Preview
CM-110
ATTQRNEY QR pARTY wlTHQUT ATTQRNEY (Name, stale Bar numoer and address) FOR COURT USE ONL Y
Matthew A. Haulk (SBN: 272457)
RAGGHIANTI FREITAS, LLP
1101 Fifth Avenue, Suite 100
San Rafael, California 94901
453-9433 11/5/2019
~ELE~~o~ENo. (415) Fax (41 5)
No(oprionat). 453 8269
(0 Io
E MAIL ADDREss I) mhau(kerf lawllp.corn
ATTQRNEY FQR (Name)Defendants and Cross-Complainants PUNITK. SARNA ft PUJA SARNA
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO
sTREETADDREss 400 County Center
MAILING ADDRESS
c(TY AND 2(P coDE Redwood City, CA 94063-1 655
BRANCH NAME
PLAiNTiFFA ETmoNER: LOUIS PAYCHECK, et al.
DEFENDANT/REsPQNDENT: PUNIT K. SARNA, et al.
CASE MANAGEMENT STATEMENT
~
CASE NUMBER
(Check one)( ~X UNLIMITED CASE LIMITED CASE 19CIV02595
(Amount demanded (Amount demanded is $ 25,000
exceeds $ 25,000) orless)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: November 20, 2019 Time: 9:00 a.m. Deptc 11 Div J Room:
Address of court the address above):
((f different from
Notice of Intent to Appear by Telephone, by (name)( MattheWA. Haulk
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)( Defendants and Cross-Comptainants pUNIT It pUJA SARNA
b. ~ This statement is submitted jointly by parties (names)(
K. SARNA
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-comp/a/nants only)
a. The complaint was filed on (date)(
b. ~x The cross-complaint, if any, was filed on (date): July 11, 2019
3 Service (to be answered by plaintiffs and cross-comp/a/nants 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 (spec(fy 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 (n case, and the date by which
they may be served):
4. Description of case
a. Type of case in
Breach
~
of Contract,
complaint
Breach
~x
of
cross-complaint
Express Warranty,
(Describe, including causes of act/on):
Breach of Implied Warranty, Negligence,
for Violation of B&P 57160 B on License Bond.
Page I of 5
MandatoryUse,
Form Adoptedfor ~
ESSentialI CASE MANAGEMENT STATEMENT Cal Rules of Court
Judea( Counaiof California
20lfl
CMI(0(Rev )utrf
ILJ3
ces
I
mI I&MFOrma
rules 3 720-3 730
www,courts ca gov
CM-110
PLAINTIFF/PETITIDNER:LOU (5 PAYCHECK, et al. CASE NUMBER
19CIV02595
DEFENDANT/REsr DNDENT: PUN)T K. SARNA, 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 (/nd/ca/e 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)
Contractor used an il(egal contract, violated the Contractor State Licence Law, failed to
complete the work within the agreed-upon deadline, and the work was shoddy, and failed to
conform to standard of care.
~ (If morespace is needed, check th/s box and attach a page designated as Attachment 45.)
5. Jury or nonjury trial
The party or parties request
requesting a jury trial):
~» a jury trial ~ a nonjury trial. (If more than one party, provide the name of each party
6. Trial date
a.
b.
~~»
The trial has been set for (date):
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 (I/
not, explain):
c. Dates on which parties or attorneys will not be available for trial (spec/fy dates and explain reasons for unavailability):
March 9-31, 2020.
7. Estimated length of trial
The party or parties estimate that the trial
willtake (check one):
a. ~» days (spemfy number): 3-4
b. ~ hours (short causes) (spec//y):
Trial representation (to be answered for each partyj
The party or parties will be represented at trial
a. Attorney:
~» by the attorney or party listed in the caption ~ by the following
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: Party represented.
~ Additional representation is described inAttachment 8.
g.
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
in rule 3.221
~» has ~ has not provided the ADR information package identified
to the ckent 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 section1141.11 or to civil action
mediation under of 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
mediation under Code of Civil Procedure section 1775 et seq.
of the California Rules of Court or from civil action
(specify exemption):
CM-110IRee J ly1,2011] CASE MANAGEMENT STATEMENT Page2 of 5
( p~P; 'ssential
ces.corn,bbFOrlria-
CM-110
PLAINTIFF/PETITIDNER:LOUI5 PAYCHE(.K, et a(. CASE NUMBER
19CIV02595
DEFENDANT/REsPQNDENT: PUNIT K. SARNA, 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 a// that app/y 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'DR
processes (check a// that app/y): stipulation):
Mediation session not yet scheduled
(1) Mediation ~ Mediation session scheduled for (date):
~ 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
(3) Neutral evaluation
~ Neutral evaluation scheduled for (date):
~ Agreed to complete neutral evaluation by (date)
~ Neutral evaluation completed on (date):
~ Judicial arbitration not yet scheduled
(4) Nonbinding judicial ~ Judicial arbitration scheduled for (daie):
arbitration
~ Agreed to complete iudicial arbitration by (date):
~ Judicial arbitration completed on (da/e):
~ Private arbitration not yet scheduled
(5) Binding private ~ Private arbitration scheduled for (date):
arbitration
~ Agreed to complete private arbitration by (da/e):
~ Private arbitration completed on (da/e):
~ ADR session not yet scheduled
(6) Other (speci/y): ~ ADR session scheduled for (date):
~ Agreed to complete ADR session by (date):
~ ADR completed on (date):
CM-110 IReu July
201II
1, CASE NIANAGEMENT STATEMENT Page 0 of 5
( Lrg ESSential
cegcom egf erma
.1
CM-110
PLAINTIFF/PETITIONER: LOUIS PAYCHECK, et al. CASE NUMBER
19CIV02595
DEFENDANT/RESPONDENT: PUNIT K. SARNA, et al.
11. Insurance
a.
b
~ Insurance carrier, if any, for party filing this statement (name):
Reservation ofrights: ~ Yes ~ No
c. ~ Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's lurisdiction or processing of this case, and describe the status
~ Bankruptcy
Status.
~ Other (specify):
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:
b.
~
~
Additional cases are descnbed in Attachment 13a.
A motion to ~ consolidate ~ coordinate willbe 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.
b.
~
~54
The party or parties have completed all discovery.
The following discovery will be completed by the date specified (descnbe a/I anticipated discovery):
~part Descriotion Date
TBD.
c. ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (speci fy):
CM-110 IRey July 1, 2011I CASE MANAGEMENT STATEMENT Peg 4415
QJLP'ssential
'gponns-
CM-110
PLAINTIFF/PETITIQNER'OUIS PAYCHECK, et aI. CASE NUMBER
19CIV02595
DEFENDANT/REsPQNDENT: PUNIT K. SARNA, et al.
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 specifical/y why economic litigation procedures relating to discovery or trial
should not apply to this case):
18 Otherissues
~ 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. ~)r 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 nol, 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):
Iam completely famihar 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: NOvember 5, 2019
Matt hpw A HA((lk
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
~ Additional signatures are attached.
Cra-110(ReJuly 1,201(] CASE MANAGEMENT STATEMENT Page 5 of
5
( L[3 Essential
if~JForms.
PROOF OF SERVICE
Paycheck v. Sama, et al.
San Mateo County Superior Court Case Noc 19CIV02595
4 1. At the time of service, Iwas at least 18 years of age and not a party to this legal action.
5 2. My business address is 1101 Fifth Avenue, Suite 100, San Rafael, CA 94901.
3. I served Copies ofthe Following Documents:
~ CASE MANAGEMENT STATEMENT
9
4 I served the documents listed above in Item 3on the following persons at the addresses
10 listed:
Richard M. Kelly
12 Michael Mengarelli
KELLY LITIGATION GROUP, INC.
13 3 Lagoon Drive, Suite 225
Redwood City,CA 94065
14 T: 650-591-2282
F;
15
E: rkellytmkellylitigationgroup.corn
16 Attorneys for Plaintiff and Cross-DeFendants
LOUIS PAYCHECK dba EUROPEAN
17 ENTERPRISES and Cross-Defendant
SURETEC INDEMNITY COMPANY
By Personal Service. I personally delivered the documents on the date shown below to
19
the persons at the addresses listed above in Item 4. (1) For a party represented by an
20 attorney, delivery was made to the attorney or at the attorney's office by leaving the
documents in an envelope or package clearly labeled to identify the attorney being
21 served with a receptionist or an individual in charge of the office. (2) For a party
delivery was made to the party or by leaving the documents in the party's residence
22 between the hours of eight in the morning and six inthe evening with some person
not less than 18 years of age.
23
By United States Mail. I enclosed the documents in a sealed envelope or package, in
the mail at San Rafael, California, where I am a resident or employee in the County of
24
Marin where the mailing occurred. I addressed the sealed envelope or package to the
25
persons at the addresses in Item 4 and (specify one):
(1) Deposited the sealed envelope in a United States Postal Service mailbox with
26 the postage fully prepaid on the date shown below
(2)X Placed the envelope for collection and mailing on the date shown below,
27 following our ordinary business practices and I am readily familiar with this
business's practice for collecting and processing correspondence For mailing.
PROOF OF SERVICE
On the same day that correspondence is placed for 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.
c. By Overnight Delivery. Pursuant to California Rules of Court, Rule 8.25, Ienclosed the
documents on the date shown below in an envelope or package provided by an
overnight delivery carrier and addressed to the person at the addresses in Item 4.
placed the envelope or package for collection and overnight delivery at an officeor a
regularly utilized drop box of the overnight delivery carrier.
d. By Messenger Service. I served the documents on the date shown below by placing
them in an envelope or package addressed to the person on the addresses listed in
Item 4 and providing them to a professional messenger service for service.
e. By Fax Transmission. Based on an agreement to accept service by fax transmission, I
faxed the documents on the date shown below to the fax numbers of persons listed in
Item 4. No error was reported by the fax machine that I used
f. By Electronic Transmission. Based on a court order or an agreement of the parties to
accept electronic service, Icaused the documents to be sent on the date shown below
to the persons at the electronic service address listed above in Item 4. Idid not receive
10 within a reasonable time af'terthe transmission any electronic message or other
indication that the transmission was unsuccessful.
Iserved the documents by the means described above on November 5, 2019
12
Ideclare under penalty of perjuiy that this document is signed in San Rafael, California
13 under the laws of the State of California and that the foregoing is true and correct.
14
15
November 5,
Date
2019 jennifer L. Page, CCLS
IType or Print Name)
-f. W0'o~
(Sigihfture@ Declarant) U
16
17
19
20
21
22
23
24
25
26
27
28
PROOF OF SERVICE
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CM-110 ATTQRNEY QR pARTY wlTHQUT ATTQRNEY (Name, stale Bar numoer and address) FOR COURT USE ONL Y Matthew A. Haulk (SBN: 272457) RAGGHIANTI FREITAS, LLP 1101 Fifth Avenue, Suite 100 San Rafael, California 94901 453-9433 11/5/2019 ~ELE~~o~ENo. (415) Fax (41 5) No(oprionat). 453 8269 (0 Io E MAIL ADDREss I) mhau(kerf lawllp.corn ATTQRNEY FQR (Name)Defendants and Cross-Complainants PUNITK. SARNA ft PUJA SARNA SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO sTREETADDREss 400 County Center MAILING ADDRESS c(TY AND 2(P coDE Redwood City, CA 94063-1 655 BRANCH NAME PLAiNTiFFA ETmoNER: LOUIS PAYCHECK, et al. DEFENDANT/REsPQNDENT: PUNIT K. SARNA, et al. CASE MANAGEMENT STATEMENT ~ CASE NUMBER (Check one)( ~X UNLIMITED CASE LIMITED CASE 19CIV02595 (Amount demanded (Amount demanded is $ 25,000 exceeds $ 25,000) orless) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: November 20, 2019 Time: 9:00 a.m. Deptc 11 Div J Room: Address of court the address above): ((f different from Notice of Intent to Appear by Telephone, by (name)( MattheWA. Haulk 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)( Defendants and Cross-Comptainants pUNIT It pUJA SARNA b. ~ This statement is submitted jointly by parties (names)( K. SARNA 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-comp/a/nants only) a. The complaint was filed on (date)( b. ~x The cross-complaint, if any, was filed on (date): July 11, 2019 3 Service (to be answered by plaintiffs and cross-comp/a/nants 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 (spec(fy 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 (n case, and the date by which they may be served): 4. Description of case a. Type of case in Breach ~ of Contract, complaint Breach ~x of cross-complaint Express Warranty, (Describe, including causes of act/on): Breach of Implied Warranty, Negligence, for Violation of B&P 57160 B on License Bond. Page I of 5 MandatoryUse, Form Adoptedfor ~ ESSentialI CASE MANAGEMENT STATEMENT Cal Rules of Court Judea( Counaiof California 20lfl CMI(0(Rev )utrf ILJ3 ces I mI I&MFOrma rules 3 720-3 730 www,courts ca gov CM-110 PLAINTIFF/PETITIDNER:LOU (5 PAYCHECK, et al. CASE NUMBER 19CIV02595 DEFENDANT/REsr DNDENT: PUN)T K. SARNA, 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 (/nd/ca/e 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) Contractor used an il(egal contract, violated the Contractor State Licence Law, failed to complete the work within the agreed-upon deadline, and the work was shoddy, and failed to conform to standard of care. ~ (If morespace is needed, check th/s box and attach a page designated as Attachment 45.) 5. Jury or nonjury trial The party or parties request requesting a jury trial): ~» a jury trial ~ a nonjury trial. (If more than one party, provide the name of each party 6. Trial date a. b. ~~» The trial has been set for (date): 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 (I/ not, explain): c. Dates on which parties or attorneys will not be available for trial (spec/fy dates and explain reasons for unavailability): March 9-31, 2020. 7. Estimated length of trial The party or parties estimate that the trial willtake (check one): a. ~» days (spemfy number): 3-4 b. ~ hours (short causes) (spec//y): Trial representation (to be answered for each partyj The party or parties will be represented at trial a. Attorney: ~» by the attorney or party listed in the caption ~ by the following b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: Party represented. ~ Additional representation is described inAttachment 8. g. 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 in rule 3.221 ~» has ~ has not provided the ADR information package identified to the ckent 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 section1141.11 or to civil action mediation under of 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 mediation under Code of Civil Procedure section 1775 et seq. of the California Rules of Court or from civil action (specify exemption): CM-110IRee J ly1,2011] CASE MANAGEMENT STATEMENT Page2 of 5 ( p~P; 'ssential ces.corn,bbFOrlria- CM-110 PLAINTIFF/PETITIDNER:LOUI5 PAYCHE(.K, et a(. CASE NUMBER 19CIV02595 DEFENDANT/REsPQNDENT: PUNIT K. SARNA, 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 a// that app/y 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'DR processes (check a// that app/y): stipulation): Mediation session not yet scheduled (1) Mediation ~ Mediation session scheduled for (date): ~ 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 (3) Neutral evaluation ~ Neutral evaluation scheduled for (date): ~ Agreed to complete neutral evaluation by (date) ~ Neutral evaluation completed on (date): ~ Judicial arbitration not yet scheduled (4) Nonbinding judicial ~ Judicial arbitration scheduled for (daie): arbitration ~ Agreed to complete iudicial arbitration by (date): ~ Judicial arbitration completed on (da/e): ~ Private arbitration not yet scheduled (5) Binding private ~ Private arbitration scheduled for (date): arbitration ~ Agreed to complete private arbitration by (da/e): ~ Private arbitration completed on (da/e): ~ ADR session not yet scheduled (6) Other (speci/y): ~ ADR session scheduled for (date): ~ Agreed to complete ADR session by (date): ~ ADR completed on (date): CM-110 IReu July 201II 1, CASE NIANAGEMENT STATEMENT Page 0 of 5 ( Lrg ESSential cegcom egf erma .1 CM-110 PLAINTIFF/PETITIONER: LOUIS PAYCHECK, et al. CASE NUMBER 19CIV02595 DEFENDANT/RESPONDENT: PUNIT K. SARNA, et al. 11. Insurance a. b ~ Insurance carrier, if any, for party filing this statement (name): Reservation ofrights: ~ Yes ~ No c. ~ Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's lurisdiction or processing of this case, and describe the status ~ Bankruptcy Status. ~ Other (specify): 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: b. ~ ~ Additional cases are descnbed in Attachment 13a. A motion to ~ consolidate ~ coordinate willbe 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. b. ~ ~54 The party or parties have completed all discovery. The following discovery will be completed by the date specified (descnbe a/I anticipated discovery): ~part Descriotion Date TBD. c. ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (speci fy): CM-110 IRey July 1, 2011I CASE MANAGEMENT STATEMENT Peg 4415 QJLP'ssential 'gponns- CM-110 PLAINTIFF/PETITIQNER'OUIS PAYCHECK, et aI. CASE NUMBER 19CIV02595 DEFENDANT/REsPQNDENT: PUNIT K. SARNA, et al. 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 specifical/y why economic litigation procedures relating to discovery or trial should not apply to this case): 18 Otherissues ~ 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. ~)r 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 nol, 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): Iam completely famihar 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: NOvember 5, 2019 Matt hpw A HA((lk (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) ~ Additional signatures are attached. Cra-110(ReJuly 1,201(] CASE MANAGEMENT STATEMENT Page 5 of 5 ( L[3 Essential if~JForms. PROOF OF SERVICE Paycheck v. Sama, et al. San Mateo County Superior Court Case Noc 19CIV02595 4 1. At the time of service, Iwas at least 18 years of age and not a party to this legal action. 5 2. My business address is 1101 Fifth Avenue, Suite 100, San Rafael, CA 94901. 3. I served Copies ofthe Following Documents: ~ CASE MANAGEMENT STATEMENT 9 4 I served the documents listed above in Item 3on the following persons at the addresses 10 listed: Richard M. Kelly 12 Michael Mengarelli KELLY LITIGATION GROUP, INC. 13 3 Lagoon Drive, Suite 225 Redwood City,CA 94065 14 T: 650-591-2282 F; 15 E: rkellytmkellylitigationgroup.corn 16 Attorneys for Plaintiff and Cross-DeFendants LOUIS PAYCHECK dba EUROPEAN 17 ENTERPRISES and Cross-Defendant SURETEC INDEMNITY COMPANY By Personal Service. I personally delivered the documents on the date shown below to 19 the persons at the addresses listed above in Item 4. (1) For a party represented by an 20 attorney, delivery was made to the attorney or at the attorney's office by leaving the documents in an envelope or package clearly labeled to identify the attorney being 21 served with a receptionist or an individual in charge of the office. (2) For a party delivery was made to the party or by leaving the documents in the party's residence 22 between the hours of eight in the morning and six inthe evening with some person not less than 18 years of age. 23 By United States Mail. I enclosed the documents in a sealed envelope or package, in the mail at San Rafael, California, where I am a resident or employee in the County of 24 Marin where the mailing occurred. I addressed the sealed envelope or package to the 25 persons at the addresses in Item 4 and (specify one): (1) Deposited the sealed envelope in a United States Postal Service mailbox with 26 the postage fully prepaid on the date shown below (2)X Placed the envelope for collection and mailing on the date shown below, 27 following our ordinary business practices and I am readily familiar with this business's practice for collecting and processing correspondence For mailing. PROOF OF SERVICE On the same day that correspondence is placed for 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. c. By Overnight Delivery. Pursuant to California Rules of Court, Rule 8.25, Ienclosed the documents on the date shown below in an envelope or package provided by an overnight delivery carrier and addressed to the person at the addresses in Item 4. placed the envelope or package for collection and overnight delivery at an officeor a regularly utilized drop box of the overnight delivery carrier. d. By Messenger Service. I served the documents on the date shown below by placing them in an envelope or package addressed to the person on the addresses listed in Item 4 and providing them to a professional messenger service for service. e. By Fax Transmission. Based on an agreement to accept service by fax transmission, I faxed the documents on the date shown below to the fax numbers of persons listed in Item 4. No error was reported by the fax machine that I used f. By Electronic Transmission. Based on a court order or an agreement of the parties to accept electronic service, Icaused the documents to be sent on the date shown below to the persons at the electronic service address listed above in Item 4. Idid not receive 10 within a reasonable time af'terthe transmission any electronic message or other indication that the transmission was unsuccessful. Iserved the documents by the means described above on November 5, 2019 12 Ideclare under penalty of perjuiy that this document is signed in San Rafael, California 13 under the laws of the State of California and that the foregoing is true and correct. 14 15 November 5, Date 2019 jennifer L. Page, CCLS IType or Print Name) -f. W0'o~ (Sigihfture@ Declarant) U 16 17 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE