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1 Collin J. Vierra (State Bar No. 322720)
EIMER STAHL LLP
2
99 Almaden Blvd., Suite 642
3 San Jose, CA 95113-1605
Telephone: (408) 889-1668
4
Email: cvierra@eimerstahl.com
5
Attorney for Plaintiffs
6
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
COUNTY OF SAN MATEO
9
10
11 Robert Arntsen; Mary Lee; Arntsen Case No. 22-CIV-01148
Family Partnership, LP; and Brian
12 Christopher Dunn Custodianship; Dept. 21
13
Plaintiffs, Hon. Robert D. Foiles
14 v.
15 AFFIDAVIT OF
David M. Bragg; Kurtis Stuart Kludt; COLLIN J. VIERRA
16 Silicon Valley Real Ventures LLC;
17 SVRV 385 Moore, LLC; SVRV 387
Moore, LLC; Gregory J. Davis;
18 Paramont Woodside, LLC; and
19 Paramont Capital, LLC;
20 Defendants.
21
22
23
24
25
26
27
28 1
AFFIDAVIT OF COLLIN J. VIERRA
1 I, Collin James Vierra, attest as follows:
2
1. I am over 18 years of age, of sound mind, and otherwise competent to
3
make this Affidavit.
4
2. I am not a party to this action.
5
3. I am an attorney at Eimer Stahl, LLP, and am Plaintiffs’ counsel of
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record in this action.
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4. On March 16, 2022, I engaged Process Server One to serve Defendant
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David M. Bragg and the other Defendants. On March 21, 2022, Process Server
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One provided me with a Proof of Service indicating that it had served Mr. Bragg
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on March 17, 2022 at one of his places of employment, the Menlo Park Fire
11
Protection District, Station 77, located at 1467 Chilco Street, Menlo Park,
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California 94025. That Proof of Service is attached as Exhibit A.
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5. Because in the course of serving the Defendants, Process Server One
14
provided me with several Proofs of Service that I believed had been prepared
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incorrectly, I instructed my paralegal, Mina Al-Ansari, to re-serve each of the
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Defendants, including Mr. Bragg, by mail, to ensure service was completed
17
correctly.
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6. On April 8, 2022, at my instruction, Ms. Al-Ansari mailed the service
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papers to Mr. Bragg at the Menlo Park Fire Protection District, located at 170
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Middlefield Road, Menlo Park, California 94025, which according to Mr. Bragg’s
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LinkedIn page is his current place of employment. A printout of Mr. Bragg’s
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LinkedIn page is attached as Exhibit B. Tracking information confirms these
23
papers were delivered successfully. The tracking information is attached as Exhibit
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C. The Proof of Service for this mailing is attached as Exhibit D.
25
7. Having not received a response from Mr. Bragg, on April 29, 2022, at
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my instruction, Ms. Al-Ansari mailed additional copies of the service papers to Mr.
27
28 2
AFFIDAVIT OF COLLIN J. VIERRA
1 Bragg at Silicon Valley Real Ventures, LLC (“SVRV”), located at 205
2 Constitution Drive, Menlo Park, California 99025, which according to Mr. Bragg’s
3 LinkedIn page is his other current place of employment. See Exhibit B. A printout
4 of SVRV’s website confirming its address is attached as Exhibit E. According to
5 the United States Postal Service, no one was present at SVRV’s business address
6 during each delivery attempt. The tracking information is attached as Exhibit F.
7 The Proof of Service for this mailing is attached as Exhibit G.
8 8. Having still not received a response from Mr. Bragg, on May 12,
9 2022, I contacted Mr. Bragg both by electronic mail at his email address that he
10 uses for SVRV business, and by telephone at the phone number that he uses for
11 SVRV business. I attached the service papers to the email. Mr. Bragg did not
12 answer his phone, so I left him a voicemail informing him of our attempts to reach
13 him and our need for a prompt response. An email from Mr. Bragg to Plaintiff
14 Robert Arntsen showing Mr. Bragg’s email address and phone number in his
15 signature block is attached as Exhibit H. My email to Mr. Bragg is attached as
16 Exhibit I. A screenshot from my cell phone showing that I placed a 1 minute, 11
17 second phone call to Mr. Bragg’s number on May 12, 2022 is attached as Exhibit J.
18 9. Having still not received a response from Mr. Bragg, on May 13,
19 2022, I signed up for a trial of LinkedIn premium, on which platform I sent Mr.
20 Bragg a message informing him of our attempts to reach him and our need for a
21 prompt response. My LinkedIn message to Mr. Bragg is attached as Exhibit K.
22 10. Also on May 13, 2022, at my instruction, Ms. Al-Ansari mailed
23 additional copies of the service papers to Mr. Bragg at his last-known home
24 address, which was provided to me by Mr. Bragg’s co-Defendant and fellow
25 Managing Director of SVRV, Kurtis M. Kludt. Mr. Bragg signed for this delivery
26 on May 16, 2022. The signature confirmation is attached as Exhibit L.
27 11. In or around the first week of May 2022, the webpage for Silicon
28 3
AFFIDAVIT OF COLLIN J. VIERRA
Valh:y Real Ventures, realsv.com, was taken down. On information and belief, Mr.
2 Bragg removed this website after being served in this action. According to Mr.
3 Kludt, with whom I have been in periodic contact since Plaintiffs initiated this
4 action, Mr. Bragg controls the realsv.com website.
5 12. According to Mr. Kludt, Mr. Bragg has spoken with Mr. Kludt about
6 this action since being served.
7 13. Plaintiffs have incurred significant expense in serving Mr. Bragg.
8 14. Mr. Bragg still has not responded.
9
10 I declare under penalty of perjury under the laws of the State of California that
11
the foregoing is true and correct.
12
13
14 Dated: May 16, 2022
Collin J. Vierra
15
16
EIMER STAI-ll.., LLP .I
I
17 Attorney for Plaintiffs Robert
Arntsen, Mary Lee, the Arntsen
18
Family Partnership, LP, and the
19 Brian Christopher Dunn
Custodianship
20
21
22
23
24
25
26
27
28
4
AFFIDAVIT OF COLLIN J. VIERRA
Exhibit A
POS-010
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Collin James Vierra SBN 322720
Collin James Vierra - Eimer Stahl LLP
99 S. Almaden Blvd. 641
San Jose, CA 95113
TELEPHONE NO.: (831) 917-8266 FAX NO. (Optional):
E-MAIL ADDRESS (Optional):
ATTORNEY FOR (Name): Plaintiff
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO - REDWOOD CITY (EFILING)
STREET ADDRESS: 400 County Center
MAILING ADDRESS: 400 County Center
CITY AND ZIP CODE: Redwood City, CA 94063
BRANCH NAME: SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO -
REDWOOD CITY (EFILING)
PLAINTIFF/PETITIONER: ARNTSEN FAMILY PARTNERSHIP, LP CASE NUMBER:
22-CIV-01148
DEFENDANT/RESPONDENT: SILICON VALLEY REAL VENTURES, LLC
Ref. No. or File No.:
PROOF OF SERVICE SUMMONS 0000
(Separate proof of service is required for each party served.)
1. At the time of service I was at least 18 years of age and not a party to this action.
2. I served copies of: Complaint; Civil Case Cover Sheet; Summons - Brag; Summons - Kludt; Summons - Davis; Summons -
SVRV; Summons - SVRV 385 Moore; Summons - SVRV 387 Moore; Summons - Paramont Capital;
Summons - Paramont Woodside
3. a. Party served (specify name of party as shown on documents served): David M. Bragg
b. Person (other than the party in item 3a) served on behalf of an entity or as an authorized agent (and not a person
D under item 5b on whom substituted service was made) (specify name and relationship to the party named in item 3a):
4. Address where the party was served: 1467 Chilco St, Menlo Park, CA 94025
5. I served the party (check proper b ox)
a. by personal service. I personally delivered the documents listed in item 2 to the party or person authorized to receive
service of process for the party (1) on:(2) at:
b. by substituted service. On: at: I left the documents listed in item 2 with or in the presence of (name and title or
relationship to person indicated in item 3):
(1) (business) a person at least 18 years of age apparently in charge at the office or usual place of business
D of the person to be served. I informed him or her of the general nature of the papers.
(2) (home) a competent member of the household (at least 18 years of age) at the dweling house or usual
D place of abode of the party. I informed him or her of the general nature of the papers.
(3) (physical address unknown) a person of at least 18 years of age apparently in charge at the usual
D mailing address of the person to be served, other than a United States Postal Service post office box. I
informed him or her of the general nature of the papers.
(4) I thereafter mailed (by first-class, postage prepaid) copies of the documents to the person to be served at
□ the place where the copies were left (Code Civ. Proc., § 415.20). I mailed the documents:
Page 1 of 3
POS-010 [Rev. January 1, 2007] PROOF OF SERVICE OF SUMMONS
Invoice # 5657757-02
PLAINTIFF/PETITIONER: ARNTSEN FAMILY PARTNERSHIP, LP CASE NUMBER:
DEFENDANT/RESPONDENT: SILICON VALLEY REAL VENTURES, LLC 22-CIV-01148
on: from: or a declaration of mailing is attached.
(5) I attach a declaration of diligence stating actions taken first to attempt personal service.
5. c. by mail and acknowledgment of receipt of service. I mailed the documents listed in item 2 to the party, to the
address shown in item 4, by first-class mail, postage prepaid,
(1) on: (2) from:
(3) with two copies of the Notice and Acknowledgment of Receipt and a postage-paid return envelope
addressed to me. (Attach completed Notice and Acknowledgment of Receipt.) (Code Civ. Proc., § 415.30.)
(4) to an address outside California with return receipt requested. (Code Civ. Proc., § 415.40.)
d. by other means (specify means of service and authorizing code section):
Additional page describing service is attached.
6. The "Notice to the Person Served" (on the summons) was completed as follows:
a. as an individual defendant.
b. as the person sued under the fictitious name of (specify):
c. as occupant.
d. On behalf of (specify): David M. Bragg
under the following Code of Civil Procedure section:
416.10 (corporation) 415.95 (business organization, form unknown)
416.20 (defunct corporation) 416.60 (minor)
416.30 (joint stock 416.70 (ward or conservatee)
company/association)
416.40 (association or partnership) 416.90 (authorized person)
416.50 (public entity) 415.46 (occupant)
other:
7. Person who served papers
a. Name: Ellenor Rios
b. Address: 555 Anton Blvd 150, Costa Mesa, CA 92626
c. Telephone number: 855-545-1303
d. The fee for service was: $115.00
e. I am:
(1) not a registered California process server.
(2) exempt from registration under Business and Professions Code section 22350(b).
(3) a registered California process server:
(i) owner employee independent contractor.
(ii) Registration No.:
(iii) County: 0
POS-010 [Rev. January 1, 2007] Page 2 of 3
PROOF OF SERVICE OF SUMMONS
Invoice #: 5657757-02
PLAINTIFF/PETITIONER: ARNTSEN FAMILY PARTNERSHIP, LP CASE NUMBER:
DEFENDANT/RESPONDENT: SILICON VALLEY REAL VENTURES, LLC 22-CIV-01148
8. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Ellenor Rios
Ellenor Rios Date: 03/17/2022
POS-010 [Rev. January 1, 2007] Page 3 of 3
PROOF OF SERVICE OF SUMMONS
Invoice #: 5657757-02
Exhibit B
3/18/22, 1:46 PM (2) Experience | Dave Bragg | LinkedIn
2
Home My Network Jobs Messaging Notifications Me Work
Dave Bragg
Message Connect
Engineer/Acting Captain at Menlo Park Fire Protection …
Experience
Engineer/Acting Captain
Menlo Park Fire Protection District · Full-time
Nov 2003 - Present · 18 yrs 5 mos
Menlo Park, California, United States
Managing Director/CEO of Silicon Valley Real Estate Ventures
BRE#01997389
Silicon Valley Real Ventures
Jul 2014 - Present · 7 yrs 9 mos
Menlo Park, CA
Silicon Valley Real Ventures offers international investors access to the
Silicon Valley economy. We invest in a high end single family, multi family
and commercial real estate. We are a diverse team of professionals sharing
Silicon Valley opportunities with the world.
Silicon Valley Real Ventures
SVRV (Silicon Valley Real Ventures) is a fully integrated
Private Equity firm with specializations in Venture Capit…
Founding Partner
VIP Car Vault LLC
Apr 2013 - Jun 2017 · 4 yrs 3 mos
Redwood City, CA
Built the business around VIP car storage. In a partnership with
AutoVino.org we offer VIP car storage. Our brilliant partners continue the
work.
Founding Partner/CEO
https://www.linkedin.com/in/davebraggsvrv/details/experience/ 1/3
3/18/22, 1:46 PM (2) Experience | Dave Bragg | LinkedIn
California Luxury Properties & Development LLC 2
Jul 2012 - Jul 2014 · 2 yrs 1 mo
Home My Network Jobs Messaging Notifications Me Work
Menlo Park, California
California Luxury Properties & Development offers investment opportunities
in luxury homes in Silicon Valley.
Founder and CEO
Thor Construction
May 2009 - Sep 2013 · 4 yrs 5 mos
Menlo Park, CA
Built and grew this real estate construction company from 1 to 40
employees with 200 clients over a four-year period. Invested in and raised
financing for 20+ real estate projects. Notable clients include executives at
Apple, Google, Facebook, LinkedIn, Yahoo, and eBay. Projects included both
residential and commercial, small, and large construction projects.
Founder/CEO
Bragg Investment Group, LLC
May 2006 - May 2010 · 4 yrs 1 mo
CA & TX
Privately held company that purchased, managed, and maintained
residential real estate assets. We operated in Menlo Park, San Mateo, Santa
Barbara County, Laguna Niguel, Orange County, Solvang, and Lompoc
(California) and in Austin and Killeen (Texas).
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https://www.linkedin.com/in/davebraggsvrv/details/experience/ 2/3
3/18/22, 1:46 PM (2) Experience | Dave Bragg | LinkedIn
LinkedIn Corporation © 2022 2
Home My Network Jobs Messaging Notifications Me Work
https://www.linkedin.com/in/davebraggsvrv/details/experience/ 3/3
Exhibit C
April 8, 2022 U.S. Certified Mail Receipt to David Bragg
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Exhibit D
Exhibit E
PROPERTY LISTINGS
AVAILABLE (/AVAILABLE-LISTINGS)
SOLD (/SOLD-LISTINGS)
CUSTOM HOMES (/CUSTOM-HOMES)
DEVELOPMENT (/DEVELOPMENT)
ABOUT (/ABOUT)
D AV E BRAGG
Dave was born and raised in a Real Estate Development family
and started working in the industry in 1989. Dave made his first
investment in real estate at the age of 21. His geographical focus
has been Northern and Southern California, Texas, and Oregon.
Dave has worked in Silicon Valley since 1998 and is actively
involved in the Bay Area community.
Dave Bragg is the managing partner at Silicon Valley Real
Ventures. He oversees the daily operations of the firm and is
responsible for raising capital, evaluating investment dealflow and
setting strategic vision for SVRV shareholders. His main focus is
identifying and executing on innovative investment strategies.
Dave has over 15 years of experience in real estate investing, fund
management and operations.
Dave is a consummate entrepreneur, having financed and
developed over $100 million of real estate during his career. He
continues to invest in California and International real estate and
has successfully raised financing for 25+ projects. Dave lives with
his family in Atherton, CA where he is active in community service
and philanthropy. In the past, he has served as a state licensed
General Contractor (Builder) where he scaled his Silicon Valley
construction company from 1 to 40 employees with 200 clients
over a four-year period. Notable clients include individuals from
Apple, Google, Facebook, LinkedIn, Yahoo, eBay and many from
the Venture Capital community. He has worked as firefighter in
the community for over 10 years. In 2003, he was deployed to the
Middle East, where he was among the first group of Marines to
lead the ground invasion into Iraq.
Dave volunteers hundreds of hours each year to serve the local
community. He has served on the Menlo-Atherton Little League
Baseball Board of Directors, the Menlo-Atherton Pop Warner
Football Board of Directors, coaches youth baseball, soccer and
football, volunteers as a fundraiser for Jerry’s Kids, co-chairs the
Menlo Park food and toy drive, serves as a house captain for
Rebuilding Together Peninsula, and is a donor-builder for Dreams
Happen Playhouse.
KURTIS KLUDT
Kurtis was born and raised in Silicon Valley. Kurtis is a financial
engineer in the public equity markets and residential property
market. He is CEO of ANA Holdings (Angel Networking Access), a
diversified management and consulting company. Kurtis handles
public equities, real estate and start-up investments.
Kurtis is an avid researcher and analyst of public equity markets,
investment opportunities, and new technologies. He is an angel
investor and a financial adviser. He is an avid follower of the real
estate market in Silicon Valley and brings a strong track record in
investor fund acquisition. $100M of public equities transacted
since inception with Charles Schwab and Interactive Brokers.
Specialty research areas of fund management: real estate,
dividend income, growth stocks, commodities, IPOs, and the
technology sector.
Kurtis works with and supports non-profit organizations such as
the National Multiple Sclerosis Society, Leukemia & Lymphoma
Society, and Poppy Foundation Animal Hospital.
Kurtis graduated with honors from the UCLA College of Letters
and Science in conjunction with the Anderson School of
Management, where he earned his B.S. degree in Business
Economics.
.
PETE SAMIS
Pete Samis was born in San Jose, CA where his dad worked as a
general contractor building custom homes in Saratoga and Los
Gatos. When Pete was 10 years old he started to work for his
dad during the summer earning 25 cents a hour. After high school
he joined the Airforce and was stationed in Las Vegas where he
worked as a Carpenter Specialist.
After working on residential and commercial projects in in Las
Vegas for 20 years, including for celebrities including Robert
Goulet, Jerry Lewis, Liberace and Wayne Newton and on large
public works projects on the UNLV campus and at city hall, Pete
returned to the Bay Area with Cupertino Kitchen Design (Remodel
West) and American Kitchen & Bath. As the General Manager of
Thor Construction from 2011-213, Pete led more than 25 full house
remodel projects. During his time at Silicon Valley Real Ventures
as Vice President of Construction he has worked on numerous
development deals in the capacity of a project manager, general
contractor, and construction supervision.
Contact Us
Please get in touch if you would like to learn about how we can help you build OUR OFFICE
your own dream home, or how one of our developments could be a good fit
205 Constitution Dr
for you!
Menlo Park, CA 94025
Name *
First Name Last Name
Email Address *
Subject *
Message *
(https://maps.google.com/maps?
7.4832688,-122.1700815,12z/data=!10m1!1e1!12b1?source=apiv3&rapsrc=apiv3)
2 km
ll=37.483269,-122.170081&z=12&t=m&hl=en&gl=US&mapclient=apiv3)
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SEND MESSAGE
In the Community
SVRV values its deep connection in the local community.
DREAMS HAPPEN 2 017 P L AY H O U S : FIREHOUSE
Since 1993, Stanford Shopping Center has hosted and produced the biennial Dreams
Happen event benefiting Rebuilding Together Peninsula. Playhouses have sold for amounts
ranging from $13,000 to $101,000.
In 2017 the SVRV staff helped local firefighters build "Station 2," a classically themed
firehouse.
DREAMS HAPPEN 2 0 15 P L AY H O U S : FIRE LO O KO U T
SVRV contributes materials and our staff’s labor every second year to help build a Fire
House themed playhouse designed by Larry Kahle & John Onken and built buy San Mateo
County Firefighters, IAFF Local 2400.
In 2015 the fire-themed playhouse was styled after the wildland fire lookout towers
HOMER FIELD AT WILLIE M AYS B A L L PA R K
SVRV built the new stadium for Atherton's Homer Field at Willie Mays Ballpark, completed
in 2015
PROPERTY L I ST I N G S
AVA I L A B L E( / AVA I L A B L E - L I S T I N G S )
SOLD ( / S O L D - L I ST I N G S )
C U STO M HOMES ( / C U STO M - H O M E S )
D E V E LO P M E N T ( / D E V E LO P M E N T )
[ABOUT] (/ABOUT)
S V R V, 16 5 C O N ST I T U T I O N
DRIVE, M E N LO PA R K , CA, 94 0 2 5 ,UNITED S TAT E S
Exhibit F
April 29, 2022 U.S. Certified Mail Receipt to David Bragg
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1 Collin J. Vierra (State Bar No. 322720) EIMER STAHL LLP 2 99 Almaden Blvd., Suite 642 3 San Jose, CA 95113-1605 Telephone: (408) 889-1668 4 Email: cvierra@eimerstahl.com 5 Attorney for Plaintiffs 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF SAN MATEO 9 10 11 Robert Arntsen; Mary Lee; Arntsen Case No. 22-CIV-01148 Family Partnership, LP; and Brian 12 Christopher Dunn Custodianship; Dept. 21 13 Plaintiffs, Hon. Robert D. Foiles 14 v. 15 AFFIDAVIT OF David M. Bragg; Kurtis Stuart Kludt; COLLIN J. VIERRA 16 Silicon Valley Real Ventures LLC; 17 SVRV 385 Moore, LLC; SVRV 387 Moore, LLC; Gregory J. Davis; 18 Paramont Woodside, LLC; and 19 Paramont Capital, LLC; 20 Defendants. 21 22 23 24 25 26 27 28 1 AFFIDAVIT OF COLLIN J. VIERRA 1 I, Collin James Vierra, attest as follows: 2 1. I am over 18 years of age, of sound mind, and otherwise competent to 3 make this Affidavit. 4 2. I am not a party to this action. 5 3. I am an attorney at Eimer Stahl, LLP, and am Plaintiffs’ counsel of 6 record in this action. 7 4. On March 16, 2022, I engaged Process Server One to serve Defendant 8 David M. Bragg and the other Defendants. On March 21, 2022, Process Server 9 One provided me with a Proof of Service indicating that it had served Mr. Bragg 10 on March 17, 2022 at one of his places of employment, the Menlo Park Fire 11 Protection District, Station 77, located at 1467 Chilco Street, Menlo Park, 12 California 94025. That Proof of Service is attached as Exhibit A. 13 5. Because in the course of serving the Defendants, Process Server One 14 provided me with several Proofs of Service that I believed had been prepared 15 incorrectly, I instructed my paralegal, Mina Al-Ansari, to re-serve each of the 16 Defendants, including Mr. Bragg, by mail, to ensure service was completed 17 correctly. 18 6. On April 8, 2022, at my instruction, Ms. Al-Ansari mailed the service 19 papers to Mr. Bragg at the Menlo Park Fire Protection District, located at 170 20 Middlefield Road, Menlo Park, California 94025, which according to Mr. Bragg’s 21 LinkedIn page is his current place of employment. A printout of Mr. Bragg’s 22 LinkedIn page is attached as Exhibit B. Tracking information confirms these 23 papers were delivered successfully. The tracking information is attached as Exhibit 24 C. The Proof of Service for this mailing is attached as Exhibit D. 25 7. Having not received a response from Mr. Bragg, on April 29, 2022, at 26 my instruction, Ms. Al-Ansari mailed additional copies of the service papers to Mr. 27 28 2 AFFIDAVIT OF COLLIN J. VIERRA 1 Bragg at Silicon Valley Real Ventures, LLC (“SVRV”), located at 205 2 Constitution Drive, Menlo Park, California 99025, which according to Mr. Bragg’s 3 LinkedIn page is his other current place of employment. See Exhibit B. A printout 4 of SVRV’s website confirming its address is attached as Exhibit E. According to 5 the United States Postal Service, no one was present at SVRV’s business address 6 during each delivery attempt. The tracking information is attached as Exhibit F. 7 The Proof of Service for this mailing is attached as Exhibit G. 8 8. Having still not received a response from Mr. Bragg, on May 12, 9 2022, I contacted Mr. Bragg both by electronic mail at his email address that he 10 uses for SVRV business, and by telephone at the phone number that he uses for 11 SVRV business. I attached the service papers to the email. Mr. Bragg did not 12 answer his phone, so I left him a voicemail informing him of our attempts to reach 13 him and our need for a prompt response. An email from Mr. Bragg to Plaintiff 14 Robert Arntsen showing Mr. Bragg’s email address and phone number in his 15 signature block is attached as Exhibit H. My email to Mr. Bragg is attached as 16 Exhibit I. A screenshot from my cell phone showing that I placed a 1 minute, 11 17 second phone call to Mr. Bragg’s number on May 12, 2022 is attached as Exhibit J. 18 9. Having still not received a response from Mr. Bragg, on May 13, 19 2022, I signed up for a trial of LinkedIn premium, on which platform I sent Mr. 20 Bragg a message informing him of our attempts to reach him and our need for a 21 prompt response. My LinkedIn message to Mr. Bragg is attached as Exhibit K. 22 10. Also on May 13, 2022, at my instruction, Ms. Al-Ansari mailed 23 additional copies of the service papers to Mr. Bragg at his last-known home 24 address, which was provided to me by Mr. Bragg’s co-Defendant and fellow 25 Managing Director of SVRV, Kurtis M. Kludt. Mr. Bragg signed for this delivery 26 on May 16, 2022. The signature confirmation is attached as Exhibit L. 27 11. In or around the first week of May 2022, the webpage for Silicon 28 3 AFFIDAVIT OF COLLIN J. VIERRA Valh:y Real Ventures, realsv.com, was taken down. On information and belief, Mr. 2 Bragg removed this website after being served in this action. According to Mr. 3 Kludt, with whom I have been in periodic contact since Plaintiffs initiated this 4 action, Mr. Bragg controls the realsv.com website. 5 12. According to Mr. Kludt, Mr. Bragg has spoken with Mr. Kludt about 6 this action since being served. 7 13. Plaintiffs have incurred significant expense in serving Mr. Bragg. 8 14. Mr. Bragg still has not responded. 9 10 I declare under penalty of perjury under the laws of the State of California that 11 the foregoing is true and correct. 12 13 14 Dated: May 16, 2022 Collin J. Vierra 15 16 EIMER STAI-ll.., LLP .I I 17 Attorney for Plaintiffs Robert Arntsen, Mary Lee, the Arntsen 18 Family Partnership, LP, and the 19 Brian Christopher Dunn Custodianship 20 21 22 23 24 25 26 27 28 4 AFFIDAVIT OF COLLIN J. VIERRA Exhibit A POS-010 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Collin James Vierra SBN 322720 Collin James Vierra - Eimer Stahl LLP 99 S. Almaden Blvd. 641 San Jose, CA 95113 TELEPHONE NO.: (831) 917-8266 FAX NO. (Optional): E-MAIL ADDRESS (Optional): ATTORNEY FOR (Name): Plaintiff SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO - REDWOOD CITY (EFILING) STREET ADDRESS: 400 County Center MAILING ADDRESS: 400 County Center CITY AND ZIP CODE: Redwood City, CA 94063 BRANCH NAME: SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO - REDWOOD CITY (EFILING) PLAINTIFF/PETITIONER: ARNTSEN FAMILY PARTNERSHIP, LP CASE NUMBER: 22-CIV-01148 DEFENDANT/RESPONDENT: SILICON VALLEY REAL VENTURES, LLC Ref. No. or File No.: PROOF OF SERVICE SUMMONS 0000 (Separate proof of service is required for each party served.) 1. At the time of service I was at least 18 years of age and not a party to this action. 2. I served copies of: Complaint; Civil Case Cover Sheet; Summons - Brag; Summons - Kludt; Summons - Davis; Summons - SVRV; Summons - SVRV 385 Moore; Summons - SVRV 387 Moore; Summons - Paramont Capital; Summons - Paramont Woodside 3. a. Party served (specify name of party as shown on documents served): David M. Bragg b. Person (other than the party in item 3a) served on behalf of an entity or as an authorized agent (and not a person D under item 5b on whom substituted service was made) (specify name and relationship to the party named in item 3a): 4. Address where the party was served: 1467 Chilco St, Menlo Park, CA 94025 5. I served the party (check proper b ox) a. by personal service. I personally delivered the documents listed in item 2 to the party or person authorized to receive service of process for the party (1) on:(2) at: b. by substituted service. On: at: I left the documents listed in item 2 with or in the presence of (name and title or relationship to person indicated in item 3): (1) (business) a person at least 18 years of age apparently in charge at the office or usual place of business D of the person to be served. I informed him or her of the general nature of the papers. (2) (home) a competent member of the household (at least 18 years of age) at the dweling house or usual D place of abode of the party. I informed him or her of the general nature of the papers. (3) (physical address unknown) a person of at least 18 years of age apparently in charge at the usual D mailing address of the person to be served, other than a United States Postal Service post office box. I informed him or her of the general nature of the papers. (4) I thereafter mailed (by first-class, postage prepaid) copies of the documents to the person to be served at □ the place where the copies were left (Code Civ. Proc., § 415.20). I mailed the documents: Page 1 of 3 POS-010 [Rev. January 1, 2007] PROOF OF SERVICE OF SUMMONS Invoice # 5657757-02 PLAINTIFF/PETITIONER: ARNTSEN FAMILY PARTNERSHIP, LP CASE NUMBER: DEFENDANT/RESPONDENT: SILICON VALLEY REAL VENTURES, LLC 22-CIV-01148 on: from: or a declaration of mailing is attached. (5) I attach a declaration of diligence stating actions taken first to attempt personal service. 5. c. by mail and acknowledgment of receipt of service. I mailed the documents listed in item 2 to the party, to the address shown in item 4, by first-class mail, postage prepaid, (1) on: (2) from: (3) with two copies of the Notice and Acknowledgment of Receipt and a postage-paid return envelope addressed to me. (Attach completed Notice and Acknowledgment of Receipt.) (Code Civ. Proc., § 415.30.) (4) to an address outside California with return receipt requested. (Code Civ. Proc., § 415.40.) d. by other means (specify means of service and authorizing code section): Additional page describing service is attached. 6. The "Notice to the Person Served" (on the summons) was completed as follows: a. as an individual defendant. b. as the person sued under the fictitious name of (specify): c. as occupant. d. On behalf of (specify): David M. Bragg under the following Code of Civil Procedure section: 416.10 (corporation) 415.95 (business organization, form unknown) 416.20 (defunct corporation) 416.60 (minor) 416.30 (joint stock 416.70 (ward or conservatee) company/association) 416.40 (association or partnership) 416.90 (authorized person) 416.50 (public entity) 415.46 (occupant) other: 7. Person who served papers a. Name: Ellenor Rios b. Address: 555 Anton Blvd 150, Costa Mesa, CA 92626 c. Telephone number: 855-545-1303 d. The fee for service was: $115.00 e. I am: (1) not a registered California process server. (2) exempt from registration under Business and Professions Code section 22350(b). (3) a registered California process server: (i) owner employee independent contractor. (ii) Registration No.: (iii) County: 0 POS-010 [Rev. January 1, 2007] Page 2 of 3 PROOF OF SERVICE OF SUMMONS Invoice #: 5657757-02 PLAINTIFF/PETITIONER: ARNTSEN FAMILY PARTNERSHIP, LP CASE NUMBER: DEFENDANT/RESPONDENT: SILICON VALLEY REAL VENTURES, LLC 22-CIV-01148 8. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Ellenor Rios Ellenor Rios Date: 03/17/2022 POS-010 [Rev. January 1, 2007] Page 3 of 3 PROOF OF SERVICE OF SUMMONS Invoice #: 5657757-02 Exhibit B 3/18/22, 1:46 PM (2) Experience | Dave Bragg | LinkedIn 2 Home My Network Jobs Messaging Notifications Me Work Dave Bragg Message Connect Engineer/Acting Captain at Menlo Park Fire Protection … Experience Engineer/Acting Captain Menlo Park Fire Protection District · Full-time Nov 2003 - Present · 18 yrs 5 mos Menlo Park, California, United States Managing Director/CEO of Silicon Valley Real Estate Ventures BRE#01997389 Silicon Valley Real Ventures Jul 2014 - Present · 7 yrs 9 mos Menlo Park, CA Silicon Valley Real Ventures offers international investors access to the Silicon Valley economy. We invest in a high end single family, multi family and commercial real estate. We are a diverse team of professionals sharing Silicon Valley opportunities with the world. Silicon Valley Real Ventures SVRV (Silicon Valley Real Ventures) is a fully integrated Private Equity firm with specializations in Venture Capit… Founding Partner VIP Car Vault LLC Apr 2013 - Jun 2017 · 4 yrs 3 mos Redwood City, CA Built the business around VIP car storage. In a partnership with AutoVino.org we offer VIP car storage. Our brilliant partners continue the work. Founding Partner/CEO https://www.linkedin.com/in/davebraggsvrv/details/experience/ 1/3 3/18/22, 1:46 PM (2) Experience | Dave Bragg | LinkedIn California Luxury Properties & Development LLC 2 Jul 2012 - Jul 2014 · 2 yrs 1 mo Home My Network Jobs Messaging Notifications Me Work Menlo Park, California California Luxury Properties & Development offers investment opportunities in luxury homes in Silicon Valley. Founder and CEO Thor Construction May 2009 - Sep 2013 · 4 yrs 5 mos Menlo Park, CA Built and grew this real estate construction company from 1 to 40 employees with 200 clients over a four-year period. Invested in and raised financing for 20+ real estate projects. Notable clients include executives at Apple, Google, Facebook, LinkedIn, Yahoo, and eBay. Projects included both residential and commercial, small, and large construction projects. Founder/CEO Bragg Investment Group, LLC May 2006 - May 2010 · 4 yrs 1 mo CA & TX Privately held company that purchased, managed, and maintained residential real estate assets. We operated in Menlo Park, San Mateo, Santa Barbara County, Laguna Niguel, Orange County, Solvang, and Lompoc (California) and in Austin and Killeen (Texas). About Accessibility Talent Solutions Questions? Select Language Visit our Help Center. Community Guidelines Careers Marketing Solutions English (English) Privacy & Terms Ad Choices Advertising Manage your account and privacy Go to your Settings. Sales Solutions Mobile Small Business Safety Center https://www.linkedin.com/in/davebraggsvrv/details/experience/ 2/3 3/18/22, 1:46 PM (2) Experience | Dave Bragg | LinkedIn LinkedIn Corporation © 2022 2 Home My Network Jobs Messaging Notifications Me Work https://www.linkedin.com/in/davebraggsvrv/details/experience/ 3/3 Exhibit C April 8, 2022 U.S. Certified Mail Receipt to David Bragg 5/15/22, 12:03 PM USPS.com® - USPS Tracking® Results USPS Tracking ® FAQs Track Another Package + Remove Tracking Number: 70151730000244060947 Your item was delivered to an individual at the address at 10:38 am on April 14, 2022 in MENLO PARK, CA 94025. USPS Tracking Plus® Available Feedback Delivered, Left with Individual April 14, 2022 at 10:38 am MENLO PARK, CA 94025 Get Updates Text & Email Updates Tracking History USPS Tracking Plus® Product Information See Less https://tools.usps.com/go/TrackConfirmAction?qtc_tLabels1=70151730000244060947 1/2 Exhibit D Exhibit E PROPERTY LISTINGS AVAILABLE (/AVAILABLE-LISTINGS) SOLD (/SOLD-LISTINGS) CUSTOM HOMES (/CUSTOM-HOMES) DEVELOPMENT (/DEVELOPMENT) ABOUT (/ABOUT) D AV E BRAGG Dave was born and raised in a Real Estate Development family and started working in the industry in 1989. Dave made his first investment in real estate at the age of 21. His geographical focus has been Northern and Southern California, Texas, and Oregon. Dave has worked in Silicon Valley since 1998 and is actively involved in the Bay Area community. Dave Bragg is the managing partner at Silicon Valley Real Ventures. He oversees the daily operations of the firm and is responsible for raising capital, evaluating investment dealflow and setting strategic vision for SVRV shareholders. His main focus is identifying and executing on innovative investment strategies. Dave has over 15 years of experience in real estate investing, fund management and operations. Dave is a consummate entrepreneur, having financed and developed over $100 million of real estate during his career. He continues to invest in California and International real estate and has successfully raised financing for 25+ projects. Dave lives with his family in Atherton, CA where he is active in community service and philanthropy. In the past, he has served as a state licensed General Contractor (Builder) where he scaled his Silicon Valley construction company from 1 to 40 employees with 200 clients over a four-year period. Notable clients include individuals from Apple, Google, Facebook, LinkedIn, Yahoo, eBay and many from the Venture Capital community. He has worked as firefighter in the community for over 10 years. In 2003, he was deployed to the Middle East, where he was among the first group of Marines to lead the ground invasion into Iraq. Dave volunteers hundreds of hours each year to serve the local community. He has served on the Menlo-Atherton Little League Baseball Board of Directors, the Menlo-Atherton Pop Warner Football Board of Directors, coaches youth baseball, soccer and football, volunteers as a fundraiser for Jerry’s Kids, co-chairs the Menlo Park food and toy drive, serves as a house captain for Rebuilding Together Peninsula, and is a donor-builder for Dreams Happen Playhouse. KURTIS KLUDT Kurtis was born and raised in Silicon Valley. Kurtis is a financial engineer in the public equity markets and residential property market. He is CEO of ANA Holdings (Angel Networking Access), a diversified management and consulting company. Kurtis handles public equities, real estate and start-up investments. Kurtis is an avid researcher and analyst of public equity markets, investment opportunities, and new technologies. He is an angel investor and a financial adviser. He is an avid follower of the real estate market in Silicon Valley and brings a strong track record in investor fund acquisition. $100M of public equities transacted since inception with Charles Schwab and Interactive Brokers. Specialty research areas of fund management: real estate, dividend income, growth stocks, commodities, IPOs, and the technology sector. Kurtis works with and supports non-profit organizations such as the National Multiple Sclerosis Society, Leukemia & Lymphoma Society, and Poppy Foundation Animal Hospital. Kurtis graduated with honors from the UCLA College of Letters and Science in conjunction with the Anderson School of Management, where he earned his B.S. degree in Business Economics. . PETE SAMIS Pete Samis was born in San Jose, CA where his dad worked as a general contractor building custom homes in Saratoga and Los Gatos. When Pete was 10 years old he started to work for his dad during the summer earning 25 cents a hour. After high school he joined the Airforce and was stationed in Las Vegas where he worked as a Carpenter Specialist. After working on residential and commercial projects in in Las Vegas for 20 years, including for celebrities including Robert Goulet, Jerry Lewis, Liberace and Wayne Newton and on large public works projects on the UNLV campus and at city hall, Pete returned to the Bay Area with Cupertino Kitchen Design (Remodel West) and American Kitchen & Bath. As the General Manager of Thor Construction from 2011-213, Pete led more than 25 full house remodel projects. During his time at Silicon Valley Real Ventures as Vice President of Construction he has worked on numerous development deals in the capacity of a project manager, general contractor, and construction supervision. Contact Us Please get in touch if you would like to learn about how we can help you build OUR OFFICE your own dream home, or how one of our developments could be a good fit 205 Constitution Dr for you! Menlo Park, CA 94025 Name * First Name Last Name Email Address * Subject * Message * (https://maps.google.com/maps? 7.4832688,-122.1700815,12z/data=!10m1!1e1!12b1?source=apiv3&rapsrc=apiv3) 2 km ll=37.483269,-122.170081&z=12&t=m&hl=en&gl=US&mapclient=apiv3) Map data ©2022 Google SEND MESSAGE In the Community SVRV values its deep connection in the local community. DREAMS HAPPEN 2 017 P L AY H O U S : FIREHOUSE Since 1993, Stanford Shopping Center has hosted and produced the biennial Dreams Happen event benefiting Rebuilding Together Peninsula. Playhouses have sold for amounts ranging from $13,000 to $101,000. In 2017 the SVRV staff helped local firefighters build "Station 2," a classically themed firehouse. DREAMS HAPPEN 2 0 15 P L AY H O U S : FIRE LO O KO U T SVRV contributes materials and our staff’s labor every second year to help build a Fire House themed playhouse designed by Larry Kahle & John Onken and built buy San Mateo County Firefighters, IAFF Local 2400. In 2015 the fire-themed playhouse was styled after the wildland fire lookout towers HOMER FIELD AT WILLIE M AYS B A L L PA R K SVRV built the new stadium for Atherton's Homer Field at Willie Mays Ballpark, completed in 2015 PROPERTY L I ST I N G S AVA I L A B L E( / AVA I L A B L E - L I S T I N G S ) SOLD ( / S O L D - L I ST I N G S ) C U STO M HOMES ( / C U STO M - H O M E S ) D E V E LO P M E N T ( / D E V E LO P M E N T ) [ABOUT] (/ABOUT) S V R V, 16 5 C O N ST I T U T I O N DRIVE, M E N LO PA R K , CA, 94 0 2 5 ,UNITED S TAT E S Exhibit F April 29, 2022 U.S. Certified Mail Receipt to David Bragg 5/16/22, 4:48 PM USPS.com® - USPS Tracking® Results USPS Tracking ® FAQs Track Another Package + Remove Tracking Number: 70151730000243657520 Your item arrived at our USPS facility in CHICAGO IL DISTRIBUTION CENTER on May 16, 2022 at 6:11 am. The item is currently in transit to the destination. USPS Tracking Plus® Available Feedback Arrived at USPS Regional Facility May 16, 2022 at 6:11 am CHICAGO IL DISTRIBUTION CENTER Get Updates Text & Email Updates Tracking History May 16, 2022, 6:11 am Arrived at USPS Regional Facility CHICAGO IL DISTRIBUTION CENTER Your item arrived at our USPS facility in CHICAGO IL DISTRIBUTION CENTER on May 16, 2022 at 6:11 am. The item is currently in transit to the destination. May 15, 2022 In Transit to Next Facility https://tools.usps.com/go/TrackConfirmAction?qtc_tLabels1=70151730000243657520 1/3 5/16/22, 4:48 PM USPS.com® - USPS Tracking® Results May 14, 2022, 7:50 pm Departed USPS Regional Facility SAN FRANCISCO CA DISTRIBUTION CENTER May 12, 2022, 1:33 pm Vacant MENLO PARK, CA 94025 May 11, 2022, 3:09 pm Delivery Attempted - No Access to Delivery Location MENLO PARK, CA 94025 May 9, 2022, 10:17 am Delivery Attempted - No Access to Delivery Location MENLO PARK, CA 94025 May 7, 2022, 12:35 pm Arrived at USPS Regional Facility Feedback SAN FRANCISCO CA DISTRIBUTION CENTER May 3, 2022, 12:02 am Arrived at USPS Regional Facility BEDFORD PARK IL DISTRIBUTION CENTER USPS Tracking Plus® Product Information See Less Can’t find what you’re looking for? Go to our FAQs section to find answers to your tracking questions. https://tools.usps.com/go/TrackConfirmAction?qtc_tLabels1=70151730000243657520 2/3