Preview
CM-110
"ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY
Michelle D. Jew, SBN 208853
Johnson, Alvarez, Zakarian, Mail: 330 North Brand Blvd., Suite 900
Glendale, CA 91203-2340 (San Francisco Office)
TELEPHONE NO. 415-281-7107 FAX NO. (Optional): 1-877-268-9751
E-MAIL ADDRESS (Optional): Michelle.Jew@allstate.com
ATTORNEY FOR (Name): AVA TSUTSUI WOODS.
‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sonoma
STREET ADpREss: 3055 Cleveland Avenue
MAILING ADDRESS:
city AND zip cove: Santa Rosa, CA 95403
BRANCH NAME: Sonoma County Superior Court
PLAINTIFF/PETITIONER: LAURA DAHL-SAVAGE
DEFENDANT/RESPONDENT: AVA TSUTSUI WOOD
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one). UNLIMITED CASE [2 umrrep case SCV-272808
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows
Date: May 28, 2024 Time: 3:00 PM Dept. 18 Div. Room:
Address of court (if different from the address above).
[Z] Notice of Intent to Appear by Telephone, by (name): Michelle D. Jew
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): AVA TSUTSUI WOODS
b. [1 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)
C5 al 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) [1 have not been served (specify names and explain why not)
(2) [1 have been served but have not appeared and have not been dismissed (specify names).
(3) [2] have had a default entered against them (specify names).
©. Co The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served).
Description of case
a Type of case in complaint [1 cross. complaint (Describe, including causes of action).
Personal Injury involving 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. July 1, 2011] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: LAURA DAHL-SAVAGE CASE NUMBER:
SCV-272808
DEFENDANT/RESPONDENT: AVA TSUTSUI WOOD
4. b. Provide a brief statement of the case, including any damages. (/f 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
to date, and estimated future lost earnit in
earnings
is fawsuit arises out of an accident on 3/ Bie oB
litable relief is sought, describe the nature of the relief.
laintiff claims injuries and damages as a result of { the
accident. Defendant disputes the nature and extent of Plaintiff's claimed injuries and damages.
[) (/fmore space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request a jury trial C5) a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a. [1] 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):
& BAS, SYP '9) PaFHRS OF PP BIS SHE BRS GYRE. Bad SERSEY FBI9S FOR PAG, FARO ROSAE/S038)
4 124,
2/21, 2/24/2025, 3/3/2025, 9/20, 9/23, 9/24, 6/30/2:
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 5-7 days
b. [1 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 [1 by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: 9 Party represented:
[1 Additional representation is described in Attachment 8.
Preference
[1] 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 [1] 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 [7] has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
a) CoO This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
2) CE] 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) CO 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):
Ci-110 (Rev. July 1, 2017) CASE MANAGEMENT STATEMENT Page 20f5
CM-110
PLAINTIFF/PETITIONER: LAURA DAHL-SAVAGE [CASE NUMBER:
SCV-272808
DEFENDANT/RESPONDENT: AVA TSUTSUI WOOD
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):
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
(CM-110 [Rev. July 1, 2011] Page 30f5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: LAURA DAHL-SAVAGE ‘CASE NUMBER:
SCV-272808
DEFENDANT/RESPONDENT: AVA TSUTSUI WOOD
11. Insurance
[4] Insurance carrier, if any, for party filing this statement (name):
Reservation of rights: Co Yes No
[C1 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.
[5 Bankruptcy L_] 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:
[1] Additional cases are described in Attachment 13a.
b. [] A motion to EE) consolidate [1 coordinate will be filed by (name party):
14. Bifurcation
[7] 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.
The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Descriptio! Date
Defendant Depositions December 2024
Defendant Written Discovery December 2024
Defendant Independent Medical Records Exam December 2024
Defendant Subpoena of Medical Records December 2024
c. [__] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
(CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5
CM-110
PLAINTIFF/PETITIONER: LAURA DAHL-SAVAGE CASE NUMBER:
L SCV-272808
DEFENDANT/RESPONDENT: AVA TSUTSUI WOOD
17. Economic litigation
a. [] This is a limited civil case (i.¢., 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. [J 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
Co The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
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
(SSeRGant recent answered the complaint. Discovery has just begun. Plaintiff's deposition is set for
September 2024. b efendant will need to subpoena medical records from Plaintiff's medical providers.
Defendant is interested in mediation once discovery is completed.
20. Total number of pages attached (if any):
| 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: May 6, 2024
Michelle D. Jew >
(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] CASE MANAGEMENT STATEMENT Page 5 of 5
PROOF OF SERVICE BY ELECTRONIC TRANSMISSION
[CCP 1010.6(a)(2)(A)(i), 1010.6(a)(2)(A)(ii), CRC 2.251(c)(3), 2.251(b)]
STATE OF CALIFORNIA, COUNTY OF SONOMA
I am employed in the County of Los Angeles, State of California, I am over the age of
eighteen (18) years, and not a party to the within action; my business address is PHYSICAL
MAILING ADDRESS:
330 N. Brand Blvd., Suite 900, Glendale, CA 91203-2340.
That the necessity resulting from Executive Order N-33-20 (also referred to as the
“Stay-at-Home Order") issued on March 19, 2020, by the Governor of the State of
10 California in response to the Covid-19 virus which has presented a national emergency as
11 declared by the President of the United States, has resulted in this office’s use of remote
12 working staff members and the interruption of our normal capabilities to accept, dispatch
13 and process physical mail causing the use of electronic service as this office’s principal
14 means of dispatch.
15 On May 07, 2024, I caused the within CASE MANAGEMENT STATEMENT on the
16 party or parties named on the attached mailing list to be served, by dispatching a true and correct
17 copy thereof via electronic mail (e-mail) addressed as follows: SEE ATTACHED MAILING
18 LIST.
19 No electronic message or other notice that the transmission electronically sent was
20 unsuccessfully dispatched, was received within a reasonable period after the transmission.
21 I declare under penalty of perjury under the laws of the State of California that the
22 foregoing Proofof Service is true and correct, and that this declaration was executed on May 07.
23 2024, at Glendale, California.
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» Sods
Jess Salinas
27 Email: SanFranciscoLegal@allstate.com
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PROOF OF SERVICE BY ELECTRONIC TRANSMISSION
PROOF OF SERVICE E-MAILING LIST
Savage vs. Woods
Case No. SCV-272808
Michael J. Guglielmino, SBN. 104484
LAW OFFICES OF M.J. GUGLIELMINO
PO Box 210107
San Francisco, CA 94121
(415) 221-7174
gug64@comcast.net
Attorneys for Plaintiff
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PROOF OF SERVICE BY ELECTRONIC TRANSMISSION