Preview
CM-110
ATTORNEY G8 PARTY Wr HGUT ATTORNEY (Mame, Slate Bar number and adaress)
Ned E. Dunphy SBN: 128601
THE LAW OFFICES YOUNG WOOLDRIDGE, LLP
1800 30th Street. Fourth Floor,
Bakersficld. CA 93301
TeLepuovz no 661-327-966) FAK NO. Optanall. 661-327-1087
Bwalacoress. ndunphy@youngwooldridge.com
ATTORNEY FOR (Neme!: Plaintiffs, Levi Cole Mass, a minor, and Aiden Lee Moss, a minor
SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN
STREET ADORESS = 1215 Truxtun Avenue
MARING ADDRESS 1215 Truxtun Avenue
SMV ANDZIF COPE. Bakersfield, 93301
BRANCH MAE Metro Justice Building
PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor
DEFENDANT/RESPONDENT: Noe Garcia, et al.
FOR COURT USE ONLY
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): [_X_] UNLIMITED CASE (J LIMITED CASE BCV 19-103330 CW/
(Amount demanded {Amount demanded is $25,000
exceeds $25,000) or less} BCV 20-102977 and BCV-21-101449
iA CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: July 27, 2022 Time:$:30 a.m. Dept. Ow.
[Address of court (if different from the address above):
[[X_] Notice of intent to Appear by Telephone, by (name): Ned E. Dunphy
Room:
INSTRUCTIONS: Alt applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
b. This statement is submitted jointly by patties (names):
This statement is submitted by party (name): Plaintiffs, Levi Cole Moss and Aiden Lee Moss
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): December 21, 2020
b, [77] 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 Fave been served, have appeared, or have been dismissed.
b. [_] The following parties named in the complaint or cross-complaint
(4) [[5J have not been served (specify names and explain why nol):
(2) [C7] have been served but have not appeared and have not been dismissed (specify names): Eric Sertic
(3) [°7] 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 ofcasein [-X] complaint ~~] cross-complaint (Describe, inckiding causes of action): Motor vehicle
accident resulting in wrongful death.
Page 1 of §
Fern ree or acetone CASE MANAGEMENT STATEMENT ‘ak Roles of Cou.
ew courts.ca gor
CM-480 [Rey Septamber 1. 2021}
\Wesaw Doc For BrCM-110
: PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor CASE VUMBER:
| DEFENDANT/RESPONDENT: Noe Garcia, et al. BCV 20-102977 and BCV-21-101449
4. b. Provide a brief statement of the case, including any damages (if personal injury damages are sought, specify the injury and
damages clajined, 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, Levi Cole Moss and Aiden Lee Moss are the chilcren of Kylee Jordan Moss, Deceased. Plaintiffs suffered loss of
love, companionship, comfort, care, assistance and protection,
{if more space is needed. check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury triat
The party or parties request [X"] a jury trial anonjury trial. (Hf more than one party. provide the name of each party
requesting a jury trial):
6. Trial date
a. [[_] The trial has been set for (daie).
b. [7X"] 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}:
¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
41/14/22-11/25/22; 05/01/23-05/08/23; 05/22/23-05/29/23 duc to other trials currently set.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a, days (specify number): 7-10
b. ["] hours (short causes) (specify):
8. Trial representation (to fe answered for each party)
The party or parties will be represented at trial hy the attorney or party listed in the caption [7] by the following:
a. Attorney:
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
[1] This case is entitied to preference (specify code section):
10. Alternative dispute resolution (ADR)
@. 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 pragrarrs in this case.
(1) For parties represented by counsel: Counsel [7] 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 efects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.17
(3) [_] This case is exempt from judicial arbitration under rule 3.811 of the California Rujes of Court or from civit action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CMTTO Rev Seprember #, 2027} CASE MANAGEMENT STATEMENT Page 2 of 5CM-110
PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lec Moss, a Minor
DEFENDANT/RESPONDENT: x,
‘oe Garcia, et al.
CASE VUMBER
BCV 20- 102977 and BCV-21-101449
10. ¢. 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 afi that apply and provide 'he specified information):
The party or parties completing
Ithis form are willing to
participate in the following ADR:
processes (check ail that apply):
If the party or parties completing this form in the case have agreed to
participate in or have already completed an ADR process or processes,
indicate the status of the processes (attach a copy of the parties' ADR
stipulation).
(1) Mediation
(36) Mediation session not yet scheduled
{[7] Mediation session scheduled for (date):
{[_] Agreed to complete mediation by (date):
[[7] Mediation compieted on (date):
(2) Settlement
conference
[2€1 Settlement conference not yet scheduled
[7] Settlement conference scheduled for (date).
[__] Agreed to complete settlement conference by (date):
[7] Settiement conference completed on (date):
[2] Neutral evaluation nat yet scheduled
[[7] Neutrat evatuation scheduled for (date)
(3) Neutral evaluation Co
{<7 ] Agreed to complete neutral evaluation by (date):
[| Neutral evaluation completed on (date):
(J Judicial arbitration not yet scheduled
{4) Nonbinding judicial co [J] Judicial arbitration scheduled for (date):
arbitration Agreed to complete judicial arbitration by (date):
(7) Judiciat arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Co ({] Private arbitration scheduled for (date):
arbitration (7) Agreed to complete private arbitration by (date):
[C7] Private arbitration completed on (date):
ADR session not yet scheduled
(6) Other (specify): co [7] ADR session scheduled for (date):
[7] Agreed to complete ADR session by (date):
[C7] ADR completed on (date):
GM-10 (Rev September 1, 2021]
CASE. MANAGEMENT STATEMENT
Page dofsCM-110
PLAINTIFFPETITIONER: Levi Cole Moss, a minor ,and Aiden Lee Moss, a Minor | case wwoee
DEFENDANT/RESPONDENT. Noe Garcia, ct al. BCV 20-102977 and BCV-21-101449
11. Insurance
a. ["_] Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: [J Yes [77] No
c, [7] Coverage issues will significantly affect resolution of this case (expiain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
[__] Bankruptey Other (specify):
Status:
43. Related cases, consolidation, and coordination
a There are companion, underlying, or related cases.
(1) Name of case: Sertic v. Garcia, ct al.
(2) Name of court: Kern County Superior Court
(3) Case number BCV-19-103330
(4) Status: consolidated with BCV-20-102977
[-_] Additional cases are described in Attachment 13a.
b. [_] Amotionto — [_] consolidate (C] coordinate will be filed by (name party):
14. Bifurcation
[7] The patty 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).
1. Other motions
[2] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motions in Limine
16. Discovery
a. [J The party or parties have completed all discovery.
b. [XJ The following discovery will be completed by the date specified (describe all anticipated discovery):
Party, Description Date
Plaintiffs Deposition of Defendant October, 2022
Plaintiffs Depositions of several PMKS October, 2022
Plaintiffs Further written Discovery November, 2022
Plaintiffs Expert Discovery per code
Plaintiffs Supplemental Discovery per code
c. [""} The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify).
EMG Rew Senterer 1 2071] CASE MANAGEMENT STATEMENT Pages ofSCM-110
PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor CASE NUMBER:
DEFENDANTIRESPONDENT: Ning Gai etal BCV 20-102977 and BCV-21-40449
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 fo this case.
b. This is a limited civil case and a motion to withdraw the case from the economic iitigation 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). Defendant, Eric Sertic is facing criminal charges as a result of the accident. Preliminary hearing
is scheduled for July 12, 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 nat. 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):
} am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as weil 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 F- 13-QoA2 SI
NED _E. DUNPHY > Z )
(TYPE 08 PRIS NAVE (sent
>
(PE OF PRINT NAMED (SIGNATURE OF PARTY OR ATTORNEY}
[“] Additional signatures are attached.
CAETTO Bey Serember 120] CASE MANAGEMENT STATEMENT Page 5 ofSihe Law Offices Of
gy PROOF OF SERVICE
2 2|| STATE OF CALIFORNIA, COUNTY OF KERN
&
: 3 1, YESENIA LAMBARENA, declare: | am and was at the times of the service hereunder
2 4 mentioned, over the age of eighteen (18) years, and not a party to the within cause. My business address is
g The Westchester Corporate Plaza, 1800 30th Street, Fourth Floor, Bakersfield, CA 93301,
2
: 5 On July 13, 2022, I caused to be served the below listed document(s) titled as: CASE
5 6|| MANAGEMENT STATEMENT on the interested parties in this action, as listed below:
g
& 7
8 8 See Attached Service List
met ill (BY MAIL), pursuant to C.C.P. § 1013(a). By placing /__/ the original or /.x/ a true copy
422 thereof enclosed in a sealed envelope. | am readily familiar with the firm's practice of
se . Ps 'y
ca YT collection and processing of documents for mailing. Under that practice it would be deposited
oO s with United States Postal Service on chat same day with postage thereon fully prepaid at
onze, 12 Bakersfield, California in the ordinary course of business.
Hee
‘oie B {BY FACSIMILE TRANSMISSION), pursuant to Rule § 2.306 of the California Rules of
im ce —
Ts, 14 Court. The telephone number of the sending facsimile machine was (661) 327-1087. A
6 Ex transmission report was properly issued by the sending facsimile machine, and the
oO g ie 15 transmission was reported as complete and without error.
23
28
S Zo (16: (BY PERSONAL SERVICE), pursuant to C.C.P. § 1011, 1 caused such envelope to be
od delivered by hand to the offices of the addressee(s),
cc 17
mee _X_ ONLY BY EMAIL TRANSMISSION: Pursuant to Emergency Rule 12 of the California
2 gency |
9 aS 18 Code of Civil Procedure, which was adopted by the Judicial Counsel in response to the
> E * 49 COVID-19 pandemic, this document is being served by electronic transmission only.
“s 20 Executed on July 13, 2022, at Bakersfield, California.
& 214||_X_ (STATE) I declare under penalty of perjury under the laws of the State of California that the
2 above is true and correct.
4 22
8 (PEDERAL) I declare that | am employed in the office of a member of the bar of this Court
zB 23 at whose direction the service was made.
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z 3]| Brooklyn Deann Moss V. Noe Garcia, et al.
2 4 Case No. BCV-19-103330 CW/ BCV-20-102977 and BCV-21-101449
2 5 Justin Lowtrip, Esq.
; 11150 W. Olympic Blvd., Suite 1050
B 6 Los Angeles, CA 90064
Z T: (424) 273-1462
8 7 Howtrip'@lowtriplave.com
s 8 vena lowtriplay. com
3 Atiorneys for Defendants/Cross-Defendants
4 2 9 LAURA GUIDO and NOE GARCIA AND D&L TRUCKING DOE 1
j £10
ee ont Thomas W. Shaver, Esq.
z 2 SHAVER, KORFF & CASTRONOVO LLP
g 2 12 16255 Ventura Boulevard, Suite 850
54 Encino, CA 91436
Attorney for Defendant ERIC SERTIC
Desyke-law.coii
Ashkhan Mohamadi, Esq.
SWEET JAMES, LLP
4220 Von Karman Avenue, Suite 200
Attorneys for Plaintiff ERIC SERTIC
Related Case No. BCV-19-103330
asbk.
Preview
CM-110 ATTORNEY G8 PARTY Wr HGUT ATTORNEY (Mame, Slate Bar number and adaress) Ned E. Dunphy SBN: 128601 THE LAW OFFICES YOUNG WOOLDRIDGE, LLP 1800 30th Street. Fourth Floor, Bakersficld. CA 93301 TeLepuovz no 661-327-966) FAK NO. Optanall. 661-327-1087 Bwalacoress. ndunphy@youngwooldridge.com ATTORNEY FOR (Neme!: Plaintiffs, Levi Cole Mass, a minor, and Aiden Lee Moss, a minor SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN STREET ADORESS = 1215 Truxtun Avenue MARING ADDRESS 1215 Truxtun Avenue SMV ANDZIF COPE. Bakersfield, 93301 BRANCH MAE Metro Justice Building PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor DEFENDANT/RESPONDENT: Noe Garcia, et al. FOR COURT USE ONLY CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): [_X_] UNLIMITED CASE (J LIMITED CASE BCV 19-103330 CW/ (Amount demanded {Amount demanded is $25,000 exceeds $25,000) or less} BCV 20-102977 and BCV-21-101449 iA CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: July 27, 2022 Time:$:30 a.m. Dept. Ow. [Address of court (if different from the address above): [[X_] Notice of intent to Appear by Telephone, by (name): Ned E. Dunphy Room: INSTRUCTIONS: Alt applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): b. This statement is submitted jointly by patties (names): This statement is submitted by party (name): Plaintiffs, Levi Cole Moss and Aiden Lee Moss 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): December 21, 2020 b, [77] 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 Fave been served, have appeared, or have been dismissed. b. [_] The following parties named in the complaint or cross-complaint (4) [[5J have not been served (specify names and explain why nol): (2) [C7] have been served but have not appeared and have not been dismissed (specify names): Eric Sertic (3) [°7] 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 ofcasein [-X] complaint ~~] cross-complaint (Describe, inckiding causes of action): Motor vehicle accident resulting in wrongful death. Page 1 of § Fern ree or acetone CASE MANAGEMENT STATEMENT ‘ak Roles of Cou. ew courts.ca gor CM-480 [Rey Septamber 1. 2021} \Wesaw Doc For BrCM-110 : PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor CASE VUMBER: | DEFENDANT/RESPONDENT: Noe Garcia, et al. BCV 20-102977 and BCV-21-101449 4. b. Provide a brief statement of the case, including any damages (if personal injury damages are sought, specify the injury and damages clajined, 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, Levi Cole Moss and Aiden Lee Moss are the chilcren of Kylee Jordan Moss, Deceased. Plaintiffs suffered loss of love, companionship, comfort, care, assistance and protection, {if more space is needed. check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury triat The party or parties request [X"] a jury trial anonjury trial. (Hf more than one party. provide the name of each party requesting a jury trial): 6. Trial date a. [[_] The trial has been set for (daie). b. [7X"] 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}: ¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 41/14/22-11/25/22; 05/01/23-05/08/23; 05/22/23-05/29/23 duc to other trials currently set. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a, days (specify number): 7-10 b. ["] hours (short causes) (specify): 8. Trial representation (to fe answered for each party) The party or parties will be represented at trial hy the attorney or party listed in the caption [7] by the following: a. Attorney: 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 [1] This case is entitied to preference (specify code section): 10. Alternative dispute resolution (ADR) @. 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 pragrarrs in this case. (1) For parties represented by counsel: Counsel [7] 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 efects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.17 (3) [_] This case is exempt from judicial arbitration under rule 3.811 of the California Rujes of Court or from civit action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CMTTO Rev Seprember #, 2027} CASE MANAGEMENT STATEMENT Page 2 of 5CM-110 PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lec Moss, a Minor DEFENDANT/RESPONDENT: x, ‘oe Garcia, et al. CASE VUMBER BCV 20- 102977 and BCV-21-101449 10. ¢. 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 afi that apply and provide 'he specified information): The party or parties completing Ithis form are willing to participate in the following ADR: processes (check ail that apply): If the party or parties completing this form in the case have agreed to participate in or have already completed an ADR process or processes, indicate the status of the processes (attach a copy of the parties' ADR stipulation). (1) Mediation (36) Mediation session not yet scheduled {[7] Mediation session scheduled for (date): {[_] Agreed to complete mediation by (date): [[7] Mediation compieted on (date): (2) Settlement conference [2€1 Settlement conference not yet scheduled [7] Settlement conference scheduled for (date). [__] Agreed to complete settlement conference by (date): [7] Settiement conference completed on (date): [2] Neutral evaluation nat yet scheduled [[7] Neutrat evatuation scheduled for (date) (3) Neutral evaluation Co {<7 ] Agreed to complete neutral evaluation by (date): [| Neutral evaluation completed on (date): (J Judicial arbitration not yet scheduled {4) Nonbinding judicial co [J] Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): (7) Judiciat arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Co ({] Private arbitration scheduled for (date): arbitration (7) Agreed to complete private arbitration by (date): [C7] Private arbitration completed on (date): ADR session not yet scheduled (6) Other (specify): co [7] ADR session scheduled for (date): [7] Agreed to complete ADR session by (date): [C7] ADR completed on (date): GM-10 (Rev September 1, 2021] CASE. MANAGEMENT STATEMENT Page dofsCM-110 PLAINTIFFPETITIONER: Levi Cole Moss, a minor ,and Aiden Lee Moss, a Minor | case wwoee DEFENDANT/RESPONDENT. Noe Garcia, ct al. BCV 20-102977 and BCV-21-101449 11. Insurance a. ["_] Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: [J Yes [77] No c, [7] Coverage issues will significantly affect resolution of this case (expiain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. [__] Bankruptey Other (specify): Status: 43. Related cases, consolidation, and coordination a There are companion, underlying, or related cases. (1) Name of case: Sertic v. Garcia, ct al. (2) Name of court: Kern County Superior Court (3) Case number BCV-19-103330 (4) Status: consolidated with BCV-20-102977 [-_] Additional cases are described in Attachment 13a. b. [_] Amotionto — [_] consolidate (C] coordinate will be filed by (name party): 14. Bifurcation [7] The patty 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). 1. Other motions [2] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Motions in Limine 16. Discovery a. [J The party or parties have completed all discovery. b. [XJ The following discovery will be completed by the date specified (describe all anticipated discovery): Party, Description Date Plaintiffs Deposition of Defendant October, 2022 Plaintiffs Depositions of several PMKS October, 2022 Plaintiffs Further written Discovery November, 2022 Plaintiffs Expert Discovery per code Plaintiffs Supplemental Discovery per code c. [""} The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify). EMG Rew Senterer 1 2071] CASE MANAGEMENT STATEMENT Pages ofSCM-110 PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor CASE NUMBER: DEFENDANTIRESPONDENT: Ning Gai etal BCV 20-102977 and BCV-21-40449 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 fo this case. b. This is a limited civil case and a motion to withdraw the case from the economic iitigation 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). Defendant, Eric Sertic is facing criminal charges as a result of the accident. Preliminary hearing is scheduled for July 12, 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 nat. 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): } am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as weil 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 F- 13-QoA2 SI NED _E. DUNPHY > Z ) (TYPE 08 PRIS NAVE (sent > (PE OF PRINT NAMED (SIGNATURE OF PARTY OR ATTORNEY} [“] Additional signatures are attached. CAETTO Bey Serember 120] CASE MANAGEMENT STATEMENT Page 5 ofSihe Law Offices Of gy PROOF OF SERVICE 2 2|| STATE OF CALIFORNIA, COUNTY OF KERN & : 3 1, YESENIA LAMBARENA, declare: | am and was at the times of the service hereunder 2 4 mentioned, over the age of eighteen (18) years, and not a party to the within cause. My business address is g The Westchester Corporate Plaza, 1800 30th Street, Fourth Floor, Bakersfield, CA 93301, 2 : 5 On July 13, 2022, I caused to be served the below listed document(s) titled as: CASE 5 6|| MANAGEMENT STATEMENT on the interested parties in this action, as listed below: g & 7 8 8 See Attached Service List met ill (BY MAIL), pursuant to C.C.P. § 1013(a). By placing /__/ the original or /.x/ a true copy 422 thereof enclosed in a sealed envelope. | am readily familiar with the firm's practice of se . Ps 'y ca YT collection and processing of documents for mailing. Under that practice it would be deposited oO s with United States Postal Service on chat same day with postage thereon fully prepaid at onze, 12 Bakersfield, California in the ordinary course of business. Hee ‘oie B {BY FACSIMILE TRANSMISSION), pursuant to Rule § 2.306 of the California Rules of im ce — Ts, 14 Court. The telephone number of the sending facsimile machine was (661) 327-1087. A 6 Ex transmission report was properly issued by the sending facsimile machine, and the oO g ie 15 transmission was reported as complete and without error. 23 28 S Zo (16: (BY PERSONAL SERVICE), pursuant to C.C.P. § 1011, 1 caused such envelope to be od delivered by hand to the offices of the addressee(s), cc 17 mee _X_ ONLY BY EMAIL TRANSMISSION: Pursuant to Emergency Rule 12 of the California 2 gency | 9 aS 18 Code of Civil Procedure, which was adopted by the Judicial Counsel in response to the > E * 49 COVID-19 pandemic, this document is being served by electronic transmission only. “s 20 Executed on July 13, 2022, at Bakersfield, California. & 214||_X_ (STATE) I declare under penalty of perjury under the laws of the State of California that the 2 above is true and correct. 4 22 8 (PEDERAL) I declare that | am employed in the office of a member of the bar of this Court zB 23 at whose direction the service was made. z 24 5 25 E 26 o 2 27 z 28The Law Offices OF Young Wooldridge, LLP 3 z é a 3 2 = . § 3 = gz & 3 5 Z 3 2 21 22 23 24 25 26 27 28 5 gol SERVICE LIST = z 2 z 3]| Brooklyn Deann Moss V. Noe Garcia, et al. 2 4 Case No. BCV-19-103330 CW/ BCV-20-102977 and BCV-21-101449 2 5 Justin Lowtrip, Esq. ; 11150 W. Olympic Blvd., Suite 1050 B 6 Los Angeles, CA 90064 Z T: (424) 273-1462 8 7 Howtrip'@lowtriplave.com s 8 vena lowtriplay. com 3 Atiorneys for Defendants/Cross-Defendants 4 2 9 LAURA GUIDO and NOE GARCIA AND D&L TRUCKING DOE 1 j £10 ee ont Thomas W. Shaver, Esq. z 2 SHAVER, KORFF & CASTRONOVO LLP g 2 12 16255 Ventura Boulevard, Suite 850 54 Encino, CA 91436 Attorney for Defendant ERIC SERTIC Desyke-law.coii Ashkhan Mohamadi, Esq. SWEET JAMES, LLP 4220 Von Karman Avenue, Suite 200 Attorneys for Plaintiff ERIC SERTIC Related Case No. BCV-19-103330 asbk.