Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
Sevan Gobel (SBN: 221768)
Artin Avetisove (SBN: 258777) ELECTRONICALLY FILED
LAGASSE BRANCH BELL + KINKEAD LLP Superior Court of California
626 Wilshire Blvd., Suite 1000
Los Angeles, CA 90017 County of Santa Barbara
TELEPHONE NO.: (213) 817-9152 FAX NO. (Optional): (213) 817-9154 Darrel E. Parker, Executive Officer
E-MAIL ADDRESS (Optional): sgobel@lbbklaw.com
6/7/2021 2:45 PM
ATTORNEY FOR (Name): Plaintiff, KHP IV SANTA BARBARA, LLC
By: Sasha Nasir, Deputy
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA
STREET ADDRESS: 100 Anacapa Street
MAILING ADDRESS: 100 Anacapa Street
CITY AND ZIP CODE: Santa Barbara, CA 93101
BRANCH NAME: Anacapa, South County
PLAINTIFF/PETITIONER: KHP IV SANTA BARBARA, LLC
DEFENDANT/RESPONDENT: YOUNG BROTHERS CONSTRUCTION COMPANY
dba YOUNG COMPANY
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): X UNLIMITED CASE LIMITED CASE 21CV00676
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: June 22, 2021 Time: 8:30 a.m. Dept.: SB3 Div.: Room:
Address of court (if different from the address above):
X Notice of Intent to Appear by Telephone, by (name): Artin Avetisove, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. X This statement is submitted by party (name): Plaintiff, KHP IV SANTA BARBARA, LLC
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): 2/18/2021
b. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. X 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 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):
COMPLAINT FOR DAMAGES: (1) NEGLIGENCE; (2) BREACH OF CONTRACT
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California
CASE MANAGEMENT STATEMENT rules 3.720–3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: KHP IV SANTA BARBARA, LLC CASE NUMBER:
21CV00676
DEFENDANT/RESPONDENT: YOUNG BROTHERS CONSTRUCTION COMPANY
dba YOUNG COMPANY
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.)
Plaintiff alleges defendant breached its construction contract and was negligent in connection with work done at the Hyatt Mar Monte Hotel.
Hazardous materials were released as a result of Defendant’s conduct, causing damages to Plaintiff, including but not limited to remediation costs
and delays in the completion of the project.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
a. The party or parties request X a jury triaI 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):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. X days (specify number): Seven
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial 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 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 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) 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):
CM-110 [Rev. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: KHP IV SANTA BARBARA, LLC CASE NUMBER:
DEFENDANT/RESPONDENT: YOUNG BROTHERS CONSTRUCTION COMPANY 21CV00676
dba YOUNG COMPANY
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):
X Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation X
Agreed to complete mediation by (date):
Mediation completed on (date):
X Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference
X
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
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
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: KHP IV SANTA BARBARA, LLC CASE NUMBER:
YOUNG BROTHERS CONSTRUCTION COMPANY 21CV00676
DEFENDANT/RESPONDENT:
dba YOUNG COMPANY
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes No
c. Coverage issues will significantly affect resolution 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 consolidate wiII 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):
Discovery motions and Pre-Trial Motions
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
Plaintiff Written Discovery December 2021
KHP IV SANTA BARBARA, LLC Depositions December 2021
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: KHP IV SANTA BARBARA, LLC CASE NUMBER:
DEFENDANT/RESPONDENT: YOUNG BROTHERS CONSTRUCTION COMPANY 21CV00676
dba YOUNG COMPANY
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
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
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):
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):
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 7,2021
Artin Avetisove, Esq.
(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. July 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
SUPERIOR COURT OF CALIFORNIA, COURT USE ONLY
SANTA BARBARA COUNTY
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name and Address): TELEPHONE NO.:
Sevan Gobel (SBN: 221768) Tel: (213) 817-9152
Artin Avetisove (SBN: 258777)
LAGASSE BRANCH BELL + KINKEAD LLP
626 Wilshire Blvd., Suite 1000
Los Angeles, CA 90017
SHORT CASE TITLE Judge: Thomas P. Anderle
KHP Capital Partners, et al. v Young Brothers Construction Co. DEPT: SB3
ATTORNEY FOR DEFENDANT: CASE NUMBER:
KHP IV SANTA BARBARA, LLC 21CV00676
I am a resident of the State of California, over the age of eighteen years, and not a party to the within
action. My business address is 626 Wilshire Blvd., Suite 1000, Los Angeles, CA 90017
On June 7, 2021, I caused to be served the within document(s): KHP IV SANTA BARBARA, LLC’S
CASE MANAGEMENT STATEMENT by placing a copy thereof in a separate envelope for each addressee
named hereafter and addressed as follows:
Alex M. Giannetto, Esq.
Natasha Mayat, Esq.
BREMER WHYTE BROWN & O’MEARA LLP
501 West Broadway, Suite 1700
San Diego, CA 92101
Telephone: (619) 236-0048
Facsimile: (619) 236-0047
agiannetto@bremerwhyte.com
nmayat@bermerwhyte.com
Attorneys for Defendant,
YOUNG BROTHERS CONSTRUCTION
COMPANY dba YOUNG COMPANY
.
(XX) ONLY BY ELECTRONIC TRANSMISSION. Only by e-mailing the document(s) to the persons at
the e-mail address(es) listed during the Coronavirus (COVID-19) pandemic, this office will be working
remotely, not able to send physical mail as usual, and is therefore using only electronic mail. No
electronic message or other indication that the transmission was unsuccessful was received within a
reasonable time after the transmission.
( ) BY FAX. In addition to service by mail as set forth above, a copy of said document(s) were also
delivered by facsimile transmission to the addressee pursuant to Code of Civil Procedure §1013(e).
( ) BY PERSONAL SERVICE. I caused said documents to be hand-delivered to the addressee(s) on said
date below, pursuant to Code of Civil Procedure §1011.
( ) BY OVERNIGHT DELIVERY. I deposited said document(s) in a box or other facility regularly
maintained by the express service carrier providing Norco overnight delivery pursuant to Code of Civil
Procedure §1013(c).
( ) BY CERTIFIED MAIL. I am familiar with this firm’s practice of collection and processing
correspondence for mailing with the United States Postal Service, and that the correspondence shall be
deposited with the United States Postal Service this same day in the ordinary course of business pursuant
to Code of Civil Procedure §1020.
I declare under penalty of perjury under the laws of the State of California that the above is true and
correct. Executed on June 7, 2021, at Los Angeles, California.
___________________________________
Evelia Izaguirre
1
PROOF OF SERVICE
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Sevan Gobel (SBN: 221768) Artin Avetisove (SBN: 258777) ELECTRONICALLY FILED LAGASSE BRANCH BELL + KINKEAD LLP Superior Court of California 626 Wilshire Blvd., Suite 1000 Los Angeles, CA 90017 County of Santa Barbara TELEPHONE NO.: (213) 817-9152 FAX NO. (Optional): (213) 817-9154 Darrel E. Parker, Executive Officer E-MAIL ADDRESS (Optional): sgobel@lbbklaw.com 6/7/2021 2:45 PM ATTORNEY FOR (Name): Plaintiff, KHP IV SANTA BARBARA, LLC By: Sasha Nasir, Deputy SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA STREET ADDRESS: 100 Anacapa Street MAILING ADDRESS: 100 Anacapa Street CITY AND ZIP CODE: Santa Barbara, CA 93101 BRANCH NAME: Anacapa, South County PLAINTIFF/PETITIONER: KHP IV SANTA BARBARA, LLC DEFENDANT/RESPONDENT: YOUNG BROTHERS CONSTRUCTION COMPANY dba YOUNG COMPANY CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): X UNLIMITED CASE LIMITED CASE 21CV00676 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: June 22, 2021 Time: 8:30 a.m. Dept.: SB3 Div.: Room: Address of court (if different from the address above): X Notice of Intent to Appear by Telephone, by (name): Artin Avetisove, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. X This statement is submitted by party (name): Plaintiff, KHP IV SANTA BARBARA, LLC b. This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): 2/18/2021 b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. X 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 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): COMPLAINT FOR DAMAGES: (1) NEGLIGENCE; (2) BREACH OF CONTRACT Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: KHP IV SANTA BARBARA, LLC CASE NUMBER: 21CV00676 DEFENDANT/RESPONDENT: YOUNG BROTHERS CONSTRUCTION COMPANY dba YOUNG COMPANY 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.) Plaintiff alleges defendant breached its construction contract and was negligent in connection with work done at the Hyatt Mar Monte Hotel. Hazardous materials were released as a result of Defendant’s conduct, causing damages to Plaintiff, including but not limited to remediation costs and delays in the completion of the project. (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial a. The party or parties request X a jury triaI 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): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. X days (specify number): Seven b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial 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 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 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) 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): CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: KHP IV SANTA BARBARA, LLC CASE NUMBER: DEFENDANT/RESPONDENT: YOUNG BROTHERS CONSTRUCTION COMPANY 21CV00676 dba YOUNG COMPANY 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): X Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation X Agreed to complete mediation by (date): Mediation completed on (date): X Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference X Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation 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 ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: KHP IV SANTA BARBARA, LLC CASE NUMBER: YOUNG BROTHERS CONSTRUCTION COMPANY 21CV00676 DEFENDANT/RESPONDENT: dba YOUNG COMPANY 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes No c. Coverage issues will significantly affect resolution 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 consolidate wiII 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): Discovery motions and Pre-Trial Motions 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 Plaintiff Written Discovery December 2021 KHP IV SANTA BARBARA, LLC Depositions December 2021 c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: KHP IV SANTA BARBARA, LLC CASE NUMBER: DEFENDANT/RESPONDENT: YOUNG BROTHERS CONSTRUCTION COMPANY 21CV00676 dba YOUNG COMPANY 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 The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 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): 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): 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 7,2021 Artin Avetisove, Esq. (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. July 1, 2011] Page 5 of 5 CASE MANAGEMENT STATEMENT SUPERIOR COURT OF CALIFORNIA, COURT USE ONLY SANTA BARBARA COUNTY ATTORNEY OR PARTY WITHOUT ATTORNEY (Name and Address): TELEPHONE NO.: Sevan Gobel (SBN: 221768) Tel: (213) 817-9152 Artin Avetisove (SBN: 258777) LAGASSE BRANCH BELL + KINKEAD LLP 626 Wilshire Blvd., Suite 1000 Los Angeles, CA 90017 SHORT CASE TITLE Judge: Thomas P. Anderle KHP Capital Partners, et al. v Young Brothers Construction Co. DEPT: SB3 ATTORNEY FOR DEFENDANT: CASE NUMBER: KHP IV SANTA BARBARA, LLC 21CV00676 I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is 626 Wilshire Blvd., Suite 1000, Los Angeles, CA 90017 On June 7, 2021, I caused to be served the within document(s): KHP IV SANTA BARBARA, LLC’S CASE MANAGEMENT STATEMENT by placing a copy thereof in a separate envelope for each addressee named hereafter and addressed as follows: Alex M. Giannetto, Esq. Natasha Mayat, Esq. BREMER WHYTE BROWN & O’MEARA LLP 501 West Broadway, Suite 1700 San Diego, CA 92101 Telephone: (619) 236-0048 Facsimile: (619) 236-0047 agiannetto@bremerwhyte.com nmayat@bermerwhyte.com Attorneys for Defendant, YOUNG BROTHERS CONSTRUCTION COMPANY dba YOUNG COMPANY . (XX) ONLY BY ELECTRONIC TRANSMISSION. Only by e-mailing the document(s) to the persons at the e-mail address(es) listed during the Coronavirus (COVID-19) pandemic, this office will be working remotely, not able to send physical mail as usual, and is therefore using only electronic mail. No electronic message or other indication that the transmission was unsuccessful was received within a reasonable time after the transmission. ( ) BY FAX. In addition to service by mail as set forth above, a copy of said document(s) were also delivered by facsimile transmission to the addressee pursuant to Code of Civil Procedure §1013(e). ( ) BY PERSONAL SERVICE. I caused said documents to be hand-delivered to the addressee(s) on said date below, pursuant to Code of Civil Procedure §1011. ( ) BY OVERNIGHT DELIVERY. I deposited said document(s) in a box or other facility regularly maintained by the express service carrier providing Norco overnight delivery pursuant to Code of Civil Procedure §1013(c). ( ) BY CERTIFIED MAIL. I am familiar with this firm’s practice of collection and processing correspondence for mailing with the United States Postal Service, and that the correspondence shall be deposited with the United States Postal Service this same day in the ordinary course of business pursuant to Code of Civil Procedure §1020. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on June 7, 2021, at Los Angeles, California. ___________________________________ Evelia Izaguirre 1 PROOF OF SERVICE