Preview
CM-110
ATTORNEY OR PARTY INITHOUT ATTORNEY fName Slale Bar number
end addmssi
Amanda FOR COURT USE ONLY
N Esq. (SBN 288164)
Griffith,
BERMAN BERMAN BERMAN SCHNEIDER & LQINARY, LLP
2390 Professional Drive
Roseville, CA 95661
TELEPHONE No (916) 846-9391 FAx No fopfmneg(916) 672-9290
E-MAIL angriffith@b3law.corn
ADDREss fonfronalf 11/17/2020
ATroRNEY FoR fwamelCross-Defendant KBR INC. RASH CURTIS & ASSOCIATES
SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE
BTREETAoDREss 1775 Concord Avenue
MniuNC AoDREss 1775 Concord Avenue
cIIYANI31IP coDEChico, CA 95928
BRANCH NAME
PLAINTIFF/PETITIONER KBR INC. RASH CURTIS & ASSOCIATES
DEFENDANT/RESPONDENT: LINDA SALAZARAKA LINDA HEREDIA
CASE
(Check one): ~x UNLIMITED CASE
(Amount demanded
~
MANAGEMENT STATEMENT
LIMITED CASE
(Amount demanded is $ 25,000
CASE NUMBER
~C V0((ff Z.5
exceeds $ 25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: December 9, 2020 Time: 10:30 a.m. Dept.; 1 Dive Room:
Address of court (if different from the address above):
~x Notice of Intent to Appear by Telephone, by (name)f Amanda N. Griffith,
Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
2.
a.
b. ~~x This statement is submitted by party (name): Cross-Defendant KBR INC, RASH CURTIS & ASSOCIATES only
This statement is submitted jointly by parties(names):
Complaint and cross-complaint (to be answered by plaintiffs and cmss-compieinanls only)
The complaint was filed on
~
a. (date):
b. The cross-complaint, if any, was filed on (date):
3.
a.
b.
~
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.
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 (speciyy names, nature of involvement in case,
they may be served):
and date by which
4. Description of case
a. Type of case in
Complaint.
~x complaint
1) Common Counts
~ cross-complaint (Describe, including causes of action):
Cross-Compliant: 1) Violation of California Rosenthal Fair Debt Collection Practices Act C.C.P. sections 1788
et seq., 2) Unfair
Practices Act; 3) violation of Fair Debt collection Practices Act 15 U.s.c. 1692 et seqc 4) Declaratory Relief
Page I of 5
Fo Ad pl dfo
Ma CstoWUse Cel
Iof Col lorn e
J uCr eral Donne
CASE MANAGEMENT STATEMENT R s of Co rl
I
rules 3 120-3 T30
CM-110 IRev July I, 2011I www coons cs gov
CM-110
PLAINTIFF/PETITIONER: KBR INC. RASH CURTIS 8 ASSOCIATES CASE NUMBER
DEFENDANT/RESPONDENT. LINDA SALAZAR AKA LINDA HEREDIA Z.OCVnl(f 2,5
4. b. Provide a brief statement af the case, including any damages. (If personatinjury damages are sought, specify the injury and
damages claimed, including medica( expenses to date (indicate source and amount), estimated future medical expenses, lost
earnings to date,end estimated future Iasl earnings. If equitable relic/is sought, describe Ihe nature of the relief)
This matter arises out of a Cross-Defendant's collection of a medical debt owed by Cross-Complainant Cross-Defendant
denies all allegations of wrong doing.
~ (If more space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
a. The party or parties request ~x
requesting e jury trial):
a jury trial ~ a nonjury trial.(If more than one party, provide the name of each party
Trial date
a.
b,
~
~x
The trial has been set for(date)J
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):
This case is nat yet at issue against the Cross-Defendant.
c. Dates on which parties or attorneys will nat be available for trial (specify dates and explain reasons for unavailability):
Please refer to attachment 6.c.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a.
b ~
~x days (specify number):3-5 inclusive of jury selection
hours (short causes) (specify):
Trial representation (to be answered far each party)
B.
The party ar parties will be represented at trial
a. Attorney:
~x by the attorney or party listed in the caption ~ by the following:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
~e. E-mail address:
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
(2) ~
For self-represented parties: Party has ~
in rule 3.221 to the client and reviewed ADR options withthe dient.
has not reviewed the ADR information package identified in rule 3 221
b.
(1)~
Referral to judicial arbitration or civil action mediation (if available).
This matter is subject to mandatory judicial arbitration under Cade 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
(2)~ statutory limit.
Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
(3)~ Civil Procedure section 1141.11.
This case is exempt from judicial arbitration under rule 3.811
of the California Rules of Court or from cwil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM 110 IRoJuly \
2BI Il gogo2of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER. KBR INC. RASH CURTIS & ASSOCIATES
DEFENDANT/RESPONDENT'INDA SALAZAR AKA LINDA HEREDIA
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 thai 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'DR
processes (check a/I that app/y): stipulation)i
(1) Mediation
~
~x
~
Mediation session not yet scheduled
Mediation session scheduled for (date):
~ Agreed to complete mediation by (dale):
Mediation completed on (date)i
(2) Settlement
conference
~
~x
~
Settlement conference not yet scheduled
Settlement conference scheduled for(dale):
~ Agreed to complete settlement conference by(dele):
Settlement conference completed on (dale):
~
~ Neutral evaluation not yet scheduled
(3) Neutral evaluation
~
~
Neutral evaluation scheduled for (dale):
Agreed to complete neutral evaluation by
Neutral evaluation completed on (date):
(date):
~
~ Judicial arbitration not yet scheduled
(4) Nonbinding judicial
arbitration ~
~
Judicial arbitration scheduled for
(date):
Agreed to complete iudicial arbitration by
Judicial arbitration completed on (dale):
(date):
~
~ Private arbitration not yet scheduled
(5) Binding private
arbitration ~ Private arbitration scheduled for(dale):
Agreed to complete private arbitration by
Private arbitration completed on (dale):
(dale)'
~
~ ADR session not yet scheduled
(5) Other (specify);
~
~
ADR session scheduled for (dale).
Agreed to complete ADR session by (dale):
ADR completed on (date)i
CM110[ne Jly1 2011I 0 0 3013
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER KBR INC. RASH CURTIS & ASSOCIATES CASE NUMBER
DEFENDANT/RESPONDENT: LINDA SALAZAR AKA LINDA HEREDIA
11. Insurance
a.
b.
~ Insurance carrier,
Reservation of rights: ~
ifany, far party filing this statement (name)/
Yes ~ No
c. ~ Coverage issues will significantly affect resolution of this case
(exp/ain)/
12.Jurisdiction
~ Bankruptcy
Status;
~
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
Other (specify):
13.
a. ~
Related cases, consolidation, and coordination
There are companion, underlying, or related cases.
(1) Name of case;
(2) Name of court:
(3) Case number:
Status:
~ (4)
Additional cases are described in Attachment 13a.
b. ~ A motion to ~ consolidate ~ coordinate will be filed by
(name perry):
Bifurcation
14
~ The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (spec/fy moving party, type ofmotion. and reasons):
15. Other motions
~x The party or parties expect to file the fallowing motions before trial
(specify moving party,type of motion, and issues):
Cross-Defendant was served with the Amended Cross-Complaint on November 16, 2020 and are reviewing for a demurrer
and motion to strike.
Discovery
~
16.
a. The party or parties have completed all discovery.
b. ~x The following discovery will be compteted by the date specified (describe s/I anticipated discovery):
Pa~rt Descriotion Date
Cross-Defendant Wntten Discovery Per Code
Cross-Defendant Depositions Per Code
Cross-Defendant Expert Discovery Per Code
c. ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify)
BM-110 IReu July 1, 2011/
CASE MANAGEMENT STATEMENT Page 4 of
5
CM-1 10
PLAINTIFF/PETITIONER: KBR INC. RASH CURTIS & ASSOCIATES CASE NUMBER
DEFENDANT/RESPONDENT LINDA SAI AZAR AKA LINDA HEREDIA
M CVO (lto 2-5
Economic litigation
~
17.
a. (ie, the amount demanded is $25,000 ar less) and the economic litigation
This is a limited civil case procedures inCode
case.
of Civil Procedure sections 90-98 will apply to this
b ~ This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
(if checked, explain specifically why economic litigation procedures relating lo discovery or trial
discovery will be filed
should nol apply lo this case):
Other issues
~
18.
The party ar parties request that the following additional matters be considered or determined at the case management
conference (specify)i
19. Meet and confer
a. ~x 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 explain):
(if nol,
b. ~x After meeting and canferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
Cross-Defendant met and conferred with counsel for Cross-Complainant prior to filing a demurrer. As a result, Cross-
Complainant filed an amended complaint on November 16, 2020.
20. Total number of pages attached (ff any): 1
Iam 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 17, 2020
Amanda Esq.
N. Gnffith,
(TYPE OR PRINT NAMEI QF PARTY jIR AfTCRNkyi
1TYPE OR PRINT NAME) i
~
(SIGNATURE OF PARTY OR
ATTORNEY
Additional signatures are attached
OM-IIDIReeJIy I20III Page5of 6
CASE MANAGEMENT STATEMENT
MC-025
SHORT CASE NUMBER
TITLE'BR
INC. RASH CURTIS k. ASSOCIATFS v. SALAZAR, et al. 20CV01623
ATTACHMENT (Number)f 6 C.
(This Attachmenl may be used with any Judicial Council form.)
DATES OF UNAVAILABILITY
I/25/2021 (5 day trial); I/27/2021 (5 day trial); 2/16/2021 (5 day trial); 3/8/2021 (5 day trial); 4/7/2021 (5 day
trial); 4/19/2021 (5 day trial);4/19/2021 (5 day trial); 4/30/2020 (5 day trial); 5/18/2021; 6/28/2021 (5 day
trial); 8/2/2021 (5 day trial); 9/9/2021 (5 day trial) 10/12/2021 (5 day trial); 12/13/2021 (5 day trial); 6/24/2022
(if the item thai this Attachment concerns is made under penalty of penury, all slatements in this Page 6 of 6
Altachment are made under penalty of perjury)
(Add pages as required)
Form Approved for Optional Uae www courltnfo ca gav
Jud c at Counol of Cal forn a ATTACHMENT
MC-029 IRev July 1
20tlgl to Judicial Council Form
PROOF OF SERVICE
STATE OI'AI.IFORNIA )
3 ) ss.
COUNTY OF PLACER )
4
I am employed in the County of Placer, State of California. Iam over the age of 18 and not
a party to the within action. My business address is 2390 Professional Drive„Roseville, CA
6
95661.
7 On November 17, 2020, I served the foregoing document described as "CASE
MANGEMENT STATEMENT" on the interested parties in this action by placing a [X] true
copy thereol'J the original document enclosed in a sealed envelope addressed as I'ollows:
10
12
13
X
ot'his
United
(BY
business
business,
electronic
noted
(BY
in
I
MAIL)
States
office,
Postal
In
with
Service
deposited such sealed
ordinary business practices.
ELECTRONIC
transmission,
thc
I
attached
sent
[SEE ATTACHED SERVICE LISTJ
accordance
which
at
the
service
I am
with
Roseville,
the regular
familiar, by
California
envelope for collection
MAIL) Based
above document(s)
list from
on
my
mail
means
the
to
that
and
the
collection
of
same
which
day
mailing on
parties'greement
person(s)
electronic
and
mail
in
processing
this
at the
service
is
the
to
deposited
ordinary
same date
accept
electronic
address
practices
with
course
the
following
service
address(cs)
which
of
by
is
"damainQab31aw.corn'6
(BY OVERNIGHT MAIL)
17 I caused such envelope to be delivered by hand to the office of the
addressee, either by overnight delivery via Federal Express or Overnite Express.
18
19
(BY PERSONAL SERVICE)
By personally delivering copies to the person served.
20 I delivered such envelope by hand to the office of the addressee pursuant to
C.C.P. Section 1011.
21 I caused such envelope to be delivered by hand to the office of the
addressee, by local courier service.
22 I caused such envelope to be delivered to the office of the addressee, by
23
telecopier or facsimile machine. Proof of such delivery is attached hereto.
STATE
25 X I declare under penalty of perjury under the laws of the State of California that the above is
true and correct.
26
27
Executed November 17, 2020, at Roseville, California.
Debbie Main
Name Signature
Service List
KBA, inc. Rasit Curtis d'c Associates v. Linda Salazar, et al.
Butter County Superior Court Case No: 20CV01623
3
Duane S. Olivcira, Esq.
4 OLIVERIA LAW FIRM
190 S. Orchard Avenue, Suite A-200
Vacaville, CA 95688
Tel: (707) 454-2041
Attorneys for PLAINTIFF KBR INC. DBA RASH CURTIS & ASSOCIATES
JillL. Harris, Esq.
HARRIS CONSUMER LAW
1809 S Street, Suite 101-174
Sacramento, CA 95811
Tel: (916) 572-9410
Fax: (916) 905-3088
E-mail:iiIIFa.harrisconsumerlaw.corn
Attorney for DEFENDANT & CROSS-COMPLAINANT LINDA SALAZAR
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Preview
CM-110 ATTORNEY OR PARTY INITHOUT ATTORNEY fName Slale Bar number end addmssi Amanda FOR COURT USE ONLY N Esq. (SBN 288164) Griffith, BERMAN BERMAN BERMAN SCHNEIDER & LQINARY, LLP 2390 Professional Drive Roseville, CA 95661 TELEPHONE No (916) 846-9391 FAx No fopfmneg(916) 672-9290 E-MAIL angriffith@b3law.corn ADDREss fonfronalf 11/17/2020 ATroRNEY FoR fwamelCross-Defendant KBR INC. RASH CURTIS & ASSOCIATES SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE BTREETAoDREss 1775 Concord Avenue MniuNC AoDREss 1775 Concord Avenue cIIYANI31IP coDEChico, CA 95928 BRANCH NAME PLAINTIFF/PETITIONER KBR INC. RASH CURTIS & ASSOCIATES DEFENDANT/RESPONDENT: LINDA SALAZARAKA LINDA HEREDIA CASE (Check one): ~x UNLIMITED CASE (Amount demanded ~ MANAGEMENT STATEMENT LIMITED CASE (Amount demanded is $ 25,000 CASE NUMBER ~C V0((ff Z.5 exceeds $ 25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: December 9, 2020 Time: 10:30 a.m. Dept.; 1 Dive Room: Address of court (if different from the address above): ~x Notice of Intent to Appear by Telephone, by (name)f Amanda N. Griffith, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): 2. a. b. ~~x This statement is submitted by party (name): Cross-Defendant KBR INC, RASH CURTIS & ASSOCIATES only This statement is submitted jointly by parties(names): Complaint and cross-complaint (to be answered by plaintiffs and cmss-compieinanls only) The complaint was filed on ~ a. (date): b. The cross-complaint, if any, was filed on (date): 3. a. b. ~ 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. 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 (speciyy names, nature of involvement in case, they may be served): and date by which 4. Description of case a. Type of case in Complaint. ~x complaint 1) Common Counts ~ cross-complaint (Describe, including causes of action): Cross-Compliant: 1) Violation of California Rosenthal Fair Debt Collection Practices Act C.C.P. sections 1788 et seq., 2) Unfair Practices Act; 3) violation of Fair Debt collection Practices Act 15 U.s.c. 1692 et seqc 4) Declaratory Relief Page I of 5 Fo Ad pl dfo Ma CstoWUse Cel Iof Col lorn e J uCr eral Donne CASE MANAGEMENT STATEMENT R s of Co rl I rules 3 120-3 T30 CM-110 IRev July I, 2011I www coons cs gov CM-110 PLAINTIFF/PETITIONER: KBR INC. RASH CURTIS 8 ASSOCIATES CASE NUMBER DEFENDANT/RESPONDENT. LINDA SALAZAR AKA LINDA HEREDIA Z.OCVnl(f 2,5 4. b. Provide a brief statement af the case, including any damages. (If personatinjury damages are sought, specify the injury and damages claimed, including medica( expenses to date (indicate source and amount), estimated future medical expenses, lost earnings to date,end estimated future Iasl earnings. If equitable relic/is sought, describe Ihe nature of the relief) This matter arises out of a Cross-Defendant's collection of a medical debt owed by Cross-Complainant Cross-Defendant denies all allegations of wrong doing. ~ (If more space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial a. The party or parties request ~x requesting e jury trial): a jury trial ~ a nonjury trial.(If more than one party, provide the name of each party Trial date a. b, ~ ~x The trial has been set for(date)J 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): This case is nat yet at issue against the Cross-Defendant. c. Dates on which parties or attorneys will nat be available for trial (specify dates and explain reasons for unavailability): Please refer to attachment 6.c. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. b ~ ~x days (specify number):3-5 inclusive of jury selection hours (short causes) (specify): Trial representation (to be answered far each party) B. The party ar parties will be represented at trial a. Attorney: ~x by the attorney or party listed in the caption ~ by the following: b. Firm: c. Address: d. Telephone number: f. Fax number: ~e. E-mail address: 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 (2) ~ For self-represented parties: Party has ~ in rule 3.221 to the client and reviewed ADR options withthe dient. has not reviewed the ADR information package identified in rule 3 221 b. (1)~ Referral to judicial arbitration or civil action mediation (if available). This matter is subject to mandatory judicial arbitration under Cade 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 (2)~ statutory limit. Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of (3)~ Civil Procedure section 1141.11. This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from cwil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM 110 IRoJuly \ 2BI Il gogo2of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER. KBR INC. RASH CURTIS & ASSOCIATES DEFENDANT/RESPONDENT'INDA SALAZAR AKA LINDA HEREDIA 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 thai 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'DR processes (check a/I that app/y): stipulation)i (1) Mediation ~ ~x ~ Mediation session not yet scheduled Mediation session scheduled for (date): ~ Agreed to complete mediation by (dale): Mediation completed on (date)i (2) Settlement conference ~ ~x ~ Settlement conference not yet scheduled Settlement conference scheduled for(dale): ~ Agreed to complete settlement conference by(dele): Settlement conference completed on (dale): ~ ~ Neutral evaluation not yet scheduled (3) Neutral evaluation ~ ~ Neutral evaluation scheduled for (dale): Agreed to complete neutral evaluation by Neutral evaluation completed on (date): (date): ~ ~ Judicial arbitration not yet scheduled (4) Nonbinding judicial arbitration ~ ~ Judicial arbitration scheduled for (date): Agreed to complete iudicial arbitration by Judicial arbitration completed on (dale): (date): ~ ~ Private arbitration not yet scheduled (5) Binding private arbitration ~ Private arbitration scheduled for(dale): Agreed to complete private arbitration by Private arbitration completed on (dale): (dale)' ~ ~ ADR session not yet scheduled (5) Other (specify); ~ ~ ADR session scheduled for (dale). Agreed to complete ADR session by (dale): ADR completed on (date)i CM110[ne Jly1 2011I 0 0 3013 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER KBR INC. RASH CURTIS & ASSOCIATES CASE NUMBER DEFENDANT/RESPONDENT: LINDA SALAZAR AKA LINDA HEREDIA 11. Insurance a. b. ~ Insurance carrier, Reservation of rights: ~ ifany, far party filing this statement (name)/ Yes ~ No c. ~ Coverage issues will significantly affect resolution of this case (exp/ain)/ 12.Jurisdiction ~ Bankruptcy Status; ~ Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Other (specify): 13. a. ~ Related cases, consolidation, and coordination There are companion, underlying, or related cases. (1) Name of case; (2) Name of court: (3) Case number: Status: ~ (4) Additional cases are described in Attachment 13a. b. ~ A motion to ~ consolidate ~ coordinate will be filed by (name perry): Bifurcation 14 ~ The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (spec/fy moving party, type ofmotion. and reasons): 15. Other motions ~x The party or parties expect to file the fallowing motions before trial (specify moving party,type of motion, and issues): Cross-Defendant was served with the Amended Cross-Complaint on November 16, 2020 and are reviewing for a demurrer and motion to strike. Discovery ~ 16. a. The party or parties have completed all discovery. b. ~x The following discovery will be compteted by the date specified (describe s/I anticipated discovery): Pa~rt Descriotion Date Cross-Defendant Wntten Discovery Per Code Cross-Defendant Depositions Per Code Cross-Defendant Expert Discovery Per Code c. ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify) BM-110 IReu July 1, 2011/ CASE MANAGEMENT STATEMENT Page 4 of 5 CM-1 10 PLAINTIFF/PETITIONER: KBR INC. RASH CURTIS & ASSOCIATES CASE NUMBER DEFENDANT/RESPONDENT LINDA SAI AZAR AKA LINDA HEREDIA M CVO (lto 2-5 Economic litigation ~ 17. a. (ie, the amount demanded is $25,000 ar less) and the economic litigation This is a limited civil case procedures inCode case. of Civil Procedure sections 90-98 will apply to this b ~ This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional (if checked, explain specifically why economic litigation procedures relating lo discovery or trial discovery will be filed should nol apply lo this case): Other issues ~ 18. The party ar parties request that the following additional matters be considered or determined at the case management conference (specify)i 19. Meet and confer a. ~x 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 explain): (if nol, b. ~x After meeting and canferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): Cross-Defendant met and conferred with counsel for Cross-Complainant prior to filing a demurrer. As a result, Cross- Complainant filed an amended complaint on November 16, 2020. 20. Total number of pages attached (ff any): 1 Iam 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 17, 2020 Amanda Esq. N. Gnffith, (TYPE OR PRINT NAMEI QF PARTY jIR AfTCRNkyi 1TYPE OR PRINT NAME) i ~ (SIGNATURE OF PARTY OR ATTORNEY Additional signatures are attached OM-IIDIReeJIy I20III Page5of 6 CASE MANAGEMENT STATEMENT MC-025 SHORT CASE NUMBER TITLE'BR INC. RASH CURTIS k. ASSOCIATFS v. SALAZAR, et al. 20CV01623 ATTACHMENT (Number)f 6 C. (This Attachmenl may be used with any Judicial Council form.) DATES OF UNAVAILABILITY I/25/2021 (5 day trial); I/27/2021 (5 day trial); 2/16/2021 (5 day trial); 3/8/2021 (5 day trial); 4/7/2021 (5 day trial); 4/19/2021 (5 day trial);4/19/2021 (5 day trial); 4/30/2020 (5 day trial); 5/18/2021; 6/28/2021 (5 day trial); 8/2/2021 (5 day trial); 9/9/2021 (5 day trial) 10/12/2021 (5 day trial); 12/13/2021 (5 day trial); 6/24/2022 (if the item thai this Attachment concerns is made under penalty of penury, all slatements in this Page 6 of 6 Altachment are made under penalty of perjury) (Add pages as required) Form Approved for Optional Uae www courltnfo ca gav Jud c at Counol of Cal forn a ATTACHMENT MC-029 IRev July 1 20tlgl to Judicial Council Form PROOF OF SERVICE STATE OI'AI.IFORNIA ) 3 ) ss. COUNTY OF PLACER ) 4 I am employed in the County of Placer, State of California. Iam over the age of 18 and not a party to the within action. My business address is 2390 Professional Drive„Roseville, CA 6 95661. 7 On November 17, 2020, I served the foregoing document described as "CASE MANGEMENT STATEMENT" on the interested parties in this action by placing a [X] true copy thereol'J the original document enclosed in a sealed envelope addressed as I'ollows: 10 12 13 X ot'his United (BY business business, electronic noted (BY in I MAIL) States office, Postal In with Service deposited such sealed ordinary business practices. ELECTRONIC transmission, thc I attached sent [SEE ATTACHED SERVICE LISTJ accordance which at the service I am with Roseville, the regular familiar, by California envelope for collection MAIL) Based above document(s) list from on my mail means the to that and the collection of same which day mailing on parties'greement person(s) electronic and mail in processing this at the service is the to deposited ordinary same date accept electronic address practices with course the following service address(cs) which of by is "damainQab31aw.corn'6 (BY OVERNIGHT MAIL) 17 I caused such envelope to be delivered by hand to the office of the addressee, either by overnight delivery via Federal Express or Overnite Express. 18 19 (BY PERSONAL SERVICE) By personally delivering copies to the person served. 20 I delivered such envelope by hand to the office of the addressee pursuant to C.C.P. Section 1011. 21 I caused such envelope to be delivered by hand to the office of the addressee, by local courier service. 22 I caused such envelope to be delivered to the office of the addressee, by 23 telecopier or facsimile machine. Proof of such delivery is attached hereto. STATE 25 X I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 26 27 Executed November 17, 2020, at Roseville, California. Debbie Main Name Signature Service List KBA, inc. Rasit Curtis d'c Associates v. Linda Salazar, et al. Butter County Superior Court Case No: 20CV01623 3 Duane S. Olivcira, Esq. 4 OLIVERIA LAW FIRM 190 S. Orchard Avenue, Suite A-200 Vacaville, CA 95688 Tel: (707) 454-2041 Attorneys for PLAINTIFF KBR INC. DBA RASH CURTIS & ASSOCIATES JillL. Harris, Esq. HARRIS CONSUMER LAW 1809 S Street, Suite 101-174 Sacramento, CA 95811 Tel: (916) 572-9410 Fax: (916) 905-3088 E-mail:iiIIFa.harrisconsumerlaw.corn Attorney for DEFENDANT & CROSS-COMPLAINANT LINDA SALAZAR 11 13 14 15 16 17 18 20 21 22 24 o5 26 27 28