`
`CM-110
`
`ELECTRONICALLY
`F I L E D
`
`Superior Court of California,
`County of San Francisco
`07/29/2024
`Clerk of the Court
`BY: JEFFREY FLORES
`Deputy Clerk
`
`CASE NUMBER:
`CGC-23-608087
`
`Div.: Civil
`
`Room:
`
`ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
`Thomas S. Gelini (SBN: 154314) Mark P. Edson(SBN 213081)
`Bennett, Gelini & Gelini, APC
`1301 Marina Village Parkway, Suite 300
`Alameda, CA 94501-1084
`FAX NO. (Optional): 510-444-5849
`TELEPHONE NO.: 510-444-7688
`E-MAIL ADDRESS: tgelini@bsralaw.com; medson@bsralaw.com
`ATTORNEY FOR (Name): Defendants Gary F. Grossman, et al.
`SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
`STREET ADDRESS: 400 McAllister St.
`MAILING ADDRESS:
`CITY AND ZIP CODE: San Francisco, 94102
`BRANCH NAME: Civic Center Courthouse
`PLAINTIFF/PETITIONER: Kassandra Gomez, et al.
`DEFENDANT/RESPONDENT: Gary F. Grossman, et al.
` CASE MANAGEMENT STATEMENT
` UNLIMITED CASE
` LIMITED CASE
`(Check one):
`(Amount demanded
`(Amount demanded is $25,000
`exceeds $25,000)
`or less)
`A CASE MANAGEMENT CONFERENCE is scheduled as follows:
`Date: August 14, 2024
`Time: 10:30 AM
`Dept.: 610
`Address of court (if different from the address above):
`
` Notice of Intent to Appear by Telephone, by (name): Mark P. Edson
`INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
`1. Party or parties (answer one):
` This statement is submitted by party (name): See Attached MC-025 Form
`a.
` This statement is submitted jointly by parties (names):
`b.
`2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
`a. The complaint was filed on (date):
` The cross-complaint, if any, was filed on (date): November 13, 2023
`b.
`3. Service (to be answered by plaintiffs and cross-complainants only)
` All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
`a.
` The following parties named in the complaint or cross-complaint
`b.
` have not been served (specify names and explain why not):
`(1)
`Not located for service yet.
` have been served but have not appeared and have not been dismissed (specify names):
`
` have had a default entered against them (specify names):
`
`4. Description of case
` cross-complaint
` complaint
`a. Type of case in
`Third party criminal action caused the injuries.
`
`
`(2)
`
`(3)
`
`(Describe, including causes of action): Personal Injury,
`
`Form Adopted for Mandatory Use
`Judicial Council of California
`CM-110 [Rev. September 1, 2021]
`
`
`CASE MANAGEMENT STATEMENT
`
`Page 1 of 5
`Cal. Rules of Court,
`rules 3.720–3.730
`www.courts.ca.gov
`
`
`
`
`CM-110
`
` a jury triaI
`
` a nonjury trial.
`
`(If more than one party, provide the name of each party
`
`PLAINTIFF/PETITIONER: Kassandra Gomez, et al
`CASE NUMBER:
`CGC-23-608087
`DEFENDANT/RESPONDENT: Gary F. Grossman, 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.)
`Plaintiffs allege personal injuries arising on premises at 314 11th Street, San Francisco, CA, 94103. Liability is
`disputed. Defendants deny knowledge of any prior criminal events at subject property.
` (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
`requesting a jury trial):
`
`6. Trial date
` The trial has been set for (date):
`a.
` 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
`b.
`not, explain):
`
`c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
`See attached
`7. Estimated length of trial
`The party or parties estimate that the trial will take (check one):
` days (specify number): 15-20
`a.
` hours (short causes) (specify):
`b.
`8. Trial representation (to be answered for each party)
`The party or parties will be represented at trial
`a. Attorney:
`b. Firm:
`c. Address:
`d. Telephone number:
`e. E-mail address:
` 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 of the California Rules of Court for information about the
`processes available through the court and community programs in this case.
` has
` has not
`provided the ADR information package
`(1) For parties represented by counsel: Counsel
`identified in rule 3.221 to the client and reviewed ADR options with the client.
` has
` has not reviewed the ADR information package identified in rule 3.221.
`(2) For self-represented parties: Party
`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.
` 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.
` 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):
`
`
` by the attorney or party listed in the caption
`
` by the following:
`
`f. Fax number:
`g. Party represented:
`
`(2)
`
`(3)
`
`CM-110 [Rev. September 1, 2021]
`
`CASE MANAGEMENT STATEMENT
`
`Page 2 of 5
`
`
`
`PLAINTIFF/PETITIONER: Kassandra Gomez, et al
`DEFENDANT/RESPONDENT: Gary F. Grossman, et al.
`
`CASE NUMBER:
`CGC-23-608087
`
`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, or
`have already participated in (check all that apply and provide the specified information):
`
`
`
`
`
`(1) Mediation
`
`(2) Settlement
`conference
`
`(3) Neutral evaluation
`
`(4) Nonbinding judicial
`arbitration
`
`(5) Binding private
`arbitration
`
`(6) Other (specify):
`
`
`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):
` Mediation session not yet scheduled
` Mediation session scheduled for (date):
` Agreed to complete mediation by (date):
` Mediation completed on (date):
` Settlement conference not yet scheduled
` Settlement conference scheduled for (date):
` Agreed to complete settlement conference by (date):
` Settlement conference completed on (date):
` Neutral evaluation not yet scheduled
` Neutral evaluation scheduled for (date):
` Agreed to complete neutral evaluation by (date):
` Neutral evaluation completed on (date):
`
` Judicial arbitration not yet scheduled
` Judicial arbitration scheduled for (date):
` Agreed to complete judicial arbitration by (date):
` Judicial arbitration completed on (date):
`
` Private arbitration not yet scheduled
` Private arbitration scheduled for (date):
` Agreed to complete private arbitration by (date):
` Private arbitration completed on (date):
`
` ADR session not yet scheduled
` ADR session scheduled for (date):
` Agreed to complete ADR session by (date):
` ADR completed on (date):
`
`CM-110 [Rev. September 1, 2021]
`
`CASE MANAGEMENT STATEMENT
`
`Page 3 of 5
`
`
`
`CM-110
`
`PLAINTIFF/PETITIONER: Kassandra Gomez, et al
`DEFENDANT/RESPONDENT: Gary F. Grossman, et al.
`
`CASE NUMBER:
`CGC-23-608087
`
`11. Insurance
`Insurance carrier, if any, for party filing this statement (name): AmeriTrust Group, Inc.
`
`
`a.
` Yes
` No
`b. Reservation of rights:
` Coverage issues will significantly affect resolution of this case (explain):
`c.
`
`
`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
` There are companion, underlying, or related cases.
`a.
`(1) Name of case:
`(2) Name of court:
`(3) Case number:
`(4) Status:
` Additional cases are described in Attachment 13a.
` A motion to
`
`consolidate
` coordinate
`
`b.
`
`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):
`Standard pre-trial motions and motions in limine
`
`16. Discovery
` The party or parties have completed all discovery.
`a.
`
`The following discovery will be completed by the date specified (describe all anticipated discovery):
`b.
`Party
`Description
`Date
`Defendants
`Written Discovery
`Ongoing
`Defendants
`Depositions
`To be set
`Defendants
`Expert
`Per code
`
`
`
`
`c.
`
` The following discovery issues, including issues regarding the discovery of electronically stored information, are
`anticipated (specify):
`
`
`CM-110 [Rev. September 1, 2021]
`
`CASE MANAGEMENT STATEMENT
`
`Page 4 of 5
`
`
`
`PLAINTIFF/PETITIONER: Kassandra Gomez, et al
`DEFENDANT/RESPONDENT: Gary F. Grossman, et al.
`
`CASE NUMBER:
`CGC-23-608087
`
`CM-110
`
`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 90-98 will apply to this case.
`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):
`
`b.
`
`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):
`Parties anticipate completing initial discovery and proceeding to informal resolution or Mediation
`
`20. Total number of pages attached (if any): 1
`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 at the time of
`the case management conference, including the written authority of the party where required.
`Date: July 29, 2024
`
` Thomas S. Gelini
`(TYPE OR PRINT NAME)
`
`(TYPE OR PRINT NAME)
`
`►
`►
`
`(SIGNATURE OF PARTY OR ATTORNEY)
`
`(SIGNATURE OF PARTY OR ATTORNEY)
` Additional signatures are attached.
`
`CM-110 [Rev. September 1, 2021]
`
`CASE MANAGEMENT STATEMENT
`
`Page 5 of 5
`
`
`
`SHORT TITLE:
`Gomez v Grossman, et al.
`
`MC-025
`
`CASE NUMBER:
`
`CGC-23-608087
`
`ATTACHMENT (Number):
`
`1
`
`(This Attachment may be used with any Judicial Council form.)
`
`(If the item that this Attachment concerns is made under penalty of perjury, all statements in this
`Attachment are made under penalty of perjury.)
`
`Form Approved for Optional Use
`Judicial Council of California
`MC-025 [Rev. July 1, 2009]
`
`ATTACHMENT
`to Judicial Council Form
`
`Page
`
`1
`
`of
`
`1
`
`(Add pages as required)
`www.courtinfo.ca.gov
`
`
`
`TRIAL DATES
`Updated: 7/27/2024
`
`Case Name
`Date
`9/9/2024 Angel v. Bluewater Property Investments, et al
`9/16/2024 Khatri v West Valley Ventures, et al
`9/20/2024 Kaur v Mosleh
`10/21/2024 Zurich v. Automotion
`10/21/2024 Lopez v. City of Alameda
`11/4/2024 Washington, et al. v Raj Properties
`11/4/2024 West v Levine
`11/12/2024 Sorensen v Asher, et al
`11/18/2024 Joch v Sethi
`12/2/2024 Cashion v. Schreier
`12/16/2024 Vidrio, et al. v. Woo, et al.
`1/6/2025
`In Re: Davis Street Community Center
`1/6/2025 Cardona v. 14735 Blythe Street LLC
`1/6/2025 Silk v 780 Guerrero, et al
`1/13/2025 Evans v Cannizzaro
`1/13/2025 Allen v Micciche, et al
`1/21/2025 Lopez v. Big Bear Cool Cabins
`1/21/2025 Eifler v. Carollo
`1/21/2025 Battaglia v City of Alameda
`1/27/2025 Grade v Coast Property
`1/31/2025 Gonzalez v. Verona Court Venture, LLC, et al.
`2/11/2025 Daniel v. Charles & Cynthia Eberly Inc., et al
`2/18/2025 Elrod v 974 Gramercy
`2/18/2025 Wang v. McVeigh
`2/24/2025 Robinson v. Chinatown
`3/10/2025 Mason v International City Property Mgmt, et al
`3/17/2025 Sepulveda v International City Property Mgmt
`3/24/2025 Roth v. Fong
`4/7/2025 Belloso Jr. v. PBM 2, LLC
`4/14/2025 Newell v. Langton Lofts
`4/15/2025 Diaz v. Westley Truck Stop
`4/28/2025 Chan, Gerald v City of Alameda, et al.
`5/6/2025 Carranza et al vs Laurel Tower
`5/19/2025 Chiagoroh v. C. Cournale & Co., Inc.
`5/30/2025 Gomez Mas v The Lapham Co
`6/2/2025 Ajaebo v Infinite Glow, LLC
`6/9/2025
`Fauria v. Liz Leon A Work
`6/10/2025 Uribe v. Belfort Mangement, Inc.
`6/17/2025 Salas v Hoa Tea
`6/30/2025 Bonney v 1810 Jackson St.
`7/14/2025 Sanchez v. H&M Trucking (Sanchez v Juarez)
`7/21/2025 Hutson v. 1701-1703 36th Avenue
`9/29/2025 Low v City of Fresno
`11/3/2025 Saavedra v. 12th & 13th Webster LLC, et al
`12/3/2025 Sidlo v Southland
`1/27/2026 Louis v. GLPP, Living Trust
`
`County
`Los Angeles
`San Mateo
`Alameda
`Orange
`Alameda
`Alameda
`Los Angeles
`Placer
`Los Angeles
`San Francisco
`Los Angeles
`ALJ
`Los Angeles
`San Francisco
`San Francisco
`San Joaquin
`Los Angeles
`Sacramento
`Alameda
`Los Angeles
`Los Angeles
`Los Angeles
`Los Angeles
`San Francisco
`San Francisco
`Los Angeles
`Los Angeles
`San Joaquin
`Los Angeles
`San Francisco
`Stanislaus
`Alameda
`Los Angeles
`San Francisco
`Alameda
`Alameda
`Los Angeles
`Sacramento
`Stanislaus
`San Francisco
`Fresno
`Alameda
`Fresno
`Alameda
`Los Angeles
`Sacramento
`
`Case Number
`21STCV34336
`21-CIV-00764
`22CV022897
`2022-01251875
`22CV011895
`22CV006948
`22STCV12807
`S-CV-0049847
`20STCV22402
`CGC-21-595028
`23STCV18261
`CSPP8028
`21STCV24996
`CGC-23-610786
`CGC-22-601877
`STK-CV-UNPI-2021-0009485
`21STCV15465
`2022-00324813
`23CV033380
`23SMCV03148
`23STCV18473
`20STCV08595
`22STCV34192
`CGC-22-598517
`CGC-22597463
`23STCV16901
`23STCV18823
`2022-0007516
`23BBCV01201
`CGC-23-608002
`CV-23-001516
`23CV025218
`23STCV20474
`CGC-23-609461
`23CV041788
`23CV051235
`23CHCV00600
`34-2022-00318922
`CV-23-000927
`CGC-23-609401
`20CECG03504
`22CV014867
`24CECG00584
`23CV049535
`21STCV40496
`23CV003261
`
`
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`PROOF OF SERVICE
`I am a resident of the State of California, over the age of eighteen years, and not a party
`to the within action. My business address is BENNETT, GELINI & GELINI, APC, 1301 Marina
`Village Parkway, Suite 300, Alameda, California 94501.
`On July 29, 2024, I served the following document(s) by the method indicated below:
`
`CASE MANAGEMENT STATEMENT
`
`☐ BY MAIL - by placing the document(s) listed above in a sealed envelope with postage
`thereon fully prepaid, in the United States mail at Alameda, California addressed as set forth
`below:
`
`☒ BY EMAIL - by electronically transmitting a true copy thereof via computer, addressed
`to the person(s) and email address(es) below:
`
`EMAIL ONLY
`Jonathan Meislin
`Colin M. Jones
`Xena R. Mashburn
`Wilshire Law Firm, PLC
`3055 Wilshire Blvd, Fl 12
`Los Angeles, CA 90010-1176
`Ph: 213-381-9988
`
`jmeislin@wilshirelawfirm.com
`colinsteam@wilshirelawfirm.com
`eharwood@wilshirelawfirm.com
`
`Attorneys for Plaintiffs
`
`VIA MAIL ONLY
`Embattle Protective Services
`Paul Alvarez
`4735 Mission Street, Suite C,
`San Francisco, CA 94112
`
`In Pro Per Defendant
`Embattle Protective Services
`
`EMAIL ONLY
`Christopher P. Bates
`Jenn N. Crittondon
`Britney Lucchesi
`Kahana & Feld LLP
`475 14th Street, Suite 800
`Oakland, CA 94612
`Ph: 510-859-8017
`Fax: 949-246-7597
`
`cbates@kahanafeld.com
`jcrittondon@kahanafeld.com
`blucchesi@kahanafeld.com
`
`Attorneys for Defendants and Cross-
`Complainant 314 11th Street, LLC, a
`California limited liability company dba
`Halcyon SF and Defendant Gina Milano
`
`-6-
`CASE MANAGEMENT STATEMENT
`
`
`
`I declare under penalty of perjury under the laws of the State of California that the
`above is true and correct. Executed on July 29, 2024, at Alameda, California.
`
`___________________________________
`Kat Nguyen
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`-7-
`CASE MANAGEMENT STATEMENT
`
`



