Preview
CM-110
[ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY
Kevin Y. Jacobson, Esq. (SBN 320532)
QUILL & ARROW, LLP
ELECTRONICALLY
10900 Wilshire Boulevard, Suite 300
Los Angeles, CA 90024 FILED
Superior Court of California,
TELEPHONE
NO. (310) 933-4271 FAX NO. (Optionay: (310) 889-0645 County of San Francisco
E-MAIL ADDRESS: kjacobson@quillarrowlaw.com
06/06/2023
ATTORNEY FOR (Name): Plaintiff: KAITLIN KELLY DUNN Clerk of the Court
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO BY: VERA MU
STREET ADDRESS: 400 McAllister St. Deputy Clerk
MAILING ADDRESS: 400 McAllister St.
CITy AND ziP CODE: San Francisco, CA 94102-4515
BRANCH NAME: CIVIC CENTER COURTHOUSE
PLAINTIFF/PETITIONER: KAITLIN KELLY DUNN
DEFENDANT/RESPONDENT: GENERAL MOTORS LLC.
CASE MANAGEMENT STATEMENT ‘CASE NUMBER.
(Check one): [G<] UNLIMITED CASE [—] Limitep CASE CGC-23-604304
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: June 28, 2023 Time: 10:30 a.m. Dept. 610 Div. Room:
Address of court (if different from the address above).
[5c] Notice of Intent to Appear by Telephone, by (name): Kevin Y. Jacobson
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one).
a. [6<] This statement is submitted by party (name): Plaintiff. KAITLIN KELLY DUNN
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): January 27, 2023
b. [__] The cross-compiaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
a. [3c] 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 ofcase in [x] complaint [] cross-complaint (Describe, including causes of action):
See Attachment 4a
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. September1, 2021] wwe courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: KAITLIN KELLY DUNN CASE NUMBER.
DEFENDANT/RESPONDENT: GENERAL MOTORS LLC. CGC-23-604304
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
earings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
[5¢] (lf 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 [x_] a jury trial [) 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):
b. [5€] 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. [x] days (specify number): 5 -7
b. [_] hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial [5] by the attorney or party listed in the caption [_) by the following:
a Attorney:
b, Firm.
©. Address:
d, Telephone number: f. Fax number:
e, E-mail address: g. Party represented:
[J 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 [x] 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 [x] 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) [52] 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):
The amount in controversy exceeds $50,000.00 and involves multiple causes of actions pursuant to rule 3.811(b)(8).
(CM-110 [Rev. September1, 2024] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: KAITLIN KELLY DUNN CASE NUMBER.
DEFENDANT/RESPONDENT: GENERAL MOTORS LLC CGC-23-604304
10. ¢. 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).
[4<] Mediation session not yet scheduled
[J Mediation session scheduled for (date):
(1) Mediation Ba [_) 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).
[J 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 [J Judicial arbitration scheduled for (date):
arbitration [_) Agreed to complete judicial arbitration by (date).
[] Judicial arbitration completed on (date)
[_] Private arbitration not yet scheduled
(8) Binding private [_] Private arbitration scheduled for (date):
arbitration [_] Agreed to complete private arbitration by (date):
[_) Private arbitration completed on (date).
[1] ADR session not yet scheduled
[1] ADR session scheduled for (date).
(6) Other (specify):
[_] Agreed to complete ADR session by (date):
[_] ADR completed on (date):
(CM-110 [Rev. September1, 2024] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: KAITLIN KELLY DUNN CASE NUMBER.
DEFENDANT/RESPONDENT: GENERAL MOTORS LLC CGC-23-604304
11. Insurance
a. [__] Insurance carrier, if any, for party filing this statement (name).
b. Reservation of rights: [__] Yes [1] 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 [7] 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. [-] Amotion to [] 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):
16. Discovery
a. [__] The party or parties have completed all discovery.
b. [5] The following discovery will be completed by the date specified (describe all anticipated discovery).
Party Descriptior Date
Plaintiff Written Discovery December 2023
Plaintiff Depositions of Dealership Technicians and PMQ December 2023
Plaintiff Depositions of Defendant's PMK December 2023
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. September1, 2024] Page 4of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: KAITLIN KELLY DUNN CASE NUMBER.
DEFENDANT/RESPONDENT: GENERAL MOTORS LLC CGC-23-604304
17. Economic litigation
a. [__] This isa 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. [3] 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): 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: June 6, 2023
Kevin Y. Jacobson, Esq.
(TYPE OR PRINT NAME)
> Kura, ¥
narun fry omar cH
(TYPE OR PRINT NAME)
> (SIGNATURE OF PARTY OR ATTORNEY)
[) Additional signatures are attached.
(CM-110 [Rev. September1, 2021] Page 5 of §
CASE MANAGEMENT STATEMENT
MC-025
SHORT TITLE: ‘CASE NUMBER.
| Dunn, Kaitlin Kelly v. General Motors LLC CGC-23-604304
ATTACHMENT (Number): 4a
(This Attachment may be used with any Judicial Council form.)
The instant matter involves a 2020 Chevrolet Malibu manufactured by Defendant.
Plaintiff's causes of action are numbered as follows:
1. VIOLATION OF SONG-BEVERLY ACT - BREACH OF EXPRESS WARRANTY
2. VIOLATION OF SONG-BEVERLY ACT - BREACH OF IMPLIED WARRANTY
3. VIOLATION OF SONG-BEVERLY ACT - SECTION 1793.2
(If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 6 of 7
Attachment are made under penalty of perjury.)
(Add pages as required)
Form Approved for Optional Use ATTACHMENT wwnw.courtinfo.ca.gov
Judicial Counell of California
1C-025 (Rev. July 1, 2009] to Judicial Council Form
MC-025
SHORT TITLE: ‘CASE NUMBER.
| Dunn, Kaitlin Kelly v. General Motors LLC CGC-23-604304
ATTACHMENT (Number): 4b
(This Attachment may be used with any Judicial Council form.)
Plaintiff purchased a 2020 Chevrolet Malibu ("subject vehicle") from and manufactured by Defendant.
Defendant provided Plaintiff with express warranties accompanied the sale of the vehicle to Plaintiff by which
Defendants undertook to preserve or maintain the utility or performance of Plaintiff's vehicle or to provide
compensation if there was a failure in such utility or performance.
The vehicle was delivered to Plaintiff with serious defects and nonconformities to warranty and developed
other serious defects and nonconformities to warranty. Plaintiff delivered the vehicle to Defendants authorized
repair facilities multiple times. Defendant failed to repair the vehicle after a reasonable number of
opportunities.
Defendant violated the Song-Beverly Consumer Warranty Act by not replacing the vehicle or repurchasing the
vehicle after being given a reasonable number of opportunities to repair the vehicle.
Plaintiff seeks rescission of the purchase contract, restitution of all monies expended for the vehicle, incidental
and consequential damages, civil penalties in the amount of two times Plaintiff's actual damages, diminution in
value, prejudgment interest, reasonable attorneys' fees and costs of suit, general, special, and actual damages
according to proof at trial. Plaintiff's restitution damages are in excess of $50,000.00 and attorney's fees and
costs are currently in excess of $20,000.00.
Defendant has answered the Complaint and the matter is at issue. Plaintiff requests that the Court set trial.
(If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 7 of 7
Attachment are made under penalty of perjury.)
(Add pages as required)
Form Approved for Optional Use ATTACHMENT wwnw.courtinfo.ca.gov
Judicial Counell of California
1C-025 (Rev. July 1, 2009] to Judicial Council Form
PROOF OF SERVICE BY MAIL
I am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action. My business address is 10900 Wilshire Blvd., Suite 300, Los
Angeles, CA 90024.
On June 6, 2023, I served the following document(s) described as:
CASE MANANGEMENT STATEMENT
That document was served on parties herein in this proceeding by placing true copies of the original
in enclosed, sealed envelope(s) addressed as follows:
SEE ATTACHED SERVICE LIST
[](BY MAIL) I am “readily familiar” with the practices of QUILL & ARROW, LLP, in
10 collecting and processing correspondence and documents for mailing. Under that practice,
documents for mailing would be deposited with the US Postal Service on that same day this
ll affidavit is signed with postage fully prepaid at Los Angeles, California in the ordinary course of
business. I am aware that on motion of the party served, service is presumed invalid if the postal
12 cancellation date is more than 1-day after the day of deposit for mailing the affidavit. [CCP §
1013]
13
14 {] (BY OVERNIGHT MAIL) | am “readily familiar” with the practices of the QUILL &
ARROW, LLP, for collection and processing of documents for mailing via overnight delivery. I
15 caused such document(s) to be placed in a sealed envelope designated by the overnight service
carrier, addressed to the person(s) on whom it is to be served pursuant to the attached service list,
16 and deposited said envelope in a box or other facility regularly maintained by the overnight
service carrier with delivery fees paid or provided for. [CCP § 1013(c)]
17
[X] (BY ELECTRONIC MAIL) I caused the document(s) to be transmitted by electronic mail
18 to the e-mail addresses for each party indicated on the attached service list.
19 [] (BY PERSONAL DELIVERY) I caused to be delivered such envelope by hand to the
addressee at the address indicated on the attached service list.
20
21
I declare under penalty of perjury under the laws of the State of California that the foregoing is
22 true and correct.
23 Executed on June
June 6,
6, 2025,
2023.
/s/ Arianna eZ,
24 Arianna Y;
25
26
27
28
PROOF OF SERVICE
SERVICE LIST
Counsel for Defendants
Jonathan Shugart, Esq.
jshugart@erskinelaw.cor
Jesse Valencia, Esq.
ivalencia@erskinelaw.com
Mary Arens McBride, Esq.
marensmebride@erskinelaw.com
service-ca@erskinelaw.com
THE ERSKINE LAW GROUP, PC.
1592 N. Batavia Street., Ste.1A
Orange, CA 92867
10
Adam Reinke, Esq.
ll areinke@kslaw.com
Susan Clare, Esq.
12 clare@kslaw.com
13 Troy D. McMahan, Esq.
TMcMahan@kslaw.com
14 Geoffrey M. Drake, Esq.
gdrake@kslaw.com
15
gmquilleservice@kslaw.com
16 KING AND SPALDING LLP
50 California Street, Suite 3300
17 San Francisco, CA 94111
18
19
20
21
22
23
24
25
26
27
28
PROOF OF SERVICE
Preview
CM-110 [ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY Kevin Y. Jacobson, Esq. (SBN 320532) QUILL & ARROW, LLP ELECTRONICALLY 10900 Wilshire Boulevard, Suite 300 Los Angeles, CA 90024 FILED Superior Court of California, TELEPHONE NO. (310) 933-4271 FAX NO. (Optionay: (310) 889-0645 County of San Francisco E-MAIL ADDRESS: kjacobson@quillarrowlaw.com 06/06/2023 ATTORNEY FOR (Name): Plaintiff: KAITLIN KELLY DUNN Clerk of the Court SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO BY: VERA MU STREET ADDRESS: 400 McAllister St. Deputy Clerk MAILING ADDRESS: 400 McAllister St. CITy AND ziP CODE: San Francisco, CA 94102-4515 BRANCH NAME: CIVIC CENTER COURTHOUSE PLAINTIFF/PETITIONER: KAITLIN KELLY DUNN DEFENDANT/RESPONDENT: GENERAL MOTORS LLC. CASE MANAGEMENT STATEMENT ‘CASE NUMBER. (Check one): [G<] UNLIMITED CASE [—] Limitep CASE CGC-23-604304 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: June 28, 2023 Time: 10:30 a.m. Dept. 610 Div. Room: Address of court (if different from the address above). [5c] Notice of Intent to Appear by Telephone, by (name): Kevin Y. Jacobson INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one). a. [6<] This statement is submitted by party (name): Plaintiff. KAITLIN KELLY DUNN 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): January 27, 2023 b. [__] The cross-compiaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) a. [3c] 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 ofcase in [x] complaint [] cross-complaint (Describe, including causes of action): See Attachment 4a 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. September1, 2021] wwe courts.ca.gov CM-110 PLAINTIFF/PETITIONER: KAITLIN KELLY DUNN CASE NUMBER. DEFENDANT/RESPONDENT: GENERAL MOTORS LLC. CGC-23-604304 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 earings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) [5¢] (lf 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 [x_] a jury trial [) 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): b. [5€] 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. [x] days (specify number): 5 -7 b. [_] hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial [5] by the attorney or party listed in the caption [_) by the following: a Attorney: b, Firm. ©. Address: d, Telephone number: f. Fax number: e, E-mail address: g. Party represented: [J 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 [x] 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 [x] 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) [52] 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): The amount in controversy exceeds $50,000.00 and involves multiple causes of actions pursuant to rule 3.811(b)(8). (CM-110 [Rev. September1, 2024] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: KAITLIN KELLY DUNN CASE NUMBER. DEFENDANT/RESPONDENT: GENERAL MOTORS LLC CGC-23-604304 10. ¢. 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). [4<] Mediation session not yet scheduled [J Mediation session scheduled for (date): (1) Mediation Ba [_) 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). [J 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 [J Judicial arbitration scheduled for (date): arbitration [_) Agreed to complete judicial arbitration by (date). [] Judicial arbitration completed on (date) [_] Private arbitration not yet scheduled (8) Binding private [_] Private arbitration scheduled for (date): arbitration [_] Agreed to complete private arbitration by (date): [_) Private arbitration completed on (date). [1] ADR session not yet scheduled [1] ADR session scheduled for (date). (6) Other (specify): [_] Agreed to complete ADR session by (date): [_] ADR completed on (date): (CM-110 [Rev. September1, 2024] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: KAITLIN KELLY DUNN CASE NUMBER. DEFENDANT/RESPONDENT: GENERAL MOTORS LLC CGC-23-604304 11. Insurance a. [__] Insurance carrier, if any, for party filing this statement (name). b. Reservation of rights: [__] Yes [1] 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 [7] 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. [-] Amotion to [] 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): 16. Discovery a. [__] The party or parties have completed all discovery. b. [5] The following discovery will be completed by the date specified (describe all anticipated discovery). Party Descriptior Date Plaintiff Written Discovery December 2023 Plaintiff Depositions of Dealership Technicians and PMQ December 2023 Plaintiff Depositions of Defendant's PMK December 2023 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. September1, 2024] Page 4of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: KAITLIN KELLY DUNN CASE NUMBER. DEFENDANT/RESPONDENT: GENERAL MOTORS LLC CGC-23-604304 17. Economic litigation a. [__] This isa 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. [3] 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): 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: June 6, 2023 Kevin Y. Jacobson, Esq. (TYPE OR PRINT NAME) > Kura, ¥ narun fry omar cH (TYPE OR PRINT NAME) > (SIGNATURE OF PARTY OR ATTORNEY) [) Additional signatures are attached. (CM-110 [Rev. September1, 2021] Page 5 of § CASE MANAGEMENT STATEMENT MC-025 SHORT TITLE: ‘CASE NUMBER. | Dunn, Kaitlin Kelly v. General Motors LLC CGC-23-604304 ATTACHMENT (Number): 4a (This Attachment may be used with any Judicial Council form.) The instant matter involves a 2020 Chevrolet Malibu manufactured by Defendant. Plaintiff's causes of action are numbered as follows: 1. VIOLATION OF SONG-BEVERLY ACT - BREACH OF EXPRESS WARRANTY 2. VIOLATION OF SONG-BEVERLY ACT - BREACH OF IMPLIED WARRANTY 3. VIOLATION OF SONG-BEVERLY ACT - SECTION 1793.2 (If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 6 of 7 Attachment are made under penalty of perjury.) (Add pages as required) Form Approved for Optional Use ATTACHMENT wwnw.courtinfo.ca.gov Judicial Counell of California 1C-025 (Rev. July 1, 2009] to Judicial Council Form MC-025 SHORT TITLE: ‘CASE NUMBER. | Dunn, Kaitlin Kelly v. General Motors LLC CGC-23-604304 ATTACHMENT (Number): 4b (This Attachment may be used with any Judicial Council form.) Plaintiff purchased a 2020 Chevrolet Malibu ("subject vehicle") from and manufactured by Defendant. Defendant provided Plaintiff with express warranties accompanied the sale of the vehicle to Plaintiff by which Defendants undertook to preserve or maintain the utility or performance of Plaintiff's vehicle or to provide compensation if there was a failure in such utility or performance. The vehicle was delivered to Plaintiff with serious defects and nonconformities to warranty and developed other serious defects and nonconformities to warranty. Plaintiff delivered the vehicle to Defendants authorized repair facilities multiple times. Defendant failed to repair the vehicle after a reasonable number of opportunities. Defendant violated the Song-Beverly Consumer Warranty Act by not replacing the vehicle or repurchasing the vehicle after being given a reasonable number of opportunities to repair the vehicle. Plaintiff seeks rescission of the purchase contract, restitution of all monies expended for the vehicle, incidental and consequential damages, civil penalties in the amount of two times Plaintiff's actual damages, diminution in value, prejudgment interest, reasonable attorneys' fees and costs of suit, general, special, and actual damages according to proof at trial. Plaintiff's restitution damages are in excess of $50,000.00 and attorney's fees and costs are currently in excess of $20,000.00. Defendant has answered the Complaint and the matter is at issue. Plaintiff requests that the Court set trial. (If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 7 of 7 Attachment are made under penalty of perjury.) (Add pages as required) Form Approved for Optional Use ATTACHMENT wwnw.courtinfo.ca.gov Judicial Counell of California 1C-025 (Rev. July 1, 2009] to Judicial Council Form PROOF OF SERVICE BY MAIL I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action. My business address is 10900 Wilshire Blvd., Suite 300, Los Angeles, CA 90024. On June 6, 2023, I served the following document(s) described as: CASE MANANGEMENT STATEMENT That document was served on parties herein in this proceeding by placing true copies of the original in enclosed, sealed envelope(s) addressed as follows: SEE ATTACHED SERVICE LIST [](BY MAIL) I am “readily familiar” with the practices of QUILL & ARROW, LLP, in 10 collecting and processing correspondence and documents for mailing. Under that practice, documents for mailing would be deposited with the US Postal Service on that same day this ll affidavit is signed with postage fully prepaid at Los Angeles, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if the postal 12 cancellation date is more than 1-day after the day of deposit for mailing the affidavit. [CCP § 1013] 13 14 {] (BY OVERNIGHT MAIL) | am “readily familiar” with the practices of the QUILL & ARROW, LLP, for collection and processing of documents for mailing via overnight delivery. I 15 caused such document(s) to be placed in a sealed envelope designated by the overnight service carrier, addressed to the person(s) on whom it is to be served pursuant to the attached service list, 16 and deposited said envelope in a box or other facility regularly maintained by the overnight service carrier with delivery fees paid or provided for. [CCP § 1013(c)] 17 [X] (BY ELECTRONIC MAIL) I caused the document(s) to be transmitted by electronic mail 18 to the e-mail addresses for each party indicated on the attached service list. 19 [] (BY PERSONAL DELIVERY) I caused to be delivered such envelope by hand to the addressee at the address indicated on the attached service list. 20 21 I declare under penalty of perjury under the laws of the State of California that the foregoing is 22 true and correct. 23 Executed on June June 6, 6, 2025, 2023. /s/ Arianna eZ, 24 Arianna Y; 25 26 27 28 PROOF OF SERVICE SERVICE LIST Counsel for Defendants Jonathan Shugart, Esq. jshugart@erskinelaw.cor Jesse Valencia, Esq. ivalencia@erskinelaw.com Mary Arens McBride, Esq. marensmebride@erskinelaw.com service-ca@erskinelaw.com THE ERSKINE LAW GROUP, PC. 1592 N. Batavia Street., Ste.1A Orange, CA 92867 10 Adam Reinke, Esq. ll areinke@kslaw.com Susan Clare, Esq. 12 clare@kslaw.com 13 Troy D. McMahan, Esq. TMcMahan@kslaw.com 14 Geoffrey M. Drake, Esq. gdrake@kslaw.com 15 gmquilleservice@kslaw.com 16 KING AND SPALDING LLP 50 California Street, Suite 3300 17 San Francisco, CA 94111 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE