Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Bar number, and address/: FOR COURT VSE ONLY
Patrick O'rien 167957/Zsuzsanna Veres 315782
O'RIEN LAW, P.C.
755 Baywood Dr., Ste. 185, Petaluma, California 94954
TELEPHONENOJ (707) 789-6500 FAXNO.(OPb'anat(; (707) 789-6520
E-MAILADDREss (optional): suzie@pobrienlaw.corn
ATTORNEY FOR PAVLETICH ELECTRIC & COMMUNICATIONS, INC.
(Namai:
SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN
sTREETADDREss.'415 Truxtun Ave
MAIUNG ADDRESS:
OITYAN»lpcoDE: Bakersfield, CA 93301
BRANOH NAMLE
Metro olitan Division Justice Buildin
PLAINTIFF/PETITIONER: ZURICH AMERICAN INTERNATIONAL COMPANY
DEFENDANT/RESPONDENT: PAVLETICH ELECTRIC & COMMUNICATIONS, INC
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): Hv'NLIMITED CASE
(Amount demanded
W LIMITED CASE BC V-20-100473
(Amount demanded is $ 25,000
exceeds $25,000) orless)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: September 9, 2022 Time: 8:15 am Dept.: 17 Div.: Room: 17
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name)r Zsuzsanna Veres
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a.
b. ~
~vr This statement is submitted by party (name):PAVLETICH ELECTRIC
This statement is submitted jointly by parties (names):
& COMMUNICATIONS, INC.
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a.
b. ~
The complaint was filed on (date):02/14/2020
The cross-complaint, if any, was filed on (date):
10/13/2020
3. Service (to be answered by plaintiffs and cross-complainanls only)
a. ~v'll parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. H ~
The following parties named in the complaint or cross-complaint
have not been served (specify names and explain why not):
(1)
(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 ofinvolvementin case, and date by which
they may be served):
4. Description of case
a. Type of case in ~v'omplaint cross-complaint (Describe, including causes of action):
Personal Injury
Pa e1of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judisaal Council of California
CASE MANAGEMENT STATEMENT rules 3.720-3.730
CM-110 IRev. July 1. 2011] wwrv. Courts ca.pov
CM-110
PLAINTIFF/PETITIONER: ZURICH AMERICAN INTERNATIONAL COMPANY
BC V-20-100473
DEFENDANT/RESPONDENT: PAVLETICH ELECTRIC 8 COMMUNICATIONS, INC
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 reliefis sought, describe the nature of the relief)
Subrogation case in which an employee of Plaintiffs insured was allegedly injured at work site due to unmarked
piece of plumbing, piping or conduit sticking out of the ground.
(If morespaceis needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parfies request C~] C]
a jury trial a nonjury trial. (If more than one party, provide the name of each party
requesting aj ury trial):
6.
a.
b.
~
Trial date
~v
The tdial has been set for (date):
No tdial 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):
c. Dates on which parties or attorneys
willnot be available for trial (specify dates and explain reasons for unavailability):
See attached
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
~e'ays
a.
b. ~ (specify number):3-5
hours (short causes) (specify):
8.
~
Trial representation (to be answered for each party)
The party or parties will be represented at trial
a. Attorney:
~
by the attorney or party listed in the caption by the following:
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: CounselK has H has not
to the client and reviewed ADR options with the client.
in rule 3.221
provided the ADR information package identified
(2) H
For self-represented parties: Party has H has not reviewed the ADR information package identified in rule 3.221.
b.
(1) ~
Referral to judicial arbitration or civil action mediation (if available).
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) ~ case to judicial arbitration and agrees to limit recovery to the amount specified
Plaintiff elects to refer this
Procedure section 1141.11.
Civil
inCode of
(3) ~ This case is exempt from judicial arbitration under rule 3.811
of the California Rules of Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM-ug IRev. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: ZURICH AMERICAN INTERNATIONAL COMPANY '" R
EFENDANT/RESPONDENT: PAVLETICH ELECTRIC & COMMUNICATIONS, INC
10. c. Indicate the ADR processor processes that the party or parties are willing to participate in, have agreed to participate
in, or
have already participatedin (check all that apply and provide the specifiedinformation):
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
Binding private Private arbitration scheduled for (date):
(5)
arbitration
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other (speciTy):
Agreed to complete ADR session by (date):
ADR completed on (date):
C M-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
PLAINTIFF/PETITIONER: ZURICH AMERICAN INTERNATIONAL COMPANY
BCV-20-100473
DEFENDANT/RESPONDENT: PAVLETICH ELECTRIC & COMMUNICATIONS, INC
11.Insurance
a. ~v'nsurance camer, if any, for party filing this statement (name);
National Claim Services
M M
b.
c. ~
Reservation of rights: Yes No
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.
Status:
Bankruptcy H Other (specify):
~
13. Related cases, consolidation, and coordination
There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
b.
~
H
(4) Status:
Additional cases are described in Attachment 13a.
A motion to H consolidate W 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 motions before trial (specify moving party, type of motion, and issues):
16.
a.
b.
~
Discovery
~f'he
The party or parties have completed all discovery.
by the date specified (describe ail anticipated discovery):
following discovery will be completed
~Paft ~as n Date
Defendant Experts Per Code
c, ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-1 10 [Rau. July 1, 2011I
CASE MANAGEMENT STATEMENT Page 4 of 5
CM-110
PLAINTIFF/PETITIONER: ZURICH AMERICAN INTERNATIONAL COMPANY
BCV-20-100473
DFFBN()ANTtRE$ PON05NT. PAVLETICH ELECTRIC & COMMUNICATIONS, INC
17.
a.~
Economic litigation
This is a limited civil case (I.e., the amount demanded is $ 25,000 or less) and the economic litigation procedures in Code
b.~ of Civil Procedure sections 90-98 will apply to this case.
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 frial
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. ~v'he 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 conferringas 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): 2
Iam 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 parly where re
uir
Date: August 10, 2022
ZSUZSANNA VERES
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(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
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PROOF OF SERVICE
Zurich v Pavletich Electric d'c Communications, Inc.
Kern
Case No. BCV-20-100473
I, the undersigned, hereby declare that I am over the age of 18 years and not a party to the
above-captioned action; that my business address is 755 Baywood Drive, Suite 185 Petaluma,
CA 94954.
On the date set forth below, the following document(s) were served:
CASE MANAGEMENT STATEMENT
on the other party to this action at the following address:
9
10 Patrick Quigley Ernest A. Vargas
Morales, Fierro 4 Reeves LAW OFFICES OF VARGAS 8c VARGAS
2151 Salvio St ¹280 301 North Lake Avenue ¹120
Concord, CA 94520 Pasadena, CA 91101
12 Main: (626) 440-1111
Main: (925) 288-1776
Attorneys for Plaintiff Attorneys for Plaintiff
Zurich American International Company Hugo Gomez
14
15 Peter M. Hughes
Darren W, Epps
16 EPPS k GILROY, LLP Wilson, Elser, Moskowitz, Edelman k Dicker,
2650 Industrial Parkway, Sutie 100 LLP
17 Santa Maria, CA 93455 401 West A Street, Suite 1900
Main: (805) 544-4875 San Diego, CA 92101-8484
Attorneys for Defendant Main: (619) 321-6200
19 Gandola's Landscaping A Lawn Care, Attorneys for
Inc. Rios Design Studio, LLC
20
21
22 I caused such documents to be sent via electronic transmission to the
H (BY E-MAIL)
persons listed above.
24 Ideclare under penalty of perjury under the laws of the United States that the foregoing is
25 true and correct.
Executed August 12, 2022, at Petaluma, California.
26
27
28 ia Jo
Proof of Service