Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
COURTNEY P. PENDRY, Esq. (State Bar No. 327382)
MANLY, STEWART & FINALDI
19100 Von Karman Ave., Suite 800
Irvine, CA 92612
TELEPHONE NO.:(949) 252-9990 (949) 252-9991
FAX NO. (Optional):
cpendry@manlystewart.com
E-MAIL ADDRESS (Optional):
Plaintiff, JANE BE DOE
ATTORNEY FOR (Name):
SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY
STREET ADDRESS:1200 Aguajito Road
MAILING ADDRESS:
Monterey, CA 93940
CITY AND ZIP CODE:
BRANCH NAME:Monterey Branch
PLAINTIFF/PETITIONER: JANE BE DOE
DEFENDANT/RESPONDENT: BIG BROTHERS BIG SISTERS OF AMERICA, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE LIMITED CASE 21CV000805
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: February 22, 222 Time: 9:00 a.m. Dept.: 15 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Courtney P. Pendry, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. This statement is submitted by party (name): Plaintiff, JANE BE DOE
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): 3/12/2021
b. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. The following parties named in the complaint or cross-complaint
(1) have not been served (specify names and explain why not):
Defendant Woody. See attached Decls. of Courtney P. Pendry; Kevin Antunez; and Carlos Valerrama.
(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 complaint cross-complaint (Describe, including causes of action):
Complaint for (1) Intentional Infliction of Emotional Distress; (2) Negligence; (3) Breach of Fiduciary Duty; (4) Constructive
Fraud (Civil Code Sec. 1573); (5) Sexual Harassment (Civil Code Sec. 51.9; (6) Sexual Battery; (7) Gender Violence (Civil
Code Sec. 52.4; (8) Violation of Penal Code Sec. 288(a); and (9) Violation of Penal Code Sec. 647.6(a)(1).
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] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: JANE BE DOE CASE NUMBER:
DEFENDANT/RESPONDENT: BIG BROTHERS BIG SISTERS OF AMERICA, et al. 21CV000805
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.)
The Plaintiff, a victim of childhood sexual abuse, was sexually abused by Defendant Jon David Woody, an agent and/or
employee of Big Brother's Big Sisters of America and Big Brothers Big Sisters of Monterey County. Plaintiff has alleged
various damages as a result of the abuse she suffered, including economic pain and suffering.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
a. 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):
6. Trial date
a. The trial has been set for(date):
b. (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):
Trials already set for: 02/23/2022-04/23/2022; 08/26/2022-09/26/2022; and 10/03/2022-11/03/2022.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): five (5) days
b. hours (short causes) (specify):
8. 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:
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 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: JANE BE DOE CASE NUMBER:
DEFENDANT/RESPONDENT: BIG BROTHERS BIG SISTERS OF AMERICA, et al. 21CV000805
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. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: JANE BE DOE CASE NUMBER:
DEFENDANT/RESPONDENT: BIG BROTHERS BIG SISTERS OF AMERICA, et al. 21CV000805
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
(specify moving party, type of motion, and issues):
The party or parties expect to file the following motions before trial
16. Discovery
a. The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiff Written Discovery Within 9 mos.
Plaintiff Depositions Within 9 mos.
Plaintiff Subpoena's to Third Parties Within 6 mos.
Plaintiff 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: JANE BE DOE CASE NUMBER:
DEFENDANT/RESPONDENT: BIG BROTHERS BIG SISTERS OF AMERICA, et al. 21CV000805
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. 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): 16
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: February 7, 2022
Courtney Pendry, Esq.
(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
EXHIBIT 1
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF ORANGE
3
I am employed in the county of Orange, State of California. I am over the age of 18 and
4 not a party to the within action; my business address is 19100 Von Karman Ave., Suite 800,
Irvine, CA 92612.
5
On February 7, 2022 I served the foregoing document described as CASE
6 MANAGEMENT STATEMENT on the interested parties in this action by placing a true copy
thereof enclosed in sealed envelope(s) addressed as follows:
7
SEE ATTACHED SERVICE LIST
8 [X] BY U.S. MAIL: I served the documents on the parties indicate on the attached service list by
enclosing them in an envelope and placing the envelope for collection and mailing following our
9 ordinary business practices. I am readily familiar with this business’s practice of collection and
processing of correspondence for mailing. On the same day that correspondence is placed for
10 collection and mailing, it is deposited in the ordinary course of business with the United States
Postal Service in a sealed envelope with postage fully prepaid.
11
12 [X] BY E-MAIL OR ELECTRONIC TRANSMISSION Due to the extraordinary
circumstances of the current COVID-19 pandemic, and in accordance with the Governor of
19100 Von Karman Avenue, Suite 800
California’s “Shelter-In-Place” order, and by further judicial mandate under Rule 12, or an
MANLY, STEWART & FINALDI
13
Telephone: (949) 252-9990
agreement of the parties to accept service by electronic transmission, I emailed from Irvine,
ATTORNEYS AT LAW
14 California, a true and correct copy of the above-referenced document(s) described above to the
Irvine, CA 92612
persons and email addresses identified below:
15
16 BY FACSIMILE TRANSMISSION: The facsimile machine I used complied with California
Rules of Court 2.301 and no error was reported by the machine. Pursuant to rule 2.306(h), I
17 caused the machine to print a record of the transmission, a copy of which is attached to this proof
of service.
18
BY OVERNIGHT DELIVERY: I caused the above-referenced document(s) to be delivered via
19 overnight delivery, for delivery to the above address(es).
20
_____(State) I declare under penalty of perjury under the laws of the State of California that the
21 above is true and correct.
_____(Federal) I declare that I am employed in the office of a member of the bar of this court
22 at whose direction, the service was made.
23
Executed on February 7, 2022, Irvine, California.
24
___________________________
25 Ashley Brimhall
26
27
28
1
PROOF OF SERVICE
1
2 SERVICE LIST
3
VIA ELECTRONIC SERVICE ONLY
4
Alison M. Crane, Esq., Partner
5 Tara A. Murray, Esq.
Bledsoe, Diestel, Treppa & Crane LLP
6
180 Sansome, 5th Floor
7 San Francisco, CA 94104
T: 415-981-5411
8 F: 415-981-0352
acrane@bledsoelaw.com
9 tmurray@bledsoelaw.com
calendar@bledsoelaw.com
10
Counsel for Defendants Big Brothers Big Sisters of America
11
12 VIA U.S. MAIL ONLY
19100 Von Karman Avenue, Suite 800
JON DAVID WOODY
MANLY, STEWART & FINALDI
13
CDCR # AI0930
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 DOB 07/08/45
Irvine, CA 92612
RJ Donovan Correctional Facility
15 480 Alta Road
San Diego, CA 92179
16
VIA U.S. MAIL AND EMAIL
17 Boys & Girls Club of Monterey County
Paul Caleo
18 Mark Heisey
1332 La Salle Ave.
19 Seaside, CA 93955
Email: pcaleo@grsm.com
20 mheisey@grsm.com
21
22
23
24
25
26
27
28
2
PROOF OF SERVICE
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CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY COURTNEY P. PENDRY, Esq. (State Bar No. 327382) MANLY, STEWART & FINALDI 19100 Von Karman Ave., Suite 800 Irvine, CA 92612 TELEPHONE NO.:(949) 252-9990 (949) 252-9991 FAX NO. (Optional): cpendry@manlystewart.com E-MAIL ADDRESS (Optional): Plaintiff, JANE BE DOE ATTORNEY FOR (Name): SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY STREET ADDRESS:1200 Aguajito Road MAILING ADDRESS: Monterey, CA 93940 CITY AND ZIP CODE: BRANCH NAME:Monterey Branch PLAINTIFF/PETITIONER: JANE BE DOE DEFENDANT/RESPONDENT: BIG BROTHERS BIG SISTERS OF AMERICA, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE 21CV000805 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: February 22, 222 Time: 9:00 a.m. Dept.: 15 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Courtney P. Pendry, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): Plaintiff, JANE BE DOE 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): 3/12/2021 b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. The following parties named in the complaint or cross-complaint (1) have not been served (specify names and explain why not): Defendant Woody. See attached Decls. of Courtney P. Pendry; Kevin Antunez; and Carlos Valerrama. (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 complaint cross-complaint (Describe, including causes of action): Complaint for (1) Intentional Infliction of Emotional Distress; (2) Negligence; (3) Breach of Fiduciary Duty; (4) Constructive Fraud (Civil Code Sec. 1573); (5) Sexual Harassment (Civil Code Sec. 51.9; (6) Sexual Battery; (7) Gender Violence (Civil Code Sec. 52.4; (8) Violation of Penal Code Sec. 288(a); and (9) Violation of Penal Code Sec. 647.6(a)(1). 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] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: JANE BE DOE CASE NUMBER: DEFENDANT/RESPONDENT: BIG BROTHERS BIG SISTERS OF AMERICA, et al. 21CV000805 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.) The Plaintiff, a victim of childhood sexual abuse, was sexually abused by Defendant Jon David Woody, an agent and/or employee of Big Brother's Big Sisters of America and Big Brothers Big Sisters of Monterey County. Plaintiff has alleged various damages as a result of the abuse she suffered, including economic pain and suffering. (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial a. 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): 6. Trial date a. The trial has been set for(date): b. (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): Trials already set for: 02/23/2022-04/23/2022; 08/26/2022-09/26/2022; and 10/03/2022-11/03/2022. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): five (5) days b. hours (short causes) (specify): 8. 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: 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 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: JANE BE DOE CASE NUMBER: DEFENDANT/RESPONDENT: BIG BROTHERS BIG SISTERS OF AMERICA, et al. 21CV000805 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. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: JANE BE DOE CASE NUMBER: DEFENDANT/RESPONDENT: BIG BROTHERS BIG SISTERS OF AMERICA, et al. 21CV000805 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 (specify moving party, type of motion, and issues): The party or parties expect to file the following motions before trial 16. Discovery a. The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Plaintiff Written Discovery Within 9 mos. Plaintiff Depositions Within 9 mos. Plaintiff Subpoena's to Third Parties Within 6 mos. Plaintiff 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: JANE BE DOE CASE NUMBER: DEFENDANT/RESPONDENT: BIG BROTHERS BIG SISTERS OF AMERICA, et al. 21CV000805 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. 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): 16 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: February 7, 2022 Courtney Pendry, Esq. (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 EXHIBIT 1 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF ORANGE 3 I am employed in the county of Orange, State of California. I am over the age of 18 and 4 not a party to the within action; my business address is 19100 Von Karman Ave., Suite 800, Irvine, CA 92612. 5 On February 7, 2022 I served the foregoing document described as CASE 6 MANAGEMENT STATEMENT on the interested parties in this action by placing a true copy thereof enclosed in sealed envelope(s) addressed as follows: 7 SEE ATTACHED SERVICE LIST 8 [X] BY U.S. MAIL: I served the documents on the parties indicate on the attached service list by enclosing them in an envelope and placing the envelope for collection and mailing following our 9 ordinary business practices. I am readily familiar with this business’s practice of collection and processing of correspondence for mailing. On the same day that correspondence is placed for 10 collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service in a sealed envelope with postage fully prepaid. 11 12 [X] BY E-MAIL OR ELECTRONIC TRANSMISSION Due to the extraordinary circumstances of the current COVID-19 pandemic, and in accordance with the Governor of 19100 Von Karman Avenue, Suite 800 California’s “Shelter-In-Place” order, and by further judicial mandate under Rule 12, or an MANLY, STEWART & FINALDI 13 Telephone: (949) 252-9990 agreement of the parties to accept service by electronic transmission, I emailed from Irvine, ATTORNEYS AT LAW 14 California, a true and correct copy of the above-referenced document(s) described above to the Irvine, CA 92612 persons and email addresses identified below: 15 16 BY FACSIMILE TRANSMISSION: The facsimile machine I used complied with California Rules of Court 2.301 and no error was reported by the machine. Pursuant to rule 2.306(h), I 17 caused the machine to print a record of the transmission, a copy of which is attached to this proof of service. 18 BY OVERNIGHT DELIVERY: I caused the above-referenced document(s) to be delivered via 19 overnight delivery, for delivery to the above address(es). 20 _____(State) I declare under penalty of perjury under the laws of the State of California that the 21 above is true and correct. _____(Federal) I declare that I am employed in the office of a member of the bar of this court 22 at whose direction, the service was made. 23 Executed on February 7, 2022, Irvine, California. 24 ___________________________ 25 Ashley Brimhall 26 27 28 1 PROOF OF SERVICE 1 2 SERVICE LIST 3 VIA ELECTRONIC SERVICE ONLY 4 Alison M. Crane, Esq., Partner 5 Tara A. Murray, Esq. Bledsoe, Diestel, Treppa & Crane LLP 6 180 Sansome, 5th Floor 7 San Francisco, CA 94104 T: 415-981-5411 8 F: 415-981-0352 acrane@bledsoelaw.com 9 tmurray@bledsoelaw.com calendar@bledsoelaw.com 10 Counsel for Defendants Big Brothers Big Sisters of America 11 12 VIA U.S. MAIL ONLY 19100 Von Karman Avenue, Suite 800 JON DAVID WOODY MANLY, STEWART & FINALDI 13 CDCR # AI0930 Telephone: (949) 252-9990 ATTORNEYS AT LAW 14 DOB 07/08/45 Irvine, CA 92612 RJ Donovan Correctional Facility 15 480 Alta Road San Diego, CA 92179 16 VIA U.S. MAIL AND EMAIL 17 Boys & Girls Club of Monterey County Paul Caleo 18 Mark Heisey 1332 La Salle Ave. 19 Seaside, CA 93955 Email: pcaleo@grsm.com 20 mheisey@grsm.com 21 22 23 24 25 26 27 28 2 PROOF OF SERVICE