Preview
CM-110
AT TORTIE” OR BARTY WF HOUT ATTORNEY (ame, Sale Oar number, ond aadress}
Ned E. Dunphy SBN: 128601 FOR COURT USE Oni
THE LAW OFFICES YOUNG WOOLDRIDGE, LLP
1800 30th Sirect, Fourth Floor,
Bakersfield, CA 93301
yeteruoxe no: 661-327-9661 FAK NO. (Optional 661-327-1087
Ewa acorese ndunphy@youngwooldridge.com
ATTORNEY FOR (Name) Plaintiffs, Levi Cole Moss, a minor, and Aiden Lee Moss, a minor
SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN
STREET ADDRESS {245 Truxtun Avenue
MAILING ADDRESS: 1215 Truxtun Avenue
SFYANOZPCODE Bakersfield. 93301
BRANGHNAVE” Metro Justice Buildin;
PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor
DEFENDANT/RESPONDENT: Noe Garcia, ct al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE [<7] 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: August 26, 2022 Time:8:30 a.m. Dept.: Div.) Room:
Address of court (if different from the address above):
|X] Notice of intent to Appear by Telephone, by (name): Ned E. Dunphy
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
4. Party or parties (answer ona):
a This statement is submitted by party (name): Plaintiffs, Levi Cole Mass and Aiden Lee Moss
b. [(—] This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to 5e answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): December 21, 2020
b. [(_] The cross-compiaint, if any, was fited on (date):
3. Service (to be answered by plaintiffs and crass-complainants only)
a, Ai! parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [77] The following parties named in the complaint or cross-complaint
(1) ([ 5) have not been served (specify names and explain why nol):
{2) [__] 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. [77] 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 [C2] cross-complaint (Describe, including causes of action): Motor vehicle
accident resulting in wrongfil death,
Paget ofS
Cal Rules ef Cour,
‘eaten CASE MANAGEMENT STATEMENT ARSSS
SNe
wom ccurts.e@ gov
estan Di & Fr BudeCM-110
PLAINTIFF/PET:TIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor CASE NUMBER:
DEFENDANTIRESPONDENT: Noo Garcia, et al. BCV 20-102977 and BCV-21-101449
A. 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 fo dale {indicate source and amount], estimated future medical expenses, iost
earnings to date, and estimated future /ost earnings. if equitable relief is sought, describe the nature of the relief.)
Plaintiffs, Levi Cole Moss and Aiden Lee Moss are the children 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 trial
The party or parties request a jury trial [7] a nonjury trial. (/f more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a, ["7] 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):
¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
11/14/22-1 1/25/22; 05/01/23-05/08/23; 05/22/23-05/29/23 due 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
6. [[~] hours (short causes) (specify):
8. Trial representation (fo be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption [7] 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 (speciiy 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 setf-represented parties: Party [[] has [77] 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 177£.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 fimit recovery to the amount specified in Code of
Civil Procedure section 1141.11
(3) (""] This case is exempt from judicial arbitration under rule 3.641 of the California Ruies of Court or from civil action
mediation under Code of Civit Procedure section 1775 et seq. (specify exemption):
Page 2 of 5
EMO Rev September 1 2021) CASE MANAGEMENT STATEMENTCM-110
PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor __| case vewser.
DEFENDANT/RESPONDENT: Noe Garcia,
etal,
BCV 20-!02977 and BCV-21-101449
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 ihe specified information):
|The party or parties completing
Ithis form are willing to
participate in the following ADR
processes (check ail that apply):
If the pary cr 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):
Mediation session not yet scheduled
[] Mediation session scheduled for (date)
1) Mediation
[£7] Agreed to complete mediation by (date):
[7] Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement [} Settlement conference scheduled for (date):
conference [J Agreed to complete settlement conference by (date):
[-_] Settiement conference completed on (date):
[~~] Neutral evaluation not yet scheduled
Neutral hati heduied fos te):
(3) Neutrat evaluation [7] Neutral evaluation scheduted for (date).
[C7] Agreed to complete neutral evaluation by (date).
[| Neutral evaluation completed on (date):
[] Judicial arbitration not yet scheduled
(4) Nonbinding judicial co [[] Judicial arbitration scheduled for (date)
arbitration (7) Acreed to complete judicial arbitration by (date):
[1 Judicial arbitration completed on (date):
(=) Private arbitration not yet scheduled
(5) Binding private Eo [-] Private arbitration scheduled for (date):
arbitration [77] Agreed to complete private arbitration by (date)
[_] Private arbitration completed on (date):
[([7’] ADR session not yet scheduled
(6) Other (specify): co [_] AOR session scheduled for (date):
[C3] Agreed to comptete ADR session by (date):
[7] ADR completed on (date)
GM i0 (Rev. September 1. 2023]
CASE MANAGEMENT STATEMENT Pages ofSCM-140
PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lez Moss, a Minor CASE NUMBER:
DEFENDANT/RESPONDENT: Noe Garcia, et al. BCV 20-102977 and BCV-21-101449
41. Insurance
a. [7] 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.
[7] Bankruptcy [[7] Other (specify):
Status:
13. Related cases, consolidation, and coordination
a There are companion, underlying, or related cases.
(1) Name of case: Sertic v. Garcia, et al.
(2) Name of court: Kern County Superior Court
(3) Case numberBCV-19-103330
(4) Status: consolidated with BCV-20-102977
{__] Additional cases are described in Attachment 13a.
b. (J Amotion to [J consolidate [_} coordinate will 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 mations before trial (specify moving party, type of motion, and issues):
Motions in Limine
18. Discovery
a The party or parties have completed ail discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiffs Deposition of Defendant November, 2022
Plaintiffs Depositions of several PMKS November, 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):
EMENO Rew September |, 2021) CASE MANAGEMENT STATEMENT Page sorsCM-110
PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor | case wuneer
DEFENDANT/RESPONDENT: Noe Garcia, et al BCV 20-102977 and BCV-21-10/449
17. Economic litigation
a, [""] This is a limited civil case (1.¢., 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, (C7) 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 ary):
| 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 wil! possess the authority to enter into stipulations on these issues at the time of
the case management conference, inciuding the written authority of the party where required. seen on,
date Z- if - QetL oe Ti |v
NED E. DUNPHY
ena Oo Sater TET
(TYPE OR PRINT NAME} (SIGNATURE OF PARTY OR ATTORNEY]
{} Additional signatures are attached.
(FYPE OR PRINT NAB
Page § of 6
OMG (Rey Semerber 1.2024] CASE MANAGEMENT STATEMENTithe Law Ottices Ot
Young Wooldridge, LLP
ARTNERSHIP COMPOSED OF PROFESSIONAL CORPORATIONS,
CA 93301-5298 © Telephone 661-327-9661 © Facsimile 661-327-1087 ¢ http://www.youngwooidridge.com
Westchester Corporate Plaza # 1806 30" Street, Fourth Floor «© Bakersfiel
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF KERN
1, YESENIA LAMBARENA, declare: | am and was at the times of the service hereunder
mentioned, over the age of eighteen (18) years, and not a party to the within cause. My business address is
The Westchester Corporate Plaza, 1800 30th Street, Fourth Floor, Bakersfield, CA 93301.
On August [ 1, 2022, I caused to be served the below listed document(s) titled as: CASE
MANAGEMENT STATEMENT on the interested parties in this action, as listed below:
See Attached Service List
(BY MAIL), pursuant to C.C.P. § 1013(a). By placing /_/ the original or /x/ a true copy
thereof’ enclosed in a sealed envelope. I am readily familiar with the firm's practice of
collection and processing of documents for mailing. Under that practice it would be deposited
with United States Postal Service on that same day with postage thereon fully prepaid at
Bakersfield, California in the ordinary course of business.
(BY FACSIMILE TRANSMISSION), pursuant to Rule § 2.306 of the California Rules of
Court. The telephone number of the sending facsimile machine was (661) 327-1087. A
transmission report was properly issued by the sending facsimile machine, and the
transmission was reported as complete and without error.
(BY PERSONAL SERVICE), pursuant to C.C.P. § 1011, 1 caused such envelope to be
delivered by hand to the offices of the addressee(s).
x ONLY BY EMAIL TRANSMISSION: Pursuant fo Emergency Rule 12 of the California
Code of Civil Procedure, which was adopted by the Judicial Counsel in response to the
COVID-19 pandemic, this document is being served by electronic transmission only.
Executed on August 11, 2022, at Bakersfield, California.
Xx (STATE) I declare under penalty of perjury under the laws of the State of California that the
above is true and correct,
(FEDERAL) I declare that | am employed in the office of a member of the bar of this Court
at whose direction the service was made. /
[ [tyes HL saben”
mia Lambarena.&
2 1 SERVICE LIST
<
2 2
# .
2 3|| Brooklyn Deann Moss V. Noe Garcia, et al.
Z 4 Case No. BCV-19-103330 CW/ BCV-20-102977 and BCV-21-101449
=
= 5 Justin Lowtrip, Esq.
. 11150 W. Olympic Blvd., Suite 1050
5 6 Los Angeles, CA 90064
= T: (424) 273-1462
8 7 Howtrip@Glowtriplaw.com
= 8 edentqlowtriplaw.com
z Attorneys for Defendants/Cross-Defendants
vi 9 LAURA GUIDO and NOE GARCIA AND D&L TRUCKING DOE 1}
Be gg (10 Thomas W. Shaver, Esq.
see oa SHAVER, KORFF & CASTRONOVO LLP
ia 16255 Ventura Boulevard, Suite 850
et 12 Encino, CA 91436
asd Attorney for Defendant ERIC SERTIC
weg 1 fs@ske-law.com
oss
2 6 4 Jaw. com
5 Ort
z = Ashkhan Mohamadi, Esq.
See «J SWEET JAMES, LLP
& ons 3 17 4220 Von Karman Avenue, Suite 200
= g 2¢ Attorneys for Plaintiff ERIC SERTIC
° 32 18 Related Case No. BCV-19-103330
> z ashkahn{@sweetjames.com
19 emil cijames.com
= a9 piperj@sweetjames.com
F kiannaw@sweeljames.com
= 2
E
e 2
3 23
; 44
3 25
EB 26
3
2 27
28
Preview
CM-110 AT TORTIE” OR BARTY WF HOUT ATTORNEY (ame, Sale Oar number, ond aadress} Ned E. Dunphy SBN: 128601 FOR COURT USE Oni THE LAW OFFICES YOUNG WOOLDRIDGE, LLP 1800 30th Sirect, Fourth Floor, Bakersfield, CA 93301 yeteruoxe no: 661-327-9661 FAK NO. (Optional 661-327-1087 Ewa acorese ndunphy@youngwooldridge.com ATTORNEY FOR (Name) Plaintiffs, Levi Cole Moss, a minor, and Aiden Lee Moss, a minor SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN STREET ADDRESS {245 Truxtun Avenue MAILING ADDRESS: 1215 Truxtun Avenue SFYANOZPCODE Bakersfield. 93301 BRANGHNAVE” Metro Justice Buildin; PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor DEFENDANT/RESPONDENT: Noe Garcia, ct al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE [<7] 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: August 26, 2022 Time:8:30 a.m. Dept.: Div.) Room: Address of court (if different from the address above): |X] Notice of intent to Appear by Telephone, by (name): Ned E. Dunphy INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 4. Party or parties (answer ona): a This statement is submitted by party (name): Plaintiffs, Levi Cole Mass and Aiden Lee Moss b. [(—] This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to 5e answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): December 21, 2020 b. [(_] The cross-compiaint, if any, was fited on (date): 3. Service (to be answered by plaintiffs and crass-complainants only) a, Ai! parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [77] The following parties named in the complaint or cross-complaint (1) ([ 5) have not been served (specify names and explain why nol): {2) [__] 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. [77] 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 [C2] cross-complaint (Describe, including causes of action): Motor vehicle accident resulting in wrongfil death, Paget ofS Cal Rules ef Cour, ‘eaten CASE MANAGEMENT STATEMENT ARSSS SNe wom ccurts.e@ gov estan Di & Fr BudeCM-110 PLAINTIFF/PET:TIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor CASE NUMBER: DEFENDANTIRESPONDENT: Noo Garcia, et al. BCV 20-102977 and BCV-21-101449 A. 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 fo dale {indicate source and amount], estimated future medical expenses, iost earnings to date, and estimated future /ost earnings. if equitable relief is sought, describe the nature of the relief.) Plaintiffs, Levi Cole Moss and Aiden Lee Moss are the children 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 trial The party or parties request a jury trial [7] a nonjury trial. (/f more than one party, provide the name of each party requesting a jury trial): 6. Trial date a, ["7] 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): ¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 11/14/22-1 1/25/22; 05/01/23-05/08/23; 05/22/23-05/29/23 due 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 6. [[~] hours (short causes) (specify): 8. Trial representation (fo be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption [7] 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 (speciiy 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 setf-represented parties: Party [[] has [77] 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 177£.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 fimit recovery to the amount specified in Code of Civil Procedure section 1141.11 (3) (""] This case is exempt from judicial arbitration under rule 3.641 of the California Ruies of Court or from civil action mediation under Code of Civit Procedure section 1775 et seq. (specify exemption): Page 2 of 5 EMO Rev September 1 2021) CASE MANAGEMENT STATEMENTCM-110 PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor __| case vewser. DEFENDANT/RESPONDENT: Noe Garcia, etal, BCV 20-!02977 and BCV-21-101449 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 ihe specified information): |The party or parties completing Ithis form are willing to participate in the following ADR processes (check ail that apply): If the pary cr 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): Mediation session not yet scheduled [] Mediation session scheduled for (date) 1) Mediation [£7] Agreed to complete mediation by (date): [7] Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement [} Settlement conference scheduled for (date): conference [J Agreed to complete settlement conference by (date): [-_] Settiement conference completed on (date): [~~] Neutral evaluation not yet scheduled Neutral hati heduied fos te): (3) Neutrat evaluation [7] Neutral evaluation scheduted for (date). [C7] Agreed to complete neutral evaluation by (date). [| Neutral evaluation completed on (date): [] Judicial arbitration not yet scheduled (4) Nonbinding judicial co [[] Judicial arbitration scheduled for (date) arbitration (7) Acreed to complete judicial arbitration by (date): [1 Judicial arbitration completed on (date): (=) Private arbitration not yet scheduled (5) Binding private Eo [-] Private arbitration scheduled for (date): arbitration [77] Agreed to complete private arbitration by (date) [_] Private arbitration completed on (date): [([7’] ADR session not yet scheduled (6) Other (specify): co [_] AOR session scheduled for (date): [C3] Agreed to comptete ADR session by (date): [7] ADR completed on (date) GM i0 (Rev. September 1. 2023] CASE MANAGEMENT STATEMENT Pages ofSCM-140 PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lez Moss, a Minor CASE NUMBER: DEFENDANT/RESPONDENT: Noe Garcia, et al. BCV 20-102977 and BCV-21-101449 41. Insurance a. [7] 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. [7] Bankruptcy [[7] Other (specify): Status: 13. Related cases, consolidation, and coordination a There are companion, underlying, or related cases. (1) Name of case: Sertic v. Garcia, et al. (2) Name of court: Kern County Superior Court (3) Case numberBCV-19-103330 (4) Status: consolidated with BCV-20-102977 {__] Additional cases are described in Attachment 13a. b. (J Amotion to [J consolidate [_} coordinate will 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 mations before trial (specify moving party, type of motion, and issues): Motions in Limine 18. Discovery a The party or parties have completed ail discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Plaintiffs Deposition of Defendant November, 2022 Plaintiffs Depositions of several PMKS November, 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): EMENO Rew September |, 2021) CASE MANAGEMENT STATEMENT Page sorsCM-110 PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor | case wuneer DEFENDANT/RESPONDENT: Noe Garcia, et al BCV 20-102977 and BCV-21-10/449 17. Economic litigation a, [""] This is a limited civil case (1.¢., 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, (C7) 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 ary): | 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 wil! possess the authority to enter into stipulations on these issues at the time of the case management conference, inciuding the written authority of the party where required. seen on, date Z- if - QetL oe Ti |v NED E. DUNPHY ena Oo Sater TET (TYPE OR PRINT NAME} (SIGNATURE OF PARTY OR ATTORNEY] {} Additional signatures are attached. (FYPE OR PRINT NAB Page § of 6 OMG (Rey Semerber 1.2024] CASE MANAGEMENT STATEMENTithe Law Ottices Ot Young Wooldridge, LLP ARTNERSHIP COMPOSED OF PROFESSIONAL CORPORATIONS, CA 93301-5298 © Telephone 661-327-9661 © Facsimile 661-327-1087 ¢ http://www.youngwooidridge.com Westchester Corporate Plaza # 1806 30" Street, Fourth Floor «© Bakersfiel PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF KERN 1, YESENIA LAMBARENA, declare: | am and was at the times of the service hereunder mentioned, over the age of eighteen (18) years, and not a party to the within cause. My business address is The Westchester Corporate Plaza, 1800 30th Street, Fourth Floor, Bakersfield, CA 93301. On August [ 1, 2022, I caused to be served the below listed document(s) titled as: CASE MANAGEMENT STATEMENT on the interested parties in this action, as listed below: See Attached Service List (BY MAIL), pursuant to C.C.P. § 1013(a). By placing /_/ the original or /x/ a true copy thereof’ enclosed in a sealed envelope. I am readily familiar with the firm's practice of collection and processing of documents for mailing. Under that practice it would be deposited with United States Postal Service on that same day with postage thereon fully prepaid at Bakersfield, California in the ordinary course of business. (BY FACSIMILE TRANSMISSION), pursuant to Rule § 2.306 of the California Rules of Court. The telephone number of the sending facsimile machine was (661) 327-1087. A transmission report was properly issued by the sending facsimile machine, and the transmission was reported as complete and without error. (BY PERSONAL SERVICE), pursuant to C.C.P. § 1011, 1 caused such envelope to be delivered by hand to the offices of the addressee(s). x ONLY BY EMAIL TRANSMISSION: Pursuant fo Emergency Rule 12 of the California Code of Civil Procedure, which was adopted by the Judicial Counsel in response to the COVID-19 pandemic, this document is being served by electronic transmission only. Executed on August 11, 2022, at Bakersfield, California. Xx (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and correct, (FEDERAL) I declare that | am employed in the office of a member of the bar of this Court at whose direction the service was made. / [ [tyes HL saben” mia Lambarena.& 2 1 SERVICE LIST < 2 2 # . 2 3|| Brooklyn Deann Moss V. Noe Garcia, et al. Z 4 Case No. BCV-19-103330 CW/ BCV-20-102977 and BCV-21-101449 = = 5 Justin Lowtrip, Esq. . 11150 W. Olympic Blvd., Suite 1050 5 6 Los Angeles, CA 90064 = T: (424) 273-1462 8 7 Howtrip@Glowtriplaw.com = 8 edentqlowtriplaw.com z Attorneys for Defendants/Cross-Defendants vi 9 LAURA GUIDO and NOE GARCIA AND D&L TRUCKING DOE 1} Be gg (10 Thomas W. Shaver, Esq. see oa SHAVER, KORFF & CASTRONOVO LLP ia 16255 Ventura Boulevard, Suite 850 et 12 Encino, CA 91436 asd Attorney for Defendant ERIC SERTIC weg 1 fs@ske-law.com oss 2 6 4 Jaw. com 5 Ort z = Ashkhan Mohamadi, Esq. See «J SWEET JAMES, LLP & ons 3 17 4220 Von Karman Avenue, Suite 200 = g 2¢ Attorneys for Plaintiff ERIC SERTIC ° 32 18 Related Case No. BCV-19-103330 > z ashkahn{@sweetjames.com 19 emil cijames.com = a9 piperj@sweetjames.com F kiannaw@sweeljames.com = 2 E e 2 3 23 ; 44 3 25 EB 26 3 2 27 28