Preview
t
CM-110
[IWORNEY 0R (Nam
PARTV WITHOUT ATTORNEY am amass)-
ear number.
Stare
THOMAS J. MURRAY, ESQ. 154245; DANIEL G. BALICH
KERN, NODA, DEVINE & SEGAL
1388 SUTTER ST., SUITE 600 SF, CA 94109
TELEPHONE N0 41 5-474-1 900 FAX no 4 1 5-474-0302
(Optional):
ADDRESS
E-MAI‘L (Oph'ana!)
ATTORNEY FOR (Name;
Defendant
SUPERIOR COURT 0F CALIFORNIA, COUNTY OF santa Clara
STREET ADDRESS191 N.First Street
MAILING ADDRESS
AND
CITY CODE:
Zip
San Jose, 951 13
BRANCH NAME:
PLAINTIFF/PETITIONER; Latani Nailau
DEFENDANTIRESPONDENT: Susan M. Clarke and Albert K. Clarke
CASE MANAGEMENT STATEMENT CASE NUMBER
(Check one): UNLIMITED CASE
(Amount demanded
E LIMITED CASE
(Amount demanded is$25,000
160v299824
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE isscheduled as follows:
Date: 1/10/1 7 Time: 9:00 AM Dept: 9 Div.: Room:
Address of court different from the
(if address above):
Notice of Intent to Appear by Telephone, by (name): Daniel G, Balich
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1, Party or parties (answer one):
a.
E
I
v’
| This statement
This statement
issubmitted by party fname): Defendants Susan
submitted jointly by parties (names):
M. Clarke and Albert K. Clarke
F AX
b. is
2. Complaint and cross-complaint be answered by plaintiffs and cross-comp/ainants only)
Y
(to
a. The complaint was filed on (date):
b. C] The cross-complaim. ifany.was on (date):
filed
3.
a1
b1
D
Service
E
(tobe answered by
AH
The
partiesnamed in
and cross—complainants
plaintiffs only)
the complaint and cross-complaint have been served.
named
foilowing parties inthe complaint or cross-complaint
have appeared, or have been dismissed.
(1) [:3 have not been served (specify names and explain why not):
(2) D have been served but have not appeared and have not been dismissed (specify names):
(3) D have had a them
default entered against (specify names):
c. C] The may be added
following additional parties names,
(specify nature of involvementIncase. and date by which
they may be served).
4, Description of case
a- Type Ofcase l" complaint cross—complaint (Describe, including causes ofaction):
Motor vehicle accident
Page1o! 5
Form Adopied
Mandatory Use
for
Como!
Juducza! of Cahfcrma
CASE MANAGEMENT STATEMENT Caé Rutes
ofCoon.
ruzes 3 720.3 .730
CM-HC 20:
[Rev July
t 13
wwwcourfs ca gov
CM-1 1O
CASE NUMBER
_
‘ PLAINTIFF/PETITIONER: Lalani Nailau
160v299824
DEFENDANT/RESPONDENT: Susan M. Clarke and Albert K. Clarke
4. b. (/fpersona/ injury damages are sought, specify the injury and
Provide a brief statement of the case. including any damages.
damages claimed, including medical expenses to date {indicate source and amount], estimated future medical expenses, lost
eamings to date,and estimated future lost earnings.
Ifequitable relief
is sought,describe the nature of the
relief.)
Plaintiffwas a passenger in Defendant's vehicie, which was broad sided by another vehicle. Plaintiff alleges
Defendant ran a stop sign.
more space box and attach a page designated as Attachment
'
I (If isneeded, check this 4b.)
5. Jury or nonjury trial
’
The pany or parties request a jury
trial I a nonjurytriaL (Ifmore than one name
pan‘y, provide the of each party
requesting a jury
tn'al):
6. Trialdate
av E] The has been set
trial for (date):
b No date has been set This case
trial be ready
will for within 12
trial months of the date of the filing of the complaint
(If
not, explain):
The case is not yet at issue.
c. Dates on which panies or attorneys will not be available for trial (specify dates and explain Ieasons for unavailability):
1/17/17 — 1/20/17; 2/16/17- 4/14/1 7 (set for 8 concurrent or overlapping trials over this period); 5/15/1 7 —
5/19/17; 5/30/17 —— 6/30/17; 7/24/17 — 8/3/17; 9/15/17 — 9/24/17; 1/26/18 — 2/2/18; 3/9/18 — 3/16/18
7. Estimated length of trial
The party or parties estimate that the take (check one):
tn‘al will
5‘7
a.
b. E days (specify number):
hours (short causes)(specify):
8‘
The
at
party or parties
Attorney:
will
be answered
Trial representation (to for
be represented attrial E
each party)
by the attorney or party the caption
listed in l
lby the following:
b. Firm:
c Address:
d. Telephone number: f. Fax number:
a
e E-mailaddress:
Additional representation
isdescribed lnAttachment 8.
gt Partyrepresented:
9.
10.
D
Preference
This caseis preference (specify code section):
entitled to
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
courtand community programs in thiscase
(1) Counsel
For parties represented by counsel: has [:3 has not provided theADR informationpackage identified
in rule ADR
3.221 to the client and reviewed options with the
client.
(2) For self—represented Party
parties: E has E has not reviewed the ADR information package identified 3.221.
in rule
b. Referral to judicial arbitration or civil action mediation
available).
(if
(1) E3 This matter is sub‘ect to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under ode of Civil Procedure section
1775.3 because the amount in controversy does not exceed the
statutorylimit.
(2)E Civil
case to
Plaintiff elects to refer this
Procedure section 1141 .111
and agrees
judicial arbitration recovery to the amount specified
to limit inCode of
(3)E: This case is exempt from judicial arbitration under rule 3.811
mediation under Code of Civil Procedure section
ot the California Rules of Courtor from
1775 et seq. (specify exemption):
action
civil
CM-“Mev Ju'w 2W CASE MANAGEMENT STATEMENT WM
CM-110
‘
PLAINTIFF/PETITIONER: CASE NUMBER:
LalaniNailau
DEFENDANT/RESPONDENT? 16CV299824
Susan M. Clarke and Afbert K. Clarke
10. c. ADR
Indicate the process or processes that the party or parties are wining to participate
in,have agreed to participate or
in,
have already participatedin {check all that apply and provide the specified information):
The party or parties completing If in the case have agreed to
the oarty or parties completing this form
thisform are wiltingto have already completed an ADR prowss or processes,
participate in or
ADR
participate in the foliowing indicate the status of the processes (attach a copy of the parties'ADR
processes {check allthat 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
Settlement Settlement conference scheduled for (date):
(2)
conference DUDE
Agreed to complete settlement conference by (date):
Settlement conference compieted on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutralevaluation DUDE
Agreed tocomptete neutral evaluation by
(date):
Neutral evaluation completed on (date):
scheduled
Judiciai arbitration not yet
Nonbinding judicial
scheduled
Judicial arbitration for (date):
(4)
arbitration
EDD!
Agreed tocomplete judicial arbitration
by (date):
compteted on
Judicial arbitration (date):
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
(5) Binding private
arbitration
DUDE
Agreed tocomplete privatearbitration
by (date):
on
Private arbitration completed (date):
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other(specify): DUDE
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-E TD 201
(Rev. Juiy
‘2‘
1] Page 3
of 5
CASE MANAGEMENT STATEMENT
CM:11_Q
~ CASENUMBER.
PLAINTIFF/PETITIONER: LalaniNauau
16CV299824
DEFENDANT/RESPONDENT; Susan M. C1arke and Albert K. Clarke
11.Insurance
a‘
b.
c. E
Insurance
Reservation of
carrier,
rights:
Coverage issues
D
if
will
Yes [a No
Geico Insurance
any, for party filing this statement (name):
significanfly affect resolution of this case (explain):
12. Jurisdiction
Indicate
:3
any matters
Bankruptcy E
thatmay
Other (specify):
case and describe the status.
affect the court's jurisdiction or processing of this
Status:
13.
a. a
Related cases, consolidation, and coordination
There are companion,
(1)Name of case:
undedying, or related cases.
(2)Name of court:
(3)Case number:
(4) Status:
b.
a
E
Additional cases are described
A motion to [:1
in
COHSO‘idate
Attachment 13a.
D coordinate willbe fited by (name pany):
14. Bifurcation
The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or
causes of
moving party, type of motion,
action (specify and reasons):
Possible motion to bifurcate liability and damages
15.Other motions
The party or parties expect to file the following motions before moving pafly, type ofmotion, and issues):
(specify
trial
Motion to Strike PuniQtive Damages 0n catendar for 1/10/17
16. Discovery
a. C] The have completed an discovery.
party or parties
b. The following discovery
willbe completed by the date specified(describeallanticipated discovery):
Party Descrigtion Date
’
Defendants Written discovery t0 Plaintiff January, 2017
Deposition of Plaintiff January 25, 201 7
Witness depositions March 2017
Expert discovery TBD
c‘ [j The including issues regarding the discovery of electronically stored information, are
following discovery issues.
anticipated(specify):
CM~l EGIREV.
July
1,20H]
CASE MANAGEMENT STATEMENT P3924015
CM-110
-
PLAINTIFF/PETITIONER: LalaniNailau CASENWBER-
" 16CV29 98 24
DEFENDANT/RESPONDENT' susan M Clarke and A|bert K C'arke
17‘
a. a
Economic litigation
This isa limited
Prowdure
of Civil
civi!case (i‘eq the amount demanded is$25000
sections 90-98 will apply to this case.
and the economic
or less) procedures
litigation in Code
b, C: This isa case and a motion to withdraw the case from the economic litigation procedures or for admtional
limiteu‘ civil
discovery be fiied (if checked, explain specifically why economic litigation procedures relating to discovery or trial
wiil
should not applyto this case):
18.
m
Other issues
The party or parties request that the following additional matters be considered or determined at the case
conference (specify):
management
Itisrequested the CMC be continued 90 days to allow for discovery to occur and for pieadings to be set
initial
following Motion to Strike punitivedamages.
19.
a. E
Meet and confer
The party
of Court
have met and conferred with
or parties
not, explain):
(if
parties
all on alisubjects required by rute 3.724 ofthe California Rules
Not as of the date thisstatement was filed. Defendants are waiting until punitivedamages issue isresolved
b4 After meetingand conferring as required byrule3.724 of the California Rules of Court, the parties agree on the following
(specify):
20‘ Totalnumber ofpages attached any):
(if 0
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: December 12, 201 6
Daniel G. Baiich
{TYPE OP. PRINT NAME}
} / 7A,» Z,INN
OF PARTY OR ATTORNEY)
(Si-GNATURE
{?YPECR PRlNT NAME} {SlGNATURE OF PARTY OR ATTORNEY)
|
Additional signatures are attached.
CM-“OIRW M 2°“:
CASE MANAGEMENT STATEMENT W 5°”
PROOF OF SERVICE BY MAIL
Nailau v. Clarke
Santa Clara County Superior Court Case No. 16CV29982
"
Ideclare that:
CO NT‘Y
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 0f 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 PlaintiffLALANI NAILA U
Tel: (408) 733-0100
Fax: (408) 733-0123
Email: ree wvanderwaldacom
dcs vanderwaldacom
Documents mailed:
DEFENDANTS SUSAN M. CLARKE AND ALBERT K. CLARKE’S CASE
MANAGEMENT STATEMENT
I declare under penalty 0f perjury that the foregoing is true and correct, and that this
Om
declaration was executed on December 12, 2016 at San Francisco, California.
Signed:
CINDY VOONdV V 7
Preview
t CM-110 [IWORNEY 0R (Nam PARTV WITHOUT ATTORNEY am amass)- ear number. Stare THOMAS J. MURRAY, ESQ. 154245; DANIEL G. BALICH KERN, NODA, DEVINE & SEGAL 1388 SUTTER ST., SUITE 600 SF, CA 94109 TELEPHONE N0 41 5-474-1 900 FAX no 4 1 5-474-0302 (Optional): ADDRESS E-MAI‘L (Oph'ana!) ATTORNEY FOR (Name; Defendant SUPERIOR COURT 0F CALIFORNIA, COUNTY OF santa Clara STREET ADDRESS191 N.First Street MAILING ADDRESS AND CITY CODE: Zip San Jose, 951 13 BRANCH NAME: PLAINTIFF/PETITIONER; Latani Nailau DEFENDANTIRESPONDENT: Susan M. Clarke and Albert K. Clarke CASE MANAGEMENT STATEMENT CASE NUMBER (Check one): UNLIMITED CASE (Amount demanded E LIMITED CASE (Amount demanded is$25,000 160v299824 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE isscheduled as follows: Date: 1/10/1 7 Time: 9:00 AM Dept: 9 Div.: Room: Address of court different from the (if address above): Notice of Intent to Appear by Telephone, by (name): Daniel G, Balich INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1, Party or parties (answer one): a. E I v’ | This statement This statement issubmitted by party fname): Defendants Susan submitted jointly by parties (names): M. Clarke and Albert K. Clarke F AX b. is 2. Complaint and cross-complaint be answered by plaintiffs and cross-comp/ainants only) Y (to a. The complaint was filed on (date): b. C] The cross-complaim. ifany.was on (date): filed 3. a1 b1 D Service E (tobe answered by AH The partiesnamed in and cross—complainants plaintiffs only) the complaint and cross-complaint have been served. named foilowing parties inthe complaint or cross-complaint have appeared, or have been dismissed. (1) [:3 have not been served (specify names and explain why not): (2) D have been served but have not appeared and have not been dismissed (specify names): (3) D have had a them default entered against (specify names): c. C] The may be added following additional parties names, (specify nature of involvementIncase. and date by which they may be served). 4, Description of case a- Type Ofcase l" complaint cross—complaint (Describe, including causes ofaction): Motor vehicle accident Page1o! 5 Form Adopied Mandatory Use for Como! Juducza! of Cahfcrma CASE MANAGEMENT STATEMENT Caé Rutes ofCoon. ruzes 3 720.3 .730 CM-HC 20: [Rev July t 13 wwwcourfs ca gov CM-1 1O CASE NUMBER _ ‘ PLAINTIFF/PETITIONER: Lalani Nailau 160v299824 DEFENDANT/RESPONDENT: Susan M. Clarke and Albert K. Clarke 4. b. (/fpersona/ injury damages are sought, specify the injury and Provide a brief statement of the case. including any damages. damages claimed, including medical expenses to date {indicate source and amount], estimated future medical expenses, lost eamings to date,and estimated future lost earnings. Ifequitable relief is sought,describe the nature of the relief.) Plaintiffwas a passenger in Defendant's vehicie, which was broad sided by another vehicle. Plaintiff alleges Defendant ran a stop sign. more space box and attach a page designated as Attachment ' I (If isneeded, check this 4b.) 5. Jury or nonjury trial ’ The pany or parties request a jury trial I a nonjurytriaL (Ifmore than one name pan‘y, provide the of each party requesting a jury tn'al): 6. Trialdate av E] The has been set trial for (date): b No date has been set This case trial be ready will for within 12 trial months of the date of the filing of the complaint (If not, explain): The case is not yet at issue. c. Dates on which panies or attorneys will not be available for trial (specify dates and explain Ieasons for unavailability): 1/17/17 — 1/20/17; 2/16/17- 4/14/1 7 (set for 8 concurrent or overlapping trials over this period); 5/15/1 7 — 5/19/17; 5/30/17 —— 6/30/17; 7/24/17 — 8/3/17; 9/15/17 — 9/24/17; 1/26/18 — 2/2/18; 3/9/18 — 3/16/18 7. Estimated length of trial The party or parties estimate that the take (check one): tn‘al will 5‘7 a. b. E days (specify number): hours (short causes)(specify): 8‘ The at party or parties Attorney: will be answered Trial representation (to for be represented attrial E each party) by the attorney or party the caption listed in l lby the following: b. Firm: c Address: d. Telephone number: f. Fax number: a e E-mailaddress: Additional representation isdescribed lnAttachment 8. gt Partyrepresented: 9. 10. D Preference This caseis preference (specify code section): entitled to 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 courtand community programs in thiscase (1) Counsel For parties represented by counsel: has [:3 has not provided theADR informationpackage identified in rule ADR 3.221 to the client and reviewed options with the client. (2) For self—represented Party parties: E has E has not reviewed the ADR information package identified 3.221. in rule b. Referral to judicial arbitration or civil action mediation available). (if (1) E3 This matter is sub‘ect to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutorylimit. (2)E Civil case to Plaintiff elects to refer this Procedure section 1141 .111 and agrees judicial arbitration recovery to the amount specified to limit inCode of (3)E: This case is exempt from judicial arbitration under rule 3.811 mediation under Code of Civil Procedure section ot the California Rules of Courtor from 1775 et seq. (specify exemption): action civil CM-“Mev Ju'w 2W CASE MANAGEMENT STATEMENT WM CM-110 ‘ PLAINTIFF/PETITIONER: CASE NUMBER: LalaniNailau DEFENDANT/RESPONDENT? 16CV299824 Susan M. Clarke and Afbert K. Clarke 10. c. ADR Indicate the process or processes that the party or parties are wining to participate in,have agreed to participate or in, have already participatedin {check all that apply and provide the specified information): The party or parties completing If in the case have agreed to the oarty or parties completing this form thisform are wiltingto have already completed an ADR prowss or processes, participate in or ADR participate in the foliowing indicate the status of the processes (attach a copy of the parties'ADR processes {check allthat 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 Settlement Settlement conference scheduled for (date): (2) conference DUDE Agreed to complete settlement conference by (date): Settlement conference compieted on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutralevaluation DUDE Agreed tocomptete neutral evaluation by (date): Neutral evaluation completed on (date): scheduled Judiciai arbitration not yet Nonbinding judicial scheduled Judicial arbitration for (date): (4) arbitration EDD! Agreed tocomplete judicial arbitration by (date): compteted on Judicial arbitration (date): Private arbitration not yet scheduled Private arbitration scheduled for (date): (5) Binding private arbitration DUDE Agreed tocomplete privatearbitration by (date): on Private arbitration completed (date): ADR session not yet scheduled ADR session scheduled for (date): (6) Other(specify): DUDE Agreed to complete ADR session by (date): ADR completed on (date): CM-E TD 201 (Rev. Juiy ‘2‘ 1] Page 3 of 5 CASE MANAGEMENT STATEMENT CM:11_Q ~ CASENUMBER. PLAINTIFF/PETITIONER: LalaniNauau 16CV299824 DEFENDANT/RESPONDENT; Susan M. C1arke and Albert K. Clarke 11.Insurance a‘ b. c. E Insurance Reservation of carrier, rights: Coverage issues D if will Yes [a No Geico Insurance any, for party filing this statement (name): significanfly affect resolution of this case (explain): 12. Jurisdiction Indicate :3 any matters Bankruptcy E thatmay Other (specify): case and describe the status. affect the court's jurisdiction or processing of this Status: 13. a. a Related cases, consolidation, and coordination There are companion, (1)Name of case: undedying, or related cases. (2)Name of court: (3)Case number: (4) Status: b. a E Additional cases are described A motion to [:1 in COHSO‘idate Attachment 13a. D coordinate willbe fited by (name pany): 14. Bifurcation The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of moving party, type of motion, action (specify and reasons): Possible motion to bifurcate liability and damages 15.Other motions The party or parties expect to file the following motions before moving pafly, type ofmotion, and issues): (specify trial Motion to Strike PuniQtive Damages 0n catendar for 1/10/17 16. Discovery a. C] The have completed an discovery. party or parties b. The following discovery willbe completed by the date specified(describeallanticipated discovery): Party Descrigtion Date ’ Defendants Written discovery t0 Plaintiff January, 2017 Deposition of Plaintiff January 25, 201 7 Witness depositions March 2017 Expert discovery TBD c‘ [j The including issues regarding the discovery of electronically stored information, are following discovery issues. anticipated(specify): CM~l EGIREV. July 1,20H] CASE MANAGEMENT STATEMENT P3924015 CM-110 - PLAINTIFF/PETITIONER: LalaniNailau CASENWBER- " 16CV29 98 24 DEFENDANT/RESPONDENT' susan M Clarke and A|bert K C'arke 17‘ a. a Economic litigation This isa limited Prowdure of Civil civi!case (i‘eq the amount demanded is$25000 sections 90-98 will apply to this case. and the economic or less) procedures litigation in Code b, C: This isa case and a motion to withdraw the case from the economic litigation procedures or for admtional limiteu‘ civil discovery be fiied (if checked, explain specifically why economic litigation procedures relating to discovery or trial wiil should not applyto this case): 18. m Other issues The party or parties request that the following additional matters be considered or determined at the case conference (specify): management Itisrequested the CMC be continued 90 days to allow for discovery to occur and for pieadings to be set initial following Motion to Strike punitivedamages. 19. a. E Meet and confer The party of Court have met and conferred with or parties not, explain): (if parties all on alisubjects required by rute 3.724 ofthe California Rules Not as of the date thisstatement was filed. Defendants are waiting until punitivedamages issue isresolved b4 After meetingand conferring as required byrule3.724 of the California Rules of Court, the parties agree on the following (specify): 20‘ Totalnumber ofpages attached any): (if 0 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: December 12, 201 6 Daniel G. Baiich {TYPE OP. PRINT NAME} } / 7A,» Z,INN OF PARTY OR ATTORNEY) (Si-GNATURE {?YPECR PRlNT NAME} {SlGNATURE OF PARTY OR ATTORNEY) | Additional signatures are attached. CM-“OIRW M 2°“: CASE MANAGEMENT STATEMENT W 5°” PROOF OF SERVICE BY MAIL Nailau v. Clarke Santa Clara County Superior Court Case No. 16CV29982 " Ideclare that: CO NT‘Y 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 0f 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 PlaintiffLALANI NAILA U Tel: (408) 733-0100 Fax: (408) 733-0123 Email: ree wvanderwaldacom dcs vanderwaldacom Documents mailed: DEFENDANTS SUSAN M. CLARKE AND ALBERT K. CLARKE’S CASE MANAGEMENT STATEMENT I declare under penalty 0f perjury that the foregoing is true and correct, and that this Om declaration was executed on December 12, 2016 at San Francisco, California. Signed: CINDY VOONdV V 7