Preview
DOM
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Sep-27-2012 2:35 pm
Case Number: CGC-12-520844
Filing Date: Sep-27-2012 2:35
Filed by: RONNIE OTERO
Juke Box: 001 Image: 03782598
CASE MANAGEMENT STATEMENT
BUNDY CHANOCK VS. CITY AND COUNTY OF SAN FRANCISCO et al
001003782598
Instructions:
Please place this sheet on top of the document to be scanned._oM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and adaress)’
Jobn D. Winer/Shawn D. Tillis 091078/224539
Winer & McKenna LLP
artornev For name Plaintiff Bundy Chanock
1999 Harrison Street, Suite 600
Oakland, CA 94612
yeceponeno: (510) 433-1000 Fax NO (Optionay: (510) 433-1001
E-MAIL ADDRESS (Options)
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco
streetaporess 400 McAllister Street
MAILING ADDRESS:
catvanoziecooe San Francisco, CA 94102
BRANCH NAME.
Public Health; OMI Family Center, Christine LeBlanc, et al.
PLAINTIFF/PETITIONER: Bundy Chanock
DEFENDANT/RESPONDENT: City and County of San Francisco; SF Dept.
CASE MANAGEMENT STATEMENT CASE NUMBER
(Check one): (XJ UNLIMITED CASE () timitep case CGC-12-520844
(Amount demanded (Amount demanded is $25,000
[ exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: October 17,2012 Time: 2:00 PM Dept: 610 Div.: Room:
Address of court (if different from the address above):
[4] Notice of intent to Appear by Telephone, by (name): Shawn D. Tillis
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. [&) This statement is submitted by party (name): Plaintiff Bundy Chanock
b. (2) This statement is submitted jointly by parties (names):
2. Complaint and cross-compiaint (fo be answered by plaintiffs and cross-complainants only)
a. The compiaint was filed on (date): May 17, 2012
b. (2) The cross-compiaini, if any, was filed on (date):
3 Service (to be answered by plaintiffs and cross-compfainants only)
a. (&) All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [O) The following parties named in the complaint or cross-complaint
(1) [Cy have not been served (specify names and explain why not): LU
(2) [l) have been served but have not appeared and have not been dismissed (specify names):
(3) CO) have had a default entered against them (specify names).
ce (2) The following additional parties may be added (specify names, nature of involvement in case, and the date by which !
they may be served):
4. Description of case
a. Typeofcasein [QQ complaint [2) cross-complaint (Describe, inclucting causes of action):
Negligence, medical malpractice, TED, battery, sexual battery, breach of fiduciary duty, fraud, sexual contact
psychotherapist, sexual harassment, premises liability, negligent hiring and supervison.
Page 10f5
RARER SOE A umm CASE MANAGEMENT STATEMENT Ca eof Cou
CM-440 [Rev. July 1, 201 4} ‘oros) ESSERTIAL Forms” wunw.courts. Ca.gOV
ChanockCM-110
PLAINTIFE/PETITIONER: Bundy Chanock CASE NUMBER:
CGC-12-520844
DEFENDANT/RESPONDENT: City and County of San Francisco; SF Dept.
Public Health; OMI Family Center, Christine LeBlanc 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 fost eamings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff received individual psychotherapy from Defendants following the untimely death of his wife. Plaintiff treated with Defendants from
approximately August 2010 to December 2011, During this time period, Defendants committed numcrous boundary violations and negligently
and carelessly treated, diagnosed, and supervised Plaintiff. Defendants further sexually assaulted Plaintiff during the therapeutic relationship.
Asa result of Defendants! conduct, Plaintiff has and will continue to suffer from severe emotional distress.
(C) (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 [XQ ajurytrial (2) anonjury trial. (f more than one party, provide the name of each party
requesting a jury trial):
8. Trial date
a. (C] The trial has been set for (date):
b. [XQ No trial date has been set. This case will be ready for triat within 12 months of the date of the filing of the complaint (if
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
1A/5-10/2012; 11/26-12/5/2012; 1/11-16/2013; 2/25-3/10/2013; 5/20-25/2013, 6/24-6/30/2013, 7/1-5/2013
7. Estimated length of trial
The party or parties estimate that the triai will take (check one):
a. [EX] days (specify number): 10
b. EC] hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial [X]) by the attorney or party listed in the caption (2) by the following:
a Altorney:
b. Firm:
c, Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
(C) Additional representation is described in Attachment 8.
9. Preference
Cd This case is entitled to preference (specify code section):
40. 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 availabe through the
court and community programs in this case.
(1) For parties represented by counsel. Counsel C&¥has [LD 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 [Jhas oO has not reviewed the ADR information package identified in rule 3.221,
b. Referral to judicial arbitration or civit action mediation (if available).
(1) CCQ This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) (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 1141.17
(3) [2] This case is exempt from fucicial 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):
Gha-110 Row su 1, 2011) ~~" CASE MANAGEMENT STATEMENT Page2 of 8
Chanock.CM-110
PLAINTIFF/PETINIONER: Bundy Chanock
DEFENDANT/RESPONDENT: City and County of San Francisco; SF Dept.
Public Health; OMI Family Center; Christine LeBlanc et al.
CASE NUMBER
CGC-12-520844
40. ¢. 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 all that apply):
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):
[QJ Mediation session not yet scheduled
[(C) Mediation session scheduled for (date):
(1) Mediation @
(5) Agreed to complete mediation by (date):
() Mediation completed on (date):
(J Settlement conference not yet scheduled
{2) Settlement a (2 Settlement conference scheduled for (date):
conference
[-) Agreed to complete settlement conference by (date):
C2 Settlement conference completed on (date):
(CQ Neutral evaluation not yet scheduled
(9) Neutral evaiuation a (2) Neutra! evaluation scheduled for (date):
[2] Agreed to complete neutral evaluation by (date):
(C} Neutral evaluation completed on (date):
C2] Judicial arbitration not yet scheduled
(4) Nonbinding judiciat qo (2 Judicial arbitration scheduled for (date):
‘bitrate
arbitration (2) Agreed to complete judicial arbitration by (date):
(2 Juciciat arbitration completed on (date):
(.] Private arbitration not yet scheduled
(8) Binding private t [] Private arbitration scheduled for (dafe):
arbitration (2) Agreed to complete private arbitration by (date),
(CC) Private arbitration completed on (date):
{LJ ADR session not yet scheduled
(8) Other (specify): oO LA} ADR session scheduled for (date):
(L] Agreed to complete ADR session by (date):
CCV ADR completed on (date):
(al
23}
CASE MANAGEMENT STATEMENT
Chanock
Page 3 of §CM-110
PLAINTIFF/PETITIONER: Bundy Chanock ‘CASE NUMBER:
CGC-12-520844
DEFENDANTRESPONDENT; City and County of San Francisco; SF Dept.
Public Health; OMI Family Center; Christine LeBlanc et al.
41. Insurance
a. [2] Insurance carrier, if any, for party filing this staternent (name):
b. Reservation of rights: CVves (CJ No
c. (2) 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.
[J Bankruptey (Le Other (specify):
Status:
13, Related cases, consolidation, and coordination
a. [i] 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. (L} Amotionto [J consolidate [.) coordinate will be filed by (name party):
14. Bifurcation
(2) The party oF 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
QO The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. [2] The patty or parties have completed all discovery.
b. QQ] The following discovery will be completed by the date specified (describe all anticipated discovery):
Party - Description Date
Plaintiff Written Discovery Nov. - Dec. 2013
Plaintiff Depositions March 2013
c. [2] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-140 Rov. July 1, 2021} CASE MANAGEMENT STATEMENT Page Aor S
(775) Manes
3) ESSERTIAL FORMS ChanockCM-110
PLAINTIFF/PETITIONER: Bundy Chanock CASE NUMBER:
CGC-12-520844
DEFENDANTIRESPONDENT: City and County of San Francisco;
Public Health; OMI Family Center; Christine LeBlanc et al.
17. Economic titigation
a. (CJ Thisis 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. [2] 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 inal
should not apply fo this case):
18. Other issues
(CC) 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. (CJ The party or parties have met and conferred wiih all parties on ail 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):
2€ ‘otal 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 wel! 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: September 27, 2012
Shawn D. Tillis.
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(2) Additional signatures are attached
EM-110 [Rev day 1, 2017] ~~" GASE MANAGEMENT STATEMENT Page Sof
tin Deas
ESSENTIAL FORMS
ChanockoO mo I DA
Chanock y. City & County of San Francisco, et al.
San Francisco Superior Court, Case No.; CGC 12-520844
PROOF OF SERVICE
I, the undersigned, declare that I am employed in the County of Alameda, California. My
business address is Lake Merritt Plaza, 1999 Harrison Street, Suite 600, Oakland, California 94612.
Iam over the age of eighteen (18) years and am not a party to the within action.
On the below date, | served the following documents:
PLAINTIFF'S CASE MANAGEMENT STATEMENT
on the parties listed below, by placing a true and correct copy thereof addressed as follows:
Autorneys for Defendants City and County Attorney for Defendant, Christine
of San Francisco; San Francisco LeBlanc:
Department of Public Health; OMI
s : sa, Geoffrey Gordon-Creed, Esq.
Family Center; Christine LeBlanc, Ph.D. Gordon:Creed, Kelley, Holl & Sugerman
222 Kearny Street, Suite 650
Donald P. Margolis, Esq. San Francisco, CA 94108
Deputy City Attorney Tel: (415) 421-3100
Fox Plaza Fax: (415) 421-3150
1390 Market Street, 6 Floor
San Francisco, CA 94102-5408
Tel: (415) 554-3891
Fax: (415) 554-3837
2 BY MAIL - I placed each such sealed envelope, with postage thereon fully prepaid for first-
class mail, for collection and mailing at Oakland, California, following ordinary business practices,
being familiar with the practice of WINER & McKENNA, LLP for processing correspondence.
O BY FACSIMILE - I caused the said document to be transmitted by Facsimile machine to the
number indicated after the address(es) noted above.
BY PERSONAL SERVICE - I caused each such envelope to be delivered by hand to the
addressee(s) noted above.
L_| BY OVERNIGHT DELIVERY - I caused such envelope(s) with fees thereon fully prepaid to
e placed in the Overnight Express box at Oakland, California for next day delivery as addressed
above.
I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct,
Dated: September 27, 2012
im
PROOF OF SERVICE
Preview
DOM SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Sep-27-2012 2:35 pm Case Number: CGC-12-520844 Filing Date: Sep-27-2012 2:35 Filed by: RONNIE OTERO Juke Box: 001 Image: 03782598 CASE MANAGEMENT STATEMENT BUNDY CHANOCK VS. CITY AND COUNTY OF SAN FRANCISCO et al 001003782598 Instructions: Please place this sheet on top of the document to be scanned._oM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and adaress)’ Jobn D. Winer/Shawn D. Tillis 091078/224539 Winer & McKenna LLP artornev For name Plaintiff Bundy Chanock 1999 Harrison Street, Suite 600 Oakland, CA 94612 yeceponeno: (510) 433-1000 Fax NO (Optionay: (510) 433-1001 E-MAIL ADDRESS (Options) SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco streetaporess 400 McAllister Street MAILING ADDRESS: catvanoziecooe San Francisco, CA 94102 BRANCH NAME. Public Health; OMI Family Center, Christine LeBlanc, et al. PLAINTIFF/PETITIONER: Bundy Chanock DEFENDANT/RESPONDENT: City and County of San Francisco; SF Dept. CASE MANAGEMENT STATEMENT CASE NUMBER (Check one): (XJ UNLIMITED CASE () timitep case CGC-12-520844 (Amount demanded (Amount demanded is $25,000 [ exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: October 17,2012 Time: 2:00 PM Dept: 610 Div.: Room: Address of court (if different from the address above): [4] Notice of intent to Appear by Telephone, by (name): Shawn D. Tillis INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. [&) This statement is submitted by party (name): Plaintiff Bundy Chanock b. (2) This statement is submitted jointly by parties (names): 2. Complaint and cross-compiaint (fo be answered by plaintiffs and cross-complainants only) a. The compiaint was filed on (date): May 17, 2012 b. (2) The cross-compiaini, if any, was filed on (date): 3 Service (to be answered by plaintiffs and cross-compfainants only) a. (&) All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [O) The following parties named in the complaint or cross-complaint (1) [Cy have not been served (specify names and explain why not): LU (2) [l) have been served but have not appeared and have not been dismissed (specify names): (3) CO) have had a default entered against them (specify names). ce (2) The following additional parties may be added (specify names, nature of involvement in case, and the date by which ! they may be served): 4. Description of case a. Typeofcasein [QQ complaint [2) cross-complaint (Describe, inclucting causes of action): Negligence, medical malpractice, TED, battery, sexual battery, breach of fiduciary duty, fraud, sexual contact psychotherapist, sexual harassment, premises liability, negligent hiring and supervison. Page 10f5 RARER SOE A umm CASE MANAGEMENT STATEMENT Ca eof Cou CM-440 [Rev. July 1, 201 4} ‘oros) ESSERTIAL Forms” wunw.courts. Ca.gOV ChanockCM-110 PLAINTIFE/PETITIONER: Bundy Chanock CASE NUMBER: CGC-12-520844 DEFENDANT/RESPONDENT: City and County of San Francisco; SF Dept. Public Health; OMI Family Center, Christine LeBlanc 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 fost eamings. If equitable relief is sought, describe the nature of the relief.) Plaintiff received individual psychotherapy from Defendants following the untimely death of his wife. Plaintiff treated with Defendants from approximately August 2010 to December 2011, During this time period, Defendants committed numcrous boundary violations and negligently and carelessly treated, diagnosed, and supervised Plaintiff. Defendants further sexually assaulted Plaintiff during the therapeutic relationship. Asa result of Defendants! conduct, Plaintiff has and will continue to suffer from severe emotional distress. (C) (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 [XQ ajurytrial (2) anonjury trial. (f more than one party, provide the name of each party requesting a jury trial): 8. Trial date a. (C] The trial has been set for (date): b. [XQ No trial date has been set. This case will be ready for triat within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 1A/5-10/2012; 11/26-12/5/2012; 1/11-16/2013; 2/25-3/10/2013; 5/20-25/2013, 6/24-6/30/2013, 7/1-5/2013 7. Estimated length of trial The party or parties estimate that the triai will take (check one): a. [EX] days (specify number): 10 b. EC] hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial [X]) by the attorney or party listed in the caption (2) by the following: a Altorney: b. Firm: c, Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: (C) Additional representation is described in Attachment 8. 9. Preference Cd This case is entitled to preference (specify code section): 40. 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 availabe through the court and community programs in this case. (1) For parties represented by counsel. Counsel C&¥has [LD 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 [Jhas oO has not reviewed the ADR information package identified in rule 3.221, b. Referral to judicial arbitration or civit action mediation (if available). (1) CCQ This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) (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 1141.17 (3) [2] This case is exempt from fucicial 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): Gha-110 Row su 1, 2011) ~~" CASE MANAGEMENT STATEMENT Page2 of 8 Chanock.CM-110 PLAINTIFF/PETINIONER: Bundy Chanock DEFENDANT/RESPONDENT: City and County of San Francisco; SF Dept. Public Health; OMI Family Center; Christine LeBlanc et al. CASE NUMBER CGC-12-520844 40. ¢. 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 all that apply): 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): [QJ Mediation session not yet scheduled [(C) Mediation session scheduled for (date): (1) Mediation @ (5) Agreed to complete mediation by (date): () Mediation completed on (date): (J Settlement conference not yet scheduled {2) Settlement a (2 Settlement conference scheduled for (date): conference [-) Agreed to complete settlement conference by (date): C2 Settlement conference completed on (date): (CQ Neutral evaluation not yet scheduled (9) Neutral evaiuation a (2) Neutra! evaluation scheduled for (date): [2] Agreed to complete neutral evaluation by (date): (C} Neutral evaluation completed on (date): C2] Judicial arbitration not yet scheduled (4) Nonbinding judiciat qo (2 Judicial arbitration scheduled for (date): ‘bitrate arbitration (2) Agreed to complete judicial arbitration by (date): (2 Juciciat arbitration completed on (date): (.] Private arbitration not yet scheduled (8) Binding private t [] Private arbitration scheduled for (dafe): arbitration (2) Agreed to complete private arbitration by (date), (CC) Private arbitration completed on (date): {LJ ADR session not yet scheduled (8) Other (specify): oO LA} ADR session scheduled for (date): (L] Agreed to complete ADR session by (date): CCV ADR completed on (date): (al 23} CASE MANAGEMENT STATEMENT Chanock Page 3 of §CM-110 PLAINTIFF/PETITIONER: Bundy Chanock ‘CASE NUMBER: CGC-12-520844 DEFENDANTRESPONDENT; City and County of San Francisco; SF Dept. Public Health; OMI Family Center; Christine LeBlanc et al. 41. Insurance a. [2] Insurance carrier, if any, for party filing this staternent (name): b. Reservation of rights: CVves (CJ No c. (2) 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. [J Bankruptey (Le Other (specify): Status: 13, Related cases, consolidation, and coordination a. [i] 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. (L} Amotionto [J consolidate [.) coordinate will be filed by (name party): 14. Bifurcation (2) The party oF 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 QO The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. [2] The patty or parties have completed all discovery. b. QQ] The following discovery will be completed by the date specified (describe all anticipated discovery): Party - Description Date Plaintiff Written Discovery Nov. - Dec. 2013 Plaintiff Depositions March 2013 c. [2] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-140 Rov. July 1, 2021} CASE MANAGEMENT STATEMENT Page Aor S (775) Manes 3) ESSERTIAL FORMS ChanockCM-110 PLAINTIFF/PETITIONER: Bundy Chanock CASE NUMBER: CGC-12-520844 DEFENDANTIRESPONDENT: City and County of San Francisco; Public Health; OMI Family Center; Christine LeBlanc et al. 17. Economic titigation a. (CJ Thisis 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. [2] 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 inal should not apply fo this case): 18. Other issues (CC) 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. (CJ The party or parties have met and conferred wiih all parties on ail 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): 2€ ‘otal 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 wel! 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: September 27, 2012 Shawn D. Tillis. (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (2) Additional signatures are attached EM-110 [Rev day 1, 2017] ~~" GASE MANAGEMENT STATEMENT Page Sof tin Deas ESSENTIAL FORMS ChanockoO mo I DA Chanock y. City & County of San Francisco, et al. San Francisco Superior Court, Case No.; CGC 12-520844 PROOF OF SERVICE I, the undersigned, declare that I am employed in the County of Alameda, California. My business address is Lake Merritt Plaza, 1999 Harrison Street, Suite 600, Oakland, California 94612. Iam over the age of eighteen (18) years and am not a party to the within action. On the below date, | served the following documents: PLAINTIFF'S CASE MANAGEMENT STATEMENT on the parties listed below, by placing a true and correct copy thereof addressed as follows: Autorneys for Defendants City and County Attorney for Defendant, Christine of San Francisco; San Francisco LeBlanc: Department of Public Health; OMI s : sa, Geoffrey Gordon-Creed, Esq. Family Center; Christine LeBlanc, Ph.D. Gordon:Creed, Kelley, Holl & Sugerman 222 Kearny Street, Suite 650 Donald P. Margolis, Esq. San Francisco, CA 94108 Deputy City Attorney Tel: (415) 421-3100 Fox Plaza Fax: (415) 421-3150 1390 Market Street, 6 Floor San Francisco, CA 94102-5408 Tel: (415) 554-3891 Fax: (415) 554-3837 2 BY MAIL - I placed each such sealed envelope, with postage thereon fully prepaid for first- class mail, for collection and mailing at Oakland, California, following ordinary business practices, being familiar with the practice of WINER & McKENNA, LLP for processing correspondence. O BY FACSIMILE - I caused the said document to be transmitted by Facsimile machine to the number indicated after the address(es) noted above. BY PERSONAL SERVICE - I caused each such envelope to be delivered by hand to the addressee(s) noted above. L_| BY OVERNIGHT DELIVERY - I caused such envelope(s) with fees thereon fully prepaid to e placed in the Overnight Express box at Oakland, California for next day delivery as addressed above. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, Dated: September 27, 2012 im PROOF OF SERVICE