Preview
CM-110
"ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY
Shawn Ridgell (SBN 201179) ELECTRONICALLY
Law Offices of Shawn Ridgell FILED
2128 Broadway, Oakland, CA 94612 Superior Court of California,
Teveprone no. (510) 986-1300 FAX No. (optonay:(5410) 986-1301 |
E-MAIL ADDRESS (Optiona): Sridgell@aol.com 05 / 24/2017
ATTORNEY FOR (Name): Plaintiff Alvaro Elvir Rodriguez : oY: DORA LOUIE rH
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco Deputy Clerk
street aooress: 400 McAllister Street
MAILING ADDRESS:
erry ano zip cope: San Francisco, CA 94102
BRANCH NAME:
PLAINTIFF/PETITIONER: Alvaro Elvir Rodriguez
DEFENDANT/RESPONDENT: Jake Weir, Betty Weir, Scott Weir
CASE MANAGEMENT STATEMENT ee
(Check one): [4%] UNLIMITED CASE LIMITED CASE CGC-17-556326
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less) £
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 6/14/17 Time: 10:30 a.m. Dept.: 610 Div.: Room:
Address of court (if different from the address above):
{] Notice of intent to Appear by Telephone, by (name):
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. L¥] This statement is submitted by party (name): Plaintiff Alvaro Elvir Rodriguez
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): January 10, 2017
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) (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 L¥ ] complaint cross-complaint (Describe, including causes of action):
Complaint for damages arising out of an automobile accident.
Page 1 of 5
F
‘orm Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Co eee
(CM-110 (Rev. July 4, 2011] www-courts.ca.govCM-110
|__ PLAINTIFF/PETITIONER: Alvaro Elvir Rodriguez piso-uyingeabe
DEFENDANT/RESPONDENT: Jake Weir, Betty Weir, Scott Weir et
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.)
The subject accident occurred on January 24, 2015 in San Francisco. Plaintiff was a passenger in a vehicle and
had proceeded to cross a green light. At that time, defendant Jake Weir, who was driving defendant Betty and
Scott Weir's vehicle, negligently ran a red light and boradsided into plaintiff. Plaintiff sustained a worsening of his
knee condition, and injuries to his ribs chest, and neck. His medical specials are $55,000, wage loss is $33,000.
(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 ¥_| ajury trial a nonjury 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. [7] Notrial 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):
© RRGSAUPED BOK SERIA" BNF ARM RCE PEA seen earns for unovoliiy
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [7] days (specify number): 4-5
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial v | 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 LY ] has [_] has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client. 7
(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):
TRETAO Rev. day 1.2017] CASE MANAGEMENT STATEMENT ereCM-110
PLAINTIFF/PETITIONER: Alvaro Elvir Rodriguez [CASE NUMBER:
be cr 17-551
DEFENDANT/RESPONDENT: Jake Weir, Betty Weir, Scott Weir Gaal esreeee
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 ai 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 al/ that apply): | stipulation):
Mediation session not yet scheduled
ae 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 Oo Judicial arbitration scheduled for (date):
arbitration Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) 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):
OO0O;O0U0;0000;0000;0000;/0008
ADR completed on (date):
(CM-110 Rev. July 1, 2017) Page 3 of 5
CASE MANAGEMENT STATEMENTPLAINTIFF/PETITIONER: Alvaro Elvir Rodriguez oe eee
CGC-17-556326
DEFENDANT/RESPONDENT: Jake Weir, Betty Weir, Scott Weir
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.
(1) Name of case:
(2) Name of court: 7
(3) Case number: 7
(4) Status:
Additional cases are described in Attachment 13a.
b. A motion to 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.
¥ 1} The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motions in limne.
16. Discovery
a. The party or parties have completed all discovery.
b. L¥_J The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiff Written Discovery TBD
Plantiff Depositions TBD
Plaintiff Expert Discovery Per C.C.P.
= The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
(CM-110 Rev. July 1, 2011]
CASE MANAGEMENT STATEMENT Page 4 of 5CM-110
PLAINTIFF/PETITIONER: Alvaro Elvir Rodriguez CASE NUMBER:
_ 7 iF CGC-17-556326
DEFENDANT/RESPONDENT: Jake Weir, Betty Weir, Scott Weir
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
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 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: May 16, 2017
Shawn Ridgell > A A
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
‘OM TT0 Rev. Jay 1.2591) CASE MANAGEMENT STATEMENT aoco mw IN AY
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PROOF OF SERVICE BY U.S.MAIL
I declare that:
I am employed in the County of Alameda, State of California. I am over 18 years
of age and not a party to the within action. My business address is 2128 Broadway,
Oakland, California 94612.
On the date signed hereunder, I served the within Case Management Statement
by U.S. MAIL addressed as follows:
Kevin J. Gray, Esq.
Harrington, Foxx, Dubrow & Canter LLP
601 Montgomery Street, Suite 800
San Francisco, CA 94111
I declare under penalty of perjury under the laws of California that the foregoing
is true and correct. Executed on May 16, 2017 at San Francisco, California.
ae
Shawn Ridgell
Preview
CM-110 "ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY Shawn Ridgell (SBN 201179) ELECTRONICALLY Law Offices of Shawn Ridgell FILED 2128 Broadway, Oakland, CA 94612 Superior Court of California, Teveprone no. (510) 986-1300 FAX No. (optonay:(5410) 986-1301 | E-MAIL ADDRESS (Optiona): Sridgell@aol.com 05 / 24/2017 ATTORNEY FOR (Name): Plaintiff Alvaro Elvir Rodriguez : oY: DORA LOUIE rH SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco Deputy Clerk street aooress: 400 McAllister Street MAILING ADDRESS: erry ano zip cope: San Francisco, CA 94102 BRANCH NAME: PLAINTIFF/PETITIONER: Alvaro Elvir Rodriguez DEFENDANT/RESPONDENT: Jake Weir, Betty Weir, Scott Weir CASE MANAGEMENT STATEMENT ee (Check one): [4%] UNLIMITED CASE LIMITED CASE CGC-17-556326 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) £ A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 6/14/17 Time: 10:30 a.m. Dept.: 610 Div.: Room: Address of court (if different from the address above): {] Notice of intent to Appear by Telephone, by (name): INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. L¥] This statement is submitted by party (name): Plaintiff Alvaro Elvir Rodriguez 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): January 10, 2017 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) (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 L¥ ] complaint cross-complaint (Describe, including causes of action): Complaint for damages arising out of an automobile accident. Page 1 of 5 F ‘orm Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Co eee (CM-110 (Rev. July 4, 2011] www-courts.ca.govCM-110 |__ PLAINTIFF/PETITIONER: Alvaro Elvir Rodriguez piso-uyingeabe DEFENDANT/RESPONDENT: Jake Weir, Betty Weir, Scott Weir et 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.) The subject accident occurred on January 24, 2015 in San Francisco. Plaintiff was a passenger in a vehicle and had proceeded to cross a green light. At that time, defendant Jake Weir, who was driving defendant Betty and Scott Weir's vehicle, negligently ran a red light and boradsided into plaintiff. Plaintiff sustained a worsening of his knee condition, and injuries to his ribs chest, and neck. His medical specials are $55,000, wage loss is $33,000. (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 ¥_| ajury trial a nonjury 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. [7] Notrial 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): © RRGSAUPED BOK SERIA" BNF ARM RCE PEA seen earns for unovoliiy 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [7] days (specify number): 4-5 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial v | 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 LY ] has [_] has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. 7 (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): TRETAO Rev. day 1.2017] CASE MANAGEMENT STATEMENT ereCM-110 PLAINTIFF/PETITIONER: Alvaro Elvir Rodriguez [CASE NUMBER: be cr 17-551 DEFENDANT/RESPONDENT: Jake Weir, Betty Weir, Scott Weir Gaal esreeee 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 ai 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 al/ that apply): | stipulation): Mediation session not yet scheduled ae 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 Oo Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) 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): OO0O;O0U0;0000;0000;0000;/0008 ADR completed on (date): (CM-110 Rev. July 1, 2017) Page 3 of 5 CASE MANAGEMENT STATEMENTPLAINTIFF/PETITIONER: Alvaro Elvir Rodriguez oe eee CGC-17-556326 DEFENDANT/RESPONDENT: Jake Weir, Betty Weir, Scott Weir 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. (1) Name of case: (2) Name of court: 7 (3) Case number: 7 (4) Status: Additional cases are described in Attachment 13a. b. A motion to 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. ¥ 1} The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Motions in limne. 16. Discovery a. The party or parties have completed all discovery. b. L¥_J The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Plaintiff Written Discovery TBD Plantiff Depositions TBD Plaintiff Expert Discovery Per C.C.P. = The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): (CM-110 Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5CM-110 PLAINTIFF/PETITIONER: Alvaro Elvir Rodriguez CASE NUMBER: _ 7 iF CGC-17-556326 DEFENDANT/RESPONDENT: Jake Weir, Betty Weir, Scott Weir 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 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 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: May 16, 2017 Shawn Ridgell > A A (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. ‘OM TT0 Rev. Jay 1.2591) CASE MANAGEMENT STATEMENT aoco mw IN AY 10 i 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 7g PROOF OF SERVICE BY U.S.MAIL I declare that: I am employed in the County of Alameda, State of California. I am over 18 years of age and not a party to the within action. My business address is 2128 Broadway, Oakland, California 94612. On the date signed hereunder, I served the within Case Management Statement by U.S. MAIL addressed as follows: Kevin J. Gray, Esq. Harrington, Foxx, Dubrow & Canter LLP 601 Montgomery Street, Suite 800 San Francisco, CA 94111 I declare under penalty of perjury under the laws of California that the foregoing is true and correct. Executed on May 16, 2017 at San Francisco, California. ae Shawn Ridgell