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  • ANDY SABERI VS LES STANFORD, ETAL(06) Unlimited Breach of Contract/Warranty document preview
  • ANDY SABERI VS LES STANFORD, ETAL(06) Unlimited Breach of Contract/Warranty document preview
  • ANDY SABERI VS LES STANFORD, ETAL(06) Unlimited Breach of Contract/Warranty document preview
  • ANDY SABERI VS LES STANFORD, ETAL(06) Unlimited Breach of Contract/Warranty document preview
  • ANDY SABERI VS LES STANFORD, ETAL(06) Unlimited Breach of Contract/Warranty document preview
  • ANDY SABERI VS LES STANFORD, ETAL(06) Unlimited Breach of Contract/Warranty document preview
  • ANDY SABERI VS LES STANFORD, ETAL(06) Unlimited Breach of Contract/Warranty document preview
  • ANDY SABERI VS LES STANFORD, ETAL(06) Unlimited Breach of Contract/Warranty document preview
						
                                

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GII-110 sar ntrrrider, eitd addreeeX ATTORNEY OR PARTY WiTHOUTATTORNEY (Name, State FOR couaruse oNLv JAMES M. DOMBROSKI (SBN 056898) P.O. Box 751027 Petalumn, California 94975 TELEPHONE NOJ707-762-7807 707-769-0419 FAI(NO (Optionero (optfanar/'dOrnaki@aOI, E4IJAtL ADDREss OOm Plaintiff ATTORNEY FOR (Nameh supERIOR cOURT OF cALIFORNIA,cOUNTY Of SAN MATEO sTREETADDREss'00 County Center NIAILINQADDRESS: - c(TYANozlPODDE: @mt, -.'y Redwood City, California 94063 / BRANCH NAME. ;1 PttuNTIFF/PETITIONER: Andy Saben, an individual DEFENDANT/REsPONDENT; BJ Auto Auto Transporters, Inc.,et al CASE MANAGEMENTSTATEIIENT ~ CASE NUMBER: (Check one); ~e" UNLIMITEDCASE LIINITEDCASE CIV 536 294 (Amount demanded (Amount demanded is $ 25,000 exceeds $ 25,000) or less) A CASE MANAGEMENTCONFERENCE is scheduledas follows; Date. March 17, 2016 Time; 9:00am Dept„. 21 Dlv,; Room: Address of court (ifdifferent from the address abave): Notice of intent to Appear by Teiephone, by (names: James Dombroski arid/or ThofrtaeSaberl INSTRUCTIONS. All applicable hoxaa must ba checked, and the specifiedirlformation must be provided. 1. a. ~ "Party or parties ~ (answer This statement one); is submittedby party (name); Plaintiff Aridy Saberi b. This statement is submittedjointly by parties (names): By FAX 2, Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a, b. ~ The complaint was filed on (date). The cross-complaint, November if any, 18, 2015 was filed on (date): 3. a. ~ Service ~ (to be answered All parties by plaintiffs and cross-compiainants named in the complaint and only) cross-complaint have been served, have appeared, or havebeen dismissed. I b. (1) ~ The following parties have named not been in the complaint or cross-complaint served (specify names and exp(at'n why not): (2) ~ Defendant have been Les served Stanford but have Chevrolet Cadillac, not appeared and a have Michigan not been corporation dismissed (specify names): (3) ~ have had a default enteredagainstthem (specify names). c. ~ BJ Interstata, The following additional they may be served); Inc. parties and may Bogdan be added Dedyk (specify names,nature of involvementin case,and date by which 4. Description of case a. Type of case in ~Y'omplaint cross-complaint (Describe,including causes of action): Fraud and negligence ot 3 Pea e 1 Farm Adopted for Meridetary V« CASE MANAISEMENTSTATEMENT Cel. Rules ot Court, Judioal Caultalt at Celltarnra tutee 3.720 3.730 CM-1 10 IRov. July 1, 2011) wtrIIv.ooorte.oe.goy CII-110 PLAINTlFFIPETITiONER: Andy Saberi, an individual CIV 536 294 DEPENDANT/RESPONDENT: BJ Auto Auto TransPorters, Inc., et al. 4. b. Provide a brief statementofthe case,including any damages. (ifpersonaiinjurydamages are sought, specify theinjury and damages claimed, including medicei expenses end amountj, to date (indicate source estimated future medicei expenses, last earnings to date,and estimated Ifequitabie future lost earnings. descnbe reiief is sought, the nature of the relief) Plaintiff purchased a new 2016 Chevrolet Corvette 206 convertible which was damaged and lost substantial value'hen it was delivered. Defendants intentionally concealed damage entitling Plaintiff to punitive damages. (Ifmore space is needed,check this box and attach a page designated as Attachment 4b,) 5. Jury or nonjury trial The party or parties request rertiiestfng s jury fn'ai); ~~ a juty trial~ a nonjury trial, (Ifmore than one palty. provide the nameof each party'I„ I 8, a. b. ~ Trial date ~y The trial has No trial date been has set for (date). been set.This case of the date for tiiai within 12 months will be ready of the filing o(the complaint (if not, explain); c. Dates on which partiesOr attorneyswill not beavailable end explain reasons for trial (specify dates for unavailability): 7. Estimated length of trial a, b. ~ The party or parties ~ days hours estimate that the trial will take (specify number); {short causes)(specify): (check one); 8 Trial representation The party or parties a, Attorney: (to be answered for each will be represented Thomas I. Saberi ~ party) at trial or party listed in the caption by the attorney ~ by the following; b. Firm; LAWOFFICE OF WILLIAMH, PAYNTER Address: 1045 Airport Blvd., Suite 12, South San Francisco, CA 94080 d. Telephone number: (650) 588-2428 f. Fax number: {850) 873-7046 e. E-mail address: tsaberi@aol.corn g. Partyrepresented: Plaintiff Additional representationis describedin Attachment 8. 9. Preference This case is entitled to preference (specify code sectt'on). 10. Alternative dispute resolution (ADR) ADR information package. Please note that different ADR processesare availablein different courts and communities; read ADR information package provided by the court underrule 3.221for information about the processes available through the 'he court and {1) community programs Fcr partiesrepresented In this case. by counsel:Counsel CG has ~ has reviewed ADR options with the client. to the client and not provided the ADR information package identified'n ~ rule 3.221 (2) For self-representedparties:Party has E3 has not reviewed the ADR information package identifiedin rule 3.221. b, {1) ~ Referral to judicial arbitration 'ediation statutory under limit. Code or civil action to mandatory This matter is subject mediation {ifavailable). judicial arbitration under of Civil Procedure'section'1775.3 Code because of Civil Procedure the'amount section in controversy 1141.11 does or to civil action not exceed the {2) ~ Civil Proceduresection to judicial arbitration and to refer this case Plaintiff elects 1141.11. agrees to limit recovery to the amount specifiedin Code of, {3) ~ This case mediation is exempt under from judicial arbitration under'ule Code of Civil Procedure section 1775 3 811 of the California Rules et seq.(specify exemption); of Courtor from civil action GM-110 [Aev. July 1, 201u PIC CASE MANAGEMENTSTATEMENT 2 Ot 5 CM-110 cASE wulleeeft: PLAINTIFF/PETITIONER: Andy Saberi, an individual CIV 636 294 ~ EFENDANTiRESPoNDENT: 9J Auto /4'rensporters, inc.,et al. 10. C. IndiCate the AOR prOCeSS Or prOCeaaea that the party Or partieS in, haVe agreed are Willing tO partiCipate tOpartiCipatein, Or have already in (oheck all that apply and provide the specified information); participated The party or parties completing If the party or parties completing this form in tha case have agreed to this form are willing to in or have participate already completed an ADR process or processes, . participatein the following ADR of the processes indicate the status {attach a copy of the padies'AOR processes {check all that applyj: stipulation). Mediation session not yet scheduled Nlediation sessionscheduled for (date). (0) 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 settlementconference by {date); Settlement conference completed on (date): Neutral evaluationnot yet scheduled Neutral evaluationscheduled for {date): (3) Neutral evaluation Agreed to complete neutralevaluationby (date): Neutral evaluationcompleted on (date); Judicial not yet scheduled arbitration {Jo Nonbinding judicial Judicial arbitration scheduled for {date); arbitration Agraad to cornplata judicial arbitration by (rife). Judicialarbitration completedon (date): Privatearbitrationnot yet scheduled Binding prlvaie for (date). Private arbitration scheduled {5) arbitration Agreed to complete private arbitration by (date): Private arbitration completed on {date): AOR session not yet scheduled ADR session scheduled for (date): (6) Other {specify): Agreed to completeADR session by (date); ADR completed on (date): ' CM-110 [Rev. July 1, 2011i Peee3ef6 CASE MANAGEMENTSTATEMENT CM-1 8Q;: CASE Ni/MBER: I PLAINTIFF/PETITIoNER: Andy Saberi, an individual CIV 536 294 DEFENDANT/REsl oNoENT; BJ Auto Auto Transporters, Inc„et ai 11. a. ~ Insurance Insurance ~ if any, carrier, ~ for party filing this statement (name): b. c. ~ Reservation of rights: Coverage issues Yes No of this case will significantly affect resolution (explain): 12 Jurisdiction ~ ~ Indicate any matters Status: Bankruptcy that may affect the court's jurisdiction or processing Other (specify): of this caseand describe the status, ~ 13. Related cases, There consolidation, are companion, (1) Name of case'. and coordination underlying, or related cases. (2) Name of court: (3) Case number: b. ~ M (4) Status; Additional cases A motion to ~ are described ~ in Attachment consolidate 13a. coordinate will be filed by (name party) I ~ 14. IMfurcation The party or parties intend to file a motion for an order bifurcating, severing, (specify moving party,type of motion, end masons): or coordinating the following issuesor causes of 'ction ~ 15. Other motions The party or parties expect Iype af motion, to file the following motions before trial (specify moving party, and issues): 16, a, b. ~ Discovery ~ The party or parties have completed all discovery. The following discovery will be completed by the datespecified(descntre aii anticipated discovery); ~Pa Oescriotion Date c. ~ The following discovery anticipated(specify): issues,including issuesregarding the discoveryof electrcniCally stored information, are cM-110 IRev. July f, 2011l CASE MANAGENIENTSTATEMENT rago4 of I CM-110 CABE NUMBER; PLAlNT(FFIPETIT)ONER'ndy Saberi, an individual GIV 536 294 DEFENDANT/RESPONDENT: BJ Auto Auto Transportera, Inc., at al. 17; e. ~ Economic litigation This is a limited civil case (i e., the amount demanded or less) is $ 25,000 and the economic in Code litigation procedures b. ~ of Civil Proceduresections90-98 will apply to this case. This is a limited civil case and a motion to withdraw the case discovery will be filed (if checked, from the economic why economic explain specifically or for additional litigation procedures relating to discovery or trial litigation procedures should not apply to this case): 18. Other issues i lle party Or partieS requeSt tnar Ina lOI)OWing aaalrlcnal marrerSbe COnsidered Ordeieiirilrred ai (lie used nraiiuigeiiiWii conference (specify): 19, a. ~ Neet snd confer of Court (ifnot, have The party or parties explain). met and conferred on all subjects with all parties required by rule 3.724of the California Rules b. After meetingand conferring asrequiredby rule 3.724of the California Rules of Court, the parties agree on the following (specify) 20. Total number of pages attached (ifany): i am completely and fami)lar with this case will be fully prepared to discussthe status icovery and alternativedisputeresolution, as well asother issuesraised by this statement, and will possessthe authority tc e r int stipulations on these issues at the time of the case management conference, including the written authority of the party whe requi d. Date: March 7, 2036 JAMES M. DOMBROSKj (TYPE QR PRINT NNIIB) (SIGNATURE QF PARTV OR ATTORNFV) (TYPE PR PRINT NAME) ~ (SIGNATURE OF PARTY OR AT)'ORNEY) Addlt(onal signaturesareattached. 'I, CM;110 (Rev. July 2011) CASE IIANAGEMENTSTATEMENT Fegeeefe mOOr OF SZRVICZ STATE OP CALIFORNIA,COUNTY OF SONOMA 3 I am employed in the County of Sonoma, State of California. I am over the age of 18 and not a paity to the within action. My business address is P.O. Box 751027, Petaluma, CA 94975. 5 On March 7, 2016, I served the foregoing document described as CASE MANAGEMENTSTATEMENT, as follows: 6 Bogdan Dedyk, dba Safe Auto Transport BJ Interstate Auto Transporters, Inc. 1756 Heather Garden Lane 6625 W. Sahara Avenue, Suite 1 Roseville, California 95661 Las Uegas, Nevada 89146 [ X] U,S, MAA.- I deposited such envelope in the mail at Petaluma, California. The envelope was mailed with postage thereon fully prepaid as follows'I am readily familiar with firm's practice of collectio~ and processing correspondence for mailing. Under the practice it would be deposited wi(h U.S. postal service on the saine day with postage thcrcon fully prepaid at Petaluma, California, in the ordinary cause of business. 12 [ ] BY FACSIMILE - To the facsimile number of the firm listed above. 13 [ ] OVERNIGHT MI,IVKRY- I deposited such envelope in the drop box at Petaluma, 14 California, l am readily familiar with firm's practice of collection and processing correspondence for Fcdcral Express. Under the practice, it would be deposited in the Overnite Express drop-box for pickup on the same day at Petaluma, California, in the ordinary course of lpusliless. 17 [ ] BY PERSONAL SE~RVICE - I caused such an envelope to be hand delivered to the office of the wldtessee. 18 [ ] BY EMAIL- I caused a copy to be emw'le:d to the firm listed above. Ig 20 I declare under penalty of perjury under the laws of'the State nf'.'alifornia that the above is true and correct, I declare that I sm employed in tlie office of a member of thc bar of this court 21 at whose direction the service was made. Executed on March 7, 2016, at Petaluma, Californi, 23 'l4 JAM'. DOMBROSK1 PRINT NAME SIGNATURE 25 27