Document for IDA CHRISTINA FUA CRUZ VS. JOEL ENRIQUE ANDINO SANCHEZ et al

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D. Dougias Shureen, SBN 124613

McMILLAN & SHUREEN_ ip ELECTRONICALLY
50 Santa Rosa Avenue, Suite 200 FILED
Santa Rosa, CA 95404 Superior Court of California,
(707) 525-5400 County of San Francisco
(707) 576-7955 (Fax) MAR 05 2015
Attorneys for DefendantiCross Complainant Clerk of the Court
JOEL ENRIQUE ANDINO SANCHE. BY: RONNIE OTERO
eputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
IDA CRISTINA CRUZ FUA, CASE No. CGC-11-515542 (Lead

Case) Consolidated with Case Nos.

Plaintiff, ) GGC-12-519794 and CGC-13-529705
vs. DEFENDANT/CROSS-
COMPLAINANT JOEL ENRIQUE
JOEL ENRIQUE ANDINO SANCHEZ, an ) ANDINO SANCHEZ’S SEPARATE
individual, et al., ) STATEMENT RE: TRIAL TIME

LIMITS

Date: March 9, 2015

Time: 9:30 a.m. -

AND RELATED CROSS-ACTIONS. Dept.: 206

) Action filed: 10/31/11
Defendant/Cross-Complainant JOEL ENRIQUE ANDINO SANCHEZ (hereafter

“Defendant/Cross-Complainant’) hereby submits his statement re: trial time limits as

Defendants.

foliows:
A. TOTAL NUMBER OF HOURS TO TRY THE CASE:

Defendant/Cross-Complainant believes it may take four weeks, or 140 hours to try
this case. ,

B. WITNESS LIST:

Defendant/Cross-Complainant intends to cail the following witnesses to testify at
trial:
Hil
fil

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DEFENDANT/CROSS-COMPLAINANT JOEL ENRIQUE ANDINO SANCHEZ'S SEPARATE STATEMENT
RE: TRIAL TIME LIMITSoD we ND HW RB BW

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NN YN NY NY NY KN YY
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1. Joel Sanchez: Mr. Sanchez is expected to testify regarding the accident and
his employment relationship with Defendant Yellow Cab and others; 3 hours.

2. James Gillespie: Mr. Gillespie is expected to testify regarding the
employment relationship between Yellow Cab and Joel Sanchez, 2 hours.

3. Ivan Gaviria: Mr. Gaviria is expected to testify regarding the employment of
Ms. Fua with his firm, her performance, and the firm's general expectations regarding Ms.
Fua’s legal career; 1 hour.

4. Jeffrey Cheng is expected to testify regarding the accident and his
relationship with Ms. Fua; 1 hour.

5. Raymond Samatovich is expected to testify as Ms. Fua’s treating physician;
2 hours.

6. Danielle Alleven is expected to testify regarding her neuropsychological
evaiuation of Ms. Fua; 2 hours.

7. Daniel Borg is expected to testify regarding inspections of the taxi cab by the
City and County of San Francisco, 1 hour.

8. Alan DaSilva is expected to testify regarding the employment relationship
between Yellow Cab and Mr. Sanchez, 1 hour.

9. Larue Perkins is expected to testify regarding the medical charges incurred
by Plaintiff from Stanford Hospital, 2 hours.

10. Dennis Fua is expected to testify regarding Ida Fua’s contacts with him; 1
hour.

41. Josephina Fua is expected to testify regarding Ida Fua’s daily routines,
rehabilitation, and exercise schedule; 1 hour.

12. Santiago Fua is expected to testify regarding Ida Fua's daily routines,
rehabilitation and exercise schedule; 1 hour.

13. Ida Fua is expected to testify about her efforts to return to work and obtain
vocational rehabilitation; 1 hour.

itl

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DEFENDANT/CROSS-COMPLAINANT JOEL ENRIQUE ANDINO SANCHEZ’S SEPARATE STATEMENT
RE: TRIAL TIME LIMITScow oe IN DH RB YW NY

14, Peter Cassini, M.D. will testify as an expert regarding Ms. Fua’s injuries and
condition; 3 hours.

15. Alan Shonkoff will testify as an expert regarding Ms. Fua’s
neuropsychological condition; 3 hours.

16. Timothy Farrell will testify as an expert regarding Ms. Fua’s vocational
abilities and opportunities; 3 hours.

17. James Mason will testify as an expert regarding the accident and the effect
of Ms. Fua’s failure to wear her seat belt; 2 hours.

18. — Philp Aliman will testify as an economics expert regarding the economic
damages sustained by Ms. Fua; 2 hours.

19. Tamera Rockholt will testify as an expert regarding the cost of medical
services incurred by Ms. Fua as a result of the accident; 1 hour.

20. Diana Bubanja will testify as an expert regarding the life care costs expected
to be incurred by Ms. Fua; 1 hour.

c. TOTAL NUMBER OF HOURS OF DIRECT EXAMINATION: 34 hours.

DATED: March~_, 2015 McMILLAN & SHUREEN LLP

By: Lr

D. Douglas Shureen

Attorneys for Defendant/Cross-
Complainant JOEL ENRIQUE
ANDINO SANCHEZ

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DEFENDANT/GROSS-COMPLAINANT JOEL ENRIQUE ANDINO SANCHEZ’S SEPARATE STATEMENT
RE: TRIAL TIME LIMITSOo eo ND tr RB WN

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woe yy NN NY BY
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FUA v. SANCHEZ, et al.
SAN FRANCISCO COUNTY SUPERIOR COURT CASE No. CGC-11-515542 (Lead
Case) Consolidated with Case Nos. CGC-12-619794 and CGC-13-529705

PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF SONOMA

| am employed in the County of Sonoma, State of California. 1am over the age of
18 and not a party.to the within action: my business address is 50 Santa Rosa Avenue,
Suite 200, Santa Rosa, California 95404. On the date below indicated, and as
required by the Court's Order re: Electronic Service of Pleadings in Case No. CGC-
11-515542 (Lead Case) Consolidated with Case Nos, CGC-12-519794 and CGC-13-
529705, | served on the interested parties through File and Serve Xpress in this
action the within document(s) described as:

DEFENDANT/CROSS-COMPLAINANT JOEL ENRIQUE ANDINO SANCHEZ’S
SEPARATE STATEMENT RE: TRIAL TIME LIMITS

on the recipients designated on the Transaction Receipt located on the File and Serve
Xpress website.

X_ (BY ELECTRONIC MAIL) Based on a court order or an agreement of the parties to
accept service by electronic transmission, on March 4, 2015, | caused the
documents to be sent to the persons at the electronic notification addresses listed
above. | did not receive. within a reasonable time after the transmission, any
electronic message or other indication that the transmission was unsuccessful.

PLEASE SEE ATTACHED SERVICE LIST.

X_ (BY MAIL) by placing the true copies thereof enclosed in sealed envelopes,
postage prepaid, addressed as noted below. | caused such envelope to be
deposited in the mail at Santa Rosa, California 95404. The envelope was mailed
with postage thereon fully prepaid. | am ‘readily familiar’ with our firm's practice of
collection and processing correspondence for mailing. Itis deposited with the U.S.
postal service on that same day in the ordinary course of business. | am aware
that on motion of party served, service is presumed invalid if postal cancellation
date or postage meter date is more than 1 day after date of deposit for mailing in
affidavit.

Attorneys for Plaintiff
Mitchell E. Green, Esq. Allstate Insurance Company
Law Offices of Mitchell E. Green
P.O. Box 630550
Simi Valley, CA 93063
Tel: (805) 823-0915
Fax: (805) 823-0916
MitchGreenLaw@aol.com

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DEFENDANT/CROSS-COMPLAINANT JOEL ENRIQUE ANDINO SANGHEZ’S SEPARATE STATEMENT
RE: TRIAL TIME LIMITS ,Thomas M. Downey, Esq. Attorneys for Defendants

Gregory H. McCormick, Esq. San Francisco independent Taxi
Burnham Brown Association and Alan Da Silva
P.O. Box 119

Oakland, CA 94604

Tel: (510) 444-6800

Fax: (510) 835-6666
tdowney@burnhambrown.com
gmecormick@burnhambrown.com

| declare under penalty of perjury under the laws of the State of California that the
above is true and correct, and that this declaration was executed on March 4, 2015 at
Santa Rosa, California.

RoseAnne Powell : Cow une we

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DEFENDANT/CROSS-COMPLAINANT JOEL ENRIQUE ANDINO SANCHEZ’S SEPARATE STATEMENT
RE: TRIAL TIME LIMITSFua v. Sanchez (lead case)
San Francisco County Superior Court Case No. CGC-11-515542

Service List

Todd P. Emanuel, Esq.

Mark D. Rosenberg, Esq.
Emanuel Law Group

702 Marshall Street, Suite 400
Redwocd City, CA 94063

Tel: (650) 369-8900

Fax: (650) 369-8999
Todd@TEinjurylaw.com
Mark@TEiniurylaw.com

Robert Peterson, Esq.

Colin C. Munro, Esq.
Christopher J. Weber, Esq.
Carlson, Calladine Peterson, LLP
353 Sacramento Street, 16th Floor
San Francisco, CA 94111

Tel: (415) 391-3911

Fax: (415) 391-3898
rpeterson@ccplaw.com
cmunro@ccplaw.com
cweber@ccplaw.com

Robert S. Aaron, Esq.
Aaron & Wilson, LLP

150 Post Street, Suite 400
San Francisco, CA 94108
Tel: (415) 438-7800

Fax: (415) 438-7808
rsaaron@aaron-wilson.com

Attorneys for Plaintiff
Ida Cristina Cruz Fua

Attorneys for Defendants/Cross-
Defendants Yellow Cab
Cooperative, Inc., Taxi Equipment
Leasing, LLC and Caroline Miller

Attorneys for Defendanis/Cross-
Defendants YeHow Cab
Cooperative, inc., Taxi Equipment
Leasing, LLC, Taxi Property
Gompany, Inc., Wolley, LLC,
James Gillespie, Hal Mellegard,
Nick Olsen, Pamela Martinez,
Richard Wiener, and Steven
Reimers