Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Nama Slate Bar number, and address): FOR COURT USE ONLY
Shawn A. Toliver, SB# 148349; Jessica N. Wahl, SB# 321887 ELECTRONICALLY FILED
LEWIS BRISBOIS BISGAARD & SMITH LLP Superior Court of California
2185 N. California Boulevard, Suite 300 of Santa Barbara
County
Walnut Creek, California 94596
Darrel E. Parker, Executive Officer
TELEPHONE NO.: 925.357.3456 FAX NO. (Optional): 925.478.3260
E-MAIL ADDRESS (Oplinnal): jessica.wahl@lewisbrisbois.com
2/18/2021 4:59 PM
ATTORNEY FOR(Name): Defendant MOHAMMAD BIN FAHD AL SAUD By: Narzralli Baksh, Deputy
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA
STREET ADDRESS:1 100 Anacapa Street
MAILING ADDRESS:
CITYANDZIP CODE:Santa Barbara, CA 93101
BRANCH NAME:
PLAINTIFF/PETITIONER: ERNESTO CERVANTES
DEFENDANT/RESPONDENT: MOHAMMAD BIN FAHD AL SAUD, ET AL.
CASE MANAGEMENT STATEMENT :ASEQ/UM3321
9C 06
(Check one): IE UNLIMITED CASE I:| LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: March 8,2021 Time: 8:30 am. Dept: 5 Div.: Room:
Address of court (if different from the address above):
XI Notice of Intent to Appear by Telephone, by (name): Jessica N. Wahl
INSTRUCTIONS: All applicable boxes must be checked, and t he specified information must be provided”
1. Party or parties (answer one):
a. [XI This statement is submitted by pany (name): Defendant MOHAMMAD BIN FAHD AL SAUD
b. D 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. D The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. El All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. D The following parties named in the complaint or cross-complain t
(1) El have not been served (specify names and explain why not):
(2) CI have been sewed but have not appeared and have not been dismissed (specify names):
(3) D have had a default entered against them (specify names):
c. D 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 IE complaint I:I cross-complaint (Describe, including causes of action):
Personal injury - motor vehicle accident
Page1of 5
Fm mm“ W ”mm “5e CASE MANAGEMENT STATEMENT Cal. Rules 01 Court.
Judicial Council 01 California rules 3120—3130
CM-110 [Rev. July 1, 2011] www.cnuris.ca.gnv
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PLAINTIFF/PETITIONER: ERNESTO CERVANTES
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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 Ernesto Cervantes claims injuries and damages sustained when a vehicle driven by Susan McKnight
collided with the Metropolitan City Bus driven by Mr. Cervantes.
El (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 IXI a jury trial I:I a nonjury trial. (If more than one party, provide the name of each patty
requesting a jury trial):
6. Trial date
a. CI The trial has been set for (date):
b. IE N0 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):
(2. Dates on which parties or attorneys will not be available for trial
(specify dates and explain reasons for unavailability):
See Attachment.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. IE days (specify number): 7-10
b. [I hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The pafly or parties will be represented at trialX by the attorney or pany listed in the caption E] by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: 9. Party represented:
[I Additional representation is described in Attachment 8.
9. Preference
[I 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 coun 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 El has D has not provided the ADR information package identified
in rule 3.221to the client and reviewed ADR options with the client.
(2) For self-represented parties:Party I:] has D has not reviewed the ADR information package identified in rule 3.221.
b. Referral tojudicial arbitration or civil action mediation (if available).
(1) [I 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) [I Plaintiff elects to refer this case tojudicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) [I This case is exempt from judicial arbitration under rule 3.811
of the California Rules of Coud or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM—HOIRev—Juw 110111
CASE MANAGEMENT STATEMENT PM 0.5
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CM-110
PLAINTIFF/PETITIONER: ERNESTO CERVANTES (EIASECVBAEEZRZ
EFENDANTIRESPONDENT: MOHAMMAD BIN FAHD AL SAUD, ET AL.
10. 0. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already padicipated 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 palties'ADR
processes (check all that apply): stipulation):
Mediation session not yet scheduled
Mediation session scheduled for (date):
EDDIE
(1) Mediation IX]
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
Settlement conference scheduled for (date):
(2) Settlement
conference g DDDQ
Agreed to complete settlement conference by (date) .'
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
DDDEI
Neutral evaluation scheduled for (date):
(3) Neutral evaluation El
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
arb'trat'on El DUDE
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
. . .
Blndln 9 P rlvate Private arbitration scheduled for (date):
(5 )
arbitration D
Agreed to complete private arbitration by (date):
IZIIZIDD
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other (specify);
D DUDE
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-WRev-Ju'y 110111 CASE MANAGEMENT STATEMENT Pas-2W5
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CM-110
PLAINTIFF/PETITIONER: ERNESTO CERVANTES
2:5?783321
—DEFENDANT/RESPONDENT: MOHAMMAD BIN FAHD AL SAUD, ET AL.
11. Insurance
a. [Z Insurance carrier, if any, for pany filing this statement (name): Chubb
b. Reservation of rights: E] Yes D No
0. CI 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.
El Bankruptcy I] Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. El There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
I:I Additional cases are described in Attachment 13a.
b. El A motion to [I consolidate D coordinate will be filed by {name pan‘y):
14. Bifurcation
CI 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
[I (specify moving party, type of motion, and issues):
The pany or parties expect to file the following motions before trial
16. Discovery
a. CI The party or parties have completed all discovery.
b I:I The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendants Depositions of 3"1 Parties/Treaters March 2021
Defendants Request for Admissions March 2021
0. CI The following discovery issues, including issues regarding the discovery of electronically stored
information, are
anticipated (specify):
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CASE MANAGEMENT STATEMENT Ham's
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CASENUMBERZ
PLAINTIFF/PETITIONER: ERNESTO CERVANTES
BEFENDANT/RESPONDENT: MOHAMMAD BIN FAHD AL SAUD, ET AL.
17. Economic litigation
a. D 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. |:I 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
|:I 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): 1
Iam completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the pany where required.
Date: February 18, 2021
Jessica N.Wah|
(TYPE OR PRINT NAME)
} a E
(SIGNATURE OF PARTY OR ATTORNEY)
b
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR AWORNEY)
E] Additional signatures are attached.
CM" 1° Re“ My1-20"] CASE MANAGEMENT STATEMENT
MC-025
SHORT TITLE: CASE NUMBER:
Ernesto Cervantes v. Mohammad Bin Fahd Al Saud, et al. 19CV06221
ATTACHMENT (Number): 6C
(This Attachment may be used with any Judicial Council form.)
Trials/Arbs: (2021): 3/1/2021, 3/29/201, 4/5/2021, 5/3/2021, 5/7/2021, 5/10/2021, 6/1/2021, 6/11/2021, 6/18/2021,
6/21/2021, 7/12/2021, 7/26/2021, 8/6/2021, 8/9/2021, 8/13/2021, 8/16/2021, 8/23/2021, 8/27/2021, 8/30/2021, 9/10/2021,
9/13/2021, 9/17/2021, 9/18/2021, 9/27/2021, 10/4/2021, 10/12/2021, 10/18/2021, 10/22/2021, 10/25/2021, 11/8/2021,
11/15/2021, 12/13/2021
Trials/Arbs: (2022): 2/25/2022, 3/4/2022
(If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 1 of 1
Attachment are made under penalty of perjury.)
(Add pages as required)
Form Approved for Optional Use
Judicial Council of California
ATTACHMENT www.courtinfo.ca.gov
American LegalNet, Inc.
MC-025 [Rev. July 1, 2009] to Judicial Council Form www.FormsWorkflow.com
CALIFORNIA STATE COURT PROOF OF SERVICE
Ernest Cervantes v. Mohammad Bin Fahd Al Sand, et a].
Santa Barbara County Superior Court, Case No. 19CV06221
STATE OF CALIFORNIA, COUNTYOF CONTRA COSTA
At the time of service, I was over 18 years of age and not a party to the action. My
business
\DMQOUI-BWNh—l
address is 2185 North California Boulevard, Suite 300, Walnut Creek, California 94596.
On February 18, 2021, I served the following document:
DEFENDANT MOHAMMAD BIN FAHD AL SAUD’S CASE
MANAGEMENT CONFERENCE STATEMENT
I served the document on the following persons at the following addresses (including fax
numbers and e-mail addresses, ifapplicable):
SEE ATTACHED SERVICE LIST
The document was served by the following means:
IZI (BY E-MAIL OR ELECTRONIC TRANSMISSION) Based on a court order or an
agreement of the parties to accept service by e-mail or electronic transmission, I caused the
documents to be sent from e-mail address Nicole.TaVis@lewisbrisbois.com to the persons at the e-
mail addresses listed above. I did not receive, within a reasonable time after the transmission, any
electronic message or other indication that the transmission was unsuccessful.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed on February 18, 2021, at Walnut Creek, California.
NNNNNNNNNHHHHHHHHHI—l
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Nicole M. Tavis
LEWIS
BRISBOIS
BISGAARD 4825-4224-68491
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ATTORNEYS AT LAW
PROOF OF SERVICE
SERVICE LIST
Ernest Cervantes v. Mohammad Bin Fahd Al Sand, et a].
Santa Barbara County Superior Court, Case No. 19CV06221
Jan Eric Kaestner, Esq. Attorneys for Plou'ntiflr ERNEST0
GHITTERMAN
UIAUON
GHITTERMAN & FELD CER VANTES
418 E. Canon Perdido Street
Santa Barbara, CA 93101 Tel: (805) 965-4540
Fax: (805) 965-5009
Email: workcomp@ghitterman.com
an@ ghitterman. com
1'
Alan J.Beardsley, Esq. Attorney for Workers Compensation
TOBTN ° LUCKS LLP
\Omfla
21300 Victory B1Vd., Third Floor Tel: (818) 226-3400
Woodland Hills, CA 91367 Fax: (818) 226-3401
Email: abeardslev@tobinlucks.com
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LEWIS
BRISBOIS
BISGAARD 4825-4224-6849l
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Aflomxivs
AT LAW
SERVICE LIST