case management statement

Cal. Super. - 1st Dist.September 27, 2021

X X X X COLLINS + COLLINS LLP 790 E. Colorado Boulevard, Suite 600, Pasadena, CA 91101 This is a wrongful death / survival action filed by the decedent’s alleged sister. Plaintiff’s complaint included causes of action for negligence, wrongful death, and “Tort Claims Act”. SAN FRANCISCO CITY AND COUNTY OF SAN FRANCISCO, et al. CAHILL CONTRACTORS LLC ANGELA STARKS 10:30 a.m. 09/29/2021 CGC-20-588155 Taylor J. Pohle, Esq. (State Bar No. 299794) Edward J. Riffle, Esq. (State Bar No. 193983) (626) 243-1100 (626) 243-1111 CAHILL CONTRACTORS LLC Taylor J. Pohle, Esq. 400 McAllister Street 400 McAllister Street San Francisco, 94102-4515 Civic Center Courthouse 610 610 ELECTRONICALLY F I L E D Superior Court of California, County of San Francisco 09/01/2021 Clerk of the Court BY: VERA MU Deputy Clerk X X X X Plaintiff Angela Starks is the alleged “immediate sibling” and “successor of interest” of decedent Angelique Starks; however, Plaintiff did not file a Code of Civil Procedure section 377.32 declaration. This court recently sustained Cahill’s demurrer with leave to amend. As of the date of filing this case management statement, Plaintiff has not amended her complaint. Plaintiff has not shared with Cahill the nature or extent of her alleged damages. Plaintiff has not amended her complaint following the demurrer. Discovery not started; COVID may impact scheduling. 10/04/21; 10/18/21; 10/21/21; 10/25/21; 11/01/21; 11/08/21; 12/30/21; 01/10/22; 01/14/22; 01/18/22; 01/21/22; 01/31/22; 02/04/22; 02/14/22; 02/28/22; 03/07/22; 04/04/22; 04/05/22; 05/02/22; 06/07/22; 06/15/22; 06/21/22; 09/06/22; 09/19/22; 04/10/23; 06/12/23 (Trial Start Dates) X ANGELA STARKS CITY AND COUNTY OF SAN FRANCISCO, et al. CGC-20-588155 5-7 days X X X X CITY AND COUNTY OF SAN FRANCISCO, et al. ANGELA STARKS CGC-20-588155 X X X Defendant may also file a demurrer, MSJ, and/or MSA depending on allegations in the not yet filed First Amended Complaint. Other motions may be required based on the nature of the new amended allegations. Pending San Francisco County Superior Court CGC-21-592213 Angela Johnson v. City and County of San Francisco et al. Per Code CITY AND COUNTY OF SAN FRANCISCO, et al. ANGELA STARKS CGC-20-588155 Liberty Mutual Insurance Per Code Per Code Expert discovery and depositions Third party discovery and depositions Written discovery and depositions Cahill Contractors LLC Cahill has met and conferred with Plaintiff as to the viability of Plaintiff’s claims against Cahill. September 1, 2021 Taylor J. Pohle, Esq. ANGELA STARKS CITY AND COUNTY OF SAN FRANCISCO, et al. CGC-20-588155 0 PROOF OF SERVICE (CCP §§ 1013(a) and 2015.5; FRCP 5) State of California, ) ) ss. County of Contra Costa. ) I am employed in the County of Contra Costa, State of California. I am over the age of 18 and not a party to the within action; my business address is 2175 N California Boulevard., Suite 835, Walnut Creek, California 94596. On this date, I served the foregoing document described as CASE MANAGEMENT STATEMENT on the interested parties in this action by placing same in a sealed envelope, addressed as follows: SEE ATTACHED SERVICE LIST (BY MAIL) - I caused such envelope(s) with postage thereon fully prepaid to be placed in the United States mail in Walnut Creek, California to be served on the parties as indicated on the attached service list. I am “readily familiar” with the firm’s practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at Walnut Creek, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. (BY CERTIFIED MAIL) - I caused such envelope(s) with postage thereon fully prepaid via Certified Mail Return Receipt Requested to be placed in the United States Mail in Walnut Creek, California. FEDERAL EXPRESS - I caused the envelope to be delivered to an authorized courier or driver authorized to receive documents with delivery fees provided for. (BY ELECTRONIC FILING AND/OR SERVICE) - I served a true copy, with all exhibits, electronically on designated recipients listed on the attached service list. (ELECTRONIC SERVICE PER CODE CIV. PROC., § 1010.6) - By prior consent or request or as required by rules of court (Code Civ. Proc., § 1010.6 (amended Jan. 1, 2021); Code Civ. Proc., § 1013(g); Cal. Rules of Court, rule 2.251(a)). (BY PERSONAL SERVICE) - I caused such envelope(s) to be delivered by hand to the office(s) of the addressee(s). Executed on September 1, 2021 at Walnut Creek, California. (STATE) - I declare under penalty of perjury under the laws of the State of California that the above is true and correct. (FEDERAL) - I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. Kelly Forst kforst@ccllp.law ANGELA STARKS v. CITY AND COUNTY OF SAN FRANCISCO, et al. San Francisco County Superior Court Case Number: CGC-20-588155 CCCLP File Number: 22847 SERVICE LIST Brian L. Larsen, Esq. Joseph Lee, Esq. Marven Masihi, Esq. LAW OFFICES OF BRIAN L. LARSEN 530 Jackson Street, Second Floor San Francisco, CA 94133 Tel: (415) 398-5000 brian@brianlarsenlaw.com joseph@brianlarsenlaw.com marven@brianlarsenlaw.com ATTORNEYS FOR Plaintiff ANGELA STARKS Dennis J. Herrera,City Attorney Meredith B. Osborn, Chief Trial Deputy Sabrina M. Berdux, Deputy City Attorney Fox Plaza 1390 Market Street, Sixth Floor San Francisco, CA 94102-5408 Tel: (415) 554-3929 - Fax: (415) 554-3837 sabrina.m.berdux@sfcityatty.org ATTORNEYS FOR Defendant CITY AND COUNTY OF SAN FRANCISCO