Preview
CM-110
ATTORNEY 0 R PARTY WITHOUT ATTORNEY (Name. State Bar number, muf eddn.ssi FOR COURT USE ONLY
Judice L. Pinkerton, Esq., (252218)
Carbone, Smith & Koyama
555 12th Street, Suite 1250
Oakland, CA 94607X095
ELECTRONICALLY
TELEPHONE NOJ (510) 267-7271 Fpx No. /opso ad
E-MAIL ADDREsS foptmnap FILED
Defendant Elizabeth J. Lance Superior Court of California,
ATTDRNEY FQR (N J
County of San Francisco
SUPERIQR coURT oF CALIFQRNIA, coUNTY oF SAN FRANCISCO
sTREETADDREss. 4QQ McAllister St.
02/27/2020
Clerk of the Court
MAILINGADDREss 4QQ McAllister St. BY: DARLENE LUM
Deputy Clerk
OITYANDzIPODDE: San Francisco, CA 94102
BRANcHNAME Unlimited Civil Jurisdiction
Erika Gottschalk
PLAINTIFF/PETITIQNER:
oEFENoaayiREspoNoENTI Elizabeth J. Lance; and Does 1 to 10, Inclus
CASE NUMBER
CASE MANAGEMENT STATEMENT
CGC-19-580252
(Check one)J H UNLIMITED CASE Q LIMITED CASE
(Amount demanded (Amount demanded is $ 25,000
exceeds $ 25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: March 24, 2020 Time: 10:30 a.m. Dept.: 610 Divx Room:
Address of court (if diFerent from the address above)/
H Notice of Intent to Appear by Telephone, by (name)T Judice L. PinkertOn
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. H This statement is submitted by party (name): Defendant, Elizabeth J. Lance
b. 0 This statement is submitted jointly by parties (names):
2. Complaint and crosswomplaint (to be answered by p/aintiffs and c/Dss~mp/a/nants only)
a. The complaint was filed on (dale): October 24, 2019
b. The cross-complaint, if any, was filed on (date)J
3. Service (io be answered by p/aint/ffs and c/oss~mp/a/nants only)
a. C] All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. Q The following parties named in the complaint or cross-complaint
(1) P
have not been served (specify names and explain why noi):
(2) have been served but have not appeared and have not been dismissed (specify names):
(3) Q have had a default entered against them (specify names):
c. The following additional parties may be added (specify names, nature ofinvolvementin case, and date by which
they may be served) I
4. Description of case
a. Type of case in H complaint Q cross-complaint (Describe, inc/Udtng causes of action):
Personal Injury Automobile Accident
—
Paoe I of 0
Form Adopted for Mendatrsy Use CASE MANAGEMENT STATEMENT Cal Rdesofcoun
Judroel Counol of Cat feme rules 3 T20-3./30
CM-110IRe J IY1,2011] Innr norrrts oe onr
CM-110
Gottschalk
PLAINTIFF/PETITIONER: Erika
tDEFENDANT/REsPQNDENT: Elizabeth J. Lance; and Does
4. b,
1 to 10, Inclus
Provide a brief statement of the case, including any damages. (If personalinjury damages are sought, specify the Injury and
earnings claimed, including medical expenses to date (indicate source and amount), estimated future medical expenses, Iosl
damages
to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief)
Plaintiff alleges she was injured when she fell while exiting the rear passenger side of defendant's vehicle.
(If more space is needed, check this box and attach a page designated as Attachment 45.)
lri e):
5. Jury or nonjury trial
The party or parties request H a jury trial a nonjury trial. (If more then one party, provide the name of each party
requesting a jury
6. Trial date
a. The trial has been set for (date):
b. H 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):
c. Dates on which parties or attorneys will not be available for trial (specify dales and explain reasons for unavailability):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. H days (specify numtier): 4-5 days
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial H by the attorney or party listed in the caption Q 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 H has Q has not provided the ADR information package identified
in rule 3.221 to the dient and reviewed ADR options with the client.
(2) For self-represented parties: Party Q
has Q has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) H 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) 0 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):
Race 2 af 5
CM-1 10 [Rev. Juy 1, 20111 CASE MANAGEMENT STATEMENT
CM-110
E NUMBER.
t Enka Gottschalk
PLAINTIFF/PETITIQNER:
DEFENDANT/RESPONDENT: Elizabeth J. Lance; and Does 1 to 10, Inclus
CGC-19-580252
10. c, Indicate the ADR process or processes that the parly or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that app/y and provide the specified infonnafion):
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/I that app/y): stipulation):
H Mediation session not yet scheduled
Mediation session scheduled for (date):
(I) Mediation
Agreed to complete mediation by (date):
P Mediation completed on (date):
H Settlement conference not yet scheduled
(2) Settlement
Q Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
0 Neutral evaluation not yet scheduled
P Neutral evaluation scheduled for (date):
(3) Neutral evaluation
P Agreed to complete neutral evaluation by (date):
Q Neutral evaluation completed on (date):
Q Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date):
(4) Nonbinding judicial
arbitration
Q Agreed to complete judicial arbitration by (date):
Q Judicial arbitration completed on (dale):
0 Private arbitration not yet scheduled
(5) Binding private
0 Private arbitration scheduled for (date):
arbitration
Q Agreed to complete private arbitration by (date):
0 Private arbitration completed on (date):
P ADR session not yet scheduled
(6) Other (specify): Q ADR session scheduled for (date):
Agreed to complete ADR by (dale):
ADR completed on (date):
Peoe 3 of 3
CM-110 [Rev July 1, 2011i CASE MANAGEMENT STATEMENT
CM-110
CASE NUMBER.
Enka Gottschalk
t
PtAIMIFF/PETITIQNER:
CGC-19-580252
OEFENoANT/RcspoNOENR Elizabeth J. Lance; and Does 1 to 10, Inclus
11. Insurance
a. H Insurance carrier, if any, for party filing this statement (name)/ CSAA Insurance Exchange
b. Reservation of dghts: P Yes H 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.
P Bankruptcy Q Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. 0
There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
C] Additional cases are described in Attachment 13a.
b. 0 A motion to Q 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
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. 0 The party or parties have completed all discovery.
b H The following discovery will be completed by the date specified (describe a/I anticipated discovery):
Party Descriotion Date
Defendant Interrogatories & Document Production Per Code
Defendant Deposition of Plaintiff May 2020
Defendant Final Subpoenas of Records Per Code
Defendant Possible IME of Plaintiff TBD
The following discovery issues, induding issues regarding the discovery of electronically stored information, are
anticipated (specify)/
Reeeeer B
CM-11B IRev. July 1, 2011] CASE MANAGEMENT STATEMENT
CM-110
CASE NUMBER
t PLAINTIFF/PETITIQNER:
DEFENDANTIREsPONDENT:
Erika Gottschalk
Elizabeth J. Lance; and Does 1 to 10, Inclus
CGC-1 9-580252
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 specifics/ly why economic Iiiigaiion procedures relating fo discovery or trial
should nof apply fo 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. H 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 nor, explain):
b. Afler 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: February 27, 2020
Judice L. Pinkerton
(TYPE OR PRINT NAME) NATU~ROE PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
0 Additional signatures are attached.
Peoe 5 of 5
CM-110 [Reu July I, 2011) CASE MANAGEMENT STATEMENT
POS-030
ATTORNEY OR PARTY WITHOUT ATTORNEY /meme State Sar number, end aptfremb FOR COURT USE ONLY
Carbone, Smith & Koyama
Judice L. Pinkerton, Esq. (252218)
555 12th Street, Suite 1250
Oakland, CA 94607%095
TELEPHONE Nou (510) 267-7271 FAX NO fcp!amatt
0 JMIL ADDRESS
Elizabeth J. Lance
(Ontmna/I'TTORNFy
FOR /N I
SUPERIQR coURT oF GALIFQRNIA, coUNTY QF SAN FRANCISCO
sTREETADDREss 400 McAllister St.
MAILING ADDREss: 400 McAllister St.
cITYANDEIPDDDE: San Francisco, CA 94102
BRANDHNAME Unlimited Civil Jurisdiction
PLAINTIFF/PETITIQNER: Erika Gottschalk
DEFENDANT/REST oNDENT: Elizabeth J. Lance; and Does 1 to 10, Inclus
CASE NUMBER.
PROOF OF SERVICE BY FIRST-CLASS MAIL — CIVIL
CGC-19-580252
(Do not use this Proof of Service to show service of a Summons and Complaint)
1. Iam over 18 years of age and not a party to this action. I am a resident or employed in the county where the mailing took
place.
2. My business or residence address is:
555 12th Street, Suite 1250, Oakland, CA 94607-4095
3. On (date): February 27, 2020, I mailed from (City and State): Oakland, CA
The following documents (Specify):
CASE MANAGEMENT STATEMENT
Q The documents are listed in the Attachment to Proof of Service by First-Class Mail — Civil (Documents Served) (form
POS-030(D)).
4. Iserved the documents by enclosing them in an envelope and (check one):
a. depositing the sealed envelope with the United States Postal Service with the postage fully prepaid.
b. 2 placing the envelope for collection and mailing following our ordinary business practices. am readily familiar with this
I
business's practice for collecting and processing correspondence for mailing. 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.
5. The envelope was addressed and mailed as follows:
a. Name of the person served: Rozy Lahlouh Boulos
b. Address of the person served: 1570 the Alameda, Ste. 215,
San Jose, CA 95126-2331
Attorney for Plaintiff
The name and address of each person to whom I mailed the documents is listed in the Attachment to Proof of Service by First-
Class Mail — Civil (Persons Served) (form POS-030(D)).
Ideclare under penalty of perjury under the laws of the state of California that the foregoing is true and correct.
Date: February 27, 2020
Jeannie Scannell-Fraser
(TYPE OF PRINT NAME OF PERSON COMPLETING THIS FORM) (SIIIATURE OF PERSON COMPLETING THIS FORM)
Form Appnmad for Ormrmal Uae Code of Clos Proomiure, EEIOI3, t013a
Judiaal Coundl of Cehfolma PROOF OF SERVICE BY FIRST-CLASS MAIL — CIVIL www.oorrrdrrfo.ae.sou
POSJDC (New January I, 2000] (Proof of Service)