On June 11, 2020 a
Conference
was filed
involving a dispute between
Duke Realty Limited Partnership,
Insurance Company Of The West,
Madrigal, Adriana Quintero,
Marquez, Rafael Carvajal,
and
Does 2-100,
Duke Realty Corporation,
Duke Realty Limited Partnership,
Genie Industries, Inc.,
Gregg Electric, Inc.,
I.E. General Engineering Inc.,
King Equipment, Llc,
Terex Corporation,
General Engineering, Inc,
Gregg Electric, Inc., I.E.,
King Equipment, Inc.,
Roes 2 To 100,
for Personal Injury Non-Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
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Law Offices °f A’aSh Khmsandi §§W325263 v
E;”"°“‘E‘°’*é“‘f3“
2960 WllShil’e Boulevard, LA. CA 90010 “UPERIOR
D COURT 0F CALIFORNIA
TELEPHONE N0; 31 0-277—7529 COUNTY OF SAN BERNARDINO
E-MAIL ADDRESS: david SAN BERNARWWD DISTRICT
.arashlaw.comRIAL SEWING CONFERENCE DATE: 12/ 1 1/2020
ATTORNEV FOR (Name): P ihtlfis UNLMTED CASE: X
FAX NO. (Optional): _~.
LIMITED CASE: N D V 2 4 2020
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO 6...“!
COURTHOUSE Ress: es I ee . an mar mo, _
f».w.-_.-
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PLAINTIFF: Rafael Carvajal Marquez, et al.
SAMANTHA NEUBAUER. DEPUTY
DEFENDANT: GWWEE; mt: efal.
INITIAL TRIAL SETTING CONFERENCE STATEMENT CéfiVWEBHoam
INSTRUCTIONS: All applicable boxes must be checked, and tho specified information mun be provided. This document must be filed 5nd
.
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1. Party or parties (answer one):
a. This statement is submitted by party (name): Rafael Carvajal Marquez, at al.
b. This statement is submitted jointly by parties (names):
2. Service of Complaint on all parties has a has not D been completed.
3. Service of Crou-Complaint on all parties has E has not D been completed.
4. Dascrlptlon of case in Complaint On July 17, 2018. Plaintiff was inside a Genie Lifi while Mfforming drywall \NOfk. As a_ result of
the lack of safety measures, Plaintiff lost. hls_balance a_nd fen many feet. Plaintiff sustained
wtastrophic injuries, inciuding fractures In hrs skull, Injuries to bram, neck and back.
5. Description of case in Cross—Complaint
6. Has all discovery been completed: Yes D No E Date discovery anticipated to bu completed:
Per COde
a D x
7.
B.
Do you agreeto mediation? Yes No
Related cases, consolidation, and coordination: Please attach a Notice of Related Case.
P&ease checktype agreed to: Private: Coun—sponsored:
X
D A motion to D consoiidate D Trial dates requested: YesD No D Available dates:
a 'l
Time
estimate: >m
m1
Other issues:
9.
D The following additional matters are requested to be considered by the Court:
m
u]
10. Meet and Confer:
=1!
m The parties represent that they have met and conferred on all subjects required byCallfornia Rules of Court, Rule 3.724. u“
D The parties have entered into the following stipulation(s):
11. Total number of pages attached (ifany):
I am completely familiar with this case and will be fully prepared to discuss the status ofdbcovery and alternative dispute resolution, as well as
other issues raised by this statement, and will possess the authority to enter into-stipum on these issues at the time of the Initial Trial Setting
Conference, including the written authority of the party where required.
Date: November 24 2020
David J. Ebenhack "
(TYPE 0R PRINT NAME) (SIGNATURE 0F PARTY 0R ATrORNEY
(TYPE 0R PRINT NAME) (SIGNATWOF PARTY 0R ATTORNEY
Form fl 13-09001 —360
Rwazozn Mandalay INITIAL TRIAL SETTINGCONFERENCE STATEMENT » m
f Amrrimu up . m.
PROOF 0F SERVICE
y.“
m—A
I declar‘e that I am over the age of eighteen
(1 8) and not a party to this action. My
business address is 2960 Wilshire Blvd., Third Floor, Los Angeles, California 90010.
On November 24, 2020, I caused to be saved the following document(s):
INITIAL TRIAL SETTING CONFERENCE STATEMENT
on the interested party(ies) in this action by placing a true and correct
copy of document(s) in a
EOOOQOSMAWN
sealed envelope addressed as follows:
SEE ATTACHED SERVICE LIST
(X) [U.S. MAIL] I am readily familiar with the business practice for collection and
processing of correspondence for mailing with the United States Postal Service.
I know
that the correspondence is deposited with the United States Postal
Service on the same
day this declaration was executed in the ordin course of business. I know that the
—~
G envelope was sealed and, with postage thereon 1y prepaid, placed for collection and
.
mailing on this date, following ordinary business practices in the United States
p-s-n mailed at
Los Angeles, California.
N?“
u—n‘
() [OVERNIGHT DELIVERY] Via Federal Express or similar overnight courier service,
by depositing in a box or other maintained by such overnight delivery
facility regularly
LO
service, or delivering such envelope to a courier or driver authorized
by said overnight
delivery service to receive documents, in an envelope designated
by said overnight
delivery service with delivery fees paid or provided for, addressed to the address last
shown by that person on any documents filed in this action.
[FACSIMILE] Via facsimile machine, I caused the above-referenced document(s) to be
transmitted to the person(s) listed above.
(X) [ELECTRONIC MAIL] Via electronic mail, Icaused the above—referenced document(s)
to be transmitted to the address listed above.
(X) (STATE) I declare under penalty of perjury under the laws of the State of California that
the above is true and correct.
Executed on November 24, 2020, at Los Aug
PROOF OF SERVICE
Document Filed Date
November 24, 2020
Case Filing Date
June 11, 2020
Category
Personal Injury Non-Motor Vehicle Unlimited
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l’L/H $23 \v ..._-~‘....._,.. \r 0R3 A w NAL I ‘ thwu... ...-.‘............‘.... «i "mm”??? $TT§EN§EW5WB£WJTT€§§Ehack Law Offices °f A’aSh Khmsandi §§W325263 v E;”"°“‘E‘°’*é“‘f3“ 2960 WllShil’e Boulevard, LA. CA 90010 “UPERIOR D COURT 0F CALIFORNIA TELEPHONE N0; 31 0-277—7529 COUNTY OF SAN BERNARDINO E-MAIL ADDRESS: david SAN BERNARWWD DISTRICT .arashlaw.comRIAL SEWING CONFERENCE DATE: 12/ 1 1/2020 ATTORNEV FOR (Name): P ihtlfis UNLMTED CASE: X FAX NO. (Optional): _~. LIMITED CASE: N D V 2 4 2020 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO 6...“! COURTHOUSE Ress: es I ee . an mar mo, _ f».w.-_.- B‘ PLAINTIFF: Rafael Carvajal Marquez, et al. SAMANTHA NEUBAUER. DEPUTY DEFENDANT: GWWEE; mt: efal. INITIAL TRIAL SETTING CONFERENCE STATEMENT CéfiVWEBHoam INSTRUCTIONS: All applicable boxes must be checked, and tho specified information mun be provided. This document must be filed 5nd . i x w. A 3L3 .23. .' t m 1 .e A - . y I , u: u: z: 1;. I 1. Party or parties (answer one): a. This statement is submitted by party (name): Rafael Carvajal Marquez, at al. b. This statement is submitted jointly by parties (names): 2. Service of Complaint on all parties has a has not D been completed. 3. Service of Crou-Complaint on all parties has E has not D been completed. 4. Dascrlptlon of case in Complaint On July 17, 2018. Plaintiff was inside a Genie Lifi while Mfforming drywall \NOfk. As a_ result of the lack of safety measures, Plaintiff lost. hls_balance a_nd fen many feet. Plaintiff sustained wtastrophic injuries, inciuding fractures In hrs skull, Injuries to bram, neck and back. 5. Description of case in Cross—Complaint 6. Has all discovery been completed: Yes D No E Date discovery anticipated to bu completed: Per COde a D x 7. B. Do you agreeto mediation? Yes No Related cases, consolidation, and coordination: Please attach a Notice of Related Case. P&ease checktype agreed to: Private: Coun—sponsored: X D A motion to D consoiidate D Trial dates requested: YesD No D Available dates: a 'l Time estimate: >m m1 Other issues: 9. D The following additional matters are requested to be considered by the Court: m u] 10. Meet and Confer: =1! m The parties represent that they have met and conferred on all subjects required byCallfornia Rules of Court, Rule 3.724. u“ D The parties have entered into the following stipulation(s): 11. Total number of pages attached (ifany): I am completely familiar with this case and will be fully prepared to discuss the status ofdbcovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into-stipum on these issues at the time of the Initial Trial Setting Conference, including the written authority of the party where required. Date: November 24 2020 David J. Ebenhack " (TYPE 0R PRINT NAME) (SIGNATURE 0F PARTY 0R ATrORNEY (TYPE 0R PRINT NAME) (SIGNATWOF PARTY 0R ATTORNEY Form fl 13-09001 —360 Rwazozn Mandalay INITIAL TRIAL SETTINGCONFERENCE STATEMENT » m f Amrrimu up . m. PROOF 0F SERVICE y.“ m—A I declar‘e that I am over the age of eighteen (1 8) and not a party to this action. My business address is 2960 Wilshire Blvd., Third Floor, Los Angeles, California 90010. On November 24, 2020, I caused to be saved the following document(s): INITIAL TRIAL SETTING CONFERENCE STATEMENT on the interested party(ies) in this action by placing a true and correct copy of document(s) in a EOOOQOSMAWN sealed envelope addressed as follows: SEE ATTACHED SERVICE LIST (X) [U.S. MAIL] I am readily familiar with the business practice for collection and processing of correspondence for mailing with the United States Postal Service. I know that the correspondence is deposited with the United States Postal Service on the same day this declaration was executed in the ordin course of business. I know that the —~ G envelope was sealed and, with postage thereon 1y prepaid, placed for collection and . mailing on this date, following ordinary business practices in the United States p-s-n mailed at Los Angeles, California. N?“ u—n‘ () [OVERNIGHT DELIVERY] Via Federal Express or similar overnight courier service, by depositing in a box or other maintained by such overnight delivery facility regularly LO service, or delivering such envelope to a courier or driver authorized by said overnight delivery service to receive documents, in an envelope designated by said overnight delivery service with delivery fees paid or provided for, addressed to the address last shown by that person on any documents filed in this action. [FACSIMILE] Via facsimile machine, I caused the above-referenced document(s) to be transmitted to the person(s) listed above. (X) [ELECTRONIC MAIL] Via electronic mail, Icaused the above—referenced document(s) to be transmitted to the address listed above. (X) (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on November 24, 2020, at Los Aug PROOF OF SERVICE