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  • Ana M Bravo Campos et al. vs Jim Ressler Trucking, Inc. et al. Unlimited Civil Auto Tort document preview
  • Ana M Bravo Campos et al. vs Jim Ressler Trucking, Inc. et al. Unlimited Civil Auto Tort document preview
  • Ana M Bravo Campos et al. vs Jim Ressler Trucking, Inc. et al. Unlimited Civil Auto Tort document preview
  • Ana M Bravo Campos et al. vs Jim Ressler Trucking, Inc. et al. Unlimited Civil Auto Tort document preview
  • Ana M Bravo Campos et al. vs Jim Ressler Trucking, Inc. et al. Unlimited Civil Auto Tort document preview
  • Ana M Bravo Campos et al. vs Jim Ressler Trucking, Inc. et al. Unlimited Civil Auto Tort document preview
  • Ana M Bravo Campos et al. vs Jim Ressler Trucking, Inc. et al. Unlimited Civil Auto Tort document preview
  • Ana M Bravo Campos et al. vs Jim Ressler Trucking, Inc. et al. Unlimited Civil Auto Tort document preview
						
                                

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CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Mark Saakian, Esq. 315902 Electronically Filed Stratman, Schwartz & Williams-Abrego Superior Court of California PO Box 258829 County of San Joaquin Oklahoma City, OK 73125-8829 2021-06-16 15:32:33 TELEPHONE NO.: (916) 503-2755 FAX NO. (Optional): (916) 503-2769 Clerk: Taylor Hiedeman mark.saakian@farmersinsurance.com E-MAIL ADDRESS (Optional): Cross-Defendants, Ana M. Bravo Campos, Julio Miranda ATTORNEY FOR (Name): Sr. and Marco Antonio Sanchez SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN STREET ADDRESS: 180 E. Weber Ave. MAILING ADDRESS: 180 E. Weber Ave. CITY AND ZIP CODE:Stockton, CA 95202 BRANCH NAME: PLAINTIFF/PETITIONER: Ana M. Bravo Campos, et al. DEFENDANT/RESPONDENT: Jim Ressler Trucking, Inc., et al. CASE MANAGEMENT STATEMENT CASE NUMBER: STK-CV-UAT-2020-0009433 (Check one): UNLIMITED CASE LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: June 29, 2021 Time: 8:45AM Dept.: 10D Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Mark Saakian INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): Ana M. Bravo Campos, Julio Miranda Sr. and Marco Antonio Sanchez b. 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): b. 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 served, or 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 not): (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 the date by which they may be served): 4. Description of case a. Type of case in complaint cross-complaint (Describe, including causes of action): Motor vehicle accident. Plaintiff Ana Bravo Campos and Julio Miranda Sr. and Marco Antonio Sanchez are brought in on a cross-complaint. CM-110 [Rev. July 1, 2011] Page 1 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Ana M. Bravo Campos, et al. CASE NUMBER: STK-CV-UAT-2020-0009433 DEFENDANT/RESPONDENT: Jim Ressler Trucking, Inc., et al. 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 future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) The case stems from a collision between a truck/trailer and a sedan. Plaintiffs allege personal injuries that lead to general and special damages. Discovery is underway. (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 a non-jury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. 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 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): Trials – 8/30/21; 9/20/21; 10/25/20; 11/4/21; 11/15/21; 12/13/21; 1/10/22; 1/24/22; 2/28/22; 3/14/22; 5/2/22; 5/16/22; 6/6/22; 6/27/22; 10/11/22; 1/23/23 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 5-7 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: e. Fax number: f. 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; 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 has reviewed ADR options with the client. (2) For self-represented parties: Party has 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) CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER:Ana M. Bravo Campos, et al. CASE NUMBER: STK-CV-UAT-2020-0009433 DEFENDANT/RESPONDENT: Jim Ressler Trucking, Inc., et al. 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 If the party or parties completing this form in the case have agreed form are willing to participate in the to participate in or have already completed an ADR process or following ADR processes (check all processes, indicate the stat us of the processes (attach a copy of that apply): the parties’ ADR stipulation) Mediation session not yet scheduled Mediation session scheduled for (date): August 16, 2021 (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): Conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral Evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (date): (6) Other (specify) Agreed to complete ADR session by (date): ADR session completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Ana M. Bravo Campos, et al. CASE NUMBER: STK-CV-UAT-2020-0009433 DEFENDANT/RESPONDENT: Jim Ressler Trucking, Inc., et al. 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): Farmers Specialty Insurance Company b. Reservation of rights: Yes 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 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 14a. b. A motion to consolidate coordinate wiII 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 of action (specify 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, 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 all anticipated discovery): Party Description Date Defendant(s) Written Discovery to Plaintiff August 2021 Defendant(s) Deposition of Plaintiffs Completed Defendant(s) Subpoena of Medical and other records Tbd Defendant(s) Medical Examination of Plaintiff (IME) Per Code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Ana M. Bravo Campos, et al. CASE NUMBER: STK-CV-UAT-2020-0009433 DEFENDANT/RESPONDENT: Jim Ressler Trucking, Inc., et al. 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 Code of Civil Procedure sections 90 through 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, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues 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. 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 ADR, 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: June 14, 2021 Mark Saakian (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. July 1, 2011] Page 5 of 5 CASE MANAGEMENT STATEMENT 1 Re: Ana M. Bravo Campos, et al. v. Jim Ressler Trucking, Inc., et al. Case Number: STK-CV-UAT-2020-0009433 2 3 PROOF OF SERVICE Code of Civil Procedure §§ 1013a, 2015.5 4 I am a resident of the State of California and over the age of eighteen years, and not a party to the 5 within action. My business address is PO Box 258829, Oklahoma City, OK 73125-8829. On June 14, 2021, I served the following document(s): 6 7 CASE MANAGEMENT STATEMENT By placing the document(s) listed above in a sealed envelope, addressed as set forth 8 below, with postage fully prepaid, and placing the envelope for collection and mailing 9 by the U.S. Postal Service on the same day following the firm’s ordinary business practices of which I am readily familiar. I am aware that on motion of the party 10 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. 11 By causing a true copy thereof to be personally delivered to the person(s) at the 12 address(es) set forth below. 13 By electronically serving the document(s) described above via a Court approved File 14 & Serve vendor on those recipients designated on the Transaction Receipt located on the vendor’s Website. 15 By electronically serving the document(s) to the electronic mail address set forth 16 below on this date before 11:59:59 p.m. pursuant to and consistent with Code of Civil 17 Procedure §§1010.6(a)(2), (4), (5) and 1010.6(e) from email address X brenda.perezrangel@farmersinsurance.com. 18 19 I declare under penalty of perjury under the laws of the State of California that the above is true 20 and correct. 21 Executed on June 14, 2021, at Rancho Cordova, California. 22 23 24 BRENDA PEREZ-RANGEL 25 26 27 28 1 Re: Ana M. Bravo Campos, et al. v. Jim Ressler Trucking, Inc., et al. Case Number: STK-CV-UAT-2020-0009433 2 SERVICE LIST 3 Kevin Danesh, Esq. 4 Banafsheh, Danesh & Javid, APLC 9454 Wilshire Blvd, #830 5 Beverly Hills, CA 90212-2930 Attorney for Plaintiffs, Ana M. Bravo Campos, an individual; Graciela Campos de Bravo, an individual; 6 Julio Miranda Bravo and Mizael Raul Miranda Bravo, both minors, by and through their Guardian Ad Litem, Ana M. Bravo Campos 7 Phone: (310) 887-1818 Fax: (310) 887-1880 8 tq@bhattorneys.com; kd@bhattorneys.com 9 John S. Williamson, Esq. Williamson Law Group 10 1851 E. First Street, Suite 1225 Santa Ana, CA 92705 11 Attorney for Defendant/Cross-Complainant, Jim Ressler Trucking, Inc. Phone: (657) 229-7400 12 Fax: (657) 229-7444 jwilliamson@williamsonlawgroup.net 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28