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ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Kevin Piekut, Esq. 185353
Law Offices of Scott C Stratman
PO Box 258829
Oklahoma City, OK 73125-8829
TELEPHONE NO.: (916) 503-2742 FAX NO. (Optional):
E-MAIL ADDRESS (Optional): la.legal@farmersinsurance.com
Defendant, WINGSTOP RESTAURANTS, INC.
ATTORNEY FOR (Name):
SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN
STREET ADDRESS: 1215 Truxtun Avenue
MAILING ADDRESS: Bakersfield,
1215 TruxtunCA 93301
Avenue
CITY AND ZIP CODE: Bakersfield, CA 93301
BRANCH NAME:
PLAINTIFF/PETITIONER: Elizabeth Hernandez
DEFENDANT/RESPONDENT: Ahmad Cahla Plaza LLC, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
BCV-23-103005
(Check one): UNLIMITED CASE LIMITED CASE
(Amount demanded (Amount demanded is
exceeds $35,000) $35,000 or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: May 10, 2024 Time: 8:15 AM Dept.: 17 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Kevin Piekut
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. This statement is submitted by party (name): WINGSTOP RESTAURANTS, INC.
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, or have appeared, or have been dismissed,
b. 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):
(3) have had a default entered against them (specify names):
c. The following additional parties may be added (specify names, nature of involvement in case, and the date by which
they may be served):
4. Description of case
a. Type of case in complaint cross-complaint (Describe, including causes of action):
Alleged Slip and fall. Alleged negligence and premises liability.
CM-110 [Rev. January 1, 2024] Cal. Rules of Court,
CASE MANAGEMENT STATEMENT rules 3.720-3.730
www.courts.ca gov
CM-110
PLAINTIFF/PETITIONER: Elizabeth Hernandez CASE NUMBER:
BCV-23-103005
DEFENDANT/RESPONDENT: Ahmad Cahla Plaza LLC, et al.
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.)
Alleged slip and fall. Liability and damages are in dispute.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request a jury trial a non-jury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. The trial has been set for (date):
b. 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):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 7
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: e. Fax number:
f. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
9. 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 has has not provided the ADR information package identified
In rule 3.221 to the client and has 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.
b. 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: Elizabeth Hernandez CASE NUMBER:
BCV-23-103005
DEFENDANT/RESPONDENT: Ahmad Cahla Plaza LLC, et al.
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 this If the party or parties completing this form in the case have agreed
form are willing to participate in the to participate in or have already completed an ADR process or
following ADR processes (check all processes, indicate the stat us of the processes (attach a copy of
that apply): the parties’ ADR stipulation)
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date):
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 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
ADR session scheduled for (date):
(6) Other (specify)
Agreed to complete ADR session by (date):
ADR session completed on (date):
CM-110 [Rev. January 1, 2024] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Elizabeth Hernandez CASE NUMBER:
BCV-23-103005
DEFENDANT/RESPONDENT: Ahmad Cahla Plaza LLC, et al.
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name): Mid-Century Insurance Company
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:
13. 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:
Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate wiII 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
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendant(s) Written Discovery to Plaintiff Ongoing
Defendant(s) Deposition of Plaintiff August 2024
Defendant(s) Subpoena of Medical and other records Ongoing
Defendant(s) Medical Examination of Plaintiff (IME) Dec 2024
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. January 1, 2024] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Elizabeth Hernandez CASE NUMBER:
BCV-23-103005
DEFENDANT/RESPONDENT: Ahmad Cahla Plaza LLC, et al.
17. Economic litigation
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
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. 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): 0
I 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 24, 2024
Kevin Piekut 
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)

(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev. January 1, 2024] Page 5 of 5
CASE MANAGEMENT STATEMENT
1 Re: Hernandez v. Ahmad Cahla Plaza, LLC, et al.
Case Number: BCV-23-103005
2
PROOF OF SERVICE
3
Code of Civil Procedure §§ 1013a, 2015.5
4
I am a resident of the State of California and over the age of eighteen years, and not a
5 party to the within action. My business address is P.O. Box 258829, Oklahoma City, OK
73125-8829. On April 24, 2024, I served the following document(s):
6
CASE MANAGEMENT STATEMENT
7
By placing the document(s) listed above in a sealed envelope, addressed as set
8
forth below, with postage fully prepaid, and placing the envelope for collection
9 and mailing by the U.S. Postal Service on the same day following the firm’s
ordinary business practices of which I am readily familiar. I am aware that on
10 motion of the party served, service is presumed invalid if postal cancellation
date or postage meter date is more than one day after date of deposit for
11 mailing in affidavit.
12
By causing a true copy thereof to be personally delivered to the person(s) at the
13 address(es) set forth below.
14 By electronically serving the document(s) described above via a Court
approved File & Serve vendor on those recipients designated on the
15
Transaction Receipt located on the vendor’s Website.
16
By electronically serving the document(s) to the electronic mail address set
17 forth below on this date before 11:59:59 p.m. pursuant to and consistent with
Code of Civil Procedure §§1010.6(a)(2), (4), (5) and 1010.6(e) from email
18 X address beth.goering@farmersinsurance.com.
19
I declare under penalty of perjury under the laws of the State of California that the
20 above is true and correct.
21 Executed on April 24, 2024, at Woodland Hills, California.
22
23
BETH L. GOERING
24
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1 Re: Hernandez v. Ahmad Cahla Plaza, LLC, et al.
Case Number: BCV-23-103005
2
SERVICE LIST
3
Anthony Werbin
4 Downtown L.A. Law Group
910 S. Broadway Avenue
5 Los Angeles, CA 90015
Attorney for Plaintiff, Elizabeth Hernandez
6 Phone: (213) 389-3765
Fax: (877) 389-2775
7 Anthony@downtownlalaw.com
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ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Kevin Piekut, Esq. 185353 Law Offices of Scott C Stratman PO Box 258829 Oklahoma City, OK 73125-8829 TELEPHONE NO.: (916) 503-2742 FAX NO. (Optional): E-MAIL ADDRESS (Optional): la.legal@farmersinsurance.com Defendant, WINGSTOP RESTAURANTS, INC. ATTORNEY FOR (Name): SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN STREET ADDRESS: 1215 Truxtun Avenue MAILING ADDRESS: Bakersfield, 1215 TruxtunCA 93301 Avenue CITY AND ZIP CODE: Bakersfield, CA 93301 BRANCH NAME: PLAINTIFF/PETITIONER: Elizabeth Hernandez DEFENDANT/RESPONDENT: Ahmad Cahla Plaza LLC, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: BCV-23-103005 (Check one): UNLIMITED CASE LIMITED CASE (Amount demanded (Amount demanded is exceeds $35,000) $35,000 or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 10, 2024 Time: 8:15 AM Dept.: 17 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Kevin Piekut INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): WINGSTOP RESTAURANTS, INC. b. This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, or have appeared, or have been dismissed, b. 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): (3) have had a default entered against them (specify names): c. The following additional parties may be added (specify names, nature of involvement in case, and the date by which they may be served): 4. Description of case a. Type of case in complaint cross-complaint (Describe, including causes of action): Alleged Slip and fall. Alleged negligence and premises liability. CM-110 [Rev. January 1, 2024] Cal. Rules of Court, CASE MANAGEMENT STATEMENT rules 3.720-3.730 www.courts.ca gov CM-110 PLAINTIFF/PETITIONER: Elizabeth Hernandez CASE NUMBER: BCV-23-103005 DEFENDANT/RESPONDENT: Ahmad Cahla Plaza LLC, et al. 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.) Alleged slip and fall. Liability and damages are in dispute. (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request a jury trial a non-jury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. The trial has been set for (date): b. 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): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 7 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: e. Fax number: f. E-mail address: g. Party represented: Additional representation is described in Attachment 8. 9. 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 has has not provided the ADR information package identified In rule 3.221 to the client and has 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. b. 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: Elizabeth Hernandez CASE NUMBER: BCV-23-103005 DEFENDANT/RESPONDENT: Ahmad Cahla Plaza LLC, et al. 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 this If the party or parties completing this form in the case have agreed form are willing to participate in the to participate in or have already completed an ADR process or following ADR processes (check all processes, indicate the stat us of the processes (attach a copy of that apply): the parties’ ADR stipulation) Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): 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 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 ADR session scheduled for (date): (6) Other (specify) Agreed to complete ADR session by (date): ADR session completed on (date): CM-110 [Rev. January 1, 2024] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Elizabeth Hernandez CASE NUMBER: BCV-23-103005 DEFENDANT/RESPONDENT: Ahmad Cahla Plaza LLC, et al. 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): Mid-Century Insurance Company 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: 13. 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: Additional cases are described in Attachment 13a. b. A motion to consolidate coordinate wiII 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 The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant(s) Written Discovery to Plaintiff Ongoing Defendant(s) Deposition of Plaintiff August 2024 Defendant(s) Subpoena of Medical and other records Ongoing Defendant(s) Medical Examination of Plaintiff (IME) Dec 2024 c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. January 1, 2024] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Elizabeth Hernandez CASE NUMBER: BCV-23-103005 DEFENDANT/RESPONDENT: Ahmad Cahla Plaza LLC, et al. 17. Economic litigation 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 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. 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): 0 I 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 24, 2024 Kevin Piekut  (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)  (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. January 1, 2024] Page 5 of 5 CASE MANAGEMENT STATEMENT 1 Re: Hernandez v. Ahmad Cahla Plaza, LLC, et al. Case Number: BCV-23-103005 2 PROOF OF SERVICE 3 Code of Civil Procedure §§ 1013a, 2015.5 4 I am a resident of the State of California and over the age of eighteen years, and not a 5 party to the within action. My business address is P.O. Box 258829, Oklahoma City, OK 73125-8829. On April 24, 2024, I served the following document(s): 6 CASE MANAGEMENT STATEMENT 7 By placing the document(s) listed above in a sealed envelope, addressed as set 8 forth below, with postage fully prepaid, and placing the envelope for collection 9 and mailing by the U.S. Postal Service on the same day following the firm’s ordinary business practices of which I am readily familiar. I am aware that on 10 motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for 11 mailing in affidavit. 12 By causing a true copy thereof to be personally delivered to the person(s) at the 13 address(es) set forth below. 14 By electronically serving the document(s) described above via a Court approved File & Serve vendor on those recipients designated on the 15 Transaction Receipt located on the vendor’s Website. 16 By electronically serving the document(s) to the electronic mail address set 17 forth below on this date before 11:59:59 p.m. pursuant to and consistent with Code of Civil Procedure §§1010.6(a)(2), (4), (5) and 1010.6(e) from email 18 X address beth.goering@farmersinsurance.com. 19 I declare under penalty of perjury under the laws of the State of California that the 20 above is true and correct. 21 Executed on April 24, 2024, at Woodland Hills, California. 22 23 BETH L. GOERING 24 25 26 27 28 1 Re: Hernandez v. Ahmad Cahla Plaza, LLC, et al. Case Number: BCV-23-103005 2 SERVICE LIST 3 Anthony Werbin 4 Downtown L.A. Law Group 910 S. Broadway Avenue 5 Los Angeles, CA 90015 Attorney for Plaintiff, Elizabeth Hernandez 6 Phone: (213) 389-3765 Fax: (877) 389-2775 7 Anthony@downtownlalaw.com 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28