Preview
CM-110
‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Namo, Stato Bar number, end address): FOR COURT USE ONLY
H. Grant Law SBN 144505 Brittany B. Wilson SBN 319977 FILES
Shook, Hardy & Bacon L.L.P. 7
2600 Montgomery, Suite 2600 59 Oy
San Francisco, CA 94104 N20 OCT 28 PH S37
veLePHone xo: 415-544-1900 FAX NO. (Optionay: 415-391-0281
E-MAIL ADDRESS (Optional):
ATTORNEY FOR (Names: Defendant Ford Motor Company
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN
street aporess: 180 E. Weber Street
MAILING ADDRESS:
cry ano zip cone: Stockton, CA 95202
BRANCH NAME:
BRANDON E. RILEY, CLERK
PLAINTIFF/PETITIONER: Arti Singh Ghotra
DEFENDANT/RESPONDENT: Elk Grove Ford, et al.
(Check one):
CASE MANAGEMENT STATEMENT ‘CASE NUMBER:
& UNLIMITED cASE Cs uimitep case STK-CV-UPL-2020-0000748
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: November 12, 2020 Time: 8:40 a.m. Dept.: 10D Div: Room:
Address of court (if different from the address above):
[Notice of Intent to Appear by Telephone, by (name): Brittany B. Wilson
Judicial Councit of California
GM-110 [Rev. July 1, 2011]
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. Ed This statement is submitted by party (name): Defendant Ford Motor Company
b. [1 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. [1 The cross-compiaint, if any, was filed on (date):
3. Service (fo be answered by plaintilfs and cross-complainants only)
a. [1 Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [1 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) [1 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 of case in ® complaint oO cross-complaint (Describe, including causes of action):
Plaintiff alleges defects to the wheel assembly on a 2017 F-150 and claims strict products liability, general
negligence, res ipsa loquiter, and breach of implied warranty against Ford and the dealership defendants.
Form Adopted for Mandatory Uso CASE MANAGEMENT STATEMENT
FILE BY FAXCM-110
i Sis CASE NUMBER:
| PLAINTIFF/PETITIONER: Arti Singh Ghotra STI-CV-UPL-2020-0000748
DEFENDANT/RESPONDENT: Elk Grove Ford, 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 fo date findicate source and amount]. estimated future medical expenses, lost
earnings fo date, and estimated future lost earnings. if equitable relief is sought, describe the nature of the relief.)
Plaintiff alleges that while driving her 2017 Ford F-150 northbound on CA-99 in San Joaquin County near the
Calaveras River on January 24, 2018, her right-side wheel assembly detached causing her to lose control of the
vehicle and swerve into a tractor-trailer truck. Plaintiff asserts wage loss, loss of earning capacity, property
damage, medical expenses, and general damages as a result of alleged defects in the F-150's wheel assembly.
Ford denies Plaintiff's allegations.
C1 (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 [) ajurytrial [1] 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. 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):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
KK days (specify number): 5-7
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial DX] by the attorney or party listed in the caption 11 by the following:
a. Attorney:
b, Firm:
c. Address:
é Telephone number: f. Fax number:
E-mail address: g. Party represented:
o Additional representation is described in Attachment 8.
9, Preference
Cs 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 has (0 hasnot . provided ihe 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 te 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 Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
(CH-190 [Rev duly 1, 2011] CASE MANAGEMENT STATEMENT Page 20f8CM-110
= Hi Si (CASE NUMBER:
L_ PLAINTIFF/PETITIONER: Arti Singh Ghotra STK-CV-UPL-2020-0000748
IDEFENDANT/RESPONDENT: Elk Grove Ford, et al.
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 aif 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 ail that apply): | stipulation):
KX] Mediation session not yet scheduled
. 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 (dafe) :
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 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):
QOOOOQ;/OO00O;J;OOOO{OL
ADR completed on (date):
ConA Re. Jays 2049) CASE MANAGEMENT STATEMENT Poge Sof
sucusFoomeWWorkElow,comCM-110
INTI H Si (CASE NUMBER:
|___ PLAINTIFF/PETITIONER: Arti Singh Ghotra STK-CV-UPL-2020-0000748
DEFENDANT/RESPONDENT: Elk Grove Ford, et al.
11. Insurance
a. [1 Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes 0 no
c. [1 _ Coverage issues will significantly affect resolution of this case (expiain):
12, Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status,
1 Bankruptey [] Other (specify):
Status:
13, Related cases, consolidation, and coordination
a. LJ There are companion, uncerlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
Additional cases are described in Attachment 13a.
b. [] Amotionto [] consolidate coordinate will be filed by (name party):
14. Bifurcation
C1 The party or parties intend to file a mation 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
EI The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Potential summary judgment motion depending on discovery responses.
16. Discovery
a. (1 The party or parties have completed all discovery.
b &X] The following discovery will be completed by the date specified (describe ail anticipated discovery):
Party Description Date-
Ford Motor Company Fact Discovery Per Code
Ford Motor Company Expert Discovery Per Code
CQ The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
See attachment 16c.
CMO Rev. duly 1, 2044] CASE MANAGEMENT STATEMENT Page 4 of 5
‘American LegaiNet, Ine.
sew FormsWorklow.comCM-110
ITION » Arti Si Gl ‘CASE NUMBER:
| PLAINTIFF/PETITIONER: Arti Singh Ghotra STK-CV-UPL-2020-0000748
DEFENDANT/RESPONDENT: Elk Grove Ford, et al.
17, Economic litigation
a. This is a limited clvil 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. [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 Califomia Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any): 2
1am 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: October 28, 2020
Brittany B. Wilson rR Ree
xv
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(1 Additional signatures are attached.
CMe Rov. ay $2049 CASE MANAGEMENT STATEMENT Pages of5MC-025
| SHORT TITLE: CASE NUMBER:
Arti Singh Ghotra v. Elk Grove Ford, et al. STK-CV-UPL-2020-0000748
ATTACHMENT (Number): 6c
(This Attachment.may be used with any Judicial Council form.)
Unavailability:
1/25/2021 — 2/7/2021 — Trial in Vazquez (Arriaga) v. Ford Motor Company, Contra Costa Superior Court Case No. C17-
02374
2/2/2021 - 2/19/2021 - Trial in Ford Motor Warranty Cases, Los Angeles County Superior Court, JCCP 4856
2/26/2021 - 3/5/2021 - Trial in Franklin v. Ford Motor Company, Sonoma Superior Court Case No. SCV-258391
2/8/2021 — 2/19/2021 — Trial in Employers Mutual Casualty Company, et al. v. Ford Motor Company, Alameda County
Superior Court Case No. RG19006164
4/13/2021 - 4/30/2021 - Trial in Ford Motor Warranty Cases, Los Angeles County Superior Court, JCCP 4856
4/27/2021 - 5/11/2021 - Trial in Hobart v. Ford Motor Company, U.S.D.C. Central District of California Case No. 2:18-ml-
02814-AB-FFM
5/10/2021 — 6/4/2021 — Trial in Dias v. Ford Motor Company, San Joaquin Superior Court Case No.
STKCVUPL2019001 11314
5/25/2021 ~- 6/4/2021 - Trial in Altamirano-Torres v. Ford Motor Company, U.S.D.C. Central District of California Case No.
2:18-ml-02814-AB-FFM
Page
(If the item that this Attachment concerns is made under penalty of perjury, all statements in this 1 of 1
Attachment are made under penaity of perjury.) (Add pages as require! d)
Form Approved for Optional Use ATTACHMENT waww.courtinfo.cagor
Judicial Counct of California
"M0025 (Rev. duly 1, 2008} to Judicial Council Form Aner a eae« MC-025
SHORT TITLE: CASE NUMBER:
Arti Singh Ghotra v. Elk Grove Ford, et al. STK-CV-UPL-2020-0000748
ATTACHMENT (Number): 16c
(This Attachment may be used with any Judicial Council form.)
|, Scope of Discovery: Ford will limit its production to documents relevant to Plaintiff's allegations, the front right wheel
assembly installed on the subject vehicle, and to vehicles with the same front right wheel assemblies.
Il. Supplier Documents: The parties do not anticipate seeking proprietary documents from suppliers of Ford that are not
within Ford's possession, custody or control.
Ill, Production Format: The production of documents and things will be made in a commercially reasonable manner
and/or as they are kept within the ordinary course of business, whichever is less burdensome and more economical for
the producing party, including, but not limited to, electronically stored information. Ford will produce documents in an
electronic multi-page .tiff format containing viewable images and corresponding OCR text load files allowing Plaintiff to
load materials into a standard, industry-wide desktop document management program. Production formats may also
include drawings in the form of .tiff, jpeg, pdf files, etc. Ford will produce these documents to Plaintiff on CD, DVD, hard
drive, by e-mail, or by other electronic means, including by FTP.
IV. Protective Order: Some of the documents offered for production will be made available to Plaintiff subject to their
agreement to an appropriate Protective Order. The parties have agreed to meet and confer regarding the terms of a
protective order. Should the parties not be able to come to an agreement, Ford will seek the entry of protective order with
this Court.
V. Meet and Confer Obligations: Consistent with the requirements under the California Code of Civil Procedure, Ford
proposes that ta the extent disputes arise during discovery, the parties will meet and confer in good faith via telephone
and no discovery motions will be filed until after the parties have exchanged their respective factual and legal positions
related to each discovery concern. .
VI. Privileged Material: Ford understands that Plaintiff is not seeking materials protected from disclosure by the attorney-
client privilege or work-product doctrine; therefore, these materials are not considered responsive and a privilege log is
not necessary with respect to production of these materials.
Page
(if the item that this Attachment concerns is made under penalty of perjury, all statements in this 1 of 1
Attachment are made under penalty of perjury.) (Add pages as required)
Form Approved for Optional Use -courtinfo.ce. go
“Teall eauncl of toa ATTACHMENT __mneats
MO-026 [Rov. July 1, 2008] to Judicial Council FormPROOF OF SERVICE
The undersigned declare: I am over the age of 18 years and not a party to the within action. I am
employed in the county where this service occurs. My business address is One Montgomery, Suite
2600, San Francisco, California 94104, my facsimile number is (415) 391-0281. On the date shown
below I served the following document(s):
« DEFENDANT FORD MOTOR COMPANY’S CASE MANAGEMENT STATEMENT
on the interested parties named herein and in the manner indicated below:
David A. Kleczek
KLECZEK LAW OFFICE
825 Washington Street #301
Oakland, CA 94607
Tel: 510-663-7100
Fax: 510-663-7102
david.kleczek@kleczeklaw.com
jahaira.rodriguez@kleczeklaw,com
Attomey for Plaintiff Arti Singh Ghotra
FIRST CLASS U.S. MAIL: I enclosed the document(s) in a sealed envelope or package
addressed to the persons listed above by placing the envelope(s) for collection and mailing
following our ordinary business practices. I am readily familiar with this business’ practice
for collecting and processing correspondence for mailing. On the same day that
correspondence is placed for collection and mailing, it is deposited in the ordinary course of
business with the United States Postal Service in a sealed envelope with postage fully
prepaid.
BY EXPRESS MAIL NEXT DAY DELIVERY, AN OVERNIGHT DELIVERY
SERVICE: By placing a true and correct copy of the above document(s) in a sealed
envelope addressed as indicated above and causing such envelope(s) to be delivered to the
Federal Express Service Center, on , to be delivered by their next business day
delivery service on , to the addressee designated.
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 to the person(s) at the e-mail address(es) 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 October 28, 2020, at San Francisco, California.
of
Chh/ KO.
Christopher J. Martinez l
PROOF OF SERVICE,
4891279951182 2
Preview
CM-110 ‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Namo, Stato Bar number, end address): FOR COURT USE ONLY H. Grant Law SBN 144505 Brittany B. Wilson SBN 319977 FILES Shook, Hardy & Bacon L.L.P. 7 2600 Montgomery, Suite 2600 59 Oy San Francisco, CA 94104 N20 OCT 28 PH S37 veLePHone xo: 415-544-1900 FAX NO. (Optionay: 415-391-0281 E-MAIL ADDRESS (Optional): ATTORNEY FOR (Names: Defendant Ford Motor Company SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN street aporess: 180 E. Weber Street MAILING ADDRESS: cry ano zip cone: Stockton, CA 95202 BRANCH NAME: BRANDON E. RILEY, CLERK PLAINTIFF/PETITIONER: Arti Singh Ghotra DEFENDANT/RESPONDENT: Elk Grove Ford, et al. (Check one): CASE MANAGEMENT STATEMENT ‘CASE NUMBER: & UNLIMITED cASE Cs uimitep case STK-CV-UPL-2020-0000748 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: November 12, 2020 Time: 8:40 a.m. Dept.: 10D Div: Room: Address of court (if different from the address above): [Notice of Intent to Appear by Telephone, by (name): Brittany B. Wilson Judicial Councit of California GM-110 [Rev. July 1, 2011] INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. Ed This statement is submitted by party (name): Defendant Ford Motor Company b. [1 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. [1 The cross-compiaint, if any, was filed on (date): 3. Service (fo be answered by plaintilfs and cross-complainants only) a. [1 Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [1 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) [1 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 of case in ® complaint oO cross-complaint (Describe, including causes of action): Plaintiff alleges defects to the wheel assembly on a 2017 F-150 and claims strict products liability, general negligence, res ipsa loquiter, and breach of implied warranty against Ford and the dealership defendants. Form Adopted for Mandatory Uso CASE MANAGEMENT STATEMENT FILE BY FAXCM-110 i Sis CASE NUMBER: | PLAINTIFF/PETITIONER: Arti Singh Ghotra STI-CV-UPL-2020-0000748 DEFENDANT/RESPONDENT: Elk Grove Ford, 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 fo date findicate source and amount]. estimated future medical expenses, lost earnings fo date, and estimated future lost earnings. if equitable relief is sought, describe the nature of the relief.) Plaintiff alleges that while driving her 2017 Ford F-150 northbound on CA-99 in San Joaquin County near the Calaveras River on January 24, 2018, her right-side wheel assembly detached causing her to lose control of the vehicle and swerve into a tractor-trailer truck. Plaintiff asserts wage loss, loss of earning capacity, property damage, medical expenses, and general damages as a result of alleged defects in the F-150's wheel assembly. Ford denies Plaintiff's allegations. C1 (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 [) ajurytrial [1] 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. 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): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): KK days (specify number): 5-7 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial DX] by the attorney or party listed in the caption 11 by the following: a. Attorney: b, Firm: c. Address: é Telephone number: f. Fax number: E-mail address: g. Party represented: o Additional representation is described in Attachment 8. 9, Preference Cs 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 has (0 hasnot . provided ihe 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 te 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 Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): (CH-190 [Rev duly 1, 2011] CASE MANAGEMENT STATEMENT Page 20f8CM-110 = Hi Si (CASE NUMBER: L_ PLAINTIFF/PETITIONER: Arti Singh Ghotra STK-CV-UPL-2020-0000748 IDEFENDANT/RESPONDENT: Elk Grove Ford, et al. 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 aif 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 ail that apply): | stipulation): KX] Mediation session not yet scheduled . 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 (dafe) : 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 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): QOOOOQ;/OO00O;J;OOOO{OL ADR completed on (date): ConA Re. Jays 2049) CASE MANAGEMENT STATEMENT Poge Sof sucusFoomeWWorkElow,comCM-110 INTI H Si (CASE NUMBER: |___ PLAINTIFF/PETITIONER: Arti Singh Ghotra STK-CV-UPL-2020-0000748 DEFENDANT/RESPONDENT: Elk Grove Ford, et al. 11. Insurance a. [1 Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes 0 no c. [1 _ Coverage issues will significantly affect resolution of this case (expiain): 12, Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status, 1 Bankruptey [] Other (specify): Status: 13, Related cases, consolidation, and coordination a. LJ There are companion, uncerlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: Additional cases are described in Attachment 13a. b. [] Amotionto [] consolidate coordinate will be filed by (name party): 14. Bifurcation C1 The party or parties intend to file a mation 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 EI The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Potential summary judgment motion depending on discovery responses. 16. Discovery a. (1 The party or parties have completed all discovery. b &X] The following discovery will be completed by the date specified (describe ail anticipated discovery): Party Description Date- Ford Motor Company Fact Discovery Per Code Ford Motor Company Expert Discovery Per Code CQ The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): See attachment 16c. CMO Rev. duly 1, 2044] CASE MANAGEMENT STATEMENT Page 4 of 5 ‘American LegaiNet, Ine. sew FormsWorklow.comCM-110 ITION » Arti Si Gl ‘CASE NUMBER: | PLAINTIFF/PETITIONER: Arti Singh Ghotra STK-CV-UPL-2020-0000748 DEFENDANT/RESPONDENT: Elk Grove Ford, et al. 17, Economic litigation a. This is a limited clvil 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. [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 Califomia Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 2 1am 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: October 28, 2020 Brittany B. Wilson rR Ree xv (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (1 Additional signatures are attached. CMe Rov. ay $2049 CASE MANAGEMENT STATEMENT Pages of5MC-025 | SHORT TITLE: CASE NUMBER: Arti Singh Ghotra v. Elk Grove Ford, et al. STK-CV-UPL-2020-0000748 ATTACHMENT (Number): 6c (This Attachment.may be used with any Judicial Council form.) Unavailability: 1/25/2021 — 2/7/2021 — Trial in Vazquez (Arriaga) v. Ford Motor Company, Contra Costa Superior Court Case No. C17- 02374 2/2/2021 - 2/19/2021 - Trial in Ford Motor Warranty Cases, Los Angeles County Superior Court, JCCP 4856 2/26/2021 - 3/5/2021 - Trial in Franklin v. Ford Motor Company, Sonoma Superior Court Case No. SCV-258391 2/8/2021 — 2/19/2021 — Trial in Employers Mutual Casualty Company, et al. v. Ford Motor Company, Alameda County Superior Court Case No. RG19006164 4/13/2021 - 4/30/2021 - Trial in Ford Motor Warranty Cases, Los Angeles County Superior Court, JCCP 4856 4/27/2021 - 5/11/2021 - Trial in Hobart v. Ford Motor Company, U.S.D.C. Central District of California Case No. 2:18-ml- 02814-AB-FFM 5/10/2021 — 6/4/2021 — Trial in Dias v. Ford Motor Company, San Joaquin Superior Court Case No. STKCVUPL2019001 11314 5/25/2021 ~- 6/4/2021 - Trial in Altamirano-Torres v. Ford Motor Company, U.S.D.C. Central District of California Case No. 2:18-ml-02814-AB-FFM Page (If the item that this Attachment concerns is made under penalty of perjury, all statements in this 1 of 1 Attachment are made under penaity of perjury.) (Add pages as require! d) Form Approved for Optional Use ATTACHMENT waww.courtinfo.cagor Judicial Counct of California "M0025 (Rev. duly 1, 2008} to Judicial Council Form Aner a eae« MC-025 SHORT TITLE: CASE NUMBER: Arti Singh Ghotra v. Elk Grove Ford, et al. STK-CV-UPL-2020-0000748 ATTACHMENT (Number): 16c (This Attachment may be used with any Judicial Council form.) |, Scope of Discovery: Ford will limit its production to documents relevant to Plaintiff's allegations, the front right wheel assembly installed on the subject vehicle, and to vehicles with the same front right wheel assemblies. Il. Supplier Documents: The parties do not anticipate seeking proprietary documents from suppliers of Ford that are not within Ford's possession, custody or control. Ill, Production Format: The production of documents and things will be made in a commercially reasonable manner and/or as they are kept within the ordinary course of business, whichever is less burdensome and more economical for the producing party, including, but not limited to, electronically stored information. Ford will produce documents in an electronic multi-page .tiff format containing viewable images and corresponding OCR text load files allowing Plaintiff to load materials into a standard, industry-wide desktop document management program. Production formats may also include drawings in the form of .tiff, jpeg, pdf files, etc. Ford will produce these documents to Plaintiff on CD, DVD, hard drive, by e-mail, or by other electronic means, including by FTP. IV. Protective Order: Some of the documents offered for production will be made available to Plaintiff subject to their agreement to an appropriate Protective Order. The parties have agreed to meet and confer regarding the terms of a protective order. Should the parties not be able to come to an agreement, Ford will seek the entry of protective order with this Court. V. Meet and Confer Obligations: Consistent with the requirements under the California Code of Civil Procedure, Ford proposes that ta the extent disputes arise during discovery, the parties will meet and confer in good faith via telephone and no discovery motions will be filed until after the parties have exchanged their respective factual and legal positions related to each discovery concern. . VI. Privileged Material: Ford understands that Plaintiff is not seeking materials protected from disclosure by the attorney- client privilege or work-product doctrine; therefore, these materials are not considered responsive and a privilege log is not necessary with respect to production of these materials. Page (if the item that this Attachment concerns is made under penalty of perjury, all statements in this 1 of 1 Attachment are made under penalty of perjury.) (Add pages as required) Form Approved for Optional Use -courtinfo.ce. go “Teall eauncl of toa ATTACHMENT __mneats MO-026 [Rov. July 1, 2008] to Judicial Council FormPROOF OF SERVICE The undersigned declare: I am over the age of 18 years and not a party to the within action. I am employed in the county where this service occurs. My business address is One Montgomery, Suite 2600, San Francisco, California 94104, my facsimile number is (415) 391-0281. On the date shown below I served the following document(s): « DEFENDANT FORD MOTOR COMPANY’S CASE MANAGEMENT STATEMENT on the interested parties named herein and in the manner indicated below: David A. Kleczek KLECZEK LAW OFFICE 825 Washington Street #301 Oakland, CA 94607 Tel: 510-663-7100 Fax: 510-663-7102 david.kleczek@kleczeklaw.com jahaira.rodriguez@kleczeklaw,com Attomey for Plaintiff Arti Singh Ghotra FIRST CLASS U.S. MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the persons listed above by placing the envelope(s) for collection and mailing following our ordinary business practices. I am readily familiar with this business’ practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service in a sealed envelope with postage fully prepaid. BY EXPRESS MAIL NEXT DAY DELIVERY, AN OVERNIGHT DELIVERY SERVICE: By placing a true and correct copy of the above document(s) in a sealed envelope addressed as indicated above and causing such envelope(s) to be delivered to the Federal Express Service Center, on , to be delivered by their next business day delivery service on , to the addressee designated. 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 to the person(s) at the e-mail address(es) 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 October 28, 2020, at San Francisco, California. of Chh/ KO. Christopher J. Martinez l PROOF OF SERVICE, 4891279951182 2