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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
JOHN L. SUPPLE (SBN: 94582); ROBERT DEERING (SBN: 258043); MADELEINE LOUGH-
STEVENS (SBN: 323789)
J SUPPLE LAW, A Professional Corporation
990 FIFTH AVENUE
ELECTRONICALLY
SAN RAFAEL, CA 94901
TELEPHONE NO.: (415) 366-5533 (415) 480-6301
FAX NO. (Optional): F I L E D
Superior Court of California,
E-MAIL ADDRESS /Optional/ : jsupple@jsupplelaw.com;
rdeering@jsupplelaw.com; mlough-stevens@jsupplelaw.com
County of San Francisco
ATTORNEYFOR(NameJ DANIELLE LANE, M.D.; MARK FAN, M.D., and DANIELLE E. LANE, M.D.
INC. dba LANE FERTILITY INSTITUTE 03/17/2020
Clerk of the Court
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO BY: DAVID YUEN
Deputy Clerk
srnEET ADDREss 400 McAllister Street
MAILING ADDRESS:
CITY AND ZIP CODE: San Francisco, CA 94102-3680
BRANCH NAME:
PLAINTIFFS/PETITIONERS: PATRICK WILLIAMS RODRIGUEZ, et al./
CASEY FREITAS, an individual
DEFENDANTS/RESPONDENTS: DANIELLE LANE, M.D., an individual, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
CGC-19-580309
(Check one): (8] UNLIMITED CASE O LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: April 1, 2020 Time: 10:30 AM Dept.: 610 Div. : Room:
Address of court (if different from the address above):
D Notice of Intent to Appear by Telephone, by (name):
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. [8J This statement is submitted by party (name) : Defendants DANIELLE LANE, M.D.; MARK FAN, M.D., and
DANIELLE E. LANE, M.D.
b. D 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): October 28, 2019 (Rodriguez Complaint) / November 8, 2019 (Freitas Complaint)
b. D The cross-complaint, if any, date): D
3. Service (to be answered by plaintiffs and cross-complainants only)
a. D All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. â–¡ The following parties named in the complaint or cross-complaint
(1) D have not been served (specify names and explain why not):
(2) D have been served but have not appeared and have not been dismissed (specify names):
(3) D have had a default entered against them (specify names):
c. D 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 [8] complaint D cross-complaint (Describe, including causes of action):
Plaintiffs allege causes of action for: 1) Negligence, 2) Failure to Obtain Informed Consent, 3) Breach of Contract
(for the Rodriguez Complaint only), 4) Intentional Misrepresentation, 5) Negligent Misrepresentation, 6)
Fraudulent Concealment. and 7) Violation of B&P Code &17200. et. al.
Pa e 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 July 1, 2011) www.courts.ca.gov
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CM-110
PLAINTIFFS/PETITIONERS: PATRICK WILLIAMS RODRIGUEZ, et al. I CASEY FREITAS, CASE NUMBER:
an individual CGC-19-580309
DEFENDANTS/RESPONDENTS: DANIELLE LANE, M.D., an individual, et al.
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 allege negligence associated with defendants' performance of fertility services. Defendants deny all
liability.
D (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 [8J a jury trial D a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. D The trial has been set for (date):
b. [8] 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): This is a complex medical negligence case and time is needed to complete the investigation
and discovery.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
See Attachment 6c.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [8] days (specify number): 7-10
b. D hours (short causes) (specify):
8. Trial representation (to be answered for each party)
D
The party or parties will be represented at trial by the attorney or party listed in the caption [8] by the following :
a. Attorney: John L. Supple
b. Firm: J Supple Law, PC
c. Address: 990 Fifth Avenue, San Rafael, CA 94901
d. Telephone number: 415-366-5533 f. Fax number: 415-480-6301
e. E-mail address: jsupple@jsupplelaw.com g. Party represented : Defendants DANIELLE LANE,
M.D.; MARK FAN, M.D., and DANIELLE E. LANE, M.D.
D Additional representation is described in Attachment 8.
9. Preference
D 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 [8] has D 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 D has D has not reviewed the ADR information package identified in rule 3.221 .
b. Referral to judicial arbitration or civil action mediation (if available).
( 1)D 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) D 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) D 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 IRev. July 1, 20111 Page 2 of 5
CASE MANAGEMENT STATEMENT
American Lega lNet, Inc.
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CM-110
CASE NUMBER:
PLAINTIFFS/PETITIONERS: PATRICK WILLIAMS RODRIGUEZ, et al./ CASEY FREITAS,
an individual CGC-19-580309
DEFENDANTS/RESPONDENTS: DANIELLE LANE, M.D., an individual, et al.
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):
â–¡ Mediation session not yet scheduled
â–¡ Mediation session scheduled for (date):
(1) Mediation
â–¡
â–¡ Agreed to complete mediation by (date):
â–¡ Mediation completed on (date):
â–¡ Settlement conference not yet scheduled
(2) Settlement â–¡ Settlement conference schedu led for (date) :
conference â–¡
â–¡ Agreed to complete settlement conference by (date) :
â–¡ Settlement conference completed on (date) :
â–¡ Neutral evaluation not yet scheduled
â–¡ Neutral evaluation scheduled for (date):
(3) Neutral evaluation
â–¡
â–¡ Agreed to complete neutral evaluation by (date):
â–¡ Neutral evaluation completed on (date):
â–¡ Judicial arbitration not yet scheduled
(4) Nonbinding judicial â–¡ Judicial arbitration sched uled for (date):
arbitration â–¡
â–¡ Agreed to complete judicial arbitration by (date) :
â–¡ Judicial arbitration completed on (date) :
â–¡ Private arbitration not yet scheduled
(5) Binding private â–¡ Private arbitration scheduled for (date):
arbitration â–¡
â–¡ Agreed to complete private arbitration by (date):
â–¡ Private arbitration completed on (date):
â–¡ ADR session not yet scheduled
(6) Other (specify): â–¡ ADR session scheduled for (date) :
â–¡
â–¡ Agreed to complete ADR session by (date) :
â–¡ ADR completed on (date):
CM-110 [Rev. July 1, 2011) Page 3 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
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CM-110
CASE NUMBER:
PLAINTIFFS/PETITIONERS: PATRICK WILLIAMS RODRIGUEZ, et al./ CASEY FREITAS,
an individual CGC-19-580309
DEFENDANTS/RESPONDENTS: DANIELLE LANE, M.D., an individual, et al.
11 .Insurance
a. l8] CAP/MPT
Insurance carrier, if any, for party filing this statement (name) :
b. Reservation of rights : D Yes l8] No None known at this time .
c. D 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.
D Bankruptcy D Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. D There are companion, underlying, or related cases .
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
D Additional cases are described in Attachment 13a.
b. D A motion to D consolidate D coordinate will be filed by (name party):
14. Bifurcation
D 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
D The party or parties expect to file the following motions before trial (specify moving party, type of motion,
and issues):
Defendant may file a motion for summary judgment; other motions unknown at this time.
16. Discovery
a. D The party or parties have completed all discovery.
b D The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendant Written Discovery Ongoing
Defendant Plaintiffs' Deposition Summer 2020
Defendant Record Subpoenas Ongoing
Defendant Witness/Treating Doctor Depositions Fall/Winter 2020
c. D 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
111:'A,
v.lJ
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFFS/PETITIONERS: PATRICK WILLIAMS RODRIGUEZ, et al./ CASEY FREITAS,
an individual CGC-19-580309
DEFENDANTS/RESPONDENTS: DANIELLE LANE, M.D., an individual, et al.
17. Economic litigation
a. D 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. D 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
D The party or parties request that the following additional matters be considered or determined at the case management
conference (specify) :
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): _ _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: March 17, 2020 J SUPPLE LAW, PC
Lf /
111l,l+(r'h½d=--·- ·- ·
Madeleine Lough-Stevens
(TYPE OR PRINT NAME)
â–º (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME)
â–º (SIGNATURE OF PARTY OR ATTORNEY)
D Additional signatures are attached .
Page 5 of 5
CM-110 [Rev. July 1. 2011)
CASE MANAGEMENT STATEMENT
American Lega lNet, Inc.
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MC-025
isHORT TITLE: PATRICK WILLIAMS RODRIGUEZ, et al./
, _ !CASEY FREITAS an individual
ATTACHMENT (Number): 6c Page 1 of 1
(This Attachment may be used with any Judicial Council form.) (Add pages as required)
2
3 ATTACHMENT 6.c. to Case Management Statement
4
Trial Dates:
5
4/20/20
6
4/20/20
7 5/11/20
5/18/20
8
5/26/20
9
6/1/20
6/2/20
10 6/8/20
6/15/20
11
6/22/20
12 6/29/20
7/6/20
13
7/24/20
14 9/3/20
9/15/20
15 9/28/20
10/5/20
16
10/19/20
17 11/3/20
11/5/20
18
11/9/20
19 12/15/20
1/4/21
20 1/19/21
1/29/21
21
2/16/21
22 3/29/21
5/3/21
23
5/3/21
24
25
C:\Userslksovyak\Desktop\Attachment 6c for CMS 03-09-20.docx
26
27
Re : Rodriguez v. Danielle E. Lane, MD., et al.
1 San Francisco County Superior Court Case No: CGC-19-580309
Consolidated with
2 Freitas v. Danielle E. Lane, MD., et al.
San Francisco County Superior Court Case No: CGC-19-580659
3
4 PROOF OF SERVICE BY U.S. MAIL
5 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 J SUPPLE LAW, PC, 990 Fifth Avenue, San
6 Rafael, CA 94901. On the date indicated below, I served the within document:
7 CASE MANAGEMENT STATEMENT
8
â–¡
by placing a true copy thereof enclosed in a sealed envelope, at a station designated
9 for collection and processing of envelopes and packages for overnight delivery by
Golden State Overnight as part of the ordinary business practices of J SUPPLE
10 LAW, PC described below, addressed as follows :
â–¡
by transmitting via facsimile the document listed above to the fax numbers set forth
11 below on this date before 5 :00 p.m.
u ....
0 12 ~ by placing the document(s) listed above in a sealed envelope with postage thereon
fully prepaid, in United States Mail in the State of California at San Rafael,
~ = ...,
i:i,. 0\
Ill
addressed as set forth below.
~ ~ 0\ 13
< <;,
..,;j
<
u
~ .c ...:- 14
~
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i:..
i,;I;,
.... Attorneys for Plaintiff
i:..o~
.;;;i
0\ 15
...,
Cl)0\ C
~
Cl)
Nancy Hersh, Esq.
16 Kate Hersh-Boyle, Esq.
Montana Baker, Esq.
17 HERSH and HERSH
601 Van Ness Avenue, Suite 2080
18 San Francisco, CA 94102
19 I am readily familiar with the firm's practice of collection and processing correspondence
for mailing. Under that practice it would be deposited with the U.S . Postal Service on that same
20 day with postage thereon fully prepaid in the ordinary course of business. I am aware that on
motion of the party served, service is presumed invalid if postal cancellation date or postage
21 meter date is more than one day after the date of deposit for mailing in affidavit.
22 I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.
23
Executed on March 17, 2020, at San Rafael, California.
24
25
26 Kathleen A. Sovyak
27
28
-1-
PROOF OF SERVICE BY U.S. MAIL
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY JOHN L. SUPPLE (SBN: 94582); ROBERT DEERING (SBN: 258043); MADELEINE LOUGH- STEVENS (SBN: 323789) J SUPPLE LAW, A Professional Corporation 990 FIFTH AVENUE ELECTRONICALLY SAN RAFAEL, CA 94901 TELEPHONE NO.: (415) 366-5533 (415) 480-6301 FAX NO. (Optional): F I L E D Superior Court of California, E-MAIL ADDRESS /Optional/ : jsupple@jsupplelaw.com; rdeering@jsupplelaw.com; mlough-stevens@jsupplelaw.com County of San Francisco ATTORNEYFOR(NameJ DANIELLE LANE, M.D.; MARK FAN, M.D., and DANIELLE E. LANE, M.D. INC. dba LANE FERTILITY INSTITUTE 03/17/2020 Clerk of the Court SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO BY: DAVID YUEN Deputy Clerk srnEET ADDREss 400 McAllister Street MAILING ADDRESS: CITY AND ZIP CODE: San Francisco, CA 94102-3680 BRANCH NAME: PLAINTIFFS/PETITIONERS: PATRICK WILLIAMS RODRIGUEZ, et al./ CASEY FREITAS, an individual DEFENDANTS/RESPONDENTS: DANIELLE LANE, M.D., an individual, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: CGC-19-580309 (Check one): (8] UNLIMITED CASE O LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: April 1, 2020 Time: 10:30 AM Dept.: 610 Div. : Room: Address of court (if different from the address above): D Notice of Intent to Appear by Telephone, by (name): INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. [8J This statement is submitted by party (name) : Defendants DANIELLE LANE, M.D.; MARK FAN, M.D., and DANIELLE E. LANE, M.D. b. D 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): October 28, 2019 (Rodriguez Complaint) / November 8, 2019 (Freitas Complaint) b. D The cross-complaint, if any, date): D 3. Service (to be answered by plaintiffs and cross-complainants only) a. D 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) D have not been served (specify names and explain why not): (2) D have been served but have not appeared and have not been dismissed (specify names): (3) D have had a default entered against them (specify names): c. D 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 [8] complaint D cross-complaint (Describe, including causes of action): Plaintiffs allege causes of action for: 1) Negligence, 2) Failure to Obtain Informed Consent, 3) Breach of Contract (for the Rodriguez Complaint only), 4) Intentional Misrepresentation, 5) Negligent Misrepresentation, 6) Fraudulent Concealment. and 7) Violation of B&P Code &17200. et. al. Pa e 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 July 1, 2011) www.courts.ca.gov ~ American LegalNet, Inc. '11f.lJ www Form sWorkFlow.com CM-110 PLAINTIFFS/PETITIONERS: PATRICK WILLIAMS RODRIGUEZ, et al. I CASEY FREITAS, CASE NUMBER: an individual CGC-19-580309 DEFENDANTS/RESPONDENTS: DANIELLE LANE, M.D., an individual, et al. 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 allege negligence associated with defendants' performance of fertility services. Defendants deny all liability. D (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 [8J a jury trial D a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. D The trial has been set for (date): b. [8] 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): This is a complex medical negligence case and time is needed to complete the investigation and discovery. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): See Attachment 6c. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [8] days (specify number): 7-10 b. D hours (short causes) (specify): 8. Trial representation (to be answered for each party) D The party or parties will be represented at trial by the attorney or party listed in the caption [8] by the following : a. Attorney: John L. Supple b. Firm: J Supple Law, PC c. Address: 990 Fifth Avenue, San Rafael, CA 94901 d. Telephone number: 415-366-5533 f. Fax number: 415-480-6301 e. E-mail address: jsupple@jsupplelaw.com g. Party represented : Defendants DANIELLE LANE, M.D.; MARK FAN, M.D., and DANIELLE E. LANE, M.D. D Additional representation is described in Attachment 8. 9. Preference D 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 [8] has D 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 D has D has not reviewed the ADR information package identified in rule 3.221 . b. Referral to judicial arbitration or civil action mediation (if available). ( 1)D 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) D 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) D 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 IRev. July 1, 20111 Page 2 of 5 CASE MANAGEMENT STATEMENT American Lega lNet, Inc. ~ -_; V.4 www.Form sWorkFlow.com CM-110 CASE NUMBER: PLAINTIFFS/PETITIONERS: PATRICK WILLIAMS RODRIGUEZ, et al./ CASEY FREITAS, an individual CGC-19-580309 DEFENDANTS/RESPONDENTS: DANIELLE LANE, M.D., an individual, et al. 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 schedu led 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 sched uled 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): CM-110 [Rev. July 1, 2011) Page 3 of 5 CASE MANAGEMENT STATEMENT American LegalNet, Inc. ~ -' Vfl www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFFS/PETITIONERS: PATRICK WILLIAMS RODRIGUEZ, et al./ CASEY FREITAS, an individual CGC-19-580309 DEFENDANTS/RESPONDENTS: DANIELLE LANE, M.D., an individual, et al. 11 .Insurance a. l8] CAP/MPT Insurance carrier, if any, for party filing this statement (name) : b. Reservation of rights : D Yes l8] No None known at this time . c. D 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. D Bankruptcy D Other (specify): Status: 13. Related cases, consolidation, and coordination a. D There are companion, underlying, or related cases . (1) Name of case: (2) Name of court: (3) Case number: (4) Status: D Additional cases are described in Attachment 13a. b. D A motion to D consolidate D coordinate will be filed by (name party): 14. Bifurcation D 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 D The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Defendant may file a motion for summary judgment; other motions unknown at this time. 16. Discovery a. D The party or parties have completed all discovery. b D The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant Written Discovery Ongoing Defendant Plaintiffs' Deposition Summer 2020 Defendant Record Subpoenas Ongoing Defendant Witness/Treating Doctor Depositions Fall/Winter 2020 c. D 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 111:'A, v.lJ American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFFS/PETITIONERS: PATRICK WILLIAMS RODRIGUEZ, et al./ CASEY FREITAS, an individual CGC-19-580309 DEFENDANTS/RESPONDENTS: DANIELLE LANE, M.D., an individual, et al. 17. Economic litigation a. D 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. D 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 D The party or parties request that the following additional matters be considered or determined at the case management conference (specify) : 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): _ _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: March 17, 2020 J SUPPLE LAW, PC Lf / 111l,l+(r'h½d=--·- ·- · Madeleine Lough-Stevens (TYPE OR PRINT NAME) ► (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) ► (SIGNATURE OF PARTY OR ATTORNEY) D Additional signatures are attached . Page 5 of 5 CM-110 [Rev. July 1. 2011) CASE MANAGEMENT STATEMENT American Lega lNet, Inc. ~ -- V,.H www.FormsWork.flow.com MC-025 isHORT TITLE: PATRICK WILLIAMS RODRIGUEZ, et al./ , _ !CASEY FREITAS an individual ATTACHMENT (Number): 6c Page 1 of 1 (This Attachment may be used with any Judicial Council form.) (Add pages as required) 2 3 ATTACHMENT 6.c. to Case Management Statement 4 Trial Dates: 5 4/20/20 6 4/20/20 7 5/11/20 5/18/20 8 5/26/20 9 6/1/20 6/2/20 10 6/8/20 6/15/20 11 6/22/20 12 6/29/20 7/6/20 13 7/24/20 14 9/3/20 9/15/20 15 9/28/20 10/5/20 16 10/19/20 17 11/3/20 11/5/20 18 11/9/20 19 12/15/20 1/4/21 20 1/19/21 1/29/21 21 2/16/21 22 3/29/21 5/3/21 23 5/3/21 24 25 C:\Userslksovyak\Desktop\Attachment 6c for CMS 03-09-20.docx 26 27 Re : Rodriguez v. Danielle E. Lane, MD., et al. 1 San Francisco County Superior Court Case No: CGC-19-580309 Consolidated with 2 Freitas v. Danielle E. Lane, MD., et al. San Francisco County Superior Court Case No: CGC-19-580659 3 4 PROOF OF SERVICE BY U.S. MAIL 5 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 J SUPPLE LAW, PC, 990 Fifth Avenue, San 6 Rafael, CA 94901. On the date indicated below, I served the within document: 7 CASE MANAGEMENT STATEMENT 8 □ by placing a true copy thereof enclosed in a sealed envelope, at a station designated 9 for collection and processing of envelopes and packages for overnight delivery by Golden State Overnight as part of the ordinary business practices of J SUPPLE 10 LAW, PC described below, addressed as follows : □ by transmitting via facsimile the document listed above to the fax numbers set forth 11 below on this date before 5 :00 p.m. u .... 0 12 ~ by placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid, in United States Mail in the State of California at San Rafael, ~ = ..., i:i,. 0\ Ill addressed as set forth below. ~ ~ 0\ 13 < <;, ..,;j < u ~ .c ...:- 14 ~ ..,;j ~ i:.. i,;I;, .... Attorneys for Plaintiff i:..o~ .;;;i 0\ 15 ..., Cl)0\ C ~ Cl) Nancy Hersh, Esq. 16 Kate Hersh-Boyle, Esq. Montana Baker, Esq. 17 HERSH and HERSH 601 Van Ness Avenue, Suite 2080 18 San Francisco, CA 94102 19 I am readily familiar with the firm's practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S . Postal Service on that same 20 day with postage thereon fully prepaid in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage 21 meter date is more than one day after the date of deposit for mailing in affidavit. 22 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 23 Executed on March 17, 2020, at San Rafael, California. 24 25 26 Kathleen A. Sovyak 27 28 -1- PROOF OF SERVICE BY U.S. MAIL