Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNE Y (Name, Stale Bar number, and ad'drone/r
TAMINEH ROSHANIAN (BN 139216) ¹ FOR COURTUSE ONLY
ROSHANIAN PAYMAN, PC
30721 RUSSELL RANCH RD, SUITE 140
WESTLAKE VILLAGE, CA 91362
TELEPHQNE Nod 818-330-5162 FAX NO. (Optional/:
EJSAILADDRESS: tami roshanianpayman.corn
ATTORNEY FOR (Namex NIGGLE E. JORDAN
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA
BTREETADDRESB 1100 ANACAPA STREET
MAILING
ADDRESS'ITY
AND ZIP CODE; SANTA BARBARA, CA 93121
BRANGH NAME: ANACAPA
PLAINTIFF/PETITIONER: NIGGLE E. JORDAN
DEFENDANT/RESPONDENT: ROGERS, SHEFFILED & CAMPBELL, LLP, ET. AL.
CASE MANAGEMENT STATEMENT
(Checkone)( ~x UNLIMITED CASE
(Amount demanded
~ LIMITEDCASE
(Amount demanded is $ 25,000
CASE NUMBER
23CV02702
exceeds $ 25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 12/1 1/2023 Time: 8:30 AM Dept.: SB5 Div J Room:
Address of court (if different /fom 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. ~x This statement is submitted by party (name)(PLAINTIFF NICOLE E. JORDAN
b. ~
This statement is submitted jointly by parties (names)(
2. Complaint and cross-complaint (lo be answered by p/a/n/iffs and cross-comp/ainanls
only)
a. The complaint was filed on (date)( 06/22/2023
b. ~
The cross-complaint, if any, was filed on (date):
a.
b.
~
3. Service (lo be answered by plaintiffs and cross-comp/ainan/s only)
~x
parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
All
The following parties named in the complaint or cross-complaint
(1) ~x have not been served (speci/y names and exp/a/n why not):
ANGELA HART (JORDAN)
(2) ~x have been served but have not appeared and have not been dismissed (specify names):
JENNIFER HEMFPLING
(3) ~ have had a default entered against them (specify names):
c. ~ The following additional parties may be added (speci/y names, nature of involvement in case, and date
they may be served):
by which
ADULT PROTECTIVE SERVICES OF COUNTY OF SANTA BARBARA
4. Description of case
a. Type of case in ~x complaint ~
cross-complaint (Descn'be, including causes of ac/ion):
17 Causes of Actions for Breach of (1) Fiduciary Duty, (2) Duty to Preserve Confidentiality,
(3) Contract, (4) Implied Duty of
Good Faith and Fair Dealing; and for Legal Malpractice, Intentional Interference With Contractual Relations, Fraud related
causes of actions, Negligence, Adult Abuse, Intentional Infliction of Emotional Distress, Reformation of Trust, &
Dedaratory Rel
Pane 1 ore
Form Adopted far Mandatory Uee
Judeial Cannoli of Calrfamre CASE MANAGEMENT STATEMENT
DM-110 IReu. september I, 2021]
awn tonne oa.gov
CM-110
PLAINTIFF/PETITIONER: NIGGLE E. JORDAN CASE NUMBER:
DEFENDANT/RESPONDENT: ROGERS, SHEFFILED & CAMPBELL, LLP, ET. AL. 23CV02702
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 jindicale source and amounlj, estimated future medical expenses, lost
earnings Io date, and estimated future last earnings. If equitable relief is sought, describe the nature of the relief)
Plaintiff has been damaged due to Defendant's intentional and negligent acts that may potentially disinherit her in the Probate
case. The amount of damages will depend on (1) outcome of pending appeal on whether Plaintiff's Probate Petition is a Trust
Contest, and whether the 6th Trust Amendment was a valid expression of Mr. and Mrs. Jordan's final testimentory wishes
~ (If more space is needed, check this box and attach a page designated as Aitachmen(4b.)
Jury or nonjury trial
The party or parties request ~x
requesting a jury trial):
a jury trial ~ a nonjury trial. (If more then one party, provide the name ofeach party
Trial date
a.
b.
~
~x
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):
the court is requested to set a trial date afier the final disposition of the Probate Case No. 21PR00040
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. ~x days (specify number): 8-10 days
b.
8. Trial
~ hours (short causes) (spec)fy):
representation (Io be answered for each party)
The party or parties will be represented at trial ~x by the attorney or party listed
a. Attorney:
in the caption ~ by the following:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
~
e. E-mail address:
Additional representation is described in Attachment 8.
g. Party represented:
~
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 ~x has ~ has not provided the ADR information package identified
(2) For self-represented parties: Party ~ ~
in rule 3.221 to the client and reviewed ADR options with the client.
has has not reviewed the ADR information package identified in rule 3.221.
b.
(1)~
Referral to judicial arbitration or civil action mediation (if available).
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
(2)~ statutory limit.
Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
(3)~ Civil Procedure section 1141.11.
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 [Re . Seplemem 1,2021I
CASE MANAGEMENT STATEMENT Peso 2 of 0
CM-110
PLAINTIFF/PETITIONER: NIGGLE E. JORDAN CASE NUMBER:
DEFENDANT/RESPONDENT: ROGERS, SHEFFILED & 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 a/I 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 AD R indicate the status of the processes (attach a copy of the parties'DR
processes (check a/I that apply): stipulation):
~
~ Mediation session not yet scheduled
(1) Mediation
~
~
Mediation session scheduled for (date)i
Agreed to complete mediation by (date)i
Mediation completed on (date):
~
~ Settlement conference not yet scheduled
(2) Settlement
conference
~
~
Settlement conference scheduled for (date):
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):
(4) Nonbinding judicial
~
~ Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date):
arbitration
~
~ Agreed to complete judicial arbitration by (date)i
Judicial arbitration completed on (date) 2
(5) Binding private
~
~ Private arbitration not yet scheduled
arbitration
~
~
Private arbitration scheduled for (date):
Agreed to complete private arbitration by (date)i
Private arbitration completed on (date)i
~
~ ADR session not yet scheduled
(6) Other (specify):
~
~
ADR session scheduled for (date):
Agreed to complete ADR session by (date)i
ADR completed on (date):
CM-110 [Ref. Sepimmeef I, 202'I]
CASE MANAGEMENT STATEMENT Page 3 of 6
CII-1 10
PLAINTIFF/PETITIONER; NIGGLE E. JORDAN CASE NUMBER:
DEFENDANT/RESPONDENT: ROGERS, SHEFFILED & CAMPBELL, LLP, ET. AL. 23CV02702
11. Insurance
a. ~ Insurance carrier,
b. Reservation ofrights: ~ ~
if any,
Yes
for party filing this statement (name):
c. ~ No
Coverage issues will significantly affect resolution of this case (e//plain):
12. Jurisdiction
~
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
Bankruptcy ~x Other (specify): Plaintiff requests the court to transfer the case to Ventura or Los Angeles County
Statusui Plaintiff is filing a Section 170.1 Motion and a request to transfer the case to another
County due to prejudice
13. Related cases, consolidation, and coordination
a. ~x There are companion, underlying, or related cases.
(1) Name of case: In re matter of THE BORIMIR AND VIRIGINA JORDAN FAMILY TRUST,
(2) Name of court: SANTA BARBARA SUPERIOR COURT
(3) Case number: 21PR00040
(4) Status: Awaiting outcome of Nicole Jordan's Appeal of the Court's granting Angela Jordan's Demurrer
~ Additional cases are described in Attachment 13a.
~
b. A motion to ~
consolidate ~x coordinate will befiledby (name party):
The Motion to coordinate will be filed after the Court of Appeals issues its ruling
14. Bifurcation
~ The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes
action (specify moving party, type of motion, and reasons)/
of
15. Other motions
~x The party or parties expect to file the following motions before trial (specify moving party, lype of motion, and issues):
A motion to remove Judge Sterne under CCP Section 170.1 and a Motion to transfer the case to Ventura or Los Angeles
County
16. Discovery
a.
b.
~
~x
The party or parties have completed all discovery.
The following discovery will be completed by the date specified (descnbe all anlicipaled d/scovefy)/
~rt Descriotion Date
NIGGLE JORDAN WRITTEN OTHER DISCOVER TO BE CONDUCTED
& FEBRUARY 2024
DEPOSITION OF DEFENDANTS PER CCP
EXPERT DISCOVERY PER CCP
REQUEST TO SUBMIT TO MEDICAL EXAMINATION TBD
OF DEFENDANTS ANGELA AND JENNIFER
c. ~x The following discovery issues, including issues regarding the discovery of electronically stored
information, are
anticipated (specify):
NONE OF THE WITNESSES WHO HAD PERSONAL KKNOWLEDGE OF THE MATTERS COMPLAINT OF IN CAUSES
OF
ACTIONS AGAINST ROGERS, SEHFFIELD & CAMPBELL ARE AVAILABLE (HOMER SHEFFIELD IS DECEASED
AND
THE OTHER EMPLOYEES WITH FIRST HAND KNOWELDGE DO NOT APPEAR TO BE WORKING AT THE FIRM
ANY
LONGER. IT IS ALSO ANTICIPATED THAT ONE OR MORE DEFENDANTS OR THIRD PARTIES HAVE
OR MAY ATTEMPT
TO INTIMIDATE WITNESSES AND FRAME PLAINTIFF FOR OFFENSES TO GAIN AN ADVANTAGE IN THIS
LITIGATION
CM 110 IRev. S apl emfer 1, 2021]
CASE MANAGEMENT STATEMENT Page 4 of S
CM-110
PLAINTIFF/PETITIONER: NICOLE E. JORDAN CASE NUMBER;
DEFENDANT/RESPONDENT: ROGERS, SHEFFILED & 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
of Civil Procedure sections 90-98 will apply to this case.
Code
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 relaling lo discovery or Irial
should not apply fo this case):
18. Otherissues
~x The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
JUDGE STERNE RECUSES HERSELF FROM THE CASE DUE TO PRECEIVED PREJUDGE AGAINST PLAINTIFF
NIGGLE JORDAN AND HER COUNSEL TAMINEH ROSHANIAN AND THE CASE BE DESIGNATED COMPLEX
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 confemng
(specify):
as required by rule 3.724 of the California Rules of Court, the parties agree on the following
20. Total number of pages attached (if any):
Iam 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: 12(07(2023
TAMINEH ROSHANIAN
(TYPE OR PRINT NAME) (SIGNAT(IRE OF PARTY OR ATTORNEY)
ITYPE OR PRINT NAME)
~
(SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 IRm. Soptmoter I, 2021)
CASE MANAGEMENT STATEMENT Poso 0 or S
PROOF OF SERVICE
Nicole Jordan v. Rogers Sheffield 4k Campbell, et al.
Case No.: 23CV02702
I, Tamineh Roshanian, am a citizen of the United States and employed in the county aforesaid; I am
over the age of 18 years and not a party to the within action; my business address is 30721 Russell Ranch
Rd, Suite 140, Westlake Village, CA 91362.
I served the foregoing documents described as followed:
NICOLE JORDAN'S CASE MANAGEMENT STATEMENT
Upon the interested parties in the action as follows:
KENNY C. BROOKS (SBN 254842)
MICHAEL MCCARTHY (SBN 89588)
NEMECEK&COLE
16255 Ventura Boulevard, Suite 300
Encino, California 91436-2300
EmaiL Kim Brooks KBrooks&nemecek-cole.corn
Michelle Stoecker: mshaoirolRnemecek-cole.corn
Rachel Van Mullem, County Counsel
Jennifer J. Lee, Deputy
COUNTY OF SANTA BARBARA
105 E. Anapamu Street, Suite 201
Santa Barbara, CA 93101
Email: ilee&countvofsb.org
X BY ELECTRONIC MAIL [to individual person(s)]: By electronically transmitting the
document(s) listed above to the e-mail address(es) of the person(s) set forth on the attached
service list from the e-mail address mstoecker nemecek-cole.corn To my knowledge, the
transmission was reported as completed and without error. See, California Rules of Court,
Rule 2.25 I.
I declare under penalty of perjury that the forgoing is true and correct, and that this declaration
was executed 12/17/2023, at Ventura County, California.
Tamineh Roshanian
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNE Y (Name, Stale Bar number, and ad'drone/r TAMINEH ROSHANIAN (BN 139216) ¹ FOR COURTUSE ONLY ROSHANIAN PAYMAN, PC 30721 RUSSELL RANCH RD, SUITE 140 WESTLAKE VILLAGE, CA 91362 TELEPHQNE Nod 818-330-5162 FAX NO. (Optional/: EJSAILADDRESS: tami roshanianpayman.corn ATTORNEY FOR (Namex NIGGLE E. JORDAN SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA BTREETADDRESB 1100 ANACAPA STREET MAILING ADDRESS'ITY AND ZIP CODE; SANTA BARBARA, CA 93121 BRANGH NAME: ANACAPA PLAINTIFF/PETITIONER: NIGGLE E. JORDAN DEFENDANT/RESPONDENT: ROGERS, SHEFFILED & CAMPBELL, LLP, ET. AL. CASE MANAGEMENT STATEMENT (Checkone)( ~x UNLIMITED CASE (Amount demanded ~ LIMITEDCASE (Amount demanded is $ 25,000 CASE NUMBER 23CV02702 exceeds $ 25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 12/1 1/2023 Time: 8:30 AM Dept.: SB5 Div J Room: Address of court (if different /fom 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. ~x This statement is submitted by party (name)(PLAINTIFF NICOLE E. JORDAN b. ~ This statement is submitted jointly by parties (names)( 2. Complaint and cross-complaint (lo be answered by p/a/n/iffs and cross-comp/ainanls only) a. The complaint was filed on (date)( 06/22/2023 b. ~ The cross-complaint, if any, was filed on (date): a. b. ~ 3. Service (lo be answered by plaintiffs and cross-comp/ainan/s only) ~x parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. All The following parties named in the complaint or cross-complaint (1) ~x have not been served (speci/y names and exp/a/n why not): ANGELA HART (JORDAN) (2) ~x have been served but have not appeared and have not been dismissed (specify names): JENNIFER HEMFPLING (3) ~ have had a default entered against them (specify names): c. ~ The following additional parties may be added (speci/y names, nature of involvement in case, and date they may be served): by which ADULT PROTECTIVE SERVICES OF COUNTY OF SANTA BARBARA 4. Description of case a. Type of case in ~x complaint ~ cross-complaint (Descn'be, including causes of ac/ion): 17 Causes of Actions for Breach of (1) Fiduciary Duty, (2) Duty to Preserve Confidentiality, (3) Contract, (4) Implied Duty of Good Faith and Fair Dealing; and for Legal Malpractice, Intentional Interference With Contractual Relations, Fraud related causes of actions, Negligence, Adult Abuse, Intentional Infliction of Emotional Distress, Reformation of Trust, & Dedaratory Rel Pane 1 ore Form Adopted far Mandatory Uee Judeial Cannoli of Calrfamre CASE MANAGEMENT STATEMENT DM-110 IReu. september I, 2021] awn tonne oa.gov CM-110 PLAINTIFF/PETITIONER: NIGGLE E. JORDAN CASE NUMBER: DEFENDANT/RESPONDENT: ROGERS, SHEFFILED & CAMPBELL, LLP, ET. AL. 23CV02702 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 jindicale source and amounlj, estimated future medical expenses, lost earnings Io date, and estimated future last earnings. If equitable relief is sought, describe the nature of the relief) Plaintiff has been damaged due to Defendant's intentional and negligent acts that may potentially disinherit her in the Probate case. The amount of damages will depend on (1) outcome of pending appeal on whether Plaintiff's Probate Petition is a Trust Contest, and whether the 6th Trust Amendment was a valid expression of Mr. and Mrs. Jordan's final testimentory wishes ~ (If more space is needed, check this box and attach a page designated as Aitachmen(4b.) Jury or nonjury trial The party or parties request ~x requesting a jury trial): a jury trial ~ a nonjury trial. (If more then one party, provide the name ofeach party Trial date a. b. ~ ~x 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): the court is requested to set a trial date afier the final disposition of the Probate Case No. 21PR00040 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. ~x days (specify number): 8-10 days b. 8. Trial ~ hours (short causes) (spec)fy): representation (Io be answered for each party) The party or parties will be represented at trial ~x by the attorney or party listed a. Attorney: in the caption ~ by the following: b. Firm: c. Address: d. Telephone number: f. Fax number: ~ e. E-mail address: Additional representation is described in Attachment 8. g. Party represented: ~ 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 ~x has ~ has not provided the ADR information package identified (2) For self-represented parties: Party ~ ~ in rule 3.221 to the client and reviewed ADR options with the client. has has not reviewed the ADR information package identified in rule 3.221. b. (1)~ Referral to judicial arbitration or civil action mediation (if available). 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 (2)~ statutory limit. Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of (3)~ Civil Procedure section 1141.11. 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 [Re . Seplemem 1,2021I CASE MANAGEMENT STATEMENT Peso 2 of 0 CM-110 PLAINTIFF/PETITIONER: NIGGLE E. JORDAN CASE NUMBER: DEFENDANT/RESPONDENT: ROGERS, SHEFFILED & 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 a/I 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 AD R indicate the status of the processes (attach a copy of the parties'DR processes (check a/I that apply): stipulation): ~ ~ Mediation session not yet scheduled (1) Mediation ~ ~ Mediation session scheduled for (date)i Agreed to complete mediation by (date)i Mediation completed on (date): ~ ~ Settlement conference not yet scheduled (2) Settlement conference ~ ~ Settlement conference scheduled for (date): 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): (4) Nonbinding judicial ~ ~ Judicial arbitration not yet scheduled Judicial arbitration scheduled for (date): arbitration ~ ~ Agreed to complete judicial arbitration by (date)i Judicial arbitration completed on (date) 2 (5) Binding private ~ ~ Private arbitration not yet scheduled arbitration ~ ~ Private arbitration scheduled for (date): Agreed to complete private arbitration by (date)i Private arbitration completed on (date)i ~ ~ ADR session not yet scheduled (6) Other (specify): ~ ~ ADR session scheduled for (date): Agreed to complete ADR session by (date)i ADR completed on (date): CM-110 [Ref. Sepimmeef I, 202'I] CASE MANAGEMENT STATEMENT Page 3 of 6 CII-1 10 PLAINTIFF/PETITIONER; NIGGLE E. JORDAN CASE NUMBER: DEFENDANT/RESPONDENT: ROGERS, SHEFFILED & CAMPBELL, LLP, ET. AL. 23CV02702 11. Insurance a. ~ Insurance carrier, b. Reservation ofrights: ~ ~ if any, Yes for party filing this statement (name): c. ~ No Coverage issues will significantly affect resolution of this case (e//plain): 12. Jurisdiction ~ Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Bankruptcy ~x Other (specify): Plaintiff requests the court to transfer the case to Ventura or Los Angeles County Statusui Plaintiff is filing a Section 170.1 Motion and a request to transfer the case to another County due to prejudice 13. Related cases, consolidation, and coordination a. ~x There are companion, underlying, or related cases. (1) Name of case: In re matter of THE BORIMIR AND VIRIGINA JORDAN FAMILY TRUST, (2) Name of court: SANTA BARBARA SUPERIOR COURT (3) Case number: 21PR00040 (4) Status: Awaiting outcome of Nicole Jordan's Appeal of the Court's granting Angela Jordan's Demurrer ~ Additional cases are described in Attachment 13a. ~ b. A motion to ~ consolidate ~x coordinate will befiledby (name party): The Motion to coordinate will be filed after the Court of Appeals issues its ruling 14. Bifurcation ~ The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes action (specify moving party, type of motion, and reasons)/ of 15. Other motions ~x The party or parties expect to file the following motions before trial (specify moving party, lype of motion, and issues): A motion to remove Judge Sterne under CCP Section 170.1 and a Motion to transfer the case to Ventura or Los Angeles County 16. Discovery a. b. ~ ~x The party or parties have completed all discovery. The following discovery will be completed by the date specified (descnbe all anlicipaled d/scovefy)/ ~rt Descriotion Date NIGGLE JORDAN WRITTEN OTHER DISCOVER TO BE CONDUCTED & FEBRUARY 2024 DEPOSITION OF DEFENDANTS PER CCP EXPERT DISCOVERY PER CCP REQUEST TO SUBMIT TO MEDICAL EXAMINATION TBD OF DEFENDANTS ANGELA AND JENNIFER c. ~x The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): NONE OF THE WITNESSES WHO HAD PERSONAL KKNOWLEDGE OF THE MATTERS COMPLAINT OF IN CAUSES OF ACTIONS AGAINST ROGERS, SEHFFIELD & CAMPBELL ARE AVAILABLE (HOMER SHEFFIELD IS DECEASED AND THE OTHER EMPLOYEES WITH FIRST HAND KNOWELDGE DO NOT APPEAR TO BE WORKING AT THE FIRM ANY LONGER. IT IS ALSO ANTICIPATED THAT ONE OR MORE DEFENDANTS OR THIRD PARTIES HAVE OR MAY ATTEMPT TO INTIMIDATE WITNESSES AND FRAME PLAINTIFF FOR OFFENSES TO GAIN AN ADVANTAGE IN THIS LITIGATION CM 110 IRev. S apl emfer 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of S CM-110 PLAINTIFF/PETITIONER: NICOLE E. JORDAN CASE NUMBER; DEFENDANT/RESPONDENT: ROGERS, SHEFFILED & 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 of Civil Procedure sections 90-98 will apply to this case. Code 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 relaling lo discovery or Irial should not apply fo this case): 18. Otherissues ~x The party or parties request that the following additional matters be considered or determined at the case management conference (specify): JUDGE STERNE RECUSES HERSELF FROM THE CASE DUE TO PRECEIVED PREJUDGE AGAINST PLAINTIFF NIGGLE JORDAN AND HER COUNSEL TAMINEH ROSHANIAN AND THE CASE BE DESIGNATED COMPLEX 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 confemng (specify): as required by rule 3.724 of the California Rules of Court, the parties agree on the following 20. Total number of pages attached (if any): Iam 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: 12(07(2023 TAMINEH ROSHANIAN (TYPE OR PRINT NAME) (SIGNAT(IRE OF PARTY OR ATTORNEY) ITYPE OR PRINT NAME) ~ (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 IRm. Soptmoter I, 2021) CASE MANAGEMENT STATEMENT Poso 0 or S PROOF OF SERVICE Nicole Jordan v. Rogers Sheffield 4k Campbell, et al. Case No.: 23CV02702 I, Tamineh Roshanian, am a citizen of the United States and employed in the county aforesaid; I am over the age of 18 years and not a party to the within action; my business address is 30721 Russell Ranch Rd, Suite 140, Westlake Village, CA 91362. I served the foregoing documents described as followed: NICOLE JORDAN'S CASE MANAGEMENT STATEMENT Upon the interested parties in the action as follows: KENNY C. BROOKS (SBN 254842) MICHAEL MCCARTHY (SBN 89588) NEMECEK&COLE 16255 Ventura Boulevard, Suite 300 Encino, California 91436-2300 EmaiL Kim Brooks KBrooks&nemecek-cole.corn Michelle Stoecker: mshaoirolRnemecek-cole.corn Rachel Van Mullem, County Counsel Jennifer J. Lee, Deputy COUNTY OF SANTA BARBARA 105 E. Anapamu Street, Suite 201 Santa Barbara, CA 93101 Email: ilee&countvofsb.org X BY ELECTRONIC MAIL [to individual person(s)]: By electronically transmitting the document(s) listed above to the e-mail address(es) of the person(s) set forth on the attached service list from the e-mail address mstoecker nemecek-cole.corn To my knowledge, the transmission was reported as completed and without error. See, California Rules of Court, Rule 2.25 I. I declare under penalty of perjury that the forgoing is true and correct, and that this declaration was executed 12/17/2023, at Ventura County, California. Tamineh Roshanian