Preview
Exhibit A
1 PROOF OF SERVICE
2 I declare under penalty of perjury that:
3 I am a citizen of the United States and am employed in the County of Contra Costa. I am
over the age of eighteen years and not a party to the within action. My business address
4 is 2300 Contra Costa Boulevard, Suite 350, Pleasant Hill, CA 94523-2398.
5 On the date set forth below, I caused the attached DECLARATION OF B. EDWARD
MCCUTCHAN, JR., IN SUPPORT OF DEFENDANT SUNDERLAND | MCCUTCHAN,
6 INC.’S MOTION FOR PROTECTIVE ORDER to be served on the parties to this action
as follows:
7
BY MAIL.
8
I placed a true copy thereof, enclosed in a sealed envelope with postage thereon
9 fully prepaid, in the United States mail at Pleasant Hill, California, addressed to the
parties as set forth on the attached service list. C.C.P. §§ 1013(a), 2015.5.
10
11 BY ELECTRONIC SERVICE.
12 I electronically served a true copy thereof on the parties at said electronic
notification addresses as set forth on the attached service list from my electronic
13 notification address: hehmke@glattys.com. The transmission was reported as
complete and without error. C.C.P. § 1010.6(a) and C.R.C. Rule 2.251.
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15 Executed on October 20, 2021 at Pleasant Hill, California.
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17 Heidi Ehmke
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GALLOWAY, LUCCHESE,
EVERSON & PICCHI
2300 Contra Costa Blvd.,
1
Suite 350 __________________________________
Pleasant Hill, CA 94523
(925) 930-9090
SCV263456: DECLARATION OF B. ED 956-10761/HME/1211971
1
ABEL V. MCCUTCHAN
2
SONOMA COUNTY SUPERIOR COURT CASE NO. SCV263456
3
SERVICE LIST
4
5
Mr. Richard Abel Counsel for Plaintiff in propria persona
6 P. O. Box 9301
Santa Rosa, CA 95405
7 Fax:
Email: perere1@gmail.com
8
9 B. Edward McCutchan, Jr., Esq. Counsel for Defendants JIM NORD
Sunderland | McCutchan, LLP and DALE DAVIS
10 1083 Vine Street, Suite 907
Healdsburg, CA 95448
11 Fax: (707) 284-5527
Email: emccutchan@sunmclaw.com
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956-10761/HME/1211971
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SCV263456
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GALLOWAY, LUCCHESE,
EVERSON & PICCHI
2300 Contra Costa Blvd.,
2
Suite 350 __________________________________
Pleasant Hill, CA 94523
(925) 930-9090
SCV263456: DECLARATION OF B. ED 956-10761/HME/1211971
Exhibit B
IE Superior Court of California, County of Sonoma
MINUTE ORDERS
SCV-263456 - ABEL VS MCCUTCHAN, JR
Date of Hearing Vacate
March 02,2022 Courtroom 18
3:00 PM
Judicial Officer: Jennifer V Dollard Courtroom Clerk: Melissa J. Waters
Court Reporter: None
Parties Present
There are no appearances.
Law and Motion Calendar
Issues: Motion to Vacate
There being no opposition to the Court’s tentative ruling and no request for oral argument,
the Court ADOPTS its previously published tentative ruling as follows:
Tentative Ruling; The evidence presently before the Court is that moving party Defendant
Sunderland McCutchan, Inc. is in suspended status. (Decl. of Abel, Exhibit C.) A suspended
corporation may not prosecute or defend an action while its corporate rights are suspended.
(Alhambra-Shumway Mines, Inc. v. Alhambra Gold Mine Corp. (1957) 155 Cal.App.2d 46,
49; Cal. Rev. & Tax. Code § 23301.) Defendant Sunderland McCutchan, Inc. has represented
to the Court that Defendant Sunderland McCutchan, LLC was converted into it, creating one
entity. According to Corporations Code § 1158, “An entity that converts into another entity
pursuant to this chapter is.. .the same entity that existed before the conversion.” Thus, the
suspended status of Sunderland McCutchan, Inc. directly hinders its ability to request the
Court vacate the default entered against the entity it absorbed.
The hearing on the instant motion is CONTINUED to April 20, 2022 at 3:00 p.m. in
Department 18 for Defendant Sunderland McCutchan, Inc. to provide the Court information
establishing that the Corporation is not suspended or that any suspension has since been
lifted, thus giving it capacity to bring and prosecute this motion. Any such evidence should
be filed and served at least 10 days before the hearing. If Defendant fails to do so, the Court
will deny the motion for Defendant’s lack of power to file it. Alternately, Defendant may
request oral argument if it is able to file and serve by email such information prior to the
hearing on this motion. If the Court is satisfied with such proof, the Court will proceed to
hear argument from both sides on the merits of the motion.
Hearing Events/Documents Filed
- Court announces tentative decision
- The Court adopts its previously published tentative ruling
-End of Minute Order-
Generated: 3/2/2022 4:13:44 PM 1IPage
Next Hearing(s) - Information current as of March 02, 2022
March 23, 2022 3:00 PM
Motion to Compel
Courtroom 18
Dollard, Jennifer V
March 30, 2022 3:00 PM
Motion
Courtroom 18
Dollard, Jennifer V
April 20, 2022 3:00 PM
Motion
Courtroom 18
Dollard, Jennifer V
May 04,2022 3:00 PM
Judgment on Pleadings
Courtroom 18
Dollard, Jennifer V
October 07, 2022 8:30 AM
Jury Trial
Courtroom 18
Dollard, Jennifer V
For more information please contact the Clerk’s Office at (707) 521-6500 during official business hours.
www. sonoma. courts, ca.gov
Generated: 3/2/2022 4:13:44 PM 2 | P a g e
SCV-263456
PROOF OF SERVICE BY MAIL
I certify that I am an employee of the Superior Court of California, County of Sonoma,
and that my business address is 600 Administration Drive, Santa Rosa, CA 95403; that I am not
a party to this cause; that I am over the age of 18 years; that I am readily familiar with this
office’s practice for collection and processing of correspondence for mailing with the United
States Postal Service; and that on the date shown below I placed a true copy of the attached
Minute Orders in an envelope, sealed and addressed as shown below, for collection and mailing
at Santa Rosa, California, first class, postage fully prepaid, following ordinary business practices.
Date: March 02, 2022
Arlene D. Junior,
Clerk of the Court
By:
Melissa Waters, Deputy Clerk
-ADDRESSEES-
RICHARD ABEL JOSEPH S PICCHI
P O BOX 9301 GALLOWAY LUCCHESE EVERSON
SANTA ROSA CA 95405 & PICCHI
2300 CONTRA COSTA BLVD STE 350
PLEASANT HILL CA 94523-2398
B EDWARD MCCUTCHAN JR
SUNDERLAND MCCUTCHAN LLP
1083 VINE STREET SUITE 907
HEALDSBURG CA 95448
Generated: 3/2/2022 4:13:44 PM 3 | P a g e
Exhibit C
Exhibit D
Exhibit E
Delivered
Monday, April 4, 2022 9:26 AM
SACRAMENTO, CA 95814
Tracking:
9449011899561030179116
Create Return LabelFile Claim
Email Tracking Info Check Claim Status Refund Late Delivery
Addresses
Personal data removed
Shipped To:
CALIFORNIA SECRETARY OF STATE: DOCUMENT FILING SUPPORT UNIT
1500 11TH ST FL 3
SACRAMENTO, CA 95814-5701
United States
Shipped From:
95448
Return To:
Sunderland | McCutchan
1083 Vine Street # 907
Healdsburg, CA 95448
Exhibit F
From: Acredolo, Kate
To: Edward McCutchan
Cc: McClain, Wendy; Tufono, Mele; Lopez, Tricia; Petty, Anniah
Subject: RE: Accessibility Inquiry
Date: Tuesday, May 3, 2022 12:33:00 PM
Attachments: image001.png
Hello,
Unfortunately our new filing system does not include tracking for incoming paper submissions and we are unable to
provide the status of any particular submission. As of today, it does not appear that this dissolution has been filed;
however, please be aware that as a result of the transition to our new filing system we are currently experiencing
significant delays in processing times. Current processing times are provided on the Secretary of State’s Processing
Times webpage at www.sos.ca.gov/business-programs/business-entities/processing-
times. Please note that filings of this
type for FTB suspended entities may experience additional delays at this time due to a technical issue related to
modifying the suspended status.
Thank you,
Kate Acredolo
Program Technician II
Business Entities
California Secretary of State
Shirley N. Weber, Ph.D.
T: 916 695-1224
E: kate.acredolo@sos.ca.gov
bizfile.sos.ca.gov
Making it easier to do business in California!
Save money and paper by filing online.
Confidentiality Notice: This email message, including any attachments, is for the sole use of the intended
recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or
distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy
all copies of the original message.
From: Green, Michael >
Sent: Wednesday, April 27, 2022 3:18 PM
To: Corporations@sos.ca.gov
>
Subject: FW: Accessibility Inquiry
From: ADA Coordinator >
Sent: Wednesday, April 27, 2022 2:35 PM
To: Green, Michael >
Subject: Accessibility Inquiry
Short Description: status of corporate dissolition
Your Question or Comment: In late March 2022 I sent a letter with the signed application to dissolve Sunderland |
McCutchan, Inc and a FTB letter allowing such to end the FTB suspension. What is the status of the filing for the
dissolution of this entity? I cannot speak with a live person because the Secretary of State's answering machine
states employees are working from home due to COVID 19. Thank you.
Name: : Edward McCutchan
Email address: : emccutchan@sunmclaw.com
Phone number (including Area Code):: 7074330377
Company or Organization: Sunderland | McCutchan, Inc.
Mailing address:: 1083 Vine Street # 907 Healdsburg, CA 95448
City:: Healdsburg
State:: CA
ZIP code:: 95448
_____
Regards,
Accessibility Coordinator
California Secretary of State
1 PROOF OF SERVICE
2 I declare under penalty of perjury that:
3 I am a citizen of the United States and am employed in the County of Contra Costa. I am
over the age of eighteen years and not a party to the within action. My business address
4 is 2300 Contra Costa Boulevard, Suite 350, Pleasant Hill, CA 94523-2398.
5 On the date set forth below, I caused the attached SUPPLEMENTAL DECLARATION
OF B. EDWARD MCCUTCHAN, JR., IN SUPPORT OF DEFENDANT SUNDERLAND |
6 MCCUTCHAN, INC.'S MOTION TO SET ASIDE DEFAULT OF SUNDERLAND
MCCUTCHAN, LLC to be served on the parties to this action as follows:
7
BY MAIL. *as to plaintiff
8
I placed a true copy thereof, enclosed in a sealed envelope with postage thereon
9 fully prepaid, in the United States mail at Pleasant Hill, California, addressed to the
parties as set forth on the attached service list. C.C.P. §§ 1013(a), 2015.5.
10
11 BY ELECTRONIC SERVICE.
12 I electronically served a true copy thereof on the parties at said electronic
notification addresses as set forth on the attached service list from my electronic
13 notification address: hehmke@glattys.com. The transmission was reported as
complete and without error. C.C.P. § 1010.6(a) and C.R.C. Rule 2.251.
14
15
16 Executed on May 6, 2022 at Pleasant Hill, California.
17
18 Heidi Ehmke
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GALLOWAY, LUCCHESE, __________________________________
EVERSON & PICCHI
SCV263456:
2300 Contra Costa Blvd.,
SUPPLEMENTAL DECLARATION OF B. EDWARD MCCUTCHAN, JR., 956-10761/HME/1239180
Suite 350 IN SUPPORT OF DEFENDANT SUNDERLAND | MCCUTCHAN, INC.'S MOTION TO
Pleasant Hill, CA 94523
(925) 930-9090
SET ASIDE DEFAULT OF SUNDERLAND MCCUTCHAN, LLC
1
ABEL V. MCCUTCHAN
2
SONOMA COUNTY SUPERIOR COURT CASE NO. SCV263456
3
SERVICE LIST
4
5
Mr. Richard Abel Counsel for Plaintiff in propria persona
6 P. O. Box 9301
Santa Rosa, CA 95405
7 Fax:
Email: perere1@gmail.com
8
9 B. Edward McCutchan, Jr., Esq. Counsel for Defendants JIM NORD
Sunderland | McCutchan, LLP and DALE DAVIS
10 1083 Vine Street, Suite 907
Healdsburg, CA 95448
11 Fax: (707) 284-5527
Email: emccutchan@sunmclaw.com
12
13
956-10761/HME/1239180
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SCV263456
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GALLOWAY, LUCCHESE, __________________________________
EVERSON & PICCHI
SCV263456:
2300 Contra Costa Blvd.,
SUPPLEMENTAL DECLARATION OF B. EDWARD MCCUTCHAN, JR., 956-10761/HME/1239180
Suite 350 IN SUPPORT OF DEFENDANT SUNDERLAND | MCCUTCHAN, INC.'S MOTION TO
Pleasant Hill, CA 94523
(925) 930-9090
SET ASIDE DEFAULT OF SUNDERLAND MCCUTCHAN, LLC
Preview
Exhibit A 1 PROOF OF SERVICE 2 I declare under penalty of perjury that: 3 I am a citizen of the United States and am employed in the County of Contra Costa. I am over the age of eighteen years and not a party to the within action. My business address 4 is 2300 Contra Costa Boulevard, Suite 350, Pleasant Hill, CA 94523-2398. 5 On the date set forth below, I caused the attached DECLARATION OF B. EDWARD MCCUTCHAN, JR., IN SUPPORT OF DEFENDANT SUNDERLAND | MCCUTCHAN, 6 INC.’S MOTION FOR PROTECTIVE ORDER to be served on the parties to this action as follows: 7 BY MAIL. 8 I placed a true copy thereof, enclosed in a sealed envelope with postage thereon 9 fully prepaid, in the United States mail at Pleasant Hill, California, addressed to the parties as set forth on the attached service list. C.C.P. §§ 1013(a), 2015.5. 10 11 BY ELECTRONIC SERVICE. 12 I electronically served a true copy thereof on the parties at said electronic notification addresses as set forth on the attached service list from my electronic 13 notification address: hehmke@glattys.com. The transmission was reported as complete and without error. C.C.P. § 1010.6(a) and C.R.C. Rule 2.251. 14 15 Executed on October 20, 2021 at Pleasant Hill, California. 16 17 Heidi Ehmke 18 19 20 21 22 23 24 25 26 27 28 GALLOWAY, LUCCHESE, EVERSON & PICCHI 2300 Contra Costa Blvd., 1 Suite 350 __________________________________ Pleasant Hill, CA 94523 (925) 930-9090 SCV263456: DECLARATION OF B. ED 956-10761/HME/1211971 1 ABEL V. MCCUTCHAN 2 SONOMA COUNTY SUPERIOR COURT CASE NO. SCV263456 3 SERVICE LIST 4 5 Mr. Richard Abel Counsel for Plaintiff in propria persona 6 P. O. Box 9301 Santa Rosa, CA 95405 7 Fax: Email: perere1@gmail.com 8 9 B. Edward McCutchan, Jr., Esq. Counsel for Defendants JIM NORD Sunderland | McCutchan, LLP and DALE DAVIS 10 1083 Vine Street, Suite 907 Healdsburg, CA 95448 11 Fax: (707) 284-5527 Email: emccutchan@sunmclaw.com 12 13 956-10761/HME/1211971 14 SCV263456 15 16 17 18 19 20 21 22 23 24 25 26 27 28 GALLOWAY, LUCCHESE, EVERSON & PICCHI 2300 Contra Costa Blvd., 2 Suite 350 __________________________________ Pleasant Hill, CA 94523 (925) 930-9090 SCV263456: DECLARATION OF B. ED 956-10761/HME/1211971 Exhibit B IE Superior Court of California, County of Sonoma MINUTE ORDERS SCV-263456 - ABEL VS MCCUTCHAN, JR Date of Hearing Vacate March 02,2022 Courtroom 18 3:00 PM Judicial Officer: Jennifer V Dollard Courtroom Clerk: Melissa J. Waters Court Reporter: None Parties Present There are no appearances. Law and Motion Calendar Issues: Motion to Vacate There being no opposition to the Court’s tentative ruling and no request for oral argument, the Court ADOPTS its previously published tentative ruling as follows: Tentative Ruling; The evidence presently before the Court is that moving party Defendant Sunderland McCutchan, Inc. is in suspended status. (Decl. of Abel, Exhibit C.) A suspended corporation may not prosecute or defend an action while its corporate rights are suspended. (Alhambra-Shumway Mines, Inc. v. Alhambra Gold Mine Corp. (1957) 155 Cal.App.2d 46, 49; Cal. Rev. & Tax. Code § 23301.) Defendant Sunderland McCutchan, Inc. has represented to the Court that Defendant Sunderland McCutchan, LLC was converted into it, creating one entity. According to Corporations Code § 1158, “An entity that converts into another entity pursuant to this chapter is.. .the same entity that existed before the conversion.” Thus, the suspended status of Sunderland McCutchan, Inc. directly hinders its ability to request the Court vacate the default entered against the entity it absorbed. The hearing on the instant motion is CONTINUED to April 20, 2022 at 3:00 p.m. in Department 18 for Defendant Sunderland McCutchan, Inc. to provide the Court information establishing that the Corporation is not suspended or that any suspension has since been lifted, thus giving it capacity to bring and prosecute this motion. Any such evidence should be filed and served at least 10 days before the hearing. If Defendant fails to do so, the Court will deny the motion for Defendant’s lack of power to file it. Alternately, Defendant may request oral argument if it is able to file and serve by email such information prior to the hearing on this motion. If the Court is satisfied with such proof, the Court will proceed to hear argument from both sides on the merits of the motion. Hearing Events/Documents Filed - Court announces tentative decision - The Court adopts its previously published tentative ruling -End of Minute Order- Generated: 3/2/2022 4:13:44 PM 1IPage Next Hearing(s) - Information current as of March 02, 2022 March 23, 2022 3:00 PM Motion to Compel Courtroom 18 Dollard, Jennifer V March 30, 2022 3:00 PM Motion Courtroom 18 Dollard, Jennifer V April 20, 2022 3:00 PM Motion Courtroom 18 Dollard, Jennifer V May 04,2022 3:00 PM Judgment on Pleadings Courtroom 18 Dollard, Jennifer V October 07, 2022 8:30 AM Jury Trial Courtroom 18 Dollard, Jennifer V For more information please contact the Clerk’s Office at (707) 521-6500 during official business hours. www. sonoma. courts, ca.gov Generated: 3/2/2022 4:13:44 PM 2 | P a g e SCV-263456 PROOF OF SERVICE BY MAIL I certify that I am an employee of the Superior Court of California, County of Sonoma, and that my business address is 600 Administration Drive, Santa Rosa, CA 95403; that I am not a party to this cause; that I am over the age of 18 years; that I am readily familiar with this office’s practice for collection and processing of correspondence for mailing with the United States Postal Service; and that on the date shown below I placed a true copy of the attached Minute Orders in an envelope, sealed and addressed as shown below, for collection and mailing at Santa Rosa, California, first class, postage fully prepaid, following ordinary business practices. Date: March 02, 2022 Arlene D. Junior, Clerk of the Court By: Melissa Waters, Deputy Clerk -ADDRESSEES- RICHARD ABEL JOSEPH S PICCHI P O BOX 9301 GALLOWAY LUCCHESE EVERSON SANTA ROSA CA 95405 & PICCHI 2300 CONTRA COSTA BLVD STE 350 PLEASANT HILL CA 94523-2398 B EDWARD MCCUTCHAN JR SUNDERLAND MCCUTCHAN LLP 1083 VINE STREET SUITE 907 HEALDSBURG CA 95448 Generated: 3/2/2022 4:13:44 PM 3 | P a g e Exhibit C Exhibit D Exhibit E Delivered Monday, April 4, 2022 9:26 AM SACRAMENTO, CA 95814 Tracking: 9449011899561030179116 Create Return LabelFile Claim Email Tracking Info Check Claim Status Refund Late Delivery Addresses Personal data removed Shipped To: CALIFORNIA SECRETARY OF STATE: DOCUMENT FILING SUPPORT UNIT 1500 11TH ST FL 3 SACRAMENTO, CA 95814-5701 United States Shipped From: 95448 Return To: Sunderland | McCutchan 1083 Vine Street # 907 Healdsburg, CA 95448 Exhibit F From: Acredolo, Kate To: Edward McCutchan Cc: McClain, Wendy; Tufono, Mele; Lopez, Tricia; Petty, Anniah Subject: RE: Accessibility Inquiry Date: Tuesday, May 3, 2022 12:33:00 PM Attachments: image001.png Hello, Unfortunately our new filing system does not include tracking for incoming paper submissions and we are unable to provide the status of any particular submission. As of today, it does not appear that this dissolution has been filed; however, please be aware that as a result of the transition to our new filing system we are currently experiencing significant delays in processing times. Current processing times are provided on the Secretary of State’s Processing Times webpage at www.sos.ca.gov/business-programs/business-entities/processing- times. Please note that filings of this type for FTB suspended entities may experience additional delays at this time due to a technical issue related to modifying the suspended status. Thank you, Kate Acredolo Program Technician II Business Entities California Secretary of State Shirley N. Weber, Ph.D. T: 916 695-1224 E: kate.acredolo@sos.ca.gov bizfile.sos.ca.gov Making it easier to do business in California! Save money and paper by filing online. Confidentiality Notice: This email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. From: Green, Michael > Sent: Wednesday, April 27, 2022 3:18 PM To: Corporations@sos.ca.gov > Subject: FW: Accessibility Inquiry From: ADA Coordinator > Sent: Wednesday, April 27, 2022 2:35 PM To: Green, Michael > Subject: Accessibility Inquiry Short Description: status of corporate dissolition Your Question or Comment: In late March 2022 I sent a letter with the signed application to dissolve Sunderland | McCutchan, Inc and a FTB letter allowing such to end the FTB suspension. What is the status of the filing for the dissolution of this entity? I cannot speak with a live person because the Secretary of State's answering machine states employees are working from home due to COVID 19. Thank you. Name: : Edward McCutchan Email address: : emccutchan@sunmclaw.com Phone number (including Area Code):: 7074330377 Company or Organization: Sunderland | McCutchan, Inc. Mailing address:: 1083 Vine Street # 907 Healdsburg, CA 95448 City:: Healdsburg State:: CA ZIP code:: 95448 _____ Regards, Accessibility Coordinator California Secretary of State 1 PROOF OF SERVICE 2 I declare under penalty of perjury that: 3 I am a citizen of the United States and am employed in the County of Contra Costa. I am over the age of eighteen years and not a party to the within action. My business address 4 is 2300 Contra Costa Boulevard, Suite 350, Pleasant Hill, CA 94523-2398. 5 On the date set forth below, I caused the attached SUPPLEMENTAL DECLARATION OF B. EDWARD MCCUTCHAN, JR., IN SUPPORT OF DEFENDANT SUNDERLAND | 6 MCCUTCHAN, INC.'S MOTION TO SET ASIDE DEFAULT OF SUNDERLAND MCCUTCHAN, LLC to be served on the parties to this action as follows: 7 BY MAIL. *as to plaintiff 8 I placed a true copy thereof, enclosed in a sealed envelope with postage thereon 9 fully prepaid, in the United States mail at Pleasant Hill, California, addressed to the parties as set forth on the attached service list. C.C.P. §§ 1013(a), 2015.5. 10 11 BY ELECTRONIC SERVICE. 12 I electronically served a true copy thereof on the parties at said electronic notification addresses as set forth on the attached service list from my electronic 13 notification address: hehmke@glattys.com. The transmission was reported as complete and without error. C.C.P. § 1010.6(a) and C.R.C. Rule 2.251. 14 15 16 Executed on May 6, 2022 at Pleasant Hill, California. 17 18 Heidi Ehmke 19 20 21 22 23 24 25 26 27 28 1 GALLOWAY, LUCCHESE, __________________________________ EVERSON & PICCHI SCV263456: 2300 Contra Costa Blvd., SUPPLEMENTAL DECLARATION OF B. EDWARD MCCUTCHAN, JR., 956-10761/HME/1239180 Suite 350 IN SUPPORT OF DEFENDANT SUNDERLAND | MCCUTCHAN, INC.'S MOTION TO Pleasant Hill, CA 94523 (925) 930-9090 SET ASIDE DEFAULT OF SUNDERLAND MCCUTCHAN, LLC 1 ABEL V. MCCUTCHAN 2 SONOMA COUNTY SUPERIOR COURT CASE NO. SCV263456 3 SERVICE LIST 4 5 Mr. Richard Abel Counsel for Plaintiff in propria persona 6 P. O. Box 9301 Santa Rosa, CA 95405 7 Fax: Email: perere1@gmail.com 8 9 B. Edward McCutchan, Jr., Esq. Counsel for Defendants JIM NORD Sunderland | McCutchan, LLP and DALE DAVIS 10 1083 Vine Street, Suite 907 Healdsburg, CA 95448 11 Fax: (707) 284-5527 Email: emccutchan@sunmclaw.com 12 13 956-10761/HME/1239180 14 SCV263456 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 GALLOWAY, LUCCHESE, __________________________________ EVERSON & PICCHI SCV263456: 2300 Contra Costa Blvd., SUPPLEMENTAL DECLARATION OF B. EDWARD MCCUTCHAN, JR., 956-10761/HME/1239180 Suite 350 IN SUPPORT OF DEFENDANT SUNDERLAND | MCCUTCHAN, INC.'S MOTION TO Pleasant Hill, CA 94523 (925) 930-9090 SET ASIDE DEFAULT OF SUNDERLAND MCCUTCHAN, LLC