Preview
CM-110
"ATTORNEY OR PARTY WATHOUT ATTORNEY (Name, S810 BEF AUMDOT, On BOTTOSST. FOR COURT USE ONLY
Bevin Alten Pike (SBN 221936); Orlando Villalba (SBN 232165)
Capstone Law APC
1875 Century Park East, Los Angeles, CA 90067
‘yevepHone No.. (310) 556-4811 FAX NO, (Optional: (310) 493-0396
E-MAIL ADDRESS (Optional.
ATTORNEY FOR (Nemo! Plaintiff Mishelte Neverson
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Joaquin VW
srreeT appress: 180 E, Weber Ave,
mauinc adores: 180 E, Weber Ave.
erry aNd21P cove: Stockton, 95202
BRANCH NAME: Stockton Courthouse.
PLAINTIFF/PETITIONER: Mishelle Neverson
DEFENDANT/RESPONDENT: Brookdale Senior Living, Inc., et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): (Z] UNLIMITED CASE [5 umitep case STK-CV-UOE-2017-4356
(Amount demanded (Amount demanded is $25,000
exceeds $26,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: May 20, 2020 Time: 9:45 a.m. Dept: 10B Div: - Room: -
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Bevin Allen Pike
INSTRUCTIONS: All applicable boxes must be checked, and the specified Information must be provided.
1. Party or parties (answer one):
a. [7] This statement is submitted by party (name): Plaintiff Mishelle Neverson
b. [1] 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): May 1, 2017
b. [J The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a 4 ai parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [7] The following parties named in the complaint or cross-complaint
(1) [21 have not been served (specify names and explain why not):
(2) (J have been served but have not appeared and have not been dismissed (specify names):
(3) [1 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 date by which
they may be served):
4. Description of case
a. Type of case in complaint [—] cross-complaint (Describe, including causes of action):
Representative enforcement action under the Private Attorneys General Act of 2004, Cal. Labor Code 2698, et
seq. ("PAGA’). Plaintiff seeks civil penalties for various violations of the California Labor Codes.
Page tots
Foam Adora for Mangatery Ute CASE MANAGEMENT STATEMENT Gal, Rules of Court
(CM-110 (Rev. July 4, 2014} mecouriece gor
FILED BY FAXo
CM-110
PLAINTIFF/PETITIONER: Mishelle Neverson CASE NUMBER: 017-4986
DEFENDANT/RESPONDENT: Brookdale Senior Living, Inc., et al. STK-CV-UOE-2017-
4. b. Provide a brief statement of the case, including any damages. (if personal injury damages ere sought, specify the injury and
damages claimed, including medical expenses to date [indicate source end amount), estimated future medical expenses, lost
gamings to date, and estimated future lost earings. if equitable relief is sought, describe the nature of the relief.)
Plaintiff's PAGA claim relates to underlying Labor Code violations tor unpaid overtime, unpaid minimum wages,
failure to provide meal and rest perlods or premium payments, non compliant wage statements, requiring
employees to pay for cost of medical or physical examination, faiiure to reimburse business expenses, and failure
to provide notice of the material terms of employment, Plaintiff seeks civil penalties under PAGA.
() (it more space is needed, check this box and attach @ page designated as Atfachment 4b.)
5. Jury or nonjury tral
‘The party or parties request
requesting a jury trial):
a jury trial [2 anonjury trial. (if more than one party, provide the name of each party
6. Trial date
a. (_] The wial has been set for (date):
b. CZ No tral 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):
Plaintiff anticipates discovery related to all aggrieved employees will require a trial date beyond 12 months.
¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
7. Estimated length of triat
The party or parties estimate that the trial will take (check one):
a. [41 days (specify number): 15-20 days
b. [_] hours (short causes) (specify):
8. Trial representation (to be answared for each party) . .
‘The party or parties will be represented at trial [J by the attomey or party listed in the caption [__] by the following:
a. Attorney:
b. Firm:
c, Address:
d. Telephone number: f, Fax number:
e. €-mail address: g. Party represented:
{1 Additional representation is described in Attachment 8.
9. Preference
[1 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 (7 has [21 hasnot 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 [5 hes [1 has not reviewed the ADR information package identified in cule 3.221.
b, Referral to judicla! arbitration or clyll action mediation (if available).
(1) (2) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mecer ee ‘ode of Civil Protedure section 1775.3 because the amount in controversy does not exceed the
imit.
(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 Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (Specify exemption):
Cae Rav day CASE MANAGEMENT STATEMENT - Page Zott
CM-110
PLAINTIFF/PETITIONER: Mishel for ovt
Mishelle Neverson STK-CV-UOE-2017-4356
DEFENDANT/RESPONDENT: Brookdale Senior Living, Inc., et al.
10. ¢, Indicate the ADR process or processes that the party of parties are willing to participate in, have agreed to participate in, or
have already participated in (check aif 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 ail that apply): | stipulation):
Mediation session not yet scheduled
wm Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date): Sept. 11, 2018
Settlement conference not yet scheduled
(2) Settlement Cc Settlement conference scheduled for (date):
conference Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
(2) Neutral evaluati oOo Neutral evaluation scheduled for (date):
jeutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date): ”
Judicial arbitration not yet scheduled
(4) Nonbinding judicial oO 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 oOo 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 (specity): oo ADR session scheduled for (date): :
OOO; O000/O000/0O000/0000);8000
Agreed to complete ADR session by (date):
(7) ADR completed on (date):
(CM-110 (Rev. July 1, 2071) ° Pagesofs
CASE MANAGEMENT STATEMENTCM-110-
CASE NUMBER;
PLAINTIFF/PETITIONER: + Mishelle Neverson
STK-CV-UOE-2017-4356
DEFENDANTIRESPONDENT: Brookdale Senior Living, Inc., at al.
41, Insurance
a. [__] insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: [7] Yes No
c. (J 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.
[J Bankruptey [1 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:
(J Additional cases are described in Attachment 13a.
pb. [_JAmotionto [__] consolidate [7] coordinate will be filed by (name party):
14, Bifurcation
[1] 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
(Z The panty or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Plaintiff reserves the right to file a Motion for Summary Judgment or Summary Adjudication if discovery
warrants, :
16. Discovery
a. ("J The party or parties have completed all discovery.
b. [7] The following discovery will be completed by the date specified (describe ail anticipated discovery):
Party Description Date
Plaintiff PMQ Depositions July 2020
«7 The following discovery issues, including issues regarding the discovery of electronically stared information, are
anticipated (specify): :
CH Row ay 1, 2010] _ CASE MANAGEMENT STATEMENT Page aorCM-110
PLAINTIFFIPETITIONER: — Mishelle Neverson CASE NUMBER
STK-CV-UOE-2017-4356
DEFENDANT/RESPONDENT: Brookdale Senior Living, Inc., et al.
17. Economic litigation
a, [__] This is a limited civil case (i.¢., 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 anc 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
(7) the party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
Plaintiff was notified of Defendants settlement in Callahan v, Brookdale Senior Living Communities, inc., et al.
Plaintiff has attempted to request more information regarding the settlement's terms, however, Defendants’
counsel and Callahan's counsel have both declined to provide any information about the settlement. Plaintiff
has fited a notice of intent to intervene in Callahan and will most likely object.
19, Meet and confer
The party or parties have met and conferred with all Parties 0 on ail 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 pares agree on the following
(spacity):
20. Total number of pages attached (if any):
lam 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 5, 2020
Bevin Allen Pike > BoM te
(TYPE OR PRINT NAME)
(SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
[1] Additional signatures are attached.
CM-140 [Rav. duly 4, 2011]
CASE MANAGEMENT STATEMENT Page 5018PROOF OF SERVICE
T am employed in the State of California, County of Los Angeles. I am over the age of
18 and not a party to the within suit; my business address is 1875 Century Park East, Suite 1000
Los Angeles, California 90067.
On May 5, 2020, I served the document(s) described as: CASE MANAGEMENT
STATEMENT on the interested parties in this action by sending [ _] the original [or] [“] a true copy
thereof [¥] to interested parties as follows [or] [ ] as stated on the attached service list:
J. KEVIN LILLY, Bar No. 119981 Attorneys for Defendants
klilly@littler.com BROOKDALE SENIOR LIVING
SHANNON R. BOYCE, Bar No. 229041 COMMUNITIES, INC. and
SBoyce@littler.com EMERITUS CORPORATION
LITTLER MENDELSON, P.C.
2049 Century Park East, 5th Floor
Los Angeles, CA 90067.31 07
Telephone: 310.553.0308
Fax No. : 310,553.5583
JEFFREY J. MANN, Bar No. 253440
JMann@littler.com
LITTLER MENDELSON, P.C.
Treat Towers
1255 Treat Boulevard, Suite 600
Walnut Creek, CA 94597
Telephone; 925.932.2468
[ ] BY MAIL (ENCLOSED IN A SEALED ENVELOPE): I deposited the envelope(s)
for mailing in the ordinary course of business at Los Angeles, California. I am “readily
familiar” with this firm’s practice of collection and processing correspondence for
mailing. Under that practice, sealed envelopes are deposited with the U.S. Postal
Service that same day in the ordinary course of business with postage thereon fully
prepaid at Los Angeles, California.
[X] BY E-MAIL: I hereby certify that this document was served from Los Angeles,
California, by e-mail delivery on the parties listed herein at their most recent known e-
mail address or e-mail of record in this action.
[ ] BY FAX: L hereby certify that this document was served from Los Angeles, California,
by facsimile delivery on the parties listed herein at their most recent fax number of
record in this action.
[ ] BY PERSONAL SERVICE: | delivered the document, enclosed in a sealed envelope,
by hand to the counsel for Defendant.
‘it
‘1
PROOF OF SERVICE[ ] BY OVERNIGHT DELIVERY: I am “readily familiar” with this firm’s practice of
collection and processing correspondence for overnight delivery. Under that practice,
overnight packages are enclosed in a sealed envelope with a packing slip attached
thereto fully prepaid. The packages are picked up by the carrier at our offices or
delivered by our office to a designated collection site.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct. Executed on May 5, 2020 at Los Angeles, California.
Xochit! Tapia x Lz =
Type/Print Name Signature
PROOF OF SERVICE
Preview
CM-110 "ATTORNEY OR PARTY WATHOUT ATTORNEY (Name, S810 BEF AUMDOT, On BOTTOSST. FOR COURT USE ONLY Bevin Alten Pike (SBN 221936); Orlando Villalba (SBN 232165) Capstone Law APC 1875 Century Park East, Los Angeles, CA 90067 ‘yevepHone No.. (310) 556-4811 FAX NO, (Optional: (310) 493-0396 E-MAIL ADDRESS (Optional. ATTORNEY FOR (Nemo! Plaintiff Mishelte Neverson SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Joaquin VW srreeT appress: 180 E, Weber Ave, mauinc adores: 180 E, Weber Ave. erry aNd21P cove: Stockton, 95202 BRANCH NAME: Stockton Courthouse. PLAINTIFF/PETITIONER: Mishelle Neverson DEFENDANT/RESPONDENT: Brookdale Senior Living, Inc., et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): (Z] UNLIMITED CASE [5 umitep case STK-CV-UOE-2017-4356 (Amount demanded (Amount demanded is $25,000 exceeds $26,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 20, 2020 Time: 9:45 a.m. Dept: 10B Div: - Room: - Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Bevin Allen Pike INSTRUCTIONS: All applicable boxes must be checked, and the specified Information must be provided. 1. Party or parties (answer one): a. [7] This statement is submitted by party (name): Plaintiff Mishelle Neverson b. [1] 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): May 1, 2017 b. [J The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a 4 ai parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [7] The following parties named in the complaint or cross-complaint (1) [21 have not been served (specify names and explain why not): (2) (J have been served but have not appeared and have not been dismissed (specify names): (3) [1 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 date by which they may be served): 4. Description of case a. Type of case in complaint [—] cross-complaint (Describe, including causes of action): Representative enforcement action under the Private Attorneys General Act of 2004, Cal. Labor Code 2698, et seq. ("PAGA’). Plaintiff seeks civil penalties for various violations of the California Labor Codes. Page tots Foam Adora for Mangatery Ute CASE MANAGEMENT STATEMENT Gal, Rules of Court (CM-110 (Rev. July 4, 2014} mecouriece gor FILED BY FAXo CM-110 PLAINTIFF/PETITIONER: Mishelle Neverson CASE NUMBER: 017-4986 DEFENDANT/RESPONDENT: Brookdale Senior Living, Inc., et al. STK-CV-UOE-2017- 4. b. Provide a brief statement of the case, including any damages. (if personal injury damages ere sought, specify the injury and damages claimed, including medical expenses to date [indicate source end amount), estimated future medical expenses, lost gamings to date, and estimated future lost earings. if equitable relief is sought, describe the nature of the relief.) Plaintiff's PAGA claim relates to underlying Labor Code violations tor unpaid overtime, unpaid minimum wages, failure to provide meal and rest perlods or premium payments, non compliant wage statements, requiring employees to pay for cost of medical or physical examination, faiiure to reimburse business expenses, and failure to provide notice of the material terms of employment, Plaintiff seeks civil penalties under PAGA. () (it more space is needed, check this box and attach @ page designated as Atfachment 4b.) 5. Jury or nonjury tral ‘The party or parties request requesting a jury trial): a jury trial [2 anonjury trial. (if more than one party, provide the name of each party 6. Trial date a. (_] The wial has been set for (date): b. CZ No tral 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): Plaintiff anticipates discovery related to all aggrieved employees will require a trial date beyond 12 months. ¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of triat The party or parties estimate that the trial will take (check one): a. [41 days (specify number): 15-20 days b. [_] hours (short causes) (specify): 8. Trial representation (to be answared for each party) . . ‘The party or parties will be represented at trial [J by the attomey or party listed in the caption [__] by the following: a. Attorney: b. Firm: c, Address: d. Telephone number: f, Fax number: e. €-mail address: g. Party represented: {1 Additional representation is described in Attachment 8. 9. Preference [1 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 (7 has [21 hasnot 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 [5 hes [1 has not reviewed the ADR information package identified in cule 3.221. b, Referral to judicla! arbitration or clyll action mediation (if available). (1) (2) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mecer ee ‘ode of Civil Protedure section 1775.3 because the amount in controversy does not exceed the imit. (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 Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (Specify exemption): Cae Rav day CASE MANAGEMENT STATEMENT - Page Zott CM-110 PLAINTIFF/PETITIONER: Mishel for ovt Mishelle Neverson STK-CV-UOE-2017-4356 DEFENDANT/RESPONDENT: Brookdale Senior Living, Inc., et al. 10. ¢, Indicate the ADR process or processes that the party of parties are willing to participate in, have agreed to participate in, or have already participated in (check aif 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 ail that apply): | stipulation): Mediation session not yet scheduled wm Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): Sept. 11, 2018 Settlement conference not yet scheduled (2) Settlement Cc Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled (2) Neutral evaluati oOo Neutral evaluation scheduled for (date): jeutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): ” Judicial arbitration not yet scheduled (4) Nonbinding judicial oO 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 oOo 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 (specity): oo ADR session scheduled for (date): : OOO; O000/O000/0O000/0000);8000 Agreed to complete ADR session by (date): (7) ADR completed on (date): (CM-110 (Rev. July 1, 2071) ° Pagesofs CASE MANAGEMENT STATEMENTCM-110- CASE NUMBER; PLAINTIFF/PETITIONER: + Mishelle Neverson STK-CV-UOE-2017-4356 DEFENDANTIRESPONDENT: Brookdale Senior Living, Inc., at al. 41, Insurance a. [__] insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: [7] Yes No c. (J 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. [J Bankruptey [1 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: (J Additional cases are described in Attachment 13a. pb. [_JAmotionto [__] consolidate [7] coordinate will be filed by (name party): 14, Bifurcation [1] 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 (Z The panty or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Plaintiff reserves the right to file a Motion for Summary Judgment or Summary Adjudication if discovery warrants, : 16. Discovery a. ("J The party or parties have completed all discovery. b. [7] The following discovery will be completed by the date specified (describe ail anticipated discovery): Party Description Date Plaintiff PMQ Depositions July 2020 «7 The following discovery issues, including issues regarding the discovery of electronically stared information, are anticipated (specify): : CH Row ay 1, 2010] _ CASE MANAGEMENT STATEMENT Page aorCM-110 PLAINTIFFIPETITIONER: — Mishelle Neverson CASE NUMBER STK-CV-UOE-2017-4356 DEFENDANT/RESPONDENT: Brookdale Senior Living, Inc., et al. 17. Economic litigation a, [__] This is a limited civil case (i.¢., 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 anc 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 (7) the party or parties request that the following additional matters be considered or determined at the case management conference (specify): Plaintiff was notified of Defendants settlement in Callahan v, Brookdale Senior Living Communities, inc., et al. Plaintiff has attempted to request more information regarding the settlement's terms, however, Defendants’ counsel and Callahan's counsel have both declined to provide any information about the settlement. Plaintiff has fited a notice of intent to intervene in Callahan and will most likely object. 19, Meet and confer The party or parties have met and conferred with all Parties 0 on ail 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 pares agree on the following (spacity): 20. Total number of pages attached (if any): lam 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 5, 2020 Bevin Allen Pike > BoM te (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) [1] Additional signatures are attached. CM-140 [Rav. duly 4, 2011] CASE MANAGEMENT STATEMENT Page 5018PROOF OF SERVICE T am employed in the State of California, County of Los Angeles. I am over the age of 18 and not a party to the within suit; my business address is 1875 Century Park East, Suite 1000 Los Angeles, California 90067. On May 5, 2020, I served the document(s) described as: CASE MANAGEMENT STATEMENT on the interested parties in this action by sending [ _] the original [or] [“] a true copy thereof [¥] to interested parties as follows [or] [ ] as stated on the attached service list: J. KEVIN LILLY, Bar No. 119981 Attorneys for Defendants klilly@littler.com BROOKDALE SENIOR LIVING SHANNON R. BOYCE, Bar No. 229041 COMMUNITIES, INC. and SBoyce@littler.com EMERITUS CORPORATION LITTLER MENDELSON, P.C. 2049 Century Park East, 5th Floor Los Angeles, CA 90067.31 07 Telephone: 310.553.0308 Fax No. : 310,553.5583 JEFFREY J. MANN, Bar No. 253440 JMann@littler.com LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard, Suite 600 Walnut Creek, CA 94597 Telephone; 925.932.2468 [ ] BY MAIL (ENCLOSED IN A SEALED ENVELOPE): I deposited the envelope(s) for mailing in the ordinary course of business at Los Angeles, California. I am “readily familiar” with this firm’s practice of collection and processing correspondence for mailing. Under that practice, sealed envelopes are deposited with the U.S. Postal Service that same day in the ordinary course of business with postage thereon fully prepaid at Los Angeles, California. [X] BY E-MAIL: I hereby certify that this document was served from Los Angeles, California, by e-mail delivery on the parties listed herein at their most recent known e- mail address or e-mail of record in this action. [ ] BY FAX: L hereby certify that this document was served from Los Angeles, California, by facsimile delivery on the parties listed herein at their most recent fax number of record in this action. [ ] BY PERSONAL SERVICE: | delivered the document, enclosed in a sealed envelope, by hand to the counsel for Defendant. ‘it ‘1 PROOF OF SERVICE[ ] BY OVERNIGHT DELIVERY: I am “readily familiar” with this firm’s practice of collection and processing correspondence for overnight delivery. Under that practice, overnight packages are enclosed in a sealed envelope with a packing slip attached thereto fully prepaid. The packages are picked up by the carrier at our offices or delivered by our office to a designated collection site. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on May 5, 2020 at Los Angeles, California. Xochit! Tapia x Lz = Type/Print Name Signature PROOF OF SERVICE