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
NAME AND ADDRESS OF "ARTYWITHOUT ATTORN STATE BAR NUMBE! Reserved for Cletks Fite Samp
Daniel R. Friedenthal “SBN 136847); Michael G. Rix (SBN 233453}
1520 W. Colorado Blvd., 2nd Fl,
Pasadena, CA 9110!
TELEPHONE NO. : (626) 628-2800
E-MAIL ADDRESStfriedenthal@fhblawyers.comTRIAL SETTING CONFERENCE DATE: December 11, 2020
ATTORNEY FOR (Name)Duke Realty Limited ParUNLIMITED CASE: x
FAX NO. (Optional): (626) 628-2828 LIMITED CASE:
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
DEC 0 4 2020
COURTHOUSE ADDRESS: 247 w. 2rd St., San Bernardino,
CA 92408
PLAINTIFF: Rafael Carvajal Marquez, et al wy Bate aohe, _
“DEFENDANT: Genie Industries, Inc,, et al. Deputy
INITIAL TRIAL SETTING CONFERENCE STATEMENT CASE NUMBE!
civp$2010310
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. This document must be filed and
erved at least 15 days prior to the trial setting conference date.
1 Party or parties (answer one) ~
a. This statement is submitted by party (name): Duke Realty Limited Partnership
b. This statement is submitted jointly by parties (names):
Service of Complaint on all parties has L] has not (] been completed
Service of Cross-Complaint on all parties has IX] has not []_ been completed.
Description of case in Complaint: Complaint for Personal Injury. Plaintiff, Rafael Carvajal Marquez claims on or about July 17, 2018, he was injured when he
fell off a motorized scissor lift while working at a job site in Fontana, CA. As a result, Plaintiffs are claiming personal injury/
property damage. The extent of the damages are unknown at this time. His wife is making a claim of loss of consortium.
Description of case in Cross-Complaint: Cross-Complaint for Equitable Indemnity , Apportionment of Fault, Declaratory Releif, Express Indemnity and
Comparative Negligence.
Has all discovery been completed: Yes ] No [x] Date discovery anticipated to be completed: _ September 2021
Do you agree to mediation? Yes EX] No L] Please check type agreed to: Private: x Court-sponsored: —
Related cases, consolidation, and coordination: Please attach a Notice of Related Case.
[1 amotionto [1 consolidate [1 Trial dates requested: Yes[_] No (] Available dates Time
estimate:
Other issues:
#i [7] the following additional matters are requested to be considered by the Court
10. Meet and Confer:
ee
LU The parties represent that they have met and conferred on all subjects required by California Rules of Court, Rule 3.724.
(1 the parties have entered into the following stipulation(s):
11 Total number of pages attached (if any)
| 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 Initial Trial Setting
Conference, including the written authority of the party where required
December 4, 2020
Warts)Deg
Date:
Michael G. Rix
hees (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY
Form# 13-09001-360
Rev.6-2020 Mandatory INITIAL TRIAL SETTING CONFERENCE STATEMEN
PROOF OF SERVICE
Marquez, et al. v. Genie Industries, Inc., et al.
Case No.: CIVDS2010310
STATE OF CALIFORNIA )
ss:
COUNTY OF LOS ANGELES )
| am employed in the County of Los Angeles, State of California. | am over the
age of 18 and not a party to the within action; my business address is: 1520 W.
Colorado Boulevard, Second Floor, Pasadena, California 91105.
On December 4, 2020, | served the foregoing document as INITIAL TRIAL
SETTING CONFERENCE STATEMENT on the parties in this action by placing a true
copy thereof enclosed in a sealed envelope addressed as follows:
~
* PLEASE SEE ATTACHED SERVICE LIST *
10 [0 MAIL SERVICE: As follows: | am “readily familiar" with the firm's practice of
11 collection and processing correspondence for mailing. Under that practice it would
be deposited with U.S. postal service on that same day with postage thereon fully
12 prepaid at Pasadena, California, in the ordinary course of business. | am aware that
on motion of the party served, service is presumed invalid if postal cancellation date
13 or postage meter date is more than one day after date of deposit for mailing in
affidavit.
14
(] FEDERAL EXPRESS SERVICE: | caused such envelopes to be delivered by
15 Federal Express to the offices of the addressee listed on the attached Service List. |
16 further designed such envelopes to be delivered to all addressees on the attached
Service List utilizing Fed-Ex's “Overnight Next-Day Delivery Service.”
17
KX] ELECTRONIC MEANS (EMAIL): | caused such document(s) to be electronically
18 served through email for the above-entitled matter. This service complies with
Emergency Rule 12 of the California Rules of Court. The file transmission was
19 reported as complete and a copy of the “Sent” page noting the date and time of such
transmission will be maintained with the file copy of the document(s) in our office.
20
[] PERSONAL SERVICE: | caused such document to be hand-delivered to the
21 addressees indicated below, via First Legal.
22 (1 FACSIMILE SERVICE: | caused such document to be faxed to the addressee.
23 | declare under penalty of perjury under the laws of the State of California that
the above is true and correct. Executed on December 4, 2020, at Pasadena,
24
ot
California.
2
25
26 Natasha ee)
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28
-1-
PROOF OF SERVICE
Document Filed Date
December 04, 2020
Case Filing Date
June 11, 2020
Category
Personal Injury Non-Motor Vehicle Unlimited
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