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  • Ernesto Cervantes vs Mohammad Bin Fahd Al Saud et alUnlimited Auto (22) document preview
  • Ernesto Cervantes vs Mohammad Bin Fahd Al Saud et alUnlimited Auto (22) document preview
  • Ernesto Cervantes vs Mohammad Bin Fahd Al Saud et alUnlimited Auto (22) document preview
  • Ernesto Cervantes vs Mohammad Bin Fahd Al Saud et alUnlimited Auto (22) document preview
  • Ernesto Cervantes vs Mohammad Bin Fahd Al Saud et alUnlimited Auto (22) document preview
  • Ernesto Cervantes vs Mohammad Bin Fahd Al Saud et alUnlimited Auto (22) document preview
  • Ernesto Cervantes vs Mohammad Bin Fahd Al Saud et alUnlimited Auto (22) document preview
  • Ernesto Cervantes vs Mohammad Bin Fahd Al Saud et alUnlimited Auto (22) document preview
						
                                

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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 calNL‘L um American @ CM-110 PLAINTIFF/PETITIONER: ERNESTO CERVANTES igévgggéfi —DEFENDANT/RESPONDENT: MOHAMMAD BIN FAHD AL SAUD, ET AL. 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 American LegalNet, Inc, M“ FurmnI‘kFlnw cum 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 a American LegalNe!, Inc, 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): CM.110[REV_Ju.y1,zom CASE MANAGEMENT STATEMENT Ham's Legal, lnc‘ American \\ww.FuaurkFlu“ cum CM-110 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 WQQUIAUJNl-lWflQUIAWNl-lc my .w. ABA-ax Nicole M. Tavis LEWIS BRISBOIS BISGAARD 4825-4224-68491 1 & SMII'H up 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 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LEWIS BRISBOIS BISGAARD 4825-4224-6849l 1 & SMII'H up Aflomxivs AT LAW SERVICE LIST