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  • Elizabeth Serrano vs  Estate of Manuel Sanchez, deceased22 Unlimited - Auto document preview
  • Elizabeth Serrano vs  Estate of Manuel Sanchez, deceased22 Unlimited - Auto document preview
  • Elizabeth Serrano vs  Estate of Manuel Sanchez, deceased22 Unlimited - Auto document preview
  • Elizabeth Serrano vs  Estate of Manuel Sanchez, deceased22 Unlimited - Auto document preview
  • Elizabeth Serrano vs  Estate of Manuel Sanchez, deceased22 Unlimited - Auto document preview
  • Elizabeth Serrano vs  Estate of Manuel Sanchez, deceased22 Unlimited - Auto document preview
  • Elizabeth Serrano vs  Estate of Manuel Sanchez, deceased22 Unlimited - Auto document preview
  • Elizabeth Serrano vs  Estate of Manuel Sanchez, deceased22 Unlimited - Auto document preview
						
                                

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CM-110 ATI'ORNEY OR PARTY WITHOUT ATTORNEY (Name, and address): Slate Bar number, FOR COURT USE ONLY Adam B. Stirrup, No.257683 SBN: BARADAT & PABOOJIAN, INC. 720 W. Alluvial Avenue Fresno, California 93711 E-FILED TELEPHONE No; (559) 43 1 .5366 FAX No. (Optional):(559) 43 1- l702 2/14/2019 9:19 AM ADDRESS EAMAIL abs@bplaw-inc.com (Optional): ATTORNEY FOR FRESNO COUNTY SUPERIOR COURT (Name): Plaintiffs SUPERIOR COURT OF CALIFORNIA, COUNTY OFFRESNO By: J. Nelson, Deputy sTREEr ADDRESS:1 130 O Street MAILINGADDRESSI 130 "O" Street CITvANDZIPCODE:Fresno, 93721-2220 BRANCHNAMEBF. Sisk Courthouses PLAINTIFF/PETITIONER: ELIZABETH ALICE SERRANO; et al. DEFENDANT/RESPONDENT: ESTATE OF MANUEL SANCHEZ; 6t al. CASE MANAGEMENT STATEMENT CASE NUMBER (Check one): UNLIMITED CASE (Amount demanded E LIMITED CASE (Amount demanded is$25,000 ISCECGOMH exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE iSscheduled as follows: DateIMarch 7, 2019 Timez3230 p.m. Dept.:402 Div.: Room: Address of court (ifdifferent from the address above): E Notice of Intent to Appear by Telephone, by (name): 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):Elizabeth Alice Serrano; Elizabeth Leticia Serrano; Juan submitted jointly by parties (names): Serrano 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-comp/ainants only) a, b, E The complaint was filed on (date),'September The cross-complaint,ifany, was filed 12, 2018 on (date): 3, Service (tobe answered by and cross-comp/ainants plaintiffs only) a, b. E The (1) E named All parties inthe complaint and cross-complaint have been served, named following parties inthe complaint or cross-complaint have not been served (specify names and explain why have appeared, or have been dismissed. not): (2) E have been sewed but have not appeared and have not been dismissed (specify names): (3) E have had a default entered againstthem names): (specilj/ c. E The theymay be served): may be added following additional parties (specifynames, nature of/nvo/vement incase, and date by Which Description of case av TYpe 0f case In complaint injured in a motor vehicle accident. E cross—complaint (Describe, including causes of action): Plaintiffs were Page1of 5 Form AdoptedMandateUse for Judicial Council of Califo‘zua CAS E MANAGEM ENT STATEMEN T C R |. \ f rautesuae;2%—Cao7uanol CM»110[Rev.Ju\y1,2o11] ' ' www gov courts.ca Westlaw Do: E Farm Eullder- CM-110 CASE NUMBER: PLAlNTIFF/PETITIONER: ELIZABETH ALICE SERRANO; et a1. 18CECG03411 DEFENDANT/RESPONDENT: ESTATE 0F MANUEL SANCHEZ; et a1. 4. b, Provide a brief statement of the case, including any damages. (/fpersona/ 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.) Motor vehicle accident. Damages are still being calculated. E (/fmore space isneeded, check box and attach a page designated as Attachment this 4b.) 5. Jury or nonjury The requesting ajury trial party or parties request trial): a jurytrial E a nonjury trial. name (lfmore than one party, provide the of each party 6. a‘ b. E Trialdate The No has been setfor (date): trial date has been trial set.This case willbe ready 12 months ofthe date ofthe filing of the complaint for trial within (if not, explain): o. Dates on which be available parties or attorneys will not fortrial(specify datesand explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the take (check one): trial will a. b. E days (specify number):4-5 hours (short causes) (specify): 8. Trial representation The a. party or parties Attorney: (to will be answered for be represented each attrial party) by the attorney or party the caption listed in E by the following: b Firm: c Address: d. Telephone number: f, Fax number: Ee E-mail address: Additional representationisdescribed inAttachment 8. g‘ Party represented: 9. 10. E Preference This case is code entitled to preference (specifi/ Alternative dispute resolution (ADR) section): 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 3.221for information aboutthe processes available through the and community programs court (1) For parties represented by counsel: inrule 3.221 case. in this Counsel and reviewed to the client ADR has E options with the has not client. providedthe ADR information package identified (2) For self—represented parties: PartyE has E has not reviewed the ADR information package identified in rule3.221. b. (1) E Referral tojudicial arbitration or mediation under civilaction mediation available). (if This matter is sub‘ectto mandatory judicial arbitration under Code of Civil ode of Civil Procedure section Procedure section 1141.11 orto civil action 1775.3 because the amount in controversy does not exceed the statutorylimit. (2) E CivilProcedure section case to Plaintiff elects to refer this 1141,11. and agrees judicial arbitration amount specified to limit recovery to the inCode of (3) E This case is exemptfrom judicial arbitration under rule 3,811 mediation under Code of Civil ofthe California Rules of Courtorfrom Procedure section 1775 et seq. (specify exemption): civilaction 0M4 10 [Ru July 1,2011] CASE MANAGEMENT STATEMENT PageZOfs CM-110 PLAINTIFF/PETITIONER: ELIZABETH ALICE SERRANO; et a1. CASE NUMBER DEFENDANT/RESPONDENT:ESTATE 0F MANUEL SANCHEZ; et a1. 13CECG°3411 10_ c. ADR Indicate the process or processes thatthe party or parties are willing to participate in,have agreed to participate in,or have already participatedin(check al/ that apply and provide the specified information): The party or parties completing the party or parties completing this form If in the case have agreed to thisform are willing to participate inorhave already completed an ADR process or processes, participate inthe followingADR indicate the status of the processes (attach a copy ofthe panies’ADR processes (check allthat apply):stipulation): Mediation session not yet scheduled Mediation session scheduled for (date): (1)Mediation DUDE Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2)Settlement Settlement conference scheduled for (date): conference DUDE 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 DUDE Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): scheduled Judicial arbitration not yet (4) Nonbinding judicial scheduled Judicial arbitration for (date): arbitration DUDE Agreed to complete judicial arbitration by (date): completed on Judicial arbitration (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration DUDE Agreed to complete privatearbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (date): (6) Other (specify): DUDE Agreed to complete ADR session by (date): ADR completed on (date): CM-110[Rev. July1, 2011] Page3°f5 CASE MANAGEMENT STATEMENT CM-11o CASE NUMBER: PLA'NT'FF/PETITIONERELIZABETH ALICE SERRANO; et a1. 18CECG03411 DEFENDANT/RESPONDENTESTATE 0F MANUEL SANCHEZ; et a1. 11. a. D Insurance Insurance carrier, E if E any, for party statement (name): filing this b. c. E Reservation of rights: Coverage issues will Yes No case significantly affect resolution ofthis (explain): 12. Jurisdiction E Indicate Status: any matters Bankruptcy E thatmay affect the court's jurisdiction or processing of this Other(spec/fy): case and describe thestatus. 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: E E Additional cases are described Attachment 13a. E E in b. A motion to consolidate coordinate willbe filedby (name party): 14. EBifurcation The party or parties intend to moving action (specify a motion for fiIe an order bifurcating, severing, and reasons): party, type of motion, or coordinating the following issues or causes of Other motions E 15. The party or parties expect to file the following motions before(specify trial moving party, type ofmofion,and issues): 16. a. E Discovery The have completed patty or parties alldiscovery. b. m The Plaintiffs following discoverywillbe completed by the date specified (describe Written Discovery Description al/ m anticipated discovely): Pursuant to Code Plaintiffs Depositions Pursuant to Code Plaintiffs Expert Witness Depositions Pursuant t0 Code C. D The following discovery issues, including issues regarding the discovery of electronically stored information, anticipated (specify): are CM-11O[Rev. July 2011] 1, CASE MANAGEMENT STATEMENT Page4of5 CM-110 PLAINTrFF/PETITIONERzELIZABETH ALICE SERRANO; et a1. CASE NUMBER? 18CECG03411 DEFENDANT/RESPONDENT: ESTATE OF MANUEL SANCHEZ; et al. Econom ic 17‘ a. E litigation This isa limited civil case (i.e,, the amount demanded is $25,000 or less)and the economic procedures litigation inCode b, E This is Procedure sections 90—98 will apply to this case. of Civil a limited discovery will civil case and a motion to withdraw the case from the economic litigation procedures or for additional be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. DOther issues The party or parties request thatthe following additional matters be considered or determined conference (specify): atthe case management 19. Meet and confer a. The party have met and conferred with or parties allparties onallsubjects required by rule 3.724 ofthe California Rules 0fCourt (/fnot,explain): b. After meeting and conferring as required byrule3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number ofpages attached (I'fany): lam 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 atthe time of the case management conference, including the written authority ofthe party where required. Date: Z /\% ?\C‘ ‘ Adam B. Stirrup, N0. 257683 p (TYPEOR PRINT NAME) V (SIGWURE 0F PARTY AR A?TQQE? OR (TYPE PRINT NAME) E (SIGNATURE 0F PARTY 0R AWORNEY) Additional signatures are attached. CM-1 1O [Rev. July201 1, 1] CASE MANAGEMENT STATEMENT Pa9e50f5 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF FRESNO Iam employed in the County 0f Fresno, State of California. I am over the age 0f 18 and not a pafiy to the within action. My business address is 720 West Alluvial Avenue, Fresno, California 9371 1. My email address is mls@bp1aw—inc.com. On February 14, 2019, at 9:13 am, I served the foregoing document described as QAS_E MANAGEMENT STATEMENT on all interested parties in this action, as listed below: Joseph D. Cooper Anthony T. Case COOPER & COOPER, LLP FARMER CASE & FEDOR 5756 N. Marks Ave., Suite 160 402 W. Broadway, Suite 1100 Fresno, CA 93711 San Diego, CA 92101 10 Fax: (559) 442—1659 Fax: (619) 338-0180 joe@coopllp.com tcase@farmercase.com 11 Attorneysfor Defendant Attorneysfor Defendant ESTA TE OF MANUEL SANCHEZ, Defendant, JUAN DELAROSA 12 deceased CAMPOS 4,3 W {JiiBiYiMA’IL - Iiam’readfly’fami’liar’with’tll’e’firm‘s practice of collectlon and processinig’” 7W documents for mailing. Under that practice, each envelope would be deposited with the 14 U.S. Postal Service on that same day With postage thereon fully prepaid at Fresno, California, in the ordinary course of business. I am aware 0n motion 0f the party served, 15 service is presumed invalid if postal cancellation date or postage meter date is more than one day after date 0f deposit for mailing in affidavit. 16 [XX] BY ELECTRONIC TRANSMISSION — A PDF version of said document was served by 17 lylerhostnet Via electronic mail to the party(s) identified herein using the e-mail address(es) indicated. 18 [] BY OVERNIGHT DELIVERY - I enclosed said document in an envelope or package 19 provided by an overnight delivery carrier with delivery fees paid. Iam readily familiar with the firm’s practice 0f collection and processing packages for overnight delivery. 20 They are deposited with a facility regularly maintained by the overnight delivery carrier for receipt 0n the same day in the ordinary course 0f business. 21 I declare under penalty ofperjury, under the laws 0fthe State of California, that the above is true 22 and correct. Executed 0n Februaly 14, 2019, at Fresno, California. 23 F 24 25 1 26 27 28 PROOF OF SERVICE FILE NO. 2159