Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
David D. Schneider 211498
Dowling Aaron Incorporated
8080 N. Palm Avenue, Third Floor
E-FILED
11/20/2019 5:22 PM
Fresno, CA 93711
TELEPHONE NO: (559) 432-4500 FAX NO (559) 432-4590
(Optional)
Superior Court of California
E-MAIL ADDRESS (Optional): dSChneider@dOWlingaaron
County of Fresno
By: A. Rodriguez, Deputy
Omni Women's Health Medical Group, Inc.
ATTORNEY FOR (Name)
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Fresno
srnEET ADDREss:1130 "O" Street
1130 "O" Street
MAILING ADDREss:
Fresno 93721
CITY AND ZIP CODE:
BRANCH NAME:
PLAINTIFF/PETITIONER: OMNI WOMEN'S HEALTH MEDICAL GROUP, INC.
DEFENDANT/RESPONDENT: HAROLD GROOMS, M.D.
CASE MANAGEMENT STATEMENT CASE NUMBER:
19CECG02730
(Check one): D UNLIMITED CASE D LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: December 5, 2019 Time: 3:30 p.m. Dept.: 402 Div.: Room:
Address of court (if different from the address above):
D Notice of Intent to Appear by Telephone, by (name): David D. Schneider
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. � This statement is submitted by party (name): OMNI WOMEN'S HEALTH MEDICAL GROUP, INC.
b. D This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): July 29, 2019
b. D The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. D All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. � The following parties named in the complaint or cross-complaint
(1) � have not been served (specify names and explain why not): Harold Grooms, M.D.: Plaintiff's counsel
and Defendant's counsel discussed potentially submitting this dispute to arbitration, but did not come to an
agreement to do so. Plaintiff is arranging for service to be effectuated on Defendant and expects that
service will be complete prior to the Case Management Conference
(2) D have been served but have not appeared and have not been dismissed (specify names):
(3) D have had a default entered against them (specify names):
c. D 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 � complaint D cross-complaint (Describe, including causes of action):
BREACH OF FIDUCIARY DUTY; BREACH OF WRITTEN CONTRACT; CONSTRUCTIVE TRUST; UNJUST
ENRICHMENT; FRAUD AND DECEIT - SUPPRESSION AND CONCEALMENT OF MATERIAL FACTS
Pa e 1 of 5
Form Adopted for Mandatory Use
Judicial Council of California
CASE MANAGEMENT STATEMENT Cal. Rules of Court,
rules 3 720-3 730
CM-110 [Rev. July 1, 2011] www.courts�ca.gov
cM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: OMNI WOMEN'S HEALTH MEDICAL GROUP, lNC.
19C8CG02724
-OrrrruonruT/RESPONDENT: HAROLD GROOMS, M.D.
4. b, Provide a brief statement of the case, includingany damages . (lf personal
injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, /osf
earnings to date, and estimated future lost eamings. lf equitable
relief is sought, describethe nature of the relief.)
Defendant was formerly a shareholder, officer, director, physician and President of Plaintiff.While operating in
those roles, Defendant engaged in a series of actions that resulted in damage to Plaintiff.
n (frnore space rs needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request fi a jury trial ! a nonjury trial. (lf more than one party, provide the name of each pafty
requesting a jury trial):
6. Trial date
a. n The trial has been set for (dafe):
b. X 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
(rT
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify
dates and explain reasons for unavailability):
April & May 2020 (trial prep. & trial, Fresno County); July & August 2020 (lrial prep. & trial, Fresno County);
December 2020-Feb. 2021 (trial & prep., Los Angeles)
7. Estimated length of trial
The party or partiesestimate that the trial will lake (check
one):
a. X days (specify number): Five
b. n hours (short causes) (specify):
8. Trial representation (to be answered for each paftv)
The party or parties will be represented at trialX caption
by the attorney or party listed in the n by the following
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: S. Party represented
n Additional representation is described in Attachment 8.
9. Preference
n This case is entitledto preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are availablein different courts and communities; read
the ADR information package provided about the processes
by the court under rule 3.221 for information availablethrough the
court and community programs in this case.
(1) For parties represented by counsel: Counsel X has n has not provided the ADR information package identifìed
ADR options
in rule 3.221 to the client and reviewed with the client.
(2) Forself-representedparties: Party n has n nasnotreviewedtheADRinformationpackageidentifiedinrule3.22l.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) n Thismatterissubjecttomandatoryjudicial arbitrationunderCodeof Civil Proceduresection 1141 .ll ortocivilaction
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) n elects to refer this case to judicial arbitration
Plaintiff and agrees to limit recovery to the amountspecified in Code of
Civil Procedure section 1141 .11.
(3) n This case is exempt from judicial arbitration
under rule 3.81 1 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 el seq. (specfy exemption):
CM-1 10 [Rev. July 1, 201 1] Page 2 of 5
CASE MANAGEMENT STATEMENT
Amer¡c¡n LegalNet, Inc.
@
wHrv,-Es¡¡r0s-W-p-r.kElsrv-sqm
cM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: OMNI WOMEN'S HEALTH MEDICAL GROUP, INC
19C8CG02724
ñrrruoRnr/RESpoNDENT: HARoLD GRooMS, M.D.
10. c. lndicate 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 partiescompleting lf 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,
participatein the following ADR indicatethe status of the processes (aftach a copy of the parties' ADR
processes (check all that apply): stipulation):
N Mediation session not yet scheduled
n Mediation session scheduled for (dafe);
(1) Mediation X
tr Agreed to complete mediation by (dafe)
n Mediation completed on (dafe):
X Settlement conference not yet scheduled
(2) Settlement n Settlement conference scheduled for (dafe);
conference
n Agreed to complete settlement conference by (dafe)
tr Settlement conference completed on (dafe):
I Neutral evaluation not yet scheduled
n Neutral evaluation scheduled for (dafe):
(3) Neutral evaluation
I Agreed to complete neutral evaluation by (date):
n Neutral evaluation completed on (dafe):
n Judicial arbitration not yet scheduled
(4) Nonbinding judicial n Judicial arbitration scheduledfor (dafe);
arbitration tr
n Agreed to complete judicial arbitration by (date):
n Judicialarbitrationcompleted on (dafe):
n Private arbitration not yet scheduled
(5) Binding private n Private arbitration scheduled 'for (date):
arbitration
n Agreed to complete private arbitration by (date):
n Private arbitration completed on (dafe):
n ADR session not yet scheduled
(6) Other (specify) f ADR session scheduled for (date):
n
n Agreed to complete ADR session by (dafe)
n ADR completed on (dafe):
July I , 201 1]
CM-1 10 [Rev. Page 3 of 5
CASE MANAGEMENT STATEMENT
Âmerican LegâlNet, Inc.
@
www,F_o-¡¡¡slVqrkFlow.ç¡m
cM-110
CASE NUMBER:
PLAINTIFF/PErlrloNER: OMNI WOMEN'S HEALTH MEDICAL GROUP, INC
19CF-CG02724
ierEruonrulRESpoNDENT: HARoLD GRooMS, M.D.
11. lnsurance
a. n lnsurance carrier, if any, for party filing this statemenl (name):
b. Reservation of rights: n Yes n ¡lo
c. n Coverage issues will significantlyaffect resolutionof this case (explain)
12. Jurisdiction
lndicate any matters that may affect the couft's jurisdiction or processing
of this case and describe the status.
n Bankruptcy n Oldr'er (specify):
Status:
13. Related cases, consolidation, and coordination
a. n There are companion, underlying, or relatedcases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
tr Additional cases are described in Attachment 13a.
b. ¡ A motion to t] consolidate n coordinate will be filed by (name pañy)
14. Bifurcation
n The party or parties intend to file a motion
for an order bifurcating, severing, or coordinating
the following issues or causes of
action (specifymoving pafty, type of motion, and reasons):
15. Other motions
n The party or parties expect to fìle the following motions before trial (specify
moving pafty, type of motion, and issues)
16. Discovery
a. n fne party or parties have completed all discovery.
b n The following discovery will be completed by the date specifìed (describe all anticipated discovery):
Party Description Date
Plaintiff Written Discovery Per Code
Plaintiff Non-Expert Depositions Per Code
Plaintiff Expert Depositions Per Code
c. n ffie following discovery issues,including issues regarding the discovery of electronically stored information,
are
anticipated (specify)
:
CM¡10 [Rev. July 1,2011] Pago 4 of 5
CASE MANAGEMENT STATEMENT
Amer¡c{n LegalNet, Inc.
@
uu¡r...8,o...ün¡,\ry,0¡kF,l,o..w,c,o...m
cM-110
CASE NUMBER:
PLAINTIFF/PErlrloNER: OMNI WOMEN'S HEALTH MEDICAL GROUP, INC
19CECGO2724
oereruonrulRESPoNDENT: HAROLD GROOMS, M.D.
17. Economic litigation
a. tr fn¡s is a limitedcivil 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. n fn¡s 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 litigationprocedures relating to discoveryor trial
should not apply to this case):
18. Other issues
X The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meetand confer
a. I fne party or parties have met and conferred with all parties on all subjects required
by rule 3.724 of lhe California Rules of
Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of lhe California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any): I
I am completely familiar with this case and will be fully prepared
to discussthe status of discovery and alternativedispute resolution,
as well as other issues raised by this statement, and will possessthe authorityto enter into stipulations
on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: November 20,2019
David D. Schneider
(TYPE OR PRINT NAME) OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATUREOF PARTY OR ATTORNEY)
fl nOOitional signatures are attached.
CMI 1 0 [Rev. July 1,20111 Pagå 5 of 5
CASE MANAGEMENT STATEMENT
American L€galNet, Inc.
@
l¡yy.Form sWq¡kÌlq..td,,ç.9m
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA )
) SS
J COUNTY OF FRESNO )
4 I am a citizen of the United States and a resident of the County aforesaid; I am over the age
of eighteen (18) years and not aparty to the within-entitled action. My business address is Dowling
5 Aaron Incorporated, 8080 N. Palm Avenue, Third Floor, Fresno, California 937II. On November
20,2079,I served the within document(s):
6
CASE MANAGEMENT STATEMENT
7
BY FAX: By transmitting via facsimile transmission the document(s) listed above to the
8 fax number(s) set forth below on this date before 5:00 p.m.
9 BY HAND: By personally delivering the document(s) listed above to the person(s) at the
address(es) set forth below.
10
BY MAIL: By placing the document(s) listed above in a sealed envelope with postage
11 thereon fully prepaid, in the United States mail at Fresno, California, addressed as set forth
below.
I2
BY E-MAIL [when indicated]
13
BY OVERNIGHT COURIER: By causing the document(s) listed above to be picked up
t4 by an overnight courier service company for delivery to the address(es) listed below on the
next business day.
15
Charles Doerksen
t6 DOERKSEN TAYLOR
724 "P" Street, Suite 29
I7 Fresno, CA 93721
PH: (ss9) 233-3434
18 FAX (ss9) 233-3939
E-mail: cldlÐdoerksentaylor.com
t9
Attorneys for Defendant, HAROLD
20 GROOMS, M.D.
2l I am readily familiar with the firm's practices of collection and processing of
correspondence for mailing. Under that practice, itwould be deposited with the United States
22 Postal Service on that same day with postage thereon fully prepaid in the ordinary course of
business. I am aware that on motion of the party served, service is presumed invalid if postal
23 cancellation date or postage meter date is more than one day after date of deposit for mailing in
affidavit. I declare under penalfy of perjury under the laws of the State of California that
24 the foregoing is true and correct. Executed ovember 20, 20 9, at Fresno, alifornia.
25
George
0I8407-000002 -02770878-|
26
27
28
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY David D. Schneider 211498 Dowling Aaron Incorporated 8080 N. Palm Avenue, Third Floor E-FILED 11/20/2019 5:22 PM Fresno, CA 93711 TELEPHONE NO: (559) 432-4500 FAX NO (559) 432-4590 (Optional) Superior Court of California E-MAIL ADDRESS (Optional): dSChneider@dOWlingaaron County of Fresno By: A. Rodriguez, Deputy Omni Women's Health Medical Group, Inc. ATTORNEY FOR (Name) SUPERIOR COURT OF CALIFORNIA, COUNTY OF Fresno srnEET ADDREss:1130 "O" Street 1130 "O" Street MAILING ADDREss: Fresno 93721 CITY AND ZIP CODE: BRANCH NAME: PLAINTIFF/PETITIONER: OMNI WOMEN'S HEALTH MEDICAL GROUP, INC. DEFENDANT/RESPONDENT: HAROLD GROOMS, M.D. CASE MANAGEMENT STATEMENT CASE NUMBER: 19CECG02730 (Check one): D UNLIMITED CASE D LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: December 5, 2019 Time: 3:30 p.m. Dept.: 402 Div.: Room: Address of court (if different from the address above): D Notice of Intent to Appear by Telephone, by (name): David D. Schneider INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. � This statement is submitted by party (name): OMNI WOMEN'S HEALTH MEDICAL GROUP, INC. b. D This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): July 29, 2019 b. D The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. D All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. � The following parties named in the complaint or cross-complaint (1) � have not been served (specify names and explain why not): Harold Grooms, M.D.: Plaintiff's counsel and Defendant's counsel discussed potentially submitting this dispute to arbitration, but did not come to an agreement to do so. Plaintiff is arranging for service to be effectuated on Defendant and expects that service will be complete prior to the Case Management Conference (2) D have been served but have not appeared and have not been dismissed (specify names): (3) D have had a default entered against them (specify names): c. D 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 � complaint D cross-complaint (Describe, including causes of action): BREACH OF FIDUCIARY DUTY; BREACH OF WRITTEN CONTRACT; CONSTRUCTIVE TRUST; UNJUST ENRICHMENT; FRAUD AND DECEIT - SUPPRESSION AND CONCEALMENT OF MATERIAL FACTS Pa e 1 of 5 Form Adopted for Mandatory Use Judicial Council of California CASE MANAGEMENT STATEMENT Cal. Rules of Court, rules 3 720-3 730 CM-110 [Rev. July 1, 2011] www.courts�ca.gov cM-110 CASE NUMBER: PLAINTIFF/PETITIONER: OMNI WOMEN'S HEALTH MEDICAL GROUP, lNC. 19C8CG02724 -OrrrruonruT/RESPONDENT: HAROLD GROOMS, M.D. 4. b, Provide a brief statement of the case, includingany damages . (lf personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, /osf earnings to date, and estimated future lost eamings. lf equitable relief is sought, describethe nature of the relief.) Defendant was formerly a shareholder, officer, director, physician and President of Plaintiff.While operating in those roles, Defendant engaged in a series of actions that resulted in damage to Plaintiff. n (frnore space rs needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request fi a jury trial ! a nonjury trial. (lf more than one party, provide the name of each pafty requesting a jury trial): 6. Trial date a. n The trial has been set for (dafe): b. X 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 (rT not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): April & May 2020 (trial prep. & trial, Fresno County); July & August 2020 (lrial prep. & trial, Fresno County); December 2020-Feb. 2021 (trial & prep., Los Angeles) 7. Estimated length of trial The party or partiesestimate that the trial will lake (check one): a. X days (specify number): Five b. n hours (short causes) (specify): 8. Trial representation (to be answered for each paftv) The party or parties will be represented at trialX caption by the attorney or party listed in the n by the following a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: S. Party represented n Additional representation is described in Attachment 8. 9. Preference n This case is entitledto preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are availablein different courts and communities; read the ADR information package provided about the processes by the court under rule 3.221 for information availablethrough the court and community programs in this case. (1) For parties represented by counsel: Counsel X has n has not provided the ADR information package identifìed ADR options in rule 3.221 to the client and reviewed with the client. (2) Forself-representedparties: Party n has n nasnotreviewedtheADRinformationpackageidentifiedinrule3.22l. b. Referral to judicial arbitration or civil action mediation (if available). (1) n Thismatterissubjecttomandatoryjudicial arbitrationunderCodeof Civil Proceduresection 1141 .ll ortocivilaction mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) n elects to refer this case to judicial arbitration Plaintiff and agrees to limit recovery to the amountspecified in Code of Civil Procedure section 1141 .11. (3) n This case is exempt from judicial arbitration under rule 3.81 1 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 el seq. (specfy exemption): CM-1 10 [Rev. July 1, 201 1] Page 2 of 5 CASE MANAGEMENT STATEMENT Amer¡c¡n LegalNet, Inc. @ wHrv,-Es¡¡r0s-W-p-r.kElsrv-sqm cM-110 CASE NUMBER: PLAINTIFF/PETITIONER: OMNI WOMEN'S HEALTH MEDICAL GROUP, INC 19C8CG02724 ñrrruoRnr/RESpoNDENT: HARoLD GRooMS, M.D. 10. c. lndicate 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 partiescompleting lf 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, participatein the following ADR indicatethe status of the processes (aftach a copy of the parties' ADR processes (check all that apply): stipulation): N Mediation session not yet scheduled n Mediation session scheduled for (dafe); (1) Mediation X tr Agreed to complete mediation by (dafe) n Mediation completed on (dafe): X Settlement conference not yet scheduled (2) Settlement n Settlement conference scheduled for (dafe); conference n Agreed to complete settlement conference by (dafe) tr Settlement conference completed on (dafe): I Neutral evaluation not yet scheduled n Neutral evaluation scheduled for (dafe): (3) Neutral evaluation I Agreed to complete neutral evaluation by (date): n Neutral evaluation completed on (dafe): n Judicial arbitration not yet scheduled (4) Nonbinding judicial n Judicial arbitration scheduledfor (dafe); arbitration tr n Agreed to complete judicial arbitration by (date): n Judicialarbitrationcompleted on (dafe): n Private arbitration not yet scheduled (5) Binding private n Private arbitration scheduled 'for (date): arbitration n Agreed to complete private arbitration by (date): n Private arbitration completed on (dafe): n ADR session not yet scheduled (6) Other (specify) f ADR session scheduled for (date): n n Agreed to complete ADR session by (dafe) n ADR completed on (dafe): July I , 201 1] CM-1 10 [Rev. Page 3 of 5 CASE MANAGEMENT STATEMENT Âmerican LegâlNet, Inc. @ www,F_o-¡¡¡slVqrkFlow.ç¡m cM-110 CASE NUMBER: PLAINTIFF/PErlrloNER: OMNI WOMEN'S HEALTH MEDICAL GROUP, INC 19CF-CG02724 ierEruonrulRESpoNDENT: HARoLD GRooMS, M.D. 11. lnsurance a. n lnsurance carrier, if any, for party filing this statemenl (name): b. Reservation of rights: n Yes n ¡lo c. n Coverage issues will significantlyaffect resolutionof this case (explain) 12. Jurisdiction lndicate any matters that may affect the couft's jurisdiction or processing of this case and describe the status. n Bankruptcy n Oldr'er (specify): Status: 13. Related cases, consolidation, and coordination a. n There are companion, underlying, or relatedcases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: tr Additional cases are described in Attachment 13a. b. ¡ A motion to t] consolidate n coordinate will be filed by (name pañy) 14. Bifurcation n The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specifymoving pafty, type of motion, and reasons): 15. Other motions n The party or parties expect to fìle the following motions before trial (specify moving pafty, type of motion, and issues) 16. Discovery a. n fne party or parties have completed all discovery. b n The following discovery will be completed by the date specifìed (describe all anticipated discovery): Party Description Date Plaintiff Written Discovery Per Code Plaintiff Non-Expert Depositions Per Code Plaintiff Expert Depositions Per Code c. n ffie following discovery issues,including issues regarding the discovery of electronically stored information, are anticipated (specify) : CM¡10 [Rev. July 1,2011] Pago 4 of 5 CASE MANAGEMENT STATEMENT Amer¡c{n LegalNet, Inc. @ uu¡r...8,o...ün¡,\ry,0¡kF,l,o..w,c,o...m cM-110 CASE NUMBER: PLAINTIFF/PErlrloNER: OMNI WOMEN'S HEALTH MEDICAL GROUP, INC 19CECGO2724 oereruonrulRESPoNDENT: HAROLD GROOMS, M.D. 17. Economic litigation a. tr fn¡s is a limitedcivil 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. n fn¡s 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 litigationprocedures relating to discoveryor trial should not apply to this case): 18. Other issues X The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meetand confer a. I fne party or parties have met and conferred with all parties on all subjects required by rule 3.724 of lhe California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of lhe California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): I I am completely familiar with this case and will be fully prepared to discussthe status of discovery and alternativedispute resolution, as well as other issues raised by this statement, and will possessthe authorityto enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: November 20,2019 David D. Schneider (TYPE OR PRINT NAME) OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATUREOF PARTY OR ATTORNEY) fl nOOitional signatures are attached. CMI 1 0 [Rev. July 1,20111 Pagå 5 of 5 CASE MANAGEMENT STATEMENT American L€galNet, Inc. @ l¡yy.Form sWq¡kÌlq..td,,ç.9m 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA ) ) SS J COUNTY OF FRESNO ) 4 I am a citizen of the United States and a resident of the County aforesaid; I am over the age of eighteen (18) years and not aparty to the within-entitled action. My business address is Dowling 5 Aaron Incorporated, 8080 N. Palm Avenue, Third Floor, Fresno, California 937II. On November 20,2079,I served the within document(s): 6 CASE MANAGEMENT STATEMENT 7 BY FAX: By transmitting via facsimile transmission the document(s) listed above to the 8 fax number(s) set forth below on this date before 5:00 p.m. 9 BY HAND: By personally delivering the document(s) listed above to the person(s) at the address(es) set forth below. 10 BY MAIL: By placing the document(s) listed above in a sealed envelope with postage 11 thereon fully prepaid, in the United States mail at Fresno, California, addressed as set forth below. I2 BY E-MAIL [when indicated] 13 BY OVERNIGHT COURIER: By causing the document(s) listed above to be picked up t4 by an overnight courier service company for delivery to the address(es) listed below on the next business day. 15 Charles Doerksen t6 DOERKSEN TAYLOR 724 "P" Street, Suite 29 I7 Fresno, CA 93721 PH: (ss9) 233-3434 18 FAX (ss9) 233-3939 E-mail: cldlÐdoerksentaylor.com t9 Attorneys for Defendant, HAROLD 20 GROOMS, M.D. 2l I am readily familiar with the firm's practices of collection and processing of correspondence for mailing. Under that practice, itwould be deposited with the United States 22 Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal 23 cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. I declare under penalfy of perjury under the laws of the State of California that 24 the foregoing is true and correct. Executed ovember 20, 20 9, at Fresno, alifornia. 25 George 0I8407-000002 -02770878-| 26 27 28