On July 10, 2020 a
Conference
was filed
involving a dispute between
Garibay, Christian,
Ramirez, Jose A.,
Menor-Cruz, Moises,
Romero-Neri, Yolanda,
and
City Of Colton, A Government Entity .,
Garibay, Christian,
Ramirez, Jose A.,
San Bernardino County, A Government Entity,
for Wrongful Death Non-Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
NAME AND ADDRESS 0F ATTORNEY 0R PARTY WITHOUT ATTORNEY: STATE BAR NUMBER Reserved Stamp
for Clerk’s File
Alexander M. Brand 305748
m
Best Best & Krieger LLP
F
SUPERIOR co: EST E5
E D
COUNTY o; QEI‘CALzFORNa/x
300 S. Grand Ave., 25‘“ Floor, Los Angeles, CA 90071 SAN BER“.
\ w «jfimwARDINo
TELEPHONE No.:(21 3) 61 7-81
00 mi) msmlcr
E—MAIL ADDRESS: alexander.brand@bbklaw.comTRIAL SEWING CONFERENCE DATE: JAN O 8 2021
ATTORNEY FOR (Name):City of Colton UNLIMITED CASE: X
FAX No. (21 3) 61 7-7480
(Optional): LIMITED CASE: ‘-
IJY
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
‘ N.
my»
v_z-‘ifl‘g
i
m/
RZFAEL HEBmNa "f?” ‘-
COURTHOUSE ADDRESS: 247 West Third Street, San Bernardino, CA 92415 )Tfiy
PLAINTIFF:MOISES MENOR-CRUZ, et al.
DEFENDANT: CHRISTIAN GARIBAY, et al.
CASE NUMBER:
INITIAL TRIAL SETTING CONFERENCE STATEMENT CIVDSZO1 3878
INSTRUCTIONS: All applicable boxes must be checked, and the specified information
must be provided. This document must be filed and
served at least 15 days grior to the trial setting conference date.
\_
1. Party or parties (answer one):
a. g This statement
is Colton
submitted by party (name): City 0f
b. D This statement
issubmitted jointly by parties (names):
2. Service of Complaint onall E
parties has has notD been completed.
3. Service of Cross-Complaint on
all has
parties X has notD been completed.
4. Description of case
inComplaint:
This isa wrongful death action involving an accident between a pedestrian and a private motorist. The motorist
struck the pedestrian, who was a minor, while she was allegedly in the cross-walk.
5. Description of case
inCross-Complaint:
The City's cross-complaint against the cross-defendants is for equitable indemnity and contribution.
6. Has Yes
discovery been completed:
all D No E Date discovery anticipated to be compIeted:Segtember 2021
Court-
7. Do you agreeto mediation? Yes E No D Please check type agreed A
to: Private: sponsored:
8. Related cases, consolidation, and coordination: Please attach a Notice of Related Case.
D Amotionto
estimate:
D consolidate D Trialdates requested: YesE No D Available dates:Februa! x 2022 Time
5-7 days
The City Requests a February 2022 trial date because in other litigations matters, the City has experienced
substantial delays in discovery due to COVID-1 9. Additionally the City anticipates that there wi|| be extensive
discovery in thismatter, of the
in light damages alleged.
9. Other issues:
D The following additional matters are requested to be considered by the
Court
10. Meet and Confer:
D The have met and conferred on
parties represent that they allsubjects required by California Rules of Court, Rule 3.724.
The have entered
parties intothe following stipulation(s):
The City attempted to meet and confer prior to the TSC however, was not possible.
it Should the parties reach an
agreement on any issue prior to the TSC, the City will inform the Court at the TSC.
11. Totalnumber ofpages attached any):
(if
|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 Initial Trial
Setting
Conference, including the written authority of the pariy where required,
Date; Janua 8, 2021 4:
Alexander M. Brand
(TYPE 0R PRINT NAME) (SIGNATURE UHFARTY 0R ATTofi'NE
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY
Form # 13-09001-360
Rev.6—2020 Mandatory INITIAL TRIAL SETTING CONFERENCE STATEMENT
23152.04331\33590784.1 American LegalNet, Inc.
www.FormsWorkFlow,com
1i
PROOF OF SERVICE
I am a citizen of the United States and employed in Los Angeles County, California. I am
over the age of eighteen years and not a party to the within-entitled action. My business address
is 300 South Grand Avenue, 25th Floor, Los Angeles, California 90071. On January 8, 2021, I
served a copy of the within document(s):
Lh-hUJN
INITIAL TRIAL SETTING CONFERENCE STATEMENT
by transmitting Via facsimile the document(s) listedabove to the fax number(s) set
forth below on this date before 5:00 p.m.
by placing the document(s) listed above in a sealed envelope with postage thereon
fully prepaid, the United States mail at Los Angeles, California addressed as set
OOOONON
forth below.
DUDE
by placing the document(s) listed above in a sealed envelop} and affixing
a pre-paid air bill, and causing the envelope to be delivered to an agent for
delivery.
by personally delivering the document(s) listed above to the person(s) at the
address(es) set forth below.
FLOOR
LLP
9007]
12 by transmitting via e-mail or electronic transmission the document(s) listed above
25TH
LAW
KRIEGER
Immm
to the person(s) at the e-mail address(es) set forth below.
AT
AVENUE
CA1
13
& AkaNEYs
GRAND
ANGELES.
David F. Makkabi Attorneysfor Plaintifi‘s
BEST
SOUTH
14 Karla Ruiz MOISES MENOR-CRUZ, an individual
BEST Los
3m!
Matthew P. Foose and as successor-in-interest to the estate
15 MAKKABI LAW GROUP of LESLIE DENISE MENOR ROMERO,
9454 Wilshire Boulevard, Suite 900 decedent; and YOLANDA ROMERO-
16 Beverly Hills, CA 90212 NERI, an individual and as successor-in-
Tel. (310) 887-8000 / Fax (310) 887-8001 interest to the estate of LESLIE DENISE
17 Email: dmakkabi@makkabilaw.com MENOR ROMERO, decedent
kruiz@makkabilaw.com
18 info@makkabilaw.com
19 Robert L. Reisinger Attorneysfor Defendants and Cross-
FORD WALKER HAGGERTY & BEHAR Complainants
20 One World Trade Center, 27th Floor CHRISTIAN GARIBAY, JOSE A.
Long Beach, CA 90831-2700 RAMIREZ
21 Tel. (562) 983-2500
Email: bob@fwhb.com
22
I am readily familiar with the firm's practice 0f collection and processing correspondence
23 for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same
day with postage thereon fully prepaid in the ordinary course of business. I am aware that on
24 motion 0f the party served, service is presumed invalid if postal cancellation date or postage
meter date is more than one day after date of deposit for mailing in affidavit.
25
I declare under penalty 0f perjury under the laws 0f the State of California that the above
26 istrue and correct. Executed 0n January 8, 2021, at Los Angeles, California.
27
(EEfifiIA DURAN
28
-1-
PROOF OF SERVICE
23152043318359] 384.1
Preview
NAME AND ADDRESS 0F ATTORNEY 0R PARTY WITHOUT ATTORNEY: STATE BAR NUMBER Reserved Stamp for Clerk’s File Alexander M. Brand 305748 m Best Best & Krieger LLP F SUPERIOR co: EST E5 E D COUNTY o; QEI‘CALzFORNa/x 300 S. Grand Ave., 25‘“ Floor, Los Angeles, CA 90071 SAN BER“. \ w «jfimwARDINo TELEPHONE No.:(21 3) 61 7-81 00 mi) msmlcr E—MAIL ADDRESS: alexander.brand@bbklaw.comTRIAL SEWING CONFERENCE DATE: JAN O 8 2021 ATTORNEY FOR (Name):City of Colton UNLIMITED CASE: X FAX No. (21 3) 61 7-7480 (Optional): LIMITED CASE: ‘- IJY SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO ‘ N. my» v_z-‘ifl‘g i m/ RZFAEL HEBmNa "f?” ‘- COURTHOUSE ADDRESS: 247 West Third Street, San Bernardino, CA 92415 )Tfiy PLAINTIFF:MOISES MENOR-CRUZ, et al. DEFENDANT: CHRISTIAN GARIBAY, et al. CASE NUMBER: INITIAL TRIAL SETTING CONFERENCE STATEMENT CIVDSZO1 3878 INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. This document must be filed and served at least 15 days grior to the trial setting conference date. \_ 1. Party or parties (answer one): a. g This statement is Colton submitted by party (name): City 0f b. D This statement issubmitted jointly by parties (names): 2. Service of Complaint onall E parties has has notD been completed. 3. Service of Cross-Complaint on all has parties X has notD been completed. 4. Description of case inComplaint: This isa wrongful death action involving an accident between a pedestrian and a private motorist. The motorist struck the pedestrian, who was a minor, while she was allegedly in the cross-walk. 5. Description of case inCross-Complaint: The City's cross-complaint against the cross-defendants is for equitable indemnity and contribution. 6. Has Yes discovery been completed: all D No E Date discovery anticipated to be compIeted:Segtember 2021 Court- 7. Do you agreeto mediation? Yes E No D Please check type agreed A to: Private: sponsored: 8. Related cases, consolidation, and coordination: Please attach a Notice of Related Case. D Amotionto estimate: D consolidate D Trialdates requested: YesE No D Available dates:Februa! x 2022 Time 5-7 days The City Requests a February 2022 trial date because in other litigations matters, the City has experienced substantial delays in discovery due to COVID-1 9. Additionally the City anticipates that there wi|| be extensive discovery in thismatter, of the in light damages alleged. 9. Other issues: D The following additional matters are requested to be considered by the Court 10. Meet and Confer: D The have met and conferred on parties represent that they allsubjects required by California Rules of Court, Rule 3.724. The have entered parties intothe following stipulation(s): The City attempted to meet and confer prior to the TSC however, was not possible. it Should the parties reach an agreement on any issue prior to the TSC, the City will inform the Court at the TSC. 11. Totalnumber ofpages attached any): (if |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 Initial Trial Setting Conference, including the written authority of the pariy where required, Date; Janua 8, 2021 4: Alexander M. Brand (TYPE 0R PRINT NAME) (SIGNATURE UHFARTY 0R ATTofi'NE (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY Form # 13-09001-360 Rev.6—2020 Mandatory INITIAL TRIAL SETTING CONFERENCE STATEMENT 23152.04331\33590784.1 American LegalNet, Inc. www.FormsWorkFlow,com 1i PROOF OF SERVICE I am a citizen of the United States and employed in Los Angeles County, California. I am over the age of eighteen years and not a party to the within-entitled action. My business address is 300 South Grand Avenue, 25th Floor, Los Angeles, California 90071. On January 8, 2021, I served a copy of the within document(s): Lh-hUJN INITIAL TRIAL SETTING CONFERENCE STATEMENT by transmitting Via facsimile the document(s) listedabove to the fax number(s) set forth below on this date before 5:00 p.m. by placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid, the United States mail at Los Angeles, California addressed as set OOOONON forth below. DUDE by placing the document(s) listed above in a sealed envelop} and affixing a pre-paid air bill, and causing the envelope to be delivered to an agent for delivery. by personally delivering the document(s) listed above to the person(s) at the address(es) set forth below. FLOOR LLP 9007] 12 by transmitting via e-mail or electronic transmission the document(s) listed above 25TH LAW KRIEGER Immm to the person(s) at the e-mail address(es) set forth below. AT AVENUE CA1 13 & AkaNEYs GRAND ANGELES. David F. Makkabi Attorneysfor Plaintifi‘s BEST SOUTH 14 Karla Ruiz MOISES MENOR-CRUZ, an individual BEST Los 3m! Matthew P. Foose and as successor-in-interest to the estate 15 MAKKABI LAW GROUP of LESLIE DENISE MENOR ROMERO, 9454 Wilshire Boulevard, Suite 900 decedent; and YOLANDA ROMERO- 16 Beverly Hills, CA 90212 NERI, an individual and as successor-in- Tel. (310) 887-8000 / Fax (310) 887-8001 interest to the estate of LESLIE DENISE 17 Email: dmakkabi@makkabilaw.com MENOR ROMERO, decedent kruiz@makkabilaw.com 18 info@makkabilaw.com 19 Robert L. Reisinger Attorneysfor Defendants and Cross- FORD WALKER HAGGERTY & BEHAR Complainants 20 One World Trade Center, 27th Floor CHRISTIAN GARIBAY, JOSE A. Long Beach, CA 90831-2700 RAMIREZ 21 Tel. (562) 983-2500 Email: bob@fwhb.com 22 I am readily familiar with the firm's practice 0f collection and processing correspondence 23 for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I am aware that on 24 motion 0f the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. 25 I declare under penalty 0f perjury under the laws 0f the State of California that the above 26 istrue and correct. Executed 0n January 8, 2021, at Los Angeles, California. 27 (EEfifiIA DURAN 28 -1- PROOF OF SERVICE 23152043318359] 384.1