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  • Nicole E Jordan vs Rogers Sheffield & Campbell LLP et alUnlimited Breach of Contract/Warranty (06) document preview
  • Nicole E Jordan vs Rogers Sheffield & Campbell LLP et alUnlimited Breach of Contract/Warranty (06) document preview
  • Nicole E Jordan vs Rogers Sheffield & Campbell LLP et alUnlimited Breach of Contract/Warranty (06) document preview
  • Nicole E Jordan vs Rogers Sheffield & Campbell LLP et alUnlimited Breach of Contract/Warranty (06) document preview
  • Nicole E Jordan vs Rogers Sheffield & Campbell LLP et alUnlimited Breach of Contract/Warranty (06) document preview
  • Nicole E Jordan vs Rogers Sheffield & Campbell LLP et alUnlimited Breach of Contract/Warranty (06) document preview
  • Nicole E Jordan vs Rogers Sheffield & Campbell LLP et alUnlimited Breach of Contract/Warranty (06) document preview
  • Nicole E Jordan vs Rogers Sheffield & Campbell LLP et alUnlimited Breach of Contract/Warranty (06) document preview
						
                                

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CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Rachel Van Mullem, County Counsel Jennifer J. Lee, Deputy County Counsel (SBN 249357) COUNTY OF SANTA BARBARA 105 E. Anapamu Street, Suite 201, Santa Barbara, California 93101 (805) 568-2950 TELEPHONE NO.: FAX NO. (Optional): (805) 568-2982 jenlee@countyofsb.org E-MAIL ADDRESS: ATTORNEY FOR (Name): Defendant, Jamie Cathleen Green SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA STREET ADDRESS: 1100 Anacapa Street MAILING ADDRESS: P.O. Box 21107 CITY AND ZIP CODE: Santa Barbara 93121-1107 BRANCH NAME: Anacapa Division PLAINTIFF/PETITIONER: Nicole Emily Jordan DEFENDANT/RESPONDENT: Rogers, Sheffield & Campbell, LLP, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE 23CV02702 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: December 11, 2023 Time: 8:30 a.m. Dept.: SB5 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. 1. Party or parties (answer one): a. This statement is submitted by party (name): Defendant, Jamie Cathleen Green b. 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): b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. The following parties named in the complaint or cross-complaint (1) have not been served (specify names and explain why not): (2) 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 complaint cross-complaint (Describe, including causes of action): Complaint contains 17 causes of action. 5 of these causes of action are against defendant Green and range from interference with contractual relations to emotional abuse and harassment of a dependent adult as well as an elderly person. Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730 CM-110 [Rev. September 1, 2021] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: Nicole Emily Jordan CASE NUMBER: DEFENDANT/RESPONDENT: Rogers, Sheffield & Campbell, LLP, et al. 23CV02702 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.) Plaintiff alleged various causes of action against multiple defendants over the course of at least 5 plus years. With respect to defendant Green, a public employee, plaintiff failed to comply with the Government Claims Act, which is the subject of a Demurrer and Motion to Strike set for hearing on December 11, 2023. (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request a jury triaI a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. The trial has been set for (date): b. No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 5-7 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: Additional 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 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 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) 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): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5 CM-110 PLAINTIFF/PETITIONER: Nicole Emily Jordan CASE NUMBER: DEFENDANT/RESPONDENT: Rogers, Sheffield & Campbell, LLP, et al. 23CV02702 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 Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): 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: Nicole Emily Jordan CASE NUMBER: DEFENDANT/RESPONDENT: Rogers, Sheffield & Campbell, LLP, et al. 23CV02702 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): County is self-insured 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. Bankruptcy 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. A motion to consolidate coordinate wiII 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): 16. Discovery a. 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 County of Santa Barbara Written discovery Feb 2024 County of Santa Barbara Plaintiff's Deposition March 2024 County of Santa Barbara Independent Medical Exam May 2024 County of Santa Barbara Expert Discovery Per CCP c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: Nicole Emily Jordan CASE NUMBER: DEFENDANT/RESPONDENT: Rogers, Sheffield & Campbell, LLP, et al. 23CV02702 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 The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 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: November 20, 2023 Jennifer J. Lee, Deputy County Counsel ► (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) ► (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5 1 PROOF OF SERVICE (C.C.P. §§ 1013(a), 2015.5) 2 STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA 3 4 I am a citizen of the United States and a resident of the county aforesaid; I am over the age of eighteen years and not a party to the within entitled action; my business address is 105 East 5 Anapamu Street, Santa Barbara, California. 6 On November 20, 2023, I served a true copy of the within DEFENDANT JAMIE CATHLEEN GREEN’S CASE MANAGEMENT CONFERENCE STATEMENT on the 7 Interested Parties in this action: 8 by mail to the person(s) indicted below. I am familiar with the practice of the Office of Santa Barbara County Counsel for the collection and processing of correspondence for 9 mailing with the United States Postal Service. In accordance with the ordinary course of 10 business, the above-mentioned document would have been deposited with the United States Postal Service, after having been deposited and processed for postage with the County of 11 Santa Barbara Central Mail Room. 12 SEE SERVICE LIST 13 14 15 via Federal Express delivery services company to the person(s) indicated below. 16 by e-mail or electronic transmission. I caused the document(s) to be sent from e-mail address mheuvel@countyofsb.org, to the persons at the e-mail addresses listed in the below. I 17 did not receive, within a reasonable time after the transmission, any electronic message or 18 other indication that the transmission was unsuccessful. Tamineh Roshanian, Attorneys for Plaintiff: tami@roshanianpayman.com 19 Kenny C. Brooks and Michael McCarthy, Attorneys for Defendants, Rogers Sheffield & Campbell, LLP and Sheila Price (as Representative of the estate of Homer 20 Sheffield): kbrooks@nemecek-cole.com and mstoecker@nemecek-cole.com 21 22 (State) I declare, under penalty of perjury, that the above is true and correct. 23 (Federal) I declare that I am employed in the office of a member of the Bar of this Court at whose direction the service was made. 24 Executed on November 20, 2023 at Santa Barbara, California. 25 26 _______________________ 27 COUNTY COUNSEL County of Santa Barbara Marleen van den Heuvel 105 East Anapamu Street Santa Barbara, CA 93101 (805) 568-2950 28 1. DEFENDANT GREEN’S DEMAND FOR JURY TRIAL 1 SERVICE LIST 2 3 Tamineh Roshanian 4 Roshanian Payman, PC 30721 Russell Ranch Road, Suite 140 5 Westlake Village, CA 91362-7383 (818) 330-5162 6 tami@roshanianpayman.com 7 Attorneys for Plaintiff 8 Kenny C. Brooks Michael McCarthy 9 NEMECEK & COLE A Professional Corporation 10 16255 Ventura Boulevard, Suite 300 11 Encino, California 91436-2300 (818) 788-9500 12 kbrooks@nemecek-cole.com mstoecker@nemecek-cole.com 13 Attorneys for Defendants, 14 Rogers Sheffield & Campbell, LLP and Sheila Price (as Representative of the estate 15 of Homer Sheffield) 16 17 18 19 20 21 22 23 24 25 26 27 COUNTY COUNSEL County of Santa Barbara 105 East Anapamu Street Santa Barbara, CA 93101 (805) 568-2950 28 2. DEFENDANT GREEN’S DEMAND FOR JURY TRIAL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 COUNTY COUNSEL County of Santa Barbara 105 East Anapamu Street Santa Barbara, CA 93101 (805) 568-2950 28 3. PROOF OF SERVICE