Preview
FlLED
S u p e r ior C p u r t Of C s l i f o r n i s ,
SccrBmento CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Barnumber, and address)
Morgan P. Forsey SBN 241207; Amanda E. Beckwith, SBN 312967
Sheppard, Mullin, Richter & Hampton LLP ddonKIn
Four Embarcadero Center, 17* Floor
, Deputy
San Francisco, CA 94111
Case fiiumber:
TELEPHONE NO (415) 434-9100 FAX NO (Optional) (415) 434-3947
E-MAILADDRESS mforsey@sheppardmullin.eom
34-2019
ATTORNEY FOR fwame;. Defendant Phillips & Jordan, Inc.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO
STREETADDRESS 720 Ninth street
MAILING ADDRESS
CITY AND ZIP CODE Sacfamento, CA 95814
BRANCH NAME
PLAINTIFF/PETITIONER: Jay Robinson, et. al.
DEFENDANT/RESPONDENT: Asomeo Evironmental Restoration Industry, et. al.
CASE MANAGEMENT STATEMENT CASE NUMBER.
(Check one): UNLIMITED CASE • LIMITED CASE 34-2019-00262942-CU-OE- GDS
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: July 8, 2022 Time: 8:30 a.m. Dept.: 31 Div.: Room:
Address of court (if different from the address above):
^ Notice of Intent to Appear by Telephone, by (name): Amanda Beckwith
INSTRUCTIONS'. All applicable boxes must be checked, and the specified information must be provided.
Party or parties ^answer one):
a. ^ This statement is submitted by party (name): Defendant Philips & Jordan, Inc.
b. • This statement is submitted jointly by parties (names):
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):
Service (to be answered by plaintiffs and cross-complainants only)
03
a. O All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. O The following parties named in the complaint or cross-complaint
(1) Q have not been served (specify names and explain why not):
(2) D have been served but have not appeared and have not been dismissed (specify names):
(3) D 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 sen/ed):
4. Description of case
a. Type of case in | ^ complaint • cross-complaint CDescrifte,/nc/ud/ng causes of acf/on|-Class Action
Complaint alleging vairous wage and hour violations, such as meal and rest periods, pay overtime and minimum
wages, reimburse for employment related expenses, and provide accurate wage statements.
Page 1 of S
Form Adapted fbr Mandatory Use Cal. Rules of Court,
Judicial Council of California C A S E MANAGEMENT STATEMENT mles 3 720-3.730
CM-110 [Rev. September 1,2021] www courts.ca gov
CM-110
PLAINTIFF/PETITIONER: Jay Robinson, et. al. CASE NUMBER
DEFENDANT/RESPONDENT; Asomeo Evironmental Restoration Industry, et. al. 34-2019-00262942-CU-OE-GDS
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 ofthe relief.)
Class Action Complaint alleging vairous wage and hour violations based on Defendant's purported failure to
provide meal and rest periods, pay earned wages, reimburse for employment related expenses, and provide
accurate wage statements. Defendant contests that it employed and denies all of Plaintiffs' claims and contentions.
• (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 trial Q a nonjury trial. (If more than one party, provide the name of each party
requesting a Jury trial):
6. Trial date
a. [JThe 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):
Pre-certification and post-certification procedure (if any) preclude trial within 12 months of filing ofthe
complaint.
c. Dates on which parties or attomeys will not be available for trial (specify dates and explain reasons for unavailability):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. K days (specify number): 5-7
b. HJ 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. Finn:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
O Additional representation is described in Attachment 8.
9. Preference
O 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 infonnation package provided by the court under rule 3.221 ofthe California Rules of Court for infonnation 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 infomiation 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) D 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) n 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) K This case is exempt from judicial arbitration under rule 3.811 of the Califomia Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
Rule 3.811(b)(2) ofthe Califomia Rules of Court
CM-110 [Rev September 1,2021] C A S E MANAGEMENT STATEMENT Page 2 of 6
CM-110
PLAINTIFF/PETITIONER: Jay Robinson, et. al. CASE NUMBER
DEFENDANT/RESPONDENT: Asomeo Evironmental Restoration Industry, et. al. 34-2019-00262942-CU-OE-GDS
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 Ifthe 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 ofthe processes (attach a copy of the parties'ADR
processes (check all that apply): stipulation):
r~l Mediation session not yet scheduled
• Mediation session scheduled for (date):
(1) Mediation m • Agreed to complete mediation by (date):
• Mediation completed on (date):
r~l Settlement conference not yet scheduled
(2) Settlement • Settlement conference scheduled for (dafe):
conference • Agreed to complete settlement conference by (dafe);
• Settlement conference completed on (dafe);
• Neutral evaluation not yet scheduled
• Neutral evaluation scheduled for (date):
(3) Neutral evaluation •
• Agreed to complete neutral evaluation by (date):
O Neutral evaluation completed on (date):
l~1 Judicial arbitration not yet scheduled
(4) Nonbinding judicial l~l Judicial arbitration scheduled for (date):
arbitration •
• Agreed to complete judicial arbitration by (date):
D Judicial arbitration completed on (date):
n Private arbitration not yet scheduled
(5) Binding private D Private arbitration scheduled for (date):
arbitration •
O Agreed to complete private arbitration by (date):
D Private arbitration completed on (date):
• ADR session not yet scheduled
(6) Other (specify): • ADR session scheduled for (date):
•
D Agreed to complete ADR session by (date):
n ADR completed on (date):
CM-110 [Rev Septemberl. 2021] CASE MANAGEMENT STATEMENT Page 3 of 6
CM-110
PLAINTIFF/PETITIONER: Jay Robinson, et. al. CASE NUMBER
DEFENDANT/RESPONDENT: Asomeo Evironmental Restoration Industry, et. al. 34-2019-00262942-CU-OE-GDS
11. Insurance
a. • Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Q 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 Cspec/^;;
Status:
13. Related cases, consolidation, and coordination
a. O 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.
• A motion to • consolidate • coordinate will 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
K The party or parties expect to file the following motions before trial (specity moving party; type of motion, and issues):
Defendant's motion for class decertification in the event a prior motion for class certification is granted.
Defendant will file a motion for summary judgment/adjudication.
16. Discovery
a. CH The party or parties have completed all discovery.
b. 13 The following discovery will be completed by the date specified (describe all anticipated discovety):
Partv Description Date
Defendant Document Inspection Demand January 2023
Defendant Special Interrogatories January 2023
Defendant Plaintiffs' Depositions January 2023
c. n The following discovery issues, including issues regarding the discovery of electronically stored infonmation, are
anticipated (specify):
CM-110 [Rev September 1.2021] C A S E MANAGEMENT STATEMENT Page 4 of S
CM-110
PLAINTIFF/PETITIONER: Jay RobinsoH, et. al. CASE NUMBER
DEFENDANT/RESPONDENT: Asomeo Evironmental Restoration Industry, et. al. 34-2019-00262942-CU-OE-GDS
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. CH 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 discovety or trial
should not apply to this case):
18. Other issues
l~l 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 ofthe 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): 0
I am completely familiar with this case and will be fully prepared to discuss the status of discovery and altemative 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: June 29, 2022
Amanda E. Beckwith
(TYPE OR PRINT NAME)
• (s'iGNA' URE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME)
• (SIGNATURE OF PARTY OR ATTORNEY)
CD Additional signatures are attached.
CM-110 [Rev September 1,2021] C A S E MANAGEMENT STATEMENT Page S of 6
PROOF OF S E R V I C E
2 Sacramento County Superior Court Case No. 34-2019-00262942
3 At the time of service, I was over 18 years of age and not a party to this action. I am
employed in the County of San Francisco, State ofCalifomia. My business address is Four
4 Embarcadero Center, 17th Floor, San Francisco, CA 94111-4109.
5 On June 29, 2022,1 served true copies ofthe following document(s) described as:
6 CASE MANAGEMENT STATEMENT
7 on the interested parties in this action as follows:
8 Patricia A. Savage, Esq. Attomeys for Plaintiff,
SAVAGE & LAMB, PC JA Y ROBINSON
9 1550 Humboldt Road and HUGO PINEDA, individually and on
^V'^^^^A rw/rr.-^o bchalf of oll otkcrs simHarlv situoted
10 Chico, CA 95928
Telephone: (530) 592-3861
11 Facsimile: (530) 592-3865
Email:
12
Shane Singh, Esq. Attomeys for Defendant
13 Grace E. Mehla, Esq. Asomeo Environmental Restoration Industry,
LEWIS, BRISBOIS, BISGAARD & LLC
14 SMITH, L L P
2020 W. El Camino Ave. #700
15 Sacramento, Califomia 95833
Telephone: (916) 564-5400
16 Facsimile: (916) 564-5444
Email: Shane.Singh(3),lewisbriscois.com
17
18 ^ BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the
persons at the addresses listed in the Service List and placed the envelope for collection
19 and mailing, following our ordinary business practices. I am readily familiar with the
firm's practice for collecting and processing correspondence for mailing. On the same day
20 that correspondence is placed for collection and mailing, it is deposited in the ordinary
course ofbusiness with the United States Postal Service, in a sealed envelope with postage
21 fully prepaid. I am a resident or employed in the county where the mailing occurred.
22 • BY FAX TRANSMISSION: I faxed a copy ofthe document(s) to the persons at the fax
numbers listed in the Service List. The telephone number ofthe sending facsimile
23 machine was 415.434.3947. The transmission was reported as complete and without error.
No error was reported by the fax machine that I used. A transmission report was properly
24 issued by the sending fax machine.
25 lEl BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
document(s) to be sent from e-mail address: lsegura(^sheppardmullin.com to the persons
26 at the e-mail addresses listed in the Service List. I did not receive, within a reasonable
time after the transmission, any electronic message or other indication that the transmission
27 was unsuccessful.
28
Case No. 34-2019-00262942
SMRH 4891-8141-7255 1 PROOF OF SERVICE
1 • BY OVERNIGHT DELIVERY: I enclosed said document(s) in an envelope or package
provided by the ovemight service carrier and addressed to the persons at the addresses
2 listed in the Service List. I placed the envelope or package for collection and ovemight
delivery at an office or a regularly utilized drop box of the ovemight service carrier or
3 delivered such document(s) to a courier or driver authorized by the ovemight service
carrier to receive documents.
4
• BY PERSONAL SERVICE: I delivered the document(s) to the person at the addresses
5 listed in the Service List. (1) For a party represented by an attomey, delivery was made to
the attomey or at the attomey's office by leaving the documents in an envelope or package
6 clearly labeled to identify the attomey being served with a receptionist or an individual in
charge of the office. (2) For a party, delivery was made to the party or by leaving the
7 documents at the party's residence with some person not less than 18 years of age between
the hours of eight in the moming and six in the evening.
8
I declare under penalty of perjury under the laws of the State of Califomia that the
9 foregoing is tme and correct.
10 Executed on June 29, 2022, at San Francisco, Califomia.
11
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Lucia M. Segura
13
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-2- Case No. 34-2019-00262942
SMRH 4891-8141-7255.1 PROOF OF SERVICE
Preview
FlLED S u p e r ior C p u r t Of C s l i f o r n i s , SccrBmento CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Barnumber, and address) Morgan P. Forsey SBN 241207; Amanda E. Beckwith, SBN 312967 Sheppard, Mullin, Richter & Hampton LLP ddonKIn Four Embarcadero Center, 17* Floor , Deputy San Francisco, CA 94111 Case fiiumber: TELEPHONE NO (415) 434-9100 FAX NO (Optional) (415) 434-3947 E-MAILADDRESS mforsey@sheppardmullin.eom 34-2019 ATTORNEY FOR fwame;. Defendant Phillips & Jordan, Inc. SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO STREETADDRESS 720 Ninth street MAILING ADDRESS CITY AND ZIP CODE Sacfamento, CA 95814 BRANCH NAME PLAINTIFF/PETITIONER: Jay Robinson, et. al. DEFENDANT/RESPONDENT: Asomeo Evironmental Restoration Industry, et. al. CASE MANAGEMENT STATEMENT CASE NUMBER. (Check one): UNLIMITED CASE • LIMITED CASE 34-2019-00262942-CU-OE- GDS (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: July 8, 2022 Time: 8:30 a.m. Dept.: 31 Div.: Room: Address of court (if different from the address above): ^ Notice of Intent to Appear by Telephone, by (name): Amanda Beckwith INSTRUCTIONS'. All applicable boxes must be checked, and the specified information must be provided. Party or parties ^answer one): a. ^ This statement is submitted by party (name): Defendant Philips & Jordan, Inc. b. • This statement is submitted jointly by parties (names): 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): Service (to be answered by plaintiffs and cross-complainants only) 03 a. O All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. O The following parties named in the complaint or cross-complaint (1) Q have not been served (specify names and explain why not): (2) D have been served but have not appeared and have not been dismissed (specify names): (3) D 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 sen/ed): 4. Description of case a. Type of case in | ^ complaint • cross-complaint CDescrifte,/nc/ud/ng causes of acf/on|-Class Action Complaint alleging vairous wage and hour violations, such as meal and rest periods, pay overtime and minimum wages, reimburse for employment related expenses, and provide accurate wage statements. Page 1 of S Form Adapted fbr Mandatory Use Cal. Rules of Court, Judicial Council of California C A S E MANAGEMENT STATEMENT mles 3 720-3.730 CM-110 [Rev. September 1,2021] www courts.ca gov CM-110 PLAINTIFF/PETITIONER: Jay Robinson, et. al. CASE NUMBER DEFENDANT/RESPONDENT; Asomeo Evironmental Restoration Industry, et. al. 34-2019-00262942-CU-OE-GDS 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 ofthe relief.) Class Action Complaint alleging vairous wage and hour violations based on Defendant's purported failure to provide meal and rest periods, pay earned wages, reimburse for employment related expenses, and provide accurate wage statements. Defendant contests that it employed and denies all of Plaintiffs' claims and contentions. • (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 trial Q a nonjury trial. (If more than one party, provide the name of each party requesting a Jury trial): 6. Trial date a. [JThe 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): Pre-certification and post-certification procedure (if any) preclude trial within 12 months of filing ofthe complaint. c. Dates on which parties or attomeys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. K days (specify number): 5-7 b. HJ 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. Finn: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: O Additional representation is described in Attachment 8. 9. Preference O 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 infonnation package provided by the court under rule 3.221 ofthe California Rules of Court for infonnation 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 infomiation 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) D 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) n 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) K This case is exempt from judicial arbitration under rule 3.811 of the Califomia Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): Rule 3.811(b)(2) ofthe Califomia Rules of Court CM-110 [Rev September 1,2021] C A S E MANAGEMENT STATEMENT Page 2 of 6 CM-110 PLAINTIFF/PETITIONER: Jay Robinson, et. al. CASE NUMBER DEFENDANT/RESPONDENT: Asomeo Evironmental Restoration Industry, et. al. 34-2019-00262942-CU-OE-GDS 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 Ifthe 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 ofthe processes (attach a copy of the parties'ADR processes (check all that apply): stipulation): r~l Mediation session not yet scheduled • Mediation session scheduled for (date): (1) Mediation m • Agreed to complete mediation by (date): • Mediation completed on (date): r~l Settlement conference not yet scheduled (2) Settlement • Settlement conference scheduled for (dafe): conference • Agreed to complete settlement conference by (dafe); • Settlement conference completed on (dafe); • Neutral evaluation not yet scheduled • Neutral evaluation scheduled for (date): (3) Neutral evaluation • • Agreed to complete neutral evaluation by (date): O Neutral evaluation completed on (date): l~1 Judicial arbitration not yet scheduled (4) Nonbinding judicial l~l Judicial arbitration scheduled for (date): arbitration • • Agreed to complete judicial arbitration by (date): D Judicial arbitration completed on (date): n Private arbitration not yet scheduled (5) Binding private D Private arbitration scheduled for (date): arbitration • O Agreed to complete private arbitration by (date): D Private arbitration completed on (date): • ADR session not yet scheduled (6) Other (specify): • ADR session scheduled for (date): • D Agreed to complete ADR session by (date): n ADR completed on (date): CM-110 [Rev Septemberl. 2021] CASE MANAGEMENT STATEMENT Page 3 of 6 CM-110 PLAINTIFF/PETITIONER: Jay Robinson, et. al. CASE NUMBER DEFENDANT/RESPONDENT: Asomeo Evironmental Restoration Industry, et. al. 34-2019-00262942-CU-OE-GDS 11. Insurance a. • Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Q 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 Cspec/^;; Status: 13. Related cases, consolidation, and coordination a. O 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. • A motion to • consolidate • coordinate will 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 K The party or parties expect to file the following motions before trial (specity moving party; type of motion, and issues): Defendant's motion for class decertification in the event a prior motion for class certification is granted. Defendant will file a motion for summary judgment/adjudication. 16. Discovery a. CH The party or parties have completed all discovery. b. 13 The following discovery will be completed by the date specified (describe all anticipated discovety): Partv Description Date Defendant Document Inspection Demand January 2023 Defendant Special Interrogatories January 2023 Defendant Plaintiffs' Depositions January 2023 c. n The following discovery issues, including issues regarding the discovery of electronically stored infonmation, are anticipated (specify): CM-110 [Rev September 1.2021] C A S E MANAGEMENT STATEMENT Page 4 of S CM-110 PLAINTIFF/PETITIONER: Jay RobinsoH, et. al. CASE NUMBER DEFENDANT/RESPONDENT: Asomeo Evironmental Restoration Industry, et. al. 34-2019-00262942-CU-OE-GDS 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. CH 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 discovety or trial should not apply to this case): 18. Other issues l~l 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 ofthe 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): 0 I am completely familiar with this case and will be fully prepared to discuss the status of discovery and altemative 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: June 29, 2022 Amanda E. Beckwith (TYPE OR PRINT NAME) • (s'iGNA' URE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) • (SIGNATURE OF PARTY OR ATTORNEY) CD Additional signatures are attached. CM-110 [Rev September 1,2021] C A S E MANAGEMENT STATEMENT Page S of 6 PROOF OF S E R V I C E 2 Sacramento County Superior Court Case No. 34-2019-00262942 3 At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of San Francisco, State ofCalifomia. My business address is Four 4 Embarcadero Center, 17th Floor, San Francisco, CA 94111-4109. 5 On June 29, 2022,1 served true copies ofthe following document(s) described as: 6 CASE MANAGEMENT STATEMENT 7 on the interested parties in this action as follows: 8 Patricia A. Savage, Esq. Attomeys for Plaintiff, SAVAGE & LAMB, PC JA Y ROBINSON 9 1550 Humboldt Road and HUGO PINEDA, individually and on ^V'^^^^A rw/rr.-^o bchalf of oll otkcrs simHarlv situoted 10 Chico, CA 95928 Telephone: (530) 592-3861 11 Facsimile: (530) 592-3865 Email: 12 Shane Singh, Esq. Attomeys for Defendant 13 Grace E. Mehla, Esq. Asomeo Environmental Restoration Industry, LEWIS, BRISBOIS, BISGAARD & LLC 14 SMITH, L L P 2020 W. El Camino Ave. #700 15 Sacramento, Califomia 95833 Telephone: (916) 564-5400 16 Facsimile: (916) 564-5444 Email: Shane.Singh(3),lewisbriscois.com 17 18 ^ BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the persons at the addresses listed in the Service List and placed the envelope for collection 19 and mailing, following our ordinary business practices. I am readily familiar with the firm's practice for collecting and processing correspondence for mailing. On the same day 20 that correspondence is placed for collection and mailing, it is deposited in the ordinary course ofbusiness with the United States Postal Service, in a sealed envelope with postage 21 fully prepaid. I am a resident or employed in the county where the mailing occurred. 22 • BY FAX TRANSMISSION: I faxed a copy ofthe document(s) to the persons at the fax numbers listed in the Service List. The telephone number ofthe sending facsimile 23 machine was 415.434.3947. The transmission was reported as complete and without error. No error was reported by the fax machine that I used. A transmission report was properly 24 issued by the sending fax machine. 25 lEl BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the document(s) to be sent from e-mail address: lsegura(^sheppardmullin.com to the persons 26 at the e-mail addresses listed in the Service List. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission 27 was unsuccessful. 28 Case No. 34-2019-00262942 SMRH 4891-8141-7255 1 PROOF OF SERVICE 1 • BY OVERNIGHT DELIVERY: I enclosed said document(s) in an envelope or package provided by the ovemight service carrier and addressed to the persons at the addresses 2 listed in the Service List. I placed the envelope or package for collection and ovemight delivery at an office or a regularly utilized drop box of the ovemight service carrier or 3 delivered such document(s) to a courier or driver authorized by the ovemight service carrier to receive documents. 4 • BY PERSONAL SERVICE: I delivered the document(s) to the person at the addresses 5 listed in the Service List. (1) For a party represented by an attomey, delivery was made to the attomey or at the attomey's office by leaving the documents in an envelope or package 6 clearly labeled to identify the attomey being served with a receptionist or an individual in charge of the office. (2) For a party, delivery was made to the party or by leaving the 7 documents at the party's residence with some person not less than 18 years of age between the hours of eight in the moming and six in the evening. 8 I declare under penalty of perjury under the laws of the State of Califomia that the 9 foregoing is tme and correct. 10 Executed on June 29, 2022, at San Francisco, Califomia. 11 12 Lucia M. Segura 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- Case No. 34-2019-00262942 SMRH 4891-8141-7255.1 PROOF OF SERVICE