Preview
ISM-110
M’CRNEY (Name.
HTTORNEF {JR F'K-RTY WITHOUT" “was:
same 5a: m3;
E-IU FOR CDURI'USE DNL‘P'
Mark T. Coffin [SB-N 1635?“
MARK T. COFFIN, P.C.
ELECTRONICALLY
LECTRONICALLY FILED
21 E. CarrilloSt, Suite 2413,Santa Barbara. CA 93101 Superior
uperior Court of California
305—24831 '15
TELEPI mus: NO- 5»; N0rounonalj 305—567—4028
County
ounty of Santa Barbara
Fme nnnRFSS[am-Iw' mtc@markcoffinlaw.com
Darrel
arrel E. Parker, Executive Officer
AIIUHNtY Hm [mm APPELLANT
8/22/2019
/22/2019 3:13 PM
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA
1100 Anacapa Street
STREET HEZREES.
By:
E y: Terri Chavez, Deputy
wh-ING HDI'MESS:
‘I100 An acapa Street
COD“
CITY AND ZIP Santa Barbara 93101
HRANL‘H NAME.
ANACAPA
PLHINTIFFIF'ETITIONER: DAVID B. BERTRAND. et al.
DEFENDANTJRESF‘ONDENT.‘ JESSICA BERRY
CASE MANAGEMENT STATEMENT CASE NUMBER
{Check one): UNLIMITED CASE
{Amount demanded
El LIMITED CASE
(Amount demanded is $25,000
1QCV02429
exceeds 325,000] or less]
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: September 09, 2019 Time: 8:30 am. Dept; 5 Div; Room:
Address of court {If dr'fi'erenf from the addmss above):
|:I Notice of Intentto Appear by Telephone. by (name):
FNSTRUCWONSi A" applicable bOXBB must be checked. and the specified information must be provided.
1. Party or parties (answer one]:
a. This statement is submitted by party meme}.- Plaintiffs DAVID G. BERTRAND, et af.
b. [:I This stalement is submitted jolntly by parties {names}:
2. Complaint and cross-compiaint {to be answered by plaintiffs and cmss-mmplamants only)
a. The cumplaint was flied on (date): May 0?, 2019
In. CI The crass-cumplaint ifany, was filed on {date}:
3. Service (to be answered by plaintiffs and cmss—complamanrs 0:1n
a. |:] Alf parties named in the complaint and cross-mplaint have been served. have appeared. or have been dismissed.
in. E! The following parties named in the complaint or CrDSE-onrnplainl
{1} El have not been served (specffir names and expfal'n why not):
{2) D have been served but have not appeared and have not been dismissed (Specify names}:
(3] have had a default entered against them {mdfil names};
JESSICA BERRY
0. CI The following additional parties be added (.309c}: names,
may“r natune ofinvaivemenr in case, and date by which
may may be served:
Description of cage
3- Type 0f0359 In complaint |:| cross—complaint (Describe. including causes of actimu:
The issues in the case involve Defendant BERRY and her iibel,defamation per se, intrusion, intentional
infliction of emotional distress. unfair business practices. and elder abuse towards Plaintiffs.
PageI of
B
”'3323$.Déiflfififigifififli2“ CA5 E MANAGEM EN T STATE ME NT Bfiglzgzfiurgn
CM-' ID |Htw. 20-1]
J.';.-' 1. mw.cmr!:.c.:.g:w
CHI-110
“SW-WW”
_ PLAINTJFHPETITIONER: DAVID G. BERTRAND. et al.
19CV02429
DEFENDANTJRESF'DNDENT; JESSICA BERRY
4. h. Provide a brief statement of the case, including any damages. {persanah'njury damages am sougm, specific H15 r'njwy and
damages claimed, including medical! expenses to dafe fi'ndr'care source and amount}, esfimated {amne- medical expenses, rust
earnings in date.and estimated Mum (as! earnings. if ego-flame refiefis sought describe the nature of the refiei}
Defendant made defamatory statements about both Plaintiffs. has accused Plaintiff of beinga "pimp", a
"cn'rninar', and "rapist" among other things with the intent toharass and defame BERTRAND. Delendanl was
unjustly enriched by unreimbursed payments and loans made by Plaintiff BERTRAND.
[:l (Ifmore space is needed, check this box and attach a page designafed as Anacnmeni 4b.)
5. Jury or nonjury trial
The party or parties rEquest
noquesfing a jury mm}:
a jury trialI: a nDnq triaJ. (Hmong than me party. provide me name of each party
5. Tria! date
a. CI The trial has bean set for (dam);
b. No Trial date has been set. This case will be read}.r for triaf within 12 months of the date of the filing of the Complaint (If
not.explain):
6. Dates on which parties or attorneys will not be available for trial (specify dates and axpfar'n reasons for unavailability):
9:10—11r19 and 1Df11-1Bf19.
T. Estimated Fength of trial
The party ur parties esfimate that the trial will take (check oneJ:
5. III days (specfflr number): 4
b. 1:] hours(5hor1 causes] {specify}:
3. Trial representation (fa be answered for each party)
The party or parfies will be represented at trial
a. Attorney:
IE by the attorney or pany listed in the caption |:I by the following:
b. Firm:
C. Address:
{1. Telephone number: f_ Fax number:
e E-mail address;
|:| Additiunal represerflation is described in Attachment 8.
9. Pariy represented:
El. Preference
This case is entitled to preferenoe (specfly code 59mm).- CCF’ section 36(23) - Plaintifi BERTRAND i5 90 years old,
10. Allernaflva dispute msalution {ADR}
3. AD“ information package‘ Please note Ihat different ADR processes are available in different courts and communities;read
the ADR information package provided by the caurt under rule 3.221 for information about the processes availablethrough the
court and community programs in this case.
{1} Forparties represented by :ounsei: Counsel has El has not provided the ADP. informalion package identified
in rule 3.221to the client and reviewed ADR opfions with the ciient.
b.
(2} For self—represented parties: PartyE has I: has not reuiewecf the AER infnrmatiun package identified in rule 3.221.
Referral to judicial arbitration or civil action mediation (if available].
(1] |:I This matter is sub'ect to mandatory judicial arbitration under Code of Civil Procedure section
mediation under Procedure section
ode of Civil
1141.11 or to civil action
1??5.3 because the amount in controversy does not exceed the
matutory limit.
[2) |:] Plaintiff elects to refer this case [CI judicial arbitration and agrees to limit recovery to the amount specified in Code of
Ciuir Procedure seclion 1141.11.
{3) :I mediation under ode OT Ci'u'if Procedure section
ofthe Call'lornia Rules of Caurtor from civil action
This case is exemgt from judicial arbitration under rule 3.811
1??5 et SEQ. {special exemption);
WW "W W- =51"
CASE MANAGEMENT STATEMENT ”-5- = n' 5
CHI—11D
PLAlNTIFFa'PETITIONER: CASE Nb MEICR'
_ DAVID E3.BERTRAND. et al.
DEFENDANTIRESPONDENT: 1QCV02429
JESSICA BERRY
113.c. Indicate the ADR process or processes that the party or parties are willing Io participate in, have agreed to participate in. ur
have already participated in (check all that apply and provide fhe specified :‘rvfonnafionJ:
The party or parties completing ”the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already com plated an ADR process or processes.
padicipate in the following ADR indicate the status of the processes {attach a copy ofrhe pam‘es' ADR
processes (check all thatappfy}: gripuran'on):
Mediation session not yet scheduled
{1) Mediatinn III DUDE
Mediatinn session scheduled for [date]:
Agreed la complete madiation by (date):
Mediation compieted on (date):
Settlement conference not yet scheduled
(2} Settlement
con lerence
III DUDE] Settlement conference scheduled for (date).-
Agreed tn-oumplete settlement conference by {date}.-
Selflement conference compreted on {date}:
Neutrafl evaluation not yet scheduled
{3} Neutral evaluatinn I:| HEIDI]
Natural Evaluation scheduled for {date}.-
Agreed to complete neutral evaluation by (date):
Neutral evaluatiun completed on (date);
Judicial arbitralion not yet scheduled
(4] Nonbinding judicial
arbitration
El Judicial arbitration scheduled
IIIIJIIID
for [date]:
Agreed to completejudicial arbitration by (date):
Judicial arbitration completed on {date}:
Private arbilration not yet scheduled
(5} Binding private
arbitration
|:| Private arbitration scheduled for (date).-
Agreed to complete private arbitration by {date}.-
IIIIIIDD
F’rivate arbitralion completed on (data):
ADR session no! yet scheduled
{6) Other (specify); E HEIDI]
ADR session scheduled for (date):
Agreed to complete ADR Sessinn by (date):
ADR completed on {date}:
Lin-11039.:
July 1.2011; Page 3 ol' 5
CASE MANAGEMENT STATEMENT
0131:1111.
PLAINTIFFPETITIONEFE: CMSI: NLNHER.
DAVID G_ BERT—RAND, et Ell.
1QCVDZ429
r—DEFENDANTIRESPONDENT: JESSiCA BERRY
11. Insurance
a. I:! Insurance cam‘er. if any. for party filing this slaternenl (name):
b.
c. :I
Resemalion of rights: D Yes 1: No
Cuuerage issues will significantly affect resolution of this case (explain).-
12. Jurisdiction
If
Indicate any matmrs that may affect the court's jurisdiction
Stalus:
Bankruptcy |___| Other {specify}:
or processing of Ihis case and describe the status
13. Related cases. consolidation, and coordination
a. [II There are companion. under‘fying‘ or related cases.
[1] Name afcaS-E' DAVID G. BERTRAND, at al. V. JESSICA BERRY, at al.
{23 Name afeuurt: Santa Barbara Superior Court - Anacapa Division
{3) Case number 19¢V02429
b.
I:
I:|
{4) SIHTUS:
A molion
Discovery in progress; CMC set for 109812019
Additional cases are described in Attachment 133.
1:: CI consofidate l:l coordinate willhe fifed hymame pafly}:
14. Bifurcation
CI The party or parties intend to file a molion for an order bifurcating, severing. or coordinating the following issues or causes of
actron {specify moving party.J‘ype of motion.and reasons):
15.Other motlons
III The party or parties expect la fiie the following motions before triai (Spea'fy moving pany, type a! motion.
and r'ssuesJ.‘
Plaintiffs will file a motionfor default judgment.
16. Discovery
a. CI The party or parties have completed all discovery.
b. The follnwing discovery Will be completed by the date specified {deson'be all anticipated mason-reg»).-
Pam Descrigfion Date
Plaintiff Percipient Discovery Per Code
Praintifi Depositions Per Code
Plaintiff Record Subpoena to 3rd Parties Per Code
a. [:I The lollnwing discovery issues.
anticipated (anemia).-
including issues regarding the discovery of electntmicallyr stored information, are
[2M4 :RI'N Jllly 1. 2011|
1-3)
Page-4M5
CA3 E MANAG EM ENT STATE MENT
CHI-110
PLAINTIFFIPETITIONER: DAVID G. BERTRAND, et al. CASE ”WEE-"-
1QCVUZ42Q
DEFENDANTIRESPDNDENT: JESSICA BERRY
1?. Economic litigation
3. |_—_IThis is a limited civil case (i.e., the amount demanded
is. 325.0130 or less} and the economic litigation procedures in Code
of Civil Procedure sedians 90-98 will apply to this Case.
b.E] This is a limited civil case and
discovery wilt filed
a mation to withdraw the case from the economic Iitigalion procedures Cir for additional
be (i! checked.explain specificafly why economic litigation pmoedums relating to discovery or rn'ar
should nor apply m 1a case}:
18.
I:
Other issues
The party or parties request that the follcmring additional matters he considered or determined at the case management
conference {specifiws
19. Meet and confer
EL :1 The Daffy or parties have mel and conferred with all parties on all subjects required by rule 3.?24 of the Calflomia Rules.
of Court (if not.
explain).-
b- After meeting and 38 FEQUif‘Bd by rule 3.?24 UflhE California Rules of Court. the parties agree on the following
CUFIfBFTiHQ
(specifyi-
20. Tutal number of pages attached {Harry}.-
Iam completery familiarwith this case arm! will be full}.r prepared to discuss the status of discovery and altemative dispute resolution.
as well 35 other i55ues raised by this statement and will possess the authority to enter into simulations on these issues atthe time of
the case management conference. including the wn'Hen authority of the party where required.
Date: August 22. 2019
Mark T. Coffin, Attorney for PIaintifis
Mme]
:TYF‘E are PRINT
’ W/
Usfifi'fi‘fifié'mn OF: ATTORNEY]
II'WI:
OH PRINT MIME] (SIGNATURE OF FARM UHAfiDRNEfi
|:| Additional signatures are attached.
"WEIR” "'""2m“
"-
CASE MANAGEMENT STATEMENT Fmifli
PROOF OF SERVICE
m
STATE 01" CALIFORNIA, COUN'I‘Y OF SANTA BARBARA
"4.!
I am employed in the Count}; (3!" Santa Barbara, State Of California. I am over the age of IS
years and nut 21 party to this action. My business address is 2] E. Carrillo Sweat, Suite 240, Santa
Barbara, California 93101. 011 August 22, 2019, Iscrved the fbl'egoing documents described as
U- PLAINTIFFS’ CASE MANAGEMENT STATEMENT, on the interested parties in this action:
SEE. ATTACHED SERVICE LIST
BY US. MAIL: This document was served by United Sta’ras maik through the US Postal
w Service. I enclosed the document in
at the addressfles) above
a sealed envelope or package addressed to the pcrsun(s)
and placed the envelopefi) for collection and mafling, following our
ordinary business practices, I am readily familiar with this firm’s practioc nf‘colleuing and
pmcessing correspondence I'm mailing. On the same day that correspondencc is placed Fur
coilcclinn and mailing. it is deposited in the ordinary course nl‘husimtss With Th: United
States Postal Service at Santa Barbara, California, in a scaled Envelope with postage fully
paid.
El BY FACSIMILE: The documcnfis) were served by facsimile. The facsimile transmission
was without error and completed prior to 5:03 pm. A copy of the Transmission report is
available upon request.
Ci BY OVERNIGHT DELIVERY: The documcnfls] were served by overnight delivery via
()nTrac. T enclosed the document in a sealed envelope or package addressed to the pcrson(s)
and the addressfits) abovc and placed the envelopefs) for pick-up by UnTrac. I am readily
familiar with the firm’s practice of collection and processing corraspondcncc on the same day
with this courier service, for overnight delivery.
III VIA EMAIL: I sewed the documents; above on all parties via electronic mail, 10 the
addresses as listed on the attached service list,following my employer’s business practice For
mliucfinn and processing of corrcswndencc. Such electronic transmission was. reported as
complete and wilhuul cum on This date.
IE (State) ideclare under penaltyr of pcajury under the laws of the State of Calilbmia that the
foregoing true and correct.
is:
20
21 Executed on August 22, 2019. at Santa Barbara,
22
23 Garcia-1m
See I A.
24
26
27‘
28
' 6
PLM—NTIFFS‘ CASE MANAGEMENT STATFHFNT
SERVICE LIST
|_
I
Je'ssica Berry
PO. Box 54|
Address
Courtesy Copy mJE‘JSFCA
Pa rfy
BERRK mm
]
Santa Ynez, CA 93460
appearing Defendant.
24
25
26
2?
28
T
PLAJNTIFFS“ CASE Ii-‘IANAGEMEN'I' S'I'A'I'E MENT
Preview
ISM-110 M’CRNEY (Name. HTTORNEF {JR F'K-RTY WITHOUT" “was: same 5a: m3; E-IU FOR CDURI'USE DNL‘P' Mark T. Coffin [SB-N 1635?“ MARK T. COFFIN, P.C. ELECTRONICALLY LECTRONICALLY FILED 21 E. CarrilloSt, Suite 2413,Santa Barbara. CA 93101 Superior uperior Court of California 305—24831 '15 TELEPI mus: NO- 5»; N0rounonalj 305—567—4028 County ounty of Santa Barbara Fme nnnRFSS[am-Iw' mtc@markcoffinlaw.com Darrel arrel E. Parker, Executive Officer AIIUHNtY Hm [mm APPELLANT 8/22/2019 /22/2019 3:13 PM SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA 1100 Anacapa Street STREET HEZREES. By: E y: Terri Chavez, Deputy wh-ING HDI'MESS: ‘I100 An acapa Street COD“ CITY AND ZIP Santa Barbara 93101 HRANL‘H NAME. ANACAPA PLHINTIFFIF'ETITIONER: DAVID B. BERTRAND. et al. DEFENDANTJRESF‘ONDENT.‘ JESSICA BERRY CASE MANAGEMENT STATEMENT CASE NUMBER {Check one): UNLIMITED CASE {Amount demanded El LIMITED CASE (Amount demanded is $25,000 1QCV02429 exceeds 325,000] or less] A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: September 09, 2019 Time: 8:30 am. Dept; 5 Div; Room: Address of court {If dr'fi'erenf from the addmss above): |:I Notice of Intentto Appear by Telephone. by (name): FNSTRUCWONSi A" applicable bOXBB must be checked. and the specified information must be provided. 1. Party or parties (answer one]: a. This statement is submitted by party meme}.- Plaintiffs DAVID G. BERTRAND, et af. b. [:I This stalement is submitted jolntly by parties {names}: 2. Complaint and cross-compiaint {to be answered by plaintiffs and cmss-mmplamants only) a. The cumplaint was flied on (date): May 0?, 2019 In. CI The crass-cumplaint ifany, was filed on {date}: 3. Service (to be answered by plaintiffs and cmss—complamanrs 0:1n a. |:] Alf parties named in the complaint and cross-mplaint have been served. have appeared. or have been dismissed. in. E! The following parties named in the complaint or CrDSE-onrnplainl {1} El have not been served (specffir names and expfal'n why not): {2) D have been served but have not appeared and have not been dismissed (Specify names}: (3] have had a default entered against them {mdfil names}; JESSICA BERRY 0. CI The following additional parties be added (.309c}: names, may“r natune ofinvaivemenr in case, and date by which may may be served: Description of cage 3- Type 0f0359 In complaint |:| cross—complaint (Describe. including causes of actimu: The issues in the case involve Defendant BERRY and her iibel,defamation per se, intrusion, intentional infliction of emotional distress. unfair business practices. and elder abuse towards Plaintiffs. PageI of B ”'3323$.Déiflfififigifififli2“ CA5 E MANAGEM EN T STATE ME NT Bfiglzgzfiurgn CM-' ID |Htw. 20-1] J.';.-' 1. mw.cmr!:.c.:.g:w CHI-110 “SW-WW” _ PLAINTJFHPETITIONER: DAVID G. BERTRAND. et al. 19CV02429 DEFENDANTJRESF'DNDENT; JESSICA BERRY 4. h. Provide a brief statement of the case, including any damages. {persanah'njury damages am sougm, specific H15 r'njwy and damages claimed, including medical! expenses to dafe fi'ndr'care source and amount}, esfimated {amne- medical expenses, rust earnings in date.and estimated Mum (as! earnings. if ego-flame refiefis sought describe the nature of the refiei} Defendant made defamatory statements about both Plaintiffs. has accused Plaintiff of beinga "pimp", a "cn'rninar', and "rapist" among other things with the intent toharass and defame BERTRAND. Delendanl was unjustly enriched by unreimbursed payments and loans made by Plaintiff BERTRAND. [:l (Ifmore space is needed, check this box and attach a page designafed as Anacnmeni 4b.) 5. Jury or nonjury trial The party or parties rEquest noquesfing a jury mm}: a jury trialI: a nDnq triaJ. (Hmong than me party. provide me name of each party 5. Tria! date a. CI The trial has bean set for (dam); b. No Trial date has been set. This case will be read}.r for triaf within 12 months of the date of the filing of the Complaint (If not.explain): 6. Dates on which parties or attorneys will not be available for trial (specify dates and axpfar'n reasons for unavailability): 9:10—11r19 and 1Df11-1Bf19. T. Estimated Fength of trial The party ur parties esfimate that the trial will take (check oneJ: 5. III days (specfflr number): 4 b. 1:] hours(5hor1 causes] {specify}: 3. Trial representation (fa be answered for each party) The party or parfies will be represented at trial a. Attorney: IE by the attorney or pany listed in the caption |:I by the following: b. Firm: C. Address: {1. Telephone number: f_ Fax number: e E-mail address; |:| Additiunal represerflation is described in Attachment 8. 9. Pariy represented: El. Preference This case is entitled to preferenoe (specfly code 59mm).- CCF’ section 36(23) - Plaintifi BERTRAND i5 90 years old, 10. Allernaflva dispute msalution {ADR} 3. AD“ information package‘ Please note Ihat different ADR processes are available in different courts and communities;read the ADR information package provided by the caurt under rule 3.221 for information about the processes availablethrough the court and community programs in this case. {1} Forparties represented by :ounsei: Counsel has El has not provided the ADP. informalion package identified in rule 3.221to the client and reviewed ADR opfions with the ciient. b. (2} For self—represented parties: PartyE has I: has not reuiewecf the AER infnrmatiun package identified in rule 3.221. Referral to judicial arbitration or civil action mediation (if available]. (1] |:I This matter is sub'ect to mandatory judicial arbitration under Code of Civil Procedure section mediation under Procedure section ode of Civil 1141.11 or to civil action 1??5.3 because the amount in controversy does not exceed the matutory limit. [2) |:] Plaintiff elects to refer this case [CI judicial arbitration and agrees to limit recovery to the amount specified in Code of Ciuir Procedure seclion 1141.11. {3) :I mediation under ode OT Ci'u'if Procedure section ofthe Call'lornia Rules of Caurtor from civil action This case is exemgt from judicial arbitration under rule 3.811 1??5 et SEQ. {special exemption); WW "W W- =51" CASE MANAGEMENT STATEMENT ”-5- = n' 5 CHI—11D PLAlNTIFFa'PETITIONER: CASE Nb MEICR' _ DAVID E3.BERTRAND. et al. DEFENDANTIRESPONDENT: 1QCV02429 JESSICA BERRY 113.c. Indicate the ADR process or processes that the party or parties are willing Io participate in, have agreed to participate in. ur have already participated in (check all that apply and provide fhe specified :‘rvfonnafionJ: The party or parties completing ”the party or parties completing this form in the case have agreed to this form are willing to participate in or have already com plated an ADR process or processes. padicipate in the following ADR indicate the status of the processes {attach a copy ofrhe pam‘es' ADR processes (check all thatappfy}: gripuran'on): Mediation session not yet scheduled {1) Mediatinn III DUDE Mediatinn session scheduled for [date]: Agreed la complete madiation by (date): Mediation compieted on (date): Settlement conference not yet scheduled (2} Settlement con lerence III DUDE] Settlement conference scheduled for (date).- Agreed tn-oumplete settlement conference by {date}.- Selflement conference compreted on {date}: Neutrafl evaluation not yet scheduled {3} Neutral evaluatinn I:| HEIDI] Natural Evaluation scheduled for {date}.- Agreed to complete neutral evaluation by (date): Neutral evaluatiun completed on (date); Judicial arbitralion not yet scheduled (4] Nonbinding judicial arbitration El Judicial arbitration scheduled IIIIJIIID for [date]: Agreed to completejudicial arbitration by (date): Judicial arbitration completed on {date}: Private arbilration not yet scheduled (5} Binding private arbitration |:| Private arbitration scheduled for (date).- Agreed to complete private arbitration by {date}.- IIIIIIDD F’rivate arbitralion completed on (data): ADR session no! yet scheduled {6) Other (specify); E HEIDI] ADR session scheduled for (date): Agreed to complete ADR Sessinn by (date): ADR completed on {date}: Lin-11039.: July 1.2011; Page 3 ol' 5 CASE MANAGEMENT STATEMENT 0131:1111. PLAINTIFFPETITIONEFE: CMSI: NLNHER. DAVID G_ BERT—RAND, et Ell. 1QCVDZ429 r—DEFENDANTIRESPONDENT: JESSiCA BERRY 11. Insurance a. I:! Insurance cam‘er. if any. for party filing this slaternenl (name): b. c. :I Resemalion of rights: D Yes 1: No Cuuerage issues will significantly affect resolution of this case (explain).- 12. Jurisdiction If Indicate any matmrs that may affect the court's jurisdiction Stalus: Bankruptcy |___| Other {specify}: or processing of Ihis case and describe the status 13. Related cases. consolidation, and coordination a. [II There are companion. under‘fying‘ or related cases. [1] Name afcaS-E' DAVID G. BERTRAND, at al. V. JESSICA BERRY, at al. {23 Name afeuurt: Santa Barbara Superior Court - Anacapa Division {3) Case number 19¢V02429 b. I: I:| {4) SIHTUS: A molion Discovery in progress; CMC set for 109812019 Additional cases are described in Attachment 133. 1:: CI consofidate l:l coordinate willhe fifed hymame pafly}: 14. Bifurcation CI The party or parties intend to file a molion for an order bifurcating, severing. or coordinating the following issues or causes of actron {specify moving party.J‘ype of motion.and reasons): 15.Other motlons III The party or parties expect la fiie the following motions before triai (Spea'fy moving pany, type a! motion. and r'ssuesJ.‘ Plaintiffs will file a motionfor default judgment. 16. Discovery a. CI The party or parties have completed all discovery. b. The follnwing discovery Will be completed by the date specified {deson'be all anticipated mason-reg»).- Pam Descrigfion Date Plaintiff Percipient Discovery Per Code Praintifi Depositions Per Code Plaintiff Record Subpoena to 3rd Parties Per Code a. [:I The lollnwing discovery issues. anticipated (anemia).- including issues regarding the discovery of electntmicallyr stored information, are [2M4 :RI'N Jllly 1. 2011| 1-3) Page-4M5 CA3 E MANAG EM ENT STATE MENT CHI-110 PLAINTIFFIPETITIONER: DAVID G. BERTRAND, et al. CASE ”WEE-"- 1QCVUZ42Q DEFENDANTIRESPDNDENT: JESSICA BERRY 1?. Economic litigation 3. |_—_IThis is a limited civil case (i.e., the amount demanded is. 325.0130 or less} and the economic litigation procedures in Code of Civil Procedure sedians 90-98 will apply to this Case. b.E] This is a limited civil case and discovery wilt filed a mation to withdraw the case from the economic Iitigalion procedures Cir for additional be (i! checked.explain specificafly why economic litigation pmoedums relating to discovery or rn'ar should nor apply m 1a case}: 18. I: Other issues The party or parties request that the follcmring additional matters he considered or determined at the case management conference {specifiws 19. Meet and confer EL :1 The Daffy or parties have mel and conferred with all parties on all subjects required by rule 3.?24 of the Calflomia Rules. of Court (if not. explain).- b- After meeting and 38 FEQUif‘Bd by rule 3.?24 UflhE California Rules of Court. the parties agree on the following CUFIfBFTiHQ (specifyi- 20. Tutal number of pages attached {Harry}.- Iam completery familiarwith this case arm! will be full}.r prepared to discuss the status of discovery and altemative dispute resolution. as well 35 other i55ues raised by this statement and will possess the authority to enter into simulations on these issues atthe time of the case management conference. including the wn'Hen authority of the party where required. Date: August 22. 2019 Mark T. Coffin, Attorney for PIaintifis Mme] :TYF‘E are PRINT ’ W/ Usfifi'fi‘fifié'mn OF: ATTORNEY] II'WI: OH PRINT MIME] (SIGNATURE OF FARM UHAfiDRNEfi |:| Additional signatures are attached. "WEIR” "'""2m“ "- CASE MANAGEMENT STATEMENT Fmifli PROOF OF SERVICE m STATE 01" CALIFORNIA, COUN'I‘Y OF SANTA BARBARA "4.! I am employed in the Count}; (3!" Santa Barbara, State Of California. I am over the age of IS years and nut 21 party to this action. My business address is 2] E. Carrillo Sweat, Suite 240, Santa Barbara, California 93101. 011 August 22, 2019, Iscrved the fbl'egoing documents described as U- PLAINTIFFS’ CASE MANAGEMENT STATEMENT, on the interested parties in this action: SEE. ATTACHED SERVICE LIST BY US. MAIL: This document was served by United Sta’ras maik through the US Postal w Service. I enclosed the document in at the addressfles) above a sealed envelope or package addressed to the pcrsun(s) and placed the envelopefi) for collection and mafling, following our ordinary business practices, I am readily familiar with this firm’s practioc nf‘colleuing and pmcessing correspondence I'm mailing. On the same day that correspondencc is placed Fur coilcclinn and mailing. it is deposited in the ordinary course nl‘husimtss With Th: United States Postal Service at Santa Barbara, California, in a scaled Envelope with postage fully paid. El BY FACSIMILE: The documcnfis) were served by facsimile. The facsimile transmission was without error and completed prior to 5:03 pm. A copy of the Transmission report is available upon request. Ci BY OVERNIGHT DELIVERY: The documcnfls] were served by overnight delivery via ()nTrac. T enclosed the document in a sealed envelope or package addressed to the pcrson(s) and the addressfits) abovc and placed the envelopefs) for pick-up by UnTrac. I am readily familiar with the firm’s practice of collection and processing corraspondcncc on the same day with this courier service, for overnight delivery. III VIA EMAIL: I sewed the documents; above on all parties via electronic mail, 10 the addresses as listed on the attached service list,following my employer’s business practice For mliucfinn and processing of corrcswndencc. Such electronic transmission was. reported as complete and wilhuul cum on This date. IE (State) ideclare under penaltyr of pcajury under the laws of the State of Calilbmia that the foregoing true and correct. is: 20 21 Executed on August 22, 2019. at Santa Barbara, 22 23 Garcia-1m See I A. 24 26 27‘ 28 ' 6 PLM—NTIFFS‘ CASE MANAGEMENT STATFHFNT SERVICE LIST |_ I Je'ssica Berry PO. Box 54| Address Courtesy Copy mJE‘JSFCA Pa rfy BERRK mm ] Santa Ynez, CA 93460 appearing Defendant. 24 25 26 2? 28 T PLAJNTIFFS“ CASE Ii-‘IANAGEMEN'I' S'I'A'I'E MENT