stanislaus County 24. Johnson, Beverly v. Dollar Tree 11/28/22 10/26/22 TRC: 11/18/22 CASE SETTLED 25. Angulo, Adelio v. Juan Munoz Granados 12/6/22 11/14/22 Stanislaus County 26. Kim, Edward v. Starbucks Corp. 1/9/23 1/4/23 Santa Clara County 27. Doe (C.L.) v. University Club 1/30/23 San Francisco County 28. Lujan, Nancy v Gokstad Group LP, et al. 2/21/23 TRC: 2/16/23 San Bernardino County 29. Marco Flores v. BC Systems, Inc., et al. 3/26/23 2/3/23 Monterey County 30. Newman, Nicole R. v Starbucks 9/5/2023 8/7/23 San Joaquin County 31. Zavalza, Marcelina v. Dollar Tree 9/11/23 8/15/23 TRC: 9/8/23 Fresno County SC = STATUS CONF. TRC = TRIAL READINESS CONF. PTC = PRE TRIAL CONF. 1 PROOF OF SERVICE Doe, Jane (B.E.) v. Boys & Girls Clubs of Monterey 2 Monterey Superior Court, Case No.: 21CV000805 3 I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is: Gordon Rees Scully Mansukhani, LLP 275 Battery 4 Street, Suite 2000 San Francisco, CA 94111. On the date set forth below, I served the within documents: 5 CASE MANAGEMENT STATEMENT 6 7  by transmitting via facsimile the document(s) listed above to the fax number(s) set forth below on this date before 5:00 p.m. 8  VIA E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the document(s) to be sent by electronically mailing a true and correct copy through the Gordon Rees Scully Mansukhani, LLP electronic mail system from my email address: 9 khernandez@grsm.com, to the email address(s) set forth herein. 10  by having Nationwide PERSONALLY DELIVER the document(s) listed above to the person(s) at the address(es) set forth below. Gordon Rees Scully Mansukhani, LLP 11  by placing the document(s) listed above in a sealed envelope with postage thereon 1111 Broadway, Suite 1700 12 fully prepaid, in United States mail in the State of California at San Francisco, Oakland, CA 94607 addressed as set forth below. 13  by placing a true copy thereof enclosed in a sealed envelope, at a station designated for collection and processing of envelopes and packages for overnight delivery by 14 FEDEX as part of the ordinary business practices of Gordon Rees Scully Mansukhani, LLP described below, addressed as follows: 15 16 Attorneys for Plaintiff Attorneys for Defendant JANE BE DOE BIG BROTHERS BIG SISTERS OF AMERICA 17 John C. Manly, Esq. Alison M. Crane, Esq. 18 Vince W. Finaldi, Esq. BLEDSOE, DIESTEL, TREPPA & CRANE Alex E. Cunny, Esq. LLP 19 Courtney P. Pendry, Esq. MANLY, STEWART & FINALDI 180 Sansome, 5th Floor 20 19100 Von Karman Ave., Suite 800 San Francisco, CA 94104 Irvine, CA 92612 Tel: (415) 981-5411 21 Tel: (949) 252-9990. Fax: (415) 981-0352 Fax: (949) 252-9991 Email: acrane@bledsoelaw.com 22 Email: jmanly@manlystewart.com tmurray@bledsoelaw.com vfinaldi@manlystewart.com calendar@bledsoelaw.com 23 acunny@manlysteward.com cpendry@manlystewart.com 24 kfrederiksen@manlystewart.com 25 26 27 28 -1- CASE MANAGEMENT STATEMENT 1 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 2 Executed on April 28, 2022 at San Francisco, California. 3 4 Kristie Hernandez 5 6 7 8 9 10 Gordon Rees Scully Mansukhani, LLP 11 1111 Broadway, Suite 1700 12 Oakland, CA 94607 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- CASE MANAGEMENT STATEMENT