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  • DOBBINS, ANNIE V. CHICO TERRACE HEALTHCARE & WELLNESS(36) Unlimited Wrongful Termination document preview
  • DOBBINS, ANNIE V. CHICO TERRACE HEALTHCARE & WELLNESS(36) Unlimited Wrongful Termination document preview
  • DOBBINS, ANNIE V. CHICO TERRACE HEALTHCARE & WELLNESS(36) Unlimited Wrongful Termination document preview
  • DOBBINS, ANNIE V. CHICO TERRACE HEALTHCARE & WELLNESS(36) Unlimited Wrongful Termination document preview
  • DOBBINS, ANNIE V. CHICO TERRACE HEALTHCARE & WELLNESS(36) Unlimited Wrongful Termination document preview
  • DOBBINS, ANNIE V. CHICO TERRACE HEALTHCARE & WELLNESS(36) Unlimited Wrongful Termination document preview
  • DOBBINS, ANNIE V. CHICO TERRACE HEALTHCARE & WELLNESS(36) Unlimited Wrongful Termination document preview
  • DOBBINS, ANNIE V. CHICO TERRACE HEALTHCARE & WELLNESS(36) Unlimited Wrongful Termination document preview
						
                                

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CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Grace Y. Horoupian, SBN 180337, Gregory L. Blueford, SBN 302628 Fisher & Phillips LLP 2050 Main Street, Suite 1000/621 Capitol Mall, Suite 1400 Irvine, CA 92614/Sacramento, CA 95814 (916) 210-0400 TELEPHONE NO.: FAX NO. (Optional): (916) 210-0401 ghoroupian@fisherphillips.com; gblueford@fisherphillips.com E-MAIL ADDRESS: 11/29/2022 ATTORNEY FOR (Name): Defendant, Windsor Chico Care Center, LLC SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE STREET ADDRESS: 1775 Concord Avenue MAILING ADDRESS: 1775 Concord Avenue CITY AND ZIP CODE: Chico 95928 BRANCH NAME: North Butte County Courthouse PLAINTIFF/PETITIONER: Annie Dobbins DEFENDANT/RESPONDENT: Windsor Chico Care Center, LLC, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE 22CV00718 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: December 14, 2022 Time: 10:30 a.m. Dept.: 1 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Gregory L. Blueford 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): Defendant, Windsor Chico Care Center, LLC b. 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): b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. 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): (2) 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 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 cross-complaint (Describe, including causes of action): Plaintiff alleges (1) Retaliation in Violation of Labor Code Section 1102.5; and (2) Wrongful Termination in Violation of Public Policy. Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730 CM-110 [Rev. September 1, 2021] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: Annie Dobbins CASE NUMBER: DEFENDANT/RESPONDENT: Windsor Chico Care Center, LLC, et al. 22CV00718 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 earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff alleges causes of action for retaliation, and wrongful termination. Defendant denies any and all of Plaintiff's claims and deny that she has suffered any damages. (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 a jury triaI a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. The trial has been set for (date): b. 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 (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 1/3-1/13/23; 2/14-2/24/23; 2/20-2/27/23; 3/13-4/7/23; 4/18-4/21/23; 5/1-5/5/23; 5/15-5/17/23; 5/22-5/26/23; 6/12- 6/16/23; 6/23-6/30/23; 8/14/-8/18/23; 8/28-9/20/23; 10/16-10/27/23; 11/1-11/30/23; 12/4-12/15/23 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 5-7 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: Additional representation is described in Attachment 8. 9. Preference This case is entitled to preference (specify code section): 10. 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 of the California Rules of Court for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel has 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 has has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (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 1141.11. (3) This case is exempt from judicial 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): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5 CM-110 PLAINTIFF/PETITIONER: Annie Dobbins CASE NUMBER: DEFENDANT/RESPONDENT: Windsor Chico Care Center, LLC, et al. 22CV00718 10. c. 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 If 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, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5 CM-110 PLAINTIFF/PETITIONER: Annie Dobbins CASE NUMBER: DEFENDANT/RESPONDENT: Windsor Chico Care Center, LLC, et al. 22CV00718 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): RSUI Group, Inc. b. Reservation of rights: Yes No c. 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. Bankruptcy Other (specify): Status: 13. Related cases, consolidation, and coordination a. 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. A motion to consolidate coordinate wiII be filed by (name party): 14. Bifurcation The party or 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 The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Defendant will file a Motion to Compel Arbitration. 16. Discovery a. The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant Written Discovery Per Code Defendant Depositions Per Code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: Annie Dobbins CASE NUMBER: DEFENDANT/RESPONDENT: Windsor Chico Care Center, LLC, et al. 22CV00718 17. Economic litigation a. This is 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. 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 trial should not apply to this case): 18. Other issues 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. The party or parties have met and conferred with all parties on all 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): 20. Total number of pages attached (if any): I am 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, including the written authority of the party where required. Date: November 29, 2022 Gregory L. Blueford  (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME)  (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5 1 PROOF OF SERVICE (CCP § 1013(a) and 2015.5) 2 3 I, the undersigned, am at least 18 years old and not a party to this action. I am employed in the County of Sacramento with the law offices of Fisher & Phillips LLP and itsbusiness address is 621 4 Capitol Mall, Suite 1400, Sacramento, California 95814. 5 On November 29, 2022, I served the foregoing document(s) DEFENDANT WINDSOR CHICO CARE CENTER, LLC’S CASE MANAGEMENT STATEMENT on the person(s) listed 6 below as follows: 7 Joseph M. Earley III Attorneys for Plaintiff 8 Cameron Easterling ANNIE DOBBINS Law Offices of Joseph M. Earley III 9 331 Wall Street Emails: joe@josephearley.com Chico, CA 95928 cameron@josephearley.com 10 mary@josephearley.com ashley@josephearley.com 11 12  [by MAIL] - I enclosed the document(s) in a sealed envelope or package addressed to the person(s) whose address(es) are listed above and placed the envelope for collection and mailing, 13 following our ordinary business practices. I am readily familiar with this firm’s practice for collecting and processing correspondence for mailing. On the same day that correspondence is 14 placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service in Sacramento, California, in a sealed envelope with postage fully 15 prepaid. 16  [by FAX] - Based on an agreement of the parties to accept service by fax transmission, I faxed the document(s) to the person(s) at fax number(s) listed above from fax number (916) 210-0401. 17 The machine printed a record of the transmission, and no error was reported by the machine. 18  [by OVERNIGHT DELIVERY] - I enclosed the document(s) in an envelope or package provided by an overnight delivery carrier and addressed to the person(s) at the address(es) listed 19 above. I placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight carrier. 20  [by ELECTRONIC SERVICE] - Based on a court order or an agreement of the parties to accept 21 service by electronic transmission, I electronically served the document(s) to the person(s) at the electronic service address(es) listed above. 22 I declare under penalty of perjury under the laws of the State of California that the foregoing is 23 true and correct. 24 Executed November 29, 2022, at Sacramento, California. 25 Alicia P. Malerbi By: Print Name Signature 26 27 28 1 PROOF OF SERVICE FP 45753577.1