Preview
CM-4110
"AUIOANEY OR PARTY WITHOUT ATTORNEY (Name, Sia Bar number, and ade ASF 5329 FOR COURT USE ONLY
Brian C. O'Hara, Esq. #134024
ISKEBBA, ISAAC & BISHOP
One Montgomery St. #2550; San Francisco, CA 94104 ELECTRONICALLY
‘verertone no” 415-836-2626 FAX.NO (Options FILED
EYANL ADORESS (Optora? brian.ohara@aig.com Superior Court of California
atToaney FoR amo) JONES LASALLE AMERICAS, INC. County of San Francisco
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO 01/22/2018
street aconess 400 McAllister Street Clerk of the Court
sauna aooress: San Francisco, CA 94102 BY-RANL EDWARDS:
Gity aN 21 Cons Deputy Clorh
BRANCH NAME:
PLAINTIFF/PETITIONER: MARIE DeGUZMAN
DEFENDANTIRESPONDENT: COLUMBIA PROPERTY TRUST et al
CASE MANAGEMENT STATEMENT (CASE MUNBER
(Check one): [2] UNLIMITED CASE () umitep case CGC-17-561142
(Amount demanded (Amount demanded is $25,000
exceeds $25.000) or fess)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 2-07-18 Time: 10:30 a.m. Dept.: 610 Div: Room: 610
Address of court (if different irom the address above):
Notice of Intent to Appear by Telephone, by (name): Brian C. O'Hara
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 JONES LANG LASALLE AMERICAS, INC.
b. () Thisstatementis submitted Jointly by parties (names):
2. Complaint and cross-complaint (fo be answered by plaintiffs and crass-complainants only)
a. The complaint was filed on (date):
b. (J The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
The following parties named in the complaint or cross-complaint
(1) £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) (2) have had a default entered against them (specify names):
cs [J 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 of case in
compiaint [7] cross-compiaint (Describe, including causes of action):
Personal injury action; slip & fall accident on wet floor in labby of building owned by dft Columbia. Dft JLL is
facilities manager, dit ABM dba Crown Janitorial is janitorial service. Discovery underway.
Page tots.
Fog Agana iene oo CASE MANAGEMENT STATEMENT STS
CMA110 (Rev, July 4, 2053)
wrancoums.c3 govCM-110
PLAINTIFF/PETITIONER: MARIE DeGUZMAN sole
DEFENDANT/RESPONDENT: COLUMBIA PROPERTY TRUST et al CGC-17-561142
4. b. Provide a brief statement of the case, including any damages. (If persona! injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount), estimated future medical expenses, lost
eamings to date, and estimated future fost eamings. if equitable relief is sought, describe the nature of the relief.)
Plif DeGUZMAN slipped and fell on wet floor, injuring her right knee (patella fx) and L ankle, L Knee and low
back. Plaintiff filed suit against building owner, property mgr, and janitorial service. Discovery underway. No
depositions have been taken yet.
[2] (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
requesting a jury trial):
a jury triat Coa nonjury trial. (if more than one party, provide the name of each party
6. Trial date
a. C2) The tiat has been set for (date):
b. CZ Notral 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):
TRIALS: 3/5/18; 4/08/18; 8/21/15; 10/15/18
7. Estimated length of trial
‘The party or parties estimate that the trial will take (check one):
a. LZ) days (specify number: 5
b. (7) hours (short causes) (specify):
8. Trlal representation (to be answered for each party)
The party or parties will be represented at trial [LY] by the attomey or party listed in the caption [7] by the following:
a. Attorney:
bd. Firm:
c. Address:
d. Telephone number f,
e. E-mail address:
(J 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 [2] has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
Fax number.
g. Party represented:
(2) For setf-represented parties: Party (—] has [1] has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or clvil 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 ‘ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory lim’
(2) (1 Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.17.
(3) () This case is exempt from judicial arbitration under mule 3.811 of the Califomia Rules of Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CHAO Rw yO CASE MANAGEMENT STATEMENT PapetetscM-110
PLAINTIFF/PETITIONER: MARIE DeGUZMAN [CASE NUMBER:
PEFENDANTIRESPONDENT: COLUMBIA PROPERTY TRUST et al per irenae
40. 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 ai that apply and provide the specified information):
‘The party of 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 aif that apply): | stipulation):
(1) Mediation
{2) Settlement
conference
(3) Neutral evaluation
Mediation session not yet scheduled
Mediation session scheduled for (data):
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduted
Settlement conference scheduled for (date):
Agreed to complete settlement conference by (date):
Settlement conference completed on (data):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
{4) Nonbinding judicial
arbitration
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date):
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
(8) Sinding private
arbitration
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
Agreed to complete private arbitration by (date):
(6) Other (specify):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
0
QOOU;O000;0000;/0000/0008;0008
“CHAO (Rov duly 3,203)
Pagosors
CASE MANAGEMENT STATEMENTa.
b. Reservation of rights: [[_] Yes [7] No
c. [J Coverage issues will significantly affect resolution of this case (explain):
Insurance carrier, if any, for party filing this statement (name): AIAC (an AIG company)
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
(5) Bankruptey [1 other (specify):
Status:
13. Related cases, consolldation, and coordination
a. ((_] There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
(1) Additional cases are described in Attachment 13a.
b. CJAmotionto [2] consolidate (7) coordinate
14, Bifurcation
will be filed by (name party):
‘The party or parties intend ta 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):
45, Other motions
C7 the party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. (7) The party or parties have completed all discovery.
w
b The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendant JLL Written discovery March 2018
Defendant JLL Subpoena records Mar/Apr 2018
Defendant JLL Depositions Apr-May 2018
Defendant JLL Expert discovery per Code
c. [7] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
No significant issues expected. Written discovery underway; depositions to be scheduled,
CMeA40 Rev. Jty 1. 2018} CASE MANAGEMENT STATEMENT
Page dot &= - 7 oo CM-110
PLAINTIFF/PETITIONER: MARIE DeGUZMAN eee
L | cGC-17-
DEFENDANTIRESPONDENT. COLUMBIA PROPERTY TRUST et al | CGC-17-561 142
17. Economic litigation
a. This is a limited civil case (i.¢., 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.
6. L__] 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. L¥_] The party or parties have met and conferred with ail 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).
Cooperate re discovery
20. Total number of pages attached (if any)
1am 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 wiations on these issues at the timg of
the case management conference, including the written authority of the party where r¢
Date: January 22, 2018
Brian C. O'Hara, Esq
(TYPE OR PRINT NAME) (2-7 SIGNATURE OF PARTY OR ArtORNEW)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
ONTO TRev ly 1.2948 CASE MANAGEMENT STATEMENT Pion or27
28
PROOF OF SERVICE BY MAIL (1013A(3) C.C.P.
State of California, County of San Francisco
{am employed in the County of San Francisco, State of California. | am over the age of
eighteen years and not a party to the within entitled action. My business address is:
SKEBBA, ISAAC & BISHOP, One Montgomery Street, Suite 2550 in San Francisco, CA
94104. telephone (415) 836-2626 and Facsimile (415) 836-3104.
On the date entered below. I served the foregoing document described as:
CASE MANAGEMENT STATEMENT DATED 1/22/18
On all interested parties in said action by placing true copies thereof enclosed in sealed
envelopes addressed as follows:
Nikolaus W. Reed BREMER WHYTE BROWN & O’MEARA
LAW OFFICE OF NIKOLAUS REED LLP
135 10th Street Alison K. Hurley
San Francisco, CA 94103 20320 S.W. Birch Street, 2nd Floor
ATTORNEY FOR PLAINTIFF Newport Beach, CA 92660
CROWN BUILDING MAINTENANCE
co.
DBA ABLE BUILDING MAINTENANCE
& BY MAIL AS FOLLOWS - | am "readily familiar" with the firm's practice of collection
and processing correspondence for mailing. Under that practice it would be deposited
with the U.S. Postal Service on that same day with postage thereon fully prepaid at San
Francisco, California, in the ordinary course of business. | am aware that on motion of
the party served, service is presumed invalid if postal cancellation date or postage meter
date is more than one (1) day after date of deposit for mailing in affidavit.
I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.
EXECUTED ON: January 22, 2018
Vithvrun lea)
CATHERINE LOGAN 7 _)
Preview
CM-4110 "AUIOANEY OR PARTY WITHOUT ATTORNEY (Name, Sia Bar number, and ade ASF 5329 FOR COURT USE ONLY Brian C. O'Hara, Esq. #134024 ISKEBBA, ISAAC & BISHOP One Montgomery St. #2550; San Francisco, CA 94104 ELECTRONICALLY ‘verertone no” 415-836-2626 FAX.NO (Options FILED EYANL ADORESS (Optora? brian.ohara@aig.com Superior Court of California atToaney FoR amo) JONES LASALLE AMERICAS, INC. County of San Francisco SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO 01/22/2018 street aconess 400 McAllister Street Clerk of the Court sauna aooress: San Francisco, CA 94102 BY-RANL EDWARDS: Gity aN 21 Cons Deputy Clorh BRANCH NAME: PLAINTIFF/PETITIONER: MARIE DeGUZMAN DEFENDANTIRESPONDENT: COLUMBIA PROPERTY TRUST et al CASE MANAGEMENT STATEMENT (CASE MUNBER (Check one): [2] UNLIMITED CASE () umitep case CGC-17-561142 (Amount demanded (Amount demanded is $25,000 exceeds $25.000) or fess) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 2-07-18 Time: 10:30 a.m. Dept.: 610 Div: Room: 610 Address of court (if different irom the address above): Notice of Intent to Appear by Telephone, by (name): Brian C. O'Hara 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 JONES LANG LASALLE AMERICAS, INC. b. () Thisstatementis submitted Jointly by parties (names): 2. Complaint and cross-complaint (fo be answered by plaintiffs and crass-complainants only) a. The complaint was filed on (date): b. (J The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. The following parties named in the complaint or cross-complaint (1) £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) (2) have had a default entered against them (specify names): cs [J 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 of case in compiaint [7] cross-compiaint (Describe, including causes of action): Personal injury action; slip & fall accident on wet floor in labby of building owned by dft Columbia. Dft JLL is facilities manager, dit ABM dba Crown Janitorial is janitorial service. Discovery underway. Page tots. Fog Agana iene oo CASE MANAGEMENT STATEMENT STS CMA110 (Rev, July 4, 2053) wrancoums.c3 govCM-110 PLAINTIFF/PETITIONER: MARIE DeGUZMAN sole DEFENDANT/RESPONDENT: COLUMBIA PROPERTY TRUST et al CGC-17-561142 4. b. Provide a brief statement of the case, including any damages. (If persona! injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount), estimated future medical expenses, lost eamings to date, and estimated future fost eamings. if equitable relief is sought, describe the nature of the relief.) Plif DeGUZMAN slipped and fell on wet floor, injuring her right knee (patella fx) and L ankle, L Knee and low back. Plaintiff filed suit against building owner, property mgr, and janitorial service. Discovery underway. No depositions have been taken yet. [2] (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 requesting a jury trial): a jury triat Coa nonjury trial. (if more than one party, provide the name of each party 6. Trial date a. C2) The tiat has been set for (date): b. CZ Notral 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): TRIALS: 3/5/18; 4/08/18; 8/21/15; 10/15/18 7. Estimated length of trial ‘The party or parties estimate that the trial will take (check one): a. LZ) days (specify number: 5 b. (7) hours (short causes) (specify): 8. Trlal representation (to be answered for each party) The party or parties will be represented at trial [LY] by the attomey or party listed in the caption [7] by the following: a. Attorney: bd. Firm: c. Address: d. Telephone number f, e. E-mail address: (J 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 [2] has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. Fax number. g. Party represented: (2) For setf-represented parties: Party (—] has [1] has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or clvil 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 ‘ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory lim’ (2) (1 Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.17. (3) () This case is exempt from judicial arbitration under mule 3.811 of the Califomia Rules of Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CHAO Rw yO CASE MANAGEMENT STATEMENT PapetetscM-110 PLAINTIFF/PETITIONER: MARIE DeGUZMAN [CASE NUMBER: PEFENDANTIRESPONDENT: COLUMBIA PROPERTY TRUST et al per irenae 40. 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 ai that apply and provide the specified information): ‘The party of 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 aif that apply): | stipulation): (1) Mediation {2) Settlement conference (3) Neutral evaluation Mediation session not yet scheduled Mediation session scheduled for (data): Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduted Settlement conference scheduled for (date): Agreed to complete settlement conference by (date): Settlement conference completed on (data): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): {4) Nonbinding judicial arbitration Judicial arbitration not yet scheduled Judicial arbitration scheduled for (date): Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): (8) Sinding private arbitration Private arbitration not yet scheduled Private arbitration scheduled for (date): Agreed to complete private arbitration by (date): (6) Other (specify): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): 0 QOOU;O000;0000;/0000/0008;0008 “CHAO (Rov duly 3,203) Pagosors CASE MANAGEMENT STATEMENTa. b. Reservation of rights: [[_] Yes [7] No c. [J Coverage issues will significantly affect resolution of this case (explain): Insurance carrier, if any, for party filing this statement (name): AIAC (an AIG company) 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. (5) Bankruptey [1 other (specify): Status: 13. Related cases, consolldation, and coordination a. ((_] There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: (1) Additional cases are described in Attachment 13a. b. CJAmotionto [2] consolidate (7) coordinate 14, Bifurcation will be filed by (name party): ‘The party or parties intend ta 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): 45, Other motions C7 the party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. (7) The party or parties have completed all discovery. w b The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant JLL Written discovery March 2018 Defendant JLL Subpoena records Mar/Apr 2018 Defendant JLL Depositions Apr-May 2018 Defendant JLL Expert discovery per Code c. [7] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): No significant issues expected. Written discovery underway; depositions to be scheduled, CMeA40 Rev. Jty 1. 2018} CASE MANAGEMENT STATEMENT Page dot &= - 7 oo CM-110 PLAINTIFF/PETITIONER: MARIE DeGUZMAN eee L | cGC-17- DEFENDANTIRESPONDENT. COLUMBIA PROPERTY TRUST et al | CGC-17-561 142 17. Economic litigation a. This is a limited civil case (i.¢., 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. 6. L__] 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. L¥_] The party or parties have met and conferred with ail 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). Cooperate re discovery 20. Total number of pages attached (if any) 1am 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 wiations on these issues at the timg of the case management conference, including the written authority of the party where r¢ Date: January 22, 2018 Brian C. O'Hara, Esq (TYPE OR PRINT NAME) (2-7 SIGNATURE OF PARTY OR ArtORNEW) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. ONTO TRev ly 1.2948 CASE MANAGEMENT STATEMENT Pion or27 28 PROOF OF SERVICE BY MAIL (1013A(3) C.C.P. State of California, County of San Francisco {am employed in the County of San Francisco, State of California. | am over the age of eighteen years and not a party to the within entitled action. My business address is: SKEBBA, ISAAC & BISHOP, One Montgomery Street, Suite 2550 in San Francisco, CA 94104. telephone (415) 836-2626 and Facsimile (415) 836-3104. On the date entered below. I served the foregoing document described as: CASE MANAGEMENT STATEMENT DATED 1/22/18 On all interested parties in said action by placing true copies thereof enclosed in sealed envelopes addressed as follows: Nikolaus W. Reed BREMER WHYTE BROWN & O’MEARA LAW OFFICE OF NIKOLAUS REED LLP 135 10th Street Alison K. Hurley San Francisco, CA 94103 20320 S.W. Birch Street, 2nd Floor ATTORNEY FOR PLAINTIFF Newport Beach, CA 92660 CROWN BUILDING MAINTENANCE co. DBA ABLE BUILDING MAINTENANCE & BY MAIL AS FOLLOWS - | am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at San Francisco, California, in the ordinary course of business. | am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one (1) day after date of deposit for mailing in affidavit. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. EXECUTED ON: January 22, 2018 Vithvrun lea) CATHERINE LOGAN 7 _)