On May 10, 2019 a
Party Statement
was filed
involving a dispute between
Msalam, Andrew,
Msalam, Ghassan,
Msalam, Jamie,
Msalam, Jamilah,
Msalam, Jimilah,
Msalam, Jonathan,
Msalam, Julnar,
Msalam, Khalil,
and
Arellano, Fred,
Arellano, Freddie A., Jr,
Aria Sarbeland Trust,
Does 4-20 Individually And In Their Official Capacities,
Does 7-20, Individually And In Their Official Capacities,
Gonzalez, Miguel,
Martha Fabiola Sarbeland Trust,
Sarbeland, Aria,
Sarbeland, Martha,
Sarbeland Trust,
for (26) Unlimited Other Real Property
in the District Court of San Mateo County.
Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY
(Name, State Bar number, and address):
Etfltmnififly
L.M. Parmenter (SBN 1761 96) gupemr
b], cm...ficalmhmmnmw agar. Mama
PARMENTER LAW OFFICES gm 11/7/201 9
501 B Street, Ste. 200, San Rafael, CA 94901
BY E5E canfii I gum
TELEPHONE 41 5-738—7901
No.: FAX No. 41 5-738-7901
(Optional): Dfiputj' Cleri-
ADDRESS
E-MAIL LM Parmenter@LawPar.com
(Optional):
KHALIL MSALAM, et
ATTORNEY FOR(Name): Plaintiffs al.
SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F SAN MATEO
STREET ADDRESS: 400 County Center
same
MAILING ADDRESS:
CITYAND ZIP CODERedwood City, CA 94063
BRANCH NAME Superior Court of San Mateo
PLAINTIFF/PETITIONER: KHALIL MSALAM, et al.
DEFENDANT/RESPONDENT: ARIA SARBELAND. et al.
CASE MANAGEMENT STATEMENT CASE NUMBERI
(Check one): UNLIMITED CASE
(Amount demanded
E LIMITED CASE
(Amount demanded is$25,000
19 CIV 02602
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: NOV. 13, 2019 Time: 9:00 AM Dept: 11 Div.: Room:
Address of court different
(if from the address above):
Notice of Intent to Appear by Telephone, by (name): Ligia M. Parmenter
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
1.
a.
b.
E This statement
This statement
is
is
submitted by party (name):
submitted jointly by parties (names): Plaintiffs
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a.
b. E
The complaint was filed on (date):
The cross—complaint, any,
if
May 10, 2019
was filedon (date):
3.
a. E
Service
m
(to be answered by plaintiffs and cross-complainants
A|| partiesnamed in
only)
the complaint and cross-complaint have
named
been served, have appeared, or have been dismissed.
b. The
(1) m
following parties inthe complaint or cross-complaint
have not been served (specify names and explain why not):
(2) E FREDDIE A. ARELLANO, JR. has not been served Motion to Serve by Publication to be
have been served but have not appeared and have not been dismissed (specify names):
filed
(3) E have had a default entered against them (specify names):
c. E The
they may be served):
may be added
following additional parties (specifynames, nature ofinvolvement incase, and date by which
4. Description of ca_se
3- Type 0f case m
Plaintiffswere caused
complaint E cross-complaint (Describe, including causes of action):
injuries and damages as a result of a tenancy at the subject premises. Defendants were
the managers and owners of the subject premises. Minor Plaintiff sustained personal injuries.
Page1of 5
Form AdoptedMandatory Use
for
Judicial Council of California
CAS E MANAG EM ENT STATEM E NT Cal. Rules of Court,
3720—3730
rules
CM—1 1o [Rev.
July
1,201
1] www.courts.ca.gov
CM-110
CASENUMBER=
— PLAINTIFF/PETITIONER: KHALIL MSALAM, et aI.
19 CIV 02602
DEFENDANT/RESPONDENT: ARIA SARBELAND. etaI.
4. b. Provide a brief statement of the case, including any damages. (prersonal 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 reliefis sought, describe the nature of the relief.)
were caused
Plaintiffs injuries and damages as a result of a tenancy at the subject premises. Defendants were
the managers and owners of the subject premises. Minor Plaintiff sustained personal injuries. Plaintiffs
sustained personal injuries, loss of quality of life, emotional distress attorney fees,
,
moving expenses, and other
damages as may be awarded.
E more space
(If isneeded, check thisbox and attach a page designated as Attachment 4b.)
5. Jury or nonjury
The
trial
party or parties request
requesting a jurytrial):
a jury trial E a nonjury trial. more than one party, provide
(If the name of each party
6.
a.
b.
E
Trialdate
The
No
trial
trial
has been setfor
date has been
(date):
set. This case willbe ready for within 12
trial months of the date of the filing of the complaint
(if
not, explain):
c. Dates on which parties or attorneys not be available for
will (specify dates
trial and explain reasons for unavailability):
7. Estimated length of trial
The party or parties estimate that the take (check one):
trial will
7'8
a.
b. E days (specify number):
hours (short causes) (specify):
8. Trial
The
a.
representation
party or parties
Attorney: Trial
(to
will
be answered
be represented
for
at trial
counsel shall be associated.
m
each party)
by the attorney or party
listed inthe caption E by the following:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
Ee. E-mail address:
Additional representation isdescribed inAttachment 8.
g. Party represented:
9.
10.
E
Preference
This case
Alternative
is preference (specify code section):
entitled to
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
(1)
in rule
community programs
3.221
case.
in this
For parties represented by counsel: Counsel
to the client and reviewed
E has E
ADR options with the
has not
client.
provided the ADR information package identified
(2) For self—represented parties:Party E has E has not reviewed the ADR information package identifiedin rule3.221.
b.
(1) E
Referral to judicial arbitration or civil action mediation available).
(if
This matter is subject to mandatoryjudicial 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) E Civil
case to
Plaintiff elects to refer this
Procedure section 1141.11.
and agrees
judicial arbitration to limitrecovery to the amount specified inCode of
(3) E This case is exempt from judicial arbitration under rule 3.811
ofthe California Rules of Courtor from
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
action
civil
CM-“O [ReV-Ju'y
1'2°11]
CASE MANAGEMENT STATEMENT ”962°”
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: KHALIL MSALAM,
_ et al.
19 CIV 02602
DEFENDANT/RESPONDENT: ARIA SARBELAND, et al.
10. c. Indicate theADR process or processes that the party or parties are willing to participate
in,have agreed to participate in, or
have already participatedin (check all that apply and provide the specified information):
The party or parties completing If in the case have agreed to
the party or parties completing this form
thisform are willing to have already completed an ADR process or processes,
participate in or
ADR
participate in the following indicate the status of the processes (attach a copy of the parties'ADR
processes (check allthat apply): stipulation):
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1)Mediation DUDE
Agreed tocomplete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
Settlement Settlement conference scheduled for (date):
(2)
conference DUDE
Agreed tocomplete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation DUDE
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
scheduled
Judicial arbitration not yet
scheduled for (date):
Judicial arbitration
(4) Nonbinding judicial
arbitration
DUDE
Agreed to complete judicial arbitration
by (date):
completed on
Judicial arbitration (date):
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
(5) Binding private
arbitration
DUDE
Agreed to complete private arbitration
by (date):
Private arbitration completedon (date):
ADR session not yet scheduled
(6)Other (specify):
E DUDE
ADR session
Agreed to
scheduled
complete
for (date):
ADR session by (date):
ADR completed on (date):
CM-110 2011]
[Rev. July
1, Page 3 of 5
CASE MANAGEMENT STATEMENT
CMfllfl
CASE NUMBER:
PLAINTIFF/PETITIONER: KHALIL MSALAM et 3L
19 CIV 02602
DEFENDANT/RESPONDENT: ARIA SARBELAND. et al.
11.
a. E
Insurance
Insurance carrier,
E
if
E
any, for party statement (name):
filing this
b.
c. EReservation of rights:
Coverage issues
Yes
will significantly
No
case
affect resolution of this (explain):
12. Jurisdiction
E
Indicate
Status:
any matters
Bankruptcy E
thatmay affect the
Other (specify):
case and describe the
court's jurisdiction or processing of this status.
13.
a_ E
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:
b.
E
E
Additional cases are described
A motion to E
in
consolidate
Attachment 13a.
E coordinate willbe filedby (name party):
E
14. Bifu rcation
The file a motion for an order bifurcating, severing, or coordinating the
party or parties intend to
action (specifymoving party, type of motion, and reasons):
following issues orcauses of
15. Other motions
E The party or parties expect to the following motions before
file (specify
trial moving party, type of motion, and issues):
16.
a. E
Discovery
The party or parties have completed alldiscovery.
b.
m
The
Plaintiffs to
following discovery
the Defendants
willbe completed by the date specified (describe
Description
Form Interogs
allanticipated discovery):
E
TBA
Plaintiffs tothe Defendants Special Interogs TBA
Plaintiffs tothe Defendants Req. Production of Doc. TBA
Plaintiffs tothe Defendants Req. for Adm. TBA
Plaintiffs tothe Defendants Deposition(s) TBA
c_ E The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-1 10 [Rev.
July
1,2011]
CASE MANAGEMENT STATEMENT Page 4 of 5
CM-110
CASE NUMBER
PLAINTIFF/PETITIONER: KHALIL MSALAM, et al.
— 19 CIV 02602
DEFENDANT/RESPONDENT: ARIA SARBELAND- 9t a'-
17.
a. E
Economic litigation
This isa limited case
civil the
(i.e.,
of Civil Procedure sections 90-98
amount demanded is
apply to this case.
$25,000 or less) and the economic procedures
litigation inCode
b. E This
will
is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
explain specifically why economic litigation procedures relating to discovery or trial
discovery will be filed (if checked,
should not apply to this case):
18.
E
Other issues
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19.
a. E
Meet and confer
The party or
of Court(if
parties have met and conferred with
not, explain):
allpartieson allsubjects required by rule 3.724 ofthe California Rules
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. Totalnumber ofpages attached (ifany):
|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: November 4, 2019
Ligia M. Parmenter ’
(TYPEOR PRINT NAM E) OR ATTORNEY)
(SIGNATURE OF PARTY
D
(TYPEOR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
E Additional signatures are attached.
CM-“O [ReV-Ju'v 1120111
CASE MANAGEMENT STATEMENT ”965°”
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Etfltmnififly L.M. Parmenter (SBN 1761 96) gupemr b], cm...ficalmhmmnmw agar. Mama PARMENTER LAW OFFICES gm 11/7/201 9 501 B Street, Ste. 200, San Rafael, CA 94901 BY E5E canfii I gum TELEPHONE 41 5-738—7901 No.: FAX No. 41 5-738-7901 (Optional): Dfiputj' Cleri- ADDRESS E-MAIL LM Parmenter@LawPar.com (Optional): KHALIL MSALAM, et ATTORNEY FOR(Name): Plaintiffs al. SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F SAN MATEO STREET ADDRESS: 400 County Center same MAILING ADDRESS: CITYAND ZIP CODERedwood City, CA 94063 BRANCH NAME Superior Court of San Mateo PLAINTIFF/PETITIONER: KHALIL MSALAM, et al. DEFENDANT/RESPONDENT: ARIA SARBELAND. et al. CASE MANAGEMENT STATEMENT CASE NUMBERI (Check one): UNLIMITED CASE (Amount demanded E LIMITED CASE (Amount demanded is$25,000 19 CIV 02602 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: NOV. 13, 2019 Time: 9:00 AM Dept: 11 Div.: Room: Address of court different (if from the address above): Notice of Intent to Appear by Telephone, by (name): Ligia M. Parmenter INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): 1. a. b. E This statement This statement is is submitted by party (name): submitted jointly by parties (names): Plaintiffs 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. b. E The complaint was filed on (date): The cross—complaint, any, if May 10, 2019 was filedon (date): 3. a. E Service m (to be answered by plaintiffs and cross-complainants A|| partiesnamed in only) the complaint and cross-complaint have named been served, have appeared, or have been dismissed. b. The (1) m following parties inthe complaint or cross-complaint have not been served (specify names and explain why not): (2) E FREDDIE A. ARELLANO, JR. has not been served Motion to Serve by Publication to be have been served but have not appeared and have not been dismissed (specify names): filed (3) E have had a default entered against them (specify names): c. E The they may be served): may be added following additional parties (specifynames, nature ofinvolvement incase, and date by which 4. Description of ca_se 3- Type 0f case m Plaintiffswere caused complaint E cross-complaint (Describe, including causes of action): injuries and damages as a result of a tenancy at the subject premises. Defendants were the managers and owners of the subject premises. Minor Plaintiff sustained personal injuries. Page1of 5 Form AdoptedMandatory Use for Judicial Council of California CAS E MANAG EM ENT STATEM E NT Cal. Rules of Court, 3720—3730 rules CM—1 1o [Rev. July 1,201 1] www.courts.ca.gov CM-110 CASENUMBER= — PLAINTIFF/PETITIONER: KHALIL MSALAM, et aI. 19 CIV 02602 DEFENDANT/RESPONDENT: ARIA SARBELAND. etaI. 4. b. Provide a brief statement of the case, including any damages. (prersonal 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 reliefis sought, describe the nature of the relief.) were caused Plaintiffs injuries and damages as a result of a tenancy at the subject premises. Defendants were the managers and owners of the subject premises. Minor Plaintiff sustained personal injuries. Plaintiffs sustained personal injuries, loss of quality of life, emotional distress attorney fees, , moving expenses, and other damages as may be awarded. E more space (If isneeded, check thisbox and attach a page designated as Attachment 4b.) 5. Jury or nonjury The trial party or parties request requesting a jurytrial): a jury trial E a nonjury trial. more than one party, provide (If the name of each party 6. a. b. E Trialdate The No trial trial has been setfor date has been (date): set. This case willbe ready for within 12 trial months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attorneys not be available for will (specify dates trial and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the take (check one): trial will 7'8 a. b. E days (specify number): hours (short causes) (specify): 8. Trial The a. representation party or parties Attorney: Trial (to will be answered be represented for at trial counsel shall be associated. m each party) by the attorney or party listed inthe caption E by the following: b. Firm: c. Address: d. Telephone number: f. Fax number: Ee. E-mail address: Additional representation isdescribed inAttachment 8. g. Party represented: 9. 10. E Preference This case Alternative is preference (specify code section): entitled to 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 (1) in rule community programs 3.221 case. in this For parties represented by counsel: Counsel to the client and reviewed E has E ADR options with the has not client. provided the ADR information package identified (2) For self—represented parties:Party E has E has not reviewed the ADR information package identifiedin rule3.221. b. (1) E Referral to judicial arbitration or civil action mediation available). (if This matter is subject to mandatoryjudicial 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) E Civil case to Plaintiff elects to refer this Procedure section 1141.11. and agrees judicial arbitration to limitrecovery to the amount specified inCode of (3) E This case is exempt from judicial arbitration under rule 3.811 ofthe California Rules of Courtor from mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): action civil CM-“O [ReV-Ju'y 1'2°11] CASE MANAGEMENT STATEMENT ”962°” CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: KHALIL MSALAM, _ et al. 19 CIV 02602 DEFENDANT/RESPONDENT: ARIA SARBELAND, et al. 10. c. Indicate theADR process or processes that the party or parties are willing to participate in,have agreed to participate in, or have already participatedin (check all that apply and provide the specified information): The party or parties completing If in the case have agreed to the party or parties completing this form thisform are willing to have already completed an ADR process or processes, participate in or ADR participate in the following indicate the status of the processes (attach a copy of the parties'ADR processes (check allthat apply): stipulation): Mediation session not yet scheduled Mediation session scheduled for (date): (1)Mediation DUDE Agreed tocomplete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled Settlement Settlement conference scheduled for (date): (2) conference DUDE Agreed tocomplete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation DUDE Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): scheduled Judicial arbitration not yet scheduled for (date): Judicial arbitration (4) Nonbinding judicial arbitration DUDE Agreed to complete judicial arbitration by (date): completed on Judicial arbitration (date): Private arbitration not yet scheduled Private arbitration scheduled for (date): (5) Binding private arbitration DUDE Agreed to complete private arbitration by (date): Private arbitration completedon (date): ADR session not yet scheduled (6)Other (specify): E DUDE ADR session Agreed to scheduled complete for (date): ADR session by (date): ADR completed on (date): CM-110 2011] [Rev. July 1, Page 3 of 5 CASE MANAGEMENT STATEMENT CMfllfl CASE NUMBER: PLAINTIFF/PETITIONER: KHALIL MSALAM et 3L 19 CIV 02602 DEFENDANT/RESPONDENT: ARIA SARBELAND. et al. 11. a. E Insurance Insurance carrier, E if E any, for party statement (name): filing this b. c. EReservation of rights: Coverage issues Yes will significantly No case affect resolution of this (explain): 12. Jurisdiction E Indicate Status: any matters Bankruptcy E thatmay affect the Other (specify): case and describe the court's jurisdiction or processing of this status. 13. a_ E 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: b. E E Additional cases are described A motion to E in consolidate Attachment 13a. E coordinate willbe filedby (name party): E 14. Bifu rcation The file a motion for an order bifurcating, severing, or coordinating the party or parties intend to action (specifymoving party, type of motion, and reasons): following issues orcauses of 15. Other motions E The party or parties expect to the following motions before file (specify trial moving party, type of motion, and issues): 16. a. E Discovery The party or parties have completed alldiscovery. b. m The Plaintiffs to following discovery the Defendants willbe completed by the date specified (describe Description Form Interogs allanticipated discovery): E TBA Plaintiffs tothe Defendants Special Interogs TBA Plaintiffs tothe Defendants Req. Production of Doc. TBA Plaintiffs tothe Defendants Req. for Adm. TBA Plaintiffs tothe Defendants Deposition(s) TBA c_ E The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-1 10 [Rev. July 1,2011] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 CASE NUMBER PLAINTIFF/PETITIONER: KHALIL MSALAM, et al. — 19 CIV 02602 DEFENDANT/RESPONDENT: ARIA SARBELAND- 9t a'- 17. a. E Economic litigation This isa limited case civil the (i.e., of Civil Procedure sections 90-98 amount demanded is apply to this case. $25,000 or less) and the economic procedures litigation inCode b. E This will is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional explain specifically why economic litigation procedures relating to discovery or trial discovery will be filed (if checked, should not apply to this case): 18. E Other issues The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. a. E Meet and confer The party or of Court(if parties have met and conferred with not, explain): allpartieson allsubjects required by rule 3.724 ofthe California Rules 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. Totalnumber ofpages attached (ifany): |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: November 4, 2019 Ligia M. Parmenter ’ (TYPEOR PRINT NAM E) OR ATTORNEY) (SIGNATURE OF PARTY D (TYPEOR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) E Additional signatures are attached. CM-“O [ReV-Ju'v 1120111 CASE MANAGEMENT STATEMENT ”965°”