Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Paul A. Traina, SBN 155805
John Shaller, SBN 276084
PANISH SHEA & BOYLE LLP
11111 Santa Monica Blvd, Suite 700
Los Angeles,CA 90025
TELEPHONE NO.: 310.477.1700 FAX NO. (Optional): 310.477.1699
E-MAIL ADDRESS (Optional): shaller@psblaw.com
ATTORNEY FOR (Name): Plaintiffs
SUPERIOR COURT OF CALIFORNIA, COUNTY OF ALAMEDA
STREET ADDRESS: 1225 Fallon Street
MAILING ADDRESS:
Oakland, CA 94612
CITY AND ZIP CODE:
Rene C. Davidson Courthouse
BRANCH NAME:
PLAINTIFF/PETITIONER: JOSEPH C. ROTELLI
DEFENDANT/RESPONDENT: JAIME ROMERO MAGALLANES, ET AL
CASE NUMBER:
CASE MANAGEMENT STATEMENT
(Check one): X UNLIMITED CASE LIMITED CASE RG21100138
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as
follows: Date: January 25, 2022 Time: 9:3:00 p.m. Dept.: 25 Div.: Room:
Address of court (if different from the address above):
X Notice of Intent to Appear by Telephone, by (name): John W. Shaller
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): Plaintiff Joseph C. Rotelli
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): 5/19/2021
b. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. X 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 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):
Negligence. Pedestrian versus Tractor Trailer.
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730
CM-110 [Rev. July 1, 2011]
CM-110
PLAINTIFF/PETITIONER: ROTELLI CASE NUMBER:
RG21100138
DEFENDANT/RESPONDENT: MAGANALLES, 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.)
Please see Attachment 4B, which is attached hereto.
(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 triaI 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):
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 (short causes) (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:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
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 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] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: ROTELLI CASE NUMBER:
RG21100138
DEFENDANT/RESPONDENT: MAGANALLES, 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):
X Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation X
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date):
(4) Nonbinding judicial
arbitration Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
(5) Binding private
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: ROTELLI CASE NUMBER:
DEFENDANT/RESPONDENT: MAGANALLES, ET AL RG21100138
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: 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.
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 wiII 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):
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
Plaintiffs Written discovery April 20222
Plaintiffs Depositions of the parties and witnesses April 2022
Plaintiffs 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] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: ROTELLI CASE NUMBER:
DEFENDANT/RESPONDENT: MAGANALLES, ET AL RG21100138
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
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. X 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): 1
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: January 7, 2022
John W. Shaller
(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] Page 5 of 5
CASE MANAGEMENT STATEMENT
SHORT TITLE: ROTELLI v. MAGANALLES, ET AL CASE NUMBER:
RG21100138
1
ATTACHMENT 4b
2
3 On December 21, 2020, at approximately 6:15 p.m., Defendant Magallanes was operating a tractor
trailer on eastbound I-580. After a warning light for his transmission activated on his dashboard,
4 Defendant Magallanes exited the I-580 at North Flynn Road and pulled into a brake check area,
which was located above and/or adjacent to the eastbound on-ramp of I-580. At the same time
5
and place, Plaintiff was standing on the right shoulder of the on-ramp of I-580, adjacent to his
6 vehicle, a green 2017 Freightliner Cascadia tractor, performing a vehicle inspection. As Defendant
Maganalles opened his driver door, he slipped and fell out of his vehicle and onto the roadway, and his
7
tractor trailer began to roll away down the on-ramp towards Plaintiff and Plaintiff's vehicle and
8
subsequently did strike Plaintiff's vehicle and Plaintiff with tremendous force causing Plaintiff to be
thrown to the ground, thereby causing Plaintiff to sustain severe and permanent injuries.
9
As a legal, direct and proximate result of said negligence of defendants, as aforesaid, plaintiff
10 has sustained serious and permanent injuries, including but not limited to pain, suffering, and has
11
incurred, and in the future will be required to incur, expenses for the services of physicians to
examine, diagnose, prescribe, treat, and care for him and to incur other medical, hospital, and
12 incidental expenses. Plaintiff has also sustained a loss of earnings and loss of future earning capacity.
13
14
15
16
17
18
19
20
21
22
23
24
25
26 (Required for verified pleading) The items on this page stated on information and belief are (specify item numbers, not line
numbers):
27
This page may be used with any Judicial Council form or any other paper filed with the court. 6
Page
Form Approved by the ADDITIONAL PAGE
Judicial Council of California
MC-020 [New January 1, 1987]
Attach to Judicial Council Form or Other Court Paper CRC 201, 501
1 PROOF OF SERVICE
2 Joseph C. Rotelli v. Jaime Romero Magallanes, et al.
Case No. RG21100138
3
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
4
At the time of service, I was over 18 years of age and not a party to this action. I am
5 employed in the County of Los Angeles, State of California. My business address is 11111 Santa
Monica Boulevard, Suite 700, Los Angeles, CA 90025.
6
On January 10, 2022, I served true copies of the following document(s) described as
7 PLAINTIFF'S CASE MANAGEMENT STATEMENT on the interested parties in this action
as follows:
8
Edgar W. Hawkyard, Esq.
9 JEANETTE N. LITTLE & ASSOCIATES
4450 Rosewood Drive, Suite 450
10 Pleasanton, CA 94588
T: (925)225-6838
11 F: (855)732-9437
LLP
E: ed.hawkyard@statefarm.com
11111 Santa Monica Boulevard, Suite 700
310.477.1700 phone • 310.477.1699 fax
12 cali.law-pleasanton-
P ANISH S HEA & B OYLE
Los Angeles, California 90025
eservice.081o02@statefarm.com
13
Attorneys for Defendant,
14 JAIME ROMERO MAGALLANES
15 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
document(s) to be sent from e-mail address lucio@psblaw.com to the persons at the e-mail
16 addresses listed in the Service List. I did not receive, within a reasonable time after the
transmission, any electronic message or other indication that the transmission was unsuccessful.
17
I declare under penalty of perjury under the laws of the State of California that the
18 foregoing is true and correct.
19 Executed on January 10, 2022, at Los Angeles, California.
20
21 /s/ Jaqueline Lucio
Jaqueline Lucio
22
23
24
25
26
27
28
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Paul A. Traina, SBN 155805 John Shaller, SBN 276084 PANISH SHEA & BOYLE LLP 11111 Santa Monica Blvd, Suite 700 Los Angeles,CA 90025 TELEPHONE NO.: 310.477.1700 FAX NO. (Optional): 310.477.1699 E-MAIL ADDRESS (Optional): shaller@psblaw.com ATTORNEY FOR (Name): Plaintiffs SUPERIOR COURT OF CALIFORNIA, COUNTY OF ALAMEDA STREET ADDRESS: 1225 Fallon Street MAILING ADDRESS: Oakland, CA 94612 CITY AND ZIP CODE: Rene C. Davidson Courthouse BRANCH NAME: PLAINTIFF/PETITIONER: JOSEPH C. ROTELLI DEFENDANT/RESPONDENT: JAIME ROMERO MAGALLANES, ET AL CASE NUMBER: CASE MANAGEMENT STATEMENT (Check one): X UNLIMITED CASE LIMITED CASE RG21100138 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: January 25, 2022 Time: 9:3:00 p.m. Dept.: 25 Div.: Room: Address of court (if different from the address above): X Notice of Intent to Appear by Telephone, by (name): John W. Shaller 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): Plaintiff Joseph C. Rotelli 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): 5/19/2021 b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. X 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 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): Negligence. Pedestrian versus Tractor Trailer. Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730 CM-110 [Rev. July 1, 2011] CM-110 PLAINTIFF/PETITIONER: ROTELLI CASE NUMBER: RG21100138 DEFENDANT/RESPONDENT: MAGANALLES, 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.) Please see Attachment 4B, which is attached hereto. (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 triaI 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): 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 (short causes) (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: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: 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 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] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: ROTELLI CASE NUMBER: RG21100138 DEFENDANT/RESPONDENT: MAGANALLES, 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): X Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation X Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled Judicial arbitration scheduled for (date): (4) Nonbinding judicial arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled Private arbitration scheduled for (date): (5) Binding private arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: ROTELLI CASE NUMBER: DEFENDANT/RESPONDENT: MAGANALLES, ET AL RG21100138 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: 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. 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 wiII 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): 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 Plaintiffs Written discovery April 20222 Plaintiffs Depositions of the parties and witnesses April 2022 Plaintiffs 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] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: ROTELLI CASE NUMBER: DEFENDANT/RESPONDENT: MAGANALLES, ET AL RG21100138 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 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. X 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): 1 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: January 7, 2022 John W. Shaller (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] Page 5 of 5 CASE MANAGEMENT STATEMENT SHORT TITLE: ROTELLI v. MAGANALLES, ET AL CASE NUMBER: RG21100138 1 ATTACHMENT 4b 2 3 On December 21, 2020, at approximately 6:15 p.m., Defendant Magallanes was operating a tractor trailer on eastbound I-580. After a warning light for his transmission activated on his dashboard, 4 Defendant Magallanes exited the I-580 at North Flynn Road and pulled into a brake check area, which was located above and/or adjacent to the eastbound on-ramp of I-580. At the same time 5 and place, Plaintiff was standing on the right shoulder of the on-ramp of I-580, adjacent to his 6 vehicle, a green 2017 Freightliner Cascadia tractor, performing a vehicle inspection. As Defendant Maganalles opened his driver door, he slipped and fell out of his vehicle and onto the roadway, and his 7 tractor trailer began to roll away down the on-ramp towards Plaintiff and Plaintiff's vehicle and 8 subsequently did strike Plaintiff's vehicle and Plaintiff with tremendous force causing Plaintiff to be thrown to the ground, thereby causing Plaintiff to sustain severe and permanent injuries. 9 As a legal, direct and proximate result of said negligence of defendants, as aforesaid, plaintiff 10 has sustained serious and permanent injuries, including but not limited to pain, suffering, and has 11 incurred, and in the future will be required to incur, expenses for the services of physicians to examine, diagnose, prescribe, treat, and care for him and to incur other medical, hospital, and 12 incidental expenses. Plaintiff has also sustained a loss of earnings and loss of future earning capacity. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 (Required for verified pleading) The items on this page stated on information and belief are (specify item numbers, not line numbers): 27 This page may be used with any Judicial Council form or any other paper filed with the court. 6 Page Form Approved by the ADDITIONAL PAGE Judicial Council of California MC-020 [New January 1, 1987] Attach to Judicial Council Form or Other Court Paper CRC 201, 501 1 PROOF OF SERVICE 2 Joseph C. Rotelli v. Jaime Romero Magallanes, et al. Case No. RG21100138 3 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 4 At the time of service, I was over 18 years of age and not a party to this action. I am 5 employed in the County of Los Angeles, State of California. My business address is 11111 Santa Monica Boulevard, Suite 700, Los Angeles, CA 90025. 6 On January 10, 2022, I served true copies of the following document(s) described as 7 PLAINTIFF'S CASE MANAGEMENT STATEMENT on the interested parties in this action as follows: 8 Edgar W. Hawkyard, Esq. 9 JEANETTE N. LITTLE & ASSOCIATES 4450 Rosewood Drive, Suite 450 10 Pleasanton, CA 94588 T: (925)225-6838 11 F: (855)732-9437 LLP E: ed.hawkyard@statefarm.com 11111 Santa Monica Boulevard, Suite 700 310.477.1700 phone • 310.477.1699 fax 12 cali.law-pleasanton- P ANISH S HEA & B OYLE Los Angeles, California 90025 eservice.081o02@statefarm.com 13 Attorneys for Defendant, 14 JAIME ROMERO MAGALLANES 15 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the document(s) to be sent from e-mail address lucio@psblaw.com to the persons at the e-mail 16 addresses listed in the Service List. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. 17 I declare under penalty of perjury under the laws of the State of California that the 18 foregoing is true and correct. 19 Executed on January 10, 2022, at Los Angeles, California. 20 21 /s/ Jaqueline Lucio Jaqueline Lucio 22 23 24 25 26 27 28