Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
Laura A. Wolfe #266751
McCormick Barstow Sheppard Wayte & Carruth LLP E-FILED
7647 N Fresno Street 4/5/2022 11:43 AM
Fresno CA 93720 Superior Court of California
559 433-1300
TELEPHONE NO.: FAX NO. (Optional): 559 433-2300
County of Fresno
laura.wolfe@mccormickbarstow.com
E-MAIL ADDRESS:
By: L. Whipple, Deputy
ATTORNEY FOR (Name): Defendants Pacific Grain & Foods LLC, et al
SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO
1130 O Street
STREET ADDRESS:
MAILING ADDRESS:
Fresno CA 93721
CITY AND ZIP CODE:
B.F. Sisk Courthouse, Civil Unlimited
BRANCH NAME:
PLAINTIFF/PETITIONER: JUAN ZAVALA, et al
DEFENDANT/RESPONDENT: PACIFIC GRAIN & FOODS LLC et al
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE LIMITED CASE
21CECG01658
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: April 21, 2022 Time: 3:30 pm Dept.: 402 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Laura A. Wolfe
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):
b. This statement is submitted jointly by parties (names): Pacific Grain & Foods LLC, Perkins, Abina, Ramirez
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): Disparate
Treatment; Hostile Work Environment; Retaliation; Harassment; Constructive Discharge in Violation of Public
Policy; Civil Assault & Battery; Civil Rights Violations; Wrongful Use of Civil Proceedings; Wage Claims
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
048525-000230 8161768.1
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
PLAINTIFF/PETITIONER: JUAN ZAVALA CASE NUMBER:
DEFENDANT/RESPONDENT: PACIFIC GRAIN & FOODS LLC 21CECG01658
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.) Plaintiffs
contend that they were disparately treated by Defendants, suffered adverse employment actions, hostile
conditions, lost wages, mental suffering, other damages, and constructive discharge. Zavala also alleges he was
physically pushed from Pacific Grain's premises and verbally harassed by Defendants. Plaintiffs seek special and
general damages, penalties, exemplary damages, fees and costs. Defendants deny Plaintiffs' claims.
(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):
Defense counsel anticipates delays related counsel's maternity leave and Covid's impact on the Courts.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Please see Attachment 6 attached hereto and incorporated herein
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 10 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 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):
CCP 1775.5 - potential amount in controversy; CRC 3.811(b)(1) form of relief sought
048525-000230 8161768.1 CM-110 [Rev. September 1, 2021]CASE
MANAGEMENT STATEMENT Page 2 of 5
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CM-110
PLAINTIFF/PETITIONER: JUAN ZAVALA CASE NUMBER:
DEFENDANT/RESPONDENT: PACIFIC GRAIN & FOODS LLC 21CECG01658
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
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
048525-000230 8161768.1 CM-110 [Rev. September 1, 2021]CASE
MANAGEMENT STATEMENT Page 3 of 5
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CM-110
PLAINTIFF/PETITIONER: JUAN ZAVALA CASE NUMBER:
DEFENDANT/RESPONDENT: PACIFIC GRAIN & FOODS LLC 21CECG01658
11. Insurance
a. 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):
Defense counsel anticipates filing a Motion For Summary Judgment/Summary Adjudication of Issues and
motions in limine should this matter proceed to trial. Additionally Defense counsel will be filing a motion to
withdraw as counsel for defendant Raquel Ramirez.
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
Defendants written discovery per code
Defendants depositions per code
Defendants expert discovery per code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
048525-000230 8161768.1 CM-110 [Rev. September 1, 2021]CASE
MANAGEMENT STATEMENT Page 4 of 5
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CM-110
PLAINTIFF/PETITIONER: JUAN ZAVALA CASE NUMBER:
DEFENDANT/RESPONDENT: PACIFIC GRAIN & FOODS LLC 21CECG01658
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):
Pursuant to the Court's ruling of February 23, 2022, Defendants' Demurrer and Motion to Strike Portions of
Plaintiffs' First Amened Complaint were granted in part and denied in part. Plaintiffs were granted leave to
amend and were ordered to serve and file their second amended complaint within 10 days of the court's order.
As of the date of this Case Management Statement, Plaintiffs have not yet filed an amended pleading.
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):
It is Defense counsel's intention to meet and confer with opposing counsel prior to the CMC.
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): 1
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 5, 2022
Laura A. Wolfe â–º
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
â–º
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
048525-000230 8161768.1 CM-110 [Rev. September 1, 2021]CASE
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ATTACHMENT 6c
CMC Statement
ZAVALA v PACIFIC GRAIN & FOODS LLC
SUPERIOR COURT OF FRESNO CASE NO. 21CECG01658
DATE EVENT/DAYS CASE NAME VENUE
07/01/2022- Defense counsel’s anticipated
11/01/2022 maternity leave
10/03/2022 Trial 4-7 days Juarez v Selma Unified School Fresno Superior
District
11/28/2022 Trial 5-9 days Wood v. Sanger Unified School Fresno Superior
District
01/10/2023 Trial 7 days Davis v Patterson Unified School Stanislaus
District Superior
01/31/2023 Trial 5 days Craven-Neely v Modesto City Stanislaus
Schools Superior
03/20/2023 Trial 7 days Underwood v. Allan Hancock Santa Barbara
College Superior
04/10/2023 pending Trial 7 days Aqra v Burton School District Tulare Superior
court approval of
continuance from
08/23/22
04/24/2023 Trial 7 days Todd v West Hills Community Kings Superior
College
05/09/2023 Trial 5 days Shelton v Stanislaus Union School Stanislaus
District Superior
05/29/2023 Trial 3-5 days Jaques v Sylvan School District Stanislaus
Superior
10/30/2023 Trial 5 days Salenik v Floyd Skeren Fresno Superior
Manukian Langevin, LLP
02/06/2024 Trial 5 days JM v Parlier Unified School District USDC-ED
069939-000033 8318082.1 1
PROOF OF SERVICE
Case No. 21CECG01658
STATE OF CALIFORNIA, COUNTY OF FRESNO
4 At the time of service, 1 was over 18 years of age and not a party to this action. I am
employed in the County of Fresno, State of California. My business address is 7647 North Fresno
5 Street, Fresno, OA 93720.
6 On April 5, 2022, I served true copies of the following document(s) described as CASE
MANAGEMENT STATEMENT on the interested parties in this action as follows:
7
ATTORNEYS FOR PLAINTIFFS:
8
Kevin G. Little, Esq.
9 LAW OFFICE OF KEVIN G. LITTLE
Post Office Box 8656
10 Fresno, California 93747
T: (559)342-5800
11 F: (559) 242-2400
Emails:
12 service@,kevinglittle.com
kevin@kevinglittle.com
13 tvler.durnell@,kevinglittle.com
roger@,kevinglittle.com
14
15 BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the
persons at the addresses listed in the Service List and placed the envelope for collection and mailing,
16 following our ordinary business practices. I am readily familiar with this business's practice for
collecting and processing correspondence for mailing. On the same day that the correspondence is
17 placed for collection and mailing, it is deposited in the ordinary course of business with the United
States Postal Service, in a sealed envelope with postage fully prepaid.
18
I declare under penalty of perjury under the laws of the State of California that the foregoing
19 is true and correct.
20 Executed on April 5, 2022, at Fresno, California
21
22
23
24
25
26
27
28
McCormick, Barstow,
Sheppard, Wayte &
Carruth LLP
7647 NORTH FRESNO STREET
FRESNO, OA 93720
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Laura A. Wolfe #266751 McCormick Barstow Sheppard Wayte & Carruth LLP E-FILED 7647 N Fresno Street 4/5/2022 11:43 AM Fresno CA 93720 Superior Court of California 559 433-1300 TELEPHONE NO.: FAX NO. (Optional): 559 433-2300 County of Fresno laura.wolfe@mccormickbarstow.com E-MAIL ADDRESS: By: L. Whipple, Deputy ATTORNEY FOR (Name): Defendants Pacific Grain & Foods LLC, et al SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO 1130 O Street STREET ADDRESS: MAILING ADDRESS: Fresno CA 93721 CITY AND ZIP CODE: B.F. Sisk Courthouse, Civil Unlimited BRANCH NAME: PLAINTIFF/PETITIONER: JUAN ZAVALA, et al DEFENDANT/RESPONDENT: PACIFIC GRAIN & FOODS LLC et al CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE 21CECG01658 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: April 21, 2022 Time: 3:30 pm Dept.: 402 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Laura A. Wolfe 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): b. This statement is submitted jointly by parties (names): Pacific Grain & Foods LLC, Perkins, Abina, Ramirez 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): Disparate Treatment; Hostile Work Environment; Retaliation; Harassment; Constructive Discharge in Violation of Public Policy; Civil Assault & Battery; Civil Rights Violations; Wrongful Use of Civil Proceedings; Wage Claims 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 048525-000230 8161768.1 American LegalNet, Inc. www.FormsWorkFlow.com CM-110 PLAINTIFF/PETITIONER: JUAN ZAVALA CASE NUMBER: DEFENDANT/RESPONDENT: PACIFIC GRAIN & FOODS LLC 21CECG01658 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.) Plaintiffs contend that they were disparately treated by Defendants, suffered adverse employment actions, hostile conditions, lost wages, mental suffering, other damages, and constructive discharge. Zavala also alleges he was physically pushed from Pacific Grain's premises and verbally harassed by Defendants. Plaintiffs seek special and general damages, penalties, exemplary damages, fees and costs. Defendants deny Plaintiffs' claims. (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): Defense counsel anticipates delays related counsel's maternity leave and Covid's impact on the Courts. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Please see Attachment 6 attached hereto and incorporated herein 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 10 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 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): CCP 1775.5 - potential amount in controversy; CRC 3.811(b)(1) form of relief sought 048525-000230 8161768.1 CM-110 [Rev. September 1, 2021]CASE MANAGEMENT STATEMENT Page 2 of 5 American LegalNet, Inc. www.FormsWorkFlow.com CM-110 PLAINTIFF/PETITIONER: JUAN ZAVALA CASE NUMBER: DEFENDANT/RESPONDENT: PACIFIC GRAIN & FOODS LLC 21CECG01658 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 (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): 048525-000230 8161768.1 CM-110 [Rev. September 1, 2021]CASE MANAGEMENT STATEMENT Page 3 of 5 American LegalNet, Inc. www.FormsWorkFlow.com CM-110 PLAINTIFF/PETITIONER: JUAN ZAVALA CASE NUMBER: DEFENDANT/RESPONDENT: PACIFIC GRAIN & FOODS LLC 21CECG01658 11. Insurance a. 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): Defense counsel anticipates filing a Motion For Summary Judgment/Summary Adjudication of Issues and motions in limine should this matter proceed to trial. Additionally Defense counsel will be filing a motion to withdraw as counsel for defendant Raquel Ramirez. 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 Defendants written discovery per code Defendants depositions per code Defendants expert discovery per code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): 048525-000230 8161768.1 CM-110 [Rev. September 1, 2021]CASE MANAGEMENT STATEMENT Page 4 of 5 American LegalNet, Inc. www.FormsWorkFlow.com CM-110 PLAINTIFF/PETITIONER: JUAN ZAVALA CASE NUMBER: DEFENDANT/RESPONDENT: PACIFIC GRAIN & FOODS LLC 21CECG01658 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): Pursuant to the Court's ruling of February 23, 2022, Defendants' Demurrer and Motion to Strike Portions of Plaintiffs' First Amened Complaint were granted in part and denied in part. Plaintiffs were granted leave to amend and were ordered to serve and file their second amended complaint within 10 days of the court's order. As of the date of this Case Management Statement, Plaintiffs have not yet filed an amended pleading. 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): It is Defense counsel's intention to meet and confer with opposing counsel prior to the CMC. 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): 1 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 5, 2022 Laura A. Wolfe ► (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) ► (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. 048525-000230 8161768.1 CM-110 [Rev. September 1, 2021]CASE MANAGEMENT STATEMENT Page 5 of 5 American LegalNet, Inc. www.FormsWorkFlow.com ATTACHMENT 6c CMC Statement ZAVALA v PACIFIC GRAIN & FOODS LLC SUPERIOR COURT OF FRESNO CASE NO. 21CECG01658 DATE EVENT/DAYS CASE NAME VENUE 07/01/2022- Defense counsel’s anticipated 11/01/2022 maternity leave 10/03/2022 Trial 4-7 days Juarez v Selma Unified School Fresno Superior District 11/28/2022 Trial 5-9 days Wood v. Sanger Unified School Fresno Superior District 01/10/2023 Trial 7 days Davis v Patterson Unified School Stanislaus District Superior 01/31/2023 Trial 5 days Craven-Neely v Modesto City Stanislaus Schools Superior 03/20/2023 Trial 7 days Underwood v. Allan Hancock Santa Barbara College Superior 04/10/2023 pending Trial 7 days Aqra v Burton School District Tulare Superior court approval of continuance from 08/23/22 04/24/2023 Trial 7 days Todd v West Hills Community Kings Superior College 05/09/2023 Trial 5 days Shelton v Stanislaus Union School Stanislaus District Superior 05/29/2023 Trial 3-5 days Jaques v Sylvan School District Stanislaus Superior 10/30/2023 Trial 5 days Salenik v Floyd Skeren Fresno Superior Manukian Langevin, LLP 02/06/2024 Trial 5 days JM v Parlier Unified School District USDC-ED 069939-000033 8318082.1 1 PROOF OF SERVICE Case No. 21CECG01658 STATE OF CALIFORNIA, COUNTY OF FRESNO 4 At the time of service, 1 was over 18 years of age and not a party to this action. I am employed in the County of Fresno, State of California. My business address is 7647 North Fresno 5 Street, Fresno, OA 93720. 6 On April 5, 2022, I served true copies of the following document(s) described as CASE MANAGEMENT STATEMENT on the interested parties in this action as follows: 7 ATTORNEYS FOR PLAINTIFFS: 8 Kevin G. Little, Esq. 9 LAW OFFICE OF KEVIN G. LITTLE Post Office Box 8656 10 Fresno, California 93747 T: (559)342-5800 11 F: (559) 242-2400 Emails: 12 service@,kevinglittle.com kevin@kevinglittle.com 13 tvler.durnell@,kevinglittle.com roger@,kevinglittle.com 14 15 BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the persons at the addresses listed in the Service List and placed the envelope for collection and mailing, 16 following our ordinary business practices. I am readily familiar with this business's practice for collecting and processing correspondence for mailing. On the same day that the correspondence is 17 placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid. 18 I declare under penalty of perjury under the laws of the State of California that the foregoing 19 is true and correct. 20 Executed on April 5, 2022, at Fresno, California 21 22 23 24 25 26 27 28 McCormick, Barstow, Sheppard, Wayte & Carruth LLP 7647 NORTH FRESNO STREET FRESNO, OA 93720