Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and agdross) FOR COURT USE ONLY
Sybil L. Renick (#213149)
Prather Law Offices
245 Fifth Street, Suite 204, San Francisco, CA 94103 ELECTRONICALLY
Tevernioneno. (415) 881-7774 FAXNO. (Optina FILED
E-MAIL ADDRESS (Optionay: Sybil @ pratherlawoffices.com Superior Court of California,
ATTORNEY FOR (Nene): Defendant Security Intelliaence Specialist Corporation County of Sen Frapeisee
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco 02/26/2019
streer appress: 400 McAllister Street Clerk of the Court
MAILING ADDRESS: eee
i Deputy Clerk
city AND zip cope: San Francisco, CA 94102
RANCH NAME:
PLAINTIFF/PETITIONER: Justin Pham
DEFENDANT/RESPONDENT: Zen Compound, LLC, et al.
CASE MANAGEMENT STATEMENT ee
(Check one): [¥] UNLIMITED CASE LIMITED CASE CGC-18-564727
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: March 13, 2019 Time: 10:30 a.m. Dept.: 610 Div.: Room:
Address of court (if different from the address above):
v | Notice of Intent to Appear by Telephone, by (name): Sybil Renick
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): Defendant Security Intelligence Specialist Corporation
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
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 ofcase in [7] complaint ctoss-complaint (Describe, including causes of action):
Personal Injury; Negligence; Premises Liability
Page 1 ot
Formdeist Court Caltorrig CASE MANAGEMENT STATEMENT Gal Ries of Cou,
CM-110 Rev. July 4, 2011] www. courts.ca.gouCM-110
PLAINTIFF/PETITIONER: Justin Pham
DEFENDANT/RESPONDENT: Zen Compound, LLC, et al.
‘CASE NUMBER:
CGC-18-564727
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 claims he sustained personal injuries in an altercation involving Defendant's security guards employees
while they were on duty at Temple Nightclub. Defendant denies the allegations.
5. Jury or nonjury trial
(if more space is needed, check this box and attach a page designated as Attachment 4b.)
The party or parties request. [7] a jury trial anonjury 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. L¥] 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):
Defendant was not served with the complaint until December 18, 2018
cc. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [7] days (specify number): 5 days
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial [47] 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
statutory limit.
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
(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 Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
Pe ep eet CASE MANAGEMENT STATEMENT
Page 20f5CM-110
PLAINTIFF/PETITIONER: Justin Pham [EASE NUMBER:
IEFENDANT/RESPONDENT: Zen Compound, LLC, et al. CGC-18-564727
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
(6) 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
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
OOOUO;/OO00;O000;0000
ADR completed on (date):
‘GN=TTO [Rev. July 1, 2019) Page 3 ofS
CASE MANAGEMENT STATEMENTCM-1
PLAINTIFF/PETITIONER: Justin Pham CASE NUMBER:
io CGC-18-564727
DEFENDANT/RESPONDENT: Zen Compound, LLC, et al.
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.
(4) Status:
(1) Name of case:
(2) Name of court:
(3) Case number:
Additional cases are described in Attachment 13a.
b. A mation to
consolidate coordinate will be filed by (name party):
14. Bifurcation
15. Other motions
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):
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. The party or parties have completed all discovery.
b. L¥ | The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendant Written Discovery July 2019
Defendant Depositions October 2019
Defendant Expert Discovery per code
c The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
‘M110 [Rev, July 1, 2011)
CASE MANAGEMENT STATEMENT
Page 4 of 5cmM-11
PLAINTIFFIPETITIONER: Justin Pham eT
DEFENDANT/RESPONDENT: _2€N Compound, LLC, et al. cee teeearet
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. [£1] 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’ 7
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):
| 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: February 26, 2019
Sybil L. Renick Sabi
(TYPE OR PRINT NAME) PARTY OR ATTORNEY)
‘(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
7 Additional signatures are attached.
HCHO Ree aay 204) CASE MANAGEMENT STATEMENT SrPROOF OF SERVICE
Justin Pham v. Zen Compound, LLC dba Temple SF Night Club, et al.
San Francisco Superior Court Case No. CGC-18-564727
I, the undersigned, declare: :
Iam over the age of 18 years, a resident of the State of California and employed in San
Francisco County, California, and not a party to the within action or cause. My business address
is 245 Fifth Street, Suite 103, San Francisco, California 94103.
I served a copy of the document listed below by placing said copy in an envelope which
was then sealed with postage fully prepaid thereon, and deposited same with the United States
Postal Service in the city of San Francisco, California.
Document: : 7
Defendant Security Intelligence Specialist Corporation’s Case Management Statement
Recipients: :
John P. Strouss, IIT
Law Offices of John P. Strouss, IIT
819. Eddy St.
San Francisco, CA 94109
I certify (or declare) under penalty of perjury under the laws of the State of California that the
foregoing is true and correct and that this Declaration was executed on February 26, 2019.
Proof of Service
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and agdross) FOR COURT USE ONLY Sybil L. Renick (#213149) Prather Law Offices 245 Fifth Street, Suite 204, San Francisco, CA 94103 ELECTRONICALLY Tevernioneno. (415) 881-7774 FAXNO. (Optina FILED E-MAIL ADDRESS (Optionay: Sybil @ pratherlawoffices.com Superior Court of California, ATTORNEY FOR (Nene): Defendant Security Intelliaence Specialist Corporation County of Sen Frapeisee SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco 02/26/2019 streer appress: 400 McAllister Street Clerk of the Court MAILING ADDRESS: eee i Deputy Clerk city AND zip cope: San Francisco, CA 94102 RANCH NAME: PLAINTIFF/PETITIONER: Justin Pham DEFENDANT/RESPONDENT: Zen Compound, LLC, et al. CASE MANAGEMENT STATEMENT ee (Check one): [¥] UNLIMITED CASE LIMITED CASE CGC-18-564727 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: March 13, 2019 Time: 10:30 a.m. Dept.: 610 Div.: Room: Address of court (if different from the address above): v | Notice of Intent to Appear by Telephone, by (name): Sybil Renick 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): Defendant Security Intelligence Specialist Corporation b. This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): 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 ofcase in [7] complaint ctoss-complaint (Describe, including causes of action): Personal Injury; Negligence; Premises Liability Page 1 ot Formdeist Court Caltorrig CASE MANAGEMENT STATEMENT Gal Ries of Cou, CM-110 Rev. July 4, 2011] www. courts.ca.gouCM-110 PLAINTIFF/PETITIONER: Justin Pham DEFENDANT/RESPONDENT: Zen Compound, LLC, et al. ‘CASE NUMBER: CGC-18-564727 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 claims he sustained personal injuries in an altercation involving Defendant's security guards employees while they were on duty at Temple Nightclub. Defendant denies the allegations. 5. Jury or nonjury trial (if more space is needed, check this box and attach a page designated as Attachment 4b.) The party or parties request. [7] a jury trial anonjury 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. L¥] 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): Defendant was not served with the complaint until December 18, 2018 cc. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [7] days (specify number): 5 days b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial [47] 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 statutory limit. mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the (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 Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): Pe ep eet CASE MANAGEMENT STATEMENT Page 20f5CM-110 PLAINTIFF/PETITIONER: Justin Pham [EASE NUMBER: IEFENDANT/RESPONDENT: Zen Compound, LLC, et al. CGC-18-564727 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 (6) 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 ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): OOOUO;/OO00;O000;0000 ADR completed on (date): ‘GN=TTO [Rev. July 1, 2019) Page 3 ofS CASE MANAGEMENT STATEMENTCM-1 PLAINTIFF/PETITIONER: Justin Pham CASE NUMBER: io CGC-18-564727 DEFENDANT/RESPONDENT: Zen Compound, LLC, et al. 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. (4) Status: (1) Name of case: (2) Name of court: (3) Case number: Additional cases are described in Attachment 13a. b. A mation to consolidate coordinate will be filed by (name party): 14. Bifurcation 15. Other motions 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): The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. The party or parties have completed all discovery. b. L¥ | The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant Written Discovery July 2019 Defendant Depositions October 2019 Defendant Expert Discovery per code c The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): ‘M110 [Rev, July 1, 2011) CASE MANAGEMENT STATEMENT Page 4 of 5cmM-11 PLAINTIFFIPETITIONER: Justin Pham eT DEFENDANT/RESPONDENT: _2€N Compound, LLC, et al. cee teeearet 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. [£1] 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’ 7 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): | 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: February 26, 2019 Sybil L. Renick Sabi (TYPE OR PRINT NAME) PARTY OR ATTORNEY) ‘(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) 7 Additional signatures are attached. HCHO Ree aay 204) CASE MANAGEMENT STATEMENT SrPROOF OF SERVICE Justin Pham v. Zen Compound, LLC dba Temple SF Night Club, et al. San Francisco Superior Court Case No. CGC-18-564727 I, the undersigned, declare: : Iam over the age of 18 years, a resident of the State of California and employed in San Francisco County, California, and not a party to the within action or cause. My business address is 245 Fifth Street, Suite 103, San Francisco, California 94103. I served a copy of the document listed below by placing said copy in an envelope which was then sealed with postage fully prepaid thereon, and deposited same with the United States Postal Service in the city of San Francisco, California. Document: : 7 Defendant Security Intelligence Specialist Corporation’s Case Management Statement Recipients: : John P. Strouss, IIT Law Offices of John P. Strouss, IIT 819. Eddy St. San Francisco, CA 94109 I certify (or declare) under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this Declaration was executed on February 26, 2019. Proof of Service