Statement Case Management ConferenceCal. Super. - 6th Dist.November 20, 2020ZOCV373875 Santa Clara - Civil System System ArrORNEY 0R PARTY WTHOUT ATTORNEY (Name, Slate Bar number. and address): E|ectronicaflyffledw CM 1 1 o Arash Khorsandi. Esq. (249405)/Judd Allen. Esq. (251327) by Superior Court 0f CA, The Law Offices of Arash Khorsandi, PC County of Santa Clara, 2960 Wilshire Blvd., Third Floor. Los Angeles, CA 90010 on 8/1 8/2021 3:23 PM TELEPHONE No: (310) 277-7529 FAX No (Optimal); (310) 388-8442 ReVieWGd By: system system E-MAILADDRESS (Optional): ak@arashlaw.com; judd@arashlaw.com Case #20CV373875 ATTORNEY FOR (Namer Plaintiff, LIDIA RODRIGUEZ CRUZ Envelope: 70901 76 SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F SANTA CLARA STREET ADDRESS: 191 N. First Street MAILING ADDRESS: 191 N. First Street CITY AND ZIP CODE: San Jose, CA 951 13 BRANCH NAME: Downtown Superior Court PLAINTIFFIPETITIONER: Lidia Rodriguez Cruz DEFENDANT/RESPONDENT: Sandman, Inc., et aI. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one).- UNLIMITED CASE E LIMITED CASE 200V373875 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: September 2. 2021 Time: 10:00 a.m. Dept: 20 Div.: Room: Address of court (if different from (he address above): Notice of Intent to Appear by Telephone, by (name): Judd Allen, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. m This statement is submitted by pany (name): Plaintiff. LIDIA RODRIGUEZ CRUZ b. D This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-compiainants only) a. The complaint was filed on (date): November 20, 2020 b. E The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been sewed, have appeared. or have been dismissed b. E The following parties named in the complaint or cross-complaint (1) E 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) E have had a default entered against them (specify names): c. E: The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a- TVPe 0f case in complaint E cross-complaint (Descn‘be, including causes of action): High speed crash on a street due to Defendant's carelessness; negligence/negligence per se/negligent entrustment. Page 1 of 5 F°5'3d?£:.%:za°cn.”é:2‘;::zvmz5° CASE MANAGEMENT STATEMENT C:J.;“§:§L§°7“§s CM-11O [Rev. July 1. 2011] www courtscargov CM-1 10 PLAINTIFF/PETITIONER: Lidia Rodriguez Cruz CASE "UMBER- 200V373875 DEFENDANT/RESPONDENT; Sandman, Inc., et aI. 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 fulure medical expenses, lost earnings to date, and estimated future lost earnings. If equitable reliefis sought, describe the nature of the relief.) High speed car crash on street caused by Defendants' carelessness. Plaintiff has suffered serious injuries to her neck, back, bilateral shoulders. Medical specials to date; excessive of $370,779.23 and cont. Future Medical Specials; Subject to experts. Discovery is continuing. Loss of earnings/earning capacity: Subject to experts. 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 a jury trial E a nonjury trialA {If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. E The trial has been set for (date): b. No trial date has been set. This case will be ready for trial within 12 months of the date of the filing ofthe complaint (if not, explain): c, Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Trial: 10/4/21; 11/29/21; 12/2/21; 12/3/21; 12/8/21; 12/13/21; 1/21/22; 2/1 7/22; 2/28/22; 3/14/22; 3/22/22: 5/16/22; 10/5/22 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 5'7 days b. E hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial E by the attorney or party Iisted in the caption D by the following: a. Attorney: b. Firm: c‘ Address: d. Telephone number: f, Fax number: e. E-mail address: g. Party represented:E Additional representation is described in Attachment 8‘ 9. PreferenceE 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 has E 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: PartyD has D has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) E This matter is sub‘ect to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) [j Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.1 1. (3) E This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-“MRW Ju'v 1~ 2°“! CASE MANAGEMENT STATEMENT W 2°” CM-1 1 0 PLAINTIFF/PETITIONERI Lidia Rodriguez Cruz DEFENDANT/RESPONDENT: Sandman, Inc., et aI. CASE NUMBER: 200V373875 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): The party or parties completing this form are willing to participate in the following ADR processes (check all that apply): lfthe 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 (attach a copy of the parties’ADR stipulation): m (1) Mediation Mediation session not yet scheduled Mediation session scheduled for (date): Agreed to complete mediation by (date): Mediation completed on (date): (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): 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 private Private arbitration not yet scheduled Private arbitration scheduled for (date): DUDE DUDE DUDE DUDE DUDE DUDE amitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled E ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CM-1 10 [Rev July 1, 201 1] CASE MANAGEMENT STATEMENT Page a of 5 CM-JJn PLAINTIFF/PETITIONER: Lidia Rodriguez Cruz CASE NUMBER _ 200v373875 DEFENDANT/RESPONDENT: Sandman. |nc., et al. 11. Insurance a. E Insurance carrier, if any, for party filing this statement (name): b‘ Reservation of rights: E Yes E No c. E Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court'sjurisdiction or processing of this case and describe the status.D Bankruptcy D Other (specify): Status: 13. Related cases, consolidation, and coordination a. E 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. E A motion to E consolidate E coordinate will be filed by (name party): 14. BifurcationD 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 motionsa The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. E The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Pan! Descrigtion % Plaintiff Fact discovery Per Code P|aintiff Expert discovery per CCP 2034 Per Code c_ E The following discovery issues, including issues regarding the discovery of electronicaIly stored information. are anticipated (specify): CM-11O [Rev‘ July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-‘l 10 PLAINTIFF/PETITIONER: Lidia Rodriguez Cruz CASE NUMBER- 20CV373875 DEFENDANT/RESPONDENT: Sandman, “10-- et a'- 17. Economic litigation a.a This is a limited civil case (ile.. 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.a This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be fiIed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issuesE The party or parties request that the following additional matters be considered or determined at the case management conference (speciM: 19. Meet and confer a.E 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): 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: August 18, 2021 Judd R. Allen. Esq. ’ (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) > (TYPE 0R PRINT NAME) (SIGNATURE OF PARTY 0R ATTORNEY)E Additional signatures are attached. CM-m [Rev Ju'v 1- 20111 CAsE MANAGEMENT STATEMENT Wm 17 || 18 19 20 21 22 23!; 24 25 26 27 28 PROOF 0F SERVICE I declare that I am over the age of eighteen (1 8) and not a party t0 this action. My business address is 2960 Wilshire Blvd., Third Floor, Los Angeles, California 90010. On August 18, 2021, I caused to be served the following document(s): CASE MANAGEMENT STATEMENT on the interested pany(ies) in this action by placing a true and correct copy 0f document(s) in a sealed envelope addressed as follows: SEE ATTACHED SERVICE LIST [U.S. MAIL] I am readily familiar with the business practice for collection and processing of correspondence for mailing with the United States Postal Service. I know that the correspondence is deposited with the United States Postal Service on the same day this declaration was executed in the ordinary course of business. I know that the envelope was sealed and, with postage thereon fully prepaid, placed for collection and mailing on this date, following ordinary business practices in the United States mailed at Los Angeles, California. [FACSIMILE] Via facsimile machine, I caused the above-referenced document(s) to be transmitted to the person(s) listed above. [ELECTRONIC MAIL] Via electronic mail, I caused the above-referenced document(s) to be transmitted to the address listed above. (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on August l8, 2021, at Los Angeles, California. “MAW MARLO PALOMERA PROOF OF SERVICE SERVICE LIST Lidia Rodriguez Cruz vs. Sandman, Inc., et al. Case No. 20CV3738 75 pu-t Paul V. Samoni, Esq. LAW OFFICES OF JOHN A. BIARD P.O. Box 64093 St. Paul, Minnesota 55164-0093 Physical Address: 401 Lennon Lane, Suite 125 Walnut Creek, California 94598 Telephone: 925-746-3957 Facsimile: 855-668-5559 Email! mazngflgmlgxsmm Email: KAMABLE@travelers.com Attorneysfor Defendant SANDM4N, INC. dba STAR QUALITYCONCRETE andDICK .1 PORRAS PEREZ \OWVGUIAL'JN _. O llll 12 24H 25 26 27 28 PROOF 0F SERVICE
