On August 24, 2020 a
Conference
was filed
involving a dispute between
Brinson, Kenya,
Lopez, Chazz,
and
Does 1-50,
Socal Pacific Mf Management Corp,
Socal Pacific Mf Management Corp, A California Corporation,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
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QR G ll H N;
STATE BAR NUMBER Reserved for Clerk's File Stamp
NAME AND ADDRESS OF ATTORNEY OR PARTY WITHOUT ATIORNEY:
Roger Mansukhani; Ian Williamson; Daniel J. Quon 190800; 222616; 321532
Gordon Rees Scully Mansukhani, LLP F i LE
CALIForwA
D .
101 W. Broadway, 20‘“ Floor, San Diego, CA 92101 S ”pmoa coun'r 0F
0F SAN BEaNmomo
TELEPHONE No.; (619) 230-7797 DMSION
SAN BERNARDINO CIVIL
E—MAIL ADDRESS: dquon@grsm.com TRIAL SEWING CONFERENCE DATE; 02/24/2021
ATTORNEY FOR (Name): SoCaI Pacific MF FEB 0 9 2021
Management Corp dba Nova Point
Apartments UNLIMITED CASE: g ,
/,-‘ ,p”
¢ m" " - _- v.”
FAX No. (Optional): (61 9) 696-71 24 LIMITED CASE:
ASHLEE BAYLESS. DEPUTY
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
COURTHOUSE ADDRESS: 247 W. Third St., San Bernardino, CA 92415
E—
Kenya Brinson,
PLAINTIFF: et al.
DEFENDANT: SoCal Pacific MF Management Corp etc.
CASE NUMBER:
qx INITIAL TRIAL SETTING CONFERENCE STATEMENT CIVD8201 7097
.Iv\
Q~N INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. This document must be filed and
{33‘ served at Ieast 15 days Qrior to the trial setting conference date.
c 1. Party or parties (answer one):
a. E This statement is submitted by party (name): Defendant Socal Pacific MF Management Corp
”Ci?
b. D This statement is submitted jointly by parties (names):
l 2. Service of Complaint on all parties has D has not D been completed.
'ZC-‘Z
3. Service of Cross-Complaint on all parties has D D been
has not completed.
4. Description of case in Complaint:
Among
I
{A
’
The allege inadequate maintenance by the defendant of their leased apartment.
plaintiffs
plaintiffs allege plumbing issues, mold, insects, heater issues, and a defective front door.The plaintiffs claim
other items, the
emotional distress, lost value of their leasehold, personal injury, and property damage. The plaintiffs bring suit
against SoCal for private nuisance, breach of warranty of habitability, negligence, breach of covenant of good faith
and fair dealing, breach of implied covenant of quiet enjoyment, and retaliatory eviction. The plaintiffs’ complaint
seeks general damages, special damages, punitive damages, retroactive rent abatement, a judgment that the
subject building was uninhabitable and that the plaintiffs suffered damages due to the building’s condition, interest,
attorney’s fees, and injunctive relief.
5. Description of case in Cross-Complaint:
6. Has all discovery been completed: Yes D No E Date discovery anticipated to be completed: Segtember 2021
7. Do you agree to mediation? Yes D No E Please check type agreed to: Private: Court-sponsored:
8. Related cases, consolidation, and coordination: Please attach a Notice of Related Case.
D Amotionto D consolidate D Trial dates requested: Yes D No D Available dates: Time
estimate:
9. Other issues:
D The following additional matters are requested to be considered by the Court:
10. Meet and Confer:
E The panies represent that they have met and conferred on all subjects required by California Rules of Court, Rule 3.724.
D The parties have entered into the following stipulation(s):
11. Total number of pages attached (if any):
|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 Initial Trial Setting
Wm fi
Conference, including the written authority of the party where required.
Form # 13-09001-360
American LegalNet, Inc.
Rev.6-2020 Mandatory INITIAL TRIAL SETTING CONFERENCE STATEMENT .,
0%?
£7~Pb
§§>§
852:3 g;
$49
0%
£11707
Q
%
7,
®
®
“é?
$AQ7 §
'77 \.'W
$5” '9
$9)
S ‘ 72‘s
\./ V
Document Filed Date
February 09, 2021
Case Filing Date
August 24, 2020
Category
Breach of Contract/Warranty Unlimited
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QR G ll H N; STATE BAR NUMBER Reserved for Clerk's File Stamp NAME AND ADDRESS OF ATTORNEY OR PARTY WITHOUT ATIORNEY: Roger Mansukhani; Ian Williamson; Daniel J. Quon 190800; 222616; 321532 Gordon Rees Scully Mansukhani, LLP F i LE CALIForwA D . 101 W. Broadway, 20‘“ Floor, San Diego, CA 92101 S ”pmoa coun'r 0F 0F SAN BEaNmomo TELEPHONE No.; (619) 230-7797 DMSION SAN BERNARDINO CIVIL E—MAIL ADDRESS: dquon@grsm.com TRIAL SEWING CONFERENCE DATE; 02/24/2021 ATTORNEY FOR (Name): SoCaI Pacific MF FEB 0 9 2021 Management Corp dba Nova Point Apartments UNLIMITED CASE: g , /,-‘ ,p” ¢ m" " - _- v.” FAX No. (Optional): (61 9) 696-71 24 LIMITED CASE: ASHLEE BAYLESS. DEPUTY SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO COURTHOUSE ADDRESS: 247 W. Third St., San Bernardino, CA 92415 E— Kenya Brinson, PLAINTIFF: et al. DEFENDANT: SoCal Pacific MF Management Corp etc. CASE NUMBER: qx INITIAL TRIAL SETTING CONFERENCE STATEMENT CIVD8201 7097 .Iv\ Q~N INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. This document must be filed and {33‘ served at Ieast 15 days Qrior to the trial setting conference date. c 1. Party or parties (answer one): a. E This statement is submitted by party (name): Defendant Socal Pacific MF Management Corp ”Ci? b. D This statement is submitted jointly by parties (names): l 2. Service of Complaint on all parties has D has not D been completed. 'ZC-‘Z 3. Service of Cross-Complaint on all parties has D D been has not completed. 4. Description of case in Complaint: Among I {A ’ The allege inadequate maintenance by the defendant of their leased apartment. plaintiffs plaintiffs allege plumbing issues, mold, insects, heater issues, and a defective front door.The plaintiffs claim other items, the emotional distress, lost value of their leasehold, personal injury, and property damage. The plaintiffs bring suit against SoCal for private nuisance, breach of warranty of habitability, negligence, breach of covenant of good faith and fair dealing, breach of implied covenant of quiet enjoyment, and retaliatory eviction. The plaintiffs’ complaint seeks general damages, special damages, punitive damages, retroactive rent abatement, a judgment that the subject building was uninhabitable and that the plaintiffs suffered damages due to the building’s condition, interest, attorney’s fees, and injunctive relief. 5. Description of case in Cross-Complaint: 6. Has all discovery been completed: Yes D No E Date discovery anticipated to be completed: Segtember 2021 7. Do you agree to mediation? Yes D No E Please check type agreed to: Private: Court-sponsored: 8. Related cases, consolidation, and coordination: Please attach a Notice of Related Case. D Amotionto D consolidate D Trial dates requested: Yes D No D Available dates: Time estimate: 9. Other issues: D The following additional matters are requested to be considered by the Court: 10. Meet and Confer: E The panies represent that they have met and conferred on all subjects required by California Rules of Court, Rule 3.724. D The parties have entered into the following stipulation(s): 11. Total number of pages attached (if any): |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 Initial Trial Setting Wm fi Conference, including the written authority of the party where required. Form # 13-09001-360 American LegalNet, Inc. Rev.6-2020 Mandatory INITIAL TRIAL SETTING CONFERENCE STATEMENT ., 0%? £7~Pb §§>§ 852:3 g; $49 0% £11707 Q % 7, ® ® “é? $AQ7 § '77 \.'W $5” '9 $9) S ‘ 72‘s \./ V