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Electronically Filed Superior Court of CA County of Contra Costa 6/16/2023 11:33 AM By: B. Stubbs, Deputy
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
DANIEL J. RAFII (SBN 244174)
RAFII & ASSOCIATES, P.C.
9100 Wilshire Blvd., Suite 465E, Beverly Hills, CA 90212
(310) 777-7877
TELEPHONE NO. FAX NO (Optional) (310) 777-7855
litigation@rafiilaw.com
E-MAIL ADDRESS (Optional):
ATTORNEY FOR (Name) Plaintiff, IAN PRADO RODRIGUEZ, ET AL.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF CONTRA COSTA
sTREETADDREss 725 Court Street
MAILING ADDREss: 725 Court Street
c1TY AND z1P coDE: Martinez, CA 94553
BRANCH NAME: Martinez-Wakefield Taylor Courthouse
PLAINTIFF/PETITIONER: IAN PRADO RODRIGUEZ, ET AL.
DEFENDANT/RESPONDENT: CITY OF RICHMOND, ET AL.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): W UNLIMITED CASE CJ LIMITED CASE C23-00350
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 6/30/2023 Time: 8:30 AM Dept.: 21 Div.: Civil Room: 320
Address of court (if different from the address above):
Same
[ZJ Notice of Intent to Appear by Telephone, by (name): Daniel J. Rafii, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. [Z] This statement is submitted by party (name): Plaintiffs, IAN PRADO RODRIGUEZ, et al.
b. D 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): 2/15/2023
b. D The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. D All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. W The following parties named in the complaint or cross-complaint
(1) W have not been served (specify names and explain why not):
Plaintiffs is actively seeking early and pre-service resolution of this matter.
(2) D have been served but have not appeared and have not been dismissed (specify names):
(3) D have had a default entered against them (specify names):
c. D 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 [2J complaint D cross-complaint (Describe, including causes of action):
Auto Accident - Negligence.
Page 1 of 5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California rules 3.720-3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: IAN PRADO RODRIGUEZ, ET AL.
C23-00350
DEFENDANT/RESPONDENT: CITY OF RICHMOND, ET AL.
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)
On or about 4/2/2022, Defendants' vehicle collided with Plaintiff's vehicle. Plaintiffs suffered substantial injuries as
a result of the collision. Medical past medical expenses are approx. $9,228,00. Plaintiffs will continue to incur
medical, general, and related damages according to proof.
D (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 W a jury trial D a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. D The trial has been set for (date):
b. W 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):
June 2-22, 2023; July 7-20, 2023; September 21-October 6, 2023; October 3-17, 2023; Plaintiff's counsel has
trials set for other matters on these dates.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [ZJ days (specify number): 5-7
b. D hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial D
by the attorney or party listed in the caption [ZJ by the following:
a. Attorney: TBD
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
D Additional representation is described in Attachment 8.
9. Preference
D 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 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel W
has D 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 D has D has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
( 1) D 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) D 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) D 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. July 1, 2011) Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: IAN PRADO RODRIGUEZ, ET AL.
C23-00350
DEFENDANT/RESPONDENT: CITY OF RICHMOND, 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):
m Mediation session not yet scheduled
m D Mediation session scheduled for (date):
(1) Mediation
D Agreed to complete mediation by (date):
D Mediation completed on (date):
[Z] Settlement conference not yet scheduled
(2) Settlement [Z] D Settlement conference scheduled for (date):
conference
D Agreed to complete settlement conference by (date):
D Settlement conference completed on (date):
D Neutral evaluation not yet scheduled
D D Neutral evaluation scheduled for (date):
(3) Neutral evaluation
D Agreed to complete neutral evaluation by (date):
D Neutral evaluation completed on (date):
D Judicial arbitration not yet scheduled
(4) Nonbinding judicial D D Judicial arbitration scheduled for (date):
arbitration
D Agreed to complete judicial arbitration by (date):
D Judicial arbitration completed on (date):
D Private arbitration not yet scheduled
(5) Binding private D D Private arbitration scheduled for (date):
arbitration
D Agreed to complete private arbitration by (date):
D Private arbitration completed on (date):
D ADR session not yet scheduled
D D ADR session scheduled for (date):
(6) Other (specify):
D Agreed to complete ADR session by (date):
D ADR completed on (date):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STA TEMENT
CASE NUMBER:
PLAINTIFF/PETITIONER: IAN PRADO RODRIGUEZ, ET AL.
C23-00350
DEFENDANT/RESPONDENT: CITY OF RICHMOND, ET AL.
11. Insurance
a. D
Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: D Yes D No
c. D 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.
D Bankruptcy D Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. D
There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
D Additional cases are described in Attachment 13a.
b. D A motion to D consolidate D coordinate will be filed by (name party):
14. Bifurcation
D 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
[ZJ The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motions to compel discovery, as necessary
16. Discovery
a. D The party or parties have completed all discovery.
b. W The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiffs Written Discovery Per code
Plaintiffs Depositions of Defendants Per code
Plaintiffs Expert Discovery according to Trial Schedule Per code
Plaintiffs Expert Deposition(s) Per code
c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011] Page 4 of 5
CASE MANAGEMENT STA TEMENT
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: IAN PRADO RODRIGUEZ, ET AL.
C23-00350
DEFENDANT/RESPONDENT: CITY OF RICHMOND, ET AL.
17. Economic litigation
a. D
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. D 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
D 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. D 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): 0
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: June 15, 2023
Daniel J. Rafii, Esq.
(TYPE OR PRINT NAME) â–º --
(SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) â–º (SIGNATURE OF PARTY OR ATTORNEY)
D Additional signatures are attached .
CM-110 [Rev. July 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
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Electronically Filed Superior Court of CA County of Contra Costa 6/16/2023 11:33 AM By: B. Stubbs, Deputy CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY DANIEL J. RAFII (SBN 244174) RAFII & ASSOCIATES, P.C. 9100 Wilshire Blvd., Suite 465E, Beverly Hills, CA 90212 (310) 777-7877 TELEPHONE NO. FAX NO (Optional) (310) 777-7855 litigation@rafiilaw.com E-MAIL ADDRESS (Optional): ATTORNEY FOR (Name) Plaintiff, IAN PRADO RODRIGUEZ, ET AL. SUPERIOR COURT OF CALIFORNIA, COUNTY OF CONTRA COSTA sTREETADDREss 725 Court Street MAILING ADDREss: 725 Court Street c1TY AND z1P coDE: Martinez, CA 94553 BRANCH NAME: Martinez-Wakefield Taylor Courthouse PLAINTIFF/PETITIONER: IAN PRADO RODRIGUEZ, ET AL. DEFENDANT/RESPONDENT: CITY OF RICHMOND, ET AL. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): W UNLIMITED CASE CJ LIMITED CASE C23-00350 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 6/30/2023 Time: 8:30 AM Dept.: 21 Div.: Civil Room: 320 Address of court (if different from the address above): Same [ZJ Notice of Intent to Appear by Telephone, by (name): Daniel J. Rafii, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. [Z] This statement is submitted by party (name): Plaintiffs, IAN PRADO RODRIGUEZ, et al. b. D 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): 2/15/2023 b. D The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. D All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. W The following parties named in the complaint or cross-complaint (1) W have not been served (specify names and explain why not): Plaintiffs is actively seeking early and pre-service resolution of this matter. (2) D have been served but have not appeared and have not been dismissed (specify names): (3) D have had a default entered against them (specify names): c. D 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 [2J complaint D cross-complaint (Describe, including causes of action): Auto Accident - Negligence. Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California rules 3.720-3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: IAN PRADO RODRIGUEZ, ET AL. C23-00350 DEFENDANT/RESPONDENT: CITY OF RICHMOND, ET AL. 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) On or about 4/2/2022, Defendants' vehicle collided with Plaintiff's vehicle. Plaintiffs suffered substantial injuries as a result of the collision. Medical past medical expenses are approx. $9,228,00. Plaintiffs will continue to incur medical, general, and related damages according to proof. D (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 W a jury trial D a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. D The trial has been set for (date): b. W 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): June 2-22, 2023; July 7-20, 2023; September 21-October 6, 2023; October 3-17, 2023; Plaintiff's counsel has trials set for other matters on these dates. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [ZJ days (specify number): 5-7 b. D hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial D by the attorney or party listed in the caption [ZJ by the following: a. Attorney: TBD b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: D Additional representation is described in Attachment 8. 9. Preference D 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 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel W has D 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 D has D has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). ( 1) D 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) D 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) D 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. July 1, 2011) Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: IAN PRADO RODRIGUEZ, ET AL. C23-00350 DEFENDANT/RESPONDENT: CITY OF RICHMOND, 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): m Mediation session not yet scheduled m D Mediation session scheduled for (date): (1) Mediation D Agreed to complete mediation by (date): D Mediation completed on (date): [Z] Settlement conference not yet scheduled (2) Settlement [Z] D Settlement conference scheduled for (date): conference D Agreed to complete settlement conference by (date): D Settlement conference completed on (date): D Neutral evaluation not yet scheduled D D Neutral evaluation scheduled for (date): (3) Neutral evaluation D Agreed to complete neutral evaluation by (date): D Neutral evaluation completed on (date): D Judicial arbitration not yet scheduled (4) Nonbinding judicial D D Judicial arbitration scheduled for (date): arbitration D Agreed to complete judicial arbitration by (date): D Judicial arbitration completed on (date): D Private arbitration not yet scheduled (5) Binding private D D Private arbitration scheduled for (date): arbitration D Agreed to complete private arbitration by (date): D Private arbitration completed on (date): D ADR session not yet scheduled D D ADR session scheduled for (date): (6) Other (specify): D Agreed to complete ADR session by (date): D ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STA TEMENT CASE NUMBER: PLAINTIFF/PETITIONER: IAN PRADO RODRIGUEZ, ET AL. C23-00350 DEFENDANT/RESPONDENT: CITY OF RICHMOND, ET AL. 11. Insurance a. D Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: D Yes D No c. D 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. D Bankruptcy D Other (specify): Status: 13. Related cases, consolidation, and coordination a. D There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: D Additional cases are described in Attachment 13a. b. D A motion to D consolidate D coordinate will be filed by (name party): 14. Bifurcation D 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 [ZJ The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Motions to compel discovery, as necessary 16. Discovery a. D The party or parties have completed all discovery. b. W The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Plaintiffs Written Discovery Per code Plaintiffs Depositions of Defendants Per code Plaintiffs Expert Discovery according to Trial Schedule Per code Plaintiffs Expert Deposition(s) Per code c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STA TEMENT CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: IAN PRADO RODRIGUEZ, ET AL. C23-00350 DEFENDANT/RESPONDENT: CITY OF RICHMOND, ET AL. 17. Economic litigation a. D 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. D 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 D 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. D 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): 0 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: June 15, 2023 Daniel J. Rafii, Esq. (TYPE OR PRINT NAME) â–º -- (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) â–º (SIGNATURE OF PARTY OR ATTORNEY) D Additional signatures are attached . CM-110 [Rev. July 1, 2011] Page 5 of 5 CASE MANAGEMENT STATEMENT