Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Bar number, and address).
David Sasseen (SBN 117125)
2 North First Street, Suite 301
San Jose, CA 95113
FOR COURT USE ONLY
TELEPHONE NO. 408-569-1060 FAX NO. (Optional)
E-MAIL ADDRESS (Optional) davidsasseen@gmail.com
ATTORNEY FOR (Name): Defendant and Cross-Complainant Allwin21 Corp
|SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA
STREET ADDRESS: 191 N. First Street
MAILING ADDRESS:
Icy AND zip cope: San Jose, CA 95113
BRANCH NAME,
PLAINTIFF/PETITIONER: Rowenn Holdings, Inc. et al.
DEFENDANT/RESPONDENT: M3A, LLC, et al.
CASE MANAGEMENT STATEMENT ip mse 7
19-CV-3544
(Check one): [_x_] UNLIMITED CASE [_] LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
‘A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: July 28, 2020 Time: 10:00 a.m. Dept.: & Div. Room:
\Address of court (if different from the address above).
[_x] Notice of Intent to Appear by Telephone, by (name): David Sasseen
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): Allwin21 Corp.
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):
b, [5<] The cross-complaint, if any, was filed on (date): January 13, 2020
3. 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
The following parties named in the complaint or cross-complaint
(1) [-7] have not been served (specify names and explain why not):
(2) [5¢] have been served but have not appeared and have not been dismissed (specify names):
Kevin Wennergren (Plaintiff CEO) - see section 19a
(3) ["] have had a default entered against them (specify names):
c. [_] The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served)
4. Description of case
a. Type of case in [4] complaint [3c] cross-complaint (Describe, including causes of action)
Complaint - Unfair Competition - Business and Professions Code 17200
Cross-Complaint - Equitable indemnification
Page 1 of 5
For Adopted for Mandatory Use Cal Rules of Coun
Juseial Council of Calfomia CASE MANAGEMENT STATEMENT rues 8720-8 730
Cw-110 (Rev, Jy 1, 2011) ww cout ca govCM-110
PLAINTIFF/PETITIONER: Rowenn Holdings, Inc. et al. (CASE NUMBER:
DEFENDANT/RESPONDENT: M&A, LLC, et al. eVgoseer:
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.)
Plaintiffs claim that their former employee Mark Rudh embezzled from them by selling goods to defendants belonging to
plaintiffs using the name of a third party, namely defendant M3A, LLC. The only purchases engaged in by this defendant from
M3A were between 2008 and 2010 and totalled less than $10,000. Allwin21 alleges in its Cross-Complaint that any such
losses were caused by the actions of Cross-Defendant Wennergren.
[_] (lf more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
a. The party or parties request [_x ] a jury trial () 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. [5€] 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):
Cross-defendant Wennergren has not appeared yet - it is anticipated that the Coronavirus issue will slow matters down
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. [x] days (specify number): 3 to 5
b. [__] hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial [x] by the attorney or party listed in the caption [__] by the following:
a. Attorney:
Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
[_] 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 [x] has [__] hasnot 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 Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
(©M-110 (Rev. July 1, 2011]
CASE MANAGEMENT STATEMENT BRONPLAINTIFF/PETITIONER: Rowenn Holdings, Inc. et al.
DEFENDANT/RESPONDENT: M3A, LLC, et al.
CASE NUMBER:
19-CV-354477
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 Co
[) Mediation session not yet scheduled
[_) Mediation session scheduled for (date):
[] Agreed to complete mediation by (date):
[] Mediation completed on (date):
(2) Settlement
conference Gg)
[_] Settlement conference not yet scheduled
[_] Settlement conference scheduled for (date):
[_) Agreed to complete settlement conference by (date):
[] Settlement conference completed on (date):
(3) Neutral evaluation 4
[} Neutral evaluation not yet scheduled
(_) Neutral evaluation scheduled for (date):
[J Agreed to complete neutral evaluation by (date).
[_) Neutral evaluation completed on (date):
(4) Nonbinding judicial ba
arbitration
[} Judicial arbitration not yet scheduled
[J Judicial arbitration scheduled for (date).
[(] Agreed to complete judicial arbitration by (date):
[} Judicial arbitration completed on (date):
(5) Binding private a)
arbitration
(_) Private arbitration not yet scheduled
(_] Private arbitration scheduled for (date).
[J Agreed to complete private arbitration by (date):
[_] Private arbitration completed on (date):
(6) Other (specify): |
{__] ADR session not yet scheduled
[_] ADR session scheduled for (date):
[_) Agreed to complete ADR session by (date):
[1] ADR completed on (date):
(CM-110 [Rev. July 1, 2011)
CASE MANAGEMENT STATEMENT Page 3 of §PLAINTIFF/PETITIONER: Rowenn Holdings, Inc. et al. (CASE NUMBER:
DEFENDANT/RESPONDENT: MGA, LLC, et al. OGMSROHTT
11. Insurance
a. [__] Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: [__] Yes [__] No
c. [__] Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
(3¢) Bankruptcy ["_] Other (specify):
Status: Plaintiff settled with Mark Rudh in an adversary proceeding arising from Mr. Rudh's bankruptcy proceeding in (cont'd)
13. Related cases, consolidation, and coordination
a. [-X] There are companion, underlying, or related cases.
(1) Name of case: Rowenn Holdings, Inc. v. Mark Rudh, et al.
(2) Name of court: Santa Clara County Superior Court
(3) Case number: 16CV303337
(4) Status: Pending bankruptcy review hearing on 11/19/2020
[J Additional cases are described in Attachment 13a.
b. [-_] Amotion to [) consolidate [) coordinate will be filed by (name party):
14, Bifurcation
[Gq 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):
Unknown at this time. Defendant reserves the right to file bifurcation or other motions depending upon facts developed
relating to the prior actions in this court and the U.S. Bankruptcy Court.
15, Other motions
[3<) The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Unknown at this time, Defendant reserves the right to file motion for judgment on the pleadings, summary judgment or other
motions,
16, Discovery
a. [__] The party or parties have completed all discovery.
b. [3€] The following discovery will be completed by the date specified (describe all anticipated discovery):
Party. ription Date
Allwin21 Corp written discovery - interrogatories, rfas, document request 12/2020
depositions (unknown at this time) 2/2021
c. [_] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
aa CASE MANAGEMENT STATEMENT Page orCM-110
PLAINTIFF/PETITIONER: Rowenn Holdings, Inc. et al. CASE NUMBER:
19-CV-354477
DEFENDANT/RESPONDENT: MSA, LLG, 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. [3] 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):
Counsel for plaintiff agreed to accept service of Allwin21's cross-complaint on Mr. Wennergren via acknowledgment of
receipt form, returned the signed form to Allwin21 with a letter about a demurrer (see attachment), but has not responded
further since the shelter-in-place order went into effect in March, 2020. Allwin21 completed substitute service on Mr.
Wennergren on June 26, 2020, and will proceed to take his default in early August if no response is filed,
b. [__] After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify).
20. Total number of pages attached (if any): 2
| 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.
Date: 7/17/2020
David Sasseen banal Spi.
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
>
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
[) Additional signatures are attached.
(CM-140 [Rev, July 1, 2011]
CASE MANAGEMENT STATEMENT Page Sots12. (cont’d) In re: Mark Rudh and Maneewan Rudh; no. 17-02193 pending in the U.S. Bankruptcy Court
for the Eastern District of California. The adversary proceeding was apparently dismissed after a
settlement was reached during trial in December of 2019.POS-015
FOR COURT USE ONLY
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and sdsress)
David en (SBN 117125)
i) Street, # 301
San Jos se, CA 95113
teceprone no: 408-569-1060 FAX ND (Opnonws
E-WAll, ADDRESS (Optonay dav idsasseen@gmail,.cem
ATTORNEY FOR (Nome). Defendant Allwin2l Corp.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Clara
srreeranoress 191 N. First Street |
MAILING ADDRESS:
gavanozpcoos San Jose, CA 95113 i
BRANCH NAME
PLAINTIFFIPETITIONER: Rowenn Holdings, Inc., et al. |
DEFENDANT/RESPONDENT:;M3A, LLC, et al.
| CASE NUMBER
NOTICE AND ACKNOWLEDGMENT OF RECEIPT—CIVIL. 19 CV 354477
TO (insert name of party being served): Kevin Wennergren
r ———
NOTICE
The summons and other documents identified below are being served pursuant to section 415.30 of the California Code of Cwil
Procedure, Your failure to complete this form and return it within 20 days from the date of mailing shown below may subject you
(or the party on whose behalf you are being served) to liability for the payment of any expenses incurred in serving a summons
‘on you in any other manner permitted by law.
If you are being served on behalf of a corporation, an unincorporated association (including a partnership), or other entity, this
form must be signed by you In the name of such entity or by a person authorized to receive service of process on behalf of such
entily. In all other cases, this form must be signed by you personally or by a person authorized by you to acknowledge receipt of
summons. If you return this form to the sender, service of a summons is deemed complete on the day you sign the
acknowledgment of receipt below.
a et |
Date of mailing: February 21, 2020
David Sasseen » Daun.
f > oh
Sosa.
(TPE OR PRINT NAME)
(SIGNATURE OF SENDER—MUST NOT BE A PARTY i THIS CASE)
ACKNOWLEDGMENT OF RECEIPT
This acknowledges receipt of (to be completed by sender before mailing)
1. [XJ A copy of the summons and of the complaint
2. (__} Other (specify):
(To be completed by recipient):
Date this form is signed: Martel. / 5 2020 :
Se Ne itl Meete Lh thevpe
Daily. AL Lon (iar S OAfee ne
(TYRE GR PRINT YOUR RAME AND NAMA EXT. FANT
ON WHOSE BEMAUF THIS FORM
S'srouen
Sor Kevin We Re aye eN
,
MATURE OF PERSOP ACKNOVA EDGING RECEP? wath THM I
ACKWJOW. EDGMEN 1S MARE ON EMAL OF ANOTHER PERSON OR ENT
ee aes Mane Gee NOTICE AND ACKNOWLEDGMENT OF RECEIPT — CIVIL
POS-015 [Rev. January 1, 2096]
2 ss Att hy bh he rete 6 VeeLAW OFFICES OF DAVID SASSEEN
2 NORTH FIRST STREET, SUITE 301
San JosE, Ca 95113
‘TELEPHONE; (408)569-1060
EMAIL: davidsasseen@gmail.com
JULY 16, 2020
VIA TEXT TO ANIS DARWISH (669-226-7660) and U.S. MAIL
KSP Holdings LLC
c/o Leisure Sports Inc.
4670 Willow Road, Suite 100
Pleasanton, CA 94588
Re: Termination of tenancy at 2 North First Street Suite 10 San Jose, CA 95113
Dear KSP Holdings:
lam writing to give 30 days notice of the termination of my tenancy in your building at 2 North
First St., Suite 301, San Jose, CA 95113. If you wish to contact me in the future, I will be
moving to 236 N. Santa Cruz Ave., Suite 237-A, Los Gatos, CA 95030. You may also forward
the security deposit to that address after I vacate.
Thanks for your courtesy with regard to the administration of these changes.
Very truly yours,
David Sasseen
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Bar number, and address). David Sasseen (SBN 117125) 2 North First Street, Suite 301 San Jose, CA 95113 FOR COURT USE ONLY TELEPHONE NO. 408-569-1060 FAX NO. (Optional) E-MAIL ADDRESS (Optional) davidsasseen@gmail.com ATTORNEY FOR (Name): Defendant and Cross-Complainant Allwin21 Corp |SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA STREET ADDRESS: 191 N. First Street MAILING ADDRESS: Icy AND zip cope: San Jose, CA 95113 BRANCH NAME, PLAINTIFF/PETITIONER: Rowenn Holdings, Inc. et al. DEFENDANT/RESPONDENT: M3A, LLC, et al. CASE MANAGEMENT STATEMENT ip mse 7 19-CV-3544 (Check one): [_x_] UNLIMITED CASE [_] LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) ‘A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: July 28, 2020 Time: 10:00 a.m. Dept.: & Div. Room: \Address of court (if different from the address above). [_x] Notice of Intent to Appear by Telephone, by (name): David Sasseen 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): Allwin21 Corp. 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): b, [5<] The cross-complaint, if any, was filed on (date): January 13, 2020 3. 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 The following parties named in the complaint or cross-complaint (1) [-7] have not been served (specify names and explain why not): (2) [5¢] have been served but have not appeared and have not been dismissed (specify names): Kevin Wennergren (Plaintiff CEO) - see section 19a (3) ["] have had a default entered against them (specify names): c. [_] The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served) 4. Description of case a. Type of case in [4] complaint [3c] cross-complaint (Describe, including causes of action) Complaint - Unfair Competition - Business and Professions Code 17200 Cross-Complaint - Equitable indemnification Page 1 of 5 For Adopted for Mandatory Use Cal Rules of Coun Juseial Council of Calfomia CASE MANAGEMENT STATEMENT rues 8720-8 730 Cw-110 (Rev, Jy 1, 2011) ww cout ca govCM-110 PLAINTIFF/PETITIONER: Rowenn Holdings, Inc. et al. (CASE NUMBER: DEFENDANT/RESPONDENT: M&A, LLC, et al. eVgoseer: 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.) Plaintiffs claim that their former employee Mark Rudh embezzled from them by selling goods to defendants belonging to plaintiffs using the name of a third party, namely defendant M3A, LLC. The only purchases engaged in by this defendant from M3A were between 2008 and 2010 and totalled less than $10,000. Allwin21 alleges in its Cross-Complaint that any such losses were caused by the actions of Cross-Defendant Wennergren. [_] (lf more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial a. The party or parties request [_x ] a jury trial () 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. [5€] 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): Cross-defendant Wennergren has not appeared yet - it is anticipated that the Coronavirus issue will slow matters down 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. [x] days (specify number): 3 to 5 b. [__] hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial [x] by the attorney or party listed in the caption [__] by the following: a. Attorney: Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: [_] 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 [x] has [__] hasnot 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 Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): (©M-110 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT BRONPLAINTIFF/PETITIONER: Rowenn Holdings, Inc. et al. DEFENDANT/RESPONDENT: M3A, LLC, et al. CASE NUMBER: 19-CV-354477 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 Co [) Mediation session not yet scheduled [_) Mediation session scheduled for (date): [] Agreed to complete mediation by (date): [] Mediation completed on (date): (2) Settlement conference Gg) [_] Settlement conference not yet scheduled [_] Settlement conference scheduled for (date): [_) Agreed to complete settlement conference by (date): [] Settlement conference completed on (date): (3) Neutral evaluation 4 [} Neutral evaluation not yet scheduled (_) Neutral evaluation scheduled for (date): [J Agreed to complete neutral evaluation by (date). [_) Neutral evaluation completed on (date): (4) Nonbinding judicial ba arbitration [} Judicial arbitration not yet scheduled [J Judicial arbitration scheduled for (date). [(] Agreed to complete judicial arbitration by (date): [} Judicial arbitration completed on (date): (5) Binding private a) arbitration (_) Private arbitration not yet scheduled (_] Private arbitration scheduled for (date). [J Agreed to complete private arbitration by (date): [_] Private arbitration completed on (date): (6) Other (specify): | {__] ADR session not yet scheduled [_] ADR session scheduled for (date): [_) Agreed to complete ADR session by (date): [1] ADR completed on (date): (CM-110 [Rev. July 1, 2011) CASE MANAGEMENT STATEMENT Page 3 of §PLAINTIFF/PETITIONER: Rowenn Holdings, Inc. et al. (CASE NUMBER: DEFENDANT/RESPONDENT: MGA, LLC, et al. OGMSROHTT 11. Insurance a. [__] Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: [__] Yes [__] No c. [__] Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. (3¢) Bankruptcy ["_] Other (specify): Status: Plaintiff settled with Mark Rudh in an adversary proceeding arising from Mr. Rudh's bankruptcy proceeding in (cont'd) 13. Related cases, consolidation, and coordination a. [-X] There are companion, underlying, or related cases. (1) Name of case: Rowenn Holdings, Inc. v. Mark Rudh, et al. (2) Name of court: Santa Clara County Superior Court (3) Case number: 16CV303337 (4) Status: Pending bankruptcy review hearing on 11/19/2020 [J Additional cases are described in Attachment 13a. b. [-_] Amotion to [) consolidate [) coordinate will be filed by (name party): 14, Bifurcation [Gq 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): Unknown at this time. Defendant reserves the right to file bifurcation or other motions depending upon facts developed relating to the prior actions in this court and the U.S. Bankruptcy Court. 15, Other motions [3<) The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Unknown at this time, Defendant reserves the right to file motion for judgment on the pleadings, summary judgment or other motions, 16, Discovery a. [__] The party or parties have completed all discovery. b. [3€] The following discovery will be completed by the date specified (describe all anticipated discovery): Party. ription Date Allwin21 Corp written discovery - interrogatories, rfas, document request 12/2020 depositions (unknown at this time) 2/2021 c. [_] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): aa CASE MANAGEMENT STATEMENT Page orCM-110 PLAINTIFF/PETITIONER: Rowenn Holdings, Inc. et al. CASE NUMBER: 19-CV-354477 DEFENDANT/RESPONDENT: MSA, LLG, 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. [3] 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): Counsel for plaintiff agreed to accept service of Allwin21's cross-complaint on Mr. Wennergren via acknowledgment of receipt form, returned the signed form to Allwin21 with a letter about a demurrer (see attachment), but has not responded further since the shelter-in-place order went into effect in March, 2020. Allwin21 completed substitute service on Mr. Wennergren on June 26, 2020, and will proceed to take his default in early August if no response is filed, b. [__] After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify). 20. Total number of pages attached (if any): 2 | 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. Date: 7/17/2020 David Sasseen banal Spi. (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) > (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) [) Additional signatures are attached. (CM-140 [Rev, July 1, 2011] CASE MANAGEMENT STATEMENT Page Sots12. (cont’d) In re: Mark Rudh and Maneewan Rudh; no. 17-02193 pending in the U.S. Bankruptcy Court for the Eastern District of California. The adversary proceeding was apparently dismissed after a settlement was reached during trial in December of 2019.POS-015 FOR COURT USE ONLY ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and sdsress) David en (SBN 117125) i) Street, # 301 San Jos se, CA 95113 teceprone no: 408-569-1060 FAX ND (Opnonws E-WAll, ADDRESS (Optonay dav idsasseen@gmail,.cem ATTORNEY FOR (Nome). Defendant Allwin2l Corp. SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Clara srreeranoress 191 N. First Street | MAILING ADDRESS: gavanozpcoos San Jose, CA 95113 i BRANCH NAME PLAINTIFFIPETITIONER: Rowenn Holdings, Inc., et al. | DEFENDANT/RESPONDENT:;M3A, LLC, et al. | CASE NUMBER NOTICE AND ACKNOWLEDGMENT OF RECEIPT—CIVIL. 19 CV 354477 TO (insert name of party being served): Kevin Wennergren r ——— NOTICE The summons and other documents identified below are being served pursuant to section 415.30 of the California Code of Cwil Procedure, Your failure to complete this form and return it within 20 days from the date of mailing shown below may subject you (or the party on whose behalf you are being served) to liability for the payment of any expenses incurred in serving a summons ‘on you in any other manner permitted by law. If you are being served on behalf of a corporation, an unincorporated association (including a partnership), or other entity, this form must be signed by you In the name of such entity or by a person authorized to receive service of process on behalf of such entily. In all other cases, this form must be signed by you personally or by a person authorized by you to acknowledge receipt of summons. If you return this form to the sender, service of a summons is deemed complete on the day you sign the acknowledgment of receipt below. a et | Date of mailing: February 21, 2020 David Sasseen » Daun. f > oh Sosa. (TPE OR PRINT NAME) (SIGNATURE OF SENDER—MUST NOT BE A PARTY i THIS CASE) ACKNOWLEDGMENT OF RECEIPT This acknowledges receipt of (to be completed by sender before mailing) 1. [XJ A copy of the summons and of the complaint 2. (__} Other (specify): (To be completed by recipient): Date this form is signed: Martel. / 5 2020 : Se Ne itl Meete Lh thevpe Daily. AL Lon (iar S OAfee ne (TYRE GR PRINT YOUR RAME AND NAMA EXT. FANT ON WHOSE BEMAUF THIS FORM S'srouen Sor Kevin We Re aye eN , MATURE OF PERSOP ACKNOVA EDGING RECEP? wath THM I ACKWJOW. EDGMEN 1S MARE ON EMAL OF ANOTHER PERSON OR ENT ee aes Mane Gee NOTICE AND ACKNOWLEDGMENT OF RECEIPT — CIVIL POS-015 [Rev. January 1, 2096] 2 ss Att hy bh he rete 6 VeeLAW OFFICES OF DAVID SASSEEN 2 NORTH FIRST STREET, SUITE 301 San JosE, Ca 95113 ‘TELEPHONE; (408)569-1060 EMAIL: davidsasseen@gmail.com JULY 16, 2020 VIA TEXT TO ANIS DARWISH (669-226-7660) and U.S. MAIL KSP Holdings LLC c/o Leisure Sports Inc. 4670 Willow Road, Suite 100 Pleasanton, CA 94588 Re: Termination of tenancy at 2 North First Street Suite 10 San Jose, CA 95113 Dear KSP Holdings: lam writing to give 30 days notice of the termination of my tenancy in your building at 2 North First St., Suite 301, San Jose, CA 95113. If you wish to contact me in the future, I will be moving to 236 N. Santa Cruz Ave., Suite 237-A, Los Gatos, CA 95030. You may also forward the security deposit to that address after I vacate. Thanks for your courtesy with regard to the administration of these changes. Very truly yours, David Sasseen