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  • HALL, THOMAS v. WYNMAN, ROBERTCivil-Roseville document preview
  • HALL, THOMAS v. WYNMAN, ROBERTCivil-Roseville document preview
  • HALL, THOMAS v. WYNMAN, ROBERTCivil-Roseville document preview
  • HALL, THOMAS v. WYNMAN, ROBERTCivil-Roseville document preview
  • HALL, THOMAS v. WYNMAN, ROBERTCivil-Roseville document preview
  • HALL, THOMAS v. WYNMAN, ROBERTCivil-Roseville document preview
  • HALL, THOMAS v. WYNMAN, ROBERTCivil-Roseville document preview
  • HALL, THOMAS v. WYNMAN, ROBERTCivil-Roseville document preview
						
                                

Preview

CM-110 "ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY S. Christian Anderson (SBN 282976); Michael L. Smith (SBI N 160305) Manning & Kass, Ellrod, Ramirz, Trester LLP 1 California St, Suite 900, San Francisco, CA 94111 ELECTRONICALLY FILED Superior Court of California, ‘TELEPHONE NO. (415) 217-6990 FAX NO. (Optional (415) 219-6999 County of Placer E-MAIL ADDRESS (Optional): CSa@manningllp.com; mls@manningllp.com 7/20/2020 ATTORNEY FOR (Name): Defendant Robert Wynman By: Zacharie MeCrary, Deputy Clerk SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER STREET ADDRESS: 10820 J ustice Center Drive MAILING ADDRESS: city AND zip cove: Roseville, 95678 BRANCH NAME: Howard G. Gibson Courthouse PLAINTIFF/PETITIONER: Thomas Hall DEFENDANT/RESPONDENT: Robert Wynman CASE MANAGEMENT STATEMENT CASE NUMBER: S-CV-0038758 (Check one): [42] UNLIMITED CASE [J LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) [A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: August 4, 2020 Time: 10:00am Dept: 40 Div.: Room: \Address of court (if different from the address above): |] Notice of Intent to Appear by Telephone, by (name): S. Christian Anderson, Esq INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. [4] This statement is submitted by party (name): Defendant Robert Wynman b. [_] This statement is submitted jointly by parties (names): 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): 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) [J have not been served (specify names and explain why not): (2) [7] 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): Description of case a Type of case in [-x ] complaint [J cross-complaint (Describe, including causes of action): 1. Libel; 2. False Light Invasion of Privacy, 3. Misappropriation of Likeness; 4. Intentional Infliction of Emotional Distress Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California rules 3.720-3.730 (CM-110 [Rev. J uly 1, 2011] wwaw.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: Thomas Hall CASE NUMBER: DEFENDANT/RESPONDENT: Robert Wynman S-CV-0038758 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 eamings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff alleges various torts surrounding comments made by Defendant on an email chat group in or about 2016. Plaintiff is seeking general, special, punitive, and exemplary damages. Plaintiff is also seeking attomey's fees. [J (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial a. The party or parties request [_* ] a jury trial [J anonjury tial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a. [__] The trial has been set for (date): b. [22] 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 attome) will not be available for trial (specify dates and e lain reasons for unavailability): 2 week duration for: 8/3/20; 8/21/30; 9/22/20; 9/28/20; 10/6/20; 10/19/20; 11/3/20; 11, )9/20; 1/11/21; 2/01/21 Estimated length of trial The party or parties estimate that the trial will take (check one): a. [x ] days (specify number): 1-3 b. [_] hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial [J by the attorney or party listed in the caption [1 by the following: Attomey: Firm: Address: Telephone number: f. Fax number: E-mail address: g. Party represented: [-] Additional representation is described in Attachment 8. Preference [J This case is entitled to preference (specify code section): 10. Altemative 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 [J 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 subjectto 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 Califomia 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 PLAINTIFF/PETITIONER: Thomas Hall CASE NUMBER: DEFENDANT/RESPONDENT: Robert Wynman S-CV-0038758 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): [42] Mediation session not yet scheduled [] Mediation session scheduled for (date): (1) Mediation G4) [J Agreed to complete mediation by (date): [J Mediation completed on (date): [44] Settlement conference not yet scheduled (2) Settlement [J Settlement conference scheduled for (date): conference [_] Agreed to complete settlement conference by (date): [J Settlement conference completed on (date): [-] Neutral evaluation not yet scheduled [J Neutral evaluation scheduled for (date): (3) Neutral evaluation [J Agreed to complete neutral evaluation by (date): [J Neutral evaluation completed on (date): [J J udicial arbitration not yet scheduled (4) Nonbinding judicial [J J udicial arbitration scheduled for (date): arbitration [J Agreed to complete judicial arbitration by (date): [J J udicial arbitration completed on (date): [J Private arbitration not yet scheduled (5) Binding private [2— Private arbitration scheduled for (date): arbitration [J Agreed to complete private arbitration by (date): [J Private arbitration completed on (date): [J ADR session not yet scheduled [J ADR session scheduled for (date): (6) Other (specify): [J Agreed to complete ADR session by (date): [J ADR completed on (date): CM-110 (Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Thomas Hall CASE NUMBER: DEFENDANT/RESPONDENT: Robert Wynman S-CV-0038758 11. Insurance a. [4] Insurance canrer, if any, for party filing this statement (name): b. Reservation of rights: [x _] Yes [J 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. [J 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: [J Additional cases are described in Attachment 13a. b. [-_] A motionto [J consolidate [} coordinate will be filed by (name party): 14. Bifurcation [J 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. [4] The party or parties have completed all discovery. b. [__] The following discovery will be completed by the date specified (describe all anticipated discovery): Party Descriptiot Date c. [4] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): Plaintiff intends to call witnesses that were not disclosed during the discovery process; if Plaintiff intends to use these witnesses at trial in any capacity, we would request that discovery be reopened to allow for the depositions of these witnesses and further written discovery if needed. CM-110 [Rev. July 1, 2011) CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: Thomas Hall CASE NUMBER: DEFENDANT/RESPONDENT: Robert Wynman S-CV-0038758 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 [44] The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 1) Plaintiff is not entitled to a jury trial because he did not post jury fees at the original case management conference; 2) Plaintiff intends to call witnesses that were not disclosed during the discovery process; if Plaintiff intends to use these witnesses at trial in any capacity, we would request that discovery be reopened to allow for the depositions of these witnesses and further written discovery if needed. 19. Meet and confer a. [4] 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): Plaintiff and Defendant agreed on trial dates, however Plainitff refused to sign the stipulation and refused to allow his trial co-counsel to sign the stipulation for reasons unknown (see attachment). 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): 7 | 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 authorityto enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where r Date: J uly 20, 2020 S. Christian Anderson, Esq (TYPE OR PRINT NAME) > Lc bCEC (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) > (SIGNATURE OF PARTY OR ATTORNEY) [-] Additional signatures are attached. CM-110 [Rev. July 1, 2011) CASE MANAGEMENT STATEMENT Page 5 of 5 Grace Coller From: Grace Coller Sent: Monday, April 06, 2020 10:07 AM To: ‘tomhallfamilylaw@aol.com’; ‘akm@pmlegal.law’; ‘audiolaw@aol.com' Ce: Michael Smith; Lesley Perez Subject: RE: Hall v. Wynman: proposed Stipulation re: trial dates Tom, lam emailing to confirm that you and your trial counsel will not sign the stipulation regarding agreed upon trial dates in this matter, and that instead the court will be setting it at the trial setting conference. Thank you, Grace E. Coller, Esq. Attomey MANNING & KASS ELLROD, RAMIREZ, TRESTER LLP 1 California Street, Suite 900 San Francisco, California 9411: Tel: 415.217.6990 x 4609 | Fax: 415.217.6999 Email: gec@manningllp.com | Website: www.manningllp.com Dallas | Irvine | Los Angeles | New York | Phoenix | San Diego | San Francisco This email message, including any documents, files or other attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, or a person responsiblefor delivering this email messageto the intended recipient{s), please notify the sender of the delivery error by replying to this message, and then delete it and any attachments from your system. Thank you. From: Grace Coller Sent: Tuesday, March 17, 2020 10:49 AM To: ‘tomhallfamilylaw@aol.com'; akm@pmlegal.law; audiolaw@aol.com Cc: Michael Smith; Karen Greer Subject: RE: Hall v. Wynman: proposed Stipulation re: trial dates Tom, You seem like you have a lot of time on your hands. |, however, do not have time to engage in a back-and-forth email battle with you over something as simple as a stipulation on trial dates. You associated in Mr. McClaren as counsel in October— I’ve attached your association to this email. You’ve repeatedly represented that he will try this case with you. Therefore, he obviously must be available for our next trial date. That way we can avoid the unfortunate situation we found ourselves in last October where you showed up to t | without your trial co-counsel. Because Mr. McClaren’s promised availability as trial counsel is necessary for a trial date stipulation, | will not sign, nor will Michael sign, a stipulation without his signature on it. This case is very old and we cannot risk preparing for trial for a third time just to have you show up and say your co-counsel is not available. If you do not find the stipulation to mere trial dates agreeable, then we will simply have the court set the date at the next CMC. | would ask that Mr. McClaren also attend that CMC, as his availability for trial will be necessary as well. If he is not there and the court sets a date on which Mr. McClaren is not available, we will absolutely not stipulate to change the trial date again. Thank you, Grace E. Coller, Esq. Attomey MANNING & KASS gq | ELLROD, RAMIREZ, TRESTER LLP 1 California Street, Suite 900 San Francisco, California 94111 Tel: 415.217.6990 x 4609 | Fax: 415.217.6999 Email: gec@manningllp.com | Website: www.manningllp.com Dallas | Irvine | Los Angeles | New York | Phoenix | San Diego | San Francisco This email message, including any documents, files or other attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, or a person responsible for delivering this email messageto the intended recipient(s), please notify the sender of the delivery error by replying to this message, and then delete it and any attachments from your system. Thank you. From: tomhallfamilylaw@aol.com [mailto:tomhallfamilylaw@aol.com] Sent: Tuesday, March 17, 2020 9:22 AM To: Grace Coller; akm@pmlegal.law; audiolaw@aol.com Cc: Michael Smith; DSB@manningllp.com; EAH@manningllp.com; CEK@manningllp.com; BPS@manningllp.com; SLR@manningllp.com; Michael Watts Subject: Re: Hall v. Wynman: proposed Stipulation re: trial dates Dear Ms. Coller: As a courtesy to you, | copy your "colleagues" with this email. | believe that my "cc" list does not include all of your "colleagues" who have appeared in this case, but! think that | have picked up most of them. It is not my intention to continue to send email to each of your "colleagues." | have faith in the internal distribution capabilities of Manning & Kass to rely on that. One of your earlier emails to me pointed out a spelling error in my initial draft of a stipulation. Allow me to return the favor. The plural of "counsel" is "counsel," not "counsels" as it appears on line 19 of the first page of your draft stipulation. You have stated clearlythat Michael L. Smith has refused to sign any trial date stipulation. So it is inappropriate to put his name on where you will be signing. Please remove it, or have him change position on refusing to sign the stipulation. Mr. Smith is counsel of record, at this time, for Defendant. You are not. But you say that your's is the only signature needed for Defendant on the stipulation. | am counsel of record for Plaintiff, and will be the only signature needed for Plaintiff. Please remove Mr. McClaren's signature line. Despite your previous misrepresentation, Mr. McClaren is not counsel of record in this case. If you communicate with him in the future, please copy me on all written (including electronic) communications, and please do not communicate with him other than in writing, without first discussing it with me. Mr. McClaren has his own busy practice and should not be disturbed unnecessarily. | look forward to receiving your revised, signed draft of the stipulation. Very truly yours, Thomas M. Hall anne Original Message- aan From: Grace Coller To: ‘tomhallfamilylaw@ aol.com’ 'akm@pmlegal.law' Cc: Karen Greer ; Michael Smith Sent Mon, Mar 16, 2020 10:55 am Subject: RE: Hall v. Wynman: proposed Stipulation re: trial dates Mr. Hall, | just briefly spoke to your co-counsel, Mr. McClaren, regarding his availability for dates in August, September, and October. He stated that he was not available in September or the first two weeks of October due to various trials and travel plans. He suggested the second half of October, but after checking our calendar we unfortunately have back-to-back trials in the second half of October and cannot make those two weeks work. Therefore, | suggest we submit the stipulation with the current dates that comply with the court's original request, and the court can keep the CMC on calendar to discuss further dates if needed. I’ve re-drafted the stipulation per your request. Please sign, have your co-counsel sign, and retum to me at your earliest convenience. | will then have it filed with the court. Thank you, Grace From: Grace Coller Sent: Monday, March 16, 2020 10:19 AM To: 'tomhallfamilylaw@aol.com' Cc: Karen Greer; Michael Smith Subject: RE: Hall v. Wynman: proposed Stipulation re: trial dates Mr. Hall, Again, please stop excluding my colleagues from our emails. It significantly hinders our ability to schedule and stay organized. Please give me the name of your co-counsel and | will get you that stipulation ASAP. | checked our file, is it still Mr. McClaren? Thank you, Grace E. Coller, Esq. Attomey MANNING & KASS BE = ELLROD, RAMIREZ, TRESTER LLP 1 California Street, Suite 900 San Francisco, California 94111 Tel: 415.217.6990 x 4609 | Fax: 415.217.6999 Email: gec@manningllp.com | Website: www.manningllp.com Dallas | Irvine | Los Angeles | New York | Phoenix | San Diego | San Francisco This email message, including any documents, files or other attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, or a person responsible for delivering this email messageto the intended recipient(s), please notify the sender of the delivery error by replying to this message, and then delete it and any attachments from your system. Thank you. From: tomhallfamilylaw@ aol.com [mailto:tomhallfamilylaw@ aol.com] Sent: Monday, March 16, 2020 10:06 AM To: Grace Coller; tomhallfamilyiaw@aol.com Subject: Re: Hall v. Wynman: proposed Stipulation re: trial dates Dear Ms. Coller: Still waiting for your identification of the "multiple misrepresentations" you claim. The August date is not available to Plaintiff. The other dates are fine. | will look forward to receiving your draft of a stipulation. | think it bears considering that all courts seem to be curtailing schedules and pushing matters further into the distance. So even with a four year old case, it may be that the Court requires us to schedule beyondJ uly. Very truly yours, Thomas M. Hall anne Original Message- aan From: Grace Coller To: tomhallfamilylaw@ aol.com Cc: Michael Smith Karen Greer Sent: Thu, Mar 12, 2020 9:33 am Subject: RE: Hall v. Wynman: proposed Stipulation re: trial dates Mr. Hall, Please stop excluding my colleagues from our email chain as it hinders our availability to coordinate dates for this trial. Further, I continue to disagree with your multiple misrepresentations of past events. Weare available June 8, July 6, July 13, and August 31 I did not “reject” your stipulation, I merely pointed out a single typo and asked that your counsel of record who is associating in also sign the stipulation so it is not rejected by the court. However, in the interestof moving this forward I am happy to draft a new stipulation. Please provide the following: 1 The dates on which you are available that coincide with the above-provided dates 2. Thename of the other attomey of record for Plaintiff Without those two items I will be unable to re-draft the stipulation. Thank you, GraceE. Coller, Esq. Attomey MANNING & KASS BE ELLROD, RAMIREZ, TRESTER LLP 1 Califomia Street, Suite 900 ‘San Francisco, Califomia 94111 Tel: 415.217.6990 x 4609 | Fax: 415.217.6999 Enail: geo@manningilp.com | Website: www.manningllp.com Dallas | Irvine | Los Angeles | New Y ork | Phoenix | San Diego | San Francisoo This email message, i jany documents, files ar other attachments, is for the sole use of the intended recipient(s) and may contain confidential and information. ‘review, use, disdosure or distributionis: ‘prohibited. If you are not the intended recipient, or a person respansiblefor delivering this email message to the intended recipient(6), please notify the sender of the delivery exror by replying to this message, and then ddlete it and any attachments: your system Thank you. Fron tomhallfamilylaw@aol.com Sent: Thursday, March 12, 2020 9:19 AM To: Grace Coller ; tomhallfamilylaw@aol.com Subject: Re: Hall v. Wynman: proposed Stipulation re: trial dates Dear Ms. Coller: The Court asked that the parties attempt to find dates that are available to both sides for trial of this case, within 90-120 days. Initially Defendant did not answer the request for two weeks. When Defendant did propose dates, all within 90 days, I promptly responded, noting that two of the trial weeks proposed by Defendant were also availablefor Plaintiff. You then delayed more than another week before rejecting my draft stipulationfor those trial weeks. You then withdrew one of the remaining two weeks that Defendant had proposed, leaving only the week of June 8 to propose to the Court as a trial week. T hope that the Court may have the June 8 week available forus. But reverting to the Court original request, I now requestthat you review Defendant's calendar and propose other dates, during July and August, that we might propose if the Court cannot give us June 8. As my proposed stipulation was not acceptable to Defendant when presented, I will leave it to you to draft a better one. Please send me proposed trial dates for July and August, and I will review them. I will continue to hope that we can get the week of June 8. But let's give the Court what it asked for, which was multiple possible dates. Very truly yours, ThomasM. Hall -----Original Message----- From: Grace Coller To: tomhallfamilylaw@aol.com Cc: Michael Smith , Karen Greer ; Mark Wilson. Sent: Wed, Mar 11, 2020 10:31 am Subject: RE: Hall v. Wynman: proposed Stipulation re: trial dates Tom, We are no longer available for the week of 05/04, so the stipulation needs to reflect the June date only. Further, the attomey who has associated in as an attomey of record needs to sign this stipulation as well. Please send me the stipulation with his signature and then I will sign it. Thank you, GraceE. Coller, Esq. NY MANNING & KASS ELLROD, RAMIREZ, TRESTER LLP 1 Califomia Street, Suite 900 ‘San Francisco, Califomia 94111 Tel: 415.217.6990 x 4609 | Fax: 415.217.6999 Enail: geo@manningilp.com | Website: www.manningllp.com Dallas | Irvine | Los Angeles | New Y ork | Phoenix | San Diego | San Francisco ‘This email message, induding any documents, files or other attachments, is for the sole use of the intended recipient(s) and may contain confidential and ‘review, use, disdosure or distributionis: ‘prohibited. If you are not the intended recipient, or a person respansible for delivering this email message to the intended recipient(6), please notify the sender of the delivery exror by replying to this message, and then ddlete it and any attachments: your system Thank you. Front Grace Coller Sent: Tuesday, March 10, 2020 9:38 AM To: tomhallfamilylaw@aol.com Cc Michael Smith , Karen Greer , Mark Wilson Subject: Re: Hall v. Wynman: proposed Stipulation re: trial dates Mr. Hall, Please refrain from making inappropriate and irrelevant remarks about my career as an attomey. It is unbecoming of an experienced litigator like yourself. T amout of the office in depositions today. I will sign the stipulation when I am back in the office. Thank you, Grace Coller On Mar 10, 2020, at 9:00 AM, "tomhall familylaw@aol.co wrote: Dear Ms. Coller: Attached please find a corrected version of the stipulation re: trial dates. Mr. Wynman has been represented by four partners of your firm during this litigation. The most recent partnerto join the case, Mr. Smith, has twice expressly refused to comply with explicit Court Orders regardingtrial dates, assuring the basis for disobeying the Orders as Mr. ‘Wynman's refusal to grant him permission to obey the Court's In this context, as Mr. Smith remains the current partner of record before the Court, I believe that his signature on the stipulation is preferable to that of a new associate, who has been admitted to the bar for just 15 months, and who has never appeared for Mr. Wynman in this matter. Very truly yours, Thomas M. Hall -----Original Message----- From: Grace Coller To: tomhallfamilylaw@aol.com Cc: Michael Smith , Karen Greer ; S. Christian Anderson Sent: Mon, Mar9, 2020 1:38 pm Subject: RE: Hallv. Wynman: proposed Stipulation re: trial dates Good aftemoon Mr. Hall, I was also out of the office on Friday. That stipulation looks fine to us, however there is a typo under the first number - just missing the “T” in “The.” Otherwise that stip is fine - I cannot edit it myself because you sent it in PDF - so please send over the updated version and I will sign. Thanks so much, Grace From tomhallfamilylaw@aol.com Sent: Friday, March6, 2020 8:08 AM To: Grace Coller ; tomhallfamilylaw@aol.com Subject: Hall v. Wynman: proposed Stipulation re: trial dates Dear Ms. Coller: Attached please find a .pdf format proposed stipulation re: trial dates in the above-referenced matter. If this is acceptable to defendant, please execute it and retum it to me. I will then submit it to the Court. If defendant requires changes, please let me know what he requires, and provide a draft reflecting that. I will be away from the office today, but will advise the Court that we may have an agreement on trial dates, and. if so, will file a stipulation on Monday. Very truly yours, Thomas M. Hall PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO At the time of service, I was over 18 years of age and not a party to this action. Iam. employed in the County of San Francisco, State of Califomia. My business address is One Califomia Street, Suite 900, San Francisco, CA 94111. On July 20, 2020, I served true copies of the following document(s) described as CASE MANAGEMENT STATTEMENT on the interested parties in this action as follows: Thomas M. Hall, Esq. P.O. Box 49820 Brentwood Vill CA 90049 Tel: 310.231.3475 tomhallfamilylaw@aol.com In Propia Persona 10 ONLY BY ELECTRONIC TRANSMISSION: Only by emailing the document(s) to the 11 persons at the e-mail address(es). This is necessitated during the declared National cy due to the Coronavirus (COVID-19) pandemic because this office will be working remotely, not 12 ableto send physical mail as usual, and is therefore using only electronic mail. No electronic Qn ow ae message or other indication that the transmission was unsuccessful was received within a NH 13 reasonable time after the transmission. We will provide a physical copy, upon request only, when. we retumto the office at the conclusion of the National 14 I declare under penalty of perjury under the laws of the State of Califomia that the am 15 foregoing is true and cot 16 Executed onJuly 20, 2020, at San Francisco, Califomia. Petia. uous 17 18 Lisette Estevez- Watkins 19 20 21 22 23 24. 25 26 27 28