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