Preview
4
: CM-110
"ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar number, and address). FOR COURT USE ONLY
E-MAIL ADDRESS (Optionat:
ATTORNEY FOR (Name} Defendants, BERNARD & REBECCA DEE TE VELDE, Trustees
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN
sTReeT ApDRESS: 180 E. WEBER AVENUE
MAING ADDRESS: P.Q. BOX 201022
ciTyanp zip cone: STOCKTON, CA 95202
BRANCH NAME:
PLAINTIFF/PETITIONERMNA TOVAR, et al.
DEFENDANT/RESPONDENT:BERNARD TE VELDE, et al.
CASE MANAGEMENT STATEMENT GASE NUMBER:
(Check one): UNLIMITED CASE (] LIMITED CASE STK-CV-UPI-2018-10826
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 2/26/19 Time:8:30 a.m. Dept: 11B Div.: Room:
Address of court (if different from the address above):
| Notice of Intent to Appear by Telephone, by (name): Craig C. Caldwell
Craig A. Caldwell, SBN 88551 veeenseg af IhED
Law Office of Shawn C. Moore SUPERIOR COURT - STOCKTON
2251 Harvard Street, Suite 100 .
Sacramento, CA 95815 2019 JAK 23 PH 3:99
TELEPHONE NO: 916-921-9353 FAX NO, (Options 855-214-7884
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):Defendants, BERNARD TE VELDE & REBECCA DEE TE VELDE, Trustees
b. [_] This statement is submitted jointly by parties (names): cf the 2000 Te Velde Family Trust
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. [71 The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a (Al 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-compiaint
(1) £1) have not been served (specify 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 in case, and date by which
they may be served).
4, Description of case
a. Type of case in complaint [£1 cross-complaint (Describe, including causes of action):
Wrongful death; Negligent Infliction of Emotional Distress.
Page 1 of §
Fe CASE MANAGEMENT STATEMENT sohitfne Ries 37203730
‘CM.110 [Rev. July 4, 204%}
BY FAX? CM-140
PLAINTIFFIPETITIONER:MNA TOVAR, et al. ABE NUMBER:
| DEFENDANT/RESPONDENT: BERNARD TE VELDE, et al. STK-CV-UPI- 2018-10826
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 findicate source and amount), estimated future medical expenses, lost
eamings to date, and estimated future lost earings. If equitable relief is sought, describe the nature of the relief)
Wrongful death action arising out of a drowning which occurred at Empire Cut
waterway in the California Delta in Stockton, California.
(df 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
requesting a jury trial):
(] ajury tial [] anonjurytrial. (If more than one party, provide the name of each party
6. Trial date
a. [__] The trial has been set for (date):
b. [-] No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the compiaint (if
nat, explain):
¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
5/20/19; 7/3/19; 7/23/19; 7/29/19; 8/13/19; 8/19/19; 9/10/19; 10/8/19;
10/28/19 -current trials pending
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 15.
b. [J] hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial [2X ] by the attomey or party listed in the caption [__] by the following:
a. Attorney:
bo. Firm:
c. Address:
d, Telephone number: {Fax number:
e. &-mail address: g. Party represented:
(} Additional! representation is described in Attachment 8.
9. Preference
This case is entilled 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 etects 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 Califomia Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
SHEN Rew daly 1.2044] CASE MANAGEMENT STATEMENT Page ZotCM-110
PLAINTIFF/PETITIONER: MNA TOVAR, et al.
DEFENDANT/RESPONDENT: BERNARD TE VELDE, et al.
CASE NUMBER:
STK-CV-UPI-2018-10826
10. ¢, 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 ail that apply and provide the specified information):
The party or parties completing
this form are willing to
participate in the following ADR
processes (check all that apply):
If the party or parties completing this form in the case have agreed to
participate in or have already completed an ADR process or processes,
indicate the status of the processes (attach a copy of the parties’ ADR
stipulation):
(1) Mediation.
x)
Mediation session not yet scheduled
(J Mediation session scheduled for (date):
{[_] Agreed to complete mediation by (date):
(_] Mediation completed on (date):
(2) Settlement
conference
Settlement conference not yet scheduled
{"] Settlement conference scheduled for (date):
{_] Agreed to complete settlement conference by (date):
[_] Settlement conference completed on (date):
[] Neutral evaluation not yet scheduled
(3 Neutral evaluation scheduled for (date):
(3) Neutral evaluation Fo
®) [] Agreed to complete neutral evaluation by (date):
(} Neutral evaluation completed on (date):
[} Judicial arbitration not yet scheduled
(4) Nonbinding judicial og [] Judicial arbitration scheduled for (date):
arbitration [1] Agreed to complete judicial arbitration by (date):
{_] Judicial arbitration completed on (date):
{_] Private arbitration not yet scheduled
(8) Binding private [_] Private arbitration scheduled for (date):
arbitration cy [-} Agreed to complete private arbitration by (date):
[-} Private arbitration completed on (date):
- [-_] ADR session not yet scheduled
[J 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]
CASE MANAGEMENT STATEMENT
Page 3 of §CM-110
PLAINTIFFIPETITIONER: MONA TOVAR, et al. CASE NUMBER:
| DEFENDANT/RESPONDENT: BERNARD TE VELDE, et al. STK-CV-UPI-2018-10826
11. Insurance
a. [X] Insurance carrier, if any, for party filing this statement (name): Nationwide Agribusiness
b. Reservation of rights: [_] Yes
c. [] Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
[) Bankruptcy [1] 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:
(J Additional cases are described in Attachment 13a.
b. CJ} Amotionto [J consofidate [| coordinate will be filed by (name party):
14, Bifurcation
(J 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):
Motions in Limine.
16. Discovery
a. [_] The patty or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe ail anticipated discovery):
Party Description Date
Defendants Subpoena plaintiff's medical records Feb 2019
Defendants Deposition of witnesses Feb 2019
Defendants Deposition of plaintiffs Apr 2019
Defendants Expert discovery Per Code
c. [__] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify): os
CHO TRow. tay 9.2011 CASE MANAGEMENT STATEMENT Page dorCM-110
PLAINTIFF/PETITIONER: MONA TOVAR, et al. ‘CASE NUMBER:
| DEFENDANT/RESPONDENT: BERNARD TE VELDE, et al. STK-CV-UPI-2018-10826
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 civit 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
[1 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):
| 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: January 23 , 2019
Craig A, Caldwell
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
»
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
=] Additional signatures are attached.
GRO Ree day 3.2081 CASE MANAGEMENT STATEMENT Page 5 of27
28
Tovar y. Te Velde, et al. . .
San Joaquin County Superior Court Case #STK-CV-UPI-10826
PROOF OF SERVICE
Iam a citizen ofthe United States and a resident of the County of Sacramento; I am over the
age of eighteen (18) years and not a party to the within action; my business address is Law Office of
Shawn C. Moore, 2251 Harvard Street, Suite 100, Sacramento, California, 95815. I am readily
familiar with the business practice of Law Office of Shawn C. Moore of collecting and processing of
pleadings and correspondence for mailing and depositing with the United States Postal Service that
same day in the ordinary course of business; so that on the date indicated below, I served the
following documents: :
CASE MANAGEMENT STATEMENT
on the parties in said cause, by placing a true copy thereof enclosed in a seated envelope, addressed as
follows:
Attorneys for Plaintiffs Attorney for Defendant, Cross-Defendant & Crass-
Doug S. Saeltzer Complainant Holt Repair & Manufacturing, Inc.
Walkup, Melodia, Kelly & Schoenberger Malcolm D. Schick
650 California Street, 26" Floor Erica C. Gonzalez
San Francisco, CA 94108 G&P Schick
T: (415) 981-7210; F: (415) 358-4522 99 Almaden Blvd., Suite 740
spahlke@walkuplawoftice.com San Jose, CA 95113-1605
T: (408) 995-5050; F: (408) 995-5150
Michael B. Bassi info@gpschicklaw.com
Michael B. Bassi, A Law Corporation egonzalez(@apschicklaw.com
333 Bush Street, Suite 1100
San Francisco, CA 94104
T: (415) 986-8122: F: (415) 986-0733
mbbassi@bassilaw.com
{] U.S. POSTAL SERVICE by placing a true and correct copy of the aforementioned
document(s) in a sealed envelope and placing in the mail depository at my place of business,
with postage prepaid, addressed as listed above. [Code of Civ. Proc. § 1013a(3)]
O FACSIMILE by transmitting the aforementioned document(s) by facsimile at the number
indicated above, which is maintained by said party, and verifying receipt of same. A true and
correct copy of the transmission report is attached hereto and incorporated herein by this
reference. [Code of Civ. Proc. § 1013(e), (f]
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct. Executed on January 23, 2019, at Sacramento, California.
SHELLEY FANNING CG
Preview
4 : CM-110 "ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar number, and address). FOR COURT USE ONLY E-MAIL ADDRESS (Optionat: ATTORNEY FOR (Name} Defendants, BERNARD & REBECCA DEE TE VELDE, Trustees SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN sTReeT ApDRESS: 180 E. WEBER AVENUE MAING ADDRESS: P.Q. BOX 201022 ciTyanp zip cone: STOCKTON, CA 95202 BRANCH NAME: PLAINTIFF/PETITIONERMNA TOVAR, et al. DEFENDANT/RESPONDENT:BERNARD TE VELDE, et al. CASE MANAGEMENT STATEMENT GASE NUMBER: (Check one): UNLIMITED CASE (] LIMITED CASE STK-CV-UPI-2018-10826 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 2/26/19 Time:8:30 a.m. Dept: 11B Div.: Room: Address of court (if different from the address above): | Notice of Intent to Appear by Telephone, by (name): Craig C. Caldwell Craig A. Caldwell, SBN 88551 veeenseg af IhED Law Office of Shawn C. Moore SUPERIOR COURT - STOCKTON 2251 Harvard Street, Suite 100 . Sacramento, CA 95815 2019 JAK 23 PH 3:99 TELEPHONE NO: 916-921-9353 FAX NO, (Options 855-214-7884 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):Defendants, BERNARD TE VELDE & REBECCA DEE TE VELDE, Trustees b. [_] This statement is submitted jointly by parties (names): cf the 2000 Te Velde Family Trust 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. [71 The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a (Al 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-compiaint (1) £1) have not been served (specify 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 in case, and date by which they may be served). 4, Description of case a. Type of case in complaint [£1 cross-complaint (Describe, including causes of action): Wrongful death; Negligent Infliction of Emotional Distress. Page 1 of § Fe CASE MANAGEMENT STATEMENT sohitfne Ries 37203730 ‘CM.110 [Rev. July 4, 204%} BY FAX? CM-140 PLAINTIFFIPETITIONER:MNA TOVAR, et al. ABE NUMBER: | DEFENDANT/RESPONDENT: BERNARD TE VELDE, et al. STK-CV-UPI- 2018-10826 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 findicate source and amount), estimated future medical expenses, lost eamings to date, and estimated future lost earings. If equitable relief is sought, describe the nature of the relief) Wrongful death action arising out of a drowning which occurred at Empire Cut waterway in the California Delta in Stockton, California. (df 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 requesting a jury trial): (] ajury tial [] anonjurytrial. (If more than one party, provide the name of each party 6. Trial date a. [__] The trial has been set for (date): b. [-] No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the compiaint (if nat, explain): ¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 5/20/19; 7/3/19; 7/23/19; 7/29/19; 8/13/19; 8/19/19; 9/10/19; 10/8/19; 10/28/19 -current trials pending 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 15. b. [J] hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial [2X ] by the attomey or party listed in the caption [__] by the following: a. Attorney: bo. Firm: c. Address: d, Telephone number: {Fax number: e. &-mail address: g. Party represented: (} Additional! representation is described in Attachment 8. 9. Preference This case is entilled 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 etects 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 Califomia Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): SHEN Rew daly 1.2044] CASE MANAGEMENT STATEMENT Page ZotCM-110 PLAINTIFF/PETITIONER: MNA TOVAR, et al. DEFENDANT/RESPONDENT: BERNARD TE VELDE, et al. CASE NUMBER: STK-CV-UPI-2018-10826 10. ¢, 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 ail that apply and provide the specified information): The party or parties completing this form are willing to participate in the following ADR processes (check all that apply): If the party or parties completing this form in the case have agreed to participate in or have already completed an ADR process or processes, indicate the status of the processes (attach a copy of the parties’ ADR stipulation): (1) Mediation. x) Mediation session not yet scheduled (J Mediation session scheduled for (date): {[_] Agreed to complete mediation by (date): (_] Mediation completed on (date): (2) Settlement conference Settlement conference not yet scheduled {"] Settlement conference scheduled for (date): {_] Agreed to complete settlement conference by (date): [_] Settlement conference completed on (date): [] Neutral evaluation not yet scheduled (3 Neutral evaluation scheduled for (date): (3) Neutral evaluation Fo ®) [] Agreed to complete neutral evaluation by (date): (} Neutral evaluation completed on (date): [} Judicial arbitration not yet scheduled (4) Nonbinding judicial og [] Judicial arbitration scheduled for (date): arbitration [1] Agreed to complete judicial arbitration by (date): {_] Judicial arbitration completed on (date): {_] Private arbitration not yet scheduled (8) Binding private [_] Private arbitration scheduled for (date): arbitration cy [-} Agreed to complete private arbitration by (date): [-} Private arbitration completed on (date): - [-_] ADR session not yet scheduled [J 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] CASE MANAGEMENT STATEMENT Page 3 of §CM-110 PLAINTIFFIPETITIONER: MONA TOVAR, et al. CASE NUMBER: | DEFENDANT/RESPONDENT: BERNARD TE VELDE, et al. STK-CV-UPI-2018-10826 11. Insurance a. [X] Insurance carrier, if any, for party filing this statement (name): Nationwide Agribusiness b. Reservation of rights: [_] Yes c. [] Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. [) Bankruptcy [1] 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: (J Additional cases are described in Attachment 13a. b. CJ} Amotionto [J consofidate [| coordinate will be filed by (name party): 14, Bifurcation (J 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): Motions in Limine. 16. Discovery a. [_] The patty or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe ail anticipated discovery): Party Description Date Defendants Subpoena plaintiff's medical records Feb 2019 Defendants Deposition of witnesses Feb 2019 Defendants Deposition of plaintiffs Apr 2019 Defendants Expert discovery Per Code c. [__] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): os CHO TRow. tay 9.2011 CASE MANAGEMENT STATEMENT Page dorCM-110 PLAINTIFF/PETITIONER: MONA TOVAR, et al. ‘CASE NUMBER: | DEFENDANT/RESPONDENT: BERNARD TE VELDE, et al. STK-CV-UPI-2018-10826 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 civit 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 [1 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): | 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: January 23 , 2019 Craig A, Caldwell (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) » (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) =] Additional signatures are attached. GRO Ree day 3.2081 CASE MANAGEMENT STATEMENT Page 5 of27 28 Tovar y. Te Velde, et al. . . San Joaquin County Superior Court Case #STK-CV-UPI-10826 PROOF OF SERVICE Iam a citizen ofthe United States and a resident of the County of Sacramento; I am over the age of eighteen (18) years and not a party to the within action; my business address is Law Office of Shawn C. Moore, 2251 Harvard Street, Suite 100, Sacramento, California, 95815. I am readily familiar with the business practice of Law Office of Shawn C. Moore of collecting and processing of pleadings and correspondence for mailing and depositing with the United States Postal Service that same day in the ordinary course of business; so that on the date indicated below, I served the following documents: : CASE MANAGEMENT STATEMENT on the parties in said cause, by placing a true copy thereof enclosed in a seated envelope, addressed as follows: Attorneys for Plaintiffs Attorney for Defendant, Cross-Defendant & Crass- Doug S. Saeltzer Complainant Holt Repair & Manufacturing, Inc. Walkup, Melodia, Kelly & Schoenberger Malcolm D. Schick 650 California Street, 26" Floor Erica C. Gonzalez San Francisco, CA 94108 G&P Schick T: (415) 981-7210; F: (415) 358-4522 99 Almaden Blvd., Suite 740 spahlke@walkuplawoftice.com San Jose, CA 95113-1605 T: (408) 995-5050; F: (408) 995-5150 Michael B. Bassi info@gpschicklaw.com Michael B. Bassi, A Law Corporation egonzalez(@apschicklaw.com 333 Bush Street, Suite 1100 San Francisco, CA 94104 T: (415) 986-8122: F: (415) 986-0733 mbbassi@bassilaw.com {] U.S. POSTAL SERVICE by placing a true and correct copy of the aforementioned document(s) in a sealed envelope and placing in the mail depository at my place of business, with postage prepaid, addressed as listed above. [Code of Civ. Proc. § 1013a(3)] O FACSIMILE by transmitting the aforementioned document(s) by facsimile at the number indicated above, which is maintained by said party, and verifying receipt of same. A true and correct copy of the transmission report is attached hereto and incorporated herein by this reference. [Code of Civ. Proc. § 1013(e), (f] I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on January 23, 2019, at Sacramento, California. SHELLEY FANNING CG