Preview
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state bar number, and address) FOR COURT USE ONLY
Michael J. Fish, Esq., SBN 98161
MERRILL, ARNONE & JONES, LLP
3554 Round Barn Blvd., Ste. 303, Santa Rosa, CA 95403
TELEPHONE NO.: 707.528.2882 FAX NO. (Optional): 707.528.6015
E-MAIL ADDRESS (Optional): mfish@majlaw.com
ATTORNEY FOR (Name): plaintiff/Cross-DefendanLOIjvia Piazza_
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA
600 ADMINISTRATION DRIVE, ROOM 107-J
SANTA ROSA, CALIFORNIA 95403-2878
PLAINTIFF/PETITIONER: Olivia Piazza
DEFENDANT/RESPONDENT: Eugene Piazza and Victoria Williams
ADR INFORMATION SHEET CASE NUMBER: SCV-270969
[Sonoma County Superior Court Rules, Rule 16]
(Check one): UNLIMITED CASE LIMITED CASE Date: 10/20/2022
(Amount demanded exceeds (Amount demanded is Time: 3:00 p.m.
$25,000) $25,000 or less) Location: Dept 17
Assigned judge: Bradford DeMeo
NOTICE TO ALL PARTIES AND THEIR ATTORNEYS
The policy of the Sonoma County Superior Court is:
"The formal litigation of legal claims and disputes is expensive and time consuming. The overall results achieved by
some or all of the parties are often unsatisfactory. There are many modern alternatives to formal court litigation which are
less expensive, less time consuming, and more beneficial to the parties. It is therefore the firm policy and goal of this
court to encourage the parties in all civil cases to explore and pursue private dispute resolution alternatives at the earliest
possible date." (Local Rule 16.1.)
Although most (90-98%) cases do settle, many settlements come only after a considerable amount of time, money,
and resources have been expended. Such expenditures, as well as the adversarial nature of litigation, can be a
disincentive to settlement. The Sonoma County Superior Court encourages the use of Alternative Dispute Resolution
(ADR) as early as possible after the parties become aware of a dispute.
Most ADR processes are voluntary and are paid for by the parties themselves, but ADR has proved in many cases to
be faster, cheaper, and more effective than traditional litigation.
ADVANTAGES OF APR:
The filing of your complaint or answer may be just the beginning of the costs that you will incur during the course of
your lawsuit. Lawsuits can be extremely costly. By utilizing ADR methods early in the course of your case, you may
significantly reduce these costs by either resolving the case before expensive discovery and trial proceedings are
commenced or by narrowing the scope of your discovery by identifying disputed and undisputed factual and legal issues.
ADR can be a fast, economical, efficient, and effective way to resolve civil cases, and most litigants report satisfaction
with the process. ADR procedures can be scheduled at your convenience and can be completed in a fraction of the time
required for traditional litigation. The cost ofADR will depend on the procedure and the provider you select, and the cost
is typically less than litigation.
Most ADR processes are confidential but can result in enforceable agreements. Many ADR processes will give you an
opportunity to test the strengths and weaknesses of your case without adverse impact in the event of a trial. Depending
upon the method of ADR you select, it may be the last chance for you to control the outcome of your dispute before you
place the decision tn'the hands of a judge or Jury.
METHODS OF APR:
A. MEDIATION: Mediation is one of the most frequently used methods of ADR because it is informal, quick,
convenient and confidential. In this process the parties select a neutral mediator who facilitates the identification of issues
and areas of agreement and assists in finding a resolution or settlement of the dispute. Since mediation requires the
agreement of the parties to resolve the matter, control of the proceedings and a determination of the settlement terms
remains completely in the parties' hands. The mediator remains neutral and assists the parties in arriving at terms that
are mutually agreeable.
CV-2 [Rev. July 1,2011] ADR INFORMATION SHEET Page 1 of 2
Form adopted for mandatory use
PLAINTIFF/PETITIONER: Olivia Piazza CASE NUMBER:
SCV-270969
DEFENDANT/RESPONDENT: Eugene Piazza and Victoria Williams
B. ARBITRATION: The parties jointly employ a neutral third party or a panel of neutrals to listen to both sides and
render a decision. The parties are free to make the arbitrator's decision binding or non-binding. When non-binding, the
arbitrator's decision serves as guide or influence upon the parties to bring them closer to settlement. If it is binding, the
decision of the arbitrator will be final and generally avoids any further proceedings in the case. Non-binding judicial
arbitration may be ordered in certain cases before trial.
C. EARLY NEUTRAL EVALUATION: A neutral evaluator is hired by the parties to give an evaluation of the case to
help settle it. You or your attorney will be permitted to prepare a written statement, present critical witnesses or other
evidence, argue your case to the evaluator, meet separately and confidentially with the evaluator, and utilize the evaluator
to communicate any settlement offers to the opposing party.
D. PRIVATE SETTLEMENT CONFERENCE: A voluntary settlement conference is similar to early neutral
evaluation in that the parties employ a neutral settlement officer who attempts to persuade the parties to accept a
compromise position. It is a form of facilitated negotiation in which the settlement officer may express an opinion about
the value of the case, the substantive merits of each party's position, and the probable outcome of the trial.
There are various other methods or combinations of methods of ADR, such as summary jury trial, mini-trial, special
master and discovery referee. The court encourages the parties to be creative in selecting the process which has the
best chance of resolving the case as quickly, effectively, and inexpensively as possible. You will have a chance to review
your ADR options at the time of the Early Mediation and Case Management Conference.
The undersigned party is willing to agree to any of the following forms of ADR at this time (for family law and
probate actions only). Your selection will inform the other parties in the case of your current thoughts regarding
the use of ADR. If all parties agree on a particular ADR method, you will be asked to file a stipulation on the
court's form. The stipulation form (Sonoma County Superior Court form #MISC-101) can be found at the court's
web site and is available at the court.)
!•! Mediation Early Neutral Evaluation
Non-binding Private Arbitration Binding Private Arbitration
Voluntary Settlement Conference Summary Jury Trial
II Other Judicial Arbitration
I / We certify that I / We have read and understood (or have had explained to me / us) the forgoing.
Date:
iC /^^OZ.2 ^
V.
i; Signature of Party
I
Date:
Signature of Party
Date: 2.^2^ 7^1 - rf;''^
Signature of Attorney for Party
Additional signatures are attached . .; - ;
NOTE: This form requires the signatures of the parties and their attorney. All parties must complete, file and
serve this form in accordance with Sonoma County Superior Court Rules, Rule 16. See Rule 16.3 for specific
filing and service instructions.
CV-2[Rev. July 1,2011] ADR INFORMATION SHEET Page 2 of 2
Form adopted for mandatory use
1 PROOF OF SERVICE
2
I, the undersigned, declare:
3
I am employed in the County of Sonoma, State of California. I am over the age of
4 eighteen years and not a party to the within cause; my business address is 3554 Round
Barn Boulevard, Suite 303, Santa Rosa, California 95403.
5
On the date stated below, I caused to be served in the manner indicated the
6 foregoing
7 PLAINTIFF/CROSS-DEFENDANFS ADR INFORMA TION SHEET
8 on the parties involved addressed as follows:
9 Jeffrey S. Lyons
Clement Fitzpatrick & Kenworthy
10 3333 Mendocino Avenue, Ste. 200
Santa Rosa, CA 95403
11 ilyons@cfk.com
lholmberg(%cfk.com
12
13 [ ] BY MAIL on the following party (ies) in said action, in accordance with CCP §
1013 (a), by placing a true copy thereof enclosed in a sealed envelope in a
14 designated area for outgoing mail, addressed as set forth above. In the ordinary
course of business at the Law Offices ofMerrill, Arnone & Jones, LLP, mail
15 placed in that designated area is given the correct amount of postage, and is
deposited that same day in a United States mailbox in the city of Santa Rosa,
16 California.
17 [X] BY ELECTRONIC MAIL: My electronic business address is
krizzato(a),majlaw.com, and I caused such document(s) to be electronically served
18 to those parties listed above The file transmission ^vas reported complete and a
copy -will be maintained with the documents in our office.
19
[ ] BY PERSONAL DELIVERING a true and correct copy thereof, in accordance
20 ^vith CCP §1011, to the person(s) and at the address(es) set forth above.
21 [ ] BY FACSIMILE transmission, in accordance with CCP §1013 (e), to the
following party (ies) at the facsimile number (s) indicated.
22
[ ] BY OVERNIGHT DELIVERY on the following party (ies) in said action, in
23 accordance with CCP § 1013 (c), by placing a true copy thereof enclosed in a
sealed envelope, with delivery fees paid or provided for, in a designated area for
24 outgoing overnight mail addressed as set forth below. In the ordinary course of
business at the Law Offices ofMerrill, Arnone & Jones, LLP, mail placed in that
25 designated area is picked up that same day for delivery the following business day.
26 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct. Executed on October, 7,, 2022, at Santa Rosa, California.
27 ^.
t11 / ^)
28 Kerr izzat s arzo
PROOF OF SERVICE
Preview
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state bar number, and address) FOR COURT USE ONLY Michael J. Fish, Esq., SBN 98161 MERRILL, ARNONE & JONES, LLP 3554 Round Barn Blvd., Ste. 303, Santa Rosa, CA 95403 TELEPHONE NO.: 707.528.2882 FAX NO. (Optional): 707.528.6015 E-MAIL ADDRESS (Optional): mfish@majlaw.com ATTORNEY FOR (Name): plaintiff/Cross-DefendanLOIjvia Piazza_ SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA 600 ADMINISTRATION DRIVE, ROOM 107-J SANTA ROSA, CALIFORNIA 95403-2878 PLAINTIFF/PETITIONER: Olivia Piazza DEFENDANT/RESPONDENT: Eugene Piazza and Victoria Williams ADR INFORMATION SHEET CASE NUMBER: SCV-270969 [Sonoma County Superior Court Rules, Rule 16] (Check one): UNLIMITED CASE LIMITED CASE Date: 10/20/2022 (Amount demanded exceeds (Amount demanded is Time: 3:00 p.m. $25,000) $25,000 or less) Location: Dept 17 Assigned judge: Bradford DeMeo NOTICE TO ALL PARTIES AND THEIR ATTORNEYS The policy of the Sonoma County Superior Court is: "The formal litigation of legal claims and disputes is expensive and time consuming. The overall results achieved by some or all of the parties are often unsatisfactory. There are many modern alternatives to formal court litigation which are less expensive, less time consuming, and more beneficial to the parties. It is therefore the firm policy and goal of this court to encourage the parties in all civil cases to explore and pursue private dispute resolution alternatives at the earliest possible date." (Local Rule 16.1.) Although most (90-98%) cases do settle, many settlements come only after a considerable amount of time, money, and resources have been expended. Such expenditures, as well as the adversarial nature of litigation, can be a disincentive to settlement. The Sonoma County Superior Court encourages the use of Alternative Dispute Resolution (ADR) as early as possible after the parties become aware of a dispute. Most ADR processes are voluntary and are paid for by the parties themselves, but ADR has proved in many cases to be faster, cheaper, and more effective than traditional litigation. ADVANTAGES OF APR: The filing of your complaint or answer may be just the beginning of the costs that you will incur during the course of your lawsuit. Lawsuits can be extremely costly. By utilizing ADR methods early in the course of your case, you may significantly reduce these costs by either resolving the case before expensive discovery and trial proceedings are commenced or by narrowing the scope of your discovery by identifying disputed and undisputed factual and legal issues. ADR can be a fast, economical, efficient, and effective way to resolve civil cases, and most litigants report satisfaction with the process. ADR procedures can be scheduled at your convenience and can be completed in a fraction of the time required for traditional litigation. The cost ofADR will depend on the procedure and the provider you select, and the cost is typically less than litigation. Most ADR processes are confidential but can result in enforceable agreements. Many ADR processes will give you an opportunity to test the strengths and weaknesses of your case without adverse impact in the event of a trial. Depending upon the method of ADR you select, it may be the last chance for you to control the outcome of your dispute before you place the decision tn'the hands of a judge or Jury. METHODS OF APR: A. MEDIATION: Mediation is one of the most frequently used methods of ADR because it is informal, quick, convenient and confidential. In this process the parties select a neutral mediator who facilitates the identification of issues and areas of agreement and assists in finding a resolution or settlement of the dispute. Since mediation requires the agreement of the parties to resolve the matter, control of the proceedings and a determination of the settlement terms remains completely in the parties' hands. The mediator remains neutral and assists the parties in arriving at terms that are mutually agreeable. CV-2 [Rev. July 1,2011] ADR INFORMATION SHEET Page 1 of 2 Form adopted for mandatory use PLAINTIFF/PETITIONER: Olivia Piazza CASE NUMBER: SCV-270969 DEFENDANT/RESPONDENT: Eugene Piazza and Victoria Williams B. ARBITRATION: The parties jointly employ a neutral third party or a panel of neutrals to listen to both sides and render a decision. The parties are free to make the arbitrator's decision binding or non-binding. When non-binding, the arbitrator's decision serves as guide or influence upon the parties to bring them closer to settlement. If it is binding, the decision of the arbitrator will be final and generally avoids any further proceedings in the case. Non-binding judicial arbitration may be ordered in certain cases before trial. C. EARLY NEUTRAL EVALUATION: A neutral evaluator is hired by the parties to give an evaluation of the case to help settle it. You or your attorney will be permitted to prepare a written statement, present critical witnesses or other evidence, argue your case to the evaluator, meet separately and confidentially with the evaluator, and utilize the evaluator to communicate any settlement offers to the opposing party. D. PRIVATE SETTLEMENT CONFERENCE: A voluntary settlement conference is similar to early neutral evaluation in that the parties employ a neutral settlement officer who attempts to persuade the parties to accept a compromise position. It is a form of facilitated negotiation in which the settlement officer may express an opinion about the value of the case, the substantive merits of each party's position, and the probable outcome of the trial. There are various other methods or combinations of methods of ADR, such as summary jury trial, mini-trial, special master and discovery referee. The court encourages the parties to be creative in selecting the process which has the best chance of resolving the case as quickly, effectively, and inexpensively as possible. You will have a chance to review your ADR options at the time of the Early Mediation and Case Management Conference. The undersigned party is willing to agree to any of the following forms of ADR at this time (for family law and probate actions only). Your selection will inform the other parties in the case of your current thoughts regarding the use of ADR. If all parties agree on a particular ADR method, you will be asked to file a stipulation on the court's form. The stipulation form (Sonoma County Superior Court form #MISC-101) can be found at the court's web site and is available at the court.) !•! Mediation Early Neutral Evaluation Non-binding Private Arbitration Binding Private Arbitration Voluntary Settlement Conference Summary Jury Trial II Other Judicial Arbitration I / We certify that I / We have read and understood (or have had explained to me / us) the forgoing. Date: iC /^^OZ.2 ^ V. i; Signature of Party I Date: Signature of Party Date: 2.^2^ 7^1 - rf;''^ Signature of Attorney for Party Additional signatures are attached . .; - ; NOTE: This form requires the signatures of the parties and their attorney. All parties must complete, file and serve this form in accordance with Sonoma County Superior Court Rules, Rule 16. See Rule 16.3 for specific filing and service instructions. CV-2[Rev. July 1,2011] ADR INFORMATION SHEET Page 2 of 2 Form adopted for mandatory use 1 PROOF OF SERVICE 2 I, the undersigned, declare: 3 I am employed in the County of Sonoma, State of California. I am over the age of 4 eighteen years and not a party to the within cause; my business address is 3554 Round Barn Boulevard, Suite 303, Santa Rosa, California 95403. 5 On the date stated below, I caused to be served in the manner indicated the 6 foregoing 7 PLAINTIFF/CROSS-DEFENDANFS ADR INFORMA TION SHEET 8 on the parties involved addressed as follows: 9 Jeffrey S. Lyons Clement Fitzpatrick & Kenworthy 10 3333 Mendocino Avenue, Ste. 200 Santa Rosa, CA 95403 11 ilyons@cfk.com lholmberg(%cfk.com 12 13 [ ] BY MAIL on the following party (ies) in said action, in accordance with CCP § 1013 (a), by placing a true copy thereof enclosed in a sealed envelope in a 14 designated area for outgoing mail, addressed as set forth above. In the ordinary course of business at the Law Offices ofMerrill, Arnone & Jones, LLP, mail 15 placed in that designated area is given the correct amount of postage, and is deposited that same day in a United States mailbox in the city of Santa Rosa, 16 California. 17 [X] BY ELECTRONIC MAIL: My electronic business address is krizzato(a),majlaw.com, and I caused such document(s) to be electronically served 18 to those parties listed above The file transmission ^vas reported complete and a copy -will be maintained with the documents in our office. 19 [ ] BY PERSONAL DELIVERING a true and correct copy thereof, in accordance 20 ^vith CCP §1011, to the person(s) and at the address(es) set forth above. 21 [ ] BY FACSIMILE transmission, in accordance with CCP §1013 (e), to the following party (ies) at the facsimile number (s) indicated. 22 [ ] BY OVERNIGHT DELIVERY on the following party (ies) in said action, in 23 accordance with CCP § 1013 (c), by placing a true copy thereof enclosed in a sealed envelope, with delivery fees paid or provided for, in a designated area for 24 outgoing overnight mail addressed as set forth below. In the ordinary course of business at the Law Offices ofMerrill, Arnone & Jones, LLP, mail placed in that 25 designated area is picked up that same day for delivery the following business day. 26 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on October, 7,, 2022, at Santa Rosa, California. 27 ^. t11 / ^) 28 Kerr izzat s arzo PROOF OF SERVICE