Preview
CN-110
‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
.lohn M. Sarich (SBN 125223) Kaifivn QO. Chana (SRN 253289)
Parker Ibrahim & Berg LLP
1695 Town Center Drive, 16th Floor, Costa Mesa, CA 92626
TELEPHONE No.: (714) 361-9550 FAXNO. (optona):(714) 784-4190
E-MAIL ADDRESS (Optional)
ATTORNEY FOR (Name: Deutsche Bank National Trust Co. as Trustee for WaMu
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA
street aopress: 191 N. First Street
MALLING ADDRESS: 191 N. First Street
CITY AND ZIPCODE: San Jose 95113.
BRANCH NAME: Downtown Superior Court
PLAINTIFF/PETITIONER: DEUTSCHE BANK NATIONAL TRUST CO.
DEFENDANT/RESPONDENT: RAYMOND M. GRAY, SR., ET AL. i
‘
CASE MANAGEMENT STATEMENT i ‘CASE NUMBER:
(Check one): [4] UNLIMITED CASE [- umitep case | 170V312433
(Amount demanded (Amount demanded is $25,000 !
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: June 19, 2018 Time: 10:00 a.m. Dept.: 06 Div.: Room:
Address of court (if different from the address above):
Lv] Notice of Intent to Appear by Telephone, by (name): Deutsche Bank National Trust Co. as Trustee for WaMu
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
This statement is submitted by party (name): Deutsche Bank National Trust Co. as Trustee for WaMu
6 EI 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): June 29, 2017
vb. J 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. [__] The following parties named in the complaint or cross-complaint
(1) [1 have not been served (specify names and explain why not):
(2) have been served but have not appeared and have not been dismissed (specify names):
(3) [1 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):
Description of case
a Type of case in complaint CC) cross-complaint (Describe, includitig causes of action):
1) Cancellation of Instruments; 2) Slander of Title; 3) Declaratory and Injunctive Relief; 4) Appointment of
Receiver to Enforce Judgment; and 5) Appointment of Receiver to Enforce Right to inspect Property.
Page 1 of 5
Form Adapted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Cour,
Judicial Couneil of Califemia mules 3.720-3.730
(CM-140 (Rev, July 1, 2011] voww.courts.ca. gov
:
CM-110
PLAINTIFF/PETITIONER: DEUTSCHE BANK NATIONAL TRUST CO. CASE NUMBER:
17C0V312433
EFENDANT/RESPONDENT: RAYMOND M. GRAY, SR., ET AL.
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
earings to date, and estimated future lost earings. If equitable relief is sought, describe the nature of the relief.)
In 2009, Plaintiff became the owner of the Property following a foreclosure sale and a Lawsuit followed. On or
about October 29, 2014, the parties to the Lawsuit, including Plaintiff and Defendants, entered into a settlement
that provided for the entry of judgment. Defendants failed to deliver possession of the Property, and instead
recorded an unauthorized Grant Deed purporting to convey title from T. Gray and Ancheta to R. Gray.
[1 df more space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request C4) a jury trial [va nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a. [_] The trial has been set for (date):
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):
Trials: 7/18/18; 7/31/18; 8/6/18; 8/28/18; 10/9/18; 10/29/18; 12/18/18; 1/25/19; and 5/6/19
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [¥} days (specify number): 3-5
b. | 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 [] by the following:
a. Attorney:
b. Firm:
¢., Address: .
d. Telephone number: f 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 available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel has [_] has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party [5 has £1 has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
a)
mediation under
statutory limit.
ee
This matter is sub| ject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
de of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
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.
@ This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action
mediation under de of Civil Procedure section 1775 et seq. (specify exemption):
‘OM-119 [Rev. July 1, 20147 CASE MANAGEMENT STATEMENT Page 20f5
CM-110
Fs PLAINTIFF/PETITIONER:; DEUTSGHE BANK NATIONAL TRUST CO. [CASE NUMBER:
170V312433
FENDANT/RESPONDENT: RAYMOND M. GRAY, SR., 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 ail that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
Participate in the following ADR indicate the status of the processes (attach a copy of the parties’ ADR
Processes (check ail that apply): | stioutation):
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduted
(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
(8) Binding private Private arbitration scheduled for (date);
arbitration
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
CMA110 fRev. July
+, 2047] Page 30f 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: DEUTSCHE BANK NATIONAL TRUST CO. CASE NUMBER:
Le
17CV31 2433
DEFENDANT/RESPONDENT: RAYMOND M. GRAY, SR., ET AL.
11. Insurance
a. i__J Insurance canter, if any, for party filing this statement (name):
b. Reservation of rights: Yes [1 No
“. L__] Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
[-) Bankruptcy [_] Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. [42] There are companion, underlying, or related cases.
{1) Name of case: Ancheta, et al. v. Deutsche Bank National Trust Company
(2) Name of court: Santa Clara Superior Court
(3) Case number: 110CV179008.
{4) Status: Judgment entered on April 29, 2016
[7] Additional cases are described in Attachment 13a.
b. L_] Amation to [2] consolidate [) coordinate will be filed by (name party):
14, Bifurcation
[J The party or parties intend to file a motion for an order bifurcating, severing, ar coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15, Other motions
[1] The party or parties expect to file the folowing motions before trial (specify moving party, type of motion, and issues):
Motion for Summary Judgment.
16. Discovery
a. The party or parties have completed all discovery.
b. L¥_| The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Deutsche Bank National Trust Co. as Written discovery TBD*
Trustee for WaMu Depositions TBD*
“Defendants have recently been
represented by new counsel
c. [__] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
€M-410 [Rev. July
#, 2071] CASE MANAGEMENT STATEMENT Page 4 of §
CM-110
PLAINTIFF/PETITIONER: DEUTSCHE BANK NATIONAL TRUST GO. CASE NUMBER:
|
17GV312433
DEFENDANT/RESPONDENT: RAYMOND M. GRAY, SR., ET AL.
17. Economic litigation
a. [__] 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 90-98 will apply to this case.
b. L__] 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
{i 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 ail 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 fallowing
(specify):
20. Total number of pages attached (if any): 1
| am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as wall 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: June 4, 2018
Kaitlyn Q. Chang > i
(TYPE OR PRINT NAME) Y (SIGNATURE OF PARTY ORATIORNEY)
(TYPE OR PRINT NAME}
> {SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
M-110 [Rev. July 1, 201] Page 5 of 5
CASE MANAGEMENT STATEMENT
MC-025
SHORT TITLE: CASE NUMBER:
| DEUTSCHE BANK NATIONAL TRUST CO. v. GRAY 170V312433
ATTACHMENT (Number): 13a.
(This Attachment may be used with any Judicial Council form.)
[Attachment 13a.
1) Name of Case: In re: Raymond M. Gray
2) Name of Court: United States Bankruptcy Court, Northern District of California
3) Case Number: 16-51752 MEH
4) Status: Dismissed on September 30, 2016
1) Name of Case: Ancheta v. Deutsche Bank National Trust Company
2) Name of Court: California Court of Appeal, 6th Appellate District
3) Case Number: H044032
4) Status: Pending. Record preparation proceeding. Record on Appeal filed 5/22/18. Appellant's opening brief
due 7/2/18.
(if the item that this Attachment concems is made under penalty of perjury, all statements in this Page 6 of 6
Aitachment are made under penalty of perjury.)
(Add pages as required)
“Form Approved for Optional Use ATTACHMENT www. courtingo.ca.gow
Judicia! Council of California
MC-025 [Rev. July 1, 2003] to Judicial Council Form
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF ORANGE
Deutsche Bank National Trust Co. v. Raymond Gray, Sr., et al.
Santa Clara Superior Court Case No.: 17CV312433
Tam employed in the County of Orange, State of California. I am over the age of 18 years and not a
party to the within action. My business address is Parker Ibrahim & Berg LLC, 695 Town Center
Drive, 16" Floor, Costa Mesa, CA 92626.
On June 4, 2 018, I served the foregoing document described as CASE
MANAGEMENT STATEMENT on the interested parties in this action.
by placing the original and/or a true copy thereof enclosed in (a) sealed envelope(s),
addressed as follows:
BY REGULAR MAIL: I deposited such envelope in the mail at 695 Town Center Drive,
10 Costa Mesa, California. The envelope was mailed with postage thereon fully prepaid.
I am “readily familiar” with the firm’s practice of collection and processing correspondence
HW for mailing. It is deposited with the U.S. Postal Service on that same day in the ordinary
course of business. I am aware that on motion of the party served, service is presumed invalid
12 if postal cancellation date or postage meter date is more than one (1) day after date of deposit
for mailing in affidavit.
13
BY THE ACT OF FILING OR SERVICE, THAT THE DOCUMENT WAS
14 PRODUCED ON PAPER PURCHASED AS RECYCLED
15 BY FACSIMILE MACHINE: I Tele-Faxed a copy of the original document to the above
facsimile numbers.
16
BY OVERNIGHT MAIL: I deposited such documents at the Golden State Overnight or
17 Federal Express Drop Box located at 695 Town Center Drive, Costa Mesa, CA 92626. The
envelope was deposited with delivery fees thereon fully prepaid.
18
BY ELECTRONIC MAIL: | served the foregoing document by electronic mail to the email
19 address(es) listed on the service list.
20 BY PERSONAL SERVICE: | caused such envelope(s) to be delivered by hand to the above
addressee(s).
21
(State) I declare under penalty of perjury under the laws of the State of California that the
22 foregoing is true and correct.
23 (Federal) I declare that I am employed in the office of a member of the Bar of this Court, at
whose direction the service was made.
24
Executed on June 4, 2018, at Costa Mesa, Ssosre Onn
25
26
Laura Bremmer
27
28
{90310981 DOCK |
PROOF OF SERVICE
203.0425
SERVICE LIST
Deutsche Bank National Trust Co. v. Raymond Gray. Sr., et at.
Santa Claia Superior Court Case No.: 170V312433
Law Offices of Bruce Tichinin, Inc. Attorneys for Defendants, Raymond M. Gray,
Bruce Tichinin, Esq. Sr., Timothy A. Gray and Elizabeth P. Ancheta
17150 Wedgewood Avenue
Los. Gatos, CA 95032
10
I
12
13
14
15
16
17
18
19
21
77
ou
23
24
25
26
28
40031098) DOCK |
003.0415
PROOF OF SERVICE
Preview
CN-110 ‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY .lohn M. Sarich (SBN 125223) Kaifivn QO. Chana (SRN 253289) Parker Ibrahim & Berg LLP 1695 Town Center Drive, 16th Floor, Costa Mesa, CA 92626 TELEPHONE No.: (714) 361-9550 FAXNO. (optona):(714) 784-4190 E-MAIL ADDRESS (Optional) ATTORNEY FOR (Name: Deutsche Bank National Trust Co. as Trustee for WaMu SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA street aopress: 191 N. First Street MALLING ADDRESS: 191 N. First Street CITY AND ZIPCODE: San Jose 95113. BRANCH NAME: Downtown Superior Court PLAINTIFF/PETITIONER: DEUTSCHE BANK NATIONAL TRUST CO. DEFENDANT/RESPONDENT: RAYMOND M. GRAY, SR., ET AL. i ‘ CASE MANAGEMENT STATEMENT i ‘CASE NUMBER: (Check one): [4] UNLIMITED CASE [- umitep case | 170V312433 (Amount demanded (Amount demanded is $25,000 ! exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: June 19, 2018 Time: 10:00 a.m. Dept.: 06 Div.: Room: Address of court (if different from the address above): Lv] Notice of Intent to Appear by Telephone, by (name): Deutsche Bank National Trust Co. as Trustee for WaMu INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): This statement is submitted by party (name): Deutsche Bank National Trust Co. as Trustee for WaMu 6 EI 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): June 29, 2017 vb. J 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. [__] The following parties named in the complaint or cross-complaint (1) [1 have not been served (specify names and explain why not): (2) have been served but have not appeared and have not been dismissed (specify names): (3) [1 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): Description of case a Type of case in complaint CC) cross-complaint (Describe, includitig causes of action): 1) Cancellation of Instruments; 2) Slander of Title; 3) Declaratory and Injunctive Relief; 4) Appointment of Receiver to Enforce Judgment; and 5) Appointment of Receiver to Enforce Right to inspect Property. Page 1 of 5 Form Adapted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Cour, Judicial Couneil of Califemia mules 3.720-3.730 (CM-140 (Rev, July 1, 2011] voww.courts.ca. gov : CM-110 PLAINTIFF/PETITIONER: DEUTSCHE BANK NATIONAL TRUST CO. CASE NUMBER: 17C0V312433 EFENDANT/RESPONDENT: RAYMOND M. GRAY, SR., ET AL. 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 earings to date, and estimated future lost earings. If equitable relief is sought, describe the nature of the relief.) In 2009, Plaintiff became the owner of the Property following a foreclosure sale and a Lawsuit followed. On or about October 29, 2014, the parties to the Lawsuit, including Plaintiff and Defendants, entered into a settlement that provided for the entry of judgment. Defendants failed to deliver possession of the Property, and instead recorded an unauthorized Grant Deed purporting to convey title from T. Gray and Ancheta to R. Gray. [1 df more space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request C4) a jury trial [va nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a. [_] The trial has been set for (date): 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): Trials: 7/18/18; 7/31/18; 8/6/18; 8/28/18; 10/9/18; 10/29/18; 12/18/18; 1/25/19; and 5/6/19 Estimated length of trial The party or parties estimate that the trial will take (check one): a. [¥} days (specify number): 3-5 b. | 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 [] by the following: a. Attorney: b. Firm: ¢., Address: . d. Telephone number: f 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 available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel has [_] has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party [5 has £1 has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). a) mediation under statutory limit. ee This matter is sub| ject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action de of Civil Procedure section 1775.3 because the amount in controversy does not exceed the 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. @ This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action mediation under de of Civil Procedure section 1775 et seq. (specify exemption): ‘OM-119 [Rev. July 1, 20147 CASE MANAGEMENT STATEMENT Page 20f5 CM-110 Fs PLAINTIFF/PETITIONER:; DEUTSGHE BANK NATIONAL TRUST CO. [CASE NUMBER: 170V312433 FENDANT/RESPONDENT: RAYMOND M. GRAY, SR., 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 ail that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, Participate in the following ADR indicate the status of the processes (attach a copy of the parties’ ADR Processes (check ail that apply): | stioutation): Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduted (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 (8) Binding private Private arbitration scheduled for (date); arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CMA110 fRev. July +, 2047] Page 30f 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: DEUTSCHE BANK NATIONAL TRUST CO. CASE NUMBER: Le 17CV31 2433 DEFENDANT/RESPONDENT: RAYMOND M. GRAY, SR., ET AL. 11. Insurance a. i__J Insurance canter, if any, for party filing this statement (name): b. Reservation of rights: Yes [1 No “. L__] Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. [-) Bankruptcy [_] Other (specify): Status: 13. Related cases, consolidation, and coordination a. [42] There are companion, underlying, or related cases. {1) Name of case: Ancheta, et al. v. Deutsche Bank National Trust Company (2) Name of court: Santa Clara Superior Court (3) Case number: 110CV179008. {4) Status: Judgment entered on April 29, 2016 [7] Additional cases are described in Attachment 13a. b. L_] Amation to [2] consolidate [) coordinate will be filed by (name party): 14, Bifurcation [J The party or parties intend to file a motion for an order bifurcating, severing, ar coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15, Other motions [1] The party or parties expect to file the folowing motions before trial (specify moving party, type of motion, and issues): Motion for Summary Judgment. 16. Discovery a. The party or parties have completed all discovery. b. L¥_| The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Deutsche Bank National Trust Co. as Written discovery TBD* Trustee for WaMu Depositions TBD* “Defendants have recently been represented by new counsel c. [__] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): €M-410 [Rev. July #, 2071] CASE MANAGEMENT STATEMENT Page 4 of § CM-110 PLAINTIFF/PETITIONER: DEUTSCHE BANK NATIONAL TRUST GO. CASE NUMBER: | 17GV312433 DEFENDANT/RESPONDENT: RAYMOND M. GRAY, SR., ET AL. 17. Economic litigation a. [__] 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 90-98 will apply to this case. b. L__] 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 {i 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 ail 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 fallowing (specify): 20. Total number of pages attached (if any): 1 | am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as wall 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: June 4, 2018 Kaitlyn Q. Chang > i (TYPE OR PRINT NAME) Y (SIGNATURE OF PARTY ORATIORNEY) (TYPE OR PRINT NAME} > {SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. M-110 [Rev. July 1, 201] Page 5 of 5 CASE MANAGEMENT STATEMENT MC-025 SHORT TITLE: CASE NUMBER: | DEUTSCHE BANK NATIONAL TRUST CO. v. GRAY 170V312433 ATTACHMENT (Number): 13a. (This Attachment may be used with any Judicial Council form.) [Attachment 13a. 1) Name of Case: In re: Raymond M. Gray 2) Name of Court: United States Bankruptcy Court, Northern District of California 3) Case Number: 16-51752 MEH 4) Status: Dismissed on September 30, 2016 1) Name of Case: Ancheta v. Deutsche Bank National Trust Company 2) Name of Court: California Court of Appeal, 6th Appellate District 3) Case Number: H044032 4) Status: Pending. Record preparation proceeding. Record on Appeal filed 5/22/18. Appellant's opening brief due 7/2/18. (if the item that this Attachment concems is made under penalty of perjury, all statements in this Page 6 of 6 Aitachment are made under penalty of perjury.) (Add pages as required) “Form Approved for Optional Use ATTACHMENT www. courtingo.ca.gow Judicia! Council of California MC-025 [Rev. July 1, 2003] to Judicial Council Form PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF ORANGE Deutsche Bank National Trust Co. v. Raymond Gray, Sr., et al. Santa Clara Superior Court Case No.: 17CV312433 Tam employed in the County of Orange, State of California. I am over the age of 18 years and not a party to the within action. My business address is Parker Ibrahim & Berg LLC, 695 Town Center Drive, 16" Floor, Costa Mesa, CA 92626. On June 4, 2 018, I served the foregoing document described as CASE MANAGEMENT STATEMENT on the interested parties in this action. by placing the original and/or a true copy thereof enclosed in (a) sealed envelope(s), addressed as follows: BY REGULAR MAIL: I deposited such envelope in the mail at 695 Town Center Drive, 10 Costa Mesa, California. The envelope was mailed with postage thereon fully prepaid. I am “readily familiar” with the firm’s practice of collection and processing correspondence HW for mailing. It is deposited with the U.S. Postal Service on that same day in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid 12 if postal cancellation date or postage meter date is more than one (1) day after date of deposit for mailing in affidavit. 13 BY THE ACT OF FILING OR SERVICE, THAT THE DOCUMENT WAS 14 PRODUCED ON PAPER PURCHASED AS RECYCLED 15 BY FACSIMILE MACHINE: I Tele-Faxed a copy of the original document to the above facsimile numbers. 16 BY OVERNIGHT MAIL: I deposited such documents at the Golden State Overnight or 17 Federal Express Drop Box located at 695 Town Center Drive, Costa Mesa, CA 92626. The envelope was deposited with delivery fees thereon fully prepaid. 18 BY ELECTRONIC MAIL: | served the foregoing document by electronic mail to the email 19 address(es) listed on the service list. 20 BY PERSONAL SERVICE: | caused such envelope(s) to be delivered by hand to the above addressee(s). 21 (State) I declare under penalty of perjury under the laws of the State of California that the 22 foregoing is true and correct. 23 (Federal) I declare that I am employed in the office of a member of the Bar of this Court, at whose direction the service was made. 24 Executed on June 4, 2018, at Costa Mesa, Ssosre Onn 25 26 Laura Bremmer 27 28 {90310981 DOCK | PROOF OF SERVICE 203.0425 SERVICE LIST Deutsche Bank National Trust Co. v. Raymond Gray. Sr., et at. Santa Claia Superior Court Case No.: 170V312433 Law Offices of Bruce Tichinin, Inc. Attorneys for Defendants, Raymond M. Gray, Bruce Tichinin, Esq. Sr., Timothy A. Gray and Elizabeth P. Ancheta 17150 Wedgewood Avenue Los. Gatos, CA 95032 10 I 12 13 14 15 16 17 18 19 21 77 ou 23 24 25 26 28 40031098) DOCK | 003.0415 PROOF OF SERVICE