Preview
CM-110
[ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and adoress) FOR COURT USE ONLY
Michael A. Marino SBN 113499
WOLFE & WYMAN LLP
2301 Dupont Dr., Suite 300
Irvine, CA 92612
TELEPHONE NO: (949) 475-9200 FAX NO.(Optionaly: (949) 475-9203
E-MAIL ADDRESS (Optional): mamarino@wolfewyman.com
ATTORNEY FOR (Name): THOMAS WILLIAM CARDONE, ROWE PAUL, etc.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO
STREETADDRESS: 1130 O Street
MAILING ADDRESS: Same
CITY AND ZIP CODE: Fresno, CA 93721-2220
BRANCHNAME: B.F. Sisk Courthouse
PLAINTIFF/PETITIONER: DANIEL FLAGG, PAUL HENRY ROBLES, SR.
DEFENDANT/RESPONDENT: ROWE PAUL, individually and dba
RS MILK TRANSPORT, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): [X] UNLIMITED CASE (J Limited CASE 18CECG01922
(Amount demanded (Amount demanded is $25,000
L exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 9/24/2018 Time: 1:30 pm Dept.: Div.: Room: 305
Address of court (if different from the address above):
K) Notice of Intent to Appear by Telephone, by (name): Michael A. Marino
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
¥ THOMAS WILLIAM CARDONE; ROWE PAUL, individually and sued herein as
1. Party or parties (answer one): dba RS MILK TRANSPORT; RS MILK TRANSPORT, LLC,
a. [&) This statement is submitted by party (name): sued here as RS MILK TRANSPORT
b. [2] This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. [K) The cross-complaint, if any, was filed on (date): September 7, 2018
3. Service (to be answered by plaintiffs and cross-complainants only)
a. (2) Allparties 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) (2) have not been served (specify names and explain why not):
(2) ipa | have been served but have not appeared and have not been dismissed (specify names):
PAUL HENRY ROBLES, SR. served by mail on 9/5/2018
(3) (CC) have had a default entered against them (specify names):
c. [2] 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 Q complaint GK] cross-complaint (Describe, including causes of action):
Plaintiffs' filed their Complaint on 5/31/18, alleging negligence causes of action
regarding a rear-end motor vehicle accident.
Cross-Complaint for indemnity, contribution and declaratory relief.
Page 1 of §
Form Adopted for Mandatory U s Cal. Rules of Court,
Mudie! Council of California CEB’ Essential CASE MANAGEMENT STATEMENT rules 3.720-3.730
‘CM-110 [Rev. July 1, 2011] m | [2/Forms www.courts.ca.govDEFENDANT/RESPONDENT: ROWE PAUL, individually and dba
CM-110
PLAINTIFF/PETITIONER:DANIEL FLAGG, PAUL HENRY ROBLES, SR. | case NUMBER
18CECG01922
RS MILK TRANSPORT, 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
eamings to date, and estimated future lost earings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff Flagg has $1,791.56 in meidcal specials for treatment of neck complaints.
Plaintiff Robles has $5,488.84 in medical specials of head and neck complaints.
C) (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 (K) ajury trial =(2) a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. (C) The trial has been set for (date):
b. [KX] 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):
No dates before December 12, 2019 (trial)
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [K) days (specify number): 7-10
b. a | hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial [K) by the attorney or party listed in the caption (2) by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
(2) Additional representation is described in Attachment 8.
9. Preference
(J This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel [_} has [&) has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party (]Jhas (_] has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) [CQ 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) (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) (C) 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 fRev. July 1, 2011} CASE MANAGEMENT STATEMENT Page 2 of 5
CEB'| Essential
ceb.com | [2|/Forms"CM-110
PLAINTIFF/PETITIONER:DANIEL FLAGG, PAUL HENRY ROBLES, SR. | CASE NUMBER:
DEFENDANT/RESPONDENT: ROWE PAUL,
RS MILK TRANSPORT, et al.
individually and dba
18CECG01922
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
this form are willing to
participate in the following ADR
processes (check all that apply):
If the party or parties completing this form in the case have agreed to
participate in or have already completed an ADR process or processes,
indicate the status of the processes (attach a copy of the parties' ADR
stipulation):
(1) Mediation
[K) Mediation session not yet scheduled
(2) Mediation session scheduled for (date):
(CC) Agreed to complete mediation by (date):
Q Mediation completed on (date):
(2) Settlement
conference
[K] Settlement conference not yet scheduled
(2) Settlement conference scheduled for (date):
(2) Agreed to complete settlement conference by (date):
() Settlement conference completed on (date):
(3) Neutral evaluation
() Neutral evaluation not yet scheduled
(J Neutral evaluation scheduled for (date):
() Agreed to complete neutral evaluation by (date):
(J Neutral evaluation completed on (date):
(4) Nonbinding judicial |
arbitration
(2) Judicial arbitration not yet scheduled
(C) Judicial arbitration scheduled for (date):
(2) Agreed to complete judicial arbitration by (date):
(C) Judicial arbitration completed on (date):
(5) Binding private
arbitration
(2) Private arbitration not yet scheduled
(C) Private arbitration scheduled for (date):
[(C) Agreed to complete private arbitration by (date):
(CC) Private arbitration completed on (date):
(6) Other (specify):
(UV ADR session not yet scheduled
[CU ADR session scheduled for (date):
[() Agreed to complete ADR session by (date):
(CV ADR completed on (date):
_
CM-110 [Rev. July 1, 2014]
CB
cabscom
Essential
{2\Forms"
CASE MANAGEMENT STATEMENT "Page 30f 5CM-110
ee PLAINTIFF/PETITIONER: DANIEL FLAGG, PAUL HENRY ROBLES, SR. CASE NUMBER: |
18CECG01922
DEFENDANT/RESPONDENT: ROWE PAUL, individually and dba |
RS MILK TRANSPORT, et al.
11. Insurance
a. [X) Insurance carrier, if any, for party filing this statement (name): National Liability & Fire Insurance
b. Reservation of rights: LJ Yes [J No
c. (2) 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.
(QQ Bankruptcy (2) Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. (2) There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
C2) Additional cases are described in Attachment 13a.
b. [)Amotionto [2] consolidate [2] coordinate will be filed by (name party):
14. Bifurcation
(2) 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
CJ] 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. [K] The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendants Cardone and Paul Written discovery December 2018
Defendants Cardone and Paul Depositions January 2019
Defendants Cardone and Paul Defense medical exam March 2019
Defendants Cardone and Paul Expert depositions Per code
c. (C) The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
(OM-110[Rev. July 1, 2014] CASE MANAGEMENT STATEMENT Page 4 of §
‘ER’ | Essential
CEB formsCM-110
PLAINTIFF/PETITIONER: DANIEL FLAGG, PAUL HENRY ROBLES, SR. CASE NUMBER:
18CECG01922
DEFENDANT/RESPONDENT: ROWE PAUL, individually and dba
RS MILK TRANSPORT, et al.
17. Economic litigation
a. (CQ) 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. [2] 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, 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); —____
| 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. A
Date: SeptemberX 0, 2018 YUM”
vichast_A_yavina for Micha A. MANO
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
»
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
C2) Additional signatures are attached.
‘CM-110 [Rev. July 1, 2011) CASE MANAGEMENT STATEMENT — Page § of 5
TB’ | Essential
GB fe onms© woureswyman ice
3151608.1
i i od
NR Re RW RM RN RD Dm its
oy AN AW fF WN BF SGC we YD HW BB BW NY
PROOF OF SERVICE
STATE OF CALIFORNIA
ss.
wee
COUNTY OF ORANGE
I, Kathy Hagmaier, declare:
I am employed in the County of Orange, State of California. I am over the age of 18 and not a party to the within action.
My business address is 2301 Dupont Drive, Suite 300, Irvine, California 92612-7531.
On September 20, 2018, I served the document(s) described as CASE MANAGEMENT STATEMENT on all interested
parties in said action by placing a true copy thereof in a sealed envelope addressed as stated on the ATTACHED SERVICE
LIST.
BY MAIL: as follows:
STATE - I am “readily familiar” with Wolfe & Wyman LLP’s practice of collection and processing
correspondence for mailing. Under that practice it would be deposited with the U.S, Postal Service on that same
day with postage thereon fully prepaid at Irvine, California, in the ordinary course of business. I am aware that
on motion of party served, service is presumed invalid if postal cancellation date or postage meter date is more
than one (1) day after date of deposit for mailing in affidavit.
oO BY ELECTRONIC MAIL SERVICE as follows: I caused the following party(s) to be served the above listed
document(s) by electronic mail service at the following email addresses to the party(ies) noted on the attached
Service List: list email addresses here
Q BY PERSONAL SERVICE as follows: I caused a copy of such document(s) to be delivered by hand to the
offices of the addressee between the hours of 9:00 A.M. and 5:00 P.M.
a BY OVERNIGHT COURIER SERVICE as follows: I caused such envelope to be delivered by overnight
courier service to the offices of the addressee. The envelope was deposited in or with a facility regularly
maintained by the overnight courier service with delivery fees paid or provided for.
Q BY FACSIMILE as follows: I caused such documents to be transmitted to the telephone number of the
addressee listed on the attached service list, by use of facsimile machine telephone number. The facsimile
machine used complied with California Rules of Court, Rule 2004 and no error was reported by the machine.
Pursuant to California Rules of Court, Rule 2006(d), a transmission record of the transmission was printed.
@ STATE I declare under penalty of perjury under the laws of the State of California that the above is true
and correct.
Executed on September 20, 2018, at Irvine, California.
= HagmaierWOLFE & WYMAN LLP
ATTORNEYS & COUNSELORS AT LAW
ha
3151608.1
Co em YN Dn Fe WB NHN
~w Be YP RY KR NR KR KR YD Be Be ee ies
ota A mW ke oN Fe SC RDN DH Fe BW NY SF
SERVICE LIST
Fresno County Superior Court/ Case #18CECG01922
DANIEL FLAGG, et al. vy. ROWE PAUL, et al.
W&W File No. 1725-039
[Revised: 9/5/18]
Frank M. Nunes, Esq. Attorney for Plaintiffs .
LAW OFFICES OF FRANK M. NUNES, INC. DANIEL FLAGG and PAUL HENR
6073 N. Fresno Street, Suite 101 ROBLES, SR.
Fresno, CA 93710
Tele: (559) 436-0850
Fax: (559) 436-0802
Preview
CM-110 [ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and adoress) FOR COURT USE ONLY Michael A. Marino SBN 113499 WOLFE & WYMAN LLP 2301 Dupont Dr., Suite 300 Irvine, CA 92612 TELEPHONE NO: (949) 475-9200 FAX NO.(Optionaly: (949) 475-9203 E-MAIL ADDRESS (Optional): mamarino@wolfewyman.com ATTORNEY FOR (Name): THOMAS WILLIAM CARDONE, ROWE PAUL, etc. SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO STREETADDRESS: 1130 O Street MAILING ADDRESS: Same CITY AND ZIP CODE: Fresno, CA 93721-2220 BRANCHNAME: B.F. Sisk Courthouse PLAINTIFF/PETITIONER: DANIEL FLAGG, PAUL HENRY ROBLES, SR. DEFENDANT/RESPONDENT: ROWE PAUL, individually and dba RS MILK TRANSPORT, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): [X] UNLIMITED CASE (J Limited CASE 18CECG01922 (Amount demanded (Amount demanded is $25,000 L exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 9/24/2018 Time: 1:30 pm Dept.: Div.: Room: 305 Address of court (if different from the address above): K) Notice of Intent to Appear by Telephone, by (name): Michael A. Marino INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. ¥ THOMAS WILLIAM CARDONE; ROWE PAUL, individually and sued herein as 1. Party or parties (answer one): dba RS MILK TRANSPORT; RS MILK TRANSPORT, LLC, a. [&) This statement is submitted by party (name): sued here as RS MILK TRANSPORT b. [2] This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. [K) The cross-complaint, if any, was filed on (date): September 7, 2018 3. Service (to be answered by plaintiffs and cross-complainants only) a. (2) Allparties 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) (2) have not been served (specify names and explain why not): (2) ipa | have been served but have not appeared and have not been dismissed (specify names): PAUL HENRY ROBLES, SR. served by mail on 9/5/2018 (3) (CC) have had a default entered against them (specify names): c. [2] 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 Q complaint GK] cross-complaint (Describe, including causes of action): Plaintiffs' filed their Complaint on 5/31/18, alleging negligence causes of action regarding a rear-end motor vehicle accident. Cross-Complaint for indemnity, contribution and declaratory relief. Page 1 of § Form Adopted for Mandatory U s Cal. Rules of Court, Mudie! Council of California CEB’ Essential CASE MANAGEMENT STATEMENT rules 3.720-3.730 ‘CM-110 [Rev. July 1, 2011] m | [2/Forms www.courts.ca.govDEFENDANT/RESPONDENT: ROWE PAUL, individually and dba CM-110 PLAINTIFF/PETITIONER:DANIEL FLAGG, PAUL HENRY ROBLES, SR. | case NUMBER 18CECG01922 RS MILK TRANSPORT, 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 eamings to date, and estimated future lost earings. If equitable relief is sought, describe the nature of the relief.) Plaintiff Flagg has $1,791.56 in meidcal specials for treatment of neck complaints. Plaintiff Robles has $5,488.84 in medical specials of head and neck complaints. C) (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 (K) ajury trial =(2) a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. (C) The trial has been set for (date): b. [KX] 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): No dates before December 12, 2019 (trial) 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [K) days (specify number): 7-10 b. a | hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial [K) by the attorney or party listed in the caption (2) by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: (2) Additional representation is described in Attachment 8. 9. Preference (J This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel [_} has [&) has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party (]Jhas (_] has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) [CQ 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) (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) (C) 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 fRev. July 1, 2011} CASE MANAGEMENT STATEMENT Page 2 of 5 CEB'| Essential ceb.com | [2|/Forms"CM-110 PLAINTIFF/PETITIONER:DANIEL FLAGG, PAUL HENRY ROBLES, SR. | CASE NUMBER: DEFENDANT/RESPONDENT: ROWE PAUL, RS MILK TRANSPORT, et al. individually and dba 18CECG01922 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 this form are willing to participate in the following ADR processes (check all that apply): If the party or parties completing this form in the case have agreed to participate in or have already completed an ADR process or processes, indicate the status of the processes (attach a copy of the parties' ADR stipulation): (1) Mediation [K) Mediation session not yet scheduled (2) Mediation session scheduled for (date): (CC) Agreed to complete mediation by (date): Q Mediation completed on (date): (2) Settlement conference [K] Settlement conference not yet scheduled (2) Settlement conference scheduled for (date): (2) Agreed to complete settlement conference by (date): () Settlement conference completed on (date): (3) Neutral evaluation () Neutral evaluation not yet scheduled (J Neutral evaluation scheduled for (date): () Agreed to complete neutral evaluation by (date): (J Neutral evaluation completed on (date): (4) Nonbinding judicial | arbitration (2) Judicial arbitration not yet scheduled (C) Judicial arbitration scheduled for (date): (2) Agreed to complete judicial arbitration by (date): (C) Judicial arbitration completed on (date): (5) Binding private arbitration (2) Private arbitration not yet scheduled (C) Private arbitration scheduled for (date): [(C) Agreed to complete private arbitration by (date): (CC) Private arbitration completed on (date): (6) Other (specify): (UV ADR session not yet scheduled [CU ADR session scheduled for (date): [() Agreed to complete ADR session by (date): (CV ADR completed on (date): _ CM-110 [Rev. July 1, 2014] CB cabscom Essential {2\Forms" CASE MANAGEMENT STATEMENT "Page 30f 5CM-110 ee PLAINTIFF/PETITIONER: DANIEL FLAGG, PAUL HENRY ROBLES, SR. CASE NUMBER: | 18CECG01922 DEFENDANT/RESPONDENT: ROWE PAUL, individually and dba | RS MILK TRANSPORT, et al. 11. Insurance a. [X) Insurance carrier, if any, for party filing this statement (name): National Liability & Fire Insurance b. Reservation of rights: LJ Yes [J No c. (2) 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. (QQ Bankruptcy (2) Other (specify): Status: 13. Related cases, consolidation, and coordination a. (2) There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: C2) Additional cases are described in Attachment 13a. b. [)Amotionto [2] consolidate [2] coordinate will be filed by (name party): 14. Bifurcation (2) 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 CJ] 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. [K] The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendants Cardone and Paul Written discovery December 2018 Defendants Cardone and Paul Depositions January 2019 Defendants Cardone and Paul Defense medical exam March 2019 Defendants Cardone and Paul Expert depositions Per code c. (C) The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): (OM-110[Rev. July 1, 2014] CASE MANAGEMENT STATEMENT Page 4 of § ‘ER’ | Essential CEB formsCM-110 PLAINTIFF/PETITIONER: DANIEL FLAGG, PAUL HENRY ROBLES, SR. CASE NUMBER: 18CECG01922 DEFENDANT/RESPONDENT: ROWE PAUL, individually and dba RS MILK TRANSPORT, et al. 17. Economic litigation a. (CQ) 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. [2] 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, 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); —____ | 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. A Date: SeptemberX 0, 2018 YUM” vichast_A_yavina for Micha A. MANO (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) » (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) C2) Additional signatures are attached. ‘CM-110 [Rev. July 1, 2011) CASE MANAGEMENT STATEMENT — Page § of 5 TB’ | Essential GB fe onms© woureswyman ice 3151608.1 i i od NR Re RW RM RN RD Dm its oy AN AW fF WN BF SGC we YD HW BB BW NY PROOF OF SERVICE STATE OF CALIFORNIA ss. wee COUNTY OF ORANGE I, Kathy Hagmaier, declare: I am employed in the County of Orange, State of California. I am over the age of 18 and not a party to the within action. My business address is 2301 Dupont Drive, Suite 300, Irvine, California 92612-7531. On September 20, 2018, I served the document(s) described as CASE MANAGEMENT STATEMENT on all interested parties in said action by placing a true copy thereof in a sealed envelope addressed as stated on the ATTACHED SERVICE LIST. BY MAIL: as follows: STATE - I am “readily familiar” with Wolfe & Wyman LLP’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S, Postal Service on that same day with postage thereon fully prepaid at Irvine, California, in the ordinary course of business. I am aware that on motion of party served, service is presumed invalid if postal cancellation date or postage meter date is more than one (1) day after date of deposit for mailing in affidavit. oO BY ELECTRONIC MAIL SERVICE as follows: I caused the following party(s) to be served the above listed document(s) by electronic mail service at the following email addresses to the party(ies) noted on the attached Service List: list email addresses here Q BY PERSONAL SERVICE as follows: I caused a copy of such document(s) to be delivered by hand to the offices of the addressee between the hours of 9:00 A.M. and 5:00 P.M. a BY OVERNIGHT COURIER SERVICE as follows: I caused such envelope to be delivered by overnight courier service to the offices of the addressee. The envelope was deposited in or with a facility regularly maintained by the overnight courier service with delivery fees paid or provided for. Q BY FACSIMILE as follows: I caused such documents to be transmitted to the telephone number of the addressee listed on the attached service list, by use of facsimile machine telephone number. The facsimile machine used complied with California Rules of Court, Rule 2004 and no error was reported by the machine. Pursuant to California Rules of Court, Rule 2006(d), a transmission record of the transmission was printed. @ STATE I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on September 20, 2018, at Irvine, California. = HagmaierWOLFE & WYMAN LLP ATTORNEYS & COUNSELORS AT LAW ha 3151608.1 Co em YN Dn Fe WB NHN ~w Be YP RY KR NR KR KR YD Be Be ee ies ota A mW ke oN Fe SC RDN DH Fe BW NY SF SERVICE LIST Fresno County Superior Court/ Case #18CECG01922 DANIEL FLAGG, et al. vy. ROWE PAUL, et al. W&W File No. 1725-039 [Revised: 9/5/18] Frank M. Nunes, Esq. Attorney for Plaintiffs . LAW OFFICES OF FRANK M. NUNES, INC. DANIEL FLAGG and PAUL HENR 6073 N. Fresno Street, Suite 101 ROBLES, SR. Fresno, CA 93710 Tele: (559) 436-0850 Fax: (559) 436-0802