Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Jeffrey M. Lenkov (SBN: 156478)
Daniel J. Sullivan (SBN: 251455)
MANNING & KASS, ELLROD, RAMIREZ, TRESTER LLP
801 S. Figueroa St., 15th Floor
Los Angeles, CA 90017-3012
TELEPHONE NO.: (213) 624-6900 (213)
FAX NO. (Optional): 624-6999
E-MAIL ADDRESS (Optional): jml@manningllp.com; djs@manningllp.com
ATTORNEY FOR (Name): Dfts.,
MAURICIO G. CEJA MADRIGAL; CARRERA GARCIA ET AL.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA
600
STREET ADDRESS: Administration Drive
600
MAILING ADDRESS: Administration Drive
CITY AND ZIP CODE: Santa Rosa, 95403-2878
BRANCH NAME: Civil Division
PLAINTIFF/PETITIONER:MARINA MIRANDA; ISABELLA MIRANDA by GAL -
DAVID MIRANDA; WYATT MIRANDA by GAL - RUDY MIRADA
DEFENDANT/RESPONDENT:MAURICIO G. CEJA MADRIGAL; CARRERA GARCIA
TRANSPORT, LLC; WADE TRANSPORTATION COMPANY, INC.; ET AL.
CASE NUMBER:
CASE MANAGEMENT STATEMENT
(Check one): X UNLIMITED CASE LIMITED CASE SCV-270065
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 08/25/2022 Time: 3:00 p.m. Dept.: 19 Div.: Civil Room:
Address of court (if different from the address above):
3055 Cleveland Avenue, Santa Rosa, CA 95403
X Notice of Intent to Appear by Telephone, by (name): Daniel J. Sullivan, Esq.
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. X This statement is submitted jointly by parties (names): Defendants, MAURICIO G. CEJA MADRIGAL;
CARRERA GARCIA TRANSPORT, LLC; WADE TRANSPORTATION COMPANY, INC.
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): 01/25/2022
b. X The cross-complaint, if any, was filed on (date):06/03/2022, by WADE TRANSPORTATION COMPANY
3. Service (to be answered by plaintiffs and cross-complainants only)
a. X 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. X The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served): Defendants anticipate a Motion for Leave to File Cross-Complaint against
plantiff MARINA MIRANDA for motor vehicle neglgience/nelgigent entrustment and against the Estate
of Stephanie Elizabeth Miranda for apportionment of fault and declaratory relief.
4. Description of case
a. Type of case in X complaint cross-complaint (Describe, including causes of action):
Motor vehicle and general negligence action seeks property damages and
wrongful death damages.
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]
CM-110
PLAINTIFF/PETITIONER: MARINA MIRANDA; ISABELLA MIRANDA by CASE NUMBER:
GAL - DAVID MIRANDA; WYATT MIRANDA by GAL - RUDY MIRAD SCV-270065
DEFENDANT/RESPONDENT: MAURICIO G. CEJA MADRIGAL; CARRERA
GARCIA TRANSPORT, LLC; WADE TRANSPORTATION COMPANY, IN
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.)
X (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 X a jury triaI a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial): Defendants, MAURICIO G. CEJA MADRIGAL; CARRERA GARCIA TRANSPORT,
LLC; WADE TRANSPORTATION COMPANY, INC.
6. Trial date
a. The trial has been set for (date):
b. X 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):Extensive discovery and motion practice is needed. Defendants
request a mid-2023 trial date.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Defense Counsel is unavailble due to trials and mandatory appearances as follows: February 8-9, 17, 21-28, 2023;
March 1-2, 6, 9-30, 2022; April 3-7, 12, 17-28, 2023; May 1-3, 10-17, 30-31, 2023; June 1-6, 12-16, 26-30, 2023;
July 5, 14, 18-25, 2023; August 4-11, 25, 31, 2023; September 8-21, 2023; October 2-6, 2023.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. X days (specify number): 5-7
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial X 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 X 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
CM-110
PLAINTIFF/PETITIONER: MARINA MIRANDA; ISABELLA MIRANDA by CASE NUMBER:
GAL - DAVID MIRANDA; WYATT MIRANDA by GAL - RUDY MIRAD SCV-270065
DEFENDANT/RESPONDENT: MAURICIO G. CEJA MADRIGAL; CARRERA
GARCIA TRANSPORT, LLC; WADE TRANSPORTATION COMPANY, IN
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):
X Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation X
Agreed to complete mediation by (date):
Mediation completed on (date):
X Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference X
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
Judicial arbitration scheduled for (date):
(4) Nonbinding judicial
arbitration Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
(5) Binding private
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 (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: MARINA MIRANDA; ISABELLA MIRANDA by CASE NUMBER:
GAL - DAVID MIRANDA; WYATT MIRANDA by GAL - RUDY MIRAD
DEFENDANT/RESPONDENT: MAURICIO G. CEJA MADRIGAL; CARRERA SCV-270065
GARCIA TRANSPORT, LLC; WADE TRANSPORTATION COMPANY, IN
11. Insurance
a. X DB
Insurance carrier, if any, for party filing this statement (name): Insurance Co., LTD
b. Reservation of rights: Yes X 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:
(2) Name of court:
(3) Case number:
(4) Status:
Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate wiII be filed by (name party):
14. Bifurcation
X 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): Defendants anticipate filing a motion
to bifurcate trial of liability from damages due to relative length and
expense of liability portion vs. the damages portion of trial and the
questionable liability in this case.
15. Other motions
X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Defendants anticipate filing Motions for Summary Judgment, or, in the
Alternative, Summary Adjuication.
16. Discovery
a. The party or parties have completed all discovery.
b. X The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendants Additional Written Discovery Within 120
days.
Defendants Depositions of Plaintiffs and Within 160
Witnesses days.
Defendants Expert Discovery Per Code.
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
CM-110
PLAINTIFF/PETITIONER: MARINA MIRANDA; ISABELLA MIRANDA by CASE NUMBER:
GAL - DAVID MIRANDA; WYATT MIRANDA by GAL - RUDY MIRA
DEFENDANT/RESPONDENT: MAURICIO G. CEJA MADRIGAL; CARRERA SCV-270065
GARCIA TRANSPORT, LLC; WADE TRANSPORTATION COMPANY, I
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. X 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): One(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: August 19, 2022
Daniel J. Sullivan
(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
PETITIONER/PLAINTIFF: MIRANDA, MARINA; Et Al. CASE NUMBER:
RESPONDENT/DEFENDANT: MADRIGAL, MAURICIO G. CEJA; Et Al. SCV-270065
38 Year-old decedent Stephaine Elizabeth Miranda, the mother of
Plaintiffs, was operating a 2016 Mazda 6 owned by plaintiff MARINA
MIRANDA, northbound on the US-101 in the City of Santa Rosa, County of
Sonoma, on 02/04/2020, at approximately 1:25 a.m. She was driving at an
excessive rate of speed and under the influence alcohol with a BAC of
0.250%, more than three times the legal limit. For unknown reasons,
potentially intentionally, she radically changed lanes from the number
one through number two lanes of US-101 to the off-ramp to Bicentennial
Way and drifted from the number one lane of the off-ramp, through the
number two lane of the off-ramp, through the right shoulder of the
northbound US-101 off-ramp to Bicentennial Way, and struck the rear of
Defendants' tractor-trailer stopped to the right of the right shoulder
of the off-ramp. Defendants' tactor and trailer lights and hazard
lights were activiated. Decedent was pronouced dead at the scene. The
California Highway Patrol traffic collision investigation, with the
assistance of their MAIT unit, determined the primary collision factor
was Decedent for violating Vehicle Code section 22107, unsafe turn.
Defendants' were not determined to be an associated factor.
Defendants dispute liability, and both the cause and extent of
Plaintiff's alleged damages.
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 801 S.
4 Figueroa St, 15th Floor, Los Angeles, CA 90017-3012.
5 On August 19, 2022, I served true copies of the following document(s) described as CASE
MANAGEMENT STATEMENT on the interested parties in this action as follows:
6
Anna Dubrovsky, Esq.
7 ANNA DUBROVSKY LAW GROUP, INC.
750 Battery Street, Suite 700
8 San Francisco, CA 94111
T: (415) 746-1477
9 F: (415) 746-1478
anna@dubrovskylawyers.com
10 clerk@dubrovskylawyers.com
Attorneys for Plaintiffs
11
ONLY BY ELECTRONIC TRANSMISSION: Only by emailing the document(s) to the
12 persons at the e-mail address(es). This is necessitated during the declared National Emergency
due to the Coronavirus (COVID-19) pandemic because this office will be working remotely, not
13 able to send physical mail as usual, and is therefore using only electronic mail. No electronic
message or other indication that the transmission was unsuccessful was received within a
14 reasonable time after the transmission. We will provide a physical copy, upon request only, when
we return to the office at the conclusion of the National Emergency.
15
I declare under penalty of perjury under the laws of the State of California that the
16 foregoing is true and correct.
17 Executed on August 19, 2022, at Los Angeles, California.
18
19
Elizabeth Solorza
20
21
22
23
24
25
26
27
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Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Jeffrey M. Lenkov (SBN: 156478) Daniel J. Sullivan (SBN: 251455) MANNING & KASS, ELLROD, RAMIREZ, TRESTER LLP 801 S. Figueroa St., 15th Floor Los Angeles, CA 90017-3012 TELEPHONE NO.: (213) 624-6900 (213) FAX NO. (Optional): 624-6999 E-MAIL ADDRESS (Optional): jml@manningllp.com; djs@manningllp.com ATTORNEY FOR (Name): Dfts., MAURICIO G. CEJA MADRIGAL; CARRERA GARCIA ET AL. SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA 600 STREET ADDRESS: Administration Drive 600 MAILING ADDRESS: Administration Drive CITY AND ZIP CODE: Santa Rosa, 95403-2878 BRANCH NAME: Civil Division PLAINTIFF/PETITIONER:MARINA MIRANDA; ISABELLA MIRANDA by GAL - DAVID MIRANDA; WYATT MIRANDA by GAL - RUDY MIRADA DEFENDANT/RESPONDENT:MAURICIO G. CEJA MADRIGAL; CARRERA GARCIA TRANSPORT, LLC; WADE TRANSPORTATION COMPANY, INC.; ET AL. CASE NUMBER: CASE MANAGEMENT STATEMENT (Check one): X UNLIMITED CASE LIMITED CASE SCV-270065 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 08/25/2022 Time: 3:00 p.m. Dept.: 19 Div.: Civil Room: Address of court (if different from the address above): 3055 Cleveland Avenue, Santa Rosa, CA 95403 X Notice of Intent to Appear by Telephone, by (name): Daniel J. Sullivan, Esq. 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. X This statement is submitted jointly by parties (names): Defendants, MAURICIO G. CEJA MADRIGAL; CARRERA GARCIA TRANSPORT, LLC; WADE TRANSPORTATION COMPANY, INC. 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): 01/25/2022 b. X The cross-complaint, if any, was filed on (date):06/03/2022, by WADE TRANSPORTATION COMPANY 3. Service (to be answered by plaintiffs and cross-complainants only) a. X 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. X The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): Defendants anticipate a Motion for Leave to File Cross-Complaint against plantiff MARINA MIRANDA for motor vehicle neglgience/nelgigent entrustment and against the Estate of Stephanie Elizabeth Miranda for apportionment of fault and declaratory relief. 4. Description of case a. Type of case in X complaint cross-complaint (Describe, including causes of action): Motor vehicle and general negligence action seeks property damages and wrongful death damages. 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] CM-110 PLAINTIFF/PETITIONER: MARINA MIRANDA; ISABELLA MIRANDA by CASE NUMBER: GAL - DAVID MIRANDA; WYATT MIRANDA by GAL - RUDY MIRAD SCV-270065 DEFENDANT/RESPONDENT: MAURICIO G. CEJA MADRIGAL; CARRERA GARCIA TRANSPORT, LLC; WADE TRANSPORTATION COMPANY, IN 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.) X (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 X a jury triaI a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): Defendants, MAURICIO G. CEJA MADRIGAL; CARRERA GARCIA TRANSPORT, LLC; WADE TRANSPORTATION COMPANY, INC. 6. Trial date a. The trial has been set for (date): b. X 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):Extensive discovery and motion practice is needed. Defendants request a mid-2023 trial date. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Defense Counsel is unavailble due to trials and mandatory appearances as follows: February 8-9, 17, 21-28, 2023; March 1-2, 6, 9-30, 2022; April 3-7, 12, 17-28, 2023; May 1-3, 10-17, 30-31, 2023; June 1-6, 12-16, 26-30, 2023; July 5, 14, 18-25, 2023; August 4-11, 25, 31, 2023; September 8-21, 2023; October 2-6, 2023. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. X days (specify number): 5-7 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial X 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 X 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 CM-110 PLAINTIFF/PETITIONER: MARINA MIRANDA; ISABELLA MIRANDA by CASE NUMBER: GAL - DAVID MIRANDA; WYATT MIRANDA by GAL - RUDY MIRAD SCV-270065 DEFENDANT/RESPONDENT: MAURICIO G. CEJA MADRIGAL; CARRERA GARCIA TRANSPORT, LLC; WADE TRANSPORTATION COMPANY, IN 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): X Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation X Agreed to complete mediation by (date): Mediation completed on (date): X Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference X 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 Judicial arbitration scheduled for (date): (4) Nonbinding judicial arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled Private arbitration scheduled for (date): (5) Binding private 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 (specify): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: MARINA MIRANDA; ISABELLA MIRANDA by CASE NUMBER: GAL - DAVID MIRANDA; WYATT MIRANDA by GAL - RUDY MIRAD DEFENDANT/RESPONDENT: MAURICIO G. CEJA MADRIGAL; CARRERA SCV-270065 GARCIA TRANSPORT, LLC; WADE TRANSPORTATION COMPANY, IN 11. Insurance a. X DB Insurance carrier, if any, for party filing this statement (name): Insurance Co., LTD b. Reservation of rights: Yes X 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: (2) Name of court: (3) Case number: (4) Status: Additional cases are described in Attachment 13a. b. A motion to consolidate coordinate wiII be filed by (name party): 14. Bifurcation X 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): Defendants anticipate filing a motion to bifurcate trial of liability from damages due to relative length and expense of liability portion vs. the damages portion of trial and the questionable liability in this case. 15. Other motions X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Defendants anticipate filing Motions for Summary Judgment, or, in the Alternative, Summary Adjuication. 16. Discovery a. The party or parties have completed all discovery. b. X The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendants Additional Written Discovery Within 120 days. Defendants Depositions of Plaintiffs and Within 160 Witnesses days. Defendants Expert Discovery Per Code. 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 CM-110 PLAINTIFF/PETITIONER: MARINA MIRANDA; ISABELLA MIRANDA by CASE NUMBER: GAL - DAVID MIRANDA; WYATT MIRANDA by GAL - RUDY MIRA DEFENDANT/RESPONDENT: MAURICIO G. CEJA MADRIGAL; CARRERA SCV-270065 GARCIA TRANSPORT, LLC; WADE TRANSPORTATION COMPANY, I 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. X 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): One(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: August 19, 2022 Daniel J. Sullivan (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 PETITIONER/PLAINTIFF: MIRANDA, MARINA; Et Al. CASE NUMBER: RESPONDENT/DEFENDANT: MADRIGAL, MAURICIO G. CEJA; Et Al. SCV-270065 38 Year-old decedent Stephaine Elizabeth Miranda, the mother of Plaintiffs, was operating a 2016 Mazda 6 owned by plaintiff MARINA MIRANDA, northbound on the US-101 in the City of Santa Rosa, County of Sonoma, on 02/04/2020, at approximately 1:25 a.m. She was driving at an excessive rate of speed and under the influence alcohol with a BAC of 0.250%, more than three times the legal limit. For unknown reasons, potentially intentionally, she radically changed lanes from the number one through number two lanes of US-101 to the off-ramp to Bicentennial Way and drifted from the number one lane of the off-ramp, through the number two lane of the off-ramp, through the right shoulder of the northbound US-101 off-ramp to Bicentennial Way, and struck the rear of Defendants' tractor-trailer stopped to the right of the right shoulder of the off-ramp. Defendants' tactor and trailer lights and hazard lights were activiated. Decedent was pronouced dead at the scene. The California Highway Patrol traffic collision investigation, with the assistance of their MAIT unit, determined the primary collision factor was Decedent for violating Vehicle Code section 22107, unsafe turn. Defendants' were not determined to be an associated factor. Defendants dispute liability, and both the cause and extent of Plaintiff's alleged damages. 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 801 S. 4 Figueroa St, 15th Floor, Los Angeles, CA 90017-3012. 5 On August 19, 2022, I served true copies of the following document(s) described as CASE MANAGEMENT STATEMENT on the interested parties in this action as follows: 6 Anna Dubrovsky, Esq. 7 ANNA DUBROVSKY LAW GROUP, INC. 750 Battery Street, Suite 700 8 San Francisco, CA 94111 T: (415) 746-1477 9 F: (415) 746-1478 anna@dubrovskylawyers.com 10 clerk@dubrovskylawyers.com Attorneys for Plaintiffs 11 ONLY BY ELECTRONIC TRANSMISSION: Only by emailing the document(s) to the 12 persons at the e-mail address(es). This is necessitated during the declared National Emergency due to the Coronavirus (COVID-19) pandemic because this office will be working remotely, not 13 able to send physical mail as usual, and is therefore using only electronic mail. No electronic message or other indication that the transmission was unsuccessful was received within a 14 reasonable time after the transmission. We will provide a physical copy, upon request only, when we return to the office at the conclusion of the National Emergency. 15 I declare under penalty of perjury under the laws of the State of California that the 16 foregoing is true and correct. 17 Executed on August 19, 2022, at Los Angeles, California. 18 19 Elizabeth Solorza 20 21 22 23 24 25 26 27 28