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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Barnumber, and address: FOR COURT USE ONLY
Joseph R. Zoucha, Esq. (78696) .
2400 Broadway Street, Suite 230
Redwood City, Ca 94063
TELEPHONE N0.: 650-261-9600 FAX NO. (Optiona01650'261'9650 ‘E E
E-MAILAooREsS(0piiona/): jzouchalaW@gmail.C0m
Plaintiff
ATTORNEY FOR (Name): Avo Sadakian,
n
fiM ‘_€J
‘TF0 GOUN
.
TY
s AN '1“ \6
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Mateo ‘Z1
STREET ADDRESS: 400 County Center
lm-
1
MAILING ADDRESS:
CITY ANDZlP CODE:
Redwood City, Ca 94063
BRANCH NAME:
Unlimited
PLAINTIFF/PETITIONER: Avo A. Sadakian
DEFENDANT/RESPONDENT: Vinit Nirmal Singh, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE
(Amount demanded
:1 LIMITED CASE
(Amount demanded is $25,000.
ClV531899
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
'
Date: Juky 28, 2016 Time: 9 a.m. Dept: 21 Div.: Room:
Address of court (if different from the address above):
:1 Notice of Intent to Appear by Telephone, by (name):
INSTRUCTIONS: All applicable boxes must be Checked, and the specified information must be provided.
1. Party or parties (answer one):
a. [E AVO A. Sadakian
This statement is submitted by party (name):
b. :1 This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):December 29, 2014
b. :1 The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. 1:] The following parties named in the complaint or cross-complaint
(1) 1:] have not been served (specify names and explain why not):
-
(2) 1:] 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):
C. 1:1 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 0f case In complaint 1:1 cross-complaint of action):
(Descn'be, including causes
Personal injury auto
Page1of 5
Form Adopted torMandatory Use Cal. Rules of Court
Judicial Counu'l of Cafitomia
CASE MANAGEMENT STATEMENT rules 3720-3730
CM-110 [Rev July 1, 2011] www.murts.ca.gov
CM-11O
CASE NUMBER
_ PLAINTlFF/PETlTlONER: Avo A. Sadakian
. . . . CIV531899
DEFENDANT/RESPONDENT: vlmt Nlrmal singh. et al-
4. b. Provide a brief statement of the case, including any damages. (lf 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.)
See Attachement 4b
|_—_| (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 tn'al):
a jury triall: a nonjury trial. (if more than one party, provide the name of each party
6. Trial date
_ _
a. trial continued
The trial has been set for (date):
b. :1 No trial date has been set. This case will be ready fortrial 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):
NOvember and December 2016 and January, 2017
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 4
b. II] hours (short causes) (specify):
8. Trial representation (to be answered for each party)
a. Attorney:
[I]
The party or parties will be represented at trial [:1
by the attorney or party listed in the caption by the following:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
: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) [:1
For parties represented by counsel: Counsel has i:| has not provided the ADR information package identified
b.
(2) [:1
For self-represented parties: Party has l:
in rule 3.221 to the client and reviewed ADR options with the client.
has not reviewed the ADR information package identified in rule 3.221.
Referral to judicial arbitration or civil action mediation (if available).
(1) :1 This matter is sub'ect to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 0r to civil action
mediation under ode of Civil Procedure section
1775.3 because the amount in controversy does not exceed the
statutory limit.
(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) |:| 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):
I
CM-110[Rev.July1,2011] PageZof5
CASE MANAGEMENT STATEMENT
CM-11O
PLAINTIFF/PETITIONER: CASE NUMBRZ
_ Avo A, Sadakian
DEFENDANT/RESPONDENT:
C|V531899
Vinit Nirmal Singh, et al.
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 app/y and provide the specified information):
The party or parties completing lfthe 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 ADRindicate the status of the processes (attach a copy of the parties'ADR
processes (check all that app/y):
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 UUUEI Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date):
-
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
(3) Neutral evaluation ‘:1 Neutral evaluation scheduled for (date):
IIIIIIUU
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
‘:1 [IUUU
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
Binding private Private arbitration scheduled for (date):
(5) UUUI]
arbitration
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
(6) Other (specify): [I] UUUU
ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
cM-11o [Rev July
1. 20111 Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
CASE NUMBER
PLAINTIFF/PETITIONER: Avo A. Sadakian
DEFENDANT/RESPONDENT:
.. . .
Vinit Nirmal Singh, et al.
CIV531899
11.
a. :I
Insurance
lnsurance carrier, if any, for party filing this statement (name):
:1
b.
c. l:
Reservation of rights:[:1 Yes No
Coverage issues will significantly affect resolution of this case (explain):
12.Jurisdiction
lndicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
\:| Bankruptcy |:] Other (specify):
Status:
13. Related cases,consolidation, and coordination
a. |:| There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
:1 Additional cases are described in Attachment 13a.
b. :1 A motion to \:] consolidate :I coordinate will be filed by (name party):
14.
l:
Bifurcation
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):
ln Limine
16. Discovery
a. [:1 The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiff Experts 30 days prior to
trial.
c. [:1 The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated(specify):
CM-110lRev. July
1. 20111 Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Avo A. Sadakian CASE NUMBER:
_ ..
DEFENDANT/RESPONDENT: et .
N'rmal
.
Smgh, et al-
C|V531899
17. Economic litigation
a. :1 This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
ofCivil 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 fi led (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
(specify):
Set matter for mediation and trial date
20. Total number of pages attached(if any):
l 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: July 27, 2016
Joseph R. Zoucha
(TYPE OR PRINT NAME)
P
/ Q /
(SIGN
fi /'
OF PAéTY/OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
|___1 Additional signatures are attached.
CM-110 [Rev. July 1,2011] Page50f5
CASE MANAGEMENT STATEMENT
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Barnumber, and address: FOR COURT USE ONLY Joseph R. Zoucha, Esq. (78696) . 2400 Broadway Street, Suite 230 Redwood City, Ca 94063 TELEPHONE N0.: 650-261-9600 FAX NO. (Optiona01650'261'9650 ‘E E E-MAILAooREsS(0piiona/): jzouchalaW@gmail.C0m Plaintiff ATTORNEY FOR (Name): Avo Sadakian, n fiM ‘_€J ‘TF0 GOUN . TY s AN '1“ \6 SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Mateo ‘Z1 STREET ADDRESS: 400 County Center lm- 1 MAILING ADDRESS: CITY ANDZlP CODE: Redwood City, Ca 94063 BRANCH NAME: Unlimited PLAINTIFF/PETITIONER: Avo A. Sadakian DEFENDANT/RESPONDENT: Vinit Nirmal Singh, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE (Amount demanded :1 LIMITED CASE (Amount demanded is $25,000. ClV531899 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: ' Date: Juky 28, 2016 Time: 9 a.m. Dept: 21 Div.: Room: Address of court (if different from the address above): :1 Notice of Intent to Appear by Telephone, by (name): INSTRUCTIONS: All applicable boxes must be Checked, and the specified information must be provided. 1. Party or parties (answer one): a. [E AVO A. Sadakian This statement is submitted by party (name): b. :1 This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date):December 29, 2014 b. :1 The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. 1:] The following parties named in the complaint or cross-complaint (1) 1:] have not been served (specify names and explain why not): - (2) 1:] 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): C. 1:1 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 0f case In complaint 1:1 cross-complaint of action): (Descn'be, including causes Personal injury auto Page1of 5 Form Adopted torMandatory Use Cal. Rules of Court Judicial Counu'l of Cafitomia CASE MANAGEMENT STATEMENT rules 3720-3730 CM-110 [Rev July 1, 2011] www.murts.ca.gov CM-11O CASE NUMBER _ PLAINTlFF/PETlTlONER: Avo A. Sadakian . . . . CIV531899 DEFENDANT/RESPONDENT: vlmt Nlrmal singh. et al- 4. b. Provide a brief statement of the case, including any damages. (lf 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.) See Attachement 4b |_—_| (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 tn'al): a jury triall: a nonjury trial. (if more than one party, provide the name of each party 6. Trial date _ _ a. trial continued The trial has been set for (date): b. :1 No trial date has been set. This case will be ready fortrial 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): NOvember and December 2016 and January, 2017 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 4 b. II] hours (short causes) (specify): 8. Trial representation (to be answered for each party) a. Attorney: [I] The party or parties will be represented at trial [:1 by the attorney or party listed in the caption by the following: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: :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) [:1 For parties represented by counsel: Counsel has i:| has not provided the ADR information package identified b. (2) [:1 For self-represented parties: Party has l: in rule 3.221 to the client and reviewed ADR options with the client. has not reviewed the ADR information package identified in rule 3.221. Referral to judicial arbitration or civil action mediation (if available). (1) :1 This matter is sub'ect to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 0r to civil action mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (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) |:| 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): I CM-110[Rev.July1,2011] PageZof5 CASE MANAGEMENT STATEMENT CM-11O PLAINTIFF/PETITIONER: CASE NUMBRZ _ Avo A, Sadakian DEFENDANT/RESPONDENT: C|V531899 Vinit Nirmal Singh, et al. 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 app/y and provide the specified information): The party or parties completing lfthe 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 ADRindicate the status of the processes (attach a copy of the parties'ADR processes (check all that app/y): 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 UUUEI Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date): - Settlement conference completed on (date): Neutral evaluation not yet scheduled (3) Neutral evaluation ‘:1 Neutral evaluation scheduled for (date): IIIIIIUU 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 ‘:1 [IUUU Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled Binding private Private arbitration scheduled for (date): (5) UUUI] arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled (6) Other (specify): [I] UUUU ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): cM-11o [Rev July 1. 20111 Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 CASE NUMBER PLAINTIFF/PETITIONER: Avo A. Sadakian DEFENDANT/RESPONDENT: .. . . Vinit Nirmal Singh, et al. CIV531899 11. a. :I Insurance lnsurance carrier, if any, for party filing this statement (name): :1 b. c. l: Reservation of rights:[:1 Yes No Coverage issues will significantly affect resolution of this case (explain): 12.Jurisdiction lndicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. \:| Bankruptcy |:] Other (specify): Status: 13. Related cases,consolidation, and coordination a. |:| There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: :1 Additional cases are described in Attachment 13a. b. :1 A motion to \:] consolidate :I coordinate will be filed by (name party): 14. l: Bifurcation 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): ln Limine 16. Discovery a. [:1 The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Plaintiff Experts 30 days prior to trial. c. [:1 The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated(specify): CM-110lRev. July 1. 20111 Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Avo A. Sadakian CASE NUMBER: _ .. DEFENDANT/RESPONDENT: et . N'rmal . Smgh, et al- C|V531899 17. Economic litigation a. :1 This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code ofCivil 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 fi led (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 (specify): Set matter for mediation and trial date 20. Total number of pages attached(if any): l 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: July 27, 2016 Joseph R. Zoucha (TYPE OR PRINT NAME) P / Q / (SIGN fi /' OF PAéTY/OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) |___1 Additional signatures are attached. CM-110 [Rev. July 1,2011] Page50f5 CASE MANAGEMENT STATEMENT