Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY(Name. Sfa/e Bar number, anb abCire$$) FOR COURT USE ONLY
Andrew B. Jones 076915 E-FILED
ANDREW B. JONES PC 12/17/2020 9:57 AM
1111 East Herndon, Suite 109 Superior Court of California
Fresno, CA 93720
TELEPHONENO 559/449-1800 FAXNO (Optiona/J
559/449-1341
County of Fresno
E-MAIL ADDRESS(opwnaDkschemen@wagnerjOHCS.com By: A. Rodriguez, Deputy
ATTORNEY FOR Wame) VERONICA CASIDA
SUPERIOR COURT OF CAUFORNIA,COUNTY OF FRESNO
STREET ADDRESS 1130 "0" St.
MAILING ADDRESS
CITY AND ZIP CODEFresno, CA 93724
BRANCH NAME
PLAINT!FF/PETITIONER:VERONICA CASIDA
DEFENDANT/RESP0NDENT:CALIF0RNIA prison industry AUTHORITY,
PLEASANT VALLEY STATE PRISON
CASE NUMBER
CASE MANAGEMENT STATEMENT
(Check one): X UNLIMITED CASE LIMITED CASE 20CECG00849
(Amount demanded (Amount demanded is 525,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is sctieduled as follows:
Date: 1/12/21 Time: 1:30 pm Dept.: 402 Div.: Room:
Address of court (if different from the address above):
.X Notice of Intent to Appear by Teleptione, by (name): Andrew B. Jones
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1 Party or parties(answer one):
a. X 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): VERONICA CASIDA
b. X The cross-complaint, if any, was filed on (date): 3/5/2020
3. Service (to be answered by plaintiffs and cross-complainants only)
a. X Ail parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. The following parlies 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 ofinvolvement in case, and date by which
they may be served):
Description of case
a. Type of case in x complaint cross-complaint (Describe, including causes of action):
Wrongful icrminalion in violation of public policy
Page 1 of S
Form Adopted (or Mandatory Uso Cal Rules of Court
JudtCrai Council of California CASE MANAGEMENT STATEMENT rules 3 720-3 730
CM HO(Rev Juty 1 2011) SoIuD 11s-
lus
CM-110
PLAINTIFF/PETITIONER; VERONICA CASIDA case number
DEFENDANT/RESPONDENT:CALIFORNIA PRISON INDUSTRY 20C1:CG00849
AUTHORITY. PLEASANT VALLEY STATE PRISON
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 eamings. If equitable reliefis sought, describe the nature of the relief.)
On or about April 12,2018. plaintifT was terminated from her employment with defendant without justifiable cause and in violation of public policy
A
motivating factor for Defendants, and each of their termination of Plaintiff was Plaintiffs reporting objections, protests, and complaints that Defendants, and
each of them, were illegally, improperly and wrongfully assigning an inmate's daily time keeping for milestone credits. Plaintiff reported, complained and
objected to Defendants' illegal violation of law, violation ofthe CDCR rules, conflicts, policy, and practices.
(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 X a jury trial 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. X 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):
1/25-29/21, 2/16-20/21,3/1-5/21, 5/17-21/21, 7/22-26/21, 7/26-30/21, 8/30-9/3/21, 9/7-11/21,9/27-I0/I/2I, I I/I-5/2I, 1/24-
28/22,2/7-11/22,2/28-3/3/22, due to current trial schedule
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. X days (specify number): 3-5 days
b. hours (short causes)(specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial x 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 X has has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the dient.
(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 dvil 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) X 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): Exceeds Judicial limits
cM-ii0|Rev July 1.2011) CASE MANAGEMENT STATEMENT
PLAINTIFF/PETITIONER: VERONICA CASIDA CASE NUMBER
20Ci;CG00849
DEFENDANT/RESPONDENT: CALIFORNIA PRISON INDUSTRY
AUTHORITY. PLEASANT VALLEY STATE PRISON
10. c. Indicate the ADR process or processes that the party or parlies are willing to participate in. have agreed to participate in. or
have already participated in (check all that apply and provide the specihed 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):
X Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation X
Agreed to complete mediation by (dafe).
Mediation completed on (dafe);
X Settlement conference not yet scheduled
Settlement conference scheduled for {date):
(2) Settlement X
conference Agreed to complete settlement conference by (dafe);
Settlement conference completed on (dafe):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for {date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (dafe);
Neutral evaluation completed on (dafe):
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (dafe);
(4) Nonbinding judicial
arbitration Agreed to complete judicial arbitration by {date):
Judicial arbitration completed on (dafe):
Private arbitration not yet scheduled
Private arbitration scheduled for (dafe);
(5) Binding private
arbitration Agreed to complete private arbitration by (dafe);
Private arbitration completed on (dafe):
ADR session not yet scheduled
ADR session scheduled for (dafe);
(6) Other {specify):
Agreed to complete ADR session by (dafe);
ADR completed on (dafe):
CM l10(Rev July 1. 2011J Page 3 of S
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: VERONICA CASIDA case number
"DEFENDANT/RESPONDENT: CALIFORNIA PRISON INDUSTRY AUTHORITY, 20CECG00849
PLEASANT VALLEY STATE PRISON
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 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
X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motions in limine
16. Discovery
a. The party or parties have completed all discovery.
b. X The following discovery will be completed by the date specified (describe ail anticipated discovery):
Party Description Date
Plaintiff written discovery, party & witness depositions, expert Per Code
designation, discovery & depositions
The following discovery Issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM noiRev July 1 2011) MANAGEfWIENT STATEMENT PagoAois
CM-110
PLAINTIFF/PETITIONER: VERONICA CASIDA CASE NUMBER
"DEFENDANT/RESPONDENT: CALIFORNIA PRISON INDUSTRY AUTHORITY, 21)CHCCK)08'19
PLEASANT VALLEY STATE PRISON
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 specirically why economic liligation procedures relating to discovery or trial
should not apply to this case):
16. Other issues
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19 Meetand confer
a. The party or parties have met and conferred with all parlies 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 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: December/^2020 ^_r
Andrew B. Jones
(TYPE OR PtriMT NAME) (SIGNATURE OF P-ilY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM.MO(Ro. jui,1,2011) CASE MANAGEMENT STATEMENT Pagesors
PROOF OF SERVICE
1 STATE OF CALIFORNIA, COUNTY OF FRESNO
2 I am employed in the County of Fresno, State of California. 1 am over the age of
18 and not a party to the within action; my business address is 1111 East Hcmdon, Suite
3 317, Fresno, California.
4 On December 17,2020,1 served the CASE MANAGEMENT CONFERENCE
STATEMENT on the interested parties in this action by placing a true copy thereof enclosed in sealed envelopes
5 addressed as follows:
6
Xavier Becerra
7
Peter Halloran
1300 I St., Ste. 125
8
Sacramento,CA 94244-2550
9
Peter.HallorantSldoi.ca.eov
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[X] ONLY BY ELECTRONIC TRANSMISSION. Only by e-mailing the
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document(s) to the persons at the e-mail address(es) below. This is necessitated
during the declared national emergency due to the Coronavirus(COVlD-19)
14 pandemic because staff in this office is working remotely, and is unable to send
physical mail as usual. Therefore, the document(s) referenced above is/are served
15 only by using electronic mail. We will provide a physical copy, upon request
only, when we return to the office at the conclusion of the national emergency.
16
17 Please consider this email to signify our acceptance of your office following the
same procedure and that electronic service will add five extra days, like US mail,
18 so no one is prejudiced by the electronics service.
19 [ J (BY MAIL)placing the envelopes for collection and mailing on the date and at my
address shown above following our ordinary business practices. 1 am completely
20 familiar with Wagner & Jones' practice of collection and processing
correspondence for mailing pursuant to which the envelopes would be deposited
21 with the United States Postal Service the same day in the ordinary course of
business.
22
[] (BY OVERNIGHT MAIL SERVICE) by placing the envelope for collection
23 following our ordinary business practices for collection and processing
correspondence for mailing by express or overnight mail.
24
[] (BY FACSIMILE)In addition to service by mail as set forth above, the person(s)
25 by whose name an asterisk is affixed, was also forwarded a copy ofsaid documents
by facsimile.
26
[] (BY PERSONAL SERVICE) I caused such envelope to be delivered by hand to
27 the offices of the addressee.
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1 [] (BY E-MAIL SERVICE)I caused such documenl lo be delivered by e-mail to the
offices of the addressee.
2
[] (BY FEDERAL ELECTRONIC FILING) I caused the documents lo be
3 electronically filed with the Clerk of the Court using the CM/l-CF system, which
will send notification of such filing and copies of the documents to the parties.
4
[] (BY CERTIFIED MAIL, RETURN RECEIPT REQUESTED)
5
I declare under penalty of perjury under the laww)f the State of California that the
6 foregoing is true and correct. Executed on December^,2020, at Fresno, California.
7
/s/ Karin L. Schemen
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