Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
Raquel M. Busani, SBN 323162 / Robert J. Rosati, SBN 112006
ERISA Law Center
6485 N. Palm Avenue, Suite 105, Fresno, California 93704
TELEPHONE NO.:(559) 478-4119 (559) 478-5939
FAX NO. (Optional):
E-FILED
raquel@erisalg.com; robert@erisalg.com
E-MAIL ADDRESS (Optional):
1/20/2021 11:18 AM
Plaintiffs Deborah Brewer and Jaida Mcall, by and through her GAL
ATTORNEY FOR (Name): Superior Court of California
SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO County of Fresno
STREET ADDRESS:1130 "O" Street By: J. Nelson, Deputy
MAILING ADDRESS:
Fresno
CITY AND ZIP CODE: 93724
BRANCH NAME:
PLAINTIFF/PETITIONER: Deborah Brewer and Jaida McCall, by and through her GAL
DEFENDANT/RESPONDENT: Noe Ramirez-Henriquez, Sonia Hernandez de Ramirez, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE LIMITED CASE 20CECG02908
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: February 4, 2021 Time: 1:30 p.m. Dept.: 501 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Raquel M. Busani
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. This statement is submitted by party (name):
b. This statement is submitted jointly by parties (names): Plaintiffs Deborah Brewer and Jaida McCall, by and through GAL
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): October 1, 2020
b. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. 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 (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of case in complaint cross-complaint (Describe, including causes of action):
Motor Vehicle, General Negligence, Personal Injury, Property Damage.
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California
CASE MANAGEMENT STATEMENT rules 3.720–3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: Deborah Brewer and Jaida McCall, by and through her GAL CASE NUMBER:
DEFENDANT/RESPONDENT: Noe Ramirez-Henriquez, Sonia Hernandez de Ramirez, et al. 20CECG02908
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 earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff Deborah Brewer ("Brewer") was waiting to make a left hand turn at the intersection of N. Brawley and Fedora Avenues
with her left hand blinker on. Defendant Sonia Hernandez de Ramirez a.k.a Elizabeth Ramirez ("Sonia") was obviously driving
too fast and/or not paying attention, rear-ended Brewer's vehicle. Plaintiff Jaida McCall, was a passenger in Brewer's vehicle.
The car driven by Sonia was owned by Def. Noe Ramirez-Henriquez. Plaintiffs have suffered general and special damages.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
a. The party or parties request a jury triaI 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. (if
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
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
10/15 – 10/22/21; 11/7 – 11/19/21; 11/22 – 12/3/21; 12/19 – 12/31;1/1 – 1/7/22; 2/20 – 3/4/22,due to pre-scheduled family
obligations.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 3 to 4 days.
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption 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 has has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2)For self-represented parties: Party 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 civil 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) 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):
CM-110 [Rev. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Deborah Brewer and Jaida McCall, by and through her GAL CASE NUMBER:
DEFENDANT/RESPONDENT: Noe Ramirez-Henriquez, Sonia Hernandez de Ramirez, et al. 20CECG02908
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply):stipulation):
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
(4) Nonbinding judicial Judicial arbitration scheduled for
(date):
arbitration Agreed to complete judicial arbitration by(date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for(date):
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Deborah Brewer and Jaida McCall, by and through her GAL CASE NUMBER:
DEFENDANT/RESPONDENT: Noe Ramirez-Henriquez, Sonia Hernandez de Ramirez, et al. 20CECG02908
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 wiII 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
(specify moving party, type of motion, and issues):
The party or parties expect to file the following motions before trial
Motions in Limine
16. Discovery
a. The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendants Written Discovery Requests/Responses Per Code
Plaintiffs Written Discovery Requests/Responses Per Code
Plaintiffs Depositions of both Defendants Per Code
Defendants Depositions of Plaintiffs Deborah Brewer and GAL Per Code
Plaintiffs/Defendants Depositions of Expert Witnesses Per Code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Deborah Brewer and Jaida McCall, by and through her GAL CASE NUMBER:
DEFENDANT/RESPONDENT: Noe Ramirez-Henriquez, Sonia Hernandez de Ramirez, et al. 20CECG02908
17. Economic litigation
a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules
of Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any):
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 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: January 20, 2021
Raquel M. Busani, Esq. /s/ Raquel M. Busani
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev. July 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
1 CERTIFICATE OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF FRESNO
3 I certify and declare as follows: I am a citizen of the United States and a resident of the
County aforesaid; I am over the age of eighteen years and not a party to the within above-
4 entitled action; my business address is 6485 North Palm Street, Suite 105, Fresno, California
93704.
5
I, Leanne Capuchin, hereby certify that on January 20, 2021, I served the foregoing
6 document described as: PLAINTIFFS’ CASE MANAGEMENT STATEMENT on the
interested parties as follows:
7
8 Manuel Garcia, Esq. (SBN 183535) Attorney for Defendants, NOE RAMIREZ-
PEEL I GARCIA LLP HENRIQUEZ; SONIA HERNANDEZ DE
9 3585 W. Beechwood, Suite 101 RAMIREZ, a.k.a. ELIZABETH RAMIREZ
Fresno, California 93711
10 Telephone: (559) 431-1300
Facsimile: (559) 431-1442
11 Emails: M. Garcia
Lanette Andrist
12
13 [X] ELECTRONICALLY: I caused a true and correct copy thereof to be electronically
filed using the Court’s Electronic Court Filing (“ECF”) System and service was
14 completed by electronic means by transmittal of a Notice of Electronic Filing on the
registered participants of the ECF System. I served those parties who are not registered
15 participants of the ECF System as indicated below.
16
[X ] BY EMAIL: I electronically transmitted a true and correct copy thereof to the interested
17 parties’ electronic notification address(es) of record before close of business for the
purpose of effecting service and the transmission was reported as complete and without
18 error.
19 I am employed in the office of a member of the bar of this Court at whose direction the
service was made. I declare under penalty of perjury under the laws of the United States of
20 America that the above is true and correct. Executed on January 20, 2021, at Fresno,
California.
21
22
/s/ Leanne Capuchin
23 LEANNE CAPUCHIN
24
25
26
27
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PLAINTIFFS’ CASE MANAGEMENT STATEMENT
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Raquel M. Busani, SBN 323162 / Robert J. Rosati, SBN 112006 ERISA Law Center 6485 N. Palm Avenue, Suite 105, Fresno, California 93704 TELEPHONE NO.:(559) 478-4119 (559) 478-5939 FAX NO. (Optional): E-FILED raquel@erisalg.com; robert@erisalg.com E-MAIL ADDRESS (Optional): 1/20/2021 11:18 AM Plaintiffs Deborah Brewer and Jaida Mcall, by and through her GAL ATTORNEY FOR (Name): Superior Court of California SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO County of Fresno STREET ADDRESS:1130 "O" Street By: J. Nelson, Deputy MAILING ADDRESS: Fresno CITY AND ZIP CODE: 93724 BRANCH NAME: PLAINTIFF/PETITIONER: Deborah Brewer and Jaida McCall, by and through her GAL DEFENDANT/RESPONDENT: Noe Ramirez-Henriquez, Sonia Hernandez de Ramirez, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE 20CECG02908 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: February 4, 2021 Time: 1:30 p.m. Dept.: 501 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Raquel M. Busani INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): b. This statement is submitted jointly by parties (names): Plaintiffs Deborah Brewer and Jaida McCall, by and through GAL 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): October 1, 2020 b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. 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 (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type of case in complaint cross-complaint (Describe, including causes of action): Motor Vehicle, General Negligence, Personal Injury, Property Damage. Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: Deborah Brewer and Jaida McCall, by and through her GAL CASE NUMBER: DEFENDANT/RESPONDENT: Noe Ramirez-Henriquez, Sonia Hernandez de Ramirez, et al. 20CECG02908 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 earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff Deborah Brewer ("Brewer") was waiting to make a left hand turn at the intersection of N. Brawley and Fedora Avenues with her left hand blinker on. Defendant Sonia Hernandez de Ramirez a.k.a Elizabeth Ramirez ("Sonia") was obviously driving too fast and/or not paying attention, rear-ended Brewer's vehicle. Plaintiff Jaida McCall, was a passenger in Brewer's vehicle. The car driven by Sonia was owned by Def. Noe Ramirez-Henriquez. Plaintiffs have suffered general and special damages. (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial a. The party or parties request a jury triaI 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. (if 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 not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 10/15 – 10/22/21; 11/7 – 11/19/21; 11/22 – 12/3/21; 12/19 – 12/31;1/1 – 1/7/22; 2/20 – 3/4/22,due to pre-scheduled family obligations. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 3 to 4 days. b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption 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 has has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2)For self-represented parties: Party 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 civil 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) 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): CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Deborah Brewer and Jaida McCall, by and through her GAL CASE NUMBER: DEFENDANT/RESPONDENT: Noe Ramirez-Henriquez, Sonia Hernandez de Ramirez, et al. 20CECG02908 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply):stipulation): Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by(date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for(date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Deborah Brewer and Jaida McCall, by and through her GAL CASE NUMBER: DEFENDANT/RESPONDENT: Noe Ramirez-Henriquez, Sonia Hernandez de Ramirez, et al. 20CECG02908 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 wiII 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 (specify moving party, type of motion, and issues): The party or parties expect to file the following motions before trial Motions in Limine 16. Discovery a. The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendants Written Discovery Requests/Responses Per Code Plaintiffs Written Discovery Requests/Responses Per Code Plaintiffs Depositions of both Defendants Per Code Defendants Depositions of Plaintiffs Deborah Brewer and GAL Per Code Plaintiffs/Defendants Depositions of Expert Witnesses Per Code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Deborah Brewer and Jaida McCall, by and through her GAL CASE NUMBER: DEFENDANT/RESPONDENT: Noe Ramirez-Henriquez, Sonia Hernandez de Ramirez, et al. 20CECG02908 17. Economic litigation a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 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 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: January 20, 2021 Raquel M. Busani, Esq. /s/ Raquel M. Busani (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. July 1, 2011] Page 5 of 5 CASE MANAGEMENT STATEMENT 1 CERTIFICATE OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF FRESNO 3 I certify and declare as follows: I am a citizen of the United States and a resident of the County aforesaid; I am over the age of eighteen years and not a party to the within above- 4 entitled action; my business address is 6485 North Palm Street, Suite 105, Fresno, California 93704. 5 I, Leanne Capuchin, hereby certify that on January 20, 2021, I served the foregoing 6 document described as: PLAINTIFFS’ CASE MANAGEMENT STATEMENT on the interested parties as follows: 7 8 Manuel Garcia, Esq. (SBN 183535) Attorney for Defendants, NOE RAMIREZ- PEEL I GARCIA LLP HENRIQUEZ; SONIA HERNANDEZ DE 9 3585 W. Beechwood, Suite 101 RAMIREZ, a.k.a. ELIZABETH RAMIREZ Fresno, California 93711 10 Telephone: (559) 431-1300 Facsimile: (559) 431-1442 11 Emails: M. Garcia Lanette Andrist 12 13 [X] ELECTRONICALLY: I caused a true and correct copy thereof to be electronically filed using the Court’s Electronic Court Filing (“ECF”) System and service was 14 completed by electronic means by transmittal of a Notice of Electronic Filing on the registered participants of the ECF System. I served those parties who are not registered 15 participants of the ECF System as indicated below. 16 [X ] BY EMAIL: I electronically transmitted a true and correct copy thereof to the interested 17 parties’ electronic notification address(es) of record before close of business for the purpose of effecting service and the transmission was reported as complete and without 18 error. 19 I am employed in the office of a member of the bar of this Court at whose direction the service was made. I declare under penalty of perjury under the laws of the United States of 20 America that the above is true and correct. Executed on January 20, 2021, at Fresno, California. 21 22 /s/ Leanne Capuchin 23 LEANNE CAPUCHIN 24 25 26 27 28 PLAINTIFFS’ CASE MANAGEMENT STATEMENT