Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
WELTY, WEAVER & CURRIE, Jack Weaver, Esq. (SBN 278469), Rachel Mache, Esq. (SBN 318461) 3554
Round Barn Blvd., Santa Rosa, CA 95403
SCHACK LAW GROUP, Alexander Schack, Esq. (SBN 99126), Natasha Serino, Esq. (SBN 284711),
Shannon Nocon, Esq. (SBN 316523), 16870 W Bernardo Dr., Ste. 400, San Diego, CA 92127
Welty, Weaver & Currie: 707-433-4842
TELEPHONE NO.: Schack Law Group: 858-485-6535 FAX NO. (Optional):
jack@weltyweaver.com, shannonnocon@schacklawgroup.com
E-MAIL ADDRESS (Optional):
Plaintiffs David Suchard, Jody Suchard, and JANE DOE, individually, and
ATTORNEY FOR (Name):
on behalf of all others similarly situated
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sonoma
STREET ADDRESS: 3055 Cleveland Avenue
MAILING ADDRESS:
CITY AND ZIP CODE: Santa Rosa, CA 95403
BRANCH NAME:
PLAINTIFF/PETITIONER: David Suchard, et al.,
DEFENDANT/RESPONDENT: Sonoma Academy
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): ✔ UNLIMITED CASE LIMITED CASE SCV-270984
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as
follows: Date: 3/23/2023 Time: 3:00 PM Dept.: 19 Div.: Room:
Address of court (if different from the address above):
✔ Notice of Intent to Appear by Telephone, by (name): Jack Weaver, Shannon Nocon
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):
b.! x This statement is submitted jointly by parties (names):
Plaintiffs David Suchard, Jody Suchard, and JANE DOE, individually, and on behalf of all others
similarly situated
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): June 10, 2022
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):
The complaint alleges that Defendant wrongfully concealed information concerning sexual abuse and
harassment committed and/or covered up by it’s employees against its students and alleges causes of action for
violations of the California Unfair Competition Law, false advertising, and fraud.
Page 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: David Suchard, et al.,
SCV-270984
DEFENDANT/RESPONDENT: Sonoma Academy
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.)
See attachment 4b.
✔ (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):
The parties require additional time to complete motion work and discovery, including class certification and class and expert discovery.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
See attachment 6(c).
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. ✔ days (specify number): 20 court days
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 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):
California Rule of Court 3.811(b)(1), (2), (8).
CM-110 [Rev. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: David Suchard, et al.,
SCV-270984
DEFENDANT/RESPONDENT: Sonoma Academy
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
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: David Suchard, et al.,
SCV-270984
DEFENDANT/RESPONDENT: Sonoma Academy
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
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: Jane Doe v. Sonoma Academy, et al.
(2) Name of court: Sonoma County Superior Court
(3) Case number: SCV-269851
(4) Status: Filed and pending
✔ 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):
Coordination with related cases, motion for class certification, potential discovery motions.
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
Sonoma Academy Written Discovery March 2023
Sonoma Academy Depositions August 2023
Sonoma Academy Expert Discovery October 2023
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Jane Doe CASE NUMBER:
SCV-270984
DEFENDANT/RESPONDENT: Sonoma Academy
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): 4
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: March 21, 2023
Jack Weaver, Esq.
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Shannon Nocon, Esq.
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev. July 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
For your protection and privacy, please Save This Form Print This Form Clear This Form
Jane Doe v. Sonoma Academy (SCV – 270984)
Attachment 4.b.
In derogation of its community identity and Defendant Sonoma Academy’s (“SA”)
repeated promises to provide a safe and highly reputable educational environment, SA actively
concealed the fact that it employed Marco Morrone, a serial sexual predator, as a full-time
teacher, and knowingly permitted him unfettered sexual access to students for over eighteen
years under the guise of quality education, including for at least fourteen years after SA first
received reports of Morrone's sexual abuse of students in early 2007. SA also covered up reports
of sexual abuse committed by other staff members. As the sexual abuse continued, SA continued
to promote itself as a safe and prestigious educational institution, all while charging students
yearly tuition of approximately $50,000 per student. As a result of SA’s unlawful conduct,
Plaintiff and the Class members have suffered harm in that they incurred substantial expenses for
SA tuition and related expenses that they would not otherwise have paid.
Jane Doe v. Sonoma Academy (SCV – 270984)
Attachment 13.a
Name of Case: Jacob Succhard v. Sonoma Academy et al.
Name of Court: Sonoma County Superior Court
Case Number: SCV-270993
Status: Filed and pending
Case Management Statement
Attachment 1
6 (c): Dates on which parties or attorneys will not be available for trial (specify dates and
explain reasons for unavailability):
Counsel Weaver is unavailable for the following dates:
1. April 28, 2023 (Trial Call)
2. May 12, 2023 (Trial Call)
3. June 9, 2023 (Trial Call)
4. June 12-16, 2024 (Family Vacation)
5. July 28, 2023 (Trial Call)
6. July 31, 2023 (Readiness Conference)
7. August 7, 2023 (Trial Call)
8. September 5, 7, 8 and 12, 2023 (Arbitration)
9. September 25, 2023 (Trial Call)
10. October 26 – November 1, 2023 (Family Vacation)
11. January 22, 2024 (Mandatory Settlement Conference)
12. May 6, 2024 (Trial Management Conference)
13. May 10, 2024 (Trial Calling)
14. May 15, 2024 (Trial)
15. May 24, 2024 (Trial)
Schack Law Group is unavailable for the following dates:
1. June 27-July 4, 2023 (vacations)
2. August 1-4, 2023 (vacations)
3. November 3, 2023 (Trial Call)
PROOF OF SERVICE
1
I am a citizen of the United States and employed in the County of Sonoma, California. I am
2 over the age of eighteen years and not a party to the within entitles cause; my business address is
3554 Round Barn Blvd., Ste. 300, Santa Rosa, CA 95403.
3
On the date below, I served the following document(s):
4
CASE MANAGEMENT STATEMENT
5
On the interested parties in said cause, by placing a true copy thereof in a sealed envelope
6 addressed as follows:
7
Paul E. Gaspari, State Bar No. 76496 Attorneys for Defendant,
8 WEINTRAUB TOBIN CHEDIAK COLEMAN GRODIN SONOMA ACADEMY
LAW CORPORATION
9 475 Sansome Street, Suite 510
San Francisco, California 941 t I
10 Telephone: 415.433.1400
11 Facsimile: 415.433.3883
Email: pgaspari@weintraub.com
12
Ryan E. Abernethy, State Bar No. 267538
13 WEINTRAUB TOBIN CHEDIAK COLEMAN GRODIN
LAW CORPORATION
14 400 Capitol Mall, 11th Floor
15 Sacramento, California 95814
Telephone: 916.558.6000
16 Facsimile: 916.446.1611
Email: rabernethy@weintraub.com
17
Alexander M. Schack Co-Counsel for Plaintiffs
18
Natasha N. Serino
19 Shannon F. Nocon
SCHACK LAW GROUP
20 16870 West Bernardo Drive, Suite 400
San Diego, CA 92127
21 Telephone: (858) 485-6535
Facsimile: (858) 485-0608
22
Email: alexschack@schacklawgroup.com
23 natashaserino@schacklawgroup.com
shannonnocon@schacklawgroup.com
24
_X___ (BY ELECTRONIC TRANSMISSION) I caused said document(s) to be transmitted
25 electronically to the email addresses indicated after the address(es) noted above. My email address is:
Shannon@weltyweaver.com
26
I declare under penalty of perjury under the laws of the State of California that the foregoing is
27 true and correct, and that this declaration was executed on 3/21/2023, at Santa Rosa, California.
28 ________________________________
Shannon Monaco
PROOF OF SERVICE
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY WELTY, WEAVER & CURRIE, Jack Weaver, Esq. (SBN 278469), Rachel Mache, Esq. (SBN 318461) 3554 Round Barn Blvd., Santa Rosa, CA 95403 SCHACK LAW GROUP, Alexander Schack, Esq. (SBN 99126), Natasha Serino, Esq. (SBN 284711), Shannon Nocon, Esq. (SBN 316523), 16870 W Bernardo Dr., Ste. 400, San Diego, CA 92127 Welty, Weaver & Currie: 707-433-4842 TELEPHONE NO.: Schack Law Group: 858-485-6535 FAX NO. (Optional): jack@weltyweaver.com, shannonnocon@schacklawgroup.com E-MAIL ADDRESS (Optional): Plaintiffs David Suchard, Jody Suchard, and JANE DOE, individually, and ATTORNEY FOR (Name): on behalf of all others similarly situated SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sonoma STREET ADDRESS: 3055 Cleveland Avenue MAILING ADDRESS: CITY AND ZIP CODE: Santa Rosa, CA 95403 BRANCH NAME: PLAINTIFF/PETITIONER: David Suchard, et al., DEFENDANT/RESPONDENT: Sonoma Academy CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): ✔ UNLIMITED CASE LIMITED CASE SCV-270984 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 3/23/2023 Time: 3:00 PM Dept.: 19 Div.: Room: Address of court (if different from the address above): ✔ Notice of Intent to Appear by Telephone, by (name): Jack Weaver, Shannon Nocon 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): b.! x This statement is submitted jointly by parties (names): Plaintiffs David Suchard, Jody Suchard, and JANE DOE, individually, and on behalf of all others similarly situated 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): June 10, 2022 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): The complaint alleges that Defendant wrongfully concealed information concerning sexual abuse and harassment committed and/or covered up by it’s employees against its students and alleges causes of action for violations of the California Unfair Competition Law, false advertising, and fraud. Page 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: David Suchard, et al., SCV-270984 DEFENDANT/RESPONDENT: Sonoma Academy 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.) See attachment 4b. ✔ (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): The parties require additional time to complete motion work and discovery, including class certification and class and expert discovery. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): See attachment 6(c). 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. ✔ days (specify number): 20 court days 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 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): California Rule of Court 3.811(b)(1), (2), (8). CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: David Suchard, et al., SCV-270984 DEFENDANT/RESPONDENT: Sonoma Academy 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 ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: David Suchard, et al., SCV-270984 DEFENDANT/RESPONDENT: Sonoma Academy 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): 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: Jane Doe v. Sonoma Academy, et al. (2) Name of court: Sonoma County Superior Court (3) Case number: SCV-269851 (4) Status: Filed and pending ✔ 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): Coordination with related cases, motion for class certification, potential discovery motions. 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 Sonoma Academy Written Discovery March 2023 Sonoma Academy Depositions August 2023 Sonoma Academy Expert Discovery October 2023 c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Jane Doe CASE NUMBER: SCV-270984 DEFENDANT/RESPONDENT: Sonoma Academy 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): 4 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: March 21, 2023 Jack Weaver, Esq. (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Shannon Nocon, Esq. (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. July 1, 2011] Page 5 of 5 CASE MANAGEMENT STATEMENT For your protection and privacy, please Save This Form Print This Form Clear This Form Jane Doe v. Sonoma Academy (SCV – 270984) Attachment 4.b. In derogation of its community identity and Defendant Sonoma Academy’s (“SA”) repeated promises to provide a safe and highly reputable educational environment, SA actively concealed the fact that it employed Marco Morrone, a serial sexual predator, as a full-time teacher, and knowingly permitted him unfettered sexual access to students for over eighteen years under the guise of quality education, including for at least fourteen years after SA first received reports of Morrone's sexual abuse of students in early 2007. SA also covered up reports of sexual abuse committed by other staff members. As the sexual abuse continued, SA continued to promote itself as a safe and prestigious educational institution, all while charging students yearly tuition of approximately $50,000 per student. As a result of SA’s unlawful conduct, Plaintiff and the Class members have suffered harm in that they incurred substantial expenses for SA tuition and related expenses that they would not otherwise have paid. Jane Doe v. Sonoma Academy (SCV – 270984) Attachment 13.a Name of Case: Jacob Succhard v. Sonoma Academy et al. Name of Court: Sonoma County Superior Court Case Number: SCV-270993 Status: Filed and pending Case Management Statement Attachment 1 6 (c): Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Counsel Weaver is unavailable for the following dates: 1. April 28, 2023 (Trial Call) 2. May 12, 2023 (Trial Call) 3. June 9, 2023 (Trial Call) 4. June 12-16, 2024 (Family Vacation) 5. July 28, 2023 (Trial Call) 6. July 31, 2023 (Readiness Conference) 7. August 7, 2023 (Trial Call) 8. September 5, 7, 8 and 12, 2023 (Arbitration) 9. September 25, 2023 (Trial Call) 10. October 26 – November 1, 2023 (Family Vacation) 11. January 22, 2024 (Mandatory Settlement Conference) 12. May 6, 2024 (Trial Management Conference) 13. May 10, 2024 (Trial Calling) 14. May 15, 2024 (Trial) 15. May 24, 2024 (Trial) Schack Law Group is unavailable for the following dates: 1. June 27-July 4, 2023 (vacations) 2. August 1-4, 2023 (vacations) 3. November 3, 2023 (Trial Call) PROOF OF SERVICE 1 I am a citizen of the United States and employed in the County of Sonoma, California. I am 2 over the age of eighteen years and not a party to the within entitles cause; my business address is 3554 Round Barn Blvd., Ste. 300, Santa Rosa, CA 95403. 3 On the date below, I served the following document(s): 4 CASE MANAGEMENT STATEMENT 5 On the interested parties in said cause, by placing a true copy thereof in a sealed envelope 6 addressed as follows: 7 Paul E. Gaspari, State Bar No. 76496 Attorneys for Defendant, 8 WEINTRAUB TOBIN CHEDIAK COLEMAN GRODIN SONOMA ACADEMY LAW CORPORATION 9 475 Sansome Street, Suite 510 San Francisco, California 941 t I 10 Telephone: 415.433.1400 11 Facsimile: 415.433.3883 Email: pgaspari@weintraub.com 12 Ryan E. Abernethy, State Bar No. 267538 13 WEINTRAUB TOBIN CHEDIAK COLEMAN GRODIN LAW CORPORATION 14 400 Capitol Mall, 11th Floor 15 Sacramento, California 95814 Telephone: 916.558.6000 16 Facsimile: 916.446.1611 Email: rabernethy@weintraub.com 17 Alexander M. Schack Co-Counsel for Plaintiffs 18 Natasha N. Serino 19 Shannon F. Nocon SCHACK LAW GROUP 20 16870 West Bernardo Drive, Suite 400 San Diego, CA 92127 21 Telephone: (858) 485-6535 Facsimile: (858) 485-0608 22 Email: alexschack@schacklawgroup.com 23 natashaserino@schacklawgroup.com shannonnocon@schacklawgroup.com 24 _X___ (BY ELECTRONIC TRANSMISSION) I caused said document(s) to be transmitted 25 electronically to the email addresses indicated after the address(es) noted above. My email address is: Shannon@weltyweaver.com 26 I declare under penalty of perjury under the laws of the State of California that the foregoing is 27 true and correct, and that this declaration was executed on 3/21/2023, at Santa Rosa, California. 28 ________________________________ Shannon Monaco PROOF OF SERVICE