Preview
——— CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY
name: Michael J. Czeshinski, #138063; Kelsey T. Schulteis, #349876
Firmname: Wilkins, Drolshagen & Czeshinski LLP
STREET ADDRESS: 6785 N. Willow Avenue
crry: Fresno STATE CA ZIP CODE: 93710
TELEPHONE NO.: (559) 438-2390 FAXNO. (559) 438-2393
EMAILADDRESS: mjc@wdcllp.com
ATTORNEY FOR (name): Defendants, ANGEL F. FLORES and CLAUDIA RIOS
SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN
‘STREET ADDRESS: 1215 Truxtun Avenue
MAILING ADDRESS: 1215 Truxtun Avenue
city AND zIPcopE: Bakersfield, 93301
BRANCH NAME: Metro Justice Building
PLAINTIFF/PETITIONER: OCTAVIO L, SALGADO; DIGNA M. RAMIREZ
DEFENDANT/RESPONDENT: ANGEL F. FLORES and CLAUDIA RIOS
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): |X] UNLIMITED CASE (J LiMiTED CASE
(Amount demanded (Amount demanded is $35,000
exceeds $35,000) or less) BCV-23-102357
‘A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: May 15, 2024 Time:8:15 a.m, Dept.:17 Div.: Room:
\Address of court (if different from the address above): 1415 Truxtun Avenue, Bakersfield, CA 93301
Notice of Intent to Appear by Telephone, by (name): Michael J, Czeshinski
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
This statement is submitted by party (name): ANGEL F, FLORES and CLAUDIA RIOS
b. (__] This statement is submitted jointly by parties (names):
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):
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. [[_] The following parties named in the complaint or cross-complaint
(1) [{_] have not been served (specify names and explain why not):
(2) [7] 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 date by which
they may be served):
4 Description of case
a. Type ofcasein [xX] complaint [J cross-complaint (Describe, including causes of action): Plaintiffs filed a
Complaint alleging motor vehicle and general negligence against Defendants, Angel F. Flores and Claudia Rios arising
out of a motor vehicle accident which occurred on August 4, 2021 in Bakersfield, California.
Page 4 of §
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California ules 3.720-3.730
(OM-110 [Rev. January 1, 2024) www. courts.ca,gov
Westlaw Doc & Form Builder
CM-110
PLAINTIFF/PETITIONER: OCTAVIO L, SALGADO; DIGNA M. RAMIREZ CASE NUMBER:
DEFENDANT/RESPONDENT: ANGEL F, FLORES and CLAUDIA RIOS BCV-23-102357
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 allege they suffered wage loss; loss of use of property; hospital and medical expenses; general damage; property
damage; loss of earning capacity; and other damage including cost of suit and any other costs that the Court may deem just and
proper. Plaintiffs pray for compensatory damages according to proof.
(] (f 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 (3) ajury trial [J 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. 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)
days (specify number): 5 - 7 days.
b. [-_] hours (short causes) (specify):
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:
Attorney:
Firm:
Address:
Telephone number: f. Fax number:
Email address: g. Party represented:
[] 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 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) [7] 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):
(M-110 [Rev. January 1, 2024] Page 20f 5
CASE MANAGEMENT STATEMENT
CM-110
| PLAINTIFF/PETITIONER: OCTAVIO L. SALGADO; DIGNA M. RAMIREZ CASE NUMBER:
BCV-23-102357
| DEFENDANT/RESPONDENT:ANGEL F. FLORES and CLAUDIA RIOS
10. c. Inthe 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 ail 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 al! that apply): | stipulation):
Mediation session not yet scheduled
[] Mediation session scheduled for (date):
(1) Mediation
[7 Agreed to complete mediation by (date):
(J 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):
[J 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 completed ‘on (date):
(OM-110 [Rev. January 1, 2024) Page
3 of 5
CASE MANAGEMENT ‘STATEMENT
CM-110
PLAINTIFF/PETITIONER: OCTAVIO L. SALGADO; DIGNA M. RAMIREZ CASE NUMBER:
DEFENDANT/RESPONDENT: ANGEL F. FLORES and CLAUDIA RIOS BCV-23-102357
_ _ —_ ee
11. Insurance
a Insurance carrier, if any, for party filing this statement (name): Progressive Insurance Company.
b. Reservation of rights: [~ _] Yes [x] 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.
[J 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:
[__] 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
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Typical motions in limine.
16. Discovery
a. [__] The party or parties have completed all discovery.
The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendants. Subpoena and review records. October 2024.
Defendants. Party depositions. October 2024,
Defendants. Expert discovery. Per code.
Defendants. Written discovery. October 2024.
The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify): None at the present time.
Page
4 of 5
CM-110 [Rev, January 1, 2024) CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: OCTAVIO L. SALGADO; DIGNA M, RAMIREZ CASE NUMBER;
DEFENDANT/RESPONDENT: ANGEL F. FLORES and CLAUDIA RIOS BCV-23-102357
17. Economic ‘igation
a. [__] Thisis 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):
41, 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. [_] 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): 1
1 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 32, 2024.
Kelsey T. Schulteis
(TYPE OR PRINT NAME)
> Raw T.
(fsenatune (OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME)
> (SIGNATURE OF PARTY OR ATTORNEY)
[-) Additional signatures are attached.
OM-110 [Rev. January 1, 2024] CASE MANAGEMENT STATEMENT Page Sof 5
MC-025
SHORT TITLE: SALGADO v. FLORES CASE NUMBER:
| BCV-23-102357
ATTACHMENT (Number): 6c.
(This Attachment may be used with any Judicial Council form.)
Attachment 6c to Case Management Conference Statement
Dates defense counsel is unavailable for trial:
71-7/5/24; 7/22-7/26/24; 7/29-8/1/24; 8/5-8/16/24; 8/12-8/16/24, 8/15-8/20/24; 8/26-8/30/24; 9/2-9/5/24;
9/10-9/24/24; 9/16-9/20/24; 9/23-10/4/24; 9/30-10/3/24; 10/7-10/10/24; 10/14-10/23/24; 10/21-10/25/24;
11/18-11/22/24; 12/2-12/6/24; 12/9-12/20/24; 1/13-1/22/25; 1/20-1/24/25; 1/27-2/4/25; 2/3-2/7/25; 2/10-
2/14/25 ; 3/3-3/7/25; 3/24-3/28/25, 4/7-4/18/25; 4/14-4/18/25; 4/21-5/2/25; 4/28-5/2/25; 5/5-5/9/25; 5/12-
5/16/25; 5/19-5/23/25; 5/27-6/3/25; 6/9-6/13/25; 6/16-6/24/25; 7/7-7/1 1/25; 8/11-8/15/25; 8/25-8/29/25;
9/2-9/5/25; 9/15-9/19/25.
(if the item that this Attachment concerns is made under penalty of perjury, all statements in this Page of
Attachment are made under penaity of perjury.)
(Add pages as required)
Form Approved for Optional Use ATTACHMENT www.courtinfo.ca.gov
Judicial Council of ‘fornia ‘Westlaw
Doc & Form Bullder=
MC-025 [Rev. July1, 2009} to Judicial Council Form
PROOF OF SERVICE
lam a resident of the State of California, over the age of eighteen years, and not a party to
the within action. My business address is 6785 N. Willow Ave., Fresno, CA 93710 (Business
Phone: 559-438-2390). On April 30, 2024, I served the following described document(s) on the
interested parties herein as follows: CASE MANAGEMENT STATEMENT
O BY FACSIMILE: Based on an agreement of the parties to accept service by fax
transmission, I faxed the documents listed above to the persons at the fax numbers listed
below. No error was reported by the fax machine that I used.
BY MAIL: I enclosed the document(s) listed above in an envelope addressed as set
forth below and (check one): L] deposited the sealed envelope with the United States
Postal Service with the postage prepaid. placed the envelope for collection and
mailing following our ordinary business practices. 1 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 in a sealed envelope
10 with postage fully prepaid.
11 BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package
provided by an overnight delivery carrier and addressed to the person(s) at the
12| address(es) listed below. I placed the envelope or package for collection and overnight
delivery at an office or a regularly utilized drop box of the overnight delivery carrier or
13) by delivery to the overnight delivery carrier's authorized courier or driver.
14 BY MESSENGER SERVICE: I served the above listed document(s) by placing said
document(s) in an envelope or package addressed to the person(s) at the address(es)
15 listed below and providing them to a professional messenger service for service. The
Declaration of the Messenger is attached to this Proof of Service.
16
BY PERSONAL SERVICE: I personally delivered the documents to the person(s) at
17| the address(es) set forth below. (1) Fora party represented by an attorney, delivery was
made to the attorney or at the attorney's office by leaving the documents in an envelope
18 or package clearly labeled to identify the attorney being served with a receptionist or an
individual in charge of the office. (2) For a party, delivery was made to the party or by
19) leaving the documents at the party's residence with some person not less than 18 years
of age between the hours of eight in the moming and six in the evening.
BY ELECTRONIC SERVICE: By sending the document(s) listed above via
21 electronic mail to the person at the email address set forth below from teri@
wdcllp.com. I did not receive, within a reasonable time after the transmission, any
22 electronic message or other identification that the transmission was unsuccessful.
Oscar R. Swinton swinton@yahoo.com
23) Law Office of Oscar R. Swinton adanswintonlaw@yahoo.com
5411 Long Beach Blvd.
24 Long Beach, CA 90805
25| I declare under penalty of perjury under the laws of the State of California that the
above is true and correct. Executed on April 30, 2024, at Fresno, California.
27
Teri Lamley
28
WILKINS, -i-
DROLSHAGEN &
CZESHINSKI LLP
6785 N. Willow Ave,
Fresno, CA 93710
Preview
——— CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY name: Michael J. Czeshinski, #138063; Kelsey T. Schulteis, #349876 Firmname: Wilkins, Drolshagen & Czeshinski LLP STREET ADDRESS: 6785 N. Willow Avenue crry: Fresno STATE CA ZIP CODE: 93710 TELEPHONE NO.: (559) 438-2390 FAXNO. (559) 438-2393 EMAILADDRESS: mjc@wdcllp.com ATTORNEY FOR (name): Defendants, ANGEL F. FLORES and CLAUDIA RIOS SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN ‘STREET ADDRESS: 1215 Truxtun Avenue MAILING ADDRESS: 1215 Truxtun Avenue city AND zIPcopE: Bakersfield, 93301 BRANCH NAME: Metro Justice Building PLAINTIFF/PETITIONER: OCTAVIO L, SALGADO; DIGNA M. RAMIREZ DEFENDANT/RESPONDENT: ANGEL F. FLORES and CLAUDIA RIOS CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): |X] UNLIMITED CASE (J LiMiTED CASE (Amount demanded (Amount demanded is $35,000 exceeds $35,000) or less) BCV-23-102357 ‘A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 15, 2024 Time:8:15 a.m, Dept.:17 Div.: Room: \Address of court (if different from the address above): 1415 Truxtun Avenue, Bakersfield, CA 93301 Notice of Intent to Appear by Telephone, by (name): Michael J, Czeshinski INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): This statement is submitted by party (name): ANGEL F, FLORES and CLAUDIA RIOS b. (__] This statement is submitted jointly by parties (names): 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): 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. [[_] The following parties named in the complaint or cross-complaint (1) [{_] have not been served (specify names and explain why not): (2) [7] 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 date by which they may be served): 4 Description of case a. Type ofcasein [xX] complaint [J cross-complaint (Describe, including causes of action): Plaintiffs filed a Complaint alleging motor vehicle and general negligence against Defendants, Angel F. Flores and Claudia Rios arising out of a motor vehicle accident which occurred on August 4, 2021 in Bakersfield, California. Page 4 of § Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California ules 3.720-3.730 (OM-110 [Rev. January 1, 2024) www. courts.ca,gov Westlaw Doc & Form Builder CM-110 PLAINTIFF/PETITIONER: OCTAVIO L, SALGADO; DIGNA M. RAMIREZ CASE NUMBER: DEFENDANT/RESPONDENT: ANGEL F, FLORES and CLAUDIA RIOS BCV-23-102357 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 allege they suffered wage loss; loss of use of property; hospital and medical expenses; general damage; property damage; loss of earning capacity; and other damage including cost of suit and any other costs that the Court may deem just and proper. Plaintiffs pray for compensatory damages according to proof. (] (f 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 (3) ajury trial [J 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. 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) days (specify number): 5 - 7 days. b. [-_] hours (short causes) (specify): 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: Attorney: Firm: Address: Telephone number: f. Fax number: Email address: g. Party represented: [] 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 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) [7] 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): (M-110 [Rev. January 1, 2024] Page 20f 5 CASE MANAGEMENT STATEMENT CM-110 | PLAINTIFF/PETITIONER: OCTAVIO L. SALGADO; DIGNA M. RAMIREZ CASE NUMBER: BCV-23-102357 | DEFENDANT/RESPONDENT:ANGEL F. FLORES and CLAUDIA RIOS 10. c. Inthe 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 ail 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 al! that apply): | stipulation): Mediation session not yet scheduled [] Mediation session scheduled for (date): (1) Mediation [7 Agreed to complete mediation by (date): (J 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): [J 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 completed ‘on (date): (OM-110 [Rev. January 1, 2024) Page 3 of 5 CASE MANAGEMENT ‘STATEMENT CM-110 PLAINTIFF/PETITIONER: OCTAVIO L. SALGADO; DIGNA M. RAMIREZ CASE NUMBER: DEFENDANT/RESPONDENT: ANGEL F. FLORES and CLAUDIA RIOS BCV-23-102357 _ _ —_ ee 11. Insurance a Insurance carrier, if any, for party filing this statement (name): Progressive Insurance Company. b. Reservation of rights: [~ _] Yes [x] 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. [J 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: [__] 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 The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Typical motions in limine. 16. Discovery a. [__] The party or parties have completed all discovery. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendants. Subpoena and review records. October 2024. Defendants. Party depositions. October 2024, Defendants. Expert discovery. Per code. Defendants. Written discovery. October 2024. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): None at the present time. Page 4 of 5 CM-110 [Rev, January 1, 2024) CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: OCTAVIO L. SALGADO; DIGNA M, RAMIREZ CASE NUMBER; DEFENDANT/RESPONDENT: ANGEL F. FLORES and CLAUDIA RIOS BCV-23-102357 17. Economic ‘igation a. [__] Thisis 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): 41, 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. [_] 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): 1 1 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 32, 2024. Kelsey T. Schulteis (TYPE OR PRINT NAME) > Raw T. (fsenatune (OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) > (SIGNATURE OF PARTY OR ATTORNEY) [-) Additional signatures are attached. OM-110 [Rev. January 1, 2024] CASE MANAGEMENT STATEMENT Page Sof 5 MC-025 SHORT TITLE: SALGADO v. FLORES CASE NUMBER: | BCV-23-102357 ATTACHMENT (Number): 6c. (This Attachment may be used with any Judicial Council form.) Attachment 6c to Case Management Conference Statement Dates defense counsel is unavailable for trial: 71-7/5/24; 7/22-7/26/24; 7/29-8/1/24; 8/5-8/16/24; 8/12-8/16/24, 8/15-8/20/24; 8/26-8/30/24; 9/2-9/5/24; 9/10-9/24/24; 9/16-9/20/24; 9/23-10/4/24; 9/30-10/3/24; 10/7-10/10/24; 10/14-10/23/24; 10/21-10/25/24; 11/18-11/22/24; 12/2-12/6/24; 12/9-12/20/24; 1/13-1/22/25; 1/20-1/24/25; 1/27-2/4/25; 2/3-2/7/25; 2/10- 2/14/25 ; 3/3-3/7/25; 3/24-3/28/25, 4/7-4/18/25; 4/14-4/18/25; 4/21-5/2/25; 4/28-5/2/25; 5/5-5/9/25; 5/12- 5/16/25; 5/19-5/23/25; 5/27-6/3/25; 6/9-6/13/25; 6/16-6/24/25; 7/7-7/1 1/25; 8/11-8/15/25; 8/25-8/29/25; 9/2-9/5/25; 9/15-9/19/25. (if the item that this Attachment concerns is made under penalty of perjury, all statements in this Page of Attachment are made under penaity of perjury.) (Add pages as required) Form Approved for Optional Use ATTACHMENT www.courtinfo.ca.gov Judicial Council of ‘fornia ‘Westlaw Doc & Form Bullder= MC-025 [Rev. July1, 2009} to Judicial Council Form PROOF OF SERVICE lam a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is 6785 N. Willow Ave., Fresno, CA 93710 (Business Phone: 559-438-2390). On April 30, 2024, I served the following described document(s) on the interested parties herein as follows: CASE MANAGEMENT STATEMENT O BY FACSIMILE: Based on an agreement of the parties to accept service by fax transmission, I faxed the documents listed above to the persons at the fax numbers listed below. No error was reported by the fax machine that I used. BY MAIL: I enclosed the document(s) listed above in an envelope addressed as set forth below and (check one): L] deposited the sealed envelope with the United States Postal Service with the postage prepaid. placed the envelope for collection and mailing following our ordinary business practices. 1 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 in a sealed envelope 10 with postage fully prepaid. 11 BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided by an overnight delivery carrier and addressed to the person(s) at the 12| address(es) listed below. I placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier or 13) by delivery to the overnight delivery carrier's authorized courier or driver. 14 BY MESSENGER SERVICE: I served the above listed document(s) by placing said document(s) in an envelope or package addressed to the person(s) at the address(es) 15 listed below and providing them to a professional messenger service for service. The Declaration of the Messenger is attached to this Proof of Service. 16 BY PERSONAL SERVICE: I personally delivered the documents to the person(s) at 17| the address(es) set forth below. (1) Fora party represented by an attorney, delivery was made to the attorney or at the attorney's office by leaving the documents in an envelope 18 or package clearly labeled to identify the attorney being served with a receptionist or an individual in charge of the office. (2) For a party, delivery was made to the party or by 19) leaving the documents at the party's residence with some person not less than 18 years of age between the hours of eight in the moming and six in the evening. BY ELECTRONIC SERVICE: By sending the document(s) listed above via 21 electronic mail to the person at the email address set forth below from teri@ wdcllp.com. I did not receive, within a reasonable time after the transmission, any 22 electronic message or other identification that the transmission was unsuccessful. Oscar R. Swinton swinton@yahoo.com 23) Law Office of Oscar R. Swinton adanswintonlaw@yahoo.com 5411 Long Beach Blvd. 24 Long Beach, CA 90805 25| I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on April 30, 2024, at Fresno, California. 27 Teri Lamley 28 WILKINS, -i- DROLSHAGEN & CZESHINSKI LLP 6785 N. Willow Ave, Fresno, CA 93710