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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Sar number, and address): FOR COURT USE ONLY
Janette Leonidou (SBN 155257); Roger F. Liu (SBN 218345)
Leonidou & Rosin Professional Corporation
777 Cuesta Drive, Suite 200
Mountain View, CA 94040
tevepHone No: 650-691-2888 FAX NO (Optiona):650-69 11-2889
ear aooress: jleonidou@alr-law.com; rliu@alr-law.com
ATTORNEY FOR (Name): S.J. Amoroso Construction Co., LLC
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Barbara
STREET ADDRESS: 312-C East Cook Street 115 Civic Center
MAILING ADDRESS:
CITY AND ZIP CODE: Santa Maria, CA 93454
BRANCH NAME: Civil
PLAINTIFF/PETITIONER: BONESO BROTHERS CONSTRUCTION, INC.
DEFENDANT/RESPONDENT: S.J. AMOROSO CONSTRUCTION CO., LLC, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): [%]) UNLIMITED CASE ( Limitep case 21CV04742
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: November 1, 2023 Time: 8:30 Dept.: SM4 Div.: Room:
Address of court (if different from the address above):
{Z] Notice of intent to Appear by Telephone, by (name): Roger F. Liu
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a (J) This statement is submitted by party (name):
b. [XJ] This statement is submitted jointly by parties (names):
S.J. Amoroso, Federal Insurance Company and Liberty Mutual Insurance Company
Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. CC] The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
a (2) All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [2] The following parties named in the complaint or cross-complaint
(1) (D have not been served (specify names and explain why not):
(2) (CD have been served but have not appeared and have not been dismissed (specify names):
(3) (2) have had a default entered against them (specify names):
©. (2) The following additional parties may be added (specify names, nature of involvement in case, and the date by which
they may be served):
Description of case
a Type of case in (Q complaint C2) cross-complaint (Describe, including causes of action):
Complaint for breach of contract; open book account; quantum meruit; penalty and attorney's fees per B&P Cor
section 7108.5; claim on payment bond; and penalty and attorney's fees per PCC section 7107
Page 1 of 5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal, Rules of Court
Judicial Council of California CEB Essential rules 3,720-3.730
CM-110 [Rev. September 1, 2021] www.courts.ca.gov
ceb.com f:]Forms:
30273-161
CM-110
PLAINTIFF/PETITIONER: BONESO BROTHERS CONSTRUCTION, INC. CASE NUMBER:
21CV04742
DEFENDANT/RESPONDENT: S.J. AMOROSO CONSTRUCTION CO., LLC, et al.
4. b. Provide a brief statement of the case, including any damages. (/f 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.)
Plaintiff is a subcontractor to S.J. Amoroso on a public work of improvement owned by the County of Santa
Barbara and alleges claims for payment and purported extra work, delays and inefficiencies. The complaint
includes the public works payment bond sureties.
C (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 [X]) a jury trial C2) a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a. (QQ The trial has been set for (date): September 23, 2024
b. (CJ 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 [K) days (specify number): 10-15
b. [2] hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial [Z) by the attorney or party listed in the caption (Cy by the following:
a Attorney:
b Firm:
c. Address:
d Telephone number: f. Fax number:
e. E-mail address: g Party represented:
a Additional representation is described in Attachment 8.
9. Preference
C1 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 CQ) has (1 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 [L] has (1 has not reviewed the ADR information package identified in rule 3.221.
Referral to judicial arbitration or civil action mediation (if available).
(1) (2) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) C) 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) [&] 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):
Exceeds applicable limit
CM-110 (Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page
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GECEB | Essential
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PLAINTIFF/PETITIONER: BONESO BROTHERS CONSTRUCTION, INC. CASE NUMBER:
21CV04742
DEFENDANT/RESPONDENT: S.J. AMOROSO CONSTRUCTION CO., LLC, et al.
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):
(E) Mediation session not yet scheduled
C Mediation session scheduled for (date):
(1) Mediation
(Agreed to complete mediation by (date):
C2 Mediation completed on (date):
[K] Settlement conference not yet scheduled
(2) Settlement CC) Settlement conference scheduled for (date):
conference (2) Agreed to complete settlement conference by (date):
C) Settlement conference completed on (date):
C2 Neutral evaluation not yet scheduled
(2) Neutral evaluation scheduled for (date):
(3) Neutral evaluation
(J Agreed to complete neutral evaluation by (date):
() Neutral evaluation completed on (date):
(2) Judicial arbitration not yet scheduled
(4) Nonbinding judicial (2) Judicial arbitration scheduled for (date):
arbitration (2) Agreed to complete judicial arbitration by (date):
(C) Judicial arbitration completed on (date):
(2) Private arbitration not yet scheduled
(5) Binding private (C) Private arbitration scheduled for (date):
arbitration (2) Agreed to complete private arbitration by (date):
(] Private arbitration completed on (date):
(K] ADR session not yet scheduled
(6) Other (specify): (1 ADR session scheduled for (date):
Al (Cy Agreed to complete ADR session by (date):
(CV ADR completed on (date):
(CM-110 (Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page
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30273-161
CM-110
PLAINTIFF/PETITIONER: BONESO BROTHERS CONSTRUCTION, INC. CASE NUMBER:
21CV04742
DEFENDANT/RESPONDENT: S.J. AMOROSO CONSTRUCTION CO., LLC, et al.
41. Insurance
a (2) Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: U1 Yes No
c. CC) 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 CD Other (specify):
Status:
13. Related cases, consolidation, and coordination
a CC) 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 C2) 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
(&) The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Discovery and dispositive motions as necessary. A motion to stay this action pending ADR with the County ma,
need to be filed by defendants.
16 Discovery
a. (CJ The party or parties have completed all discovery.
b. [J The following discovery will be completed by the date specified (describe all anticipated discovery):
Desecriptior Date
Party
Defendants Written Discovery Per Code
Defendants Depositions Per Code
Defendants Expert Discovery Per Code
c. (2) The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
M-110 [Rev. September1, 2021] CASE MANAGEMENT STATEMENT Page
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GICEB| Forms: ential
30273-161
ceb.com
CM-110
PLAINTIFF/PETITIONER: BONESO BROTHERS CONSTRUCTION, INC. ‘CASE NUMBER:
21CV04742
DEFENDANT/RESPONDENT: S.J. AMOROSO CONSTRUCTION CO., LLC, et al.
17. Economic litigation
a (A This is a limited civil case (.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. (J 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
(QQ The party or parties request that the following additional matters be considered or determined at the case management
conference (specify): S.J. Amoroso has come to a form of ADR Agreement with the County in lieu of litigation. «
draft of the ADR has been proposed to Plaintiff. If Plaintiff agrees to the ADR agreement,
this action will be stayed pending completion of the ADR process. To date, Plaintiff has
not agreed to the ADR agreement or process.
19 Meet and confer
a 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. [Z] After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify): Please see Paragraph 18 above. A potential ADR agreement would stay this action and include th
other pending/related cases listed in Attachment 13a. The pending and related cases cannot be
consolidated/coordinated as two of the subcontractor actions are stayed and all are non-complex
cases.
20. Total number of pages attached (if any): JL
| 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: 10/17/2023
.
Roger F. Liu
(TYPE OR PRINT NAME)
»_ Voc IGN PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(CC) Additional signatures are attached.
(CM-110 (Rev. September 1, 2021) CASE MANAGEMENT STATEMENT Page 5 of 5
GICEB Essential
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30273-161
Attachment 13a
Federal Insurance
1. Cornerstone Detention Products, Inc. v. S.J, Amoroso Construction Ca., LLC,
Company and Liberty Mutual Insurance Company
Santa Barbara County Superior Court Case No. 22CV01946
Pending (action filed on May 23, 2022)
and
Thoma Electric, ine. v. S.J, Amoroso Construction Co., LLC, Federal Insurance Company
Uberty Mutual Insurance Company
Santa Barbara County Superior Court Case No. 22CV01852
Pending (action filed on May 13, 2022)
S.J. Amoroso Construction Co., LLCv. County of Santa Barbara
Orange County Superior Court Case No. 2022-01274057-CU-BC-CIC
Pending (action filed on August 5, 2022)
PROOF OF SERVICE
I am a resident of the State of Califomia, over the age of eighteen years, and nota
party to the within action. My business address is Leonidou & Rosin, 777 Cuesta Drive, Suite
200, Mountain View, CA 94040. On October 17, 2023, I served the within documents:
CASE MANAGEMENT STATEMENT
by electronically serving the above-referenced document(s) through One Legal,
LLC and/or File and ServexX press, an e-filing provider for Santa Barbara County
Superior Court. E-service in this action was completed on all parties listed on the
service list with the Court. This service complies with the Court’s order in this
case.
10
George F. Vogt, Jr., Esq.
11 Anthony C. Nichols
Herrig & Vogt
12 4210 Douglas Boulevard, Suite 100
Granite Bay, CA 95746
13 Tel: 916-960-1000
14 Fax: 916-960-1005
Email: g.vogt@ hvh.law
15 .nichols@hvh.law (Paralegal)
e Attomeys for Boneso Brothers Construction, Inc.
16
17 Tam readily familiar with the firm’s practice of collection and processing
18 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 in the ordinary course of business.
19
I declare that I am employed in the office of a member of the bar of this court at
20 whose direction the service was made.
21
I declare under penalty of perjury under the laws of the State of California that the|
22 above is true and correct.
23 Executed on October 17, 2023, at Mountain View, California.
24
25
Kimuyr (ew
—-----e---
26 Kamryn Cosmero
27
28
00260700.DOCX
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Sar number, and address): FOR COURT USE ONLY Janette Leonidou (SBN 155257); Roger F. Liu (SBN 218345) Leonidou & Rosin Professional Corporation 777 Cuesta Drive, Suite 200 Mountain View, CA 94040 tevepHone No: 650-691-2888 FAX NO (Optiona):650-69 11-2889 ear aooress: jleonidou@alr-law.com; rliu@alr-law.com ATTORNEY FOR (Name): S.J. Amoroso Construction Co., LLC SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Barbara STREET ADDRESS: 312-C East Cook Street 115 Civic Center MAILING ADDRESS: CITY AND ZIP CODE: Santa Maria, CA 93454 BRANCH NAME: Civil PLAINTIFF/PETITIONER: BONESO BROTHERS CONSTRUCTION, INC. DEFENDANT/RESPONDENT: S.J. AMOROSO CONSTRUCTION CO., LLC, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): [%]) UNLIMITED CASE ( Limitep case 21CV04742 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: November 1, 2023 Time: 8:30 Dept.: SM4 Div.: Room: Address of court (if different from the address above): {Z] Notice of intent to Appear by Telephone, by (name): Roger F. Liu INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a (J) This statement is submitted by party (name): b. [XJ] This statement is submitted jointly by parties (names): S.J. Amoroso, Federal Insurance Company and Liberty Mutual Insurance Company Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. CC] The cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) a (2) All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [2] The following parties named in the complaint or cross-complaint (1) (D have not been served (specify names and explain why not): (2) (CD have been served but have not appeared and have not been dismissed (specify names): (3) (2) have had a default entered against them (specify names): ©. (2) The following additional parties may be added (specify names, nature of involvement in case, and the date by which they may be served): Description of case a Type of case in (Q complaint C2) cross-complaint (Describe, including causes of action): Complaint for breach of contract; open book account; quantum meruit; penalty and attorney's fees per B&P Cor section 7108.5; claim on payment bond; and penalty and attorney's fees per PCC section 7107 Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal, Rules of Court Judicial Council of California CEB Essential rules 3,720-3.730 CM-110 [Rev. September 1, 2021] www.courts.ca.gov ceb.com f:]Forms: 30273-161 CM-110 PLAINTIFF/PETITIONER: BONESO BROTHERS CONSTRUCTION, INC. CASE NUMBER: 21CV04742 DEFENDANT/RESPONDENT: S.J. AMOROSO CONSTRUCTION CO., LLC, et al. 4. b. Provide a brief statement of the case, including any damages. (/f 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.) Plaintiff is a subcontractor to S.J. Amoroso on a public work of improvement owned by the County of Santa Barbara and alleges claims for payment and purported extra work, delays and inefficiencies. The complaint includes the public works payment bond sureties. C (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 [X]) a jury trial C2) a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a. (QQ The trial has been set for (date): September 23, 2024 b. (CJ 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 [K) days (specify number): 10-15 b. [2] hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial [Z) by the attorney or party listed in the caption (Cy by the following: a Attorney: b Firm: c. Address: d Telephone number: f. Fax number: e. E-mail address: g Party represented: a Additional representation is described in Attachment 8. 9. Preference C1 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 CQ) has (1 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 [L] has (1 has not reviewed the ADR information package identified in rule 3.221. Referral to judicial arbitration or civil action mediation (if available). (1) (2) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) C) 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) [&] 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): Exceeds applicable limit CM-110 (Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5 GECEB | Essential ceb.com | Sz 30273-161 CM-110 PLAINTIFF/PETITIONER: BONESO BROTHERS CONSTRUCTION, INC. CASE NUMBER: 21CV04742 DEFENDANT/RESPONDENT: S.J. AMOROSO CONSTRUCTION CO., LLC, et al. 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): (E) Mediation session not yet scheduled C Mediation session scheduled for (date): (1) Mediation (Agreed to complete mediation by (date): C2 Mediation completed on (date): [K] Settlement conference not yet scheduled (2) Settlement CC) Settlement conference scheduled for (date): conference (2) Agreed to complete settlement conference by (date): C) Settlement conference completed on (date): C2 Neutral evaluation not yet scheduled (2) Neutral evaluation scheduled for (date): (3) Neutral evaluation (J Agreed to complete neutral evaluation by (date): () Neutral evaluation completed on (date): (2) Judicial arbitration not yet scheduled (4) Nonbinding judicial (2) Judicial arbitration scheduled for (date): arbitration (2) Agreed to complete judicial arbitration by (date): (C) Judicial arbitration completed on (date): (2) Private arbitration not yet scheduled (5) Binding private (C) Private arbitration scheduled for (date): arbitration (2) Agreed to complete private arbitration by (date): (] Private arbitration completed on (date): (K] ADR session not yet scheduled (6) Other (specify): (1 ADR session scheduled for (date): Al (Cy Agreed to complete ADR session by (date): (CV ADR completed on (date): (CM-110 (Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5 GEICEB | Essential ceb.com i §2/Forms: 30273-161 CM-110 PLAINTIFF/PETITIONER: BONESO BROTHERS CONSTRUCTION, INC. CASE NUMBER: 21CV04742 DEFENDANT/RESPONDENT: S.J. AMOROSO CONSTRUCTION CO., LLC, et al. 41. Insurance a (2) Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: U1 Yes No c. CC) 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 CD Other (specify): Status: 13. Related cases, consolidation, and coordination a CC) 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 C2) 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 (&) The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Discovery and dispositive motions as necessary. A motion to stay this action pending ADR with the County ma, need to be filed by defendants. 16 Discovery a. (CJ The party or parties have completed all discovery. b. [J The following discovery will be completed by the date specified (describe all anticipated discovery): Desecriptior Date Party Defendants Written Discovery Per Code Defendants Depositions Per Code Defendants Expert Discovery Per Code c. (2) The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): M-110 [Rev. September1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5 GICEB| Forms: ential 30273-161 ceb.com CM-110 PLAINTIFF/PETITIONER: BONESO BROTHERS CONSTRUCTION, INC. ‘CASE NUMBER: 21CV04742 DEFENDANT/RESPONDENT: S.J. AMOROSO CONSTRUCTION CO., LLC, et al. 17. Economic litigation a (A This is a limited civil case (.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. (J 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 (QQ The party or parties request that the following additional matters be considered or determined at the case management conference (specify): S.J. Amoroso has come to a form of ADR Agreement with the County in lieu of litigation. « draft of the ADR has been proposed to Plaintiff. If Plaintiff agrees to the ADR agreement, this action will be stayed pending completion of the ADR process. To date, Plaintiff has not agreed to the ADR agreement or process. 19 Meet and confer a 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. [Z] After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): Please see Paragraph 18 above. A potential ADR agreement would stay this action and include th other pending/related cases listed in Attachment 13a. The pending and related cases cannot be consolidated/coordinated as two of the subcontractor actions are stayed and all are non-complex cases. 20. Total number of pages attached (if any): JL | 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: 10/17/2023 . Roger F. Liu (TYPE OR PRINT NAME) »_ Voc IGN PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (CC) Additional signatures are attached. (CM-110 (Rev. September 1, 2021) CASE MANAGEMENT STATEMENT Page 5 of 5 GICEB Essential ceb.com 2 Forms 30273-161 Attachment 13a Federal Insurance 1. Cornerstone Detention Products, Inc. v. S.J, Amoroso Construction Ca., LLC, Company and Liberty Mutual Insurance Company Santa Barbara County Superior Court Case No. 22CV01946 Pending (action filed on May 23, 2022) and Thoma Electric, ine. v. S.J, Amoroso Construction Co., LLC, Federal Insurance Company Uberty Mutual Insurance Company Santa Barbara County Superior Court Case No. 22CV01852 Pending (action filed on May 13, 2022) S.J. Amoroso Construction Co., LLCv. County of Santa Barbara Orange County Superior Court Case No. 2022-01274057-CU-BC-CIC Pending (action filed on August 5, 2022) PROOF OF SERVICE I am a resident of the State of Califomia, over the age of eighteen years, and nota party to the within action. My business address is Leonidou & Rosin, 777 Cuesta Drive, Suite 200, Mountain View, CA 94040. On October 17, 2023, I served the within documents: CASE MANAGEMENT STATEMENT by electronically serving the above-referenced document(s) through One Legal, LLC and/or File and ServexX press, an e-filing provider for Santa Barbara County Superior Court. E-service in this action was completed on all parties listed on the service list with the Court. This service complies with the Court’s order in this case. 10 George F. Vogt, Jr., Esq. 11 Anthony C. Nichols Herrig & Vogt 12 4210 Douglas Boulevard, Suite 100 Granite Bay, CA 95746 13 Tel: 916-960-1000 14 Fax: 916-960-1005 Email: g.vogt@ hvh.law 15 .nichols@hvh.law (Paralegal) e Attomeys for Boneso Brothers Construction, Inc. 16 17 Tam readily familiar with the firm’s practice of collection and processing 18 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 in the ordinary course of business. 19 I declare that I am employed in the office of a member of the bar of this court at 20 whose direction the service was made. 21 I declare under penalty of perjury under the laws of the State of California that the| 22 above is true and correct. 23 Executed on October 17, 2023, at Mountain View, California. 24 25 Kimuyr (ew —-----e--- 26 Kamryn Cosmero 27 28 00260700.DOCX