Preview
CM-110
ATTORNEY OR PARI'YWDHOUTAI (¹
&ORIOEY e Stale de
na bet a d add assi FOR COURT USE ONL Y
Michel le IL I'erber (149929)
Connor M. Day (233245) E-FILED
Iderber Law, P C 11/19/2019 10:39 AM
2603 Camino RD&non, Suite 3II5 Superior Court of California
SmT ka&non, CA 97I583 County of Fresno
TEICPHONENO 925-355-9800 FAxNO (Opto al)925-263-1676
By: A. Rodriguez, Deputy
E MAIL ADDRESS Itlniro
ab
3» T C PA *'»' O» ~C»
SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO
STREET ADDRESS I130 n0n Streei
I'DDRESS
MAB ING
c&TYANDzip coDEFresno, CA 93721
BRANCII NAME
PLAINTIFF/PETITIONER Edward I uncs, an individual
DEFENDANTLREsPDNDENT,I&ire Insurance I.xchange, et al.
CASE NUMBER
CASE MANAGEMENT STATEMENT
(Check one): Ix I UNLIIVIITED CASE
(Amount demanded
M LIMITED CASE
(Amount demanded is $ 25,000
19CECG02755
exceeds $ 25,000) or less)
A CASE MANAGEMENT CONFERENCE is
Date December 4, 2019 Time
scheduled as follows
3:30 p.m.
Address of court (if different frotn lhe address abave)
Dept 402 Dfv'oom
~x Notice of Intent to Appear by Telephone, by (name): Connor M. Day
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one)
a. I
x] This statement is submitted by party (name) American Contractors Indemnity Company
b. [ j This statement is submitted jointly by parties (nsmes).
2. Complaint and crass-complaint (to be answered by plaintiffs and cross-complainanls only)
a.
b. ~
The complaint was filed on (date)t
The cross-complaint, if any, was filed on(dafe)
3 Service (la be answered by p/aintiffs and cross-romplainanls only)
a. All patties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed
b,
I j
The following parties named in the complaint or cross-complamt
j
(1) ~ have not been served (specify names and explain evhy not):
(2) j 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 fallowing additional parties may be added (specify natnes, nature ofinvalvemenlin rase,
they may be served):
and date by which
4 Description of case
a Type of case in ~x complaint ~ cross-complaint (Descnbe, including causes of action)
Plaintifl'alleges insurance bad faith against Farmers Insurance, negligence against Service Masicr, and aciion on
license bond against American Contractors Indemnity Company.
Pan I to
F Adoptdf Mand lotyu CalR ofr tl,
J dtcl
C
I nnl ICabf inta CASE MANAGEMENT STATEIIENT j.egal I
372n-3 730
CM-110&Re J 2dltl Solut&t &ns.
4 Plus
&71
PLAINTIFFIPETITIQNER Edward Fttnez, an individual CASk. NUIIBCN
19CECC&0275 5
DEFENDANTIRESPQNDLNT Fire Insui ance Exchange, el. aj
5 Provide a bnef stalement of the case including any damages (IF persor1ai in/ury damages are sought, specify the Nvury and
damage'leaned, inchrdinrJ rnedrcai expenses io date (1ndicafe so1 iree and arnouni), esir1nated firture medical expense",
Io I
eammgs to dais,and fufure
esiir11aled Iosiearrvngs IFequrlebiereliefissoughi, rfescnbe Ihenaiure oF reaeF)
ih1.
PlaintiFf has liled s cjaiin agamst the hcense bond issued by Amencan Contractors Indemnity Company to
Benevento's Cleanmg dc Restoration Service, Inc.
[ ] (If morespace is needed, ches)i this box and aifach a page designated as Affachmeni 48 )
Jury or noniury trial
5.
The party or parties iequest
reques1'ing a iury trial)
~x a lury tnal~ a noniury trial (If&nore than one party, provide the nan&e of each party
6. Trial date
a LJ The tnal has been set for (dais)
b. ~x No trial date has been set This case will be ready for trial wilhm 12 months of the date ofthe filing of the complaint
(IF
nof, exp/ain)
c Dates on which parties or attorneys not be available for tnal (specify dates and explain reasons for unavailabriity)
will
12/23/19 —
I/6/20 Pzenlanned vacation I/27/20 - 2/7/20 Trial 2/14/20 - 2/25/20 Preplanrted vacation;
2/28/20 - 3/5/20 Trial; 3/23/20 —
4/3/20 Trial; 4/20/20 - 5/I/2(j Trial; 6/I/20 —
6/12/20 Trial; 6/29/20-
7/31/20 Preplanned vacation; 8/3/20 - 8/14/20 Trial
7 Estimated length of trial
The party or parties estimate that the tnal take (check one)
will
a. jx] days (spervfy r1urnher).3-5
b. ~j hours (short causes) (specii'y):
8. Trial representation (to be answered for each party)
The party or parties will be represented at tnalI x ) by the attorney or party listed m the caption
L I by the following
a Attorney
b Firm.
c Address
d Telephone number. f. Fax number:
Party represented
~
e. E-mail address:
Additional representation is describedm Attachment 8
g.
0
~
Preference
to preference (specrfy code seclion)
This case is entitled
10. Alternativedispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR informationpackage provided bythe court under rule3.221 for informationabout the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel x j has
in rule 3 221 to the client and rewewed ADR options withthe
~ has not
client
provided the ADR information package identified
(2) For self-represented parties partyj J has j I has not reviewed Ihe ADR information package ideniified in rule 3 221
b Referral to judicial arbitration or civil action mediation (if available)
(1) j
or to owl action
This matter is sublect to mandatory judimal arbitration under Code of Cwil Procedure section 1141.11
mediation under Code of Civtl Procedure section 1775 3 because the amount in controversy does noi exceed Ihe
statutory limit
(2) ~ Plaintiff elects to refer this case to ludiaal arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11
(3) x I
Court or from avil action
of the California Rules of
This case is exempt from ludimal arbitration under rule 3 811
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): Exceeds siatutory limits.
('alif Rules of Conrt, I&ule 3.811(b)(8)
cM110IN 20ul 00211
.I111
CASE IVIANAGEIVIENT STATEIVIENT
PLAINTIFF/PETITIONER Edwarrl Punez, an individual CASE NUMBER
DEFENDANT/RESPONDENT Fire Insurance Exchange, et al. 19CECG302755
10 c Indicate the ADR process or processes that tiie paify or parfies are willing to pariicipeie
01,lieve agi cad to parhmpate in, or
have already parfimpated in (ciieck all ihai app/y and piovide the specified information)
The party or parties completing Itthe party or parties completing this form in the case have agreed to
this form are willing to participate m 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 aif that apply). stipulation):
[~ Mediation session not yet scheduled
Mediation session scheduted for (daie)
(1) Mediation
Agreed to complete mediation by (dafe)
~ Mediation completed on (date)
~X Settlement conference not yet scheduled
(2) Settlement
conference LxJ
~ Settlement conference scheduled for (daie):
Agreed to complete settlement conference by (date):
3
~ Settlement confeience completed on (date):
[ ] Neutral evaluation not yet scheduled
] Neutral evaluation scheduled for (dafe):
(3) Neutral evafuation
.] Agreed to complete neutral evaluation by (date)
]
Neutrat evaluation completed on (dare).
~ Judicial arbitration not yet scheduled
~ Judicial arbitratron scheduled for (date)
(4) Nonbinding iudicial
arbitration ~ Agreed to complete judicial arbitration by (daie).
Judicial arbitration completed on (date).
]
[ ] Pnvate arbitration not yet scheduled
] Pnvate arbitration scheduled for (date).
(5) Binding private
arbitration M Agreed to complete private arbitration by (daie):
Private arbitration completed on (date):
] ADR session not yet schedufed
ADR session scheduled for (date):
~
]
(6) Other (specify)
Agreed to complete ADR session by (date).
] ADR completed on (date)
CM-110 fsey 3 111
2011i P'e 3 of 5
CASE MANAGEMENT STATEMENT
PLAINTIFF/PETI I IONER Edward Fitnez, an iitdiviriusi CASE NutgSER
DEFENDANDREspoNDEN t Insurance Exchange, et al
Pii e I
0)C(!C() 02755
fnsurance
~
'11
a Insurance carrier, ifany for party filing this statemeni (name)
3
6
c ~
Reservation ofnishts Yes [ ] No
Coverage issues will significantly affect resolution of this case (explain)
12 Jurisdiction
Indicate any matters that may afFect the court's iurisdiction or processing of this case and descnbe the status
. ] Bankruptcy [~ Other (specify).
Status
13. Related cases, consolidation, and coordination
a [ ] There are comparvon, underlying, or related cases.
(1) Name of case
(2) Name of court
(3) Case number
(4) Status.
Additional cases are descnbed in Attachment 13a
b ] A motion to,'onsolidate [ j coordmate (name party)
will be filed by
14. Bifurcation
] The party or parties intend Io file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (spewfy mowng party, type of motion, and reasons):
15. Other motions
[ ]
type of motion,
The party or parties expect to file the following motions before tnal (specify moving party, and rssues)
1tk Discovery
a. M The party or parties have completed all discovery
b. ~x The following discovery will be completed by the date specified (descnbe aif anncipsted discovery):
Pa re Descriotion
Defendant Written discovery per code
Def'endant D)amitff s depositton per code
Defendant Third party depositions per code
c ~ The following discovery issues, including issues regarding the discovery of elertronically stored informahon, are
anticipated (specify).
cu i, 20ui
E 0*4 t5
110 IR2 ly CASE MANAGEMENT STATEMENT
CM-140
PLAINTIFF/PETITIONER. Edward Funez, an individual CASE NUMBER
DEFENDANT/REsPQNDENT: Fire Insurance Exchange, et al. 19CECG02755
17.
a. ~
Economic litigation
This is a hmited Owl 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 fo discovery or trial
should not apply to this case):
t8. Other issues
~ The party or parties request that the following additional matters be considered or determined at the case management
conference (specify)i
t9. Meet and confer
a. ~x The party or parties have met and conferred with all parties on
allsubjects required by rule 3.724 of the Cahfornia 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):
Iam 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, mcluding the written authority of the party where required.
Date: November 19, 2019
Connor M. Dav
OR PRINT NAME)
ECTYPE
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 IReu July I, 201 1I P 0 5 of 5
CASE MANAGEMENT STATEMENT
PROOF OF SERVICE
1 declare that 1 am over the age of 18 and not a party to the within-entitled action. 1 am employed
at Ferber Law, A Professional Corporation, and my business address is 2603 Camino Ramon, Suite 385,
San Ramon, California 94583.
On November 19, 2019, 1 served the within document(s):
CASE MANAGEMENT STATEMENT and NOTICE OF COURTCALL APPEARANCE
(X) VIA MAIL by placing a true copy in a sealed envelope with postage thereon fully prepaid in the
United States Mail at San Ramon, California addressed as shown below. 1 am readily familiar
with this firm's business practice for collection and processing of correspondence for mailing
with the United States Postal Service. 1 caused such sealed envelope with postage thereon fully
prepaid to be placed in the United States mail the same day as this declaration at San Ramon,
California, in the ordinary course of business. I am aware that on motion of party served, service
is presumed invalid if postal cancellation date or postage meter date is more than one day after the
10 date of deposit for mailing in affidavit.
11 ) VIA ELECTRONIC TRANSMISSION — 1 transmitted a PDF version of this document by
electronic mail to the parties identified below using the email addresses indicated.
12
) VIA FACSIMILE by transmitting the document(s) listed above to the fax number(s) set forth
13 below on this date before 5:00 p.m.
14 ) VIA OVERNIGHT DELIVERY by placing the documents listed above in a sealed envelope, in
a box regularly maintained by United Parcel Service, with delivery fees paid, at San Ramon,
15 California addressed as set forth below.
16 ) VIA HAND DELIVERY by personally delivering the document(s) listed above to the person(s)
at the address(es) set forth below.
17
J. Edward Kerley, Esq. Daniel V. Kohls, Esq.
18
Dylan L. Schaffer, Esq. Leighton B. Koberlein, Esq.
Yasineen Omidi, Esq. Hansen, Kohls, Sommer &
19
Kerley Schaffer LLP Jacob, LLP
1939 Harrison Street, ¹500 1520 Eureka Road, Ste. 100
20
Oakland, CA 94612 Roseville, CA 95661
21
Patrick S. Schoenburg, Esq.
Wood Smith Henning & Berman
22 LLP
7108 N. Fresno St., Ste. 250
23
Fresno, CA 93720
24
Executed on November 19, 2019, at San Ramon, California.
25 1 declare under penalty of perjury that the foregoing is true and correct.
26
27
(6uPiw
Christine Pierce
PL~p
28
Preview
CM-110 ATTORNEY OR PARI'YWDHOUTAI (¹ &ORIOEY e Stale de na bet a d add assi FOR COURT USE ONL Y Michel le IL I'erber (149929) Connor M. Day (233245) E-FILED Iderber Law, P C 11/19/2019 10:39 AM 2603 Camino RD&non, Suite 3II5 Superior Court of California SmT ka&non, CA 97I583 County of Fresno TEICPHONENO 925-355-9800 FAxNO (Opto al)925-263-1676 By: A. Rodriguez, Deputy E MAIL ADDRESS Itlniro ab 3» T C PA *'»' O» ~C» SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO STREET ADDRESS I130 n0n Streei I'DDRESS MAB ING c&TYANDzip coDEFresno, CA 93721 BRANCII NAME PLAINTIFF/PETITIONER Edward I uncs, an individual DEFENDANTLREsPDNDENT,I&ire Insurance I.xchange, et al. CASE NUMBER CASE MANAGEMENT STATEMENT (Check one): Ix I UNLIIVIITED CASE (Amount demanded M LIMITED CASE (Amount demanded is $ 25,000 19CECG02755 exceeds $ 25,000) or less) A CASE MANAGEMENT CONFERENCE is Date December 4, 2019 Time scheduled as follows 3:30 p.m. Address of court (if different frotn lhe address abave) Dept 402 Dfv'oom ~x Notice of Intent to Appear by Telephone, by (name): Connor M. Day INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one) a. I x] This statement is submitted by party (name) American Contractors Indemnity Company b. [ j This statement is submitted jointly by parties (nsmes). 2. Complaint and crass-complaint (to be answered by plaintiffs and cross-complainanls only) a. b. ~ The complaint was filed on (date)t The cross-complaint, if any, was filed on(dafe) 3 Service (la be answered by p/aintiffs and cross-romplainanls only) a. All patties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed b, I j The following parties named in the complaint or cross-complamt j (1) ~ have not been served (specify names and explain evhy not): (2) j 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 fallowing additional parties may be added (specify natnes, nature ofinvalvemenlin rase, they may be served): and date by which 4 Description of case a Type of case in ~x complaint ~ cross-complaint (Descnbe, including causes of action) Plaintifl'alleges insurance bad faith against Farmers Insurance, negligence against Service Masicr, and aciion on license bond against American Contractors Indemnity Company. Pan I to F Adoptdf Mand lotyu CalR ofr tl, J dtcl C I nnl ICabf inta CASE MANAGEMENT STATEIIENT j.egal I 372n-3 730 CM-110&Re J 2dltl Solut&t &ns. 4 Plus &71 PLAINTIFFIPETITIQNER Edward Fttnez, an individual CASk. NUIIBCN 19CECC&0275 5 DEFENDANTIRESPQNDLNT Fire Insui ance Exchange, el. aj 5 Provide a bnef stalement of the case including any damages (IF persor1ai in/ury damages are sought, specify the Nvury and damage'leaned, inchrdinrJ rnedrcai expenses io date (1ndicafe so1 iree and arnouni), esir1nated firture medical expense", Io I eammgs to dais,and fufure esiir11aled Iosiearrvngs IFequrlebiereliefissoughi, rfescnbe Ihenaiure oF reaeF) ih1. PlaintiFf has liled s cjaiin agamst the hcense bond issued by Amencan Contractors Indemnity Company to Benevento's Cleanmg dc Restoration Service, Inc. [ ] (If morespace is needed, ches)i this box and aifach a page designated as Affachmeni 48 ) Jury or noniury trial 5. The party or parties iequest reques1'ing a iury trial) ~x a lury tnal~ a noniury trial (If&nore than one party, provide the nan&e of each party 6. Trial date a LJ The tnal has been set for (dais) b. ~x No trial date has been set This case will be ready for trial wilhm 12 months of the date ofthe filing of the complaint (IF nof, exp/ain) c Dates on which parties or attorneys not be available for tnal (specify dates and explain reasons for unavailabriity) will 12/23/19 — I/6/20 Pzenlanned vacation I/27/20 - 2/7/20 Trial 2/14/20 - 2/25/20 Preplanrted vacation; 2/28/20 - 3/5/20 Trial; 3/23/20 — 4/3/20 Trial; 4/20/20 - 5/I/2(j Trial; 6/I/20 — 6/12/20 Trial; 6/29/20- 7/31/20 Preplanned vacation; 8/3/20 - 8/14/20 Trial 7 Estimated length of trial The party or parties estimate that the tnal take (check one) will a. jx] days (spervfy r1urnher).3-5 b. ~j hours (short causes) (specii'y): 8. Trial representation (to be answered for each party) The party or parties will be represented at tnalI x ) by the attorney or party listed m the caption L I by the following a Attorney b Firm. c Address d Telephone number. f. Fax number: Party represented ~ e. E-mail address: Additional representation is describedm Attachment 8 g. 0 ~ Preference to preference (specrfy code seclion) This case is entitled 10. Alternativedispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR informationpackage provided bythe court under rule3.221 for informationabout the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel x j has in rule 3 221 to the client and rewewed ADR options withthe ~ has not client provided the ADR information package identified (2) For self-represented parties partyj J has j I has not reviewed Ihe ADR information package ideniified in rule 3 221 b Referral to judicial arbitration or civil action mediation (if available) (1) j or to owl action This matter is sublect to mandatory judimal arbitration under Code of Cwil Procedure section 1141.11 mediation under Code of Civtl Procedure section 1775 3 because the amount in controversy does noi exceed Ihe statutory limit (2) ~ Plaintiff elects to refer this case to ludiaal arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11 (3) x I Court or from avil action of the California Rules of This case is exempt from ludimal arbitration under rule 3 811 mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): Exceeds siatutory limits. ('alif Rules of Conrt, I&ule 3.811(b)(8) cM110IN 20ul 00211 .I111 CASE IVIANAGEIVIENT STATEIVIENT PLAINTIFF/PETITIONER Edwarrl Punez, an individual CASE NUMBER DEFENDANT/RESPONDENT Fire Insurance Exchange, et al. 19CECG302755 10 c Indicate the ADR process or processes that tiie paify or parfies are willing to pariicipeie 01,lieve agi cad to parhmpate in, or have already parfimpated in (ciieck all ihai app/y and piovide the specified information) The party or parties completing Itthe party or parties completing this form in the case have agreed to this form are willing to participate m 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 aif that apply). stipulation): [~ Mediation session not yet scheduled Mediation session scheduted for (daie) (1) Mediation Agreed to complete mediation by (dafe) ~ Mediation completed on (date) ~X Settlement conference not yet scheduled (2) Settlement conference LxJ ~ Settlement conference scheduled for (daie): Agreed to complete settlement conference by (date): 3 ~ Settlement confeience completed on (date): [ ] Neutral evaluation not yet scheduled ] Neutral evaluation scheduled for (dafe): (3) Neutral evafuation .] Agreed to complete neutral evaluation by (date) ] Neutrat evaluation completed on (dare). ~ Judicial arbitration not yet scheduled ~ Judicial arbitratron scheduled for (date) (4) Nonbinding iudicial arbitration ~ Agreed to complete judicial arbitration by (daie). Judicial arbitration completed on (date). ] [ ] Pnvate arbitration not yet scheduled ] Pnvate arbitration scheduled for (date). (5) Binding private arbitration M Agreed to complete private arbitration by (daie): Private arbitration completed on (date): ] ADR session not yet schedufed ADR session scheduled for (date): ~ ] (6) Other (specify) Agreed to complete ADR session by (date). ] ADR completed on (date) CM-110 fsey 3 111 2011i P'e 3 of 5 CASE MANAGEMENT STATEMENT PLAINTIFF/PETI I IONER Edward Fitnez, an iitdiviriusi CASE NutgSER DEFENDANDREspoNDEN t Insurance Exchange, et al Pii e I 0)C(!C() 02755 fnsurance ~ '11 a Insurance carrier, ifany for party filing this statemeni (name) 3 6 c ~ Reservation ofnishts Yes [ ] No Coverage issues will significantly affect resolution of this case (explain) 12 Jurisdiction Indicate any matters that may afFect the court's iurisdiction or processing of this case and descnbe the status . ] Bankruptcy [~ Other (specify). Status 13. Related cases, consolidation, and coordination a [ ] There are comparvon, underlying, or related cases. (1) Name of case (2) Name of court (3) Case number (4) Status. Additional cases are descnbed in Attachment 13a b ] A motion to,'onsolidate [ j coordmate (name party) will be filed by 14. Bifurcation ] The party or parties intend Io file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (spewfy mowng party, type of motion, and reasons): 15. Other motions [ ] type of motion, The party or parties expect to file the following motions before tnal (specify moving party, and rssues) 1tk Discovery a. M The party or parties have completed all discovery b. ~x The following discovery will be completed by the date specified (descnbe aif anncipsted discovery): Pa re Descriotion Defendant Written discovery per code Def'endant D)amitff s depositton per code Defendant Third party depositions per code c ~ The following discovery issues, including issues regarding the discovery of elertronically stored informahon, are anticipated (specify). cu i, 20ui E 0*4 t5 110 IR2 ly CASE MANAGEMENT STATEMENT CM-140 PLAINTIFF/PETITIONER. Edward Funez, an individual CASE NUMBER DEFENDANT/REsPQNDENT: Fire Insurance Exchange, et al. 19CECG02755 17. a. ~ Economic litigation This is a hmited Owl 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 fo discovery or trial should not apply to this case): t8. Other issues ~ The party or parties request that the following additional matters be considered or determined at the case management conference (specify)i t9. Meet and confer a. ~x The party or parties have met and conferred with all parties on allsubjects required by rule 3.724 of the Cahfornia 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): Iam 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, mcluding the written authority of the party where required. Date: November 19, 2019 Connor M. Dav OR PRINT NAME) ECTYPE (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 IReu July I, 201 1I P 0 5 of 5 CASE MANAGEMENT STATEMENT PROOF OF SERVICE 1 declare that 1 am over the age of 18 and not a party to the within-entitled action. 1 am employed at Ferber Law, A Professional Corporation, and my business address is 2603 Camino Ramon, Suite 385, San Ramon, California 94583. On November 19, 2019, 1 served the within document(s): CASE MANAGEMENT STATEMENT and NOTICE OF COURTCALL APPEARANCE (X) VIA MAIL by placing a true copy in a sealed envelope with postage thereon fully prepaid in the United States Mail at San Ramon, California addressed as shown below. 1 am readily familiar with this firm's business practice for collection and processing of correspondence for mailing with the United States Postal Service. 1 caused such sealed envelope with postage thereon fully prepaid to be placed in the United States mail the same day as this declaration at San Ramon, California, in the ordinary course of business. I am aware that on motion of party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after the 10 date of deposit for mailing in affidavit. 11 ) VIA ELECTRONIC TRANSMISSION — 1 transmitted a PDF version of this document by electronic mail to the parties identified below using the email addresses indicated. 12 ) VIA FACSIMILE by transmitting the document(s) listed above to the fax number(s) set forth 13 below on this date before 5:00 p.m. 14 ) VIA OVERNIGHT DELIVERY by placing the documents listed above in a sealed envelope, in a box regularly maintained by United Parcel Service, with delivery fees paid, at San Ramon, 15 California addressed as set forth below. 16 ) VIA HAND DELIVERY by personally delivering the document(s) listed above to the person(s) at the address(es) set forth below. 17 J. Edward Kerley, Esq. Daniel V. Kohls, Esq. 18 Dylan L. Schaffer, Esq. Leighton B. Koberlein, Esq. Yasineen Omidi, Esq. Hansen, Kohls, Sommer & 19 Kerley Schaffer LLP Jacob, LLP 1939 Harrison Street, ¹500 1520 Eureka Road, Ste. 100 20 Oakland, CA 94612 Roseville, CA 95661 21 Patrick S. Schoenburg, Esq. Wood Smith Henning & Berman 22 LLP 7108 N. Fresno St., Ste. 250 23 Fresno, CA 93720 24 Executed on November 19, 2019, at San Ramon, California. 25 1 declare under penalty of perjury that the foregoing is true and correct. 26 27 (6uPiw Christine Pierce PL~p 28