Statement Case Management ConferenceCal. Super. - 6th Dist.February 26, 2018ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Douglas E. Johns, Esq. (SBN 314798) Coddington, Hicks & Danforth 555 Twin Dolphin Drive, Suite 300 Redwood City, CA 94065 TELEPHONE NO.: (650) 5 92 - 5 4 0 0 FAX NO.(Optional) : ( 65 0) 5 92 - 5 0 2 7 E-MAILADDRESS(Optional): djohns@chdlawyers.com ATTORNEY FOR (Name) : Kam Yung Chow SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA STREET ADDRESS: 191 North Fir ,st Street MAILING ADDRESS. CITY AND ZIP CODE: San lJ 0 S e , Cal i for n i a 9 5113 BRANCH NAME: PLAINTIFF/PETITIONER: Jaeill Park I DEFENDANT/RESPONDENT: Kam Yung Chow CASE MANAGEMENT STATEMENT (Check one): W UNLIMITED CASE D LIMITED CASE (Amount demanded exceeds $25,000) (Amount demanded is $25,000 or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: November 13, 2018 Time: 10: 00 a . m. Dept. : 9 Address of court (if different from the address above): CASE NUMBER: 18CV323948 Div.: W Notice of Intent to Appear by Telephone, by (name): Douglas E. Johns FOR COURT USE ONL Y Room: INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. IX) This statement is submitted by party (name): De f endan t Kam Yung Chow b. D This statement is submitted jointly by parties (namesj.o 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date) : b. D The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) CM-110 a. D All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. D The following parties named in the complaint or cross-complaint (1) D have not been served (specify names and explain why not): (2) D have been served but have not appeared and have not been dismissed (specify names): (3) D have had a default entered against them (specify names): c. D The following additional parties may be added (specify names, nature of involvement in case, and the date by which they may be served): 4. Description of case a. Type of case in IX) complaint D cross-complaint (Describe, including causes of action): Motor vehicle accident which occurred on July 15, 2017. Form Adopted for Mandatory Use Judicial Council of California CM-110 [Rev. July 1, 2011] ern- I ~. nti~ c£o.com ma:c IS CASE MANAGEMENT STATEMENT Page 1 of 5 Cal. Rules of Court, rules 3.720-3.730 www.courts.ca.gov Electronically Filed by Superior Court of CA, County of Santa Clara, on 10/29/2018 2:43 PM Reviewed By: System System Case #18CV323948 Envelope: 2112155 18CV323948 Santa Clara - Civil System System CM-110 PLAINTIFF/PETITIONER:Jaeill Park CASE NUMBER: 18CV323948 DEFENDANT/RESPONDENT: Kam Yung Cho 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.) Plaintiff alleges personal injuries and property damage res u lting fr om a vehicle accident which occurred on July 15, 2017 . D (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 I]J a jury trial 0 a nonjury trial. (If more than one party, provide the name of each party requesting a jury triaij : 6. Trial date a. 0 The trial has been set for (date) : b. W No trial date has been set. This case will be ready for tria! 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 dates and explain reasons for unavailability): see attached 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. W days (specify number): 3-5 b. 0 hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties wil! be represented at trial [Xl by the attorney or party listed in the caption o by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: D Additional representation is described in Attachment 8. 9. Preference o 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 !XI has 0 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 D has 0 has not reviewed the ADR information package identified in rule 3.221 . b. Referral to judicial arbitration or civil action mediation (if available). (1) U This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under of 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) D This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or fiOm civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-110 [Rev. July 1, 2011] ern-I Em;enUa~ ceb.com EJ forms' CASE MANAGEMENT STATEMENT Page 2 of 5 CM-110 PLAINTIFt-/PETITIONER:Jaeill Park CASE NUMBER: - 18CV323948 DEFENDANT/RESPONDENT: Kam Yung Cho 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): I (i) Mediation (2) Settlement conference (3) Neutral evaluation (4) Nonbinding judicial arbitration \ (5, Binding private arbitration (6) Other (specify): CM-110 [Rev_ July 1, 2011] ern" I Essen-tial Cl!b.com o Fom'is' I The party or parties completing this form are willing to I participate in the following ADR I processes (check ail that appiyj: I \Ai 0 D D o D 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, I indicate the status of the processes (attach a copy of the parties' ADR stipulationj: W Mediation session not yet scheduled o Mediation session scheduled for (date)' I D Agreed to complete mediation by (date): D Mediation completed on (date): D Settlement conference not yet scheduled D Settlement conference scheduled for (date): D Agreed to complete settlement conference by (date): D Settlement conference completed on (date): D Neutral evaluation not yet scheduled D Neutral evaluation scheduled for (date): D Agreed to complete neutral evaluation by (date) : D Neutral evaluation completed on (date): D Judicial arbitration not yet scheduled D Judicial arbitration scheduled for (date): D Agreed to complete judicial arbitration by (date): D Judicial arbitration completed on (date): o Private arbitration not yet scheduled o Private arbitration scheduled tor (date): o Agreed to complete private arbitration by (date): o Private arbitration completed on (date): D ADR session not yet scheduled o ADR session scheduled for (date): o Agreed to complete ADR session by (date): o ADR completed on (date): CASE MANAGEMENT STATEMENT Page 3 of 5 PLAINTIFF/PETITIONER: J a e i 11 Par k CASE NUMBER: 18CV323948 DEFENDANT/RESPONDENT: Karn Yung Cho 11. Insurance a. W Insurance carrier, if any, for party filing this statement (name): CSAA Insurance Group b. Reservation of rights: DYes W No c. 0 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. D Bankruptcy D Other (specify): Status: 13. Related cases, consolidation, and coordination a. D There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: D Additional cases are described in Attachment 13a. b. D A motion to 0 consolidate D coordinate 14. Bifurcation will be filed by (name party): CM-110 D 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 U The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. \XI The party or parties have completed all discovery. b. 0 The following discovery will be completed by the date specified (describe all anticipated discoveryj : Party Description Defendant Written Discovery Defendant Depositions Defendant Expert Discovery Date Feb . 2019 Dec ; 2018 Per Code c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011) CASE MANAGEMENT STATEMENT Page 4 of 5 Crn", ~ .. ~~ta~! ceb.com El Fomur CM-110 PLAINTIFF/PETITIONER: Jaeill Park CASE NUMBER: - 18CV323948 DEFENDANT/RESPONDENT: Kam Yung Cho 17. Economic litigation a. D 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. D 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 tria! should not apply to this case): 18. Other issues o The party or parties request that the following additional matters be considered or determined at [he case management conference (specify): 19. Meet and confer a. /Xl 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): ~4 ______ _ 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 29, 2018 00119 J as E ,Tohn s CM-110 [Rev. July 1, 2011] rrB- I Essential vL I ~"' ForMs' ceb.com .. ::J __ (TYPE OR PRINT NAME) (TYPE OR PRINT NAME) ~ ----------------------------~---------------- (SIGNATURE OF PARTY OR ATIORNEY) D Additional signatures are attached. CASE MANAGEMENT STATEMENT Page 5 of 5 Attachment 6c Case Management Statement I January 7, 2019 to January 11, 2019 I I January 14,2019 to January 18, 2019 I I January 19, 2019 to January 26,2019 I I February 11,2019 to February 22,2019 February 25,2019 to March 1,2019 March 1, 2019 to March 8, 2019 March 11,2019 to March 22, 2019 April 2, 2019 to April 6, 2019 April 8, 2019 to April 12, 2019 April 15, 2019 to April 19, 2019 April 29, 2019 to May 3,2019 May 6, 2019 to May 17, 2019 May 20, 2019 to Ivfay 24, 2019 Rev. 8/31/18 Trial Dates I June 3,2019 to June 7,2019 I June 19,2019 to June 27, 2019 I July 1, 2019 to July 5,2019 I July 8, 2019 to July 12, 2019 August 26, 2019 to August 30, 2019 September 23, 2019 to September 27, 2019 October 15, 2019 to October 21 , 2019 CCourtCalr Couri'Call Appeara61ce - Service Copy 6383 Arizona Circle Los Angeles, CA 90045 Phone: (888) 882 6878 Fax: (888) 883~2946 CourtCall.com This document shall serve as notice of a CourtCal! Appearance by the participant listed below in the referenced case. Others wishing to appear remotely should contact CourtCall, LLC at (888) 882-6878 or (310) 342-0888. Douglas E Johns Coddington, Hicks & Danforth Tel: (650) 592-5400 Fax: (650) 592-5027 Case Name: Park v. Chow Case Number: 18CV323948 Court Name: Santa Clara County Superior Court (CA) Dept/Judge: 9 / Judge Mary Arand Proceeding: Case Management Conference Date/Time: Tuesday, November 13th, 2018 at 10:00 AM PT Note: this is not a Confirmation of your CourtCall Appearance. Each participant must make his or her own arrangements with CourtCali. While clients can save money and Courts can become more efficient and generate revenue, CourtCaii has the most impact upon practicing attorneys as it helps to give them their lives back. Attorneys can use the time they save using CourtCali to catch-up on other pressing matters, enjoy time with family and friends or otherwise take advantage of the time no longer spent traveling to and from Court. Call us for details. There are no subscriptions or equipment to buy. COURTCALL VIDEO IS HERE! CourtCali is equipping Courtrooms of interested judges with its state-of-the-art, browser-based video conferencing platform, enabling full video participation for traditional CourtCall Appearances. Lawyers only need a computer with sufficient bandwidth and a webcam to view and/or share video in accordance with a Judge's preferences. To learn more about video options, please ask a CourtCall representative. The foregoing information may have been obtained from court records which may not reflect recent calendar changes. If it is inaccurate because your appearance has been continued, please apply this information to the new date. If the matter is off calendar; you have no involvement in the case or you do not wish to use this service, please disregard this notice. Do not call the Court Clerk. Our representatives are available to make presentations for your firm, your clients, Bar Associations or other groups. Please can to schedule a presentation. Remote Appearances. Simplified. Courteai! Appearances are available monthly. Please visit our website at across the US, Canada and other jurisdictions. NOTFD [P] for over 2,000 Judges www.courtcall.com for a nationwide, complete with additional COUits list of participating Courts being and added Judges SERVICE COPY FOR COURTCALL® APPEARANCE Copyright © 2018 CourtCall, LLC. All Rights Reserved. 1 2 3 PROOF OF SERVICE California Code of Civil Procedure sections 1011, 1013, 1013a, 2015.5 California Rule of Court rule 2.251 Federal Rule of Civil Procedure Rule 5(b) 4 I, the undersigned, declare that I am employed in the County of San Mateo, State of 5 California. I am over the age of eighteen (18) years and not a party to the within action" My 6 I business address is 555 Twin Dolphin Drive~ Suite 300~ Redwood City, California 94065. My 7 I electronic rnail address is Eva@chdlawyers.com. 8 I am readily familiar \vith my employer's business practice for collection and processing 9 of correspondence and documents for mailing with the United States Postal Service, mailing via 10 overnight delivery, transmission by facsimile machine, and delivery by hand. 11 On October 29, 2018, I served a copy of each of the documents listed below by placing 12 said copies for processing as indicated herein. 13 CASE MANAGEMENT STATEMENT; 14 15 16 17 18 19 20 21 22 23 1 24 25" 26 27 28 x COURTCALL APPEARANCE - SERVICE COpy United States Mail: The correspondence or documents were placed in sealed, labeled envelopes with postage thereon fully prepaid on the above date placed for collection and mailing at my place of business to be deposited with the U.S. Postal Service at Redwood City, California on this same date in the ordinary course of business. Overnight Delivery: The correspondence or documents were placed in sealed, labeled packaging for overnight delivery, with Federal Express, with all charges to be paid by my employer on the above date for collection at my place of business to be deposited in a facility regularly maintained by the overni~ht delivery carrier, or delivered to a courier or driver authorized by the overnight delivery carrier to receive such packages, on this date in the ordinary course of business. Hand Delivery: The correspondence or documents were placed in sealed~ labeled envelopes and served by personal delivef"tJ to the parrJ or attorney indicated herein, or if upon attorney, by leaving the labeled envelopes with a receptionist or other person having charge of the attorney's office. Facsimile Transmission: The correspondence or documents were placed for transmission from (650) 592-5027 at Redwood City, California, and were transmitted to ~ f~csimile ~achine 1 maintaine~ by the. ?arqr or ~~torney to be served at ~~e faCSltIllle machine telepnone number provided by saict party or attorney, on tills same date in the ordinary course of business. The transmission was reported as complete and without error, and a record of the transmission was properly issued by the transmitting facsimile machine. Electronic Transmission: The correspondence or documents "\\Tere trans!l1itted I electronically to the electronic address set forth below. 1 2 3 4 5 6 7 State. The recipient has filed and served notice that he or she accepts electronic service; the recipient has electronically filed a document with the court; and/ or the Court has mandated that the parties serve documents through its Court approved vendor. The printed form of this document bearing the original signature is on file and available for inspection at the request of the court or any party to the action 5.?r proceedir:g in which it is filed, in the manner provided in California Rule of Court Kufe 2.257 (a). Federal. The recipient of this electronic service has consented to this method of service in writing: a copy of which is on file and available for inspection in mv emolover's office. I have received no indication the electronic transmission did not {each 1. th~ recipient. 8 PERSONS OR PARTIES SERVED: 9 Attomeys for Plaintiff 10 Brian J. O'Grady, Esq. Law Office of Brian J. O'Grady 11 1150 W. El Camino Real, Suite B Mountain View, CA 94040 12 13 14 Telephone: Facsimile: E-mail: (650) 968-9612 (866) 901-1142 brian@brianogradylaw.com 15 I certify (or declare) under penalty of perjury under the laws of the State of California that 16 17 18 19 20 the foregoing is true and correct and that this ded 29, 2018. Eva Oliveira Court: Superior Court of California,5 anta Clara Counry 21 Action No: 18CV323948 22 23 24 2511 ,. 26 27 28 Case Name: Park, Jaiell v. Chow