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1 Timothy M. Flaherty, Esq., SBN 99666
Christian P. Foote, Esq., SBN 240919
2 CLARK HILL LLP
ELECTRONICALLY
505 Montgomery Street, 13th Floor
3 San Francisco, CA 94111 F I L E D
Superior Court of California,
Telephone: (415) 984-8500 County of San Francisco
4 Facsimile: (415) 984-8599
TFlaherty@clarkhill.com 04/16/2021
5 CFoote@clarkhill.com Clerk of the Court
BY: EDNALEEN ALEGRE
Deputy Clerk
6 Attorneys for Defendant/Cross-Complainant
ALICE PHELAN SULLIVAN CORPORATION
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 CITY AND COUNTY OF SAN FRANCISCO
10
11 WHITE HOUSE VENTURES, LLC, a Case No. CGC-20-582659
California limited liability company,
12 NOTICE OF ERRATA RE: EXHIBITS TO
Plaintiff, DECLARATION OF CHRISTIAN P. FOOTE
13 IN SUPPORT OF ALICE PHELAN
v. SULLIVAN CORPORATION’S MOTIONS IN
14 LIMINE
ALICE PHELAN SULLIVAN
15 CORPORATION, a California corporation; and
DOES 1-100, Complaint filed: February 3, 2020
16
Defendants. Cross-Complaint Filed: May 29, 2020
17
________________________________________
18
ALICE PHELAN SULLIVAN
19 CORPORATION, a California corporation,
20 Cross-Complainant,
21 v.
22 WHITE HOUSE VENTURES, LLC, a
California limited liability company, and ROES
23 1-10,
24 Cross-Defendants.
25
PLEASE TAKE NOTICE THAT on April 14, 2021 Counsel for Defendant and Cross-
26
Complainant Alice Phelan Sullivan Corporation filed the EXHIBITS TO DECLARATION OF
27
1
28 NOTICE OF ERRATA OF EXHIBITS TO DECLARATION OF CHRISTIAN P. FOOTE IN SUPPORT OF ALICE
PHELAN SULLIVAN CORPORATION’S MOTIONS IN LIMINE
ClarkHill\62578\372310\262722547.v1-4/16/21
1 CHRISTIAN P. FOOTE IN SUPPORT OF ALICE PHELAN SULLIVAN CORPORATION’S
2 MOTIONS IN LIMINE (“Declaration Exhibits”). Counsel inadvertently omitted pages of deposition
3 excerpts that were referenced in APS’s Motions in Limine as follows:
4 Exhibit C: Pages 228-229 from the April 5, 2021 Deposition of George Karas;
5 Exhibit D: Pages 289-292 from the March 11, 2021 Deposition of Erin Doyle Ebeling;
6 Exhibit F: Page 80 from the March 23, 2021 Deposition of Andrew McLaughlin.
7 The deposition excerpts referenced above have been added to the “Amended Exhibits to
8 Declaration of Christian P. Foote in Support of Alice Phelan Sullivan Corporation’s Motions in
9 Limine,” which is being filed and served herewith. The exhibits are identical in all respects other
10 than the addition of the above-referenced pages.
11
12 Dated: April 16, 2021 CLARK HILL LLP
13
14
15 By:
Timothy M. Flaherty
16 Christian P. Foote
Attorneys for Defendant/Cross-Complainant
17 ALICE PHELAN SULLIVAN
CORPORATION
18
19
20
21
22
23
24
25
26
27
2
28 NOTICE OF ERRATA OF EXHIBITS TO DECLARATION OF CHRISTIAN P. FOOTE IN SUPPORT OF ALICE
PHELAN SULLIVAN CORPORATION’S MOTIONS IN LIMINE
ClarkHill\62578\372310\262722547.v1-4/16/21
1 PROOF OF SERVICE
2 I, the undersigned, am employed in the County of San Francisco, State of California. I am
over the age of 18 and not a party to the within action; my business address is Clark Hill LLP, 505
3 Montgomery Street, 13th Floor, San Francisco, CA 94111.
4 On April 16, 2021, I served the following document(s) in the manner described below:
5
NOTICE OF ERRATA RE: EXHIBITS TO DECLARATION OF CHRISTIAN P. FOOTE IN
6 SUPPORT OF ALICE PHELAN SULLIVAN CORPORATION’S MOTIONS IN LIMINE
7
" [BY ELECTRONIC SERVICE VIA FILE AND SERVE EXPRESS]: Based on a court
8 order, I caused the above-entitled document(s) to be served through File & ServeXpress
at http://secure.fileandserveexpress.com addressed to all parties appearing on the
9 electronic service list for the above-entitled case. The service transmission was reported
as complete and a copy of the File & ServeXpress filing Receipt Page/Confirmation will
10 be filed, deposited or maintained with the original document(s) in this office.
11
On the following part(ies) in this action:
12
Gregory S. Cavallo, Esq. Attorneys for Plaintiff/Cross-Defendant
13 Jeffrey W. Shopoff, Esq. WHITE HOUSE VENTURES, LLC
James M. Robinson, Esq.
14 SHOPOFF CAVALLO LLP
155 Montgomery Street, Suite 401
15 San Francisco, CA 94104
Telephone: (415) 854-0370
16 Facsimile: (415) 854-0370
Email: greg@shopoffcavallo.com
17
18 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
19
Executed on April 16, 2021, at San Francisco, California.
20
21
22 TERESA L. STEEN
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24
25
26
27
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28 NOTICE OF ERRATA OF EXHIBITS TO DECLARATION OF CHRISTIAN P. FOOTE IN SUPPORT OF ALICE
PHELAN SULLIVAN CORPORATION’S MOTIONS IN LIMINE
ClarkHill\62578\372310\262722547.v1-4/16/21
Preview
1 Timothy M. Flaherty, Esq., SBN 99666 Christian P. Foote, Esq., SBN 240919 2 CLARK HILL LLP ELECTRONICALLY 505 Montgomery Street, 13th Floor 3 San Francisco, CA 94111 F I L E D Superior Court of California, Telephone: (415) 984-8500 County of San Francisco 4 Facsimile: (415) 984-8599 TFlaherty@clarkhill.com 04/16/2021 5 CFoote@clarkhill.com Clerk of the Court BY: EDNALEEN ALEGRE Deputy Clerk 6 Attorneys for Defendant/Cross-Complainant ALICE PHELAN SULLIVAN CORPORATION 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 CITY AND COUNTY OF SAN FRANCISCO 10 11 WHITE HOUSE VENTURES, LLC, a Case No. CGC-20-582659 California limited liability company, 12 NOTICE OF ERRATA RE: EXHIBITS TO Plaintiff, DECLARATION OF CHRISTIAN P. FOOTE 13 IN SUPPORT OF ALICE PHELAN v. SULLIVAN CORPORATION’S MOTIONS IN 14 LIMINE ALICE PHELAN SULLIVAN 15 CORPORATION, a California corporation; and DOES 1-100, Complaint filed: February 3, 2020 16 Defendants. Cross-Complaint Filed: May 29, 2020 17 ________________________________________ 18 ALICE PHELAN SULLIVAN 19 CORPORATION, a California corporation, 20 Cross-Complainant, 21 v. 22 WHITE HOUSE VENTURES, LLC, a California limited liability company, and ROES 23 1-10, 24 Cross-Defendants. 25 PLEASE TAKE NOTICE THAT on April 14, 2021 Counsel for Defendant and Cross- 26 Complainant Alice Phelan Sullivan Corporation filed the EXHIBITS TO DECLARATION OF 27 1 28 NOTICE OF ERRATA OF EXHIBITS TO DECLARATION OF CHRISTIAN P. FOOTE IN SUPPORT OF ALICE PHELAN SULLIVAN CORPORATION’S MOTIONS IN LIMINE ClarkHill\62578\372310\262722547.v1-4/16/21 1 CHRISTIAN P. FOOTE IN SUPPORT OF ALICE PHELAN SULLIVAN CORPORATION’S 2 MOTIONS IN LIMINE (“Declaration Exhibits”). Counsel inadvertently omitted pages of deposition 3 excerpts that were referenced in APS’s Motions in Limine as follows: 4 Exhibit C: Pages 228-229 from the April 5, 2021 Deposition of George Karas; 5 Exhibit D: Pages 289-292 from the March 11, 2021 Deposition of Erin Doyle Ebeling; 6 Exhibit F: Page 80 from the March 23, 2021 Deposition of Andrew McLaughlin. 7 The deposition excerpts referenced above have been added to the “Amended Exhibits to 8 Declaration of Christian P. Foote in Support of Alice Phelan Sullivan Corporation’s Motions in 9 Limine,” which is being filed and served herewith. The exhibits are identical in all respects other 10 than the addition of the above-referenced pages. 11 12 Dated: April 16, 2021 CLARK HILL LLP 13 14 15 By: Timothy M. Flaherty 16 Christian P. Foote Attorneys for Defendant/Cross-Complainant 17 ALICE PHELAN SULLIVAN CORPORATION 18 19 20 21 22 23 24 25 26 27 2 28 NOTICE OF ERRATA OF EXHIBITS TO DECLARATION OF CHRISTIAN P. FOOTE IN SUPPORT OF ALICE PHELAN SULLIVAN CORPORATION’S MOTIONS IN LIMINE ClarkHill\62578\372310\262722547.v1-4/16/21 1 PROOF OF SERVICE 2 I, the undersigned, am employed in the County of San Francisco, State of California. I am over the age of 18 and not a party to the within action; my business address is Clark Hill LLP, 505 3 Montgomery Street, 13th Floor, San Francisco, CA 94111. 4 On April 16, 2021, I served the following document(s) in the manner described below: 5 NOTICE OF ERRATA RE: EXHIBITS TO DECLARATION OF CHRISTIAN P. FOOTE IN 6 SUPPORT OF ALICE PHELAN SULLIVAN CORPORATION’S MOTIONS IN LIMINE 7 " [BY ELECTRONIC SERVICE VIA FILE AND SERVE EXPRESS]: Based on a court 8 order, I caused the above-entitled document(s) to be served through File & ServeXpress at http://secure.fileandserveexpress.com addressed to all parties appearing on the 9 electronic service list for the above-entitled case. The service transmission was reported as complete and a copy of the File & ServeXpress filing Receipt Page/Confirmation will 10 be filed, deposited or maintained with the original document(s) in this office. 11 On the following part(ies) in this action: 12 Gregory S. Cavallo, Esq. Attorneys for Plaintiff/Cross-Defendant 13 Jeffrey W. Shopoff, Esq. WHITE HOUSE VENTURES, LLC James M. Robinson, Esq. 14 SHOPOFF CAVALLO LLP 155 Montgomery Street, Suite 401 15 San Francisco, CA 94104 Telephone: (415) 854-0370 16 Facsimile: (415) 854-0370 Email: greg@shopoffcavallo.com 17 18 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 19 Executed on April 16, 2021, at San Francisco, California. 20 21 22 TERESA L. STEEN 23 24 25 26 27 3 28 NOTICE OF ERRATA OF EXHIBITS TO DECLARATION OF CHRISTIAN P. FOOTE IN SUPPORT OF ALICE PHELAN SULLIVAN CORPORATION’S MOTIONS IN LIMINE ClarkHill\62578\372310\262722547.v1-4/16/21