Preview
1|| Raymond N. Stella Erlach, SBN 056958
LAW OFFICES OF
2 || RAYMOND N. STELLA ERLACH
100 Smith Ranch Road, Suite 107
3 || San Rafael, CA 94903
Telephone: 415-788-3322
4 || Facsimile: 415-788-8613
E-mail: rerlach@rayerlach.com
5
Attorneys for Defendants
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SONOMA, UNLIMITED JURISDICTION
10 a
)
Il | VILLA ROSA HOMEOWNERS ) Case No. SCV-267991
ASSOCIATION, )
12 )
Plaintiff, )
13 )
v. ) DEFENDANT VALLEN W. COOPER'S
14 ) ACCEPTANCE OF OFFER
VALLEN W. COOPER, an individual; )} TO COMPROMISE
15 | VALLEN W. COOPER, CPM, INC., ) (CCP §998)
individually and dba )
16 | COMMONWEALTH PROPERTY )
MANAGEMENT; )
17 | COMMONWEALTH ASSOCIATION )
MANAGEMENT, INC.; )
18 |]KELLIN A. BAKER, individually and dba)
ACCURATE PROPERTY SERVICES aka )
19 | ACCURATE )
MAINTENANCE & JANITORIAL; }
20 || CHAD W. COOPER, an individual; and )
DOES 1 through 50, }
21 )
Defendants. } Complaint Filed: March 12, 2021
22 ) Trial Date: None Set
} Department: 18
23 } Judge: Honorable Jennifer V. Dollard
ee Y
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28 |] jpX5iCo'proof.evr4
Case No. SCV-26799|
DEFENDANT V. COOPER'S ACCEPTANCE
OF OFFER TO COMPROMISE (CCP §998)
1 | PETER C. De GOLIA (SBN 113103)
NICHOLAS BERNATE (SBN 288187)
2 | CLEMENT, FITZPATRICK & KENWORTHY
3 3333 Mendocino Avenue, Suite 200
Santa Rosa, CA 95403
4 | Telephone: (707) 523-1181
Facsimile: (707) 546-1360
5 | pdegolia@cfk.com
é nbernate@cfk.com
7 | Attorneys for Plaintiff, Villa Rosa Homeowners Association
8
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
11 COUNTY OF SONOMA
12
VILLA ROSA HOMEOWNERS Case No. SCV-267991
13 ASSOCIATION,
OFFER TO COMPROMISE
14 Plaintiff, (CCP §998)
15
vs.
16
VALLEN W. COOPER, an individual;
17 VALLEN W. COOPER, CPM, INC.,
individually and dba COMMONWEALTH
18 | PROPERTY MANAGEMENT;
19 COMMONWEALTH ASSOCIATION
MANAGEMENT, INC.; KELLIN A,
20 BAKER, individually and dba
ACCURATE PROPERTY SERVICES aka
21 ACCURATE MAINTENANCE &
JANITORIAL; CHAD W. COOPER, an
22 | individual; and DOES 1 through 50,
23 Defendants.
24
25 TO DEFENDANT VALLEN W. COOPER AND HER ATTORNEY OF RECORD:
26 Pursuant to Code of Civil Procedure §998, VILLA ROSA HOMEOWNERS
27 | ASSOCIATION (“Plaintiff”) hereby offers to have judgment taken in this action as follows:
28 | VALLEN W. COOPER, an individual, will pay to Plaintiff the amount of Ten Thousand Dollars
OFFER TO COMPROMISE (CCP §998) TO DEFENDANT VALLEN W. COOPER
!
1 | ($10,000.00) in satisfaction of allclaims, damages, costs, expenses, attorneys’ fees and interest
2| claimed in this action as related to Defendant VALLEN W. COOPER.
3 If you accept this offer, please date and sign the acceptance form below and return to
4 | Plaintiff's counsel.
5 PLEASE TAKE NOTICE that if this offer is not accepted prior to trial or within 30 days
6 || after itis made, whichever occurs first,itshall be deemed withdrawn pursuant to CCP §998.
7
8 DATED: April 25, 2022 CLEMENT, FITZPATRICK & KENWORTHY
9 ete
By: L7o™N
10 ICHOLAS J.BEBANATE
Atterneys-for Plaintiff
11 Villa Rosa Homeowners Association
12
13 ACCEPTANCE OF OFFER
14
15 The undersigned accepts Plaintiff's offer to allow judgment in this action to be
16 || entered as specified above.
17 LAW OFFICES OF RAYMOND N. STELLA ERLACH
DATED: Yow LAT, AOfA By:_ J \Aypiin Jb i Celek nn
19 j " Raymond Niéfiolas Stella Erlach
20 Attorney for Defendant Vallen W. Cooper, an Individual
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OFFER TO COMPROMISE (CCP §998) TO DEFENDANT VALLEN W. COOPER
2
PROOF OF SERVICE
2 Iam a citizen of the United States. My business address is 3333 Mendocino Avenue, Suite |
200, Santa Rosa, California 95403. [ am employed in the County of Sonoma where this service
31) occurs. Iam over the age of 18 years and not a party to the within cause.
4
On the date set forth below, I served the attached document entitled: OF FER TO
5 |} COMPROMISE (CCP §998) as follows:
6 Oo BY MAIE: I placed each such sealed envelope, with postage thereon fully
prepaid for first-class mail and mailing at Santa Rosa, California. I am readily |
7 familiar with the practice of Clement, Fitzpatrick & Kenworthy for processing of |
8 correspondence, said practice being that in the ordinary course of business, |
correspondence is deposited inthe United States Postal Service the same day as it i
9 is placed for processing.
10 SJ BY ELECTRONIC SERVICE: Pursuant to Code of Civil Procedure section
1010.6 and California Rules of Court section 2.256(a)(4), Icaused such
il documents to be served by an electronic filing service and/or email on this date to
all parties listed below at the email address(es) listed below. My eService
12 address istdurler(@cfk.com.
13 q BY OVERNIGHT DELIVERY: Icaused such envelope(s) to be delivered on
the same day to an authorized courier or driver or to a regular box or other facility
14 regularly maintained by FEDERAL EXPRESS with delivery fees provided for, |
15 addressed to the person(s) on whom itis to be served.
on the interested party(ies) to the within cause addressed as follows:
16
7 Raymond Nicholas Stella Erlach Attorney for Defendants
Law Offices of Raymond N. Stella Erlach
13 |] | 100 Smith Ranch Road, Suite 107
San Rafael, CA 94903-1954
19 |]| rerlach@rayerlach.com |
20 || | Courtesy copy to:
214 | Jennifer Pearl
2 Law Offices of Raymond N. Stella Erlach
100 Smith Ranch Road, Suite 107
33 San Rafael, CA 94903-1954
jpearl@rayerlach.com |
24
25 Ideclare under penalty of perjury under the laws of the State of California that the foregoing |
is true and correct.
26 Executed on April 26, 2022, at Santa Rosa, California.
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PATRICIA RIL URLER
sweeten _— SI 75°01171 77 1 (7 SE
1 Sonoma County Superior Court Case No. SCV-267991
2 PROOF OF SERVICE BY E-MAIL
3 I,the undersigned, say:
4 I am a resident of the State of California and not a party to the within action; my
5 || business address isthe Law Offices of Raymond N. Stella Erlach, 100 Smith Ranch Road,
6 || Suite 107, San Rafael, California 94903; my e-mail address isjpearl@rayerlach.com.
7 On April 27, 2022, on behalf of Raymond N. Stella Erlach, counsel for
8 |] Vallen W. Cooper, whose electronic service address is rerlach@rayerlach.com, I served the within: |
9 DEFENDANT VALLEN W. COOPER'S
ACCEPTANCE OF OFFER TO COMPROMISE |
10 (CCP §998)
11 || on the interested parties in said action by electronic service to each of the following:
2 Name of person/entity served: To electronic service address: |
13 On behalf of Villa Rosa Homeowners Association: |
4 Peter C. De Golia, Esq. pdegolia@cfk.com |
15 Nicholas Bernate, Esq. nbernate@cfk.com
Clement, Fitzpatrick & Kenworthy iholmberg@cfk.com
16 tdurler@cfk.com
17 I declare under penalty of perjury under the laws of the State of California that the i
18 | foregoing is true and correct. ; An f
20 || Dated: April 27, 2022 Ih lh KL i4y A
1 jpX5‘Co'proofemonly.| i Jennifer k earl fo |
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Preview
1|| Raymond N. Stella Erlach, SBN 056958 LAW OFFICES OF 2 || RAYMOND N. STELLA ERLACH 100 Smith Ranch Road, Suite 107 3 || San Rafael, CA 94903 Telephone: 415-788-3322 4 || Facsimile: 415-788-8613 E-mail: rerlach@rayerlach.com 5 Attorneys for Defendants 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SONOMA, UNLIMITED JURISDICTION 10 a ) Il | VILLA ROSA HOMEOWNERS ) Case No. SCV-267991 ASSOCIATION, ) 12 ) Plaintiff, ) 13 ) v. ) DEFENDANT VALLEN W. COOPER'S 14 ) ACCEPTANCE OF OFFER VALLEN W. COOPER, an individual; )} TO COMPROMISE 15 | VALLEN W. COOPER, CPM, INC., ) (CCP §998) individually and dba ) 16 | COMMONWEALTH PROPERTY ) MANAGEMENT; ) 17 | COMMONWEALTH ASSOCIATION ) MANAGEMENT, INC.; ) 18 |]KELLIN A. BAKER, individually and dba) ACCURATE PROPERTY SERVICES aka ) 19 | ACCURATE ) MAINTENANCE & JANITORIAL; } 20 || CHAD W. COOPER, an individual; and ) DOES 1 through 50, } 21 ) Defendants. } Complaint Filed: March 12, 2021 22 ) Trial Date: None Set } Department: 18 23 } Judge: Honorable Jennifer V. Dollard ee Y 24 25 26 27 28 |] jpX5iCo'proof.evr4 Case No. SCV-26799| DEFENDANT V. COOPER'S ACCEPTANCE OF OFFER TO COMPROMISE (CCP §998) 1 | PETER C. De GOLIA (SBN 113103) NICHOLAS BERNATE (SBN 288187) 2 | CLEMENT, FITZPATRICK & KENWORTHY 3 3333 Mendocino Avenue, Suite 200 Santa Rosa, CA 95403 4 | Telephone: (707) 523-1181 Facsimile: (707) 546-1360 5 | pdegolia@cfk.com é nbernate@cfk.com 7 | Attorneys for Plaintiff, Villa Rosa Homeowners Association 8 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 11 COUNTY OF SONOMA 12 VILLA ROSA HOMEOWNERS Case No. SCV-267991 13 ASSOCIATION, OFFER TO COMPROMISE 14 Plaintiff, (CCP §998) 15 vs. 16 VALLEN W. COOPER, an individual; 17 VALLEN W. COOPER, CPM, INC., individually and dba COMMONWEALTH 18 | PROPERTY MANAGEMENT; 19 COMMONWEALTH ASSOCIATION MANAGEMENT, INC.; KELLIN A, 20 BAKER, individually and dba ACCURATE PROPERTY SERVICES aka 21 ACCURATE MAINTENANCE & JANITORIAL; CHAD W. COOPER, an 22 | individual; and DOES 1 through 50, 23 Defendants. 24 25 TO DEFENDANT VALLEN W. COOPER AND HER ATTORNEY OF RECORD: 26 Pursuant to Code of Civil Procedure §998, VILLA ROSA HOMEOWNERS 27 | ASSOCIATION (“Plaintiff”) hereby offers to have judgment taken in this action as follows: 28 | VALLEN W. COOPER, an individual, will pay to Plaintiff the amount of Ten Thousand Dollars OFFER TO COMPROMISE (CCP §998) TO DEFENDANT VALLEN W. COOPER ! 1 | ($10,000.00) in satisfaction of allclaims, damages, costs, expenses, attorneys’ fees and interest 2| claimed in this action as related to Defendant VALLEN W. COOPER. 3 If you accept this offer, please date and sign the acceptance form below and return to 4 | Plaintiff's counsel. 5 PLEASE TAKE NOTICE that if this offer is not accepted prior to trial or within 30 days 6 || after itis made, whichever occurs first,itshall be deemed withdrawn pursuant to CCP §998. 7 8 DATED: April 25, 2022 CLEMENT, FITZPATRICK & KENWORTHY 9 ete By: L7o™N 10 ICHOLAS J.BEBANATE Atterneys-for Plaintiff 11 Villa Rosa Homeowners Association 12 13 ACCEPTANCE OF OFFER 14 15 The undersigned accepts Plaintiff's offer to allow judgment in this action to be 16 || entered as specified above. 17 LAW OFFICES OF RAYMOND N. STELLA ERLACH DATED: Yow LAT, AOfA By:_ J \Aypiin Jb i Celek nn 19 j " Raymond Niéfiolas Stella Erlach 20 Attorney for Defendant Vallen W. Cooper, an Individual 21 22 23 24 25 26 27 28 OFFER TO COMPROMISE (CCP §998) TO DEFENDANT VALLEN W. COOPER 2 PROOF OF SERVICE 2 Iam a citizen of the United States. My business address is 3333 Mendocino Avenue, Suite | 200, Santa Rosa, California 95403. [ am employed in the County of Sonoma where this service 31) occurs. Iam over the age of 18 years and not a party to the within cause. 4 On the date set forth below, I served the attached document entitled: OF FER TO 5 |} COMPROMISE (CCP §998) as follows: 6 Oo BY MAIE: I placed each such sealed envelope, with postage thereon fully prepaid for first-class mail and mailing at Santa Rosa, California. I am readily | 7 familiar with the practice of Clement, Fitzpatrick & Kenworthy for processing of | 8 correspondence, said practice being that in the ordinary course of business, | correspondence is deposited inthe United States Postal Service the same day as it i 9 is placed for processing. 10 SJ BY ELECTRONIC SERVICE: Pursuant to Code of Civil Procedure section 1010.6 and California Rules of Court section 2.256(a)(4), Icaused such il documents to be served by an electronic filing service and/or email on this date to all parties listed below at the email address(es) listed below. My eService 12 address istdurler(@cfk.com. 13 q BY OVERNIGHT DELIVERY: Icaused such envelope(s) to be delivered on the same day to an authorized courier or driver or to a regular box or other facility 14 regularly maintained by FEDERAL EXPRESS with delivery fees provided for, | 15 addressed to the person(s) on whom itis to be served. on the interested party(ies) to the within cause addressed as follows: 16 7 Raymond Nicholas Stella Erlach Attorney for Defendants Law Offices of Raymond N. Stella Erlach 13 |] | 100 Smith Ranch Road, Suite 107 San Rafael, CA 94903-1954 19 |]| rerlach@rayerlach.com | 20 || | Courtesy copy to: 214 | Jennifer Pearl 2 Law Offices of Raymond N. Stella Erlach 100 Smith Ranch Road, Suite 107 33 San Rafael, CA 94903-1954 jpearl@rayerlach.com | 24 25 Ideclare under penalty of perjury under the laws of the State of California that the foregoing | is true and correct. 26 Executed on April 26, 2022, at Santa Rosa, California. 27 28 PATRICIA RIL URLER sweeten _— SI 75°01171 77 1 (7 SE 1 Sonoma County Superior Court Case No. SCV-267991 2 PROOF OF SERVICE BY E-MAIL 3 I,the undersigned, say: 4 I am a resident of the State of California and not a party to the within action; my 5 || business address isthe Law Offices of Raymond N. Stella Erlach, 100 Smith Ranch Road, 6 || Suite 107, San Rafael, California 94903; my e-mail address isjpearl@rayerlach.com. 7 On April 27, 2022, on behalf of Raymond N. Stella Erlach, counsel for 8 |] Vallen W. Cooper, whose electronic service address is rerlach@rayerlach.com, I served the within: | 9 DEFENDANT VALLEN W. COOPER'S ACCEPTANCE OF OFFER TO COMPROMISE | 10 (CCP §998) 11 || on the interested parties in said action by electronic service to each of the following: 2 Name of person/entity served: To electronic service address: | 13 On behalf of Villa Rosa Homeowners Association: | 4 Peter C. De Golia, Esq. pdegolia@cfk.com | 15 Nicholas Bernate, Esq. nbernate@cfk.com Clement, Fitzpatrick & Kenworthy iholmberg@cfk.com 16 tdurler@cfk.com 17 I declare under penalty of perjury under the laws of the State of California that the i 18 | foregoing is true and correct. ; An f 20 || Dated: April 27, 2022 Ih lh KL i4y A 1 jpX5‘Co'proofemonly.| i Jennifer k earl fo | 24 2 25 | 26 27 28