Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
David L. Jones (SBN: 109859)
Christopher R. Wagner (SBN: 112307)
Steven R. Inouye (SBN: 245024)
GORDON REES SCULLY MANSUKHANI, LLP
633 West Fifth Street, 52nd Floor
Los Angeles, CA 90017
TELEPHONE NO.: (213) 576-5075 FAX NO. (Optional): (213) 680-4470 12/31/2019
djones@grsm.com; cwagner@grsm.com; sinouye@grsm.com
E-MAIL ADDRESS (Optional):
FARMERS GROUP, INC.
ATTORNEY FOR (Name):
SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE
STREET ADDRESS: 1775 Concord Ave.
MAILING ADDRESS:
Chico, CA
CITY AND ZIP CODE: 94928
BRANCH NAME:North Butte County Courthouse
PLAINTIFF/PETITIONER: Liza Sims, et al.
DEFENDANT/RESPONDENT: Dawn Foster, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
19CV01700
(Check one): UNLIMITED CASE LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: January 22, 2020 Time: 10:30 a.m. Dept.: TBA Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Steven R. Inouye
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. This statement is submitted by party (name): FARMERS GROUP, INC.
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. The cross-complaint, if any, was filed on (date):
3. 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) 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) 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):
4. Description of case
a. Type of case in complaint cross-complaint (Describe, including causes of action):
Claims against PG&E: Negligence, Inverse Condemnation, Public and Private Nuisance, Premises Liability,
Trespass, Violation of Health & Safety Code. Claims against Farmers: Broker Negligence and Misrepresentation
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California
CASE MANAGEMENT STATEMENT rules 3.720–3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Liza Sims, et al.
19CV01700
DEFENDANT/RESPONDENT: Dawn Foster, 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
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff Sims has sued her mother’s insurer, Farmers, and her mother’s insurance agent, Dawn Foster, for
allegedly failing to advise Plaintiff Sims that she should have purchased “tenants insurance” and a policy which
covered commercial activities – which were never disclosed. Farmers denies Plaintiff's claims.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request a jury triaI a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. The trial has been set for (date):
b. 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 set: 2/01/20, 3/01/20, 3/16/20, 4/03/20, 4/21/20, 5/08/20, 6/12/20, 7/17/20, 8/14/20, 9/8/20, 9/28/20,10/9/20
7. Estimated length of trial
The party or parties estimate that the trial will take (check one): 5-7 days
a. days (specify number):
b. hours (short causes) (specify):
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 by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
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 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 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 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(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.
(3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM-110 [Rev. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Liza Sims, et al.
19CV01700
DEFENDANT/RESPONDENT: Dawn Foster, et al.
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):
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 scheduled
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) 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
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Liza Sims, et al.
19CV01700
DEFENDANT/RESPONDENT: Dawn Foster, et al.
11. 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.
Bankruptcy 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 13a.
b. A motion to consolidate coordinate wiII 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 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 The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
FARMERS INSURANCE Written discovery Per Code
FARMERS INSURANCE Depositions Per Code
FARMERS INSURANCE Expert depositions Per Code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011] Page 4 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Liza Sims, et al.
19CV01700
DEFENDANT/RESPONDENT: Dawn Foster, et al.
17. Economic litigation
a. This is a limited civil case (i.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. 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
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify): (1) Plaintiff's counsel William McCann filed a pro hac vice application in this case which failed
to mention that he resigned his California license with charges pending in 2007 (07-Q-10457). He was also
ineligble to practice law in California since 2005. This material information was required to be disclosed as part
of the application under CRC 9.40(d). (2) PG&E has filed for bankruptcy and the claims against it may be
stayed.
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 not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any):
I am 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 30, 2019
STEVEN R. INOUYE
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev. July 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
1 PROOF OF SERVICE
2 I am a resident of the State of California, over the age of eighteen years, and not a party
to the within action. My business address is: Gordon Rees Scully Mansukhani, LLP 633 West
3 Fifth Street, 52nd floor, Los Angeles, CA 90071. On December 31, 2019, I served the within
documents:
4
CASE MANAGEMENT STATEMENT
5
6 By FedEx: By placing a true copy thereof enclosed in a sealed envelope, at a station
designated for collection and processing of envelopes and packages for overnight
delivery by FedEx as part of the ordinary business practices of Gordon & Rees LLP
7 described below, addressed as follows:
8 By U.S. Mail: By placing the document(s) listed above in a sealed envelope with
postage thereon fully prepaid, in United States mail in the State of California at Los
Angeles, addressed as set forth below.
9
10 Jane Luciano, Esq. Attorneys for plaintiffs Liza Sims and Edna
9000 Crow Canyon Road, Suite #168 Gleason
11 Danville, California 94506
Email: jane-luciano@comcast.net
Gordon Rees Scully Mansukhani, LLP
12 Tel: (925) 216-6030
633 West Fifth Street, 52nd floor
13 William McCann, Esq. Attorneys for plaintiffs Liza Sims and Edna
Los Angeles, CA 90071
P.O. Box 370 Gleason
14 Genoa, NV 89411
Email: wdmccann@gmail.com *Courtesy Copy
15 Tel: (775) 200-0627
16 Daniel Kohls, Esq. Attorneys for Dawn Foster
Shannon L. Knorr, Esq.
17 Hansen, Kohls, Sommer & Jacob, LLP
1520 Eureka Road, Suite 100
18 Roseville, CA 95661
Email: dkohls@hansenkohls.com
19 sknorr@hansenkohls.com
kpiceno@hansenkohls.com
20 (916) 781-2550 (telephone)
(916) 781-5339 (fax)
21
22 I am readily familiar with the firm’s practice of collection and processing correspondence
for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same
23 day with postage thereon fully prepaid in the ordinary course of business. I am aware that on
motion of the party served, service is presumed invalid if postal cancellation date or postage
24 meter date is more than one day after the date of deposit for mailing in affidavit.
25 I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.
26
Executed on December 31, 2019 at Los Angeles, California.
27
28
Jennifer Odell
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY David L. Jones (SBN: 109859) Christopher R. Wagner (SBN: 112307) Steven R. Inouye (SBN: 245024) GORDON REES SCULLY MANSUKHANI, LLP 633 West Fifth Street, 52nd Floor Los Angeles, CA 90017 TELEPHONE NO.: (213) 576-5075 FAX NO. (Optional): (213) 680-4470 12/31/2019 djones@grsm.com; cwagner@grsm.com; sinouye@grsm.com E-MAIL ADDRESS (Optional): FARMERS GROUP, INC. ATTORNEY FOR (Name): SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE STREET ADDRESS: 1775 Concord Ave. MAILING ADDRESS: Chico, CA CITY AND ZIP CODE: 94928 BRANCH NAME:North Butte County Courthouse PLAINTIFF/PETITIONER: Liza Sims, et al. DEFENDANT/RESPONDENT: Dawn Foster, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: 19CV01700 (Check one): UNLIMITED CASE LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: January 22, 2020 Time: 10:30 a.m. Dept.: TBA Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Steven R. Inouye INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): FARMERS GROUP, INC. b. This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. The cross-complaint, if any, was filed on (date): 3. 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) 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) 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): 4. Description of case a. Type of case in complaint cross-complaint (Describe, including causes of action): Claims against PG&E: Negligence, Inverse Condemnation, Public and Private Nuisance, Premises Liability, Trespass, Violation of Health & Safety Code. Claims against Farmers: Broker Negligence and Misrepresentation Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Liza Sims, et al. 19CV01700 DEFENDANT/RESPONDENT: Dawn Foster, 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 earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff Sims has sued her mother’s insurer, Farmers, and her mother’s insurance agent, Dawn Foster, for allegedly failing to advise Plaintiff Sims that she should have purchased “tenants insurance” and a policy which covered commercial activities – which were never disclosed. Farmers denies Plaintiff's claims. (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request a jury triaI a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. The trial has been set for (date): b. 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 set: 2/01/20, 3/01/20, 3/16/20, 4/03/20, 4/21/20, 5/08/20, 6/12/20, 7/17/20, 8/14/20, 9/8/20, 9/28/20,10/9/20 7. Estimated length of trial The party or parties estimate that the trial will take (check one): 5-7 days a. days (specify number): b. hours (short causes) (specify): 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 by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: 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 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 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 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (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. (3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Liza Sims, et al. 19CV01700 DEFENDANT/RESPONDENT: Dawn Foster, et al. 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): 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 scheduled (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) 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 (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Liza Sims, et al. 19CV01700 DEFENDANT/RESPONDENT: Dawn Foster, et al. 11. 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. Bankruptcy 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 13a. b. A motion to consolidate coordinate wiII 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 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 The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date FARMERS INSURANCE Written discovery Per Code FARMERS INSURANCE Depositions Per Code FARMERS INSURANCE Expert depositions Per Code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Liza Sims, et al. 19CV01700 DEFENDANT/RESPONDENT: Dawn Foster, et al. 17. Economic litigation a. This is a limited civil case (i.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. 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 The party or parties request that the following additional matters be considered or determined at the case management conference (specify): (1) Plaintiff's counsel William McCann filed a pro hac vice application in this case which failed to mention that he resigned his California license with charges pending in 2007 (07-Q-10457). He was also ineligble to practice law in California since 2005. This material information was required to be disclosed as part of the application under CRC 9.40(d). (2) PG&E has filed for bankruptcy and the claims against it may be stayed. 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 not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): I am 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 30, 2019 STEVEN R. INOUYE (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. July 1, 2011] Page 5 of 5 CASE MANAGEMENT STATEMENT American LegalNet, Inc. www.FormsWorkFlow.com 1 PROOF OF SERVICE 2 I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is: Gordon Rees Scully Mansukhani, LLP 633 West 3 Fifth Street, 52nd floor, Los Angeles, CA 90071. On December 31, 2019, I served the within documents: 4 CASE MANAGEMENT STATEMENT 5 6 By FedEx: By placing a true copy thereof enclosed in a sealed envelope, at a station designated for collection and processing of envelopes and packages for overnight delivery by FedEx as part of the ordinary business practices of Gordon & Rees LLP 7 described below, addressed as follows: 8 By U.S. Mail: By placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid, in United States mail in the State of California at Los Angeles, addressed as set forth below. 9 10 Jane Luciano, Esq. Attorneys for plaintiffs Liza Sims and Edna 9000 Crow Canyon Road, Suite #168 Gleason 11 Danville, California 94506 Email: jane-luciano@comcast.net Gordon Rees Scully Mansukhani, LLP 12 Tel: (925) 216-6030 633 West Fifth Street, 52nd floor 13 William McCann, Esq. Attorneys for plaintiffs Liza Sims and Edna Los Angeles, CA 90071 P.O. Box 370 Gleason 14 Genoa, NV 89411 Email: wdmccann@gmail.com *Courtesy Copy 15 Tel: (775) 200-0627 16 Daniel Kohls, Esq. Attorneys for Dawn Foster Shannon L. Knorr, Esq. 17 Hansen, Kohls, Sommer & Jacob, LLP 1520 Eureka Road, Suite 100 18 Roseville, CA 95661 Email: dkohls@hansenkohls.com 19 sknorr@hansenkohls.com kpiceno@hansenkohls.com 20 (916) 781-2550 (telephone) (916) 781-5339 (fax) 21 22 I am readily familiar with the firm’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same 23 day with postage thereon fully prepaid in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage 24 meter date is more than one day after the date of deposit for mailing in affidavit. 25 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 26 Executed on December 31, 2019 at Los Angeles, California. 27 28 Jennifer Odell