On June 23, 2022 a
Initial Trial Setting Conf Statement Electronically Filed - Initial Trial Setting Conference Statement Electronically filed (Statements)
was filed
involving a dispute between
Curtis, Mary Ruth,
Estate Of Mary Ruth Curtis,
Heine, Nancy,
Hudson, Carol,
Kibler, Colleen,
O'Shaughnessy, Sharon,
and
Atria Senior Living, Inc,
Brown, Jeff,
Does 1 To 50,
Holiday Al General Partner Ii Llc,
Holiday Al Management Sub Llc,
Mission Commons Retirement Residence Limited Partnership,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
NAME AND ADDRESS OF ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NUMBER Reserved for Clerk’s File Stamp
wggfgflfisfi 113%.
/ Devon B. Moore, Esq. Michael P. West SBN: 172478 ELECTRON ICALLY Fl LED (Auto)
’ ' '
D evon B. M oore SBN: 308838 SUPERIOR COURT OF CALI FORN IA
402 w Broadway, Suite 400, San Diego, CA 92101
TELEPHONE
Mg; 6194383240 TRIAL SETTINGCONFERENCE DATE: February 13, 2024 COUNTY OF SAN BERNARDINO
E-MAIL ADDRE m_west moorean dl ee.com
2/2/2024 4'08 PM
-
UNL'M'TED CASE X
:
_
ATTORNEY FOR (Name): Defendants S30
FAX NO (Optional): LIMITED CASE: DEPT:
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
COURTHOUSE ADDRESS: 247 W. 3rd St., San Bernardino, CA 92415
PLAINTIFF:
Mary Ruth Curtis
DEFENDANT: Mission Commons, et a1.
CASE NUMBER:
INITIAL TRIAL SETTING CONFERENCE STATEMENT c1V332213163
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
“This
MISSIONCOMMONS RETIREMENT RESIDENCE LIMITED PARTNERSHIP; HOLIDAY AL GENERAL
a. statement is submitted by party (name).
PARTNER II LLC; HOLIDAY AL MANAGEMENT SUB LLC; and ATRIA SENIOR LIVING, INC.
b. DThis statement'Is submitted jointly by panies (names).
2. Service of Complaint on all parties D has been completed.
D has not been completed.
3. Service of Cross-Complaint on all parties D has been completed.
D has not been completed.
4. Description of case in Complaint: personal Injury; wrongful Death
5. Description of case in Cross-Complaint:
6. Has all discovery been completed: Yes D No Date discovery anticipated to be completed: OCtOber 2024
7. Do you agree to mediation? Yes No D Please check type agreed to: Private: X Court-sponsored:
8. 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:
b. DA motion to D consolidate D coordinate wi|| be filed by (name ofparty):
9. Trial dates requested: Yes No D Available dates: MarCh 2025 Time estimate: Z—lfl days JTD COURTD
10. Other issues:
D The following additional matters are requested to be considered by the Court:
11. Meet and Confer:
The parties represent that they have met and conferred on all subjects required by California Rules of Court, Rule 3.724.
D The
—
parties have entered into the following stipulation(s):
A
12. Total number of pages attached (if any):
| am completely familiar with this case and wi|| be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by
this statement, and
ofthe party where required.
Date; 2/2/24
Michael
wi||
P.
possess the authority
West, Esq.
to enter into stipulations on these issues at the time of the Initial
7’
Trial Setting Conference, including the written authority
(TYPE OR PRINT NAME) S(IGNATURE OF PARTY OR ATTORNEY
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY
Form # 13-09001-360
Rev. 11-2021 Mandatory
INITIAL TRIAL SETTINGCONFERENCE STATEMENT
PROOF OF SERVICE
V Mission Commons, et a1.
Curtis
San Bernardino Superior Court Case N0. CIVSB2213 163
I am employed in the county of San Diego, state 0f California. I am over the age of 18 and not
a party t0 this action. My business address is 402 West Broadway, Suite 400, San Diego, California
92101.
On February 2, 2024, I caused t0 be served the foregoing document(s) described as:
DEFENDANTS’ INITIAL TRIAL SETTING CONFERENCE STATEMENT
0n the interested parties in this action as follows:
KOOOQQ Cory R. Weck (SBN 183805) Attorneysfor Plaintiffs
Brynna O. Popka (SBN 310801) bdp(a)mccunewright.com
McCUNE WRIGHT AREVALO, LLP crw@mccunewright,com
3281 East Guasti Road, Suite 100
Ontario, CA 91761
10
909-557-1250 909-557-1275 Fax
|
11
D (BY U.S. MAIL) I am personally and readily familiar With the business practice 0f
12
Moore and Lee, P.C. for collection and processing of correspondence for mailing with the
United States Parcel Service, and I caused such envelope(s) With postage thereon fully
prepaid t0 be placed in the United States Postal Service.
13
14 D (BY MESSENGER SERVICE) by consigning the document(s) to an authorized courier
and/or process server for hand delivery 0n this date.
15
D (BY FACSIMILE) I am personally and readily familiar With the business practice of
16
Moore and Lee, P.C. for collection and processing 0f document(s) t0 be transmitted by
facsimile and I caused such document(s) on this date t0 be transmitted by facsimile to the
offices 0f addressee(s) at the numbers listed below.
17
18 D (BY OVERNIGHT MAIL) I am personally and readily familiar with the business
practice 0f Moore and Lee, P.C. for collection and processing of correspondence for
overnight delivery, and I caused such document(s) described herein t0 be deposited for
19
delivery to a facility regularly maintained by Federal Express for overnight delivery.
20
E BY ELECTRONIC SERVICE: By electronically mailing a true and correct copy through
21
Moore and Lee, P.C.’s electronic mail system from i.chavez@mooreandlee.com t0 the
email addresses set forth above.
22
D (BY PERSONAL DELIVERY) I caused such envelope to be delivered by hand to the
offices 0f each addressee below.
23
I declare under penalty of perjury under the laws 0f the State of California, that the above is true and
24
correct. Executed on February 2, 2024, at San Diego, California.
25
26 m/w w?O
Ian Chavez
27
28
1
DEFENDANTS’ INITIAL TRIAL SETTING CONFERENCE STATEMENT
Document Filed Date
February 02, 2024
Case Filing Date
June 23, 2022
Category
Other PI/PD/WD Unlimited
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Preview
NAME AND ADDRESS OF ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NUMBER Reserved for Clerk’s File Stamp wggfgflfisfi 113%. / Devon B. Moore, Esq. Michael P. West SBN: 172478 ELECTRON ICALLY Fl LED (Auto) ’ ' ' D evon B. M oore SBN: 308838 SUPERIOR COURT OF CALI FORN IA 402 w Broadway, Suite 400, San Diego, CA 92101 TELEPHONE Mg; 6194383240 TRIAL SETTINGCONFERENCE DATE: February 13, 2024 COUNTY OF SAN BERNARDINO E-MAIL ADDRE m_west moorean dl ee.com 2/2/2024 4'08 PM - UNL'M'TED CASE X : _ ATTORNEY FOR (Name): Defendants S30 FAX NO (Optional): LIMITED CASE: DEPT: SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO COURTHOUSE ADDRESS: 247 W. 3rd St., San Bernardino, CA 92415 PLAINTIFF: Mary Ruth Curtis DEFENDANT: Mission Commons, et a1. CASE NUMBER: INITIAL TRIAL SETTING CONFERENCE STATEMENT c1V332213163 INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): “This MISSIONCOMMONS RETIREMENT RESIDENCE LIMITED PARTNERSHIP; HOLIDAY AL GENERAL a. statement is submitted by party (name). PARTNER II LLC; HOLIDAY AL MANAGEMENT SUB LLC; and ATRIA SENIOR LIVING, INC. b. DThis statement'Is submitted jointly by panies (names). 2. Service of Complaint on all parties D has been completed. D has not been completed. 3. Service of Cross-Complaint on all parties D has been completed. D has not been completed. 4. Description of case in Complaint: personal Injury; wrongful Death 5. Description of case in Cross-Complaint: 6. Has all discovery been completed: Yes D No Date discovery anticipated to be completed: OCtOber 2024 7. Do you agree to mediation? Yes No D Please check type agreed to: Private: X Court-sponsored: 8. 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: b. DA motion to D consolidate D coordinate wi|| be filed by (name ofparty): 9. Trial dates requested: Yes No D Available dates: MarCh 2025 Time estimate: Z—lfl days JTD COURTD 10. Other issues: D The following additional matters are requested to be considered by the Court: 11. Meet and Confer: The parties represent that they have met and conferred on all subjects required by California Rules of Court, Rule 3.724. D The — parties have entered into the following stipulation(s): A 12. Total number of pages attached (if any): | am completely familiar with this case and wi|| be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and ofthe party where required. Date; 2/2/24 Michael wi|| P. possess the authority West, Esq. to enter into stipulations on these issues at the time of the Initial 7’ Trial Setting Conference, including the written authority (TYPE OR PRINT NAME) S(IGNATURE OF PARTY OR ATTORNEY (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY Form # 13-09001-360 Rev. 11-2021 Mandatory INITIAL TRIAL SETTINGCONFERENCE STATEMENT PROOF OF SERVICE V Mission Commons, et a1. Curtis San Bernardino Superior Court Case N0. CIVSB2213 163 I am employed in the county of San Diego, state 0f California. I am over the age of 18 and not a party t0 this action. My business address is 402 West Broadway, Suite 400, San Diego, California 92101. On February 2, 2024, I caused t0 be served the foregoing document(s) described as: DEFENDANTS’ INITIAL TRIAL SETTING CONFERENCE STATEMENT 0n the interested parties in this action as follows: KOOOQQ Cory R. Weck (SBN 183805) Attorneysfor Plaintiffs Brynna O. Popka (SBN 310801) bdp(a)mccunewright.com McCUNE WRIGHT AREVALO, LLP crw@mccunewright,com 3281 East Guasti Road, Suite 100 Ontario, CA 91761 10 909-557-1250 909-557-1275 Fax | 11 D (BY U.S. MAIL) I am personally and readily familiar With the business practice 0f 12 Moore and Lee, P.C. for collection and processing of correspondence for mailing with the United States Parcel Service, and I caused such envelope(s) With postage thereon fully prepaid t0 be placed in the United States Postal Service. 13 14 D (BY MESSENGER SERVICE) by consigning the document(s) to an authorized courier and/or process server for hand delivery 0n this date. 15 D (BY FACSIMILE) I am personally and readily familiar With the business practice of 16 Moore and Lee, P.C. for collection and processing 0f document(s) t0 be transmitted by facsimile and I caused such document(s) on this date t0 be transmitted by facsimile to the offices 0f addressee(s) at the numbers listed below. 17 18 D (BY OVERNIGHT MAIL) I am personally and readily familiar with the business practice 0f Moore and Lee, P.C. for collection and processing of correspondence for overnight delivery, and I caused such document(s) described herein t0 be deposited for 19 delivery to a facility regularly maintained by Federal Express for overnight delivery. 20 E BY ELECTRONIC SERVICE: By electronically mailing a true and correct copy through 21 Moore and Lee, P.C.’s electronic mail system from i.chavez@mooreandlee.com t0 the email addresses set forth above. 22 D (BY PERSONAL DELIVERY) I caused such envelope to be delivered by hand to the offices 0f each addressee below. 23 I declare under penalty of perjury under the laws 0f the State of California, that the above is true and 24 correct. Executed on February 2, 2024, at San Diego, California. 25 26 m/w w?O Ian Chavez 27 28 1 DEFENDANTS’ INITIAL TRIAL SETTING CONFERENCE STATEMENT