Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY lmame. Sfafe ssr nunmer, end addrsser
FOR COURT USE ONLY
Matthew J. Gluck (221571 ) - Jusfin L. Sowa (305002)
GLUCK DANIEL ATKINSON LLP
201 Mission Street, Suits 1330
San Fmndsco, CA 94105 ELECTRONICALLY
TELEPHONE NO415u610-21 14 fo~&415-510-2208
rnx No FILED
EOOAL AUGREBBIifigafion@gluckdanlei-corn Superior Court of California,
ATfoRNEY FQR seams/ DsllX~mplalnant EARL G. 'RICK" STOKES County of San Francisco
SUPERIOR COURT OF CAUFORNIA, COUNTY OF SAN FRANCISCO
04/07/2023
sTREET AGUREss 400 MCAlllster Stmet
Clerk of the Court
MAIUNG AOORESS BY: RONNIE OTERO
cnY rwo zn cooE.San Francisco, CA 94102 Deputy Clerk
BRANOH NAMEtCivic Center Courthouse
PLAINTIFF/PETITIONER. ROSS H. MOORE on beltui or STEAMWORKS
DEFENDANT/RESPONDENT GREAT WORKS, INC., ET AL
CASE MANAGEMENT STATEMENT
(Checlr one): ~x UNIJMITED CASE
(Amount demanded
~ LIMITED CASE
(Amount demanded is $ 25,000
CASE NUMBER
CGC-1 8-568669
exceeds $ 25,000) Of ISSS)
A CASE MANAGEMENT CONFERENCE is scheduled ss follows:
Date: April 26, 2023 Time: 10:30 am Dsptz 610 Divz Civil
Address of court (if di/fereni from the address above):
~x Notice of Intent to Appear by Telephone, by fnsma)l JustlnL Sows
INSTRUCTIONS: All applicable boxes must be checked, and the speclfisd information must be provided.
1. Party or parties (answer one):
b. ~
a. ~x This statement is submitted by party (name): EARL G. "RICK" STOKES
This statement is submitted jointly by parsee (names) f
2. Complaint and crosswomplaint fro be answered by p/ainliffs and cross-complsinsnts only)
s. The complaint wss filed on (dais)/
b. ~x The uoss-complaint if any, was filed on (dsfe)/ September 25, 2018
s. ~
3. Service (Io be enswsmd by p/ainfiffs snd cmss-comp/sinanls only)
All parties named in the complaint snd crossNxfmplaint have been served, have appeared, or have been dismissed.
b. ~x The following psrtfes named in the complaint or crosscomplsint
(I ) ~ have not been served (spec/Ty names snd exp/sin why nor):
(2) ~x have been served but have not appeared and have not been dismissed (specify names).
Dominic Paramore (sub-served)
(3) ~ have hsd a default entered against them (specify names):
c. ~ The following additional parties may be added (specify names, ne/Urs of involvement in case, end dale by which
they msy bs se/vsd):
4. Description of case
a. Type of case in ~x complaint ~
cras~mplstnt (Describe, including causes of action):
Dispute among owners of related business enfifies. Mr. Stokes afieges that Mr. Moore hss breached fidudary duties owed to
him, end that uosedefandants invaded his privacy end vlolaled P.C. 528.5
Pride I ol 3
Form Amtnted lor landatme Usa Cm Rules of Coutl
Judftfat CoUrutl of Camorms CASE MANAGEMENTSTATEMENT fulas 3 Tla-3 T30
cM-tlsllum septa emt,202R nuo omnfs oa doe
CM-110
PLAINTIFF/PETITIONER ROSS H. MOORE on behalf of STEAMWORKS cAsE mvusER
DEFENDANTIRESPONDENT'GREAT WORKS, INC., ET AL. CGC-18468669
b. Provide a brief statement of the case, induding sny damages. (If personal injury damages am sought, specify the injury and
damages claimed, including medical expenses to date (indicale source end emountj, esb'mated future medical expenses, Iosl
earnings to date, and estimated future Iosl earnings. I(equitable relief is sought, descn'be lhe nature of dre reiiefJ
Stokes and Moore were coowners and members of Steamworks Management, LLC. Disputes have arisen regarding past
conduct end tha opersgons of Steamworks and related businesses.
~ (If more space is needed, check this box and attach e Page designated sx Attachment 4b.)
Jury or nonjury trial
The party or parties request ~x s jury trial
requesting s jury hie!j:
~a nonjury trial. (If more ihsn one psriy, pmvide the name of sech party
Trial date
a.
b.
~
~x
The trial hssbeen setfor (dele):
No trial date has been set. This case will be reedy for trial within 12 months of the date of the filing of the complaint (if
not, explain):
Stayed pending setgament dkicusslons.
c. Dates on which parties or attorneys will not be available tor trial (specify dates and explain reasons for unsvailsbililyj:
Estimated length of trial
The party or parties estimate that the trial will take (check one):
b ~
s. ~x days (specify number): 3-5.
hours (short causes) (specify):
Trial representation (lo be answered for each party)
The party or parties will be represented at trial ~x by the attorney or party listed in the caption
s. Attorney:
~ by the following:
b. Firm:
c. Address:
d. Telephone nurnberi f. Fax number:
e. E-mail address:
~ Additional representation is described in Attachment 8.
g. Party represented:
~
Preference
This csee is entitled to preference (specify code section)i
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes ars available in diffemnt courts and communities; reed
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 cess.
(1} For parties represented by counsel: Counsel ~x has ~ hss not provided the ADR informabon package identified
(2) For self-represented parties: Party ~ ~
in rule 3.221 to the client snd reviewed ADR options with the dient.
hss has not reviewed the ADR information package idenb6sd in rule 3.221.
(1) ~
b. Refenal to judicial arbitration or civil action mediation (if available).
This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil actlofl
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
(2) ~ statutory limit.
Plaintilf elects to refer this case to judicial arbitration and agrees to limit recovery to the amount spedfisd in Code of
Civil Procedure section 1141.11.
{3) ~x 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 exemptionj:
CM.11O Iivm Seemmem 1, 2S21I
Oeee 2 oi 2
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER ROSS H. MOORE on behalf of STEABSRKmKS CASE NUMBER.
DEFENDANT/RESPONDENT GREAT WORKS, INC., ET AL CGC-1 8-568669
10. c. Indicate ths ADR process or processes that the party or parties are willing to psrbcipste in, have agreed to participate in, or
have already partiupsted in (chec/I e// test apply snd pmvide the Spec//fed information)/
The party or parties completing If the party or parties complebng 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 e copy of fhe parties'DR
processes (chec/l sl/ that spp/yj: st/pu/af/onj:
~x Mediation session not yet scheduled
(1) Mediation Dx
~
~
Mediabon session scheduled for (date)/
Agreed to complete mediation by (date):
~ Mediation completed on (dale):
(2) Settlement
conference
~
~x Setbemsnt conference not yet scheduled
~
SBNement conference scheduled for (dale)/
Agreed to complete settlement conference by (dste):
~ Settlement conference completed on (date)/
~
~ Neutral evaluation not yet scheduled
(3) Neutral evaluation
~
~
Neutral evaluation scheduled for (date):
Agreed to complete neutral evaluation by (dale):
Neutral evaluation completed on (dsfe):
~
~ Judicial arbitration not yet scheduled
(4) Nonbinding judicial
arbitration
~ Judicial arbitration scheduled for (dale)/
Agreed to complete judicial arbitration by (dsfe)/
Judicial arbitration completed on (dsfe):
~
~ Private arbitration not yet scheduled
Private arbitration scheduled for (dais)/
(5) Binding private
arbitration
~
~ Agreed to complete private arbitration by (date):
Private arbitration completed on (dale):
~
~ ADR session not yet scheduled
(6) Other (specify):
~
~
ADR Session scheduled for (dale)/
Agreed to complete ADR session by {date)/
ADR completed on (dele)/
CM-110 IRe SeeleNSN 2021I
2
CASE MANAGEMENT STATEMENT reeeee/I
CM-110
PLAINTIFF/PETITIONER ROSS H. MOORE on behalf of STEAMWORKS CASE RURIIER.
DEFENDANT/RESPONDENT.GREAT WORKS, INC.. ET AL CGC-18-568868
11. Insurance
a. ~ Insurance camer,
b. Reservation of rights: ~ ~
if any, for parly filing this statement (name):
Yes No
c. ~ Coverage issues will significantly sfiect resolution of this case (explain):
12. Jurtsdlctlon
~
Indicate any matters that may afiect the court's jurisdiction or processing of this cess and describe the status.
Bankruptcy ~x Other (specify)i On April 4, 2019, the Court entered s stay in the pmcsedings to allow the parties to
Status: negotiate s global resolution.
13. Related cases. consolidation, and coordination
a. ~x There are companion, underiying, or related cases.
(1) Name of cess: Moore v. Unicorn Club, LTD.
{2) Name of court: San Francisco County Superior
(3) Case number. CGC-18-564'onsofidsted with Case No. CGC-18-564826
(4) Status: Acbve
~x Additional cases are described in Attachment 13s.
b. ~x A motion to ~x consolidate
Great Works, Inc. (CGC-1 8464825)
C]
coordinate will bs filed by (name party):
~
14. Bifurcation
Ths party or parties intend to file a motion for sn order bifurcating, severing, or coordinating the following issues or causes of
adion (specify moving perly, type of mobon, snd reasons):
15. Other motions
~x The party or parties expect to file the following motions before trial (specify moving psrly, type of morion, end issues):
Discovery motions as deemed rwcesssry, mobons in fimlne.
16. Discovery
a.
b.
~
~ The party or parties have completed afi discovery
The following discovery will be completed by the date spscNed (describe ell snlicipaled discovery):
'
Para ~Descri
Please see 612 above.
c. ~ The fallowing discovery issues, induding issues regarding the discovery of electronicaily stored information, are
arrbcipated (specify):
cu-110 IRIR sereeeeee 1 101 1I
CASE MANAGEMENT STATEMENT peee 1 et 1
CM-110
PLAINTIFF/PETITIONER ROSS H. MOORE on behalf of STEAMWORKS CASE NUMBER.
DEFENDANT/RESPONDENT GREAT WORKS, INC., ET AL CGC-18-568669
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 Epenfically why economic lihgalion procedures relating Io discovery or In'el
should nol apply lo 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 (specifyj/
The parties request that the case management conference be continued for 90 days.
19. Meet and confer
a. ~x The party or parties have met end conferred with all parties on all subjects required by rule 3.724 of the Cal/fornia Rules
of Court (if nol, explain):
b. ~ After meeting and confemng as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specifyj:
20. Total number of pages attached (if enyf: 1
Iem completely familiar v Tth this case and w/ll be fully prepared to discuss the status of discovery and alternative dispute resolution,
as weft 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, induding the written authority of the parly where required.
Date: April 4, 2023
Justin L. Sowa
/TYPE OR PRINT NAME) RE OF PARTY OR ATTORNEYI
(~ION
/TYPE OR PRINT NAME)
~
(SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures ere attached.
CM-110 IRee Beemmim 1, 50/1I
CASE MANAGEMENT STATEMENT Peee 5 ei 5
'%RP
Brivacy,plsasepresstheclesryhlsFormbunonafteryi printthis form
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Save this form )
~'Cfear th(s form 1
TO keep Other peOple frOm Seeing What ycu ent6vnredl:Oit":yecttnr, fenny put'etrSIEypreea ttyI'e"CIeavr:@iS.Falls'I
MCA)25
t
CASE MUMSEA.
SHORT TITLE;
MOORE v. GREAT WORKS, INC., ET AL. CGC-18-566669
ATTACHMENT (Number) 13a
(This Atlechment mey be used with eny Judiuel Councyt form)
13a. Additional Cases
Ross Moore v. Earl G. Stokes Case No. CGC-18-564351. Partition action case was settled.
(lf the item thet this Attachment concerns is msde under penelty of penury, eil stetements in this esg0 1 ct 1
Attechment sm msde under penelty of perluyy.)
(Add psges es required)
Form Aneovoo lor CF5onol Uoo ooo nounnlo uo nov
Jutunol collllun of coolufno ATTACHMENT
Mc-025 Enny. July l. 2MMI
to Judicial Council Form
I. For, your protection arid priyacyr please seve This Form ]
Frlnt This Form / J,"ctearuilhfs:Fsrmil
PROOF OF SERVICE
I
I, Brenda Martinez-Eby, declare as follows: I am a citizen of the United States, over the age of
eighteen years and not a party to the within entitled action. My business address is Gluck Daniel Atkinson
LLP, 201 Mission Street, Suite 1330, San Francisco, California 94105. I served thc attached paper
identified below on the interested parties in said action, by placing a true copy thereof in scaled envclopc(s)
addressed as indicated and served the named document in the manner indicated below:
CASE MANAGEMENT STATEMENT
Service upon:
Jamie C. Couche, Esq. Mark Epstein, Esq.
Anderson k Poole, P.C. Seiler Epstein LLP
601 California St Stc 1300 275 Battery Street, Ste. 1600
9 San Francisco, CA 94108 San Francisco. CA 94111
jcouche(a)adplaw.corn mwcfri sczalaw.corn
10
II A uorneys for Defendant and Cross- Clai mant Aaorne& s for Defendant and Cross-Claimant
Greal )parks lnc. Laurence Hl ckev
12 Charles J. Wisch, Esq.
LAW OFFICES OFCHARLES J. WISCH
13 275 Battery Street, Suite 1300
San Francisco, CA 94111
14
Tcl: 415-788-1945
15
Fax: 415-788-1948
Email: cjwlsch wischlaw.corn
16
.Aunrne&'s for Plainrtjfand Cross-Defendant
17 Ross H. Moore
18
BY HAND DELIVERY: I caused true and correct copies of the above document(s) to be placed wiihin
n sealed envelope or other package suitable for handling by s messenger or courier service and then caused
19
thc package tu be hsnd-delivered by n snme-dsy messenger service to the addressee(s) on this date.
20 BY EMAIL: I caused true and corretn copies of the above docuntcnt(s) to be sent vis email to the
addressee(s) on this date. I did not receive a notice indicating delivery failure.
21
BY E-SERVICF.'. I caused true and correct copies of the above document(s) to be sent vis electronic
trmsinission through the Coun's E-service vendor in conformity with Ssn Fmnciscu Superior Court Local
22 Rulc 2.10.
23
I declare under penalty of perjury under the laws of the State of California that the
24 foregoing is true and correct. Executed April 4, 2023, at San Francisco, Californi.
25
Alsala llhht4lg )sRLV
'gg
26 Brentla Irtlartinez-Ebf
27
PROOF OF SERVICE
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY lmame. Sfafe ssr nunmer, end addrsser FOR COURT USE ONLY Matthew J. Gluck (221571 ) - Jusfin L. Sowa (305002) GLUCK DANIEL ATKINSON LLP 201 Mission Street, Suits 1330 San Fmndsco, CA 94105 ELECTRONICALLY TELEPHONE NO415u610-21 14 fo~&415-510-2208 rnx No FILED EOOAL AUGREBBIifigafion@gluckdanlei-corn Superior Court of California, ATfoRNEY FQR seams/ DsllX~mplalnant EARL G. 'RICK" STOKES County of San Francisco SUPERIOR COURT OF CAUFORNIA, COUNTY OF SAN FRANCISCO 04/07/2023 sTREET AGUREss 400 MCAlllster Stmet Clerk of the Court MAIUNG AOORESS BY: RONNIE OTERO cnY rwo zn cooE.San Francisco, CA 94102 Deputy Clerk BRANOH NAMEtCivic Center Courthouse PLAINTIFF/PETITIONER. ROSS H. MOORE on beltui or STEAMWORKS DEFENDANT/RESPONDENT GREAT WORKS, INC., ET AL CASE MANAGEMENT STATEMENT (Checlr one): ~x UNIJMITED CASE (Amount demanded ~ LIMITED CASE (Amount demanded is $ 25,000 CASE NUMBER CGC-1 8-568669 exceeds $ 25,000) Of ISSS) A CASE MANAGEMENT CONFERENCE is scheduled ss follows: Date: April 26, 2023 Time: 10:30 am Dsptz 610 Divz Civil Address of court (if di/fereni from the address above): ~x Notice of Intent to Appear by Telephone, by fnsma)l JustlnL Sows INSTRUCTIONS: All applicable boxes must be checked, and the speclfisd information must be provided. 1. Party or parties (answer one): b. ~ a. ~x This statement is submitted by party (name): EARL G. "RICK" STOKES This statement is submitted jointly by parsee (names) f 2. Complaint and crosswomplaint fro be answered by p/ainliffs and cross-complsinsnts only) s. The complaint wss filed on (dais)/ b. ~x The uoss-complaint if any, was filed on (dsfe)/ September 25, 2018 s. ~ 3. Service (Io be enswsmd by p/ainfiffs snd cmss-comp/sinanls only) All parties named in the complaint snd crossNxfmplaint have been served, have appeared, or have been dismissed. b. ~x The following psrtfes named in the complaint or crosscomplsint (I ) ~ have not been served (spec/Ty names snd exp/sin why nor): (2) ~x have been served but have not appeared and have not been dismissed (specify names). Dominic Paramore (sub-served) (3) ~ have hsd a default entered against them (specify names): c. ~ The following additional parties may be added (specify names, ne/Urs of involvement in case, end dale by which they msy bs se/vsd): 4. Description of case a. Type of case in ~x complaint ~ cras~mplstnt (Describe, including causes of action): Dispute among owners of related business enfifies. Mr. Stokes afieges that Mr. Moore hss breached fidudary duties owed to him, end that uosedefandants invaded his privacy end vlolaled P.C. 528.5 Pride I ol 3 Form Amtnted lor landatme Usa Cm Rules of Coutl Judftfat CoUrutl of Camorms CASE MANAGEMENTSTATEMENT fulas 3 Tla-3 T30 cM-tlsllum septa emt,202R nuo omnfs oa doe CM-110 PLAINTIFF/PETITIONER ROSS H. MOORE on behalf of STEAMWORKS cAsE mvusER DEFENDANTIRESPONDENT'GREAT WORKS, INC., ET AL. CGC-18468669 b. Provide a brief statement of the case, induding sny damages. (If personal injury damages am sought, specify the injury and damages claimed, including medical expenses to date (indicale source end emountj, esb'mated future medical expenses, Iosl earnings to date, and estimated future Iosl earnings. I(equitable relief is sought, descn'be lhe nature of dre reiiefJ Stokes and Moore were coowners and members of Steamworks Management, LLC. Disputes have arisen regarding past conduct end tha opersgons of Steamworks and related businesses. ~ (If more space is needed, check this box and attach e Page designated sx Attachment 4b.) Jury or nonjury trial The party or parties request ~x s jury trial requesting s jury hie!j: ~a nonjury trial. (If more ihsn one psriy, pmvide the name of sech party Trial date a. b. ~ ~x The trial hssbeen setfor (dele): No trial date has been set. This case will be reedy for trial within 12 months of the date of the filing of the complaint (if not, explain): Stayed pending setgament dkicusslons. c. Dates on which parties or attorneys will not be available tor trial (specify dates and explain reasons for unsvailsbililyj: Estimated length of trial The party or parties estimate that the trial will take (check one): b ~ s. ~x days (specify number): 3-5. hours (short causes) (specify): Trial representation (lo be answered for each party) The party or parties will be represented at trial ~x by the attorney or party listed in the caption s. Attorney: ~ by the following: b. Firm: c. Address: d. Telephone nurnberi f. Fax number: e. E-mail address: ~ Additional representation is described in Attachment 8. g. Party represented: ~ Preference This csee is entitled to preference (specify code section)i 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes ars available in diffemnt courts and communities; reed 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 cess. (1} For parties represented by counsel: Counsel ~x has ~ hss not provided the ADR informabon package identified (2) For self-represented parties: Party ~ ~ in rule 3.221 to the client snd reviewed ADR options with the dient. hss has not reviewed the ADR information package idenb6sd in rule 3.221. (1) ~ b. Refenal to judicial arbitration or civil action mediation (if available). This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil actlofl mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the (2) ~ statutory limit. Plaintilf elects to refer this case to judicial arbitration and agrees to limit recovery to the amount spedfisd in Code of Civil Procedure section 1141.11. {3) ~x 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 exemptionj: CM.11O Iivm Seemmem 1, 2S21I Oeee 2 oi 2 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER ROSS H. MOORE on behalf of STEABSRKmKS CASE NUMBER. DEFENDANT/RESPONDENT GREAT WORKS, INC., ET AL CGC-1 8-568669 10. c. Indicate ths ADR process or processes that the party or parties are willing to psrbcipste in, have agreed to participate in, or have already partiupsted in (chec/I e// test apply snd pmvide the Spec//fed information)/ The party or parties completing If the party or parties complebng 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 e copy of fhe parties'DR processes (chec/l sl/ that spp/yj: st/pu/af/onj: ~x Mediation session not yet scheduled (1) Mediation Dx ~ ~ Mediabon session scheduled for (date)/ Agreed to complete mediation by (date): ~ Mediation completed on (dale): (2) Settlement conference ~ ~x Setbemsnt conference not yet scheduled ~ SBNement conference scheduled for (dale)/ Agreed to complete settlement conference by (dste): ~ Settlement conference completed on (date)/ ~ ~ Neutral evaluation not yet scheduled (3) Neutral evaluation ~ ~ Neutral evaluation scheduled for (date): Agreed to complete neutral evaluation by (dale): Neutral evaluation completed on (dsfe): ~ ~ Judicial arbitration not yet scheduled (4) Nonbinding judicial arbitration ~ Judicial arbitration scheduled for (dale)/ Agreed to complete judicial arbitration by (dsfe)/ Judicial arbitration completed on (dsfe): ~ ~ Private arbitration not yet scheduled Private arbitration scheduled for (dais)/ (5) Binding private arbitration ~ ~ Agreed to complete private arbitration by (date): Private arbitration completed on (dale): ~ ~ ADR session not yet scheduled (6) Other (specify): ~ ~ ADR Session scheduled for (dale)/ Agreed to complete ADR session by {date)/ ADR completed on (dele)/ CM-110 IRe SeeleNSN 2021I 2 CASE MANAGEMENT STATEMENT reeeee/I CM-110 PLAINTIFF/PETITIONER ROSS H. MOORE on behalf of STEAMWORKS CASE RURIIER. DEFENDANT/RESPONDENT.GREAT WORKS, INC.. ET AL CGC-18-568868 11. Insurance a. ~ Insurance camer, b. Reservation of rights: ~ ~ if any, for parly filing this statement (name): Yes No c. ~ Coverage issues will significantly sfiect resolution of this case (explain): 12. Jurtsdlctlon ~ Indicate any matters that may afiect the court's jurisdiction or processing of this cess and describe the status. Bankruptcy ~x Other (specify)i On April 4, 2019, the Court entered s stay in the pmcsedings to allow the parties to Status: negotiate s global resolution. 13. Related cases. consolidation, and coordination a. ~x There are companion, underiying, or related cases. (1) Name of cess: Moore v. Unicorn Club, LTD. {2) Name of court: San Francisco County Superior (3) Case number. CGC-18-564'onsofidsted with Case No. CGC-18-564826 (4) Status: Acbve ~x Additional cases are described in Attachment 13s. b. ~x A motion to ~x consolidate Great Works, Inc. (CGC-1 8464825) C] coordinate will bs filed by (name party): ~ 14. Bifurcation Ths party or parties intend to file a motion for sn order bifurcating, severing, or coordinating the following issues or causes of adion (specify moving perly, type of mobon, snd reasons): 15. Other motions ~x The party or parties expect to file the following motions before trial (specify moving psrly, type of morion, end issues): Discovery motions as deemed rwcesssry, mobons in fimlne. 16. Discovery a. b. ~ ~ The party or parties have completed afi discovery The following discovery will be completed by the date spscNed (describe ell snlicipaled discovery): ' Para ~Descri Please see 612 above. c. ~ The fallowing discovery issues, induding issues regarding the discovery of electronicaily stored information, are arrbcipated (specify): cu-110 IRIR sereeeeee 1 101 1I CASE MANAGEMENT STATEMENT peee 1 et 1 CM-110 PLAINTIFF/PETITIONER ROSS H. MOORE on behalf of STEAMWORKS CASE NUMBER. DEFENDANT/RESPONDENT GREAT WORKS, INC., ET AL CGC-18-568669 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 Epenfically why economic lihgalion procedures relating Io discovery or In'el should nol apply lo 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 (specifyj/ The parties request that the case management conference be continued for 90 days. 19. Meet and confer a. ~x The party or parties have met end conferred with all parties on all subjects required by rule 3.724 of the Cal/fornia Rules of Court (if nol, explain): b. ~ After meeting and confemng as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specifyj: 20. Total number of pages attached (if enyf: 1 Iem completely familiar v Tth this case and w/ll be fully prepared to discuss the status of discovery and alternative dispute resolution, as weft 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, induding the written authority of the parly where required. Date: April 4, 2023 Justin L. Sowa /TYPE OR PRINT NAME) RE OF PARTY OR ATTORNEYI (~ION /TYPE OR PRINT NAME) ~ (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures ere attached. CM-110 IRee Beemmim 1, 50/1I CASE MANAGEMENT STATEMENT Peee 5 ei 5 '%RP Brivacy,plsasepresstheclesryhlsFormbunonafteryi printthis form ~ ) ~ Save this form ) ~'Cfear th(s form 1 TO keep Other peOple frOm Seeing What ycu ent6vnredl:Oit":yecttnr, fenny put'etrSIEypreea ttyI'e"CIeavr:@iS.Falls'I MCA)25 t CASE MUMSEA. SHORT TITLE; MOORE v. GREAT WORKS, INC., ET AL. CGC-18-566669 ATTACHMENT (Number) 13a (This Atlechment mey be used with eny Judiuel Councyt form) 13a. Additional Cases Ross Moore v. Earl G. Stokes Case No. CGC-18-564351. Partition action case was settled. (lf the item thet this Attachment concerns is msde under penelty of penury, eil stetements in this esg0 1 ct 1 Attechment sm msde under penelty of perluyy.) (Add psges es required) Form Aneovoo lor CF5onol Uoo ooo nounnlo uo nov Jutunol collllun of coolufno ATTACHMENT Mc-025 Enny. July l. 2MMI to Judicial Council Form I. For, your protection arid priyacyr please seve This Form ] Frlnt This Form / J,"ctearuilhfs:Fsrmil PROOF OF SERVICE I I, Brenda Martinez-Eby, declare as follows: I am a citizen of the United States, over the age of eighteen years and not a party to the within entitled action. My business address is Gluck Daniel Atkinson LLP, 201 Mission Street, Suite 1330, San Francisco, California 94105. I served thc attached paper identified below on the interested parties in said action, by placing a true copy thereof in scaled envclopc(s) addressed as indicated and served the named document in the manner indicated below: CASE MANAGEMENT STATEMENT Service upon: Jamie C. Couche, Esq. Mark Epstein, Esq. Anderson k Poole, P.C. Seiler Epstein LLP 601 California St Stc 1300 275 Battery Street, Ste. 1600 9 San Francisco, CA 94108 San Francisco. CA 94111 jcouche(a)adplaw.corn mwcfri sczalaw.corn 10 II A uorneys for Defendant and Cross- Clai mant Aaorne& s for Defendant and Cross-Claimant Greal )parks lnc. Laurence Hl ckev 12 Charles J. Wisch, Esq. LAW OFFICES OFCHARLES J. WISCH 13 275 Battery Street, Suite 1300 San Francisco, CA 94111 14 Tcl: 415-788-1945 15 Fax: 415-788-1948 Email: cjwlsch wischlaw.corn 16 .Aunrne&'s for Plainrtjfand Cross-Defendant 17 Ross H. Moore 18 BY HAND DELIVERY: I caused true and correct copies of the above document(s) to be placed wiihin n sealed envelope or other package suitable for handling by s messenger or courier service and then caused 19 thc package tu be hsnd-delivered by n snme-dsy messenger service to the addressee(s) on this date. 20 BY EMAIL: I caused true and corretn copies of the above docuntcnt(s) to be sent vis email to the addressee(s) on this date. I did not receive a notice indicating delivery failure. 21 BY E-SERVICF.'. I caused true and correct copies of the above document(s) to be sent vis electronic trmsinission through the Coun's E-service vendor in conformity with Ssn Fmnciscu Superior Court Local 22 Rulc 2.10. 23 I declare under penalty of perjury under the laws of the State of California that the 24 foregoing is true and correct. Executed April 4, 2023, at San Francisco, Californi. 25 Alsala llhht4lg )sRLV 'gg 26 Brentla Irtlartinez-Ebf 27 PROOF OF SERVICE