Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Jason Kearnaghan, CBN 207707 Y. Douglas Yang, CBN 307550
Sheppard Mullin Richter & Hampton LLP
333 South Hope Street, 43rd Floor
Los Angeles, CA 90071
TELEPHONE NO.: (213) 620-1780 FAX NO. (Optional): (213) 620-1398 ELECTRONICALLY
jkearnaghan@sheppardmullin.com;dyang@sheppardmullin.com
E-MAIL ADDRESS (Optional):
Defendant Levi Strauss & Co.
ATTORNEY FOR (Name):
F I L E D
Superior Court of California,
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco County of San Francisco
STREET ADDRESS: 400 McAllister Street 04/23/2020
MAILING ADDRESS: Clerk of the Court
BY: DAVID YUEN
San Francisco, 94102-4514
CITY AND ZIP CODE:
Deputy Clerk
BRANCH NAME:Civic Center Courthouse
PLAINTIFF/PETITIONER: Winona Powers
DEFENDANT/RESPONDENT: Levi Strauss & Co.
CASE MANAGEMENT STATEMENT CASE NUMBER:
CGC-19-581624
(Check one): UNLIMITED CASE LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: May 20, 2020 Time: 10:30 a.m. Dept.: 610 Div.: Room: 610
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Y. Douglas Yang for Def.; John Matheny for Pla.
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): Plaintiff Winona Powers; Defendant Levi Strauss & Co.
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): Dec. 18, 2019
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):
Wage-and-hour lawsuit asserting 12 causes of action for Waiting Time Penalties under California Labor Code
Section 203.
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. July 1, 2011] www.courts.ca.gov
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Winona Powers
CGC-19-581624
DEFENDANT/RESPONDENT: Levi Strauss & Co..
4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff Winona Powers alleges that from 2017-2019, she was an employee of Defendant Levi Strauss & Co., and
that on 12 separate occassions, she was not paid wages in a timely manner, and thus she asserts she is entitled
to waiting time penalties under Labor Code section 203. Defendant denies all of Plaintiff's allegations and claims,
and denies that Plaintiff is entitled to any waiting time penalties.
(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): Due to ongoing COVID-19 Pandemic, trial may not be possible within 12 months of the date of
the filing of the complaint.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Please see attached.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 5-7 (if not consolidated with the related matter detailed below)
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
9. Preference
This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel has has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM-110 [Rev. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Winona Powers
CGC-19-581624
DEFENDANT/RESPONDENT: Levi Strauss & Co.
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):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Winona Powers
CGC-19-581624
DEFENDANT/RESPONDENT: Levi Strauss & Co.
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: Winona Powers, et al. v. Levi Strauss & Co., et al.
(2) Name of court: San Francisco Superior Court
(3) Case number: CGC-20-584035
(4) Status: Pending
Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate wiII be filed by (name party): Defendant
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):
Defendant reserves the right to file a Motion for Summary Judgment or Motion for Summary Adjudication.
16. Discovery
a. The party or parties have completed all discovery.
b The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendant Plaintiff's Deposition August 2020
Defendant Third-Party Discovery November 2020
Defendant Expert Discovery January 2021
Plaintiff Written Discovery November 2020
Plaintiff Depositions November 2020
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011] Page 4 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Winona Powers
CGC-19-581624
DEFENDANT/RESPONDENT: Levi Strauss & Co.
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):
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: 4/23/2020.
Jason Kearnaghan /s/Jason Kearnaghan
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
John Matheny /s/John Matheny
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev. July 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
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Winona Powers v. Levi Strauss & Co., S.F. Superior Court Case No. CGC-19-581624
Attached to Joint Case Management Statement
DATES OF TRIAL UNAVAILABILITY
All Dates Subject to Change Due to COVID-19 Pandemic
Party Dates Unavailable Reason
Defendant 4/27/20 – 5/15/20 Trial
Defendant 5/27/20 – 6/9/20 Trial
Defendant 6/2/20 – 6/3/20 Trial
Defendant 6/16/20 – 7/3/20 Trial
Defendant 6/12/20 – 6/26/20 Trial
Defendant 8/10/20 – 8/28/20 Trial
Defendant 8/10/20 – 8/28/20 Trial
Defendant 7/27/20 – 8/14/20 Vacation
Defendant 8/17/20 – 8/28/20 Trial
Defendant 9/12/20 – 9/28/20 Trial
Defendant 10/26/20 – 10/29/20 Trial
Defendant 11/9/20 – 11/20/20 Trial
Defendant 11/9/20 – 11/17/20 Trial
Defendant 11/16/20 – 11/27/20 Trial
Defendant 12/8/20 – 12/11/20 Arbitration
Defendant 12/14/20 – 12/23/20 Trial
SMRH:4840-7119-6090.1 -1-
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
3 At the time of service, I was over 18 years of age and not a party to this action. I
am employed in the County of Los Angeles, State of California. My business address is
4 333 South Hope Street, 43rd Floor, Los Angeles, CA 90071-1422.
5 On April 23, 2020, I served true copies of the following document(s) described as
CASE MANAGEMENT STATEMENT on the interested parties in this action as
6 follows:
7 SERVICE LIST
8 Joseph H. Low IV Attorneys for Plaintiff Winona Powers
THE LAW FIRM OF JOSEPH H. LOW IV
9 100 Oceangate, 12th Floor
Long Beach, CA 90802
10 Tel: (562) 901-0840
Fax: (562) 901-0841
11 E-Mail: joseph@jhllaw.com
12 Roger Y. Muse
John R. Matheny
13 EXCELSIOR LAW
9595 Wilshire Blvd., Suite 900
14 Beverly Hills, CA 90212
Tel: (310) 205—3981
15 Fax: (310) 205-0594
E-Mail: roger@excelsior-law.com;
16 john@excelsior-law.com
17 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
document(s) to be sent from e-mail address bdelacruz@sheppardmullin.com to the persons
18 at the e-mail addresses listed in the Service List. I did not receive, within a reasonable
time after the transmission, any electronic message or other indication that the
19 transmission was unsuccessful.
20 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
21
Executed on April 23, 2020, at Los Angeles, California.
22
23
24 Beannette De La Cruz
25
26
27
28
SMRH:4820-9270-4178.1
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Jason Kearnaghan, CBN 207707 Y. Douglas Yang, CBN 307550 Sheppard Mullin Richter & Hampton LLP 333 South Hope Street, 43rd Floor Los Angeles, CA 90071 TELEPHONE NO.: (213) 620-1780 FAX NO. (Optional): (213) 620-1398 ELECTRONICALLY jkearnaghan@sheppardmullin.com;dyang@sheppardmullin.com E-MAIL ADDRESS (Optional): Defendant Levi Strauss & Co. ATTORNEY FOR (Name): F I L E D Superior Court of California, SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco County of San Francisco STREET ADDRESS: 400 McAllister Street 04/23/2020 MAILING ADDRESS: Clerk of the Court BY: DAVID YUEN San Francisco, 94102-4514 CITY AND ZIP CODE: Deputy Clerk BRANCH NAME:Civic Center Courthouse PLAINTIFF/PETITIONER: Winona Powers DEFENDANT/RESPONDENT: Levi Strauss & Co. CASE MANAGEMENT STATEMENT CASE NUMBER: CGC-19-581624 (Check one): UNLIMITED CASE LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 20, 2020 Time: 10:30 a.m. Dept.: 610 Div.: Room: 610 Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Y. Douglas Yang for Def.; John Matheny for Pla. 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): Plaintiff Winona Powers; Defendant Levi Strauss & Co. 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): Dec. 18, 2019 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): Wage-and-hour lawsuit asserting 12 causes of action for Waiting Time Penalties under California Labor Code Section 203. 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. July 1, 2011] www.courts.ca.gov American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Winona Powers CGC-19-581624 DEFENDANT/RESPONDENT: Levi Strauss & Co.. 4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff Winona Powers alleges that from 2017-2019, she was an employee of Defendant Levi Strauss & Co., and that on 12 separate occassions, she was not paid wages in a timely manner, and thus she asserts she is entitled to waiting time penalties under Labor Code section 203. Defendant denies all of Plaintiff's allegations and claims, and denies that Plaintiff is entitled to any waiting time penalties. (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): Due to ongoing COVID-19 Pandemic, trial may not be possible within 12 months of the date of the filing of the complaint. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Please see attached. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 5-7 (if not consolidated with the related matter detailed below) b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: Additional representation is described in Attachment 8. 9. Preference This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel has has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Winona Powers CGC-19-581624 DEFENDANT/RESPONDENT: Levi Strauss & Co. 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): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Winona Powers CGC-19-581624 DEFENDANT/RESPONDENT: Levi Strauss & Co. 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: Winona Powers, et al. v. Levi Strauss & Co., et al. (2) Name of court: San Francisco Superior Court (3) Case number: CGC-20-584035 (4) Status: Pending Additional cases are described in Attachment 13a. b. A motion to consolidate coordinate wiII be filed by (name party): Defendant 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): Defendant reserves the right to file a Motion for Summary Judgment or Motion for Summary Adjudication. 16. Discovery a. The party or parties have completed all discovery. b The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant Plaintiff's Deposition August 2020 Defendant Third-Party Discovery November 2020 Defendant Expert Discovery January 2021 Plaintiff Written Discovery November 2020 Plaintiff Depositions November 2020 c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Winona Powers CGC-19-581624 DEFENDANT/RESPONDENT: Levi Strauss & Co. 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): 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: 4/23/2020. Jason Kearnaghan /s/Jason Kearnaghan (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) John Matheny /s/John Matheny (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. July 1, 2011] Page 5 of 5 CASE MANAGEMENT STATEMENT American LegalNet, Inc. www.FormsWorkFlow.com Winona Powers v. Levi Strauss & Co., S.F. Superior Court Case No. CGC-19-581624 Attached to Joint Case Management Statement DATES OF TRIAL UNAVAILABILITY All Dates Subject to Change Due to COVID-19 Pandemic Party Dates Unavailable Reason Defendant 4/27/20 – 5/15/20 Trial Defendant 5/27/20 – 6/9/20 Trial Defendant 6/2/20 – 6/3/20 Trial Defendant 6/16/20 – 7/3/20 Trial Defendant 6/12/20 – 6/26/20 Trial Defendant 8/10/20 – 8/28/20 Trial Defendant 8/10/20 – 8/28/20 Trial Defendant 7/27/20 – 8/14/20 Vacation Defendant 8/17/20 – 8/28/20 Trial Defendant 9/12/20 – 9/28/20 Trial Defendant 10/26/20 – 10/29/20 Trial Defendant 11/9/20 – 11/20/20 Trial Defendant 11/9/20 – 11/17/20 Trial Defendant 11/16/20 – 11/27/20 Trial Defendant 12/8/20 – 12/11/20 Arbitration Defendant 12/14/20 – 12/23/20 Trial SMRH:4840-7119-6090.1 -1- 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 3 At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of Los Angeles, State of California. My business address is 4 333 South Hope Street, 43rd Floor, Los Angeles, CA 90071-1422. 5 On April 23, 2020, I served true copies of the following document(s) described as CASE MANAGEMENT STATEMENT on the interested parties in this action as 6 follows: 7 SERVICE LIST 8 Joseph H. Low IV Attorneys for Plaintiff Winona Powers THE LAW FIRM OF JOSEPH H. LOW IV 9 100 Oceangate, 12th Floor Long Beach, CA 90802 10 Tel: (562) 901-0840 Fax: (562) 901-0841 11 E-Mail: joseph@jhllaw.com 12 Roger Y. Muse John R. Matheny 13 EXCELSIOR LAW 9595 Wilshire Blvd., Suite 900 14 Beverly Hills, CA 90212 Tel: (310) 205—3981 15 Fax: (310) 205-0594 E-Mail: roger@excelsior-law.com; 16 john@excelsior-law.com 17 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the document(s) to be sent from e-mail address bdelacruz@sheppardmullin.com to the persons 18 at the e-mail addresses listed in the Service List. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the 19 transmission was unsuccessful. 20 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 21 Executed on April 23, 2020, at Los Angeles, California. 22 23 24 Beannette De La Cruz 25 26 27 28 SMRH:4820-9270-4178.1