STATE BAR NUMBER:
`ATTORNEY OR PARTY WITHOUT ATTORNEY
`NAME: Mark S. Askanas (SBN 122745) | Kara A. Goidosik (SBN 337705)
`FIRM NAME: JACKSON LEWIS P.C.
`STREET ADDRESS: 50 California Street, 9th Floor
`STATE: CA ZIP CODE: 94111-4615
`CITY: San Francisco
`FAX NO.: (415) 394-9401
`TELEPHONE NO.: (415) 394-9400
`EMAIL ADDRESS: Mark.askanas@jacksonlewis.com; Kara.Goidosik@jacksonlewis.com
`ATTORNEY FOR (name): Defendant PARAMOUNT PROPERTY COMPANY, LTD.
`SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
`STREET ADDRESS: 400 McAllister Street
`MAILING ADDRESS: 400 McAllister Street
`CITY AND ZIP CODE: San Francisco, CA 94102-3680
`BRANCH NAME: Civic Center Courthouse
`PLAINTIFF/PETITIONER: KRYSTAL MARTIN
`DEFENDANT/RESPONDENT: PARAMOUNT PROPERTY COMPANY LTD. ET AL
`CASE MANAGEMENT STATEMENT
` UNLIMITED CASE
` LIMITED CASE
`(Amount demanded
`(Amount demanded is $35,000
`exceeds $35,000)
`or less)
`
`(Check one):
`
`FOR COURT USE ONLY
`
`CM-110
`
`ELECTRONICALLY
`F I L E D
`
`Superior Court of California,
`County of San Francisco
`11/04/2024
`Clerk of the Court
`BY: JEFFREY FLORES
`Deputy Clerk
`
`CASE NUMBER:
`CGC-24-615595
`
`Div.:
`
`Room:
`
`A CASE MANAGEMENT CONFERENCE is scheduled as follows:
`Date: November 20, 2024
`Time: 10:30 a.m.
`Dept.: 610
`Address of court (if different from the address above):
`
` Notice of Intent to Appear by Telephone, by (name): Kara A. Goidosik
`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): Defendant PARAMOUNT PROPERTY COMPANY LTD.
`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):
` The cross-complaint, if any, was filed on (date):
`b.
`3. Service (to be answered by plaintiffs and cross-complainants only)
`a.
` All 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 not):
`
` have been served but have not appeared and have not been dismissed (specify names):
`
` have had a default entered against them (specify names):
`
` The following additional parties may be added (specify names, nature of involvement in case, and date by which
`they may be served):
`
`
`(2)
`
`(3)
`
`c.
`
`4. Description of case
`(Describe, including causes of action):
` cross-complaint
` complaint
`a. Type of case in
`Disability discrimination in violation of Cal. Gov. Code §§ 12940; 12926(o); 12945.2; 12900 et seq.,; Wrongful
`Termination.
`
`Form Adopted for Mandatory Use
`Judicial Council of California
`CM-110 [Rev. January 1, 2024]
`
`
`CASE MANAGEMENT STATEMENT
`
`Page 1 of 5
`Cal. Rules of Court,
`rules 3.720–3.730
`www.courts.ca.gov
`
`
`

`

`PLAINTIFF/PETITIONER: KRYSTAL MARTIN
`DEFENDANT/RESPONDENT: PARAMOUNT PROPERTY COMPANY, LTD. 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):
`Plaintiff claims that Defendant discriminated against her for a disability related to her jaw and retaliated against her
`for taking meidcal leave related to her medical condition. Defendant denies these claims. Defendant terminated
`Plaintiff for lawful, non-discriminatory and non-retaliatory reasons.
`
`CASE NUMBER:
`CGC-24-615595
`
`CM-110
`
` a jury triaI
`
`(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):
`
` a nonjury trial. (If more than one party, provide the name of each party
`
` by the attorney or party listed in the caption
`
` by the following:
`
`f. Fax number:
`g. Party represented:
`
`c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
`12/02/24 – Trial; 01/13 to 01/17/2025 – trial; 03/25/2025 -trial; 51/12/2025 – trial; 5/19/20256 – arbitration; 08/18 to 08/26/2025 –
`arbitration; 09/19/2025 – arbitration; 09/22/2025- trial; 10/20/2025 – arbitration; 10/27/2025 – arbitration; 12/08/2025 - trial
`
`7. Estimated length of trial
`The party or parties estimate that the trial will take (check one)
`days (specify number): 3-5 days
`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. Email 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 identified
`(1) For parties represented by counsel: Counsel
`in rule 3.221 to the client and reviewed ADR options with the client.
` has not reviewed the ADR information package identified in rule 3.221.
` has
`(2) For self-represented parties: Party
`b. Referral to judicial arbitration or civil action mediation (if available).
` This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
`(1)
`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 1 775 et seq. (specify exemption):
`
`(2)
`
`(3)
`
`CM-110 [Rev. January 1, 2024]
`
`
`
`CASE MANAGEMENT STATEMENT
`
`Page 2 of 5
`
`

`

`PLAINTIFF/PETITIONER: KRYSTAL MARTIN
`DEFENDANT/RESPONDENT: PARAMOUNT PROPERTY COMPANY, LTD. ET AL
`
`CASE NUMBER:
`CGC-24-615595
`
`CM-110
`
`10. c. In the table below, 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):
`
`(1) Mediation
`
`(2) Settlement
`conference
`
`(3) Neutral evaluation
`
`(4) Nonbinding judicial
`arbitration
`
`(5) Binding private
`arbitration
`
`(6) Other (specify):
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`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. January 1, 2024]
`
`
`
`CASE MANAGEMENT STATEMENT
`
`Page 3 of 5
`
`

`

`PLAINTIFF/PETITIONER: KRYSTAL MARTIN
`DEFENDANT/RESPONDENT: PARAMOUNT PROPERTY COMPANY, LTD. ET AL
`11. Insurance
`
`Insurance carrier, if any, for party filing this statement (name): Zurich
`a.
` Yes
` No
`b. Reservation of rights:
` Coverage issues will significantly affect resolution of this case (explain):
`c.
`Unknown to date.
`
`CASE NUMBER:
`CGC-24-615595
`
`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
` 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):
`Defendant reserves the right to file a motion for summary judgment, or in the alternative, summary adjudication of
`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):
`Date
`Party
`Description
`Per Code
`Defendant
`Plaintiff’s Deposition
`Per Code
`Defendant
`Written Discovery
`Per Code
`Defendant
`Third-Party Discovery
`Per Code
`Defendant
`Expert Discovery
`
`
`
`
`
`
` The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated
`(specify):
`
`
`c.
`
`CM-110 [Rev. January 1, 2024]
`
`
`
`CASE MANAGEMENT STATEMENT
`
`Page 4 of 5
`
`

`

`PLAINTIFF/PETITIONER: KRYSTAL MARTIN
`DEFENDANT/RESPONDENT: PARAMOUNT PROPERTY COMPANY, LTD. ET AL
`
`CASE NUMBER:
`CGC-24-615595
`
`CM-110
`
`17. Economic litigation
` This is a limited civil case (i.e., the amount demanded is $35,000 or less) and the economic litigation procedures in Code
`a.
`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
` The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of
`a.
`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 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: November 4, 2024
`
`Kara A. Goidosik
`
`(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. January 1, 2024]
`
`
`
`CASE MANAGEMENT STATEMENT
`
`Page 5 of 5
`
`

`

`
`
`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 [CCP § 1013(g) and CRC Rule 2.253]
`I, Larry Nelson, declare that I am employed with the law firm of Jackson Lewis P.C., whose
`address is 50 California Street, 9th Floor, San Francisco, California 94111-4615; I am over the age
`of eighteen (18) years and am not a party to this action.
`On November 4, 2024, I caused to be e-served the attached CASE MANAGEMENT
`STATEMENT in this action by uploading a true and correct copy thereof, in PDF format, for
`electronic filing and service by First Legal (a court-approved Electronic Filing Service Provider),
`pursuant to Local Rule 2.11. Said document(s) to be filed with the Court and e-served on Plaintiff’s
`counsel of record, whose contact information is as follows:
`Nathan Kingery, Esq.
`Attorney for Plaintiff
`WILSHIRE LAW FIRM PLC
`
`3055 Wilshire Blvd, 12th Fl.
`KRYSTAL MARTIN
`Los Angeles, CA 90010-1176
`Tel.:
`(213) 381-9988
`Fax:
`(213) 381-9989
`E-mails:
`nkingery@wilshirelawfirm.com
`nathankingerysteam@wilshirelawfirm.com
`I declare under penalty of perjury, under the laws of the State of California, that the above
`is true and correct.
`Executed on November 4, 2024, at San Francisco, California.
`
`
`
`
`
`
`
`
`Larry Nelson
`
`
`
`
`
`
`
`
`
`
`
`Proof of Service [CCP § 1013(g) and CRC Rule 2.253]
`
`
`
`
`Case No. . CGC-24-615595
`
`