Preview
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
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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:
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16 Attorneys for Plaintiff Attorneys for Defendant
JANE BE DOE BIG BROTHERS BIG SISTERS OF AMERICA
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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
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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.
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4 Kristie Hernandez
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Gordon Rees Scully Mansukhani, LLP
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1111 Broadway, Suite 1700
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Oakland, CA 94607
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CASE MANAGEMENT STATEMENT