Preview
20CV368229
Santa Clara — Civil
Systom-Syetym
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Randall J. Dean, Esq., Bar No. 110441 Electronically Filed
CHAPMAN GLUCKSMAN DEAN & ROEB, APC
by Superior Court of CA,
11900 WEST OLYMPIC BOULEVARD, SUITE 800
LOS ANGELES, CALIFORNIA 90064-0704 County of Santa Clara,
‘TELEPHONE NO. (310) 207-7722 FAX NO.(Optionay): (310 ) 207-6550 on 10/27/2020 5:03 PM
E-MAIL ADDRESS (Optionay: TYdean@cgdrlaw.com Reviewed By: System System
ATTORNEY FOR (Name): Defendants Spot On Consulting Group, Jonathan R. Laddy, & Kelly P. Playle Case #20CV368229
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA Envelope: 5189519
STREET ADDRESS: Old Courthouse
MAILING ADDRESS: 161 North First Street
CITY AND ZIP CODE: SanCA 95113
Jose,
BRANCH NAME: CIVIL DIVISION
PLAINTIFF/PETITIONER: PACIFIC OFFICE DESIGNS, INC., etc.
DEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, etc., et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): [X] UNLIMITED CASE () Limitep CASE 20 CV 368229
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: November 10, 2020 Time: 3:00 p.m. Dept.: 20 Div.: Room:
Address of court (if different from the address above):
[4] Notice of Intent to Appear by Telephone, by (name): Randall J. Dean, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. [C) This statement is submitted by party (name):
b. [&] This statement is submitted jointly by parties (names):
Defendants Spot On Consulting Group, A Professional Accountancy
Corporation, Jonathan R. Laddy, CRAY and Keddy. be Pillayie)
Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. CC) The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
a. Q) All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. CC) The following parties named in the complaint or cross-complaint
(1) (2D have not been served (specify names and explain why not):
(2) (CD 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. CC) The following additional parties may be added (specify names, nature of involvement in case, and the date by which
they may be served):
Description of case
a. [) complaint
Type of case in (2) cross-complaint (Describe, including causes of action):
"Intentional Misrepresentation; Negligent Misrepresentation; Breach of
Contract; Negligence; Breach of Implied Contract; Attorneys Fees re
Tort of Another; Breach of Contract; and Negligence: Res Ipsa Loquitor
[sic]"
Page 1 of 5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of Califomia
(CM-110 [Rev. July 1, 2011] CEB E\Forms-
Essential ules 3.720-3.7:
www.courts.ca.gov
0782.763
CM-110
PLAINTIFF/PETITIONER: CASE NUMBER:
| PACIFIC OFFICE DESIGNS, INC., etc. 20 CV 368229
DEFENDANT/RESPONDENT:
SPOT ON CONSULTING GROUP, etc., 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.)
Of nine purported causes of action, only six (Intentional Misrepresentation; Negligent Misrepresentation; Breach of Contract; Negligence; Attorneys Fees re Tort of
‘Another, and Negligence: Res Ipsa Loquitor [sic]) are directed toward these accountant defendants, who have not yet filed any responsive pleading to the operative
first amended complaint (the "FAC"). The FAC alleges that the Accountants were fraudulently induced by third party criminals to disburse payment by their client,
plaintiff, to its trade creditor, defendant Exemplis. The Accountants assert that most such claims are legally untenable, and deny all liability.
CC) (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 EX) a jury trial CC) anoniury 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. [XJ] 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):
©. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
March-April 2021 are the defendants accountants' tax season, and trial counsel is engaged in other trials.
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [] days (specify number): 5-10
b. (} hours (short causes) (specify):
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: 9. Party represented:
a 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: Counsel () has (Cy 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 [J has (C)} has not reviewed the ADR information package identified in rule 3.221.
Referral to judicial arbitration or civil action mediation (if available).
q) (2) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) (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) (2) 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] CASE MANAGEMENT STATEMENT Page 2 of 5
Ca
ceb.com
Essential
\Forms- 0782.763
CM-110
PLAINTIFF/PETITIONER: CASE NUMBER:
| PACIFIC OFFICE DESIGNS, NCE etc. 20 CV 368229
DEFENDANT/RESPONDENT:
SPOT ON CONSULTING GROUP, etc., et al.
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):
[&] Mediation session not yet scheduled
C) Mediation session scheduled for (date):
(1) Mediation
[C) Agreed to complete mediation by (date):
C) Mediation completed on (date):
CC) Settlement conference not yet scheduled
(2) Settlement () Settlement conference scheduled for (date):
conference
(-) Agreed to complete settlement conference by (date):
CD Settlement conference completed on (date):
CC) Neutral evaluation not yet scheduled
(2) Neutral evaluation scheduled for (date):
(3) Neutral evaluation
(2) Agreed to complete neutral evaluation by (date):
(] Neutral evaluation completed on (date):
[C) Judicial arbitration not yet scheduled
(4) Nonbinding judicial C2) Judicial arbitration scheduled for (date):
arbitration
CC) Agreed to complete judicial arbitration by (date):
(2) Judicial arbitration completed on (date):
CC) Private arbitration not yet scheduled
(5) Binding private (C) Private arbitration scheduled for (date):
arbitration
(2) Agreed to complete private arbitration by (date):
() Private arbitration completed on (date):
(1 ADR session not yet scheduled
(6) Other (specify): () ADR session scheduled for (date):
CC) Agreed to complete ADR session by (date):
[2] ADR completed on (date):
(M-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5
GB
ceb.com
Essential
\Forms-
0782.763
CM-110
PLAINTIFF/PETITIONER: CASE NUMBER:
| PACIFIC OFFICE DESIGNS, INC., etc. 20 CV 368229
DEFENDANT/RESPONDENT:
SPOT ON CONSULTING GROUP, etc., et al.
11. Insurance
a. [&] Insurance carrier, if any, for party filing this statement (name): CAMICO Mutual Insurance Company
b. Reservation of rights: CU) 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.
CD Bankruptcy C) Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. CC) There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
(C) Additional cases are described in Attachment 13a.
b. () A motion to (2) 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
[&] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Unless voluntarily dismissed by plaintiff, the accountant defendants anticipate filing demurrers or motions for judgment on the
pleadings as to all claims against them other than negligence and breach of contract.
Possible motion for summary judgment and/or summary adjudication following completion of discovery.
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 Descriptio Date
Accountant Defendants Written Discovery July 2021
Accountant Defendants Party Depositions October 2021
Accountant Defendants Third Party & Expert Discovery December 2021
c. CC) The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5
Ca
ceb.com
Essential
\Forms- 0782.763
CM-110
PLAINTIFF/PETITIONER: CASE NUMBER:
| PACIFIC OFFICE DESIGNS, INC., etc. 20 CV 368229
DEFENDANT/RESPONDENT:
SPOT ON CONSULTING GROUP, etc., 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. (2) 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. (CC) 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): No appearance in this matter to date by these parties.
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): QO
| 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: October 27, 2020.
Randall i Dean Esq »
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
>
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(2) Additional signatures are attached.
(CN-110 [Rev. July1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5
CEB’ Essential
ceb.com Forms:
Forms:
0782.763
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
I am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action; my business address is 11900 W. Olympic Boulevard, Suite
800, Los Angeles, California 90064.
On October 27, 2020, I served the foregoing document described as CASE
MANAGEMENT STATEMENT (11/10/20; 3:00 p.m.; Dept. 20) on the parties in this action as
follows:
SEE ATTACHED SERVICE LIST
(BY MAIL)
I placed said document in an envelope addressed as shown above. I am “readily familiar" with
10 the firm's practice of collection and processing correspondence for mailing with the United
States Postal Service. Under that practice, said correspondence will be deposited with the
11 United States Postal Service the same day in the ordinary course of business. I sealed said
envelope and placed it for collection and mailing on the date stated below to the addressed
12
stated on the attached service list, following the firm's ordinary business practices.
13
(ELECTRONIC MAIL)
14 By transmitting a copy of the foregoing document(s) via internet/electronic mail to a Court
Approved e-filing/e-service portal ONE LEGAL for service on all parties in this case via their
15 email addresses pursuant to the General Court Order authorizing e-service of documents.
16
(STATE)
17 I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct.
18
Executed on October 27, 2020, at Los Angeles, California.
19
20 /s/
C. Taylor
21
22
23
24
25
26
27
28
0782.763
Case Management Statement
PROOF OF SERVICE
PACIFIC OFFICE DESIGNS, INC. v. SPOT ON CONSULTING GROUP, et al.
Superior Court of the State of California — Santa Clara County
Case No. .: 20 CV 368229
Terry J. Mollica, Esq. Attorneys for Plaintiff,
Mollica Law PACIFIC OFFICE DESIGNS, INC., a
560 First Street, Suite B201 California Corporation
Benicia, CA. 94510
Tele: (925) 239-2380
Fax: (925)239-2382
10 E-mail: E-mail: tim@caattnys.com
11
Glen H. Olives, Esq. Attorneys for Plaintiff,
12 Law Office of Glen H. Olives PACIFIC OFFICE DESIGNS, INC., a
4701 Soquel Drive, Suite E California Corporation
13 Soquel, CA. 95073
14 Telephone: (408) 505-6889
E-mail: gho57942@gmail.com
15
16 Teresa C. Chow, Esq. Attorneys for Defendants,
BakerHostetler JONATHAN RONALD LADDY;
17 11601 Wilshire Boulevard,| Suite 1400 EXEMPLIS, LLC, a California Limited
Los Angeles, CA 90025-0509 Liability Company; PAUL DE VRIES;
18 KELLY PAULINE and PLAYLE;
Telephone: (310) 979-8458 NANCY LOPEZ
19 tchow@bakerlaw.com
20
21
22
23
24
25
26
27
28
782.763 2
Case Management Statement
Preview
20CV368229 Santa Clara — Civil Systom-Syetym ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Randall J. Dean, Esq., Bar No. 110441 Electronically Filed CHAPMAN GLUCKSMAN DEAN & ROEB, APC by Superior Court of CA, 11900 WEST OLYMPIC BOULEVARD, SUITE 800 LOS ANGELES, CALIFORNIA 90064-0704 County of Santa Clara, ‘TELEPHONE NO. (310) 207-7722 FAX NO.(Optionay): (310 ) 207-6550 on 10/27/2020 5:03 PM E-MAIL ADDRESS (Optionay: TYdean@cgdrlaw.com Reviewed By: System System ATTORNEY FOR (Name): Defendants Spot On Consulting Group, Jonathan R. Laddy, & Kelly P. Playle Case #20CV368229 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA Envelope: 5189519 STREET ADDRESS: Old Courthouse MAILING ADDRESS: 161 North First Street CITY AND ZIP CODE: SanCA 95113 Jose, BRANCH NAME: CIVIL DIVISION PLAINTIFF/PETITIONER: PACIFIC OFFICE DESIGNS, INC., etc. DEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, etc., et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): [X] UNLIMITED CASE () Limitep CASE 20 CV 368229 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: November 10, 2020 Time: 3:00 p.m. Dept.: 20 Div.: Room: Address of court (if different from the address above): [4] Notice of Intent to Appear by Telephone, by (name): Randall J. Dean, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. [C) This statement is submitted by party (name): b. [&] This statement is submitted jointly by parties (names): Defendants Spot On Consulting Group, A Professional Accountancy Corporation, Jonathan R. Laddy, CRAY and Keddy. be Pillayie) Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. CC) The cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) a. Q) All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. CC) The following parties named in the complaint or cross-complaint (1) (2D have not been served (specify names and explain why not): (2) (CD 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. CC) The following additional parties may be added (specify names, nature of involvement in case, and the date by which they may be served): Description of case a. [) complaint Type of case in (2) cross-complaint (Describe, including causes of action): "Intentional Misrepresentation; Negligent Misrepresentation; Breach of Contract; Negligence; Breach of Implied Contract; Attorneys Fees re Tort of Another; Breach of Contract; and Negligence: Res Ipsa Loquitor [sic]" Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of Califomia (CM-110 [Rev. July 1, 2011] CEB E\Forms- Essential ules 3.720-3.7: www.courts.ca.gov 0782.763 CM-110 PLAINTIFF/PETITIONER: CASE NUMBER: | PACIFIC OFFICE DESIGNS, INC., etc. 20 CV 368229 DEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, etc., 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.) Of nine purported causes of action, only six (Intentional Misrepresentation; Negligent Misrepresentation; Breach of Contract; Negligence; Attorneys Fees re Tort of ‘Another, and Negligence: Res Ipsa Loquitor [sic]) are directed toward these accountant defendants, who have not yet filed any responsive pleading to the operative first amended complaint (the "FAC"). The FAC alleges that the Accountants were fraudulently induced by third party criminals to disburse payment by their client, plaintiff, to its trade creditor, defendant Exemplis. The Accountants assert that most such claims are legally untenable, and deny all liability. CC) (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 EX) a jury trial CC) anoniury 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. [XJ] 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): ©. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): March-April 2021 are the defendants accountants' tax season, and trial counsel is engaged in other trials. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [] days (specify number): 5-10 b. (} hours (short causes) (specify): 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: 9. Party represented: a 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: Counsel () has (Cy 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 [J has (C)} has not reviewed the ADR information package identified in rule 3.221. Referral to judicial arbitration or civil action mediation (if available). q) (2) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) (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) (2) 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] CASE MANAGEMENT STATEMENT Page 2 of 5 Ca ceb.com Essential \Forms- 0782.763 CM-110 PLAINTIFF/PETITIONER: CASE NUMBER: | PACIFIC OFFICE DESIGNS, NCE etc. 20 CV 368229 DEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, etc., et al. 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): [&] Mediation session not yet scheduled C) Mediation session scheduled for (date): (1) Mediation [C) Agreed to complete mediation by (date): C) Mediation completed on (date): CC) Settlement conference not yet scheduled (2) Settlement () Settlement conference scheduled for (date): conference (-) Agreed to complete settlement conference by (date): CD Settlement conference completed on (date): CC) Neutral evaluation not yet scheduled (2) Neutral evaluation scheduled for (date): (3) Neutral evaluation (2) Agreed to complete neutral evaluation by (date): (] Neutral evaluation completed on (date): [C) Judicial arbitration not yet scheduled (4) Nonbinding judicial C2) Judicial arbitration scheduled for (date): arbitration CC) Agreed to complete judicial arbitration by (date): (2) Judicial arbitration completed on (date): CC) Private arbitration not yet scheduled (5) Binding private (C) Private arbitration scheduled for (date): arbitration (2) Agreed to complete private arbitration by (date): () Private arbitration completed on (date): (1 ADR session not yet scheduled (6) Other (specify): () ADR session scheduled for (date): CC) Agreed to complete ADR session by (date): [2] ADR completed on (date): (M-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5 GB ceb.com Essential \Forms- 0782.763 CM-110 PLAINTIFF/PETITIONER: CASE NUMBER: | PACIFIC OFFICE DESIGNS, INC., etc. 20 CV 368229 DEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, etc., et al. 11. Insurance a. [&] Insurance carrier, if any, for party filing this statement (name): CAMICO Mutual Insurance Company b. Reservation of rights: CU) 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. CD Bankruptcy C) Other (specify): Status: 13. Related cases, consolidation, and coordination a. CC) There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: (C) Additional cases are described in Attachment 13a. b. () A motion to (2) 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 [&] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Unless voluntarily dismissed by plaintiff, the accountant defendants anticipate filing demurrers or motions for judgment on the pleadings as to all claims against them other than negligence and breach of contract. Possible motion for summary judgment and/or summary adjudication following completion of discovery. 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 Descriptio Date Accountant Defendants Written Discovery July 2021 Accountant Defendants Party Depositions October 2021 Accountant Defendants Third Party & Expert Discovery December 2021 c. CC) The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5 Ca ceb.com Essential \Forms- 0782.763 CM-110 PLAINTIFF/PETITIONER: CASE NUMBER: | PACIFIC OFFICE DESIGNS, INC., etc. 20 CV 368229 DEFENDANT/RESPONDENT: SPOT ON CONSULTING GROUP, etc., 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. (2) 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. (CC) 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): No appearance in this matter to date by these parties. 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): QO | 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: October 27, 2020. Randall i Dean Esq » (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) > (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (2) Additional signatures are attached. (CN-110 [Rev. July1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5 CEB’ Essential ceb.com Forms: Forms: 0782.763 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is 11900 W. Olympic Boulevard, Suite 800, Los Angeles, California 90064. On October 27, 2020, I served the foregoing document described as CASE MANAGEMENT STATEMENT (11/10/20; 3:00 p.m.; Dept. 20) on the parties in this action as follows: SEE ATTACHED SERVICE LIST (BY MAIL) I placed said document in an envelope addressed as shown above. I am “readily familiar" with 10 the firm's practice of collection and processing correspondence for mailing with the United States Postal Service. Under that practice, said correspondence will be deposited with the 11 United States Postal Service the same day in the ordinary course of business. I sealed said envelope and placed it for collection and mailing on the date stated below to the addressed 12 stated on the attached service list, following the firm's ordinary business practices. 13 (ELECTRONIC MAIL) 14 By transmitting a copy of the foregoing document(s) via internet/electronic mail to a Court Approved e-filing/e-service portal ONE LEGAL for service on all parties in this case via their 15 email addresses pursuant to the General Court Order authorizing e-service of documents. 16 (STATE) 17 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 18 Executed on October 27, 2020, at Los Angeles, California. 19 20 /s/ C. Taylor 21 22 23 24 25 26 27 28 0782.763 Case Management Statement PROOF OF SERVICE PACIFIC OFFICE DESIGNS, INC. v. SPOT ON CONSULTING GROUP, et al. Superior Court of the State of California — Santa Clara County Case No. .: 20 CV 368229 Terry J. Mollica, Esq. Attorneys for Plaintiff, Mollica Law PACIFIC OFFICE DESIGNS, INC., a 560 First Street, Suite B201 California Corporation Benicia, CA. 94510 Tele: (925) 239-2380 Fax: (925)239-2382 10 E-mail: E-mail: tim@caattnys.com 11 Glen H. Olives, Esq. Attorneys for Plaintiff, 12 Law Office of Glen H. Olives PACIFIC OFFICE DESIGNS, INC., a 4701 Soquel Drive, Suite E California Corporation 13 Soquel, CA. 95073 14 Telephone: (408) 505-6889 E-mail: gho57942@gmail.com 15 16 Teresa C. Chow, Esq. Attorneys for Defendants, BakerHostetler JONATHAN RONALD LADDY; 17 11601 Wilshire Boulevard,| Suite 1400 EXEMPLIS, LLC, a California Limited Los Angeles, CA 90025-0509 Liability Company; PAUL DE VRIES; 18 KELLY PAULINE and PLAYLE; Telephone: (310) 979-8458 NANCY LOPEZ 19 tchow@bakerlaw.com 20 21 22 23 24 25 26 27 28 782.763 2 Case Management Statement