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- DO NOT FILE WTH THE COURT- CIV-OsO
-u rtEss You ARE APPLYTNG FOR A DEFAULT JUDGMENT ttNDER CODE OF CtVtL pROCEDttRE
S 585 -
ATTORNEYORPARryWTHOUTATTORNEY (NareandAddcss): TELEPHONE NO.: FOR COURT USE ONLY
Ioseph Whittington, Esq. (661)323-1400
Rodriguez & Associates SBN: 295516
I128 Truxtun Avenue, Bakersfield, CA 93301
fax number: (661) 323-0132 email:
ATToRNEY FoR (name):
[1411SCOtt Hair
SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN
STREETADDRESS: I2I5 TTXIUN AVCNUE
MAILINGADDRESS,121 5 TrUXtun AVenUe
clw AND ztP cooe' Bakersfield,
93301
BMNCH NAME: Metro Division
PLAINTIFF:AIan Scott Hair and Mary Charles Hair
DEFENDANT:3MB, LLC., et al.
CASE NUMBER:
STATEMENT OF DAMAGES
(Personal Injury or Wrongful Death) BCV-18-100592
To (name of one defendanton\y):CITADEVELOPMENT, INC.
(name of one plaintiff only):Mary
Plaintiff Charles Hair
seeks damages in the above-entitled action, as follows:
1. General damaoes AMOUNT
l-l Pain, sluffering,
and inmnvenience $
".
b. l-l Emotional distress. $
[X-l Loss of consortium ............ $ 1,000,000
".
d. l-l Loss of sociey and companionship (wrongfu! death actions only) ............. $
e. l-l Other (specifi) $
f. l-l other (specify) $
S.t-l Continued on Attachment 1.g.
2. Specialdamages
$
$
$
d. l-l Loss of future earningcapacity (present value) ........... $
l-l Property damage $
".
f. l-l Funeral expenses (wrongful death actions onty) ............ $
$
$
i. l-l other (specify) $
j. l-l offer (specify) $
k. l--l Continued on Attachment 2.k.
3. l-l Punitive damages: Plaintiff reserves the right to seek punitive damages in the amount
when pursuing a judgment in the suit filed against you.
Date: fiugus123,2022
Joseph Whittineton. Esq.
(TYPE OR PRINT NAME) OF PLAINTIFF
OR PLAINTIFF)
(Proof of service on reverse)
U*
Form Adooted for Mandatoru STATEMENT OF DAMAGES Pmedure
Code of Civil 425.115
SS 425.1'1,
d Califo6ia
JudichICouncil M.wdinfo.a.gov
C|V45O [Rev. January 1,2OO71 (Personal lnjury or Wrongful Death) W€sfta{r Doc & Fdm Builder-
Alan Scott Hair and Mary Charles Hair
BCV-18-100592
3MB, LLC., et al.
X
CITA DEVELOPMENT, INC.
X
X PROOF OF SERVICE OF DELIVERY TO CITA DEVELOPMENT, INC. PROOF OF
X SERVICE OTHER DEFENADANTS VIA ELECTRONIC MAIL.
Attorney or Party without Attorney: For Court Use Only
JOSEPH WHITTINGTON (SBN 295516)
RODRIGUEZ & ASSOCIATES
1128 TRUXTUN AVENUE
BAKERSFIELD, CA 93301
Telephone No: (661) 323-1400
Attorney For: Ref. No. or File No.:
ALAN SCOTT HAIR
Insert name of Court, and Judicial District and Branch Court:
SUPERIOR COURT OF CALIFORNIA COUNTY OF KERN
Plaintiff:ALAN SCOTT HAIR; et al.
Defendant: CITA DEVELOPMENT, INC.; et al.
PROOF OF SERVICE Hearing Date: Time: Dept/Div: Case Number:
BCV-18-100592
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 the STATEMENT OF DAMAGES (PERSONAL INJURY OR WRONGFUL DEATH) X2 (ALAN SCOTT HAIR; MARY
CHARLES HAIR)
3. a. Party served: CITA DEVELOPMENT, INC.
b. Person served: KASANDRA DOE, CLERK , Hispanic , Female , Age: 30 , Hair: Black , Eyes: Brown , 5'6" , Weight: 180
4. Address where the party was served: 1201 24TH STREET B110, BAKERSFIELD, CA 93301
5. I served the party:
a. by substituted service. On: Tue, Sep 06 2022 at: 10:15 AM by leaving the copies with or in the presence of:
KASANDRA DOE, CLERK , Hispanic , Female , Age: 30 , Hair: Black , Eyes: Brown , 5'6" , Weight: 180
(1) ( a Person in charge at least 18 years of age apparently in charge of the office or usual place of business of the person
served. I informed him or her of the general nature of the papers.
(2) A declaration of mailing is attached.
Recoverable cost Per CCP 1033.5(a)(4)(B)
6. Person Who Served Papers:
a. Larry Billingsley (507, Kern County) d. The Fee for Service was:
b. FIRST LEGAL e. I am: A Registered California Process Server
2300 Tulare Street, Suite 130
FRESNO, CA 93721
c. (559) 233-1993
7. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
09/06/2022
(Date) (Signature)
Judicial Council Form PROOF OF 7556443
Rule 2.150.(a)&(b) Rev January 1, 2007 SERVICE (8395229)
Attorney or Party without Attorney: For Court Use Only
JOSEPH WHITTINGTON (SBN 295516)
RODRIGUEZ & ASSOCIATES
1128 TRUXTUN AVENUE
BAKERSFIELD CA, 93301
Telephone No: (661) 323-1400
Attorney For: Ref. No. or File No.:
ALAN SCOTT HAIR
Insert name of Court, and Judicial District and Branch Court:
SUPERIOR COURT OF CALIFORNIA COUNTY OF KERN
Plaintiff:ALAN SCOTT HAIR; et al.
Defendant: CITA DEVELOPMENT, INC.; et al.
PROOF OF SERVICE Hearing Date: Time: Dept/Div: Case Number:
BCV-18-100592
By Mail
1. I am over the age of 18 and not a party to this action. I am employed in the county where the mailing occurred.
2. I served copies of the STATEMENT OF DAMAGES (PERSONAL INJURY OR WRONGFUL DEATH) X2 (ALAN SCOTT HAIR; MARY
CHARLES HAIR)
3. By placing a true copy of each document in the United States mail, in a sealed envelope by First Class mail with postage
prepaid as follows:
a. Date of Mailing: Tue, Sep 6, 2022
b. Place of Mailing: FRESNO, CA
c. Addressed as follows: CITA DEVELOPMENT, INC.
1201 24TH STREET, B110 BAKERSFIELD, CA 93301
4. I am readily familiar with the business practice for collection and processing of correspondence as deposited with the U.S. Postal
Service on Tue, Sep 6, 2022 in the ordinary course of business.
Recoverable cost Per CCP 1033.5(a)(4)(B)
5. Person Serving:
a. Jennifer White d. The Fee for Service was:
b. FIRST LEGAL e. I am: Not a Registered California Process Server
2300 Tulare Street, Suite 130
FRESNO, CA 93721
c. (559) 233-1993
6. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
09/06/2022
(Date) (Signature)
Judicial Council Form PROOF OF SERVICE 7556443
Rule 2.150.(a)&(b) Rev January 1, 2007 BY MAIL (8395229)
1
PROOF OF SERVICE
2
3
STATE OF CALIFORNIA, COUNTY OF KERN
4
I am employed in the County of Kern, State of California. I am over the age of 18
5 and not a party to the within action; my business address is 1128 Truxtun Avenue,
Bakersfield, California 93301
6
7 On August 24, 2022, I served the foregoing document described as follows:
STATEMENT OF DAMAGES
8
9
X by placing the true copies thereof
10 by placing the original
11
addressed as follows:
12
13 BY MAIL - I enclosed such document in a sealed envelope and caused such
envelope to be deposited in the mail at Bakersfield, California. The envelope was mailed
14
with postage thereon fully prepaid. I am “readily familiar” with this firm’s practice of
15 collection and processing of correspondence for mailing. It is deposited with the U.S.
16 Postal Service on that same day in the ordinary course of business. I am aware that on
motion of party, service is presumed invalid if postal cancellation date or postage meter date
17
is more than one day after date of deposit for mailing affidavit.
18
BY OVERNIGHT DELIVERY - I enclosed such document in a sealed envelope
19
and caused it to be deposited in a box or other facility regularly maintained by the express
20 service carrier, or delivered to an authorized courier or driver authorized by the express
21
service carrier to receive documents, in an envelope or package designated by the express
service carrier with delivery fees paid or provided for, addressed to the person on whom it is
22 to be served, at the office address as last given by that person.
23
BY FACSIMILE - I caused such document to be transmitted to a facsimile machine
24
maintained by the person on whom it is served at the facsimile machine telephone number
25 as last given by that person.
26
BY PERSONAL SERVICE - I enclosed such document in a sealed envelope and
27 caused it to be delivered by hand to the offices of the addressee(s).
28
PROOF OF SERVICE
1
X BY ELECTRONIC MAIL - I caused the above-referenced document to be
2 delivered to the e-mail address as noted.
3
Executed on August 24, 2022, at Bakersfield, California.
4
5
X (State) I declare under penalty of perjury under the laws of the State of
California that the above is true and correct.
6
7
8
9 STEPHANIE LOPEZ
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
PROOF OF SERVICE
1
SERVICE LIST
2
3
Mary E. Ashcraft, Esq. Attorneys for Defendants/Cross-
4 Elizabeth A. Thomasian, Esq. Complainants:
5
CHURCH LAW GROUP, INC. 3MB, LLC and Robert E. Bell
802 West Pinedale Avenue, Suite 104
6 Fresno, CA 93711
7 eservice@churh-law.com
mashcraft@church-law.com
8
ethomasian@church-law.com
9
mlujan@church-law.com
10
Jody Steinberg, Esq. Attorneys for Defendant:
11
Nicholas S. Walls, Esq. Juicy Burger Corporation and
12 Hanger, Steinberg, Shapiro & Ash, ALC Mohamed Muthana, Jr.
13 LOS ANGELES • Inland Empire •
Bakersfield
14
21031 Ventura Blvd, Suite 800,
15 Woodland Hills, CA 91364
direct (818) 206-0216
16
nsw@hssalaw.com
17 js@hssalaw.com
18
19
Nathan M. Hodges, Esq. Attorneys for Defendant:
Hodges Law Group Treble LLC
20 1925 G Street
21 Bakersfield, CA 93301
Nathan@hodges-lawgroup.com
22
kelly@hodges-lawgroup.com
23
24
25
26
27
28
SERVICE LIST -3
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- DO NOT FILE WTH THE COURT- CIV-OsO -u rtEss You ARE APPLYTNG FOR A DEFAULT JUDGMENT ttNDER CODE OF CtVtL pROCEDttRE S 585 - ATTORNEYORPARryWTHOUTATTORNEY (NareandAddcss): TELEPHONE NO.: FOR COURT USE ONLY Ioseph Whittington, Esq. (661)323-1400 Rodriguez & Associates SBN: 295516 I128 Truxtun Avenue, Bakersfield, CA 93301 fax number: (661) 323-0132 email: ATToRNEY FoR (name): [1411SCOtt Hair SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN STREETADDRESS: I2I5 TTXIUN AVCNUE MAILINGADDRESS,121 5 TrUXtun AVenUe clw AND ztP cooe' Bakersfield, 93301 BMNCH NAME: Metro Division PLAINTIFF:AIan Scott Hair and Mary Charles Hair DEFENDANT:3MB, LLC., et al. CASE NUMBER: STATEMENT OF DAMAGES (Personal Injury or Wrongful Death) BCV-18-100592 To (name of one defendanton\y):CITADEVELOPMENT, INC. (name of one plaintiff only):Mary Plaintiff Charles Hair seeks damages in the above-entitled action, as follows: 1. General damaoes AMOUNT l-l Pain, sluffering, and inmnvenience $ ". b. l-l Emotional distress. $ [X-l Loss of consortium ............ $ 1,000,000 ". d. l-l Loss of sociey and companionship (wrongfu! death actions only) ............. $ e. l-l Other (specifi) $ f. l-l other (specify) $ S.t-l Continued on Attachment 1.g. 2. Specialdamages $ $ $ d. l-l Loss of future earningcapacity (present value) ........... $ l-l Property damage $ ". f. l-l Funeral expenses (wrongful death actions onty) ............ $ $ $ i. l-l other (specify) $ j. l-l offer (specify) $ k. l--l Continued on Attachment 2.k. 3. l-l Punitive damages: Plaintiff reserves the right to seek punitive damages in the amount when pursuing a judgment in the suit filed against you. Date: fiugus123,2022 Joseph Whittineton. Esq. (TYPE OR PRINT NAME) OF PLAINTIFF OR PLAINTIFF) (Proof of service on reverse) U* Form Adooted for Mandatoru STATEMENT OF DAMAGES Pmedure Code of Civil 425.115 SS 425.1'1, d Califo6ia JudichICouncil M.wdinfo.a.gov C|V45O [Rev. January 1,2OO71 (Personal lnjury or Wrongful Death) W€sfta{r Doc & Fdm Builder- Alan Scott Hair and Mary Charles Hair BCV-18-100592 3MB, LLC., et al. X CITA DEVELOPMENT, INC. X X PROOF OF SERVICE OF DELIVERY TO CITA DEVELOPMENT, INC. PROOF OF X SERVICE OTHER DEFENADANTS VIA ELECTRONIC MAIL. Attorney or Party without Attorney: For Court Use Only JOSEPH WHITTINGTON (SBN 295516) RODRIGUEZ & ASSOCIATES 1128 TRUXTUN AVENUE BAKERSFIELD, CA 93301 Telephone No: (661) 323-1400 Attorney For: Ref. No. or File No.: ALAN SCOTT HAIR Insert name of Court, and Judicial District and Branch Court: SUPERIOR COURT OF CALIFORNIA COUNTY OF KERN Plaintiff:ALAN SCOTT HAIR; et al. Defendant: CITA DEVELOPMENT, INC.; et al. PROOF OF SERVICE Hearing Date: Time: Dept/Div: Case Number: BCV-18-100592 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 the STATEMENT OF DAMAGES (PERSONAL INJURY OR WRONGFUL DEATH) X2 (ALAN SCOTT HAIR; MARY CHARLES HAIR) 3. a. Party served: CITA DEVELOPMENT, INC. b. Person served: KASANDRA DOE, CLERK , Hispanic , Female , Age: 30 , Hair: Black , Eyes: Brown , 5'6" , Weight: 180 4. Address where the party was served: 1201 24TH STREET B110, BAKERSFIELD, CA 93301 5. I served the party: a. by substituted service. On: Tue, Sep 06 2022 at: 10:15 AM by leaving the copies with or in the presence of: KASANDRA DOE, CLERK , Hispanic , Female , Age: 30 , Hair: Black , Eyes: Brown , 5'6" , Weight: 180 (1) ( a Person in charge at least 18 years of age apparently in charge of the office or usual place of business of the person served. I informed him or her of the general nature of the papers. (2) A declaration of mailing is attached. Recoverable cost Per CCP 1033.5(a)(4)(B) 6. Person Who Served Papers: a. Larry Billingsley (507, Kern County) d. The Fee for Service was: b. FIRST LEGAL e. I am: A Registered California Process Server 2300 Tulare Street, Suite 130 FRESNO, CA 93721 c. (559) 233-1993 7. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 09/06/2022 (Date) (Signature) Judicial Council Form PROOF OF 7556443 Rule 2.150.(a)&(b) Rev January 1, 2007 SERVICE (8395229) Attorney or Party without Attorney: For Court Use Only JOSEPH WHITTINGTON (SBN 295516) RODRIGUEZ & ASSOCIATES 1128 TRUXTUN AVENUE BAKERSFIELD CA, 93301 Telephone No: (661) 323-1400 Attorney For: Ref. No. or File No.: ALAN SCOTT HAIR Insert name of Court, and Judicial District and Branch Court: SUPERIOR COURT OF CALIFORNIA COUNTY OF KERN Plaintiff:ALAN SCOTT HAIR; et al. Defendant: CITA DEVELOPMENT, INC.; et al. PROOF OF SERVICE Hearing Date: Time: Dept/Div: Case Number: BCV-18-100592 By Mail 1. I am over the age of 18 and not a party to this action. I am employed in the county where the mailing occurred. 2. I served copies of the STATEMENT OF DAMAGES (PERSONAL INJURY OR WRONGFUL DEATH) X2 (ALAN SCOTT HAIR; MARY CHARLES HAIR) 3. By placing a true copy of each document in the United States mail, in a sealed envelope by First Class mail with postage prepaid as follows: a. Date of Mailing: Tue, Sep 6, 2022 b. Place of Mailing: FRESNO, CA c. Addressed as follows: CITA DEVELOPMENT, INC. 1201 24TH STREET, B110 BAKERSFIELD, CA 93301 4. I am readily familiar with the business practice for collection and processing of correspondence as deposited with the U.S. Postal Service on Tue, Sep 6, 2022 in the ordinary course of business. Recoverable cost Per CCP 1033.5(a)(4)(B) 5. Person Serving: a. Jennifer White d. The Fee for Service was: b. FIRST LEGAL e. I am: Not a Registered California Process Server 2300 Tulare Street, Suite 130 FRESNO, CA 93721 c. (559) 233-1993 6. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 09/06/2022 (Date) (Signature) Judicial Council Form PROOF OF SERVICE 7556443 Rule 2.150.(a)&(b) Rev January 1, 2007 BY MAIL (8395229) 1 PROOF OF SERVICE 2 3 STATE OF CALIFORNIA, COUNTY OF KERN 4 I am employed in the County of Kern, State of California. I am over the age of 18 5 and not a party to the within action; my business address is 1128 Truxtun Avenue, Bakersfield, California 93301 6 7 On August 24, 2022, I served the foregoing document described as follows: STATEMENT OF DAMAGES 8 9 X by placing the true copies thereof 10 by placing the original 11 addressed as follows: 12 13 BY MAIL - I enclosed such document in a sealed envelope and caused such envelope to be deposited in the mail at Bakersfield, California. The envelope was mailed 14 with postage thereon fully prepaid. I am “readily familiar” with this firm’s practice of 15 collection and processing of correspondence for mailing. It is deposited with the U.S. 16 Postal Service on that same day in the ordinary course of business. I am aware that on motion of party, service is presumed invalid if postal cancellation date or postage meter date 17 is more than one day after date of deposit for mailing affidavit. 18 BY OVERNIGHT DELIVERY - I enclosed such document in a sealed envelope 19 and caused it to be deposited in a box or other facility regularly maintained by the express 20 service carrier, or delivered to an authorized courier or driver authorized by the express 21 service carrier to receive documents, in an envelope or package designated by the express service carrier with delivery fees paid or provided for, addressed to the person on whom it is 22 to be served, at the office address as last given by that person. 23 BY FACSIMILE - I caused such document to be transmitted to a facsimile machine 24 maintained by the person on whom it is served at the facsimile machine telephone number 25 as last given by that person. 26 BY PERSONAL SERVICE - I enclosed such document in a sealed envelope and 27 caused it to be delivered by hand to the offices of the addressee(s). 28 PROOF OF SERVICE 1 X BY ELECTRONIC MAIL - I caused the above-referenced document to be 2 delivered to the e-mail address as noted. 3 Executed on August 24, 2022, at Bakersfield, California. 4 5 X (State) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 6 7 8 9 STEPHANIE LOPEZ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE 1 SERVICE LIST 2 3 Mary E. Ashcraft, Esq. Attorneys for Defendants/Cross- 4 Elizabeth A. Thomasian, Esq. Complainants: 5 CHURCH LAW GROUP, INC. 3MB, LLC and Robert E. Bell 802 West Pinedale Avenue, Suite 104 6 Fresno, CA 93711 7 eservice@churh-law.com mashcraft@church-law.com 8 ethomasian@church-law.com 9 mlujan@church-law.com 10 Jody Steinberg, Esq. Attorneys for Defendant: 11 Nicholas S. Walls, Esq. Juicy Burger Corporation and 12 Hanger, Steinberg, Shapiro & Ash, ALC Mohamed Muthana, Jr. 13 LOS ANGELES • Inland Empire • Bakersfield 14 21031 Ventura Blvd, Suite 800, 15 Woodland Hills, CA 91364 direct (818) 206-0216 16 nsw@hssalaw.com 17 js@hssalaw.com 18 19 Nathan M. Hodges, Esq. Attorneys for Defendant: Hodges Law Group Treble LLC 20 1925 G Street 21 Bakersfield, CA 93301 Nathan@hodges-lawgroup.com 22 kelly@hodges-lawgroup.com 23 24 25 26 27 28 SERVICE LIST -3