Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Eric J. Bengtson - Bar No. 254167
Davis Bengtson & Young, APLC
1960 The Alameda, Suite 210
San Jose, CA 95126-1493
669-245-4200
TELEPHONE NO.: FAX NO. (Optional):
eric@dby-law.com
E-MAIL ADDRESS (Optional):
ATTORNEY FOR (Name): Cotati-Rohnert Park Unified SD (Doe 1)
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA
STREET ADDRESS: 600 Administration Drive, Room 107-J
MAILING ADDRESS:
CITY AND ZIP CODE: Santa Rosa, CA 95403
BRANCH NAME:
PLAINTIFF/PETITIONER: JANE DOE KB
DEFENDANT/RESPONDENT: DOE 1, et al.
CASE NUMBER:
CASE MANAGEMENT STATEMENT
(Check one): X UNLIMITED CASE LIMITED CASE SCV-272161
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: May 9, 2024 Time: 3:00 p.m. Dept.: 19 Div.: Room:
Address of court (if different from the address above):
X Notice of Intent to Appear by Telephone, by (name): Eric Bengtson or other member of firm
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. X This statement is submitted by party (name): Cotati-Rohnert Park USD (Doe 1)
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, 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 date by which
they may be served):
4. Description of case
a. Type of case in
X complaint cross-complaint (Describe, including causes of action):
Childhood sexual abuse; intentional infliction of emotional distress;
negligence (Govt Code secs 815.2 and 820); failure to report suspected child
abuse; negligent supervision of a minor; negligence
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730
CM-110 [Rev. July 1, 2011]
CM-110
PLAINTIFF/PETITIONER: JANE DOE KB CASE NUMBER:
DEFENDANT/RESPONDENT: DOE 1, et al. SCV-272161
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.)
Plaintiff alleges she was a victim of childhood sexual abuse by a teacher
when she was 8-11 years old in 1987-1990.
(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 X a jury triaI a nonjury 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. 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 attached list of trials for unavailability of defense counsel.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. X days (specify number): 5-7
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial X by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. 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 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 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. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: JANE DOE KB CASE NUMBER:
DEFENDANT/RESPONDENT: DOE 1, et al. SCV-272161
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 all that apply): stipulation):
X Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation X
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
Judicial arbitration scheduled for (date):
(4) Nonbinding judicial
arbitration Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
(5) Binding private
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):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: JANE DOE KB CASE NUMBER:
DEFENDANT/RESPONDENT: DOE 1, et al. SCV-272161
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes No
c. x Coverage issues will significantly affect resolution of this case (explain): Defendant is a self-insured
member of a joint powers authority.
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
x 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. X The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Def Cotati-Rohnert Park SD Written discovery ongoing
Def Cotati-Rohnert Park SD Depo of Plaintiff 8/2024
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: JANE DOE KB CASE NUMBER:
DEFENDANT/RESPONDENT: DOE 1, et al. SCV-272161
17. Economic litigation
a. 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. 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. x 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
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
Eric J. Bengtson
(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. July 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
DAVIS, BENGTSON & YOUNG, APLC
Current Trials / Unavailability
4/29/24 Borja v. Brown, Santa Clara Superior Court; Case No. 17CV318915
05/15/24-05/30/24 MED Medical
05/20/24 – 05/31/24 Lopez v. Gilroy Unified School District; Santa Clara Superior, Case No. 20CV368793
06/10/24 - 06/14/24 HMBY (Andalucia) v. Lissoy; Monterey County Sup. Ct; Case No. 21CV001478
06/17/24 – 06/28/24 Caserta v. Santa Clara USD, Santa Clara Superior Court; Case No. 19CV346990
06/24/24 – 07/03/24 Doe (Banwart) v. Mountain View Whisman SD, Santa Clara Sup. Ct.; Case No. 19CV352932
06/25/24-7/10/24 T.Y. v. Sylvan USD, Stanislaus Superior Court, Case No. CV21004338
07/15/24 – 07/26/24 E.S. v. Pajaro Valley USD, Santa Cruz Superior Court, Case No. 21CV02166
07/22/24 – 08/02/24 Y.S. v. Hollister School District, San Benito Superior Court; Case No. CU-19-00212
07/29/24 – 08/10/24 Martinez v. Gonzales USD; Monterey Superior Court; Case No. 22CV000554
08/05/24 – 08/09/24 Terry v. Hollister SD, San Benito Superior Court; Case No. CU-22-00062
08/05/24 – 08/09/24 John Doe v. Tamalpais UHSD, Marin Superior Court, Case No.: CIV2202251
08/12/24 – 08/23/24 Wynn v. Gurholt, Alameda Superior Court; Case No. RG21113363
08/12/24 – 08/17/24 Hale v. OUSD, Alameda Superior Court; Case No. 22CV009845
08/27/24 - 09/06/24 Jane Roe A.P. v. Gateway USD, Shasta County Superior Court, Case No.: 203308
08/28/24 – 09/06/24 John Doe 1-3 v. MUSD, Santa Barbara County Superior Court, Case No. 22CV05157
09/03/24 –09/07/24 Flowers-Haywood v. MVWSD, et al., Santa Clara Sup. Ct.; Case No. 19CV347525
09/09/24 - 09/13/24 John Doe C.G. v. Stockton USD; San Joaquin Superior Court; Case No. STK-CV-UPI-2022-0007076
09/09/24 – 09/13/24 Jane Doe (Coe) v. East Side Union HSD, Santa Clara Superior Court, Case No. 20CV366373
09/09/24 – 09/13/24 Iliya v. City of Sunnyvale, US District Court, Northern District, Case No. 5:23-CV-01249-NC
09/10/24 – 09/20/24 Diamond v. Yosemite CCD, Stanislaus County Superior Court, Case No. CV-22-005626
09/16/24-09/20/24 Jane Doe (Pimeneau) v. Scotts Valley USD, Santa Cruz Superior Court, Case No. 20CV02109
09/17/24 – 09/27/24 Robinson v. Los Banos Unified School District, Merced Superior Court, Case No. 20CV-02099
09/23/24-09/30/24 Warmack v. Palo Alto USD, Santa Clara Superior Court, Case No 21CV381742
09/23/24-09/30/24 Olea v. Hollister SD, San Benito Superior Court, Case No. CU-22-00084
09/30/24 – 10/11/24 Watkins-Wright v. Kahil, Berkeley USD, Alameda Superior Court, Case No. 22CV015268
09/30/24 – 10/11/24 Carter v. Livermore Valley JUHSD, Contra Costa Superior Court; Case No. HG21101135
10/07/24 – 10/11/24 AA v. Palo Alto USD, Santa Clara Superior Court, Case No. 22CV401300
10/14/24 – 10/25/24 Elias v. Oakland USD, Alameda Superior Court, Case No. 23CV030261
10/21/24 – 11/01/24 M.T. v. Pajaro Valley USD, Santa Cruz Superior Court, Case No. 22CV00971
10/28/24 – 11/01/24 Reynaga v. Stockton USD, San Joaquin Superior Court, Case No. STK-CV-UPI-2023-2710
11/04/24 -- 11/08/24 Villareal v. City of San Jose; Federal Court, Northern District, Case No. 22-cv-09152-VKD
11/04/24 – 11/08/24 Choi v. Los Altos School District; Santa Clara Superior Court, Case No. 19-cv-352378
11/12/24 – 11/22/24 Jane Doe (Farias) v. Doe 1 (OGSD), Santa Clara Superior Court, Case No. 22CV403364
11/12/24 – 11/15/24 Patel v. Santa Clara USD, Santa Clara Superior Court, Case No. 20CV365010
11/18/24 – 11/22/24 Whittelsey v. Hopkins & Carely; Bruce B. Roberts, Santa Clara Sup. Court, Case No. 21CV384630
11/25/24 – 12/04/24 Krier v. PAUSD, Santa Clara Superior Court, Case No. 20CV369931
12/02/24 – 12/13/24 John Doe JH v. Doe 1, Alameda Superior Court, Case No. 22CV016355
12/03/24 – 12/13/24 Cramer/Rhoades v. Amador County USD, Amador Superior Court; Case No. 22-CV-12779
12/12/24 – 12/22/24 John Doe JH v. Doe 1; Alameda Superior Court; Case No. 22CV016355
01/06/25 – 01/17/25 Jane Doe DL v. ESUHSD, Santa Clara Superior Court, Case No. 22CV404624
01/13/25 – 01/17/25 John Doe v. Carmel USD, Monterey Superior Court, Case No.: 23CV002840
01/27/25 – 01/31/25 Jane Doe E.W. v. Piper, Santa Clara Superior Court, Case No.: 22CV407905 Consolidated w/
Jane Roe 1-3 v. Alum Rock USD, Santa Clara Superior Court Case No.: 22CV409107
02/03/25 – 02/14/25 Castro v. Berkeley USD, Alameda County Superior Court, Case No. 23CV039713
02/10/25 – 02/21/25 Russell v. Jefferson ESD, San Mateo Superior Court, Case No. 22-CIV-04663
02/25/25 – 03/07/25 McLaurin v. Los Rios CCD; Sacramento Superior Court, Case No. 34-2022-00315187
03/17/25 – 03/28/25 Jane Doe AN v. Does 1-3; Los Angeles Superior Court; Case No. 22STCV29793
03/24/25 – 04/04/25 Curtis v. Oakland Unified School District, Alameda Superior Court, Case No. 23CV041412
04/14/25 – 04/25/25 Facciano v. Mt. View Whisman SD, Santa Clara Superior Court, Case No. 21cv388696
05/05/25 – 05/09/25 Lopez v. Salinas Union HSD, Monterey Superior Court, Case No.
05/19/25 – 05/30/25 Jane Doe v. Winchester; Sacramento Superior Court, Case No. 34-2022-00316580
06/02/25 - 06/06/25 Vasquez v. Gonzales USD, Monterey Superior Court, Case No. 22CV002124
06/09/25 – 06/13/25 Sosa v. Lodi USD, San Joaquin Superior Court, Case No.
06/23/25 – 06/27/25 Serrato v. Greenfield, USD, et al., Monterey Superior Court, Case No. 22CV003574
07/07/25 – 07/11/25 Doe (Foster) v. Carmel USD, et al., Monterey Superior Court, Case No. 23CV003225
09/08/25 – 09/19/25 Doe (Cruz) v. Carmel USD, et al., Monterey Superior Court, Case No. 23CV003505
.92289
1 PROOF OF SERVICE
2 I, the undersigned, say:
3 I am a citizen of the United States. My business address is 1960 The Alameda,
Suite 210, San Jose, CA 95126. I am employed with Davis Bengtson & Young, APLC in
4 the County of Santa Clara, where this service occurs. I am over the age of 18 years, and
not a party to the within matter. On the date set forth below, I served the attached
5 document(s) described as follows:
6 CASE MANAGEMENT STATEMENT
on the following person(s) in this action by providing a true copy thereof, to the following:
7
Attorneys for Plaintiff
8
Andrew I. Chung
9 Cindy K. Suh
Slater Slater Schulman
10 8383 Wilshire Blvd., Ste. 255
Beverly Hills, CA 90211
11 310-341-2086
12 achung@sssfirm.com
csuh@sssfirm.com
13 Cosima Martus cosima.martus@sssfirm.com
Angie Guzman angie.guzman@sssfirm.com
14
15 [ ] (BY MAIL) I am familiar with my firm’s practice for collecting and processing
correspondence for mailing with the United States Postal Service, to wit, that
16 correspondence will be deposited with the United States Postal Service this same day in
the ordinary course of business. Following ordinary business practices, I sealed said
17 envelope and placed it for collection and mailing on April 24, 2024.
18 [ ] (BY OVERNIGHT MAIL) I enclosed the documents in an envelope or package provided
by an overnight delivery carrier and addressed to the person(s) at the address(es) listed
19 above. 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.
20
[XX] (BY EMAIL OR ELECTRONIC TRANSMISSION) I caused the documents to be sent
21 to the person(s) at the electronic service address(es) listed above.
22 I declare under penalty of perjury under the laws of the State of California that the
23 foregoing is true and correct and that this Declaration was executed on April 24, 2024.
24
25
Julie Heaton
26
27
28
-1-
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Eric J. Bengtson - Bar No. 254167 Davis Bengtson & Young, APLC 1960 The Alameda, Suite 210 San Jose, CA 95126-1493 669-245-4200 TELEPHONE NO.: FAX NO. (Optional): eric@dby-law.com E-MAIL ADDRESS (Optional): ATTORNEY FOR (Name): Cotati-Rohnert Park Unified SD (Doe 1) SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA STREET ADDRESS: 600 Administration Drive, Room 107-J MAILING ADDRESS: CITY AND ZIP CODE: Santa Rosa, CA 95403 BRANCH NAME: PLAINTIFF/PETITIONER: JANE DOE KB DEFENDANT/RESPONDENT: DOE 1, et al. CASE NUMBER: CASE MANAGEMENT STATEMENT (Check one): X UNLIMITED CASE LIMITED CASE SCV-272161 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 9, 2024 Time: 3:00 p.m. Dept.: 19 Div.: Room: Address of court (if different from the address above): X Notice of Intent to Appear by Telephone, by (name): Eric Bengtson or other member of firm INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. X This statement is submitted by party (name): Cotati-Rohnert Park USD (Doe 1) 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, 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 date by which they may be served): 4. Description of case a. Type of case in X complaint cross-complaint (Describe, including causes of action): Childhood sexual abuse; intentional infliction of emotional distress; negligence (Govt Code secs 815.2 and 820); failure to report suspected child abuse; negligent supervision of a minor; negligence Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730 CM-110 [Rev. July 1, 2011] CM-110 PLAINTIFF/PETITIONER: JANE DOE KB CASE NUMBER: DEFENDANT/RESPONDENT: DOE 1, et al. SCV-272161 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.) Plaintiff alleges she was a victim of childhood sexual abuse by a teacher when she was 8-11 years old in 1987-1990. (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 X a jury triaI a nonjury 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. 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 attached list of trials for unavailability of defense counsel. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. X days (specify number): 5-7 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial X by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. 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 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 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. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: JANE DOE KB CASE NUMBER: DEFENDANT/RESPONDENT: DOE 1, et al. SCV-272161 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 all that apply): stipulation): X Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation X 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 Judicial arbitration scheduled for (date): (4) Nonbinding judicial arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled Private arbitration scheduled for (date): (5) Binding private 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): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: JANE DOE KB CASE NUMBER: DEFENDANT/RESPONDENT: DOE 1, et al. SCV-272161 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes No c. x Coverage issues will significantly affect resolution of this case (explain): Defendant is a self-insured member of a joint powers authority. 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 x 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. X The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Def Cotati-Rohnert Park SD Written discovery ongoing Def Cotati-Rohnert Park SD Depo of Plaintiff 8/2024 c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: JANE DOE KB CASE NUMBER: DEFENDANT/RESPONDENT: DOE 1, et al. SCV-272161 17. Economic litigation a. 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. 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. x 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 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 Eric J. Bengtson (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. July 1, 2011] Page 5 of 5 CASE MANAGEMENT STATEMENT DAVIS, BENGTSON & YOUNG, APLC Current Trials / Unavailability 4/29/24 Borja v. Brown, Santa Clara Superior Court; Case No. 17CV318915 05/15/24-05/30/24 MED Medical 05/20/24 – 05/31/24 Lopez v. Gilroy Unified School District; Santa Clara Superior, Case No. 20CV368793 06/10/24 - 06/14/24 HMBY (Andalucia) v. Lissoy; Monterey County Sup. 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Alum Rock USD, Santa Clara Superior Court Case No.: 22CV409107 02/03/25 – 02/14/25 Castro v. Berkeley USD, Alameda County Superior Court, Case No. 23CV039713 02/10/25 – 02/21/25 Russell v. Jefferson ESD, San Mateo Superior Court, Case No. 22-CIV-04663 02/25/25 – 03/07/25 McLaurin v. Los Rios CCD; Sacramento Superior Court, Case No. 34-2022-00315187 03/17/25 – 03/28/25 Jane Doe AN v. Does 1-3; Los Angeles Superior Court; Case No. 22STCV29793 03/24/25 – 04/04/25 Curtis v. Oakland Unified School District, Alameda Superior Court, Case No. 23CV041412 04/14/25 – 04/25/25 Facciano v. Mt. View Whisman SD, Santa Clara Superior Court, Case No. 21cv388696 05/05/25 – 05/09/25 Lopez v. Salinas Union HSD, Monterey Superior Court, Case No. 05/19/25 – 05/30/25 Jane Doe v. Winchester; Sacramento Superior Court, Case No. 34-2022-00316580 06/02/25 - 06/06/25 Vasquez v. Gonzales USD, Monterey Superior Court, Case No. 22CV002124 06/09/25 – 06/13/25 Sosa v. Lodi USD, San Joaquin Superior Court, Case No. 06/23/25 – 06/27/25 Serrato v. Greenfield, USD, et al., Monterey Superior Court, Case No. 22CV003574 07/07/25 – 07/11/25 Doe (Foster) v. Carmel USD, et al., Monterey Superior Court, Case No. 23CV003225 09/08/25 – 09/19/25 Doe (Cruz) v. Carmel USD, et al., Monterey Superior Court, Case No. 23CV003505 .92289 1 PROOF OF SERVICE 2 I, the undersigned, say: 3 I am a citizen of the United States. My business address is 1960 The Alameda, Suite 210, San Jose, CA 95126. I am employed with Davis Bengtson & Young, APLC in 4 the County of Santa Clara, where this service occurs. I am over the age of 18 years, and not a party to the within matter. On the date set forth below, I served the attached 5 document(s) described as follows: 6 CASE MANAGEMENT STATEMENT on the following person(s) in this action by providing a true copy thereof, to the following: 7 Attorneys for Plaintiff 8 Andrew I. Chung 9 Cindy K. Suh Slater Slater Schulman 10 8383 Wilshire Blvd., Ste. 255 Beverly Hills, CA 90211 11 310-341-2086 12 achung@sssfirm.com csuh@sssfirm.com 13 Cosima Martus cosima.martus@sssfirm.com Angie Guzman angie.guzman@sssfirm.com 14 15 [ ] (BY MAIL) I am familiar with my firm’s practice for collecting and processing correspondence for mailing with the United States Postal Service, to wit, that 16 correspondence will be deposited with the United States Postal Service this same day in the ordinary course of business. Following ordinary business practices, I sealed said 17 envelope and placed it for collection and mailing on April 24, 2024. 18 [ ] (BY OVERNIGHT MAIL) I enclosed the documents in an envelope or package provided by an overnight delivery carrier and addressed to the person(s) at the address(es) listed 19 above. 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. 20 [XX] (BY EMAIL OR ELECTRONIC TRANSMISSION) I caused the documents to be sent 21 to the person(s) at the electronic service address(es) listed above. 22 I declare under penalty of perjury under the laws of the State of California that the 23 foregoing is true and correct and that this Declaration was executed on April 24, 2024. 24 25 Julie Heaton 26 27 28 -1-