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SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Mar-14-2014 12:31 pm
Case Number: CGC-13-528383
Filing Date: Mar-14-2014 12:30
Filed by: RONNIE OTERO
Juke Box: 001 Image: 04412173
CASE MANAGEMENT STATEMENT
NINA ZHIGADLO VS. MERIDIAN MANAGEMENT GROUP et al
001004412173
Instructions:
Please place this sheet on top of the document to be scanned.©
CM-110
Eric L. Lifschitz, State Bar No. 215252 Aaron H. Darsky, State Bar No. 2
Law Offices of Eric L. Lifschitz . 16 MAR Ih Py
345 Franklin Street, San Francisco, CA 94102
TELEPHONE NO: 415-553-6055 FAXINO. (Optional: fs. BERRAIE
toe en PILED
ay
‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Bar number, and address): mn AEE ISto eh 175 ” FOR COURT USE ONLY
E-MAIL ADDRESS (Optiona): info @ franklinstreetlaw.com. THE Cou
ATTORNEY FOR (Name): Plaintiffs Nina Zhigadlo, Aurora King, Justin Allen, € o
SUPERIOR COURT OF CALIFORNIA, COUNTY OF
street aopress: 400 McAllister Street
MAILING ADDRESS:
ciry ano zip cove: San Francisco CA, 94102
BRANCH NAME: Civil-Unlimited Jurisdiction
PLAINTIFF/PETITIONER: Nina Zhigadio, et al.
DEFENDANT/RESPONDENT: Meridian Management Group, et al.
Address of court (if different from the address above):
Notice of intent to Appear by Telephone, by (name):
CASE MANAGEMENT STATEMENT (CASE NUMBER:
(Check one): UNLIMITED CASE CJ ute case CGC-13-528383
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: April 9, 2014 Time: 10:30 am Dept.: 610 Div.: Room:
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. LY] This statement is submitted by party (name): Nina Zhigadlo, Aurora King, Justin Allen, et al.
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): January 30, 2013
b. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. L¥] 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) have not been served (specify names and explain why not):
(2) [21 have been served but have not appeared and have not been dismissed (specify names):
(3) have had a default entered against them (specify names):
c. [-] The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type ofcase in [¥] complaint cross-complaint (Describe, including causes of action):
See Attachment 4
Page 10f5
Form Api or Mandan Use CASE MANAGEMENT STATEMENT Cal Rules of Cour,
GMTTO Ron sy 2oTT
‘www.courts.ca.gov©
38
CM-110
PLAINTIFF/PETITIONER: Nina Zhigadio, et al.
DEFENDANT/RESPONDENT: Meridian Management Group, et al.
‘CASE NUMBER:
CGC-13-528383
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.)
Injuries to person and property and constructive eviction due to bedbug infestation, in violation of San Francisco
rent ordinance. Injuries to plaintiffs include loss of possessory interest in a rent controlled unit and personal injury
including, but not limited to, skin lesions, sleeplessness, fatigue, humiliation, discomfort, and annoyance, all to
their general damage.
5, Jury or nonjury trial
The party or parties request L¥_] ajury trial (_] a nonjury trial.
requesting a jury trial):
6. Trial date
a. The trial has been set for (date):
(if more space is needed, check this box and attach a page designated as Attachment 4b.)
(if more than one party, provide the name of each party
b. LJ 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):
Within 18 Months of the date of filing of the complaint.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
See Attachment 6
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [#1] days (specify number): 7-14 Days
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial Lv | by the attorney or party listed in the caption
a. Attorney:
Firm:
Address:
Telephone number:
E-mail address:
[1 Additional representation is described in Attachment 8.
9. Preference
This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
gpaos
by the following:
f. Fax number:
g. Party represented:
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel LY | has
has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party has
has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under
statutory limit.
le of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
(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) Lv] 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):
Exceeds jurisdictional limits.
‘OM-110 [Rev. July 1, 2011]
CASE MANAGEMENT STATEMENT Page 2 otsoO
38
CM-110
L PLAINTIFF/PETITIONER: Nina Zhigadlo, et al.
PEFENDANT/RESPONDENT: Meridian Management Group, et al.
[CASE NUMBER:
CGC-13-528383
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):
The party or parties completing
this form are willing to
participate in the following ADR
processes (check ail that apply):
(1) Mediation
(2) Settlement
conference
(3) Neutral evaluation
(4) Nonbinding judicial
arbitration
(5) Binding private
arbitration
(6) Other (specify):
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):
Mediation session not yet scheduled
Mediation session scheduled for (date):
Agreed to complete mediation by (date):
Mediation completed on (date):
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):
ADR session not yet scheduled
ADR session scheduled for (date):
Agreed to complete ADR session by (date):
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ADR completed on (date):
(CM-110 (Rev. July 1, 2011]
CASE MANAGEMENT STATEMENT
Page 3 of 5© 38
PLAINTIFFIPETITIONER: Nina Zhigadio, et al. ‘CASE NUMBER:
a CGC-13-528383
DEFENDANT/RESPONDENT: Meridian Management Group, et al.
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. [Ly] There are companion, underlying, or related cases.
(1) Name of case: Geyer v. Meridian Management Group
(2) Name of court: San Francisco Superior Court
(3) Case number: CGC-12-527520
(4) Status: Active
(71 Additional cases are described in Attachment 13a.
b. L¥_J Amotion to ¥'| consolidate coordinate will be filed by (name party):
See Attachment 13
14. Bifurcation
The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
¥ | The party or parties expect to file the following 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. L¥_] The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiff Written Discovery 3 Months after CMC
Depositions of Defendants December 2013
Non-Expert Depositions Per Code
c. [4] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Plaintiffs anticipated working out a discovery stipulation to prevent duplicative deposition and document
production.
ON-110 (Rov. dy 1, 2011] CASE MANAGEMENT STATEMENT Page 4or5oO °o
CM-110
PLAINTIFF/PETITIONER: Nina Zhigadlio, et al. CASE NUMBER:
—~ aay CGC-13-528383
DEFENDANT/RESPONDENT: _ Meridian Management Group, et al.
17. Economic litigation
a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
(5 The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a. L¥_] The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules
of Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any): 3
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: March 14, 2014
Conor Granahan, Esq. >
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY AR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
COMETTO Rev. Joy 1, 20FT) CASE MANAGEMENT STATEMENT Pages of© °
MC-025
| SHORT TITLE: ‘CASE NUMBER:
| | Nina Zhigadlo v. Meridian Management Group, et al. CGC-13-528383
ATTACHMENT (Number): 4
(This Attachment may be used with any Judicial Council form.)
ATTACHMENT 4 Description of Case in CASE MANAGEMENT CONFERENCE STATEMENT
1. Breach of Contract
2. Negligent Violation of Statutory Duty/Negligence Per Se
3. Harassment - Violation of San Francisco Administrative Code § 37.10 B
4. Wrongful Eviction - Violation of San Francisco Administrative Code § 37.9
5. Breach of the Implied Warranty of Habitability
6. Breach of the Statutory Warranty of Habitability
7. Constructive Eviction
8. Negligence/Personal Injury
9. Nuisance
10. Breach of the Covenant of Quiet Enjoyment
11. Collection of Rent for Untenantable Dwelling,
Civil Code §§ 1941 and 1942.4
12. Intentional Infliction of Emotional Distress
(if the item that this Attachment concems is made under penalty of perjury, all statements in this Page 6 of 8
Attach jury.,
tachment are made under penalty of perjury.) (Add pages as required)
Form Approved fo Optional Use ATTACHMENT som coutintocagoy
‘MC-026 (Rev. July 4, 2008) to Judicial Council Form© °
MC-025
SHORT TITLE:
| Lorena Plaza v. Meridian Management Group, et al.
CASE NUMBER:
CGC-13-529614
ATTACHMENT (Number): 6
(This Attachment may be used with any Judicial Council form.)
6 (c) Dates on which parties or attorneys will not be available for trial:
1)Date:April 7, 2014
Case: Gary Streng v. Keynote Properties, Inc., et al.
Duration: 7-14 days
2)Date: April 28, 2014
Case: Neil Hayes and Holly Hayes v. Lisa Pham, et al.
Duration: 7-14 days
3)Date: June 16, 2014
Case: Carolina Flores-Crowe v. Chandler Properties, et al., et al.
Duration: 7-14 days
4)Date:September 15, 2014
Case:Gabriela Geyer and Travis Geyer v. Meridian Management Group, et al.
Duration: 5 days
5)Date:September 22, 2014
Case:Finauga v. Remy' Construction, et al.
Duration: 7 days
6)Date:October 14, 2014
Case: Mario Palomo v. Meridian Management Group, et al.
Duration: 5 days
7)Date:October 20, 2014
Case: Fabian Oliva v. Meridian Management Group, et al.
Duration: 5 days
8)Date:October 27, 2014
Case: Latasha Poindexter, et al. v. Meridian Management Group, et al.
Duration: 5 days
(If the item that this Attachment concerns is made under penalty of perjury, all statements in this
Attachment are made under penalty of perjury.)
Page 7 of 8
(Add pages as required)
"EAS Caan” ATTACHMENT
'MC-025 [Rev. July 1, 2008} to Judicial Council Form
www courtnfo.ca.gov© Qo
MC-025
SHORT TITLE: ‘CASE NUMBER:
| Nina Zhigadlo v. Meridian Management Group, et al. CGC-13-528383
ATTACHMENT (Number): 13
(This Attachment may be used with any Judicial Council form.)
13 (a):
Name of Case: Plaza v. Meridian Management Group, et al.
Name of Court: San Francisco County Superior Court
Case Number: CGC-13-529614
Status: Active
| Name of Case: Poindexterv. Meridian Management Group, et al.
Name of Court: San Francisco County Superior Court
Case Number: CGC-13-529613
Status: Active
Name of Case: Oliva v. Meridian Management Group, et al.
Name of Court: San Francisco County Superior Court
Case Number: CGC-13-532145
Status: Active
Name of Case: Palomo v. Meridian Management Group, et al.
Name of Court: San Francisco County Superior Court
Case Number: CGC-13-532143
Status: Active
13 (b):
Defendant Meridian Management Group. Defendants filed motion to consolidate in wrong department.
Plaintiff expects them to re-file.
(if the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 8 of 8
Attachment are made under penaity of perjury.) (Ada 8 as required)
Form Approved for Optional Use ATTACHMENT ww. courtingo.ca.gov
Judicial Counel of California at ;
'MC-026 [Rev. July 1, 2009} to Judicial Council FormNina Zhigadlo et al. v. Meridign Management Group et al.
Case No.: CGC-13-528383 ©
1 PROOF OF SERVICE
2 The undersigned certifies and declares the following: I am over the age of 18 years and am
not a party to this action; that my business address is 345 Franklin Street, San Francisco, CA
3 94102. On the date below, I served the following documents:
4
CASE MANAGEMENT STATEMENT (CM-110)
5 on the interested parties in this action by placing a true and correct copy thereof in (a) sealed
6 envelope(s) addressed to:
7
John H. Podesta, Esq. Gregory De La Pena, Esq.
8 Dana L. Tom, Esq. Malcolm E. McLorg, Esq.
i Murchison & Cumming, LLP De La Pena & Holiday, LLP
! 9 Embarcadero Center West One Embarcadero Center, Suite 2860
| 10 275 Battery Street, Suite 550 San Francisco, CA 94111
| San Francisco, CA 94111
i 11
| 12 Ramsey Fakhry Kawar, Esq.
| Kurt Bridgeman, Esq.
| 13 Low Ball & Lynch
} 505 Montgomery Street, 7 Floor
4 San Francisco, CA 94111
i
i 15 XX MAIL: I caused such envelope to be deposited in the mail, with postage thereon
' 16 fully prepaid, addressed to the addressee(s) designated.
17 HAND DELIVERY: | caused such document to be served via hand delivery. If
upon an attorney, service may be made at the attorney’s office, by leaving the
18 notice or other papers in an envelope clearly labeled to identify the attorney being
served, with a receptionist. When there is not person in the office, service may be
19 made by leaving them between the hours of 9:00 am and 5:00 pm, in a conspicuous
20 place in the office. (CCP section 1011(a))
: 21
} I swear under penalty of perjury of the laws of the State of California that the foregoing is
22 || true and correct.
23 Dated: March 14, 2014
(Ce Manager / Paralegal
PROOF OF SERVICE
Preview
a SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Mar-14-2014 12:31 pm Case Number: CGC-13-528383 Filing Date: Mar-14-2014 12:30 Filed by: RONNIE OTERO Juke Box: 001 Image: 04412173 CASE MANAGEMENT STATEMENT NINA ZHIGADLO VS. MERIDIAN MANAGEMENT GROUP et al 001004412173 Instructions: Please place this sheet on top of the document to be scanned.© CM-110 Eric L. Lifschitz, State Bar No. 215252 Aaron H. Darsky, State Bar No. 2 Law Offices of Eric L. Lifschitz . 16 MAR Ih Py 345 Franklin Street, San Francisco, CA 94102 TELEPHONE NO: 415-553-6055 FAXINO. (Optional: fs. BERRAIE toe en PILED ay ‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Bar number, and address): mn AEE ISto eh 175 ” FOR COURT USE ONLY E-MAIL ADDRESS (Optiona): info @ franklinstreetlaw.com. THE Cou ATTORNEY FOR (Name): Plaintiffs Nina Zhigadlo, Aurora King, Justin Allen, € o SUPERIOR COURT OF CALIFORNIA, COUNTY OF street aopress: 400 McAllister Street MAILING ADDRESS: ciry ano zip cove: San Francisco CA, 94102 BRANCH NAME: Civil-Unlimited Jurisdiction PLAINTIFF/PETITIONER: Nina Zhigadio, et al. DEFENDANT/RESPONDENT: Meridian Management Group, et al. Address of court (if different from the address above): Notice of intent to Appear by Telephone, by (name): CASE MANAGEMENT STATEMENT (CASE NUMBER: (Check one): UNLIMITED CASE CJ ute case CGC-13-528383 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: April 9, 2014 Time: 10:30 am Dept.: 610 Div.: Room: INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. LY] This statement is submitted by party (name): Nina Zhigadlo, Aurora King, Justin Allen, et al. b. This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): January 30, 2013 b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. L¥] 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) have not been served (specify names and explain why not): (2) [21 have been served but have not appeared and have not been dismissed (specify names): (3) have had a default entered against them (specify names): c. [-] The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type ofcase in [¥] complaint cross-complaint (Describe, including causes of action): See Attachment 4 Page 10f5 Form Api or Mandan Use CASE MANAGEMENT STATEMENT Cal Rules of Cour, GMTTO Ron sy 2oTT ‘www.courts.ca.gov© 38 CM-110 PLAINTIFF/PETITIONER: Nina Zhigadio, et al. DEFENDANT/RESPONDENT: Meridian Management Group, et al. ‘CASE NUMBER: CGC-13-528383 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.) Injuries to person and property and constructive eviction due to bedbug infestation, in violation of San Francisco rent ordinance. Injuries to plaintiffs include loss of possessory interest in a rent controlled unit and personal injury including, but not limited to, skin lesions, sleeplessness, fatigue, humiliation, discomfort, and annoyance, all to their general damage. 5, Jury or nonjury trial The party or parties request L¥_] ajury trial (_] a nonjury trial. requesting a jury trial): 6. Trial date a. The trial has been set for (date): (if more space is needed, check this box and attach a page designated as Attachment 4b.) (if more than one party, provide the name of each party b. LJ 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): Within 18 Months of the date of filing of the complaint. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): See Attachment 6 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [#1] days (specify number): 7-14 Days b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial Lv | by the attorney or party listed in the caption a. Attorney: Firm: Address: Telephone number: E-mail address: [1 Additional representation is described in Attachment 8. 9. Preference This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) gpaos by the following: f. Fax number: g. Party represented: a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel LY | has has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under statutory limit. le of Civil Procedure section 1775.3 because the amount in controversy does not exceed the (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) Lv] 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): Exceeds jurisdictional limits. ‘OM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 otsoO 38 CM-110 L PLAINTIFF/PETITIONER: Nina Zhigadlo, et al. PEFENDANT/RESPONDENT: Meridian Management Group, et al. [CASE NUMBER: CGC-13-528383 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): The party or parties completing this form are willing to participate in the following ADR processes (check ail that apply): (1) Mediation (2) Settlement conference (3) Neutral evaluation (4) Nonbinding judicial arbitration (5) Binding private arbitration (6) Other (specify): 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): Mediation session not yet scheduled Mediation session scheduled for (date): Agreed to complete mediation by (date): Mediation completed on (date): 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): ADR session not yet scheduled ADR session scheduled for (date): Agreed to complete ADR session by (date): m4 co Co co Cl Co Co Oo oO Co CI Co Co co CI oo Co oO oO oO Co oO Co oO ADR completed on (date): (CM-110 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5© 38 PLAINTIFFIPETITIONER: Nina Zhigadio, et al. ‘CASE NUMBER: a CGC-13-528383 DEFENDANT/RESPONDENT: Meridian Management Group, et al. 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. [Ly] There are companion, underlying, or related cases. (1) Name of case: Geyer v. Meridian Management Group (2) Name of court: San Francisco Superior Court (3) Case number: CGC-12-527520 (4) Status: Active (71 Additional cases are described in Attachment 13a. b. L¥_J Amotion to ¥'| consolidate coordinate will be filed by (name party): See Attachment 13 14. Bifurcation The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions ¥ | The party or parties expect to file the following 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. L¥_] The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Plaintiff Written Discovery 3 Months after CMC Depositions of Defendants December 2013 Non-Expert Depositions Per Code c. [4] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): Plaintiffs anticipated working out a discovery stipulation to prevent duplicative deposition and document production. ON-110 (Rov. dy 1, 2011] CASE MANAGEMENT STATEMENT Page 4or5oO °o CM-110 PLAINTIFF/PETITIONER: Nina Zhigadlio, et al. CASE NUMBER: —~ aay CGC-13-528383 DEFENDANT/RESPONDENT: _ Meridian Management Group, et al. 17. Economic litigation a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues (5 The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. L¥_] The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 3 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: March 14, 2014 Conor Granahan, Esq. > (TYPE OR PRINT NAME) (SIGNATURE OF PARTY AR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. COMETTO Rev. Joy 1, 20FT) CASE MANAGEMENT STATEMENT Pages of© ° MC-025 | SHORT TITLE: ‘CASE NUMBER: | | Nina Zhigadlo v. Meridian Management Group, et al. CGC-13-528383 ATTACHMENT (Number): 4 (This Attachment may be used with any Judicial Council form.) ATTACHMENT 4 Description of Case in CASE MANAGEMENT CONFERENCE STATEMENT 1. Breach of Contract 2. Negligent Violation of Statutory Duty/Negligence Per Se 3. Harassment - Violation of San Francisco Administrative Code § 37.10 B 4. Wrongful Eviction - Violation of San Francisco Administrative Code § 37.9 5. Breach of the Implied Warranty of Habitability 6. Breach of the Statutory Warranty of Habitability 7. Constructive Eviction 8. Negligence/Personal Injury 9. Nuisance 10. Breach of the Covenant of Quiet Enjoyment 11. Collection of Rent for Untenantable Dwelling, Civil Code §§ 1941 and 1942.4 12. Intentional Infliction of Emotional Distress (if the item that this Attachment concems is made under penalty of perjury, all statements in this Page 6 of 8 Attach jury., tachment are made under penalty of perjury.) (Add pages as required) Form Approved fo Optional Use ATTACHMENT som coutintocagoy ‘MC-026 (Rev. July 4, 2008) to Judicial Council Form© ° MC-025 SHORT TITLE: | Lorena Plaza v. Meridian Management Group, et al. CASE NUMBER: CGC-13-529614 ATTACHMENT (Number): 6 (This Attachment may be used with any Judicial Council form.) 6 (c) Dates on which parties or attorneys will not be available for trial: 1)Date:April 7, 2014 Case: Gary Streng v. Keynote Properties, Inc., et al. Duration: 7-14 days 2)Date: April 28, 2014 Case: Neil Hayes and Holly Hayes v. Lisa Pham, et al. Duration: 7-14 days 3)Date: June 16, 2014 Case: Carolina Flores-Crowe v. Chandler Properties, et al., et al. Duration: 7-14 days 4)Date:September 15, 2014 Case:Gabriela Geyer and Travis Geyer v. Meridian Management Group, et al. Duration: 5 days 5)Date:September 22, 2014 Case:Finauga v. Remy' Construction, et al. Duration: 7 days 6)Date:October 14, 2014 Case: Mario Palomo v. Meridian Management Group, et al. Duration: 5 days 7)Date:October 20, 2014 Case: Fabian Oliva v. Meridian Management Group, et al. Duration: 5 days 8)Date:October 27, 2014 Case: Latasha Poindexter, et al. v. Meridian Management Group, et al. Duration: 5 days (If the item that this Attachment concerns is made under penalty of perjury, all statements in this Attachment are made under penalty of perjury.) Page 7 of 8 (Add pages as required) "EAS Caan” ATTACHMENT 'MC-025 [Rev. July 1, 2008} to Judicial Council Form www courtnfo.ca.gov© Qo MC-025 SHORT TITLE: ‘CASE NUMBER: | Nina Zhigadlo v. Meridian Management Group, et al. CGC-13-528383 ATTACHMENT (Number): 13 (This Attachment may be used with any Judicial Council form.) 13 (a): Name of Case: Plaza v. Meridian Management Group, et al. Name of Court: San Francisco County Superior Court Case Number: CGC-13-529614 Status: Active | Name of Case: Poindexterv. Meridian Management Group, et al. Name of Court: San Francisco County Superior Court Case Number: CGC-13-529613 Status: Active Name of Case: Oliva v. Meridian Management Group, et al. Name of Court: San Francisco County Superior Court Case Number: CGC-13-532145 Status: Active Name of Case: Palomo v. Meridian Management Group, et al. Name of Court: San Francisco County Superior Court Case Number: CGC-13-532143 Status: Active 13 (b): Defendant Meridian Management Group. Defendants filed motion to consolidate in wrong department. Plaintiff expects them to re-file. (if the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 8 of 8 Attachment are made under penaity of perjury.) (Ada 8 as required) Form Approved for Optional Use ATTACHMENT ww. courtingo.ca.gov Judicial Counel of California at ; 'MC-026 [Rev. July 1, 2009} to Judicial Council FormNina Zhigadlo et al. v. Meridign Management Group et al. Case No.: CGC-13-528383 © 1 PROOF OF SERVICE 2 The undersigned certifies and declares the following: I am over the age of 18 years and am not a party to this action; that my business address is 345 Franklin Street, San Francisco, CA 3 94102. On the date below, I served the following documents: 4 CASE MANAGEMENT STATEMENT (CM-110) 5 on the interested parties in this action by placing a true and correct copy thereof in (a) sealed 6 envelope(s) addressed to: 7 John H. Podesta, Esq. Gregory De La Pena, Esq. 8 Dana L. Tom, Esq. Malcolm E. McLorg, Esq. i Murchison & Cumming, LLP De La Pena & Holiday, LLP ! 9 Embarcadero Center West One Embarcadero Center, Suite 2860 | 10 275 Battery Street, Suite 550 San Francisco, CA 94111 | San Francisco, CA 94111 i 11 | 12 Ramsey Fakhry Kawar, Esq. | Kurt Bridgeman, Esq. | 13 Low Ball & Lynch } 505 Montgomery Street, 7 Floor 4 San Francisco, CA 94111 i i 15 XX MAIL: I caused such envelope to be deposited in the mail, with postage thereon ' 16 fully prepaid, addressed to the addressee(s) designated. 17 HAND DELIVERY: | caused such document to be served via hand delivery. If upon an attorney, service may be made at the attorney’s office, by leaving the 18 notice or other papers in an envelope clearly labeled to identify the attorney being served, with a receptionist. When there is not person in the office, service may be 19 made by leaving them between the hours of 9:00 am and 5:00 pm, in a conspicuous 20 place in the office. (CCP section 1011(a)) : 21 } I swear under penalty of perjury of the laws of the State of California that the foregoing is 22 || true and correct. 23 Dated: March 14, 2014 (Ce Manager / Paralegal PROOF OF SERVICE