Preview
a Doe CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar aumber, and address): _ bet ee FaR EO oF SE ONLY
David A. Kleczek, SBN 244045 . SUPERIOR COURT - STOCKTON
825 Washington Street, Suite 301 nat . . E3219
Oakland, CA $4607 me @20 NOV -2 PH St
‘TELEPHONE NO.: (510) 663-7100 FAX NO. (Optional: (510) 663-7102 BRANSON E.R CLERK
E-MAIL ADDRESS (Optonay: david. kleczek@kleczeklaw.com
ATTORNEY FOR (Name): Plaintiff Nicole Chambers
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Joaquin
street anpress: 180 E. Weber Avenue
MAILING ADDRESS:
emry AND ZIP CODE: Stockton 95202
BRANCH NAME:
PLAINTIFF/PETITIONER: Arti Singh Ghotra
DEFENDANT/RESPONDENT: Elk Grove Ford, Ford Motor Company , Performance
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): CZ] UNLIMITED CASE [41 umrep case STK-CV-UPL-2020-0000748
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or lass)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: November 12, 2020 Time: 8:45am Dept: 10D Div.: Civil Room:
Address of court (if different from the address above):
County of San Joaquin 180 E Weber Avenue Stockton, CA 95202
[Z) Notice of Intent to Appear by Telephone, by (name): David A. Kleczek
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. [4] This statement is submitted by party (name): Plaintiff Arti Singh Ghotra
b. This statement is submitted jointly by parties (games):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): January 15, 2020
b. [71 The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. [71] Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. C4] The following parties named in the complaint or cross-complaint
(1) [41 have not been served (specify names and explain why not):
See attachment 3{b)(1)
(2) [1 have been served but have not appeared and have not been dismissed (specify names):
____Elk Grove Ford, responsive pleading due November 8, 2020.
(3) L#]_ have had a default entered against them (specify names):
Current Auto Performance Group, Inc.
c. L_1 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 ofcasein [¥] complaint cross-complaint (Describe, including causes of action):
This case involves general negligence and product liability. Plaintiff was driving her brand new truck down the
freeway when the front right wheel suddenly without warning came off causing her to swerve in front of a truck.
Page t of §
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal Rules ot Co
CM-110 (Rev. July 1, 2014] www courts.ca.gov
jo0
WeCM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Arti Singh Ghotra
STK-CV-UPL-2020-0000748
DEFENDANT/RESPONDENT: Elk Grove Ford, Ford Motor Company , Performance
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
earings to date, and estimated future lost earnings. if equitable relief is sought, describe the nature of the relief.)
The Plaintiff was struck by a semi-tractor trailer causing traumatic brain injuries, and neck and back injuries.
[1 (ifmore space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
‘The party or parties request 4) ajurytrial [ a nonjury trial. (if more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
The trial has been set for (date): .
S (1) No tral 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):
11/2-11/6/2020 (arb.), 12/7-12/11/2020 (jury tial), 12/21/2020-1/8/2021 (vacation), 2/22-2/26/2020 (jry trial)
7. Estimated length of trial
‘The party or parties estimate that the trial will take (check one):
a. [¥] days (specify number): 3-5
b. haurs (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial [YZ] by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
a Telephone number: f. Fax number:
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 Lv] has has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party [1 has [1 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 ‘ade of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
si ry 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.
@) 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):
CMO Row sey 4.2014] CASE MANAGEMENT STATEMENT PagezersPLAINTIFF/PETITIONER: Arti Singh Ghotra
IEFENDANT/RESPONDENT: Elk Grove Ford, Ford Motor Company , Performance
CM-110
[CASE NUMBER:
STK-CV-UPL-2020-0000748
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 all that apply and provide the specified information):
(1) Mediation
(2) Settlement
conference
(3) Neutral evaluation
The party or parties completing
this form are willing to
participate in the following ADR
processes (check ail that apply):
If the party or parties completing this form in the case have agreed to
participate in or have already completed an ADR process or processes,
indicate the status of the processes (attach a copy of the parties‘ ADR
stipulation):
(4) Nonbinding judicial
arbitration
(5) Binding private
arbitration
(6) Other (specify):
Ww
Mediation session not yet scheduled
Mediation session scheduled for (date):
Agreed to complete mediation by (date):
Mediation completed on (dafe):
Settlement conference not yet scheduled
Settlement conference scheduled for (date):
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date):
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
OOOO;/OU00/OO00;/OO00;O0U8| odd
ADR session not yet scheduled
ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
(CM-110 (Rev. duly 4, 2011]
CASE MANAGEMENT STATEMENT
Page 30f6PLAINTIFF/PETITIONER: Arti Singh Ghotra ‘CASE NUMBER:
DEFENDANT/RESPONDENT: Elk Grove Ford, Ford Motor Company , Performance STK-CV-UPL-2020-0000748
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:
(3) Case number:
(4) Status:
[_] Additional cases are described in Attachment 13a.
b. [J] Amotionto [_] consolidate [(_] coordinate _ will be filed by (name party):
14, Bifurcation
[7 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
[] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16, Discovery
a. [_] The party or parties have completed all discovery.
b. (7 The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiff Depositions of Defendants. Within 180 days
Plaintiff Written Discovery to Defendants Within 90 days
c, [__] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
OM 410 Row. ha, 2041 CASE MANAGEMENT STATEMENT Page otCM-110
PLAINTIFF/PETITIONER: — Arti Singh Ghotra CASE NUMBER:
STK-CV-UPL-2020-0000748
DEFENDANT/RESPONDENT: Elk Grove Ford, Ford Motor Company , Performance
17. Economic litigation
a. This is a limited civil case (i.¢., 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 casa):
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 ‘The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules
of Count (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):
Jam 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 QO Sa” )
David A. Kleczek >
(TYPE OR PRINT NAME)
(SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CMH few 12011 CASE MANAGEMENT STATEMENT Page SorGhotra v. Ford, et al., San Joaquin Superior Court Case No. STK-CV-UPL-2020-0000748
Attachment 3(b)(1)
Service was effectuated on Elk Grove Ford on October 8, 2020, and a response is due November
8, 2020,
For Performance Auto Group, Inc. service was attempted on two separate attempts, but the prior
listed agent pursuant to the California Secretary of State’s Office was a gas station. A new filing
on October 5, 2020 with the Secretary of State website shows a new agent for service of process.
On October 28, 2020, Plaintiff's counsel submitted a request for service of the summons,
complaint and civil cover sheet to the new address,
A default was entered as to Current Performance. Auto Group, Inc.PROOF OF SERVICE
Arti Singh Ghotra, et. al. v. Elk Grove Ford; Ford Motor Company; Performance Group Auto
Group, Inc; Current Auto Performance Group, Inc,; and Does 1-50,
San Joaquin, County Superior Court Case No.: STK-CV-UPL-2020-0000748
STATE OF CALIFORNIA, COUNTY OF SAN JOAQUIN:
1am employed in the County of Alameda, State of California. I am over the age of
eighteen (18) and am not a party to the within action; my business address is 825 Washington
St., Ste 301, Oakland, CA 94607.
On October 28, 2020, I served the following document(s) described as
CASE MANAGEMENT STATEMENT- ATTACHMENT
ENTRY OF DEFAULT- CURRENT AUTO PERFORMANCE GROUP, INC
on all interested parties as follows:
MI by placing o the original Ma true copy thereof enclosed in a sealed envelope
addressed as follows:
SHOOK, HARDY & BACON L.L.P
One Montgomery, Suite 2600
San Francisco, California 94104
Email: fkelly@shb.com
hlaw@shb.com
bwilson@shb.com
mmanetti@shb.com
CMARTINEZ@shb.com
Attorney for Defendants
FORD MOTOR COMPANY
M BY ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the
parties to accept service by e-mail or electronic transmission, I cause the documents to be
sent from e-mail address jahaira.rodriguez@kleczeklaw.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.
PROOF OF SERVICEv BY MAIL: On October 28, 2020, by placing a true copy thereof in a sealed envelope
addressed as above and placing it for collection and mailing following ordinary business
practices. I am readily familiar with Kleczek Law Office’s practice of collection and
processing correspondence for mailing. Under that practice it would be deposited with
U.S. postal service on that same day with postage thereon fully prepaid at Oakland,
California, in the ordinary course of business. i am aware that on motion of party served,
service is presumed invalid if postal cancellation date of postage meter date is more that
one date of deposit for mailing in affidavit.
VM [State] 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 Oakland, California
PROOF OF SERVICE
Preview
a Doe CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar aumber, and address): _ bet ee FaR EO oF SE ONLY David A. Kleczek, SBN 244045 . SUPERIOR COURT - STOCKTON 825 Washington Street, Suite 301 nat . . E3219 Oakland, CA $4607 me @20 NOV -2 PH St ‘TELEPHONE NO.: (510) 663-7100 FAX NO. (Optional: (510) 663-7102 BRANSON E.R CLERK E-MAIL ADDRESS (Optonay: david. kleczek@kleczeklaw.com ATTORNEY FOR (Name): Plaintiff Nicole Chambers SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Joaquin street anpress: 180 E. Weber Avenue MAILING ADDRESS: emry AND ZIP CODE: Stockton 95202 BRANCH NAME: PLAINTIFF/PETITIONER: Arti Singh Ghotra DEFENDANT/RESPONDENT: Elk Grove Ford, Ford Motor Company , Performance CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): CZ] UNLIMITED CASE [41 umrep case STK-CV-UPL-2020-0000748 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or lass) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: November 12, 2020 Time: 8:45am Dept: 10D Div.: Civil Room: Address of court (if different from the address above): County of San Joaquin 180 E Weber Avenue Stockton, CA 95202 [Z) Notice of Intent to Appear by Telephone, by (name): David A. Kleczek INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. [4] This statement is submitted by party (name): Plaintiff Arti Singh Ghotra b. This statement is submitted jointly by parties (games): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): January 15, 2020 b. [71 The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. [71] Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. C4] The following parties named in the complaint or cross-complaint (1) [41 have not been served (specify names and explain why not): See attachment 3{b)(1) (2) [1 have been served but have not appeared and have not been dismissed (specify names): ____Elk Grove Ford, responsive pleading due November 8, 2020. (3) L#]_ have had a default entered against them (specify names): Current Auto Performance Group, Inc. c. L_1 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 ofcasein [¥] complaint cross-complaint (Describe, including causes of action): This case involves general negligence and product liability. Plaintiff was driving her brand new truck down the freeway when the front right wheel suddenly without warning came off causing her to swerve in front of a truck. Page t of § Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal Rules ot Co CM-110 (Rev. July 1, 2014] www courts.ca.gov jo0 WeCM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Arti Singh Ghotra STK-CV-UPL-2020-0000748 DEFENDANT/RESPONDENT: Elk Grove Ford, Ford Motor Company , Performance 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 earings to date, and estimated future lost earnings. if equitable relief is sought, describe the nature of the relief.) The Plaintiff was struck by a semi-tractor trailer causing traumatic brain injuries, and neck and back injuries. [1 (ifmore space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial ‘The party or parties request 4) ajurytrial [ a nonjury trial. (if more than one party, provide the name of each party requesting a jury trial): 6. Trial date The trial has been set for (date): . S (1) No tral 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): 11/2-11/6/2020 (arb.), 12/7-12/11/2020 (jury tial), 12/21/2020-1/8/2021 (vacation), 2/22-2/26/2020 (jry trial) 7. Estimated length of trial ‘The party or parties estimate that the trial will take (check one): a. [¥] days (specify number): 3-5 b. haurs (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial [YZ] by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: a Telephone number: f. Fax number: 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 Lv] has has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party [1 has [1 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 ‘ade of Civil Procedure section 1775.3 because the amount in controversy does not exceed the si ry 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. @) 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): CMO Row sey 4.2014] CASE MANAGEMENT STATEMENT PagezersPLAINTIFF/PETITIONER: Arti Singh Ghotra IEFENDANT/RESPONDENT: Elk Grove Ford, Ford Motor Company , Performance CM-110 [CASE NUMBER: STK-CV-UPL-2020-0000748 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 all that apply and provide the specified information): (1) Mediation (2) Settlement conference (3) Neutral evaluation The party or parties completing this form are willing to participate in the following ADR processes (check ail that apply): If the party or parties completing this form in the case have agreed to participate in or have already completed an ADR process or processes, indicate the status of the processes (attach a copy of the parties‘ ADR stipulation): (4) Nonbinding judicial arbitration (5) Binding private arbitration (6) Other (specify): Ww Mediation session not yet scheduled Mediation session scheduled for (date): Agreed to complete mediation by (date): Mediation completed on (dafe): Settlement conference not yet scheduled Settlement conference scheduled for (date): Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled Judicial arbitration scheduled for (date): Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled Private arbitration scheduled for (date): Agreed to complete private arbitration by (date): Private arbitration completed on (date): OOOO;/OU00/OO00;/OO00;O0U8| odd ADR session not yet scheduled ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): (CM-110 (Rev. duly 4, 2011] CASE MANAGEMENT STATEMENT Page 30f6PLAINTIFF/PETITIONER: Arti Singh Ghotra ‘CASE NUMBER: DEFENDANT/RESPONDENT: Elk Grove Ford, Ford Motor Company , Performance STK-CV-UPL-2020-0000748 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: (3) Case number: (4) Status: [_] Additional cases are described in Attachment 13a. b. [J] Amotionto [_] consolidate [(_] coordinate _ will be filed by (name party): 14, Bifurcation [7 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 [] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16, Discovery a. [_] The party or parties have completed all discovery. b. (7 The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Plaintiff Depositions of Defendants. Within 180 days Plaintiff Written Discovery to Defendants Within 90 days c, [__] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): OM 410 Row. ha, 2041 CASE MANAGEMENT STATEMENT Page otCM-110 PLAINTIFF/PETITIONER: — Arti Singh Ghotra CASE NUMBER: STK-CV-UPL-2020-0000748 DEFENDANT/RESPONDENT: Elk Grove Ford, Ford Motor Company , Performance 17. Economic litigation a. This is a limited civil case (i.¢., 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 casa): 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 ‘The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Count (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): Jam 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 QO Sa” ) David A. Kleczek > (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CMH few 12011 CASE MANAGEMENT STATEMENT Page SorGhotra v. Ford, et al., San Joaquin Superior Court Case No. STK-CV-UPL-2020-0000748 Attachment 3(b)(1) Service was effectuated on Elk Grove Ford on October 8, 2020, and a response is due November 8, 2020, For Performance Auto Group, Inc. service was attempted on two separate attempts, but the prior listed agent pursuant to the California Secretary of State’s Office was a gas station. A new filing on October 5, 2020 with the Secretary of State website shows a new agent for service of process. On October 28, 2020, Plaintiff's counsel submitted a request for service of the summons, complaint and civil cover sheet to the new address, A default was entered as to Current Performance. Auto Group, Inc.PROOF OF SERVICE Arti Singh Ghotra, et. al. v. Elk Grove Ford; Ford Motor Company; Performance Group Auto Group, Inc; Current Auto Performance Group, Inc,; and Does 1-50, San Joaquin, County Superior Court Case No.: STK-CV-UPL-2020-0000748 STATE OF CALIFORNIA, COUNTY OF SAN JOAQUIN: 1am employed in the County of Alameda, State of California. I am over the age of eighteen (18) and am not a party to the within action; my business address is 825 Washington St., Ste 301, Oakland, CA 94607. On October 28, 2020, I served the following document(s) described as CASE MANAGEMENT STATEMENT- ATTACHMENT ENTRY OF DEFAULT- CURRENT AUTO PERFORMANCE GROUP, INC on all interested parties as follows: MI by placing o the original Ma true copy thereof enclosed in a sealed envelope addressed as follows: SHOOK, HARDY & BACON L.L.P One Montgomery, Suite 2600 San Francisco, California 94104 Email: fkelly@shb.com hlaw@shb.com bwilson@shb.com mmanetti@shb.com CMARTINEZ@shb.com Attorney for Defendants FORD MOTOR COMPANY M BY ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the parties to accept service by e-mail or electronic transmission, I cause the documents to be sent from e-mail address jahaira.rodriguez@kleczeklaw.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. PROOF OF SERVICEv BY MAIL: On October 28, 2020, by placing a true copy thereof in a sealed envelope addressed as above and placing it for collection and mailing following ordinary business practices. I am readily familiar with Kleczek Law Office’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited with U.S. postal service on that same day with postage thereon fully prepaid at Oakland, California, in the ordinary course of business. i am aware that on motion of party served, service is presumed invalid if postal cancellation date of postage meter date is more that one date of deposit for mailing in affidavit. VM [State] 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 Oakland, California PROOF OF SERVICE