Preview
F?! {‘5‘
:
:L..;:g_bM.11o
ATTORNEY 0R PARTY WITHOUT ATTORNEY
(Name, State Bar numbel, and address)‘ FOR COURT USE ONLY
THOMAS J. MURRAY, ESQ. 154245; DANIEL G. BAUCH
KERN, NODA, DEVINE & SEGAL
1388 SUTTER ST.. SUITE 600 SF, CA 94109
TELEPHONE No41 5—474-1900 41 5.474-0302
FAX N0. (Opaonau:
EMAIL ADDRESS
(Optional):
ATTORNEY FOR Defendant
(Name):
SUPERIOR COURT OF CALIFORNIA, COUNTY OF santa Clara
191
STREET ADDRESS N. First Street
MAILING ADDRESS
AND ZIPCODE:
CITY San Jose, 951 13
BRANCH NAME.
PLAINTIFF/PETITIONER: LaIani Nailau
DEFENDANT/RESPONDENT: Susan M. Clarke and Albert K. Clarke
CASE MANAGEMENT STATEMENT CASE NUMBER
(Check one): UNLIMITED CASE
(Amount demanded
E LIMITED CAss
(Amount demanded is$25,000
160v299824
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE isscheduled as follows:
Date: 7
9/1 2/1 Time: 11 AM Dept: 9 Div; Room:
Address of coun from the address above):
different
(if
Notice of Intent to Appear by Telephone,by (name): Daniel G. Balich
INSTRUCTIONS: All applicableboxes must be checked, and the specified information must be provided.
1. Party or parties (answerona):
a.
b. D This statement
This statement
is
is
Defendants Susan M. Clarke and Albert K. Clarke
submitted by party (name):
submitted jointly by parties (names):
F
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-compla/nanfs
only)
a.
b. E
The complaint was filed on (date):
The cross—oomplaint,
ifany,was filed on (date):
3.
a. E
Sewice
E
(tobe answe/ed by plaintiffs and cross-complainants
named
All parties
The
inthe complaint
named
only)
and cross-complaint have been served,
have appeared, or have been dismissed.
b1
(1) E
following parties inthe complaint or cross-complaint
have not been served (specify names and explain why
not):
(2) E have been served but have not appeared and have not been dismissed (specify names):
(3) E have had a default entered against them (specify names):
c, [j The may be added
following additional parties names, natwe ofinvolvement
(specify /'n
case.and date by which
theymay be served):
4, Description of ca_se
3r TYPe Of 0356'n complaint cross-complaint causes of action):
(Describe. including
Motor vehicle accident
mg. 1 «5
Fogdmvaggglgfgggggggw CASE MANAGEMENT STATEMENT cmgumggug
CM-1 1O
[Rev. July 1,201 1] www courts,sa gov
CM-11O
PLAINT!FF/PETITIONER: Lalani Nailau
C?ssEgs/Zagfigég
DEFENDANT/RESPONDENT: Susan M. Clarke and Albert K. Clarke
4. b. Provide a brief statement of the case. induding any damages.
(/fpersonal injury damages are sought, specify the injury and
damages claimed, including medical expenses (o date [indicate source and amount], estimated future medical expenses, lost
earnings to dale, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
was a passenger in Defendant‘s vehicle, which was broad sided by another vehicIe.
Plaintiff Plaintiff alleges
Defendant ran a stop sign.
D more space
(If is needed, checkthisbox and attach a page designated as Attachment
4b.)
5. Jury or nonjury
The
trial
party or parties request
requesting a jury
trial):
a jury
trial E a nonjurytrial, name ofeach party
(/fmore than one pany, provide the
6.
a‘
b.
E
Trial
m
date
The
No tn'al
has been set
trial
date has been
for (date):
set.This casewillbe readyfortrial months
within 12 of the date of the filing of the complaint
(if
not, explain):
The case isnot yet at issue.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain masons for unavailability):
1/8/18 — 1l19/18;1/22/18 — 1/28/18; 1/26/18 — 2/2/18; 2/20/18 — 2/28/18; 3/5/18 — 3/9/18; 3/9/18 — 3/16/18;
4/10/18 — 4/20/18; 4/30/18 — 5/4/18; 6/1 8/18— 6/29/18; 9/24/18 — 9/28/18; 11/19/18 — 11/23/18
7. Estimated length oftrial
The
a.
b.
m
party or parties estimate that the
E hours (short causes)
5'7
days (specify number):
(special):
take (check one):
trial will
Trialrepresenuflon be answered each
E
8. (to for party)
The party or parties be represented
will attrial [E by the attorney or party the caption
listed in by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
Ee. E-mail address:
Additional representation
isdescribedinAttachment 8.
g. Party represented:
9.
10.
D
Preference
This caseis preference (specify code section):
entitled to
dispute resolution (ADR)
Alternative
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
and community programs
court
(1)
case.
in this
For parties represented by counsel: Counsel has D has not
in mle 3.221 to the client and reviewed ADR options with the client
ADR
provided the infomation package identified
(2)For self-represented D
parties: Party has E: has not reviewed theADR informationpackage identified 3.221.
in rule
b.
(1) E
Referral to judicial arbihation or
This.m_atter
is
clvllaction mediation(ifavailable).
sub'ect to mandatoryjudicial arbitration under Code of Civil Procedure section 1141.11 or to civil
mediation under
action
ode of CiVII Procedure section 1775.3 because the amount in controversy does not exceed the
statutory
limit.
(2) E elects to refer this case to
Plaintiff
Procedure section 1141.11.
Civil
and agrees
judicial arbitration amount specified
to limit recovery to the inCode of
(3) D This case is exempt from judicial arbitration under rule 3.811
of the California Rules of Courtor from
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
action
civil
CM-HOIR" My 12°”!
CASE MANAGEMENT STATEMENT “mo"
CM-11O
PLAINTIFF/PETITIONER: CASE NUMBER
Lalani Nailau
1 GCV299824
DEFENDANT/RESPONDENTI Susan M. Clarke and Albert K. Clarke
10‘c. ADR process or processes
Indicate the in,have agreed
that the party or parties are willing to participate to participate or
in,
have alreadyparticipated
in(check all and provide
that apply the specified information):
The party or parties completingIf the case
the party or parties completing this form
in have agreed to
thisform are willing to participate
inor have already completed
an ADR process or processes,
participmein ADR
the following indicate the status of the processes (attach a copy of the parties' ADR
processes (checkallthat apply):stipulation):
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1)Mediation DUDE
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2)Settlement
conference
E DUDE
Settlement conference scheduled for (date):
Agreed to complete settlement conference by (dale):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
(3)Neutral evaluation D DUDE
Neutral evaluation scheduled for (date):
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
scheduled
Judicial arbitration not yet
(4) Nonbindingjudicial
arbitration
m DUDE
Agreed
scheduled for (date):
Judicial arbitration
to completejudicial arbitration
by (date):
completed on
Judicial arbitration (date):
Private arbitration not yet scheduled
(5) Binding private
arbitration
E DUDE]
Private arbitration scheduled for (date):
Agreed to complete private arbitration by (date):
Pn'vate arbitration completed
on (dale):
ADR session not yet scheduled
(6)Other(specify): D DUDE]
ADR session scheduled for (date):
Agreed to completeADR session by (date):
ADR completed on (date):
cmme [Rev
Juvy1
2011) P1993045
CASE MANAGEMENT STATEMENT
cM-JJQ
PLAINTIFF/PETITIONER: CASENUMBER:
La|ani Nanau
160V 299 8 24
DEFENDANT/RESPONDENT; Susan M. Clarke and Albert K. Clarke
11.Insurance
a4
b.
c, E
Insurance
Reservation ofrights:
Coverage issues
E
carrier,
Yes E No
GeiCO Insurance
any, for party filing this statement (name):
if
significantly affect resolution of this case (explain):
will
12. Jurisdiction
E
Status:
Bankruptcy E
any matters that
Indicate may affect the
Other
court's jurisdiction or processing of this
(specify):
case and describe the
status.
13.
a, D
Related cases, consolidation, and coordination
There are companion, underlying. or related cases.
(1)Name of case:
(2)Name of court:
(3)Case number
(4) Status:
D Additional cases are described
E Attachment 13a.
E
in
b, EAmotionto consolidate coordinate winbe filed by(nameparty):
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):
Possible motion to bifurcate and damages
liability
15.Other motions
The party or parties expect to file the foliowing motions before moving
(specify
trial ofmotion, and issues):
patty, type
Motion forSummary Adjudication on claims against Defendant A. Clarke.
Plaintiff's
16.
a.
b4
E
Discovery
The
The
have completed
party or parties
following discovery
will
alldiscovery.
be completed by the date specified (describeanticipated discovery):
all
Party Desaigtion Date
Defendants Written discovery to Plaintiff Complete
Deposition of Plaintiff Complete
Witness depositions TBD
Expert discovery TBD
c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CMAnotRevJuiyi
2011]
CASE MANAGEMENT STATEMENT P1994016
CM-110
PLAINTIFF/PETITwNER: Lalani Nailau CASE “UMBER-
Susan M. Clarke and Albert
1GCV299824
DEFENDANTRESPONDENT; K. Clarke
17‘
avE
Economic litigation
This is a limited civil case (i.e., the amount demanded is $25,000 or
less)and the economic procedures
litigation inCode
b.E of Civil Procedure sections 90-98 will apply to this wse.
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
E] The party or parties request that the following additional matters
be considered or determin ed case management
at the
conference (specify):
Defendant's insurance policy limits have been offered to the Plaintiff and Declaration
re Assets was provided to
Plaintiffs counsel evidencing Defendant's inability to contribute to
any settlement.
194
a.D
Meet and confer
The party have met and conferred with
or parties
of Court (ifnot, explain):
parties
all on subjects required by rule 3.724 of the California Rules
ail
'
b. After meeting and conferring as required by rule 3.724 of the California Rules of
Court, the parties agree on the following
(Specify):
number
20. Total ofpages attached any):
(if 0
Iam 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 muse management conference. inciuding the written authority of the party where
required.
Date:August 16. 2017
Daniele. Bench
y / ‘4 / 1.;
OR PRtNT NAME)
(TYPE
(SIGNATURE 0F PARTY
OR ATTORNEY)
OR PRtNT NAME)
(TYPE
E (SIGNATURE OF PARTY 0R ATTORNEY)
Additional signatures are attached.
CM-110 [Rev
July 1, 2011]
CASE MANAGEMENT STATEMENT P-o-
5d6
PROOF OF SERVICE BY MAIL
FELEE
£13 16 ii?
Nailau v. Clarke
‘
"
Santa Clara County Superior
‘
Coun Case No. 16CV2§9 4"
._'~’
"j'5‘
Ideclare that:
Iam employed in San Francisco County, California. I am over the age of 18 years and
not a party to the within cause; my business address is 1388 Sutter Street, Suite 600, San
Francisco, California 94109.
On the date set forth below, I served a copy of the foregoing document by mail by
placing the same in an envelope, sealing, fully preparing postage thereon, and depositing said
envelope in the U.S. Mail at San Francisco, California. Said envelope was addressed as follows:
Mailed to:
Richard E. Eichenbaum, Esq.
Dan C. Schaar, Esq.
Caputo & Van Der Walde LLP
51 E. Campbell Avenue, Suite 120
Campbell, CA 95008
Attorneyfor PlaintifllALANI NA ILA U
Tel: (408) 733-0100
Fax: (408) 733-0123
Email: ree@vanderwalde.com
dcs@vanderwalde. com
Documents mailed:
DEFENDANTS SUSAN M. CLARKE AND ALBERT K. CLARKE’S CASE
MANAGEMENT STATEMENT
I declare under penalty of pexjury that the foregoing is true and ‘correct, and that this
declaration was executed on August 2017 San Francisco, California.
CmV
16, at
‘>
Signed:
CINDY voorw L/
Preview
F?! {‘5‘ : :L..;:g_bM.11o ATTORNEY 0R PARTY WITHOUT ATTORNEY (Name, State Bar numbel, and address)‘ FOR COURT USE ONLY THOMAS J. MURRAY, ESQ. 154245; DANIEL G. BAUCH KERN, NODA, DEVINE & SEGAL 1388 SUTTER ST.. SUITE 600 SF, CA 94109 TELEPHONE No41 5—474-1900 41 5.474-0302 FAX N0. (Opaonau: EMAIL ADDRESS (Optional): ATTORNEY FOR Defendant (Name): SUPERIOR COURT OF CALIFORNIA, COUNTY OF santa Clara 191 STREET ADDRESS N. First Street MAILING ADDRESS AND ZIPCODE: CITY San Jose, 951 13 BRANCH NAME. PLAINTIFF/PETITIONER: LaIani Nailau DEFENDANT/RESPONDENT: Susan M. Clarke and Albert K. Clarke CASE MANAGEMENT STATEMENT CASE NUMBER (Check one): UNLIMITED CASE (Amount demanded E LIMITED CAss (Amount demanded is$25,000 160v299824 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE isscheduled as follows: Date: 7 9/1 2/1 Time: 11 AM Dept: 9 Div; Room: Address of coun from the address above): different (if Notice of Intent to Appear by Telephone,by (name): Daniel G. Balich INSTRUCTIONS: All applicableboxes must be checked, and the specified information must be provided. 1. Party or parties (answerona): a. b. D This statement This statement is is Defendants Susan M. Clarke and Albert K. Clarke submitted by party (name): submitted jointly by parties (names): F 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-compla/nanfs only) a. b. E The complaint was filed on (date): The cross—oomplaint, ifany,was filed on (date): 3. a. E Sewice E (tobe answe/ed by plaintiffs and cross-complainants named All parties The inthe complaint named only) and cross-complaint have been served, have appeared, or have been dismissed. b1 (1) E following parties inthe complaint or cross-complaint have not been served (specify names and explain why not): (2) E have been served but have not appeared and have not been dismissed (specify names): (3) E have had a default entered against them (specify names): c, [j The may be added following additional parties names, natwe ofinvolvement (specify /'n case.and date by which theymay be served): 4, Description of ca_se 3r TYPe Of 0356'n complaint cross-complaint causes of action): (Describe. including Motor vehicle accident mg. 1 «5 Fogdmvaggglgfgggggggw CASE MANAGEMENT STATEMENT cmgumggug CM-1 1O [Rev. July 1,201 1] www courts,sa gov CM-11O PLAINT!FF/PETITIONER: Lalani Nailau C?ssEgs/Zagfigég DEFENDANT/RESPONDENT: Susan M. Clarke and Albert K. Clarke 4. b. Provide a brief statement of the case. induding any damages. (/fpersonal injury damages are sought, specify the injury and damages claimed, including medical expenses (o date [indicate source and amount], estimated future medical expenses, lost earnings to dale, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) was a passenger in Defendant‘s vehicle, which was broad sided by another vehicIe. Plaintiff Plaintiff alleges Defendant ran a stop sign. D more space (If is needed, checkthisbox and attach a page designated as Attachment 4b.) 5. Jury or nonjury The trial party or parties request requesting a jury trial): a jury trial E a nonjurytrial, name ofeach party (/fmore than one pany, provide the 6. a‘ b. E Trial m date The No tn'al has been set trial date has been for (date): set.This casewillbe readyfortrial months within 12 of the date of the filing of the complaint (if not, explain): The case isnot yet at issue. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain masons for unavailability): 1/8/18 — 1l19/18;1/22/18 — 1/28/18; 1/26/18 — 2/2/18; 2/20/18 — 2/28/18; 3/5/18 — 3/9/18; 3/9/18 — 3/16/18; 4/10/18 — 4/20/18; 4/30/18 — 5/4/18; 6/1 8/18— 6/29/18; 9/24/18 — 9/28/18; 11/19/18 — 11/23/18 7. Estimated length oftrial The a. b. m party or parties estimate that the E hours (short causes) 5'7 days (specify number): (special): take (check one): trial will Trialrepresenuflon be answered each E 8. (to for party) The party or parties be represented will attrial [E by the attorney or party the caption listed in by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: Ee. E-mail address: Additional representation isdescribedinAttachment 8. g. Party represented: 9. 10. D Preference This caseis preference (specify code section): entitled to dispute resolution (ADR) Alternative 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 and community programs court (1) case. in this For parties represented by counsel: Counsel has D has not in mle 3.221 to the client and reviewed ADR options with the client ADR provided the infomation package identified (2)For self-represented D parties: Party has E: has not reviewed theADR informationpackage identified 3.221. in rule b. (1) E Referral to judicial arbihation or This.m_atter is clvllaction mediation(ifavailable). sub'ect to mandatoryjudicial arbitration under Code of Civil Procedure section 1141.11 or to civil mediation under action ode of CiVII Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) E elects to refer this case to Plaintiff Procedure section 1141.11. Civil and agrees judicial arbitration amount specified to limit recovery to the inCode of (3) D This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): action civil CM-HOIR" My 12°”! CASE MANAGEMENT STATEMENT “mo" CM-11O PLAINTIFF/PETITIONER: CASE NUMBER Lalani Nailau 1 GCV299824 DEFENDANT/RESPONDENTI Susan M. Clarke and Albert K. Clarke 10‘c. ADR process or processes Indicate the in,have agreed that the party or parties are willing to participate to participate or in, have alreadyparticipated in(check all and provide that apply the specified information): The party or parties completingIf the case the party or parties completing this form in have agreed to thisform are willing to participate inor have already completed an ADR process or processes, participmein ADR the following indicate the status of the processes (attach a copy of the parties' ADR processes (checkallthat apply):stipulation): Mediation session not yet scheduled Mediation session scheduled for (date): (1)Mediation DUDE Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2)Settlement conference E DUDE Settlement conference scheduled for (date): Agreed to complete settlement conference by (dale): Settlement conference completed on (date): Neutral evaluation not yet scheduled (3)Neutral evaluation D DUDE Neutral evaluation scheduled for (date): Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): scheduled Judicial arbitration not yet (4) Nonbindingjudicial arbitration m DUDE Agreed scheduled for (date): Judicial arbitration to completejudicial arbitration by (date): completed on Judicial arbitration (date): Private arbitration not yet scheduled (5) Binding private arbitration E DUDE] Private arbitration scheduled for (date): Agreed to complete private arbitration by (date): Pn'vate arbitration completed on (dale): ADR session not yet scheduled (6)Other(specify): D DUDE] ADR session scheduled for (date): Agreed to completeADR session by (date): ADR completed on (date): cmme [Rev Juvy1 2011) P1993045 CASE MANAGEMENT STATEMENT cM-JJQ PLAINTIFF/PETITIONER: CASENUMBER: La|ani Nanau 160V 299 8 24 DEFENDANT/RESPONDENT; Susan M. Clarke and Albert K. Clarke 11.Insurance a4 b. c, E Insurance Reservation ofrights: Coverage issues E carrier, Yes E No GeiCO Insurance any, for party filing this statement (name): if significantly affect resolution of this case (explain): will 12. Jurisdiction E Status: Bankruptcy E any matters that Indicate may affect the Other court's jurisdiction or processing of this (specify): case and describe the status. 13. a, D Related cases, consolidation, and coordination There are companion, underlying. or related cases. (1)Name of case: (2)Name of court: (3)Case number (4) Status: D Additional cases are described E Attachment 13a. E in b, EAmotionto consolidate coordinate winbe filed by(nameparty): 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): Possible motion to bifurcate and damages liability 15.Other motions The party or parties expect to file the foliowing motions before moving (specify trial ofmotion, and issues): patty, type Motion forSummary Adjudication on claims against Defendant A. Clarke. Plaintiff's 16. a. b4 E Discovery The The have completed party or parties following discovery will alldiscovery. be completed by the date specified (describeanticipated discovery): all Party Desaigtion Date Defendants Written discovery to Plaintiff Complete Deposition of Plaintiff Complete Witness depositions TBD Expert discovery TBD c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CMAnotRevJuiyi 2011] CASE MANAGEMENT STATEMENT P1994016 CM-110 PLAINTIFF/PETITwNER: Lalani Nailau CASE “UMBER- Susan M. Clarke and Albert 1GCV299824 DEFENDANTRESPONDENT; K. Clarke 17‘ avE Economic litigation This is a limited civil case (i.e., the amount demanded is $25,000 or less)and the economic procedures litigation inCode b.E of Civil Procedure sections 90-98 will apply to this wse. 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 E] The party or parties request that the following additional matters be considered or determin ed case management at the conference (specify): Defendant's insurance policy limits have been offered to the Plaintiff and Declaration re Assets was provided to Plaintiffs counsel evidencing Defendant's inability to contribute to any settlement. 194 a.D Meet and confer The party have met and conferred with or parties of Court (ifnot, explain): parties all on subjects required by rule 3.724 of the California Rules ail ' b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (Specify): number 20. Total ofpages attached any): (if 0 Iam 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 muse management conference. inciuding the written authority of the party where required. Date:August 16. 2017 Daniele. Bench y / ‘4 / 1.; OR PRtNT NAME) (TYPE (SIGNATURE 0F PARTY OR ATTORNEY) OR PRtNT NAME) (TYPE E (SIGNATURE OF PARTY 0R ATTORNEY) Additional signatures are attached. CM-110 [Rev July 1, 2011] CASE MANAGEMENT STATEMENT P-o- 5d6 PROOF OF SERVICE BY MAIL FELEE £13 16 ii? Nailau v. Clarke ‘ " Santa Clara County Superior ‘ Coun Case No. 16CV2§9 4" ._'~’ "j'5‘ Ideclare that: Iam employed in San Francisco County, California. I am over the age of 18 years and not a party to the within cause; my business address is 1388 Sutter Street, Suite 600, San Francisco, California 94109. On the date set forth below, I served a copy of the foregoing document by mail by placing the same in an envelope, sealing, fully preparing postage thereon, and depositing said envelope in the U.S. Mail at San Francisco, California. Said envelope was addressed as follows: Mailed to: Richard E. Eichenbaum, Esq. Dan C. Schaar, Esq. Caputo & Van Der Walde LLP 51 E. Campbell Avenue, Suite 120 Campbell, CA 95008 Attorneyfor PlaintifllALANI NA ILA U Tel: (408) 733-0100 Fax: (408) 733-0123 Email: ree@vanderwalde.com dcs@vanderwalde. com Documents mailed: DEFENDANTS SUSAN M. CLARKE AND ALBERT K. CLARKE’S CASE MANAGEMENT STATEMENT I declare under penalty of pexjury that the foregoing is true and ‘correct, and that this declaration was executed on August 2017 San Francisco, California. CmV 16, at ‘> Signed: CINDY voorw L/