Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Raymond N. Stella Erlach, Esq., SBN 056958
LAW OFFICES OF RAYMOND N. STELLA ERLACH
232 West Napa Street
Sonoma, CA 95476
TELEPHONE NO.: 415-788-3322 FAX NO.(Optional): 415-788-8613
rerlach@rayerlach.com
E-MAIL ADDRESS:
ATTORNEY FOR (Name): Defendants
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA
STREET ADDRESS: 600 Administration Drive, Room 107
MAILING ADDRESS:600 Administration Drive, Room 107
Santa
CITY AND ZIP CODE: Rosa, CA 95403
BRANCH NAME: Hall of Justice, Civil Division
PLAINTIFF/PETITIONER:
VILLA ROSA HOMEOWNERS ASSOCIATION,
DEFENDANT/RESPONDENT:
VALLEN W. COOPER, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): X UNLIMITED CASE LIMITED CASE SCV-267991
(Amount demanded (Amount demanded is $25,000 Hon. Judge Jennifer V. Dollard
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: June 28, 2022 Time: 3:00 PM Dept.: 18 Div.: Room:
Address of court (if different from the address above):
3055 Cleveland Avenue
Santa Rosa, CA 95403
X Notice of Intent to Appear by Telephone, by (name): Raymond N. Stella Erlach (Zoom)
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one): Defendants Vallen W. Cooper, CPM, Inc., dba
a. X This statement is submitted by party (name): Commonwealth Property Management, and
b. This statement is submitted jointly by parties (names):Commonwealth Association Management, Inc.
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): March 12, 2021
b. The cross-complaint, if
any, was filedon (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. The following parties named in the complaint or cross-complaint
(1) have not been served (specify names and explain why not):
(2) have been served but have not appeared and have not been dismissed (specify names):
(3) have had a default entered against them (specify names):
c. The following additional parties may be added (specify names, nature of involvement in case, and the date by which
they may be served):
4. Description of case
a. Type of case in X complaint cross-complaint (Describe, including causes of action):
Plaintiff now claims it did not know the insurance company paid on a
"claim" and has abandoned its earlier outrageous claims of fraud (which
are provably false). The case arises over insurance claims submitted by
plaintiff's broker, NOT defendants.
Page 1 of 5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California rules 3.720–3.730
CM-110 [Rev. September 1, 2021] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: CASE NUMBER:
VILLA ROSA HOMEOWNERS ASSOCIATION, SCV-267991
DEFENDANT/RESPONDENT:
VALLEN W. COOPER, et al.
4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages 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.)
Please see Attachment 4.b.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request X a jury trial a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. The trial has been set for (date):
b. X No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Trial in another matter currently scheduled in Department 16 of this court
for November 18, 2022.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. X days (specify number): Seven (7) days
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial X by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
9. Preference
This case is entitled to preference (specify code section):
10. 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 of the California Rules of Court for information about the
processes available through the court and community programs in this case.
(1) For parties represented by counsel: Counsel X has has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) X This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
Excess damages.
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5
CM-110
PLAINTIFF/PETITIONER: CASE NUMBER:
VILLA ROSA HOMEOWNERS ASSOCIATION, SCV-267991
DEFENDANT/RESPONDENT:
VALLEN W. COOPER, et al.
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):
Mediation session not yet scheduled
(1) Mediation Mediation session scheduled for (date):
Agreed to complete mediation by (date):
Mediation completed on (date):
X Settlement conference not yet scheduled
(2) Settlement
X Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
X Neutral evaluation not yet scheduled
(3) Neutral evaluation X Neutral evaluation scheduled for (date):
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
arbitration
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5
CM-110
PLAINTIFF/PETITIONER: CASE NUMBER:
VILLA ROSA HOMEOWNERS ASSOCIATION, SCV-267991
DEFENDANT/RESPONDENT:
VALLEN W. COOPER, et al.
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes No
c. Coverage issues willsignificantly
affectresolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
Bankruptcy Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate will be filed by (name party):
14. Bifurcation
The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motion for Summary Judgment.
16. Discovery
a. The party or parties have completed all discovery.
b. X The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendants Three depositions of plaintiff's Board of August 2022
Directors
Defendants Written discovery to plaintiff October 2022
Defendants Seven depositions of percipient witnesses December 2022
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5
CM-110
PLAINTIFF/PETITIONER: CASE NUMBER:
VILLA ROSA HOMEOWNERS ASSOCIATION, SCV-267991
DEFENDANT/RESPONDENT:
VALLEN W. COOPER, et al.
17. Economic litigation
a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
X The party or parties request that the following additional matters be considered or determined at the case management
conference (specify): (1) The pleadings are not settled; motion to strike
Second Amended Complaint is set for July 20, 2022.
(2) Awaiting Section 998 Judgments for $10,000 for
individual Defendants Vallen W. Cooper,
Kellin A. Baker, and Chad W. Cooper in "defense costs"
compromise.
19. Meet and confer
a. X The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of
Court (if not, explain):The pleadings are not settled.
b. After meeting 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): 2 (Attachment 4.b and Proof of Service)
I am completely familiar with this case and will 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: June 11, 2022 LAW OFFICES OF RAYMOND N. STELLA ERLACH
Raymond N. Stella Erlach
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5
VILLA ROSA HOMEOWNERS ASSOCIATION v. COOPER, et al.
Sonoma County Superior Court Case No. SCV-267991
Attachment 4.b
To CASE MANAGEMENT STATEMENT
4.b. Provide a brief statement of the case, including any damages.
Plaintiff cannot prove liability or damages.
The individual defendants have compromised via Section 998 for defense costs ($10,000
each). Awaiting Clerk's Judgments.
Motion to strike set for July 20, 2022. Plaintiff alleges it did not know "claims" were
filed. Plaintiff's broker filed the claims and was involved in every step of the claims. The
broker's knowledge is attributable to plaintiff under the laws of agency, and the action should be
dismissed.
jpSS\Co\attach4bcms
6
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 is the Law Offices of Raymond N. Stella Erlach, 232 West Napa Street, Sonoma,
6 California 95476; my e-mail address is jpearl@rayerlach.com.
7 On June 11, 2022, on behalf of Raymond N. Stella Erlach, counsel for
8 Vallen W. Cooper; Vallen W. Cooper, CPM, Inc., dba Commonwealth Property Management;
9 Commonwealth Association Management, Inc.; Kellin A. Baker, individually and dba Accurate
10 Property Services, aka Accurate Maintenance & Janitorial; and Chad W. Cooper, whose electronic
11 service address is rerlach@rayerlach.com, I served the within:
12 (1) CASE MANAGEMENT STATEMENT;
(2) CORRESPONDENCE DATED JUNE 11, 2022, TO THE
13 HONORABLE JUDGE JENNIFER V. DOLLARD
14 on the interested parties in said action by electronic service to each of the following:
15
Name of person/entity served: To electronic service address:
16 On behalf of Villa Rosa Homeowners Association:
17 Peter C. De Golia, Esq. pdegolia@cfk.com
Nicholas Bernate, Esq. nbernate@cfk.com
18 Clement, Fitzpatrick & Kenworthy lholmberg@cfk.com
tdurler@cfk.com
19
20 I declare under penalty of perjury under the laws of the State of California that the
21 foregoing is true and correct.
22
Jennifer Pearl
23 Dated: June 11, 2022 _______________________________________
jpX5\Co\proofemonly.1 Jennifer Pearl
24
25
26
27
28
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CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Raymond N. Stella Erlach, Esq., SBN 056958 LAW OFFICES OF RAYMOND N. STELLA ERLACH 232 West Napa Street Sonoma, CA 95476 TELEPHONE NO.: 415-788-3322 FAX NO.(Optional): 415-788-8613 rerlach@rayerlach.com E-MAIL ADDRESS: ATTORNEY FOR (Name): Defendants SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA STREET ADDRESS: 600 Administration Drive, Room 107 MAILING ADDRESS:600 Administration Drive, Room 107 Santa CITY AND ZIP CODE: Rosa, CA 95403 BRANCH NAME: Hall of Justice, Civil Division PLAINTIFF/PETITIONER: VILLA ROSA HOMEOWNERS ASSOCIATION, DEFENDANT/RESPONDENT: VALLEN W. COOPER, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): X UNLIMITED CASE LIMITED CASE SCV-267991 (Amount demanded (Amount demanded is $25,000 Hon. Judge Jennifer V. Dollard exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: June 28, 2022 Time: 3:00 PM Dept.: 18 Div.: Room: Address of court (if different from the address above): 3055 Cleveland Avenue Santa Rosa, CA 95403 X Notice of Intent to Appear by Telephone, by (name): Raymond N. Stella Erlach (Zoom) INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): Defendants Vallen W. Cooper, CPM, Inc., dba a. X This statement is submitted by party (name): Commonwealth Property Management, and b. This statement is submitted jointly by parties (names):Commonwealth Association Management, Inc. 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): March 12, 2021 b. The cross-complaint, if any, was filedon (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. The following parties named in the complaint or cross-complaint (1) have not been served (specify names and explain why not): (2) have been served but have not appeared and have not been dismissed (specify names): (3) have had a default entered against them (specify names): c. The following additional parties may be added (specify names, nature of involvement in case, and the date by which they may be served): 4. Description of case a. Type of case in X complaint cross-complaint (Describe, including causes of action): Plaintiff now claims it did not know the insurance company paid on a "claim" and has abandoned its earlier outrageous claims of fraud (which are provably false). The case arises over insurance claims submitted by plaintiff's broker, NOT defendants. Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California rules 3.720–3.730 CM-110 [Rev. September 1, 2021] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: CASE NUMBER: VILLA ROSA HOMEOWNERS ASSOCIATION, SCV-267991 DEFENDANT/RESPONDENT: VALLEN W. COOPER, et al. 4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages 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.) Please see Attachment 4.b. (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request X a jury trial a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. The trial has been set for (date): b. X No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Trial in another matter currently scheduled in Department 16 of this court for November 18, 2022. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. X days (specify number): Seven (7) days b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial X by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: Additional representation is described in Attachment 8. 9. Preference This case is entitled to preference (specify code section): 10. 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 of the California Rules of Court for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel X has has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) X This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): Excess damages. CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5 CM-110 PLAINTIFF/PETITIONER: CASE NUMBER: VILLA ROSA HOMEOWNERS ASSOCIATION, SCV-267991 DEFENDANT/RESPONDENT: VALLEN W. COOPER, et al. 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): Mediation session not yet scheduled (1) Mediation Mediation session scheduled for (date): Agreed to complete mediation by (date): Mediation completed on (date): X Settlement conference not yet scheduled (2) Settlement X Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): X Neutral evaluation not yet scheduled (3) Neutral evaluation X Neutral evaluation scheduled for (date): Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5 CM-110 PLAINTIFF/PETITIONER: CASE NUMBER: VILLA ROSA HOMEOWNERS ASSOCIATION, SCV-267991 DEFENDANT/RESPONDENT: VALLEN W. COOPER, et al. 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes No c. Coverage issues willsignificantly affectresolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Bankruptcy Other (specify): Status: 13. Related cases, consolidation, and coordination a. There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: Additional cases are described in Attachment 13a. b. A motion to consolidate coordinate will be filed by (name party): 14. Bifurcation The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Motion for Summary Judgment. 16. Discovery a. The party or parties have completed all discovery. b. X The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendants Three depositions of plaintiff's Board of August 2022 Directors Defendants Written discovery to plaintiff October 2022 Defendants Seven depositions of percipient witnesses December 2022 c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: CASE NUMBER: VILLA ROSA HOMEOWNERS ASSOCIATION, SCV-267991 DEFENDANT/RESPONDENT: VALLEN W. COOPER, et al. 17. Economic litigation a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues X The party or parties request that the following additional matters be considered or determined at the case management conference (specify): (1) The pleadings are not settled; motion to strike Second Amended Complaint is set for July 20, 2022. (2) Awaiting Section 998 Judgments for $10,000 for individual Defendants Vallen W. Cooper, Kellin A. Baker, and Chad W. Cooper in "defense costs" compromise. 19. Meet and confer a. X The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain):The pleadings are not settled. b. After meeting 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): 2 (Attachment 4.b and Proof of Service) I am completely familiar with this case and will 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: June 11, 2022 LAW OFFICES OF RAYMOND N. STELLA ERLACH Raymond N. Stella Erlach (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5 VILLA ROSA HOMEOWNERS ASSOCIATION v. COOPER, et al. Sonoma County Superior Court Case No. SCV-267991 Attachment 4.b To CASE MANAGEMENT STATEMENT 4.b. Provide a brief statement of the case, including any damages. Plaintiff cannot prove liability or damages. The individual defendants have compromised via Section 998 for defense costs ($10,000 each). Awaiting Clerk's Judgments. Motion to strike set for July 20, 2022. Plaintiff alleges it did not know "claims" were filed. Plaintiff's broker filed the claims and was involved in every step of the claims. The broker's knowledge is attributable to plaintiff under the laws of agency, and the action should be dismissed. jpSS\Co\attach4bcms 6 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 is the Law Offices of Raymond N. Stella Erlach, 232 West Napa Street, Sonoma, 6 California 95476; my e-mail address is jpearl@rayerlach.com. 7 On June 11, 2022, on behalf of Raymond N. Stella Erlach, counsel for 8 Vallen W. Cooper; Vallen W. Cooper, CPM, Inc., dba Commonwealth Property Management; 9 Commonwealth Association Management, Inc.; Kellin A. Baker, individually and dba Accurate 10 Property Services, aka Accurate Maintenance & Janitorial; and Chad W. Cooper, whose electronic 11 service address is rerlach@rayerlach.com, I served the within: 12 (1) CASE MANAGEMENT STATEMENT; (2) CORRESPONDENCE DATED JUNE 11, 2022, TO THE 13 HONORABLE JUDGE JENNIFER V. DOLLARD 14 on the interested parties in said action by electronic service to each of the following: 15 Name of person/entity served: To electronic service address: 16 On behalf of Villa Rosa Homeowners Association: 17 Peter C. De Golia, Esq. pdegolia@cfk.com Nicholas Bernate, Esq. nbernate@cfk.com 18 Clement, Fitzpatrick & Kenworthy lholmberg@cfk.com tdurler@cfk.com 19 20 I declare under penalty of perjury under the laws of the State of California that the 21 foregoing is true and correct. 22 Jennifer Pearl 23 Dated: June 11, 2022 _______________________________________ jpX5\Co\proofemonly.1 Jennifer Pearl 24 25 26 27 28 7