Preview
CM-110
ATTORNEY 0R PARTY W|THOUT ATTORNEY (Namo, State Barnumber, and address):
Gerald E. Brunn, Esq., SBN 107004
Law Offices of Brunn & Flynn
928 12th Street, Suite 200
Modesto, CA 95354 '
"’5
(209) 521—2133 FAXNo.(0puona1): (209)
TELEPHONENO.; 521—7584
E.MAlLAooaess gbrunn@brunn— flynn com
(omzonal):
scum: 0r 7m: sawmum ceum
MTORNEYFORm/ame):Defendant, GEORGE REED, INC.
.
e-oumv or smmsuuu
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Stani Slaus
STREETADDR5352801 10th Street, 4th Floor I.Wq I
MAILINGADDRESS:801 10th Street, 4th Floor >
CITYANDZIP conaModesto, CA 95354
BRANCH NAME:
DAVID BERNAL,
PLAINTIFF/PETITIONERiDOROTHY BERNAL,
ANGELICA BERNAL, a minor, by and through her guardian
DEFENDANT/RESPONDENT:FRED MENDEZ, RALPH JUAREZ, GEOREGE
REED CONSTRUCTION, CITY OF MODESTO, CALIFORNIA D
CASE MANAGEMENT STATEMENT CASENUMBEF“
(Check one): UNLIMITED CASE
(Amount demanded
E LIMlTED CASE
(Amount demanded is $25,000
20212 4 3
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE Is scheduled as follows:
Date: March 18 , 2019 Tlme: 8 : 30 a .m. Dept: 24 Div.: Room:
Address of court (if differentfrom the address above):
D Notice of Intent to Appear by Telephone, by (name):
lNSTRUCTlONS: All applicable boxes must be checked. and the specified information must be provided.
1. Party or parties (answer one):
This statement (name):GEORGE REED, INC
a.
b. E This statement
is
is
submitted by party
submitted Jointly by parties (names):
.
2. Complaint and cross-complaint (to be answered by plaintITfs and cross-oomplainants only)
The complaint was filed on (date):
a.
b. D The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainanls only)
a. I
AH parties named in the complaint and cross—complaint have been served. have appeared, or have been dismissed.
b. E]- The following parties named In thepomplaint or cross—complaint
(1) E have not been served (specify names and explain whynot):
(2) E have been served but have not appeared and have not been dismissed (specifynames);
(3) D have had a default entered against them (specify names):
c. C] The following additional parties may be added (specify names, nalure of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of case in
Complaint for personal injuries
complaint D cross—complaint
— motor vehicle
(Describe, including causes of action):
Pagu 1 o! 5
Form A‘dopled [or Mandatmy Usa
Judicial Councll cl Callfomia
'
CASE MANAGEMENT STATEMENT C d1
‘ , Cal. Rules ofCowl,
rules 3.720—a.730
CAM 1 o [Rom July 1, 201 1]
»
HS"
80%?) US
CM-11O
PLAINTIFF/PETITIONER:DOROTHY BERNAL,
DAVID BERNAL, CASENUMBER
MANGELICA BERNAL, a minor, by and through-her guardian
DEFENDANT/RESPONDENT:FRED MENDEZ, RALPH JUAREZ, GEOREGE 2021243
REED CONSTRUCTION, CITY OF MODESTO, CALIFORNIA D
4, b. Provide a brief statement of the case. including any damages.
(/fpersonal 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, a'nd estimated future lost earnings. If equitable
reliefis sought, describe the nature of the relief.)
PlAainti ffs allege they sustained inj uri es and damages as a result of a motor
vehi cle accident ~‘which occurred in a construction zone.
E {)Ifmore’ space is needed, check (his box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request a jury trial L_l a nonjury {/fmore than one parfy, pmvide the
trial.
name ofeach parry
requesting a jury trial):
6. Trial date
a. _
The trial has been set for (date):
b. No trial date has been set. This case will be ready for (rial within ‘12 months of the date of the filing 0f the complaint (if
nor, explain):
c. Dates on which parties or attorneys will not be available for (specify dates and
trial explain reasons for unavailability):
Trials: May 6—20, 2019; Mag 14—24, 2019; June 17-28, 2019; September —
October ll, 2019; October — November l, 2019; November 13—27, 24
December 3—13, 2019; February 24 - March 6, 2020 2019;
7. Estimated length of trial
The party or parties estimate that the trial will lake (check one):
days (specify number): 5—7
a.
b. D hours (short causes) (specify):
8. Trial representation (lo be answered for each party)
The
a.
party or parties
Attorney:
will be represented at trial by the attorney or party listed in the caption D by the following:
b. Firm:
c. Address:
I
d. Telephone number: f. Faxnumber:
9.
D
e
Preference
E—mailaddress:
Additional representation is described in Attachment 8.
g. Party represented:
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 couns and
communities; read
ADR information package provided by the court under ruIe 3.221 for information about the processes available
the
through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel
in
has
rule 3.221 to the client and reviewed ADR options with the
[j has not provided the ADR information package identified
client.
b.
(2) For self-represented parties: Party
Referral to judicial arbitration or
D has E has not reviewed the ADR informaiion package identified in rule 3.221.
action mediation
(1) D civil
This matter is subject to mandatoryjudicial arbitration under Code 0f Civil
mediation under Code of Civil Procedure section 1775.3 because the amount in
(if available).
Procedure section 1141.11 or to civil action
controversy does not exceed the
statutory limit.
(2) E Plaintiffelects lo refer this
Civil
case to
Procedure section 1141 .11.‘
judicial arbitration and agrees to limit recovery to the amount specified in Code of
(3) D .This case is exempt from judicial arbitration under rule 3.811
ofthe California Rules
mediafion under Code of Civil Procedure section 1775 et seq. (specify exemption):
of Court or from civil action
CM‘HMRW-JU'YLZM”
CASE MANAGEMENT STATEMENT Pagm”
CNl-1'10
DOROTHY BERNAL, DAVI D BERNAL
PLAINTIFF/PETITIONER: , CASE NUMBER:
ANGELICA BERNAL, a minor, by and through her guardian
DEFENDANT/RESPONDENT: FRED MENDEZ, RALPH JUAREZ, GEOREGE 2021243
REED CONSTRUCTION, CITY OF MODESTO, CALIFORNIA D
10. c. Indicate the ADR process or processes that the party or parties are wIlling to participate have agreed
in, 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 orhave already completed an ADR process or processes,
participate in the following ADR indicate the status ofthe processes (atiach a copy ofihe parfies'ADR
processes (check all that apply): stipulation).-
[Z] Mediation session not yet scheduled
E Mediation Session scheduled for (dafe):
(1) Mediation
Z Agreed to complete mediation by (date):
S Mediation completed 0n (date):
Settlement conference not yet scheduled
(2) Settlement E Settlement conference scheduled for (date):
conference
E Agreed to complete settlement conference by (date):
B Settlement conference completed on (date):
D Neutral evaluation not yet scheduled
E Neutral evaluation scheduled for (date):
(3) Neutral evaluation
E Agreed to complete neutral evaluation by (date):
E Neutral evaluation completed on (date):
D Judicial arbitration not yet scheduled
Nonbinding D Judicial arbitration scheduled for (date):
(4)
arbitration
judicial
E Agreed to complete judiciél arbitration by (date):
E: Judlcial arbitration completed on (date):
E] Private arbitration not yet scheduled
(5) Binding prlvate
D Private arbitration scheduled for (date):
arbitration
C3 Agreed to complete private arbitratlon by (date):
D Private arbitration completed on (date):
E ADR sesslon not yet scheduled
E] ADR session scheduled for (date):
(6) Other (specify):
D Agreed to complete ADR session by (date):
a ADR completed on (date):
CM-‘l 10 (REV. July 1, 201 1]
CASE MANAGEMENT STATEMENT P39930'5
CM-110
DOROTHY BERNAL, DAVID BERNAL,
PIAlNTIFF/PETITIONER: CASENUMBERI
_ANGELICA BERNAL, a minor, by and through her guardian
DEFENDANT/RESPONDENT: FRED MENDEZ, RALPH JUAREZ, GEOREGE
REED CONSTRUCTION, CITY OF MODESTO, CALIFORNIA D 2021243
11. Insurance
a. E] Insurance
-
b.
c.
Reservation ofrights:
D Coverage issues
carrier, if
will
S Yes D
any. for party filing this statement (name):
No
significantly affect resolution 0f this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court‘s jurisdiction or processing ofthis case and describe the status.
I: Bankruptcy :I Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. E] There are companion, underlying, or related cases.
I
('1) Name ofcase:
(2) Name ofcourt
(3) Case number:
(4) Status:
D
E
Additional cases are described in Attachment 13a.
b. A motion to E consolidate [j coordinate will be filed by (name party):
Bifurcation
14.
E The party or parties intend t0 file a motion fdr
action (specify moving party, type ofmotion, and reasons):
an order bifurcating. severing, or coordinating the following issues or causes of
15. bthermotions
E The party or panies expect to file the foilowing motions before trial (specify moving party, type ofmotion, and issues):
'
16.
a.
b.
E
Discovery
The
The
party or parties
following discovery
have completed
will
all discovery.
be completed by the date specified (descn’be all anticmated discovery):
Pany Descfigfion Dam
GEORGE REED, INC. Written discovery to parties April 2017
Depositions of parties and April 2019
witnesses
\
Expert discovery; supplemental Per trial
written discovery date
c. [j The following discovery issues. including issues regarding the discovery ofelectronically stored
informaiion, are
anticipated (specify):
CM-110[Rev.July 1,2011]
CASE MANAGEMENT STATEMENT Page4015
TCM-110'
DOROTHY BERNAL, DAVID BERNAL,
PLAINTIFF/PETITIONER. CASE-NUMBER:”
_ANGELICA BERNAL, a minor, by and through he'r guardian , . .
DEFENDANT/RESPONDENT' FRED MENDEZ, RALPH JUAREz, GEOREGE 2021243.
REED CONSTRUCTION, CITY OF MODESTO, CALIFORNIA D '
17 Economic litigation
a. This Is a limited civil case e. the amount demanded $25, 000 or less) and the economic
(i Is litigation procedures in Code-
of Civil Procedure sections 90- 98 will apply to this case.
.b‘.
E This Is
a'
di'scove‘ry will
limited civil case and a motion to withdraw the case frbm the economic lifigation
prqcedures or for additional
be filed (if checked, explain specifically why economic litigation procedures relating lo discovery or tn'al
should not apply to this case).
18. Other issues
The pany or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. 'Meet‘
a‘.
Eand confer
The party or parties
of Court (ifnot, eXp/ain):
have m'et and conferred with all parties on all subjects required b_y rul'e 3 7-24 thhe California Rules
b, After meeting and conferring as required by rule 3. 724 ofthe California Rules of Court the parties agr‘ée on _the following
(specify)
20i Total number of pages attached-(if any):-
I am completely. familiar. with this case and will be fully prepared to discuss "the status of discovery and alternative dispute resolution
as well as other Issues _r'aise'd 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.
Gerald E. Brunn, Esq.
(TYPE OR PRINT NAME)
> MC) ‘
(II (SIGNATURE 0F PARTY 0R A'TTORNEY)
(TYPE OR PRINT NAME) KSIGNATURE 0F PARTY OR ATTORNEY)
'
D Additional signatures are attached.
CM-11D[Rev.July1,2011]
CASE MANAGEMENT STATEMENT PageSofS
PROOF 0F SERVICE
(1013a, 2015.5 (3.01),)
STATE OF CALIFORNIA, COUNTY OF STANISLAUS
L HEATHER J. MCCAULEY, declare that:
I am employed in the County of Stanislaus: California. II am over the age of eighteen (18) years
and not a mey to the within action. My business address is 928 12th Street, Suite 200, Modesto,
California, 95353.
OW
On March 1, 2019, I served the within:
-J
CASE MANAGEMENT STATEMENT
KC)
on the interested parties as follows:
SEE ATTACHED SERVICE LIST.
10
The following is the procedure in which service of this documenth’ras effected:
ll
12
XXXXX U.S. Postal Sewiceby'placin’g such_enve1_op‘e($)wwitli postage thereon fully prepaid in the
designated area forou'tgoing mail iniaCcor'dance with this office's practice, whereby the
mail is deposited. in a U.S. MailbOx'i—ih the City of'Modesto, California after the close of the
13
day's business.
14
United Parcel Service —.
Next Day Air
l5
Express Mail
16
FAX
l7
Ceflified Mail -
Return Receipt R'equeSted
18
I declare under penalty 0f perjmy under the laws of the .Stat‘eof California that the foregoing is true
and con‘ect.
l9
Executed on March 1, 2019, at Modesto, 'C Iifornia.
20
21
22
Mb-
imATI—IER J. McCAULEY
23
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27
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SERVICE LIST
Wade M. Hansardg Esq. Attorneys for Plaintiffs
McCormick, Barstow, Sheppard,
Wayte & Carruth, LLP
7647 Nofih Fresno Street
Fresno, CA 93720
Tel: (559) 433—1300
Fax: (559) 433—2300
M. Jacqueline Yates, Esq. Attorneys for Defendant: FRED MENDEZ
Vail & Wells
Box 258829
13.0.
Oklahoma City, OK 73125-8829
71 08 N. Fresno Street, Suite 31 O (physical address)
Fresno, CA 93740
\Q
Tel: (559) 434—0308
Fax: (559) 434—1750
10
E. Daniel Farrar, Esq. Attorneys for Defendant, COUNTY OF
11 Attorney at Law STANISLAUS
600 E. Main Street, Suite 100
12 Tul'lock, CA 95380
Tel: (209) 634—5500
13 Fax: (209) 634-5556
l4
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Preview
CM-110 ATTORNEY 0R PARTY W|THOUT ATTORNEY (Namo, State Barnumber, and address): Gerald E. Brunn, Esq., SBN 107004 Law Offices of Brunn & Flynn 928 12th Street, Suite 200 Modesto, CA 95354 ' "’5 (209) 521—2133 FAXNo.(0puona1): (209) TELEPHONENO.; 521—7584 E.MAlLAooaess gbrunn@brunn— flynn com (omzonal): scum: 0r 7m: sawmum ceum MTORNEYFORm/ame):Defendant, GEORGE REED, INC. . e-oumv or smmsuuu SUPERIOR COURT OF CALIFORNIA, COUNTY OF Stani Slaus STREETADDR5352801 10th Street, 4th Floor I.Wq I MAILINGADDRESS:801 10th Street, 4th Floor > CITYANDZIP conaModesto, CA 95354 BRANCH NAME: DAVID BERNAL, PLAINTIFF/PETITIONERiDOROTHY BERNAL, ANGELICA BERNAL, a minor, by and through her guardian DEFENDANT/RESPONDENT:FRED MENDEZ, RALPH JUAREZ, GEOREGE REED CONSTRUCTION, CITY OF MODESTO, CALIFORNIA D CASE MANAGEMENT STATEMENT CASENUMBEF“ (Check one): UNLIMITED CASE (Amount demanded E LIMlTED CASE (Amount demanded is $25,000 20212 4 3 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE Is scheduled as follows: Date: March 18 , 2019 Tlme: 8 : 30 a .m. Dept: 24 Div.: Room: Address of court (if differentfrom the address above): D Notice of Intent to Appear by Telephone, by (name): lNSTRUCTlONS: All applicable boxes must be checked. and the specified information must be provided. 1. Party or parties (answer one): This statement (name):GEORGE REED, INC a. b. E This statement is is submitted by party submitted Jointly by parties (names): . 2. Complaint and cross-complaint (to be answered by plaintITfs and cross-oomplainants only) The complaint was filed on (date): a. b. D The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainanls only) a. I AH parties named in the complaint and cross—complaint have been served. have appeared, or have been dismissed. b. E]- The following parties named In thepomplaint or cross—complaint (1) E have not been served (specify names and explain whynot): (2) E have been served but have not appeared and have not been dismissed (specifynames); (3) D have had a default entered against them (specify names): c. C] The following additional parties may be added (specify names, nalure of involvement in case, and date by which they may be served): 4. Description of case a. Type of case in Complaint for personal injuries complaint D cross—complaint — motor vehicle (Describe, including causes of action): Pagu 1 o! 5 Form A‘dopled [or Mandatmy Usa Judicial Councll cl Callfomia ' CASE MANAGEMENT STATEMENT C d1 ‘ , Cal. Rules ofCowl, rules 3.720—a.730 CAM 1 o [Rom July 1, 201 1] » HS" 80%?) US CM-11O PLAINTIFF/PETITIONER:DOROTHY BERNAL, DAVID BERNAL, CASENUMBER MANGELICA BERNAL, a minor, by and through-her guardian DEFENDANT/RESPONDENT:FRED MENDEZ, RALPH JUAREZ, GEOREGE 2021243 REED CONSTRUCTION, CITY OF MODESTO, CALIFORNIA D 4, b. Provide a brief statement of the case. including any damages. (/fpersonal 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, a'nd estimated future lost earnings. If equitable reliefis sought, describe the nature of the relief.) PlAainti ffs allege they sustained inj uri es and damages as a result of a motor vehi cle accident ~‘which occurred in a construction zone. E {)Ifmore’ space is needed, check (his box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request a jury trial L_l a nonjury {/fmore than one parfy, pmvide the trial. name ofeach parry requesting a jury trial): 6. Trial date a. _ The trial has been set for (date): b. No trial date has been set. This case will be ready for (rial within ‘12 months of the date of the filing 0f the complaint (if nor, explain): c. Dates on which parties or attorneys will not be available for (specify dates and trial explain reasons for unavailability): Trials: May 6—20, 2019; Mag 14—24, 2019; June 17-28, 2019; September — October ll, 2019; October — November l, 2019; November 13—27, 24 December 3—13, 2019; February 24 - March 6, 2020 2019; 7. Estimated length of trial The party or parties estimate that the trial will lake (check one): days (specify number): 5—7 a. b. D hours (short causes) (specify): 8. Trial representation (lo be answered for each party) The a. party or parties Attorney: will be represented at trial by the attorney or party listed in the caption D by the following: b. Firm: c. Address: I d. Telephone number: f. Faxnumber: 9. D e Preference E—mailaddress: Additional representation is described in Attachment 8. g. Party represented: 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 couns and communities; read ADR information package provided by the court under ruIe 3.221 for information about the processes available the through the court and community programs in this case. (1) For parties represented by counsel: Counsel in has rule 3.221 to the client and reviewed ADR options with the [j has not provided the ADR information package identified client. b. (2) For self-represented parties: Party Referral to judicial arbitration or D has E has not reviewed the ADR informaiion package identified in rule 3.221. action mediation (1) D civil This matter is subject to mandatoryjudicial arbitration under Code 0f Civil mediation under Code of Civil Procedure section 1775.3 because the amount in (if available). Procedure section 1141.11 or to civil action controversy does not exceed the statutory limit. (2) E Plaintiffelects lo refer this Civil case to Procedure section 1141 .11.‘ judicial arbitration and agrees to limit recovery to the amount specified in Code of (3) D .This case is exempt from judicial arbitration under rule 3.811 ofthe California Rules mediafion under Code of Civil Procedure section 1775 et seq. (specify exemption): of Court or from civil action CM‘HMRW-JU'YLZM” CASE MANAGEMENT STATEMENT Pagm” CNl-1'10 DOROTHY BERNAL, DAVI D BERNAL PLAINTIFF/PETITIONER: , CASE NUMBER: ANGELICA BERNAL, a minor, by and through her guardian DEFENDANT/RESPONDENT: FRED MENDEZ, RALPH JUAREZ, GEOREGE 2021243 REED CONSTRUCTION, CITY OF MODESTO, CALIFORNIA D 10. c. Indicate the ADR process or processes that the party or parties are wIlling to participate have agreed in, 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 orhave already completed an ADR process or processes, participate in the following ADR indicate the status ofthe processes (atiach a copy ofihe parfies'ADR processes (check all that apply): stipulation).- [Z] Mediation session not yet scheduled E Mediation Session scheduled for (dafe): (1) Mediation Z Agreed to complete mediation by (date): S Mediation completed 0n (date): Settlement conference not yet scheduled (2) Settlement E Settlement conference scheduled for (date): conference E Agreed to complete settlement conference by (date): B Settlement conference completed on (date): D Neutral evaluation not yet scheduled E Neutral evaluation scheduled for (date): (3) Neutral evaluation E Agreed to complete neutral evaluation by (date): E Neutral evaluation completed on (date): D Judicial arbitration not yet scheduled Nonbinding D Judicial arbitration scheduled for (date): (4) arbitration judicial E Agreed to complete judiciél arbitration by (date): E: Judlcial arbitration completed on (date): E] Private arbitration not yet scheduled (5) Binding prlvate D Private arbitration scheduled for (date): arbitration C3 Agreed to complete private arbitratlon by (date): D Private arbitration completed on (date): E ADR sesslon not yet scheduled E] ADR session scheduled for (date): (6) Other (specify): D Agreed to complete ADR session by (date): a ADR completed on (date): CM-‘l 10 (REV. July 1, 201 1] CASE MANAGEMENT STATEMENT P39930'5 CM-110 DOROTHY BERNAL, DAVID BERNAL, PIAlNTIFF/PETITIONER: CASENUMBERI _ANGELICA BERNAL, a minor, by and through her guardian DEFENDANT/RESPONDENT: FRED MENDEZ, RALPH JUAREZ, GEOREGE REED CONSTRUCTION, CITY OF MODESTO, CALIFORNIA D 2021243 11. Insurance a. E] Insurance - b. c. Reservation ofrights: D Coverage issues carrier, if will S Yes D any. for party filing this statement (name): No significantly affect resolution 0f this case (explain): 12. Jurisdiction Indicate any matters that may affect the court‘s jurisdiction or processing ofthis case and describe the status. I: Bankruptcy :I Other (specify): Status: 13. Related cases, consolidation, and coordination a. E] There are companion, underlying, or related cases. I ('1) Name ofcase: (2) Name ofcourt (3) Case number: (4) Status: D E Additional cases are described in Attachment 13a. b. A motion to E consolidate [j coordinate will be filed by (name party): Bifurcation 14. E The party or parties intend t0 file a motion fdr action (specify moving party, type ofmotion, and reasons): an order bifurcating. severing, or coordinating the following issues or causes of 15. bthermotions E The party or panies expect to file the foilowing motions before trial (specify moving party, type ofmotion, and issues): ' 16. a. b. E Discovery The The party or parties following discovery have completed will all discovery. be completed by the date specified (descn’be all anticmated discovery): Pany Descfigfion Dam GEORGE REED, INC. Written discovery to parties April 2017 Depositions of parties and April 2019 witnesses \ Expert discovery; supplemental Per trial written discovery date c. [j The following discovery issues. including issues regarding the discovery ofelectronically stored informaiion, are anticipated (specify): CM-110[Rev.July 1,2011] CASE MANAGEMENT STATEMENT Page4015 TCM-110' DOROTHY BERNAL, DAVID BERNAL, PLAINTIFF/PETITIONER. CASE-NUMBER:” _ANGELICA BERNAL, a minor, by and through he'r guardian , . . DEFENDANT/RESPONDENT' FRED MENDEZ, RALPH JUAREz, GEOREGE 2021243. REED CONSTRUCTION, CITY OF MODESTO, CALIFORNIA D ' 17 Economic litigation a. This Is a limited civil case e. the amount demanded $25, 000 or less) and the economic (i Is litigation procedures in Code- of Civil Procedure sections 90- 98 will apply to this case. .b‘. E This Is a' di'scove‘ry will limited civil case and a motion to withdraw the case frbm the economic lifigation prqcedures or for additional be filed (if checked, explain specifically why economic litigation procedures relating lo discovery or tn'al should not apply to this case). 18. Other issues The pany or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. 'Meet‘ a‘. Eand confer The party or parties of Court (ifnot, eXp/ain): have m'et and conferred with all parties on all subjects required b_y rul'e 3 7-24 thhe California Rules b, After meeting and conferring as required by rule 3. 724 ofthe California Rules of Court the parties agr‘ée on _the following (specify) 20i Total number of pages attached-(if any):- I am completely. familiar. with this case and will be fully prepared to discuss "the status of discovery and alternative dispute resolution as well as other Issues _r'aise'd 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. Gerald E. Brunn, Esq. (TYPE OR PRINT NAME) > MC) ‘ (II (SIGNATURE 0F PARTY 0R A'TTORNEY) (TYPE OR PRINT NAME) KSIGNATURE 0F PARTY OR ATTORNEY) ' D Additional signatures are attached. CM-11D[Rev.July1,2011] CASE MANAGEMENT STATEMENT PageSofS PROOF 0F SERVICE (1013a, 2015.5 (3.01),) STATE OF CALIFORNIA, COUNTY OF STANISLAUS L HEATHER J. MCCAULEY, declare that: I am employed in the County of Stanislaus: California. II am over the age of eighteen (18) years and not a mey to the within action. My business address is 928 12th Street, Suite 200, Modesto, California, 95353. OW On March 1, 2019, I served the within: -J CASE MANAGEMENT STATEMENT KC) on the interested parties as follows: SEE ATTACHED SERVICE LIST. 10 The following is the procedure in which service of this documenth’ras effected: ll 12 XXXXX U.S. Postal Sewiceby'placin’g such_enve1_op‘e($)wwitli postage thereon fully prepaid in the designated area forou'tgoing mail iniaCcor'dance with this office's practice, whereby the mail is deposited. in a U.S. MailbOx'i—ih the City of'Modesto, California after the close of the 13 day's business. 14 United Parcel Service —. Next Day Air l5 Express Mail 16 FAX l7 Ceflified Mail - Return Receipt R'equeSted 18 I declare under penalty 0f perjmy under the laws of the .Stat‘eof California that the foregoing is true and con‘ect. l9 Executed on March 1, 2019, at Modesto, 'C Iifornia. 20 21 22 Mb- imATI—IER J. McCAULEY 23 24 25 27 28 SERVICE LIST Wade M. Hansardg Esq. Attorneys for Plaintiffs McCormick, Barstow, Sheppard, Wayte & Carruth, LLP 7647 Nofih Fresno Street Fresno, CA 93720 Tel: (559) 433—1300 Fax: (559) 433—2300 M. Jacqueline Yates, Esq. Attorneys for Defendant: FRED MENDEZ Vail & Wells Box 258829 13.0. Oklahoma City, OK 73125-8829 71 08 N. Fresno Street, Suite 31 O (physical address) Fresno, CA 93740 \Q Tel: (559) 434—0308 Fax: (559) 434—1750 10 E. Daniel Farrar, Esq. Attorneys for Defendant, COUNTY OF 11 Attorney at Law STANISLAUS 600 E. Main Street, Suite 100 12 Tul'lock, CA 95380 Tel: (209) 634—5500 13 Fax: (209) 634-5556 l4 15 16 17 18 l9 20 21 22 23 24 25 26 27 28