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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
James J. Zenere 151724
Sheuerman Martini Tabari Zenere & Garvin
1033 Willow Street
San Jose, Ca 95125
TELEPHONE NO.:(408) 288-9700 FAX NO.(Optional): (408) 295-9900
jzenere@smtlaw.com
E-MAIL ADDRESS (Optional):
ATTORNEY FOR (Name):
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO 5/25/2021
STREET ADDRESS: 400 County Center
MAILING ADDRESS:
CITY AND ZIP CODE:Redwood City CA 94063
BRANCH NAME:
PLAINTIFF/PETITIONER: FRANK SHEE
DEFENDANT/RESPONDENT: ALBERT BOLANOS, ET AL
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): ‰X UNLIMITED CASE ‰ LIMITED CASE 21-CV-00632
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: June 10, 2021 Time: 9:00 am Dept.: 23 Div.: Room:
Address of court (if different from the address above):
‰ Notice of Intent to Appear by Telephone, by (name):
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. ‰X This statement is submitted by party (name): ALBERTO BOLANOS, M.D.
b. ‰ This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. ‰ The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. ‰ All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. ‰ The following parties named in the complaint or cross-complaint
(1) ‰ have not been served (specify names and explain why not):
(2) ‰ have been served but have not appeared and have not been dismissed (specify names):
(3) ‰ have had a default entered against them (specify names):
c. ‰ The following additional parties may be added (specify names, nature of involvement in case, and the date by which
they may be served):
4. Description of case
a. Type of case in ‰X complaint ‰ cross-complaint (Describe, including causes of action):
Plaintiff alleges medical negligence regarding shoulder surgery.
Page 1 of 5
Form Adopted for Mandatory Use
Judicial Council of California
CASE MANAGEMENT STATEMENT Cal. Rules of Court,
rules 3.720-3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
Shee, Frank
CM-110
PLAINTIFF/PETITIONER:FRANK SHEE CASE NUMBER:
21-CV-00632
DEFENDANT/RESPONDENT: ALBERT BOLANOS, 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 medical negligence regarding shoulder surgery.
‰ (If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request ‰X a jury trial ‰ a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. ‰ The trial has been set for (date):
b. ‰X 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):
Trials Scheduled: 9/17/21; 11/1/21; 11/8/21; 1/10/22; 4/18/22; 7/11/22;
8/8/22 Vacations: 5/20/21-6/10/21; 7/12/21-7/23/21; 12/20/21-1/3/22;
7/21/22-7/31/22; 10/10/22-10/15/22
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. ‰X days (specify number): 5-7
b. ‰ hours (shortcauses) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial ‰X by the attorney or party listed in the caption ‰ by the following:
a. Attorney: James J. Zenere
b. Firm: SHEUERMAN, MARTINI, TABARI, ZENERE & GARVIN
c. Address: 1033 Willow Street, San Jose CA 95125
d. Telephone number: (408)288-9700 f. Fax number: (408)295-9900
e. E-mail address: jzenere@smtlaw.com g. Party represented: ALBERTO BOLANOS, M.D.
‰ Additional representation is described in Attachment 8.
9. Preference
‰ This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel ‰X has ‰ has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party ‰ has ‰ has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) ‰ This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) ‰ Plaintiff
elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) ‰ This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 of 5
Shee, Frank
CM-110
PLAINTIFF/PETITIONER:FRANK SHEE CASE NUMBER:
21-CV-00632
DEFENDANT/RESPONDENT: ALBERT BOLANOS, 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):
‰ Mediation session not yet scheduled
(1) Mediation ‰ ‰ Mediation session scheduled for (date):
‰ 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
(3) Neutral evaluation ‰ ‰ Neutral evaluation scheduled for (date):
‰ Agreed to complete neutral evaluation by (date):
‰ Neutral evaluation completed on (date):
‰ Judicial arbitration not yet scheduled
(4) Nonbinding judicial ‰ ‰ Judicial arbitration scheduled for (date):
arbitration
‰ Agreed to complete judicial arbitration by (date):
‰ Judicial arbitration completed on (date):
‰ Private arbitration not yet scheduled
(5) Binding private ‰ ‰ Private arbitration scheduled for (date):
arbitration
‰ Agreed to complete private arbitration by (date):
‰ Private arbitration completed on (date):
‰ ADR session not yet scheduled
(6) Other (specify): ‰X ‰ ADR session scheduled for (date):
Too early
to determine ‰ Agreed to complete ADR session by (date):
‰ ADR completed on (date):
CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5
Shee, Frank
CM-110
PLAINTIFF/PETITIONER: FRANK SHEE CASE NUMBER:
21-CV-00632
DEFENDANT/RESPONDENT: ALBERT BOLANOS, ET AL
11. Insurance
a. ‰X The
Insurance carrier, if any, for party filing this statement (name): Medical Protective
b. Reservation of rights: ‰ Yes ‰X No
c. ‰ Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case, and describe the status.
‰ Bankruptcy ‰ Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. ‰ There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
‰ Additional cases are described in Attachment 13a.
b. ‰ A motion to ‰ consolidate ‰ coordinate 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
‰X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Defendant ALBERTO BOLANOS MD has filed a Motion to Strike, set for
hearing on August 23, 2021; Potential Motion for Summary Judgment
16. Discovery
a. ‰ The party or parties have completed all discovery.
b. ‰X The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendant Deposition of plaintiff(s) TBD
Defendant Depositions of treating physicians TBD
Defendant Expert Discovery Per Code
c. ‰ 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
Shee, Frank
CM-110
PLAINTIFF/PETITIONER: FRANK SHEE CASE NUMBER:
21-CV-00632
DEFENDANT/RESPONDENT: ALBERT BOLANOS, ET AL
17. Economic litigation
a. ‰ This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. ‰ This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
‰X The party or parties request that the following additional matters be considered or determined at the case management
conference (specify): Defendant ALBERTO BOLANOS MD has filed a Motion to Strike,
set for hearing on August 23, 2021. Have not received any
indication that co-defendant Mills Peninsula has appeared.
19. Meet and confer
a. ‰ The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of
Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any):
I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: May 25, 2021
James J. Zenere
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
‰ Additional signatures are attached.
CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5
Shee, Frank
1 CASE NAME: SHEE v. BOLANOS, et al ACTION NO. 21-CV-00632
2 PROOF OF SERVICE
[CCP §§ 1012.5, 1013a and 2015.5; CRC 2008]
3
I am a citizen of the United States. My business address is 1033 Willow Street, San Jose,
4 CA 95125. I am employed in Santa Clara County where this service occurred. I am over the age
of 18 years and not a party to the within cause. I am readily familiar with my employer's normal
5 business practice for collection and processing of correspondence for mailing and facsimile. In
the case of mailing [other than overnight delivery], the practice is that correspondence is
6 deposited in the U.S. Postal Service the same day as the day of collection in the ordinary course
of business.
7
On May 25, 2021, I served the within CASE MANAGEMENT STATEMENT
8 on the PARTIES in said action as follows:
9 Frank Shee
105 Lucca Drive
10 South San Francisco, CA 94080
Tel: (650) 438-5897
11 frankshee03@yahoo.com
12
X (BY MAIL) I caused a true copy of each document identified above to be placed in a
13 sealed envelope with first-class postage affixed. Each such envelope was deposited for collection
and mailing that same day in the ordinary course of business in the United States mail at San
14 Jose, California.
15 (BY PERSONAL SERVICE) I caused a true copy of each document identified above to be
delivered by hand to the offices of each addressee above.
16
(BY OVERNIGHT DELIVERY) I caused a true copy of each document identified above
17 to be sealed in an envelope to be delivered to an overnight carrier with delivery fees provided for,
addressed of each addressee above.
18
X (BY-E-MAIL OR ELECTRONIC TRANSMISSION) Based on a court order or an
19 agreement of the parties to accept service by e-mail or electronic transmission, I caused the
document(s) to be sent to the persons at the e-mail address listed above. I did not receive, within
20 a reasonable time after the transmission, any electronic message or other indication that the
transmission was unsuccessful.
21
X (BY ELECTRONIC SERVICE) I caused each of the above-named documents to be
22 delivered by email to the parties via One Legal E-Service upload link.
23 X (STATE) I declare under penalty of perjury under the laws of the State of California that
the above is true and correct.
24
(FEDERAL) I declare that I am employed in the office of a member of the bar of this court
25 at whose direction the service was made.
26
Diane Point
27
28
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY James J. Zenere 151724 Sheuerman Martini Tabari Zenere & Garvin 1033 Willow Street San Jose, Ca 95125 TELEPHONE NO.:(408) 288-9700 FAX NO.(Optional): (408) 295-9900 jzenere@smtlaw.com E-MAIL ADDRESS (Optional): ATTORNEY FOR (Name): SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO 5/25/2021 STREET ADDRESS: 400 County Center MAILING ADDRESS: CITY AND ZIP CODE:Redwood City CA 94063 BRANCH NAME: PLAINTIFF/PETITIONER: FRANK SHEE DEFENDANT/RESPONDENT: ALBERT BOLANOS, ET AL CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): ‰X UNLIMITED CASE ‰ LIMITED CASE 21-CV-00632 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: June 10, 2021 Time: 9:00 am Dept.: 23 Div.: Room: Address of court (if different from the address above): ‰ Notice of Intent to Appear by Telephone, by (name): INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. ‰X This statement is submitted by party (name): ALBERTO BOLANOS, M.D. b. ‰ This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. ‰ The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. ‰ All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. ‰ The following parties named in the complaint or cross-complaint (1) ‰ have not been served (specify names and explain why not): (2) ‰ have been served but have not appeared and have not been dismissed (specify names): (3) ‰ have had a default entered against them (specify names): c. ‰ The following additional parties may be added (specify names, nature of involvement in case, and the date by which they may be served): 4. Description of case a. Type of case in ‰X complaint ‰ cross-complaint (Describe, including causes of action): Plaintiff alleges medical negligence regarding shoulder surgery. Page 1 of 5 Form Adopted for Mandatory Use Judicial Council of California CASE MANAGEMENT STATEMENT Cal. Rules of Court, rules 3.720-3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov Shee, Frank CM-110 PLAINTIFF/PETITIONER:FRANK SHEE CASE NUMBER: 21-CV-00632 DEFENDANT/RESPONDENT: ALBERT BOLANOS, 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 medical negligence regarding shoulder surgery. ‰ (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request ‰X a jury trial ‰ a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. ‰ The trial has been set for (date): b. ‰X 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): Trials Scheduled: 9/17/21; 11/1/21; 11/8/21; 1/10/22; 4/18/22; 7/11/22; 8/8/22 Vacations: 5/20/21-6/10/21; 7/12/21-7/23/21; 12/20/21-1/3/22; 7/21/22-7/31/22; 10/10/22-10/15/22 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. ‰X days (specify number): 5-7 b. ‰ hours (shortcauses) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial ‰X by the attorney or party listed in the caption ‰ by the following: a. Attorney: James J. Zenere b. Firm: SHEUERMAN, MARTINI, TABARI, ZENERE & GARVIN c. Address: 1033 Willow Street, San Jose CA 95125 d. Telephone number: (408)288-9700 f. Fax number: (408)295-9900 e. E-mail address: jzenere@smtlaw.com g. Party represented: ALBERTO BOLANOS, M.D. ‰ Additional representation is described in Attachment 8. 9. Preference ‰ This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel ‰X has ‰ has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party ‰ has ‰ has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) ‰ This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) ‰ Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) ‰ This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 of 5 Shee, Frank CM-110 PLAINTIFF/PETITIONER:FRANK SHEE CASE NUMBER: 21-CV-00632 DEFENDANT/RESPONDENT: ALBERT BOLANOS, 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): ‰ Mediation session not yet scheduled (1) Mediation ‰ ‰ Mediation session scheduled for (date): ‰ 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 (3) Neutral evaluation ‰ ‰ Neutral evaluation scheduled for (date): ‰ Agreed to complete neutral evaluation by (date): ‰ Neutral evaluation completed on (date): ‰ Judicial arbitration not yet scheduled (4) Nonbinding judicial ‰ ‰ Judicial arbitration scheduled for (date): arbitration ‰ Agreed to complete judicial arbitration by (date): ‰ Judicial arbitration completed on (date): ‰ Private arbitration not yet scheduled (5) Binding private ‰ ‰ Private arbitration scheduled for (date): arbitration ‰ Agreed to complete private arbitration by (date): ‰ Private arbitration completed on (date): ‰ ADR session not yet scheduled (6) Other (specify): ‰X ‰ ADR session scheduled for (date): Too early to determine ‰ Agreed to complete ADR session by (date): ‰ ADR completed on (date): CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5 Shee, Frank CM-110 PLAINTIFF/PETITIONER: FRANK SHEE CASE NUMBER: 21-CV-00632 DEFENDANT/RESPONDENT: ALBERT BOLANOS, ET AL 11. Insurance a. ‰X The Insurance carrier, if any, for party filing this statement (name): Medical Protective b. Reservation of rights: ‰ Yes ‰X No c. ‰ Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case, and describe the status. ‰ Bankruptcy ‰ Other (specify): Status: 13. Related cases, consolidation, and coordination a. ‰ There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: ‰ Additional cases are described in Attachment 13a. b. ‰ A motion to ‰ consolidate ‰ coordinate 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 ‰X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Defendant ALBERTO BOLANOS MD has filed a Motion to Strike, set for hearing on August 23, 2021; Potential Motion for Summary Judgment 16. Discovery a. ‰ The party or parties have completed all discovery. b. ‰X The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant Deposition of plaintiff(s) TBD Defendant Depositions of treating physicians TBD Defendant Expert Discovery Per Code c. ‰ 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 Shee, Frank CM-110 PLAINTIFF/PETITIONER: FRANK SHEE CASE NUMBER: 21-CV-00632 DEFENDANT/RESPONDENT: ALBERT BOLANOS, ET AL 17. Economic litigation a. ‰ This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. ‰ This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues ‰X The party or parties request that the following additional matters be considered or determined at the case management conference (specify): Defendant ALBERTO BOLANOS MD has filed a Motion to Strike, set for hearing on August 23, 2021. Have not received any indication that co-defendant Mills Peninsula has appeared. 19. Meet and confer a. ‰ The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: May 25, 2021 James J. Zenere (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) ‰ Additional signatures are attached. CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5 Shee, Frank 1 CASE NAME: SHEE v. BOLANOS, et al ACTION NO. 21-CV-00632 2 PROOF OF SERVICE [CCP §§ 1012.5, 1013a and 2015.5; CRC 2008] 3 I am a citizen of the United States. My business address is 1033 Willow Street, San Jose, 4 CA 95125. I am employed in Santa Clara County where this service occurred. I am over the age of 18 years and not a party to the within cause. I am readily familiar with my employer's normal 5 business practice for collection and processing of correspondence for mailing and facsimile. In the case of mailing [other than overnight delivery], the practice is that correspondence is 6 deposited in the U.S. Postal Service the same day as the day of collection in the ordinary course of business. 7 On May 25, 2021, I served the within CASE MANAGEMENT STATEMENT 8 on the PARTIES in said action as follows: 9 Frank Shee 105 Lucca Drive 10 South San Francisco, CA 94080 Tel: (650) 438-5897 11 frankshee03@yahoo.com 12 X (BY MAIL) I caused a true copy of each document identified above to be placed in a 13 sealed envelope with first-class postage affixed. Each such envelope was deposited for collection and mailing that same day in the ordinary course of business in the United States mail at San 14 Jose, California. 15 (BY PERSONAL SERVICE) I caused a true copy of each document identified above to be delivered by hand to the offices of each addressee above. 16 (BY OVERNIGHT DELIVERY) I caused a true copy of each document identified above 17 to be sealed in an envelope to be delivered to an overnight carrier with delivery fees provided for, addressed of each addressee above. 18 X (BY-E-MAIL OR ELECTRONIC TRANSMISSION) Based on a court order or an 19 agreement of the parties to accept service by e-mail or electronic transmission, I caused the document(s) to be sent to the persons at the e-mail address listed above. I did not receive, within 20 a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. 21 X (BY ELECTRONIC SERVICE) I caused each of the above-named documents to be 22 delivered by email to the parties via One Legal E-Service upload link. 23 X (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 24 (FEDERAL) I declare that I am employed in the office of a member of the bar of this court 25 at whose direction the service was made. 26 Diane Point 27 28