Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Thomas M. Phillips, SBN 108529 Jodi Rosner, Esq., SBN 178471
The Phillips Firm, APC ELECTRONICALLY FILED
800 W. 6TH Street, Ste. 980
Superior Court of California
Los Angeles, CA 90017
County of Santa Cruz
TELEPHONE NO.213-587-7414 FAX NO. (Optional) 213-457-7515
10/1/2020 4:52 PM
E-MAIL ADDRESS (Optional): tphillips@thephillipsfirm.com
Alex Calvo, Clerk
ATTORNEY FOR (Name) Defendant, STEFAN MATIAS LEON
By: Richard Kersten Seago, Deputy
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CRUZ
STREET ADDRESS 701 Ocean Street
MAILING ADDRESS
Santa Cruz, California 95060
CITY AND ZIP CODE
BRANCH NAME Santa Cruz Courthouse
PLAINTIFF/PETITIONER: DAPHNE BELETSIS, et al.,
DEFENDANT/RESPONDENT: THETA CHI FRATERNITY, et al.,
CASE NUMBER:
CASE MANAGEMENT STATEMENT
19CV03287
(Check one): Z UNLIMITED CASE ❑ LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 10/05/2020 Time: 8:30 a.m. Dept.: 4 Div.: Room:
Address of court (if different from the address above):
Z Notice of Intent to Appear by Telephone, by (name): Jodi Rosner, Esq., SBN 178471
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): Defendant, STEFAN MATIAS LEON
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):
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. Z The following parties named in the complaint or cross-complaint
(1) Z have not been served (specify names and explain why not): John Does 1-10; their identities will be
discovered through the litigation process.
(2) Z have been served but have not appeared and have not been dismissed (specify names): Derek King
(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):
This is a wrongful death/survivial action. The FAC alleges 7 causes of action for negligence, social host liability,
and premises liability.
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
American LegalNet, Inc.
ww..w...t.ormsWorkl'10, \V C0111
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: DAPHNE BELETSIS, et al.,
19CV03289
DEFENDANT/RESPONDENT: STEFAN MATIAS LEON
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)
See Plaintiffs Questionnaire
❑ (If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request El a jury trial 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. [El No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain): Due to the complexity of the case, number of parties, and COVID-19, the case will not be ready
for trial in 12 months.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one): 10 to 15 days
a. Z days (specify number):
b. ❑ hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial
Z 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 El 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
American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: DAPHNE BELETSIS, et al.,
19CV03289
DEFENDANT/RESPONDENT: STEFAN MATIAS LEON
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 I
❑ Agreed to complete mediation by (date):
❑ Mediation completed on (date):
I Settlement conference not yet scheduled
I Settlement conference scheduled for (date):
(2) Settlement
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 j'udicial 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
(6) Other (specify): ❑ ❑ ADR session scheduled for (date):
❑ Agreed to complete ADR session by (date):
❑ ADR completed on (date):
CM-110 [Rev. July 1, 2011j Page 3 of 5
CASE MANAGEMENT STATEMENT
American LegalNet, Inc.
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CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: DAPHNE BELETSIS, et al.,
DEFENDANT/RESPONDENT: STEFAN MATIAS LEON 19CV03289
11. Insurance
a. Z Insurance carrier, if any, for party filing this statement (name): Farmers Insurance Exchange
b. Reservation of rights: Z 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 will 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
Z The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Defendant anticipates bringing a possible MSJ/MSA and Motions in Limine.
16. Discovery
a. ❑ The party or parties have completed all discovery.
b Z The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendant Written discovery January, 2021
Defendant Depositions (parties and witnesses) June, 2021
Defendant 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
American LegalNet, Inc.
www.rormsWork Flow. 0111
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: DAPHNE BELETSIS, et al.,
19CV03289
DEFENDANT/RESPONDENT: STEFAN MATIAS LEON
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. IZ 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): Attorneys for defendant, STEFAN MATIAS LEON filed a Notice of Association with the
Court on/about August 6, 2020 and having just entered the case, has not yet had a chance to adequately
meet and confer with all parties. The parties anticipate meeting and conferring prior to the scheduled hearing
dates.
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):
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: October 01, 2020
Thomas M. Phillips, Esq., SBN 108529
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY 0TTORNEY)
(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
American LegalNet, Inc.
WWW.FormsWorkFlow.com
1 Re: Alexander Beletsis v. Leon
Case Number: 19CV03287
2
3 PROOF OF SERVICE
Code of Civil Procedure §§ 1013a, 2015.5
4
I am a resident of the State of California and over the age of eighteen years, and not a party to the
5 within action. My business address is 800 West 6th Street, Suite 980, Los Angeles, CA 90017.
On October 1 , 2020, I served the following document(s):
6
7 CASE MANAGEMENT CONFERENCE STATEMENT
8
By placing the document(s) listed above in a sealed envelope, addressed as set forth
9 below, and placing the envelope for collection and mailing in the place designated for
such in our offices, following ordinary business practices.
10
By transmitting via facsimile the document(s) listed above to the fax number(s) set
11
forth below on this date before 5:00 p.m.
12
13 By causing a true copy thereof to be personally delivered to the person(s) at the
address(es) set forth below.
14
By electronically serving the document(s) described above via a Court approved File
15
& Serve vendor on those recipients designated on the Transaction Receipt located on
16
the vendor's Website.
17 By electronically serving the document(s) to the electronic mail address set forth
below on this date before 5:00 p.m. pursuant to the signed stipulation of the parties
18 X and consistent with Code of Civil Procedure section 1010.6(a)(2).
SEE ATTACHED SERVICE LIST
19
20 I am readily familiar with the firm's practice of collection and processing correspondence for
mailing with the United States Postal Service. Under that practice, it would be deposited with U.S.
21 Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I
am aware that on motion of the party served, service is presumed invalid ifpostal cancellation date or
22 postage meter date is more than one day after date of deposit for mailing in affidavit.
23
I declare under penalty of perjury under the laws of the State of California that the above is true
24 and correct.
25 Executed on October 1 , 2020, at Los Angeles, COifornia.
26
27
I
Princess McKinley
(
28
1 Re: Alexander Beletsis v. Leon
Case Number: 19CV03287
2
SERVICE LIST
3
Douglas E. Fierberg, Esq.,
4
Jonathon N. Fazzola, Esq.,
5 Lisa N. Cloutier, Esq.,
THE FIERBERG NATIONAL LAW GROUP, PLLC
6 161 East Front Street, Suite 200
Traverse City, MI 49684
7 T: (202) 351-0510
F: (231) 252-8100
8
dfierberg@tfnlgroup.com
9 jfazzola@tfnlgroup.com
lcloutier@tfnlgroup.com
10 tpicard@tfnlgroup.com
11
In Association with
12
Ivo Labar, Esq.,
13 SAWYER & LABAR, LLP
201 Mission Street, Suite 2240
14 San Francisco, CA 94105
T: (415) 262-3820
15
labar@sawyerlabar.com
16
Attorneys for Plaintiffs DAPHNE BELETSIS and YVONNE RAINEY
17
18 Matthew C. Jaime, Esq.,
Robert W. Sweetin., ESQ.,
19 METHENY SEARS LINKERT & JAIME, LLP
3638 American River Drive
20 Sacramento, CA 95864
T: (916) 978-3434
21 F: (916) 978-3430
miaimea,mathenvsears.com
22 rsweetin@mathenysears.com
23
Attorneys for Defendant, CHRISTOPHER GUEVARA
24
25
26
27
28
1 Andrew M. Lauderdale, ESQ.
STRATMAN, PEDERSEN & LAUDERDALE
2 1 Almaden Boulevard, Suite 400
San Jose, CA 95113
3
4 Mailing Address:
P.O. Box 258829
5 Oklahoma City, OK 73125-8829
T: (408) 274-5325
6 F: (408) 271-5301
andrew.lauderdale@farmersinsurance.com
7
8 Counsel for Defendant, QUINN MCLAUGHLIN
9
Michael C. Osborne, Esq.
10 Jaskiran Samra, ESQ.,
COKINOS & YOUNG
11 One Embarcadero Center, Suite 390
San Francisco, CA 94111
12 T: (415) 228-0208; T:650-291-1446
mosborne@cokinoslaw.com
13
jsamra@cokinoslaw.com
14 asanchez@cokinoslaw.com
15
Counsel for Defendant, THETA CHI FRATERNITY, INC.,
16
17 David Anthony Tartaalio, Esq.,
MUSICK PEELER
18 One Wilshire Building
624 South Grand Avenue, Suite 2000
19 Los Angeles, CA 90017-3383
T: (213) 629-7705
20
F: (213) 624-1376
21 d.tartaglio@musickpeeler.com
22 Attorney for LANDMARK AMERICAN INSURANCE COMPANY
23
24
25
26
27
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1 Derek H. Lim, Esq.
John R. Brydon, Esq.,
2 Shannon Mallory, Esq.,
DEMLER, ARMSTRONG & ROWLAND, LLP
3 1350 Treat Boulevard, Suite 400
Walnut Creek, CA 94597
4
T: (415) 949-1900
5
F: (415) 354-8380
lim@darlaw.com
6 bry@darlaw.com
mal@darlaw.com
7 gil@darlaw.eom
8 Counsel for Defendant BRADLEY VISACKI
9
Mary Childs, Esq.,
10 YOKA & SMITH, LLP
445 South Figueroa Street, 38th Floor
11
Los Angeles, CA 90071
12 T: (213) 427-2300
F: (213) 427-2330
13 mchilds@yokasmith.com
amcnulty@yokasmith.com
14 service@yokasmith.com
15 Counsel for Defendants, BOBBY KARKI, EMMANUEL THOMAS, DEREK KING AND JOHN
DYLAN LEITCH
16
17 Chris Tarkington, Esq.,
Norman L. Chong, Esq.,
18 Joseph D. O'Neil, Esq.,
Samantha Lewin, Esq..,
19 TARKINGTON, O'NEILL, BARRACK & CHONG-SR
100 Stony Point Road, Suite 270
20
Santa Rosa, CA 95401
21 T: 707-576-1380
F: 707-544-3144
22 ctarkato2law.com
joneila,to2law.com
23 therringtonato2law.com
nchon2ato2law.com
24 slewin@to2law.com
25 Counsel for Defendant, NAJPREET KAHLON
26
27
28
1 Julie Azevedo, Esq.,
Shawn Toliver, Esq.,
2 Janet H. Leader, ESQ.,
LEWIS BRISBOIS, BISGAARD & SMITH, LLP
3 2185 North California Boulevard, Suite 300
Walnut Creek, CA 94596-3577
4
T: (925) 357-3456
5 F: (925) 478-3260
julie.azevedo@lewisbrisbois.com
6 shawn.toliver@lewisbrisbois.com
janet.leader@lewisbrisbois.com
7
Counsel for Defendant, JORDAN KEIICHI TAKAYAMA
8
9 Rav Tamaddon, ESQ.
HINSHAW & CULBERTSON, LLP
10
11601 Wilshire Boulevard, Suite 800
11 Los Angeles, CA 90025
T: (310) 909-800
12 F: (310) 909-8001
rtamaddon@hinshawlaw.corn
13
In Association with
14
15 Robert Romero, Esq.,
HINSHAW & CULBERTSON, LLP
16 One California Street, 18th Floor•
San Francisco, CA 94111
17 T: 415-362-6000
F: 415-834-9070
18
rromero@hinshawlaw.com
19 KHightower@hinshawlaw.com
20 Attorneys for Defendant, ZACHARY NASH DAVIS
21
Alan F. Hunter, ESQ.
22 GAVIN CUNNINGHAM & HUNTER
1530 The Alameda, Suite 210
23 San Jose, CA 95126
T: (408) 294-8500
24
F: (408) 294-8596
25 hunter@gclitigation.com
joann@gclitigation.com
26 landess@gclitigation.com
bussell@gclitigation.com
27
Attorneys for Defendant, RAFAEL GARCIA, JR.
28
1 Patrick Ball, ESQ.,
Idin Kashefipour, Esa.,
2 MESSNER REEVES, LLP
610 Newport Center Drive, Suite 420
3
Newport Beach, CA 92660
4 T: (949) 612-9128
F: (310) 889-0896
5 pballa,messner.com
ikashefipour@messner.com
6
Attorneys for MOISES GARCIA
7
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Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Thomas M. Phillips, SBN 108529 Jodi Rosner, Esq., SBN 178471 The Phillips Firm, APC ELECTRONICALLY FILED 800 W. 6TH Street, Ste. 980 Superior Court of California Los Angeles, CA 90017 County of Santa Cruz TELEPHONE NO.213-587-7414 FAX NO. (Optional) 213-457-7515 10/1/2020 4:52 PM E-MAIL ADDRESS (Optional): tphillips@thephillipsfirm.com Alex Calvo, Clerk ATTORNEY FOR (Name) Defendant, STEFAN MATIAS LEON By: Richard Kersten Seago, Deputy SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CRUZ STREET ADDRESS 701 Ocean Street MAILING ADDRESS Santa Cruz, California 95060 CITY AND ZIP CODE BRANCH NAME Santa Cruz Courthouse PLAINTIFF/PETITIONER: DAPHNE BELETSIS, et al., DEFENDANT/RESPONDENT: THETA CHI FRATERNITY, et al., CASE NUMBER: CASE MANAGEMENT STATEMENT 19CV03287 (Check one): Z UNLIMITED CASE ❑ LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 10/05/2020 Time: 8:30 a.m. Dept.: 4 Div.: Room: Address of court (if different from the address above): Z Notice of Intent to Appear by Telephone, by (name): Jodi Rosner, Esq., SBN 178471 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): Defendant, STEFAN MATIAS LEON 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): 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. Z The following parties named in the complaint or cross-complaint (1) Z have not been served (specify names and explain why not): John Does 1-10; their identities will be discovered through the litigation process. (2) Z have been served but have not appeared and have not been dismissed (specify names): Derek King (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): This is a wrongful death/survivial action. The FAC alleges 7 causes of action for negligence, social host liability, and premises liability. 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 American LegalNet, Inc. ww..w...t.ormsWorkl'10, \V C0111 CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: DAPHNE BELETSIS, et al., 19CV03289 DEFENDANT/RESPONDENT: STEFAN MATIAS LEON 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) See Plaintiffs Questionnaire ❑ (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request El a jury trial 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. [El No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): Due to the complexity of the case, number of parties, and COVID-19, the case will not be ready for trial in 12 months. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): 10 to 15 days a. Z days (specify number): b. ❑ hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial Z 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 El 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 American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: DAPHNE BELETSIS, et al., 19CV03289 DEFENDANT/RESPONDENT: STEFAN MATIAS LEON 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 I ❑ Agreed to complete mediation by (date): ❑ Mediation completed on (date): I Settlement conference not yet scheduled I Settlement conference scheduled for (date): (2) Settlement 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 j'udicial 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 (6) Other (specify): ❑ ❑ ADR session scheduled for (date): ❑ Agreed to complete ADR session by (date): ❑ ADR completed on (date): CM-110 [Rev. July 1, 2011j Page 3 of 5 CASE MANAGEMENT STATEMENT American LegalNet, Inc. 0 14/.N`AvNI:FO.M1..$NY.OrkE10W....C.Q.!» " CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: DAPHNE BELETSIS, et al., DEFENDANT/RESPONDENT: STEFAN MATIAS LEON 19CV03289 11. Insurance a. Z Insurance carrier, if any, for party filing this statement (name): Farmers Insurance Exchange b. Reservation of rights: Z 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 will 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 Z The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Defendant anticipates bringing a possible MSJ/MSA and Motions in Limine. 16. Discovery a. ❑ The party or parties have completed all discovery. b Z The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant Written discovery January, 2021 Defendant Depositions (parties and witnesses) June, 2021 Defendant 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 American LegalNet, Inc. www.rormsWork Flow. 0111 CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: DAPHNE BELETSIS, et al., 19CV03289 DEFENDANT/RESPONDENT: STEFAN MATIAS LEON 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. IZ 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): Attorneys for defendant, STEFAN MATIAS LEON filed a Notice of Association with the Court on/about August 6, 2020 and having just entered the case, has not yet had a chance to adequately meet and confer with all parties. The parties anticipate meeting and conferring prior to the scheduled hearing dates. 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): 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: October 01, 2020 Thomas M. Phillips, Esq., SBN 108529 (TYPE OR PRINT NAME) (SIGNATURE OF PARTY 0TTORNEY) (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 American LegalNet, Inc. WWW.FormsWorkFlow.com 1 Re: Alexander Beletsis v. Leon Case Number: 19CV03287 2 3 PROOF OF SERVICE Code of Civil Procedure §§ 1013a, 2015.5 4 I am a resident of the State of California and over the age of eighteen years, and not a party to the 5 within action. My business address is 800 West 6th Street, Suite 980, Los Angeles, CA 90017. On October 1 , 2020, I served the following document(s): 6 7 CASE MANAGEMENT CONFERENCE STATEMENT 8 By placing the document(s) listed above in a sealed envelope, addressed as set forth 9 below, and placing the envelope for collection and mailing in the place designated for such in our offices, following ordinary business practices. 10 By transmitting via facsimile the document(s) listed above to the fax number(s) set 11 forth below on this date before 5:00 p.m. 12 13 By causing a true copy thereof to be personally delivered to the person(s) at the address(es) set forth below. 14 By electronically serving the document(s) described above via a Court approved File 15 & Serve vendor on those recipients designated on the Transaction Receipt located on 16 the vendor's Website. 17 By electronically serving the document(s) to the electronic mail address set forth below on this date before 5:00 p.m. pursuant to the signed stipulation of the parties 18 X and consistent with Code of Civil Procedure section 1010.6(a)(2). SEE ATTACHED SERVICE LIST 19 20 I am readily familiar with the firm's practice of collection and processing correspondence for mailing with the United States Postal Service. Under that practice, it would be deposited with U.S. 21 Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid ifpostal cancellation date or 22 postage meter date is more than one day after date of deposit for mailing in affidavit. 23 I declare under penalty of perjury under the laws of the State of California that the above is true 24 and correct. 25 Executed on October 1 , 2020, at Los Angeles, COifornia. 26 27 I Princess McKinley ( 28 1 Re: Alexander Beletsis v. Leon Case Number: 19CV03287 2 SERVICE LIST 3 Douglas E. Fierberg, Esq., 4 Jonathon N. Fazzola, Esq., 5 Lisa N. Cloutier, Esq., THE FIERBERG NATIONAL LAW GROUP, PLLC 6 161 East Front Street, Suite 200 Traverse City, MI 49684 7 T: (202) 351-0510 F: (231) 252-8100 8 dfierberg@tfnlgroup.com 9 jfazzola@tfnlgroup.com lcloutier@tfnlgroup.com 10 tpicard@tfnlgroup.com 11 In Association with 12 Ivo Labar, Esq., 13 SAWYER & LABAR, LLP 201 Mission Street, Suite 2240 14 San Francisco, CA 94105 T: (415) 262-3820 15 labar@sawyerlabar.com 16 Attorneys for Plaintiffs DAPHNE BELETSIS and YVONNE RAINEY 17 18 Matthew C. Jaime, Esq., Robert W. Sweetin., ESQ., 19 METHENY SEARS LINKERT & JAIME, LLP 3638 American River Drive 20 Sacramento, CA 95864 T: (916) 978-3434 21 F: (916) 978-3430 miaimea,mathenvsears.com 22 rsweetin@mathenysears.com 23 Attorneys for Defendant, CHRISTOPHER GUEVARA 24 25 26 27 28 1 Andrew M. Lauderdale, ESQ. STRATMAN, PEDERSEN & LAUDERDALE 2 1 Almaden Boulevard, Suite 400 San Jose, CA 95113 3 4 Mailing Address: P.O. Box 258829 5 Oklahoma City, OK 73125-8829 T: (408) 274-5325 6 F: (408) 271-5301 andrew.lauderdale@farmersinsurance.com 7 8 Counsel for Defendant, QUINN MCLAUGHLIN 9 Michael C. Osborne, Esq. 10 Jaskiran Samra, ESQ., COKINOS & YOUNG 11 One Embarcadero Center, Suite 390 San Francisco, CA 94111 12 T: (415) 228-0208; T:650-291-1446 mosborne@cokinoslaw.com 13 jsamra@cokinoslaw.com 14 asanchez@cokinoslaw.com 15 Counsel for Defendant, THETA CHI FRATERNITY, INC., 16 17 David Anthony Tartaalio, Esq., MUSICK PEELER 18 One Wilshire Building 624 South Grand Avenue, Suite 2000 19 Los Angeles, CA 90017-3383 T: (213) 629-7705 20 F: (213) 624-1376 21 d.tartaglio@musickpeeler.com 22 Attorney for LANDMARK AMERICAN INSURANCE COMPANY 23 24 25 26 27 28 1 Derek H. Lim, Esq. John R. Brydon, Esq., 2 Shannon Mallory, Esq., DEMLER, ARMSTRONG & ROWLAND, LLP 3 1350 Treat Boulevard, Suite 400 Walnut Creek, CA 94597 4 T: (415) 949-1900 5 F: (415) 354-8380 lim@darlaw.com 6 bry@darlaw.com mal@darlaw.com 7 gil@darlaw.eom 8 Counsel for Defendant BRADLEY VISACKI 9 Mary Childs, Esq., 10 YOKA & SMITH, LLP 445 South Figueroa Street, 38th Floor 11 Los Angeles, CA 90071 12 T: (213) 427-2300 F: (213) 427-2330 13 mchilds@yokasmith.com amcnulty@yokasmith.com 14 service@yokasmith.com 15 Counsel for Defendants, BOBBY KARKI, EMMANUEL THOMAS, DEREK KING AND JOHN DYLAN LEITCH 16 17 Chris Tarkington, Esq., Norman L. Chong, Esq., 18 Joseph D. O'Neil, Esq., Samantha Lewin, Esq.., 19 TARKINGTON, O'NEILL, BARRACK & CHONG-SR 100 Stony Point Road, Suite 270 20 Santa Rosa, CA 95401 21 T: 707-576-1380 F: 707-544-3144 22 ctarkato2law.com joneila,to2law.com 23 therringtonato2law.com nchon2ato2law.com 24 slewin@to2law.com 25 Counsel for Defendant, NAJPREET KAHLON 26 27 28 1 Julie Azevedo, Esq., Shawn Toliver, Esq., 2 Janet H. Leader, ESQ., LEWIS BRISBOIS, BISGAARD & SMITH, LLP 3 2185 North California Boulevard, Suite 300 Walnut Creek, CA 94596-3577 4 T: (925) 357-3456 5 F: (925) 478-3260 julie.azevedo@lewisbrisbois.com 6 shawn.toliver@lewisbrisbois.com janet.leader@lewisbrisbois.com 7 Counsel for Defendant, JORDAN KEIICHI TAKAYAMA 8 9 Rav Tamaddon, ESQ. HINSHAW & CULBERTSON, LLP 10 11601 Wilshire Boulevard, Suite 800 11 Los Angeles, CA 90025 T: (310) 909-800 12 F: (310) 909-8001 rtamaddon@hinshawlaw.corn 13 In Association with 14 15 Robert Romero, Esq., HINSHAW & CULBERTSON, LLP 16 One California Street, 18th Floor• San Francisco, CA 94111 17 T: 415-362-6000 F: 415-834-9070 18 rromero@hinshawlaw.com 19 KHightower@hinshawlaw.com 20 Attorneys for Defendant, ZACHARY NASH DAVIS 21 Alan F. Hunter, ESQ. 22 GAVIN CUNNINGHAM & HUNTER 1530 The Alameda, Suite 210 23 San Jose, CA 95126 T: (408) 294-8500 24 F: (408) 294-8596 25 hunter@gclitigation.com joann@gclitigation.com 26 landess@gclitigation.com bussell@gclitigation.com 27 Attorneys for Defendant, RAFAEL GARCIA, JR. 28 1 Patrick Ball, ESQ., Idin Kashefipour, Esa., 2 MESSNER REEVES, LLP 610 Newport Center Drive, Suite 420 3 Newport Beach, CA 92660 4 T: (949) 612-9128 F: (310) 889-0896 5 pballa,messner.com ikashefipour@messner.com 6 Attorneys for MOISES GARCIA 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28