Preview
CM-110
arne, Stale Bar number end addressr
ATTORNEY OR PARTY WITHOUT ATTORNEY
IN FOR COURT USE ONLY
Mirali Vazirinejad, Esq. (SBN 320414)
The Barnes Firm, L.C.
555 12th St. Suite 1470, Oakland, CA 94607
TELEPHONE No: (800) 800-0000 FAx No. (Ontronarx (888) 800-7050
Eon ADDREssfopironag: ali.vazirinejad@thebarnesfirm.corn
ATToRNEYFoRtn.mai:Plaintiff, Deborah Skucas
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO 6/29/2021
sTREETADDREse 400 County Center
Same
MAILING ADDRESS
cITYANDzIPDDDE;Redwood City, CA 94063
BRANcH NAME:Hall of Justice of Records
PLAINTIFF/PETITIONER: DEBORAH SKUCAS
DEFENDANT/RESPONDENT: COUNTY OF SAN MATEO, ET AL.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): MX UNLIMITED CASE
(Amount demanded
H LIMITED CASE
(Amount demanded is $ 25,000
20-CIV-05519
exceeds $ 25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: July 15, 2021 Time: 9:00 a.m. Dept,: 34 Divx Room;
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name)i Mirali Vazirinejad
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
~v'his
a.
b. ~ statement is submitted by party (name): Deborah Skucas
This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (lo be answered by plaintiffs and cross-complainants only)
a.
b. ~
The complaint was filed on (dale):12/9/2020
The cross-complaint, if any, was filed on (dale):
3. Service (io be answered by plaintiffs and cross-complainanls only)
a.
b. ~MX All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
(1) ~
The following parties named in the complaint or cross-complaint
have not been served (specify names and explain why nol):
(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 ofinvolvementin case, and date by which
they may be served);
4. Description of case
a. Type of case in ~F complaint cross-complaint (Describe, including causes of action):
Premises liability
Panel ofa
Form Adopted for Mandatorv Use CASE MANAGEMENT STATEMENT Cal Ruiasotcourl,
Judicial Counol of California rules 3.72ILS.730
CM.110 (Rev. July I, 2011I www.courts ca gov
CM-110
PLAINTIFF/PETITIONER; DEBORAH SKUCAS
t
4.
DEFENDANT/RESPONDENT
b.
COUNTY OF SAN MATEO, ET AL.
20-CIV-05519
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 re/ief is sought, describe the nature of the relief)
On 12/05/2019, plaintiff was riding on State Route 84 within the limits of Town of Woodside in the county of San
Mateo. She was in the bike lane and came across an area with tree branches and other debris that she couldn'
avoid. Plaintiff fell off her bicycle and suffered serious injuries.
space is needed, check this box and ahach a page designated as Attachment 4b.)
(If more
Jury or nonjury trial
The party or parties request
requesting a jury trial):
~v a jury trial~ a nonjury trial. (If more lhan one party, provide the name of each party
a.
b.
~
Trial date
~V
The trial has been set for (date):
No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
07/06/2021, 7/12/2021/, 8/2/2021, 11/1/2021, 11/15/2021, 2/1 5/2022. 3/7/2022
Estimated length of trial
The party or parties estimate that the trial
take (check one):
will
~u'ays
a.
b, ~ (specify number): 5/7
hours (short causes) (specify):
a, Attorney:
~
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:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
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: CounselCZ has C3 has not provided the ADR information package identified
in rule 3,221 to the client and reviewed ADR options with the client,
(2) Forself-representedparties: PartyC3 has H has not reviewedtheADRinformationpackageidentifiedinrule3.221,
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
statutory limit.
(2) ~ Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Procedure section 1141.11.
Civil
(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 IReu. July 1. 201 f] Pege 2 ef 6
CASE MANAGEMENT STATEMENT
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: DEBORAH SKUCAS
20-CIV-05519
EFENDANT/RESPONDENT: COUNTY OF SAN MATEO, ET AL
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participatedin (clyeck a)l 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 a/I that app/y):stipulation):
Mediation session not yet scheduled
Mediation session scheduled for (data):
(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 (dafe):
Settlement conference completed on (dafe):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (data):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (data):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
Nonbinding judicial Judicial arbitration scheduled for (date):
(4)
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (data):
Private arbitration not yet scheduled
Binding private Private arbitration scheduled for (date):
(5)
arbitration
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (data):
(6) Other (specify):
Agreed to complete ADR session by (data):
ADR completed on (date):
CM-110 [Reu July 1, 2011l Page 3 of 3
CASE MANAGEMENT STATEMENT
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: DEBORAH SKUCAS
t DEFENDANT/RESPONDENT COUNTY OF SAN MATEO, ET AL.
20-CIV-05519
11.
a, ~
Insurance
~ ~
Insurance carrier, if any, for party filing this statement (name):
b.
c. ~
Reservation of rights: Yes No
Coverage issues will significantly affect resolution of this case (exp/a/n):
12.Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
M Bankruptcy C3 Other (specify):
Status:
13.
~
Related cases, consolidation, and coordination
There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number
b.
~H
(4) Status
Additionalcases are described in Attachment 13a.
A motion to C3 consolidate H coordinate (name party):
will be filed by
~
14. Bifurcation
The party or parties intend to tile a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (spec/fy moving party, type of motion, and reasons):
15.
~Other motions
The party or parties expect to file the following motions before trial (spec/fy moving party, type of motion, and issues):
16.
a.
b.
~
Discovery
~v
The party or parties have completed all discovery.
The following discovery will be completed by the date specified (describe all anticipated discovery):
Para Descriotion Date
Plaintiff to Defendant Written Discovery October 2021
Plaintiff Deposition October 2021
Plainitff Expert Discovery TBD
c, ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (spec/fy):
CM110 [Rev. July
2044 I page 4 of 4
1,
CASE MANAGEMENT STATEMENT
CM-110
CASE NUMBER.
PLAINTIFF/PETITIONER: DEBORAH SKUCAS
20-CIV-05519
DEFENDANT)RE8PPNDENT. COUNTY OF SAN MATEO, ET AL.
17.
a. ~
Economic litigation
case (i.e., the amount demanded is $ 25,000 or less) and the economic litigation procedures in Code
This is a limited civil
b.~ of Civil Procedure sections 90-98 will apply to this case.
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.
~
Otherissues
The party or parties request that the following additional matters be considered or determined at the case management
conference (spec)fy):
19. Meet and confer
a. ~Z 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):
Iam 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: April 5, 2021
Mirali Vazirinejad,Esq.
(TYPE OR PRINT NAME) SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME)
~ (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
C M.110 )Re u. July
I, 2011) CASE MANAGEMENT STATEMENT Pege0 ofe
1 PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF SAN MATEO
Skucas v. County of San Mateo, et al (20-CIV-05519)
I am employed in the County of Alameda, State of California. I am over the age of 18 and not
a party to the within action. My business address is 555 12'" St., Suite 1470, Oakland, California
94607.
I served the foregoing documents described as Plaintiff's Case Management Statement on
the interested parties in this action by placing a true copy thereof enclosed in a sealed envelope
addressed as follows:
Jose A. Gonzales, Esq.
California Department of Transportation — Legal Division
10 111 Grand Avenue, Suite 11-100. Oakland, CA 94612-3717
Mail:P.O. Box 24325
Oakland, CA 94623-1325
Email: iosea.aonzaleztmdot.ca.aov
12 maria.cordoneroedot.ca.cov
Rosa lie.H. Na uven dot.ca.oov
13
14
[t VIA U.S. MAIL: I deposited such envelope with postage thereon fully prepaid, in the United
15 Stated mail at Oakland, California. I am "readily familiar" with the firm's practice of collection
and processing correspondence for mailing. It is deposited with the U.S. Postal Service on that
16 same day in the ordinary course of business. Iam aware that on motion of party served, service
is presumed invalid if postal cancellation date or postage meter date is more than one day after
17
the day of deposit for mailing in affidavit.
18
[ J PERSONAL: I caused such envelope to be delivered by hand to the office of the
19 addressee pursuant to C.C.P. 5 1011.
20
[ X] ELECTRONIC SERVICE: Based on a court order or an agreement of the parties to accept
21
service by electronic transmission. I caused the documents to be sent to the persons at the
22 electronic notification addresses listed above. Idid not receive, within reasonable time after
the transmission, any electronic message or other indication that the transmission was
unsuccessful.
24 Ideclare under penalty of perjury under the laws of California that the above is true and correct.
Executed on June 29, 2021, at Oakland, Californ
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27
Tara FerencCC
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1
PROOF OF SERVICE