Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Joseph J. Babich, Esq. / SBN: 096290
Sean D. Wisman, Esq. / SBN: 269420
DREYER BABICH BUCCOLA WOOD CAMPORA, LLP
20 Bicentennial Circle, Sacramento, CA 95826
TELEPHONE NO.: (916) 379-3500 FAX NO.(Optionay): (916 ) 379-3599
=-MAIL ADDRESS (Optinay: }babich@dbbwc.com
ATTORNEY FOR (Name Plaintiff, CHRISTOPHER DOERHOFF
SUPERIOR COURT OF CALIFORNIA, COUNTYOF Santa Clara
strcetaporess: 191 N. First Street
MAILING ADDRESS:
CITY AND ZIP CODE: San Jose, CA 95113
erancHname: Civil-Unlimited
PLAINTIFF/PETITIONER: CHRISTOPHER DOERHOFF
DEFENDANT/RESPONDENT: VARIAN MEDICAL SYSTEMS, INC.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): [{] UNLIMITED CASE © uimitep case 19C€V341394
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or tess)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date) August 13, 2020 Time: 10:30 a.m. Dept.: 8 Div.: Room:
Address of court (if different from the address above):
[X] Notice of Intent to Appear by Telephone, by (name): JOSEPH J. BABICH, ESQ.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a [XJ This statement is submitted by party (name): Christopher Doerhoff
b. [LQ This statement is submitted jointly by parties (names):
Complaint and cross-complaint (to be answered by piaintiffs and cross-complainants only)
a. The complaint was filed on (date): January 11, 2019
b. (CQ 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, (CJ The following parties named in the complaint or cross-complaint
(1) (2) have not been served (specify names and explain why not):
(2) (C) have been served but have not appeared and have not been dismissed (specify names):
(3) (2D have had a default entered against them (specify names):
c. (E) The following additional parties may be added (specify names, nature of involvement in case, and the date by which
they may be served):
Description of case
a Type of case in (QQ complaint (2) cross-complaint (Describe, including causes of action):
Premises liability; personal injury
age 1 of 5
Form Adopted lor Mandatory Use CASE MANAGEMENT STATEMENT Cal Rules Cot
Judicial Council of Califomia
‘CMe110 [Rev July 1, 2011] G Essential
cabzom Js) Forms:
tules 3.720-3. 730
www. courts.C8.90V
J-DOERHOFF, CHRISTOPHER
CM-110
PLAINTIFF/PETITIONER:CHRISTOPHER DOERHOFF CASE NUMBER:
19CV341394
DEFENDANT/RESPONDENT: VARIAN MEDICAL SYSTEMS, INC.
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
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
On or about December 16, 2017, Plaintiff CHRISTOPEER DOERHOFF, was lawfully riding his bicycle
along Hanover Street, a paved roadway in Palo Alto. As Plaintiff cycled along the roadway, a
large tree, on Defendant VARIAN MEDICAL SYSTEMS, INC.'s property, fell over and landed on top of
him, due to the negligence of the Defendants, causing injuries and damages to Plaintiff.
C2) (f more space is needed, check this box and attach a page designated as Attachment 4b.}
Jury or nonjury trial
The party or parties request CQ a jury trial CD anonjury trial. (if more than one party, provide the name of each party
requesting a jury trial):
Trial date
a, CC) The trial has been set for (date):
b. & No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
c. 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 (QQ days (specify number): 7-10
b. (C) hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial [by the attorney or party listed in the caption C2) by the following:
a Attorney:
b. Firm:
c. Address:
d Telephone number: { Fax number:
Oo 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 avaitable 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 AOR options with the client.
(2) For self-represented parties: Party [J has {] has not reviewed the ADR information package identified in rule 3.221.
Referral to judicial arbitration or ci il action mediation (if available).
(1) (} This matter is subject to mandatory judicial arbitration under Cade 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) CD This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Cade of Civil Procedure section 1775 et seq. (specify exemption):
OM-110 (Rev. July 1, 2011) ~ CASE MANAGEMENT STATEMENT Page
2 ofS
; Essential
abaom f\Forms: J-DOERHOFF, CHRISTOPHER
CM-110
PLAINTIFF/PETITIONER: CHRISTOPHER DOERHOFF CASE NUMBER:
19CV341394
DEFENDANT/RESPONDENT: VARIAN MEDICAL SYSTEMS, INC.
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):
(2 Mediation session not yet scheduled
(1) Mediation (2) Mediation session scheduled for (date):
C) Agreed to complete mediation by (date):
(K] Mediation completed on (date): May 7, 2020
[X) Settlement conference not yet scheduled
(2) Settlement C) Settlement conference scheduled for (date):
conference
C) Agreed to complete settlement conference by (date):
C) Settlement conference completed on (date):
CC) Neutral evaluation not yet scheduled
() Neutral evaluation scheduled for (date):
(3) Neutral evaluation
[C) Agreed to complete neutral evaluation by (date):
C2 Neutral evaluation completed on (date):
C2 Judicial arbitration not yet scheduled
(4) Nonbinding judicial (C) Jusicial arbitration scheduled for (date):
arbitration
CD Agreed to complete judicial arbitration by (date):
(2) Judicial arbitration completed on (date):
{(C) Private arbitration not yet scheduled
(5) Binding private {([) Private arbitration scheduled for (date):
arbitration
C1 Agreed to complete private arbitration by (date):
(CD Private arbitration completed on (date):
(5) ADA session not yet scheduled
(6) Other (specify): (CY ADR session scheduled for (date):
() Agreed to complete ADR session by (date):
(CV ADR completed on (date):
_
(CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page
3 of 5
qacabcom fe}Forms:
y Essential
J-DOERHOFF, CHRISTOPHER
CM-110
PLAINTIFF/PET:ITIONER: CHRISTOPHER DOERHOFF CASE NUMBER.
19CV341394
DEFENDANT/RESPONDENT: VARIAN MEDICAL SYSTEMS, INC.
Wi. Insurance
a (CC) Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: C) Yes [) No
¢. (CA 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.
(CD Bankruptcy ([)} Other (specify):
Status:
18. Related cases, consolidation, and coordination
a. (C) There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
(C) Additional cases are described in Attachment 13a.
b. [) Amotion to CI consolidate C) coordinate will be filed by (name party):
14. Bifurcation
(CC) 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
CQ) The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motions in Limine
16. Discovery
a. [CQ The panty or parties have completed all discovery.
b. [QQ The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Descri jn Date
Plaintiff Expert Discovery Per Code
c. (} The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
(©M-110 [fie July 1.2013] CASE MANAGEMENT STATEMENT Page 4of 5
Ce
ceb.com
fafonnst
J-DOERHOFF, CHRISTOPHER
CM-110
PLAINTIFF/PETITIONER: CHRISTOPHER DOERHOFF CASE NUMBER:
19CV341394
DEFENDANT/RESPONDENT: VARIAN MEDICAL SYSTEMS, INC.
17. Economic litigation
a {LJ 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
(2) 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 nat, 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):
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: July 29, 2020
JOSEPH J. BARTCH/SEAN D. WISMAN »
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPF OR PRINT NAME)
»
(SIGNATURE OF PARTY OR ATTORNEY)
() Additional signatures are attached.
(CM-110 [Rev. July 1, 2011} CASE MANAGEMENT STATEMENT Page
5 ofS
.
ethcom 2|Forms:
J-DOERHOFF, CHRISTOPHER
PROOF OF SERVICE - CCP § 1013, 1013a, 2015.5
and California Rules of Court, Rule 2.306
Doerhoff v. Varian Medical Systems, Inc.
Santa Clara County Superior Case No.: 19CV341394
I, the undersigned, declare that:
I am a citizen of the United States and am over the age of eighteen years and not a
party to the within above-entitled action. I am an employee of Dreyer Babich Buccola Wood
Campora, LLP and my business address is 20 Bicentennial Circle, Sacramento, CA 95826.
On the date indicated below, I served the within document
CASE MANAGEMENT STATEMENT
On the parties in said action addressed as follows:
10 RachelH. Leonard, Esq Attorneys for Defendant/Cross-
TATE & ASSOCIATES Complainant
il 1321 Eighth Street, Suite 4 VARIAN MEDICAL SYSTEMS, INC
Berkeley, CA 94710
12 Telephone: (510) 525-5100
Facsimile: (510) 525-5130
13 Email tleonard@tateandassociates-law.com
Email mdegiovenni@teteandassociates-law.co
14 Email dcrow@tateandassociates-law.com
15 Mark A. Bates Attorneys for Cross-Defendant
BATES WINTER & ASSOCIATES LLP BRIGHTVIEW TREE CARE
16 925 Highland Pointe Drive, Suite 380 SERVICES
Roseville, CA 95678
17 Telephone: (916) 789-7080
Facsimile: (916) 789-7090
18 Email: mbates@bateswinterlaw.com
Email: bperciful@bateswinterlaw.com
19
20 oO BY FACSIMILE MACHINE (FAX): On ,at a.m./p.m. by use
of facsimile machine telephone number (916) 379- 359071 I served a true copy of the
21 aforementioned document(s) on the parties in said action by transmitting by facsimile
machine to the numbers as set forth above. The facsimile machine I used complied with
22 California Rules of Court, Rule 2.301 and no error was reported by the machine. Pursuant
to California Rules of Court, Rule 2.306, I caused the machine to print a transmission
23 record of the transmission, a copy of which is attached to this Declaration.
24 BY MAIL: I am familiar with my employer's practice for the collection and processing of
correspondence for mailing with the United States Postal Service and that each day’s mail
25 is deposited with the United States Postal Service that same day in the ordinary course of
business. On the date set forth above, I served the aforementioned document(s) on the
26 parties in said action by placing a true and correct copy thereof enclosed in a sealed
envelope with postage thereon fully prepaid, for collection and mailing on this date,
27 following ordinary business practices, at Sacramento, CA, addressed as set forth above.
28 BY PERSONAL SERVICE: By personally delivering a true copy thereof to the office of the
addressee above.
-16
Proof of Service
BY ELECTRONIC TRANSMISSION: By causing a true copy thereof to be electronically
delivered via email to the addressee(s) listed above.
T declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct, and that this declaration was execut July 29, 2020, at
Sacramento, CA.
ey
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Proof of Service
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Joseph J. Babich, Esq. / SBN: 096290 Sean D. Wisman, Esq. / SBN: 269420 DREYER BABICH BUCCOLA WOOD CAMPORA, LLP 20 Bicentennial Circle, Sacramento, CA 95826 TELEPHONE NO.: (916) 379-3500 FAX NO.(Optionay): (916 ) 379-3599 =-MAIL ADDRESS (Optinay: }babich@dbbwc.com ATTORNEY FOR (Name Plaintiff, CHRISTOPHER DOERHOFF SUPERIOR COURT OF CALIFORNIA, COUNTYOF Santa Clara strcetaporess: 191 N. First Street MAILING ADDRESS: CITY AND ZIP CODE: San Jose, CA 95113 erancHname: Civil-Unlimited PLAINTIFF/PETITIONER: CHRISTOPHER DOERHOFF DEFENDANT/RESPONDENT: VARIAN MEDICAL SYSTEMS, INC. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): [{] UNLIMITED CASE © uimitep case 19C€V341394 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or tess) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date) August 13, 2020 Time: 10:30 a.m. Dept.: 8 Div.: Room: Address of court (if different from the address above): [X] Notice of Intent to Appear by Telephone, by (name): JOSEPH J. BABICH, ESQ. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a [XJ This statement is submitted by party (name): Christopher Doerhoff b. [LQ This statement is submitted jointly by parties (names): Complaint and cross-complaint (to be answered by piaintiffs and cross-complainants only) a. The complaint was filed on (date): January 11, 2019 b. (CQ 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, (CJ The following parties named in the complaint or cross-complaint (1) (2) have not been served (specify names and explain why not): (2) (C) have been served but have not appeared and have not been dismissed (specify names): (3) (2D have had a default entered against them (specify names): c. (E) The following additional parties may be added (specify names, nature of involvement in case, and the date by which they may be served): Description of case a Type of case in (QQ complaint (2) cross-complaint (Describe, including causes of action): Premises liability; personal injury age 1 of 5 Form Adopted lor Mandatory Use CASE MANAGEMENT STATEMENT Cal Rules Cot Judicial Council of Califomia ‘CMe110 [Rev July 1, 2011] G Essential cabzom Js) Forms: tules 3.720-3. 730 www. courts.C8.90V J-DOERHOFF, CHRISTOPHER CM-110 PLAINTIFF/PETITIONER:CHRISTOPHER DOERHOFF CASE NUMBER: 19CV341394 DEFENDANT/RESPONDENT: VARIAN MEDICAL SYSTEMS, INC. 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 earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) On or about December 16, 2017, Plaintiff CHRISTOPEER DOERHOFF, was lawfully riding his bicycle along Hanover Street, a paved roadway in Palo Alto. As Plaintiff cycled along the roadway, a large tree, on Defendant VARIAN MEDICAL SYSTEMS, INC.'s property, fell over and landed on top of him, due to the negligence of the Defendants, causing injuries and damages to Plaintiff. C2) (f more space is needed, check this box and attach a page designated as Attachment 4b.} Jury or nonjury trial The party or parties request CQ a jury trial CD anonjury trial. (if more than one party, provide the name of each party requesting a jury trial): Trial date a, CC) The trial has been set for (date): b. & No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): c. 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 (QQ days (specify number): 7-10 b. (C) hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial [by the attorney or party listed in the caption C2) by the following: a Attorney: b. Firm: c. Address: d Telephone number: { Fax number: Oo 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 avaitable 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 AOR options with the client. (2) For self-represented parties: Party [J has {] has not reviewed the ADR information package identified in rule 3.221. Referral to judicial arbitration or ci il action mediation (if available). (1) (} This matter is subject to mandatory judicial arbitration under Cade 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) CD This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Cade of Civil Procedure section 1775 et seq. (specify exemption): OM-110 (Rev. July 1, 2011) ~ CASE MANAGEMENT STATEMENT Page 2 ofS ; Essential abaom f\Forms: J-DOERHOFF, CHRISTOPHER CM-110 PLAINTIFF/PETITIONER: CHRISTOPHER DOERHOFF CASE NUMBER: 19CV341394 DEFENDANT/RESPONDENT: VARIAN MEDICAL SYSTEMS, INC. 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): (2 Mediation session not yet scheduled (1) Mediation (2) Mediation session scheduled for (date): C) Agreed to complete mediation by (date): (K] Mediation completed on (date): May 7, 2020 [X) Settlement conference not yet scheduled (2) Settlement C) Settlement conference scheduled for (date): conference C) Agreed to complete settlement conference by (date): C) Settlement conference completed on (date): CC) Neutral evaluation not yet scheduled () Neutral evaluation scheduled for (date): (3) Neutral evaluation [C) Agreed to complete neutral evaluation by (date): C2 Neutral evaluation completed on (date): C2 Judicial arbitration not yet scheduled (4) Nonbinding judicial (C) Jusicial arbitration scheduled for (date): arbitration CD Agreed to complete judicial arbitration by (date): (2) Judicial arbitration completed on (date): {(C) Private arbitration not yet scheduled (5) Binding private {([) Private arbitration scheduled for (date): arbitration C1 Agreed to complete private arbitration by (date): (CD Private arbitration completed on (date): (5) ADA session not yet scheduled (6) Other (specify): (CY ADR session scheduled for (date): () Agreed to complete ADR session by (date): (CV ADR completed on (date): _ (CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5 qacabcom fe}Forms: y Essential J-DOERHOFF, CHRISTOPHER CM-110 PLAINTIFF/PET:ITIONER: CHRISTOPHER DOERHOFF CASE NUMBER. 19CV341394 DEFENDANT/RESPONDENT: VARIAN MEDICAL SYSTEMS, INC. Wi. Insurance a (CC) Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: C) Yes [) No ¢. (CA 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. (CD Bankruptcy ([)} Other (specify): Status: 18. Related cases, consolidation, and coordination a. (C) There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: (C) Additional cases are described in Attachment 13a. b. [) Amotion to CI consolidate C) coordinate will be filed by (name party): 14. Bifurcation (CC) 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 CQ) The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Motions in Limine 16. Discovery a. [CQ The panty or parties have completed all discovery. b. [QQ The following discovery will be completed by the date specified (describe all anticipated discovery): Party Descri jn Date Plaintiff Expert Discovery Per Code c. (} The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): (©M-110 [fie July 1.2013] CASE MANAGEMENT STATEMENT Page 4of 5 Ce ceb.com fafonnst J-DOERHOFF, CHRISTOPHER CM-110 PLAINTIFF/PETITIONER: CHRISTOPHER DOERHOFF CASE NUMBER: 19CV341394 DEFENDANT/RESPONDENT: VARIAN MEDICAL SYSTEMS, INC. 17. Economic litigation a {LJ 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 (2) 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 nat, 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): 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: July 29, 2020 JOSEPH J. BARTCH/SEAN D. WISMAN » (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPF OR PRINT NAME) » (SIGNATURE OF PARTY OR ATTORNEY) () Additional signatures are attached. (CM-110 [Rev. July 1, 2011} CASE MANAGEMENT STATEMENT Page 5 ofS . ethcom 2|Forms: J-DOERHOFF, CHRISTOPHER PROOF OF SERVICE - CCP § 1013, 1013a, 2015.5 and California Rules of Court, Rule 2.306 Doerhoff v. Varian Medical Systems, Inc. Santa Clara County Superior Case No.: 19CV341394 I, the undersigned, declare that: I am a citizen of the United States and am over the age of eighteen years and not a party to the within above-entitled action. I am an employee of Dreyer Babich Buccola Wood Campora, LLP and my business address is 20 Bicentennial Circle, Sacramento, CA 95826. On the date indicated below, I served the within document CASE MANAGEMENT STATEMENT On the parties in said action addressed as follows: 10 RachelH. Leonard, Esq Attorneys for Defendant/Cross- TATE & ASSOCIATES Complainant il 1321 Eighth Street, Suite 4 VARIAN MEDICAL SYSTEMS, INC Berkeley, CA 94710 12 Telephone: (510) 525-5100 Facsimile: (510) 525-5130 13 Email tleonard@tateandassociates-law.com Email mdegiovenni@teteandassociates-law.co 14 Email dcrow@tateandassociates-law.com 15 Mark A. Bates Attorneys for Cross-Defendant BATES WINTER & ASSOCIATES LLP BRIGHTVIEW TREE CARE 16 925 Highland Pointe Drive, Suite 380 SERVICES Roseville, CA 95678 17 Telephone: (916) 789-7080 Facsimile: (916) 789-7090 18 Email: mbates@bateswinterlaw.com Email: bperciful@bateswinterlaw.com 19 20 oO BY FACSIMILE MACHINE (FAX): On ,at a.m./p.m. by use of facsimile machine telephone number (916) 379- 359071 I served a true copy of the 21 aforementioned document(s) on the parties in said action by transmitting by facsimile machine to the numbers as set forth above. The facsimile machine I used complied with 22 California Rules of Court, Rule 2.301 and no error was reported by the machine. Pursuant to California Rules of Court, Rule 2.306, I caused the machine to print a transmission 23 record of the transmission, a copy of which is attached to this Declaration. 24 BY MAIL: I am familiar with my employer's practice for the collection and processing of correspondence for mailing with the United States Postal Service and that each day’s mail 25 is deposited with the United States Postal Service that same day in the ordinary course of business. On the date set forth above, I served the aforementioned document(s) on the 26 parties in said action by placing a true and correct copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, for collection and mailing on this date, 27 following ordinary business practices, at Sacramento, CA, addressed as set forth above. 28 BY PERSONAL SERVICE: By personally delivering a true copy thereof to the office of the addressee above. -16 Proof of Service BY ELECTRONIC TRANSMISSION: By causing a true copy thereof to be electronically delivered via email to the addressee(s) listed above. T declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was execut July 29, 2020, at Sacramento, CA. ey 10 11 12 13 14 1s 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- Proof of Service