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  • BRYAN TRUJILLO, et al  vs.  STEPHEN MAGEE, et al(23) Unlimited Other PI/PD/WD document preview
  • BRYAN TRUJILLO, et al  vs.  STEPHEN MAGEE, et al(23) Unlimited Other PI/PD/WD document preview
  • BRYAN TRUJILLO, et al  vs.  STEPHEN MAGEE, et al(23) Unlimited Other PI/PD/WD document preview
  • BRYAN TRUJILLO, et al  vs.  STEPHEN MAGEE, et al(23) Unlimited Other PI/PD/WD document preview
  • BRYAN TRUJILLO, et al  vs.  STEPHEN MAGEE, et al(23) Unlimited Other PI/PD/WD document preview
  • BRYAN TRUJILLO, et al  vs.  STEPHEN MAGEE, et al(23) Unlimited Other PI/PD/WD document preview
  • BRYAN TRUJILLO, et al  vs.  STEPHEN MAGEE, et al(23) Unlimited Other PI/PD/WD document preview
  • BRYAN TRUJILLO, et al  vs.  STEPHEN MAGEE, et al(23) Unlimited Other PI/PD/WD document preview
						
                                

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CM-11O ATTORNEY 0R PARTY WITHOUT ATTORNEY (Name; 33339 Bar number. 3nd address}: FOR COURT USE ONLY Garry L. Montanari, SBN 89790 Michaelis, Montanari & Johnson 4333 Park Terrace Dr. #1 10, Westlake Village, CA 91 361 TELEPHONE N0; 818.865.0444 FAX N0. (Optional): 81 8365,8444 Electra nically E-MAILADDRESS gmontanari@mmjlaw.net (Optima): ATTORNEY FORrName): Defendants Stephen Magee and Sac Aero Flying Club MUM” Em" flahfflmm'cmmfla" MM" fl“ 5/08/2020 SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F SAN MATEO STREETADDRESS: 400 County Center By £5!Pidmal'll Singh Deputy Clerk same MAILING ADDRESS: CITYAND CODE: ZIP Redwood City, CA 94063 BRANCH NAME: PLAINTIFFIPETITIONER: BRYAN TRUJILLO, et al. DEFENDANTIRESPONDENT: STEPHEN MAGEE, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one).- UNLIMITED CASE (Amount demanded E LIMITED CASE (Amount demanded ' is$25,000 18CIV01901 exceeds $25,000) or less) 5/1 1/2020 A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 28, 2020 Time: 9:00 a.m. Dept: TBD Div.: Room: Address of court different from the (ff address above): Notice of Intent to Appear by Telephone, by (name): Garry L. Montanar'l, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement issubmitted by party (name): Defendants Stephen Magee and Sac Aero Flying Club b. [j This statement issubmitted jointly by parties (names): 2. Com plaint and cross—complaint (tobe answered by piainfifis and cross-complainants only) a. b. E The complaint was filed on (date): The cross—complaint, ifany. April was ’17,2018 filed on (date): be answered by plaintiffs and cross-compiainants 3. a. E Service E (to All parties The named in named only) the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. (1) E following parties inthe complaint or cross—complaint have not been sewed {specify names and expiain why not): (2) E have been served but have not appeared and have not been dismissed (specify names): (3) E have had a default entered against them (specffi/ names): c. E The theymay be served): may be added following additional parties (specifynames, nature ofinvolvement in case, and date by which 4. Description of cage 3- Type 0f case In complaint E cross-complaint (Describe, including causes ofaction): Trespass by aircraft. Paqa1 of 5 Form Adopied forMandatory Use Judicial Council of Californla CASE MANAGEMENT STATEMENT Cal.Rules 0f Court, rules 3.?20-3.730 CM-1 10 [Rem July 201 1. 1] www.mudS-Cayov CM-‘I 1 0 CASENUMBERZ — PLAINTIFF/PETITIONER: BRYAN TRUJILLO. et al. 180IV01901 DEFENDANTIRESPONDENT: STEPHEN MAGEE,-et aI. 4. b. Provide a brief statement of the case, including any damages. (lfpersonal injun/ damages are sought, specify the injun/ and damages claimed, including medica! expenses to date [indicate source and amount}, estimated future medical expenses, Iosz‘ earnings t0 date, and estimaied future lost earnings. If equitable refiefis sought,describe the nature of the relief.) See Case Management Statement. plaintiffs' E more space {If isneeded, check thisbox and ah‘ach a page designated as Attachment 4b.) 5. Jury or nonjury The trial party or parties request requesting a jurytrial): a jurytrial E a nonfury trial. (Ifmore than one party, provide thename of each pan‘y 6. a. b. E Trialdate The trial has been set for (date).- No trial date has been set. This casewillbe ready for within trial 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): March 8-19, 2021; June 1-16, 2021; August 2-20, 2021 7. Estimated length of trial The party or parties estimate that the take (check one): a. b. m E trial will days (specify number): ten (10) days hours (short causes) (specify): 8. Trial The a. representation (to party or parties will be represented at Attorney: trial m be answered for each party) by the attorney or party the caption listed in E by the following: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E—mailaddress: g. Partyrepresented: E] Additional representationisdescribed inAttachment 8. 9. 10. E Preference This case Alternative is code entitled to preference {specify dispute resolution (ADI?) section): a. ADR information package. Please note that different ADR processes are available 'm 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 (1) court and in rule community programs in thiscase. For parties represented by counsel; Counsel 3.221 to the ciient and reviewed has E has not ADR options with the client. provided the ADR information package identified (2) For self—represented parties:PartyE has E has not reviewed theADR information package identified in rule 3.221. b. (1) E Referral to judicial arbitration or civil action mediation(ifavailable). 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 CivilProcedure section 1775.3 because the amount in controversy does not exceed the statutorylimit. (2) E] case Plaintiff elects to refer this and agrees to judicial arbitration amount specified to limit recovery to the inCode of CivilProcedure section 1141.11. (3) E This page is exempt from jugipial arbitration under rule 3.811 of the California Rules of Courtor from mediation under Code 0f CIVII Procedure section 1775 et seq. (specfi'y exemption): action civil CM-HUIRW- Ju'vtzom Paaems CASE MANAGEMENT STATEMENT CM-110 CASE NUMBER: _ PLAINTIFFIPETITIONER: BRYAN TRUJILLO, et al. 1BC|V01901 DEFENDANT/RESPONDENT: STEPHEN MAGEE, et al. ’10. c. Indicate theADR process or processes that the party or parties are willing to participate in,have agreed to participate in.or have already participatedin (check all that apply and provide the specified infomation): The party or parties completing Ifthe party or parties completing this form in the case have agreed to thisform are willing to participatein 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 notyet scheduled (1)Mediation E HUDD Mediation session scheduled for (date): Agreed tocomplete mediation by (date): Mediation completed on (date): 9/12f201 9; 1H 0f2019 Settlement conference not yet scheduled Settlement Settlement conference scheduled for (date): (2) conference BUDD Agreed tocomplete settlement conference by (date): Settlement conference completed on (date): 10H Of201 9 Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3)Neutral evaluation DUDE Agreed to complete neutral evaiuation by (date): Neutral evaluation completed on (date): scheduled Judicial arbitration not yet scheduled Judicial arbitration for (date): (4) Nonbinding judicial arbitration DUDE Agreed to complete judicial arbitration by (date): completed on Judicial arbitration (date): Private arbitration not yet scheduled Private arbitration scheduled for (date): (5) Binding private DUDE arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (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-HO[Rem July 1,2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-11 0 CASE “UMBER PLAINTIFFIPETITIONER: BRYAN TRUJILLO, et al. 1BC|V01 901 DEFENDANTIRESPONDENT: STEPHEN MAGEE. et al. 11. Insurance Avemco insurance Company a. b. c. E Insurance Reservation of carrier, rights: Coverage issues D ifany, for party will Yes E] No statement (name): filing this case significantly affect resolution of this (explain): 12. Jurisdiction E Indicate any matters Bankruptcy E thatmay Other (specify).- case and describe the affect the court's jurisdiction 0r processing of this status. Status: 13. a_ E Related cases, consolidation, and coordination There are companion, underlying, or related cases. (1) Name 0f case: (2)Name of court: (3)Case number: (4) Status: b. E E Additional cases are described A motion to E in consolidate Attachment 13a. E coordinate will — be filed by (name party): E 14. Bifurcation The party or parties intend to action (specifl/ filea motion for an order bifurcating, severing, or coordinating the foltowing issues or causes of moving party, type of motion, and reasons): Other motions 15. E The party or parties expect to filethe following motions beforetrial(specifymoving party, type of motion, and issues):_ 16. a. b. E Discovery Em The The party _orpartieshave completed following discovery will alldiscovery. be completed by the date specified (describe allanticipated dmcovery). Description U CE The following discovery issues anticipated (specifir). including issues regarding the discovery of electronically stored information, are CM-HOIRW- M 20111 1: . CASE MANAGEMENT STATEMENT _ Pagan” CM-1 1 0 CASE NUMBER: PLAINTIFFIPETITIONER: BRYAN TRUJILLO, et al. "" 18CIV01 901 DEFENDANTIRESPONDENT: STEPHEN MAGEE: 9t a'- Economic 17. a. E litigation This isa limited case civil the amount (i.e., of Civil Procedure sections90-98 demanded is apply t0 this case. $25,000 or less) and the economic procedures litigation inCode b, E will 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 specificafly 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 casemanagement conference (specify): Defendants pending motion to compel production 0f documents pursuant to defendants‘ notice to appear and produce was scheduled for May 8, 2020. 19. a. D Meet and confer The party or parties havemet and conferred with of Court (ifnot, explain): allpartieson allsubjects required by rule 3.724 of the California Rules b. After meeting and conferring as required byrule 3.724 of the California Rules of Court, the parties agree on the following (specify): ' 20. Totalnumber of pages attached (ifany): 0 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 t’o enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: May 8, 2020 W I .—// ._ GARRY L.MONTANARI } Y/ @5241 ; (TYPE0R PRINT NAME} {SIGNATURE OF PARTY 0R A'ITORNEY) d D 0R PRINT NAME) (SIGNATURE 0F PARTY 0R AWORNEY) (TYPE E Additional signatures are attached. CM—m [Rsv- Ju'v 2°“! 1- CASE MANAGEMENT STATEMENT Pagewa PROOF OF SERVICE STATE 0F CALIFORNIA ) ) s.s. COUNTY 0F L03 ANGELES ) I am employed in the County 0f Los Angeles, State 0f California. I am over the age of 18 and not a party t0 the within action; my business address is 4333 Park Terrace Dr. #1 00, Westlake Village, California 91361. 0n May 8, 2020, I served the foregoing document described as CASE MANAGEMENT STATEMENT 011 the interested parties in this action by placing a true copy thereof in a sealed enve10pe with postage thereon fully prepaid in the United States mail at Westlake Village, California, addressed as follows: Michael S. Danko, Esq. Attorneys for Plaintiffs ' Danko Meredith 10 333 Twin Dolphin Dr. #1 45 Redwood Shores, CA 94065 ll tel: (650) 453—3600; fax: (650) 394-8672 Email: 1ndanko@dankolaw.com l2 l3 [X] (MAIL) I deposited such envelope addressed in the mail at Westlake Village, California. The envelope was mailed with postage thereon fully prepaid. I am “readily familiar” with film's 14 practice of collection a_nd processing correspondence for mailing. It is deposited with U.S. postal service on that same day in the ordinary course of business. I am aware that on motion of party 15 served, service is presumed invalid if postal cancellation date or postage meter date is more than 1 day after date of deposit for mailing in affidavit. l6 [] (PERSONAL SERVICE)I caused such envelope to be delivered by hand to the addressee 1'7 listed above at the Courthouse located at 400 County Center, Redwood, CA 94063. 18 [X] (ELECTRONIC TRANSFER) I caused all ofthe pages ofthe above-entitled document t0 be sent to the recipient noted above via electronic transfer (email) at the respective email address l9 indicated above. 2O [] (FEDERAL EXPRESS) I deposited such envelope addressed at the Federal Express office located at Westlake Village, California. The envelope was mailed fully prepaid. I am “readily 21 familiar” with firm’ s practice of collection and processing correspondence for mailing with Federal Express. It is deposited with the Westlake Village Federal Express service 0n that same day in the 22 ordinary course of business. 1am aware that on motion ofparty served, service is presumed invalid if cancellation date is more than 1 day after date of deposit for overnight mailing in affidavit. 23 24 I declare under penalty ofperjury under the laws ofthe State 0f California that the foregoing is true and correct. 25 26 Executed on May 8, 2020 at Westlake Villagqglifomia. 2'7 Barbara HaussrhafinJCCLS 28