Preview
CM-110
"ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY
Mark L. Dawson, Esq. (SBN 166956) Shamika K. Bains, Esq. (SBN 277450)
INORTON & MELNIK, APC
500 La Gonda Way, Suite 295, Danville, CA 94526 F Superior Court of California F
TELEPHONE No: (925) 718-1040 County of Butte
FAX NO. (Optional): (925) 743-1148
E-MAIL ADDRESS (Optional): Mdawson@nortonmelnik.com, sbains@nortonmelnik.com |
ATTORNEY
FOR (Name): Defendants, Jaycee Brooke Hague and Crystal Hutchison L 11/10/2020 L
SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE
street appress: 1775 CONCORD AVENUE
MAILING ADDRESS: Kimberty/Flener, Clerk D
CITY AND ZIP CODE: CHICO, CA 95928 By Deputy
Electronically FILED
BRANCH NAME:
PLAINTIFF/PETITIONER: Breanna Marie Lopez
DEFENDANT/RESPONDENT: Jayce Brooke Hague, Crystal Hutchison
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE [1] uitep case 19CV01872
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: December 2, 2020 Time: 10:30 a.m. Dept.: 10 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Mark L. Dawson, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specifi d information must be provided.
Party or parties (answer one):
a. This statement is submitted by party (name): Defendants, Jaycee Brooke Hague and Crystal Hutchison
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): 6/21/20
b. [-_] The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [J The following parties named in the complaint or cross-complaint
(1) [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) [shave had a default entered against them (specify names):
c. Co 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 complaint [1 cross-complaint (Describe, including causes of action):
Negligence; Negligence Per Se
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. July 1, 2011] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: Breanna Marie Lopez CASE NUMBER:
19CV01872
DEFENDANT/RESPONDENT: Jayce Brooke Hague, Crystal Hutchison
4. b. Provide a brief statement of the case, including any damages. (/f 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 personal injuries related to a January 10, 2018 motor vehicle accident.
[] (if more space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request C5) a jury trial a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a. [1 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):
Please see attached trial calendar for Mark L. Dawson, Esq.
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a days (specify number): 5-7 Days
b. [) hours (short causes) (specify):
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 [J by the following:
a Attorney:
b. Firm:
©. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
[1 Additional representation is described in Attachment 8.
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) For parties represented by counsel: Counsel has L_] 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 [J has [1] has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
@) CO This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
¢
mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
@ CO 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.
8) CO This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
‘CM-110 [Rev. July 1, 2017] CASE MANAGEMENT STATEMENT Page 20f5
CM-110
PLAINTIFF/PETITIONER: Breanna Marie Lopez [CASE NUMBER:
19CV01872
DEFENDANT/RESPONDENT: Jayce Brooke Hague, Crystal Hutchison
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. July1, 2011] Page
3 ofS
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Breanna Marie Lopez
CASE NUMBER:
|
19CV01872
DEFENDANT/RESPONDENT: Jayce Brooke Hague, Crystal Hutchison
11. Insurance
Insurance carrier, if any, for party filing this statement (name): IDS Property Casualty Insurance Company
Reservation of rights: [7 Yes No
[1 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.
[1] 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. [1 A motion to [1 consolidate [) coordinate will 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):
Various Motions in Limine Prior to Trial
16. Discovery
a. [_] The party or parties have completed all discovery.
The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Descriptio! Date
Defendants Written Discovery TBD
Defendants Oral Deposition of Plaintiff TBD
Defendants Oral Depositions of Parties/Witnesses TBD
Defendants Expert Discovery Per Code
c. [__] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
(CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page
4 of 5
CM-110
PLAINTIFF/PETITIONER: Breanna Marie Lopez CASE NUMBER:
L 19CV01872
DEFENDANT/RESPONDENT: Jayce Brooke Hague, Crystal Hutchison
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
[1 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. [7] 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): 1
lam 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: November 10, 2020
Mark L. Dawson, Esq.
(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] CASE MANAGEMENT STATEMENT Page 5 of 5
TRIAL CALENDAR
MARK L. DAWSON, ESQ.
(Updated 11/4/2020)
MATTER NAME COUNTY MSC Date TRIAL CALL | TRIAL DATE
PAAKKARI v Shuffitt Contra Costa 11/04/2020 11/04/2020 12/14/2020
WESCO v. Bedmart Shasta - 01/20/2021
HENDRICKX v. Perez Silva Sonoma - 01/22/2021
CASTILLO v Smith Fresno 01/20/2021 02/05/2021 02/08/2021
ANCHETA v Gutierrez San Francisco - 03/22/2021
TRAVELERS v Phollies, Inc. San Francisco 03/29/2021
RUIZ v New Perspectives Monterey 03/05/2021 04/05/2021
HERRERA v Rodriguez San Francisco 05/10/2021
RUIZ v Truck Driver/DR3 San Joaquin 05/03/2021 06/01/2021
Mark L. Dawson, Trial Attorney, Unavailable
Unavailable 6/20/21 through 7/11/21 6/20/21-
7/11/21
UNITED FINANCIAL v Pristupa Sonoma 07/16/2021
WOLFF v The Stable San Francisco 07/19/2021
CANTU v Hudson San Francisco 07/26/2021
KEELER v Tognoli Shasta 05/24/2021 - 08/10/2021
TRAN v Peng Alameda 07/14/2021 08/09/2021 08/16/2021
KATEN v Jucy (Cross-Complaint) San Francisco - 08/23/2021
SYED v. Sciutto Alameda 08/13/2021 08/30/2021
KRZOS v Morfin Sonoma - 09/17/2021
MAC EWYN (SKB with GPN case) 09/20/2021
LOPEZ v Mendoza San Joaquin 08/09/2021 09/27/2021
SAINOS v Temple Sonoma 10/15/2021
KATEN v Jucy (Complaint) San Francisco 12/06/2021
THOMPSON v Bayside Alameda 03/07/2022
TRIAL CALENDAR
MARK L. DAWSON, ESQ.
DAVIS v Giannecchini Alameda 04/25/2022
PROOF OF SERVICE
I am employed in the County of Contra Costa, State of California. I am over the age of
18 years and not a party to the within action. My business address is 500 La Gonda Way, Suite
295, Danville, California, 94526.
On the date set for the below, I served
e DEFENDANTS JAYCEE BROOKE HAGUE AND CRYSTAL HUTCHISON’S
CASE MANAGEMENT CONFERENCE STATEMENT
on the parties to said action by emailing a copy of the document to the email address set forth
below:
10
Attorneys for Plaintiff
11 Bobby Saadian, Esq.
12 Wilshire Law Firm
3055 Wilshire Blvd., 12 Floor.
13 Los Angeles, CA 90010
T: (213) 381-9988
14 F: (213) 381-9989
bobby@ wilshirelawfirm.com
15
16
LE] (BY MAIL) | am readily familiar with the firm's practice of collection and processing
17 correspondence for mailing. Under that practice, it would be deposited with the United States
Postal Service on that same day with first class postage thereon fully prepaid at Danville,
18 California, in the ordinary course of business.
19 (ONLY BE ELECTRONIC TRANSMISSION) Only by e-mailing the document(s)
20 I
to the persons at the e-mail address(es) listed above, that durin the Coronavirus (C ovid-19)
pandemic, Norton & Melnik will be working remotely, not ab! e to send physical mail as usual,
and are therefore using only electronic mail. No electronic message or other indication that the
21 transmission was unsuccessful was received within a reasonable time after the transmission.
22
I declare under penalty of perjury that the foregoing is true and correct. Executed at
23
Danville, California on November 10, 2020.
24
25 /s/ Catherine Hamze
26
27
28
PROOF OF SERVICE