Statement Case Management ConferenceCal. Super. - 6th Dist.April 1, 202121 CV381 538 Santa Clara - Civil CM-110 ATTORNEY 0R PARTYWITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY R- Fleming Michael Daurio, Esq. [SBN 327810] €38le W?Clzsh ' re Blvd 12th Floor Elecuonically Filed l l . . Beverly Hills , California 90212 by SUperlor court Of CA’ TELEPHONE No.: (310) 887-1818 FAXNo.(0ptiona/): (310) 887-1880 county Of santa Clara’ E-MAILADDRESS; mdo@bhatt0rneys . com on 1/18/2022 1:51 PM ATTORNEY FOR(Name).- Plaintiff RGViewed By: R. Fleming SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F SANTA CLARA Case #21 CV381 538 STREETADDRESS: l 91 North First St . Envelope: 8078828 MAILINGADDRESS: 191 North First St. CITYANDZIPCODE: San Jose, CA 95113 BRANCH NAME: DOWNTOWN COURTHOUSE PLAINTIFF/PETITIONER: Raymound D. Johnson, an individual DEFENDANT/RESPONDENT: Madian Samusundaram, an individual; Sidhart an individual; and DOES l to 20, inclusive CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): m UNLIMITED CASE D LIMITED CASE 2 1 CV3 8 1 5 3 8 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 2 / 3 /2 022 Time: l O : O O AM Dept: 2 O Div.: Room: Address of court (if different from the address above): m Notice of Intent to Appear by Telephone, by (name): Michael Daurio , E sq . 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 party (name): Plainti ff Raymound Johnson b. D This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): 4 / l /2 022 b. D The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. D A|| parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. m The following parties named in the complaint or cross-complaint (1) m have not been served (specify names and explain why not): Complaint out for service. Plaintiff humbly requests more time. (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 m complaint D cross-complaint (Describe, including causes of action): motor vehicle; general negligence Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California .CEB‘ Essential rules 3720-3130 CM-1 10 [Rev. September 1, 2021] ceb_com Epormg www.courts.ca.gov Johnson, Raymound D. CM-110 PUMNHFHPEHHONERzRaymound D. Johnson, an individual CMENUMER DEFENDANT/RESPONDENT: Madian Samusundaram, an individual; Sidhart an individual; and DOES l to 20, inclusive 4. b. Provide a brief statement of the case, including any damages. (prersonal 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.) Defendant was driving too fast for prevailing conditions and failed to notice traffic slowing ahead. As a result, defendant rear-ended Palintiff, causing property damage and personal injuries. Plaintiff's medical specials are still being ascertained but exceed $50,000.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 m a jury trial D a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. D The trial has been set for (date): b. m 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 (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. m days (specify number): 5- 7 b. D hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial D by the attorney or party listed in the caption m by the following: a. Attorney: Owili K . Eison, Esq . b. Firm: BD&J, PC c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented:D Additional representation is described in Attachment 8. 9. PreferenceD 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 of the California Rules of Court for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel m has D 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 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) D This matter is subject to mandatoryjudicial 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) D 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 from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-11o [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of5 .CEB‘ Essential mbamwfiflflfi‘ Johnson, Raymound D. CM-110 DEFENDANT/RESPONDENT: Madian Samusundaram, an individual; PLAINTIFF/PETITIONER:Raymound D. Johnson, an individual Sidhart an individual; and DOES l to 20, inclusive CASE NUMBER: 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 If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties'ADR processes (check all that apply): stipulation): (1) Mediation m m Mediation session not yet scheduled D Mediation session scheduled for (date): D Agreed to complete mediation by (date): D Mediation completed on (date): conference D Settlement conference not yet scheduled (2) Settlement D Settlement conference scheduled for (date):D D Agreed to complete settlement conference by (date): D Settlement conference completed on (date): (3) Neutral evaluation D 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): arbitration D Judicial arbitration not yet scheduled (4) Nonbinding judicial D D Judicial arbitration scheduled for (date): D Agreed to complete judicial arbitration by (date): D Judicial arbitration completed on (date): arbitration D Private arbitration not yet scheduled (5) Binding private D D Private arbitration scheduled for (date): D Agreed to complete private arbitration by (date): D Private arbitration completed on (date): D ADR session not yet scheduled (6) Other (specify): D D ADR session scheduled for (date): D Agreed to complete ADR session by (date): D ADR completed on (date): CM-1 1o [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5 .CEB‘ Essential ceb.com EM" Johnson, Raymound D. CM-110 PLAINTIFF/PETITIONER:Raymound D. Johnson, an individual CASENUMBER: DEFENDANT/RESPONDENT: Madian Samusundaram, an individual; Sidharth an individual; and DOES l to 20, inclusive 11. Insurance a. D Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: D Yes D No c. D 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 Bankru ptcy 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 Amotion to D consolidate D 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 motionsD The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. D The party or parties have completed all discovery. b. D The following discovery will be completed by the date specified (describe all anticipated discovery): PaJt Description % Plaintiff Written Discovery Per Code Plaintiff Depositions Per Code Plaintiff Expert Discovery Per Code c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-11o [Rev. September1, 2021] CASE MANAGEMENT STATEMENT Page4of5 .CEB‘ Essential mbamwfiflflfi‘ Johnson, Raymound D. CM-110 PLAINTIFF/PETITIONER:Raymound D. Johnson, an individual CASENUMBER: DEFENDANT/RESPONDENT: Madian Samusundaram, an individual; Sidhart an individual; and DOES l to 20, inclusive 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 trial should not apply to this case): 18. Other issuesD 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. D 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. D 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):- | 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. Dag 1/14/2022 Michael Daurio, Esq. ’ WW (TYPE OR PRINT NAME) V (SIGNATURE OF PARTY OR ATTORNEY) D (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)D Additional signatures are attached. CM-1 1o [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5 .CEB‘ Essential ceb.com EM" Johnson, Raymound D.
