Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY
(Name, Stale Bar number, and address): FOR COURT USE ONLY
Karen K. Gill,SBN 296365 / Lisa M. Horton. SBN 268601
SAGASER, WATKINS & WIELAND, PC
E-FILED
5260 North Palm Avenue, Suite 400, Fresno, CA 93704 4/21/2020 10:44 AM
TELEPHONE No; (559)421-7000 FAX No. (559) 473-1483
(OpHanaI):
Superior Court of California
E-MAILADDRESS karen@sw2law.com
(Optional): /Iisa@sw21aw.com County of Fresno
JASWINDER BHULLAR
ATTORNEY FORWame): Plaintiff,
By: A. Ramos, Deputy
SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F FRESNO
STREETADDRESS:1130 "O" Street
1130 "Q" Street
MAILING ADDRESS:
CITYAND CODE:
ZIP Fresno, CA 93721
BRANCH NAME B.F. Sisk Courthouse
PLAINTIFF/PETITIONER: Jaswinder Bhullar
DEFENDANTIRESPONDENT: Chooljian Brothers Packing Company, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE [:1 LIMITED CASE 190ECGOS435
(Amount demanded (Amount demanded is$25,000
exceeds $25,000) or iess)
A CASE MANAGEMENT CONFERENCE isscheduled as follows:
Date: 05/06/2020 Time: 3:30 pm Dept: 402 Div.: Room:
Address of court from the address above):
different
(if
Notice of Intent to Appear by Telephone, by (name): Lisa M. Horton
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a.
b. E This statement
This statement
is
is
submitted by party (name): Jaswinder Bhullar
Plaintiff,
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):09/20/2019
b. CI The cross-complaint, any,
if was filedon (date):
3,
a.
b.
D
Service
D
(tobe answered by plaintiffs and cross—comp/ainants
named
All parties
The
in
named
following parties in
only)
the complaint and cross-complaint have been served, have appeared, 0r have been dismissed.
the complaint or cross-complaint
(1) [:3 have not been served (specify names and explain why not):
(2) [2:] have been served but have not appeared and have not been dismissed (specify names):
Chooljian Brothers Packing Company, Michael H. Chooljian, Individuany, Does 1—10
(3) [:1 have had a default entered against them (specify names):
c. E] The may be added
following additional parties (specifynames, nature ofinvo/vementin case, and date by which
they may be served):
4. Description of ca§e
3‘ Type Ofcase m complaint E cross-complaint (Describe, including causes ofaction):
Breach of Contract, Breach 0fthe Implied Covenant of Good Faith and Fair Deatings, Fraudulent Concealment,
Fraudulent Misrepresentation, Conversion, Unjust Enrichment, and Unfair Business Practices.
Page
1 of 5
Mandatory Use
Form Adopted
for
Judicial Council of CaIiiomia
CASE MANAGEMENT STATEMENT Cal. Rules of Court,
3.7204730
rules
0M4 10 (Rev.
July
1,201 1] www.coun’sfiagov
CM-110
CASENUMBER
Jaswinder Bhuuar
_ PLAINTIFF/PETITIONER:
.. .
19CECG03435
DEFENDANT/RESPONDENT: Choolpan Brothers Packing Company, etal.
4. b4 Provide a brief statement 0f the case, including any damages. (lfpersona/ injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
On the January 12, 2019 the parties entered into a contract to pay Plaintiff $2,900 per ton, as—is over the scale
price for his organic raisins.Plaintiff delivered a total of 154,384pounds (77.192 tons). On 0r around May 9, 2019
Defendants paid $40,000.00, and have been making sporadic payments since then, but owe an
still outstanding
balance.
E (/fmore space
Jury or nonjury trial
isneeded, check box and attach a page designated as Attachment 4b.)
this
The party or parties request a jurytrial E] a nonjurytrial. name
(/fmore than one pan‘y, provide the of each party
requesting a jury
trial):
Trial date
a. E: The has been setfor
trial (date):
b. No date has been
trial set.This case willbe ready 12 months of the date of the
for trial within of the complaint
filing (if
not, explain):
c. Dates on which parties or attorneys
willnot be available for
trial(specify datesand explain reasonsfor unavailability):
Estimated length of trial
The party or parties estimate that the take (check one):
trial will
a. days (specify number): 2
b. E3 hours (short causes) (specify):
.
The
a.
party or parties
Attorney:
will
be answered
Trial representation (to for
be represented attrial E
each party)
by the attorney or party the caption
listed in E by the following:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
E
e. E-mail address:
Additional representation
isdescribed inAttachment 8.
g. Party represented:
Preference
E] This caseis code
entitled to preference (specify section):
104 Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR for information about the processes available through the
information package provided by the court under rule 3.221
courtand community programs case.
in this
(1) For parties represented by counsel: Counsel has :1 has not provided theADR information package identified
in rule ADR options with
3.221 to the client and reviewed theclient.
(2) For seIf—representedparties: PartyE has [:3 has not
action mediation
reviewed the ADR informationpackage identified 3.221.
in rule
b. Referral to judicial arbitration or
civil available).
(if
(1) This matter is sub'ect to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutorylimit‘
Code
(2)[j case to
Plaintiff elects to refer this and agrees
judicial arbitration recovery to the amount specified
to limit in of
CivilProcedure section 1141.11.
(3)E ofthe California Rules of Courtor from
This case is exempt from judicial arbitration under rule 3.811
mediation under Code 0f Civil Procedure section 1775 et seq. (specify exemption):
action
civil
Page 2 of5
CM-110 2011]
[Rev. July
1,
CASE MANAGEMENT STATEMENT
CM-1 10
CASE NUMBER:
PLAINTIFF/PETITIONER: Jaswinder Bhullar
1QCECG03435
DEFENDANT/RESPONDENTI Chooljian Brothers Packing Company, etal.
10. c. Indicate theADR process in,have agreed
or processes that the party or parties are willing t0 participate to participate or
in,
have already participated in (check all that apply and provide the specified information):
The party or parties completing Ifthe party or parties completing this form in the case have agreed to
thisform are willing to participatein or have already completed an ADR process or processes,
ADR
participate in the following indicate the status of the processes (attach a copy of the parties'ADR
processes (check allthat apply):stipulation):
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1)Mediation
[:1 DUDE
Agreed t0compIete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
Settlement conference scheduled for (date):
(2)Settlement
DUDE
conference
Agreed tocomplete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation DUDE
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
scheduled
Judicial arbitration not yet
scheduled
Judicial arbitration for (date):
(4) Nonbinding judicial
DUDE
arbitration
Agreed to complete by (date):
judicial arbitration
completed on
Judicial arbitration (date):
Private arbitration not yet scheduled
9/28/2020
Private arbitration scheduled for (date):
(5) Binding private
DEED
arbitration Agreed complete private
to arbitrationby (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
(6)Other (specify): DUDE
Agreed tocomplete ADR session by(date):
ADR completed on (date):
Page3of5
CM—11O 201
[Rev. July 1]
CASE MANAGEMENT STATEMENT
1,
CM—1 1 0
CASE NUMBER:
PLAINTIFF/PETITIONER: Jaswinder Bhuuar
.. .
1QCECG03435
DEFENDANT/RESPONDENT; Chooljlan Brothers Packing Company, et al.
11. Insurance
a. E] Insurance carrier,
ifany, for party filing this statement (name):
E] E3 No
b.
CA EReservation ofrights:
Coverage
Yes
case
issues will significantly affect resolution of this
(explain):
12. Jurisdiction
Indicate
[:3
any matters
Bankruptcy E
thatmay
Other (specify):
case and describe the
affect the court's jurisdiction or processing of this status.
Status:
13.
a‘ E
Related cases, consolidation, and coordination
There are companion, underlying, or related cases.
(1)Name of case:
(2)Name of court
(3)Case number:
(4) Status:
b.
E
E:
Additional cases are described
A motion to D
in
consolidate
Attachment 13a.
E coordinate willbe filed by (name party):
14.Bifurcation
[:1 The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
moving party, type of motion, and reasons):
action (specify
15.Other motions
E: The party 0r parties expect to the following motions before
file trial(specifymoving party, type ofmotion, and issues):
16. Discovery
a. C] The party or partieshave completed alldiscovery.
b. The following discovery
willbe completed by the date specified (describe
allanticipated discovery):
Party Description Date
Plaintiff Written Discovery Per Code
Plaintiff Depositions Per Code
Defendant Written Discovery Per Code
Defendant Depositions Per Code
c. E3 The issues, including issues regarding the discovery of electronically stored information, are
following discovery
anticipated
(specify):
Page 4 °f5
CM-11O[Rev. July 1, 2011]
CASE MANAGEMENT STATEMENT
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Jaswinder Bhullar
— 19CECG03435
DEFENDANT/RESPONDENT; ChOOljian Brothers PaCking company, et al.
17.
a. E
Economic litigation
This is civil case (i.e., the amount demanded is $25,000 or
a limited
Procedure sections 90-98 will apply to this case.
less)and the economic procedures
litigation inCode
E
of Civil
b, This isa limited case and a motion
civil to withdraw the case from the economic litigation procedures or for additional
discovery willbe checked,
filed (if explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
The case management
party or parties request that the following additional matters be considered or determined at the
conference (specify):
Pursuant to the contract, the parties are participating in binding arbitration through the American Arbitration
Association. n arbitratorhas been assigned and we had our preliminary hearing on April 9, 2020. All hearings,
procedures and deadlines have been set and the arbitration hearing is set for 09/28/2020 at 9:00 am.
Assuming everything runs according to the schedule, we should have a ruling no laterthan 10/28/2020.
19. Meet and confer
a. The party or parties havemet and conferred with parties
all on allsubjects required by rule 3.724 ofthe California Rules
of Court not, explain):
(if
b. After meeting and conferring as required by
rule 3.724 ofthe California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (ifany):
am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
l
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: Aprilfl, 2020
Lisa M. Horton
(TYPEOR PRINT NAME)
> fl (IV;
v x
(SIGNATURw PARTY OR ATTORNEY)
(TYPEOR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
:I Additional signatures are attached.
CM-“OIREV-MM 20111
CASE MANAGEMENT STATEMENT WW5
PROOF OF SERVICE
(CODE CIV. PROC. § 1013)
STATE OF CALIFORNIA, COUNTY OF FRESNO
I am employed in the County 0f Fresno, State of California. I am over the age of 18 years
and am not a party to the within action; my business address is 5260 North Palm Avenue, Suite 400,
Fresno, California 93704.
On April 21, 2020, I served the following document(s) described as CASE
MANAGEMENT STATEMENT on the interested parties in this action by placing a true copy
thereof enclosed in sealed envelopes addressed as follows:
Michael J. F. Smith, Esq.
Michael J. F. Smith, APC
1391 W. Shaw Avenue, Suite D
Fresno, CA 93711
PC 10
11
M BY MAIL: I sent the party(ies) in said action, in accordance with Code 0f Civil Procedure
section 1013(a), by depositing such sealed envelope(s) in the mail at Fresno, California,
with postage thereon fully prepaid. I am readily familiar with the firm’s practice of
WIELAND
12 collection and processing correspondence for mailing. It is deposited With U.S. postal
400
service on that same day in the ordinary course of business. I am aware that 0n motion 0f
Suite
13 service is presumed invalid ifpostal cancellation date 01‘ postage meter date is
& LAW
93704
421—7000
party served,
more than one day after date of deposit for mailing an affidavit.
ATAvenue,
14
(559)
California
D BY OVERNIGHT COURIER: I sent the following party(ies) in said action, in accordance
Palm
With Code of Civil Procedure section 1013(0), by placing a true copy thereof enclosed in a
WATKINS
ATTORNEYS
15
Telephone:
Fresno,
sealed envelope, with delivery fees paid or provided for, in a designated area for outgoing
North
overnight mail, addressed as set forth below. In the ordinary course of business, mail
16
5260
placed in that designated area is picked up that same day for delivery the following business
17 day.
SAGASER,
D BY FAX: I sent such document by use of facsimile machine telephone number (559) 473—
18 in accordance with Code 0f Civil Procedure section 1013(6) and to the following
1483, (f),
party(ies) at the facsimile number(s) indicated above. The date and place of transmission is
19 below. The facsimile machine I used complied With California Rules of Court Rule
listed
2.301(3) and n0 error was reported by the machine.
20
Ideclare under penalty 0f perjury under the laws of the State 0f California that the foregoing
21
istrue and correct.
22
Executed on April 21, 2020, at Fresno, California.
23
24
Valerie Robinson
25
26
27
28
PROOF OF SERVICE
-264121.1
015775.00002
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Bar number, and address): FOR COURT USE ONLY Karen K. Gill,SBN 296365 / Lisa M. Horton. SBN 268601 SAGASER, WATKINS & WIELAND, PC E-FILED 5260 North Palm Avenue, Suite 400, Fresno, CA 93704 4/21/2020 10:44 AM TELEPHONE No; (559)421-7000 FAX No. (559) 473-1483 (OpHanaI): Superior Court of California E-MAILADDRESS karen@sw2law.com (Optional): /Iisa@sw21aw.com County of Fresno JASWINDER BHULLAR ATTORNEY FORWame): Plaintiff, By: A. Ramos, Deputy SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F FRESNO STREETADDRESS:1130 "O" Street 1130 "Q" Street MAILING ADDRESS: CITYAND CODE: ZIP Fresno, CA 93721 BRANCH NAME B.F. Sisk Courthouse PLAINTIFF/PETITIONER: Jaswinder Bhullar DEFENDANTIRESPONDENT: Chooljian Brothers Packing Company, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE [:1 LIMITED CASE 190ECGOS435 (Amount demanded (Amount demanded is$25,000 exceeds $25,000) or iess) A CASE MANAGEMENT CONFERENCE isscheduled as follows: Date: 05/06/2020 Time: 3:30 pm Dept: 402 Div.: Room: Address of court from the address above): different (if Notice of Intent to Appear by Telephone, by (name): Lisa M. Horton INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. b. E This statement This statement is is submitted by party (name): Jaswinder Bhullar Plaintiff, 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):09/20/2019 b. CI The cross-complaint, any, if was filedon (date): 3, a. b. D Service D (tobe answered by plaintiffs and cross—comp/ainants named All parties The in named following parties in only) the complaint and cross-complaint have been served, have appeared, 0r have been dismissed. the complaint or cross-complaint (1) [:3 have not been served (specify names and explain why not): (2) [2:] have been served but have not appeared and have not been dismissed (specify names): Chooljian Brothers Packing Company, Michael H. Chooljian, Individuany, Does 1—10 (3) [:1 have had a default entered against them (specify names): c. E] The may be added following additional parties (specifynames, nature ofinvo/vementin case, and date by which they may be served): 4. Description of ca§e 3‘ Type Ofcase m complaint E cross-complaint (Describe, including causes ofaction): Breach of Contract, Breach 0fthe Implied Covenant of Good Faith and Fair Deatings, Fraudulent Concealment, Fraudulent Misrepresentation, Conversion, Unjust Enrichment, and Unfair Business Practices. Page 1 of 5 Mandatory Use Form Adopted for Judicial Council of CaIiiomia CASE MANAGEMENT STATEMENT Cal. Rules of Court, 3.7204730 rules 0M4 10 (Rev. July 1,201 1] www.coun’sfiagov CM-110 CASENUMBER Jaswinder Bhuuar _ PLAINTIFF/PETITIONER: .. . 19CECG03435 DEFENDANT/RESPONDENT: Choolpan Brothers Packing Company, etal. 4. b4 Provide a brief statement 0f the case, including any damages. (lfpersona/ injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) On the January 12, 2019 the parties entered into a contract to pay Plaintiff $2,900 per ton, as—is over the scale price for his organic raisins.Plaintiff delivered a total of 154,384pounds (77.192 tons). On 0r around May 9, 2019 Defendants paid $40,000.00, and have been making sporadic payments since then, but owe an still outstanding balance. E (/fmore space Jury or nonjury trial isneeded, check box and attach a page designated as Attachment 4b.) this The party or parties request a jurytrial E] a nonjurytrial. name (/fmore than one pan‘y, provide the of each party requesting a jury trial): Trial date a. E: The has been setfor trial (date): b. No date has been trial set.This case willbe ready 12 months of the date of the for trial within of the complaint filing (if not, explain): c. Dates on which parties or attorneys willnot be available for trial(specify datesand explain reasonsfor unavailability): Estimated length of trial The party or parties estimate that the take (check one): trial will a. days (specify number): 2 b. E3 hours (short causes) (specify): . The a. party or parties Attorney: will be answered Trial representation (to for be represented attrial E each party) by the attorney or party the caption listed in E by the following: b. Firm: c. Address: d. Telephone number: f. Fax number: E e. E-mail address: Additional representation isdescribed inAttachment 8. g. Party represented: Preference E] This caseis code entitled to preference (specify section): 104 Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR for information about the processes available through the information package provided by the court under rule 3.221 courtand community programs case. in this (1) For parties represented by counsel: Counsel has :1 has not provided theADR information package identified in rule ADR options with 3.221 to the client and reviewed theclient. (2) For seIf—representedparties: PartyE has [:3 has not action mediation reviewed the ADR informationpackage identified 3.221. in rule b. Referral to judicial arbitration or civil available). (if (1) This matter is sub'ect to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutorylimit‘ Code (2)[j case to Plaintiff elects to refer this and agrees judicial arbitration recovery to the amount specified to limit in of CivilProcedure section 1141.11. (3)E ofthe California Rules of Courtor from This case is exempt from judicial arbitration under rule 3.811 mediation under Code 0f Civil Procedure section 1775 et seq. (specify exemption): action civil Page 2 of5 CM-110 2011] [Rev. July 1, CASE MANAGEMENT STATEMENT CM-1 10 CASE NUMBER: PLAINTIFF/PETITIONER: Jaswinder Bhullar 1QCECG03435 DEFENDANT/RESPONDENTI Chooljian Brothers Packing Company, etal. 10. c. Indicate theADR process in,have agreed or processes that the party or parties are willing t0 participate to participate or in, have already participated in (check all that apply and provide the specified information): The party or parties completing Ifthe party or parties completing this form in the case have agreed to thisform are willing to participatein or have already completed an ADR process or processes, ADR participate in the following indicate the status of the processes (attach a copy of the parties'ADR processes (check allthat apply):stipulation): Mediation session not yet scheduled Mediation session scheduled for (date): (1)Mediation [:1 DUDE Agreed t0compIete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled Settlement conference scheduled for (date): (2)Settlement DUDE conference Agreed tocomplete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation DUDE Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): scheduled Judicial arbitration not yet scheduled Judicial arbitration for (date): (4) Nonbinding judicial DUDE arbitration Agreed to complete by (date): judicial arbitration completed on Judicial arbitration (date): Private arbitration not yet scheduled 9/28/2020 Private arbitration scheduled for (date): (5) Binding private DEED arbitration Agreed complete private to arbitrationby (date): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (date): (6)Other (specify): DUDE Agreed tocomplete ADR session by(date): ADR completed on (date): Page3of5 CM—11O 201 [Rev. July 1] CASE MANAGEMENT STATEMENT 1, CM—1 1 0 CASE NUMBER: PLAINTIFF/PETITIONER: Jaswinder Bhuuar .. . 1QCECG03435 DEFENDANT/RESPONDENT; Chooljlan Brothers Packing Company, et al. 11. Insurance a. E] Insurance carrier, ifany, for party filing this statement (name): E] E3 No b. CA EReservation ofrights: Coverage Yes case issues will significantly affect resolution of this (explain): 12. Jurisdiction Indicate [:3 any matters Bankruptcy E thatmay Other (specify): case and describe the affect the court's jurisdiction or processing of this status. Status: 13. a‘ E Related cases, consolidation, and coordination There are companion, underlying, or related cases. (1)Name of case: (2)Name of court (3)Case number: (4) Status: b. E E: Additional cases are described A motion to D in consolidate Attachment 13a. E coordinate willbe filed by (name party): 14.Bifurcation [:1 The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of moving party, type of motion, and reasons): action (specify 15.Other motions E: The party 0r parties expect to the following motions before file trial(specifymoving party, type ofmotion, and issues): 16. Discovery a. C] The party or partieshave completed alldiscovery. b. The following discovery willbe completed by the date specified (describe allanticipated discovery): Party Description Date Plaintiff Written Discovery Per Code Plaintiff Depositions Per Code Defendant Written Discovery Per Code Defendant Depositions Per Code c. E3 The issues, including issues regarding the discovery of electronically stored information, are following discovery anticipated (specify): Page 4 °f5 CM-11O[Rev. July 1, 2011] CASE MANAGEMENT STATEMENT CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Jaswinder Bhullar — 19CECG03435 DEFENDANT/RESPONDENT; ChOOljian Brothers PaCking company, et al. 17. a. E Economic litigation This is civil case (i.e., the amount demanded is $25,000 or a limited Procedure sections 90-98 will apply to this case. less)and the economic procedures litigation inCode E of Civil b, This isa limited case and a motion civil to withdraw the case from the economic litigation procedures or for additional discovery willbe checked, filed (if explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues The case management party or parties request that the following additional matters be considered or determined at the conference (specify): Pursuant to the contract, the parties are participating in binding arbitration through the American Arbitration Association. n arbitratorhas been assigned and we had our preliminary hearing on April 9, 2020. All hearings, procedures and deadlines have been set and the arbitration hearing is set for 09/28/2020 at 9:00 am. Assuming everything runs according to the schedule, we should have a ruling no laterthan 10/28/2020. 19. Meet and confer a. The party or parties havemet and conferred with parties all on allsubjects required by rule 3.724 ofthe California Rules of Court not, explain): (if b. After meeting and conferring as required by rule 3.724 ofthe California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (ifany): am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, l as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: Aprilfl, 2020 Lisa M. Horton (TYPEOR PRINT NAME) > fl (IV; v x (SIGNATURw PARTY OR ATTORNEY) (TYPEOR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) :I Additional signatures are attached. CM-“OIREV-MM 20111 CASE MANAGEMENT STATEMENT WW5 PROOF OF SERVICE (CODE CIV. PROC. § 1013) STATE OF CALIFORNIA, COUNTY OF FRESNO I am employed in the County 0f Fresno, State of California. I am over the age of 18 years and am not a party to the within action; my business address is 5260 North Palm Avenue, Suite 400, Fresno, California 93704. On April 21, 2020, I served the following document(s) described as CASE MANAGEMENT STATEMENT on the interested parties in this action by placing a true copy thereof enclosed in sealed envelopes addressed as follows: Michael J. F. Smith, Esq. Michael J. F. Smith, APC 1391 W. Shaw Avenue, Suite D Fresno, CA 93711 PC 10 11 M BY MAIL: I sent the party(ies) in said action, in accordance with Code 0f Civil Procedure section 1013(a), by depositing such sealed envelope(s) in the mail at Fresno, California, with postage thereon fully prepaid. I am readily familiar with the firm’s practice of WIELAND 12 collection and processing correspondence for mailing. It is deposited With U.S. postal 400 service on that same day in the ordinary course of business. I am aware that 0n motion 0f Suite 13 service is presumed invalid ifpostal cancellation date 01‘ postage meter date is & LAW 93704 421—7000 party served, more than one day after date of deposit for mailing an affidavit. ATAvenue, 14 (559) California D BY OVERNIGHT COURIER: I sent the following party(ies) in said action, in accordance Palm With Code of Civil Procedure section 1013(0), by placing a true copy thereof enclosed in a WATKINS ATTORNEYS 15 Telephone: Fresno, sealed envelope, with delivery fees paid or provided for, in a designated area for outgoing North overnight mail, addressed as set forth below. In the ordinary course of business, mail 16 5260 placed in that designated area is picked up that same day for delivery the following business 17 day. SAGASER, D BY FAX: I sent such document by use of facsimile machine telephone number (559) 473— 18 in accordance with Code 0f Civil Procedure section 1013(6) and to the following 1483, (f), party(ies) at the facsimile number(s) indicated above. The date and place of transmission is 19 below. The facsimile machine I used complied With California Rules of Court Rule listed 2.301(3) and n0 error was reported by the machine. 20 Ideclare under penalty 0f perjury under the laws of the State 0f California that the foregoing 21 istrue and correct. 22 Executed on April 21, 2020, at Fresno, California. 23 24 Valerie Robinson 25 26 27 28 PROOF OF SERVICE -264121.1 015775.00002