Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Barnumber, and address)21 FOR COURT USE ONLY
7974
Dominic M Polito. Law Office Of Mike McKone
1740 Technology Dr, Suite 250
San Jose CA 95110
TELEPHONE No.: 408-392—6966
dpoli@allstate.com
E-MAILADDRESS (Optional):
FAX NO.(Optional):415—392-0820 FILE%
SAN MATEO COUNTY
ATTORNEY FOR (Name): Martha Gonzales Jose Reyes
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Mateo
MAR 2 9 2013
STREET ADDRESS: 400 County Center
MAILING ADDRESS:
0599‘ Of the SH. ”9f Court
CIT-V ANDZ'P CODE: Redwood City, CA 94063
‘
By
BRANCH NAM E:
PLAINTIFF/PETITIONER: JUBRAN
DEFENDANT/RESPONDENT: REYES
i
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE
(Amount demanded
|:I LIMITED CASE
(Amount demanded is $25,000
17CIV05550
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 4/12/18 Time: 8:45 a.m. Dept: 21 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Dominic M. Polito
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
1.
a.
b. I:I
This statement is submitted by party (name): Defendants
This statement is submitted jointly by parties (names):
"T -__ -
17—clv—055s 0
ms
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Case Management
St aemem
1
1060496
2. 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): KI” I”," I__. -— ~—— _ ._.-__ __‘__i
3. Service (to be answered by plaintiffs and cross-complainants only)
a. IZI All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
(1) I:
b. I____I The following parties named in the complaint or cross-complaint
have not been served (specify names and explain why not):
(2) CI have been served but have not appeared and have not been dismissed (specify names):
(3) [:1 have had a default entered against them (specify names):
0. E The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type Of case In
Discovery is just beginning.
complaint I: cross-complaint (Describe, including causes of action):
Page 1 of 5
Form Adopted for Mandatory Use
Judicial Council of California
CASE MANAGEMENT STATEMENT Cal, Rules cw.’ Court.
rules 3720—3 730
CM-110 [Rev. July 1, 2011] www.courtsca gov
REQEaMED
SAN MATEO CQUNTY
MAR 2 9 2018
Cierk oi‘ the Superior Gourd ‘
CM-110
CASE NUMBER:
_ PLAINTIFF/PETITIONER: JUBRAN
17ClVO5550
DEFENDANT/RESPONDENT: REYES
4. b. Provide a brief statement of the case. including any damages. (If personal injury damages are sought, specify 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. If equitable relief is sought, describe the nature of the relief.)
Discovery is just beginning
I: (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 I: a nonjury trial. (If more than one party, provide the name of each party
6.
a.
b.
I:
Trial date
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 (specify dates and explain reasons for unavailability):
DEFENDANT COUNSEL'S TRIALS ALREADY SET PLEASE SEE ATTATCHED DOCUMENT
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 3'5
b. 1:] hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial
a. Attorney:
[I] by the attorney or party listed in the caption I:] by the following:
b Firm:
0 Address:
d. Telephone number: f. Fax number:
e E-mail address: Party represented:
9.
1:] Additional representation is described in‘Attachment 8.
9. Preference '
:1 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 has C]has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
b.
(2) For self-represented parties: Party :1 has :I
has not reviewed the ADR information package identified in rule 3.221.
Referral to judicial arbitration or civil action mediation (if available).
(1) |:| This matter is sub'ect to mandatoryjudicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediatior} under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory imit.
(2) I: 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) 1:] This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
'
CM-110[Rev.July1,2011] Page20f5
CASE MANAGEMENT STATEMENT
CM-11O
PLAINTIFF/PETITIONER: JUBRAN CASE NUM BER:
_
DEFENDANT/RESPONDENT: REYES
17C|V05550
10. 0. 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 DUI]!
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference DUDE
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 DUDE
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 DUDE
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 DUDE
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
EDEN]
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. July 1. 2011} Page 3 of 5
CASE MANAGEMENT STATEMENT
CMAJQ
CASE NUMBER:
PLAINTIFF/PETITIONER: JUBRAN
17CIV05550
DEFENDANT/RESPONDENT: REYES
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name): Allstate Insurance
b.
c.
Reservation of rights:
l:|
l:lYes l:l
No
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 l:l
Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. [:1 There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
CI Additional cases are described in Attachment 13a.
b. l:l A motion to l:l consolidate l:l coordinate will be filed by (name party):
14. Bifurcation
l:l The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
In Limne Motions at Trial
16. Discovery
a.
b.
l:l The party or parties have completed all discovery.
The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
defendant Deposition of Plaintiff TBD
IME TBD
Expert Depositions TBD
c. [:1 The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-11O [Rev. July 1, 2011]
CASE MANAGEMENT STATEMENT Page 4 °f5
CM-110
CASE NUMBERI
PLAINTIFF/PETITIONER: JUBRAN
17CIV05550
DEFENDANT/RESPONDENT: REYES
17. Economic litigation
a. CI 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 will to this case.
90—98 apply
b. I:I 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
[:1 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. [:1 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
(specify):
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: 3/28/18
Dominic M. Polito
(TYPE OR PRINT NAME)
(TYPE OR PRINT NAME)
} QM
V fl
(SIGNATURE OF PARTY 0R ATTORNEY)
(SIGNATURE OF PARTY OR ATTORNEY)
1:] Additional signatures are attached.
CM-110 [Rev. July 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
TRIALS
Harris May 7, 2018
Martinez 5/15/2018
Meyer May 29, 2018
Fosler 6/11/18
June 18 Carillo
June 25 Huang
5& H July 30,2018
Madril August 27, 2018
Calderon 9/10/18
Jackson 9/17/18
Brown: 2/19/19
PROOF OF SERVICE BY MAIL - OFFICE DEPOSIT [CCP 1013(a)(3)l
STATE OF CA, COUNTY OF SANTA CLARA
I am employed in the County of Santa Clara, State of CA, I am over the age of 18 years,
and not a party to the within action; my business address is 1740 Technology Drive, Suite 250,
San Jose, CA 95110.
\OOO\IO\Lh.l>.U—>N
I am readily familiar with my employer’s business practice for collection and processing
of correspondence by mailing with the United States Postal Service.
On March 2‘1, 2018, following ordinary business practice, I served the within CASE
MANAGEMENT STATEMENT on the party or parties named below, by placing the original
10 or a true and correct copy thereof in a sealed envelope, with postage thereon fully prepaid, for
11 collection and mailing with the United States Postal Service Where it would be deposited in the
12 United States Postal Service that same day in the ordinary course of business, addressed as
13 follows: SEE ATTACHED MAILING LIST.
14 I declare under penalty of perjury under the laws of the State of CA that the foregoing
15 Proof of Service is true and correct and that this declaration was executed on March $_(/, 2018,
16 at San Jose, CA.
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19 Bm/w‘DLojflnic Polito
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PROOF OF SERVICE BY MAIL - OFFICE DEPOSIT
PROOF OF SERVICE MAILING LIST
Jubran vs. Reyes, et a1.
Case No. 17CIV05550
\OOO\IO\U‘l-I>UJN>—t
Attorney for Plaintiff Jubran:
Philip A. Segal, Esquire
Kern, Segal & Murray
1388 Sutter St Ste 600
San Francisco CA 94109
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00\IO\UI-I>UJNb—‘O\OOO\IO\UIJ>-UJNHO
PROOF OF SERVICE BY MAIL OFFICE DEPOSIT
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