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SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Mar-20-2014 2:37 pm
Case Number: CGC-13-534478
Filing Date: Mar-20-2014 2:37
Filed by: RONNIE OTERO
Juke Box: 001 Image: 04418910
CASE MANAGEMENT STATEMENT
FUAD, SAMI, BY AND THROUGH HIS GUARDIAN AD LITEM, et al VS. CRAIG
ALAN CARDON| et al
001004418910
Instructions:
Please place this sheet on top of the document to be scanned.: . e CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stele Bar number, and address): i
DENNIS J. WARD (SBN 78493)
ROPERS, MAJESKI, KOHN & BENTLEY
50 W. San Fernando Street, Ste. 1400
San Jose, CA 95113
TELEPHONE NO.: (408) 287-6262 - _ FAK NO. (Optonay: (408) 918-4501
E-MAIL ADDRESS (Optlonay: dward@rmkb.com
ATTORNEY FOR (Name): Defendants and Cross-Complainants CENTRAL CONCRETE
SUPPLY CO., INC.; U.S. CONCRETE, INC.; and BODE CENTRAL LLC.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
streeT aopress: 400 McAllister Street
cry ano zp cove: San Francisco, CA 94102-4514
PLAINTIFF/PETITIONER: SAMU FAUD, by and through his guardian ad litem,
AHMED FUAD; AHMED FAUD
DEFENDANT/RESPONDENT: CRAIG ALAN CARDONI, et al
CASE MANAGEMENT STATEMENT
(Check one): , &) UNLIMITED CASE O_suimitep case
(Amount demanded (Amount demanded Is $25,000
exceeds $25,000) or less)
‘CASE NUMBER:
CGC-13-534478
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: April 9, 2014 Time: 10:30 a.m. Dept.: 610 Div.: Room:
Address of court (if different from the address above):
X Notice of Intent to Appear by Telephone, by (name): Dennis J. Ward, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. [X] This statement is submitted by party (name): Defendants and Cross-Complainants CENTRAL CONCRETE
SUPPLY CO,, INC.; U.S. CONCRETE, INC.; and BODE CENTRAL LLC.
b. [1 This statement is submitted jointly by parties (names): ¢ ch X
2, Complaint and cross-compiaint (to be answered by plaintiffs and cross-complainants only) a
a. The complaint was filed on (date): .
b. The cross-complaint, if any, was filed on (date): 11/22/13 on behalf of Central Concrete & U. S. Concrete; and
1/30/14 on behalf of Bode Central LLC
3; Service (to be answered by plaintiffs and cross-complainants only)
a. [XI Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. IX] The following parties named in the complaint or cross-complaint
(1) 1] _ have not been served (specify names and explain why not): John J. Cardoni
(2) [1 have been served but have not appeared and have not been dismissed (specify names):
(3) (Ds have had a default entered against them (specify names):
c. (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 of case in EX) complaint 1 cross-complaint (Describe, including causes of action):
Personal Injuries resulting from a pedestrian v. automobile incident that occurred on October 7, 2011 at the
intersection of Turk Street and Laguna Street in San Francisco.
fans
Form Adopted for Mandatay Use CASE MANAGEMENT STATEMENT Cal Rules of Cou
CM-110 [Rev. July 1, 2011] enw. cou gov
swe FormsWorklow.comPLAINTIFF/PETITIONER: SAMU FAUD, by and through his GAL, et al
| DEFENDANT/RESPONDENT: CRAIG ALAN CARDONI, et al
4. b. Provide a brief statement of the case, including any damages. (if personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
eamings to date, and estimated future lost eamings. If equitable relief is sought, describe the nature of the relief.)
Plaintiffs seek recovery for personal injuries resulting from a pedestrian v. automobile accident which occurred on
October 7, 2011 at the intersection of Turk Street and Laguna Street in San Francisco. Plaintiff Sami Fuad, who was
approximately 8 years old at the time of this incident, was struck by a vehicle being operated by Defendant Cardori.
Plaintiff Anmed Fuad, Sami Fuad’s father, witnessed this incident. Sami Fuad seeks recovery for personal injuries, while
Ahmed Fuad seeks recovery for injuries sutained under the Dillon v. Legg theory of recovery.
0 (If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request & ajurytrial (1) anonjury trial. (if more than one party, provide the name of each party
requesting a jury trial):
CM-110
6. Trial date
a. [) The trial has been set for (date):
b. EK No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
c. Dates on which parties or attomeys will not be available for trial (specify dates and explain reasons for unavailability):
Weeks of April 21, 2014 - May23, 2014 - wrongful death trial; September 5, 2014 - September 19, 2014 - trial.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. BX) days (specify number): 10 days
b. [1 _ hours (short causes) (specify):
8. Trial representation (fo be answered for each party)
The party or parties will be represented at trial [X] by the attomey or party listed in the caption [[] by the following:
Attorney:
Firm:
Address:
Telephone number: f. Fax number:
E-mail address: . g. Party represented:
(1 __ Additional representation is described in Attachment 8.
9, Preference
(1) 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 [X]_ has [J hasnot 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 (J 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) (1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) (1) 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) [1 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):
paoc®
Guer10 Rev. ay 1, 2019] CASE MANAGEMENT STATEMENT Page 20's
American LegalNet, In. @
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LAINTIFF/PETITIONER: SAMU FAUD, by and through his GAL, et al CGC-13.534478
IDEFENDANT/RESPONDENT: CRAIG ALAN CARDONI, et al
CM-110
10. ¢. 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 | 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
a Mediation session scheduled for (date):
(1) Mediation Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
of
(2) Settiement Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date) :
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
3) N | evaluatio Neutral evaluation scheduled for (date):
(3) Neutral evaluation
(4) Nonbinding judicial
arbitration
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
(5) Binding private Private arbitration scheduled for (date):
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ODO;J/OOO0OO0O;OOo0oOJ;oOoOoo0Oo; TL
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
(1 ADR completed on (date):
American LegalNet, Inc.
ww, FormsWorkFlow.comCM-110
. i CASE NUMBER:
PLAINTIFF/PETITIONER: SAMU FAUD, by and through his GAL, et al CGC-13.534478
DEFENDANT/RESPONDENT: CRAIG ALAN CARDONI, et al
11.
12.
13.
14.
15.
16.
Insurance
a. KI - Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: [] Yes [] No
c. [1 Coverage issues will significantly affect resolution of this case (explain):
Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
0 Bankruptcy [) Other (specify):
Status:
Related cases, consolidation, and coordination
a. [1 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. C1 Amotionto [1] consolidate [ coordinate will be filed by (name party):
Bifurcation
{1 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):
Other motions
[The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Reserve.
Discovery
a. [1 The party or parties have completed all discovery.
b [XX] The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Central Concrete; US Concrete; Bode Central Written discovery to Plaintiffs TBA
Central Concrete; US Concrete; Bode Central Written discovery to co-Defendants TBA
Central Concrete; US Concrete; Bode Central _ Plaintiffs’ deposition TBA
Central Concrete; US Concrete; Bode Central Obtatining medical records TBA
Central Concrete; US Concrete; Bode Central Miscellaneous TBA
c. (] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
(CMe110 [Rew July 1, 2014) CASE MANAGEMENT STATEMENT : Page sors
‘American LegalNet, Tae,
sownw.FormsWorkFlow.com‘CASE NUMBER:
CGC-13-534478
CM-110
PLAINTIFF/PETITIONER: SAMU FAUD, by and through his GAL, et al
| DEFENDANT/RESPONDENT: CRAIG ALAN CARDONI, et al
17, Economic litigation
a. [J This isa 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
[11 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 Califomia Rules of
Court (if not, explain): At the time defense counsel is preparing this Case Management Statement, no "meet and
confer" has been undertaken.
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):
| am completely familiar with this case and will be fully prepared to discuss the status of discovery and altemative 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 18, 2014
DENNIS J. WARD, ESQ.
(TYPE OR PRINT NAME)
(SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
DD Additional signatures are attached.
‘American LegalNet, Ine.
serow Forms WorkFlow.comRopers Majeski Kohn & Bentley
A Professional Corporation
San Jose
oO Oo YN DH UH FF WHY —
bb Ne bY YY NY N — — ee
®BSFRRBESORESE SR BVABDESER AS
CASE NAME: Fuad, et al v. Cardoni, et al
ACTION NO.: CGC-13-534478; San Francisco County Superior Court
PROOF OF SERVICE
METHOD OF SERVICE
4 First Class Mail D Facsimile oO Messenger Service
oOo Overnight Delivery 0 E-Mail/Electronic Delivery C1 Personal Delivery
1. At the time of service, I was over 18 years of age and not a party to this action.
2. My business address is 50 West San Fernando Street, Suite 1400, San Jose, CA 95113-2429.
3. On March 18, 2014, I served the following documents:
CASE MANAGEMENT STATEMENT
4, I served the documents on the persons at the address below (along with their fax numbers
and/or email addresses if service was by fax or email):
Thomas J. Brandi, Esq.
The Brandi Law Firm
354 Pine St., 3rd Floor
San Francisco, CA_94104
Attorney for Plaintiffs
(415) 989-1800
FAX: (415) 989-1801
Charles S. Custer, Esq.
Gordon & Rees, LLP
Embarcadero Center West
275 Battery St., Twentieth Floor
San Francisco, CA 94111
Attorney for Defendant
ALLEN COMMUNITY
DEVELOPMENT CORPORATION
(for itself and erroneously sued as
Eastern Addition Community
Technology Center)
(415) 986-5900
FAX: (415) 986-8054
Scott A. Slomiak, Esq.
Law Offices of Scott A. Slomiak, APLC
3950 Civic Center Dr., Ste. 230
San Rafael, CA 94903
Attomey for Defendant
CRAIG ALAN CARDONI
(415) 924-8870
FAX: (415) 924-7358
G. Geoffrey Wood, Esq.
Ross C. Dwyer, Esq.
Ericksen Arbuthnot
155 Grand Ave., Ste. 1050
Oakland, CA 94612
Attorney for Defendant
LG GENERAL ENGINEERING &
CONSTRUCTION, INC.
(510) 832-7770 (ext. 116)
FAX: (510) 832-0102
gwood@ericksenarbuthnot.com
5. I served the documents by the following means:
RC1/7209995.18/GH2
PROOF OF SERVICERopers Majeski Kohn & Bentley
A Professional Corporation
San Jose
oC 0D Om ND WH RF WN
eka
Oo no =
14
15
16
17
18
19
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21
2
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a. El By United States mail: I enclosed the documents in a sealed envelope or package
addressed to the persons at the addresses specified in item 4 and placed the envelope for
collection and mailing, following our ordinary business practices. I am readily familiar with this
business’s practice for collecting and processing correspondence for mailing. On the same day
that correspondence is placed for collection and mailing, it is deposited in the ordinary course of
business with the United States Postal Service, in a sealed envelope with postage fully prepaid.
b. O By overnight delivery: I enclosed the documents in an envelope or package
provided by an overnight delivery carrier and addressed to the persons at the addresses in item 4.
| I placed the envelope or package for collection and overnight delivery at an office or a regularly
utilized drop box of the overnight delivery carrier.
c. O By messenger: I served the documents by placing them in an envelope or package
addressed to the persons at the addresses listed in item 4 and providing them to a messenger for
service.
d. O By fax transmission: Based on an agreement between the parties and in
conformance with Rule 2.306, and/or as a courtesy, I faxed the documents to the persons at the
fax numbers listed in item 4.
e. 0 By email or electronic transmission: Based on an agreement between the parties
and/or as a courtesy, I sent the documents to the persons at the email addresses listed in item 4. I
did not receive, within a reasonable time after the transmission, any electronic message or other
indication that the transmission was unsuccessful.
f. 1 By personal service. I personally served the documents by placing them in an
envelope or package addressed to the persons at the address. listed in item 4.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
DATED: _March 18, 2014
GINA Q. HUERTA
Type Name
Guo Yuk
RC1/7209995.18/GH2 -2-
PROOF OF SERVICE
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SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Mar-20-2014 2:37 pm Case Number: CGC-13-534478 Filing Date: Mar-20-2014 2:37 Filed by: RONNIE OTERO Juke Box: 001 Image: 04418910 CASE MANAGEMENT STATEMENT FUAD, SAMI, BY AND THROUGH HIS GUARDIAN AD LITEM, et al VS. CRAIG ALAN CARDON| et al 001004418910 Instructions: Please place this sheet on top of the document to be scanned.: . e CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stele Bar number, and address): i DENNIS J. WARD (SBN 78493) ROPERS, MAJESKI, KOHN & BENTLEY 50 W. San Fernando Street, Ste. 1400 San Jose, CA 95113 TELEPHONE NO.: (408) 287-6262 - _ FAK NO. (Optonay: (408) 918-4501 E-MAIL ADDRESS (Optlonay: dward@rmkb.com ATTORNEY FOR (Name): Defendants and Cross-Complainants CENTRAL CONCRETE SUPPLY CO., INC.; U.S. CONCRETE, INC.; and BODE CENTRAL LLC. SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO streeT aopress: 400 McAllister Street cry ano zp cove: San Francisco, CA 94102-4514 PLAINTIFF/PETITIONER: SAMU FAUD, by and through his guardian ad litem, AHMED FUAD; AHMED FAUD DEFENDANT/RESPONDENT: CRAIG ALAN CARDONI, et al CASE MANAGEMENT STATEMENT (Check one): , &) UNLIMITED CASE O_suimitep case (Amount demanded (Amount demanded Is $25,000 exceeds $25,000) or less) ‘CASE NUMBER: CGC-13-534478 A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: April 9, 2014 Time: 10:30 a.m. Dept.: 610 Div.: Room: Address of court (if different from the address above): X Notice of Intent to Appear by Telephone, by (name): Dennis J. Ward, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. [X] This statement is submitted by party (name): Defendants and Cross-Complainants CENTRAL CONCRETE SUPPLY CO,, INC.; U.S. CONCRETE, INC.; and BODE CENTRAL LLC. b. [1 This statement is submitted jointly by parties (names): ¢ ch X 2, Complaint and cross-compiaint (to be answered by plaintiffs and cross-complainants only) a a. The complaint was filed on (date): . b. The cross-complaint, if any, was filed on (date): 11/22/13 on behalf of Central Concrete & U. S. Concrete; and 1/30/14 on behalf of Bode Central LLC 3; Service (to be answered by plaintiffs and cross-complainants only) a. [XI Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. IX] The following parties named in the complaint or cross-complaint (1) 1] _ have not been served (specify names and explain why not): John J. Cardoni (2) [1 have been served but have not appeared and have not been dismissed (specify names): (3) (Ds have had a default entered against them (specify names): c. (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 of case in EX) complaint 1 cross-complaint (Describe, including causes of action): Personal Injuries resulting from a pedestrian v. automobile incident that occurred on October 7, 2011 at the intersection of Turk Street and Laguna Street in San Francisco. fans Form Adopted for Mandatay Use CASE MANAGEMENT STATEMENT Cal Rules of Cou CM-110 [Rev. July 1, 2011] enw. cou gov swe FormsWorklow.comPLAINTIFF/PETITIONER: SAMU FAUD, by and through his GAL, et al | DEFENDANT/RESPONDENT: CRAIG ALAN CARDONI, et al 4. b. Provide a brief statement of the case, including any damages. (if personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost eamings to date, and estimated future lost eamings. If equitable relief is sought, describe the nature of the relief.) Plaintiffs seek recovery for personal injuries resulting from a pedestrian v. automobile accident which occurred on October 7, 2011 at the intersection of Turk Street and Laguna Street in San Francisco. Plaintiff Sami Fuad, who was approximately 8 years old at the time of this incident, was struck by a vehicle being operated by Defendant Cardori. Plaintiff Anmed Fuad, Sami Fuad’s father, witnessed this incident. Sami Fuad seeks recovery for personal injuries, while Ahmed Fuad seeks recovery for injuries sutained under the Dillon v. Legg theory of recovery. 0 (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request & ajurytrial (1) anonjury trial. (if more than one party, provide the name of each party requesting a jury trial): CM-110 6. Trial date a. [) The trial has been set for (date): b. EK No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attomeys will not be available for trial (specify dates and explain reasons for unavailability): Weeks of April 21, 2014 - May23, 2014 - wrongful death trial; September 5, 2014 - September 19, 2014 - trial. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. BX) days (specify number): 10 days b. [1 _ hours (short causes) (specify): 8. Trial representation (fo be answered for each party) The party or parties will be represented at trial [X] by the attomey or party listed in the caption [[] by the following: Attorney: Firm: Address: Telephone number: f. Fax number: E-mail address: . g. Party represented: (1 __ Additional representation is described in Attachment 8. 9, Preference (1) 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 [X]_ has [J hasnot 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 (J 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) (1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) (1) 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) [1 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): paoc® Guer10 Rev. ay 1, 2019] CASE MANAGEMENT STATEMENT Page 20's American LegalNet, In. @ won Forms WorkFlow.comjs CASE NUMBER: LAINTIFF/PETITIONER: SAMU FAUD, by and through his GAL, et al CGC-13.534478 IDEFENDANT/RESPONDENT: CRAIG ALAN CARDONI, et al CM-110 10. ¢. 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 | 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 a Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled of (2) Settiement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date) : Settlement conference completed on (date): Neutral evaluation not yet scheduled 3) N | evaluatio Neutral evaluation scheduled for (date): (3) Neutral evaluation (4) Nonbinding judicial arbitration 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 (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled ODO;J/OOO0OO0O;OOo0oOJ;oOoOoo0Oo; TL (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): (1 ADR completed on (date): American LegalNet, Inc. ww, FormsWorkFlow.comCM-110 . i CASE NUMBER: PLAINTIFF/PETITIONER: SAMU FAUD, by and through his GAL, et al CGC-13.534478 DEFENDANT/RESPONDENT: CRAIG ALAN CARDONI, et al 11. 12. 13. 14. 15. 16. Insurance a. KI - Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: [] Yes [] No c. [1 Coverage issues will significantly affect resolution of this case (explain): Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. 0 Bankruptcy [) Other (specify): Status: Related cases, consolidation, and coordination a. [1 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. C1 Amotionto [1] consolidate [ coordinate will be filed by (name party): Bifurcation {1 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): Other motions [The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Reserve. Discovery a. [1 The party or parties have completed all discovery. b [XX] The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Central Concrete; US Concrete; Bode Central Written discovery to Plaintiffs TBA Central Concrete; US Concrete; Bode Central Written discovery to co-Defendants TBA Central Concrete; US Concrete; Bode Central _ Plaintiffs’ deposition TBA Central Concrete; US Concrete; Bode Central Obtatining medical records TBA Central Concrete; US Concrete; Bode Central Miscellaneous TBA c. (] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): (CMe110 [Rew July 1, 2014) CASE MANAGEMENT STATEMENT : Page sors ‘American LegalNet, Tae, sownw.FormsWorkFlow.com‘CASE NUMBER: CGC-13-534478 CM-110 PLAINTIFF/PETITIONER: SAMU FAUD, by and through his GAL, et al | DEFENDANT/RESPONDENT: CRAIG ALAN CARDONI, et al 17, Economic litigation a. [J This isa 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 [11 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 Califomia Rules of Court (if not, explain): At the time defense counsel is preparing this Case Management Statement, no "meet and confer" has been undertaken. 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): | am completely familiar with this case and will be fully prepared to discuss the status of discovery and altemative 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 18, 2014 DENNIS J. WARD, ESQ. (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) DD Additional signatures are attached. ‘American LegalNet, Ine. serow Forms WorkFlow.comRopers Majeski Kohn & Bentley A Professional Corporation San Jose oO Oo YN DH UH FF WHY — bb Ne bY YY NY N — — ee ®BSFRRBESORESE SR BVABDESER AS CASE NAME: Fuad, et al v. Cardoni, et al ACTION NO.: CGC-13-534478; San Francisco County Superior Court PROOF OF SERVICE METHOD OF SERVICE 4 First Class Mail D Facsimile oO Messenger Service oOo Overnight Delivery 0 E-Mail/Electronic Delivery C1 Personal Delivery 1. At the time of service, I was over 18 years of age and not a party to this action. 2. My business address is 50 West San Fernando Street, Suite 1400, San Jose, CA 95113-2429. 3. On March 18, 2014, I served the following documents: CASE MANAGEMENT STATEMENT 4, I served the documents on the persons at the address below (along with their fax numbers and/or email addresses if service was by fax or email): Thomas J. Brandi, Esq. The Brandi Law Firm 354 Pine St., 3rd Floor San Francisco, CA_94104 Attorney for Plaintiffs (415) 989-1800 FAX: (415) 989-1801 Charles S. Custer, Esq. Gordon & Rees, LLP Embarcadero Center West 275 Battery St., Twentieth Floor San Francisco, CA 94111 Attorney for Defendant ALLEN COMMUNITY DEVELOPMENT CORPORATION (for itself and erroneously sued as Eastern Addition Community Technology Center) (415) 986-5900 FAX: (415) 986-8054 Scott A. Slomiak, Esq. Law Offices of Scott A. Slomiak, APLC 3950 Civic Center Dr., Ste. 230 San Rafael, CA 94903 Attomey for Defendant CRAIG ALAN CARDONI (415) 924-8870 FAX: (415) 924-7358 G. Geoffrey Wood, Esq. Ross C. Dwyer, Esq. Ericksen Arbuthnot 155 Grand Ave., Ste. 1050 Oakland, CA 94612 Attorney for Defendant LG GENERAL ENGINEERING & CONSTRUCTION, INC. (510) 832-7770 (ext. 116) FAX: (510) 832-0102 gwood@ericksenarbuthnot.com 5. I served the documents by the following means: RC1/7209995.18/GH2 PROOF OF SERVICERopers Majeski Kohn & Bentley A Professional Corporation San Jose oC 0D Om ND WH RF WN eka Oo no = 14 15 16 17 18 19 20 21 2 23 24 25 26 27 28 a. El By United States mail: I enclosed the documents in a sealed envelope or package addressed to the persons at the addresses specified in item 4 and placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with this business’s practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid. b. O By overnight delivery: I enclosed the documents in an envelope or package provided by an overnight delivery carrier and addressed to the persons at the addresses in item 4. | I placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier. c. O By messenger: I served the documents by placing them in an envelope or package addressed to the persons at the addresses listed in item 4 and providing them to a messenger for service. d. O By fax transmission: Based on an agreement between the parties and in conformance with Rule 2.306, and/or as a courtesy, I faxed the documents to the persons at the fax numbers listed in item 4. e. 0 By email or electronic transmission: Based on an agreement between the parties and/or as a courtesy, I sent the documents to the persons at the email addresses listed in item 4. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. f. 1 By personal service. I personally served the documents by placing them in an envelope or package addressed to the persons at the address. listed in item 4. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. DATED: _March 18, 2014 GINA Q. HUERTA Type Name Guo Yuk RC1/7209995.18/GH2 -2- PROOF OF SERVICE