arrow left
arrow right
  • BANKERS STANDARD INSURANCE COMPANY  vs.  TT LEE CORPORATION, et al(23) Unlimited Other PI/PD/WD document preview
  • BANKERS STANDARD INSURANCE COMPANY  vs.  TT LEE CORPORATION, et al(23) Unlimited Other PI/PD/WD document preview
  • BANKERS STANDARD INSURANCE COMPANY  vs.  TT LEE CORPORATION, et al(23) Unlimited Other PI/PD/WD document preview
  • BANKERS STANDARD INSURANCE COMPANY  vs.  TT LEE CORPORATION, et al(23) Unlimited Other PI/PD/WD document preview
  • BANKERS STANDARD INSURANCE COMPANY  vs.  TT LEE CORPORATION, et al(23) Unlimited Other PI/PD/WD document preview
  • BANKERS STANDARD INSURANCE COMPANY  vs.  TT LEE CORPORATION, et al(23) Unlimited Other PI/PD/WD document preview
  • BANKERS STANDARD INSURANCE COMPANY  vs.  TT LEE CORPORATION, et al(23) Unlimited Other PI/PD/WD document preview
  • BANKERS STANDARD INSURANCE COMPANY  vs.  TT LEE CORPORATION, et al(23) Unlimited Other PI/PD/WD document preview
						
                                

Preview

CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Grant H. Baker 237276 ALLEN, BAKER (s STEPHAN, PC 66 Bovet Road, Suite 250 San Mateo, CA 94402 TELEPHONE NO.:( 65 0 ) 3 4 7 — 50 0 0 650 ) FAX NO.(Optional): ( 340-6350 E-MAIL ADDREss grant Qmbal 1 enlaW . COm (optional): 2/24/2021 ATTDRNEYFQR(Name): GiSela SCiglianO suPERloR coURT oF cALIFDRNIA, coUNTY QF San Mateo sTREETADDREss: 400 County Center MAILING ADDRESS: cITYANDzIPcoDE: Redwood City, CA 94063 BRANCH NAME: PLAINTIFF(PETITIONER: Bankers Standard Insurance DEFENDANT/REsPoNDENT: TT Lee Corporation, et al. CASE MANAGEMENT STATEMENT (Check one): ~ UNLIMITED CASE (Amount demanded ~ LIMITED CASE (Amount demanded is $ 25,000 CASE NUMBER'7CIV04316 exceeds $ 25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: March 9, 2021 Time: 9: 00 a.m. Dept.: 2 Div.: Room: Address of court (if dil'ferent from the address above): Qg Notice of Intent to Appear by Telephone„by (name): Grant H. Baker INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. b. ~ ~ This statement is submitted by party (name): Gisela This statement is submitted jointly by parties (names): Scigliano 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. Qg The cross-complaint, if any, was filed on (date): July 26, 2018 3. Service (to be answered by plaintiffs and cross-complainants only) a. Qg 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): ~ The following additional parties may be added (specify names, nature ofinvolvementin case, and the date by which they may be served): 4. Description of case a. Type of case in Cross-Complainant ~ complaint Gisela ~ cross-complaint Scig1iano is (Describe, including causes of action): suing for negligence, breach of contract and breach of express warranty. Page 1 of 5 Form Adopied for Mandatory Use CASE MANAGEIIENT STATEIIENT Cal. Rules of Court, & L+p' Judicial Council of CaliforniaI ESSentialI (~,=,@FOrme- CM-110 [Rev. July 1, 2011] rules 3.720-3.730 www. courts. ca. gov a Scigliano CII-110 PLAINTIFF/PETITIONER[Bankers Standard Insurance CASE NUMBER; 17CIV04316 DEFENDANT/RESPONDENT: TT Lee Corporation, et al. 4. b. Provide a brief statement of the case, including any damages. (If personalinjury 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 reliefis sought, describe the nature of the relief) Property damage and construction defect case. ~ (If morespace is needed, check this box and attach a page designated as Attachment 4b,) 5. Jury or nonjury trial The party or parties request requesting ajury trial): ~ a jury trial ~ a nonjury trial. (If more than one party, provide the name of each party 6. Trial date a. b. ~ ~ 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): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. b. ~ ~ days (specify number): 21 days hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial a. Attorney: ~ 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: Party represented: ~ Additional representation is describedinAttachment 8. g. 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 of 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): Amount in controversy exceeds jurisdictional limits. CM-110 [Rev. July 1, 2011] CASE IIANAGEIMENT STATEIIENT Page 2 of 5 Q&~ 'Essential , eeb~o~,* g FOrllls Scigliano CII-110 PLAINTIFFlPETITIONER:Bankers S t andard Insurance CASE NUMBER: 17CIV04316 DEFENDANT/RESPONDENT: TT Lee Corporation, et al. 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 ail 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'AOR processes (check all that apply): stipulation): ~ Mediation session not yet scheduled (1) Mediation ~ Mediation session scheduled for (date): ~ Agreed to complete mediation by (date): 0 4 /2 2/2 02 1 ~ 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): ~ 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 (6) Other (specify): ~ ADR session scheduled for (date): ~ Agreed to complete ADR session by (date): ~ ADR completed on (date): CM-110 [Rev. July 1, 2011] CASE IIANAGEMENT STATEMENT Page 3 of 5 pre Essential '= ceb.corn Fo~s Scigliano i CM-410 PLAINTIFF/PETITIQNER:Bankers Standard Insurance CASE NUMBER: 17CIV04316 DEFENDANT/REsPoNDENT: TT Lee Corporation, et al. 11. Insurance a. b. ~ Insurance carrier, if any, for party filing this statement (name): Reservation of rights: ~ Yes ~ c. ~ No 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. ~ ~ (4) Additional cases are described in Attachment 13a. A motion to ~ consolidate ~ coordinate willbe 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 ~ The party or parties expect to file the following motions before trial (specify moving party, type of motion,and issues): 16. Discovery a. b. ~ jQ The party or parties have completed all discovery. The following discovery will be completed by the date specified (descnbe ail anticipated discovery): ~Part ~Deecri tioo Date Cross-complainant Depositions TBD All Parties Expert Discovery 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) CASE MANAGEMENT STATEMENT Page 4 of 5 { &&E 'ssential '.IFOrrna eeBeoo, , Scigliano CM-110 PLA)NT)FF/PET(T(oNER: Bankers Standard Insurance CASE NUMBER: 17CIVOij316 DEFENDANT/REsPGNDENT: TT Lee Corporation, et al. 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): am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, I 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: February 24, 2021 (TYPE OR PRINT NAME) (SIGN. RE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) ~ Additional signatures are attached. CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5 QLg Essential jWFOrma ceb.cooI Scigliano PROOF OF SERVICE I, Maribel Gomez, declare I am a citizen of the United States of America employed in the City and County of San Mateo, State of California. I am over the age of 18 years and am not a party to the within action. My business address is the Allen, Baker 4 Stephan, PC, 66 Bovet Road, Suite 250, San Mateo, California 94402. I am readily familiar with the practices for collection and processing of correspondence for mailing with the United States Postal Service. On February 24, 2021 I served the following documents: 1. CASE MANAGEMENT STATEMENT 10 BY MAIL:by placing a true and correct copy thereof enclosed in a sealed envelope with first-class postage thereon fully prepaid in the United States Postal Office at San Mateo, California addressed as set forth below. 12 BY E-MAIL:by scanning and e-mailing a true and correct copy thereof to the party at the e-mail address set forth below. BY PERSONAL DELIVERY: by causing to be hand delivered a true and correct copy thereof to the erson at the address below. BY FEDERAL EXPRESS: by placing a true and correct copy thereof enclosed in a sealed Federal Express envelope fully prepaid at a facility regularly maintained by Federal Express, 16 addressed as set forth below, BY FACSIMILE: by causing a true and correct copy thereof to be telecopied to the party at the facsimile number set forth below. 18 19 Ashley E. Bauerle, Esq. [Attorney for Bankers Standard Insurance Cozen O'onnor Company] 20 501 West Broadway, Suite 1610 San Diego, CA 92101 Tel: (619) 234-1700 21 Fax: (619) 234-7831 E-Mail:abauerle@co zen.corn 23 Kurt Bridgman, Esq, [Attorney for TT Lee Corporationj Vogl Meredith Burke LLP 456 Montgomery Street, 20'" Floor Tel: (415) 981-6630 San Francisco, CA 94104 Fax: (415) 982-1634 E-Mail:kbridgman@lowball.corn 26 27 PROOF OF SERVICE I Erin N. Collins [Attorney for Jeff R. Townsend dba Onsite Manning k Kass Custom Homes] Ellrod, Ramirez, Trester LP 1 California Street, Suite 900 Tel: (415) 217-6990 San Francisco, CA 94111 Fax: (415) 217-6999 E-Mail:ecn@manningllp.corn Timothy C. McNeil [Attorney for Chesler Construction, Inc.] Law Office of Patrick J. Campbell 3880 Atherton Road Tel: (916) 630-3803 Rocklin, CA 95765 Fax: (916) 630-3848 E-Mail:tmcneill@unitedfiregroup.corn Brian T. Bjorge [Attorney for Kevin Gee dba Tri-Line Mokri, Vanis k Jones, LLP Construction] 2251 Fair Oaks Blvd., Suite 100 10 Sacramento, CA 95825 Tel: (916) 306-0434 Fax: (949) 226-7150 E-Mail:bbjorge@mvjllp.corn 12 Kimberly A. Millington [Attorney for Legacy Roofing k Waterproofing, Law Offices of John A Hauser Inc] P.O. Box 2282 14 Brea, CA 92822 Tel: (714) 571-0407 Fax: (877) 369-5799 E-Mail:kimberly.millington@thehartford.corn 16 Brett T. Moroney [Attorney for Gisela Scigliano] Gordon Rees Scully Mansukhani 275 Battery Street, Suite 2000 Tel: (415) 986-5900 San Francisco, CA 94111 Fax: (415) 986-8054 E-Mail:bmoroney@grsm.corn 19 20 I declare under penalty of perjury under the laws of the State of California that the foregoing 21 statements are true and correct. Executed this 24'" day of February, 2021, at San Mateo, California. 22 23 Q)Qg$v~{i'Q PYg 3 MARIBEL GOME 26 27 28 PROOF OF SERVICE 2