Preview
Late Filed
CM-110
asls Bsr number nmf ed»sssi:
ATTDRNEY QR PARlv wlTHDU7 ATTCRNEY grume, FOR COURT USE ONLY
MICHAEL R. LOEWEN 105197
LAW OFFICES OF MICHAEL R, LOEWEN
P. O. Box 417078
Sacramento, CA 95841
TELEPHONENOJ (916) 344 2300 (916)
FFXNOfonffrnsrp 344 —
1499 10/5/2022
MRLISMRLLAW . COM
S.MAS. AOORLSS lepers»31
TOnya
ATfoRNEY FOR,INemejr LOng
EUPERioR coURT oF cALIFCRNIA, coUNTY oF But te
slREET ADoilEss 1 Court 8tree t
MAILING ADDRESS:
cfTYAeozfpcoDE Orovi lie, CA 95965
BRANCH NAME:
PLAINTIFF/PETITIQNER: Tonya Long
OEFENOANTYRESPONOENT: Anderson Merchandising LLP,
Alicia Largent
CASE MANAGENIENT STATEMENT CASE NUMBER:
~
(Check one)r gg UNLIMITED CASE Cl LIMITED CASE 21CV02098
(Amount demanded (Amount demanded is $25,000
exceeds $ 25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: October 19, 2022 Time: 1D 130 s.m Dept.: 1 Div J Room:
Address of court (if different from the address above):
L Qg Notice of Intent to Appear by Telephone, by(name)7
INSTRUCTIONS: All applicable
Michael R. Loewen
boxes must be checked, and the specified information must be provided.
1 Party or parties (answer one):
a. IXI This statement is submitted by party (name)f Tonya Long
b. ~ This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (Io be answered by plelnliffs and cross-complainanls only)
a. Thecomplalntwasfiledon(date)f 08/17/2021
b. C3 The cross-complaint,Ifany,was fikfd on (dais):
3. Service (io be answered by plain¹ and cfosscompfainanls only)
a. Afi paNes named in ths complaint and cromucomplaint have been served, have appeared, or have been dismissed.
b. ~
QQ
The following parties named in the complaint or cross-complaint
(1) ~ have not been served (spsfyfy names end explain why nol)f
(2) ~ have been served but have not appeared and have not been dismissed (specify names):
(3) ~ have had a default entered against them (specffy names):
c. ~ The following addiTional parties may be added (specify names, nature of involvement in case, snd rhe date by which
lhey may be served)I
4. Description of case
a. Type of case in gg complaint ~ cross-complaint (Describe, inPJuding causes of action):
Page1o15
forMsndsmryUne, CASE MANAGE)g)ENT STATEMENT
~~'BSelrlial
Form Adopfed Cel. Rules of Courl,
Judioiel counns
ofcslpUrnfe 8 MIN rules 3.725-3.733
CM.110 gunr.July1,2D11] HFOITES eee,no»nt.ns.gov
Long, Tonya
CM-110
pLAINTIFF/PETITIONER: Tonya Long CASE NUMBER;
2 1CV02 0 98
DEFENDANT/RESPONDENT: Anderson Merchandising LLP,
Alicia Largent
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 Io dale jindicaie source and amounlj, estimated fuiure medical expenses, lost
earnings Io date, and eslimaled future tost earnings. If equitable relief is sought, describe the nature of the relief)
~ (If more space is needed, check this box and allech a page designated as Allachmenl 4b.)
5. Jury or nonjury trial
The party or paNes request
requesling a jury lrial)i
Qaj a jury trial~ a nonjuiy trial. (If more thanone party, provide the name of each party
6. Trial date
a.
b.
~
Qg
The trial has been set for (dale)i
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
riot, explain): pLAINTIFF REQUESTS NEXT AVAILABLE TRIAL DATE
c. Dates on which parties or attorneys not be available for trial (specify dates and explain reasons fcr unavailability):
will
7 Estimated length of trial
The party or parsee estimate that the trial will take (check one):
a. Qg days (specify number): 3 -5 DayS
b. ~ hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial
a. Attorney:
QQ or party listed in the caption
by the attorney ~ by the following:
b. Firm:
c. Address:
d. Telephone number: f. Fax number.
e. E-mail address: g. Party represented:
Cl Additional representation is described in Attachment 8.
9. Preference
~ This case is entilled to preference (specify code seciion):
10. Afternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes ars 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
reviewed
in rule 3.221 to the client and ADR
~
options
has
with
~
the
has not provided the ADR information package identified
client.
(2) For self-represented parties: Party C) has ~ has not reviewed the ADR information package identified in rule 3.221
b. Referral to judicial arbitration or civil action mediation
(if availabis).
(1) ~ This matter is sub)setto mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or lo civil action
mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) ~ Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11,
(3) ~ of the California Rules of Court or from civil action
This case is exempt from judicial arbitration under rule 3.811
mediation under Cods of Civil Procedure section 1775 et seq. (specify exemplion):
CM-1 1 0 IRey. July 1. 201 II CASE MANAGEMENT STATEMENT Page 2 of 2
' Essential
j
%Forms Long, Tonya
CM-110
PLAINTIFF/PETITIONER: Tonya Long CASE NUMBER
21CV02098
DEFENDANT/REspoNDENT:Anderson Iyierchandising LLP,
Alicia Lar=ent
10. c. Indicate the ADR process or processes that the party or parlies are willing to participate In, have agreed to participate in, or
have already participated in (check all that apply and provide the Bpscii'lsd information)r
Ths party or parties completing parly or parfies completing this form in the case have agreed to
)f the
Ithis form are willing to parlicipate in or have already completed an ADR process or processes,
participate in Ihe following ADR indicate the status of the processes (aftach a copy of ihs parties'ADR
processes (check ail that apply): stIpulation):
Qg Mediation session not yet scheduled
(1) Mediation
~ Mediation session scheduled for (date):
~ Agreed to complete mediation by (dafe):
~ Mediation completed on (dais):
Qg Settlemsnt conference not yet scheduled
(2) Settlement ~ Settlement conference scheduled for (date):
conference
~ Agreed to complete settlsmsnt conference by (dais):
~ Settlement conference completed on (date):
C3 Neutral evaluation not yet scheduled
(3) Neutral evaluation
~ Neutral evaluation scheduled for (dafs):
~ Agreed to complete neutral evaluation by (dats):
~ Neutral evaluation completed on (date):
~ Judicial arbitration not yet scheduled
(4) Nonbinding judicial
'
Judicial arbitration scheduled for (date):
arbitration
~ Agreed to complete judicial arbitration by (date)r
~ Judicial arbitration completed on (dats):
~ Private arbitration not yet scheduled
(6) Binding private ~ Private arbitration scheduled for (date):
arbitration
~ Agreed to complete private arbitration by (dsts):
~ Private arbitration completed on (dare):
~ ADR session not yet scheduled
(6) Other (specify): ~ ADR session scheduled for (date):
~ Agreed to complete ADR session by (dare):
~ ADR completed on (date):
CM-110 IRev. July
1,2011i CASE MANAGEMENT STATEMENT Pese 5 ef 5
cia'sssnUal
jul Forms.
Long, Tonya
CM.110
PLAINTIFF/PETITloNER: Tonya Long CASE NUMSWE
21CV02098
DEFENOANTJRESPONOENT: AnderSOn ivierChandiSing LLP,
Alicia Largent
11. Insurance
a.
b.
~ Insurance carrier, if any, for party filing this statement (nsme):
Reservation of rights: ~ Yes D No
c. ~ Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any mattem that may affect the court's jurisdiction or processing of this case, and describe the slatus.
~ Bankruptcy
Status:
~ Other (specify)r
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:
C3 Additional cases are described in Attachment 13a.
b. Cl A motion to ~ consofidate ~ coordinate willbe filed by (name Party).
14. Bifurcation
~ The party or parties Intend to file a motion for an order bifurcating, severing, or coordinating the fallowing issues or causes af
action (specify moving party, type of motion, snd reasons):
15. Other motions
Qg The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues)i
Notions in Limine.
16. Discovery
a.
b.
~
Q3
Ths party or parties have completed afi discovery.
The following discovery will be completed by the date specmsd (describe ail snlici paled dfscoveiy):
~P Descriction Date
Plaintiff Discovery 05/2023
Plaintiff Depositions 05/2023
c. ~ The following discovery issues, including issues regarding ths discovery of electronically stored information, are
anticipated (specify):
cM-115 Inev. July 1, 5011I CASE MANAGEMENT STATEMENT peeeeef5
('+' Essential
)B Fonna
l Long, Tonya
CM-110
PLAINTIFF/PETITIQNER: Torlya Long CASE NUMBER:
2 1 CV0 2 0 9 8
DEFENDANT/RESPONDENT: Anderson Nercjlandising LLP,
Alicia Laroent
17, Economic litigation
a. C) civil case (i.e., ths amount demanded is $ 25,000 or less) snd the economic litigation procedures in Code
This is a limited
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 flied (if checked, explain specifically why economic iifigaiion procedures reiaiing lo discovery or irial
should not apply to this case):
18. Other Issues
~ The party or parties request that the following additional matters be considered or determined at ths case management
conference (specify):
19. Meet and confer
a. ~ The party or parties have met and conferred with all parties on sll subjects required by rule 3.724 of the California Rules of
Court (if nof, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the pariies agree on ths following
(specify):
20. Total number of pages attached (if sny)T
I sm completely familiar with this case and will be fully prepared to discuss the status of discovery snd alternative dispute resolution,
as well as other issues raised by this statement. End 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 d
Date: October 5, 2022
hneo1
IYII ( a T,noewnyy
RYPE OR PRINT NAME)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
~ Additional Signatures are attached.
CASE MANAGEMENT STATEMENT
~
CM-110 IRev. July I, 2011] Peoe 6 of 2
('&JJ;IEssential
fdpofms
I
Long, Tonya
PROOF OF SERVICE — CCP tt 1013, 1013a, 2015.5
1 and California Rules of Court, Rule 2.306
Long v. Anderson Merchandising LLP, et al.
Butte County Superior Case Ato.t 21CV02098
I, Alexis Porterfield, declare that:
I am a citizen of the United States and am over the age of eighteen years and not a
party to the within above-entitled action. I am an employee of THE LAW OFFICE OF
MICHAEL R. LOEWEN and my business address is 4811 Chippendale Drive, Suite 203,
Sacramento, CA 95841-7078.
On October 5, 2022, I served the within document:
CASE MANAGEMENT STATEMENT
9
On the parties in said action addressed as follows:
10
Michael W. Carruth Attorneys for Anderson
11 KLINEDINST PC Merchandising LLP, Alicia Largent
801 K Street, Suite 2100
12 Sacramento, CA 95814
Telephone: 916-282-0100
13 Facsimile: 916-444-7544
mcarruthCukhnedinstlaw. corn
14 GOsbome(r7k linedinstlaw.corn
15
BY ELECTRONIC TRANSMISSION: On October 5, 2022, at a.m./p.m. by
16 use of electronic service, My electronic service address is
mrlreception@michaelloewen.corn. I electronically served a true copy of the
17 aforementioned document(s) on the parties in said action by transmitting by electronic
service to the electronic service address as set forth above and/or attached service list.
18 The electronic machine I used complied with California Rules of Court, Rule 2.251
and no error was reported by the machine. Pursuant to California Rules of Court, Rule
2.256, I caused the machine to print a transmission record of the transmission, a copy
19
of which is attached to this Declaration.
20
BY MAIL: I am familiar with my employer's practice for the collection and
21 processing of correspondence for mailing with the United States Postal Service and
that each day's mail is deposited with the United States Postal Service that same day
22 in the ordinary course of business. On the date set forth above, I served the
aforementioned document(s) on the parties in said action by placing a true and correct
copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, for
23 ordinary business
collection and mailing on this date, following practices, at
24 Sacramento, CA, addressed as set forth above.
I declare under penalty of perjury under the laws of the State of California that the
25 and that this declaration was executed on October 2022, at
foregoing is true and correct, 5,
26 Sacramento, CA.
27 AlexisWorterfield
28