Preview
7"“
u? .i
*q‘
- - -
CM-11o
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
w
m
_
I
'
Bradley A. Post, Esq. #127028
BORTON PETRINI, LLP ,
_, _.
,
..
~ ~‘
201 Needham Street' 1a
‘s
Modesto, California 95354
TELEPHONE N0; (29) 576— 1 701 FAX No. (Optional): (209) 527-9753
é-MAIL ADDRESS (Optional): bpost@bort0npetrini.com
ATrORNEY FOR (Name): Great Valley Realtors, Inc., Trov Wright and Audrey Gocsch
SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F STANISLAUS
STREET ADDRESS: 801 10th Street, 4th Floor
MAILING ADDRESS:
CITY AND ZIP CODE: Modesto, 953 54
BRANCH NAME:
PLAINTIFF/PETITIONER2BILL BUNNELL and KIM BUNNELL
DEFENDANT/RESPONDENT:GREAT VALLEY REALTORS INC., et a1.
CASENUMBERZ
CASE MANAGEMENT STATEMENT
(Check one): UNLIMITED CASE
(Amount demanded
‘E LIMITED CASE
(Amount demanded is $25,000
2018041
,exceeds $25,000) or less) a
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: December 5, 2016 / Time: 8:30 am. ./ Dept.: 24 / Div.: Room:
Address of court (if different from the address above):
.___ N_otice 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. This statement is submitted by party (name).'Great Valley Realtors, Inc., Troy Wright and Audrey Goesch
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-com plaint (to be answered by plaintiffs and cross-complainants only)
The complaint was filed on (date): 4/22/16
a.
b. D The cross-complaint, if any. was filed on (date):‘
Service be answered by plaintiffs and cross-complainants only)
3.
a.
b.
D
E
(to
All parties named i,n the complaint and cross-complaint have been sewed, have appeared. or have been dismissed.
The following parties named in the complaint or cross-complaint
(1) E have not been served (specify names and explain why not):
(2) D 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. E The following additional parties
they may be served):
may be added (specify names, nature ofinvolvement in case, and date by which
l
4. Description of case
a. Type of case in complaint
Alleged mold infestation in a residence purchased by the Plaintiffs from
E cross—complaint (Describe, including causes of action):
Defendants,Jason Wright and Gina Wright, resulting in alleged personal injury.
Various agents of the parties related to the purchase/sale of the residence have
also been named along with an inspection company hired by the Plaintiffs
‘
'
Page1of5
Cal. Rules of Court,
Mandatory Use
Form Adopted for
Judicial Council of California
CASE MANAGEMENT STATEMENT J
a1 rules 3720—3130
CM-11O [Rev. July 1, 201 1]
6 122 1 /708 5 1 Soitb r15"
I
CM-110
I
PLAINTIFF/PETITIONER: BILL BUNNELL and KIM BUNNELL CASE NUMBER:
2.018941
“DEFENDANT/RESPONDENT; GREAT VALLEY REALTORS INC, et a1.
v
4. b. Provide a brief statement of the case, including any damages. (prersona/ injury damagés 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 reliefis sought, describe the nature of the relief.)
Alleged mold infestation in a residence purchased by the Plaintiffs from Defendants,Jason Wright and
Gina Wright, resulting in alleged personal injury. Various agents of the parties related to the purchase/sale
of the residence have also been named along with an inspection company hired by the Plaintiffs
Ev (/fmore space is needed, check this box and attach a page designated as Attachment 4b.)
'
5. Jury 9r nonjury trial.
The party or parties request
requesting a jury tn'al):
E a jury trial a nonjury trial.
'
(Ifmore than one party, provide the
_
name of each party
Trial
Edate . I
6. .
'
A
~
-
.
a. The trial has been set for (date): L
b. No trial da_te has been set. This case will be ready foritrial 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):
Hégflg-l/Zl/W; 2/6/17; 2/21/16; 2/22/17; 3/14/17; '4/4/17; 4/18/17; 5/9/17; 5/22/17;_6/13/17; 8/8/17; 10/23/17;
7. Estimated length of trial
'
The party or parties estimate that the trial will take (check one):
days (specify number): 6 — 8
a.
b. E hours (short causes) (specify):
‘
8. Trial
The
a.
representation
party or parties
Attorney:
will
(to be answered for each
be represented at trial
party)
by the attorney or party listed in
-
the caption E by the following:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
E-mailaddress: g. Panyrepresented:
9.
D
e.
Preference
Additional repres‘entation is described in Attachment 8.
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
in rule 3.221 to the client and reviewed ADR options with the
E Dclient.
has not provided the ADR information package identified
‘
‘
E E
_
(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).
V
v
(1) This matter is subject to mandatory judicial arbitration 'under Codepf 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
statutdry limit.
‘ v
(2) E case to
Plaintiff elects to refer this
Civil Procedure section 1141 .1 1.
judicial arbitration and agrees to limit recovery to the amount specified in Code of
(3) E"
This case
mediation under
is exempt from judicial
Code
arbitration
of Civil Procedure section
under
1775
rule 3.811 of the California
et seq. (specify exemption):
Rules of Court or from civil action
/«"' fl x'\‘:
”9m”
PM'"°‘R°Z:J“‘V‘-2°“1
_
JSE MANAGEMENT STATEMENT ;
\J 1»
A
.3;
CM-11O
'
PLAINTIFF/PETITIONER: BILL BUNNELL and} KIM BUNNELL 'CASE NUMBER:
2018041
SEFENDANT/RESPONDENT: GREAT VALLEY REALTORS INC., et a1.
10. c. Indicate the ADR process or processes that the party or parties are willing to panicipate'In, have agreed to participate'In or
have already participated In (check all that apply and provide the specified infonnation).
The party or parties completing If in the case have agreed to
the party or parties completing this form
this form are willing to participate in orhave 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
D Mediation session scheduled for (date).-
(1) Mediation
*
E Agreed to complete mediation by (date): v
E Mediation completed on (date):
Settlement conference not yet scheduled
Settlement
E E Settlement conference scheduled for (date):
(2)
conference
E Agreed to‘complete settlement conference by
,
(date).
E Settlement conference completed on (date):
E. Neutral evaluation n_ot yet scheduled
E E Neutral evaluation scheduled for (date):
(3) Neutral evaluation
E Agreed to complete neutral evaluation by (date):
E Neutral evaluation completed on (date):
E Judicial arbitratic‘m not yet scheduled
(4) Nonbinding judicial
E D Judicial arbitration scheduled for (date):
arbitration Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
E Private arbitration not yet scheduled
E D Private arbitration scheduled for (date):
(5) Binding private
arbitration E Agreed to complete private arbitration by (date):
E Private arbitration completed on (date):
E ADR session not yet scheduled
(6) Other (specify): D E ADR session scheduled for (date):
<
Agreed to complete ADR session by (date):
7 ADR completed (date):
9n
CM-110 [Ram 2011]
Page 3 of 5
July
QASE MANAGEMENT STATEMENT
1,
CM-110
PLAINTIFF/PETITIONER; BiLL BUNNEiL and KIM BUNNELL CASE NUMBER:
—DEFENDANT/RESP0NDENT: GREAT VALLEY REALTORS INC, et a1. 201 3041
11. Insurance
E Insurance
Reservation of
carrier,
rights:
if any, for party filing this statement (name):
D Yes CI No
b.
c. E Coverage issues will significantly affect resolution of this case (explain):
'
_
12. Jurisdiction
any matters that may affect the court's jurisdiction or processing of this case _and describe the status.
Indicate
E
Status:
Bankruptcy E Other (specify).
13. Related cases, consolidation, and coordination
a. *E Thére are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
Status:
b.
E
E]
(4)
Additional cases are described
Amotionto E consolidate
in Attachment 13a.
E coordinate will be filed by (name party):
Bifurcation
.
E The party or parties intend to file a motion for
action (specify moving party, type of motion and reasons).
an order bifurcating, esvering, or coordinating the following'Issues or causes of
—
~15. Other motions
D The party or parties expect to file the following motions before trial (specify’moving party, type ofmotion, and issues):
16. Discovery
The party or parties have completed discovery.
E
a. all
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Great Valley Realtors, Inc., Troy Wright 2-17
and Audrey Goesch Written Discovery
Great Valley Realtors, Inc., Troy Wright -
,
9—17
and Audrey Goesch Depositions of experts and witnesses I
Great Valley Realtors, Inc., Troy Wright 12 - 17
‘
'
and Audrey Goesch Expert Discovery
-
c. E The following discovery'issues, including issues regarding the discovery of electronically Stored information. are
anticipated (specify): .
.
.
.
CM-“WRW Ju'yt 2°11]
CASE MANAGEMENT STATEMENT .
”gm”
a
CM-1 10
PLAINTIFF/PETITIONER: BILL BUNNELL and KIM BUNNELL CASE NUMBER:
'
‘oEFENDANT/RESPONDENT; GREAT VALLEY_REALT0RS 1NC., et a1. _
'
201 8041
17. Economic litigation
a. E This Is a limited civil case
of Civil Procedure sections 90- 98
(i. e. the
will
amount demanded
apply to this case.
is $25,000 or Ieés) and the economic litigation procedures in Code
b D This Is
discovery
a limited
will
civil case and a motion to withdraw the case from
the' economic litigation procedures or for additional
be fi led (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
8. Other issues
E
1
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify).
19.
a E
Meet and confer
The party
of Court
or parties
(if
have met and conferred with
not, explain):
all parties on all subjects required by rule 3. 724 of the California Rules
b. After meeting and conferring as required by rule 3. 724 of the California Rules of Court the parties agree on the following
(SPGCIfYT
20. Total number of pages attached (if any):
Iam 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: November M 2016
Bradley A. Post
(TYPE 0R PRINT NAME) WIGNATURE 0F PARTY 0R ATTORNEY)
/
0R PRINT NAME) (SIGNATURE 0F PARTY 0R ATrORNEv)
(TYPE
E Additional signatures are attached.
CM-“WREV-Ju'W-Zm” -
CAéE MANAGEMENT STATEMENT
'
.
'
P6965“
PROOF 0F SERVICE (Code Civ. Prom, §§ 1013a)_
STATE 0F CALIFORNIA, COUNTY 0F STANISLAUS
I am employed in the County of STANISLAUS, State of California. I am over the age of 18 and
not a party~to the within action; my business address is Borton Petrini, LLP, 201 Needham Street,
Modesto, California 95354.
On November 1:1,, 2016, Iserved the foregoing document described as CASE MANAGEMENT
CONFERENCE STATEMENT on the other parties in this action by placing the true copies thereof
enclosed in sealed envelopes addressed as listed.
>
Kevin M. Massoni, Esq. Representing: Plaintiffs, Bill Bunnell and Kim
LAW OFFICE OF MINA L. RAMIREZ Bunnell
1165 Scenic Drive, Suite C-l .
Modesto, California 95350
Tel: (209) 491-0199
10 Fax: (209) 575-9497
E-Mail: >
11
W BY MAIL: As f0110ws: I am "readily familiar” with the firm's practice of collection and
12 processing correspondence for mailing with the United States Postal Service. Under that practice
the envelope would be deposited with U.S. postal service on that same day with postage thereon
13 fully prepaid at Modesto, California in the ordinary course of business.
{‘-
14 BY FACSIMILE: I caused each document to be delivered by electronic facsimile to the listed
above. The-facsimile machine I used complied with California Rules of Court, Rule 2.301 and
15 no error was reported by the machine. Pursuant to California Rules of Court, Rule 2.306.
16 r BY OVERNIGHT COURIER SERVICE: I caused each envelope with postage fully prepaid
to be sent by overnight. '
17
{W3
BY PERSONAL SERVICE: Pursuant to C.C.P. Section 1011, I caused to be delivered such
18 envelope by hand to the offices of the addressee(s) listed on the attached mailing list.
r-
.19 BY ELECTRONIC SERVICE: Pursuant to Code 0f Civil Procedure section 1010.6 and
California Rules of Court, Rule 2.251, service shall be completed via electronic transmission to
20 the attached person(s) transmission of such is at the e—mail address(es) indicated on the attached
. mailinglist.
21
r FEDERAL: I declare that-I am employed in the office of a member of the bar of this court at
22' whose direction the service was made.
23 I declare under penalty 0f perjury under the laWs of the State ofCalifornia that the above is true
and correct.
24
Executed 0n Novembefil, 2016, at Modesto, California.
25
26
Stephanie Lopez
‘
-/'”\\
27 Type or Print Name Si¥nature
28
h:\61221\7085
l\proof of
service.docx
ATTORNEY FOR PLAINTIFFS’:
Kevin M. Massoni, Esq.
LAW OFFICE 0F MINA L. RAMIREZ
1165 Scenic Drive, Suite C—1
Modesto, California 95350
Telephone: (209) 491-0199
Fax: (209) 575-9497
10
11
12
13
l4
15
16
17
18
19
20
21
22
23
24
25
26
27
28
h:\6122 l\7085
1\proof of
service.docx
Preview
7"“ u? .i *q‘ - - - CM-11o ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY w m _ I ' Bradley A. Post, Esq. #127028 BORTON PETRINI, LLP , _, _. , .. ~ ~‘ 201 Needham Street' 1a ‘s Modesto, California 95354 TELEPHONE N0; (29) 576— 1 701 FAX No. (Optional): (209) 527-9753 é-MAIL ADDRESS (Optional): bpost@bort0npetrini.com ATrORNEY FOR (Name): Great Valley Realtors, Inc., Trov Wright and Audrey Gocsch SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F STANISLAUS STREET ADDRESS: 801 10th Street, 4th Floor MAILING ADDRESS: CITY AND ZIP CODE: Modesto, 953 54 BRANCH NAME: PLAINTIFF/PETITIONER2BILL BUNNELL and KIM BUNNELL DEFENDANT/RESPONDENT:GREAT VALLEY REALTORS INC., et a1. CASENUMBERZ CASE MANAGEMENT STATEMENT (Check one): UNLIMITED CASE (Amount demanded ‘E LIMITED CASE (Amount demanded is $25,000 2018041 ,exceeds $25,000) or less) a A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: December 5, 2016 / Time: 8:30 am. ./ Dept.: 24 / Div.: Room: Address of court (if different from the address above): .___ N_otice 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. This statement is submitted by party (name).'Great Valley Realtors, Inc., Troy Wright and Audrey Goesch b. This statement is submitted jointly by parties (names): 2. Complaint and cross-com plaint (to be answered by plaintiffs and cross-complainants only) The complaint was filed on (date): 4/22/16 a. b. D The cross-complaint, if any. was filed on (date):‘ Service be answered by plaintiffs and cross-complainants only) 3. a. b. D E (to All parties named i,n the complaint and cross-complaint have been sewed, have appeared. or have been dismissed. The following parties named in the complaint or cross-complaint (1) E have not been served (specify names and explain why not): (2) D 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. E The following additional parties they may be served): may be added (specify names, nature ofinvolvement in case, and date by which l 4. Description of case a. Type of case in complaint Alleged mold infestation in a residence purchased by the Plaintiffs from E cross—complaint (Describe, including causes of action): Defendants,Jason Wright and Gina Wright, resulting in alleged personal injury. Various agents of the parties related to the purchase/sale of the residence have also been named along with an inspection company hired by the Plaintiffs ‘ ' Page1of5 Cal. Rules of Court, Mandatory Use Form Adopted for Judicial Council of California CASE MANAGEMENT STATEMENT J a1 rules 3720—3130 CM-11O [Rev. July 1, 201 1] 6 122 1 /708 5 1 Soitb r15" I CM-110 I PLAINTIFF/PETITIONER: BILL BUNNELL and KIM BUNNELL CASE NUMBER: 2.018941 “DEFENDANT/RESPONDENT; GREAT VALLEY REALTORS INC, et a1. v 4. b. Provide a brief statement of the case, including any damages. (prersona/ injury damagés 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 reliefis sought, describe the nature of the relief.) Alleged mold infestation in a residence purchased by the Plaintiffs from Defendants,Jason Wright and Gina Wright, resulting in alleged personal injury. Various agents of the parties related to the purchase/sale of the residence have also been named along with an inspection company hired by the Plaintiffs Ev (/fmore space is needed, check this box and attach a page designated as Attachment 4b.) ' 5. Jury 9r nonjury trial. The party or parties request requesting a jury tn'al): E a jury trial a nonjury trial. ' (Ifmore than one party, provide the _ name of each party Trial Edate . I 6. . ' A ~ - . a. The trial has been set for (date): L b. No trial da_te has been set. This case will be ready foritrial 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): Hégflg-l/Zl/W; 2/6/17; 2/21/16; 2/22/17; 3/14/17; '4/4/17; 4/18/17; 5/9/17; 5/22/17;_6/13/17; 8/8/17; 10/23/17; 7. Estimated length of trial ' The party or parties estimate that the trial will take (check one): days (specify number): 6 — 8 a. b. E hours (short causes) (specify): ‘ 8. Trial The a. representation party or parties Attorney: will (to be answered for each be represented at trial party) by the attorney or party listed in - the caption E by the following: b. Firm: c. Address: d. Telephone number: f. Fax number: E-mailaddress: g. Panyrepresented: 9. D e. Preference Additional repres‘entation is described in Attachment 8. 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 in rule 3.221 to the client and reviewed ADR options with the E Dclient. has not provided the ADR information package identified ‘ ‘ E E _ (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). V v (1) This matter is subject to mandatory judicial arbitration 'under Codepf 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 statutdry limit. ‘ v (2) E case to Plaintiff elects to refer this Civil Procedure section 1141 .1 1. judicial arbitration and agrees to limit recovery to the amount specified in Code of (3) E" This case mediation under is exempt from judicial Code arbitration of Civil Procedure section under 1775 rule 3.811 of the California et seq. (specify exemption): Rules of Court or from civil action /«"' fl x'\‘: ”9m” PM'"°‘R°Z:J“‘V‘-2°“1 _ JSE MANAGEMENT STATEMENT ; \J 1» A .3; CM-11O ' PLAINTIFF/PETITIONER: BILL BUNNELL and} KIM BUNNELL 'CASE NUMBER: 2018041 SEFENDANT/RESPONDENT: GREAT VALLEY REALTORS INC., et a1. 10. c. Indicate the ADR process or processes that the party or parties are willing to panicipate'In, have agreed to participate'In or have already participated In (check all that apply and provide the specified infonnation). The party or parties completing If in the case have agreed to the party or parties completing this form this form are willing to participate in orhave 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 D Mediation session scheduled for (date).- (1) Mediation * E Agreed to complete mediation by (date): v E Mediation completed on (date): Settlement conference not yet scheduled Settlement E E Settlement conference scheduled for (date): (2) conference E Agreed to‘complete settlement conference by , (date). E Settlement conference completed on (date): E. Neutral evaluation n_ot yet scheduled E E Neutral evaluation scheduled for (date): (3) Neutral evaluation E Agreed to complete neutral evaluation by (date): E Neutral evaluation completed on (date): E Judicial arbitratic‘m not yet scheduled (4) Nonbinding judicial E D Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): E Private arbitration not yet scheduled E D Private arbitration scheduled for (date): (5) Binding private arbitration E Agreed to complete private arbitration by (date): E Private arbitration completed on (date): E ADR session not yet scheduled (6) Other (specify): D E ADR session scheduled for (date): < Agreed to complete ADR session by (date): 7 ADR completed (date): 9n CM-110 [Ram 2011] Page 3 of 5 July QASE MANAGEMENT STATEMENT 1, CM-110 PLAINTIFF/PETITIONER; BiLL BUNNEiL and KIM BUNNELL CASE NUMBER: —DEFENDANT/RESP0NDENT: GREAT VALLEY REALTORS INC, et a1. 201 3041 11. Insurance E Insurance Reservation of carrier, rights: if any, for party filing this statement (name): D Yes CI No b. c. E Coverage issues will significantly affect resolution of this case (explain): ' _ 12. Jurisdiction any matters that may affect the court's jurisdiction or processing of this case _and describe the status. Indicate E Status: Bankruptcy E Other (specify). 13. Related cases, consolidation, and coordination a. *E Thére are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: Status: b. E E] (4) Additional cases are described Amotionto E consolidate in Attachment 13a. E coordinate will be filed by (name party): Bifurcation . E The party or parties intend to file a motion for action (specify moving party, type of motion and reasons). an order bifurcating, esvering, or coordinating the following'Issues or causes of — ~15. Other motions D The party or parties expect to file the following motions before trial (specify’moving party, type ofmotion, and issues): 16. Discovery The party or parties have completed discovery. E a. all b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Great Valley Realtors, Inc., Troy Wright 2-17 and Audrey Goesch Written Discovery Great Valley Realtors, Inc., Troy Wright - , 9—17 and Audrey Goesch Depositions of experts and witnesses I Great Valley Realtors, Inc., Troy Wright 12 - 17 ‘ ' and Audrey Goesch Expert Discovery - c. E The following discovery'issues, including issues regarding the discovery of electronically Stored information. are anticipated (specify): . . . . CM-“WRW Ju'yt 2°11] CASE MANAGEMENT STATEMENT . ”gm” a CM-1 10 PLAINTIFF/PETITIONER: BILL BUNNELL and KIM BUNNELL CASE NUMBER: ' ‘oEFENDANT/RESPONDENT; GREAT VALLEY_REALT0RS 1NC., et a1. _ ' 201 8041 17. Economic litigation a. E This Is a limited civil case of Civil Procedure sections 90- 98 (i. e. the will amount demanded apply to this case. is $25,000 or Ieés) and the economic litigation procedures in Code b D This Is discovery a limited will civil case and a motion to withdraw the case from the' economic litigation procedures or for additional be fi led (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 8. Other issues E 1 The party or parties request that the following additional matters be considered or determined at the case management conference (specify). 19. a E Meet and confer The party of Court or parties (if have met and conferred with not, explain): all parties on all subjects required by rule 3. 724 of the California Rules b. After meeting and conferring as required by rule 3. 724 of the California Rules of Court the parties agree on the following (SPGCIfYT 20. Total number of pages attached (if any): Iam 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: November M 2016 Bradley A. Post (TYPE 0R PRINT NAME) WIGNATURE 0F PARTY 0R ATTORNEY) / 0R PRINT NAME) (SIGNATURE 0F PARTY 0R ATrORNEv) (TYPE E Additional signatures are attached. CM-“WREV-Ju'W-Zm” - CAéE MANAGEMENT STATEMENT ' . ' P6965“ PROOF 0F SERVICE (Code Civ. Prom, §§ 1013a)_ STATE 0F CALIFORNIA, COUNTY 0F STANISLAUS I am employed in the County of STANISLAUS, State of California. I am over the age of 18 and not a party~to the within action; my business address is Borton Petrini, LLP, 201 Needham Street, Modesto, California 95354. On November 1:1,, 2016, Iserved the foregoing document described as CASE MANAGEMENT CONFERENCE STATEMENT on the other parties in this action by placing the true copies thereof enclosed in sealed envelopes addressed as listed. > Kevin M. Massoni, Esq. Representing: Plaintiffs, Bill Bunnell and Kim LAW OFFICE OF MINA L. RAMIREZ Bunnell 1165 Scenic Drive, Suite C-l . Modesto, California 95350 Tel: (209) 491-0199 10 Fax: (209) 575-9497 E-Mail: > 11 W BY MAIL: As f0110ws: I am "readily familiar” with the firm's practice of collection and 12 processing correspondence for mailing with the United States Postal Service. Under that practice the envelope would be deposited with U.S. postal service on that same day with postage thereon 13 fully prepaid at Modesto, California in the ordinary course of business. {‘- 14 BY FACSIMILE: I caused each document to be delivered by electronic facsimile to the listed above. The-facsimile machine I used complied with California Rules of Court, Rule 2.301 and 15 no error was reported by the machine. Pursuant to California Rules of Court, Rule 2.306. 16 r BY OVERNIGHT COURIER SERVICE: I caused each envelope with postage fully prepaid to be sent by overnight. ' 17 {W3 BY PERSONAL SERVICE: Pursuant to C.C.P. Section 1011, I caused to be delivered such 18 envelope by hand to the offices of the addressee(s) listed on the attached mailing list. r- .19 BY ELECTRONIC SERVICE: Pursuant to Code 0f Civil Procedure section 1010.6 and California Rules of Court, Rule 2.251, service shall be completed via electronic transmission to 20 the attached person(s) transmission of such is at the e—mail address(es) indicated on the attached . mailinglist. 21 r FEDERAL: I declare that-I am employed in the office of a member of the bar of this court at 22' whose direction the service was made. 23 I declare under penalty 0f perjury under the laWs of the State ofCalifornia that the above is true and correct. 24 Executed 0n Novembefil, 2016, at Modesto, California. 25 26 Stephanie Lopez ‘ -/'”\\ 27 Type or Print Name Si¥nature 28 h:\61221\7085 l\proof of service.docx ATTORNEY FOR PLAINTIFFS’: Kevin M. Massoni, Esq. LAW OFFICE 0F MINA L. RAMIREZ 1165 Scenic Drive, Suite C—1 Modesto, California 95350 Telephone: (209) 491-0199 Fax: (209) 575-9497 10 11 12 13 l4 15 16 17 18 19 20 21 22 23 24 25 26 27 28 h:\6122 l\7085 1\proof of service.docx