Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Jordan S. Altura/Margaret M. Drugan SBN 209431/175324
Gordon Rees Scully Mansukhani, LLP
633 West Fifth Street, 52nd Floor
Los Angeles, California 90071
TELEPHONE NO.: 213.576.5000 FAX NO. (Optional):
E-MAIL ADDRESS (Optional): mdrugan@grsm.com
ATTORNEY FOR (Name): Plaintiff, STANDARD INSURANCE COMPANY 07/08/2020
SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER
STREET ADDRESS: 10820 Justice Center Drive
MAILING ADDRESS:
Roseville
CITY AND ZIP CODE: 95678
BRANCH NAME:Bill Santucci Justice Center
PLAINTIFF/PETITIONER: STANDARD INSURANCE COMPANY, etc.
DEFENDANT/RESPONDENT: DAVID TEFERA, etc., et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
SCV0043710
(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: July 21, 2020 Time: 10:00 a.m. Dept.: 40 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Margaret M. Drugan
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): STANDARD INSURANCE COMPANY
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): September 27, 2019
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): David Tefera
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):
Interpleader for declaratory relief
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California
CASE MANAGEMENT STATEMENT rules 3.720–3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: STANDARD INSURANCE COMPANY, etc.
SCV0043710
DEFENDANT/RESPONDENT: DAVID TEFERA, etc., et al.
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.)
Standard Insurance Company is the insurer for a life insuance policy issued to Tsegereda Tefera, the deceased.
The named primary beneficiary on the policy, David Tefera - the husband of the deceased - has been indicted and
is awaiting trial for the death of Tsegereda Tefera. Defendants Amanuel and Hermela Tefera are the minor
children of the deceased and David Tefera and they are represented by a guardian ad litem, Janet Welborn.
Plaintiff has filed this interpleader due to the circumstances involving the indictment of David Tefera.
(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): 1-2
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
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: STANDARD INSURANCE COMPANY, etc.
SCV0043710
DEFENDANT/RESPONDENT: DAVID TEFERA, etc., 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 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
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: STANDARD INSURANCE COMPANY, etc.
SCV0043710
DEFENDANT/RESPONDENT: DAVID TEFERA, etc., 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
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
Plaintiff No Discovery Intended
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
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: STANDARD INSURANCE COMPANY, etc.
SCV0043710
DEFENDANT/RESPONDENT: DAVID TEFERA, etc., 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
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify): Standard has deposited the interpleader funds with the court as of 7/6/2020 as ordered.
Standard obtained an Entry of Default on 2/24/2020 as to David Tefera for failure to respond to the complaint.
Standard has submitted a proposed Judgment to the clerk for entry of judgment against David Tefera. The
remaining parties expect to submit a stipulation to dismiss Standard from the case and an agreement as to the
amount of attorneys' fees that Standard would be entiteld to recover as noted below.
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): I have spoken with Barbara Bender, the attorney for Janet Welborn, the guardian ad litem for the 2 minor
defendants. We agreed that we could come to a Stipulation to Dismiss Standard from this case as well as an
agreement on reasonable attorneys' fees to be paid to Standard from the funds on deposit with the court. The
remaining parties expect to submit that Stipulation to the court shortly, if not before the CMC.
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: July 8, 2020
Margaret M. Drugan
(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
American LegalNet, Inc.
www.FormsWorkFlow.com
1 PROOF OF SERVICE
2 I am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action. My business address is 633 West Fifth Street, 52nd Floor,
3
Los Angeles, California 90071.
4
On July 8, 2020, I served the following document described as CASE MANAGEMENT
5 STATEMENT on all interested parties in this action as follows:
6 Janet Welborn
7 c/o Barbara J. Bender
Law Offices of Barbara J. Bender
8 3626 Fair Oaks Boulevard, Suite 300
Sacramento, California 95864
9 (916) 550-5313
bbender@bendertrustlaw.com
10
11 [ ] (BY MAIL) I am “readily familiar” with the firm’s practice of collection and processing
correspondence by mailing. Under that practice it would be deposited with U.S. postal service
12 on that same day with postage fully prepaid at Los Angeles, California in the ordinary course of
business. I am aware that on motion of the party served, service is presumed invalid if postal
13 cancellation date or postage meter date is more than one day after date of deposit for mailing in
affidavit.
14
15 [ ] (BY FACSIMILE) The facsimile machine I used complied with Rule 2003(3) and no
error was reported by the machine. Pursuant to California Rules of Court, Rule 2008(e)(4), a
16 copy of said transmission report is attached hereto.
17 [ ] (BY OVERNIGHT DELIVERY/COURIER) I deposited such envelope in a box or
facility regularly maintained by the express service carrier in an envelope or package designated
18
by the express service carrier with delivery fees provided for.
19
[X] (BY ELECTRONIC MAIL) Based on the court order or agreement of the parties to
20 accept service by e-mail or electronic transmission, I caused the documents to be sent to the
persons identified above. I did not receive, within reasonable time after the transmission, any
21 electronic message or other indication that the transmission was unsuccessful.
22
[X] (STATE) I declare under penalty of perjury under the laws of the State of California that
23 the above is true and correct.
24 Executed on July 8, 2020, at Los Angeles, California.
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_____________________________________
26 Monine Zerby
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