Preview
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
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