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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
JOHN R. RYDELL II 62606
GRIFFITH & THORNBURGH, LLP
8 East Figueroa Street, Suite 300
Santa Barbara, CA 93101 ELECTRONICALLY FILED
TELEPHONE NO.: 805-965-5131 805-965-6751
FAX NO. (Optional):
Superior Court of California
E-MAIL ADDRESS (Optional): rydell@g-tlaw.com
County of Santa Barbara
ATTORNEY FOR (Name): Plaintiffs Darrel E. Parker, Executive Officer
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA 11/19/2021 1:36 PM
STREET ADDRESS:1100 ANACAPA STREETAnacapa Street By: Sarah Sisto, Deputy
POST OFFICE BOX 21107
MAILING ADDRESS:
SANTA BARBARA, 93121-1107
CITY AND ZIP CODE:
BRANCH NAME:ANACAPA DIVISION
PLAINTIFF/PETITIONER: Tine F. Sloan; Michael Corrigan
DEFENDANT/RESPONDENT: Michelle Ann Beltran Sell
CASE MANAGEMENT STATEMENT CASE NUMBER:
20CV01530
(Check one): UNLIMITED CASE LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 12/3/21 Time: 8:30 a.m. Dept.: 4 Div.: Room:
Address of court (if different from the address above):
Notice 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):
b. This statement is submitted jointly by parties (names): Tine F. Sloan; Michael Corrigan
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): 3/24/20
b. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. 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):
c. The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of case in complaint cross-complaint (Describe, including causes of action):
Complaint for Private Nuisance; Invasion of Privacy;
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California
CASE MANAGEMENT STATEMENT rules 3.720–3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
American LegalNet, Inc.
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CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Tine F. Sloan; Michael Corrigan
20CV01530
DEFENDANT/RESPONDENT: Michelle Ann Beltran Sell
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.)
Defendant takes video and sound recordings of private conversations between Plaintiffs when Plaintiffs are in the
privacy of their property. Defendant's conduct is an invasion of Plaintiffs' privacy and is a nuisance that obstructs
and interferes with Plaintiffs' free use and enjoyment of their property. Plaintiffs seek a permanent injunction to
prevent further audio and visual recording, a fine not less than $5k and not more than $50k, exemplary damages,
cost of suit, attorneys' fees, and other relief as the Court find appropriate.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request a jury triaI a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. The trial has been set for (date):
b. 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):
October 1, 2021 (Settlement Conference in another matter); October 26, 2021 (Trial in another matter)
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number):
b. hours (short causes) (specify): 5 hours
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
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 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):
CM-110 [Rev. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Tine F. Sloan; Michael Corrigan
20CV01530
DEFENDANT/RESPONDENT: Michelle Ann Beltran Sell
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date) :
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
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] Page 3 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Tine F. Sloan; Michael Corrigan
20CV01530
DEFENDANT/RESPONDENT: Michelle Ann Beltran Sell
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes No
c. Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
Bankruptcy Other (specify):
Status:
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:
(4) Status:
Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate wiII be 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. The party or parties have completed all discovery.
b The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiffs Deposition of Defendant Dec 2021
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011] Page 4 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Tine F. Sloan; Michael Corrigan
20CV01530
DEFENDANT/RESPONDENT: Michelle Ann Beltran Sell
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):
I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: November 19, 2021
Austin S. Payne _______________________________________
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev. July 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
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PROOF OF SERVICE
I am employed in the County of Santa Barbara, State of California. I am over the age of 18
and am not a party to the within action; my business address is 8 East Figueroa Street, Suite 300,
Santa Barbara, California 93101-2762; my business email address is schneider@g-tlaw.com.
On November 19, 2021, I served the foregoing document described as PLAINTIFF’S
CASE MANAGEMENT STATEMENT on interested parties in this action as follows:
Russell A. Brown
Law Office of Russell A. Brown
924 Anacapa Street, Suite 1-T
Santa Barbara, CA 93101
Email: rablaw805@gmail.com
BY MAIL: by placing the original a true copy thereof enclosed in sealed envelopes
addressed as shown above or on the attached service list. I am “readily familiar” with the
firm’s practice of collection and processing correspondence for mailing. Under that practice
it would be deposited with the U.S. postal service on that same day with postage thereon
fully prepaid at Santa Barbara, California, in the ordinary course of business. I am aware
that on motion of the party served, service is presumed invalid if postal cancellation date or
postage meter date is more than one day after date of deposit for mailing in affidavit.
BY OVERNIGHT COURIER: I enclosed the documents in an envelope or package
provided by an overnight delivery carrier and addressed to the persons at the addresses listed
above or on the attached service list. I placed the envelope or package for collection and
overnight delivery at an office or a regularly utilized drop box of the overnight delivery
carrier.
BY FACSIMILE: I caused to be transmitted the document described herein via the fax
number listed above or on the attached service list. Upon completion of said facsimile
transmission, the transmitting machine issued a transmission report showing the transmission
was complete and without error.
BY PERSONAL SERVICE: I delivered said document by hand to the addressee listed
above or on the attached service list.
BY E-MAIL (Pursuant to CCR 2.251 and CCP 1010.6): I caused the document to be sent
electronically to the person at the e-mail address listed above or on the attached service list.
I did not receive, within a reasonable time after the transmission, any electronic message or
other indication that the transmission was unsuccessful.
BY ELECTRONIC FILING SERVICE PROVIDER (EFSP) (Pursuant to CCR 2.251 and
CCP 1010.6): I am readily familiar with the firm’s practice for filing electronically. I
caused e-service notification to be electronically sent through the certified, court approved
EFSP, to the address which was listed as the designated service contact on the EFSP.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed on November 19, 2021, at Santa Barbara, California.
Soroth Schneider