Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Bar number, end address):
Fos coURr USE ONLY
Harvey L, Ztff/Adrienne Z. Cohn (41204/223711)
Ziff & Cohn
4962 El Camino Real, Suite 126
Los Altos, CA 94022
TELEPHONE NOJ (650) 329-0851 (650) 691-9040
FAx No. (Cpgonasf
E.MAIL ADDRESS (Optionesf
SCOtt
ATTORNEY FOR (Name/r Caaaa
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO
7/29/2021
sTREETADDREss:400 County Center
MAILING ADDRESB
Redwood City, CA 94063
clTY AND zip coDE:
BRANCtl
NAME,'LAINTIFF/PETITIONER:
Scott Cagas
DEFENDANT/RESPONDENT: Alexis Ramog, Allison Aciis-Grands and Does 1-20
CASE MANAGEMENT STATEMENT
(Checlr one): Cx] UNLIMITED CASE
(Amount demanded
~ LIMITED CASE
(Amount demanded is $ 25,000
CASE NUMBER:
21-CIV-02 I 92
exceeds $ 25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 8/1 6/2021 Time: 9:00am Dept.: 2 Divz Room;
34
Address of court (if di/ferent from the address above):
1050 Mission Road, South San Francisco, CA 94080
~x Notice of Intent to Appear by Telephone, by (name): Harvey L Ziff
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. ~x This statement is submitted by party (name): Scott Casas
2.
b, ~ This statement is submitted Jointly by parties(names):
Complaint and cross-complaint ((o be answered by plaintiffs and cross-comp/ainanis only)
a. The complaint was filed on (dale):April 15, 2021
3.
b, ~ The cross-complaint, if any, was filed on(date):
Service (to be answered by plaintiffs and cross-comp/ainan/s on/y)
a.
b. ~
~x All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
The following parties named in the complaint or cross-complaint
(1) ~ have not been served (speciiy 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 (speciiy names):
c. ~ The following additional parties may be added (specify names, na/ure of involvement in case, and date by which
they may be served):
4. Description of case
a, Type of case in ~x complaint
Auto accident, personal injury
~ cross-complaint (Describe, inc/uding causes of action):
Page1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court.
Judicial Council of Caltfomia
CASE MANAGEMENT STATEMENT rules 3.720-3.730
CM-1 10 [Rev. July 1, 2011] wwacourts.ce.gov
CM-110
PLAINTIFF/PETITIONER: Scott Casas CASE NUMBER:
DEFENDANT/RESPONDENT: Alexis Rsmos, Allison Actig-Grands and Does 1-20 21-CIV-02102
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 Io date, and estimated future lost earnings. If equitable re/iefis sought, describe the nature of the relief)
This case involved a auto accident resulting in injuries.
~ (If more space is needed, check this box and elfach a page designated as Attachment 4b.)
Jury or nonjury trial
a. The party or parties request
requesting e jury trial):
~ a jury trial ~x a nonjury trial.(If more than one party, provide the name of each party
Trial date
a.
b.
~
~x
Thetrialhasbeensetfor (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 unavsiisbi7ity):
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. ~x days (specify nufnber: 3
b C3 hours (short causes) (specify):
Trial representation (Io be answered for each party)
The party or parties will be represented at trial
a. Attorney:
~x 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 described
Preference
inAttachment S.
g.
~ 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
(2) For self-represented parties; Party~ ~
in rule 3.221 to the client and reviewed ADR options with the client.
has hes not reviewed the ADR information package identified in rule 3.221.
b.
(1)~
Referral to judicial arbitration or civil action mediation (if available).
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
(2)~ statutory limit.
Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
(3)~ Civil Procedure section 1141.11.
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 IRev. Jely1,2011I Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER; Scott Casse CASE NUMBER:
DEFENDANT/RESPONDENT: Alexis Remos, Allison Actis-Grande end Doss 1-20 21-CIV-02192
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'DR
processes (check all that apply); stipulation):
~x Mediation session not yet scheduled
(1) Mediation
~
~
Mediation session scheduled for (date):
Agreed to complete mediation by (dale):
~ Mediation completed on (date)r
~
~ 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
(3) Neutral evaluation
~
~
(date):
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (dale):
~
~ Judicial arbitration not yet scheduled
Judicial arbitration scheduled for
(date):
(4) Nonbinding judicial
arbitration ~
~ Agreed to complete judicial arbitration by
Judicial arbitration completed on (dale):
(dale):
~
~ Private arbitration not yet scheduled
Private arbitration scheduled for
(5) Binding private
arbitration ~
~
(data):
Agreed to complete private arbitration by
Private arbitration completed on (date)r
(date):
~
~ ADR session not yet scheduled
ADR session scheduled for
(6) Other (specify):
~
~
(dale):
Agreed to complete ADR session by (dale):
ADR completed on (date):
CM-110 [Ref. Juir 1, 2011I Pege 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER; Scott Cssas CASE NUMBER;
DEFENDANT/RESPONDENT: Alexis Ramno, Allison Actis-Grands snd Does 1-20 21-C IV-02192
11.Insurance
a.
b.
~ Insurance carrier,
Reservationofrights: ~
ifany, for party filing this statement (name):
Yes ~ No
c. ~ Coverage issues will significantly affect resolution ofthis case
(explain):
12. Jurisdiction
~ Bankruptcy
Status:
~
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
Other (specify)J
13.
a. ~
Related cases, consolidation, and coordination
There are companion, underlying, or related cases.
(1) Nameofcase:
(2) Nameofcourt:
(3) Case number:
Status:
~ (4)
Additionalcases are described in Attachment 13a.
b. ~ A motion to ~ consolidate ~ coordinate will 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
~ (specify moving party, type of motion, and issues):
The party or parties expect to file the following motions before trial
16. Discovery
a.
b.
~
~ The party or parties have completed all discovery.
The following discovery will be completed by the date specified (describe aii anticipated discovery):
~Part Descriotion ~Da e
Plaintiff Defendant Deposition October 2021
c. ~ The following discovery Issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM.110 (Rey. July 1, 201 1 I Peaeeefs
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER) Scott Casse CASE NUMBER;
DEFENDANT/RESPONDENT: Alexis Ramos, Allison Act(s-Grande snd Does 1-20 21-CIV-02192
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
of Civil Procedure sections 90-98 will apply to this case.
inCode
t).~ This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
(if checked, explain specifically why economic litigation procedures relating io discovery or trial
discovery will be filed
should nof app/y fo 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. ~x 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 noi, 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):
Iam completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as weil 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.
July29,2021
C~)fj~
Date:
Adrienne Z. Cohn
(TYPE OR PRINT NAME)
i (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
~ Additional signatures are attached.
OM-110 [Rev Jolr I, 2011) Page 5 of 5
CASE MANAGEMENT STATEMENT
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Bar number, end address): Fos coURr USE ONLY Harvey L, Ztff/Adrienne Z. Cohn (41204/223711) Ziff & Cohn 4962 El Camino Real, Suite 126 Los Altos, CA 94022 TELEPHONE NOJ (650) 329-0851 (650) 691-9040 FAx No. (Cpgonasf E.MAIL ADDRESS (Optionesf SCOtt ATTORNEY FOR (Name/r Caaaa SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO 7/29/2021 sTREETADDREss:400 County Center MAILING ADDRESB Redwood City, CA 94063 clTY AND zip coDE: BRANCtl NAME,'LAINTIFF/PETITIONER: Scott Cagas DEFENDANT/RESPONDENT: Alexis Ramog, Allison Aciis-Grands and Does 1-20 CASE MANAGEMENT STATEMENT (Checlr one): Cx] UNLIMITED CASE (Amount demanded ~ LIMITED CASE (Amount demanded is $ 25,000 CASE NUMBER: 21-CIV-02 I 92 exceeds $ 25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 8/1 6/2021 Time: 9:00am Dept.: 2 Divz Room; 34 Address of court (if di/ferent from the address above): 1050 Mission Road, South San Francisco, CA 94080 ~x Notice of Intent to Appear by Telephone, by (name): Harvey L Ziff INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. ~x This statement is submitted by party (name): Scott Casas 2. b, ~ This statement is submitted Jointly by parties(names): Complaint and cross-complaint ((o be answered by plaintiffs and cross-comp/ainanis only) a. The complaint was filed on (dale):April 15, 2021 3. b, ~ The cross-complaint, if any, was filed on(date): Service (to be answered by plaintiffs and cross-comp/ainan/s on/y) a. b. ~ ~x All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. The following parties named in the complaint or cross-complaint (1) ~ have not been served (speciiy 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 (speciiy names): c. ~ The following additional parties may be added (specify names, na/ure of involvement in case, and date by which they may be served): 4. Description of case a, Type of case in ~x complaint Auto accident, personal injury ~ cross-complaint (Describe, inc/uding causes of action): Page1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court. Judicial Council of Caltfomia CASE MANAGEMENT STATEMENT rules 3.720-3.730 CM-1 10 [Rev. July 1, 2011] wwacourts.ce.gov CM-110 PLAINTIFF/PETITIONER: Scott Casas CASE NUMBER: DEFENDANT/RESPONDENT: Alexis Rsmos, Allison Actig-Grands and Does 1-20 21-CIV-02102 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 Io date, and estimated future lost earnings. If equitable re/iefis sought, describe the nature of the relief) This case involved a auto accident resulting in injuries. ~ (If more space is needed, check this box and elfach a page designated as Attachment 4b.) Jury or nonjury trial a. The party or parties request requesting e jury trial): ~ a jury trial ~x a nonjury trial.(If more than one party, provide the name of each party Trial date a. b. ~ ~x Thetrialhasbeensetfor (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 unavsiisbi7ity): Estimated length of trial The party or parties estimate that the trial will take (check one): a. ~x days (specify nufnber: 3 b C3 hours (short causes) (specify): Trial representation (Io be answered for each party) The party or parties will be represented at trial a. Attorney: ~x 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 described Preference inAttachment S. g. ~ 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 (2) For self-represented parties; Party~ ~ in rule 3.221 to the client and reviewed ADR options with the client. has hes not reviewed the ADR information package identified in rule 3.221. b. (1)~ Referral to judicial arbitration or civil action mediation (if available). 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 (2)~ statutory limit. Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of (3)~ Civil Procedure section 1141.11. 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 IRev. Jely1,2011I Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER; Scott Casse CASE NUMBER: DEFENDANT/RESPONDENT: Alexis Remos, Allison Actis-Grande end Doss 1-20 21-CIV-02192 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'DR processes (check all that apply); stipulation): ~x Mediation session not yet scheduled (1) Mediation ~ ~ Mediation session scheduled for (date): Agreed to complete mediation by (dale): ~ Mediation completed on (date)r ~ ~ 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 (3) Neutral evaluation ~ ~ (date): Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (dale): ~ ~ Judicial arbitration not yet scheduled Judicial arbitration scheduled for (date): (4) Nonbinding judicial arbitration ~ ~ Agreed to complete judicial arbitration by Judicial arbitration completed on (dale): (dale): ~ ~ Private arbitration not yet scheduled Private arbitration scheduled for (5) Binding private arbitration ~ ~ (data): Agreed to complete private arbitration by Private arbitration completed on (date)r (date): ~ ~ ADR session not yet scheduled ADR session scheduled for (6) Other (specify): ~ ~ (dale): Agreed to complete ADR session by (dale): ADR completed on (date): CM-110 [Ref. Juir 1, 2011I Pege 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER; Scott Cssas CASE NUMBER; DEFENDANT/RESPONDENT: Alexis Ramno, Allison Actis-Grands snd Does 1-20 21-C IV-02192 11.Insurance a. b. ~ Insurance carrier, Reservationofrights: ~ ifany, for party filing this statement (name): Yes ~ No c. ~ Coverage issues will significantly affect resolution ofthis case (explain): 12. Jurisdiction ~ Bankruptcy Status: ~ Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Other (specify)J 13. a. ~ Related cases, consolidation, and coordination There are companion, underlying, or related cases. (1) Nameofcase: (2) Nameofcourt: (3) Case number: Status: ~ (4) Additionalcases are described in Attachment 13a. b. ~ A motion to ~ consolidate ~ coordinate will 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 ~ (specify moving party, type of motion, and issues): The party or parties expect to file the following motions before trial 16. Discovery a. b. ~ ~ The party or parties have completed all discovery. The following discovery will be completed by the date specified (describe aii anticipated discovery): ~Part Descriotion ~Da e Plaintiff Defendant Deposition October 2021 c. ~ The following discovery Issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM.110 (Rey. July 1, 201 1 I Peaeeefs CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER) Scott Casse CASE NUMBER; DEFENDANT/RESPONDENT: Alexis Ramos, Allison Act(s-Grande snd Does 1-20 21-CIV-02192 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 of Civil Procedure sections 90-98 will apply to this case. inCode t).~ This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional (if checked, explain specifically why economic litigation procedures relating io discovery or trial discovery will be filed should nof app/y fo 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. ~x 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 noi, 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): Iam completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as weil 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. July29,2021 C~)fj~ Date: Adrienne Z. Cohn (TYPE OR PRINT NAME) i (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) ~ Additional signatures are attached. OM-110 [Rev Jolr I, 2011) Page 5 of 5 CASE MANAGEMENT STATEMENT