Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Jeffrey H. Lowenthal (SBN 111763); Dana M. Andreoli (SBN 262068)
STEYER LOWENTHAL BOODROOKAS ALVAREZ & SMITH LLP
235 Pine Street, Fifteenth Floor, San Francisco, California 94104
415-421-3400
TELEPHONE NO.:
415-421-2234
FAX NO. (Optional):
10/6/2020
jlowenthal@steyerlaw.com; dandreoli@steyerlaw.com
E-MAIL ADDRESS (Optional):
ATTORNEY FOR (Name):
Defendants First American Title Insurance Co. and Brooke Walker-Fitzgerald
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Butte
STREET ADDRESS:1775 Concord Avenue
MAILING ADDRESS:
Chico 95928
CITY AND ZIP CODE:
BRANCH NAME:North Butte County Courthouse
PLAINTIFF/PETITIONER: RALPH LEAVERS, et al.
DEFENDANT/RESPONDENT: FIRST AMERICAN TITLE INS. CO., et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): X UNLIMITED CASE LIMITED CASE
(Amount demanded (Amount demanded is $25,000 18CV01420
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: October 21, 2020 Time: 10:30 a.m. Dept.: 10 Div.: Room:
Address of court (if different from the address above):
X Notice of Intent to Appear by Telephone, by (name): Dana M. Andreoli
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. This statement is submitted by party (name):
b. X This statement is submitted jointly by parties (names):
Defendants First American Title Insurance Company and Brooke Walker-Fitzgerald
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. 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. The following parties named in the complaint or cross-complaint
(1) have not been served (specify names and explain why not):
(2) have been served but have not appeared and have not been dismissed (specify names):
(3) have had a default entered against them (specify names):
c. X The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served): The case is not at issue. Plaintiffs have not named all necessary parties, and have stated
that they will be filing an amended complaint (which requires leave of court). Plaintiffs have not done so.
4. Description of case
a. Type of case in X complaint cross-complaint (Describe, including causes of action):
Plaintiffs allege causes of action for Breach of Contract, Breach of Fiduciary Duty, Negligence,
Professional Negligence
Page 1 of 5
Form Adopted for Mandatory Use
Judicial Council of California
CASE MANAGEMENT STATEMENT Cal. Rules of Court,
rules 3.720–3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
LexisNexis® Automated California Judicial Council Forms
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: RALPH LEAVERS, et al.
DEFENDANT/RESPONDENT: FIRST AMERICAN TITLE INS. CO., et al. 18CV01420
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.)
Plaintiffs allege that they obtained a cash out refinance to consolidate two mortgages on their real property, but
that the second lien was not paid through First American Title Company's escrow despite assurances that it would
be paid. First American Title Insurance Company (which did not act as the escrow company for this transaction)
and escrow officer Ms. Fitzgerald deny any liability to Plaintiffs or that Plaintiffs have any recoverable damages.
(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 X a jury triaI a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. The trial has been set for (date):
b. X 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): Plaintiffs have not named the correct and necessary parties for their claims, which will require leave of court. The amendment
will be futile and if allowed defendants will file a demurrer on the grounds that the claims are time barred and fail to state a cause of action.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
1/4/2021-7/16/2021 (trials, depositions, expert discovery and hearings in other matters)
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. X days (specify number): 3-4
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial X by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
9. Preference
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 X has 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 has has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) 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) X 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):
California Rules of Court, Rule 3.811(b)(1), (8)
CM-110 [Rev. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
LexisNexis® Automated California Judicial Council Forms
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: RALPH LEAVERS, et al.
DEFENDANT/RESPONDENT: 18CV01420
FIRST AMERICAN TITLE INS. CO., 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 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
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement X Settlement conference scheduled for (date):
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
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
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):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
LexisNexis® Automated California Judicial Council Forms
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: RALPH LEAVERS, et al.
18CV01420
DEFENDANT/RESPONDENT: FIRST AMERICAN TITLE INS. CO., et al.
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes No
c. 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.
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:
Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate wiII be filed by (name party):
14. 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
X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Demurrer to Amended Complaint, Motion for Summary Judgment
16. Discovery
a. The party or parties have completed all discovery.
b. X The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendants Written discovery Per Code
Defendants Depositions Per Code
Defendants Third party discovery Per Code
c. X The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Defendants propounded interrogatories, requests for production of documents and requests for
admission on plaintiffs in June 2018. Plaintiffs did not timely respond and waived all objections. In
September 2018, plaintiffs served partial and inadequate responses to Defendants' written discovery.
Defendants' counsel has met and conferred with Plaintiffs' counsel concerning the deficiencies and
plaintiffs agreed to supplement their responses and granted Defendants an open extension to file a
motion to compel. To date, plaintiffs have not served supplemental discovery responses as agreed.
CM-110 [Rev. July 1, 2011] Page 4 of 5
CASE MANAGEMENT STATEMENT
LexisNexis® Automated California Judicial Council Forms
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: RALPH LEAVERS, et al.
18CV01420
DEFENDANT/RESPONDENT: FIRST AMERICAN TITLE INS. CO., et al.
17. Economic litigation
a. 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. 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
X The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
The case is not at issue and the conference should be continued. Plaintiffs have not named all necessary
parties. Defendants have met and conferred with Plaintiffs concerning their objections to the first
amended complaint, and Plaintiffs have granted Defendants an open extension to respond while
Plaintiffs decide how to proceed.
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):
20. Total number of pages attached (if any): 0
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: October 5, 2020
Dana M. Andreoli
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev. July 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
LexisNexis® Automated California Judicial Council Forms
1 PROOF OF SERVICE
2 Ralph Leavers; et al. v. First American Title Insurance Company; et al.
County of Butte Superior Court, Case No. 18CV01420
3
I declare that I am over the age of eighteen years and that I am not a party to this action.
4 I am an employee of Steyer Lowenthal Boodrookas Alvarez & Smith LLP, and my business
address is 235 Pine Street, 15th Floor, San Francisco, CA 94104.
5
On the date set forth below, I served the following document(s):
6
CASE MANAGEMENT STATEMENT
7
on the interested parties in this action as follows:
8
9 Stacie L. Power
Lori Noelle Shaw
10 Power Law P.C.
1058 Mangrove Ave., Suite C
11 Chico California 95926
Telephone: (530) 576-5740
12 Facsimile: (888) 790-2216
Email: stacie@powerlawpc.com
13
[Attorneys for Plaintiffs
14 Ralph Leavers and Pricella Leavers and
Megastar Financial Corp.]
15
16  BY ONE LEGAL. I caused such document(s) to be electronically served via
OneLegal on all interested parties at the email addresses listed with the Court in this
17 matter.
18
I declare under penalty of perjury under the laws of the State of California that the
19 foregoing is true and correct.
20 Executed on October 6, 2020, at Berkeley, California.
21
22 Fred M. Terry
23
24
25
26
27
28
1
PROOF OF SERVICE
1647191.1 - F.LEAVERS
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Jeffrey H. Lowenthal (SBN 111763); Dana M. Andreoli (SBN 262068) STEYER LOWENTHAL BOODROOKAS ALVAREZ & SMITH LLP 235 Pine Street, Fifteenth Floor, San Francisco, California 94104 415-421-3400 TELEPHONE NO.: 415-421-2234 FAX NO. (Optional): 10/6/2020 jlowenthal@steyerlaw.com; dandreoli@steyerlaw.com E-MAIL ADDRESS (Optional): ATTORNEY FOR (Name): Defendants First American Title Insurance Co. and Brooke Walker-Fitzgerald SUPERIOR COURT OF CALIFORNIA, COUNTY OF Butte STREET ADDRESS:1775 Concord Avenue MAILING ADDRESS: Chico 95928 CITY AND ZIP CODE: BRANCH NAME:North Butte County Courthouse PLAINTIFF/PETITIONER: RALPH LEAVERS, et al. DEFENDANT/RESPONDENT: FIRST AMERICAN TITLE INS. CO., et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): X UNLIMITED CASE LIMITED CASE (Amount demanded (Amount demanded is $25,000 18CV01420 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: October 21, 2020 Time: 10:30 a.m. Dept.: 10 Div.: Room: Address of court (if different from the address above): X Notice of Intent to Appear by Telephone, by (name): Dana M. Andreoli INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): b. X This statement is submitted jointly by parties (names): Defendants First American Title Insurance Company and Brooke Walker-Fitzgerald 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. 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. The following parties named in the complaint or cross-complaint (1) have not been served (specify names and explain why not): (2) have been served but have not appeared and have not been dismissed (specify names): (3) have had a default entered against them (specify names): c. X The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): The case is not at issue. Plaintiffs have not named all necessary parties, and have stated that they will be filing an amended complaint (which requires leave of court). Plaintiffs have not done so. 4. Description of case a. Type of case in X complaint cross-complaint (Describe, including causes of action): Plaintiffs allege causes of action for Breach of Contract, Breach of Fiduciary Duty, Negligence, Professional Negligence Page 1 of 5 Form Adopted for Mandatory Use Judicial Council of California CASE MANAGEMENT STATEMENT Cal. Rules of Court, rules 3.720–3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov LexisNexis® Automated California Judicial Council Forms CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: RALPH LEAVERS, et al. DEFENDANT/RESPONDENT: FIRST AMERICAN TITLE INS. CO., et al. 18CV01420 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.) Plaintiffs allege that they obtained a cash out refinance to consolidate two mortgages on their real property, but that the second lien was not paid through First American Title Company's escrow despite assurances that it would be paid. First American Title Insurance Company (which did not act as the escrow company for this transaction) and escrow officer Ms. Fitzgerald deny any liability to Plaintiffs or that Plaintiffs have any recoverable damages. (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 X a jury triaI a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. The trial has been set for (date): b. X 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): Plaintiffs have not named the correct and necessary parties for their claims, which will require leave of court. The amendment will be futile and if allowed defendants will file a demurrer on the grounds that the claims are time barred and fail to state a cause of action. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 1/4/2021-7/16/2021 (trials, depositions, expert discovery and hearings in other matters) 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. X days (specify number): 3-4 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial X by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: Additional representation is described in Attachment 8. 9. Preference 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 X has 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 has has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) 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) X 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): California Rules of Court, Rule 3.811(b)(1), (8) CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT LexisNexis® Automated California Judicial Council Forms CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: RALPH LEAVERS, et al. DEFENDANT/RESPONDENT: 18CV01420 FIRST AMERICAN TITLE INS. CO., 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 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 Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement X Settlement conference scheduled for (date): 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 Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): 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): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT LexisNexis® Automated California Judicial Council Forms CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: RALPH LEAVERS, et al. 18CV01420 DEFENDANT/RESPONDENT: FIRST AMERICAN TITLE INS. CO., et al. 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes No c. 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. 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: Additional cases are described in Attachment 13a. b. A motion to consolidate coordinate wiII be filed by (name party): 14. 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 X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Demurrer to Amended Complaint, Motion for Summary Judgment 16. Discovery a. The party or parties have completed all discovery. b. X The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendants Written discovery Per Code Defendants Depositions Per Code Defendants Third party discovery Per Code c. X The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): Defendants propounded interrogatories, requests for production of documents and requests for admission on plaintiffs in June 2018. Plaintiffs did not timely respond and waived all objections. In September 2018, plaintiffs served partial and inadequate responses to Defendants' written discovery. Defendants' counsel has met and conferred with Plaintiffs' counsel concerning the deficiencies and plaintiffs agreed to supplement their responses and granted Defendants an open extension to file a motion to compel. To date, plaintiffs have not served supplemental discovery responses as agreed. CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT LexisNexis® Automated California Judicial Council Forms CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: RALPH LEAVERS, et al. 18CV01420 DEFENDANT/RESPONDENT: FIRST AMERICAN TITLE INS. CO., et al. 17. Economic litigation a. 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. 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 X The party or parties request that the following additional matters be considered or determined at the case management conference (specify): The case is not at issue and the conference should be continued. Plaintiffs have not named all necessary parties. Defendants have met and conferred with Plaintiffs concerning their objections to the first amended complaint, and Plaintiffs have granted Defendants an open extension to respond while Plaintiffs decide how to proceed. 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): 20. Total number of pages attached (if any): 0 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: October 5, 2020 Dana M. Andreoli (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. July 1, 2011] Page 5 of 5 CASE MANAGEMENT STATEMENT LexisNexis® Automated California Judicial Council Forms 1 PROOF OF SERVICE 2 Ralph Leavers; et al. v. First American Title Insurance Company; et al. County of Butte Superior Court, Case No. 18CV01420 3 I declare that I am over the age of eighteen years and that I am not a party to this action. 4 I am an employee of Steyer Lowenthal Boodrookas Alvarez & Smith LLP, and my business address is 235 Pine Street, 15th Floor, San Francisco, CA 94104. 5 On the date set forth below, I served the following document(s): 6 CASE MANAGEMENT STATEMENT 7 on the interested parties in this action as follows: 8 9 Stacie L. Power Lori Noelle Shaw 10 Power Law P.C. 1058 Mangrove Ave., Suite C 11 Chico California 95926 Telephone: (530) 576-5740 12 Facsimile: (888) 790-2216 Email: stacie@powerlawpc.com 13 [Attorneys for Plaintiffs 14 Ralph Leavers and Pricella Leavers and Megastar Financial Corp.] 15 16  BY ONE LEGAL. I caused such document(s) to be electronically served via OneLegal on all interested parties at the email addresses listed with the Court in this 17 matter. 18 I declare under penalty of perjury under the laws of the State of California that the 19 foregoing is true and correct. 20 Executed on October 6, 2020, at Berkeley, California. 21 22 Fred M. Terry 23 24 25 26 27 28 1 PROOF OF SERVICE 1647191.1 - F.LEAVERS