Page 1 19CVSanta Clara —
ATrORNEY 0R PARTY WITHOUT ATTORNEY
TELEPHONE
No.:
Facebook,
by superior Court of CA,
N
cofiqtg1olgosfgntfi4c4laprnan’
on
'
.
Eewewed
InC.
By: SYStem
SyStem
base #1 9CV
SANTA CLARA
SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F
STREETADDRESS:
0’
EIectronicalIy Filed
FAX N0. (Optional): (21 3) 532-(21 3) 532-amortimer@HuntonAK.com; kimj@HuntonAK.com
ATrORNEY FOR(Name): Plaintiff
”y
Kim (SBN 221476)
J.
CA
E—MAIL ADDRESS(0pfiona/);
9M“a "Lo °tem
FOR COURT USE ONLY
(Name, State Bar number, and address):
Ann Marie Mortimer (SBN 169077); Jason
HUNTON ANDREWS KURTH LLP
550 S. Hope Street, Suite Los Angeles,
Civil
EnveloPe:
First Street
MAILING ADDRESS:
San Jose, CA 951 Downtown Superior Court
AND ZIP CODE:
CITY
BRAucH NAME;
PLAINTIFF/PETITIONER: Facebook, Inc.
DEFENDANT/RESPONDENT: ToLocal,
|nc., et al.
CASE MANAGEMENT STATEMENT
E
(Check one):
D
UNLIMITED CASE
(Amount demanded
exceeds $25,000)
A CASE MANAGEMENT CONFERENCE
Date:
December
Address
g
of court
10,
(if
different
scheduled as follows:
Dept:
Room:
Div.:
from the address above):
All applicable
X
D
J.
Kim
boxes must be checked, and the specified information must be provided.
This statement
is
submitted by party (name): Plaintiff Facebook, Inc.
This statement
is
submitted jointly by parties (names):
Complaint and cross-complaint
a.
b.
The complaint was filed on
The cross-complaint,
D
Service
a.
b.
(to
g
D
A|| parties
The
D
D
D
(3)
D
named
in
be answered by plaintiffs and cross-complainants
if
any,
May
was
30,
only)
filed on (date):
only)
the complaint and cross-complaint have been served, have appeared, or have been dismissed.
following parties
(2)
c.
(to
(date):
be answered by plaintiffs and cross-complainants
(1)
4.
$25,
Party or parties (answer one):
b.
3.
is
Notice of Intent to Appear by Telephone, by (name): Jason
a.
2.
is
or less)
Time: 10:00 a.m.
INSTRUCTIONS:
1.
:AQSEVQAZERQ'
LIMITED CASE
(Amount demanded
named
in
the complaint or cross-complaint
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
they
may be
may be added
(specify
names, nature ofinvolvement
in
case,
and date by which
served):
Description of case
Type
a.
of
case
in
E
D
complaint
cross-complaint
(Describe, including causes of action):
Plaintiff
brings claims for Breach of Contract, violation 0f California’s Unfair Competition Law, and Breach 0f the
Implied
Covenant of Good
Faith
and
Fair Dealing.
Page
Form Adopted
for
Mandatory Use
Judicial Council of California
CM-1
[Rev. July
1,
1]
CASE MANAGEMENT STATEMENT
of
Cal. Rules of Court,
rules 3.72m3.www.couns.ca.gov
American LegalNen Inc.
www,FormsWorkFlow‘comPage 2 CM-PLAINTIFF/PETITIONER. Facebook,
.
—DEFENDANT/RESPONDENT: ToLocaI,
4.
CASE NUMBER:
Inc.
190V
|nc., et al.
Provide a brief statement of the case, including any damages. (prersonal injury damages are sought, specify the injury and
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.)
b.
damages
Defendants breached Facebook’s Terms of Service by running advertising campaigns that fraudulently induced
Facebook users to click on ads that redirected them to Defendants’ website, where Defendants harvested the
users’ contact information and used it t0 spam their email and make robocalls. Plaintiff requests damages in
amounts to be proven at trial.
D
5.
(If
more space
Jury or nonjury
The
D
E
b.
trial
E
a jury
D
trial
a nonjury
trial.
(If
more than one
party, provide the
name
of each party
trial):
date
Trial
a.
needed, check this box and attach a page designated as Attachment 4b.)
party or parties request
requesting a jury
6.
is
The trial has been set for (date):
No trial date has been set. This case
wi||
be ready
for
trial
months of the date of the
within
filing
of the complaint
(if
not, explain):
Dates on which parties or attorneys
c.
7.
Estimated length of
The
b.
8.
and explain reasons
for unavailability):
trial will
take (check one):
days (specify number): 5-1 hours (short causes) (specify):
The
party or parties
a.
Attorney:
be answered for each party)
be represented at trial
by the attorney or party
X
will
b.
Firm:
c.
Address:
d.
Telephone number:
e.
E-mail address:
Additional representation
Preference
This case
D
10.
(specify dates
trial
Trial representation (to
D
9.
not be available for
trial
party or parties estimate that the
E
D
a.
will
is
is
described
in
Attachment
entitled to preference (specify
code
listed in
D
the caption
f.
Fax number:
g.
Party represented:
by the following:
8.
section):
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
(1)
(2)
b.
community programs
in this
case.
E
D
For parties represented by counsel: Counsel
has
in rule 3.221 to the client and reviewed ADR options with the
For self—represented parties: Party
D
has
D
(1)
D
is
statutory
(2)
D
(3)
D
Code
ADR
information package identified
ADR
information package identified
Code
of Civil
Procedure section
because the amount
in
3.221.
.11 or to civil action
controversy does not exceed the
limit.
case to
Procedure section 1141.1 1.
judicial arbitration
and agrees
to limit recovery to the
amount
specified
This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM-110[Rev.July1,2011]
in rule
available).
of Civil Procedure section 1775.
Plaintiff elects to refer this
Civil
(if
subject to mandatoryjudicial arbitration under
mediation under
provided the
has not reviewed the
Referral tojudicial arbitration or civil action mediation
This matter
has not
client.
civil
in
Code
of
action
PageZoffi
CASE MANAGEMENT STATEMENT
American LegalNet,
Inc.
www.FormsWorkl-‘low‘com
_Page 3 CM-PLAINTIFF/PETITIONER: Facebook,
CASE NUMBER:
Inc.
D—EFENDANT/RESPONDENT: ToLocal,
10.
c.
Indicate the
ADR
QCV
|nc., et al.
process or processes that the party or parties are willing to participate in, have agreed to participate
in (check all that apply and provide the specified information):
in,
or
have already participated
The
this
party or parties completing
form are willing to
participate in the following
processes (check
all
ADR
that apply):
in the case have agreed to
have already completed an ADR process or processes,
indicate the status of the processes (attach a copy of the parties’ADR
If
the party or parties completing this form
participate in or
stipulation):
E
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1)
Mediation
Agreed
to
complete mediation by (date):
DD
Mediation completed on (date):
Settlement conference not yet scheduled
(2)
Settlement conference scheduled for (date):
Settlement
conference
DUDE
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
DUDE
Agreed
to
complete neutral evaluation by (date):
Neutral evaluation completed on (date):
scheduled
Judicial arbitration not yet
(4)
Nonbinding
Judicial arbitration
judicial
scheduled for (date):
DUDE
arbitration
Agreed
to
complete
Judicial arbitration
judicial arbitration
completed on
by (date):
(date):
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
(5) Binding private
DUDE
arbitration
Agreed
to
complete private
arbitration
by (date):
Private arbitration completed on (date):
(6)
Other
(specify):
ADR session
not yet scheduled
ADR session
scheduled
for (date):
DUDE
Agreed
to
complete
ADR completed
CM-1 1o
[Rev. July
1,
1]
on
CASE MANAGEMENT STATEMENT
ADR
session by (date):
(date):
Page 3 of American LegalNet, Inc.
www.FonnsWorkFlow,com
aPage 4 CM-CASE NUMBER:
PLAINTIFF/PETITIONER. Facebook, Inc.
-
TDEFENDANT/RESPONDENT: ToLocaI,
11.
Insurance
a.
D
Insurance
Reservation of
b.
D
c.
12.
9CV
|nc., et al.
carrier,
if
any, for party
D
rights:
Coverage issues
will
filing this
D
Yes
statement (name):
No
significantly affect resolution of this
case
(explain):
Jurisdiction
Indicate
D
any matters
Bankruptcy
that
D
may
affect the court's jurisdiction or processing of this
case and describe the
status.
Other (specify):
Status:
13.
Related cases, consolidation, and coordination
a.
D
There are companion, underlying, or related cases.
(2)
Name of case:
Name of court
(3)
Case number:
(1)
(4) Status:
b.
14.
D
D
Additional cases are described
A motion to
The
D
consolidate
party or parties intend to
action (specify
coordinate
will
be
filed
by (name pafly):
moving
file
a motion
for
party, type of motion,
an order
bifurcating, severing, or coordinating the following issues or
causes of
and reasons):
Other motions
g
The
party or parties expect to
Plaintiff anticipates
16.
Attachment 13a.
Bifurcation
D
15.
D
in
file
the following motions before
discovery motions, and
pre-trial
trial
motions
(specify
in
moving party, type of motion, and issues):
as necessary.
limine,
Discovery
a.
b
D
E
The
The
party or parties have completed
following discovery
Pa_rty
wi||
all
discovery.
be completed by the date specified (describe
%
0/
Interrogatories
9/
0/
Requests
9/
0/
9/
0/
Facebook,
Inc.
Facebook,
Inc.
Facebook,
Inc.
Depositions
The
Admission
9/
Inc.
X
anticipated discovery):
Descrigtion
Requests
Facebook,
c.
all
for
for Production
following discovery issues, including issues regarding the discovery of electronically stored information. are
anticipated (specify):
The
parties anticipate the need for a stipulated protective order, which they
approval at the appropriate time.
CM-110[Rev.JuIy1,2011]
CASE MANAGEMENT STATEMENT
will
present to the Court for
Page4ofAmerican LegalNet, Inc.
www.FormsWorkFlow.00mPage 5 CM-CASE NUMBER:
PLAINTIFF/PETITIONER. FacebOOK, InC.
.
—DEFENDANT/RESPONDENT: ToLocaI,
17.
Economic
D
D
a.
b.
litigation
This
is
a
limited
civil
case
(i.e.,
the
of Civil Procedure sections 90-
This
is
a
limited
discovery
will
civil
be
should not apply
18.
1QCV
|nc., et al.
amount demanded
will
is
$25,000 or less) and the economic
litigation
procedures
in
Code
apply to this case.
to withdraw the case from the economic litigation procedures or for additional
checked, explain specifically why economic litigation procedures relating to discovery or trial
case and a motion
filed (if
to this case):
Other issues
D
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
E
a.
Court
(if
After meeting
b.
or parties
have met and conferred with
all
parties
on
all
subjects required by rule 3.724 of the California Rules of
not, explain):
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):
am completely familiar with this case and wi|| 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
Jason
J.
21,
>
Kim
(TYPE
(TYPE
Jason
J.
Kim
(SIGNATURE OF PARTY OR ATTORNEY)
0R PRINT NAME)
(SIGNATURE OF PARTY OR ATTORNEY)
D
CM-110[Rev.JuIy1,2011]
ls/
OR PRINT NAME)
Additional signatures are attached.
CASE MANAGEMENT STATEMENT
Pagefiofs
American LegalNeg Inc.
www,FormsWorkFlow‘comPage 6 CERTIFICATE OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
I
am employed in the County
years and not a party t0 this action.
0f Los Angeles, State of California.
My
business address
is
I
am over the
550 South Hope
age 0f
Street, Suite
2000, Los
Angeles, California 90071-2627.
On November 21,
KOOOQQUILUJNH
2019,
I
served the foregoing document(s) described as
CASE
MANAGEMENT STATEMENT on the interested parties in this action:
M. Rosenfeld,
Liana W. Chen, Esq.
Jeffrey
Attorneysfor Defendants
Esq.
TOMONGOAD,
KRONENBERGER ROSENFELD, LLP
150 Post
Street, Suite
San Francisco,
e
38%
43:sag
£
Tel.: (415)
“Keater
Ge
TOLOCAL, INC,
INC. and MIN GE a/k/a
”
CA
955-1
Fax: (415) 955-1
Email: jeff@KRInternetLaw.com
liana@KRInternetLaw.com
§§L§
By MAIL: by placing true and correct
:S‘U
mm“
copy(ies) thereof in an envelope addressed t0 the
attorney(s) 0f record, addressed as stated above.
Eézz”
By PERSONAL SERVICE:
D
I
delivered the envelope
by hand 0n
the addressee,
addressed as stated above.
A
By
D
OVERNIGHT MAIL:
by overnight
courier,
I
arranged for the above-referenced
document(s) t0 be delivered t0 an authorized overnight courier service for delivery to the
addressee(s) above, in an envelope or package designated by the overnight courier service
With delivery fees paid or provided
By ELECTRONIC SERVICE: by
causing a true and correct copy thereof to be
transmitted electronically t0 the attorney(s) of record at the e-mail address(es) indicated
D
above.
for.
I
true
and
declare under penalty of perjury under the laws 0f the State of California that the above
correct.
Executed 0n November 21, 2019, Los Angeles, California.
/s/
073923.
EMF_US
74230509V
Mark Johnson
Mark Johnson
is
PDF Page 1
PlainSite Cover Page
PDF Page 2
19CV348954
Santa Clara —
ATrORNEY 0R PARTY WITHOUT ATTORNEY
TELEPHONE
No.:
Facebook,
by superior Court of CA,
N
cofiqtg1olgosfgntfi4c4laprnan’
on
'
.
Eewewed
InC.
By: SYStem
SyStem
base #1 9CV348954
SANTA CLARA
SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F
STREETADDRESS: 191
0’
EIectronicalIy Filed
FAX N0. (Optional): (21 3) 532-2020
(21 3) 532-2000
amortimer@HuntonAK.com; kimj@HuntonAK.com
ATrORNEY FOR(Name): Plaintiff
”y
Kim (SBN 221476)
J.
CA 90071
E—MAIL ADDRESS(0pfiona/);
9M“a "Lo °tem
FOR COURT USE ONLY
(Name, State Bar number, and address):
Ann Marie Mortimer (SBN 169077); Jason
HUNTON ANDREWS KURTH LLP
550 S. Hope Street, Suite 2000
Los Angeles,
Civil
EnveloPe: 3682267
First Street
MAILING ADDRESS:
San Jose, CA 951 13
Downtown Superior Court
AND ZIP CODE:
CITY
BRAucH NAME;
PLAINTIFF/PETITIONER: Facebook, Inc.
DEFENDANT/RESPONDENT: ToLocal,
|nc., et al.
CASE MANAGEMENT STATEMENT
E
(Check one):
D
UNLIMITED CASE
(Amount demanded
exceeds $25,000)
A CASE MANAGEMENT CONFERENCE
Date:
December
Address
g
of court
10,
(if
2019
different
scheduled as follows:
Dept: 2
Room:
Div.:
from the address above):
All applicable
X
D
J.
Kim
boxes must be checked, and the specified information must be provided.
This statement
is
submitted by party (name): Plaintiff Facebook, Inc.
This statement
is
submitted jointly by parties (names):
Complaint and cross-complaint
a.
b.
The complaint was filed on
The cross-complaint,
D
Service
a.
b.
(to
g
D
A|| parties
The
D
D
D
(3)
D
named
in
be answered by plaintiffs and cross-complainants
if
any,
May
was
30,
only)
2019
filed on (date):
only)
the complaint and cross-complaint have been served, have appeared, or have been dismissed.
following parties
(2)
c.
(to
(date):
be answered by plaintiffs and cross-complainants
(1)
4.
$25,000
Party or parties (answer one):
b.
3.
is
Notice of Intent to Appear by Telephone, by (name): Jason
a.
2.
is
54
or less)
Time: 10:00 a.m.
INSTRUCTIONS:
1.
:AQSEVQAZERQ'
LIMITED CASE
(Amount demanded
named
in
the complaint or cross-complaint
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
they
may be
may be added
(specify
names, nature ofinvolvement
in
case,
and date by which
served):
Description of case
Type
a.
of
case
in
E
D
complaint
cross-complaint
(Describe, including causes of action):
Plaintiff
brings claims for Breach of Contract, violation 0f California’s Unfair Competition Law, and Breach 0f the
Implied
Covenant of Good
Faith
and
Fair Dealing.
Page
Form Adopted
for
Mandatory Use
Judicial Council of California
CM-1 10
[Rev. July
1,
201
1]
CASE MANAGEMENT STATEMENT
1
of 5
Cal. Rules of Court,
rules 3.72m3.730
www.couns.ca.gov
American LegalNen Inc.
www,FormsWorkFlow‘com
PDF Page 3
CM-110
PLAINTIFF/PETITIONER. Facebook,
.
—DEFENDANT/RESPONDENT: ToLocaI,
4.
CASE NUMBER:
Inc.
190V348954
|nc., et al.
Provide a brief statement of the case, including any damages. (prersonal injury damages are sought, specify the injury and
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.)
b.
damages
Defendants breached Facebook’s Terms of Service by running advertising campaigns that fraudulently induced
Facebook users to click on ads that redirected them to Defendants’ website, where Defendants harvested the
users’ contact information and used it t0 spam their email and make robocalls. Plaintiff requests damages in
amounts to be proven at trial.
D
5.
(If
more space
Jury or nonjury
The
D
E
b.
trial
E
a jury
D
trial
a nonjury
trial.
(If
more than one
party, provide the
name
of each party
trial):
date
Trial
a.
needed, check this box and attach a page designated as Attachment 4b.)
party or parties request
requesting a jury
6.
is
The trial has been set for (date):
No trial date has been set. This case
wi||
be ready
for
trial
months of the date of the
within 12
filing
of the complaint
(if
not, explain):
Dates on which parties or attorneys
c.
7.
Estimated length of
The
b.
8.
and explain reasons
for unavailability):
trial will
take (check one):
days (specify number): 5-1 0
hours (short causes) (specify):
The
party or parties
a.
Attorney:
be answered for each party)
be represented at trial
by the attorney or party
X
will
b.
Firm:
c.
Address:
d.
Telephone number:
e.
E-mail address:
Additional representation
Preference
This case
D
10.
(specify dates
trial
Trial representation (to
D
9.
not be available for
trial
party or parties estimate that the
E
D
a.
will
is
is
described
in
Attachment
entitled to preference (specify
code
listed in
D
the caption
f.
Fax number:
g.
Party represented:
by the following:
8.
section):
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
(1)
(2)
b.
community programs
in this
case.
E
D
For parties represented by counsel: Counsel
has
in rule 3.221 to the client and reviewed ADR options with the
For self—represented parties: Party
D
has
D
(1)
D
is
statutory
(2)
D
(3)
D
Code
ADR
information package identified
ADR
information package identified
Code
of Civil
Procedure section 1141
because the amount
in
3.221.
.11 or to civil action
controversy does not exceed the
limit.
case to
Procedure section 1141.1 1.
judicial arbitration
and agrees
to limit recovery to the
amount
specified
This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM-110[Rev.July1,2011]
in rule
available).
of Civil Procedure section 1775.3
Plaintiff elects to refer this
Civil
(if
subject to mandatoryjudicial arbitration under
mediation under
provided the
has not reviewed the
Referral tojudicial arbitration or civil action mediation
This matter
has not
client.
civil
in
Code
of
action
PageZoffi
CASE MANAGEMENT STATEMENT
American LegalNet,
Inc.
www.FormsWorkl-‘low‘com
_
PDF Page 4
CM-110
PLAINTIFF/PETITIONER: Facebook,
CASE NUMBER:
Inc.
1
D—EFENDANT/RESPONDENT: ToLocal,
10.
c.
Indicate the
ADR
QCV348954
|nc., et al.
process or processes that the party or parties are willing to participate in, have agreed to participate
in (check all that apply and provide the specified information):
in,
or
have already participated
The
this
party or parties completing
form are willing to
participate in the following
processes (check
all
ADR
that apply):
in the case have agreed to
have already completed an ADR process or processes,
indicate the status of the processes (attach a copy of the parties’ADR
If
the party or parties completing this form
participate in or
stipulation):
E
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1)
Mediation
Agreed
to
complete mediation by (date):
DD
Mediation completed on (date):
Settlement conference not yet scheduled
(2)
Settlement conference scheduled for (date):
Settlement
conference
DUDE
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
DUDE
Agreed
to
complete neutral evaluation by (date):
Neutral evaluation completed on (date):
scheduled
Judicial arbitration not yet
(4)
Nonbinding
Judicial arbitration
judicial
scheduled for (date):
DUDE
arbitration
Agreed
to
complete
Judicial arbitration
judicial arbitration
completed on
by (date):
(date):
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
(5) Binding private
DUDE
arbitration
Agreed
to
complete private
arbitration
by (date):
Private arbitration completed on (date):
(6)
Other
(specify):
ADR session
not yet scheduled
ADR session
scheduled
for (date):
DUDE
Agreed
to
complete
ADR completed
CM-1 1o
[Rev. July
1,
201
1]
on
CASE MANAGEMENT STATEMENT
ADR
session by (date):
(date):
Page 3 of 5
American LegalNet, Inc.
www.FonnsWorkFlow,com
a
PDF Page 5
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER. Facebook, Inc.
-
1
TDEFENDANT/RESPONDENT: ToLocaI,
11.
Insurance
a.
D
Insurance
Reservation of
b.
D
c.
12.
9CV348954
|nc., et al.
carrier,
if
any, for party
D
rights:
Coverage issues
will
filing this
D
Yes
statement (name):
No
significantly affect resolution of this
case
(explain):
Jurisdiction
Indicate
D
any matters
Bankruptcy
that
D
may
affect the court's jurisdiction or processing of this
case and describe the
status.
Other (specify):
Status:
13.
Related cases, consolidation, and coordination
a.
D
There are companion, underlying, or related cases.
(2)
Name of case:
Name of court
(3)
Case number:
(1)
(4) Status:
b.
14.
D
D
Additional cases are described
A motion to
The
D
consolidate
party or parties intend to
action (specify
coordinate
will
be
filed
by (name pafly):
moving
file
a motion
for
party, type of motion,
an order
bifurcating, severing, or coordinating the following issues or
causes of
and reasons):
Other motions
g
The
party or parties expect to
Plaintiff anticipates
16.
Attachment 13a.
Bifurcation
D
15.
D
in
file
the following motions before
discovery motions, and
pre-trial
trial
motions
(specify
in
moving party, type of motion, and issues):
as necessary.
limine,
Discovery
a.
b
D
E
The
The
party or parties have completed
following discovery
Pa_rty
wi||
all
discovery.
be completed by the date specified (describe
%
0/2020
Interrogatories
9/1
0/2020
Requests
9/1
0/2020
9/1
0/2020
Facebook,
Inc.
Facebook,
Inc.
Facebook,
Inc.
Depositions
The
Admission
9/1
Inc.
X
anticipated discovery):
Descrigtion
Requests
Facebook,
c.
all
for
for Production
following discovery issues, including issues regarding the discovery of electronically stored information. are
anticipated (specify):
The
parties anticipate the need for a stipulated protective order, which they
approval at the appropriate time.
CM-110[Rev.JuIy1,2011]
CASE MANAGEMENT STATEMENT
will
present to the Court for
Page4of5
American LegalNet, Inc.
www.FormsWorkFlow.00m
PDF Page 6
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER. FacebOOK, InC.
.
—DEFENDANT/RESPONDENT: ToLocaI,
17.
Economic
D
D
a.
b.
litigation
This
is
a
limited
civil
case
(i.e.,
the
of Civil Procedure sections 90-98
This
is
a
limited
discovery
will
civil
be
should not apply
18.
1QCV348954
|nc., et al.
amount demanded
will
is
$25,000 or less) and the economic
litigation
procedures
in
Code
apply to this case.
to withdraw the case from the economic litigation procedures or for additional
checked, explain specifically why economic litigation procedures relating to discovery or trial
case and a motion
filed (if
to this case):
Other issues
D
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
E
a.
Court
(if
After meeting
b.
or parties
have met and conferred with
all
parties
on
all
subjects required by rule 3.724 of the California Rules of
not, explain):
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):
am completely familiar with this case and wi|| 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
Jason
J.
21,
2019
>
Kim
(TYPE
(TYPE
Jason
J.
Kim
(SIGNATURE OF PARTY OR ATTORNEY)
0R PRINT NAME)
(SIGNATURE OF PARTY OR ATTORNEY)
D
CM-110[Rev.JuIy1,2011]
ls/
OR PRINT NAME)
Additional signatures are attached.
CASE MANAGEMENT STATEMENT
Pagefiofs
American LegalNeg Inc.
www,FormsWorkFlow‘com
PDF Page 7
CERTIFICATE OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
I
am employed in the County
years and not a party t0 this action.
0f Los Angeles, State of California.
My
business address
is
I
am over the
550 South Hope
age 0f 18
Street, Suite
2000, Los
Angeles, California 90071-2627.
On November 21,
KOOOQQUILUJNH
2019,
I
served the foregoing document(s) described as
CASE
MANAGEMENT STATEMENT on the interested parties in this action:
M. Rosenfeld,
Liana W. Chen, Esq.
Jeffrey
Attorneysfor Defendants
Esq.
TOMONGOAD,
KRONENBERGER ROSENFELD, LLP
150 Post
Street, Suite
San Francisco,
10
e511
38%
43:12
sag
£3333
Tel.: (415)
“Keater
Ge
TOLOCAL, INC,
INC. and MIN GE a/k/a
”
520
CA 94108
955-1 155
Fax: (415) 955-1 158
Email: jeff@KRInternetLaw.com
liana@KRInternetLaw.com
§§L§14
By MAIL: by placing true and correct
:S‘U
mm“
copy(ies) thereof in an envelope addressed t0 the
attorney(s) 0f record, addressed as stated above.
Eézz”
By PERSONAL SERVICE:
D
I
delivered the envelope
by hand 0n
the addressee,
addressed as stated above.
A
17
By
D
OVERNIGHT MAIL:
by overnight
courier,
I
arranged for the above-referenced
18
document(s) t0 be delivered t0 an authorized overnight courier service for delivery to the
addressee(s) above, in an envelope or package designated by the overnight courier service
19
With delivery fees paid or provided
20
By ELECTRONIC SERVICE: by
causing a true and correct copy thereof to be
transmitted electronically t0 the attorney(s) of record at the e-mail address(es) indicated
D
above.
21
22
23
for.
I
true
and
declare under penalty of perjury under the laws 0f the State of California that the above
correct.
Executed 0n November 21, 2019, Los Angeles, California.
24
/s/
25
26
27
28
073923.0000039
EMF_US
74230509V2
Mark Johnson
Mark Johnson
is
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