Preview
CM-110
[ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 85258 FOR COURT USE ONLY
name: Marvin Pederson
Firm ame: Attorney at Law
street aporess P.O. Box 336
cry: Point Reyes Station state CA zip cove 94956
freacpHione No: (415) 785-8293 FAXNO, none
emai aooress: pederson@marvlaw.com
ATTORNEY FOR (name): BURDICK and ZUMPANO
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA
STREET ADDRESS 600 Administration Drive, Room 107-J
MAILING ADDRESS: 600 Administration Drive, Room 107-3
CITY AND ZIP CODE Santa Rosa, 95403
BRANCH NAME Hall of Justice
PLAINTIFF/PETITIONER: DOUGLAS BURDICK, et al.
DEFENDANT/RESPONDENT: BRADLEY MORAN, et al.
GASE MANAGEMENT STATEMENT CASE NUMBER
(Check one): (C0 UNLIMITED CASE (] LIMITED CASE
(Amount demanded (Amount demanded is $35,000
or less) SCV-272646
exceeds $35,000)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: Ma7 7, 2024 Time:3:30 p.m. Dept.:16 Div. Room:
Address of court (if different from the address above): 3035 Cleveland Avenue, Santa Rosa, CA 95403
[_] Notice of Intent to Appear by Telephone, by (name):
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one).
a. [QC] This statement is submitted by party (name): DOUGLAS BURDICK and OMEGA ZUMPANO
b. [[_] This statement is submitted jointly by parties (names):
Complaint and cross-complaint (to be answered by plaintiffs and cross-compiainants only)
a. The complaint was filed on (date): February 16, 2023
b. [__] The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
a. [__] All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [Qc] 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): Bradley Moran,
Calvin Moran, Heather Moran
(3) [] have had a default entered against them (specify names): See paragraph 19
c. [__] 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 casein [X] complaint [] cross-complaint (Describe, including causes of action): Breach of
warranty of habitability, nuisance, breach of covenant of quiet enjoyment, wrongful eviction, unlawful
business practices, and retroactive rent abatement.
Page 1 of 5
Cal. Rules of Court,
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT tules 3.720-3.730
Judicial Council of California
(M-110 [Rev. January 1, 2024)
Westlaw Doc & Form Builder~
CM-110
PLAINTIFF/PETITIONER: DOUGLAS BURDICK, et al. CASE NUMBER
DEFENDANT/RESPONDENT: BRADLEY MORAN, et al. SCV-272646
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):
Plaintiffs rented a home from defendants that appears to have been constructed without permits and had some
extremely dangerous conditions, including rodents and a bedroom and bathroom pulling away from its anchor
points, among other serious safety hazards. See attached statement of damages for monetary claims.
[_] (/f more space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request [3G 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. [Xx] 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): | had a very difficult time locating two of the defendants.
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): five to six
b. [__] hours (short causes) (specify).
Trial representation (to be answered for each party)
The party or parties will be represented at trial [XC] by the attorney or party listed in the caption [J by the following:
Attorney:
Firm:
Address:
Telephone number: f Fax number:
Email address: g. Party represented:
[5] 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 [Xx_] 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 [__] has [__] has not reviewed the ADR information package identified in rule 3.221
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) [_] 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. January 1, 2024] Page
2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: DOUGLAS BURDICK, et al. CASE NUMBER
DEFENDANT/RESPONDENT: BRADLEY MORAN, et al. SCV-272646
10. c. In the table below, 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
[] Mediation session scheduled for (date):
(1) Mediation Od (J Agreed to complete mediation by (date):
[-] Mediation completed on (date):
(XC) 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):
[--] 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 schedul
(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
[7] ADR session scheduled for (date)
(6) Other (specify):
[J Agreed to complete ADR session by (date)
[) ADR completed on (date):
(M-110 [Rev. January 1, 2024) Page
3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: DOUGLAS BURDICK, et al. CASE NUMBER,
DEFENDANT/RESPONDENT: BRADLEY MORAN, et al. SCV-272646
11. Insurance
a. [__] Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: [—_] Yes [] 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 [[_] Other (specify)
Status:
43, 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:
[J 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
[3c] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Ex Parte App for publication of Summons
16. Discovery
a. [__] The party or parties have completed all discovery
b. [C] The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiffs Form rogs, special rogs, RFAs, and document demand by November 2024
Depositions by December 2024
ce. [ The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Page
4 ofS
(CM-110 Rev. January 1, 2024] CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: DOUGLAS BURDICK, et al. CASE NUMBER
DEFENDANT/RESPONDENT: BRADLEY MORAN, et al. SCV-272646
17. Economic ‘igation
a. [_] This is a limited civil case (i.e., the amount demanded is $35,000 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
[1] 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. [_] 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. [Xx] After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify): The firm hired by defendants has had a serious staffing problem that they have shared with me, but
now has a more reliable attorney assigned to the case. When I last spoke to him he assured me that he had
filed the agreed stipulation to set aside the default and would answer obo all three defencants.
Accordingly, the case may be ready to set for trial by this Case Management Conference.
20. Total number of pages attached (if any): 1 + pos
| am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute sesolution,
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 21, 2024
Marvin Pederson
(TYPE OR PRINT NAME)
» (Ws (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME)
> (GIGNATURE OF PARTY OR ATTORNEY),
(] Additional signatures are attached.
CM.110 [Rev. January 1, 2024] CASE MANAGEMENT STATEMENT Page § of 5
CIV-050
- DO NOT FILE WITH THE COURT-
-UNLESS YOU ARE APPLYING FOR A DEFAULT JUDGMENT UNDER CODE OF CIVIL PROCEDURE § 585 -
"ATTORNEY OR PARTY WITHOUT ATTORNEY (Name and Address) TELEPHONE NO. FOR COURT USE ONLY
Marvin Pederson (415) 785-8293
Attorney at Law SBN: 85258
P.O. Box 336, Point Reyes Station, CA 94956
fax number: none email: pederson@marvlaw.com
ATTORNEY FOR (name): BURDICK and ZUMPANO
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA
street avoress: 600 Administration Drive, Room 107-J
maiine aporess: 600 Administration Drive, Room 107-J
crry ano zip cove: Santa Rosa, 95403
BRANCH NAME: Hall of Justice
PLAINTIFF: DOUGLAS BURDICK, et al.
DEFENDANT: BRADLEY MORAN, et al. ‘CASE NUMBER:
STATEMENT OF DAMAGES SCV-272646
(Personal Injury or Wrongful Death)
To (name of one defendant only): BRADLEY MORAN, HEATHER MORAN, CALVIN MORAN
Plaintiff (name of one plaintiff only); OMEGA ZUMPANO and DOUGLAS BURDICK
seeks damages in the above-entitled action, as follows:
AMOUNT
1. Gel ral damages
Pain, suffering, and inconvenience ..... $___100,000.00.
b. 2] Emotional distress. ......... $___ 100,000.00
c. J Loss of consortium ...
d. __] Loss of sociey and companionship (wrongful death actions only) ...
e.L_] Other (specify) .
§. (J Other (specify)
g. [1 Continued on Attachment 1.9.
Special damages
a. [5 Medical expenses (to date) .....
b. L__] Future medical expenses (present value) ....
c. (J Loss of earings (to date) ...
d, L_] Loss of future earning capacity (present value) Sees
el Property damage ......
f. (J Funeral expenses (wrongful death actions only) ...
g. [1] Future contributions (present value) (wrongful death actions only) .....
h. L_] value of personal service, advice, or training (wrongful death actions only) ....
$ 151,200.00
Other (specify) Retroactive rental
j. CX) other (specify) Return of depos! $____13,000.00
k. [1 Continued on Attachment 2
[XJ Punitive damages: Plaintiff reserves the right to seek punitive damages in the amount of (specify)... $ —____100.000.00
when pursuing a judgment in the suit filed against you.
>
Date: December 8, 2023
Marvin Pederson (SIGNATURE OF PLAINTIFF OR ATTORNEY FOR PLAINTIFF)
(TYPE OR PRINT NAME)
(Proof of service on reverse) Page 1 of 2
‘Code of Civil Procedure, §§ 425.11, 425.115
Form Adopted for Mandatory Use STATEMENT OF DAMAGES ourtinfo.ca gov
of judicial Council of Calfornia (Personal Injury or Wrongful Death) Westlaw Doc & Form Builder
Vv (050 (Rev. January 1, 2007]
Proof of Service
[C.C.P. § 1013, C.R.C. § 2008, F.R.C.P. Rule 5]
I, the undersigned, say,
1 I am a citizen of the United States. My business address is Post Office Box 336, Point
Reyes Station, CA. I am self-employed in the Town of Point Reyes Station, County of Marin, where
this mailing occurs. I am over the age of eighteen years and not a party to this action.
2 On the Date set forth below, I served a copy of the foregoing document described as
CASE MANAGEMENT STATEMENT
to the following person(s) by emailing a true copy thereof enclosed in sealed envelopes addressed as
follows:
10 gwayland@attorneysre.com
Greg Wayland, Esq.
11 905 Highland Pointe Drive, Suite 100
Roseville, CA 95678
12
/XX__/(BY ELECTRONIC TRANSMISSION) I emailed the document to the email address(es) set out
13
above. Pursuant to Cal. Civ. Proc. Code section 1010.6(e), these documents are being served via
14 electronic mail only and no hard copies will follow.
15 / /(BY PERSONAL SERVICE) I caused each such envelope to be delivered by hand to the
address(es) noted above.
16
17 / (BY FACSIMILE) I caused the said documents to be transmitted by facsimile machine to the
number indicated after the address(es) noted above.
18
3 I declare under penalty of perjury under the laws of the State of California that the
19 foregoing is true and correct and that this declaration was executed this date at Point Reyes Station,
California.
20
21 Dated: April 21, 2024
22
Marvin Pederson
23
24
25
26
27
28
Preview
CM-110 [ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 85258 FOR COURT USE ONLY name: Marvin Pederson Firm ame: Attorney at Law street aporess P.O. Box 336 cry: Point Reyes Station state CA zip cove 94956 freacpHione No: (415) 785-8293 FAXNO, none emai aooress: pederson@marvlaw.com ATTORNEY FOR (name): BURDICK and ZUMPANO SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA STREET ADDRESS 600 Administration Drive, Room 107-J MAILING ADDRESS: 600 Administration Drive, Room 107-3 CITY AND ZIP CODE Santa Rosa, 95403 BRANCH NAME Hall of Justice PLAINTIFF/PETITIONER: DOUGLAS BURDICK, et al. DEFENDANT/RESPONDENT: BRADLEY MORAN, et al. GASE MANAGEMENT STATEMENT CASE NUMBER (Check one): (C0 UNLIMITED CASE (] LIMITED CASE (Amount demanded (Amount demanded is $35,000 or less) SCV-272646 exceeds $35,000) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: Ma7 7, 2024 Time:3:30 p.m. Dept.:16 Div. Room: Address of court (if different from the address above): 3035 Cleveland Avenue, Santa Rosa, CA 95403 [_] Notice of Intent to Appear by Telephone, by (name): INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one). a. [QC] This statement is submitted by party (name): DOUGLAS BURDICK and OMEGA ZUMPANO b. [[_] This statement is submitted jointly by parties (names): Complaint and cross-complaint (to be answered by plaintiffs and cross-compiainants only) a. The complaint was filed on (date): February 16, 2023 b. [__] The cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) a. [__] All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [Qc] 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): Bradley Moran, Calvin Moran, Heather Moran (3) [] have had a default entered against them (specify names): See paragraph 19 c. [__] 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 casein [X] complaint [] cross-complaint (Describe, including causes of action): Breach of warranty of habitability, nuisance, breach of covenant of quiet enjoyment, wrongful eviction, unlawful business practices, and retroactive rent abatement. Page 1 of 5 Cal. Rules of Court, Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT tules 3.720-3.730 Judicial Council of California (M-110 [Rev. January 1, 2024) Westlaw Doc & Form Builder~ CM-110 PLAINTIFF/PETITIONER: DOUGLAS BURDICK, et al. CASE NUMBER DEFENDANT/RESPONDENT: BRADLEY MORAN, et al. SCV-272646 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): Plaintiffs rented a home from defendants that appears to have been constructed without permits and had some extremely dangerous conditions, including rodents and a bedroom and bathroom pulling away from its anchor points, among other serious safety hazards. See attached statement of damages for monetary claims. [_] (/f more space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request [3G 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. [Xx] 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): | had a very difficult time locating two of the defendants. 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): five to six b. [__] hours (short causes) (specify). Trial representation (to be answered for each party) The party or parties will be represented at trial [XC] by the attorney or party listed in the caption [J by the following: Attorney: Firm: Address: Telephone number: f Fax number: Email address: g. Party represented: [5] 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 [Xx_] 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 [__] has [__] has not reviewed the ADR information package identified in rule 3.221 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) [_] 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. January 1, 2024] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: DOUGLAS BURDICK, et al. CASE NUMBER DEFENDANT/RESPONDENT: BRADLEY MORAN, et al. SCV-272646 10. c. In the table below, 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 [] Mediation session scheduled for (date): (1) Mediation Od (J Agreed to complete mediation by (date): [-] Mediation completed on (date): (XC) 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): [--] 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 schedul (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 [7] ADR session scheduled for (date) (6) Other (specify): [J Agreed to complete ADR session by (date) [) ADR completed on (date): (M-110 [Rev. January 1, 2024) Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: DOUGLAS BURDICK, et al. CASE NUMBER, DEFENDANT/RESPONDENT: BRADLEY MORAN, et al. SCV-272646 11. Insurance a. [__] Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: [—_] Yes [] 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 [[_] Other (specify) Status: 43, 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: [J 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 [3c] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Ex Parte App for publication of Summons 16. Discovery a. [__] The party or parties have completed all discovery b. [C] The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Plaintiffs Form rogs, special rogs, RFAs, and document demand by November 2024 Depositions by December 2024 ce. [ The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): Page 4 ofS (CM-110 Rev. January 1, 2024] CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: DOUGLAS BURDICK, et al. CASE NUMBER DEFENDANT/RESPONDENT: BRADLEY MORAN, et al. SCV-272646 17. Economic ‘igation a. [_] This is a limited civil case (i.e., the amount demanded is $35,000 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 [1] 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. [_] 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. [Xx] After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): The firm hired by defendants has had a serious staffing problem that they have shared with me, but now has a more reliable attorney assigned to the case. When I last spoke to him he assured me that he had filed the agreed stipulation to set aside the default and would answer obo all three defencants. Accordingly, the case may be ready to set for trial by this Case Management Conference. 20. Total number of pages attached (if any): 1 + pos | am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute sesolution, 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 21, 2024 Marvin Pederson (TYPE OR PRINT NAME) » (Ws (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) > (GIGNATURE OF PARTY OR ATTORNEY), (] Additional signatures are attached. CM.110 [Rev. January 1, 2024] CASE MANAGEMENT STATEMENT Page § of 5 CIV-050 - DO NOT FILE WITH THE COURT- -UNLESS YOU ARE APPLYING FOR A DEFAULT JUDGMENT UNDER CODE OF CIVIL PROCEDURE § 585 - "ATTORNEY OR PARTY WITHOUT ATTORNEY (Name and Address) TELEPHONE NO. FOR COURT USE ONLY Marvin Pederson (415) 785-8293 Attorney at Law SBN: 85258 P.O. Box 336, Point Reyes Station, CA 94956 fax number: none email: pederson@marvlaw.com ATTORNEY FOR (name): BURDICK and ZUMPANO SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA street avoress: 600 Administration Drive, Room 107-J maiine aporess: 600 Administration Drive, Room 107-J crry ano zip cove: Santa Rosa, 95403 BRANCH NAME: Hall of Justice PLAINTIFF: DOUGLAS BURDICK, et al. DEFENDANT: BRADLEY MORAN, et al. ‘CASE NUMBER: STATEMENT OF DAMAGES SCV-272646 (Personal Injury or Wrongful Death) To (name of one defendant only): BRADLEY MORAN, HEATHER MORAN, CALVIN MORAN Plaintiff (name of one plaintiff only); OMEGA ZUMPANO and DOUGLAS BURDICK seeks damages in the above-entitled action, as follows: AMOUNT 1. Gel ral damages Pain, suffering, and inconvenience ..... $___100,000.00. b. 2] Emotional distress. ......... $___ 100,000.00 c. J Loss of consortium ... d. __] Loss of sociey and companionship (wrongful death actions only) ... e.L_] Other (specify) . §. (J Other (specify) g. [1 Continued on Attachment 1.9. Special damages a. [5 Medical expenses (to date) ..... b. L__] Future medical expenses (present value) .... c. (J Loss of earings (to date) ... d, L_] Loss of future earning capacity (present value) Sees el Property damage ...... f. (J Funeral expenses (wrongful death actions only) ... g. [1] Future contributions (present value) (wrongful death actions only) ..... h. L_] value of personal service, advice, or training (wrongful death actions only) .... $ 151,200.00 Other (specify) Retroactive rental j. CX) other (specify) Return of depos! $____13,000.00 k. [1 Continued on Attachment 2 [XJ Punitive damages: Plaintiff reserves the right to seek punitive damages in the amount of (specify)... $ —____100.000.00 when pursuing a judgment in the suit filed against you. > Date: December 8, 2023 Marvin Pederson (SIGNATURE OF PLAINTIFF OR ATTORNEY FOR PLAINTIFF) (TYPE OR PRINT NAME) (Proof of service on reverse) Page 1 of 2 ‘Code of Civil Procedure, §§ 425.11, 425.115 Form Adopted for Mandatory Use STATEMENT OF DAMAGES ourtinfo.ca gov of judicial Council of Calfornia (Personal Injury or Wrongful Death) Westlaw Doc & Form Builder Vv (050 (Rev. January 1, 2007] Proof of Service [C.C.P. § 1013, C.R.C. § 2008, F.R.C.P. Rule 5] I, the undersigned, say, 1 I am a citizen of the United States. My business address is Post Office Box 336, Point Reyes Station, CA. I am self-employed in the Town of Point Reyes Station, County of Marin, where this mailing occurs. I am over the age of eighteen years and not a party to this action. 2 On the Date set forth below, I served a copy of the foregoing document described as CASE MANAGEMENT STATEMENT to the following person(s) by emailing a true copy thereof enclosed in sealed envelopes addressed as follows: 10 gwayland@attorneysre.com Greg Wayland, Esq. 11 905 Highland Pointe Drive, Suite 100 Roseville, CA 95678 12 /XX__/(BY ELECTRONIC TRANSMISSION) I emailed the document to the email address(es) set out 13 above. Pursuant to Cal. Civ. Proc. Code section 1010.6(e), these documents are being served via 14 electronic mail only and no hard copies will follow. 15 / /(BY PERSONAL SERVICE) I caused each such envelope to be delivered by hand to the address(es) noted above. 16 17 / (BY FACSIMILE) I caused the said documents to be transmitted by facsimile machine to the number indicated after the address(es) noted above. 18 3 I declare under penalty of perjury under the laws of the State of California that the 19 foregoing is true and correct and that this declaration was executed this date at Point Reyes Station, California. 20 21 Dated: April 21, 2024 22 Marvin Pederson 23 24 25 26 27 28