Preview
CM-110
ATTORNEY OR PARTY WiTi.lOUT ATTORNEY STATE BAR NUMBER 333667 FOR COURT USE ONLY
NAME Adam Feldman Esq
FIRM NAME Adam Feldman Law, APC
ELECTRONICALLY FILED
STREET ADDRESS 5050 Canoga Ave, Ste 400
Superior Court of California
cn'v woodland Hills STATE Ca 2IP CODE 91367 County of Santa Barbara
TELEPHONE NO (B1s)710-3833 FAX NO
Darrel E. Parker, Executive Officer
EMAILADO ~ Ess Infofoadamreldmanlaw corn
5/22/2024 12:58 PM
ATTQRNEY FOR ldeme) Plairittff
By: Erin Josie , Deputy
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Barbara
Street
sTREET ADDREss 312-C East Cook
MAILINGADORESS Same
ciTY AND Zip coDE Santa Mana 33454
BRANGH NAME Cook Division
PLAINTIFF/PETITIONER GabrielaAnacona
DEFENDANT/RESPONDENT Dignity Health
CASE MANAGEMENT STATEMENT
(Check one)7 ~x UNLIMITED CASE
(Amount demanded
~ LIMITED CASE
(Amount demanded is $ 35,000
CASE NUMBER
24CV00455
exceeds $ 35,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows
Date. June 3, 2024 Time 1 300m Dept sM-2 Div. Room
above)'x
Address of court (if different from the address
Notice of Intent to Appear by Telephone, by (name): Adam Feldman
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). Gabriela Anacona
2
b. ~ This statement is submitted jointly by parties (names):
Complaint and cross-complaint (to be answered by plaintiffs and cross-complainanls only)
a The complaint was filed on (dale) otdwgo24
3.
b ~ The cross-complaint, if any, was filed on (date):
Service (lo be answered by plainlrffs and cross-complainanls only)
b. ~~
a ~x All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed
(1)
The following parties named in the complaint or cross-complaint
have not been served (specify names and explarn why nol).
~
(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 whrch
they may be served).
Description of case
4.
a Type of case in ~x complaint
Medical Negligence Elder Abuse.
~ cross-complaint (Descnbe, including causes of action).
Page 1 of 5
Form Adopt d for Mandatory Use Cel Rules of Court.
Judo st Co noi ot Cel forn s
CASE MANAGEMENT STATEMENT r ies3720-3730
CM 110 [Rey January 12024]
CM-110
PLAINTIFF(PETITIONER Gabriela Anacona CASE NI/MBER
24CV00455
DEFENDANT/REspoNDENT Dignity Health
b Provide a brief statement of the case, including any damages (if personal in)ury damages are sought, specify the injury and
damages claimed, inc/uding medical expenses to date (/ndicate source and amount), estimated future medica/ expenses, lost
earn/ngs to date, and est/ma/ed future lost earn/ngs; /f equ/tab/e reffef is sought, describe the nature of the re/ief)
This 1s an elder abuse and medical negligence lawsuit based on 01gn1iy Hea/th's failure Io care plan for a high fall-nsk. Spanish-speaking,
diagnosed dementia pai1ent who was admitted tc their hosp1tai. As a result of Dignity Health's levels of individual and ratified negkgence, Mra
Anancona suffered a preventable and catastrophic fall After this fall ghe required an ORIF for her right h1p, lost nearly 20 pounds, and has spent
the better part of a year confined Io an extended care facility
~x (if more space is needed, check thrs box and attach a page des/gnated as Attachment 45 )
Jury or nonjury trial
The party or parties request ~x a jury trial
requestmg a jury trial):
~
a noniury trial. (If more than one party, provide the name of each party
Mehssa Muradian, Vache Muradian, Selena Lantry, MD, and GlendaleAdventist
Trial date
a
b.
~
~x
The trial has been set for (date).
No tnal 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).
Due to the nature of discovery 1n medical mal practice cases, there will kkely be discovery disputes
c Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unava//ab///ty)
June 3-30, July 1-15, August 4,19-23, September 17,18,and 27, November 25-29, December 16-20, 23-27, and 30-31,
Estimated length of trial
The party or parties estimate that the trial will take (check ona)
a
b.
~x
~ days (spec/fynumber). 5-7 Days
hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at tnal ~44
a, Attorney; Adam Feldman, Esq.
by the attorney or party hated in the caption ~ by the following:
b. Firm. Adam Feidman Law, APC
c Address, 5850 canoga Ave, ste 400 woodland Hills, ca 81367
d Telephone number: (818)710-3833 f. Fax number.
e Email address:
~
Info@adamfeldmanlaw com g Party represented. Mekssa Muradian and Vache Mvrad1an
Additional representation is described in Attachment 8.
Preference
~ This case is entitled to preference (spec/fy code section)
10 Alternative dispute resolution (ADR)
a. ADR information package. please note that different ADR processes are available 1n 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
(2) For self-represented parties Party ~ ~
rule 3.221 to the chent and reviewed ADR options with the client.
in
has has not reviewed the ADR 1nformation package ident/f1ed1n rule 3.221
b
(1) ~
Referral to judicial arbitration or civil action mediation (if available).
This matter is subiect to mandatory ludicial arbitration under Code of Civil Procedure section 1141 11 or to cw1I action
mediation under Code of Civil Procedure section 1775.3 because the amount1n controversy does not exceed the
(2) ~statutory limit.
Platnt/ff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Ciwl Procedure section 1141.11.
(3) ~ae 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/Re Jao ary1 2024] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
pLAINTIFF/PETITIONER Gabriela Anacona CASE NUMBER
24C)/00455
DEFENDANT/RESPONDENT Dignity Health
)0. 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 a/I that app/y and provide the specified information).
The party or parties completing ff 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'DR
processes (check a/I that app/y) st/ pulation)
~
~ Mediation session not yet scheduled
Mediation session scheduled for (date).
(t) Mediation
~
~ Agreed to complete mediation by (date)
Mediation completed on (date):
~
~ Settlement conference not yet scheduled
Settlement conference scheduled for(da/e).
(2) Settlement
conference
~
~ Agreed to complete settlement conference by (data).
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 iudicial arbitration by (date):
Judicial arbitration completed on (date).
~
~ Pnvate arbitration not yet scheduled
Pnvate arbitration scheduled for (date):
(5) Binding private
arbitration
~
~ Agreed to complete private arbitration by (date).
Pnvate 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 [Re Ja N 1, 2024/ Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
pLAINTIFF/PETITIONER Gabrieia Anacona
DEFENDANT/RESPONDENT Dlgruty Health
11.insurance
a
b
~ Insurance earner,
Reservat1on of rights: ~ ~
if any, for party filing this statement (name).
Yes No
c. ~ Coverage Issues will significantly affect resolution of this case (explain):
12 Jurisdiction
~ Bankruptcy
Status;
~
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
Other (spectfy).
cases, consolidation, and coordination
~
13 Related
a.
(1)
There are companion, underlying, or related cases.
Name of case
(2) Name of court.
(3) Case number
Status:
~ (4)
Additional cases are descnbed in Attachment 13a.
b~ A motion to ~ consokdate ~ coordinate will be filed by (name party)
14, Bifurcation
~ The party or parties intend to file a motion for an order bifurcating, sevenng, or coordinating the following Issues or causes of
action (specify mowng party, type of motion, and reasons):
15 Other motions
~44 The party or parties expect to file the following motions before trial (specrfy moving party, type ofmofron, and issues):
Motion to compel, motions in limine.
16. Discovery
a.
b
~
~ee
The party or parties have completed all discovery
The following discovery wilt be completed by the date specified (descritee sil anticipated discovery)
Party Descn ation Date
Plaintiff Written Discovery 120 Days
Plaintiff Depositions September 2024
Pla1nt1fi Expert discovery Per code
c. ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specrfy):
peg 4 of 0
CM 110 Ine 0 ty1 2024] CASE MANAGEMENT STATEMENT
CM-110
pl AINTIFF/PETITIONER Gabnela Anacona
DEFENDANT/REspoNDENT Dignity Health
17. Economic litigation
a. ~ This is a limited ovil 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, exp/ain specifically why economic /itigaf/on procedures relating to discovery or trial
should not app/y to this case):
Otherissuea
19
~ 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. ~N 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)'.
~ After meeting and confernng
(speofy).
as required by rule 3 724 of the California Rules of Court, the parties agree on the following
20. Total number of pages attached (if any)
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 authonty to enter into stipulations on these issues at the time of
the case management conference, including the written authonty of the party where required
Date: 05/22/2024
Adam Feldman, Esq
(TYPE OR PRINT NAME) (SIGN4f URWOF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGN/ITURE OF PARTY OR ATTORNEY)
~ Additional signatures are attached.
OM 110 (Re 2 G I, 2024] CASE MANAGEMENT STATEMENT Pose 0 er 0
orivacy, please press theo)ear This Form button afteryi I print this form I I Save this form I I Clear this form I
PROOF OF SERVICE
2
I am employed in the County of Los Angeles, State of California. I am over the age of 18
3 years and not a party to the within action; my business address is 5850 Canoga Ave., Suite 400,
Woodland Hills, CA 91367.
4
On May 22, 2024, I served the foregoing document described as: PLAINTIFF'S CASE
5 MANAGEMENT STATEMFNT on the parties to this action by placing a true copy thereof in a
transmission or sealed envelope or package addressed to the person(s) at the address(es) as sct forth
6 below and caused said envelope, package, or transmission, to be served in the following manner:
7
BY MAIL. I caused such envelope or package with postage thereon fully prepaid to be placed
8 in the United States mail at Woodland Hills, California.
BY FAX. I caused such documents to be faxed at Woodland Hills, California f!.om fax
number 8187103802.
10
BY PERSONAL SERVICE. I caused such envelope or package to be dclivercd by hand to
the addressee(s).
17 BY OVERNIGHT MAIL. I caused such documents to be placed in a sealed envelope and
delivered to an overnight courier company for overnight service to the office(s) of the
13 addressee(s).
14 X BY ELFCTRONIC MAIL. By e-mailing the above referenced document(s) to the
person(s) at the e-mail address(es) of the addressee(s).
15 ADDRESSEE(S):
Ilngl) S, Spackman. State Bm No. 150204.1
I.ynn Stokes-Pena. State 13ar No. 223300
CI INKIIN13EIARD RAMSI(Y SPACKMAN ra
17 CEARK. EI,P P.O. Bos 21007 Santa 13arsaran
CA 93121 Pho)m: (8051 965-0043 I)a)n (I!05)
965 SS94 Anorncys I'or Dc!'cndant DKiNITY
III) AI, d!)a MA ICI AN R EOIONA I.
I I I
MI3DI CA I. C I:.5'I'I! It
19
I declare under the penalty of perjury under the laws of the State of California that the
20 foregoing is true and correct.
Executed on May 22, 2024, at Woodland Hills, California.
22
By:
Adam Feldmad
74
7(
76
PLAINTIFF'S CASE MANAGEMENT STATEMENT
Preview
CM-110 ATTORNEY OR PARTY WiTi.lOUT ATTORNEY STATE BAR NUMBER 333667 FOR COURT USE ONLY NAME Adam Feldman Esq FIRM NAME Adam Feldman Law, APC ELECTRONICALLY FILED STREET ADDRESS 5050 Canoga Ave, Ste 400 Superior Court of California cn'v woodland Hills STATE Ca 2IP CODE 91367 County of Santa Barbara TELEPHONE NO (B1s)710-3833 FAX NO Darrel E. Parker, Executive Officer EMAILADO ~ Ess Infofoadamreldmanlaw corn 5/22/2024 12:58 PM ATTQRNEY FOR ldeme) Plairittff By: Erin Josie , Deputy SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Barbara Street sTREET ADDREss 312-C East Cook MAILINGADORESS Same ciTY AND Zip coDE Santa Mana 33454 BRANGH NAME Cook Division PLAINTIFF/PETITIONER GabrielaAnacona DEFENDANT/RESPONDENT Dignity Health CASE MANAGEMENT STATEMENT (Check one)7 ~x UNLIMITED CASE (Amount demanded ~ LIMITED CASE (Amount demanded is $ 35,000 CASE NUMBER 24CV00455 exceeds $ 35,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows Date. June 3, 2024 Time 1 300m Dept sM-2 Div. Room above)'x Address of court (if different from the address Notice of Intent to Appear by Telephone, by (name): Adam Feldman 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). Gabriela Anacona 2 b. ~ This statement is submitted jointly by parties (names): Complaint and cross-complaint (to be answered by plaintiffs and cross-complainanls only) a The complaint was filed on (dale) otdwgo24 3. b ~ The cross-complaint, if any, was filed on (date): Service (lo be answered by plainlrffs and cross-complainanls only) b. ~~ a ~x All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed (1) The following parties named in the complaint or cross-complaint have not been served (specify names and explarn why nol). ~ (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 whrch they may be served). Description of case 4. a Type of case in ~x complaint Medical Negligence Elder Abuse. ~ cross-complaint (Descnbe, including causes of action). Page 1 of 5 Form Adopt d for Mandatory Use Cel Rules of Court. Judo st Co noi ot Cel forn s CASE MANAGEMENT STATEMENT r ies3720-3730 CM 110 [Rey January 12024] CM-110 PLAINTIFF(PETITIONER Gabriela Anacona CASE NI/MBER 24CV00455 DEFENDANT/REspoNDENT Dignity Health b Provide a brief statement of the case, including any damages (if personal in)ury damages are sought, specify the injury and damages claimed, inc/uding medical expenses to date (/ndicate source and amount), estimated future medica/ expenses, lost earn/ngs to date, and est/ma/ed future lost earn/ngs; /f equ/tab/e reffef is sought, describe the nature of the re/ief) This 1s an elder abuse and medical negligence lawsuit based on 01gn1iy Hea/th's failure Io care plan for a high fall-nsk. Spanish-speaking, diagnosed dementia pai1ent who was admitted tc their hosp1tai. As a result of Dignity Health's levels of individual and ratified negkgence, Mra Anancona suffered a preventable and catastrophic fall After this fall ghe required an ORIF for her right h1p, lost nearly 20 pounds, and has spent the better part of a year confined Io an extended care facility ~x (if more space is needed, check thrs box and attach a page des/gnated as Attachment 45 ) Jury or nonjury trial The party or parties request ~x a jury trial requestmg a jury trial): ~ a noniury trial. (If more than one party, provide the name of each party Mehssa Muradian, Vache Muradian, Selena Lantry, MD, and GlendaleAdventist Trial date a b. ~ ~x The trial has been set for (date). No tnal 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). Due to the nature of discovery 1n medical mal practice cases, there will kkely be discovery disputes c Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unava//ab///ty) June 3-30, July 1-15, August 4,19-23, September 17,18,and 27, November 25-29, December 16-20, 23-27, and 30-31, Estimated length of trial The party or parties estimate that the trial will take (check ona) a b. ~x ~ days (spec/fynumber). 5-7 Days hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at tnal ~44 a, Attorney; Adam Feldman, Esq. by the attorney or party hated in the caption ~ by the following: b. Firm. Adam Feidman Law, APC c Address, 5850 canoga Ave, ste 400 woodland Hills, ca 81367 d Telephone number: (818)710-3833 f. Fax number. e Email address: ~ Info@adamfeldmanlaw com g Party represented. Mekssa Muradian and Vache Mvrad1an Additional representation is described in Attachment 8. Preference ~ This case is entitled to preference (spec/fy code section) 10 Alternative dispute resolution (ADR) a. ADR information package. please note that different ADR processes are available 1n 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 (2) For self-represented parties Party ~ ~ rule 3.221 to the chent and reviewed ADR options with the client. in has has not reviewed the ADR 1nformation package ident/f1ed1n rule 3.221 b (1) ~ Referral to judicial arbitration or civil action mediation (if available). This matter is subiect to mandatory ludicial arbitration under Code of Civil Procedure section 1141 11 or to cw1I action mediation under Code of Civil Procedure section 1775.3 because the amount1n controversy does not exceed the (2) ~statutory limit. Platnt/ff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Ciwl Procedure section 1141.11. (3) ~ae 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/Re Jao ary1 2024] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 pLAINTIFF/PETITIONER Gabriela Anacona CASE NUMBER 24C)/00455 DEFENDANT/RESPONDENT Dignity Health )0. 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 a/I that app/y and provide the specified information). The party or parties completing ff 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'DR processes (check a/I that app/y) st/ pulation) ~ ~ Mediation session not yet scheduled Mediation session scheduled for (date). (t) Mediation ~ ~ Agreed to complete mediation by (date) Mediation completed on (date): ~ ~ Settlement conference not yet scheduled Settlement conference scheduled for(da/e). (2) Settlement conference ~ ~ Agreed to complete settlement conference by (data). 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 iudicial arbitration by (date): Judicial arbitration completed on (date). ~ ~ Pnvate arbitration not yet scheduled Pnvate arbitration scheduled for (date): (5) Binding private arbitration ~ ~ Agreed to complete private arbitration by (date). Pnvate 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 [Re Ja N 1, 2024/ Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 pLAINTIFF/PETITIONER Gabrieia Anacona DEFENDANT/RESPONDENT Dlgruty Health 11.insurance a b ~ Insurance earner, Reservat1on of rights: ~ ~ if any, for party filing this statement (name). Yes No c. ~ Coverage Issues will significantly affect resolution of this case (explain): 12 Jurisdiction ~ Bankruptcy Status; ~ Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Other (spectfy). cases, consolidation, and coordination ~ 13 Related a. (1) There are companion, underlying, or related cases. Name of case (2) Name of court. (3) Case number Status: ~ (4) Additional cases are descnbed in Attachment 13a. b~ A motion to ~ consokdate ~ coordinate will be filed by (name party) 14, Bifurcation ~ The party or parties intend to file a motion for an order bifurcating, sevenng, or coordinating the following Issues or causes of action (specify mowng party, type of motion, and reasons): 15 Other motions ~44 The party or parties expect to file the following motions before trial (specrfy moving party, type ofmofron, and issues): Motion to compel, motions in limine. 16. Discovery a. b ~ ~ee The party or parties have completed all discovery The following discovery wilt be completed by the date specified (descritee sil anticipated discovery) Party Descn ation Date Plaintiff Written Discovery 120 Days Plaintiff Depositions September 2024 Pla1nt1fi Expert discovery Per code c. ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specrfy): peg 4 of 0 CM 110 Ine 0 ty1 2024] CASE MANAGEMENT STATEMENT CM-110 pl AINTIFF/PETITIONER Gabnela Anacona DEFENDANT/REspoNDENT Dignity Health 17. Economic litigation a. ~ This is a limited ovil 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, exp/ain specifically why economic /itigaf/on procedures relating to discovery or trial should not app/y to this case): Otherissuea 19 ~ 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. ~N 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)'. ~ After meeting and confernng (speofy). as required by rule 3 724 of the California Rules of Court, the parties agree on the following 20. Total number of pages attached (if any) 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 authonty to enter into stipulations on these issues at the time of the case management conference, including the written authonty of the party where required Date: 05/22/2024 Adam Feldman, Esq (TYPE OR PRINT NAME) (SIGN4f URWOF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGN/ITURE OF PARTY OR ATTORNEY) ~ Additional signatures are attached. OM 110 (Re 2 G I, 2024] CASE MANAGEMENT STATEMENT Pose 0 er 0 orivacy, please press theo)ear This Form button afteryi I print this form I I Save this form I I Clear this form I PROOF OF SERVICE 2 I am employed in the County of Los Angeles, State of California. I am over the age of 18 3 years and not a party to the within action; my business address is 5850 Canoga Ave., Suite 400, Woodland Hills, CA 91367. 4 On May 22, 2024, I served the foregoing document described as: PLAINTIFF'S CASE 5 MANAGEMENT STATEMFNT on the parties to this action by placing a true copy thereof in a transmission or sealed envelope or package addressed to the person(s) at the address(es) as sct forth 6 below and caused said envelope, package, or transmission, to be served in the following manner: 7 BY MAIL. I caused such envelope or package with postage thereon fully prepaid to be placed 8 in the United States mail at Woodland Hills, California. BY FAX. I caused such documents to be faxed at Woodland Hills, California f!.om fax number 8187103802. 10 BY PERSONAL SERVICE. I caused such envelope or package to be dclivercd by hand to the addressee(s). 17 BY OVERNIGHT MAIL. I caused such documents to be placed in a sealed envelope and delivered to an overnight courier company for overnight service to the office(s) of the 13 addressee(s). 14 X BY ELFCTRONIC MAIL. By e-mailing the above referenced document(s) to the person(s) at the e-mail address(es) of the addressee(s). 15 ADDRESSEE(S): Ilngl) S, Spackman. State Bm No. 150204.1 I.ynn Stokes-Pena. State 13ar No. 223300 CI INKIIN13EIARD RAMSI(Y SPACKMAN ra 17 CEARK. EI,P P.O. Bos 21007 Santa 13arsaran CA 93121 Pho)m: (8051 965-0043 I)a)n (I!05) 965 SS94 Anorncys I'or Dc!'cndant DKiNITY III) AI, d!)a MA ICI AN R EOIONA I. I I I MI3DI CA I. C I:.5'I'I! It 19 I declare under the penalty of perjury under the laws of the State of California that the 20 foregoing is true and correct. Executed on May 22, 2024, at Woodland Hills, California. 22 By: Adam Feldmad 74 7( 76 PLAINTIFF'S CASE MANAGEMENT STATEMENT