Statement Case Management ConferenceCal. Super. - 6th Dist.October 5, 2018ATTORNEY OR PARTY INITH OUT ATTORNEY fName, State Bar numser and address) Pschard G. Grotch, Eaq. SBN:127713/Hahmoud Fadli, Eaq. SBN:280007 Coddington, Hicks & Danforth 555 Twin Dolphin Drive, Suite 300 Redwood City, CA 94065 TC.LEpHoxr: No ( 65 0 ) 5 92 5 4 0 0 Fax No fop)Noel). ( 65 0 ) 5 92 5 02 7 0 MciLaDDREssfops-»i rgrotch8chdlawyers. corn ATTURNEYFDR(Name) Southwest Airlines, . Co. I SUPERIQR coURT 0F GALIFCPNIA coUNTY QF SANTA CLARA sTREETADDREss 1 91 North First Street MAILING ADDRESS cITYANDzfPcoDE San Jose, California 95113 BRANCH NAME Pl AINTIFF/PET!TIQNER. Margoreth Galvez FOR COURT USE ONLY CM-110 CEFENoaNT/REsPONCENT: Southwest Airlines, Co. CASE MANAGEMENT STATEMENT (Check one)r [Q UNLIMITED CASE ~ LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date September 3, 2019 Time: 10:00a.m. Dept.: 8 /Address of court (if different from the address above): Judge Strickland CASE NUMBER 18CV336134 Divz Room: Notice of Intent to Appear by Telephone, by (name)I Mahmoud Fadl i INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): s. ~ This statement is submitted by party(name): Southwest Airlines, Co. b. ~ This statement is submitted)ointly by parties (names)) 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-comp/sinants only) a. The complaint was filed on (date): b ~ The cross-complaint, if any, was filed on (date)) 3. Service (to be answered by plaintiffs and cross-compiainsnfs only) a. ~ Ail parties I,amed 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-complaint (I) ~ have not been served (specify names and explain why not)i (2) ~ have been served but have not appeared and have not been dismissed (spemfy 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 the date by which they may be served): 4. Description of case a. Type of case in ~ complaint ~ cross-complaint (Describe, including causes of action): Alleged slip and fall at the San Jose International Airport FormAdoptadforMandatorruse, . CASE MANAGEMENT STATEMENTJude el Counol of Caftfomra (fg EaaeittbatCM-110 IRev July I, 2011l cam fJFOm S'age '. eCal Rules cf Courtmiss 3 720-3 73iwww courts ca gov GALVEZ HARGORETH v CITY OF SJ Electronically Filed by Superior Court of CA, County of Santa Clara, on 8/14/2019 3:02 PM Reviewed By: System System Case #18CV336134 Envelope: 3262640 18CV336134 Santa Clara - Civil System System PLAINTIFF/PETITIONER:Margoreth Galvez DEFENDANT/RESPONDENT: Southwest Airlines, Co. I CASE NUMBER 18CV336134 CM-110 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 a// that apply and provide the specified /n/orms//on): The party or parties completing this form are willing to participate in the following ADR processes (check el/ tha/ 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 (aftach a copy of the part/es'ADR stipulation): (1) Mediation ~ Mediation session not yet sclieduled ~ Mediation session scheduled for (dafe): ~ Agreed to complete mediation by (dafe): ~ Mediation completed on (dafe): (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): (3) Neutral evaluation ~ Neutral evaluation not yet scheduled ~ Neutral evaluation scheduled for (date): ~ Agreed to complete neutral evaluation by (date)2 ~ Neutral evaluation completed on (date): (4) Nonbinding judicial arbitration ~ Judicial arbitration not yet scheduled ~ Judicial arbitration scheduled for (date): ~ Agreed to complete judicial arbitration by (date): ~ Judicial arbitration completed on (date): (5) Binding pnvate arbitration ~ Private arbitration not yet scheduled ~ Private arbitration scheduled for (date): ~ Agreed to complete private arbitration by (date) ~ Private arbitration completed on (date): (6} Other (spec/fy): ~ ADR session not yet scheduled~ ADR session scheduled for (date): ~ Agreed to complete ADR session by (date) ~ ADR completed on (da/e): CM-110 IRe July 1, 2011 i { f8'~ Essential feseoal I )3Folrl1ts CASE MANAGEMENT STATEMENT Page 3 of 5 PLAINTIFF/PETITIONER1Na1go1eth Galvez EFENDANTIREsloNDFNT: Southwest Airlines, Co. CASE NUMBER 18CV336134) CM-1 10 11. Insurance a. ~ Insurance earner, if any, for party filing this statement (name): usstc b. Reservation of rights: ~ yes Qg 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.~ Bankruptcy ~ 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:~ Additional cases are described in Attachment 13a. b. ~ A motion to ~ consolidate ~ coordinate will be filed by (name party): 14 Bifurcation~ The party or paries 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. ~ The party or parties have completed all discovery. b. ~ The following discovery will be completed by the date specified (descnbe a/I anticipated discovery): ~Part Descriotion Def. Southwest Written Discovery Def. Southwest Plaintiff Deposition Def. Southwest Expert Discovery Date On going On going Per Code c. ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (spemfy): CM 110 [Rey July 1, 20111 ('80; ~ Ementtst CASE MANAGEMENT STATEMENT Page 4 of 5 PLAINTIFF/PETITIQNER. (vjargoreth Galvez DEFENDANT/REsPQNDENT: Southwest Airlines, Co. CASE NUMBER 18CV336134 CM-110 17. Economic litigation a ~ This is a limited civil case (i.eu 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 frorri the economic liiigation procedures or for additional discovery will be filed (if checked, explain specifical!y why economic litigalion procedures relating lo discovery or trial should nol apply to this case): 18. Otherissues~ 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 (il any): I am completely familiar with this case and will be fugy 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: August 13, 2019 (TYPE OR PRINT NAME) (/NATU OF PARTY ATTORNEY) ITYI E OR PRINT I!AME) (SIGNATURE OF PAR YOR AT ORNEY)~ Additional signatures are attached. CM-110 (Rev July I, 2011) CASE MANAGENIENT STATEMENT Page 6 or B Coo t& CourtCO(l i!ppeoronce - Service Copy This document shall serve as notice of a CourtCall 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. Mohmoud A. Fauli Coddington, Hicks sr Danforth Teh (650) 592-5400 Fax: (650) 592-5027 Case Name: Galvez vs. City of San Jose Case Number; 24-18CV336134 Court Name: Santa Clara County Supenor Court (CA) Dept/Judge: 8 / Judge Sunll R. Kulkarni Proceeding: Case Management Conference Date/Time: Tuesday, September 3rd, 2019 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 CourtCall. While clients can save money and Courts can become more efficient and generate revenue, CourtCali 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 farnlly and fnends or otherw(se take advantage of tl e time no longer spent traveling to and from Court. Call us for details. There are no subscnptions or equipment to buy. COURTCALL VIDEO IS HEREI CourtCall is equippmg Courtrooms of intplPSIpd Judges w!th 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 accc rdance with a Judge' preferences. To learn more about video options, please ask a CourtCall representative. The foregoing information may have been obtained from court . ecord which may not rellect 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 rlo 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 call to schedule a presentation. RelTIO(6 IAPPeBI BIICeS. Sl(TI(Jllfled. CourtCall Appearances are available for over 2,000 Judges nationwide, with additional Courts being added mOnthly. PleaSe ViSit Our Webaite at WWW.COurtCall.COm far a CamPlete hSt Of PartiCIPatinn I:Ourta and Iurjgee across the US, Canada and other jurisdictions. NOTFO [P] SERVICE COPY FOR COURTCALLIE APPEARANCE Copynsht 0 2019 Councoll, LLC AS Rights Rosorvod 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) I, the undersigned, declare that I am employed in the County of San Mateo, Siate of 5 CaL'fornia. I am over the age of eighteen (18) years and not a party io the within aciion. My 6 business address is 555 Twin Dolphin Drive, Suite 300, Redwood City, California 94065. My 7 i electronic maii aadress is Ioseguera@chdhawyers.corn. 8 I am readily familiar vath my employer's business practice for. collection and processing 9 of coriespondence and documents for mailing with the United Si.ates Postal Service, mailing via 10 overnight delivery, transmission by facsimile machine, and delivery by hand. 11 On August 14, 2019, I served a copy of each of the documents listed below by placing 12 said copies for processing as indicated herein. CASE MANAGEMENT STATEMENT 13 AND COURT CALL APPEARANCE - SERVICE COPY 14 X 15 17 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 ~vith the U.S. Postal Service at Redwood City, CaL'fornia on th'.s same date "n the ordinary course of business. 19 20 Overnight Delivery: The correspondence or documents were placed in sealed, labeled packaging for overnight: delivery, with Federal Express, wii.h 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 overnight 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. 21 22 23 24 25 26 27 28 I%and Delivery: The correspondence or clocuments were placed in sealed, labeled envelopes and served by personal delivery to the patty 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. documinis were placed for transmission from (650) 592-5027 at Redwood City, California, and were transmitted to a facsimile machine maintained by the party or attorney i.o be served at the facsimile machine telephone number. provided b- said party or attorney, on this same uai.e 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 were transmitted electronically to the electronic address set forth below. 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 thai the parties serve documents through iis Court approved vendor. The printed form of this document bearing the original signaiure is on file and available for inspection at the request of the court or any party to ihe action o" proceeding in which it is filed, in the manner provided in California Rule ol Court Rule 2.257(a). Federal. The recipient of this electronic service has consented to t.his method of service in writing, a copy of which is on file and available for inspecuon in my employer's office. I have received no indication the electronic transmission did not reach the recipient. 8 PERSONS OR PARTIES SERVED: 9 Attorneys for Plaintiff Attorneys for City of5'an Jose 10 12 Raymond Ghermezian, Esq. Raymond Ghermezian A Professional Lasv Corporation 3435 Wilshire Blvd, Suite 1800 Los Angeles, CA 90010 Richard Doyle, City Attoiney Nora Frimann, Assistant City Attorney Office oE the City Attorney 200 East Santa Clara Street, 16ra Floor San Jose, CA 95113-1905 13 Telephone: (323) 900-5800 Facsimile: (323) 900-5801 14 E-maib Telephone: (408) 535-1900 Facsimile: (408) 998-3131 Email: cao.main@sanjoseca.gov 15 16 Attorneeas for GCA Servyrces Gronp Inc 17 18 19 Scott D. Cunningham, Esq. Andrew C. Johnson, Esq. Condon tie Forsyth LLP 1901 Avenue of the Stars, Suite 850 Los Angeles, Csk 90067-6010 20 Telephone: (310) 557-2030 Facsimile: (310) 557-1299 21 E-maib scunningham@condonlaw.corn 22 23 24 I cerdfy tor declarei under penalty of perj' nder the 'aves of thc. State of Caufoivniia iha( 25 the Eoregoing is true and correct and that tliis d on August 14, 2019. 26 27 ~tea Os~dr/~ Court: Safserior Coartof'Caafornia, Santa Ctara Coarity 2.8 Action No: 18Ctr'336134 Cane Name: Catered, Marsoretts i'. City ofsan Jose