Preview
CM-110
[ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar n FOR COURT
USE ONLY
Earl E. Conaway, Ill SBN 256239
EARL E. CONAWAY, Ill - A PROFESSIONAL LAW CORPORATION
1320 Osos Street ELECTRONICALLY FILED
‘San Luis Obispo, CA 93401 ‘Superior Court of California
TELEPHONE NO: (805) 546-8797 FAX NO. (Optiona): (888) 466-8702 (County of Santa Barbara
E-MAIL ADDRESS (Optiona): earl@conawaylawfirm.com Darrel E. Parker, Executive Officer
ATTORNEY FOR (Nemo): Defendant, Jesus Reyes 8/25/2023 2:05 PM
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA yy: Robert Mendez , Deputy
‘STREET ADDRESS: 312 East Cook Street, Building E
MAILING ADDRESS: 312-C East Cook Street
city AND zp cove: Santa Maria, CA 93454
BRANCH NAME: Santa Maria - Cook Division
PLAINTIFF/PETITIONER: MARTHA E. RAMIREZ
DEFENDANT/RESPONDENT: JESUS REYES, ET AL
CASE MANAGEMENT STATEMENT ‘CASE NUMBER:
22CV03495
(Check one): (] UNLIMITED CASE [1] LimITeD CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
|A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: September 13, 2023 Time: 8:30 AM Dept: SM4 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name):
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. [4c] This statement is submitted by party (name): Defendant, Jesus Reyes
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): September 13, 2022
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) [5] 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 ofcase in [x] complaint [] cross-complaint (Describe, including causes of action):
Discrimination; Harassment; Retaliation; Declaratory Judgment; Battery; Assault; Sexual Battery; Gender Violence; Sexual
Harassment; Violation of the Ralph Civil Rights Act; and Violation of the Tom Bane Civil Rights Act
Page 10f6
Form Adopted for MandatoryUse Cal. Rules of Court,
‘Judicial Council of Califomia CASE MANAGEMENT STATEMENT ‘ules 3.720-3.730
CM-110 [Rev. July 1, 2014] wwnw.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: MARTHA E. RAMIREZ ‘CASE NUMBER:
DEFENDANT/RESPONDENT: JESUS REYES, ET AL
22CV03495
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
eamings to date, and estimated future lost earings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff alleges she was sexually assaulted by Defendant Jesus Reyes. Plaintiff additionally alleges that Defendant Jesus
Reyes retaliated against Plaintiff by evicting her from his ex-spouse's home. Defendant Jesus Reyes denies any and all claims
made against him.
() (if more space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
a. The party or parties request [_] a jury trial (J anonjury trial. (/f 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. [5c] 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):
¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [5] days (specify number): 5-7
b. [] hours (short causes) (specify):
Trial representation (fo be answered for each party)
The party or parties will be represented at trial [2c] by the attorney or party listed in the caption [) by the following:
a. Attomey:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
[) 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 [__] 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 Cade 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) [5<] 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):
Amount in controversy exceeds statutory limit
(CM-110 [Rev. July 1, 2014] Page
2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: MARTHA E. RAMIREZ CASE NUMBER:
DEFENDANT/RESPONDENT: JESUS REYES, ET AL
22CV03495
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):
[Ge] Mediation session not yet scheduled
[) Mediation session scheduled for (date):
(1) Mediation Ca [—) Agreed to complete mediation by (date):
[) Mediation completed on (date):
[Ec] Settlement conference not yet scheduled
(2) Settlement [) Settlement conference scheduled for (date):
conference (J Agreed to complete settlement conference by (date):
[J 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 [1] Agreed to complete judicial arbitration by (date):
[) Judicial arbitration completed on (date):
[1] 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):
[1 ADR completed on (date):
CMA10 (Rev. duly
1, 2017] Page
3 of 6
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: MARTHA E. RAMIREZ CASE NUMBER:
DEFENDANT/RESPONDENT: JESUS REYES, ET AL
22CV03495
11. Insurance
a. [_] Insurance carrier, if any, for party filing this statement (name).
b. Reservation of rights: [—] Yes [No
c. [__] Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
([-) Bankruptcy [__] Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. [3c] There are companion, underlying, or related cases.
(1) Name of case: Rebecca Reyes v. Monica Camacho Ramirez and Martha Ramirez
(2) Name of court: Santa Barbara Superior Court - Cook Division
(3) Case number: 22CV01298
(4) Status: Settled by Stipulation for Entry of Judgment
(Go) 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):
Motion for Stay of Discovery
16. Discovery
a. [_] The party or parties have completed all discovery.
b. [3C] The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendant, Jesus Reyes Written Discovery Per Code
Defendant, Jesus Reyes Party Depositions Per Code
Defendant, Jesus Reyes Expert Discovery & Third Party Depositions Per Code
c. [] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Defendant Jesus Reyes is currently being prosecuted in a related matter 21CR04181. Defendant Jesus Reyes will assert his
Fifth Amendment rights pending resolution of this related matter.
CM-170 [Rev. July 1, 2011) Page 4016
CASE MANAGEMENT STATEMENT
M110
PLAINTIFF/PETITIONER: MARTHA E. RAMIREZ CASE NUMBER:
22CV03495
DEFENDANT/RESPONDENT: JESUS REYES, ET AL
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. [] 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, expiain):
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
1am 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: August 25, 2023
Earl E. Conaway, Ill
(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 4, 2011] Page Sof
CASE MANAGEMENT STATEMENT
RAMIREZ V. REYES — SB CO. 22CV03495
Case Management Statement
Attachment 13a
Related cases, consolidation, and coordination
There are companion, underlying, or related cases:
Case Name: People vs. Jesus Reyes
Court Name: Santa Barbara Superior Court — Cook Division
Case Number: 21CR04181
Status: Readiness & Settlement Conference calendared for September 19, 2023
Case Management Statement — Attachment 13a
PROOF OF SERVICE
I, the undersigned, declare:
I am employed in the County of San Luis Obispo, State of California. I am over the age
of 18 years and not a party to this within action. My business address is: 1320 Osos Street, San
Luis Obispo, California, 93401. On the date set forth below, I served on all interested parties in
this action the foregoing documents described as: DEFENDANT, JESUS REYES’ CASE
MANAGEMENT STATEMENT by placing a true copy thereof enclosed in a sealed envelope
addressed as follows:
Ramin R. Younessi, Esq.
10 Setareh Panah, Esq. SPanah@younessilaw.com
Law Offices of Ramin R. Younessi
1 3435 Wilshire Blvd., Ste. 2200 T: (213) 480-6200
12 Los Angeles, CA 90010 F: (213) 480-6201
Attorneys for Plaintiff, Martha E. Ramirez
13
Vincent T. Martinez, Esq. VMartinez@twitchellandrice.com
14 Twitchell and Rice, LLP
215 No. Lincoln Street T: (805) 925-2611
15
P.O. Box 520 F: (805) 925-1635
16 Santa Maria, CA 93456
Attorneys for Defendant, Rebecca Reyes
17
v (BY MAIL) _Tenclosed the documents in a sealed envelope or package addressed to the
18
party at the address indicated above and placed it for collection and mailing, following
19 our ordinary business practices. I am readily familiar with this business’s practice for
collecting and processing correspondence for mailing. On the same day that
20
correspondence is placed for collection and mailing, it is deposited in the ordinary course
21 of business with the United States Postal Service, in a sealed envelope with postage fully
22 prepaid.
23
(STATE) I declare under penalty of perjury under the laws of the State of California
24 that the above is true and correct.
25
Executed on August 25, 2023, at San Luis Obispo, California.
26
27 Deborah W. Santana
28
DEFENDANT, JESUS REYES’ ANSWER TO PLAINTIFF, MARTHA RAMIREZ’S COMPLAINT FOR
DAMAGES AND DEMAND FOR JURY TRIAL -
Eari E. Conaway, Ill- APLC
ula Ps
1326 Osos Street 7 2
nt =
San Luis Obispo, CA 93401
a)
Zs
aoe xe
Setareh Panah, Esq.
Bil.
Law Offices of Ramin Younessi
3435 Wilshire Blvd., Ste. 2200
Los Angeles, CA 90010
neeeece
Earl E. Conaway, IIl- APLC
(By:
1320 Osos Street
3, CA $3403 b ll ie
a
aa
ae
Vincent Martinez, Esq.
Twitcneli and Rice, LLP
215 No. Lincoln Street
P.O. Box 520
Santa Maria, CA 93456
Preview
CM-110 [ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar n FOR COURT USE ONLY Earl E. Conaway, Ill SBN 256239 EARL E. CONAWAY, Ill - A PROFESSIONAL LAW CORPORATION 1320 Osos Street ELECTRONICALLY FILED ‘San Luis Obispo, CA 93401 ‘Superior Court of California TELEPHONE NO: (805) 546-8797 FAX NO. (Optiona): (888) 466-8702 (County of Santa Barbara E-MAIL ADDRESS (Optiona): earl@conawaylawfirm.com Darrel E. Parker, Executive Officer ATTORNEY FOR (Nemo): Defendant, Jesus Reyes 8/25/2023 2:05 PM SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA yy: Robert Mendez , Deputy ‘STREET ADDRESS: 312 East Cook Street, Building E MAILING ADDRESS: 312-C East Cook Street city AND zp cove: Santa Maria, CA 93454 BRANCH NAME: Santa Maria - Cook Division PLAINTIFF/PETITIONER: MARTHA E. RAMIREZ DEFENDANT/RESPONDENT: JESUS REYES, ET AL CASE MANAGEMENT STATEMENT ‘CASE NUMBER: 22CV03495 (Check one): (] UNLIMITED CASE [1] LimITeD CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) |A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: September 13, 2023 Time: 8:30 AM Dept: SM4 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. [4c] This statement is submitted by party (name): Defendant, Jesus Reyes 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): September 13, 2022 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) [5] 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 ofcase in [x] complaint [] cross-complaint (Describe, including causes of action): Discrimination; Harassment; Retaliation; Declaratory Judgment; Battery; Assault; Sexual Battery; Gender Violence; Sexual Harassment; Violation of the Ralph Civil Rights Act; and Violation of the Tom Bane Civil Rights Act Page 10f6 Form Adopted for MandatoryUse Cal. Rules of Court, ‘Judicial Council of Califomia CASE MANAGEMENT STATEMENT ‘ules 3.720-3.730 CM-110 [Rev. July 1, 2014] wwnw.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: MARTHA E. RAMIREZ ‘CASE NUMBER: DEFENDANT/RESPONDENT: JESUS REYES, ET AL 22CV03495 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 eamings to date, and estimated future lost earings. If equitable relief is sought, describe the nature of the relief.) Plaintiff alleges she was sexually assaulted by Defendant Jesus Reyes. Plaintiff additionally alleges that Defendant Jesus Reyes retaliated against Plaintiff by evicting her from his ex-spouse's home. Defendant Jesus Reyes denies any and all claims made against him. () (if more space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial a. The party or parties request [_] a jury trial (J anonjury trial. (/f 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. [5c] 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): ¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Estimated length of trial The party or parties estimate that the trial will take (check one): a. [5] days (specify number): 5-7 b. [] hours (short causes) (specify): Trial representation (fo be answered for each party) The party or parties will be represented at trial [2c] by the attorney or party listed in the caption [) by the following: a. Attomey: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: [) 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 [__] 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 Cade 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) [5<] 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): Amount in controversy exceeds statutory limit (CM-110 [Rev. July 1, 2014] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: MARTHA E. RAMIREZ CASE NUMBER: DEFENDANT/RESPONDENT: JESUS REYES, ET AL 22CV03495 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): [Ge] Mediation session not yet scheduled [) Mediation session scheduled for (date): (1) Mediation Ca [—) Agreed to complete mediation by (date): [) Mediation completed on (date): [Ec] Settlement conference not yet scheduled (2) Settlement [) Settlement conference scheduled for (date): conference (J Agreed to complete settlement conference by (date): [J 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 [1] Agreed to complete judicial arbitration by (date): [) Judicial arbitration completed on (date): [1] 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): [1 ADR completed on (date): CMA10 (Rev. duly 1, 2017] Page 3 of 6 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: MARTHA E. RAMIREZ CASE NUMBER: DEFENDANT/RESPONDENT: JESUS REYES, ET AL 22CV03495 11. Insurance a. [_] Insurance carrier, if any, for party filing this statement (name). b. Reservation of rights: [—] Yes [No c. [__] Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. ([-) Bankruptcy [__] Other (specify): Status: 13. Related cases, consolidation, and coordination a. [3c] There are companion, underlying, or related cases. (1) Name of case: Rebecca Reyes v. Monica Camacho Ramirez and Martha Ramirez (2) Name of court: Santa Barbara Superior Court - Cook Division (3) Case number: 22CV01298 (4) Status: Settled by Stipulation for Entry of Judgment (Go) 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): Motion for Stay of Discovery 16. Discovery a. [_] The party or parties have completed all discovery. b. [3C] The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant, Jesus Reyes Written Discovery Per Code Defendant, Jesus Reyes Party Depositions Per Code Defendant, Jesus Reyes Expert Discovery & Third Party Depositions Per Code c. [] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): Defendant Jesus Reyes is currently being prosecuted in a related matter 21CR04181. Defendant Jesus Reyes will assert his Fifth Amendment rights pending resolution of this related matter. CM-170 [Rev. July 1, 2011) Page 4016 CASE MANAGEMENT STATEMENT M110 PLAINTIFF/PETITIONER: MARTHA E. RAMIREZ CASE NUMBER: 22CV03495 DEFENDANT/RESPONDENT: JESUS REYES, ET AL 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. [] 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, expiain): 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 1am 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: August 25, 2023 Earl E. Conaway, Ill (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 4, 2011] Page Sof CASE MANAGEMENT STATEMENT RAMIREZ V. REYES — SB CO. 22CV03495 Case Management Statement Attachment 13a Related cases, consolidation, and coordination There are companion, underlying, or related cases: Case Name: People vs. Jesus Reyes Court Name: Santa Barbara Superior Court — Cook Division Case Number: 21CR04181 Status: Readiness & Settlement Conference calendared for September 19, 2023 Case Management Statement — Attachment 13a PROOF OF SERVICE I, the undersigned, declare: I am employed in the County of San Luis Obispo, State of California. I am over the age of 18 years and not a party to this within action. My business address is: 1320 Osos Street, San Luis Obispo, California, 93401. On the date set forth below, I served on all interested parties in this action the foregoing documents described as: DEFENDANT, JESUS REYES’ CASE MANAGEMENT STATEMENT by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Ramin R. Younessi, Esq. 10 Setareh Panah, Esq. SPanah@younessilaw.com Law Offices of Ramin R. Younessi 1 3435 Wilshire Blvd., Ste. 2200 T: (213) 480-6200 12 Los Angeles, CA 90010 F: (213) 480-6201 Attorneys for Plaintiff, Martha E. Ramirez 13 Vincent T. Martinez, Esq. VMartinez@twitchellandrice.com 14 Twitchell and Rice, LLP 215 No. Lincoln Street T: (805) 925-2611 15 P.O. Box 520 F: (805) 925-1635 16 Santa Maria, CA 93456 Attorneys for Defendant, Rebecca Reyes 17 v (BY MAIL) _Tenclosed the documents in a sealed envelope or package addressed to the 18 party at the address indicated above and placed it for collection and mailing, following 19 our ordinary business practices. I am readily familiar with this business’s practice for collecting and processing correspondence for mailing. On the same day that 20 correspondence is placed for collection and mailing, it is deposited in the ordinary course 21 of business with the United States Postal Service, in a sealed envelope with postage fully 22 prepaid. 23 (STATE) I declare under penalty of perjury under the laws of the State of California 24 that the above is true and correct. 25 Executed on August 25, 2023, at San Luis Obispo, California. 26 27 Deborah W. Santana 28 DEFENDANT, JESUS REYES’ ANSWER TO PLAINTIFF, MARTHA RAMIREZ’S COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL - Eari E. Conaway, Ill- APLC ula Ps 1326 Osos Street 7 2 nt = San Luis Obispo, CA 93401 a) Zs aoe xe Setareh Panah, Esq. Bil. Law Offices of Ramin Younessi 3435 Wilshire Blvd., Ste. 2200 Los Angeles, CA 90010 neeeece Earl E. Conaway, IIl- APLC (By: 1320 Osos Street 3, CA $3403 b ll ie a aa ae Vincent Martinez, Esq. Twitcneli and Rice, LLP 215 No. Lincoln Street P.O. Box 520 Santa Maria, CA 93456