Statement Case Management Conference

Cal. Super. - 6th Dist.November 23, 2020

ATTORNEY OR PARTY WITHOUT ATTORNEY I Name. Slate Sar number, mid eddmssi: FOR COURT USE ONLY CM-110 Jessie Serna, SBN 90912 1585 The Alameda, Suite 100 San Jose, CA 95126 TELEI NoNE NOJ 408-294-9002 Fxx No. Iopuo aa 408-294-827 E.MAIL ADDRESS (Opdones: ATTORNEYFCRI ):Plaintiff Stephanie BiSCelgia SUPERIDR coURT oF CALIFDRNIA, coUNTY QF Santa Clara STREETADDRESM 191 N. First Street Mnluxo ADDREss: 191 N. First Street OITYANDzIPODDE: San Jose, 951 13 slvwcN NAMe Civil PLAINTIFF/PETITIQNER: Stephenie Biscelgia DEFENDANT/REsPQNDENT: ChristoPher J. Solorzano CASE MANAGEMENT STATEMENT (Check one): K UNLIMITED CASE M LIMITED CASE (Amount demanded (Amount demanded is $25,000exceeds $25,000) orless) CASE NUMBER: 20CV373929 A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: April 6, 2021 Time: 3:00 P.M Address of court (if different from the address above): Dept.; 20 Divd Room; ~v Notice of intent toAppearby Telephone, by(name)f Jessie Serna INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (snslver one)f a. ~v This statement is submitted by party (name)f plaintiff Stephenie Bisceglia b. ~ This statement is submitted jointly by parties (names) I 2. Complaint snd cross-complaint (to be answered by plaintiffs and cross-compisinanis only)a. The complaint was filed on (dais): November 23, 2020 b. ~ The cross-complaint, if any, was filed on (dale)f 3. service (to be answered by plaintiffs and cross-compleinanls only) a. ~v All parties named 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 (1) M have not been served (specify names and explain why nor)i (2) M have been sewed but have not appeared and have not been dismissed (specify 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 date by whichthey may be served): 4. Description of case a. Type of case in ~v complaint C] cross-complaint (Describe, including causes of action): Automobile accident- negligence Form Adopted fer Mandelmy Use Judioal Counol of Caafomia CM-110 IRer. July 1. 201 II CASE MANAGEMENT STATEMENT Pape 1 o(0 Cal. Rules of Courb nites XT20-0 OO wuruuouftsoe.por Electronically Filed by Superior Court of CA, County of Santa Clara, on 3/30/2021 10:35 AM Reviewed By: System System Case #20CV373929 Envelope: 6136383 20CV373929 Santa Clara - Civil System System pLAINTIFF/pETITIQNER. Stephanle Blscelgla DEFENDANT/RESPONDENT: ChristoPher J. Solorzano CASE NUMBER: 20CV373929 4. b. Provide a brief statement of the case, induding any damages. (Ifpersonal injury damages ere sought, specify Ihe Injury anddamages claimed, including medical expenses to date (indicate source and amount), estimated future medical expenses, lostearnings to date, and estimated future lost earnings. Ifequitable relief is sought, describe the nature of the relief)Plaintiff sustained head concussion, eye sight, neck, shoulder and arm injuries. Medical bills are over $ 15,000.00plus wage loss is over $ 1,875.00. (Ifmore space is needed, check this box snd attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request M~ a jury trial C3 a nonjury trial. (Ifmore than one party, provide the name of each partyrequesting ajury lriai)r 6. Trial date a. ~ The trial has been set for (date)r b. K~3 No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (Ifnot, explain): c. Dates on which parties or attorneys will not be available for trial (specify dales and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. ~v days (specify number): 5 to 7 days b. C3 hours (short causes) (specify): 8. Trial representation (Io be answered for each party) The party or parties will be represented at trial ~v by the attorney or party listed in the caption ~ by the following:a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number.e. E-mail address: g. Party represented:Additional representation is described in Attachment 8. 9. Preference 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; readthe ADR information package provided by the court under rule 3.221 for information about the processes available through thecourt and community programs in this case. (1) For parties represented by counsel: Counsel H has IK has not provided the ADR information package identifiedin rule 3.221 to the client and reviewed ADR options with the dient. (2) For self-represented parties: Party H has H has not reviewed the ADR information package identified in rule 3.221.b. Referral to judicial arbitration or civil action mediation (if available). (1) ~ This matter Is subject to mandatory judicial arbitration under Code of Civil procedure section 1141.11 or to civil actionmediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed thestatutory limit. (2) ~ Plaintiff elects to refer this case tojudicial arbitration and agrees to limit recovery to the amount specified in Code ofCivil Procedure section 1141.11. (3) ~ This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil actionmediation under Code of Civil Procedure section 1775 et seq. (specify exemption): ceu110 IRev. Julr L 201 li CASE MANAGEMENT STATEMENT Reee 0 or 0 PLAINTIFF/PETITIONER: Stephanie Biscelgia EFENDANT/RESPONDENT: Christopher J. Solorzano L CASE NUMBER: 20CV373929 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, orhave already pariicipated in (check all that apply and provide the specified information)i The party or parties completing this form are willing to participate in the following ADR processes (check all that apply) If the party or parties completing this form in the case have agreed toparticipate in or have already completed an ADR process or processes.indicate the status of the processes (attach a copy of the parties'ADR stipulation): (1) Mediation Dv C~3 Mediation session not yet scheduled Mediation session scheduled for (date)i Agreed to complete mediation by (date)r Mediation completed on (date): (2) Settlement conference Settlement conference not yet scheduled Settlement conference scheduled for (date)i Agreed to complete settlement conference by (date)i Settlement conference completed on (dale): (3) Neutral evaluation C7 Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): Agreed to complete neutral evaluation by (date)i Neutral evaluation completed on (date): (4) Nonbinding judicial arbitration Judicial arbitration not yet scheduled Judicial arbitration scheduled for (date)i Agreed to complete judicial arbitration by (dare)i Judicial arbitration completed on (dafe): (5) Binding private arbitration Private arbitration not yet scheduled Private arbitration scheduled for (date): Agreed to complete private arbitration by (date)i Private arbitration completed on (date): (6) Other (specify): ADR session not yet scheduled ADR session scheduled for (date)i Agreed to complete ADR session by (date)i ADR completed on (dais): cM-110 lacy. July 1, 3011I CASE MANAGEMENT STATEMENT Page 3 of 5 FPLAINFIFFIPETITIQIJER: Stephanie BiscelgiaDEFEIJDalgTIREsr DBIDEIJT; Christopher J. Solorzano ! CASE NUMBER: 20CV373929 11. Insurance a. ~ Insurance carrier, if any, for party filing this statement (name)r AAA Insuranceb. Reservation of rights: H Yes M 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 H Other (specify): Status: 13. Related cases, consolidation, and coordination~ 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. H A motion to H consolidate ~ coordinate will be filed by (name party): 14. Bifurcation~ The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes ofaction (specify moving party, type ofmotion, and reasons): 15. Other motions~ The party or parties expect to file the fallowing motions before trial (specify moving party, type of moffon, and issues): 16. Discovery a. ~ The party or parties have completed all discovery. b. ~~ The following discovery will be completed by the date specified (describe a/I anticipated discovery):Parak Descrioticn Date Plaintiff Interrogatories July 2021 Deposition Production of Documents c. ~ The following discovery issues, including issues regarding the discovery of electronically stored information, areanticipated (specifyj: Cal.i10 Iney.July 1,20111 CASE MANAGEMENT STATEMENT page e of 0 PLAINTIFFIPETITIQNER: Stsphanis Biscelgta QEFENQANT/RE$poNDENTI Christopher J. So(orzano CASE NUMBER: 20CV373929 CM-110 17. Economic litigation a. ~ This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Codeof Civil Procedure sections 90-90 will apply to this case. b. ~ This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additionaldiscovery will be filed (if checked, explain specif(cally why economic liligadon procedures relsling lo discovery or trialshould not apply fo this case)) 1EL Other issues~ The party or parties request that the following additional matters be considered or determined at the case managementconference (specify)( 19. Meet and confer a. Cvl The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rulesof 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) I 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 ofthe case management conference, inc)uding ths written authority of the party where required. Date: March 30, 2021 Jessie Serna (TYPE OR PRINT NAME) nYPE OR PRINT NAME) (BIG/USE OF PARTY OR ATTORNEY) (SIGNATURE OF PARTY OR ATTORNEY)~ Additional signatures are attached. CM.110 Eiou July I, 2011) CASE MANAGEMENT STATEMENT paso 0 or 0 PROOF OF SERVICE 2 I declare under penalty ofperjury that the following facts are true and correct. I 3 am a citizen of the United States, overthe age of eighteen years, and not a party to or 4 interested in the within entitled action. I am an employee of the Law Office of Jessie Sema, 1585 The Alameda, Suite 100, San Jose, California 95126-1775. On March 30, 2021 I emailed the following: CASE MANAGEMENT STATEMENT 8 By Emrril: Claudia.Lozano farmersinsurnace.corn 9 10 12 13 14 15 Claudia Lozano, Esq. Stratman, Schwartz 4 Williams-Abrego P.O. Box 258829 Oklahoma City, OK 73125 I declare under penalty of perjury under the laws of the State of California that the above is both true and correct. 16 Dated: March 30, 2021 17 18 19 20 21 22 23 24 25 26 Monique Herrera 27 28