Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar number, and address)
Barbara J. Miller SBN: 167223
MORGAN LEWIS & BOCKIUS LLP
600 Anton Blvd., Suite 1800
Costa Mesa, CA 92626
TELEPHONE NO.: 714.830.0600 FAXNO, (Optional):7 114.830.0700
E-MAIL ADDRESS (Optionay: barbara.miller@morganlewis.com
ATTORNEY FOR (Name): CBRE GROUP, INC.
FOR COURT USE ONLY
ELECTRONICALLY
FILED
Superior Court of Catifornia,
SUPERIOR COURT OF CALIFORNIA, COUNTY OFSAN FRANCISCO
steer apDRESS:400 McAllister Street
MaILING ADDRESS:400 McAllister Street
County of San Francisco
02/25/2019
Clerk of the Court
BY:NEYL WEBB
CITY ANDZIP CODE: San Francisco, 94102-4515 Deputy Clerk
BRANCH NAME: Civic Center Courthouse
PLAINTIFF/PETITIONER: MELISSA WOODS.
DEFENDANT/RESPONDENT: CBRE GROUP, INC., et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): | UNLIMITED CASE LIMITED CASE 14-
(Amount demanded (Amount demanded is $25,000 CGC-14-537527
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date:March 13, 2019 Time: 10:30 am Dept.:610 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.
1. Party or parties (answer one):
a X] This statement is submitted by party (name): CBRE Group, Inc.
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): February 18, 2014
b. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a XJ All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. The following parties named in the complaint or cross-complaint
(1) have not been served (specify names and explain why not):
(2) have been served but have not appeared and have not been dismissed (specify names):
(3) have had a default entered against them (specify names):
c. The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Typeofcasein [X complaint
representative action.
cross-complaint
(Describe, including causes of action): PAGA
page tof 8
Form adopiod for Mandatory Use Cal Rules of Cour,
“ludcial Counel of Cafornia CASE MANAGEMENT STATEMENT rules 3720-3,720
CM-110 [Rev. July 1, 2011]
www.courts.ca.gov
\Westiaw Doc & Form BuilderCM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: MELISSA WOODS
CGC-14-537527
DEFENDANT/RESPONDENT: CBRE GROUP, INC., et al.
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
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
This case was compelled to individual arbitration. The arbitrator issued a decision on September 14, 2017. All that remains is a
de minimus PAGA claim.
(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 a jury trial X | a nonjury trial. (if more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. The trial has been set for (date):
b. X | No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. LX] days (specify number):One (1) day
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial [2X] by the attorney or party listed in the caption by the following:
a. Attorney: Barbara J. Miller
b. Firm: MORGAN LEWIS & BOCKIUS LLP
c. Address: 600 Anton Blvd., Suite 1800, Costa Mesa, CA 92626
d. Telephone number:714.830.0600 f. Fax number: 714.830.0700
e. E-mail address:barbara.miller@morganlewis.com g. Party represented: CBRE GROUP, INC.
Additional representation is described in Attachment 8.
9. Preference
This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 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 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 Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CMETO Rew sy 3, 2077 CASE MANAGEMENT STATEMENT Page 2015CM-110
[_ PLAINTIFF/PETITIONER: MELISSA WOODS EASE NOWBER
DEFENDANT/RESPONDENT: CBRE GROUP, INC., et al. CGC-14-537527
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 ail 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 al! that apply): | stipulation):
Mediation session not yet scheduled
Mediati Mediation session scheduled for (date):
(9) 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):
Oo
Co
Oo
Oo
Co
i
Ci
Co
Oo
Co
Oo
Oo
Co
Oo
Oo
Co
Co
Co
Co
ADR completed on (date):
CM-110 Rev. July 1, 2017] Page 3 of 5
CASE MANAGEMENT STATEMENTPLAINTIFF/PETITIONERMELISSA WOODS CASE NUMBER.
CGC-14-537527
DEFENDANT/RESPONDENTCBRE GROUP, INC.. et al.
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes X | 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. There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate will be filed by (name party):
14. Bifurcation
The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
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 5CM-110
PLAINTIFF/PETITIONER: MELISSA WOODS CASS NUMBER:
b> CGC-14-537527
DEFENDANT/RESPONDENT: CBRE GROUP, INC.), 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, 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 altemative 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 Y264
Barbara J. Miller »
(TYPE OR PRINT NAME} (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
(CN-140 Rev. July 1. 291°] CASE MANAGEMENT STATEMENT. Page 5 of 5PROOF OF SERVICE
Melissa Woods v. CBRE Group, Inc.
I am a resident of the State of California, County of Orange; | am over the age of eighteen
years and not a party to the within action; my business address is 600 Anton Blvd., Suite 1800,
Costa Mesa, California 92626.
On February 25, 2019, I served on the interested parties in this action the within
document(s) entitled:
DEFENDANT’S CASE MANAGEMENT STATEMENT
[x] BY MAIL: by placing the document(s) listed above in a sealed envelope with
postage thereon fully prepaid, in the United States mail at Irvine, California
addressed as set forth below. | am readily familiar with the firm'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 in the ordinary course of business. I am aware that on motion of the
party served, service is presumed invalid if postal cancellation date or postage
meter date is more than one day after date of deposit for mailing in affidavit.
[ ] BY OVERNIGHT MAIL: By FEDERAL EXPRESS, following ordinary
business practices for collection and processing of correspondence with said
overnight mail service, and said envelope(s) will be deposited with said overnight
mail service on said date in the ordinary course of business.
[ ] BY PERSONAL SERVICE: | delivered to an authorized courier or driver
authorized by First Legal Support Services to receive documents to be delivered on
the same date. A proof of service signed by the authorized courier will be filed
with the court upon request.
Brian F, Van Vleck, Esq. — Attorneys for Plaintiff
Van Vleck Turner & Zaller LLP
5757 Wilshire Blvd., Melissa Woods
Los Angeles, CA 90036
Telephone: 323.920.0250
bvanvleck@vtzlaw.com
[ X ] STATE: I declare under penalty of perjury, under the laws of the State of
California, that the above is true and correct.
{ ] FEDERAL: I declare that | am employed in the office of a member of the Bar of
this Court at whose direction this service was made.
Executed on February 25, 2019, at Irvine, California.
Joyce McCosco
DB2/ 26326174.1
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar number, and address) Barbara J. Miller SBN: 167223 MORGAN LEWIS & BOCKIUS LLP 600 Anton Blvd., Suite 1800 Costa Mesa, CA 92626 TELEPHONE NO.: 714.830.0600 FAXNO, (Optional):7 114.830.0700 E-MAIL ADDRESS (Optionay: barbara.miller@morganlewis.com ATTORNEY FOR (Name): CBRE GROUP, INC. FOR COURT USE ONLY ELECTRONICALLY FILED Superior Court of Catifornia, SUPERIOR COURT OF CALIFORNIA, COUNTY OFSAN FRANCISCO steer apDRESS:400 McAllister Street MaILING ADDRESS:400 McAllister Street County of San Francisco 02/25/2019 Clerk of the Court BY:NEYL WEBB CITY ANDZIP CODE: San Francisco, 94102-4515 Deputy Clerk BRANCH NAME: Civic Center Courthouse PLAINTIFF/PETITIONER: MELISSA WOODS. DEFENDANT/RESPONDENT: CBRE GROUP, INC., et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): | UNLIMITED CASE LIMITED CASE 14- (Amount demanded (Amount demanded is $25,000 CGC-14-537527 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date:March 13, 2019 Time: 10:30 am Dept.:610 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. 1. Party or parties (answer one): a X] This statement is submitted by party (name): CBRE Group, Inc. b. This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): February 18, 2014 b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a XJ All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. The following parties named in the complaint or cross-complaint (1) have not been served (specify names and explain why not): (2) have been served but have not appeared and have not been dismissed (specify names): (3) have had a default entered against them (specify names): c. The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Typeofcasein [X complaint representative action. cross-complaint (Describe, including causes of action): PAGA page tof 8 Form adopiod for Mandatory Use Cal Rules of Cour, “ludcial Counel of Cafornia CASE MANAGEMENT STATEMENT rules 3720-3,720 CM-110 [Rev. July 1, 2011] www.courts.ca.gov \Westiaw Doc & Form BuilderCM-110 CASE NUMBER: PLAINTIFF/PETITIONER: MELISSA WOODS CGC-14-537527 DEFENDANT/RESPONDENT: CBRE GROUP, INC., et al. 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 earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) This case was compelled to individual arbitration. The arbitrator issued a decision on September 14, 2017. All that remains is a de minimus PAGA claim. (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 a jury trial X | a nonjury trial. (if more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. The trial has been set for (date): b. X | No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. LX] days (specify number):One (1) day b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial [2X] by the attorney or party listed in the caption by the following: a. Attorney: Barbara J. Miller b. Firm: MORGAN LEWIS & BOCKIUS LLP c. Address: 600 Anton Blvd., Suite 1800, Costa Mesa, CA 92626 d. Telephone number:714.830.0600 f. Fax number: 714.830.0700 e. E-mail address:barbara.miller@morganlewis.com g. Party represented: CBRE GROUP, INC. Additional representation is described in Attachment 8. 9. Preference This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 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 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 Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CMETO Rew sy 3, 2077 CASE MANAGEMENT STATEMENT Page 2015CM-110 [_ PLAINTIFF/PETITIONER: MELISSA WOODS EASE NOWBER DEFENDANT/RESPONDENT: CBRE GROUP, INC., et al. CGC-14-537527 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 ail 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 al! that apply): | stipulation): Mediation session not yet scheduled Mediati Mediation session scheduled for (date): (9) 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): Oo Co Oo Oo Co i Ci Co Oo Co Oo Oo Co Oo Oo Co Co Co Co ADR completed on (date): CM-110 Rev. July 1, 2017] Page 3 of 5 CASE MANAGEMENT STATEMENTPLAINTIFF/PETITIONERMELISSA WOODS CASE NUMBER. CGC-14-537527 DEFENDANT/RESPONDENTCBRE GROUP, INC.. et al. 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes X | 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. There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: Additional cases are described in Attachment 13a. b. A motion to consolidate coordinate will be filed by (name party): 14. Bifurcation The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date 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 5CM-110 PLAINTIFF/PETITIONER: MELISSA WOODS CASS NUMBER: b> CGC-14-537527 DEFENDANT/RESPONDENT: CBRE GROUP, INC.), 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, 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 altemative 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 Y264 Barbara J. Miller » (TYPE OR PRINT NAME} (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. (CN-140 Rev. July 1. 291°] CASE MANAGEMENT STATEMENT. Page 5 of 5PROOF OF SERVICE Melissa Woods v. CBRE Group, Inc. I am a resident of the State of California, County of Orange; | am over the age of eighteen years and not a party to the within action; my business address is 600 Anton Blvd., Suite 1800, Costa Mesa, California 92626. On February 25, 2019, I served on the interested parties in this action the within document(s) entitled: DEFENDANT’S CASE MANAGEMENT STATEMENT [x] BY MAIL: by placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid, in the United States mail at Irvine, California addressed as set forth below. | am readily familiar with the firm'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 in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. [ ] BY OVERNIGHT MAIL: By FEDERAL EXPRESS, following ordinary business practices for collection and processing of correspondence with said overnight mail service, and said envelope(s) will be deposited with said overnight mail service on said date in the ordinary course of business. [ ] BY PERSONAL SERVICE: | delivered to an authorized courier or driver authorized by First Legal Support Services to receive documents to be delivered on the same date. A proof of service signed by the authorized courier will be filed with the court upon request. Brian F, Van Vleck, Esq. — Attorneys for Plaintiff Van Vleck Turner & Zaller LLP 5757 Wilshire Blvd., Melissa Woods Los Angeles, CA 90036 Telephone: 323.920.0250 bvanvleck@vtzlaw.com [ X ] STATE: I declare under penalty of perjury, under the laws of the State of California, that the above is true and correct. { ] FEDERAL: I declare that | am employed in the office of a member of the Bar of this Court at whose direction this service was made. Executed on February 25, 2019, at Irvine, California. Joyce McCosco DB2/ 26326174.1