case management statement

Cal. Super. - 1st Dist.October 18, 2021

ATTORNEY OR PARTY WITHOUT ATTORNEYIName, State sar numeer end address):Malyam Poursardar.Pro Se 64 Encanto Ave. San Francisco, CA 95115 FOR COURT USE ONLY CM-110 TELEPHQNE No.l (408) 507-9937 FAX NO foplronalil E MAILADDREssfoplonagl Mafyampsf@yahoo.corn ATTORNEY FOR (Nemell SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO sTREETnDDREss: 400 McAllister Street MAILING AODRESR cITY AND zip coDE: San Francisco 941 02 BRANCH NAME: PLAINTIFF/PETITIONER: Maryam Poursardar DEFENDANT/RESPONDENT: VY QUOD TRYINFI and DOES ONE through TWENTY CASE MANAGEMENT STATEMENT t(Check one): ~x UNLIMITED CASE ~ LIMITED CASE (Amount demanded (Amount demanded is $25,000exceeds $25,000) or less) CASE NUMBER: C GC-20-585513 A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date; Dec 23,2020 Time: 10:OOAM Dept.: 610 Address of court (if differenl from the address above): Divx Room: ~~ Notice of Intent to Appear by Telephone, by (name)r INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.1. Party or parties (answer one): a. ~x This statement is submitted by party (name): Maryam Poursardar b. ~ This statement is submitted jointly by parties (names)r 2. Complaint and cross-complaint (lo be answered by plaintiffs and cross-complainanls only) a. The complaint was filed on (dale): July 22, 2020 b. ~ The cross-complaint, if any, was filed on (dale)f 3. Service (to be answered by plaintiffs and cross-complainanls only) a. ~x Ail 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) ~ have not been served (specify names and explain why nol)r (2) ~ have been served 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 dale by whichthey may be served): 4. Description of case a. Type of case in ~x complaint ~ cross-complaint (Describe, inc/uding causes of action): Form Adopled for Mandatory Use Jud mal Counnf of Cal fomia CM-1 10 IRev. July I, 201 1I CASE MANAGEMENT STATEMENT Pago I of 3 cal Rulos of Coun, rufos 3. 720-3. 730 www menses gov ELECTRONICALLY F I L E D Superior Court of California, County of San Francisco 11/23/2020 Clerk of the Court BY: NEYL WEBB Deputy Clerk PLAINTIFF/PETITIONER: Maryam Poursardar DEFENDANT/RESPONDENT: VY QUOD TRYINH and DOES ONE through TWENTY CASE NUMBER: CGC-20-585513 CM-110 4. b. Provide a brief statement of the case, including any damages. (II personal injury damages are sought, specify the injury and damages claimed, including medical expenses Io dale (Indicate source and amount), estimated Iulure medical expenses, lost earnings Io date, and estimated future Iosl earnings. If equitable relief is sought, describe Ihe nature of the relief) I was rear ended during a car accident with extensive damage to my car and personal injury with medical expenses incurred as of today totaling $10,010.6. Expected medical expenses next year for the same amount due to continuing pain and referral to a specialist. Quality of life and work performance has been significantly impacted. Total compensation of $70k is requested, ~ a nonjury trial. (Ifmore than one party, provide the name of each party ~ (II more space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial a. The party or parties request ~ a jury trial requesting a jury tn'al): Trial date a. ~ The trial has been set for (dale): b. ~ 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 nol, explain) 1 c. Dates on which parties or attorneys will not be available for trial (specify dales and explain reasons for unavailability): Estimated length of trial The party or parties estimate that the trial will take (check one): a. ~ days (specify number): b. ~ hours (short causes) (specify): Trial representation (Io be answered for each pariy) The party or parties will be represented at trial ~ by the attorney or party listed in the caption a. Attorney: b. Firm: ~ by the following: c. Address: d. Telephone number: e. E-mail address:~ Additional representation is described in Attachment 8. Preference~ This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) f. Fax number: g. Party represented: 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 ~ 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 ~ has ~N 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 action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2)~ 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)~ 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): CM110 [Rc . July 1,2011I CASE MANAGEMENT STATEMENT Paac 2 cf 1 PLAINTIFF/PETITIONER: Maryam Poursardar DEFENDANT/RESPONDENT: VY QUOD TRYINH and DOES ONE through TWENTY CASE NUMBER: CGC-20-585513 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 participated in (check all that apply and provide the specified information): (1) Mediation The party or parties completing this form are willing to participate in the following ADR processes (check a/I that 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 (attach a copy of the parties'DR stipula lion) 2 ~31 Mediation session not yet scheduled~ Mediation session scheduled for (dale)r~ Agreed to complete mediation by (date):~ Mediation completed on (date): (2) Settlement conference ~ Settlement conference not yet scheduled~ Settlement conference scheduled for(dale):~ Agreed to complete settlement conference by (dale)r~ Settlement conference completed on(date): (3) Neutral evaluation ~ Neutral evaluation not yet scheduled~ Neutral evaluation scheduled for (date)i~ Agreed to complete neutral evaluation by (dale):~ 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)r~ Judicial arbitration completed on (dafe): (5) Binding private arbitration ~ Private arbitration not yet scheduled~ Private arbitration scheduled for (dale):~ Agreed to complete private arbitration by (date):~ Private arbitration completed on (date): (6) Other (specify): ~ ADR session not yet scheduled~ ADR session scheduled for (date):~ Agreed to complete ADR session by (date):~ ADR completed on (date): CM-110IRev.ielr 1,2011I CASE MANAGEMENT STATEMENT Page 3 ef 5 PLAINTIFF/PETITIONER: Maryam Pourssrdar DEFENDANT/RESPONDENT: 1/Y QUOD TRYINH snd DOES ONE through TWENTY 11. Insurance a ~ Insurance carrier, if any, for party filing this statement (name)/ b. Reservation of rights: ~ Yes ~ No c. ~ Coverage issues will significantly affect resolution of this case (exp/a/n)/ ! CASE Nousse CGC-20-585513 CM-110 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 parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes ofaction (spec//y 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, endissues): 16. Discovery a. ~ The party or parties have completed all discovery. b. ~ The following discovery will be completed by the date specified (describe a// anticipated discovery)/ ~patt ~Des rip~tin Date c. ~ The following discovery issues, including issues regarding the discovery of electronically stored information, areanticipated (spec//y)i CM-iio Iitov iuir i, zoiil CASE MANAGEMENT STATEMENT P o 4o/5 PLAINTIFF/PETITIONER: Maryam Poursardar DEFENDANT/RESPONDENT: VY QUOC TRYINH and DOES ONE through TWENTY CASE NUMBER CGC-20-585513 CM-1 10 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 90-98 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 additional discovery will be filed (if checked, exp/a/n specifically why economic /i/igalion procedures re/a/ing fo discovery or lris/should nof apply to this case): 18. Other issues ~N The party or parties request that the following additional matters be considered or determined at the case management conference (specify)/ I am temporarily out of the county due to a family health emergency and requesting to move the case management conference date to May 2021. 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 nol, 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 al the time ofthe case management conference, including the written authority of the paAy where required. Date: November 22, 2020 Maryam Poursardar (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)~ Additional signatures are attached. CM-11c (Rev. July I, 2011) CASE MANAGENIENT STATEMENT Page 5 er 5 For your protection and privacy, please press the Clear This Formbutton alteryouhave printed the form. ) print this form ~ ( Save this form ( ( Clear this form I Proof of Service (FRCP 5 & C.C.P. tj 1013a(3), 2009, 2015.5) I, the undersigned, under penalty of perjury, dcclarc and say: That I am, and was at the time of service hereinafter mentioned, over the age of 18 years, a citizen of the United States, and not a party to the within entitled cause of action. My business address is 101 Lucas Valley Road, Suite 273, San Rafael, CA 94903. RE: MARYAM POURSARDER VS. VY OUOC TRYINI-I. ET AL San Francisco Countv Superior Court Case No.: CGC-20-585513 9 10 ll 12 13 14 On the date last written herein, I served: CASE MANAGEMENT STATEMENT on the person(s I indicated below in a sealed envelope addrcsscd to: Kclli George Raj Chowdhury Philip M. Anderson & Associates Employees of the Law Department State Farm Mutuaal Automobile Insurance Company Cali. law-pleasanton-e service. 081 o02 statefarm. corn 16 17 18 19 20 21 22 23 [ ] VIA MAIL: I am readily familiar with the business practice for collection and processing of fully prepaid postage on correspondencc for mailing with thc United States Postal Service, service of the below described document would have bccn deposited with the United States Postal Service on the same day on which said document was placed at San Rafael Post Office for deposit.with the United States Postal Service. [ X ] VIA EMAIL:: Based on a court order or an agreement of the parties to accept service by e-mail or electronic transmission, I caused the document(s) to be sent to the respective e-mail address(es) of the party(ies) as stated above. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. 25 26 27 Executed on November 22, 2020 at San Rafael, CA. Q,~ PW+ic~a Alisa Pcrticonc