Preview
CM-110
ATTORNEY OR PARTY W"HOUT ATTORNEY (Name, Slate Bar number and address} FOR COURT USE ONLY
Ned E, Dunphy SBN: 128601
THE LAW OFFICES YOUNG WOOLDRIDGE, LLP
1800 30th Street, Fourth Floor,
Bakersfield, CA 93301
TELEPHONE NO, 661-327-9661 FAX NO. (Optionay. 661-327-1087
=MaK ADRESS. ndunphy@youngwooldridge.com
ATTORNEY FOR (Name): Plaintiffs, Levi Cole Moss, a minor, and Aiden Lee Moss, a minor
SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN
STREET ANDRESS 1215 Truxtun Avenue
MAILING ADDRESS: 1215 Truxtun Avenue
CTYARD ZIPCODE’ Bakersfield, 93301
BRANCHNAVE Metro Justice Building
PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor
DEFENDANT/RESPONDENT: Noe Garcia, et al.
CASE MANAGEMENT STATEMENT CASE NUNBER
(Check one): UNLIMITED CASE C] LIMITED CASE BCV 19-103330 CW/
(Amount demanded (Amount demanded is $25,000
BCV 20-102977 and BCV-21-101449
exceeds $25,006) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: October 26, 2022 Time:8:30 a.m. Dept.: Div..J Room.
|Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Ned E. Dunphy
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a This statement is submitted by party (name): Plaintiffs, Levi Cole Moss and Aiden Lee Moss
b. [-] This statementis submitted jointly by parties (names):
2. Complaint and cross-compliaint (fo be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date)-December 21, 2020
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) [J] have not been served (specify names and expiain why not):
(2) [[7) have been served but have not appeared and ave not been dismissed (specify names): Eric Sertic
(3) [-_] have had a default entered against them (specify names):
¢. [J The following additional parties may be added (specify names, nafure of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of casein complaint [C2] cross-compiaint (Describe, including causes of action): Motor vehicic
accident resulting in wrongful death,
Page | of8
i Cal Rules of Cour,
Forr Adopted for Mandatory Jee
Judicial Couns of Caldera CASE MANAGEMENT STATEMENT aes ee me
CM-110 fRev. September 1, 2021}
Westaw Dab Foom BolleCM-110
PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lec Moss, a Minor CASE NUMBER:
DEFENDANT/RESPONDENT: Nie Garcia, et al. BCV 20-102977 and BCV-21-101449
4. b. Provide a brief statement of the case, including any damages. (/f personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date findicate source and amount], estimated fulure medical expenses, lost
earnings to date, and estimated future lost earings. If equitable relief is sought, describe the nature of the relief.)
Plaintiffs, Levi Cote Moss and Aiden Lee Moss are the children of Kylee Jordan Moss, Deceased. Plaintiffs suffered loss of
love, companionship, comfort, care, assistance and protection.
{J (/f 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 a@ jury trial [J 4 nonjury trial, (/f 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. (£X] 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).
¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavaitabilily):
05/01/23-05/08/23; 05/22/23-05/29/23; 08/07/23-08/ 1/23 due to other trials currently set.
7. Estimated length of trial
The party or parties estimate that the teal will take (check one):
days (specify number). 7-10
b. [77] hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial
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:
[7] Additional representation is described in Attachment 8
9. Preference
[_] This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
@. 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 of the California Rules of Court for information about the
processes available through the court and community prograrrs in this case.
(1) For parties represented by counsel: Counsel [__] 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 [7] has [7] has not reviewed the ADR information package identified in rule 3.221.
b. Referrat to judicial arbitration or civil action mediation (if availabie).
(1) [7] This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1147.14 or to civil action
mediation under Code of Civi! Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) 7] 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):
Page 2015
CANO TRev Seplembor 1.2024) CASE MANAGEMENT STATEMENTCM-110
PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor CASE NUMBER.
“V 20- 21-1014
DEFENDANT/RESPONDENT xiao Garcia, et al. BCV 20-102977 and BCV-21-101449
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 ail 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 all that apply): |stipulation):
Mediation session not yet scheduled
(_] Mediation session scheduled for (date):
[_] Agreed to complete mediation by (date):
[] Mediation completed on (date):
(4) Mediation
Settlement conference not yet scheduled
[C7] Settlement conference scheduled for (date):
[J Agreed to complete settlement conference by (date):
[£7] Settlement conference completed on (date):
{2) Settlement
conference
[7] Neutral evatuation not yet scheduled
(] Neutra! evaluation scheduled for (date):
[1 Agreed to complete neutral evaluation by (date):
{__] Neutral evaluation completed on (date):
(3) Neutral evaluation Cy
( } Sudiciat arbitration not yet scheduled
(4) Nonbinding judicial co [2] Judicial arbitration scheduled for (date):
arbitration [C2] Agreed to complete judicial arbitration by (date):
(2 Judicial arbitration completed on (date):
[7] Private arbitration not yet scheduled
(8) Binding private Co [|] Pate arbitration scheduled for (date):
arbitration Agreed to complete private arbitration by (date):
[=] Private arbitration compteted on (date):
[77] ADR session not yet scheduled
[-_] AOR session scheduled for (date):
{["] Agreed to complete ADR session by (date):
[CU] ADR compieted on (date):
(6) Other (specify): co
GM.110 [Rev, September 1, 2021] CASE MANAGEMENT STATEMENT Page dotsCM-110
PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor _| case vumeer
DEFENDANT/RESPONDENT: Noe Garcia, et al. BCV 20-102977 and BCV-2}-101449
41. Insurance
a. ["_] insurance cartier, if any, for party filing this statement (rame):
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.
[7] Bankruptcy [77} Other (specify):
Status:
13, Related cases, consolidation, and coordination
a. [-X]} There are companion, underlying, or related cases.
(1) Name of case: Sertic v. Garcia, et al,
(2) Name of court: Kern County Superior Court
(3) Case numberBCV-19-103330
(4) Status: consolidated with BCV-20-102977
["] Additional cases are described in Attachment 13a.
b. [__] A motion to [J consolidate [ZZ] 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 reasans):
15. Other mations
The party or parties expect to file the folowing motions before trial (specify moving party, type of motion, and issues):
Motions in Limine
16. Discovery
a. [__] The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery).
Party Description Date
Plaintiffs Deposition of Defendant January, 2023
Plaintiffs Depositions of several PMKS January, 2023
Plaintiffs Further written Discovery January, 2023
Plaintiffs Expert Discovery per code
Plaintiffs Supplemental Discovery per code
c. [_]} The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Cx-tO Raw Septeribar + 2021) CASE MANAGEMENT STATEMENT Page sot 5cM-110
PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor ‘CASE NUMBER:
DEFENDANT/RESPONDENT: Noe Garcia, et al BCV 20-102977 and BCV-21-101449
17. Economic litigation
a. [77] 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
[£7] 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 conferted with all pariies 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):
tam completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as weil 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: F8f12 J29. a a fh om
rowan ee NON
> nt
(FYPE OR PRINT NAME} (SIGNATURE OF PARTY OR ATTORNEY)
[J Additional! signatures are attached.
NED E. DUNPHY. >
(TYPE OR PRINT NAME)
Page Sot
CMO Rew Sertenber 1 20741 CASE MANAGEMENT STATEMENTine Law Uttices Uf
Young Wooldridge, LLP
A LIMITED LIABILITY PARTNERSHIP COMPOSED OF PROFESSIONAL CORPORATIONS
Westchester Corporate Plaza ¢ £800 30" Street, Fourth Floor ® Bakersfield, CA 93301-5298 ¢ Telephone 661-327-9661 ¢ Facsimile 661-327-1087 hetp://www.youngwooldridge.com
eS Oe I Dm RB Be NY
yoN YY YP PN NR RP oe _
S2 32 FF we G8 8 SF Fe RRR GE EF Ss
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF KERN
1, YESENIA LAMBARENA, declare: I am and was at the times of the service hereunder
mentioned, over the age of eighteen (18) years, and not a party to the within cause. My business address is
The Westchester Corporate Plaza, 1800 30th Street, Fourth Floor, Bakersfield, CA 93301.
On October 12, 2022, I caused to be served the below listed document(s) titled as: CASE
MANAGEMENT STATEMENT on the interested parties in this action, as listed below:
See Attached Service List
(BY MAIL), pursuant to C.C.P. § 1013(a). By placing /__/ the original or /x/ a true copy
thereof enclosed in a sealed envelope. I am readily familiar with the firm's practice of
collection and processing of documents for mailing. Under that practice it would be deposited
with United States Postal Service on that same day with postage thereon fully prepaid at
Bakersfield, California in the ordinary course of business.
(BY FACSIMILE TRANSMISSION), pursuant to Rule § 2.306 of the California Rules of
Court. The telephone number of the sending facsimile machine was (661) 327-1087. A
transmission report was properly issued by the sending facsimile machine, and the
transmission was reported as complete and without error.
(BY PERSONAL SERVICE), pursuant to C.C.P. § 1011, | caused such envelope to be
delivered by hand to the offices of the addressee(s),
x ONLY BY EMAIL TRANSMISSION: Pursuant to Emergency Rule 12 of the California
Code of Civil Procedure, which was adopted by the Judicial Counsel in response to the
COVID-19 pandemic, this document is being served by electronic transmission only.
Executed on October 12, 2022, at Bakersfield, California.
Xx (STATE) I declare under penalty of perjury under the laws of the State of California that the
above is true and correct.
(FEDERAL) I declare that | am employed in the office of a member of the bar of this Court
at whose direction the service was made. f
( l. Lthin., tamper“
Yesenia Lambarena =~4220 Von Karman Avenue, Suite 200
Attorneys for Plaintiff ERIC SERTIC
18 Related Case No. BCV-19-103330
ashkalin@sweetjames.com
emilyci@sweetjames.com
&
4 1 SERVICE LIST
? 2
: 3|| Brooklyn Deann Moss V. Noe Garcia, et al.
2 4 Case No. BCV-19-103330 CW/ BCV-20-102977 and BCV-21-101449
=
£ 5 Justin Lowtrip, Esq.
. 11150 W. Olympic Blvd., Suite 1050
5 6 Los Angeles, CA 90064
= T: (424) 273-1462
8 7 Jlowirip@lowtriplaw.com
= 8 edent@lowtriplaw.cont
= Attorneys for Defendants/Cross-Defendants
oe 9 LAURA GUIDO and NOE GARCIA AND D&L TRUCKING DOE I
As £3 10 Thomas W. Shaver, Esq.
nd an i SHAVER, KORFF & CASTRONOVO LLP
ot 16255 Ventura Boulevard, Suite 850
ob? fon Encino, CA 91436
3 3 2 B Attomey for Defendant ERIC SERTIC
SB
BoM
2 = 23 Ashkhan Mohamadi, Esq.
Aes 1 SWEET JAMES, LLP
=
: = 20 piperi@sweetjames.com
5 kiannaw@sweetjames.com
= 21
g
a 2
&
3 23
§ 24
2 25
2 26
g
g 27
g 28
Preview
CM-110 ATTORNEY OR PARTY W"HOUT ATTORNEY (Name, Slate Bar number and address} FOR COURT USE ONLY Ned E, Dunphy SBN: 128601 THE LAW OFFICES YOUNG WOOLDRIDGE, LLP 1800 30th Street, Fourth Floor, Bakersfield, CA 93301 TELEPHONE NO, 661-327-9661 FAX NO. (Optionay. 661-327-1087 =MaK ADRESS. ndunphy@youngwooldridge.com ATTORNEY FOR (Name): Plaintiffs, Levi Cole Moss, a minor, and Aiden Lee Moss, a minor SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN STREET ANDRESS 1215 Truxtun Avenue MAILING ADDRESS: 1215 Truxtun Avenue CTYARD ZIPCODE’ Bakersfield, 93301 BRANCHNAVE Metro Justice Building PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor DEFENDANT/RESPONDENT: Noe Garcia, et al. CASE MANAGEMENT STATEMENT CASE NUNBER (Check one): UNLIMITED CASE C] LIMITED CASE BCV 19-103330 CW/ (Amount demanded (Amount demanded is $25,000 BCV 20-102977 and BCV-21-101449 exceeds $25,006) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: October 26, 2022 Time:8:30 a.m. Dept.: Div..J Room. |Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Ned E. Dunphy INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a This statement is submitted by party (name): Plaintiffs, Levi Cole Moss and Aiden Lee Moss b. [-] This statementis submitted jointly by parties (names): 2. Complaint and cross-compliaint (fo be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date)-December 21, 2020 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) [J] have not been served (specify names and expiain why not): (2) [[7) have been served but have not appeared and ave not been dismissed (specify names): Eric Sertic (3) [-_] have had a default entered against them (specify names): ¢. [J The following additional parties may be added (specify names, nafure of involvement in case, and date by which they may be served): 4. Description of case a. Type of casein complaint [C2] cross-compiaint (Describe, including causes of action): Motor vehicic accident resulting in wrongful death, Page | of8 i Cal Rules of Cour, Forr Adopted for Mandatory Jee Judicial Couns of Caldera CASE MANAGEMENT STATEMENT aes ee me CM-110 fRev. September 1, 2021} Westaw Dab Foom BolleCM-110 PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lec Moss, a Minor CASE NUMBER: DEFENDANT/RESPONDENT: Nie Garcia, et al. BCV 20-102977 and BCV-21-101449 4. b. Provide a brief statement of the case, including any damages. (/f personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date findicate source and amount], estimated fulure medical expenses, lost earnings to date, and estimated future lost earings. If equitable relief is sought, describe the nature of the relief.) Plaintiffs, Levi Cote Moss and Aiden Lee Moss are the children of Kylee Jordan Moss, Deceased. Plaintiffs suffered loss of love, companionship, comfort, care, assistance and protection. {J (/f 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 a@ jury trial [J 4 nonjury trial, (/f 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. (£X] 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). ¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavaitabilily): 05/01/23-05/08/23; 05/22/23-05/29/23; 08/07/23-08/ 1/23 due to other trials currently set. 7. Estimated length of trial The party or parties estimate that the teal will take (check one): days (specify number). 7-10 b. [77] hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial 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: [7] Additional representation is described in Attachment 8 9. Preference [_] This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) @. 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 of the California Rules of Court for information about the processes available through the court and community prograrrs in this case. (1) For parties represented by counsel: Counsel [__] 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 [7] has [7] has not reviewed the ADR information package identified in rule 3.221. b. Referrat to judicial arbitration or civil action mediation (if availabie). (1) [7] This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1147.14 or to civil action mediation under Code of Civi! Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) 7] 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): Page 2015 CANO TRev Seplembor 1.2024) CASE MANAGEMENT STATEMENTCM-110 PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor CASE NUMBER. “V 20- 21-1014 DEFENDANT/RESPONDENT xiao Garcia, et al. BCV 20-102977 and BCV-21-101449 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 ail 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 all that apply): |stipulation): Mediation session not yet scheduled (_] Mediation session scheduled for (date): [_] Agreed to complete mediation by (date): [] Mediation completed on (date): (4) Mediation Settlement conference not yet scheduled [C7] Settlement conference scheduled for (date): [J Agreed to complete settlement conference by (date): [£7] Settlement conference completed on (date): {2) Settlement conference [7] Neutral evatuation not yet scheduled (] Neutra! evaluation scheduled for (date): [1 Agreed to complete neutral evaluation by (date): {__] Neutral evaluation completed on (date): (3) Neutral evaluation Cy ( } Sudiciat arbitration not yet scheduled (4) Nonbinding judicial co [2] Judicial arbitration scheduled for (date): arbitration [C2] Agreed to complete judicial arbitration by (date): (2 Judicial arbitration completed on (date): [7] Private arbitration not yet scheduled (8) Binding private Co [|] Pate arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): [=] Private arbitration compteted on (date): [77] ADR session not yet scheduled [-_] AOR session scheduled for (date): {["] Agreed to complete ADR session by (date): [CU] ADR compieted on (date): (6) Other (specify): co GM.110 [Rev, September 1, 2021] CASE MANAGEMENT STATEMENT Page dotsCM-110 PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor _| case vumeer DEFENDANT/RESPONDENT: Noe Garcia, et al. BCV 20-102977 and BCV-2}-101449 41. Insurance a. ["_] insurance cartier, if any, for party filing this statement (rame): 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. [7] Bankruptcy [77} Other (specify): Status: 13, Related cases, consolidation, and coordination a. [-X]} There are companion, underlying, or related cases. (1) Name of case: Sertic v. Garcia, et al, (2) Name of court: Kern County Superior Court (3) Case numberBCV-19-103330 (4) Status: consolidated with BCV-20-102977 ["] Additional cases are described in Attachment 13a. b. [__] A motion to [J consolidate [ZZ] 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 reasans): 15. Other mations The party or parties expect to file the folowing motions before trial (specify moving party, type of motion, and issues): Motions in Limine 16. Discovery a. [__] The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery). Party Description Date Plaintiffs Deposition of Defendant January, 2023 Plaintiffs Depositions of several PMKS January, 2023 Plaintiffs Further written Discovery January, 2023 Plaintiffs Expert Discovery per code Plaintiffs Supplemental Discovery per code c. [_]} The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): Cx-tO Raw Septeribar + 2021) CASE MANAGEMENT STATEMENT Page sot 5cM-110 PLAINTIFF/PETITIONER: Levi Cole Moss, a minor , and Aiden Lee Moss, a Minor ‘CASE NUMBER: DEFENDANT/RESPONDENT: Noe Garcia, et al BCV 20-102977 and BCV-21-101449 17. Economic litigation a. [77] 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 [£7] 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 conferted with all pariies 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): tam completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as weil 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: F8f12 J29. a a fh om rowan ee NON > nt (FYPE OR PRINT NAME} (SIGNATURE OF PARTY OR ATTORNEY) [J Additional! signatures are attached. NED E. DUNPHY. > (TYPE OR PRINT NAME) Page Sot CMO Rew Sertenber 1 20741 CASE MANAGEMENT STATEMENTine Law Uttices Uf Young Wooldridge, LLP A LIMITED LIABILITY PARTNERSHIP COMPOSED OF PROFESSIONAL CORPORATIONS Westchester Corporate Plaza ¢ £800 30" Street, Fourth Floor ® Bakersfield, CA 93301-5298 ¢ Telephone 661-327-9661 ¢ Facsimile 661-327-1087 hetp://www.youngwooldridge.com eS Oe I Dm RB Be NY yoN YY YP PN NR RP oe _ S2 32 FF we G8 8 SF Fe RRR GE EF Ss PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF KERN 1, YESENIA LAMBARENA, declare: I am and was at the times of the service hereunder mentioned, over the age of eighteen (18) years, and not a party to the within cause. My business address is The Westchester Corporate Plaza, 1800 30th Street, Fourth Floor, Bakersfield, CA 93301. On October 12, 2022, I caused to be served the below listed document(s) titled as: CASE MANAGEMENT STATEMENT on the interested parties in this action, as listed below: See Attached Service List (BY MAIL), pursuant to C.C.P. § 1013(a). By placing /__/ the original or /x/ a true copy thereof enclosed in a sealed envelope. I am readily familiar with the firm's practice of collection and processing of documents for mailing. Under that practice it would be deposited with United States Postal Service on that same day with postage thereon fully prepaid at Bakersfield, California in the ordinary course of business. (BY FACSIMILE TRANSMISSION), pursuant to Rule § 2.306 of the California Rules of Court. The telephone number of the sending facsimile machine was (661) 327-1087. A transmission report was properly issued by the sending facsimile machine, and the transmission was reported as complete and without error. (BY PERSONAL SERVICE), pursuant to C.C.P. § 1011, | caused such envelope to be delivered by hand to the offices of the addressee(s), x ONLY BY EMAIL TRANSMISSION: Pursuant to Emergency Rule 12 of the California Code of Civil Procedure, which was adopted by the Judicial Counsel in response to the COVID-19 pandemic, this document is being served by electronic transmission only. Executed on October 12, 2022, at Bakersfield, California. Xx (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. (FEDERAL) I declare that | am employed in the office of a member of the bar of this Court at whose direction the service was made. f ( l. Lthin., tamper“ Yesenia Lambarena =~4220 Von Karman Avenue, Suite 200 Attorneys for Plaintiff ERIC SERTIC 18 Related Case No. BCV-19-103330 ashkalin@sweetjames.com emilyci@sweetjames.com & 4 1 SERVICE LIST ? 2 : 3|| Brooklyn Deann Moss V. Noe Garcia, et al. 2 4 Case No. BCV-19-103330 CW/ BCV-20-102977 and BCV-21-101449 = £ 5 Justin Lowtrip, Esq. . 11150 W. Olympic Blvd., Suite 1050 5 6 Los Angeles, CA 90064 = T: (424) 273-1462 8 7 Jlowirip@lowtriplaw.com = 8 edent@lowtriplaw.cont = Attorneys for Defendants/Cross-Defendants oe 9 LAURA GUIDO and NOE GARCIA AND D&L TRUCKING DOE I As £3 10 Thomas W. Shaver, Esq. nd an i SHAVER, KORFF & CASTRONOVO LLP ot 16255 Ventura Boulevard, Suite 850 ob? fon Encino, CA 91436 3 3 2 B Attomey for Defendant ERIC SERTIC SB BoM 2 = 23 Ashkhan Mohamadi, Esq. Aes 1 SWEET JAMES, LLP = : = 20 piperi@sweetjames.com 5 kiannaw@sweetjames.com = 21 g a 2 & 3 23 § 24 2 25 2 26 g g 27 g 28