Preview
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CM-‘I10
ATTORNEY 0R PARTY WITHOUT ATTORNEY (Name, State Barnumber, and address): FOR COURT use ONLY
CHRISTINA E. KIM, ESQ.I (SBN 241697)
GILSLEIDER, MCMAHON, MOLINELLI & PHAN
2300 Clayton Road, Suite 430 Concord, CA 94520-2100
E—MAIL
TELEPHONE No;
ADDRESS (Optlonal):
925—446-3115 FAX NO. (Optional):925-798-5355
SAN M ATFD
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F L hCOUNTY
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ATTORNEY FOR (Name): Defendant ROBINS WU H
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO MAY 2 2 2018
STREET ADDRESS: 400 COUNTY CENTER
MAILING ADDRESS: REDWOOD CITY, CA 94063
CITY AND ZIP CODE:
BRANCH NAME:
PLAINTITF/PETITIONER: NOUR—ALDINE GHASSAN DABBAGH
DEFENDANT/RESPONDENT: ROBINS WU (
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CASENUMBER-
CASE MANAGEMENT STATEMENT
(Check one): :1 UNLIMITED CASE
(Amount demanded
l:l LIMITED CASE
(Amount demanded is $25,000
17C|V02972
exceeds $25,000) or less) Statement
lllllllllllllllllllllllllllllIll
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: June 7, 2018
Address of court (if different from the address above):
1.
Time: 10:00 am. Dept: 28
Notice of Intent to Appear by Telephone, by (name): CHRISTINA E. KIM, SBN. 241697
Div.:
INSTRUCTIONS: All applicable boxes must be checked, and the specified infonnatlon must be provlded.
Party or parties (answer one):
Room:
G
02972
CIV
—-
—
OMS
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Management
Case
1164419
I
a.
b. I: This statement is submitted by party (name): Defendant ROBINS WU
This statement is submitted jointly by parties (names): Fara
3d
2.
3.
Complaint and cross-complaint (to be answered by plaintiffs and cross—complainants only)
a.
b. I:
The complaint was filed on (date):
The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
i
3
F1
CI
a.
b. I: All parties named in the complaint and cross—complaint have been served, have appeared, or have been dismissed.
The following parties named in the complaint or cross-complaint
(1) C] have not been served (specify names and explain why not):
(2) CI have been sewed but have not appeared and have not been dismissed (specify names):
(3) [:3 have had a default entered against them (specify names):
c. I: The following additional parties may be added (specify names, naturer of involvement in case, and date by which
they may be served):
4. Description of case
3- Type Of case In complaint .I::I cross-complaint (Describe, including causes of action):
Personal Injury/Motor Vehicle
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, .. , Page 1 of 6
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Form Adopted for Mandatory Use
,umdammdmfwmmm CASE MANAGEMENT STATEMENT
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CM-1 10 [Rev. July 1, 2011] www.coudscagov
Gilli-110,
CASE ”WEE“:
”‘ PLAlNTIFF/PETlTIONEFt: NOUR-ALDlNE GHASSAN DABBAGH
1 7C|V02972
DEFENDANT/RESPONDENT: ROBINS WU
4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specily 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. lf equitable relief is sought, describe the nature of the relief.)
This case stems from an accident that occurred on or about 9/6/15. Discovery has commenced and is ongoing.
1:] (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
requesting a jury trial):
a jury trial :l
a nonjury trial. (If more than one party, provide the name of each party
6. Trial date
a.
b.
>
I: The trial has been set for (date):
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 (specifir dates and explain reasons for unavailability):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a.
b. I: days (specify number):
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 [:1 by the following:
Attorney:
9-957!“
Firm:
Address: ,
'
Telephone number: f. Fax number:
e. E-mail address: 9_ Party represented;
[:1 Additional representation is described in Attachment 8.
9. Preference
|:] This case is entitled to preference (SPBCifi/ 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 1:] 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
“
I: has [:1 has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) E
This matter is sub‘ect to mandatoryjudicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediationl untder ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory imi .
(2) [:1 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) [:3 This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
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Ctll-i101Rev.July1.2011] PageZol'S
CASE MANAGEMENT STATEMENT
CM-11OA
CASE NUMBER
PLAINTIFF/PETITIONERI NOUR-ALDINE GHASSAN DABBAGH
17CIV02972
DEFENDANT/RESPONDENT: ROBINS WU
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 nun:
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
Settlement conference scheduled for (date):
(2) Settlement
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 nonoluuhlnonl
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date):
(4) Nonbinding judicial
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
)
Private arbitration scheduled for (date):
(5) Binding private
arbitration anon
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): mono
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-11O [Rem July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
CASE NUMBER
2
PLAlNTlFF/PETITIONER: NOUR—ALDINE GHASSAN DABBAGH
17CIV02972
DEFENDANTIRESPONDENT: ROBINS WU , ,
11. insurance
a. insurance carrier, if any. for party filing this statement (name): Progressive Insurance Company
b. Reservation of rights: [:1
Yes‘ No
c. :1 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.
[:1 Bankruptcy [3
Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. [:3 There are companion, undertying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number.
(4) Status:
|:l Additional cases are described in Attachment 13a.
b. :1 A motion to i:] consolidate [:1 coordinate will be filed by (name party):
14. Bifurcation
[:1 The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (special moving party, type of motion, and reasons):
15. Other motions
[:1 The party or parties expect to file the following motiOns before trial (specify moving party, type of motion, and issues):
16. Discovery
a. i:!
The party or parties have completed all discovery.
b. E The following discovery will be completed by the date specified (describe all anticipated discovery):
Peggy Description Date
Defendant written discovery June 2018
Defendant plaintiff‘s deposition July 2018
Defendant expert discovery per code
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c. [:1 The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (speciiy):
(EM-110 [Rav. July 1, 2011] Fayed 015
CASE MANAGEMENT STATEMENT
CM-110V
CASE NUMBER
PLAINTIFF/PETITIONER: NOUR~ALDINE GHASSAN DABBAGH
_ 17CIV02972'
DEFENDANTIRESPONDENT: ROBINSWU
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. 1:} 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
I:I The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
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
(specifir):
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: MAY18,2018 ’afl/‘f Wit,
CHRISTINA E. KIM, SBN. 241697 ,
V
,
(TYPE 0R PRlNT NAME) t
( aNATURE or PARTY OR eomiev)
‘
(TYPE 0R PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
|:] Additional signatures are attached.
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can-11o [Rem July 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
ZPROOF osseavrce
STATE OF CALIFORNIA )
) ss:
COUNTY OF CONTRA COSTA )
I am employed in the County of Contra Costa, State of California, I am over the age of
18 and not a party to the within action; my business address is 2300 Clayton Road,
(OWNOJU'I-hOJN—‘e
Suite 430 Concord, CA 94520-2142.
On May 18, 2018, served the foregoing document described as DEFENDANT’S CASE
I
MANAGEMENT CONFERENCE STATEMENT on the parties in this action by placing a true
. copy thereof enclosed in a sealed envelope addressed as follows:
SEE ATTACHED SERVICE LIST
.A
0 E BY MAIL: i am "readily familiar" with the finn's practice of collection and processing
correspondence for mailing. Under that practice it would be deposited with U.S. postal
_\ —‘
service on that same day with postage thereon fully prepaid at Concord, California, in
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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 meter date is more than one
.4 03 day after date of deposit for mailing in affidavit.
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A El BY PERSONAL SERVICE: I caused such envelope to be delivered by hand to the
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offices of the addressee.
_\ O)
El BY OVERNIGHT MAIL: I arranged for such envelope to be delivered to the addressees
as listed on the service list.
_‘L \I
E BY FACSIMILE: In addition to regular mail, I sent this document via facsimile to the
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numbers as listed on the service list and pursuant to GOP §1013(e).
.3
(O [II BY ELECTRONIC SERVICE: I sent this document via electronic transmission to the
offices of the addressees as listed on the service list and pursuant to GOP §1010.6.
N0
El (State)l declare under penalty of perjury under the laws of the State of California that
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the above is true and correct.
NN
El (Federal) I declare that I am employed in the office of member of the bar of this court
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at whose direction the service was made. - v
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Executed on May 18, 2018, at Concord, California.
M 01
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‘
0') Barbara L.’ Rosenbluth-
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..... 1 . . _
PROOF OF SERVICE
—\
“SERVICE LIST
Juan M. Simon, Esq.
617 Veterans Blvd., Suite 102
Redwood City, CA 94063
(650) 366—6476/(650) 369—9017 (F)
Attorney for Plaintiff
NOUR-ALDINE G. DABBAGH
COOJNOO'l-b-OJN
NMNNNNNNN—LJ—a‘i—A—A—l—L—l
mNODCh-hCDN—‘OQmNODU'l-hWN—‘O
2
"
PROOF OF SERVICE