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ATTORNEY 0R PARTY WITHOUT Aw'oRNEY (Na'rne, sure Bar number, and address): LR} E ?'?{jm FOR COUR‘I' ilsforvivl
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Jacqueline Yates, Esq.
Hartsuyker, Stratman
7108 N. Fresno Street, Suite 310
Fresno, CA 93720
E-MAIL
TELEPHONE No.2 (559) 433-2521
ADDRESS {Optional}:
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160488
Williams-Abrego
FAx no.
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(559) 434-1 750
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Defendant/Cross-Defendant, Fred Mendez
ATFORNEY FOR (Name):
.
SUPERIOR COURT 0F CALIFORNIA, CQUNTY 0F STANISLAUS
smemooaass; City Towers 4th Floor
MAILINGADDRESS: City Towers 4th Floor
crrY AND ZIP CODE: Modesto. CA 95354
BRANCH NAME:
t
PLAINTIFF/PETITIONER: Dorothy Bernal, et al.
DEFENDANT/RESPONDENT: Fred Mendez, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
2021243
(Check one): K4 UNLIMITED CASE D LIMITED CASE
(Amount demanded (Amount demanded is
$25,000 exceeds $25, 000) or less)
/
A CASE MANAGEMENT CONFERENCE Is schedul d as |:|ows
414V
Date: January 22, 2018 Time: 9:
a/gDept Not signed Div; Room;
Address of court (if different from the address aboverg
D Notice of Intent to Appear by Telephone, by (name):
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. E This statement is submitted by party (name):.Fred Mendez
b. D 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):
b. D The cross—complaint. if any, was filed 0n (date):
3. Service (to be answered by plaintiffs and cross—complainants only)
a. D All parties named'In the complaint and cross- compiaint have been sewed. or have appeared or have been dismissed
b. D The following parties named In the complaint or cross- complaint
(1) D have not been sewed (specify names and explain why not):
(2) D have been seWed but have not appeared and have not been dismissed {specifl/ names):
(3) D have had a default entered against them (specify names):
c. D The following additional parties may be added (specifiv names, nature ofinvolvement in case, and the date by which
A they may be served):
4. Description of case ‘
.a. Type of case in E
— motor vehicle
complaint D cross-complaint (Describe, including causes of action):
Personal Injury accident as'to Defendant Fred Mendez
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CASE MANAGEMENT STATEMENT Page 1 of5
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PLAINTIFF/PETITIONER: Dorothy BernaI, etai. .~
CASENUMBERI
. 2021243
DEFENDANT/RESPONDENT: Fred Mendez, e: a1.
4. b. Provide a brief statement of the case, including any damages. (”personal injury damages are sought, specify the Injury and
damages Claimed, incIuding medical expenses to date findicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost eaminga If equitable reliefis sought, describe the nature 0f the relief.)
Plaintiff’s Dorthy and Angelica Bernal claim'bodily injuries arising from a motor vehicle accident; David Bernal
(Dorothy’s husband) claims loss of consortium.
D (If more space is needed, check this box and attach a page designated astttachment 4b.)
5. Jury or nonjury trial
a
The party or parties request Ea jury trial Da non-jury triaI. (Ifmorefhan one party, provide the
’
name of each parfy
requesting a jury trial): I
6. Trial date
a. D The trial has been set for (date): I
b. E No trial date has been set. This case will be ready for tn‘al within 12 months ofthe date ofthe filing ofthe complaintfif
not, explain):
c. Dates on which parties 0r attorneys will not be available for tn'aI (specify dates and explain reasons for unavailability):
Please see attached for Ms. Yates triaI calendar Additionally, she Is not available the weeks of July 4"”
Thanksgiving and Christmas.
7. Estimated length of trial
The party 0r parties estimate that the tnal will take (check one):
a. E days (specify number): 10 15
b. D hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The partyvor parties will be represented at trial E by the attorney or party listed in tfie caption D by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: e. Fax number:
f. E- mail address. g. Party represented:
D Additional representation Is described In Attachment 8
9. Preference
E This case is entiiled 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 D provided the ADR information package identified
In rule 3.221 to the client and has reviewed ADR options with the client.
(2) For self—represented parties: Party D hasD has not reviewed the ADR Information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) D This matter subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
is
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutOry limit
)D 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.
)D This case exempt fromis 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)
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CASE MANAGEMENT STATEMENT 20f5 l
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PLAINTIFFIPETITIONERzDorothy Bernal. et al. CASE NUMBER: A
m -
2021 243
DEFENDANT/RESPONDENT: Fred Mendez, et al.
10. c. Indicate the ADR process or processes that the pady or parties are willing to participate in. have agreed t_o participate in,,or
have already panicipated in (check all that apply and provide the specified infomation):
The party or parties compieting this If in the case have agreed
the party or panies completing this form V
form are willing to participate in the have already completed an ADR process or
to participate in or
following ADR processes (check all processes, indicate the stat us of the processes (attach a copy of
that apply): ‘
the pan‘ies‘ ADR stipulatibn)
Mediation session not yet scheduled
Mediation
D Mediation session scheduled for-(date):
(1)
D Agreed t0 complete mediation by (date):
D Mediation completed on (date):
E Settlement conference not yet scheduled
(2) Settlement D Settlement conference scheduled for (date):
Conference D Agreed to complete settlement conference by (date):
D Settlement conference completed on (date):
D Neutral evaluation not yet scheduled
(3) Neutral Evaluation
D Neutral evaluation scheduled for (date):
D Agreed to complete neutral evaluation‘by (date):
D Neutral evaluation Completed 0n (date):
D Judicial arbitration not yet scheduled
(4) Nonbinding judicial D Judicial arbitration schedulefi for(date):
arbitration D Agreed to complete judicial arbitration by (date):
D Judicial arbitration completed 0n (date):
D Private arbitration ,not yet scheduled
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(5) Binding private [:1 Private arbitration scheduled for (date):
arbitration D Agreed to complete private arbitration by (date):
D Private arbitration completed on (date):
D ADR session not yet scheduled
Other (specify)
D ADR session scheduled for (date):
(6)
D Agreed to complete ADR session by (date):
D ADR session completed 0n (date):
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CASE MANAGEMENT STATEMENT
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CM-110
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PLAiNTIFFIPETITIONER: Docothy Berna]. etal. 335251NZU4M§ER
DEFENDANT/RESPONDENT; Fred Mendez, et al.
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11. Insurance .
a. i. Insurance carrier. if any, for party filing this statement (name): Farmers Insurance Exchange
b. Reservation of rights: D Yes E No
D
I
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 thé status.
D Bankruptcy D Other (specify):
Status:
13. Related cases, consolidationmnd coordination
a. D There are companion. underlying, or related cases.
(1) Name of case:
(2) Name 0f court
(3) Case number:
(4) Status:
»
4
D Additional cases are described in Attachment 14a.
b. D A motion to D consoiidate [j coordinate will be filed by (name party):
14. Bifurcation
D The party or parties intend tofile a motion for an order bifurcating, severing, or coordinating the following issues or causes 0f
action (specify moving party, type ofmotion, and reasons):
15. Other motions
D The party 0r panies expect to file the foilowing motions before trial (specify moving parry, type ofmotion, and issues):
16. Discovery
a. D The party 0r parties have completed all discovery.
b. E The following discovery will be completed by the date specified (describe all anticipated discovery):
Egg): Description Date
Defendant(s) Written Discovery to Plaintiff Generally completed
Defendant(s) Deposition of Plaintiff Completed
Defendant(s) Subpoena of Medical and other records Generally completed
Defendant(s) Medical Examination of Plaintiff (IME) w/in 90 days of trial
c. D The following discovery issues, including‘issues regarding the discovery 0f electronically stored information, are
anticipated (specify):
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PLAlNTlFFIPETITIONEfi: Dorothy Bernal, et al. CASE NUMBER:
2021 243
DEFENDANT/RESPONDENT: Fred Mendez. et al.
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17. Economic litigation
a. D This is a Iimited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90 through 98 will apply to this case.
b. D This is a limited civil case and a motion to withdraw the casé from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or tn’al
should not apply to this case):
18. Other issues
D The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meetand confer
a. E The party or parties have met and conferred with aII parties on all subjects required by rule 3.724 of the California Rules
0f Court (if not, explain):
b. After meeting 'and conferring as required by rule 3.724 of the California Rules of Court. the parties agree 0n the following
(specify):
20. Total number of pages attached (if any): l
Iam completely familiar with this case and will be fully prepared to discuss the status of discovery and ADR, a5 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 th_e party where required.
Date: January 8, 2018
M. Jacqueline Yates
[TYPE 0R PRINT NAME)
///M(W'P7v 0R ATrORNEY)
(TYPE OR PRINT NAME) [SIWF PARTY OR AWORNEY)
D Additional signatures are attached.
CM-“MM W '- 20“]
CASE MANAGEMENT STATEMENT WW
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Event Date A EVBIjEvenl Notes (lgiréMatter 1D 1C|ieiMatter Description (First Line)
2/20/2018‘9:00:00AM TriatTtial of matter. 17-473543 SnaISnaplock Industries, lnc (Judy Jensenv Jay Johnson, Laurie
4/2/2018 9:00:00 AM TrjaIETrial ofmatter. 14-360784 JoneJones Thomas (Jonalan Bravo v Caitlin Jones, Thomas Jones)
7 '
51/9/2018 9:00:00fiAM Tria Trial of manen 14 356365 Yod Yoder,‘ Sarah (John Yoderv Jonathon Williams, Michael McKinney,
4/16/201 8 9:00:00 AM «'Tria Trial ofma’tféfffi I7— 461 594‘ Rub Rubio Rodolfo Renteria H (Nannene Quinn v Margarita Remeria
4/23/2018 9: 00' 00 AM 'Tria Trial of matter, [6449193 COHECOHi Foods Pim California (Donna Strong v. Cotti FQOdS Pizza _
6/1 1/2018 9: 00: 00 AM ,Tfia Trial ofmatlcr, - 17-451305' HigliHighsmith Danny “‘ (Joe M Rodriguez v Danny Highsmilh, Blenda
6/1 1/2018 9200;00 AM ‘Trria Trial 0f matter f 16445944 ~ Corr‘Commcrcia] Properties, LLC((Betty Ann Lopez v. Commercial Properties
6l18/2018 9:00:00
AM, Tria Trial ofmaner 17450452» KlorKloning‘er, John (Desiree Genera v. John Klonihger, Peak ?EEfomwlce,
F
6/25/2018 9:00:00 AM Tria Trial 0f matter. ”47535 l 5B (SB Corpgration (Ruth Ortiz v, Holgday Inn Express, Intercontinental ‘
7/10/2018'9:30:00 AM TriafiTrial oifmaner. i6445l91 tCEEIghés AveJnc, (Violet Saveh v. Bella Maxie, DND FaShion,‘Inf:.,
8/6/20189100100‘AM TriafiTriaI éfmauer 17460179 I
{Goh’Gohrickrlfiowell (JoseA. Mejia v. Lowell T. Gohrick, Paula R“ .
I
3/13/2018’9100200 AM TriaaTrial ofmaller -,
l7f458116 SancSanjchez,AEIgel " (Paul‘Mez‘a v. City ofFresno) V I
A
7
8/20/2018 9: 00: 00AM TnaETrial ofmatter 17-4720“ Clengeferred'Power Solutions, Inc, (JlilicAnn Estes v. Billy Clgvgland): J
19/10/2018 9. 00: 00 AM TriagTrial of matter 15400662 Scthrown, ‘Roben (James Snowden v Jon Dustin Schaa) _
9/l7f2018 9: 30: 00 AM‘ Trial’Tn'al
of matter. 1174743755 rirrPrimow Landscape Maintenance *“ (Thomas Gilmore v Walgreefu Co.,.
V
1/28/2019 9:00:00 AM TriakTria] 0f matten gl7t477049 rlac 'aencl, Jeffrey (Claude Jones v. Jeff Hamel) ,
AM
21’18/2019 9:00:00 ”Tria Trlialbfmaucr. .
gl'5y-367072 A- l Byron], Stanley (Crystal Cisneros, Magy Sophia Gonzalez v A.1 Auto
2Q5(2019 9:00:00 KM Tria Trial of-imatter.‘ 17-473784
'
‘SidHSidhu Mandeep (Guillermo Gutierrez v. Mandcc‘p Kaur Sidhu, ‘Harpreet
3f4/2019 9:00:00‘AM '.
Tria Trial ofmalter.“ [7-481916 SingSingh Charanjit (Sharole Mason v. Sahjog Singh, Charanjit Singh)
‘ ‘
3/18/2019 9:00:00 6M TriaiTrial-ofi matter. 17452661 RusziRussler, Michael (Steven Hanks v Becky Russlcr)
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Re: Berna! Mendez, ct v. a1.. and Related Cross-Actions‘
Case Number: 2021243
PROOF OF SERVICE
Code 0f Civil Procedure §§ 1013a, 2015.5
I am a resident of the State of California and over the age of eighteen years, and not a party to the
within action. My business address is 7 108 N. Fresno Street, Suite 3 10, Fresno, CA 93720. On January
Q ,
2018, I served the following document(s):
CASE MANAGEMENT STATENIENT
By placing th’e‘doc'umenms) listed above in a sealed envelope, addressed as set forth
below, and placing the envelope for collection and mailing in the place designated for
>< such in our offices, following ordinary business practibes.
10 By transmitting Via facsimile the document(s) listed above to the fax number(s) set
_
forth below 0n this date before 5:00 p.111.
11
12
By causing a true copy thereof t0 be personally delivered to the person(s) at the
address(es) set forth below.
13
14 By electronically serving the document(s) described above Via a Court approved File
& Serve vendor on those recipients designated 0n the Transaction Receipt located on
15 the vendor’s Website.
16
By electronically serving the document(s) t0 the electronic mail address set forth
17
below on this date before 5:00 p.m. pursuant‘to the signed stipulation of the parties
and consistent with Code of Civil Procedure section 1010.6(a)(2).
18 SEE ATTACHED SERVICE LIST
19 I am readily familiar with the firm’s practice of collection and processing correspondence for
mailing with the United States Postal Service. Under that practice, it wOuld be deposited with U.S.
20
Postal Serviceon that same day with postage thereon fully prepaid in the ordinary course ofbusiness. I
21
am aware that on motion of the party ser’ved, service is presumed invalid if postal cancellation date 0r
postage meter date is more than one day afier date of deposit for mailing in affidavit.
22
I declare under penalty 0f peljury under the laws of the State of'Califomia that the above is true
23 and correct.
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Executed 011 January Q , 201 8, at Fresno, California.
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CE PARIS
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Re: Bemal v. Mendez, et a1., and Related Cross—Actions
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Case Number: 202 1 243
SERVICE LIST
Wade M. Hansard, Esq.
McCormick Barstow, LLP
7647 N. Fresno St.
Fresno,CA 93720
Attorney for Plaintiffs, Dorothy Bemal,‘ David Bemal, Angelica Bernal, a minor, by and through her
guardian ad Iitemv, Robert Bemal
Phone: (559) 4334300
Fax: (559) 433-2300
Jenne Scherer
California Department 0f Transportation - Legal Division
P.O. Box 1438
Sacramento, CA 958 12-1438
10
Attorney for Defendant, California Department of Transportation
Phone: (916) 654-2630
11
F ax:
12
Gerald E. Brunn
Law Offices of Brunn & Flynn
13
928 12th Street, Suite 200
Modesto, CA. 95354
14
Attorney for Defendants/Cross—Complainant, George Reed, Inc.
Phone: (209) 521-2133
15
Fax: (209) 521-7584
16
E. Daniel Farrar
Attorney at Law
17
600 E. Main Street, Suite 100
Turlock, CA 95380 '
18
Attorney for Defendant, County of Stanislaus
Phone: (209) 634—5500
'19
Fax: (209) 634-5556
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‘ ' P} mg: m, 6. ‘Av 3 a ‘ a V CM-11o I ATTORNEY 0R PARTY WITHOUT Aw'oRNEY (Na'rne, sure Bar number, and address): LR} E ?'?{jm FOR COUR‘I' ilsforvivl _M. - Jacqueline Yates, Esq. Hartsuyker, Stratman 7108 N. Fresno Street, Suite 310 Fresno, CA 93720 E-MAIL TELEPHONE No.2 (559) 433-2521 ADDRESS {Optional}: & 160488 Williams-Abrego FAx no. . . {cpuoneoz 5M figs WW mag” my pm- m coum’ 2G??? MDT?!) (559) 434-1 750 : 3 ' Defendant/Cross-Defendant, Fred Mendez ATFORNEY FOR (Name): . SUPERIOR COURT 0F CALIFORNIA, CQUNTY 0F STANISLAUS smemooaass; City Towers 4th Floor MAILINGADDRESS: City Towers 4th Floor crrY AND ZIP CODE: Modesto. CA 95354 BRANCH NAME: t PLAINTIFF/PETITIONER: Dorothy Bernal, et al. DEFENDANT/RESPONDENT: Fred Mendez, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: 2021243 (Check one): K4 UNLIMITED CASE D LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25, 000) or less) / A CASE MANAGEMENT CONFERENCE Is schedul d as |:|ows 414V Date: January 22, 2018 Time: 9: a/gDept Not signed Div; Room; Address of court (if different from the address aboverg D Notice of Intent to Appear by Telephone, by (name): INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. E This statement is submitted by party (name):.Fred Mendez b. D 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): b. D The cross—complaint. if any, was filed 0n (date): 3. Service (to be answered by plaintiffs and cross—complainants only) a. D All parties named'In the complaint and cross- compiaint have been sewed. or have appeared or have been dismissed b. D The following parties named In the complaint or cross- complaint (1) D have not been sewed (specify names and explain why not): (2) D have been seWed but have not appeared and have not been dismissed {specifl/ names): (3) D have had a default entered against them (specify names): c. D The following additional parties may be added (specifiv names, nature ofinvolvement in case, and the date by which A they may be served): 4. Description of case ‘ .a. Type of case in E — motor vehicle complaint D cross-complaint (Describe, including causes of action): Personal Injury accident as'to Defendant Fred Mendez CM-I'OIR” W '1 20“] CASE MANAGEMENT STATEMENT Page 1 of5 ‘ 14 fix , «V w > i 2,2 » _ CM-11o ' PLAINTIFF/PETITIONER: Dorothy BernaI, etai. .~ CASENUMBERI . 2021243 DEFENDANT/RESPONDENT: Fred Mendez, e: a1. 4. b. Provide a brief statement of the case, including any damages. (”personal injury damages are sought, specify the Injury and damages Claimed, incIuding medical expenses to date findicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost eaminga If equitable reliefis sought, describe the nature 0f the relief.) Plaintiff’s Dorthy and Angelica Bernal claim'bodily injuries arising from a motor vehicle accident; David Bernal (Dorothy’s husband) claims loss of consortium. D (If more space is needed, check this box and attach a page designated astttachment 4b.) 5. Jury or nonjury trial a The party or parties request Ea jury trial Da non-jury triaI. (Ifmorefhan one party, provide the ’ name of each parfy requesting a jury trial): I 6. Trial date a. D The trial has been set for (date): I b. E No trial date has been set. This case will be ready for tn‘al within 12 months ofthe date ofthe filing ofthe complaintfif not, explain): c. Dates on which parties 0r attorneys will not be available for tn'aI (specify dates and explain reasons for unavailability): Please see attached for Ms. Yates triaI calendar Additionally, she Is not available the weeks of July 4"” Thanksgiving and Christmas. 7. Estimated length of trial The party 0r parties estimate that the tnal will take (check one): a. E days (specify number): 10 15 b. D hours (short causes) (specify): 8. Trial representation (to be answered for each party) The partyvor parties will be represented at trial E by the attorney or party listed in tfie caption D by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: e. Fax number: f. E- mail address. g. Party represented: D Additional representation Is described In Attachment 8 9. Preference E This case is entiiled 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 D provided the ADR information package identified In rule 3.221 to the client and has reviewed ADR options with the client. (2) For self—represented parties: Party D hasD has not reviewed the ADR Information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) D This matter subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action is mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutOry limit )D 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. )D This case exempt fromis 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-l 20H] CASE MANAGEMENT STATEMENT 20f5 l lO [Reva July l, Page 77 ./ I CM-110 ‘ 'Lr/ PLAINTIFFIPETITIONERzDorothy Bernal. et al. CASE NUMBER: A m - 2021 243 DEFENDANT/RESPONDENT: Fred Mendez, et al. 10. c. Indicate the ADR process or processes that the pady or parties are willing to participate in. have agreed t_o participate in,,or have already panicipated in (check all that apply and provide the specified infomation): The party or parties compieting this If in the case have agreed the party or panies completing this form V form are willing to participate in the have already completed an ADR process or to participate in or following ADR processes (check all processes, indicate the stat us of the processes (attach a copy of that apply): ‘ the pan‘ies‘ ADR stipulatibn) Mediation session not yet scheduled Mediation D Mediation session scheduled for-(date): (1) D Agreed t0 complete mediation by (date): D Mediation completed on (date): E Settlement conference not yet scheduled (2) Settlement D Settlement conference scheduled for (date): Conference D Agreed to complete settlement conference by (date): D Settlement conference completed on (date): D Neutral evaluation not yet scheduled (3) Neutral Evaluation D Neutral evaluation scheduled for (date): D Agreed to complete neutral evaluation‘by (date): D Neutral evaluation Completed 0n (date): D Judicial arbitration not yet scheduled (4) Nonbinding judicial D Judicial arbitration schedulefi for(date): arbitration D Agreed to complete judicial arbitration by (date): D Judicial arbitration completed 0n (date): D Private arbitration ,not yet scheduled ‘ (5) Binding private [:1 Private arbitration scheduled for (date): arbitration D Agreed to complete private arbitration by (date): D Private arbitration completed on (date): D ADR session not yet scheduled Other (specify) D ADR session scheduled for (date): (6) D Agreed to complete ADR session by (date): D ADR session completed 0n (date): “g” “’5 CM-I 10 [Rem July l. 20H] CASE MANAGEMENT STATEMENT ‘ Cgm g , F. CM-110 - PLAiNTIFFIPETITIONER: Docothy Berna]. etal. 335251NZU4M§ER DEFENDANT/RESPONDENT; Fred Mendez, et al. V ' 11. Insurance . a. i. Insurance carrier. if any, for party filing this statement (name): Farmers Insurance Exchange b. Reservation of rights: D Yes E No D I 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 thé status. D Bankruptcy D Other (specify): Status: 13. Related cases, consolidationmnd coordination a. D There are companion. underlying, or related cases. (1) Name of case: (2) Name 0f court (3) Case number: (4) Status: » 4 D Additional cases are described in Attachment 14a. b. D A motion to D consoiidate [j coordinate will be filed by (name party): 14. Bifurcation D The party or parties intend tofile a motion for an order bifurcating, severing, or coordinating the following issues or causes 0f action (specify moving party, type ofmotion, and reasons): 15. Other motions D The party 0r panies expect to file the foilowing motions before trial (specify moving parry, type ofmotion, and issues): 16. Discovery a. D The party 0r parties have completed all discovery. b. E The following discovery will be completed by the date specified (describe all anticipated discovery): Egg): Description Date Defendant(s) Written Discovery to Plaintiff Generally completed Defendant(s) Deposition of Plaintiff Completed Defendant(s) Subpoena of Medical and other records Generally completed Defendant(s) Medical Examination of Plaintiff (IME) w/in 90 days of trial c. D The following discovery issues, including‘issues regarding the discovery 0f electronically stored information, are anticipated (specify): CM-“OIRev-Ju'y “2°“! CASE MANAGEMENT STATEMENT Page4 ofS VV\ {I z, x K ~ ‘ CM-110 PLAlNTlFFIPETITIONEfi: Dorothy Bernal, et al. CASE NUMBER: 2021 243 DEFENDANT/RESPONDENT: Fred Mendez. et al. ‘ 17. Economic litigation a. D This is a Iimited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90 through 98 will apply to this case. b. D This is a limited civil case and a motion to withdraw the casé from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or tn’al should not apply to this case): 18. Other issues D The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meetand confer a. E The party or parties have met and conferred with aII parties on all subjects required by rule 3.724 of the California Rules 0f Court (if not, explain): b. After meeting 'and conferring as required by rule 3.724 of the California Rules of Court. the parties agree 0n the following (specify): 20. Total number of pages attached (if any): l Iam completely familiar with this case and will be fully prepared to discuss the status of discovery and ADR, a5 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 th_e party where required. Date: January 8, 2018 M. Jacqueline Yates [TYPE 0R PRINT NAME) ///M(W'P7v 0R ATrORNEY) (TYPE OR PRINT NAME) [SIWF PARTY OR AWORNEY) D Additional signatures are attached. CM-“MM W '- 20“] CASE MANAGEMENT STATEMENT WW ‘x i .137 f Event Date A EVBIjEvenl Notes (lgiréMatter 1D 1C|ieiMatter Description (First Line) 2/20/2018‘9:00:00AM TriatTtial of matter. 17-473543 SnaISnaplock Industries, lnc (Judy Jensenv Jay Johnson, Laurie 4/2/2018 9:00:00 AM TrjaIETrial ofmatter. 14-360784 JoneJones Thomas (Jonalan Bravo v Caitlin Jones, Thomas Jones) 7 ' 51/9/2018 9:00:00fiAM Tria Trial of manen 14 356365 Yod Yoder,‘ Sarah (John Yoderv Jonathon Williams, Michael McKinney, 4/16/201 8 9:00:00 AM «'Tria Trial ofma’tféfffi I7— 461 594‘ Rub Rubio Rodolfo Renteria H (Nannene Quinn v Margarita Remeria 4/23/2018 9: 00' 00 AM 'Tria Trial of matter, [6449193 COHECOHi Foods Pim California (Donna Strong v. Cotti FQOdS Pizza _ 6/1 1/2018 9: 00: 00 AM ,Tfia Trial ofmatlcr, - 17-451305' HigliHighsmith Danny “‘ (Joe M Rodriguez v Danny Highsmilh, Blenda 6/1 1/2018 9200;00 AM ‘Trria Trial 0f matter f 16445944 ~ Corr‘Commcrcia] Properties, LLC((Betty Ann Lopez v. Commercial Properties 6l18/2018 9:00:00 AM, Tria Trial ofmaner 17450452» KlorKloning‘er, John (Desiree Genera v. John Klonihger, Peak ?EEfomwlce, F 6/25/2018 9:00:00 AM Tria Trial 0f matter. ”47535 l 5B (SB Corpgration (Ruth Ortiz v, Holgday Inn Express, Intercontinental ‘ 7/10/2018'9:30:00 AM TriafiTrial oifmaner. i6445l91 tCEEIghés AveJnc, (Violet Saveh v. Bella Maxie, DND FaShion,‘Inf:., 8/6/20189100100‘AM TriafiTriaI éfmauer 17460179 I {Goh’Gohrickrlfiowell (JoseA. Mejia v. Lowell T. Gohrick, Paula R“ . I 3/13/2018’9100200 AM TriaaTrial ofmaller -, l7f458116 SancSanjchez,AEIgel " (Paul‘Mez‘a v. City ofFresno) V I A 7 8/20/2018 9: 00: 00AM TnaETrial ofmatter 17-4720“ Clengeferred'Power Solutions, Inc, (JlilicAnn Estes v. Billy Clgvgland): J 19/10/2018 9. 00: 00 AM TriagTrial of matter 15400662 Scthrown, ‘Roben (James Snowden v Jon Dustin Schaa) _ 9/l7f2018 9: 30: 00 AM‘ Trial’Tn'al of matter. 1174743755 rirrPrimow Landscape Maintenance *“ (Thomas Gilmore v Walgreefu Co.,. V 1/28/2019 9:00:00 AM TriakTria] 0f matten gl7t477049 rlac 'aencl, Jeffrey (Claude Jones v. Jeff Hamel) , AM 21’18/2019 9:00:00 ”Tria Trlialbfmaucr. . gl'5y-367072 A- l Byron], Stanley (Crystal Cisneros, Magy Sophia Gonzalez v A.1 Auto 2Q5(2019 9:00:00 KM Tria Trial of-imatter.‘ 17-473784 ' ‘SidHSidhu Mandeep (Guillermo Gutierrez v. Mandcc‘p Kaur Sidhu, ‘Harpreet 3f4/2019 9:00:00‘AM '. Tria Trial ofmalter.“ [7-481916 SingSingh Charanjit (Sharole Mason v. Sahjog Singh, Charanjit Singh) ‘ ‘ 3/18/2019 9:00:00 6M TriaiTrial-ofi matter. 17452661 RusziRussler, Michael (Steven Hanks v Becky Russlcr) wk I Re: Berna! Mendez, ct v. a1.. and Related Cross-Actions‘ Case Number: 2021243 PROOF OF SERVICE Code 0f Civil Procedure §§ 1013a, 2015.5 I am a resident of the State of California and over the age of eighteen years, and not a party to the within action. My business address is 7 108 N. Fresno Street, Suite 3 10, Fresno, CA 93720. On January Q , 2018, I served the following document(s): CASE MANAGEMENT STATENIENT By placing th’e‘doc'umenms) listed above in a sealed envelope, addressed as set forth below, and placing the envelope for collection and mailing in the place designated for >< such in our offices, following ordinary business practibes. 10 By transmitting Via facsimile the document(s) listed above to the fax number(s) set _ forth below 0n this date before 5:00 p.111. 11 12 By causing a true copy thereof t0 be personally delivered to the person(s) at the address(es) set forth below. 13 14 By electronically serving the document(s) described above Via a Court approved File & Serve vendor on those recipients designated 0n the Transaction Receipt located on 15 the vendor’s Website. 16 By electronically serving the document(s) t0 the electronic mail address set forth 17 below on this date before 5:00 p.m. pursuant‘to the signed stipulation of the parties and consistent with Code of Civil Procedure section 1010.6(a)(2). 18 SEE ATTACHED SERVICE LIST 19 I am readily familiar with the firm’s practice of collection and processing correspondence for mailing with the United States Postal Service. Under that practice, it wOuld be deposited with U.S. 20 Postal Serviceon that same day with postage thereon fully prepaid in the ordinary course ofbusiness. I 21 am aware that on motion of the party ser’ved, service is presumed invalid if postal cancellation date 0r postage meter date is more than one day afier date of deposit for mailing in affidavit. 22 I declare under penalty 0f peljury under the laws of the State of'Califomia that the above is true 23 and correct. ' 24 Executed 011 January Q , 201 8, at Fresno, California. 25 26 ' CE PARIS 27 28 p g,‘ . J ~ ' k; J 74’ Re: Bemal v. Mendez, et a1., and Related Cross—Actions ‘ Case Number: 202 1 243 SERVICE LIST Wade M. Hansard, Esq. McCormick Barstow, LLP 7647 N. Fresno St. Fresno,CA 93720 Attorney for Plaintiffs, Dorothy Bemal,‘ David Bemal, Angelica Bernal, a minor, by and through her guardian ad Iitemv, Robert Bemal Phone: (559) 4334300 Fax: (559) 433-2300 Jenne Scherer California Department 0f Transportation - Legal Division P.O. Box 1438 Sacramento, CA 958 12-1438 10 Attorney for Defendant, California Department of Transportation Phone: (916) 654-2630 11 F ax: 12 Gerald E. Brunn Law Offices of Brunn & Flynn 13 928 12th Street, Suite 200 Modesto, CA. 95354 14 Attorney for Defendants/Cross—Complainant, George Reed, Inc. Phone: (209) 521-2133 15 Fax: (209) 521-7584 16 E. Daniel Farrar Attorney at Law 17 600 E. Main Street, Suite 100 Turlock, CA 95380 ' 18 Attorney for Defendant, County of Stanislaus Phone: (209) 634—5500 '19 Fax: (209) 634-5556 20 2] 22 23 24 25 26 27 28