Motion for Case Management in JOSE VERDUSCO VS. ANDY MAR, COUNTY OF SAN MATEO| Trellis.Law

On December 07, 2007 a Party Statement was filed involving a dispute between Verdusco, Jose, and County Of San Mateo, Mar, Andy, for civil in the District Court of San Mateo County.

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CM-110
ATTORNEY 0R PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY

David P. Mastagni (SBN 57721) ; Grant A. Winter (SBN 266329)
MASTAGNI HOLSTEDT , APC
1912 I Street
Sacramento, CA 95811
TELEPHONENO.: (916) 446 -4692 (916)
FAXNO.(Optiona/): 447 -4614
gwinter@mas tagni . com
I
EMAIL ADDRESS (Optional):
Defendant
ATTORNEY FOR (Name): Andy
SUPERIOR COURT OF CALIFORNIA, COUNTY OF
Mar
San Mateo L E D
STREET ADDRESS: 4O0 County Center SAN MATEO COU\NTY
MAILING ADDRESS: AUG 2 4 2016
CITY AND ZIP CODE:Redwood City, CA 94 063 ,

BRANCH NAME:

PLAINTIFF/PETITIONER: JOSE VERDUSCO

DEFENDANT/RESPONDENT: ANDY MAR; COUNTY OF SAN MATEO;
and, DOES 1 through 20, inclusive
CASE MANAGEMENT STATEMENT CASE NUMBER:

(Check one): Q UNLIMITED CASE El LIMITED CASE CIV53 7 74 0
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)

A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: September 14 , 2 016 Time: 8 :45 Dept: 21 Div.: Room:

?
:

Address of court (if different from the address above):
-

m Notice of Intent to Appear by Telephone, by (name): Grant A. Winter SW3
asea
OLLZBL

UVLLSQAIO

INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
tuauiaﬁeuew

Party or parties (answer one): IllIlllllllllllllIlllllllllllllllllllll

a. IX] This statement is submitted by party (name): Defendant Andy Mar
b. D This statement is submitted jointly by parties (names): tuauiatets

Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was ﬁled on (date):
b. C] The cross-complaint. if any, was ﬁled on (date):

Service (to be answered by plaintiffs and cross~complainants only)
a. D All parties named in the complaint and cross—complaint have been sewed, have appeared, or have been dismissed.
b. D The following parties named in the complaint or cross-complaint
(1) C] 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) C] have had a default entered against them (specify names):

0. D The following additional parties may be added (specify names, nature of involvement in case,
they be served);
and the date by which
may

Description of case
a. Type of case in
Plaintiff
[Z]
Jose
complaint
Verdusco
9 cross-complaint
asserts causes
(Describe,
of
including causes of action):
action for assault, false
imprisonment, infliction of emotional distress and work place violence,
among-others.
Page1 of 5

“armlk
ForlnﬂcfgglpEgufgéir/Ioafngaalliggnlése
CASE MANAGEMENT STATEMENT Cal. Rules of Court.
rules 3720-3130
g6) _ www.courts.ca.gov
CM-110 [Rev July
1,2011]
ESSENHM FURMSm
Mar Andy
CM-110_
PLAINTIFF/PETITIONERzJOSE VERDUSCO CASE NUMBER:

CIV537740
DEFENDANT/RESPONDENT: ANDY MAR; COUNTY OF SAN MATEO;
and, DOES 1 through 20, inclusive
4. b. Provide a brief statement of the case, including any damages. (lfpersona/ injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
eamings to date, and estimated future lost earnings.If equitable relief is sought,
describe the nature of the relief.)
Plaintiff Verdusco asserts that Defendant Mar, while acting in his capacity as an
employee of the San Mateo County Sheriff's Department, assaulted and threatened Mr.
Verdusco, in part, based upon Mr. Verdusco's race.

D (If more space is needed, check this box and attach apage designated as Attachment 4b.)

Jury or nonjury trial

-
The party or parties request
requesting a jury trial):
m ajury trial D a nonjury trial. (Ifmore than one party, provide the name ofeach party

Trial date
a. D The trial has been set for (date):
b. E No trial date has been set. This case will be ready for trial within
not,explain):
12 months of the date of the ﬁling of the complaint (if

0. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
SEE ATTACHMENT 6C

Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. m days (specify number): 5
b. D hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial
a. Attorney:
m by the attorney or party listed in the caption D by the following:

b. Firm:
0. Address:
d. Telephone number: f. Fax number:
8. E-mail address: 9. Party represented:
E] Additional representation is described in Attachment 8.
Preference
D 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
in rule 3.221
E] has D has not provided the ADR information package identiﬁed
to the client and reviewed ADR options with the client.
(2) For self-represented parties:Party C] has C] has not reviewed the ADR information package identiﬁed in rule 3.221.

b. Referral tojudicial arbitration or civil action mediation (if available).
(1) D This matter is subject to mandatory judicial arbitration
under Code of Civil Procedure section 1141.11 or to civil action
mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) D Plaintiff elects to refer this case to judicial arbitration
Civil Procedure section
and agrees to limit recovery to the amount speciﬁed in Code of
1141.11.
(3) E] This case is exempt from judicial arbitration under rule 3.811of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):

CM‘“°‘RBV‘““- 2“” CASE MANAGEMENT STATEMENT pagezofs
f“. MnrlinDL-mr‘s
___ .

FllRMS’“
ESSENTIAL
Mar , dy
CM-110
PLAINTIFF/PETITIONERZJOSE VERDUS CO CASE NUMBER:

CIVS 3 7 7 4 0
DEFENDANT/RESPONDENT: ANDY MAR; COUNTY OF SAN MATEO;
and, DOES 1 through 20, inclusive
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):

m Mediation session not yet scheduled

(1) Mediation
CI Mediation session scheduled for (date):

C] Agreed to complete mediation by (date):
C] Mediation completed on (date):

C
D Settlement conference not yet scheduled

(2) Settlement CI Settlement conference scheduled for (date):
conference
D Agreed to complete settlement conference by (date):
C] Settlement conference completed on (date):

CI Neutral evaluation not yet scheduled

(3) Neutral evaluation
CI Neutral evaluation scheduled for (date):

C] Agreed to complete neutral evaluation by (date):

CI Neutral evaluation completed on (date): L

CI Judicial arbitration not yet scheduled
(4) Nonbinding judicial 1:] Judicial arbitration scheduled for (date):
arbitration
a Agreed to complete judicial arbitration by (date):

[3 Judicial arbitration completed on (date):

CI Private arbitration not yet scheduled

(5) Binding private C] Private arbitration scheduled for (date):
arbitration
D Agreed to complete private arbitration by (date):
D Private arbitration completedon (date):

D ADR session not yet scheduled
(6) Other (specify): Cl ADR session scheduled for (date):
C] Agreed to complete ADR session by (date):
C] ADR completed on (date):

CM-110 [Rev. July
1,2011] cASE MANAGEMENT STATEMENT pageants
,
/_
Martin Dmn’;

[SSENllAl FURMS‘“
Mar, Andy
CM-110
PLAINTIFF/PETITIONER: JOSE VERDUS CO CASE NUMBER:

CIVS 3 7 74 O
D EFENDANT/RESPONDENT: ANDY MAR; COUNTY OF SAN MATEO;
and, DOES 1 through 20, inclusive
11. Insurance
a. m Insurance carrier, if any, for party ﬁling this statement (name):State Farm
b. Reservation of rights: m Yes C] No
c. C] Coverage issues will signiﬁcantly affect resolution of this case (explain):

12. Jurisdiction
or processing of this case, and describe the status.
Indicate any matters that may affect the court's jurisdiction
[I Bankruptcy
Status:
C] Other (specify):

13. Related cases, consolidation, and coordination
a. C] There are companion. underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
E Additional cases are described in Attachment 13a.
b. C] A motion to CI consolidate CI coordinate will be ﬁled by (name pan‘y):

14. Bifurcation
D The party or parties intend to ﬁle
action moving party,
a motion for an order bifurcating,
type of motion, and reasons):
severing, or coordinating the following issues or causes of
(specify

15. Other motions
CI type of motion,
The party or parties expect to ﬁle the following motions before trial (specify moving party, and issues):

16. Discovery
a. D The party or parties have completed alldiscovery.
b. m The following discovery willbe completed by the date speciﬁed (describe all anticipated discovery):
Date
Party Description
Plaintiff Written Discovery Per Code

Plaintiff Depositions Per Code

Plaintiff Expert Discovery Per Code

c. D The followingdiscovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):

cmnmwwmwimn CASEMANAGEMENTSTATEMENT PwMMS

_ Mm [in Dcau’s

HmM'sE
ESSENillll
Mar, Andy
CM-110
PLAINTIFF/PETITIONER: JOSE’ VERDUSCO CASE NUMBER:

CIVS 3 7 74 O
DEFENDANT/RESPONDENT: ANDY MAR; COUNTY OF SAN MATEO;
and, DOES 1 through 20, inclusive
17. Economic litigation
a. C] 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. C] This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
explain speciﬁcally why economic litigation procedures relating to discovery or trial
discovery will be ﬁled (if checked,
should not apply to this case):

18. Other issues
[Z] The party or parties request that the following additional matters be considered or determined at the case management
conference (specify): Mr . Mar anticipates that he will file a cross complaint for
indemnity and contribution.

19. Meet and confer
a. E] The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of
explain):
Court (if not,

b. After meeting and conferring as required by rule 3.724 of the California Rules of Court. the parties agree on the following
«waﬁw:The parties will meet and confer before the hearing.

20. Total number of pages attached (if any):_—__ of discovery and alternative dispute resolution,
I am completely familiar with this case and will be fully prepared to discuss the status

as well as other issues raisedby this statement, and willpossess the authoritytoe terinto stipulations on these issues at the time of
the case management conference. includingthe writtenauthority ofthe partyw

Dme August 19, 2019

Grant A Winter
(TYPE OR PRINT NAME)
}
w
/
(SIGNATURE OF PARTY OR ATTORNEY)

(TYPE 0R PRINT NAME) . (SIGNATURE OF PARTY OR ATTORNEY)

E] Additional signatures are attached.

cmnmwwmwemn CASEMANAGEMENTSTATEMENT wms
MarlinDran's
(‘09
ESSENlllllIﬂRMS'"
M ar, A n dy
MC-025
SHORT TITLE: CASE NUMBER:

— Verdusco v. Andy Mar, et a1. l
CIV537740

ATTACHMENT (Number) : 62—
(ThisAttachment may be used with any Judicial Council form.)

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(If the item that this Attachment concerns is made under penalty of perjury,all statements in this Page J— of2—
Attachment are made under penalty of perjury.) (Add pages as required)

ATTACHMENT www.courtinfo.ca.gov
Form Ap roved tor OptionatUse ~

Judicia Council of California _ _ .
McozsiRev. Jun/1.20091 to Judicial Councrl Form

ESSENlIlll illRMS'"
MC-025
SHORT TITLE: , CASE NUMBER:

Verdusco v. Andy Mar, et a1. CIV537740

ATTACHMENT (Number) : ﬁe—
(This Attachment ma y, be used with any Judicial Council form.)

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(If the item that this Attachment concerns is made under penalty of perjury,all statements in this Page 2__ of2__
Attachment are made under penalty of perjury.) (Add pages as required)

le
Form‘A‘pproved for Optional
JudlClal Council of Cahfomla
ATTAC H M E NT
._ _
www.courtinfotcagov

MC-ozs [Rem July 1. 20091 to JUdIClal COUI’ICII Form

HIRMS'“
ESSENTIAL
PROOF OF SERVICE (C.C.P.§1013a)

SHORT TITLE OF CASE: Verdusco v.Mar, et al.
COURT NAME: San Mateo County Superior Court
CASE NUMBER: CIV53 7740

I am a citizen of the United States and a resident of the County of Sacramento. I
am over the age of 18 years and am not a party to the within action. My business address is 1912

I Street, Sacramento, CA 9581 1.

On the date set forth below, I served the below-described document(s), on the parties
listed herein, at the addresses set forth below, by serving a true copy, or original as required by
law, of each by the following means of service:

/ BY
I am
US. FIRST-CLASS
readily familiar
MAIL
with this
[C.C.P.
ﬁrm’s
§§1013 &
business
1013(a)]:
practice of collecting and processing
11
correspondence for mailing. Under that practice, I enclosed the below-described document(s)
in a sealed envelope/package addressed to the persons set forth below to be deposited with the
12
United States Postal Service, on the same day, with postage fully prepaid.
13
NAME/DESCRIPTION OF DOCUMENT(S) SERVED:
14
Case Management Statement
15
ADDRESSES OF SERVICE:
16
Todd P. Emanuel, Esq. '

EMANUEL LAW GROUP
17
702 Marshall Street, Suite 400
Attorneys for Plaintiff Jose Verdusco
Redwood City, CA 94063
18
Sandra Zuniga Nirenberg, Esq.
SAN MATEO COUNTY COUNSEL Attorneys for Defendant County of San
19
400 County Center Mateo
20
Redwood City, CA 94063

21
I declare under penalty of perjury, under the laws of the State of California, that the
22
foregoing is true and correct.
23
Executed on August 23, 2016, at Sacramento, California.
24
52‘
25 Amanda Breeze

PROOF llPage

Case Info

Judge

Robert D. Foiles Track Judge’s New Case

Case No.

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Document Filed Date

August 24, 2016

Case Filing Date

December 07, 2007

County

Parties

COUNTY OF SAN MATEO Cross Defendant (participant)
COUNTY OF SAN MATEO Defendant
EMANUEL, TODD P. Attorney for the Plaintiff
JOHN C. BEIERS Attorneys for Defendants
JOHN C. BEIERS Attorney for the Defendant
MAR, ANDY Cross Complainant (participant)
MAR, ANDY Defendant
ROES 1-100, INCLUSIVE Cross Defendant (participant)
VERDUSCO, JOSE Plaintiff
WINTER, GRANT A Attorney
WINTER, GRANT A Attorney for the Defendant
Pamela Glazner Attorneys for Plaintiffs
Phillip Mastagni Attorneys for Defendants
Karen Rosenthal Attorneys for Defendants
Sandra Nierenberg Attorney
Deshawn Madha Attorney
Joshua Bentley Attorney
Brooks Cutter Attorneys for Plaintiffs
Jennifer Domer Attorneys for Plaintiffs
David Hughes Attorney

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Party Statement: JOSE VERDUSCO VS. ANDY MAR, COUNTY OF SAN MATEO

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Case Info

Parties