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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT
USE ONLY
Robert Javan 148806
Laughlin, Falbo, Levy & Moresi LLP
FILED
106 "K" Street, Second Floor
Sacramento, CA 95814-3213
TELEPHONE NO.: (916) 441-6045 FAXNO. (Opioney: (916) 441-7067
E-MAIL ADDRESS (Optionap: Havan@lflm.com.
ATTORNEY FOR (Name): Plaintiff, Cypress Insurance Company
SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO APR 2 0 2016
street aopress: 1130 O Street
FRESNO COUNTY SUPERIOR COURT
MAILING ADDRESS:
y
crry ano zip cope: Fresno, CA 93721-2220 DEPUTY
BRANCH NAME:
PLAINTIFF/PETITIONER: Cypress Insurance Company
DEFENDANT/RESPONDENT: Kathleen Angelique
CASE MANAGEMENT STATEMENT CASE NUMBER:
15CECG03931
(Check one): {UNLIMITED CASE oO LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: May 2, 2016 Time: 1:30 p.m. Dept. 104 Div.: Room:
Address of court (if different from the address above):
& Notice of intent to Appear by Telephone, by (name): Robert B. Javan
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. y This statement is submitted by party (name): Cypress Insurance Company
b. Oo This statement is submitted jointly by parties (names):
Complaint and cross-compiaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): December 30, 2015
b. [1 Thecross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
a. [&] Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [1 The following parties named in the complaint or cross-complaint
(1) (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):
e O The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
Description of case
a. Type
of case in [J complaint oO cross-complaint (Describe, including causes of action):
Workers compensation subrogation arising from a motor vehicle collision.
Page 1of§
Form. for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
‘Judicial Council of Califomia nulos 3.720-3.730
CM-110 [Rev, July 1, 2011] www.courts.ca.gov
American Lega Ine,
NY
CM-110
PLAINTIFF/PETITIONER: Cypress Insurance Company ‘CASE NUMBER:
15CECG03931
| DEFENDANT/RESPONDENT: Kathleen Angelique
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.)
This is a workers compensation subrogation action arising from a motor vehicle collision of 1/8/2014. An
employee of Kuckenbecker Tractor Co., Roger Baker, was injured. At the time of the loss Plaintiff insured
Kuckenbecker Tractor Co. Plaintiff has paid benefits to or for the benefit of Mr. Baker and is subrogated to the
employer's rights pursuant to California Insurance Code §11662. The subrogation action has been filed pursuant
to the mandates of Labor Code §3852, et. seq.
1) (fmore space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request Rl a jury trial 1 anonjury trial. (lf more than one party, provide the name of each party
requesting a jury trial):
Trial date
a. [1 The trial has been set for (date):
b. &X 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):
See attachment 6c
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a days (specify number): 5-7
b, oO hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial [J by the attorney or party listed in the caption 1 by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
oO Additional representation is described in Attachment 8.
Preference
Oo 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 [] has (J hasnot provided the ADR information package identified
in rule 3.224 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party [[] has 71 has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) [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) [1 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) 1 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, 2017} CASE MANAGEMENT STATEMENT Page
2 of 5
‘American LegalNet, Inc.
r-
\e
CM-110
PLAINTIFF/PETITIONER: Cypress Insurance Company CASE NUMBER:
45CECG03931
IDEFENDANT/RESPONDENT: Kathleen Angelique
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 ail that apply): | stipulation):
& Mediation session not yet scheduled
Oo Mediation session scheduled for (date):
(1) Mediation
Oo Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
xX]
conference
Agreed to complete settlement conference by (dafe) :
Settlement conference completed on (date):
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 Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
‘CM-4110 {Rev. July
1, 2011] CASE MANAGEMENT STATEMENT Page
3 of 6
American LegalNet, Ine.
Form: Hd
NY \~
CM-110
PLAINTIFF/PETITIONER: Cypress Insurance Company ‘CASE NUMBER:
15CECG03931
DEFENDANT/RESPONDENT: Kathleen Angelique
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: [1] Yes I No
.« O 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.
(1 Bankruptcy [1] Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. (1) There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
[1 Additional cases are described in Attachment 13a.
b. [J Amotionto [1 consolidate [] coordinate will be filed by (name party):
14, Bifurcation
(1 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
Ol the party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. 1 The party or parties have completed all discovery.
b & The following discovery will be completed by the date specified (describe all anticipated discovery):
Description Date
Plaintiff Written Discovery Per Code
Plaintiff Witness Depositions Per Code
Plaintiff Document Productions Per Code
c. 0 The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
‘CM-110 [Rev. July1, 2011] CASE MANAGEMENT STATEMENT Page
4 of §
American LegalNet, Ine.
NS Ne Z
CM-110
PLAINTIFF/PETITIONER: Cypress Insurance Company CASE NUMBER:
15CECG03931
| DEFENDANT/RESPONDENT: Kathleen Angelique
17. Economic litigation
a. (1 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. [J This isa 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
El The party or parties request that the following additional matters be considered or determined at the case management
conference (specify): The parties are currently in the middle of discovery.
19. Meet and confer
a. (1 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: April 18, 2016
Robert B. Javan, Esq.
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT | (SIGNATURE OF PARTY OR ATTORNEY)
C Additional signatures are attached.
1-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page
6 of 6
{ :
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Case Name: Cypress Insurance Company vs. Kathleen Angelique, et al.
Case Number: 15CECG03931
ATTACHMENT 6.c. TO CASE MANAGEMENT STATEMENT
DATES AND REASONS FOR TRIAL UNAVAILABILITY
(as of submission of CMC Statement)
Date Event Case Name Venue
4/19/16 Law & Motion Hearing Palafox Alameda
4/29/16 Law & Motion Hearing Stauffer Butte
5/13/16 MSC J. Martinez Monterey
5/16-5/23/16 Vacation
6/1/16 MSC Matney Sacramento
6/13-6/17/16 Trial J. Martinez Monterey
6/24-7/1/16 Trial A. Martinez Kings
6/27/16 MSC Falosk Shasta
6/28/16 Ms! Fine Sacramento
7/6/16 MSc Fine Sacramento
7/11-7/15/16 Trial Matney Sacramento
7/11-7/15/16 Trial Scott Santa Clara
8/15-8/26/16 Trial Fine Sacramento
9/20/16 MSC Paez-Gomez Colusa
9/27-9/28/16 Trial Falosk Shasta
10/11/16 Settlement Conference Paez-Gomez Colusa
10/18/16 MSC Coffee Alameda
10/21/16 MSC Hodge Placer
10/28/16 Pre-Trial Conference Coffee Alameda
10/28/16 MSC Joyce Placer
11/7-11/11/16 Trial Hodge Placer
11/7-11/11/16 Trial Coffee Alameda
11/14-11/18/16 Trial Joyce Placer
11/18/16 MSC Duncan Yuba
11/29-12/13-16 Trial Paez-Gomez Colusa
12/13-12/20/16 Trial Duncan Yuba
~ J
PROOF OF SERVICE
I declare that:
I am employed in the County of Sacramento, California. I am over the age of eighteen
years and not a party to the within cause; my business address is 106 “K” Street 24 Floor,
Sacramento, CA 95814.
On April 18, 2016, I served the CASE MANAGEMENT CONFERENCE STATEMENT, in
said cause, by placing a true copy thereof enclosed in a sealed envelope addressed as follows:
DSZ]
ANx] US. MAIL: I enclosed the documents in a sealed envelope or package addressed to the
persons at the addresses as set forth below and placed the envelope for collection and mailing,
following our ordinary business practices. I am readily familiar with this business’s practice for
collecting and processing correspondence for mailing. On the same day that correspondence is
placed for collection and mailing, it is deposited in the ordinary course of business with the United
States Postal Service at Sacramento, California, in a sealed envelope with postage fully prepaid.
10
O OVERNIGHT DELIVERY (FEDEX): I enclosed the documents in an envelope or package
11 and addressed to the persons at the addresses stated below. I placed the envelope or package for
collection and overnight delivery at an office or a regular utilized drop box of the overnight
12 delivery carrier.
13 oO UPS DELIVERY : I enclosed the documents in an envelope or package and addressed to
the persons at the addresses stated below. I placed the envelope or package for collection and
14 delivery at an office or a regular utilized drop box of the delivery carrier.
(]_ MESSENGER SERVICE: I served the documents by placing them. in an envelope or
15
package addressed to the persons at the addresses listed set forth below and providing them to a
16 professional messenger service for service. (A declaration by the messenger must accompany this proof
of service.)
17 O FAX TRANSMISSION: I faxed the documents to the persons at the fax numbers listed
18 below. No error was reported by the fax machine that I used. A copy of the record of the fax
transmission, which I printed out, is attached.
19 O EMAIL or ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the
parties to accept service by e-mail or electronic transmission, I caused the documents to be sent to
20 the person at the e-mail addresses listed below. I did not receive, within a reasonable time after
21 the transmission, any electronic message or other indication that the transmission was
unsuccessful.
22
Victoria R. Bernhardt, Esq.
McCORMICK BARSTOW LLP
7647 North Fresno Street
24 Fresno, CA 93720
T: (559) 433-1300; F: (559) 433-2300
Email:
victoria.bernhardt@mccormickbarstow.com
26 Attorneys for Defendant Kathleen Angelique
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Cypress Insurance Company v. Kathleen Angelique, et al., Fresno County Superior Court Case. No. 15CECG03931
PROOF OF SERVICE Page 1 of2
xX State: I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
O Federal: I declare that I am employed in the office of a member of the Bar of this Court, ai
whose direction the service was made.
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Cypress Insurance Company v. Kathleen Angelique, et al., Fresno County Superior Court Case. No. I5CECG03931
PROOF OF SERVICE Page 2 of 2
Preview
7 \ / CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Robert Javan 148806 Laughlin, Falbo, Levy & Moresi LLP FILED 106 "K" Street, Second Floor Sacramento, CA 95814-3213 TELEPHONE NO.: (916) 441-6045 FAXNO. (Opioney: (916) 441-7067 E-MAIL ADDRESS (Optionap: Havan@lflm.com. ATTORNEY FOR (Name): Plaintiff, Cypress Insurance Company SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO APR 2 0 2016 street aopress: 1130 O Street FRESNO COUNTY SUPERIOR COURT MAILING ADDRESS: y crry ano zip cope: Fresno, CA 93721-2220 DEPUTY BRANCH NAME: PLAINTIFF/PETITIONER: Cypress Insurance Company DEFENDANT/RESPONDENT: Kathleen Angelique CASE MANAGEMENT STATEMENT CASE NUMBER: 15CECG03931 (Check one): {UNLIMITED CASE oO LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 2, 2016 Time: 1:30 p.m. Dept. 104 Div.: Room: Address of court (if different from the address above): & Notice of intent to Appear by Telephone, by (name): Robert B. Javan INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. y This statement is submitted by party (name): Cypress Insurance Company b. Oo This statement is submitted jointly by parties (names): Complaint and cross-compiaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): December 30, 2015 b. [1 Thecross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) a. [&] Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [1 The following parties named in the complaint or cross-complaint (1) (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): e O The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): Description of case a. Type of case in [J complaint oO cross-complaint (Describe, including causes of action): Workers compensation subrogation arising from a motor vehicle collision. Page 1of§ Form. for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, ‘Judicial Council of Califomia nulos 3.720-3.730 CM-110 [Rev, July 1, 2011] www.courts.ca.gov American Lega Ine, NY CM-110 PLAINTIFF/PETITIONER: Cypress Insurance Company ‘CASE NUMBER: 15CECG03931 | DEFENDANT/RESPONDENT: Kathleen Angelique 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.) This is a workers compensation subrogation action arising from a motor vehicle collision of 1/8/2014. An employee of Kuckenbecker Tractor Co., Roger Baker, was injured. At the time of the loss Plaintiff insured Kuckenbecker Tractor Co. Plaintiff has paid benefits to or for the benefit of Mr. Baker and is subrogated to the employer's rights pursuant to California Insurance Code §11662. The subrogation action has been filed pursuant to the mandates of Labor Code §3852, et. seq. 1) (fmore space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request Rl a jury trial 1 anonjury trial. (lf more than one party, provide the name of each party requesting a jury trial): Trial date a. [1 The trial has been set for (date): b. &X 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): See attachment 6c Estimated length of trial The party or parties estimate that the trial will take (check one): a days (specify number): 5-7 b, oO hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial [J by the attorney or party listed in the caption 1 by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: oO Additional representation is described in Attachment 8. Preference Oo 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 [] has (J hasnot provided the ADR information package identified in rule 3.224 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party [[] has 71 has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) [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) [1 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) 1 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, 2017} CASE MANAGEMENT STATEMENT Page 2 of 5 ‘American LegalNet, Inc. r- \e CM-110 PLAINTIFF/PETITIONER: Cypress Insurance Company CASE NUMBER: 45CECG03931 IDEFENDANT/RESPONDENT: Kathleen Angelique 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 ail that apply): | stipulation): & Mediation session not yet scheduled Oo Mediation session scheduled for (date): (1) Mediation Oo Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): xX] conference Agreed to complete settlement conference by (dafe) : Settlement conference completed on (date): 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 Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): ‘CM-4110 {Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 6 American LegalNet, Ine. Form: Hd NY \~ CM-110 PLAINTIFF/PETITIONER: Cypress Insurance Company ‘CASE NUMBER: 15CECG03931 DEFENDANT/RESPONDENT: Kathleen Angelique 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: [1] Yes I No .« O 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. (1 Bankruptcy [1] Other (specify): Status: 13. Related cases, consolidation, and coordination a. (1) There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: [1 Additional cases are described in Attachment 13a. b. [J Amotionto [1 consolidate [] coordinate will be filed by (name party): 14, Bifurcation (1 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 Ol the party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. 1 The party or parties have completed all discovery. b & The following discovery will be completed by the date specified (describe all anticipated discovery): Description Date Plaintiff Written Discovery Per Code Plaintiff Witness Depositions Per Code Plaintiff Document Productions Per Code c. 0 The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): ‘CM-110 [Rev. July1, 2011] CASE MANAGEMENT STATEMENT Page 4 of § American LegalNet, Ine. NS Ne Z CM-110 PLAINTIFF/PETITIONER: Cypress Insurance Company CASE NUMBER: 15CECG03931 | DEFENDANT/RESPONDENT: Kathleen Angelique 17. Economic litigation a. (1 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. [J This isa 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 El The party or parties request that the following additional matters be considered or determined at the case management conference (specify): The parties are currently in the middle of discovery. 19. Meet and confer a. (1 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: April 18, 2016 Robert B. Javan, Esq. (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT | (SIGNATURE OF PARTY OR ATTORNEY) C Additional signatures are attached. 1-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 6 of 6 { : SH / Case Name: Cypress Insurance Company vs. Kathleen Angelique, et al. Case Number: 15CECG03931 ATTACHMENT 6.c. TO CASE MANAGEMENT STATEMENT DATES AND REASONS FOR TRIAL UNAVAILABILITY (as of submission of CMC Statement) Date Event Case Name Venue 4/19/16 Law & Motion Hearing Palafox Alameda 4/29/16 Law & Motion Hearing Stauffer Butte 5/13/16 MSC J. Martinez Monterey 5/16-5/23/16 Vacation 6/1/16 MSC Matney Sacramento 6/13-6/17/16 Trial J. Martinez Monterey 6/24-7/1/16 Trial A. Martinez Kings 6/27/16 MSC Falosk Shasta 6/28/16 Ms! Fine Sacramento 7/6/16 MSc Fine Sacramento 7/11-7/15/16 Trial Matney Sacramento 7/11-7/15/16 Trial Scott Santa Clara 8/15-8/26/16 Trial Fine Sacramento 9/20/16 MSC Paez-Gomez Colusa 9/27-9/28/16 Trial Falosk Shasta 10/11/16 Settlement Conference Paez-Gomez Colusa 10/18/16 MSC Coffee Alameda 10/21/16 MSC Hodge Placer 10/28/16 Pre-Trial Conference Coffee Alameda 10/28/16 MSC Joyce Placer 11/7-11/11/16 Trial Hodge Placer 11/7-11/11/16 Trial Coffee Alameda 11/14-11/18/16 Trial Joyce Placer 11/18/16 MSC Duncan Yuba 11/29-12/13-16 Trial Paez-Gomez Colusa 12/13-12/20/16 Trial Duncan Yuba ~ J PROOF OF SERVICE I declare that: I am employed in the County of Sacramento, California. I am over the age of eighteen years and not a party to the within cause; my business address is 106 “K” Street 24 Floor, Sacramento, CA 95814. On April 18, 2016, I served the CASE MANAGEMENT CONFERENCE STATEMENT, in said cause, by placing a true copy thereof enclosed in a sealed envelope addressed as follows: DSZ] ANx] US. MAIL: I enclosed the documents in a sealed envelope or package addressed to the persons at the addresses as set forth below and placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with this business’s practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service at Sacramento, California, in a sealed envelope with postage fully prepaid. 10 O OVERNIGHT DELIVERY (FEDEX): I enclosed the documents in an envelope or package 11 and addressed to the persons at the addresses stated below. I placed the envelope or package for collection and overnight delivery at an office or a regular utilized drop box of the overnight 12 delivery carrier. 13 oO UPS DELIVERY : I enclosed the documents in an envelope or package and addressed to the persons at the addresses stated below. I placed the envelope or package for collection and 14 delivery at an office or a regular utilized drop box of the delivery carrier. (]_ MESSENGER SERVICE: I served the documents by placing them. in an envelope or 15 package addressed to the persons at the addresses listed set forth below and providing them to a 16 professional messenger service for service. (A declaration by the messenger must accompany this proof of service.) 17 O FAX TRANSMISSION: I faxed the documents to the persons at the fax numbers listed 18 below. No error was reported by the fax machine that I used. A copy of the record of the fax transmission, which I printed out, is attached. 19 O EMAIL or ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the parties to accept service by e-mail or electronic transmission, I caused the documents to be sent to 20 the person at the e-mail addresses listed below. I did not receive, within a reasonable time after 21 the transmission, any electronic message or other indication that the transmission was unsuccessful. 22 Victoria R. Bernhardt, Esq. McCORMICK BARSTOW LLP 7647 North Fresno Street 24 Fresno, CA 93720 T: (559) 433-1300; F: (559) 433-2300 Email: victoria.bernhardt@mccormickbarstow.com 26 Attorneys for Defendant Kathleen Angelique 27 28 Cypress Insurance Company v. Kathleen Angelique, et al., Fresno County Superior Court Case. No. 15CECG03931 PROOF OF SERVICE Page 1 of2 xX State: I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. O Federal: I declare that I am employed in the office of a member of the Bar of this Court, ai whose direction the service was made. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Cypress Insurance Company v. Kathleen Angelique, et al., Fresno County Superior Court Case. No. I5CECG03931 PROOF OF SERVICE Page 2 of 2