Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
Kristen Kuse SBN 187583
Integrated General Counsel, P.C.
4900 Hopyard Rd, Suite 100
Pleasanton, CA 94588
TELEPHONE NO.:925-399-1529 FAX NO. (Optional):
E-MAIL ADDRESSKristen@integratedgeneralcousel.com
Defendants,
ATTORNEY FOR (Name): Moodie,
SUPERIOR COURT OF CALIFORNIA, COUNTY OF ALAMEDA
STREET ADDRESS:24405 Amador Street
MAILING ADDRESS:
Hayward,
CITY AND ZIP CODE: 94544
BRANCH NAME:Hayward Hall Justice
PLAINTIFF/PETITIONER: RUSSELL REDENBAUGH
DEFENDANT/RESPONDENT: DAHLIA MOODIE; FUTURE POWER CORPORATION
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE LIMITED CASE RG21113936
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: February 2022 Time: 2:30 p.m. Dept.: 521 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Kristen Hayes Kuse
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
This statement is submitted by party (name): Defendants, DAHLIA MOODIE; FUTURE POWER CORPORATION
This statement is submitted jointly by parties (names):
Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): September 21, 2021
The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
The following parties named in the complaint or cross-complaint
have not been served (specify names and explain why not):
have been served but have not appeared and have not been dismissed (specify names):
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):
Description of case
a. Type of case in complaint cross-complaint (Describe, including causes of action):
1.Breach Contract;2.Breach Fiduciary Duty;3.Breach the Implied Covenant Good Faith and Fair Dealing;4.Unjust
Enrichment;5.Conversion;6.Intentional Misrepresentation;7.Negligent Misrepresentation;8.Financial Abuse of an Elder;9.
Money Had and Received;10.Contructive Trust;11.Intentional Infliction of Emotional Distress;12. Negl Inflict Emot Distress
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. September 1, 2021] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: RUSSELL REDENBAUGH CASE NUMBER:
DEFENDANT/RESPONDENT: DAHLIA MOODIE; FUTURE POWER CORPORATION RG21113936
Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages claimed, including medical expens dat [indicat sour amount], estimated futu medica expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request a jury triaI a nonjury trial.(If more than one party, provide the name of each party
requesting a jury trial):
Trial date
The trial has been set for(date):
(if
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
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Estimated length of trial
The party or parties estimate that the trial will take (check one):
days (specify number): 4-7
hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption by the following:
Attorney:
b. Firm:
c. Address:
Telephone number: f. Fax number:
E-mail address: Party represented:
Additional representation is described in Attachment 8.
Preference
This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
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 of the California Rules of Court for information about the
processes available through the court and community programs in this case.
For parties represented by counsel: Counsel 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.
Referral to judicial arbitration or civil action mediation (if available).
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.
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.
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. September 1, 2021] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: RUSSELL REDENBAUGH CASE NUMBER:
DEFENDANT/RESPONDENT: DAHLIA MOODIE; FUTURE POWER CORPORATION RG21113936
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
Mediation session scheduled for date
(1) Mediation
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
(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
ADR session scheduled for (date
(6) Other (specify
Agreed to complete ADR session by (date
ADR completed on (date
CM-110 [Rev. September 1, 2021] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: RUSSELL REDENBAUGH CASE NUMBER:
DEFENDANT/RESPONDENT: DAHLIA MOODIE; FUTURE POWER CORPORATION RG21113936
11. Insurance
Insurance carrier, if any, for party filing this statement (name):
Reservation of rights: Yes
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
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.
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
(specify moving party, type of motion, and issues):
The party or parties expect to file the following motions before trial
16. Discovery
The party or parties have completed all discovery.
The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Inspection Demands, Set One January 17, 2022
Special Interrogatories, Set One January 17, 2022
Request for Admissions, Set One January 17, 2022
Form Interrogatories, Set One January 17, 2022
Misc. Depositions TBD
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. September 1, 2021] Page 4 of 5
CASE MANAGEMENT STATEMENT
with all
the following
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CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Kristen Kuse SBN 187583 Integrated General Counsel, P.C. 4900 Hopyard Rd, Suite 100 Pleasanton, CA 94588 TELEPHONE NO.:925-399-1529 FAX NO. (Optional): E-MAIL ADDRESSKristen@integratedgeneralcousel.com Defendants, ATTORNEY FOR (Name): Moodie, SUPERIOR COURT OF CALIFORNIA, COUNTY OF ALAMEDA STREET ADDRESS:24405 Amador Street MAILING ADDRESS: Hayward, CITY AND ZIP CODE: 94544 BRANCH NAME:Hayward Hall Justice PLAINTIFF/PETITIONER: RUSSELL REDENBAUGH DEFENDANT/RESPONDENT: DAHLIA MOODIE; FUTURE POWER CORPORATION CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE RG21113936 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: February 2022 Time: 2:30 p.m. Dept.: 521 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Kristen Hayes Kuse INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): This statement is submitted by party (name): Defendants, DAHLIA MOODIE; FUTURE POWER CORPORATION This statement is submitted jointly by parties (names): Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): September 21, 2021 The cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. The following parties named in the complaint or cross-complaint have not been served (specify names and explain why not): have been served but have not appeared and have not been dismissed (specify names): 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): Description of case a. Type of case in complaint cross-complaint (Describe, including causes of action): 1.Breach Contract;2.Breach Fiduciary Duty;3.Breach the Implied Covenant Good Faith and Fair Dealing;4.Unjust Enrichment;5.Conversion;6.Intentional Misrepresentation;7.Negligent Misrepresentation;8.Financial Abuse of an Elder;9. Money Had and Received;10.Contructive Trust;11.Intentional Infliction of Emotional Distress;12. Negl Inflict Emot Distress 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. September 1, 2021] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: RUSSELL REDENBAUGH CASE NUMBER: DEFENDANT/RESPONDENT: DAHLIA MOODIE; FUTURE POWER CORPORATION RG21113936 Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, including medical expens dat [indicat sour amount], estimated futu medica expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) (If more space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request a jury triaI a nonjury trial.(If more than one party, provide the name of each party requesting a jury trial): Trial date The trial has been set for(date): (if 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 not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Estimated length of trial The party or parties estimate that the trial will take (check one): days (specify number): 4-7 hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption by the following: Attorney: b. Firm: c. Address: Telephone number: f. Fax number: E-mail address: Party represented: Additional representation is described in Attachment 8. Preference This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) 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 of the California Rules of Court for information about the processes available through the court and community programs in this case. For parties represented by counsel: Counsel 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. Referral to judicial arbitration or civil action mediation (if available). 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. 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. 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. September 1, 2021] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: RUSSELL REDENBAUGH CASE NUMBER: DEFENDANT/RESPONDENT: DAHLIA MOODIE; FUTURE POWER CORPORATION RG21113936 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 Mediation session scheduled for date (1) Mediation 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 (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 ADR session scheduled for (date (6) Other (specify Agreed to complete ADR session by (date ADR completed on (date CM-110 [Rev. September 1, 2021] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: RUSSELL REDENBAUGH CASE NUMBER: DEFENDANT/RESPONDENT: DAHLIA MOODIE; FUTURE POWER CORPORATION RG21113936 11. Insurance Insurance carrier, if any, for party filing this statement (name): Reservation of rights: Yes 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 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. 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 (specify moving party, type of motion, and issues): The party or parties expect to file the following motions before trial 16. Discovery The party or parties have completed all discovery. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Inspection Demands, Set One January 17, 2022 Special Interrogatories, Set One January 17, 2022 Request for Admissions, Set One January 17, 2022 Form Interrogatories, Set One January 17, 2022 Misc. Depositions TBD c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. September 1, 2021] Page 4 of 5 CASE MANAGEMENT STATEMENT with all the following