Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Jeffrey N. Stewart, SBN 140607
LAW OFFICES OF KAREN M. JOHNSON
17771 Cowan, #260, Irvine, CA 92614
TELEPHONE NO.: (949) 590-4065 FAX NO. (Optional): (949) 774-4241
E-MAIL ADDRESS (Optional): jeffrey.stewart@amtrustgroup.com
ATTORNEY FOR (Name): Cross-Defendant Xavier Sanchez Construction
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CRUZ
STREET ADDRESS: 701 Ocean Street
MAILING ADDRESS: 701 Ocean Street
CITY AND ZIP CODE: Santa Cruz 95060
BRANCH NAME:
PLAINTIFF/PETITIONER: CANDACE DEKKERT
DEFENDANT/RESPONDENT: PAUL LATALA, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE LIMITED CASE 20CV02691
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: June 1, 2023 Time: 8:30 am Dept.: 10 Div.: Civil Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Jeffrey N. Stewart
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. This statement is submitted by party (name): Cross-Defendant Xavier Sanchez Construction
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):
b. The cross-complaint, if any, was filed on (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 date by which
they may be served):
4. Description of case
a. Type of case in complaint cross-complaint (Describe, including causes of action):
This is a construction defect case pertaining to the residence at 170 Belvedere Terrace, Santa Cruz. Plaintiff
has also asserted claim for failure to disclose.
Page 1 of 5
Form Adopted for Mandatory Use
Judicial Council of California
CASE MANAGEMENT STATEMENT Cal. Rules of Court,
rules 3.720–3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: CANDACE DEKKERT
20CV02691
DEFENDANT/RESPONDENT: PAUL LATALA, 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.)
Plaintiff claims that the seller did not disclose prior flooding of the property and drainage defects. Plaintiff also
claims a wide variety of construction defects.
(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 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. 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):
TRIALS: 9/25/23, 9/29/23, 10/23/23, 11/6/23, 11/17/23, 12/8/23, 2/2/24, 4/4/24, 6/17/24, 2/24/25
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 5-10
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 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
CASE NUMBER:
PLAINTIFF/PETITIONER: CANDACE DEKKERT
20CV02691
DEFENDANT/RESPONDENT: PAUL LATALA, 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
Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference
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
CASE NUMBER:
PLAINTIFF/PETITIONER: CANDACE DEKKERT
20CV02691
DEFENDANT/RESPONDENT: PAUL LATALA, et al.
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name): AmTrust International Underwriters Limited
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 coordinate 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
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendants Written Discovery Per Code
Defendants Party Depositions Per Code
Defendants Expert Discovery Per Code
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
CASE NUMBER:
PLAINTIFF/PETITIONER: CANDACE DEKKERT
20CV02691
DEFENDANT/RESPONDENT: PAUL LATALA, 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
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. 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: May 17, 2023
Jeffrey N. Stewart
(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
1 PROOF OF SERVICE
2 I, the undersigned, declare as follows:
3 I am employed in the County of Orange, State of California. I am over the age of 18
4 years, and not a party to the within action. I am an employee of or agent for LAW OFFICES
OF KAREN M. JOHNSON, whose business address is 17771 Cowan, Ste. 260, Irvine, CA
5 92614.
6 On May 17, 2023, I served the foregoing document(s): CASE MANAGEMENT
CONFERENCE STATEMENT OF CROSS-DEFENDANT XAVIER SANCHEZ
7
CONSTRUCTOIN to the following party(ies) in this action addressed as follows:
8
PLEASE SEE ATTACHED SERVICE LIST
9
(BY MAIL) I caused a true copy of each document, placed in a sealed envelope with
LAW OFFICES OF KAREN M. JOHNSON
10 postage fully paid, to be placed in the United States mail at Irvine, California. I am
“readily familiar” with this firm’s business practice for collection and processing of
11
mail, that in the ordinary course of business said document(s) would be deposited with
the U.S. Postal Service on that same day. I understand that the service shall be presumed
TEL 949.590.4065 • FAX 949.774.4241
12
invalid if the postal cancellation date or postage meter date on the envelope is more than
IRVINE, CALIFORNIA 92614
17771 COWAN, STE. 260
13 one day after the date of deposit for mailing contained in this affidavit.
14 (BY PERSONAL SERVICE) I caused to be delivered each such document by hand to
each addressee above.
15
16 (BY OVERNIGHT DELIVERY) I caused a true copy of each document, placed in a sealed
envelope with delivery fees provided for, to be deposited in a box regularly maintained
17 by Federal Express(Fedex). I am readily familiar with this firm’s practice for
collection and processing of documents for overnight delivery and know that in the
18 ordinary course of business practice the document(s) described above will be deposited
19 in a box or other facility regularly maintained by Fedex or delivered to a courier or driver
authorized by Fedex to receive documents on the same date it is placed for collection.
20
(BY FACSIMILE) By use of facsimile machine number (949) 774-4241, I served a copy
21 of the within document(s) on the above interested parties at the facsimile numbers listed
above. The transmission was reported as complete and without error. The transmission
22
report was properly issued by the transmitting facsimile machine.
23
(ONLY BY ELECTRONIC TRANSMISSION) Only by e-mailing the documents(s) to the
24 persons at the email address(es) listed, pursuant to California Code of Civil Procedure
section 1010.6(e)(1), effective January 1, 2021.
25
Executed on May 17, 2023, at Irvine, California. I declare under penalty of perjury
26 under the laws of the State of California that the above is true and correct.
27
28
JESSICA TAYLOR
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PROOF OF SERVICE
CANDACE DEKKERT v. PAUL LATALA, et al.
1 Santa Cruz Superior Court Case No: 20CV02691
2
SERVICE LIST
3
John P. Hannon II, Esq. T: 831-239-4898
4 LAW OFFICES OF JOHN P. HANNON II E: jph3003@yahoo.com;
273 Knappton Road
5 Naselle, WA 98638 Attorney for Plaintiff,
6 CANDACE DEKKERT
7 Von Ryan Reyes, Esq. T: 669-317-4282
FORAN GLENNON E: vreyes@fgppr.com;
8 1741 Technology Drive, Ste. 250
San Jose, CA 95110
9
LAW OFFICES OF KAREN M. JOHNSON
10
Nora A. Boardman, Esq. T: 714-571-0407
11 LAW OFFICES OF JOHN A. HAUSER F: 877-369-5799
One Point Drive, 6th Floor E: nora.boardman@thehartford.com;
TEL 949.590.4065 • FAX 949.774.4241
12 Brea, CA 92821
IRVINE, CALIFORNIA 92614
17771 COWAN, STE. 260
13
Attorneys for Defendant/Cross-
14 Complainants, PAUL LATALA and
LATALA HOMES, INC.
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PROOF OF SERVICE
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Jeffrey N. Stewart, SBN 140607 LAW OFFICES OF KAREN M. JOHNSON 17771 Cowan, #260, Irvine, CA 92614 TELEPHONE NO.: (949) 590-4065 FAX NO. (Optional): (949) 774-4241 E-MAIL ADDRESS (Optional): jeffrey.stewart@amtrustgroup.com ATTORNEY FOR (Name): Cross-Defendant Xavier Sanchez Construction SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CRUZ STREET ADDRESS: 701 Ocean Street MAILING ADDRESS: 701 Ocean Street CITY AND ZIP CODE: Santa Cruz 95060 BRANCH NAME: PLAINTIFF/PETITIONER: CANDACE DEKKERT DEFENDANT/RESPONDENT: PAUL LATALA, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE 20CV02691 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: June 1, 2023 Time: 8:30 am Dept.: 10 Div.: Civil Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Jeffrey N. Stewart INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): Cross-Defendant Xavier Sanchez Construction 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): b. The cross-complaint, if any, was filed on (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 date by which they may be served): 4. Description of case a. Type of case in complaint cross-complaint (Describe, including causes of action): This is a construction defect case pertaining to the residence at 170 Belvedere Terrace, Santa Cruz. Plaintiff has also asserted claim for failure to disclose. Page 1 of 5 Form Adopted for Mandatory Use Judicial Council of California CASE MANAGEMENT STATEMENT Cal. Rules of Court, rules 3.720–3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: CANDACE DEKKERT 20CV02691 DEFENDANT/RESPONDENT: PAUL LATALA, 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.) Plaintiff claims that the seller did not disclose prior flooding of the property and drainage defects. Plaintiff also claims a wide variety of construction defects. (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 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. 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): TRIALS: 9/25/23, 9/29/23, 10/23/23, 11/6/23, 11/17/23, 12/8/23, 2/2/24, 4/4/24, 6/17/24, 2/24/25 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 5-10 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 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 CASE NUMBER: PLAINTIFF/PETITIONER: CANDACE DEKKERT 20CV02691 DEFENDANT/RESPONDENT: PAUL LATALA, 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 Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference 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 CASE NUMBER: PLAINTIFF/PETITIONER: CANDACE DEKKERT 20CV02691 DEFENDANT/RESPONDENT: PAUL LATALA, et al. 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): AmTrust International Underwriters Limited 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 coordinate 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 The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendants Written Discovery Per Code Defendants Party Depositions Per Code Defendants Expert Discovery Per Code 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 CASE NUMBER: PLAINTIFF/PETITIONER: CANDACE DEKKERT 20CV02691 DEFENDANT/RESPONDENT: PAUL LATALA, 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 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. 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: May 17, 2023 Jeffrey N. Stewart (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 1 PROOF OF SERVICE 2 I, the undersigned, declare as follows: 3 I am employed in the County of Orange, State of California. I am over the age of 18 4 years, and not a party to the within action. I am an employee of or agent for LAW OFFICES OF KAREN M. JOHNSON, whose business address is 17771 Cowan, Ste. 260, Irvine, CA 5 92614. 6 On May 17, 2023, I served the foregoing document(s): CASE MANAGEMENT CONFERENCE STATEMENT OF CROSS-DEFENDANT XAVIER SANCHEZ 7 CONSTRUCTOIN to the following party(ies) in this action addressed as follows: 8 PLEASE SEE ATTACHED SERVICE LIST 9 (BY MAIL) I caused a true copy of each document, placed in a sealed envelope with LAW OFFICES OF KAREN M. JOHNSON 10 postage fully paid, to be placed in the United States mail at Irvine, California. I am “readily familiar” with this firm’s business practice for collection and processing of 11 mail, that in the ordinary course of business said document(s) would be deposited with the U.S. Postal Service on that same day. I understand that the service shall be presumed TEL 949.590.4065 • FAX 949.774.4241 12 invalid if the postal cancellation date or postage meter date on the envelope is more than IRVINE, CALIFORNIA 92614 17771 COWAN, STE. 260 13 one day after the date of deposit for mailing contained in this affidavit. 14 (BY PERSONAL SERVICE) I caused to be delivered each such document by hand to each addressee above. 15 16 (BY OVERNIGHT DELIVERY) I caused a true copy of each document, placed in a sealed envelope with delivery fees provided for, to be deposited in a box regularly maintained 17 by Federal Express(Fedex). I am readily familiar with this firm’s practice for collection and processing of documents for overnight delivery and know that in the 18 ordinary course of business practice the document(s) described above will be deposited 19 in a box or other facility regularly maintained by Fedex or delivered to a courier or driver authorized by Fedex to receive documents on the same date it is placed for collection. 20 (BY FACSIMILE) By use of facsimile machine number (949) 774-4241, I served a copy 21 of the within document(s) on the above interested parties at the facsimile numbers listed above. The transmission was reported as complete and without error. The transmission 22 report was properly issued by the transmitting facsimile machine. 23 (ONLY BY ELECTRONIC TRANSMISSION) Only by e-mailing the documents(s) to the 24 persons at the email address(es) listed, pursuant to California Code of Civil Procedure section 1010.6(e)(1), effective January 1, 2021. 25 Executed on May 17, 2023, at Irvine, California. I declare under penalty of perjury 26 under the laws of the State of California that the above is true and correct. 27 28 JESSICA TAYLOR -1- PROOF OF SERVICE CANDACE DEKKERT v. PAUL LATALA, et al. 1 Santa Cruz Superior Court Case No: 20CV02691 2 SERVICE LIST 3 John P. Hannon II, Esq. T: 831-239-4898 4 LAW OFFICES OF JOHN P. HANNON II E: jph3003@yahoo.com; 273 Knappton Road 5 Naselle, WA 98638 Attorney for Plaintiff, 6 CANDACE DEKKERT 7 Von Ryan Reyes, Esq. T: 669-317-4282 FORAN GLENNON E: vreyes@fgppr.com; 8 1741 Technology Drive, Ste. 250 San Jose, CA 95110 9 LAW OFFICES OF KAREN M. JOHNSON 10 Nora A. Boardman, Esq. T: 714-571-0407 11 LAW OFFICES OF JOHN A. HAUSER F: 877-369-5799 One Point Drive, 6th Floor E: nora.boardman@thehartford.com; TEL 949.590.4065 • FAX 949.774.4241 12 Brea, CA 92821 IRVINE, CALIFORNIA 92614 17771 COWAN, STE. 260 13 Attorneys for Defendant/Cross- 14 Complainants, PAUL LATALA and LATALA HOMES, INC. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- PROOF OF SERVICE