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  • Cristian Sanchez vs. Florence Varela/COMPLEX33 Unlimited - Wrongful Eviction document preview
  • Cristian Sanchez vs. Florence Varela/COMPLEX33 Unlimited - Wrongful Eviction document preview
  • Cristian Sanchez vs. Florence Varela/COMPLEX33 Unlimited - Wrongful Eviction document preview
  • Cristian Sanchez vs. Florence Varela/COMPLEX33 Unlimited - Wrongful Eviction document preview
  • Cristian Sanchez vs. Florence Varela/COMPLEX33 Unlimited - Wrongful Eviction document preview
  • Cristian Sanchez vs. Florence Varela/COMPLEX33 Unlimited - Wrongful Eviction document preview
  • Cristian Sanchez vs. Florence Varela/COMPLEX33 Unlimited - Wrongful Eviction document preview
  • Cristian Sanchez vs. Florence Varela/COMPLEX33 Unlimited - Wrongful Eviction document preview
						
                                

Preview

ATTORNEY OR PARTY WITHOUT ATTORNEY I Name, Slate Bar number, and address) FOR COURT USE ONLY JOHN D. SUHR, Esq. j)083023 ATTORNEY AT LAW 757 "L" STREET FRESNO, CA 93721 E-FILED TELEPHONENO. (559) 266-3327 FaxNo(optmnasl (559) t)90-t)679 10/1/2020 9:22 AM E-MAIL ADDRESS Superior Court of California Defendant/Cross-Defendant, (Opnonas'TTORNEYFoRBYamex JAIY)KE County of Fresno SUPERIDR coURT QF GALIFQRNIA, coUNTY oF FRESNO STREETaooREss B. F. SISK COURTHOUSE By: M. Sanchez, Deputy MAILINGADDRESS. 1 130 HOR STREET CITYANDZIP CODE FRESNOT CA 93721 BRANCHNAME CENTRAL DIVISION PLAINTIFF/PETITIONER: CHRISTIAN SANCHEZ, EVA SANCHEZ DEFENDANT/REsPoNDENT: FLOPRENCE VARELA, JAIv)KE, a Cal STRATEGIC REI, a California Corporation CASE MANAGEMENT STATENIENT (Check one)f ~ UNLIMITED CASE (Amount demanded ~ LIMITED CASE (Amount demanded is $ 25,000 CASE NUMBER. 20CECG00912 exceeds $ 25,000) or less) A CASE MANAGENIENT CONFERENCE is scheduled as follows: Date: 10/15/20 Time: 3: 30 Dept.: 503 DivE Room: Address of court (If different from the address above): ~ Notice of Intent to Appear by Telephone, by(name)T INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. [g This statement is submitted by party (name): a California General Partnership b. ~ JAIYIKE, This statement is submitted jointly by parties (names)) 2. Complaint and cross-complaint (to be answered by plaintllfs and cross-complainanls only) a. The complaint was filed on (date)) b. ~ The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plalntilfs and cross-complainanls only) a. b. ~Qg All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. The following parties named in the complaint or cross-complaint (1) Qg have not been served (specify names and explain why noi)) Cross-Defendant STRATEGIC REI (2) Qg have been served but have not appeared and have not been dismissed (specify names): Cross-Defendants, (3) ~ FLORENCE VARELA have had a default entered against them (speci)'y names): c. ~ The following additional parties may be added (speclly names, nature of involvement in they may be served) J case, and the date by which 4. Description of case a. Type of case in Breach of QQ complaint Warranty, ~ cross-complaint negligence, nuisance, (Descnbe, including causes and constructive of action): eviction Form adoptedforMandatoryuse Page1ofs Judlolat Counul of Cairfomra L~g . ~ Eaaential CASE MANAGEMENT STATEMENT Cal RulesofCourt, CM-110(Res July 1,2011)( rules 3.720-3 730 N m +FennS ears oourfs oe.goo CM-110 PLAINTIFF/PETITIONER:CHRISTIAN SANCHEZ f EVA SANCHE CASE NUMBER 20CECG00912 DEFENDANT/RESPONDENT: FLOPRENCE VARELA, JmfiKE, a Ca STRATEGIC REI, a California Corporation 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, descn'be the nature of the relief) Plaintiff seeks unspecified damages due to condition of property Plaintiffs rented ~ (If morespace is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request requesting a jury trial): ~ a jury trial Qg a nonjury trial. (If more than one party, provide the name of each party Trial date a. b. ~ Q3 The trial has been set for (date): 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): Estimated length of trial The party or parties estimate that the trial will take (check one): a. b. ~ ~ days (specifynumber): unknown hours (short causes) (specify): at this time Trial representation (to be answered for each party) The party or parties will be represented at trial a. Attorney: Qg by the attorney or party listed in the caption ~ by the following: b. Firm: c. Address: d. Telephone number; f. Fax number: e. E-mail address: g. Party represented: ~ Additional representation is described inAttachment 8. 9. Preference ~ This case is entitled to preference (specify code section): 10. Alternativedispute 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. 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 1141.11or to civil action mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) C3 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 IRee. Jotr 1, 20111 CASE MANAGEMENT STATEMENT Page 2 oi 5 QQJ'ssential P]Forms. 1 CM-110 PLAINTIFF/PETITIONER:CHRISTIAN SANCHEZ f EVA SANCHE CASE NIJMBER 20CECG00912 DEFENDANT/RESPONDENT: FLOPRENCE VARELA, JA(J)KE, a Ca STRATEGIC REI, a California Corporation 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 (1) Mediation ~ Mediation session scheduled for (date): ~ 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 (3) Neutral evaluation ~ Neutral evaluation scheduled for (date): ~ Agreed to complete neutral evaluation by (date)i ~ 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)i ~ Judicial arbitration completed on (date): ~ Private arbitration not yet scheduled (5) Binding private ~ Private arbitration scheduled for (dale): arbitration ~ Agreed to complete private arbitration by (date): ~ Private arbitration completed on (dafe): ~ ADR session not yet scheduled (6) Other (specify): ~ ADR session scheduled for (date)i ~ Agreed to complete ADR session by (date): ~ ADR completed on (date): CM-110 IRev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5 ( g3 Essential PgFerms CM-110 PLAINTIFF/PETITIONER:CHRISTIAN SANCHEZ, EVA SANCHEZ CASE NUMBER 20CECG00912 DEFENDANT/RESPONDENT: FLOPRENCE VARELA, JA(J)KE, a Cal STRATEGIC REI, a California Corporation 11. Insurance a. b. ~ Insurance carrier, if any, for party filing this statement (name): Reservation of rights: C3 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 Status: ~ Other (specify): 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: Status: b. ~ j3 (4) Additional cases are described in Attachment 13a. A motion to ~ consolidate ~ coordinate willbe filed by (name party): 14. Bifurcation Cl 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 ~ The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. b. ~ Q ei The party or parties have completed all discovery. The following discovery will be completed by the date specified (descn'be all anticipated discovery): Paray Descriotion Date Defendants interrogatories, deposition 3/I/21 c. ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (spec//y): CM110[Rev July1, 2011/ CASE MANAGEMENT STATEMENT Page 4 of 6 ( ~J3'ssential mgaom P]FOrme CM-110 PLAINTIFF/PETITIONER: CHRISTIAN SANCHEZ, EVA SANCHEZ CASE NUMBER 20CECG00912 DEFENDANT)RESPONDENT: FLOPRENCE VARELA, JMIIKE, a Cal STRATEGIC REI, a California Cor oration 17. Economic litigation a. ~ This is a limited civil case (i.e., the amount demanded is $ 25,000 or less) and the of Civil Procedure sections 90-98 will apply to this case. economic litigation procedures in Code 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 re/ating fo discovery or trial should not apply to this caseji 18. Otherissues ~ The party or parties request that the following additional matters be considered conference (specifyji or determined at the case management 19. Meet and confer a. Q3 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 (specifyj) No agreement s yet 20. Total number of pages attached (if anyj: 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: 9/30/20 ,TORN n qrr)TR (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) ~ Additional signatures are attached. CM-1 10 [Re July I, 2011] CASE MANAGEMENT STATEMENT ( ~'ssential Page 0 or 0 6 Forms- Re: Sanchez v Varela Case No.: 20CECL00912 2 PROOF OF SERVICE (C.C.P. sections 1013a(3), 2015.5) STATE OF CALIFORNIA) :ss COUNTY OF FRESNO ) 5 I am and at all times herein mentioned was, a citizen of the United States and a resident of the County of Fresno, over the age of 18 years and not a party to the within action; That my business address is 757 "L" Street, Fresno, California 93721; that on October I, 2020, I served the within: CMC STATEMENT OF JAMKE, On the interested parties in said action, by email/Electronic transmission. I caused the documents to be sent to the person at the email address indicated below, as follows: 10 SANTOSH NARAYAN, Esq. 223 S. Lake Ave., suite 300 12 Pasadena, CA 91101 email: snarayan@narayanlegal.corn 13 ROBERT C. ABRAMS, Esq. 5412 N. Palm Ave., Suite 101 Fresno, Ca 93704 15 email: bob@rcabramslaw.corn Kurt Bridgman VOGL MEREDITH BURKE LLP 17 456 Montgomery Street, 20th Fl 18 San Francisco, CA 94104 Email: kbridgman@vmbllp.corn 20 I certify under penalty of perjury under the laws of the State of California that the foregoing is hue and correct, and that this certification was executed on this I" day of 21 October, 2020, at Fresno, California. 22 ,JO D. SUHR 23 25