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ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Nolan S. Armstrong/Ashley K. Ayad 241311/328727
McNamara, Ney, Beatty, Slattery, Borges & Ambacher
3480 Buskirk Avenue, Suite 250
Pleasant Hill, CA 94523
TetepHoneNo.: 925-939-5330 FAX NO.(Optiona): 925-939-0203 [ IL, =
CM-110
E-MAIL ADDRESS (Optionay: NOLan.armstrong@mcnamaralaw.com
ATTORNEY FOR (Name): Defs. Pemba Pemba, Dekyi Lhamo, Pasang Lama
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Contra Costa MAY 18 2020
streeTappress: 725 Court Street
« alrken ouati
MAILING ADDRESS: A
cirvanozipcovs: Martinez, CA 94553 . By.
BRANCH NAME: UNLIMITED JURISDICTION - CIVIL
PLAINTIFF/PETITIONER: SARAH PIERCE and STANIEL CRASS
DEFENDANT/RESPONDENT: PASANG LAMA, PEMBA PEMBA,
DEKYI LHAMO, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): [jj UNLIMITED CASE () Limitep case _ |MSC19-01988
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date) June 5, 2020 Time: 8:30 am Dept: 33 Div.: Room:
Address of court (if different from the address above):
[K) Notice of Intent to Appear by Telephone, by (name): AShley K. Ayad
INSTRUCTIONS: All applicable boxes must be checked, and ihe specified information must be provided.
4, Party or parties (answer one):
a. [&] This statement is submitted by party (name): Defs. Pemba Pemba, Dekyi Lhamo, Pasang Lama
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. [2] The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. (2) Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. (2) The following parties named in the complaint or cross-complaint
(1) (CQ) have not been served (specify names and explain why not):
(2) [L} have been served but have not appeared and have not been dismissed (specify names):
(3) [CQ 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 [XQ complaint (2) cross-complaint (Describe, including causes of action):
Landlord-tenant dispute.
Page'lof 5
Form Adopted for Mandatory U ‘AS ENT ENT Gal, Rules of Court
die Gouncl of Galfornia” = OE-[3"| Esgential CASE MANAGEMENT STATEM rules 7008790
‘CM-110 [Rev. July 1, 2011] cdc | EIForms www:courts.ca.gov
NSA4
PLAINTIFF/PETITIONER:SARAH PLERCE and STANIEL CRASS | case numer:
MSC19-01988
CM-110
DEFENDANT/RESPONDENT: PasaNG LAMA, PEMBA PEMBA, DEKYI LHAMO, 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.)
This landlord-tenant action arises from their tenancy at Defendants' property.
Plaintiffs allege habitability defects, wrongful eviction, and retaliation.
Plaintiffs stopped paying rent and moved out pursuant to a move-out agreement.
Defendants deny liability. Claimed damages are unknown.
(2) (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 [QQ ajurytrial [2] anonjury trial. (if more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. (Q] The trial has been set for (date):
b. [4] 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):
See attached Trial Calendar
7. Estimated length of trial
The party or parties estimate that the trial will take (otieck one):
a. [Z) days (specify number): 4-5
b. [CJ hours (short causes) (specify):
8. Trial representation (to be answered for each party) ,
The party or parties will be represented at trial [EQ] by the attorney or party listed in the caption [J by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
6. 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 processés available through the
court and community programs in this case.
(1) For parties represented by counsel: Course! Chas (has not provided the ADR information package identified:
in rule 3.221 tothe client and reviewed ADR options with the client.
(2) For self-represented parties: Party (CQhas (2) has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) [2] This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 orto civil action
mediation under of 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) (CQ 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):
GM-110 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT "Page 2 of 5
I Essential
GB i Forms: NSACM-110
PLAINTIFF/PETITIONER: SARAH
DEFENDANT/RESPONDENT: PASANG LAMA, PEMBA PEMBA, DEKYI LHAMO, et al.
ERCE and STANIEL CRASS | casenumecn:
MSC19-01988
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 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 to
participate in or have already completed.an ADR process or processes,
indicate the status of the processes (attach a copy of the parties' ADR
stipulation):
[42 Mediation session not yet scheduled
'L) Mediation session scheduled for (date):
(} Agreed to complete ADR session by (date):
(2) ADR completed on (date):
(1) Mediation Oo
[3 Agreed to complete mediation by (date):
[3 Mediation completed on (date):
[&} Settlement conference not yet scheduled |
! (2) Settlerient Q (_} Settlement conference scheduled for (date):
en [3 Agreed to complete settlement conference by (date):
[-} Settlement conference completed on (date): ~
oOo Neutra! evaluation not yet scheduled
(3) Neutral evaluation ° a {CJ Neutral evaluation scheduled for (date):
| [3 Agreed to complete neutral evaluation by (date):
(2) Neutra! evaluation completed on (date):
(2 Judicial arbitration not yet scheduled
| (4) Nonbinding judicial GC (CC) Judicial arbitration scheduled for (date):
arbitration a2 Agreed to complete judicial arbitration by (date):
(C) dudicial arbitration completed on (date):
(2) Private arbitration not yet scheduled
(8) Binding private oO (1 Private arbitration scheduled for (date):
arbitration [) Agreed to complete private arbitration by (date):
[(C) Private arbitration completed on (date):
(-] ADR session not yet scheduled
(6) Other (specify): oO (2) ADR session scheduled for (date):
(OM-110 [Rlev. July 4, 2011]
CEB’ | Essential
CI .
cebcom | }z/Forms:
CASE MANAGEMENT STATEMENT
Page 3 of 5'
PLAINTIFF/PETITIONER: SARAH ©. and STANIEL CRASS — |casenuwper:
MSC19-01988
DEFENDANT/RESPONDENT: PASANG LAMA, PEMBA PEMBA, DEKYI LHAMO, et al.
11. Insurance
a. [&X] Insurance carrier, if any, for party filing this statement (name): CSAA
b. Reservation of rights: [ql Yes [J 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.
(CD Bankrupicy _[(L] Other (specify):
Status:
13. Related cases, consolidation, and coordination ~
a. [2] There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(8) Case number:
(4) Status:
(2) Additional cases are described in Attachment 13a.
b. [Q} Amotionto [CO] consolidate [CJ coordinate will be filed by (name party):
14, Bifurcation : .
(2) 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
(2) The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. [C) The party or parties have completéd all discovery.
b. [X] The following discovery will be completed by the date specified (describe all.anticipated discovery):
Party. . Description Date
Defendants Written Discovery Summer 2020
Defendants Depositions Fall 2020/
. Winter 2020
Defendants Experts 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] CASE MANAGEMENT STATEMENT Page 4 0f 5
IB’ | Essential
GE Borne NSA_ CM-140
PLAINTIFFIPETITIONER: SARAH @.. and STANIEL CRASS -® L
MSC19-01988
DEFENDANT/RESPONDENT: PASANG LAMA, PEMBA PEMBA, DEKYI LHAMO, et al.
17. Economic litigation
a. O 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. [C)) 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 aiscovery or trial:
should not apply to this. case):
18. Other issues
[2] The party or parties request that the. following additional matters be considered or determined at ihe case management
conference (specify):
19. ae and confer
a. | The party or parties have met and conférred with all parties on all Subjects required vs tule: 3.724 of the California Rules of
Court (if not, explain):
b. After meeting-and conferringias required by rule 3.724 of the California Rules. of Court, the parties agree on the following
(specify): The parties have discussed the timeframe for settlement
Giscussions, whether informal or through mediation.
20. Total number of pages attached (ifany): —3.--_
1 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.
Date: May 15, 2020
. . seas kaya » Nalerrs
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
>
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) ~
(2 Additional signatures’ are attached.
GWeH10 Fe. diy 3, 2077 ‘CASE MANAGEMENT STATEMENT " Page sot
Cee IE Escorted
Forms”
NSANSA TRIAL, MEDIATION, ARBITRATION & SETTLEMENT/ISSUE CONFERENCE CALENDAR
May 2020
12 1:00_| Salvador y. Kortzeborn Mediation w/Nick Pastore (telephonically)
June 2020
3 9:300| Patrick v. Jiang Mediation w/Matt Conant via Zoolm
12 10:30] Myers y. Pool Mediation w/Ken Gack (JAMS) via Zoom
17 TBC | Koppelman y. Smith Mediation w/Vivien Williamson, 1939 Harrison St., #520 Oakland
19 10:00| McAdoo v. Wellington Property _| Pre-Trial Conference, Alameda, Dept. 24
25 10:00| Luo v. Tom Mediation w/Vivien Williamson, 1939 Harrison St., #520 Oakland
29 8:30_| Kostik y. Ruiz Trial, Alameda, Dept. 517
29 9:30_| McAdoo v. Wellington Property | Trial, Alameda, Dept. 24
29 10:00 | Hayhurst v. Bullis MSC, Nevada, Dept. 6
30 10:00| Ashley v. Prenter Mediation w/Matt Conant 1101 Fifth Ave., #100, San Rafael, CA
July 2020
1 9:00 | Paster v. Handy MSC, Alameda, Dept. 303
1 10:00| Escareno v. Yamamoto MSC, Fresno, Dept. 575
7 9:00 | Smith vy. Small MSC, Alameda, Dept. 303
10 11:00| Hayhurst v. Bullis Pre-Trial Conference, Nevada, Dept. 6
13 9:30 | Boudreaux v. Hwe Trial, SF, Dept. 206
20 10:00| Borges v. Siu Mediation w/Vivien Williamson, 1939 Harrison St., #520 Oakland
21 9:00 | Hayhurst v. Bullis Trial, Nevada, Dept. 6
24 9:30 | Escareno vy. Yamamoto Trial Readiness Conference, Fresno, Dept. 502
27 9:00_| Escareno vy. Yamamoto Trial, Fresno, Dept. 502
27 9:30 | Willilams v. USAA Arbitration, w/Stephen Harper, 9 Las Aromas, Orinda CA
August 2020
7 8:30 | Paster v. Handy Pre-Trial Conference, Alameda, Dept. 517
10 9:30_| Kavanaugh v. Masterson Trial, SF, Dept. 206
1 9:30_| City of Oakland y. Chere) MSC, Alameda, Dept. 301
14 8:30 _| Smith vy. Small i Pre-Trial Conference, Alameda, Dept. 22
17 8:30 _| Paster v. Handy Trial, Alameda, Dept. 517
7 9:00_| Breckenridge v. Fujioka MSC, Marin, Dept. B
18 9:00 _| State Farm vy. Berger MSC, Alameda, Dept. 303
24 9:00 | Smith v. Small Trial, Alameda, Dept. 22
24 9:00_| State Farm v. Stein (Murphy) MSC, Alameda, Dept. 303
_ September 2020
3 9:00 | Taylor v. Ayankoya MSC, Alameda, Dept. 301
4 10:00| City of Oakland vy. Cherepy Trial, Alameda, Dept. 520
i 9:00 _| Breckenridge v. Fujioka Issue Conference, Marin, Dept. B
14 9:30 _| Garcia y. Lau Trial, SF, Dept. 206
15 9:00 _| Breckenridge v. Fujioka | Trial, Marin, Dept. B
18 8:30_| State Farm v. Berger Pre-Trial Conference, Alameda, Dept.'517
21 9:30_| Lamb y. Badillo | Trial, SF, Dept. 206.
22 8:30_| State Farm v. Stein (Murphy) Trial, Alameda, Dept. 22
28 8:30_| State Farm v. Berger Trial, Alameda, Dept. 517
October 2020
2 8:30_| Taylor v. Ayankoya PTC/CMC, Alameda, Dept. 22
6 00_| Aiken y. Coletta (settled) Issue Conference, CCC, Dept. 33
8 4:00_| Morris v. Senestraro MSC, Humboldt SC Dept- 4
13 8:00 _| Taylor v. Ayankoya Trial, Alameda, Dept. 22
19 9:00 | Aiken v. Coletta (settled) Trial, CCC, Dept. 33
26 9:30 _| Tancinco v. Bantican Trial, SESC — Dept. 206
30 NSA VACATIONNovember 2020
2-6 NSA VACATION
9 |. 9:00 | Kaul vy. Vaca MSC, Alameda, Dept. 302
16 9:30_| State Farm y. McLendon MSC, Alameda, Dept. 301
18 8:30 | State Farm v. McLendon CMC/PTC, Alameda, Dept. 514
20 9:00. | Kaul v. Vaca Pre-Trial Conference, Alameda, Dept. 25
20 1:45 _| Morris v. Senestraro TRC, Humboldt SC Dept- 4
30 8:30_| Morris v. Senestraro Trial, Humboldt SC Dept- 4
' December 2020
7 9:30 | Kaul y. Vaca Trial, Alameda, Dept. 25
21-31 NSA VACATION
January 2021
1-8 NSA VACATION
5 9:00 | Patrick v. Jiang MSC, Alameda, Dept. 301
7 9;30_| Kastning v. Weilmuenster Pre-Trial SC, Alameda, Dept. 301
8 9:00 _| Landers v. Sanders MSC, Alameda, Dept. 301
15 9:00 | Landers y. Sanders Pre-Trial Conference, Alameda, Dept. 25
15 9:00_| State Farm vy. McLendon Trial, Alameda, Dept. 514
25 9:30 | Landers v. Sanders | Trial, Alameda, Dept. 25 _
29 8:30_| Kastning v. Weilmuenster Pre-Trial Conf./CMC, Alameda, Dept. 22
February 2021
5 1:30_| Patrick v. Jiang Pre-Trial Conference, Alameda, Dept. 517
8 8:30_| Kastning v. Weilmuenster Trial, Alameda, Dept.22
22 8:30_| Patrick v. Jiang Trial, Alameda, Dept. 517
March 2021
1 2:30_| Chord v. Smith MSC, Kings SC - Dept. 7
April 2021
9 1:30_| Chord v. Smith Hearing MILs ~ Kings SC — Dept. 7
12 9:30_| Chord vy. Smith Trial, Kings SC - Dept. 7
May 2021
26 9:30_| Kavanaugh v. Masterson (Tentative) Trial, SF, Dept. 206
June 2021July 2021
26 9:30
Kavanaugh v. Masterson
(Tentative) Trial, SF, Dept. 206
Updated: 5/15/2020, e ®
CERTIFICATE OF SERVICE VIA ELECTRONIC TRANSMISSION
m
Thereby declare that I am a citizen of the United States, am over the age of eighteen years,
and not a party to the within action. My electronic notification address is:
carol.oneil@mcnamaralaw.com.
On this date, I electronically served the foregoing CASE MANAGEMENT
STATEMENT only by e-mailing the document(s) to the persons at the e-mail address(es) listed
based on notice provided on April 20, 2020, that during the Coronavirus (Covid-19) pandemic, this
office will be working remotely, not able to send physical mail as usual, and is therefore using only
oe arn nun & BW WV
electronic mail. No electronic message or other indication that the transmission was unsuccessful
eB
°
was received within a reasonable time after the transmission.
m
Attorneys For Plaintiffs Sarah Pierce and
Staniel Crass:
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Andrew Wolff, Esq.
Law Offices of Andrew Wolff, P.C.
1615 Broadway, 4th Floor
Oakland, CA 94612
BoP
BOG
Phone: 510-834-3300
Fax: 510-834-3377
E-Mail: andrew @awolfflaw.com
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ATTORNEYS AT LAW
3480 BUSKIRK AVENUE, SUITE 250, PLEASANT HILL, CA 94523
TELEPHONE: (925) 939-5330
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Wn
rPoR
co ~
I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct and that this declaration was executed on May 15, 2020 at Pleasant Hill, |
Do
oOo .
California.
McNAMARA, NEY, BEATTY, SLATTERY, BORGES & AMBACHER LLP
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Carol L. N. O'Neil
yn NY YY NY WKY N
eo IA A KF
Preview
. oo oo de a3 e @ ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Nolan S. Armstrong/Ashley K. Ayad 241311/328727 McNamara, Ney, Beatty, Slattery, Borges & Ambacher 3480 Buskirk Avenue, Suite 250 Pleasant Hill, CA 94523 TetepHoneNo.: 925-939-5330 FAX NO.(Optiona): 925-939-0203 [ IL, = CM-110 E-MAIL ADDRESS (Optionay: NOLan.armstrong@mcnamaralaw.com ATTORNEY FOR (Name): Defs. Pemba Pemba, Dekyi Lhamo, Pasang Lama SUPERIOR COURT OF CALIFORNIA, COUNTY OF Contra Costa MAY 18 2020 streeTappress: 725 Court Street « alrken ouati MAILING ADDRESS: A cirvanozipcovs: Martinez, CA 94553 . By. BRANCH NAME: UNLIMITED JURISDICTION - CIVIL PLAINTIFF/PETITIONER: SARAH PIERCE and STANIEL CRASS DEFENDANT/RESPONDENT: PASANG LAMA, PEMBA PEMBA, DEKYI LHAMO, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): [jj UNLIMITED CASE () Limitep case _ |MSC19-01988 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date) June 5, 2020 Time: 8:30 am Dept: 33 Div.: Room: Address of court (if different from the address above): [K) Notice of Intent to Appear by Telephone, by (name): AShley K. Ayad INSTRUCTIONS: All applicable boxes must be checked, and ihe specified information must be provided. 4, Party or parties (answer one): a. [&] This statement is submitted by party (name): Defs. Pemba Pemba, Dekyi Lhamo, Pasang Lama 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. [2] The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. (2) Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. (2) The following parties named in the complaint or cross-complaint (1) (CQ) have not been served (specify names and explain why not): (2) [L} have been served but have not appeared and have not been dismissed (specify names): (3) [CQ 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 [XQ complaint (2) cross-complaint (Describe, including causes of action): Landlord-tenant dispute. Page'lof 5 Form Adopted for Mandatory U ‘AS ENT ENT Gal, Rules of Court die Gouncl of Galfornia” = OE-[3"| Esgential CASE MANAGEMENT STATEM rules 7008790 ‘CM-110 [Rev. July 1, 2011] cdc | EIForms www:courts.ca.gov NSA4 PLAINTIFF/PETITIONER:SARAH PLERCE and STANIEL CRASS | case numer: MSC19-01988 CM-110 DEFENDANT/RESPONDENT: PasaNG LAMA, PEMBA PEMBA, DEKYI LHAMO, 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.) This landlord-tenant action arises from their tenancy at Defendants' property. Plaintiffs allege habitability defects, wrongful eviction, and retaliation. Plaintiffs stopped paying rent and moved out pursuant to a move-out agreement. Defendants deny liability. Claimed damages are unknown. (2) (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 [QQ ajurytrial [2] anonjury trial. (if more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. (Q] The trial has been set for (date): b. [4] 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): See attached Trial Calendar 7. Estimated length of trial The party or parties estimate that the trial will take (otieck one): a. [Z) days (specify number): 4-5 b. [CJ hours (short causes) (specify): 8. Trial representation (to be answered for each party) , The party or parties will be represented at trial [EQ] by the attorney or party listed in the caption [J by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: 6. 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 processés available through the court and community programs in this case. (1) For parties represented by counsel: Course! Chas (has not provided the ADR information package identified: in rule 3.221 tothe client and reviewed ADR options with the client. (2) For self-represented parties: Party (CQhas (2) has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) [2] This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 orto civil action mediation under of 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) (CQ 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): GM-110 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT "Page 2 of 5 I Essential GB i Forms: NSACM-110 PLAINTIFF/PETITIONER: SARAH DEFENDANT/RESPONDENT: PASANG LAMA, PEMBA PEMBA, DEKYI LHAMO, et al. ERCE and STANIEL CRASS | casenumecn: MSC19-01988 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 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 to participate in or have already completed.an ADR process or processes, indicate the status of the processes (attach a copy of the parties' ADR stipulation): [42 Mediation session not yet scheduled 'L) Mediation session scheduled for (date): (} Agreed to complete ADR session by (date): (2) ADR completed on (date): (1) Mediation Oo [3 Agreed to complete mediation by (date): [3 Mediation completed on (date): [&} Settlement conference not yet scheduled | ! (2) Settlerient Q (_} Settlement conference scheduled for (date): en [3 Agreed to complete settlement conference by (date): [-} Settlement conference completed on (date): ~ oOo Neutra! evaluation not yet scheduled (3) Neutral evaluation ° a {CJ Neutral evaluation scheduled for (date): | [3 Agreed to complete neutral evaluation by (date): (2) Neutra! evaluation completed on (date): (2 Judicial arbitration not yet scheduled | (4) Nonbinding judicial GC (CC) Judicial arbitration scheduled for (date): arbitration a2 Agreed to complete judicial arbitration by (date): (C) dudicial arbitration completed on (date): (2) Private arbitration not yet scheduled (8) Binding private oO (1 Private arbitration scheduled for (date): arbitration [) Agreed to complete private arbitration by (date): [(C) Private arbitration completed on (date): (-] ADR session not yet scheduled (6) Other (specify): oO (2) ADR session scheduled for (date): (OM-110 [Rlev. July 4, 2011] CEB’ | Essential CI . cebcom | }z/Forms: CASE MANAGEMENT STATEMENT Page 3 of 5' PLAINTIFF/PETITIONER: SARAH ©. and STANIEL CRASS — |casenuwper: MSC19-01988 DEFENDANT/RESPONDENT: PASANG LAMA, PEMBA PEMBA, DEKYI LHAMO, et al. 11. Insurance a. [&X] Insurance carrier, if any, for party filing this statement (name): CSAA b. Reservation of rights: [ql Yes [J 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. (CD Bankrupicy _[(L] Other (specify): Status: 13. Related cases, consolidation, and coordination ~ a. [2] There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (8) Case number: (4) Status: (2) Additional cases are described in Attachment 13a. b. [Q} Amotionto [CO] consolidate [CJ coordinate will be filed by (name party): 14, Bifurcation : . (2) 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 (2) The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. [C) The party or parties have completéd all discovery. b. [X] The following discovery will be completed by the date specified (describe all.anticipated discovery): Party. . Description Date Defendants Written Discovery Summer 2020 Defendants Depositions Fall 2020/ . Winter 2020 Defendants Experts 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] CASE MANAGEMENT STATEMENT Page 4 0f 5 IB’ | Essential GE Borne NSA_ CM-140 PLAINTIFFIPETITIONER: SARAH @.. and STANIEL CRASS -® L MSC19-01988 DEFENDANT/RESPONDENT: PASANG LAMA, PEMBA PEMBA, DEKYI LHAMO, et al. 17. Economic litigation a. O 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. [C)) 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 aiscovery or trial: should not apply to this. case): 18. Other issues [2] The party or parties request that the. following additional matters be considered or determined at ihe case management conference (specify): 19. ae and confer a. | The party or parties have met and conférred with all parties on all Subjects required vs tule: 3.724 of the California Rules of Court (if not, explain): b. After meeting-and conferringias required by rule 3.724 of the California Rules. of Court, the parties agree on the following (specify): The parties have discussed the timeframe for settlement Giscussions, whether informal or through mediation. 20. Total number of pages attached (ifany): —3.--_ 1 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. Date: May 15, 2020 . . seas kaya » Nalerrs (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) > (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) ~ (2 Additional signatures’ are attached. GWeH10 Fe. diy 3, 2077 ‘CASE MANAGEMENT STATEMENT " Page sot Cee IE Escorted Forms” NSANSA TRIAL, MEDIATION, ARBITRATION & SETTLEMENT/ISSUE CONFERENCE CALENDAR May 2020 12 1:00_| Salvador y. Kortzeborn Mediation w/Nick Pastore (telephonically) June 2020 3 9:300| Patrick v. Jiang Mediation w/Matt Conant via Zoolm 12 10:30] Myers y. Pool Mediation w/Ken Gack (JAMS) via Zoom 17 TBC | Koppelman y. Smith Mediation w/Vivien Williamson, 1939 Harrison St., #520 Oakland 19 10:00| McAdoo v. Wellington Property _| Pre-Trial Conference, Alameda, Dept. 24 25 10:00| Luo v. Tom Mediation w/Vivien Williamson, 1939 Harrison St., #520 Oakland 29 8:30_| Kostik y. Ruiz Trial, Alameda, Dept. 517 29 9:30_| McAdoo v. Wellington Property | Trial, Alameda, Dept. 24 29 10:00 | Hayhurst v. Bullis MSC, Nevada, Dept. 6 30 10:00| Ashley v. Prenter Mediation w/Matt Conant 1101 Fifth Ave., #100, San Rafael, CA July 2020 1 9:00 | Paster v. Handy MSC, Alameda, Dept. 303 1 10:00| Escareno v. Yamamoto MSC, Fresno, Dept. 575 7 9:00 | Smith vy. Small MSC, Alameda, Dept. 303 10 11:00| Hayhurst v. Bullis Pre-Trial Conference, Nevada, Dept. 6 13 9:30 | Boudreaux v. Hwe Trial, SF, Dept. 206 20 10:00| Borges v. Siu Mediation w/Vivien Williamson, 1939 Harrison St., #520 Oakland 21 9:00 | Hayhurst v. Bullis Trial, Nevada, Dept. 6 24 9:30 | Escareno vy. Yamamoto Trial Readiness Conference, Fresno, Dept. 502 27 9:00_| Escareno vy. Yamamoto Trial, Fresno, Dept. 502 27 9:30 | Willilams v. USAA Arbitration, w/Stephen Harper, 9 Las Aromas, Orinda CA August 2020 7 8:30 | Paster v. Handy Pre-Trial Conference, Alameda, Dept. 517 10 9:30_| Kavanaugh v. Masterson Trial, SF, Dept. 206 1 9:30_| City of Oakland y. Chere) MSC, Alameda, Dept. 301 14 8:30 _| Smith vy. Small i Pre-Trial Conference, Alameda, Dept. 22 17 8:30 _| Paster v. Handy Trial, Alameda, Dept. 517 7 9:00_| Breckenridge v. Fujioka MSC, Marin, Dept. B 18 9:00 _| State Farm vy. Berger MSC, Alameda, Dept. 303 24 9:00 | Smith v. Small Trial, Alameda, Dept. 22 24 9:00_| State Farm v. Stein (Murphy) MSC, Alameda, Dept. 303 _ September 2020 3 9:00 | Taylor v. Ayankoya MSC, Alameda, Dept. 301 4 10:00| City of Oakland vy. Cherepy Trial, Alameda, Dept. 520 i 9:00 _| Breckenridge v. Fujioka Issue Conference, Marin, Dept. B 14 9:30 _| Garcia y. Lau Trial, SF, Dept. 206 15 9:00 _| Breckenridge v. Fujioka | Trial, Marin, Dept. B 18 8:30_| State Farm v. Berger Pre-Trial Conference, Alameda, Dept.'517 21 9:30_| Lamb y. Badillo | Trial, SF, Dept. 206. 22 8:30_| State Farm v. Stein (Murphy) Trial, Alameda, Dept. 22 28 8:30_| State Farm v. Berger Trial, Alameda, Dept. 517 October 2020 2 8:30_| Taylor v. Ayankoya PTC/CMC, Alameda, Dept. 22 6 00_| Aiken y. Coletta (settled) Issue Conference, CCC, Dept. 33 8 4:00_| Morris v. Senestraro MSC, Humboldt SC Dept- 4 13 8:00 _| Taylor v. Ayankoya Trial, Alameda, Dept. 22 19 9:00 | Aiken v. Coletta (settled) Trial, CCC, Dept. 33 26 9:30 _| Tancinco v. Bantican Trial, SESC — Dept. 206 30 NSA VACATIONNovember 2020 2-6 NSA VACATION 9 |. 9:00 | Kaul vy. Vaca MSC, Alameda, Dept. 302 16 9:30_| State Farm y. McLendon MSC, Alameda, Dept. 301 18 8:30 | State Farm v. McLendon CMC/PTC, Alameda, Dept. 514 20 9:00. | Kaul v. Vaca Pre-Trial Conference, Alameda, Dept. 25 20 1:45 _| Morris v. Senestraro TRC, Humboldt SC Dept- 4 30 8:30_| Morris v. Senestraro Trial, Humboldt SC Dept- 4 ' December 2020 7 9:30 | Kaul y. Vaca Trial, Alameda, Dept. 25 21-31 NSA VACATION January 2021 1-8 NSA VACATION 5 9:00 | Patrick v. Jiang MSC, Alameda, Dept. 301 7 9;30_| Kastning v. Weilmuenster Pre-Trial SC, Alameda, Dept. 301 8 9:00 _| Landers v. Sanders MSC, Alameda, Dept. 301 15 9:00 | Landers y. Sanders Pre-Trial Conference, Alameda, Dept. 25 15 9:00_| State Farm vy. McLendon Trial, Alameda, Dept. 514 25 9:30 | Landers v. Sanders | Trial, Alameda, Dept. 25 _ 29 8:30_| Kastning v. Weilmuenster Pre-Trial Conf./CMC, Alameda, Dept. 22 February 2021 5 1:30_| Patrick v. Jiang Pre-Trial Conference, Alameda, Dept. 517 8 8:30_| Kastning v. Weilmuenster Trial, Alameda, Dept.22 22 8:30_| Patrick v. Jiang Trial, Alameda, Dept. 517 March 2021 1 2:30_| Chord v. Smith MSC, Kings SC - Dept. 7 April 2021 9 1:30_| Chord v. Smith Hearing MILs ~ Kings SC — Dept. 7 12 9:30_| Chord vy. Smith Trial, Kings SC - Dept. 7 May 2021 26 9:30_| Kavanaugh v. Masterson (Tentative) Trial, SF, Dept. 206 June 2021July 2021 26 9:30 Kavanaugh v. Masterson (Tentative) Trial, SF, Dept. 206 Updated: 5/15/2020, e ® CERTIFICATE OF SERVICE VIA ELECTRONIC TRANSMISSION m Thereby declare that I am a citizen of the United States, am over the age of eighteen years, and not a party to the within action. My electronic notification address is: carol.oneil@mcnamaralaw.com. On this date, I electronically served the foregoing CASE MANAGEMENT STATEMENT only by e-mailing the document(s) to the persons at the e-mail address(es) listed based on notice provided on April 20, 2020, that during the Coronavirus (Covid-19) pandemic, this office will be working remotely, not able to send physical mail as usual, and is therefore using only oe arn nun & BW WV electronic mail. No electronic message or other indication that the transmission was unsuccessful eB ° was received within a reasonable time after the transmission. m Attorneys For Plaintiffs Sarah Pierce and Staniel Crass: e wv Andrew Wolff, Esq. Law Offices of Andrew Wolff, P.C. 1615 Broadway, 4th Floor Oakland, CA 94612 BoP BOG Phone: 510-834-3300 Fax: 510-834-3377 E-Mail: andrew @awolfflaw.com = a ATTORNEYS AT LAW 3480 BUSKIRK AVENUE, SUITE 250, PLEASANT HILL, CA 94523 TELEPHONE: (925) 939-5330 _ Wn rPoR co ~ I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed on May 15, 2020 at Pleasant Hill, | Do oOo . California. McNAMARA, NEY, BEATTY, SLATTERY, BORGES & AMBACHER LLP wv N nN Carol L. N. O'Neil yn NY YY NY WKY N eo IA A KF