Preview
To: +15102675732 Page: 2 of 8 2021-09-08 17:00:45 GMT From: Tod Rattield
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Neme, Siete Bar number, and address): | SOR COURT USE ONLY
Tod M. Ratfield (148845) FILED BY E-DELIVERY
Tod M. Ratfieid, APC ALAMEDA COUNTY
1233 Alpine Road, Walnut Creek, CA 94596 : September 08, 2021
veLepione no. (925) 934-3300 FAX NO. (Optional: (925) OR44775 CLERK OF
E-Mail ADDRESY Optra: todratfleld @yahoo.com THE SUPERIOR COURT
’ 5 By Elaine Jefferson, Deputy
ATTORNEY FOR iNemex Cala International, ine.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Alameda CASE NUMBER:
greeeranoress: 24405 Amador Street RG19002887
MAILING ADDRESS:
CITY ANO ZIP COBE: Hayward, CA O46544
BRANCH NAME Kavward Mall of Justice
PLAINTIFFPETITIONER: Gala International, Inc.
GEFENDANTIRESPONOENT: Benito Valley Farm, LLC, et al.
CASE MANAGEMENT STATEMENT GAGE NUMBER:
(Check one): [27] UNLIMITED case {"] wmrrep case RG19002887
Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
ACASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: September 27, 2021 Time: 2:30 pry Dept: 518 Biv: Room:
Address of court (f differant fram the address above):
Notice of Intent to Appear by Telephone, by (name: Tod M. Ratfield
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
4. Party or parties (answer one):
a. This statement is submitted by party (mare): Gala international, inc.
b. [22] This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (fo be answered by plaintiffs and cross-cormplainants only}
a. The complaint was fled on (dale): 1/46/19 - 4/15/19
b, EE the cross-compiaing, if any, was filed on jdate):
Service flo be answered by plaintiffs and cross-compiainants onfy)
oe
a Cl] at parties named in the complaint and cross-compiaint have been served, have appeared, or have been dismissed.
b. [] The following parties named in the complaint or cross-compiaint
at) £2] have not been saved (specify names and explain why nog:
@) [Z") have been served bui have not appeared and have net been dismissed (specify names):
re) have had a default entered against them (specify names):
Default entered as to Defendants Ne & Berite Family Fann, LLC on 10/8/19
c. } The following additional parties may be added (specify names, nature of involvement in case, and date Sy whink
they may be served):
4. Oescription of case —
a. Typectcasein [V7] complaint [i] cross-complaint (Describe, including causes of action):
Breach of Contract, Avaidanos of Creditors, Reasonable Value of Services, ancl Account Stated/Book Account
Page iots
om felon
“ fo: thadatory ‘ les CASE MANAGEMENT STATEMENT Gal,rulesRatesof Court
BP ad 730
OM-@ 10 [Rev, July 7, 20011
store CUTE oa Re
To: +15102675732 Page: 3 of 8 2021-09-08 17:00:45 GMT From: Tod Rattield
cH-11d
PLAINTIFEPETITIONER: Gala International, inc. GABE NUMBER:
- F RG19002887
DEFENDANT/RESPONDENT: Benito Valley Farm, LLC, et al.
4, 6. Provide a brief siatement of the case, including any Gamages. (if personal injury damages are sought, specify the infury and
damages claimed, including medical expenses to date findicate source and amount] estimated fulure medical expanses, lost
samings fo date, and estimeted future jost eamings. if equitable relief is sought, describe the nature of the relief)
Collection of unpaid invoices for specially manufactured good for Defendants. Damages sought are $76,139.64
plus interest at the legal rate of $8,906.30, and attomey's fees pursuant to CC section 1717.5 of $1,200.
[X"] (more snace is needed, check tig box and allach a page designated ag Attachment 4b.)
§. dury or nonjury vial ;
The party or parties request [7] a jury trial anonjury tial. {more than one party, provide the name of each party
requesting a jury trial}:
6 rial date . :
a. [27] The tral has been set for (date): TBD - Motion pending
o CU No trial date has been set. This case will be reacly for irial within 12 months of the date of the filing of the complaint of
nol, explain):
@ Dates on which parties or attorneys will not be available for trial (apenily deies end explain reasans fer unavailability}:
October 8-30, 2021 Vacation; April 15-May 16, 2022, Vacation
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [2] days (specify number): 1
o. [7] hours (short causes} (specify):
8. Trial representation (lo be answered for each party}
The party or parties will be represented at tial [70] by the attorney or party listed in the caption [7] by the following:
a. Afforney:
Bb. Firm:
&. Address:
d. Telephone number: f. Fax number:
e, E-mail address: g. Party represented:
(CU Auditional representation is desorbed In Attachment 8.
§. Preference
(CT] | This case is entitled to preference (apecity code section):
10, Alternative dispute resolution (ADR}
@ ADR information package, Please note that different ADR processes are availabie in different courts arid communities; read
the ADR information package provided by the court under rule 3.221 for Infermation about the processes available trough the
sourt and community programs in this case.
(1) For parties represented by counsel: Counsel has Co] has not provided the ADR. information package identified
in rulé 3.221 te the client and reviewed ADR options with the cllent.
(2) For self-represented parties: Party (l has [7] has not reviewed the ADR information package identified in rule 3.221.
& Referral to judicial arbitration or civil action mediation (if available).
i) | This matter is subject to mandatory judicial arbitration under Cade of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1778.3 because the amount in controversy does not exceed the
statutory Umit.
(2) [I] Plaintiff elects to refer this case to Judicial arbitration and agrees to limit recovery fo the amount specified in Code of
Civil Procedure section 1141.11.
3} | This case is exempt from judicial arbitration under nile 3.911 of the California Rules of Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CMATO (av. Jay 3, 2074 GASE MANAGEMENT STATEMENT Page Rot &
To: +15102675732 Page: 4 of 8 2021-09-08 17:00:45 GMT From: Tod Rattield
CR-110
| PLAINTIFF/PETITIONER: Gala International, inc. GABE NUMBER:
DEFENDANT/RESPONDENT: Benito Valley Farm, LLC, et al. RE19002867
10. 6, Indicate the ADR precess or processes that the parly or parties are willing tc participate in, have agreed to participate in, or
have already participated in (eheck aff hat apply and provide the specified information):
The party or parties completing | if the party er parties completing this form in the case have agreed to
this form are willing to participate in or have already completed en ADR process or processes,
participate In the following ADR | Indicate the status of the processes (attach a copy of the parties’ ADR
processes (check aff that apply): | stipulation):
Mediation session not yet scheduled
| Medietion session scheduled for (deie):
(f) Mediation a
[=] Agreed to complete mediation by (date):
[2] Mediation completed on (dafe}:
KEI Settlement conference nat yet scheduled
(2) Settlement cc C—J Settlement conference scheduled for (Wate):
conference CI Agreed to complete settlement conference by (gafe):
EZ] Settlement conference completed on (date):
[=] Neutral evaluation not yet scheduled
; C7 C1 Neutral evaiuation scheduled for (date):
(3) Neutral evaluation
cl Agreed io complete neutral evaluation by (date):
Zz, Neutral evaluation completed on (date):
[EE] Judicial arbitration nat yet scheduled
(4) Nonbinding judicial cc EE] Jusicial arbitration scheduled for (date):
arbitration C7) Agreed to complete judicial arbitration by (date),
[=] Judicial arbitration completed on (date):
(22) Private arbitration not yet scheduled
) Binding private cc KEI Private arbitration echeduled for (date):
arbitration CI Agreed to. complete private arbitration by (ceie):
CC] Frivate arbitration completed on (date):
[=] ADR session not yet scheduled
ct [=] ADR session scheduled for (date):
(6) Other (speci):
(1 Agreed to complete ADR session by (date):
[=] ‘ADR completed on (ater:
CMG iRev. July €, 2044]
CASE MANAGEMENT STATEMENT Page sare
To: +15102675732 Page: 5 of 8 2021-09-08 17:00:45 GMT From: Tod Ratfield
CMet10
PLAINTIFF/PETITIONER: Gala International, inc. GASE NUMBER:
- ; RG 19002687
DEFENDANTIRESPONDENT: Benito Valley Farm, LLC, et al.
44. Insurance
a. [<7] insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: (“J yes CUI Ne
« Co Coverage issues will significantly affect resolution of this case (explain):
12. Juriadiction
indicate any matters that may affect the court's juriadiction or processing of this case and describe the status.
[TI Bankeuptey CO Other (epecityi:
Status:
13, Related cases, consolidation, and coordination
a, CUT) There are companion, underlying, or related cases,
(4) Name of case:
(2 Name of court:
(3 Case number:
(45 Status:
IX Additional cases are described in Atachment 13a.
». (Cl Amotionto [] consoste [7] coordinate will be filed by (name party):
14. Bifurcation
(] The party or parties interns! 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
[x0] the party or parties expect to file the following motions before trial (speci moving party, hype of motion, and Issues;:
Plaintiff was reinstated August 26, 2021. Plaintiff will be filing a Mation to Compel discovery and to strike
Defendant Corp's answer given it has refused to obtain counsel.
16, Discovery
a. ("| The parly or parties have completed all discovery.
». [77] The tollowing discovery will be completed by the date specified (clescribe alf anticipated discovery):
Party Besoriotion Date
Plaintiff Written Discovery May 2027
Plaintiff Depositions dune 2024
G. The following discovery issues, including issues regarding the diecavery of electronically stored information, are
anticipated (speci):
The Flaintiff is anticipating having io file a Motion to Cornpel since discovery responses were due per an
extension on May 20, 2021.
OM110 flav. July 1, 2014] CASE MANAGEMENT STATEMENT Page
4 od &
To: +15102675732 Page: 6 of 8 2021-09-08 17:00:45 GMT From: Tod Rattield
CM-116
PLAINTIFF/PETITIONER: Gala International, Inc, CASE NUMBER:
— RG
DEFENDANTRESPONDENT. Benilo Valley Farm, LLC, at al, 619002887
47. Economic ligation
a. (__] This is a lieved civil case (.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Givi Procedure sections &)-86 will apply to this case.
b. [_] This is a limited civil case and @ motion to withdraw the case from the economils litigation procedures or for additional
discovery will be filed (f checked, explain specifically why economic Higation procedures relating fe discovery or tial
shoud 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 (saecify):
19, Meet and confer
a. (C7! The party ov 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}:
| will attempt to meet & confer prior to the CMC. However, | have been unable to reach the Defendant.
b. Afier meeting and conferring as required by rule 2.724 of the California Rules of Court, the parties agree on the jollowing
fspechfy}:
20. Total number of pages atlached (ff any):
lar completely familiar with this cage and will be fully prepared to discuss the status of discovery and altemative dispute resciution,
as well ag other issues raised by this statement, and will possess the authority to enter into stipulations on these iasues at the time of
the case management conference, including the written authorily of the party where required.
Date: September 7, 2021
Tod M. Ratfield >
CTYPE OR PRINT NAME) (SIGNATURE OF BARTY OR ATTORNEY)
LYRE OF PRINT NABME) (SIGNATURE OF PARTY OR ATTORREY)
["] Additional signatures are attached.
Ome1O fav. ay 3 2040 CASE MANAGEMENT STATEMENT page sore
To: +15102675732 Page: 7 of 8 2021-09-08 17:00:45 GMT From: Tod Ratfield
3
PROOF OF SERVICE
2 [C.C.P, Section 1013, 2015.8, 2009]
3
i, the undersigned, declare that I am 2 citizen of the Untied States, a resident of the State
4 | of California, and am employed in the County of Contra Costa, State of California. Lam over
eighteen (18) years of age and not a party to the above-entitled action. My business address is
1233 Alpine Road, Walnut Creek, California. On the date below, I served the following
an
document(s) in the manner indicated below on the person(s) listed below:
7 CASE MANAGEMENT STATEMENT
as F
8 ‘
_ BY UNITED STATES MAIL: I enclosed the document in a sealed envelope or
8 package addressed to the persons at the addresses listed below and placed the
envelope/package for coliection and mailing, following our ordinary business
16 practices. I am readily familiar with this business’s practice for collection and
raailing, it is deposited in the ordinary course of business with the United States
i Postal Service, in a sealed envelope with postage fully prepaid. I am aware that on
motion of the party served, service is presumed invalid if postal cancellation date or
12 postage meter date is more than one day after the date of deposit for mailing an
affidavit.
13
lam a resident or employed in the county where the mailing occurred. The envelope
14 or package was placed in the mail at Angwin, California.
is ee BY FAX TRANSMISSION: Based on an agreement of the parties to accept
service by fax transmission, I faxed the documents to the persons at the fax numbers
16 listed below. No error was reported by the fax machine that Ll used. A copy of the
revord of the fax iransmission, which | printed out is attached.
oe BY OVERNIGHT DELIVERY: | enclosed the documents in an envelope or
18 package provided by an overnight delivery carrier and addressed to the persons at the
addresses listed below. I place the envelope or package for collection and overnight
2g delivery at an office or a regularly utilized drop box of the overnight delivery carrier.
28 BY PERSONAL SERVICE: I personally served the documents to the persons at
the addresses listed below. (1) for a party represented by an attorney, delivery was
a4 made to the attomey or al the attorney’s office by leaving the documents in an
envelope or package clearly labeled to identify the attorney being served with the
22 receptionist or an individual in charge of the office. (2) Fora party, delivery was
made io the party or by leaving the documents at the party’s residence with some
23 person not less than 18 years of age between the hours of eight in the morning and
six in the evening.
24
a BY MESSENGER SERVICE: | served the documents by placing them in an
25 envelope or package addressed to the persons at the addresses listed above and
26
Proof of Service
To: +15102675732 Page: 8 of 8 2021-09-08 17:00:45 GMT From: Tod Rattield
providing them to a professional messenger service for service (4 declaration by the
1 messenger must accompany this Proofof Service)
. BY E-MAIL OR ELECTRONIC TRANSMISSION: Based on a court order
or ani agreenient of the parties to accept service by e-mail or electronic transmission,
3 I caused the documents to be sent to the persons at the e-mail addressed listed below.
i did not receive, within a reasonable time alter the transmission, an electronic
4 message or other indication that the transmission was unsuccessful.
g
Linda Chu
® 118953 Ironbark Street
+ CHiroy, CA. 95026
Phone: (831) 902-6590
g | Cells (831) 902-6589
E-Mail: Undachy3333@email cor
ia || Benito Valley Farms, Inc.
8953 lronbark Street
1) Gilroy, CA 95020
42
as I declare under penalty of perjury under the laws of the State of California that the above
14 {is true and correct. Executed this PAA day of secs beer, 2021 at Anpwin,
California.
46
a)
ta Kristine Gromacki
18
20
2h
22
23
tu
it
eo
oF
bo
Proof of Service
Preview
To: +15102675732 Page: 2 of 8 2021-09-08 17:00:45 GMT From: Tod Rattield CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Neme, Siete Bar number, and address): | SOR COURT USE ONLY Tod M. Ratfield (148845) FILED BY E-DELIVERY Tod M. Ratfieid, APC ALAMEDA COUNTY 1233 Alpine Road, Walnut Creek, CA 94596 : September 08, 2021 veLepione no. (925) 934-3300 FAX NO. (Optional: (925) OR44775 CLERK OF E-Mail ADDRESY Optra: todratfleld @yahoo.com THE SUPERIOR COURT ’ 5 By Elaine Jefferson, Deputy ATTORNEY FOR iNemex Cala International, ine. SUPERIOR COURT OF CALIFORNIA, COUNTY OF Alameda CASE NUMBER: greeeranoress: 24405 Amador Street RG19002887 MAILING ADDRESS: CITY ANO ZIP COBE: Hayward, CA O46544 BRANCH NAME Kavward Mall of Justice PLAINTIFFPETITIONER: Gala International, Inc. GEFENDANTIRESPONOENT: Benito Valley Farm, LLC, et al. CASE MANAGEMENT STATEMENT GAGE NUMBER: (Check one): [27] UNLIMITED case {"] wmrrep case RG19002887 Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) ACASE MANAGEMENT CONFERENCE is scheduled as follows: Date: September 27, 2021 Time: 2:30 pry Dept: 518 Biv: Room: Address of court (f differant fram the address above): Notice of Intent to Appear by Telephone, by (name: Tod M. Ratfield INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 4. Party or parties (answer one): a. This statement is submitted by party (mare): Gala international, inc. b. [22] This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (fo be answered by plaintiffs and cross-cormplainants only} a. The complaint was fled on (dale): 1/46/19 - 4/15/19 b, EE the cross-compiaing, if any, was filed on jdate): Service flo be answered by plaintiffs and cross-compiainants onfy) oe a Cl] at parties named in the complaint and cross-compiaint have been served, have appeared, or have been dismissed. b. [] The following parties named in the complaint or cross-compiaint at) £2] have not been saved (specify names and explain why nog: @) [Z") have been served bui have not appeared and have net been dismissed (specify names): re) have had a default entered against them (specify names): Default entered as to Defendants Ne & Berite Family Fann, LLC on 10/8/19 c. } The following additional parties may be added (specify names, nature of involvement in case, and date Sy whink they may be served): 4. Oescription of case — a. Typectcasein [V7] complaint [i] cross-complaint (Describe, including causes of action): Breach of Contract, Avaidanos of Creditors, Reasonable Value of Services, ancl Account Stated/Book Account Page iots om felon “ fo: thadatory ‘ les CASE MANAGEMENT STATEMENT Gal,rulesRatesof Court BP ad 730 OM-@ 10 [Rev, July 7, 20011 store CUTE oa Re To: +15102675732 Page: 3 of 8 2021-09-08 17:00:45 GMT From: Tod Rattield cH-11d PLAINTIFEPETITIONER: Gala International, inc. GABE NUMBER: - F RG19002887 DEFENDANT/RESPONDENT: Benito Valley Farm, LLC, et al. 4, 6. Provide a brief siatement of the case, including any Gamages. (if personal injury damages are sought, specify the infury and damages claimed, including medical expenses to date findicate source and amount] estimated fulure medical expanses, lost samings fo date, and estimeted future jost eamings. if equitable relief is sought, describe the nature of the relief) Collection of unpaid invoices for specially manufactured good for Defendants. Damages sought are $76,139.64 plus interest at the legal rate of $8,906.30, and attomey's fees pursuant to CC section 1717.5 of $1,200. [X"] (more snace is needed, check tig box and allach a page designated ag Attachment 4b.) §. dury or nonjury vial ; The party or parties request [7] a jury trial anonjury tial. {more than one party, provide the name of each party requesting a jury trial}: 6 rial date . : a. [27] The tral has been set for (date): TBD - Motion pending o CU No trial date has been set. This case will be reacly for irial within 12 months of the date of the filing of the complaint of nol, explain): @ Dates on which parties or attorneys will not be available for trial (apenily deies end explain reasans fer unavailability}: October 8-30, 2021 Vacation; April 15-May 16, 2022, Vacation 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [2] days (specify number): 1 o. [7] hours (short causes} (specify): 8. Trial representation (lo be answered for each party} The party or parties will be represented at tial [70] by the attorney or party listed in the caption [7] by the following: a. Afforney: Bb. Firm: &. Address: d. Telephone number: f. Fax number: e, E-mail address: g. Party represented: (CU Auditional representation is desorbed In Attachment 8. §. Preference (CT] | This case is entitled to preference (apecity code section): 10, Alternative dispute resolution (ADR} @ ADR information package, Please note that different ADR processes are availabie in different courts arid communities; read the ADR information package provided by the court under rule 3.221 for Infermation about the processes available trough the sourt and community programs in this case. (1) For parties represented by counsel: Counsel has Co] has not provided the ADR. information package identified in rulé 3.221 te the client and reviewed ADR options with the cllent. (2) For self-represented parties: Party (l has [7] has not reviewed the ADR information package identified in rule 3.221. & Referral to judicial arbitration or civil action mediation (if available). i) | This matter is subject to mandatory judicial arbitration under Cade of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1778.3 because the amount in controversy does not exceed the statutory Umit. (2) [I] Plaintiff elects to refer this case to Judicial arbitration and agrees to limit recovery fo the amount specified in Code of Civil Procedure section 1141.11. 3} | This case is exempt from judicial arbitration under nile 3.911 of the California Rules of Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CMATO (av. Jay 3, 2074 GASE MANAGEMENT STATEMENT Page Rot & To: +15102675732 Page: 4 of 8 2021-09-08 17:00:45 GMT From: Tod Rattield CR-110 | PLAINTIFF/PETITIONER: Gala International, inc. GABE NUMBER: DEFENDANT/RESPONDENT: Benito Valley Farm, LLC, et al. RE19002867 10. 6, Indicate the ADR precess or processes that the parly or parties are willing tc participate in, have agreed to participate in, or have already participated in (eheck aff hat apply and provide the specified information): The party or parties completing | if the party er parties completing this form in the case have agreed to this form are willing to participate in or have already completed en ADR process or processes, participate In the following ADR | Indicate the status of the processes (attach a copy of the parties’ ADR processes (check aff that apply): | stipulation): Mediation session not yet scheduled | Medietion session scheduled for (deie): (f) Mediation a [=] Agreed to complete mediation by (date): [2] Mediation completed on (dafe}: KEI Settlement conference nat yet scheduled (2) Settlement cc C—J Settlement conference scheduled for (Wate): conference CI Agreed to complete settlement conference by (gafe): EZ] Settlement conference completed on (date): [=] Neutral evaluation not yet scheduled ; C7 C1 Neutral evaiuation scheduled for (date): (3) Neutral evaluation cl Agreed io complete neutral evaluation by (date): Zz, Neutral evaluation completed on (date): [EE] Judicial arbitration nat yet scheduled (4) Nonbinding judicial cc EE] Jusicial arbitration scheduled for (date): arbitration C7) Agreed to complete judicial arbitration by (date), [=] Judicial arbitration completed on (date): (22) Private arbitration not yet scheduled ) Binding private cc KEI Private arbitration echeduled for (date): arbitration CI Agreed to. complete private arbitration by (ceie): CC] Frivate arbitration completed on (date): [=] ADR session not yet scheduled ct [=] ADR session scheduled for (date): (6) Other (speci): (1 Agreed to complete ADR session by (date): [=] ‘ADR completed on (ater: CMG iRev. July €, 2044] CASE MANAGEMENT STATEMENT Page sare To: +15102675732 Page: 5 of 8 2021-09-08 17:00:45 GMT From: Tod Ratfield CMet10 PLAINTIFF/PETITIONER: Gala International, inc. GASE NUMBER: - ; RG 19002687 DEFENDANTIRESPONDENT: Benito Valley Farm, LLC, et al. 44. Insurance a. [<7] insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: (“J yes CUI Ne « Co Coverage issues will significantly affect resolution of this case (explain): 12. Juriadiction indicate any matters that may affect the court's juriadiction or processing of this case and describe the status. [TI Bankeuptey CO Other (epecityi: Status: 13, Related cases, consolidation, and coordination a, CUT) There are companion, underlying, or related cases, (4) Name of case: (2 Name of court: (3 Case number: (45 Status: IX Additional cases are described in Atachment 13a. ». (Cl Amotionto [] consoste [7] coordinate will be filed by (name party): 14. Bifurcation (] The party or parties interns! 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 [x0] the party or parties expect to file the following motions before trial (speci moving party, hype of motion, and Issues;: Plaintiff was reinstated August 26, 2021. Plaintiff will be filing a Mation to Compel discovery and to strike Defendant Corp's answer given it has refused to obtain counsel. 16, Discovery a. ("| The parly or parties have completed all discovery. ». [77] The tollowing discovery will be completed by the date specified (clescribe alf anticipated discovery): Party Besoriotion Date Plaintiff Written Discovery May 2027 Plaintiff Depositions dune 2024 G. The following discovery issues, including issues regarding the diecavery of electronically stored information, are anticipated (speci): The Flaintiff is anticipating having io file a Motion to Cornpel since discovery responses were due per an extension on May 20, 2021. OM110 flav. July 1, 2014] CASE MANAGEMENT STATEMENT Page 4 od & To: +15102675732 Page: 6 of 8 2021-09-08 17:00:45 GMT From: Tod Rattield CM-116 PLAINTIFF/PETITIONER: Gala International, Inc, CASE NUMBER: — RG DEFENDANTRESPONDENT. Benilo Valley Farm, LLC, at al, 619002887 47. Economic ligation a. (__] This is a lieved civil case (.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Givi Procedure sections &)-86 will apply to this case. b. [_] This is a limited civil case and @ motion to withdraw the case from the economils litigation procedures or for additional discovery will be filed (f checked, explain specifically why economic Higation procedures relating fe discovery or tial shoud 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 (saecify): 19, Meet and confer a. (C7! The party ov 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}: | will attempt to meet & confer prior to the CMC. However, | have been unable to reach the Defendant. b. Afier meeting and conferring as required by rule 2.724 of the California Rules of Court, the parties agree on the jollowing fspechfy}: 20. Total number of pages atlached (ff any): lar completely familiar with this cage and will be fully prepared to discuss the status of discovery and altemative dispute resciution, as well ag other issues raised by this statement, and will possess the authority to enter into stipulations on these iasues at the time of the case management conference, including the written authorily of the party where required. Date: September 7, 2021 Tod M. Ratfield > CTYPE OR PRINT NAME) (SIGNATURE OF BARTY OR ATTORNEY) LYRE OF PRINT NABME) (SIGNATURE OF PARTY OR ATTORREY) ["] Additional signatures are attached. Ome1O fav. ay 3 2040 CASE MANAGEMENT STATEMENT page sore To: +15102675732 Page: 7 of 8 2021-09-08 17:00:45 GMT From: Tod Ratfield 3 PROOF OF SERVICE 2 [C.C.P, Section 1013, 2015.8, 2009] 3 i, the undersigned, declare that I am 2 citizen of the Untied States, a resident of the State 4 | of California, and am employed in the County of Contra Costa, State of California. Lam over eighteen (18) years of age and not a party to the above-entitled action. My business address is 1233 Alpine Road, Walnut Creek, California. On the date below, I served the following an document(s) in the manner indicated below on the person(s) listed below: 7 CASE MANAGEMENT STATEMENT as F 8 ‘ _ BY UNITED STATES MAIL: I enclosed the document in a sealed envelope or 8 package addressed to the persons at the addresses listed below and placed the envelope/package for coliection and mailing, following our ordinary business 16 practices. I am readily familiar with this business’s practice for collection and raailing, it is deposited in the ordinary course of business with the United States i Postal Service, in a sealed envelope with postage fully prepaid. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or 12 postage meter date is more than one day after the date of deposit for mailing an affidavit. 13 lam a resident or employed in the county where the mailing occurred. The envelope 14 or package was placed in the mail at Angwin, California. is ee BY FAX TRANSMISSION: Based on an agreement of the parties to accept service by fax transmission, I faxed the documents to the persons at the fax numbers 16 listed below. No error was reported by the fax machine that Ll used. A copy of the revord of the fax iransmission, which | printed out is attached. oe BY OVERNIGHT DELIVERY: | enclosed the documents in an envelope or 18 package provided by an overnight delivery carrier and addressed to the persons at the addresses listed below. I place the envelope or package for collection and overnight 2g delivery at an office or a regularly utilized drop box of the overnight delivery carrier. 28 BY PERSONAL SERVICE: I personally served the documents to the persons at the addresses listed below. (1) for a party represented by an attorney, delivery was a4 made to the attomey or al the attorney’s office by leaving the documents in an envelope or package clearly labeled to identify the attorney being served with the 22 receptionist or an individual in charge of the office. (2) Fora party, delivery was made io the party or by leaving the documents at the party’s residence with some 23 person not less than 18 years of age between the hours of eight in the morning and six in the evening. 24 a BY MESSENGER SERVICE: | served the documents by placing them in an 25 envelope or package addressed to the persons at the addresses listed above and 26 Proof of Service To: +15102675732 Page: 8 of 8 2021-09-08 17:00:45 GMT From: Tod Rattield providing them to a professional messenger service for service (4 declaration by the 1 messenger must accompany this Proofof Service) . BY E-MAIL OR ELECTRONIC TRANSMISSION: Based on a court order or ani agreenient of the parties to accept service by e-mail or electronic transmission, 3 I caused the documents to be sent to the persons at the e-mail addressed listed below. i did not receive, within a reasonable time alter the transmission, an electronic 4 message or other indication that the transmission was unsuccessful. g Linda Chu ® 118953 Ironbark Street + CHiroy, CA. 95026 Phone: (831) 902-6590 g | Cells (831) 902-6589 E-Mail: Undachy3333@email cor ia || Benito Valley Farms, Inc. 8953 lronbark Street 1) Gilroy, CA 95020 42 as I declare under penalty of perjury under the laws of the State of California that the above 14 {is true and correct. Executed this PAA day of secs beer, 2021 at Anpwin, California. 46 a) ta Kristine Gromacki 18 20 2h 22 23 tu it eo oF bo Proof of Service