ATTORNEY OR PARTY WITHOUT ATTORNEY
`STATE BAR NUMBER:
`NAME: James J. Romag #241887 / Ashley N. Grindstaff #300964 / Daniel Ojeda #170539
`FIRM NAME: BROWN, KORO & ROMAG, LLP
`STREET ADDRESS: 6101 Bollinger Canyon Road, Suite 322
`STATE: CA
`ZIP CODE: 94583
`CITY: San Ramon
`TELEPHONE NO.: 925-830-4878
`FAX NO.: 925-830-4879
`jim@ruSsbrown.com / ashleyg@russbrown.com / daniel@russbrown.com
`EMAIL ADDRESS:
`ATTORNEY FOR (name): Plaintiff, Jimmy R. Arnold
`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
`BRANCH NAME: Civic Center Courthouse
`PLAINTIFF/PETITIONER: Jimmy R. Arnold
`DEFENDANT/RESPONDENT: Guy Resheff; Keren Klain, et al.
`
`CM-110
`
`FOR COURT USE ONLY
`
`ELECTRONICALLY
`F I L E D
`
`Superior Court of California,
`County of San Francisco
`12/09/2024
`Clerk of the Court
`BY: RONNIE OTERO
`Deputy Clerk
`
`(Check one):
`
`CASE MANAGEMENT STATEMENT
`LIMITED CASE
`x UNLIMITED CASE
`(Amount demanded is $35,000
`(Amount demanded
`or less)
`exceeds $35,000)
`
`CASE NUMBER:
`CGC-24-616686
`
`A CASE MANAGEMENT CONFERENCE is scheduled as follows:
`Time: 10:30 a.m.
`Dept.: 610
`Date: 01/08/2025
`
`Address of court (if different from the address above):
`
`Div.:
`
`Room:
`
`x Notice of Intent to Appear by Telephone, by (name): Daniel Ojeda, Esq.
`
`INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
`1. Party or parties (answer one):
`a. x This statement is submitted by party (name): Plaintiff, Jimmy R. Arnold
`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): 07/23/2024
`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. x The following parties named in the complaint or cross-complaint
`
`(1) TT have not been served (specify names and explain why not):
`DOES 1 to 100 have yet to be identified.
`(2) x have been served but have not appeared and have not been dismissed (specify names):
`Def., Keren Klain. Pltf. will be filing a Request for Default.
`
`(3) I- 1 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 date by which
`they may be served):
`
`4. Description of case
`x complaint
`a. Type of case in
`Personal Injury / Automobile vs. Motorcycle.
`
`cross-complaint
`
`(Describe, including causes of action):
`
`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.COuGs
`
`
`

`

`PLAINTIFF/PETITIONER: Jimmy R. Arnold
`DEFENDANT/RESPONDENT: Guy Resheff; Keren Klein, et al.
`
`CASE NUMBER:
`CGC-24-616686
`
`CM-110
`
`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):
`Defendant Resheff made an unsafe lane change and caused a collision. Plaintiff sustained an abdominal wall contusion and
`abrasion; right elbow strain, contusion, lateral epicondylitis, extensor tendon tear, nerve entrapment; right arm pain; bilateral
`elbow pain; bilateral wrist pain; and multiple other contusions/abrasions. Past medical specials are in excess of $71,000. Past
`wage loss is in excess of $34,000. To be proven at the time of trial by the appropriate expert witnesses.
`x
`(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):
`
`a nonjury trial. (If more than one party, provide the name of each party
`
`x
`
`a jury trial
`
`6. Trial date
`a.
`The trial has been set for (date):
`b. x 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 2025: 1/21-1/27; 1/27-1/31; 4/7-4/11; 4/14-4/18; 5/12-5/16; 7/7-7/11; 7/8-7/15; 8/5-8/12; 9/22-9/26; 11/4-11/11;
`11/7/11/14; 11/17-11/21; 12/5-12/12/ Trials 2026: 1/12-1/23.
`
`7. Estimated length of trial
`The party or parties estimate that the trial will take (check one)
`a.
`x days (specify number): 5 - 7
`b.
`hours (short causes) (specify):
`
`8. Trial representation (to be answered for each party)
`x by the attorney or party listed in the caption
`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.
`
`f. Fax number:
`g. Party represented:
`
`by the following:
`
`has not provided the ADR information package identified
`(1) For parties represented by counsel: Counsel x has
`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).
`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 1775 et seq. (specify exemption):
`
`(2)1
`
`(3)
`
`CM-110 [Rev. January 1, 2024]
`
`CASE MANAGEMENT STATEMENT
`
`Page 2 of 5
`
`

`

`PLAINTIFF/PETITIONER: Jimmy R. Arnold
`DEFENDANT/RESPONDENT: Guy Resheff; Keren Klein, et al.
`
`CASE NUMBER:
`CGC-24-616686
`
`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):
`
`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):
`
`(1) Mediation
`
`x
`
`(2) Settlement
`conference
`
`(3) Neutral evaluation
`
`(4) Nonbinding judicial
`arbitration
`
`(5) Binding private
`arbitration
`
`(6) Other (specify):
`
`x 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):
`
`I
`
`0
`
`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: Jimmy R. Arnold
`DEFENDANT/RESPONDENT: Guy Resheff; Keren Klain, et al.
`
`CASE NUMBER:
`CGC-24-616686
`
`11. Insurance
`
`CM-110
`
`a.
`
`Insurance carrier, if any, for party filing this statement (name):
`b. Reservation of rights:
`Yes F - 1 No
`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.
`Other (specify):
`Bankruptcy
`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 13a.
`
`b.
`
`j A motion to
`
`consolidate
`
`coordinate
`
`will 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.
`b.
`
`The party or parties have completed all discovery.
`The following discovery will be completed by the date specified (describe all anticipated discovery):
`
`Party
`
`Description
`
`Defendant Guy Resheff
`
`Answers to Written Discovery
`
`Date
`
`Due: 01/02/2025
`
`c.
`
`The following discovery issues, including issues regarding the discovery of electronically stored information, are
`anticipated (specify):
`
`CM-110 [Rev. January 1, 2024]
`
`CASE MANAGEMENT STATEMENT
`
`Page 4 of 5
`
`

`

`PLAINTIFF/PETITIONER: Jimmy R. Arnold
`DEFENDANT/RESPONDENT: Guy Resheff; Keren Klain, et al.
`
`CASE NUMBER:
`CGC-24-616686
`
`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.
`
`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
`
`x The party or parties request that the following additional matters be considered or determined at the case management
`conference (specify):
`Defendant Klain has been served but has not yet answered or otherwise appeared. Plaintiff will be filing a Request for
`Default.
`
`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
`a.
`of Court (if not, explain):
`Defendant Klain has been served but has not yet answered or otherwise appeared. Plaintiff will be filing a Request for
`Default.
`
`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): 0
`
`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: 12/09/2024
`
`Daniel Ojeda, Esq.
`
`(TYPE OR PRINT NAME)
`
`(SIGNATURE OF PARTY
`
`ORNEY)
`
`(TYPE OR PRINT NAME)
`
`(SIGNATURE OF PARTY OR ATTORNEY)
`
`Additional signatures are attached.
`
`CM-110 [Rev. January 1, 2024]
`
`CASE MANAGEMENT STATEMENT
`
`Page 5 of 5
`
`

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`STATE OF CALIFORNIA, COUNTY OF CONTRA COSTA
`
`PROOF OF SERVICE
`
`I am employed in the county aforesaid; I am over the age of eighteen years and not a party to the
`within entitled action; my business address is 6101 Bollinger Canyon Road, Suite 322, San Ramon,
`California 94583.
`
`On December 9, 2024, I served the within:
`
`CASE MANAGEMENT STATEMENT
`
`on the interested parties in said action, by placing a true copy thereof enclosed in a sealed envelope,
`addressed as follows:
`
`Gregory M. Doyle, Esq.
`James H. Ghilotti, Esq.
`TOSCHI • COLLINS • DOYLE • HOUVENER
`5145 Johnson Drive
`Pleasanton, CA 94588
`receptioni tcdlegal.corn; fileclerk(i4tcdlegal.com;
`GDoyle(t-t tcdlegal.com; jghilotti(rTtcdlegal.com;
`lzaldana0,tcdlegal.corn; jkyle@tcdlegal.com
`
`[ X ] BY MAIL - as follows: 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 United States
`Postal Service on that same day with postage thereon fully prepaid at San Ramon, California, in the
`ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if
`the postal cancellation date or postage meter date is more than one day after the date of deposit for
`mailing in the affidavit.
`
`[
`
`] BY PERSONAL DELIVERY - I caused such envelope to be delivered by hand.
`
`[ X ] BY E-MAIL - I caused such documents to be delivered by e-mail this date to the offices
`of the addressee(s), to the email address noted herein. Thereafter, I sent a true copy in a sealed envelope
`addressed and mailed as indicated above.
`
`[ ] EXPRESS SERVICE - I caused such documents to be deposited with an Express Service
`Carrier or Express Mail in accordance with the carrier's designated practice.
`
`[ X ]
`(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.
`
`I declare, under penalty of perjury under the laws of the State of California that the foregoing is true and
`correct.
`
`Executed on December 9, 2024, at San Ramon, California.
`
`Artimmis Gonzalez
`Printed Name
`
`Signature
`
`PROOF OF SERVICE
`
`