On February 05, 2021 a
Complaint,Petition
was filed
involving a dispute between
Chittim, Austin,
Chittim, Charles,
Chittim, Teresa,
Chittim, Timothy,
Chittim, Virginia,
and
Does 1-25,
Historic Inns Of Twenty Nine Palms, Llc,
Strukoff, Kathleen,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
NAME AND ADDRESS 0F ATTORNEY OR PARTY WITHOUTATTORNEY: STATE BAR NUMBER Reserved
for Olevk’s FiIe Stamp
Bradley R. Andersen 223479
Law Office of Tracey Lazarus
CA 92614
17901 Von Kannan Ave., lrvine, F l L E B
TELEPHONE No.1 g49_726_7608 sgzetmg COURT 0F CALIFORNIA
ENAKL ADDRESS: brad andemmflmna mm TRIAL SETTINGCONFERENCE DATE 08/05/21 v 0F SAN BERNARDINO
ATTORNEY FpR(Name’): Defendants
'
UNLIMITED CASE:
SA N BERNARDINO
FAX NO—(Optlona|)1
xx DJSTRICT
949.222.2940 LIMITED CASE:
JUL 21
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO 2021
COURTHOUSE ADDRESS:
247 West Third San Bemardino. CA
Street, 92415
PLAINTIFF:
CHARLES CHITTIM, anindividual, et al.
DEFENDANTI JACQUELINE HARNESS,
HISTORIC INNS 0F TWENTYNINE PALMS, LLc;
eta1. DEPUTY
CASE NUMBER:
INITIAL TRIAL SETTING CONFERENCE STATEMENT CIVSBZ1 03332
INSTRUCTIONS: Allapplicable boxesmust be checked, and the specified information must be provided.
This document must be filed and
served at least
15dag Qrior to the setting conference date.
trial
1. Party or parties (answer one):
a- This statement
issubmitted by Pafiy (name):
DefendantHISTORIC INNS 0F TWENTY NINE PALMS, LLc
b.
I This statement
issubmitted jointly by parties (names):
\
2. Service of Complaint on
all has
parties E has notD been completed.
3. Service of Crossfiomplaint on
has
parties
all D has notD been completed.
4. Description of case
inComplaint: Plaintiffs allege that
decedent, while exiting her room,
and fractured her femur, subsequently dying
fell of her
on October 4, 201 9
injuries
5. Description of case
inCross-Complaint:
6. Has discovery been completed:
all Yes D No m Date discovery anxicipated
tobe completed: presently ongoing
7. Do you agreeto mediation? Yes m No Elease check type agreedto:Private: X Court—sponsored: X
8. Related cases, consolidation, and coordination:
Please attach a Notice of Related Case.
D Amotionto D consolidate
5 t°7 days
D Trialdates requesteszesm No D Available dates: October 2022
after
Time
estimate:
9. Other issues:
D The following additional matters are requested to
be considered by the Court:
10. Meet and Confer:
a The panies represent that they have met and conferred on
subjects required by California Rules of Court, Rule 3.724.
all
Attempts be
will made to comply with
thisCRC.
The have entered
parties into the following stipulation(s):
11. Totalnumber of pages attachedany):
(if 0
lam completely familiar with this case and
be
will prepared to discuss the status of discovery and alternative dispute resolution, as well as
fully
other issues raised by this statement. and
willpossess the authority
to enter into stipulations on these issues at the time of the Initial Trial Setting
Conference, including the written authority of the party where required.
Date; July 20, 2021
Bradley R. Anderson
(TYPE OR PRINT NAME) (SIGNATU V
OF PARTY OR ATTORNEY
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY
Form # 13-09001-360
Rev,6-2020Mandatory INITIAL TRIAL SETTING CONFERENCE STATEMENT
PROOF OF SERVlGE - C.C.P. Section 1010.6
STATE OF CALIFORNIA, COUNTY OF ORANGE
l am employed in the County of Orange, State of California. l am over the age of 18
and not a party to the within action; my business address is 17901 Von Karman Ave., Suite
300, Irvine, California 92614.
On July 21 ,
2021, Isewed the foregoing document, described as:
(DmNODO‘l-wa—K
NOTICE OF JURY FEE DEPOSIT
INITIAL TRIAL SETTING CONFERENCE STATEMENT
on the interested parties in said action, by placing a true copy thereof enclosed in sealed
envelopes addressed as follows:
Attorneys for Plaintiffs, Charles Chittim, Attorney for Plaintiff, Bridget B. Chittim in
et al.: related case:
Jennifer L. Martinez, Esq. Hirad D. Dadgostar, Esq.
Michelle D. Schill, Esq. Dadgostar Law LLP
Martinez & Schill LLP 12400 Wilshire Blvd., Suite 400
11455 El Camino Real, Suite 470 Los Angeles, CA 90025-1030
San Diego, CA 92130 Tel: (310) 820-1022
Tel: (619) 512-5995 Fax: (310) 820—1088
Fax: (61 9) 331 -3708 hirad@dadqostarlaw.com
imartinez@martinezschill.com azadeh@dadqostarlaw.com
ccortez martinezschill.com
ccofle@marting;schill.com
(unavailable from July 12 to 21, 2021)
w
mem#WNAO©mN®m#wN—*O
ONLY
MNMNNMNNNAAAAAAAAAA
BY ELECTRONIC
persons at the e-mail
TRANSMISSION.
address(es). This is
Only by e-mailing the document(s) to the
necessitated during the declared National
Emergency due to the Coronavirus (Covid-19) pandemic because this office will be
working remotely, not able to send physical mail as usual, and is therefore using only
eiectronic mail pursuant to CCP 1010.6. No electronic message or other indication
that the transmission was unsuccessful was received within a reasonable time after
the transmission. We will provide a physical copy, upon request only, when we return
to the office at the conclusion of the national emergency.
Executed on July 21, 2021, at Irvine, California. I declare under penalty of perjury
under the laws of the State of California that the foregoing is true and correct.
W‘MM-“Ws
V. a
NOTICE OF JURY FEE DEPOSIT
Preview
NAME AND ADDRESS 0F ATTORNEY OR PARTY WITHOUTATTORNEY: STATE BAR NUMBER Reserved for Olevk’s FiIe Stamp Bradley R. Andersen 223479 Law Office of Tracey Lazarus CA 92614 17901 Von Kannan Ave., lrvine, F l L E B TELEPHONE No.1 g49_726_7608 sgzetmg COURT 0F CALIFORNIA ENAKL ADDRESS: brad andemmflmna mm TRIAL SETTINGCONFERENCE DATE 08/05/21 v 0F SAN BERNARDINO ATTORNEY FpR(Name’): Defendants ' UNLIMITED CASE: SA N BERNARDINO FAX NO—(Optlona|)1 xx DJSTRICT 949.222.2940 LIMITED CASE: JUL 21 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO 2021 COURTHOUSE ADDRESS: 247 West Third San Bemardino. CA Street, 92415 PLAINTIFF: CHARLES CHITTIM, anindividual, et al. DEFENDANTI JACQUELINE HARNESS, HISTORIC INNS 0F TWENTYNINE PALMS, LLc; eta1. DEPUTY CASE NUMBER: INITIAL TRIAL SETTING CONFERENCE STATEMENT CIVSBZ1 03332 INSTRUCTIONS: Allapplicable boxesmust be checked, and the specified information must be provided. This document must be filed and served at least 15dag Qrior to the setting conference date. trial 1. Party or parties (answer one): a- This statement issubmitted by Pafiy (name): DefendantHISTORIC INNS 0F TWENTY NINE PALMS, LLc b. I This statement issubmitted jointly by parties (names): \ 2. Service of Complaint on all has parties E has notD been completed. 3. Service of Crossfiomplaint on has parties all D has notD been completed. 4. Description of case inComplaint: Plaintiffs allege that decedent, while exiting her room, and fractured her femur, subsequently dying fell of her on October 4, 201 9 injuries 5. Description of case inCross-Complaint: 6. Has discovery been completed: all Yes D No m Date discovery anxicipated tobe completed: presently ongoing 7. Do you agreeto mediation? Yes m No Elease check type agreedto:Private: X Court—sponsored: X 8. Related cases, consolidation, and coordination: Please attach a Notice of Related Case. D Amotionto D consolidate 5 t°7 days D Trialdates requesteszesm No D Available dates: October 2022 after Time estimate: 9. Other issues: D The following additional matters are requested to be considered by the Court: 10. Meet and Confer: a The panies represent that they have met and conferred on subjects required by California Rules of Court, Rule 3.724. all Attempts be will made to comply with thisCRC. The have entered parties into the following stipulation(s): 11. Totalnumber of pages attachedany): (if 0 lam completely familiar with this case and be will prepared to discuss the status of discovery and alternative dispute resolution, as well as fully other issues raised by this statement. and willpossess the authority to enter into stipulations on these issues at the time of the Initial Trial Setting Conference, including the written authority of the party where required. Date; July 20, 2021 Bradley R. Anderson (TYPE OR PRINT NAME) (SIGNATU V OF PARTY OR ATTORNEY (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY Form # 13-09001-360 Rev,6-2020Mandatory INITIAL TRIAL SETTING CONFERENCE STATEMENT PROOF OF SERVlGE - C.C.P. Section 1010.6 STATE OF CALIFORNIA, COUNTY OF ORANGE l am employed in the County of Orange, State of California. l am over the age of 18 and not a party to the within action; my business address is 17901 Von Karman Ave., Suite 300, Irvine, California 92614. On July 21 , 2021, Isewed the foregoing document, described as: (DmNODO‘l-wa—K NOTICE OF JURY FEE DEPOSIT INITIAL TRIAL SETTING CONFERENCE STATEMENT on the interested parties in said action, by placing a true copy thereof enclosed in sealed envelopes addressed as follows: Attorneys for Plaintiffs, Charles Chittim, Attorney for Plaintiff, Bridget B. Chittim in et al.: related case: Jennifer L. Martinez, Esq. Hirad D. Dadgostar, Esq. Michelle D. Schill, Esq. Dadgostar Law LLP Martinez & Schill LLP 12400 Wilshire Blvd., Suite 400 11455 El Camino Real, Suite 470 Los Angeles, CA 90025-1030 San Diego, CA 92130 Tel: (310) 820-1022 Tel: (619) 512-5995 Fax: (310) 820—1088 Fax: (61 9) 331 -3708 hirad@dadqostarlaw.com imartinez@martinezschill.com azadeh@dadqostarlaw.com ccortez martinezschill.com ccofle@marting;schill.com (unavailable from July 12 to 21, 2021) w mem#WNAO©mN®m#wN—*O ONLY MNMNNMNNNAAAAAAAAAA BY ELECTRONIC persons at the e-mail TRANSMISSION. address(es). This is Only by e-mailing the document(s) to the necessitated during the declared National Emergency due to the Coronavirus (Covid-19) pandemic because this office will be working remotely, not able to send physical mail as usual, and is therefore using only eiectronic mail pursuant to CCP 1010.6. No electronic message or other indication that the transmission was unsuccessful was received within a reasonable time after the transmission. We will provide a physical copy, upon request only, when we return to the office at the conclusion of the national emergency. Executed on July 21, 2021, at Irvine, California. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. W‘MM-“Ws V. a NOTICE OF JURY FEE DEPOSIT