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  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
  • Daphne Beletsis, et al vs Christopher Guevara, et al(23) Unlimited Other PI / PD / WD document preview
						
                                

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CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY ELECTRONICALLY FILED Superior Court of California County of Santa Cruz TELEPHONE NO.: FAX NO. (Optional): 9/22/2020 12:00 PM E-MAIL ADDRESS (Optional): Alex Calvo, Clerk ATTORNEY FOR (Name): By: Sandra Gonzalez, Deputy SUPERIOR COURT OF CALIFORNIA, COUNTY OF STREET ADDRESS: MAILING ADDRESS: CITY AND ZIP CODE: BRANCH NAME: PLAINTIFF/PETITIONER: DEFENDANT/RESPONDENT: CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: Time: Dept.: Div.: Room: Address of court (if different from the address above): 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. This statement is submitted by party (name): b. 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): 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. 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 complaint 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 of Court, rules 3.720–3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: DEFENDANT/RESPONDENT: 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.) (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 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. 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): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): b. 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 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 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) 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. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: DEFENDANT/RESPONDENT: 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 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 CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: DEFENDANT/RESPONDENT: 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 The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. 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 c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: DEFENDANT/RESPONDENT: 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 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): 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: (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 Attachment 6c. (Dates on which parties or attorneys will not be available for trial) Trial dates in other cases: 10/26/20 10/30/20 11/2/20 11/3/20 11/9/20 11/16/20 11/30/20 12/4/20 12/7/20 12/14/20 1/11/21 1/19/21 1/25/21 2/1/21 2/5/21 2/8/21 2/16/21 2/22/21 2/23/21 3/1/21 3/9/21 3/15/21 3/22/21 4/5/21 4/20/21 5/3/21 5/4/21 5/17/21 5/18/21 5/21/21 5/28/21 6/1/21 6/8/21 6/18/21 6/21/21 6/25/21 6/28/21 7/12/21 7/19/21 7/23/21 7/26/21 8/2/21 8/30/21 1 PROOF OF SERVICE 2 I am employed in the County of Sacramento, State of California. I am over the age of 18 and not a party to the within action; my business address is 11341 Gold Express Drive, Suite 3 110, Gold River, California 95670. 4 On September 22, 2020, I served the foregoing document(s) described as CASE 5 MANAGEMENT STATEMENT on the interested parties in this action by placing the copies thereof enclosed in sealed envelopes addressed as follows: 6 -SEE ATTACHED SERVICE LIST- 7 BY ELECTRONIC TRANSMISSION. Only by emailing the document(s) to the persons at the e- 8 mail address(es). This is necessitated during the declared National Emergency due to the 9 Coronavirus (COVID-19) pandemic because this office will be working remotely, not able to send physical mail as usual, and is therefore using only electronic mail. No electronic message 10 or other indication that the transmission was unsuccessful was received within a reasonable time 11 after the transmission. We will provide a physical copy, upon request only, when we return to the office at the conclusion of the national emergency. 12 13 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on September 22, 2020, at Gold River, California. 14 15 Mary A. Gillis 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE SERVICE LIST Douglas E. Fierberg, Esq. Ivo Labar, Esq. Jonathon N. Fazzola, Esq. SAWYER & LABAR, LLP Lisa N. Cloutier, Esq. 201 Mission St., Suite 2240 THE FIERBERG NATIONAL LAW GROUP San Francisco, CA 94105 161 E. Front St., Suite 200 Telephone: 415-262-3820 Tiaverse City, MI 49684 Emails: labar@sawyerlabar.com Telephone: 202-351-0510 guzman@sawyerlabar.com Facsimile: 231-252-8100 Co-Counsel for Plaintiff Emails: dfierberg@tfnlgroup.com jfazzola@tfnlgroup.com lcloutier@tfnlgroup.com tpicard@tfnlgroup.com Attorney for Plaintiff Robert T. Mackey, Esq. Thomas M. Phillips, Esq. VEATCH CARLSON, LLP William P. Ryan, Esq. 1055 Wilshire Blvd., 11th Floor THE PHILLIPS FIRM, APC Los Angeles, CA 90017 800 West Sixth Street, Suite 980 Telephone: 213-381-2861 Los Angeles, CA 90017 Facsimile: 213-383-6370 Telephone: 213-587-7414 Emails: rmackey@veatchfirm.com Facsimile: 213-457-7515 cporter@veatchfirm.com Emails: tphillips@thephillipsfirm.com Attorneys for Defendant pmckinley@thephillipsfirm.com STEFAN MATIAS LEON Co-Counsel for Defendant STEFAN MATIAS LEON Matthew C. Jaime, Esq. Alan F. Hunter, Esq. MATHENY SEARS LINKERT & JAIME, LLP Elizabeth G. Landess, Esq. 3638 American River Drive Jack T. Bussell, Esq. Sacramento, CA 95864 GAVIN CUNNINGHAM & HUNTER Telephone.: 916-978-3434 x 129 1530 The Alameda, Suite 210 Email: mjaime@mathenysears.com San Jose, CA 95126 Attorneys for Defendant Tel: 408-294-8500 CHRISTOPHER GUEVARA Fax: 408-294-8596 Email: hunter@gclitigation.com Attorneys for Defendant RAFAEL GARCIA, JR. Ray Tamaddon, Esq. Robert J. Romero, Esq. HINSHAW & CULBERTSON LLP HINSHAW & CULBERTSON LLP 11601 Wilshire Blvd., Suite 800 One California Street, 18th Floor Los Angeles, CA 90025 San Francisco, CA 94111 Telephone: 310-909-8000 Telephone: 415-362-6000 Facsimile: 310-909-8001 Fax: 415-834-9070 Email: rtamaddon@hinshawlaw.com Email: rromero@hinshawlaw.com Attorneys for Defendant KHightower@hinshawlaw.com ZACHARY NASH DAVIS Co-Counsel for Defendant ZACHARY DAVIS Michael C. Osborn, Esq. Julie Azevedo, Esq. Jaskiran Samra, Esq. Shawn Toliver, Esq. COKINOS | YOUNG LEWIS BRISBOIS BISGAARD & SMITH One Embarcadero Center, Suite 390 2185 N. California Blvd., Suite 300 San Francisco, CA 94111-2585 Walnut Creek, CA 94596 Telephone: 415-228-0208 Telephone: 925.357.3456 Emails: mosborne@cokinoslaw.com Facsimile: 925.478.3260 jsamra@cokinoslaw.com Emails: Julie.Azevedo@lewisbrisbois.com asanchez@cokinoslaw.com Shawn.Toliver@lewisbrisbois.com Attorneys for Defendant Janet.leader@lewisbrisbois.com THETA CHI FRATERNITY, INC Kristen.Garcia@lewisbrisbois.com Attorneys for Defendant JORDAN KEIICHI TAKAYAMA Mary Childs, Esq. Patrick R. Ball, Esq. Aaron Case, Esq. Idin Kashefipour, Esq. YOKA & SMITH MESSNER REEVES LLC. 445 South Figueroa Street, 38th Floor 10866 Wilshire Boulevard, Suite 800 Los Angeles, CA 90071 Los Angeles, CA 90024 Telephone.: 213-427-2300 Telephone: 310-909-7440/949-612-9136 Email: mchilds@yokasmith.com Facsimile: 310-889-0896 service@yokasmith.com Email: pball@messner.com amcnulty@yokasmith.com ikashefipour@messner.com acase@yokasmith.com Attorneys for Defendant Attorneys for Defendants MOISES TENORIO GARCIA EMMANUEL THOMAS, BOBBY KARKI, DEREK KING and JOHN DYLAN LEITCH Norman L. Chong, Esq. Andrew M. Lauderdale, Esq. Samantha Lewin, Esq. HARTSUYKER STRATMAN & Joseph D. O’Neil, Esq. WILLIAMS-ABREGO TARKINGTON, O’NEILL, One Almaden Blvd., Suite 400 BARRACK & CHONG San Jose, CA 95113 A Professional Corporation Telephone: 408-271-5325/831-251-1964 201 Mission Street, Suite 710 Facsimile: 408-271-5301 San Francisco, CA 94105 Email: andrew.lauderdale@farrnersinsurance.com Telephone: 415-777-5501/707 576-1380 Attorneys for Defendant Facsimile: 415- 546-4962/707-544-3144 QUINN MCLAUGHLIN Emails: joneil@to2law.com nchong@to2law.com slewin@to2law.com therrington@to2law.com Attorneys for Defendant NAJPREET SINGH KAHLON