Preview
CM-110
[ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address). FOR COURT USE ONLY
Alicia L. Corby 269509
Herman Law
9434 Deschutes Road, Suite 1000
Palo Cedro, CA 96073
TELEPHONE NO: 305-931-2200 FAX NO. (Optional)
E-mail Aopress: acorby@hermanlaw.com
ATTORNEY FOR (Namo): Plaintiff, M.M.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Kern
sTReeT Apbress: 1215 Truxtun Avenue
MAILING ADDRESS: Same
ciry ano zip cone: Bakersfield 93301
BRANCH NAME: Metropolitan Division Justice Building
PLAINTIFF/PETITIONER: M.M.
DEFENDANT/RESPONDENT: County of Kern
CASE MANAGEMENT STATEMENT CASE NUMBER,
(Check one): UNLIMITED CASE [] LIMITED CASE BCV-22-101564
(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 AM Dept.: Div.:J Room:
\Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name):Alicia L. Corby, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
This statement is submitted by party (name): Plaintiff
b. [__] This statement is submitted jointly by parties (names):
Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): 6/21/2022
b. [___] The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
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):
Description of case
a Type of case in complaint [__] cross-complaint (Describe, including causes of action):
Plaintiff's Complaint against Defendants alleges negligence as well as physical, psychological, and emotional injuries
suffered by Plaintiff as a result of sexual conduct defined by CCP section 340.1.
Page 1 of 5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Cour,
Judicial Gouneil of California rules 3.720-3.730
CM-110 [Rev. September 1, 2021] www.courts.ce.gov
CM-110
PLAINTIFF/PETITIONER: M.M. CASE NUMBER.
DEFENDANT/RESPONDENT: County of Kern BCV-22-101564
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 alleges negligence against Defendants stemming from alleged sexual abuse of Plaintiff by a Perpetrator while Plaintiff was
in the custody and control of Defendants.
[__] (lf 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 [J 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):
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):
Please see attached list of unavailable dates.
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [Â¥ | days (specify number):5-7 court days
b. [_] 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 [Â¥] by the following:
a Attorney: Ryan D. Harvey
b. Firm: Herman Law
c., Address: 9434 Deschutes Road, Suite 1000, Palo Cedro, CA 96073
d Telephone number: 305-931-2200 f. Fax number:
e. E-mail address: rharvey@hermanlaw.com g. Party represented: Plaintiff
[-) 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 has [J 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 arbit ion or ci I 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] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: M.M. CASE NUMBER,
DEFENDANT/RESPONDENT: County of Kern BCV-22-101564
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):
[YZ] Mediation session not yet scheduled
[) Mediation session scheduled for (date):
(1) Mediation
[J Agreed to complete mediation by (date):
[__] Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement [J Settlement conference scheduled for (date):
conference [1 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
[J Agreed to complete neutral evaluation by (date):
[J 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):
[J Private arbitration not yet scheduled
(5) Binding private [J Private arbitration scheduled for (date):
arbitration [J Agreed to complete private arbitration by (date):
[__] Private arbitration completed on (date):
[J ADR session not yet scheduled
[__] ADR session scheduled for (date):
(6) Other (specify):
[-] Agreed to complete ADR session by (date):
{-_] ADR completed on (date):
(CM-110 [Rev. September 1, 2021] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: M.M. CASE NUMBER,
DEFENDANT/RESPONDENT: County of Kern BCV-22-101564
11. Insurance
a. ["_] Insurance carrier, if any, for party filing this statement (name).
b. Reservation of rights: {_] Yes [J 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 [J consolidate [5 coordinate will be filed by (name party):
14. Bifureation
[_) 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
[5 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. [QZ] The following discovery will be completed by the date specified (describe all anticipated discovery):
Descriptio Date
Plaintiff Written discovery Per Code
Plaintiff Oral depositions Per Code
Plaintiff Expert discovery Per Code
Plaintiff Expert depositions Per Code
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: M.M. CASE NUMBER,
DEFENDANT/RESPONDENT: County of Kern BCV-22-101564
17. Economic jation
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. [V] 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): TWO (2:
| 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: 11/21/2023
Alicia L. Corby
(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] Page 5 of 5
CASE MANAGEMENT STATEMENT
TRIAL CALENDAR/UNAVAILABLE DATES
RDH TRIAL CALENDAR DATES
CASE NAME COUNTY EVENT DATES
D.R. v. Orange County Orange Jury Trial 12/4/2023 - 12/11/2023
RDH Prepaid Vacation Prepaid Vacation 12/18/2023 — 1/5/2024
LC. v. Orange County Orange Jury Trial 1/8/2024 — 1/15/2024
J.W. v. Los Angeles USD Los Angeles Jury Trial 1/8/2024 - 1/15/2024
J.M. v. Los Angeles USD Los Angeles Jury Trial 2/20/2024 - 2/27/2024
R.M. v. Ducor Union SD Tulare Jury Trial 2/26/2024 - 3/5/2024
AS. v. Los Angeles USD Los Angeles Jury Trial 2/26/2024 - 3/5/2024
S.O. v. Bonita USD Los Angeles Jury Trial 2/28/2024 - 3/7/2024
G.M. v. Los Angeles USD Los Angeles Jury Trial 3/11/2024 - 3/18/2024
V.P. v. Los Angeles USD Los Angeles Jury Trial 3/11/2024 - 3/18/2024
K.A. v. Los Angeles Unified SD Los Angeles Jury Trial 3/18/2024 — 3/25/2024
JM. v. Visalia Unified SD Tulare Jury Trial 3/25/2024 - 4/2/2024
C.L. v. Los Angeles USD Los Angeles Jury Trial 3/25/2024 - 4/2/2024
K.O. v. County of Orange Orange Jury Trial 4/1/2024 - 4/5/2024
O.B. v. Los Angeles USD Los Angeles Jury Trial 4/2/2024 - 4/9/2024
B.H. v. Orange County Orange Jury Trial 4/15/2024 — 4/24/2024
J.R. v. Tustin USD Orange Jury Trial 4/22/2024 - 4/29/2024
T.C. v. Los Angeles USD Los Angeles Jury Trial 5/7/2024 - 5/14/2024
RDH Prepaid Vacation Prepaid Vacation 5/15/2024 — 5/25/2024
E.M. v. Los Angeles USD Los Angeles Jury Trial 5/28/2024 - 6/3/2024
L.M. v. Los Angeles USD Los Angeles Jury Trial 5/28/2024 - 6/3/2024
D.G. v. Tehachapi USD Kem Jury Trial 6/10/2024 — 6/15/2024
RDH Annual Reunion Prepaid Vacation 6/20/2024 - 7/14/2024
EI. v. Orange County Orange Jury Trial 7/15/2024 - 7/21/2024
J.S. v. YMCA Los Angeles Jury Trial 8/5/2024 - 8/13/2024
M.B. v. Ukiah USD Mendocino Jury Trial 8/19/2024 - 8/27/2024
C.G. v. County of Napa Napa Jury Trial 9/3/2024 - 9/10/2024
J.D. v. Los Angeles USD Los Angeles Jury Trial 9/16/2024 ~- 9/23/2024
W.B. v. County of Kern Kern Jury Trial 9/16/2024 - 9/23/2024
E.M. v. Orange County Orange Jury Trial 9/20/2024 - 9/27/2024
M.D. v. County of Butte Butte Jury Trial 9/23/2024 - 9/30/2024
AL. v. Saddleback Valley USD Orange Jury Trial 9/30/2024 - 10/5/2024
JR. v. State of California San Diego Jury Trial 10/4/2024 - 10/11/2024
R.P. v. Southeastern CA Conf Orange Jury Trial 10/7/2024 - 10/21/2024
S.B. v. Los Angeles USD Los Angeles Jury Trial 10/7/2024 - 10/15/2024
T.A. v. Los Angeles USD Los Angeles Jury Trial 10/14/2024 — 10/18/2024
C.D. v. County of Butte Butte Jury Trial 10/21/2024 — 10/27/2024
S.D. v. Orange County Orange Jury Trial 10/28/2024-11/4/2024
Page 1
TRIAL CALENDAR/UNAVAILABLE DATES
CASE NAME COUNTY EVENT DATES
Y.R. v. Los Angeles USD Los Angeles Jury Trial 10/28/2024 - 11/4/2024
R.K. v. Los Angeles USD Los Angeles Jury Trial 11/4/2024 - 11/11/2024
E.M. v. Los Angeles USD Los Angeles Jury Trial 11/13/2024-11/20/2024
D.L. v. Fresno County Fresno Jury Trial 11/25/2024 — 12/06/2024
R.P. v. Kern County Kern Jury Trial 12/2/2024 — 12/9/2024
R.H. v. Big Brothers & Big Sisters Orange Jury Trial 12/9/2024 - 12/16/2024
G.C. v. Orange County Orange Jury Trial 1/6/2026 - 1/13/2025
L.V. v. Compton Unified SD Los Angeles Jury Trial 1/13/2025 — 1/20/2025
J.D. v. Norwalk La Mirada USD Los Angeles Jury Trial 2/3/2025 — 2/10/2025
R.F. v. Kern County Kem Jury Trial 2/10/2025 — 2/16/2025
D.M. v. Orange County Orange Jury Trial 2/18/2025 - 2/25/2025
S.N.v. Fresno USD Fresno Jury Trial 2/24/2025 — 3/5/2025
A.M. v. Fresno USD Fresno Jury Trial 3/10/2025 — 3/19/2025
R.G. v. Kern County Kem Jury Trial 3/24/2025 — 3/30/2025
G.V. v. Fresno USD Fresno Jury Trial 4/1/2025 — 4/4/2025
Y.R. v. Mt. Moriah Baptist Church Los Angeles Jury Trial 4/1/2025 - 4/4/2024
T.L. v. Westminster USD Orange Jury Trial 4/7/2025 - 4/15/2025
T.Z. v. Monrovia USD Los Angeles Jury Trial 4/28/2025 - 5/2/2025
M.G. v. Montebello USD Los Angeles Jury Trial 5/12/2025 - 5/19/2025
RDH Annual Reunion Prepaid Vacation 7/21/2025 - 8/22/2025
Page 2
PROOF OF SERVICE
M.M. v. Kern County, et al.
Case No. BCV-22-101564
At the time of service, I was over 18 years of age and not a party to this action. I am employed
in the County of Shasta, State of California. My business address is 9434 Deschutes Road, Suite 1000,
Palo Cedro, California 96073. My electronic email address is lstovall@hermanlaw.com.
On the date executed below, I served the following document described as:
CASE MANAGEMENT STATEMENT
on the interested parties in this action as follows:
SEE ATTACHED SERVICE LIST
10
11 C) By United States Mail. I enclosed the documents in a sealed envelope or package addressed
to the persons at the addresses listed in the attached Service List and deposited the sealed
12 envelope with the United States Postal Service, with the postage fully prepaid. I am a resident
or employed in the county where the mailing occurred. The envelope or package was placed
13 in the mail at , California.
14
C) By Overnight Delivery. I enclosed the documents in an envelope or package provided by an
15 overnight delivery carrier and addressed to the persons at the addresses listed in the attached
Service List. I placed the envelope or package for collection and overnight delivery at an office
16 or a regularly utilized drop box of the overnight delivery carrier.
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C) By Fax Transmission. Based on an agreement of the parties to accept service by fax
18 transmission, I faxed the documents to the persons at the fax numbers listed in the attached
Service List. No error was reported by the fax machine that I used.
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20 (X) By Electronic Transmission. Pursuant to Section 1010.6 of the Code of Civil Procedure, I
transmitted the above-described document(s) by electronic transmission from the above noted
21 email address to the recipients listed in the attached Service List at the identified email
addresses, pursuant to the agreement of counsel for electronic service. I received no
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notification that the transmission was unsuccessful.
23
I declare under penalty of perjury under the laws of the State of California that the foregoing
24 is true and correct. Executed on November 21, 2023, at Palo Cedro, California.
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26 fron
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LYDIA STOVALL
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PROOF OF SERVICE
SERVICE LIST
M.M. v. Kern County, et al.
Case No. BCV-22-101564
COUNSEL ATTORNEY FOR DEFENDANT,
Andrew C. Hamilton, Esq. COUNTY OF KERN
Kathleen Rivera, Esq.
1115 Truxtun Avenue, Fourth Floor
Bakersfield, CA 93301
Service E-mails:
ahamilton@kerncounty.com
krivera@kerncounty.com
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kfoster@kerncounty.com
11 goldsberrymic@kerncounty.com
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PROOF OF SERVICE