Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY
NAME: William R. Price (SBN 171531) D. Scott Dodd (SBN 170500)
FIRM NAME: LAW OFFICES OF WILLIAM R. PRICE
STREET ADDRESS: 12636 High Bluff Dr., Suite 400
CITY: SAN DIEGO STATE: CA ZIP CODE: 92130
TELEPHONE NO.: (858) 888-0588 FAX NO.:
EMAIL ADDRESS: wprice@williamrprice.com;sdodd@williamrprice.com
ATTORNEY FOR (name): Defendant/Cross-Complainant City of Salinas
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Monterey
STREET ADDRESS: 1200 Aguajito Road
MAILING ADDRESS:
Monterey, CA 93940
CITY AND ZIP CODE:
BRANCH NAME:Monterey Courthouse
PLAINTIFF/PETITIONER: LOUIS MONTANO, et.al.
DEFENDANT/RESPONDENT: CITY OF SALINAS, et.al
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one):
X UNLIMITED CASE LIMITED CASE 21CV003635
(Amount demanded (Amount demanded is $35,000
exceeds $35,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 05/21/2024 Time: 9:00 AM Dept.: 14 Div.: Room:
Address of court (if different from the address above):
X Notice of Intent to Appear by Telephone, by (name): William R. Price and/or D. Scott Dodd
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): City of Salinas
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): City of Salinas
b.
X The cross-complaint, if any, was filed on (date): Cross-Complaint filed 01/03/23
3. Service (to be answered by plaintiffs and cross-complainants only)
a. X 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 the 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):
Auto accident
Page 1 of 5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California rules 3.720–3.730
CM-110 [Rev. January 1, 2024] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: LOUIS MONTANO, et.al CASE NUMBER:
21CV003635
DEFENDANT/RESPONDENT: CITY OF SALINAS, 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.)
Plaintiffs were injured in a motor vehicle accident during a police chase. Defendant City of Salinas is immune from liability
pursuant VC 17004.7, GS 818.2, GC 818.4, and GC 818.6. The City of Salinas seeks its attorneys fees and costs pursuant to
CCP 1038
(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 trial a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. X The trial has been set for (date): January 13, 2025
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. X days (specify number): 5-7 days
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. Email 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 X 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 of 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] CASE MANAGEMENT STATEMENT Page 2 of 5
CM-110
PLAINTIFF/PETITIONER: LOUIS MONTANO, et.al CASE NUMBER:
21CV003635
DEFENDANT/RESPONDENT: CITY OF SALINAS, et.al
10. c. In the table below, indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to
participate in, or have already participated in (check all that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):
Mediation session not yet scheduled
(1) Mediation
X Mediation session scheduled for (date):
Agreed to complete mediation by (date):
X Mediation completed on (date): 03/20/2024
X Settlement conference not yet scheduled
(2) Settlement
X Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
(3) Neutral evaluation Neutral evaluation scheduled for (date):
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
arbitration
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. January 1, 2024] CASE MANAGEMENT STATEMENT Page 3 of 5
CM-110
PLAINTIFF/PETITIONER: LOUIS MONTANO, et.al CASE NUMBER:
21CV003635
DEFENDANT/RESPONDENT: CITY OF SALINAS, et.al
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes X No
c. X Coverage issues will significantly affect resolution of this case (explain):
City of Salinas is permissibly self-insured pursuant to Gov.Code
section 990 for amounts at issue in this matter.
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. X There are companion, underlying, or related cases.
(1) Name of case: 22CV002531, 22CV003206, 22CV003261, 22CV003443, 22CV000359
(2) Name of court:
(3) Case number:
(4) Status:
Additional cases are described in Attachment 13a.
b. A motion 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):
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
City of Salinas Expert discovery Per code
City of Salinas Fact discovery Per code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. January 1, 2024] CASE MANAGEMENT STATEMENT Page 4 of 5
CM-110
PLAINTIFF/PETITIONER: LOUIS MONTANO, et.al CASE NUMBER:
21CV003635
DEFENDANT/RESPONDENT: CITY OF SALINAS, 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. 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): 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:05/06/24
D.SCOTT DODD
(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] CASE MANAGEMENT STATEMENT Page 5 of 5
1 PROOF OF SERVICE
2
3 I am employed in the County of San Diego, State of California. I am over the age of 18 and
not a party to the within action. My business address is 12636 High Bluff Dr., Suite 400, San
4 Diego, CA 92130.
5 On May 6, 2024, I served the within document(s) described as:
6
CITY OF SALINAS’ CASE MANAGEMENT STATEMENT
7
on the interested parties in this action as stated on the attached mailing list.
8
9
(BY E-MAIL) By transmitting a true copy of the foregoing document(s) to the e-mail
10 addresses set forth on the attached mailing list.
X
11
12 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
13
Executed on May 6, 2024, at San Diego, California.
14
15 Olga Barnes
(Type or print name) (Signature)
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CITY OF SALINAS’ CASE MANAGEMENT STATEMENT
1 SERVICE LIST
2 LOUIS MONTANO, JR.; et al. v. CITY OF SALINAS; et al.
Case No. 21CV003635
3
Emily A. Ruby Rodney N. Mayr
4 Sergio R. Cardenas MAYR LAW FIRM
GREENBERG AND RUBY 1010 W. Taylor Street
5 INJURY ATTORNEYS, APC San Jose, CA 95126
400 Continental Blvd, Suite 320 El Tel: (408) 331-7606
6
Segundo, CA 90245 rodney@mayrlawfirm.com
7 Tel: (323) 782-0535
emiliano@mayrlawfirm.com
eruby@caltrialpros.com
scardenas@caltrialpros.com Attorneys Defendants AUSTIN ALARCON and
8 ROSAURA ARCOS PANIAGUA
records@caltrialpros.com
9 sjuarez@caltrialpros.com
sgonzalez@caltrialpros.com
10 Attorneys for Plaintiffs LOUIS
MONTANO, JR.; LOUIE MONTANO III;
11 MICHAEL MONTANO
Cynthia Shambaugh, Esq.
12 Richard C. Alpers Chandrani Mandal, Esq.
13 ALPERS LAW GROUP, INC. LEWIS BRISBOIS BISGAARD & SMITH LLP
PO Box 1540 2185 N. California Blvd., Ste 300
14 Aptos, CA 95001 Walnut Creek, CA 94596-3577
Tel: (855) 808-1174 Tel: (925) 357-3456
15 rca@alperslawgroup.com Cynthia.Shambaugh@lewisbrisbois.com
Attorneys for Plaintiffs LOUIS Joan.Whipple@lewisbrisbois.com
16 MONTANO, JR.; LOUIE MONTANO III; Chandrani.Mandal@lewisbrisbois.com
17 MICHAEL MONTANO Izie.Hudson@lewisbrisbois.com
18 Laurie J. Elza, Esq. Attorneys for Defendants and Cross-Defendants
LAW OFFICES OF JILL A. WOOD NGOCHAO THI NGUYEN and GINO’S
19 One Pointe Drive, 6th Floor RESTAURANT, INC.
20 Brea, CA 92821
Phone: (714) 571-0407 /
21 Fax: (877) 369-5799 Joseph J. Babich
Direct: (714) 371-2311 DREYER BABICH BUCCOLA WOOD
22 E-Mail: laurie.elza@thehartford.com CAMPORA, LLP
maureen.merriles@thehartford.com 20 Bicentennial Circle
23 Sacramento, CA 95826
CaliforniaLawOffice@thehartford.com
Mailing Address: P.O. Box 2282, Brea, Tel: (916) 379-3500
24
CA 92822-2282 jbabich@dbbwc.com; tstevens@dbbwc.com;
25 Attorneys for Defendant and Cross- DBBWC-ESERVICE@dbbwc.com
Complainant NTN PROPERTIES LLC Attorneys for Plaintiff, MAIRA ARELLANO
26 Consolidated Case No. 22CV002531
Maira Arellano vs. Austin Alarcon, et al.
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1 Robert L. Reisinger Neil P. Berman
Bryan Pyles RUCKA, O'BOYLE, LOMBARDO &
2 FORD, WALKER, HAGGERTY & MCKENNA
BEHAR, LLP 245 W. Laurel Dr.
3
One World Trade Center, 27th Floor Salinas, CA 93906
4 Long Beach, CA 90831 Tel: (831) 443-1051
Tel: (562) 983-2579 E: nberman@rolmlaw.com;
5 bpyles@fwhb.com; rlrservice@fwhb.com spena@rolmlaw.com
Attorneys for Defendant/Cross- Attorneys for Plaintiff, DIANE MIDDAUGH
6 Complainant, AUSTIN ALARCON Consolidated Case No. 22CV003206
Consolidated Case No. 22CV002531
7
Maira Arellano vs Austin Alarcon, et al.
8
Shahin “Shawn” Kahroba, Esq.
9 SHERIDAN & RUND, KAHROBA PC Robert D. Ponce, Esq.
270 Coral Circle 400 Camino Aguajto, Ste 100
10 El Segundo, CA 90245 Monterey, CA 93940 Tel: 831-649-0515
Tel: (310) 640-1200 rponce@redshift.com
11 shawn@srlawyers.com Attorney for Plaintiff, KEVIN SMITH
12 Attorneys for Plaintiff, ROBERT ROSETT Consolidated Case No. 22CV003443 Kevin
Consolidated Case No. 22CV003261 Smith vs Gino's Fine Italian Food, Inc., et al.
13 Robert Rosett vs Austin Alarcon, et al.
14 Anthony F. Pinelli, Esq.
Gina Huettel, Esq.
15 WILLIAMS, PINELLI & CULLEN
16 1960 The Alameda, Suite 195
Owili K. Eison, Esq. San Jose, CA 95126
17 BD&J, PC Tel: (408) 288-3868
9701 Wilshire Blvd., 12th Floor Attorneys for Defendant BRYAN C. TENA
18 Beverly Hills, CA 90212 apinelli@wpclaw.com, ghuettel@wpclaw.com,
Tel (310) 385-8080 amagana@wpclaw.com
19
oe@bhattorneys.com;
20 jdf@bhattorneys.com
eservet1@bhattorneys.com
21 Attorneys for Plaintiffs, DANIEL
ORTEGA and YOSELIN GARCIA
22 Consolidated Case No. 22CV003598
Daniel Ortega, et al. vs. Austin Alarcon, et
23
al.
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Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY NAME: William R. Price (SBN 171531) D. Scott Dodd (SBN 170500) FIRM NAME: LAW OFFICES OF WILLIAM R. PRICE STREET ADDRESS: 12636 High Bluff Dr., Suite 400 CITY: SAN DIEGO STATE: CA ZIP CODE: 92130 TELEPHONE NO.: (858) 888-0588 FAX NO.: EMAIL ADDRESS: wprice@williamrprice.com;sdodd@williamrprice.com ATTORNEY FOR (name): Defendant/Cross-Complainant City of Salinas SUPERIOR COURT OF CALIFORNIA, COUNTY OF Monterey STREET ADDRESS: 1200 Aguajito Road MAILING ADDRESS: Monterey, CA 93940 CITY AND ZIP CODE: BRANCH NAME:Monterey Courthouse PLAINTIFF/PETITIONER: LOUIS MONTANO, et.al. DEFENDANT/RESPONDENT: CITY OF SALINAS, et.al CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): X UNLIMITED CASE LIMITED CASE 21CV003635 (Amount demanded (Amount demanded is $35,000 exceeds $35,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 05/21/2024 Time: 9:00 AM Dept.: 14 Div.: Room: Address of court (if different from the address above): X Notice of Intent to Appear by Telephone, by (name): William R. Price and/or D. Scott Dodd 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): City of Salinas 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): City of Salinas b. X The cross-complaint, if any, was filed on (date): Cross-Complaint filed 01/03/23 3. Service (to be answered by plaintiffs and cross-complainants only) a. X 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 the 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): Auto accident Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California rules 3.720–3.730 CM-110 [Rev. January 1, 2024] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: LOUIS MONTANO, et.al CASE NUMBER: 21CV003635 DEFENDANT/RESPONDENT: CITY OF SALINAS, 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.) Plaintiffs were injured in a motor vehicle accident during a police chase. Defendant City of Salinas is immune from liability pursuant VC 17004.7, GS 818.2, GC 818.4, and GC 818.6. The City of Salinas seeks its attorneys fees and costs pursuant to CCP 1038 (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 trial a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. X The trial has been set for (date): January 13, 2025 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. X days (specify number): 5-7 days 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. Email 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 X 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 of 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] CASE MANAGEMENT STATEMENT Page 2 of 5 CM-110 PLAINTIFF/PETITIONER: LOUIS MONTANO, et.al CASE NUMBER: 21CV003635 DEFENDANT/RESPONDENT: CITY OF SALINAS, et.al 10. c. In the table below, indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): Mediation session not yet scheduled (1) Mediation X Mediation session scheduled for (date): Agreed to complete mediation by (date): X Mediation completed on (date): 03/20/2024 X Settlement conference not yet scheduled (2) Settlement X Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled (3) Neutral evaluation Neutral evaluation scheduled for (date): Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. January 1, 2024] CASE MANAGEMENT STATEMENT Page 3 of 5 CM-110 PLAINTIFF/PETITIONER: LOUIS MONTANO, et.al CASE NUMBER: 21CV003635 DEFENDANT/RESPONDENT: CITY OF SALINAS, et.al 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes X No c. X Coverage issues will significantly affect resolution of this case (explain): City of Salinas is permissibly self-insured pursuant to Gov.Code section 990 for amounts at issue in this matter. 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. X There are companion, underlying, or related cases. (1) Name of case: 22CV002531, 22CV003206, 22CV003261, 22CV003443, 22CV000359 (2) Name of court: (3) Case number: (4) Status: Additional cases are described in Attachment 13a. b. A motion 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): 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 City of Salinas Expert discovery Per code City of Salinas Fact discovery Per code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. January 1, 2024] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: LOUIS MONTANO, et.al CASE NUMBER: 21CV003635 DEFENDANT/RESPONDENT: CITY OF SALINAS, 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. 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): 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:05/06/24 D.SCOTT DODD (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] CASE MANAGEMENT STATEMENT Page 5 of 5 1 PROOF OF SERVICE 2 3 I am employed in the County of San Diego, State of California. I am over the age of 18 and not a party to the within action. My business address is 12636 High Bluff Dr., Suite 400, San 4 Diego, CA 92130. 5 On May 6, 2024, I served the within document(s) described as: 6 CITY OF SALINAS’ CASE MANAGEMENT STATEMENT 7 on the interested parties in this action as stated on the attached mailing list. 8 9 (BY E-MAIL) By transmitting a true copy of the foregoing document(s) to the e-mail 10 addresses set forth on the attached mailing list. X 11 12 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 13 Executed on May 6, 2024, at San Diego, California. 14 15 Olga Barnes (Type or print name) (Signature) 16 17 18 19 20 21 22 23 24 25 26 27 28 5 CITY OF SALINAS’ CASE MANAGEMENT STATEMENT 1 SERVICE LIST 2 LOUIS MONTANO, JR.; et al. v. CITY OF SALINAS; et al. Case No. 21CV003635 3 Emily A. Ruby Rodney N. Mayr 4 Sergio R. Cardenas MAYR LAW FIRM GREENBERG AND RUBY 1010 W. Taylor Street 5 INJURY ATTORNEYS, APC San Jose, CA 95126 400 Continental Blvd, Suite 320 El Tel: (408) 331-7606 6 Segundo, CA 90245 rodney@mayrlawfirm.com 7 Tel: (323) 782-0535 emiliano@mayrlawfirm.com eruby@caltrialpros.com scardenas@caltrialpros.com Attorneys Defendants AUSTIN ALARCON and 8 ROSAURA ARCOS PANIAGUA records@caltrialpros.com 9 sjuarez@caltrialpros.com sgonzalez@caltrialpros.com 10 Attorneys for Plaintiffs LOUIS MONTANO, JR.; LOUIE MONTANO III; 11 MICHAEL MONTANO Cynthia Shambaugh, Esq. 12 Richard C. Alpers Chandrani Mandal, Esq. 13 ALPERS LAW GROUP, INC. LEWIS BRISBOIS BISGAARD & SMITH LLP PO Box 1540 2185 N. California Blvd., Ste 300 14 Aptos, CA 95001 Walnut Creek, CA 94596-3577 Tel: (855) 808-1174 Tel: (925) 357-3456 15 rca@alperslawgroup.com Cynthia.Shambaugh@lewisbrisbois.com Attorneys for Plaintiffs LOUIS Joan.Whipple@lewisbrisbois.com 16 MONTANO, JR.; LOUIE MONTANO III; Chandrani.Mandal@lewisbrisbois.com 17 MICHAEL MONTANO Izie.Hudson@lewisbrisbois.com 18 Laurie J. Elza, Esq. Attorneys for Defendants and Cross-Defendants LAW OFFICES OF JILL A. WOOD NGOCHAO THI NGUYEN and GINO’S 19 One Pointe Drive, 6th Floor RESTAURANT, INC. 20 Brea, CA 92821 Phone: (714) 571-0407 / 21 Fax: (877) 369-5799 Joseph J. Babich Direct: (714) 371-2311 DREYER BABICH BUCCOLA WOOD 22 E-Mail: laurie.elza@thehartford.com CAMPORA, LLP maureen.merriles@thehartford.com 20 Bicentennial Circle 23 Sacramento, CA 95826 CaliforniaLawOffice@thehartford.com Mailing Address: P.O. Box 2282, Brea, Tel: (916) 379-3500 24 CA 92822-2282 jbabich@dbbwc.com; tstevens@dbbwc.com; 25 Attorneys for Defendant and Cross- DBBWC-ESERVICE@dbbwc.com Complainant NTN PROPERTIES LLC Attorneys for Plaintiff, MAIRA ARELLANO 26 Consolidated Case No. 22CV002531 Maira Arellano vs. Austin Alarcon, et al. 27 28 1 Robert L. Reisinger Neil P. Berman Bryan Pyles RUCKA, O'BOYLE, LOMBARDO & 2 FORD, WALKER, HAGGERTY & MCKENNA BEHAR, LLP 245 W. Laurel Dr. 3 One World Trade Center, 27th Floor Salinas, CA 93906 4 Long Beach, CA 90831 Tel: (831) 443-1051 Tel: (562) 983-2579 E: nberman@rolmlaw.com; 5 bpyles@fwhb.com; rlrservice@fwhb.com spena@rolmlaw.com Attorneys for Defendant/Cross- Attorneys for Plaintiff, DIANE MIDDAUGH 6 Complainant, AUSTIN ALARCON Consolidated Case No. 22CV003206 Consolidated Case No. 22CV002531 7 Maira Arellano vs Austin Alarcon, et al. 8 Shahin “Shawn” Kahroba, Esq. 9 SHERIDAN & RUND, KAHROBA PC Robert D. Ponce, Esq. 270 Coral Circle 400 Camino Aguajto, Ste 100 10 El Segundo, CA 90245 Monterey, CA 93940 Tel: 831-649-0515 Tel: (310) 640-1200 rponce@redshift.com 11 shawn@srlawyers.com Attorney for Plaintiff, KEVIN SMITH 12 Attorneys for Plaintiff, ROBERT ROSETT Consolidated Case No. 22CV003443 Kevin Consolidated Case No. 22CV003261 Smith vs Gino's Fine Italian Food, Inc., et al. 13 Robert Rosett vs Austin Alarcon, et al. 14 Anthony F. Pinelli, Esq. Gina Huettel, Esq. 15 WILLIAMS, PINELLI & CULLEN 16 1960 The Alameda, Suite 195 Owili K. Eison, Esq. San Jose, CA 95126 17 BD&J, PC Tel: (408) 288-3868 9701 Wilshire Blvd., 12th Floor Attorneys for Defendant BRYAN C. TENA 18 Beverly Hills, CA 90212 apinelli@wpclaw.com, ghuettel@wpclaw.com, Tel (310) 385-8080 amagana@wpclaw.com 19 oe@bhattorneys.com; 20 jdf@bhattorneys.com eservet1@bhattorneys.com 21 Attorneys for Plaintiffs, DANIEL ORTEGA and YOSELIN GARCIA 22 Consolidated Case No. 22CV003598 Daniel Ortega, et al. vs. Austin Alarcon, et 23 al. 24 25 26 27 28