Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Mark B. Canepa #139303
WHITE CANEPA LLP
7690 N. Palm Ave., Suite 105
Fresno, CA 93711
TELEPHONE No: (559) 439-0800 FAX NO. (Optional: (559) 439-0802
E-MAIL ADDRESS (Optionay: MMCanepa@whitecanepa.com
ATTORNEY FOR (Name): Defendant Gail Mallard-Warren, M.D.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA
street aopress: 191 N. First St.
MAILING ADDRESS:
city ano zip cove: San Jose, CA 95113
BRANCH NAME: Downtown Superior Court
PLAINTIFF/PETITIONER: NICO J. COIGNY, et al.
DEFENDANT/RESPONDENT: STANFORD HEALTHCARE, et al.
—
CASE MANAGEMENT STATEMENT ‘CASE NUMBER:
19CV352637
(Check one): Q UNLIMITED CASE Oo LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: April 14, 2020 Time: 10:00 a.m. Dept.: 8 Div.: Room:
Address of court (if different from the address above):
EK] Notice of Intent to Appear by Telephone, by (name): Mark B. Canepa
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. EX This statement is submitted by party (name): Defendant Gail Mallard-Warren, M.D.
b. [1 This statement is submitted jointly by parties (names):
Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. [1 The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
a oO
All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. OoThe following parties named in the complaint or cross-complaint
(1) Ts 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) (shave had a default entered against them (specify names):
c. Oo The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
Description of case
a. Type of case in BQ) complaint 1 cross-complaint (Describe, including causes of action):
Medical malpractice- wrongful death.
Page 105
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal, Rules of Court,
Judicial Council of California rules 3720-3 730
M-110 [Rov, July1, 2011] www. cot
‘Ameri Ine.
wer Flow cor
CM-110
i
PLAINTIFF/PETITIONER: NICO J. COIGNY, et al. ‘CASE NUMBER:
19CV352637
JEFENDANT/RESPONDENT: STANFORD HEALTHCARE, 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 eamings. If equitable relief is sought, describe the nature of the relief.)
Plaintiffs claim Defendants were negligent in the care and treatment of their Decedent. This Defendant denies the
allegations in Plaintiffs' Complaint.
oO (If more space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request & a jury trial D1 a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a. (1 The trial has been set for (date):
b. EX] 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): It appears unlikely this case will be ready for trial within 12 months of the filing of the Complaint
given current Covid-19 issues.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
See Attachment 6c.
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 10-14
b. (1 hours (short causes) (specify):
Trial representation (fo be answered for each party)
The party or parties will be represented at trial LI by the attorney or party listed in the caption C1 by the following:
a Attorney:
b. Firm:
c. Address:
d Telephone number: if. Fax number:
e. E-mail address: g. Party represented:
o Additional representation is described in Attachment 8.
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 Chas 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 0 has 7 has not reviewed the ADR information package identified in rule 3.221.
b Referral to judicial arbitration or civil action mediation (if available).
(1) [1 This matter is subject to mandatory judiciat 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.
@o 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.
@ 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):
Amount in controversy exceeds limits.
CM-4110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page of6
CM-110
PLAINTIFF/PETITIONER: NICO J. COIGNY, et al. CASE NUMBER:
19CV352637
IDEFENDANT/RESPONDENT: STANFORD HEALTHCARE, et al.
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):
x Mediation session not yet scheduled
oO Mediation session scheduled for (date):
(1} Mediation
o Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
Settlement conference scheduled for (date):
(2) Settlement
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
Private arbitration scheduled for (date):
(8) Binding private
arbitration Agreed to complete private arbitration by (date);
Private arbitration completed on (date):
ADR session not yet scheduled
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
(CM-110 [Rev. July 1, 2014] CASE MANAGEMENT STATEMENT Page
3 of §
CM-110
bi PLAINTIFF/PETITIONER: NICO J. COIGNY, et al. CASE NUMBER:
19CV352637
IEFENDANT/RESPONDENT: STANFORD HEALTHCARE, et al.
11. Insurance
a Insurance carrier, if any, for party filing this statement (name): Norcal Mutual Insurance Company
b. Reservation of rights: 0 Yes 0 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.
1 Bankruptcy [J 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:
(1 Additional cases are described in Attachment 13a.
b. [1 Amotion to QO consolidate Oo coordinate will be filed by (name party):
14, Bifurcation
O 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
Kl The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Potential Motion for Summary Judgment/Summary Adjudication; Motions in Limine.
16. Discovery
a. 1 The party or parties have completed all discovery.
b XJ The following discovery will be completed by the date specified (describe all anticipated discovery):
Pa Description Date
Defendant Gail Mallard-Warren, M.D. Written Discovery June 2020
Defendant Gail Mallard-Warren, M.D. Depositions of Plaintiffs’ GALs October 2020
Defendant Gail Mallard-Warren, M.D. Expert Discovery Per Code
c. O The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CN-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page
4 of 5
Am Legaltvet,
nsWWor
CM-110
PLAINTIFF/PETITIONER: NICO J. COIGNY, et al. CASE NUMBER:
19CV352637
| DEFENDANT/RESPONDENT: STANFORD HEALTHCARE, et al.
17. Economic litigation
a (1 This is a limited civil case (.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 91 }-98 will apply to this case.
b. oO 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
0 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 OO 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): 4
lam 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: March’, 2020
Mark B. Canepa +» Fi sa
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
>
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
LA Additional signatures are attached.
M-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page
§ of 5
Attachment 6c to Case Management Statement
Case Name County Trial Dates
Barajas v. O’Hara Kings 6/1/20 — 6/12/20
Belemjian vy. Central Calif. ENT Fresno 6/29/20 — 7/10/20
Pre-planned vacation 7/10/20 — 8/16/20
MBC v. Truong Sacramento 7/20/20 — 7/24/20
Minton v. Kaweah Delta Tulare 8/24/20 — 9/4/20
Pre-planned vacation 9/14/20 — 10/1/20
Jamerson v. Gade Fresno 10/13/20 — 10/23/20
Hernandez v. Kaweah Delta Tulare 10/20/20 — 10/30/20
Bingham v. Douangmala Fresno 11/16/20 — 12/4/20
Oats v. Phillips Kern 12/7/20 — 12/18/20
Lawson v. Familiar Surroundings Santa Cruz 1/11/21 — 1/22/21
Borges v. Kaweah Delta Tulare 1/25/21 — 2/5/21
Davtyan v. Tidwell Fresno 2/1/21 — 2/12/21
Pichardo v. Avena Fresno 2/16/21 — 2/26/21
Lopez v. Adventist Fresno 3/22/21 — 4/2/21
1832237
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF FRESNO
At the time of service, I was over 18 years of age and not a party to this action. I am employed in
the County of Fresno, State of California. My business address is 7690 North Palm Avenue, Suite 105,
Fresno, California 93711.
On March 31, 2020, I served true copies of the following document described as CASE
MANAGEMENT STATEMENT on the interested parties in this action as follows:
SEE ATTACHED SERVICE LIST
BY MAIL: | enclosed the document in a sealed envelope or package addressed to the persons at the
addresses listed in the Service List and placed the envelope for collection and mailing, following our
ordinary business practices. I am readily familiar with WHITE | CANEPA LLP's practice for
collecting and processing correspondence for mailing. On the same day that the correspondence is
10 placed for collection and mailing, it is deposited in the ordinary course of business with the United
States Postal Service, in a sealed envelope with postage fully prepaid.
ll
BY FAX TRANSMISSION: Ifaxed a copy of the document to the persons at the fax numbers
12 listed in the Service List. The telephone number of the sending facsimile machine was (559) 439-
0802. No error was reported by the fax machine thatI used.
13
BY E-MAIL OR ELECTRONIC TRANSMISSION: | transmitted electronically by email to the
14 persons at the e-mail addresses listed in the Service List. I did not receive, within a reasonable time
after the transmission, any electronic message or other indication that the transmission was
15 unsuccessful. My electronic address is emceguire@whitecanepa.com.
16 BY OVERNIGHT DELIVERY: [ enclosed said document in an envelope or package provided by
the overnight service carrier and addressed to the persons at the addresses listed in the Service List. 1
17 placed the envelope or package for collection and overnight delivery at an office or a regularly
utilized drop box of the overnight service carrier or delivered such document to a courier or driver
18 authorized by the overnight service carrier to receive documents.
19 I declare under penalty of perjury under the laws of the State of California that the foregoing is true
and correct. Executed on March 31, 2020, at Fresno, California.
20
21
CUnnstina MSA wre
22 Christina McGuire
1875244/0001.0191
23
24
25
26
27
28
Proof
of Service ~ Coigny v. Stanford Healthcare
1
SERVICE LIST
Daniel R. Baradat, Esq. Attorneys for Plaintiffs
Baradat & Paboojian, Inc.
720 W. Alluvial Ave.
Fresno, CA 93711
Fax: (559) 431-1702
Email: drb@bplaw-inc.con
Daniela P. Stoutenburg, Esq. Attorneys for Defendants Lucile
Dummit Buchholz & Trapp Salter Packard Children’s Hospital
1661 Garden Hwy. and Stanford Healthcare
Sacramento, CA 95833
Fax: (916) 929-5368
10 Email: Daniela.stoutenburg@dbt.law
thomas.gray@dbt.law
11 sheryl.rodacker@dbt.law
atherine.kort@dbt.law
12
13
14
15
16
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Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Mark B. Canepa #139303 WHITE CANEPA LLP 7690 N. Palm Ave., Suite 105 Fresno, CA 93711 TELEPHONE No: (559) 439-0800 FAX NO. (Optional: (559) 439-0802 E-MAIL ADDRESS (Optionay: MMCanepa@whitecanepa.com ATTORNEY FOR (Name): Defendant Gail Mallard-Warren, M.D. SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA street aopress: 191 N. First St. MAILING ADDRESS: city ano zip cove: San Jose, CA 95113 BRANCH NAME: Downtown Superior Court PLAINTIFF/PETITIONER: NICO J. COIGNY, et al. DEFENDANT/RESPONDENT: STANFORD HEALTHCARE, et al. — CASE MANAGEMENT STATEMENT ‘CASE NUMBER: 19CV352637 (Check one): Q UNLIMITED CASE Oo LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: April 14, 2020 Time: 10:00 a.m. Dept.: 8 Div.: Room: Address of court (if different from the address above): EK] Notice of Intent to Appear by Telephone, by (name): Mark B. Canepa INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. EX This statement is submitted by party (name): Defendant Gail Mallard-Warren, M.D. b. [1 This statement is submitted jointly by parties (names): Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. [1 The cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) a oO All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. OoThe following parties named in the complaint or cross-complaint (1) Ts 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) (shave had a default entered against them (specify names): c. Oo The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): Description of case a. Type of case in BQ) complaint 1 cross-complaint (Describe, including causes of action): Medical malpractice- wrongful death. Page 105 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal, Rules of Court, Judicial Council of California rules 3720-3 730 M-110 [Rov, July1, 2011] www. cot ‘Ameri Ine. wer Flow cor CM-110 i PLAINTIFF/PETITIONER: NICO J. COIGNY, et al. ‘CASE NUMBER: 19CV352637 JEFENDANT/RESPONDENT: STANFORD HEALTHCARE, 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 eamings. If equitable relief is sought, describe the nature of the relief.) Plaintiffs claim Defendants were negligent in the care and treatment of their Decedent. This Defendant denies the allegations in Plaintiffs' Complaint. oO (If more space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request & a jury trial D1 a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a. (1 The trial has been set for (date): b. EX] 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): It appears unlikely this case will be ready for trial within 12 months of the filing of the Complaint given current Covid-19 issues. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): See Attachment 6c. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 10-14 b. (1 hours (short causes) (specify): Trial representation (fo be answered for each party) The party or parties will be represented at trial LI by the attorney or party listed in the caption C1 by the following: a Attorney: b. Firm: c. Address: d Telephone number: if. Fax number: e. E-mail address: g. Party represented: o Additional representation is described in Attachment 8. 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 Chas 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 0 has 7 has not reviewed the ADR information package identified in rule 3.221. b Referral to judicial arbitration or civil action mediation (if available). (1) [1 This matter is subject to mandatory judiciat 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. @o 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. @ 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): Amount in controversy exceeds limits. CM-4110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page of6 CM-110 PLAINTIFF/PETITIONER: NICO J. COIGNY, et al. CASE NUMBER: 19CV352637 IDEFENDANT/RESPONDENT: STANFORD HEALTHCARE, et al. 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): x Mediation session not yet scheduled oO Mediation session scheduled for (date): (1} Mediation o Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled Settlement conference scheduled for (date): (2) Settlement 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 Private arbitration scheduled for (date): (8) Binding private arbitration Agreed to complete private arbitration by (date); Private arbitration completed on (date): ADR session not yet scheduled (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): (CM-110 [Rev. July 1, 2014] CASE MANAGEMENT STATEMENT Page 3 of § CM-110 bi PLAINTIFF/PETITIONER: NICO J. COIGNY, et al. CASE NUMBER: 19CV352637 IEFENDANT/RESPONDENT: STANFORD HEALTHCARE, et al. 11. Insurance a Insurance carrier, if any, for party filing this statement (name): Norcal Mutual Insurance Company b. Reservation of rights: 0 Yes 0 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. 1 Bankruptcy [J 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: (1 Additional cases are described in Attachment 13a. b. [1 Amotion to QO consolidate Oo coordinate will be filed by (name party): 14, Bifurcation O 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 Kl The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Potential Motion for Summary Judgment/Summary Adjudication; Motions in Limine. 16. Discovery a. 1 The party or parties have completed all discovery. b XJ The following discovery will be completed by the date specified (describe all anticipated discovery): Pa Description Date Defendant Gail Mallard-Warren, M.D. Written Discovery June 2020 Defendant Gail Mallard-Warren, M.D. Depositions of Plaintiffs’ GALs October 2020 Defendant Gail Mallard-Warren, M.D. Expert Discovery Per Code c. O The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CN-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5 Am Legaltvet, nsWWor CM-110 PLAINTIFF/PETITIONER: NICO J. COIGNY, et al. CASE NUMBER: 19CV352637 | DEFENDANT/RESPONDENT: STANFORD HEALTHCARE, et al. 17. Economic litigation a (1 This is a limited civil case (.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 91 }-98 will apply to this case. b. oO 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 0 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 OO 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): 4 lam 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: March’, 2020 Mark B. Canepa +» Fi sa (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) > (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) LA Additional signatures are attached. M-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page § of 5 Attachment 6c to Case Management Statement Case Name County Trial Dates Barajas v. O’Hara Kings 6/1/20 — 6/12/20 Belemjian vy. Central Calif. ENT Fresno 6/29/20 — 7/10/20 Pre-planned vacation 7/10/20 — 8/16/20 MBC v. Truong Sacramento 7/20/20 — 7/24/20 Minton v. Kaweah Delta Tulare 8/24/20 — 9/4/20 Pre-planned vacation 9/14/20 — 10/1/20 Jamerson v. Gade Fresno 10/13/20 — 10/23/20 Hernandez v. Kaweah Delta Tulare 10/20/20 — 10/30/20 Bingham v. Douangmala Fresno 11/16/20 — 12/4/20 Oats v. Phillips Kern 12/7/20 — 12/18/20 Lawson v. Familiar Surroundings Santa Cruz 1/11/21 — 1/22/21 Borges v. Kaweah Delta Tulare 1/25/21 — 2/5/21 Davtyan v. Tidwell Fresno 2/1/21 — 2/12/21 Pichardo v. Avena Fresno 2/16/21 — 2/26/21 Lopez v. Adventist Fresno 3/22/21 — 4/2/21 1832237 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF FRESNO At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of Fresno, State of California. My business address is 7690 North Palm Avenue, Suite 105, Fresno, California 93711. On March 31, 2020, I served true copies of the following document described as CASE MANAGEMENT STATEMENT on the interested parties in this action as follows: SEE ATTACHED SERVICE LIST BY MAIL: | enclosed the document in a sealed envelope or package addressed to the persons at the addresses listed in the Service List and placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with WHITE | CANEPA LLP's practice for collecting and processing correspondence for mailing. On the same day that the correspondence is 10 placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid. ll BY FAX TRANSMISSION: Ifaxed a copy of the document to the persons at the fax numbers 12 listed in the Service List. The telephone number of the sending facsimile machine was (559) 439- 0802. No error was reported by the fax machine thatI used. 13 BY E-MAIL OR ELECTRONIC TRANSMISSION: | transmitted electronically by email to the 14 persons at the e-mail addresses listed in the Service List. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was 15 unsuccessful. My electronic address is emceguire@whitecanepa.com. 16 BY OVERNIGHT DELIVERY: [ enclosed said document in an envelope or package provided by the overnight service carrier and addressed to the persons at the addresses listed in the Service List. 1 17 placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight service carrier or delivered such document to a courier or driver 18 authorized by the overnight service carrier to receive documents. 19 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on March 31, 2020, at Fresno, California. 20 21 CUnnstina MSA wre 22 Christina McGuire 1875244/0001.0191 23 24 25 26 27 28 Proof of Service ~ Coigny v. Stanford Healthcare 1 SERVICE LIST Daniel R. Baradat, Esq. Attorneys for Plaintiffs Baradat & Paboojian, Inc. 720 W. Alluvial Ave. Fresno, CA 93711 Fax: (559) 431-1702 Email: drb@bplaw-inc.con Daniela P. Stoutenburg, Esq. Attorneys for Defendants Lucile Dummit Buchholz & Trapp Salter Packard Children’s Hospital 1661 Garden Hwy. and Stanford Healthcare Sacramento, CA 95833 Fax: (916) 929-5368 10 Email: Daniela.stoutenburg@dbt.law thomas.gray@dbt.law 11 sheryl.rodacker@dbt.law atherine.kort@dbt.law 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28