Preview
CM-110
‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Namo, Slate Bar number, and addros9: FOR COURT USE ONLY
Alison K. Hurley (234042); Sarah Felahy (306617)
BREMER WHYTE BROWN & O'MEARA, LLP
230320 S.W. Birch Street, 2nd Floor, Newport Beach, CA 92660 ELECTRONICALLY
TELEPHONE NO: 949-221-1000 FAX NO (Optonap: 949-221-1001 FILED
E-MAIL ADDRESS (Optionay: Sfelahy@bremerwhyte.com Superior Court of Catifornia,
ATTORNEY FOR (Nemer Defendant Crown Building Maintenance Co. County of San Francisco
‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco
street aooress: 400 McAllister Street euhcetecor
MALING AppREss: 400 McAllister Street BY:NEYL WEBB
crry anozip cove: San Francisco, CA 94102 Deputy Clerk
BRANCH NAME:
PLAINTIFF/PETITIONER: Marie De Guzman
DEFENDANT/RESPONDENT: Crown Building Maintenance Co., et al.
CASE MANAGEMENT STATEMENT CASE NUMBER.
(Check one): (2) untimiteo case LIMITED CASE CGC-17-561142
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: February 7, 2018 Time: 10:30 a.m. Dept.: 610 Div.: Room:
Address of court (if different from the address above):
[7] Notice of Intent to Appear by Telephone, by (name): Sarah Felahy
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. [21 This statement is submitted by party (name): Defendant Crown Building Maintenance Co.
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): September 5, 2017
b. LÂ¥J The cross-complaint, if any, was filed on (date): October 17, 2017
3. Service (to be answered by plaintiffs and cross-compiainants 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) [£1 have not been served (specify names and explain why not):
(2) (1 have been served but have not appeared and have not been dismissed (specify names):
(3) [J have had a default entered against them (specify names):
c. [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, Typeofcasein [7] complaint ¥} cross-complaint (Describe, including causes of action):
Plaintiff alleges Premises Liability and General Negligence causes of action arising from alleged personal
injuries sustained during a slip and fall. Cross-Complainant seeks indemnity.
cage tots
ror Gouna Gate CASE MANAGEMENT STATEMENT Ga Rs ofCour,
LEAS pae yt oT nous coger
3615.38Cm-110
PLAINTIFF/PETITIONER: Marie De Guzman Se
DEFENDANT/RESPONDENT: Crown Building Maintenance Co., et al. CGC-17-581142
4, b. Provide a brief statement of the case, including any damages. (/f personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated futura medical expenses, lost
eamings to date, and estimated future lost eamings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff claims she sustained personal injuries, including a right patellar fracture and a left knee sprain, as a result
of a slip and fall at the property located at 333 Market Street in San Francisco, California. Plaintiff alleges the
lobby floor was wet as a result of rain water being mopped by a janitor.
(71 (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 7) ajury trial a nonjury trial. {If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
The trial has been set for (date):
a
b. CZ] 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):
¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
02/05/18; 02/16/18; 02/28/18; 03/05/18; 03/12/18; 03/16/18; 03/23/18; 04/02/18; 04/09/18; 04/11/18; 04/16/18;
05/03/18; 05/07/18; 05/14/18; 05/21/18; 05/25/18; 06/18/18; 07/03/18; 07/26/18; 08/30;18; 09/26/18
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. (2) days (specify number): 5-7 days
b. [7] hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial ¥_] by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d.
e.
Telephone number: f. Fax number:
E-mail address: g. Party represented:
[] Additional representation is described in Attachment 8.
9. Preference
[£2] 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 LY_] 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 Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CTO Rev Jay 7 20H CASE MANAGEMENT STATEMENT Page orsCM-110
PLAINTIFFIPETITIONER: Marie De Guzman ASE HOMER
EFENDANT/RESPONDENT: Crown Building Maintenance Co., et al. SOC ise ise
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 ail that apply and provide the specified information):
The party or parties completing
this form are willing to
participate in the following ADR
processes (check all that apply):
If the party or parties completing this form in the case have agreed to
participate in or have already completed an ADR process or processes,
indicate the status of the processes (attach a copy of the parties' ADR
stipulation):
Mediation session not yet scheduled
(1) Mediation Mediation session scheduled for (date):
i
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
(3) Neutral _ Neutral evaluation scheduled for (date):
leutral 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):
7 ( Agreed to complete ADR session by (date):
OOOO;/OU0O;/CO00;/OO00;UUU8|;OUU8
ADR completed on (date):
CM-170 [Row July 4, 2017] Pages ore
CASE MANAGEMENT STATEMENTPLAINTIFF/PETITIONER: Marie De Guzman CASE NUMBER:
DEFENDANT/RESPONDENT: Crown Building Maintenance Co., et al. C6C-17-561142
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes No
ce
[J 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.
(1 Bankruptcy [7] 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. [JAmotionto [_] consolidate
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. Discovery
a. The party or parties have completed all discovery.
b. [2] The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Def. Crown Building Maintenance Written Discovery Spring '18
Def. Crown Building Maintenance Depositions Spring/Summer '18
Def. Crown Building Maintenance Expert Discovery Per Code
Def. Crown Building Maintenance Defense Medical Exam Per Code
The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-A10 (Rev. July 1, 2011]
CASE MANAGEMENT STATEMENT aCM-110
PLAINTIFF/PETITIONER: Marie De Guzman ic
| DEFENDANT/RESPONDENT: Crown Building Maintenance Co., et al. ee
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
(J The pany or parties request that the following additional matters be considered or determined at the case management
conference (specily):
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).
1am completely familiar with this case and will be fully prepared to discuss the status of discovery and altemative 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: January 23, 2018
Sarah Felahy : » a
(TYPE OR PRINT NAME}
PPPARTY OR ATTORNE}
(TYPE OR PRINT NAME), SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached
CASE MANAGEMENT STATEMENT ee1 PROOF OF SERVICE
we
1 am employed in the County of Orange, State of California. I am over the age of 18 and
not a party to the within action. My business address is 20320 S.W. Birch Street, Second Floor, |
4 | Newport Beach, California 92660.
5 On January 23, 2018, I served the within document(s) described as:
|
6 CASE MANAGEMENT STATEMENT
7 on the interested parties in this action as stated on the attached mailing list.
8 [x] (BY MAIL) By placing a true copy of the foregoing document(s) in a sealed envelope
addressed as set forth on the attached mailing list. I placed each such envelope for
9 collection and mailing following ordinary business practices. I am readily familiar with this
Firm's practice for collection and processing of correspondence for mailing. Under that
10 practice, the correspondence would be deposited with the United States Postal Service on
that same day. with postage thereon fully prepaid at Newport Beach, California, in the
ll 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 1s more than one day after)
12 date of deposit for mailing in affidavit. |
13 Executed on January 23, 2018, at Newport Beach, California.
14 I declare under penalty of perjury under the laws of the State o
foregoing is true and correct.
15
16 Hailey Williams
7 (Type or print name)
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UP
iCH STREET
FLOOR
NEWPORT BCH, cA 92040
(649) 221-1000,
CAUsersidhernandez\ND Office Echo\VAULT-8IEVBRYMPROOP OF SERVICE 4822-8212-6938 y.1.docx28
GREMER WHYTE BROWN &
(949) 221-1000
Marie De Guzman v. Columbia Property Trust, et al.
Case No. CGC-17-561142
BWB&O CLIENT: Crown Building Maintenance dba Able Building Maintenance
BWB&O FILE NO.: 3695.382
SERVICE LIST
Nikolaus W. Reed Brian C. O’Hara Debra Steel Sturmer
Law Offices of Nikolaus Reed | SKEBBA, ISAAC, BISHOP _| Nicole A. Deterding
135 10" Street & HENDERSON LERCH STURMER LLP
San Franscisco, CA 94103
T: (415) 940-7766
F: (415) 940-7706
Attorneys for Plaintiff, Marie
De Guzman
One Montgomert Street, Suite
2550
San Franscisco, CA 94104
T: (415) 836-2626
F: (415) 836-3104
Attorneys for Defendant,
Jones Lang LaSalle Americas
One Sansome Street, Ste. 2060
San Franscisco, CA 94104
T: (415) 217-6340
dstrumer@lerchsturmer.com
ndeterding@lerchsturmer.com
Attorneys for Defendant,
Columbia Party Trust
‘CA\Users\dhernandez\ND Office Echo\VAULT-81EVBRYJ\PROOF OF SERVICE 4822-8212-6938 v.1.docx