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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar number, and address): FOR COURT USE ONLY
John C. Eck; Craig Price #194975; #51361 All fees waived
Griffith & Thornburgh, LLP per Gov. Code
8 E. Figueroa St., Suite 300 Section 6103.
Santa Barbara, CA 93101
TeLePHoNE No.: 805-965-5131 FAX NO. (Optional): 805-965-6751
E-malt Appress: eckK@g-tlaw.com; price@g-tlaw.com
ATTORNEY FOR (Name): Defendant Carpinteria Unified School District
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA
‘STREET ADDRESS: 1100 Anacapa Street
maine aooress: Post Office Box 21107
cry AND zip cove: Santa Barbara, CA 93102-1107
BRANCH NAME: ANACAPA DIVISION
PLAINTIFF/PETITIONER: John Doe CLG03277
DEFENDANT/RESPONDENT: Carpinteria Unified School District, a business entity of
form unknown;
and DOES 1-500
CASE MANAGEMENT STATEMENT CASE NUMBER:
1 _sLimitep CASE 22CV05053
(Check one): [UNLIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: October 6, 2023 Time: 8:30 a.m. Dept.: 3 Div.: Room:
Address of court (if different from the address above):
(_ Notice of Intent to Appear by Telephone, by (name):
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a EK This statement is submitted by party (name): Defendant Carpinteria Unified School District ("CUSD")
b. LJ This statement is submitted jointly by parties (names):
Complaint and cross-complaint (fo be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. (1 The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
a. C1 Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
6. O The following parties named in the complaint or cross-complaint
(1) [1 have not been served (specify names and explain why not):
(2) shave been served but have not appeared and have not been dismissed (specify names):
(3) shave had a default entered against them (specify names):
c. (1 The following additional parties may be added (specify names, nature of |involvement in case, and date by which
they may be served):
Description of case
a Type of case in & complaint Oi cross-complaint (Describe, including causes of action): Please see
Plaintiffs Case Management Statement.
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California CASE MANAGEMENT STATEMENT ules 3.720-3.730
CM-110 (Rev. September 1, 2021] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: John Doe CLG03277 CASE NUMBER:
DEFENDANT/RESPONDENT: Carpinteria Unified School District, et al. 22CV05053
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
eamings to date, and estimated future lost eamings. If equitable relief is sought, describe the nature of the relief.)
Please see Plaintiffs Case Management Statement.
OO (if more space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request [] a jury trial Bd a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a The trial has been set for (date): February 28, 2024
b. [1 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):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. Bd days (specify number): 10
b. [1 hours (short causes) (specify):
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 EX by the following:
Attorney: Eric J. Bengtson
Firm: Davis, Bengtson & Young
Address: 1960 The Alameda, Suite 210; San Jose, CA 95126
Telephone number: (669) 245-4200 f. Fax number: (408) 985-1814
E-mail address: eric@dby-law.com g. Party represented: Carpinteria Unified School District
(Additional representation is described in Attachment 8.
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 of the California Rules of Court for information about the
processes available through the court and community programs in this case.
(1) For parties represented by counsel: Counsel 0 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 (1 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) C1 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) XX 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):
Plaintiff is alleging damages in excess of $50,000,
CM-110 [Rev. September
1, 2021] CASE MANAGEMENT STATEMENT Page
2 of 5
CM-110
PLAINTIFF/PETITIONER: John Doe CLG03277 CASE NUMBER:
DEFENDANT/RESPONDENT: Carpinteria Unified Schoo! District, et al. 22CV05053
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 X Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
Settlement conference scheduled for (date): January 26, 2024
(2) Settlement
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
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
(CM-110 [Rev. September 1, 2021) CASE MANAGEMENT STATEMENT Page 3 of 5
CM-110
PLAINTIFF/PETITIONER: John Doe CLG03277 CASE NUMBER:
DEFENDANT/RESPONDENT: Carpinteria Unified School District, et al. 22CV05053
11. Insurance
a 1 insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: OO Yes 1 No
c. Coverage issues will significantly affect resolution of this case (explain):
Defendant Carpinteria Unified School District has made massive efforts to ascertain possible insurance
coverage during the time periods referenced in the Second Amended Complaint, but so far it appears there
will be no insurance coverage in this matter..
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
Oo Bankruptcy DI other (specify):
Status:
13. Related cases, consolidation, and coordination
a. 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.
b. [ Amotion to Oo consolidate 1 coordinate will be filed by (name party):
14. Bifurcation
(1 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
(1 The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a CO The party or parties have completed all discovery.
b {X] The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Descriptio Date
Defendant, CUSD Written Discovery In Process
Defendant, CUSD Depositions Nov. 2023
Defendant, CUSD Third Party Discovery Jan, 2024
Defendant, CUSD Expert Witnesses Per Code
c. (1 The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
(CM-110 (Rev. September1, 2021] CASE MANAGEMENT STATEMENT Page
4 of 5
CM-110
PLAINTIFF/PETITIONER: John Doe CLG03277 CASE NUMBER:
DEFENDANT/RESPONDENT: Carpinteria Unified School District, et al. 22CV05053
17. Economic litigation
a O 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.
bO 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
XX The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
The parties reached an agreed with regard to an amendment to the First Amended Complaint, so a Demurrer did
not need to be filed. The parties entered into a Stipulation re Filing of Second Amended Complaint, whereby
certain allegations would be removed from the First Amended Complaint (striking the Sth and 6th causes of
action and the 6th prayer for relief); the Order approving the Stipulation was filed on May 18, 2023. The parties
are in the process of conducting written discovery. The matter is set for Trial on February 28, 2024. Defendant
has requested that Plaintiff stipulate to the consolidation of related actions for purposes of depositions.
19. Meet and confer
a. X]__ 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):
See 18., above.
b. [1 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):
| 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.
CEA.
Date: September 20, 2023
John C. Eck rah w—
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
>
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
C0 Additional signatures are attached.
(CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5
CASE MANAGEMENT STATEMENT - ATTACHMENT
Attachment No. 13a.
1. Related cases, consolidation, and coordination
a. There are companion, underlying, or related cases.
(1) Name of case: James M. Ruano v. Carpinteria Unified School District, et al
(2) Name of court Santa Barbara County Superior Court
(3) Case number: 22CV03051
(4) Status: CMC 10/6/23 - Dept. 4
(1) Name of case: Timothy Marquez V. Defendant Doe 1, School District, et al.
(2) Name of court Santa Barbara County Superior Court
(3) Case number: 22CV04395
(4) Status: CMC 10/6/23 — Dept. 4
(1) Name of case: Jeffrey Dreyer v. Doe 1, A Public Entity, et al.
(2) Name of court: Santa Barbara County Superior Court
(3) Case number: 22CV04877
(4) Status: CMC 12/8/23; MSC 6/7/24; Trial 6/26/24 — Dept. 3
PROOF OF SERVICE
Doe v. CUSD
Santa Barbara County Superior Court, Anacapa Division, Case No. 22CV05053
I, Evelyn R. Downs, declare:
I am employed at Griffith & Thornburgh, LLP, in the County of Santa Barbara, State of
California. I am over the age of 18 and not a party to the within action. My business address is
8 East Figueroa Street, Suite 300, Santa Barbara, California 93101. My email address is
downs@g-tlaw.com.
On Sept. 20, 2023, I served the document(s) described as DEFENDANT CUSD’S CMC
STATEMENT on the interested parties in this action as follows:
By placing the original thereof enclosed in a sealed envelope addressed as follows or as listed
below:
o BY MAIL: As follows: Iam “readily familiar” with the firm’s practice of collection and
processing correspondence for mailing. Under that practice it would be deposited with
the U.S. postal service on that same day with postage thereon fully prepaid at Santa
Barbara, California, in the ordinary course of business. ] am aware that on motion of the
party served, service is presumed invalid if postal cancellation date or postage meter date
is more than one day after date of deposit for mailing in affidavit.
BY OVERNIGHT COURIER: I enclosed the documents in an envelope or package
provided by an overnight delivery carrier and addressed to the persons at the addresses
listed above. I placed the envelope or package for collection and overnight delivery at an
office or a regularly utilized drop box of the overnight delivery carrier.
BY E-MAIL: Per agreement between the parties for electronic service of documents, I
caused the document to be sent to the persons at the e-mail address listed above. I did
not receive, within a reasonable time after the transmission, any electronic message or
other indication that the transmission was unsuccessful.
(STATE) 1 declare under penalty of perjury under the laws of the State of California that
the foregoing is true and correct.
Q,
Executed on Sept. 20, 2023, at Santa Bethea.
Evelyn R. lowns
Doe v, CUSD
Santa Barbara County Superior Court, Anacapa Division, Case No. 22CV05053
Plaintiff's Counsel:
Pedro “Peter” de la Cerda, Esq.
Edwards & De La Cerda, PLLC
1341 W. Mockingbird Ln Ste 580W
Dallas, TX 75247
E-mail peter@edwardsdelacerda.com
Ryan Cavanaugh, Esq.
Constant Legal Group LLP
737 Bolivar Rd., Ste. 440
Cleveland, OH 44115
E-mail: ryan@constantllp.com
Defendant’s Co-Counsel:
Eric J. Bengtson
DAVIS, BENGTSON & YOUNG, APLC
1960 The Alameda, Suite 210
San Jose, CA 95126
Email: eric@dby-law.com
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar number, and address): FOR COURT USE ONLY John C. Eck; Craig Price #194975; #51361 All fees waived Griffith & Thornburgh, LLP per Gov. Code 8 E. Figueroa St., Suite 300 Section 6103. Santa Barbara, CA 93101 TeLePHoNE No.: 805-965-5131 FAX NO. (Optional): 805-965-6751 E-malt Appress: eckK@g-tlaw.com; price@g-tlaw.com ATTORNEY FOR (Name): Defendant Carpinteria Unified School District SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA ‘STREET ADDRESS: 1100 Anacapa Street maine aooress: Post Office Box 21107 cry AND zip cove: Santa Barbara, CA 93102-1107 BRANCH NAME: ANACAPA DIVISION PLAINTIFF/PETITIONER: John Doe CLG03277 DEFENDANT/RESPONDENT: Carpinteria Unified School District, a business entity of form unknown; and DOES 1-500 CASE MANAGEMENT STATEMENT CASE NUMBER: 1 _sLimitep CASE 22CV05053 (Check one): [UNLIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: October 6, 2023 Time: 8:30 a.m. Dept.: 3 Div.: Room: Address of court (if different from the address above): (_ Notice of Intent to Appear by Telephone, by (name): INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a EK This statement is submitted by party (name): Defendant Carpinteria Unified School District ("CUSD") b. LJ This statement is submitted jointly by parties (names): Complaint and cross-complaint (fo be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. (1 The cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) a. C1 Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. 6. O The following parties named in the complaint or cross-complaint (1) [1 have not been served (specify names and explain why not): (2) shave been served but have not appeared and have not been dismissed (specify names): (3) shave had a default entered against them (specify names): c. (1 The following additional parties may be added (specify names, nature of |involvement in case, and date by which they may be served): Description of case a Type of case in & complaint Oi cross-complaint (Describe, including causes of action): Please see Plaintiffs Case Management Statement. Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT ules 3.720-3.730 CM-110 (Rev. September 1, 2021] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: John Doe CLG03277 CASE NUMBER: DEFENDANT/RESPONDENT: Carpinteria Unified School District, et al. 22CV05053 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 eamings to date, and estimated future lost eamings. If equitable relief is sought, describe the nature of the relief.) Please see Plaintiffs Case Management Statement. OO (if more space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request [] a jury trial Bd a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a The trial has been set for (date): February 28, 2024 b. [1 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): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Estimated length of trial The party or parties estimate that the trial will take (check one): a. Bd days (specify number): 10 b. [1 hours (short causes) (specify): 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 EX by the following: Attorney: Eric J. Bengtson Firm: Davis, Bengtson & Young Address: 1960 The Alameda, Suite 210; San Jose, CA 95126 Telephone number: (669) 245-4200 f. Fax number: (408) 985-1814 E-mail address: eric@dby-law.com g. Party represented: Carpinteria Unified School District (Additional representation is described in Attachment 8. 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 of the California Rules of Court for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel 0 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 (1 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) C1 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) XX 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): Plaintiff is alleging damages in excess of $50,000, CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5 CM-110 PLAINTIFF/PETITIONER: John Doe CLG03277 CASE NUMBER: DEFENDANT/RESPONDENT: Carpinteria Unified Schoo! District, et al. 22CV05053 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 X Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled Settlement conference scheduled for (date): January 26, 2024 (2) Settlement 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 (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): (CM-110 [Rev. September 1, 2021) CASE MANAGEMENT STATEMENT Page 3 of 5 CM-110 PLAINTIFF/PETITIONER: John Doe CLG03277 CASE NUMBER: DEFENDANT/RESPONDENT: Carpinteria Unified School District, et al. 22CV05053 11. Insurance a 1 insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: OO Yes 1 No c. Coverage issues will significantly affect resolution of this case (explain): Defendant Carpinteria Unified School District has made massive efforts to ascertain possible insurance coverage during the time periods referenced in the Second Amended Complaint, but so far it appears there will be no insurance coverage in this matter.. 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Oo Bankruptcy DI other (specify): Status: 13. Related cases, consolidation, and coordination a. 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. b. [ Amotion to Oo consolidate 1 coordinate will be filed by (name party): 14. Bifurcation (1 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 (1 The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a CO The party or parties have completed all discovery. b {X] The following discovery will be completed by the date specified (describe all anticipated discovery): Party Descriptio Date Defendant, CUSD Written Discovery In Process Defendant, CUSD Depositions Nov. 2023 Defendant, CUSD Third Party Discovery Jan, 2024 Defendant, CUSD Expert Witnesses Per Code c. (1 The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): (CM-110 (Rev. September1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: John Doe CLG03277 CASE NUMBER: DEFENDANT/RESPONDENT: Carpinteria Unified School District, et al. 22CV05053 17. Economic litigation a O 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. bO 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 XX The party or parties request that the following additional matters be considered or determined at the case management conference (specify): The parties reached an agreed with regard to an amendment to the First Amended Complaint, so a Demurrer did not need to be filed. The parties entered into a Stipulation re Filing of Second Amended Complaint, whereby certain allegations would be removed from the First Amended Complaint (striking the Sth and 6th causes of action and the 6th prayer for relief); the Order approving the Stipulation was filed on May 18, 2023. The parties are in the process of conducting written discovery. The matter is set for Trial on February 28, 2024. Defendant has requested that Plaintiff stipulate to the consolidation of related actions for purposes of depositions. 19. Meet and confer a. X]__ 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): See 18., above. b. [1 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): | 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. CEA. Date: September 20, 2023 John C. Eck rah w— (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) > (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) C0 Additional signatures are attached. (CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5 CASE MANAGEMENT STATEMENT - ATTACHMENT Attachment No. 13a. 1. Related cases, consolidation, and coordination a. There are companion, underlying, or related cases. (1) Name of case: James M. Ruano v. Carpinteria Unified School District, et al (2) Name of court Santa Barbara County Superior Court (3) Case number: 22CV03051 (4) Status: CMC 10/6/23 - Dept. 4 (1) Name of case: Timothy Marquez V. Defendant Doe 1, School District, et al. (2) Name of court Santa Barbara County Superior Court (3) Case number: 22CV04395 (4) Status: CMC 10/6/23 — Dept. 4 (1) Name of case: Jeffrey Dreyer v. Doe 1, A Public Entity, et al. (2) Name of court: Santa Barbara County Superior Court (3) Case number: 22CV04877 (4) Status: CMC 12/8/23; MSC 6/7/24; Trial 6/26/24 — Dept. 3 PROOF OF SERVICE Doe v. CUSD Santa Barbara County Superior Court, Anacapa Division, Case No. 22CV05053 I, Evelyn R. Downs, declare: I am employed at Griffith & Thornburgh, LLP, in the County of Santa Barbara, State of California. I am over the age of 18 and not a party to the within action. My business address is 8 East Figueroa Street, Suite 300, Santa Barbara, California 93101. My email address is downs@g-tlaw.com. On Sept. 20, 2023, I served the document(s) described as DEFENDANT CUSD’S CMC STATEMENT on the interested parties in this action as follows: By placing the original thereof enclosed in a sealed envelope addressed as follows or as listed below: o BY MAIL: As follows: Iam “readily familiar” with the firm’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S. postal service on that same day with postage thereon fully prepaid at Santa Barbara, California, in the ordinary course of business. ] am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. BY OVERNIGHT COURIER: I enclosed the documents in an envelope or package provided by an overnight delivery carrier and addressed to the persons at the addresses listed above. I placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier. BY E-MAIL: Per agreement between the parties for electronic service of documents, I caused the document to be sent to the persons at the e-mail address listed above. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. (STATE) 1 declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Q, Executed on Sept. 20, 2023, at Santa Bethea. Evelyn R. lowns Doe v, CUSD Santa Barbara County Superior Court, Anacapa Division, Case No. 22CV05053 Plaintiff's Counsel: Pedro “Peter” de la Cerda, Esq. Edwards & De La Cerda, PLLC 1341 W. Mockingbird Ln Ste 580W Dallas, TX 75247 E-mail peter@edwardsdelacerda.com Ryan Cavanaugh, Esq. Constant Legal Group LLP 737 Bolivar Rd., Ste. 440 Cleveland, OH 44115 E-mail: ryan@constantllp.com Defendant’s Co-Counsel: Eric J. Bengtson DAVIS, BENGTSON & YOUNG, APLC 1960 The Alameda, Suite 210 San Jose, CA 95126 Email: eric@dby-law.com