Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 07/24/2019 11:37 AM Sherri R. Carter, Executive Officer/Clerk of Court, by E. Gregg, Deputy Clerk
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Tracey A. Kennedy (150782), Ruben D. Escalante (244596) Natasha L. Domek
(314589)
Sheppard, Mullin, Richter& Hampton LLP
333 South Hope Street, 43rd Floor
Los Angeles, CA 90071
TeLerHone no.: (213) 620-1780 FAX NO. (Optional): (213) 620-1398
E-MAIL ADDRESS (Optional): Ndomek@ sheppardmullin.com
ATTORNEY FOR (Name): Defendant Molina Healthcare, Inc.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles
street aopress: 111 North Hill Street
MAILING ADDRESS:
city ano zip cove: Los Angeles, California 90012
BRANCH NAME: Stanley Mosk Courthouse
PLAINTIFF/PETITIONER: Elizabeth Flores
DEFENDANT/RESPONDENT: Molina Healthcare, Inc.
CASE MANAGEMENT STATEMENT CASE NUMBER.
19STCV10187
(Check one): X UNLIMITED CASE Oo LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: August 9, 2019 Time: 8:30 a.m. Dept.: 42 Div. Room:
Address of court (if different from the address above):
oO Notice of Intent to Appear by Telephone, by (name):
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a 1 This statement is submitted by party (name): Defendant Molina Healthcare, Inc.
b, (1 This statement is submitted jointly by parties (names):
Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a The complaint was filed on (date):
b, (The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
a (1 Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b, (1 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) [shave had a default entered against them (specify names):
c (1 The following additional parties may be added (specify names, nature of involvement in case, and date by which they
may be served):
Description of case
a Type of casein DX] complaint 1 cross-complaint (Describe, including causes of action):
(1) disability discrimination; (2) FEHA retaliation; (3) failure to accommodate; (4) failure to engage in interactive
process; (5) failure to prevent discrimination; (6) violation of CFRA; (7) violation of WARN Act; (8) wrongful
termination; (9) breach of implied contract; and (10) unfair business practices.
Page Lof5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California rules 3.720-3.730
CM-110 [Rev. J uly 1, 2011] www.courts.ca.gov
rican Li
yw.FonmsWi
CM-110
PLAINTIFF/PETITIONER: Elizabeth Flores CASE NUMBER
19STCV10187
| DEFENDANT/RESPONDENT: Defendant Molina Healthcare, Inc.
4 b. 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, describe the nature of the relief.)
Plaintiff is a former employee who alleges she was discriminated against on the basis of her disability. Plaintiff alleges
Defendant failed to engage in the interactive process and failed to accommodate her alleged disability. Plaintiff also
alleges she was wrongfully terminated and retaliated against for taking a medical leave of absence. She further alleges
that Defendant violated the WARN Act and engaged in unfair business practices. Plaintiff seeks compensatory damages,
injunctive relief, pre-judgment and post-judgment interest, punitive damages, restitution, attorneys' fees, and costs of suit.
Defendant denies all of Plaintiff's material allegations and denies itis liable to Plaintiff for any amount whatsoever.
Plaintiff was terminated because her position was eliminated for legitimate business reasons.
Oo (If more space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request Oo ajury trial & a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a (1 The trial has been set for (date):
b. Xl 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):
See attachment.
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a & days (specify number): 5-7
b. O hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial X by the attorney or party listed in the caption [1 by the following:
a Attorney:
b. Firm:
c Address:
d. Telephone number: f. Fax number:
e E-mail address: g. Party represented:
Oo Additional representation is described in Attachment 8.
Preference
Oo 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 [1 has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) [1] This matter is subject to mandatory judicial arbitration under Code of 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
statutory limit.
20 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) Xl 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
CW-110 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 0f5
American LegalNet, Inc.
www FormsWorkFlow cor
CM-110
PLAINTIFF/PETITIONER: Elizabeth Flores CASE NUMBER.
19STCV10187
DEFENDANT/RESPONDENT: Defendant Molina Healthcare, Inc.
10. ¢ 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):
Oo Mediation session not yet scheduled
Oo Mediation session scheduled for (date):
(1) Mediation
Oo Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
Settlement conference scheduled for (date):
(2) Settlement
conference
Agreed to complete settlement conference by (date) :
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
J udicial arbitration not yet scheduled
J udicial arbitration scheduled for (date):
(4) Nonbinding judicial
arbitration
Agreed to complete judicial arbitration by (date):
J udicial 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 MANAGEMENT STATEMENT Page 3 0f5
CM-110
i PLAINTIFF /PETITIONER: Elizabeth Flores CASE NUMBER
19STCV10187
EF ENDANT/RESPONDENT: Defendant Molina Healthcare, Inc.
11. Insurance
a O Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: 0 Yes 0 No
c. [J 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.
(1 Bankruptcy [J Other (specify):
Status:
13. Related cases, consolidation, and coordination
a (1 There are companion, underlying, or related cases
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
(1 Additional cases are described in Attachment 13a
b. [1 A motion to Oo consolidate Oo coordinate will be filed by (name party):
14 Bifurcation
(1 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
X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Discovery motions, motion for summary judgment/adjudication, motions in limine
16. Discovery
a (1 The party or parties have completed all discovery.
b The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Descriptio Date
Defendant Molina Healthcare, Inc Plaintiff 's deposition December 2019
Defendant Molina Healthcare, Inc Written discovery February 2020
Defendant Molina Healthcare, Inc Third party depositions February 2020
Defendant Molina Healthcare, Inc Expert witness depositions March 2020
c XX The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
The parties must meet and confer regarding entering into a protective order, before confidential documents
may be produced pursuant
to discovery.
CW-110 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 40f5
merican Li INet,
www FomsWorkFo
CM-110
PLAINTIFF /PETITIONER: Elizabeth Flores CASE NUMBER
19STCV10187
| DEFENDANT/RESPONDENT: Defendant Molina Healthcare, Inc.
17. Economic litigation
a LF 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, 1 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
[1 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 KI 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): 1
| 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:J uly 24, 2019
Natasha L. Domek
(TYPE OR PRINT NAME)
VedOwk
(SIGNATURE OF PARTY OR ATTORNEY)
»
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
C1 Additional signatures are attached
Cw-110 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 0f5
‘American LegalNet, nc
www. nko
Attachment 6c
08/02-08/20/2019 Trial
09/16-09/22/2019 Trial
09/23-09/27/2019 Arbitration
10/09-11/08/2019 Trial
11/18-11/28/2019 Trial
12/10-12/12/2019 Arbitration
01/27-02/14/2020 Trial
02/18-02/25/2020 Trial
03/03-03/20/2020 Trial
04/13-04/17/2020 Trial
05/05-05/12/2020 Trial
06/15-06/24/2020 Trial
7104-07/25/2020 Vacation
10/26-11/4/2020 Trial
01/12-01/14/2021 Arbitration
SMRH:4849-8947-2157.1 1
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
ELIZABETH FLORES. vs. MOLINA HEALTHCARE, INC.
Case No. 19STCV10187
At the time of service, I was over 18 years of age and not a party to this action. |
am employed in the County of Los Angeles, State of California. My business address is
333 South Hope Street, 43rd Floor, Los Angeles, CA 90071-1422.
On July 24, 2019, I served true copies of the following document(s) described as
CASE MANAGEMENT STATEMEN' on the interested parties in this action as follows
= <
Benjamin Davidson, Esq. laintiff’s counsel
teven M. Cischke, Esq.
|LAW OFFICES OF BENJAMIN DAVIDSON. P.C.
{8383 Wilshire Boulevard, Suite 830
10 Beverly Hills, CA 90211
ll
E-mail: bdavidson@bendavidsonlaw.com
12 E-mail: scischke@bendavidsonlaw.com
I: (323) 713-0010
13 F: (323) 488-6888
|
14 |
|
15 BY MAIL: I enclosed the document(s) in a sealed envelope or package address aa
to the persons at the addresses listed in the Service List and placed the envelope for
16 collection and mailing, following our ordinary business practices. I am readil familiar
with the firm's practice for collecting and processing correspondence for mailing. On the
17 same day that correspondence is placed for collection and mailing, it is deposited in the
ordinary course of business with the United States Postal Service. in a sealed envelope with
18 postage fully prepaid. I am a resident or employed in the county where the mailing
occurred.
19
I declare under penalty of perjury under the laws of the State of California that the
20 foregoing is true and correct.
21 Executed on July 24, 2019, at Los Angeles, California.
22
23
——
24 MA NNE GONZAL
25
26
27
28
SMRH:4833-7013-9799.1
File No: 29SE-296117
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 07/24/2019 11:37 AM Sherri R. Carter, Executive Officer/Clerk of Court, by E. Gregg, Deputy Clerk CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Tracey A. Kennedy (150782), Ruben D. Escalante (244596) Natasha L. Domek (314589) Sheppard, Mullin, Richter& Hampton LLP 333 South Hope Street, 43rd Floor Los Angeles, CA 90071 TeLerHone no.: (213) 620-1780 FAX NO. (Optional): (213) 620-1398 E-MAIL ADDRESS (Optional): Ndomek@ sheppardmullin.com ATTORNEY FOR (Name): Defendant Molina Healthcare, Inc. SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles street aopress: 111 North Hill Street MAILING ADDRESS: city ano zip cove: Los Angeles, California 90012 BRANCH NAME: Stanley Mosk Courthouse PLAINTIFF/PETITIONER: Elizabeth Flores DEFENDANT/RESPONDENT: Molina Healthcare, Inc. CASE MANAGEMENT STATEMENT CASE NUMBER. 19STCV10187 (Check one): X UNLIMITED CASE Oo LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: August 9, 2019 Time: 8:30 a.m. Dept.: 42 Div. Room: Address of court (if different from the address above): oO Notice of Intent to Appear by Telephone, by (name): INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a 1 This statement is submitted by party (name): Defendant Molina Healthcare, Inc. b, (1 This statement is submitted jointly by parties (names): Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a The complaint was filed on (date): b, (The cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) a (1 Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b, (1 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) [shave had a default entered against them (specify names): c (1 The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): Description of case a Type of casein DX] complaint 1 cross-complaint (Describe, including causes of action): (1) disability discrimination; (2) FEHA retaliation; (3) failure to accommodate; (4) failure to engage in interactive process; (5) failure to prevent discrimination; (6) violation of CFRA; (7) violation of WARN Act; (8) wrongful termination; (9) breach of implied contract; and (10) unfair business practices. Page Lof5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California rules 3.720-3.730 CM-110 [Rev. J uly 1, 2011] www.courts.ca.gov rican Li yw.FonmsWi CM-110 PLAINTIFF/PETITIONER: Elizabeth Flores CASE NUMBER 19STCV10187 | DEFENDANT/RESPONDENT: Defendant Molina Healthcare, Inc. 4 b. 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, describe the nature of the relief.) Plaintiff is a former employee who alleges she was discriminated against on the basis of her disability. Plaintiff alleges Defendant failed to engage in the interactive process and failed to accommodate her alleged disability. Plaintiff also alleges she was wrongfully terminated and retaliated against for taking a medical leave of absence. She further alleges that Defendant violated the WARN Act and engaged in unfair business practices. Plaintiff seeks compensatory damages, injunctive relief, pre-judgment and post-judgment interest, punitive damages, restitution, attorneys' fees, and costs of suit. Defendant denies all of Plaintiff's material allegations and denies itis liable to Plaintiff for any amount whatsoever. Plaintiff was terminated because her position was eliminated for legitimate business reasons. Oo (If more space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request Oo ajury trial & a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a (1 The trial has been set for (date): b. Xl 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): See attachment. Estimated length of trial The party or parties estimate that the trial will take (check one): a & days (specify number): 5-7 b. O hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial X by the attorney or party listed in the caption [1 by the following: a Attorney: b. Firm: c Address: d. Telephone number: f. Fax number: e E-mail address: g. Party represented: Oo Additional representation is described in Attachment 8. Preference Oo 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 [1 has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) [1] This matter is subject to mandatory judicial arbitration under Code of 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 statutory limit. 20 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) Xl 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 CW-110 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 0f5 American LegalNet, Inc. www FormsWorkFlow cor CM-110 PLAINTIFF/PETITIONER: Elizabeth Flores CASE NUMBER. 19STCV10187 DEFENDANT/RESPONDENT: Defendant Molina Healthcare, Inc. 10. ¢ 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): Oo Mediation session not yet scheduled Oo Mediation session scheduled for (date): (1) Mediation Oo Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled Settlement conference scheduled for (date): (2) Settlement conference Agreed to complete settlement conference by (date) : Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): J udicial arbitration not yet scheduled J udicial arbitration scheduled for (date): (4) Nonbinding judicial arbitration Agreed to complete judicial arbitration by (date): J udicial 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 MANAGEMENT STATEMENT Page 3 0f5 CM-110 i PLAINTIFF /PETITIONER: Elizabeth Flores CASE NUMBER 19STCV10187 EF ENDANT/RESPONDENT: Defendant Molina Healthcare, Inc. 11. Insurance a O Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: 0 Yes 0 No c. [J 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. (1 Bankruptcy [J Other (specify): Status: 13. Related cases, consolidation, and coordination a (1 There are companion, underlying, or related cases (1) Name of case: (2) Name of court: (3) Case number: (4) Status: (1 Additional cases are described in Attachment 13a b. [1 A motion to Oo consolidate Oo coordinate will be filed by (name party): 14 Bifurcation (1 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 X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Discovery motions, motion for summary judgment/adjudication, motions in limine 16. Discovery a (1 The party or parties have completed all discovery. b The following discovery will be completed by the date specified (describe all anticipated discovery): Party Descriptio Date Defendant Molina Healthcare, Inc Plaintiff 's deposition December 2019 Defendant Molina Healthcare, Inc Written discovery February 2020 Defendant Molina Healthcare, Inc Third party depositions February 2020 Defendant Molina Healthcare, Inc Expert witness depositions March 2020 c XX The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): The parties must meet and confer regarding entering into a protective order, before confidential documents may be produced pursuant to discovery. CW-110 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 40f5 merican Li INet, www FomsWorkFo CM-110 PLAINTIFF /PETITIONER: Elizabeth Flores CASE NUMBER 19STCV10187 | DEFENDANT/RESPONDENT: Defendant Molina Healthcare, Inc. 17. Economic litigation a LF 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, 1 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 [1 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 KI 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): 1 | 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:J uly 24, 2019 Natasha L. Domek (TYPE OR PRINT NAME) VedOwk (SIGNATURE OF PARTY OR ATTORNEY) » (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) C1 Additional signatures are attached Cw-110 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 0f5 ‘American LegalNet, nc www. nko Attachment 6c 08/02-08/20/2019 Trial 09/16-09/22/2019 Trial 09/23-09/27/2019 Arbitration 10/09-11/08/2019 Trial 11/18-11/28/2019 Trial 12/10-12/12/2019 Arbitration 01/27-02/14/2020 Trial 02/18-02/25/2020 Trial 03/03-03/20/2020 Trial 04/13-04/17/2020 Trial 05/05-05/12/2020 Trial 06/15-06/24/2020 Trial 7104-07/25/2020 Vacation 10/26-11/4/2020 Trial 01/12-01/14/2021 Arbitration SMRH:4849-8947-2157.1 1 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES ELIZABETH FLORES. vs. MOLINA HEALTHCARE, INC. Case No. 19STCV10187 At the time of service, I was over 18 years of age and not a party to this action. | am employed in the County of Los Angeles, State of California. My business address is 333 South Hope Street, 43rd Floor, Los Angeles, CA 90071-1422. On July 24, 2019, I served true copies of the following document(s) described as CASE MANAGEMENT STATEMEN' on the interested parties in this action as follows = < Benjamin Davidson, Esq. laintiff’s counsel teven M. Cischke, Esq. |LAW OFFICES OF BENJAMIN DAVIDSON. P.C. {8383 Wilshire Boulevard, Suite 830 10 Beverly Hills, CA 90211 ll E-mail: bdavidson@bendavidsonlaw.com 12 E-mail: scischke@bendavidsonlaw.com I: (323) 713-0010 13 F: (323) 488-6888 | 14 | | 15 BY MAIL: I enclosed the document(s) in a sealed envelope or package address aa to the persons at the addresses listed in the Service List and placed the envelope for 16 collection and mailing, following our ordinary business practices. I am readil familiar with the firm's practice for collecting and processing correspondence for mailing. On the 17 same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service. in a sealed envelope with 18 postage fully prepaid. I am a resident or employed in the county where the mailing occurred. 19 I declare under penalty of perjury under the laws of the State of California that the 20 foregoing is true and correct. 21 Executed on July 24, 2019, at Los Angeles, California. 22 23 —— 24 MA NNE GONZAL 25 26 27 28 SMRH:4833-7013-9799.1 File No: 29SE-296117