Preview
20CV368229
Santa Clara — Civil
M-11
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY ystenr stem
Teresa C. Chow, SBN 237694
Alexis B. Cruz, SBN 312842 Electronically Filed
BAKER & HOSTETLER LLP lby Superior Court of CA,
11601 Wilshire Boulevard, Suite 1400
Los Angeles, CA 90025-0509 (County of Santa Clara,
TeLePHone No.: 310.820.8800 FAX NO. (Optional): 310.820.8859 lon 12/4/2020 1:32 PM
E-MAIL ADDRESS (Optional): tchow@bakerlaw.com; acruz@bakerlaw.com Reviewed By: System System
ATTORNEY FOR (Name): Defendants EXEMPLIS, LLC, et al. (Case #20CV368229
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA Envelope: 5413715
STREET ADDRESS: 191 N. First Street
MAILING ADDRESS: 191 N. First Street
CITY AND ZIP CODE: San Jose, CA 95113
BRANCH NAWE: Santa Clara Superior Court
PLAINTIFF/PETITIONER: PACIFIC OFFICE DESIGNS, INC.
DEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
20CV368229
(Check one): ® UNLIMITED CASE QO LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: December 17, 2020 Time: 9:00 a.m. Dept.: 20 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Teresa C. Chow
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):
b. EX This statement is submitted jointly by parties (names): Exemplis, LLC, Paul De Vries, and Nancy Lopez (“Exemplis
Defendants”)
Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a The complaint was filed on (date):
b. (1 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) oO have not been served (specify names and explain why not):
(2) oO 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. fey 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 case in EX] complaint (1 cross-complaint (Describe, including causes of action):
Plaintiff alleges Defendants breached various duties of care and contracts arising out of a data breach by an unnamed third-
party. The Exemplis Defendants deny material allegations against them and that they are liable to Plaintiff in any amount.
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California rules 3.720-3.730,
‘CM-110 [Rev. July 1, 2011] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: PACIFIC OFFICE DESIGNS, INC. CASE NUMBER,
20CV368229
| DEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, et al.
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 alleges its accountant, Spot On Consulting Group, by and through Kelly Pauline Playle, paid over $281,000 to an
unnamed third-party, who Plaintiff alleges improperly accessed the Exemplis Defendants’ email system and sent fraudulent
payment instructions and bank account information to Plaintiff.
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 Ki a jury trial D0 anonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a. (The trial has been set for (date):
b. EJ 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):
April 26 - May 14, 2021 (trial); October4 - 22, 2021 (trial)
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 3 -5
b, Oo hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial KX. by the attorney or party listed in the caption C 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 J has C1 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) oO 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) (1 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) EX) 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):
CRC 3.811(b)(8) and CCP § 1775.5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California rules 3.720-3.730
(CM-110 [Rev. July 1, 2011]
Ame LegalN
www. rkF
CM-110
PLAINTIFF/PETITIONER: PACIFIC OFFICE DESIGNS, INC. CASE NUMBER:
20CV368229
[DEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, 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 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):
y Mediation session not yet scheduled
O Mediation session scheduled for (date):
(1) Mediation
le 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
Private arbitration scheduled for (date):
(5) Binding private
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):
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California rules 3.720-3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
Ame nL alN
www. 1 ork
CM-110
bs PLAINTIFF/PETITIONER: PACIFIC OFFICE DESIGNS, INC. CASE NUMBER:
20CV368229
IEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, et al.
11, Insurance
a &® Insurance carrier, if any, for party filing this statement (name): Beazley Insurance Services
b. Reservation of rights: & Yes 0 No
ce) 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 []_ 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 Amotion to O consolidate Oo coordinate will be filed by (name party):
14, Bifurcation
EX] 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):
The Exemplis Defendants respectfully submit that it is premature to address bifurcation, severance, or coordination of
issues/causes of action, but reserve the right to raise these issues if circumstances warrant at a later date.
15, Other motions
X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motion for Summary Judgement/Adjudication by the Exemplis Defendants.
16. Discovery
a (1 The party or parties have completed all discovery.
b KX) The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Exemplis Defendants Written discovery (SRogs, FRogs, RFPs, RFAs) Per Code
Exemplis Defendants Subpoenas to third parties Per Code
Exemplis Defendants Depositions (percipient witness and PMK) Per Code
Exemplis Defendants Expert discovery Per Code
¢, OO The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California rules 3.720-3.730
(CM-110 [Rev. July 1, 2011] www.courts.ca.gov
Ame nL
www ems im
CM-110
PLAINTIFF/PETITIONER: PACIFIC OFFICE DESIGNS, INC. CASE NUMBER:
20CV368229
| DEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, et al.
17. Economic litigation
a (2 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. o 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 I 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): The Exemplis Defendants intend to meet and confer with all parties on all subjects required by rule
3.724 of the California Rules of Court in advance of the Case Management Conference.
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): 0
| 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: December 4, 2020 BAKER & HOSTETLER LLP
Teresa C. Chow
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
»
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
C2 Additional signatures are attached.
(M-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5
PROOF OF SERVICE
Iam employed in Los Angeles County, California. I am over the age of eighteen years
and not a party to the within-entitled action. My business address is 11601 Wilshire Boulevard,
Suite 1400, Los Angeles, CA 90025-0509. On December 4, 2020, I served a copy of the within
document(s) in a sealed envelope, addressed as follows:
CASE MANAGEMENT STATEMENT
VIA EMAIL: by causing to be electronically transmitted a copy of the document
wi listed above via email to the addresses as set forth below, in accordance with the
parties’ agreement to be served electronically pursuant to Code of Civil Procedure
section 1010.6 and California Rule of Court 2.251(a) or court order. No error
messages were received after said transmissions.
Terry J. Mollica Randall J. Dean
MOLLICA LAW Mark DiMaria
560 First Street, Suite B201 CHAPMAN GLUCKSMAN,
10 Benccia, CA 94510 DEAN & ROEB
Telephone: 925.239.2380 11900 W. Olympic Blvd., Suite 800
11 Facsimile: 925.239.2382 Los Angeles, CA 90064
Email: tjim@caattnys.com Telephone: 310.207.7722
25 12 Facsimile: 310.207.6550
ase Attorneys for Plaintiff Email: rdean@cgdrblaw.com
Bea
goa
Bed 13 PACIFIC OFFICE DESIGNS, INC. mdimaria@cgdrlaw.com
gSz
mes
ge
wes Attorneys for Defendants
ged 14 Glen H. Olives
4< SPOT ON CONSULTING GROUP, JONATHAN R.
LAW OFFICE OF GLEN H. OLIVES
15 LADDY, CPA AND KELLY P. PLAYLE
4701 Soquel Drive, Suite E
Soquel, CA 95073
16 Telephone: 408.505.6889
Email: gho57942@gmail.com
17
Attorneys for Plaintiff
18 PACIFIC OFFICE DESIGNS, INC.
19 I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.
20
Executed on December 4, 2020, at Torrance, California
21
22 AG Or G2 Zt Z
23
ndre:
co ©)
24
25
26
27
28
Preview
20CV368229 Santa Clara — Civil M-11 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY ystenr stem Teresa C. Chow, SBN 237694 Alexis B. Cruz, SBN 312842 Electronically Filed BAKER & HOSTETLER LLP lby Superior Court of CA, 11601 Wilshire Boulevard, Suite 1400 Los Angeles, CA 90025-0509 (County of Santa Clara, TeLePHone No.: 310.820.8800 FAX NO. (Optional): 310.820.8859 lon 12/4/2020 1:32 PM E-MAIL ADDRESS (Optional): tchow@bakerlaw.com; acruz@bakerlaw.com Reviewed By: System System ATTORNEY FOR (Name): Defendants EXEMPLIS, LLC, et al. (Case #20CV368229 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA Envelope: 5413715 STREET ADDRESS: 191 N. First Street MAILING ADDRESS: 191 N. First Street CITY AND ZIP CODE: San Jose, CA 95113 BRANCH NAWE: Santa Clara Superior Court PLAINTIFF/PETITIONER: PACIFIC OFFICE DESIGNS, INC. DEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: 20CV368229 (Check one): ® UNLIMITED CASE QO LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: December 17, 2020 Time: 9:00 a.m. Dept.: 20 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Teresa C. Chow 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): b. EX This statement is submitted jointly by parties (names): Exemplis, LLC, Paul De Vries, and Nancy Lopez (“Exemplis Defendants”) Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a The complaint was filed on (date): b. (1 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) oO have not been served (specify names and explain why not): (2) oO 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. fey 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 case in EX] complaint (1 cross-complaint (Describe, including causes of action): Plaintiff alleges Defendants breached various duties of care and contracts arising out of a data breach by an unnamed third- party. The Exemplis Defendants deny material allegations against them and that they are liable to Plaintiff in any amount. Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California rules 3.720-3.730, ‘CM-110 [Rev. July 1, 2011] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: PACIFIC OFFICE DESIGNS, INC. CASE NUMBER, 20CV368229 | DEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, et al. 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 alleges its accountant, Spot On Consulting Group, by and through Kelly Pauline Playle, paid over $281,000 to an unnamed third-party, who Plaintiff alleges improperly accessed the Exemplis Defendants’ email system and sent fraudulent payment instructions and bank account information to Plaintiff. 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 Ki a jury trial D0 anonjury trial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a. (The trial has been set for (date): b. EJ 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): April 26 - May 14, 2021 (trial); October4 - 22, 2021 (trial) Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 3 -5 b, Oo hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial KX. by the attorney or party listed in the caption C 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 J has C1 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) oO 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) (1 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) EX) 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): CRC 3.811(b)(8) and CCP § 1775.5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California rules 3.720-3.730 (CM-110 [Rev. July 1, 2011] Ame LegalN www. rkF CM-110 PLAINTIFF/PETITIONER: PACIFIC OFFICE DESIGNS, INC. CASE NUMBER: 20CV368229 [DEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, 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 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): y Mediation session not yet scheduled O Mediation session scheduled for (date): (1) Mediation le 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 Private arbitration scheduled for (date): (5) Binding private 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): Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California rules 3.720-3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov Ame nL alN www. 1 ork CM-110 bs PLAINTIFF/PETITIONER: PACIFIC OFFICE DESIGNS, INC. CASE NUMBER: 20CV368229 IEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, et al. 11, Insurance a &® Insurance carrier, if any, for party filing this statement (name): Beazley Insurance Services b. Reservation of rights: & Yes 0 No ce) 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 []_ 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 Amotion to O consolidate Oo coordinate will be filed by (name party): 14, Bifurcation EX] 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): The Exemplis Defendants respectfully submit that it is premature to address bifurcation, severance, or coordination of issues/causes of action, but reserve the right to raise these issues if circumstances warrant at a later date. 15, Other motions X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Motion for Summary Judgement/Adjudication by the Exemplis Defendants. 16. Discovery a (1 The party or parties have completed all discovery. b KX) The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Exemplis Defendants Written discovery (SRogs, FRogs, RFPs, RFAs) Per Code Exemplis Defendants Subpoenas to third parties Per Code Exemplis Defendants Depositions (percipient witness and PMK) Per Code Exemplis Defendants Expert discovery Per Code ¢, OO The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California rules 3.720-3.730 (CM-110 [Rev. July 1, 2011] www.courts.ca.gov Ame nL www ems im CM-110 PLAINTIFF/PETITIONER: PACIFIC OFFICE DESIGNS, INC. CASE NUMBER: 20CV368229 | DEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, et al. 17. Economic litigation a (2 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. o 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 I 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): The Exemplis Defendants intend to meet and confer with all parties on all subjects required by rule 3.724 of the California Rules of Court in advance of the Case Management Conference. 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): 0 | 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: December 4, 2020 BAKER & HOSTETLER LLP Teresa C. Chow (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) » (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) C2 Additional signatures are attached. (M-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5 PROOF OF SERVICE Iam employed in Los Angeles County, California. I am over the age of eighteen years and not a party to the within-entitled action. My business address is 11601 Wilshire Boulevard, Suite 1400, Los Angeles, CA 90025-0509. On December 4, 2020, I served a copy of the within document(s) in a sealed envelope, addressed as follows: CASE MANAGEMENT STATEMENT VIA EMAIL: by causing to be electronically transmitted a copy of the document wi listed above via email to the addresses as set forth below, in accordance with the parties’ agreement to be served electronically pursuant to Code of Civil Procedure section 1010.6 and California Rule of Court 2.251(a) or court order. No error messages were received after said transmissions. Terry J. Mollica Randall J. Dean MOLLICA LAW Mark DiMaria 560 First Street, Suite B201 CHAPMAN GLUCKSMAN, 10 Benccia, CA 94510 DEAN & ROEB Telephone: 925.239.2380 11900 W. Olympic Blvd., Suite 800 11 Facsimile: 925.239.2382 Los Angeles, CA 90064 Email: tjim@caattnys.com Telephone: 310.207.7722 25 12 Facsimile: 310.207.6550 ase Attorneys for Plaintiff Email: rdean@cgdrblaw.com Bea goa Bed 13 PACIFIC OFFICE DESIGNS, INC. mdimaria@cgdrlaw.com gSz mes ge wes Attorneys for Defendants ged 14 Glen H. Olives 4< SPOT ON CONSULTING GROUP, JONATHAN R. LAW OFFICE OF GLEN H. OLIVES 15 LADDY, CPA AND KELLY P. PLAYLE 4701 Soquel Drive, Suite E Soquel, CA 95073 16 Telephone: 408.505.6889 Email: gho57942@gmail.com 17 Attorneys for Plaintiff 18 PACIFIC OFFICE DESIGNS, INC. 19 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 20 Executed on December 4, 2020, at Torrance, California 21 22 AG Or G2 Zt Z 23 ndre: co ©) 24 25 26 27 28