Preview
CM-110
ATTORNEY OR PARTY WTHOUT ATTORNEY (Name, Dale Bar number. and address) FOR COURT USE ONLY
Neil P. Berman SBN: 246637
RUCKA O'BOYLE LOMBARDO & McKENNA
245 West Laurel Drive
Salinas, CA 93906
TELEPHONE NO.: 831-443-1051 FAX NO. Optional): 831-443-6419
E-MAIL ADDRESS: sergio@rolmlaw.com
ATTORNEY FOR (Name): Rita Goel
SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY
STREET ADDRESS- 1200 Aguajito Rd.
WALING ADDRESS. 1200 Aguajito Rd.
CITY AND ZiP CODE:
Monterey, 93940
BRANCH NAVE:
Monterey Courthouse
PLAINTIFF/PETITIONER: Rita Goel
DEFENDANT/RESPONDENT: City of Watsonville; Michael Christopher McKinley
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): X UNLIMITED CASE I I LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less) 23CV000482
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: October 31, 2023 Time:9:00 AM Dept:15 Div.:Civil Room:
Address of court (if different from the address above):
I I Notice of Intent to Appear by Telephone, by (name): Neil P. Berman, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. 1=1 This statement is submitted by party (name): Plaintiff, Rita Goel
b. I I This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): February 15, 2023
b.niThe cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. niAll parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. I—I The following parties named in the complaint or cross-complaint
(1) I I have not been served (specify names and explain why not):
(2) I I have been served but have not appeared and have not been dismissed (specify names):
(3) have had a default entered against them (specify names):
c. The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of case in I—I complaint I cross-complaint (Describe. including causes of action): Personal Injury
- Auto v Pedestrian
Page 1 of 5
Form Adopted for Mandatory Use Cal Rules of Court
Judicial Council o' Calitorn a
CASE MANAGEMENT STATEMENT rules 3.720-3.730
CM-110 (Rey. September 1.20211 itimY courts.= gm
WeabwOotb RisiBubiks-
CM-110
PLAINTIFF/PETITIONER: Rita Goel CASE NUMBER.
23CV000482
DEFENDANT/RESPONDENT: City of Watsonville; Michael Christopher McKinley
4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought. specify the injury and
damages claimed, including medical expenses to date (indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief)
Please see Attachment 4b.
F-1 (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 I—I a jury trial a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a.niThe trial has been set for (date):
b. x 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):
Feb 5, 2024; Feb 26, 2024; March 11, 2024; March 18, 2024; March 25, 2024; Apr 8, 2024; May 6, 2024; May 20,
2024; July 22, 2024; July 22, 2024; Nov 18, 2024
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. f x days (specify number): 3-4
b.I—I hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial I x I by the attorney or party listed in the caption n by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
niAdditional representation is described in Attachment 8.
9. Preference
This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 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 r--1 has I 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 nihas has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1)
[-I This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) I—I 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):
CM-110 [Rev. September 1. 2021] Page 2 of
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Rita Goel CASE NUMBER:
DEFENDANT/RESPONDENT:City of Watsonville; Michael Christopher McKinley 23CV000482
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):
I I Mediation session not yet scheduled
I I Mediation session scheduled for (date):
(1) Mediation I XI
Agreed to complete mediation by (date):
I X I Mediation completed on (date): October 9, 2023
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference I I
I J 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):
I I
arbitration Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
I I Private arbitration not yet scheduled
(5) Binding private Q Private arbitration scheduled for (date):
arbitration I I Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other (specify):
I I Agreed to complete ADR session by (date):
I I ADR completed on (date):
CM-110 [Rev. September 1.2021) Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFFiPETiTioNER: Rita Goel CASE NUMBER
DEFENDANT/RESPONDENT: City of Watsonville; Michael Christopher McKinley 23CV000482
11. Insurance
a. Q Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes No
c. Coverage issues will significantly affect resolution of this case (explain):
12.Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
FT Bankruptcy F-1 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:
niAdditional cases are described in Attachment 13a.
b. ni A motion to niconsolidate I I coordinate will be filed by (name party):
14.Bifurcation
I—I 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
niThe party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
None at this time, other than standard motions in limine.
16.Discovery
a. I I The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiff Written Discovery November 2023
Plaintiff Depositions November 2023
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 (Rev. September 1. 2021] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Rita Goel CASE NUMBER:
23CV000482
DEFENDANT/RESPONDENT: City of Watsonville; Michael Christopher McKinley
17. Economic litigation
a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
[—I 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. 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):
b. I—I 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): 2
I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: October 9, 2023
Neil P. Berman
(TYPE OR PRINT NAME) (SIGNVURE OF PARTY OR ATTOR\EY)
(TYPE OR PRAT NAME) (SIGNA-URE OF PARTY OR ATTOR\EY)
I—I Additional signatures are attached.
CM•110 [Rev September 1. 2021] Page 5 of 5
CASE MANAGEMENT STATEMENT
Case Name: Rita Goel v. City of Watsonville, et al. Case No. 23CV000482
Attachment 4b
This is a personal injury motor vehicle vs. pedestrian incident. Plaintiff was injured on 10/27/22.
She was exiting the CVS on South Main in Salinas and was in the parking lot when a vehicle hit
her. The vehicle was being operated by defendant officer who was operating a City of
Watsonville patrol vehicle.
Plaintiff was knocked to the pavement. She suffered a tibial plateau fracture of the left leg. She
was taken by ambulance to Salinas Valley Memorial Hospital. Her follow-up care has been with
orthopedist Dr. Bert Tardieu at Salinas Valley Medical Clinic Ortho.
She has had to use crutches, a walker and now a brace and compression sleeve. She has had
many sessions of physical therapy.
Her wage loss claim is approximately $20,000. She has private health insurance through Blue
Cross. We don't have the final Howell number as she is still in treatment, but an estimate is the
Howell number should be between $15,000-$25,000.
The parties were scheduled for court directed mediation with John Burton, Esq. on October 9,
2023. It became apparent that afternoon that the case would not settle. Plaintiff is requesting
that a trial date be set for 2024. The parties are scheduling a session with Mr. Burton for
December 6, 2023 which should be enough time for defendant to get the CVS video of the
incident that they are seeking.
Attachment to Case Management Statement
PROOF OF SERVICE BY MAIL & VIA E-MAIL
(Code of Civ. Proc. §§ 1013 (a), 2015.5, 1010.6)
STATE OF CALIFORNIA
COUNTY OF MONTEREY
Rita Goel v. City of Watsonville, et al.
Monterey County Superior Court
Case No. 23CV000482
I am employed in the County of Monterey, California. I am over the age of eighteen
years and not a party to the within entitled action; my business address is 245 West Laurel Drive,
Salinas, CA 93906. My electronic notification address is: spena@rolmlaw.com.
On the date written below, following ordinary business practice, I served the within
CASE MANAGEMENT STATEMENT on the parties named below by placing a true copy
thereof enclosed in a sealed envelope, for collection and mailing with the United States Postal
Service where it would be deposited in the United States Postal Service that same day in the
ordinary course of business, to the address(es) as follows:
Mark J. Austin, Esq. Attorneys for Defendant(s),
Arielle I. Berne, Esq. City of Watsonville;
BURKE, WILLIAMS & SORENSON Michael Christopher McKinley
444 South Flower Street, Suite 2400
Los Angeles, CA 90071-2953
Telephone: (213) 236-0600
Facsimile: (213) 236-2700
Email: masutin@bwslaw.com
Email: aberne@bwslaw.com
Email: TPaik@bwslaw.com
On this date, I also electronically served the foregoing based on a court order or an
agreement of the parties to accept service by e-mail or electronic transmission, I caused the
documents to be sent to the persons at the email addresses listed above. I did not receive, within
a reasonable time after the transmission, any electronic message or other indication that the
transmission was unsuccessful.
I declare, under penalty of perjury under the laws of the State of California that the
foregoing is true and correct and that this declaration was executed on October 9, 2023, at
Salinas, California.
Sergio A. Perla
Preview
CM-110 ATTORNEY OR PARTY WTHOUT ATTORNEY (Name, Dale Bar number. and address) FOR COURT USE ONLY Neil P. Berman SBN: 246637 RUCKA O'BOYLE LOMBARDO & McKENNA 245 West Laurel Drive Salinas, CA 93906 TELEPHONE NO.: 831-443-1051 FAX NO. Optional): 831-443-6419 E-MAIL ADDRESS: sergio@rolmlaw.com ATTORNEY FOR (Name): Rita Goel SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY STREET ADDRESS- 1200 Aguajito Rd. WALING ADDRESS. 1200 Aguajito Rd. CITY AND ZiP CODE: Monterey, 93940 BRANCH NAVE: Monterey Courthouse PLAINTIFF/PETITIONER: Rita Goel DEFENDANT/RESPONDENT: City of Watsonville; Michael Christopher McKinley CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): X UNLIMITED CASE I I LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) 23CV000482 A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: October 31, 2023 Time:9:00 AM Dept:15 Div.:Civil Room: Address of court (if different from the address above): I I Notice of Intent to Appear by Telephone, by (name): Neil P. Berman, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. 1=1 This statement is submitted by party (name): Plaintiff, Rita Goel b. I I This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): February 15, 2023 b.niThe cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. niAll parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. I—I The following parties named in the complaint or cross-complaint (1) I I have not been served (specify names and explain why not): (2) I I have been served but have not appeared and have not been dismissed (specify names): (3) have had a default entered against them (specify names): c. The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type of case in I—I complaint I cross-complaint (Describe. including causes of action): Personal Injury - Auto v Pedestrian Page 1 of 5 Form Adopted for Mandatory Use Cal Rules of Court Judicial Council o' Calitorn a CASE MANAGEMENT STATEMENT rules 3.720-3.730 CM-110 (Rey. September 1.20211 itimY courts.= gm WeabwOotb RisiBubiks- CM-110 PLAINTIFF/PETITIONER: Rita Goel CASE NUMBER. 23CV000482 DEFENDANT/RESPONDENT: City of Watsonville; Michael Christopher McKinley 4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought. specify the injury and damages claimed, including medical expenses to date (indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief) Please see Attachment 4b. F-1 (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 I—I a jury trial a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a.niThe trial has been set for (date): b. x 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): Feb 5, 2024; Feb 26, 2024; March 11, 2024; March 18, 2024; March 25, 2024; Apr 8, 2024; May 6, 2024; May 20, 2024; July 22, 2024; July 22, 2024; Nov 18, 2024 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. f x days (specify number): 3-4 b.I—I hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial I x I by the attorney or party listed in the caption n by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: niAdditional representation is described in Attachment 8. 9. Preference This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 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 r--1 has I 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 nihas has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) [-I This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) I—I 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): CM-110 [Rev. September 1. 2021] Page 2 of CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Rita Goel CASE NUMBER: DEFENDANT/RESPONDENT:City of Watsonville; Michael Christopher McKinley 23CV000482 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): I I Mediation session not yet scheduled I I Mediation session scheduled for (date): (1) Mediation I XI Agreed to complete mediation by (date): I X I Mediation completed on (date): October 9, 2023 Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference I I I J 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): I I arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): I I Private arbitration not yet scheduled (5) Binding private Q Private arbitration scheduled for (date): arbitration I I Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (date): (6) Other (specify): I I Agreed to complete ADR session by (date): I I ADR completed on (date): CM-110 [Rev. September 1.2021) Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFFiPETiTioNER: Rita Goel CASE NUMBER DEFENDANT/RESPONDENT: City of Watsonville; Michael Christopher McKinley 23CV000482 11. Insurance a. Q Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes No c. Coverage issues will significantly affect resolution of this case (explain): 12.Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. FT Bankruptcy F-1 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: niAdditional cases are described in Attachment 13a. b. ni A motion to niconsolidate I I coordinate will be filed by (name party): 14.Bifurcation I—I 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 niThe party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): None at this time, other than standard motions in limine. 16.Discovery a. I I The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Plaintiff Written Discovery November 2023 Plaintiff Depositions November 2023 c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 (Rev. September 1. 2021] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Rita Goel CASE NUMBER: 23CV000482 DEFENDANT/RESPONDENT: City of Watsonville; Michael Christopher McKinley 17. Economic litigation a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues [—I 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. 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): b. I—I 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): 2 I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: October 9, 2023 Neil P. Berman (TYPE OR PRINT NAME) (SIGNVURE OF PARTY OR ATTOR\EY) (TYPE OR PRAT NAME) (SIGNA-URE OF PARTY OR ATTOR\EY) I—I Additional signatures are attached. CM•110 [Rev September 1. 2021] Page 5 of 5 CASE MANAGEMENT STATEMENT Case Name: Rita Goel v. City of Watsonville, et al. Case No. 23CV000482 Attachment 4b This is a personal injury motor vehicle vs. pedestrian incident. Plaintiff was injured on 10/27/22. She was exiting the CVS on South Main in Salinas and was in the parking lot when a vehicle hit her. The vehicle was being operated by defendant officer who was operating a City of Watsonville patrol vehicle. Plaintiff was knocked to the pavement. She suffered a tibial plateau fracture of the left leg. She was taken by ambulance to Salinas Valley Memorial Hospital. Her follow-up care has been with orthopedist Dr. Bert Tardieu at Salinas Valley Medical Clinic Ortho. She has had to use crutches, a walker and now a brace and compression sleeve. She has had many sessions of physical therapy. Her wage loss claim is approximately $20,000. She has private health insurance through Blue Cross. We don't have the final Howell number as she is still in treatment, but an estimate is the Howell number should be between $15,000-$25,000. The parties were scheduled for court directed mediation with John Burton, Esq. on October 9, 2023. It became apparent that afternoon that the case would not settle. Plaintiff is requesting that a trial date be set for 2024. The parties are scheduling a session with Mr. Burton for December 6, 2023 which should be enough time for defendant to get the CVS video of the incident that they are seeking. Attachment to Case Management Statement PROOF OF SERVICE BY MAIL & VIA E-MAIL (Code of Civ. Proc. §§ 1013 (a), 2015.5, 1010.6) STATE OF CALIFORNIA COUNTY OF MONTEREY Rita Goel v. City of Watsonville, et al. Monterey County Superior Court Case No. 23CV000482 I am employed in the County of Monterey, California. I am over the age of eighteen years and not a party to the within entitled action; my business address is 245 West Laurel Drive, Salinas, CA 93906. My electronic notification address is: spena@rolmlaw.com. On the date written below, following ordinary business practice, I served the within CASE MANAGEMENT STATEMENT on the parties named below by placing a true copy thereof enclosed in a sealed envelope, for collection and mailing with the United States Postal Service where it would be deposited in the United States Postal Service that same day in the ordinary course of business, to the address(es) as follows: Mark J. Austin, Esq. Attorneys for Defendant(s), Arielle I. Berne, Esq. City of Watsonville; BURKE, WILLIAMS & SORENSON Michael Christopher McKinley 444 South Flower Street, Suite 2400 Los Angeles, CA 90071-2953 Telephone: (213) 236-0600 Facsimile: (213) 236-2700 Email: masutin@bwslaw.com Email: aberne@bwslaw.com Email: TPaik@bwslaw.com On this date, I also electronically served the foregoing based on a court order or an agreement of the parties to accept service by e-mail or electronic transmission, I caused the documents to be sent to the persons at the email addresses listed above. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. I declare, under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed on October 9, 2023, at Salinas, California. Sergio A. Perla