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  • BCV-20-10047323-CV Other PI/PD/WD - Civil Unlimited document preview
  • BCV-20-10047323-CV Other PI/PD/WD - Civil Unlimited document preview
  • BCV-20-10047323-CV Other PI/PD/WD - Civil Unlimited document preview
  • BCV-20-10047323-CV Other PI/PD/WD - Civil Unlimited document preview
  • BCV-20-10047323-CV Other PI/PD/WD - Civil Unlimited document preview
  • BCV-20-10047323-CV Other PI/PD/WD - Civil Unlimited document preview
  • BCV-20-10047323-CV Other PI/PD/WD - Civil Unlimited document preview
  • BCV-20-10047323-CV Other PI/PD/WD - Civil Unlimited document preview
						
                                

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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 08/29/2022 McDougal v Estate of Vasquez 09/08/2022 PKO -VACATION Sept 8-14 10/10/2022 SP VACATION -HAWAII Oct. 10-19th 10/21/2022 Athena Grech v. Liliana Drolet-Fisher 10/24/2022 Corcoran v Irvine Community Development Co. 10/31/2022 Guerra v Singh (In Liquidation) [VON REYES] 11/14/2022 MDM -VACATION HAWAII -returns Monday 11/21 11/18/2022 Torres v John's Incredible Pizza Company, Inc. 11/21/2022 Shankar v John's Incredible Pizza Company, Inc. 11/21/2022 Luck v Labiano" In Liquidation" [WILLIAM JENKINS) 12/02/2022 Calderon v Singh; Kaur Limo, LLC (In Liquidation) [SEEGER] 12/06/2022 Banks v The Academy of MagicalArts, Inc. 12/12/2022 Mairs v Morris 12/19/2022 KATHY -VACATION Mexico 12/19-12/26 01/04/2023 Vierra v Padilla 01/10/2023 Appleby v Canton-Lamousse (In Liquidation) [SEEGER] 01/17/2023 Sifuentes v Mettler, Castro 01/30/2023 Tinkey v The Hampstead Group, Inc..; CIEW Tree 8 Landscape Co. 02/14/2023 Quach v De Anza Land and Leisure Corporation 02/24/2023 Tovar v AECOM; Pacific Steel Group 03/17/2023 Watson v. JumpSport 04/03/2023 Barlow v Espinosa 04/10/2023 Lawrence v Navarro [LEAD CASE] 04/10/2023 Davis v John's Incredible Pizza Company, Inc. 06/12/2023 Pelayo v John's Incredible Pizza Company, Inc. 06/23/2023 Nelson v Caminiti; Johnson 10/02/2023 Hedman v Keating 11/13/2023 Aguirre v Catamount Properties 2018, LLC; Dusten Perry 03/04/2024 Shaver v Vigil, Pacific Recycling 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