Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
James J. Zenere SBN 151724
ZENERE COWDEN & STODDARD APC
2005 De La Cruz Boulevard, Suite 240
Santa Clara CA 95050
TELEPHONE NO.:(408)430-3551 FAX NO. (Optional):
jzenere@zcslawfirm.com
E-MAIL ADDRESS:
Defendant ALBERTO BOLANOS, M.D.
ATTORNEY FOR (Name):
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO
STREET ADDRESS:400 County Center
400 County Center
MAILING ADDRESS:
Redwood City CA
CITY AND ZIP CODE: 94063
BRANCH NAME:
PLAINTIFF/PETITIONER: FRANK SHEE
DEFENDANT/RESPONDENT: ALBERTO BOLANOS, M.D.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE LIMITED CASE 21-CIV-00632
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: May 18, 2022 Time: 9:00 a.m. Dept.: 34 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): James J. Zenere
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 ALBERTO BOLANOS, M.D.
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 medical negligence regarding shoulder surgery.
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California
CASE MANAGEMENT STATEMENT rules 3.720–3.730
CM-110 [Rev. September 1, 2021] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: FRANK SHEE CASE NUMBER:
DEFENDANT/RESPONDENT: ALBERTO BOLANOS, M.D. 21-CIV-00632
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 medical negligence regarding shoulder surgery.
(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. (if
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
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Trials Scheduled: 7/11/22; 8/29/22; 9/12/22; 3/13/23; 4/17/23; 7/17/23; 8/14/23
Vacations: 7/21/22-7/31/22; 10/10/22-10/15/22; 12/22/22-1/6/23
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. 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: James J. Zenere
b. Firm: Zenere Cowden & Stoddard APC
c. Address: 2005 De La Cruz Boulevard, Suite 240, Santa Clara CA 95050
d. Telephone number: (408)430-3551 f. Fax number:
e. E-mail address: jzenere@zcslawfirm.com g. Party represented: Alberto Bolanos, M.D.
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 of the California Rules of Court 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. September 1, 2021] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: FRANK SHEE CASE NUMBER:
DEFENDANT/RESPONDENT: ALBERTO BOLANOS, M.D. 21-CIV-00632
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
(2) Settlement Settlement conference scheduled for (date):
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
(4) Nonbinding judicial Judicial arbitration scheduled for
(date):
arbitration Agreed to complete judicial arbitration by(date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for(date):
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):
Premature Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. September 1, 2021] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: FRANK SHEE CASE NUMBER:
DEFENDANT/RESPONDENT: ALBERTO BOLANOS, M.D. 21-CIV-00632
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name): The Medical Protective
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
(specify moving party, type of motion, and issues):
The party or parties expect to file the following motions before trial
Motion to Compel Responses to Discovery (set for October 17, 2022), Potential 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 Bolanos, M.D. Written Discovery Past Due
Deposition of Plaintiff TBD
Depositions of Witnesses TBD
Depositions of Experts Per Code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Plaintiff has failed to respond to any written discovery, which is now several months past due.
A motion to compel discovery
responses has been filed and is set for hearing on October 17, 2022.
CM-110 [Rev. September 1, 2021] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: FRANK SHEE CASE NUMBER:
DEFENDANT/RESPONDENT: ALBERTO BOLANOS, M.D. 21-CIV-00632
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
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
Plaintiff has failed to respond to any written discovery, which is now several months past due.
A motion to compel discovery
responses has been filed and is set for hearing on October 17, 2022.
19. Meet and confer
a. 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):
I am 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: April 29, 2022
James J. Zenere
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev. September 1, 2021] Page 5 of 5
CASE MANAGEMENT STATEMENT
1 PROOF OF SERVICE
[CCP §§ 1012.5, 1013a and 2015.5; CRC 2008]
2
3 I am a citizen of the United States. My business address is 2005 De La Cruz, Suite 240,
Santa Clara, CA 95050. I am employed in Santa Clara County where this service occurred. I am
4 over the age of 18 years and not a party to the within cause. I am readily familiar with my
employer's normal business practice for collection and processing of correspondence for mailing
5 and facsimile. In the case of mailing [other than overnight delivery], the practice is that
6 correspondence is deposited in the U.S. Postal Service the same day as the day of collection in
the ordinary course of business.
7
On Friday, April 29, 2022, I served the within CASE MANAGEMENT
8
STATEMENT on the PARTIES in said action as follows:
9
Frank Shee Robert S. Willoughby, Esq.
10 105 Lucca Drive Alexandra C. Seibert, Esq.
South San Francisco, CA 94080 HASSARD BONNINGTON LLP
11 Tel: (650) 438-5897 275 Battery St., Suite 1600
frankshee03@yahoo.com San Francisco, CA 94111
12 Telephone: (415) 288-9800
Fax: (415) 288-9801
13 rsw@hassard.com
acs@hassard.com
14 kij@hassard.com
Attorneys for Defendant
15 SUTTER BAY HOSPITALS dba MILLS
16 PENINSULA HEALTH SERVICES
17 ☐ (BY MAIL) I caused a true copy of each document identified above to be placed in a sealed
envelope with first-class postage affixed. Each such envelope was deposited for collection and
18
mailing that same day in the ordinary course of business in the United States mail at San Jose,
19 California.
20 ☐ (BY PERSONAL SERVICE) I caused a true copy of each document identified above to be
21 delivered by hand to the offices of each addressee above.
22 ☐ (BY OVERNIGHT DELIVERY) I caused a true copy of each document identified above to
be sealed in an envelope to be delivered to an overnight carrier with delivery fees provided for,
23
addressed of each addressee above.
24
☒ (BY-E-MAIL OR ELECTRONIC TRANSMISSION) Based on a court order or an
25 agreement of the parties to accept service by e-mail or electronic transmission, I caused the
26 document(s) to be sent to the persons at the e-mail address listed above. I did not receive,
within a reasonable time after the transmission, any electronic message or other indication that
27 the transmission was unsuccessful.
28
☐ (BY ELECTRONIC SERVICE) I caused each of the above-named documents to be
delivered by email to the parties via One Legal E-Service upload link.
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☒ (STATE) I declare under penalty of perjury under the laws of the State of California that the
2
above is true and correct.
3
☐ (FEDERAL) I declare that I am employed in the office of a member of the bar of this court
4 at whose direction the service was made.
5
Diane Point
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Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY James J. Zenere SBN 151724 ZENERE COWDEN & STODDARD APC 2005 De La Cruz Boulevard, Suite 240 Santa Clara CA 95050 TELEPHONE NO.:(408)430-3551 FAX NO. (Optional): jzenere@zcslawfirm.com E-MAIL ADDRESS: Defendant ALBERTO BOLANOS, M.D. ATTORNEY FOR (Name): SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO STREET ADDRESS:400 County Center 400 County Center MAILING ADDRESS: Redwood City CA CITY AND ZIP CODE: 94063 BRANCH NAME: PLAINTIFF/PETITIONER: FRANK SHEE DEFENDANT/RESPONDENT: ALBERTO BOLANOS, M.D. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE 21-CIV-00632 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 18, 2022 Time: 9:00 a.m. Dept.: 34 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): James J. Zenere 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 ALBERTO BOLANOS, M.D. 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 medical negligence regarding shoulder surgery. Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730 CM-110 [Rev. September 1, 2021] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: FRANK SHEE CASE NUMBER: DEFENDANT/RESPONDENT: ALBERTO BOLANOS, M.D. 21-CIV-00632 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 medical negligence regarding shoulder surgery. (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. (if 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 not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Trials Scheduled: 7/11/22; 8/29/22; 9/12/22; 3/13/23; 4/17/23; 7/17/23; 8/14/23 Vacations: 7/21/22-7/31/22; 10/10/22-10/15/22; 12/22/22-1/6/23 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. 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: James J. Zenere b. Firm: Zenere Cowden & Stoddard APC c. Address: 2005 De La Cruz Boulevard, Suite 240, Santa Clara CA 95050 d. Telephone number: (408)430-3551 f. Fax number: e. E-mail address: jzenere@zcslawfirm.com g. Party represented: Alberto Bolanos, M.D. 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 of the California Rules of Court 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. September 1, 2021] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: FRANK SHEE CASE NUMBER: DEFENDANT/RESPONDENT: ALBERTO BOLANOS, M.D. 21-CIV-00632 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 (2) Settlement Settlement conference scheduled for (date): 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 (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by(date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for(date): 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): Premature Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. September 1, 2021] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: FRANK SHEE CASE NUMBER: DEFENDANT/RESPONDENT: ALBERTO BOLANOS, M.D. 21-CIV-00632 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): The Medical Protective 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 (specify moving party, type of motion, and issues): The party or parties expect to file the following motions before trial Motion to Compel Responses to Discovery (set for October 17, 2022), Potential 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 Bolanos, M.D. Written Discovery Past Due Deposition of Plaintiff TBD Depositions of Witnesses TBD Depositions of Experts Per Code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): Plaintiff has failed to respond to any written discovery, which is now several months past due. A motion to compel discovery responses has been filed and is set for hearing on October 17, 2022. CM-110 [Rev. September 1, 2021] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: FRANK SHEE CASE NUMBER: DEFENDANT/RESPONDENT: ALBERTO BOLANOS, M.D. 21-CIV-00632 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 The party or parties request that the following additional matters be considered or determined at the case management conference (specify): Plaintiff has failed to respond to any written discovery, which is now several months past due. A motion to compel discovery responses has been filed and is set for hearing on October 17, 2022. 19. Meet and confer a. 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): I am 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: April 29, 2022 James J. Zenere (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. September 1, 2021] Page 5 of 5 CASE MANAGEMENT STATEMENT 1 PROOF OF SERVICE [CCP §§ 1012.5, 1013a and 2015.5; CRC 2008] 2 3 I am a citizen of the United States. My business address is 2005 De La Cruz, Suite 240, Santa Clara, CA 95050. I am employed in Santa Clara County where this service occurred. I am 4 over the age of 18 years and not a party to the within cause. I am readily familiar with my employer's normal business practice for collection and processing of correspondence for mailing 5 and facsimile. In the case of mailing [other than overnight delivery], the practice is that 6 correspondence is deposited in the U.S. Postal Service the same day as the day of collection in the ordinary course of business. 7 On Friday, April 29, 2022, I served the within CASE MANAGEMENT 8 STATEMENT on the PARTIES in said action as follows: 9 Frank Shee Robert S. Willoughby, Esq. 10 105 Lucca Drive Alexandra C. Seibert, Esq. South San Francisco, CA 94080 HASSARD BONNINGTON LLP 11 Tel: (650) 438-5897 275 Battery St., Suite 1600 frankshee03@yahoo.com San Francisco, CA 94111 12 Telephone: (415) 288-9800 Fax: (415) 288-9801 13 rsw@hassard.com acs@hassard.com 14 kij@hassard.com Attorneys for Defendant 15 SUTTER BAY HOSPITALS dba MILLS 16 PENINSULA HEALTH SERVICES 17 ☐ (BY MAIL) I caused a true copy of each document identified above to be placed in a sealed envelope with first-class postage affixed. Each such envelope was deposited for collection and 18 mailing that same day in the ordinary course of business in the United States mail at San Jose, 19 California. 20 ☐ (BY PERSONAL SERVICE) I caused a true copy of each document identified above to be 21 delivered by hand to the offices of each addressee above. 22 ☐ (BY OVERNIGHT DELIVERY) I caused a true copy of each document identified above to be sealed in an envelope to be delivered to an overnight carrier with delivery fees provided for, 23 addressed of each addressee above. 24 ☒ (BY-E-MAIL OR ELECTRONIC TRANSMISSION) Based on a court order or an 25 agreement of the parties to accept service by e-mail or electronic transmission, I caused the 26 document(s) to be sent to the persons at the e-mail address listed above. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that 27 the transmission was unsuccessful. 28 ☐ (BY ELECTRONIC SERVICE) I caused each of the above-named documents to be delivered by email to the parties via One Legal E-Service upload link. 1 1 ☒ (STATE) I declare under penalty of perjury under the laws of the State of California that the 2 above is true and correct. 3 ☐ (FEDERAL) I declare that I am employed in the office of a member of the bar of this court 4 at whose direction the service was made. 5 Diane Point 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2