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cM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state har number, and Address): Winn Law Group, APC. FOR COURT USE ONLY
Brian N. Winn (SBN €6779} Laura M, Hoalst (SBN 101082) John E, Gordon (SBN
180053) Jason M, Burrows (SBN 309882) Amit Taneja (SBN 304559) Grace Gail
Cara (SBN 315558}
110 E WILSHIRE AVE STE 212, FULLERTON, CA 9283.
TELEPHONE NO.: (714) 446-6686 FAX NO. (714) 446-6680
E-MAIL ADDRESS (Optione): Info@winnlawgroup.com
19-02645-0-CA3-MR (1910-00
ATTORNEY FOR ame PLAINTIFF,
STREET ADDRESS: 191 No. First St.
MAILING ADDRESS: i391 No. First St.
CITY AND ZIP CODE: San Jose CA 95113
BRANCH NAME: SAN JOSE DISTRICT, LIMITED
PLAINTIFF/PETITIONER: CAVALRY SPV I, LuL¢
DEFENDANT/RESPONDENT: MOHAMMAD HARANDT
CASE MANAGEMENT STATEMENT CASE NUMGER:
(Check one): Ml UNLIMITED CASE O Limitep case 19€V347238
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: October 29, 2019 Time:10:00 am Dept.:October 29, 2019 Div.: Room:
Address of court (if different from the address above):
C1 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): CAVALRY SPV I, LLC
b.{ ] This statement is submitted jointly by parties (name):
2. Complaint and cross-compiaint (fo be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): April 22, 2019
b.[ ] The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a.[ X ] 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
af ] have not been served (specify names and explain why not):
@) [ J 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 the date by which
they may be served):
4. Description of case
a. Type of case in [X] complaint [ ] cross-complaint (describe, including causes of action):
COMMON COUNTS
Page 1 of 5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal, Rules of Court
Judicial Council of California tules 3.720-3.730
(CM-410 (Rev. July1, 2011) www.courtinte.ca. gov.
cM~110
PLAINTIFF/PETITIONER: CAVALRY SPV I, LLC CASE NUMBER:
DEFENDANT/RESPONDENT: MOHAMMAD HARANDY 190V347238
4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount}, estimated future medical expenses, lost eamings
to date, and estimated future jost eamings. if equitable relief is sought, describe the nature of the relief.)
Within the last four years, an account was stated in writing between Plaintiff and Defendant. Thereafter, Defendant defaulted on the
terms of the agreement and failed to dispute balance. Plaintiff has been damaged in the sum of $43,547.06,
[ ] (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 [X] a nonjury trial (if more than one party, provide the names 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 attorney 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. [ ] days (specify number}:
b. [X] hours (short causes) (specify): 2.0 hours
8. 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 [X]_by the following:
Attorney: Brian N. Winn
Firm: Winn Law Group, A P.C,
Address: 110 E WILSHIRE AVE STE 212 FULLERTON CA 92832
Telephone number: (714) 446-6686
Fax number: (714) 446-6680
E-mail address: INFO@WINNLAWGROUP.COM
Party represented: PLAINTIFF
{ ] 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 the 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 [ X ] 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 114.11 or to civil action
mediation under Cade 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
Civif Procedure section 1144.14
(3) [] This case is exempt from judicial arbitration under rule 3.811 of the California Rutes of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq, (specify exemption):
CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 20f6
cM-110
PLAINTIFF/PETITIONER: CAVALRY SPV TI, LLC CASE NUMBER:
19C0V347238
DEFENDANT/RESPONDENT: MOHAMMAD HARANDT
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 infarmation):
‘The party or parties completing If the party or parties completing this form in the case have
this form are willing to agreed to participate in or have already completed an ADR
participate in the following ADR process or processes, indicate the status of the processes
processes (check all that apply): (attach a copy of the parties' ADR stipulation):
[ ] Mediation session not yet scheduled
(1) Mediation [1 [ ] Mediation session scheduled for (date):
[ ] Agreed to complete mediation by (date):
[ ] Mediation compieted on (date):
{ ] Settlement conference not yet scheduled
(2) Settlement conference t] } Settlement conference scheduled for (date):
[ ] Agreed to complete settlement conference by (date):
{ ] Settlement conference completed on (date):
[ ] Neutral evaluation not yet scheduled
(3) Neutral evatuation tl
[ ] Neutral evaluation scheduled for (date):
[ ] Agreed to complete neutral evaluation by (date):
( ] Neutral evaluation completed on (date):
[ ] Judicial arbitration not yet scheduled
(4) Nonbinding judicial [1 [ ] 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 arbitration [) [ ] Private arbitration scheduled for (date):
[ ] Agreed to complete private arbitration by (date):
t ] Private arbitration completed on (date):
{ ] ADR session not yet scheduled
(6) Other (specify): ix] [ ] ADR session scheduled for (date):
] Agreed to complete ADR session by (date):
[ ] ADR session completed on (date):
CM-110 [Rev. July 1, 2014] CASE MANAGEMENT STATEMENT Page 30f5
CM-110
PLAINTIFF/PETITIONER: CAVALRY SPV T, LLC CASE NUMBER:
19CV347238
DEFENDANT/RESPONDENT: MOHAMMAD HARANDI
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.
[ ] Bankruptey [ } 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 14a.
b. [ ] Amotion 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 motion 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 are anticipated (specify):
CM-140 fRev. July 4, 2014] CASE MANAGEMENT STATEMENT Page 4 of5
PLAINTIFF/PETITIONER: CAVALRY SPV I, LLC CASE NUMBER:
19CV347238
DEFENDANT/RESPONDENT: MOHAMMAD HARANDI
17. Economic Litigation
a. [X] This is a limited civil case (i.¢., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90 through 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 nof apply to this case):
48. Other Issues
[x ] The party or parties request that the following additional matters be considered or determined at the case management
conference (specify): PLAINTIFF SUBMITTED ITS JUDGMENT PACKAGE TO COURT ON OR AROUND SEPTEMBER 9,
2019. PLAINTIFF RESPECTFULLY REQUESTS THE COURT TO CONTINUE THE HEARING 60-80 DAYS TO ALLOW TIME
FOR THE COURT TO FILE AND ENTER JUDGMENT.
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): _0.
| am completely familiar with this case and will be fully prepared to discuss the status of discovery and ADR, as weil as other issues
taised 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: October 3, 2019
t ] Brian N. Winn ra M. Hoalst
[ ] John 2, Gordon Jason M, Burrows
[ ] Amit Paneja { ] Grace Gail Cara
TYPE OR PRINT NAME (SIGNATARE OF PARTY OR PARTY'S ATTORNEY)
TYPE OR PRINT NAME (SIGNATURE OF PARTY OR PARTY'S ATTORNEY)
] Additional signatures are attached
PROOF OF SERVICE
Iam employed in the County of Orange. My business address is 110 E. Wilshire Avenue, Suite 212,
Fullerton, CA 92832, where the mailing occurred. I am over the age of 18 years and am not a party to this cause
Iam readily familiar with the practices of Winn Law Group, A Professional Corporation for collection and
processing of correspondence for mailing with the United States Postal Service. Such correspondence is
deposited with the United States Postal Service the same day in the ordinary course of business.
On October 3, 2019, I served the document in this action bearing the title: CASE MANAGEMENT
STATEMENT by placing a true copy thereof enclosed in a sealed envelope addressed as follows:
Mohammad Harandi
3629 Copperfield Dr Apt 352
San Jose CA 95136-4028
I placed such envelope for collection and mailing on this date following ordinary business practices.
Executed on October 3, 2019, at Fullerton, California.
1 declare under penalty of perjury under the laws of the State of California that the above is true and
correct.
UM rW2.
Melina Roybal
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cM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state har number, and Address): Winn Law Group, APC. FOR COURT USE ONLY Brian N. Winn (SBN €6779} Laura M, Hoalst (SBN 101082) John E, Gordon (SBN 180053) Jason M, Burrows (SBN 309882) Amit Taneja (SBN 304559) Grace Gail Cara (SBN 315558} 110 E WILSHIRE AVE STE 212, FULLERTON, CA 9283. TELEPHONE NO.: (714) 446-6686 FAX NO. (714) 446-6680 E-MAIL ADDRESS (Optione): Info@winnlawgroup.com 19-02645-0-CA3-MR (1910-00 ATTORNEY FOR ame PLAINTIFF, STREET ADDRESS: 191 No. First St. MAILING ADDRESS: i391 No. First St. CITY AND ZIP CODE: San Jose CA 95113 BRANCH NAME: SAN JOSE DISTRICT, LIMITED PLAINTIFF/PETITIONER: CAVALRY SPV I, LuL¢ DEFENDANT/RESPONDENT: MOHAMMAD HARANDT CASE MANAGEMENT STATEMENT CASE NUMGER: (Check one): Ml UNLIMITED CASE O Limitep case 19€V347238 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: October 29, 2019 Time:10:00 am Dept.:October 29, 2019 Div.: Room: Address of court (if different from the address above): C1 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): CAVALRY SPV I, LLC b.{ ] This statement is submitted jointly by parties (name): 2. Complaint and cross-compiaint (fo be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): April 22, 2019 b.[ ] The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a.[ X ] 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 af ] have not been served (specify names and explain why not): @) [ J 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 the date by which they may be served): 4. Description of case a. Type of case in [X] complaint [ ] cross-complaint (describe, including causes of action): COMMON COUNTS Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal, Rules of Court Judicial Council of California tules 3.720-3.730 (CM-410 (Rev. July1, 2011) www.courtinte.ca. gov. cM~110 PLAINTIFF/PETITIONER: CAVALRY SPV I, LLC CASE NUMBER: DEFENDANT/RESPONDENT: MOHAMMAD HARANDY 190V347238 4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount}, estimated future medical expenses, lost eamings to date, and estimated future jost eamings. if equitable relief is sought, describe the nature of the relief.) Within the last four years, an account was stated in writing between Plaintiff and Defendant. Thereafter, Defendant defaulted on the terms of the agreement and failed to dispute balance. Plaintiff has been damaged in the sum of $43,547.06, [ ] (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 [X] a nonjury trial (if more than one party, provide the names 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 attorney 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. [ ] days (specify number}: b. [X] hours (short causes) (specify): 2.0 hours 8. 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 [X]_by the following: Attorney: Brian N. Winn Firm: Winn Law Group, A P.C, Address: 110 E WILSHIRE AVE STE 212 FULLERTON CA 92832 Telephone number: (714) 446-6686 Fax number: (714) 446-6680 E-mail address: INFO@WINNLAWGROUP.COM Party represented: PLAINTIFF { ] 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 the 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 [ X ] 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 114.11 or to civil action mediation under Cade 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 Civif Procedure section 1144.14 (3) [] This case is exempt from judicial arbitration under rule 3.811 of the California Rutes of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq, (specify exemption): CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 20f6 cM-110 PLAINTIFF/PETITIONER: CAVALRY SPV TI, LLC CASE NUMBER: 19C0V347238 DEFENDANT/RESPONDENT: MOHAMMAD HARANDT 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 infarmation): ‘The party or parties completing If the party or parties completing this form in the case have this form are willing to agreed to participate in or have already completed an ADR participate in the following ADR process or processes, indicate the status of the processes processes (check all that apply): (attach a copy of the parties' ADR stipulation): [ ] Mediation session not yet scheduled (1) Mediation [1 [ ] Mediation session scheduled for (date): [ ] Agreed to complete mediation by (date): [ ] Mediation compieted on (date): { ] Settlement conference not yet scheduled (2) Settlement conference t] } Settlement conference scheduled for (date): [ ] Agreed to complete settlement conference by (date): { ] Settlement conference completed on (date): [ ] Neutral evaluation not yet scheduled (3) Neutral evatuation tl [ ] Neutral evaluation scheduled for (date): [ ] Agreed to complete neutral evaluation by (date): ( ] Neutral evaluation completed on (date): [ ] Judicial arbitration not yet scheduled (4) Nonbinding judicial [1 [ ] 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 arbitration [) [ ] Private arbitration scheduled for (date): [ ] Agreed to complete private arbitration by (date): t ] Private arbitration completed on (date): { ] ADR session not yet scheduled (6) Other (specify): ix] [ ] ADR session scheduled for (date): ] Agreed to complete ADR session by (date): [ ] ADR session completed on (date): CM-110 [Rev. July 1, 2014] CASE MANAGEMENT STATEMENT Page 30f5 CM-110 PLAINTIFF/PETITIONER: CAVALRY SPV T, LLC CASE NUMBER: 19CV347238 DEFENDANT/RESPONDENT: MOHAMMAD HARANDI 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. [ ] Bankruptey [ } 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 14a. b. [ ] Amotion 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 motion 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 are anticipated (specify): CM-140 fRev. July 4, 2014] CASE MANAGEMENT STATEMENT Page 4 of5 PLAINTIFF/PETITIONER: CAVALRY SPV I, LLC CASE NUMBER: 19CV347238 DEFENDANT/RESPONDENT: MOHAMMAD HARANDI 17. Economic Litigation a. [X] This is a limited civil case (i.¢., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90 through 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 nof apply to this case): 48. Other Issues [x ] The party or parties request that the following additional matters be considered or determined at the case management conference (specify): PLAINTIFF SUBMITTED ITS JUDGMENT PACKAGE TO COURT ON OR AROUND SEPTEMBER 9, 2019. PLAINTIFF RESPECTFULLY REQUESTS THE COURT TO CONTINUE THE HEARING 60-80 DAYS TO ALLOW TIME FOR THE COURT TO FILE AND ENTER JUDGMENT. 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): _0. | am completely familiar with this case and will be fully prepared to discuss the status of discovery and ADR, as weil as other issues taised 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: October 3, 2019 t ] Brian N. Winn ra M. Hoalst [ ] John 2, Gordon Jason M, Burrows [ ] Amit Paneja { ] Grace Gail Cara TYPE OR PRINT NAME (SIGNATARE OF PARTY OR PARTY'S ATTORNEY) TYPE OR PRINT NAME (SIGNATURE OF PARTY OR PARTY'S ATTORNEY) ] Additional signatures are attached PROOF OF SERVICE Iam employed in the County of Orange. My business address is 110 E. Wilshire Avenue, Suite 212, Fullerton, CA 92832, where the mailing occurred. I am over the age of 18 years and am not a party to this cause Iam readily familiar with the practices of Winn Law Group, A Professional Corporation for collection and processing of correspondence for mailing with the United States Postal Service. Such correspondence is deposited with the United States Postal Service the same day in the ordinary course of business. On October 3, 2019, I served the document in this action bearing the title: CASE MANAGEMENT STATEMENT by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Mohammad Harandi 3629 Copperfield Dr Apt 352 San Jose CA 95136-4028 I placed such envelope for collection and mailing on this date following ordinary business practices. Executed on October 3, 2019, at Fullerton, California. 1 declare under penalty of perjury under the laws of the State of California that the above is true and correct. UM rW2. Melina Roybal