EXHIBIT F

Case: 19-30088 Doc# 3436-6 Filed: 08/07/19 Entered: 08/07/19 16:13:52 Page 1

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DEC 3 1 2C18 

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SUPERIOR COURT OF THE STATE OF CALIFORNIA 

COUNTY OF SAN FRANCISCO 

11 Coordination Proceeding 

Special Title (Rule 3 .550) 

JCCP No. 4955 

8.'fl:FULATIOH AN)): [~OPQiEB-) CASE 

MANAGEMENT ORDER 6 RE: 

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CALIFORNIA NORTH BAY FIRE CASES 

PREFERENCE CASE PROTOCOL 

Assigned for All Purposes to: 

Hon. Curtis E.A. Karn ow, Dept. 304 

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 

This Case Management Order shall govern all cases filed in or transferred to California 

18 North Bay Fire Cases, JCCP 4955, including all cases currently in this proceeding and any cases 

19 subsequently added to this proceeding. The Court anticipates, given the large number of filings in 

20 this JCCP and the factual nature and complexity of the claims at issue, that multiple plaintiffs may 

21 be interested in pursuing a preferential trial setting. The purpose of this Case Management Order is 

22 to establish a preference case protocol to facilitate the exchange of information related to cases 

23 potentially eligible for preferential trial setting. 

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The Com1 hereby Orders as follows: 

1. A Preference Committee for Individual Plaintiffs is hereby established to review 

26 potential preference cases and advise the submitting Plaintiff's counsel as to the viability and 

27 sequence of any potential filings. The Preference Committee shall consist of the following 

28 members of the Individual Plaintiffs' Executive Committee and shall report to (Co-Lead and Co4 

STIPULATION AND [PROPOSED] CASE MANAGEMENT ORDER 6 RE: PREFERENCE CASE PROTOCOL -

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Liaison Counsel): Thomas Brandi, Amy Eskin, Max Schuver, Mary Alexander, Allison Cordova, 

2 Angela Ja Chun, Matt Skikos, Joanna Fox, Steven Berki, and Ahmed Diab. 

3 2. The Preference Committee shall meet regularly and report to Co-Lead and Co4 Liaison counsel for Individual Plaintiffs and shall be available for consultation as a group with any 

5 individual plaintiffs counsel. For this purposes of compliance with this Order, the Preference 

6 Committee obligations are to all plaintiffs in the litigation and the litigation as a whole. 

7 3. The Preference Committee shall be responsible for meeting and conferring with the 

8 defendants regarding potential preference cases including briefing scheduling, setting of hearings, 

9 and coordination of discovery. These meet and confer efforts with Defendants will also include 

10 the Attorney for the Plaintiff moving for Preference. 

11 4. The Preference Committee shall submit to all counsel a preference questionnaire 

12 which shall be completed by the submitting Plaintiffs counsel who seeks to present a case to this 

13 Court for preferential trial setting. Given the large number of cases potentially eligible for 

14 preferential setting, counsel for any individual plaintiff seeking preference shall complete the 

15 preference questionnaire and provide it to the Preference Committee. 

16 5. Any plaintiffs counsel who, at any time, represents a Plaintiff that has a good faith 

17 basis for asse1iing entitlement to a preferential trial setting under Code of Civil Procedure § 36 

18 must provide written Notice to the Preference Committee of their potential claim of preferential 

19 trial setting eligibility at least 21 days before a motion for preference can be filed. At the time this 

20 Notice is served, the submitting Plaintiffs counsel shall also produce to the Preference Committee 

21 the following: (a) Grounds for Preference -A written statement setting forth in detail the grounds 

22 for preferential trial setting and the facts suppo1ting preference including the name of the plaitniff; 

23 (b) Records - Any medical and/or other records which the Plaintiff moving for Preference 

24 intends to submit to the Comi to supp01i the request for preferential trial setting, which will be 

25 uploaded on a secure document portal managed by Brown Greer to maintain security; (c) 

26 Declarations -Any and all declarations in suppo1t of the request for preferential trial setting (d) a 

27 completed CMO Compliance statement as required by CMO 5 uploaded to the BrownGreer portal 

28 and (e) a completed preference questionnaire as set forth in paragraph 4 above. If the Plaintiff 

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STIPULATION AND [PROPOSED] CASE MANAGEMENT ORDER 6 RE: PREFERENCE CASE PROTOCOL -

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moving for Preference has exigent circumstances that warrant an expedited process, these 

2 circumstances are to be presented to the Preference Committee at the earliest opportunity. If good 

3 cause exists, the attorney for the Plaintiff moving for Preference, Lead Plaintiffs' Counsel, and 

4 Defendants' Counsel will meet and confer as soon as practical. 

5 6. To the extent that a proposed plaintiff preference request has a corresponding 

6 Subrogation claim, Subrogation Leadership will be included and consulted as well. 

7 7. Upon receipt ofNotice(s) of potential claim(s) for preferential trial setting, the 

8 Preference Committee shall review and confirm that each request is complete and compliant with 

9 the preference protocol pursuant to C.C.P. § 36 and ready for meet and confer with Defendants. 

10 The Preference Committee shall communicate the findings of their review to the submitting 

11 Plaintiff's Counsel within 7 days of receipt ofNotice. 

12 8. Once a review of a request for preferential trial setting is deemed complete, 

13 pursuant to paragraph III above, the Preference Committee, or the submitting Plaintiffs Counsel if 

14 s/he disagrees with the Preference Committee's findings, shall provide Defendants with Notice 

15 regarding the preferential trial setting request(s) and the supporting materials to be submitted with 

16 the anticipated Preference motion(s) including any medical records and /or declarations that will 

17 be submitted. Plaintiffs and Defendants shall meet and confer within 7 days regarding the briefing 

18 and potential deposition schedule for each request for preferential trial setting. Any unresolved 

19 disputes amongst the parties regarding preferential trial settings will be decided by the Comi upon 

20 the filing and hearing of a Motion for Preferential Trial Setting pursuant to C.C.P. § 36. 

21 9. Counsel for the plaintiff bringing the preference motion shall be in compliance with 

22 the CM Os of this Court. 

23 10. After the procedure followed in this Preference Protocol is completed, any attorney 

24 representing a Plaintiff in this case may proceed with the filing of a motion for preference under 

25 California Code of Civil Procedure section 36 if that attorney believes it is appropriate to do so 

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IT IS SO ORDERED. 

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STIPULATION AND (PROPOSED] CASE MANAGEMENT ORDER 6 RE: PREFERENCE CASE PROTOCOL -

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Dated: 

Hon. Curtis .A. Karnow 

Judge of the Superior Court 

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STIPULATION AND [PROPOSED] CASE MANAGEMENT ORDER 6 RE: PREFERENCE CASE PROTOCOL -

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