On July 27, 2021 a
78931Joind00e97e
was filed
involving a dispute between
Duggan, Sean,
and
Duggan, Lynn,
Moffat, Kelly,
The Duggan Family Limited Partnership,
for 06: Unlimited Breach of Contract/Warranty
in the District Court of Sonoma County.
Preview
1 Michael Shklovsky, Esq. (Bar No. 255893)
ANDERSON ZEIGLER
2 A Professional Corporation
50 Old Courthouse Square, 5th Floor
3 Santa Rosa, CA 95404
Telephone: 707/545-4910
4 Facsimile: 707/544-0260
Email: mshklovsky@andersonzeigler.com
5
Attorneys for Nominal Defendant Kelly Moffat
6
7 SUPERIOR COURT, SONOMA COUNTY, CALIFORNIA
8
9 SEAN DUGGAN, an individual, on Case No. SCV-268905
his own behalf and derivatively on
LAW
AT
95402-18 54-026 10 behalf of the Duggan Family
Limited Partnership;
NOTICE OF JOINDER BY NOMINAL
DEFENDANT KELLY MOFFAT IN
Zeiglr ATORNEYS CALIFORN FAX
11 DEFENDANT LYNN DUGGAN’S NOTICE
Plaintiff, OF NON-OPPOSITION TO PLAINTIFF
12 vs. SEAN DUGGAN’S MOTION FOR LEAVE
(707) TO FILE A SECOND AMENDED
CAnderso ORPATIN, SANT 54-910
ROSA,
(707) 15
13
14
LYNN DUGGAN, an individual;
and DOES 1 through 25, inclusive,
Defendants,
COMPLAINT
[UNLIMITED CIVIL]
PROFESINAL
A
1498,
BOX TEL 16
P.O. 17
18
- and —
THE DUGGAN FAMILY LIMITED
PARTNERSHIP, a California
Limited Partnership; and KELLY
MOFFAT, an individual,
Jury Trial Demanded
ASSIGNED FOR ALL PURPOSES:
Judge: Bradford DeMeo
Department: 17
19 Nominal Defendants.
20
21
22
23
24
25
26
27
28
1
NOTICE OF JOINDER BY NOMINAL DEFENDANT KELLY MOFFAT TO DEFENDANT LYNN DUGGAN’S NOTICE OF NON¬
OPPOSITION TO PLAINTIFF SEAN DUGGAN’S MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT
1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN:
2 Please take notice that Nominal Defendant Kelly Moffat hereby joins in Defendant
3 Lynn Duggan’s Notice of Non-Opposition to Plaintiff Sean Duggan’s Motion for Leave to
4 File a Second Amended Complaint Pursuant to California Government Code Section
5 15910.06, filed with the Court on or about July 13, 2023.
6
Date: July 13, 2023 ANDERSON ZEIGLER
7 A Professional Corporation
8
9
Michael Shklovskv^
10 Attorneys for Kelly Moffat
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
NOTICE OF JOINDER BY NOMINAL DEFENDANT KELLY MOFFAT TO DEFENDANT LYNN DUGGAN’S NOTICE OF NON¬
OPPOSITION TO PLAINTIFF SEAN DUGGAN’S MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT
PROOF OF SERVICE
I am a citizen of the United States and a resident of Sonoma County, California. I
am over the age of 18 years and not a party to the within action. My business address is 50
Old Courthouse Sq., 5th FL, Santa Rosa, CA 95404. My electronic service address is
sfloresffandersonzeigler.com.
On July 13, 2023, 1 served the within:
• NOTICE OF JOINDER BY NOMINAL DEFENDANT KELLY MOFFAT IN
DEFENDANT LYNN DUGGAN’S NOTICE OF NON-OPPOSITION TO PLAINTIFF
SEAN DUGGAN’S MOTION FOR LEAVE TO FILE A SECOND AMENDED
COMPLAINT; as follows:
[J BY MAIL I served the above-referenced documents by sending said
document(s) by U.S. Postal Service to the address set forth herein.
BY FEDERAL EXPRESS
By placing said document(s) in a sealed envelope with postage thereon (or
Federal Express charges) fully prepaid, for collection and mailing, addressed
as follows:
SEE ATTACHED SERVICE LIST
BY PERSONAL SERVICE
By causing said document(s) to be delivered to the offices of the addressee as
set forth herein.
KI BY EMAIL TRANSMISSION
I electronically served the above-referenced documents by sending said
document(s) by email transmission to the email address set forth herein.
BY FACSIMILE TRANSMISSION
By sending said document(s) by facsimile transmission to the facsimile
number set forth herein.
COURTESY COPY BY EMAIL
By sending a courtesy copy of said document(s) to the email address set forth
herein.
I am readily familiar with this firm’s practice of collection and processing
correspondence for mailing/Federal Express. It is deposited with the U.S. Postal Service
or Federal Express depository on that same day in the ordinary course of business. I am
aware that on motion of a party served, service is presumed invalid if postal cancellation
date or postage meter date is more than one day after date of deposit for mailing.
I declare under penalty of perjury under the laws of the State of California and the
United States that the foregoing is true and correct. Executed on July 13, 2023, at Santa
Rosa, California.
Stephanie Flores
SERVICE LIST
BY EMAIL:
Attorney for Plaintiff Sean Duggan
Lisa C. McCurdy, Esq.
Blakeley S. Oranburg, Esq.
Greenberg Traurig
1840 Century Park East, Suite 1900
Los Angeles, CA 90067-2121
Tel: 310-586-6512
mccurdyl@gtlaw.com
oranburgb@ gtlaw.com @ gtlaw.com
sharifih@ gtlaw.com
Attorney for Lynn Duggan
Anne Frassetto Olsen
NOLAND, HAMERLY. ETIENNE & HOSS
A Professional Corporation
333 Salinas Street
P.O. Box 2510
Salinas, CA 93902
Tel: 831 424-1414 ext. 210
aolsenanheh.com
Attorneys for The Duggan Family Limited Partnership
Marshall E. Bluestone, Esq.
BLUESTONE ZUNINO & HAMILTON, LLP
50 Old Courthouse Square, Suite 401
Santa Rosa, CA 95404
Tel: 707 526-4250
marshalhdbzhlegal.com
emilee@bfolegal.com
Document Filed Date
July 13, 2023
Case Filing Date
July 27, 2021
Category
06: Unlimited Breach of Contract/Warranty
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1 Michael Shklovsky, Esq. (Bar No. 255893) ANDERSON ZEIGLER 2 A Professional Corporation 50 Old Courthouse Square, 5th Floor 3 Santa Rosa, CA 95404 Telephone: 707/545-4910 4 Facsimile: 707/544-0260 Email: mshklovsky@andersonzeigler.com 5 Attorneys for Nominal Defendant Kelly Moffat 6 7 SUPERIOR COURT, SONOMA COUNTY, CALIFORNIA 8 9 SEAN DUGGAN, an individual, on Case No. SCV-268905 his own behalf and derivatively on LAW AT 95402-18 54-026 10 behalf of the Duggan Family Limited Partnership; NOTICE OF JOINDER BY NOMINAL DEFENDANT KELLY MOFFAT IN Zeiglr ATORNEYS CALIFORN FAX 11 DEFENDANT LYNN DUGGAN’S NOTICE Plaintiff, OF NON-OPPOSITION TO PLAINTIFF 12 vs. SEAN DUGGAN’S MOTION FOR LEAVE (707) TO FILE A SECOND AMENDED CAnderso ORPATIN, SANT 54-910 ROSA, (707) 15 13 14 LYNN DUGGAN, an individual; and DOES 1 through 25, inclusive, Defendants, COMPLAINT [UNLIMITED CIVIL] PROFESINAL A 1498, BOX TEL 16 P.O. 17 18 - and — THE DUGGAN FAMILY LIMITED PARTNERSHIP, a California Limited Partnership; and KELLY MOFFAT, an individual, Jury Trial Demanded ASSIGNED FOR ALL PURPOSES: Judge: Bradford DeMeo Department: 17 19 Nominal Defendants. 20 21 22 23 24 25 26 27 28 1 NOTICE OF JOINDER BY NOMINAL DEFENDANT KELLY MOFFAT TO DEFENDANT LYNN DUGGAN’S NOTICE OF NON¬ OPPOSITION TO PLAINTIFF SEAN DUGGAN’S MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT 1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN: 2 Please take notice that Nominal Defendant Kelly Moffat hereby joins in Defendant 3 Lynn Duggan’s Notice of Non-Opposition to Plaintiff Sean Duggan’s Motion for Leave to 4 File a Second Amended Complaint Pursuant to California Government Code Section 5 15910.06, filed with the Court on or about July 13, 2023. 6 Date: July 13, 2023 ANDERSON ZEIGLER 7 A Professional Corporation 8 9 Michael Shklovskv^ 10 Attorneys for Kelly Moffat 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NOTICE OF JOINDER BY NOMINAL DEFENDANT KELLY MOFFAT TO DEFENDANT LYNN DUGGAN’S NOTICE OF NON¬ OPPOSITION TO PLAINTIFF SEAN DUGGAN’S MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT PROOF OF SERVICE I am a citizen of the United States and a resident of Sonoma County, California. I am over the age of 18 years and not a party to the within action. My business address is 50 Old Courthouse Sq., 5th FL, Santa Rosa, CA 95404. My electronic service address is sfloresffandersonzeigler.com. On July 13, 2023, 1 served the within: • NOTICE OF JOINDER BY NOMINAL DEFENDANT KELLY MOFFAT IN DEFENDANT LYNN DUGGAN’S NOTICE OF NON-OPPOSITION TO PLAINTIFF SEAN DUGGAN’S MOTION FOR LEAVE TO FILE A SECOND AMENDED COMPLAINT; as follows: [J BY MAIL I served the above-referenced documents by sending said document(s) by U.S. Postal Service to the address set forth herein. BY FEDERAL EXPRESS By placing said document(s) in a sealed envelope with postage thereon (or Federal Express charges) fully prepaid, for collection and mailing, addressed as follows: SEE ATTACHED SERVICE LIST BY PERSONAL SERVICE By causing said document(s) to be delivered to the offices of the addressee as set forth herein. KI BY EMAIL TRANSMISSION I electronically served the above-referenced documents by sending said document(s) by email transmission to the email address set forth herein. BY FACSIMILE TRANSMISSION By sending said document(s) by facsimile transmission to the facsimile number set forth herein. COURTESY COPY BY EMAIL By sending a courtesy copy of said document(s) to the email address set forth herein. I am readily familiar with this firm’s practice of collection and processing correspondence for mailing/Federal Express. It is deposited with the U.S. Postal Service or Federal Express depository on that same day in the ordinary course of business. I am aware that on motion of a party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing. I declare under penalty of perjury under the laws of the State of California and the United States that the foregoing is true and correct. Executed on July 13, 2023, at Santa Rosa, California. Stephanie Flores SERVICE LIST BY EMAIL: Attorney for Plaintiff Sean Duggan Lisa C. McCurdy, Esq. Blakeley S. Oranburg, Esq. Greenberg Traurig 1840 Century Park East, Suite 1900 Los Angeles, CA 90067-2121 Tel: 310-586-6512 mccurdyl@gtlaw.com oranburgb@ gtlaw.com @ gtlaw.com sharifih@ gtlaw.com Attorney for Lynn Duggan Anne Frassetto Olsen NOLAND, HAMERLY. ETIENNE & HOSS A Professional Corporation 333 Salinas Street P.O. Box 2510 Salinas, CA 93902 Tel: 831 424-1414 ext. 210 aolsenanheh.com Attorneys for The Duggan Family Limited Partnership Marshall E. Bluestone, Esq. BLUESTONE ZUNINO & HAMILTON, LLP 50 Old Courthouse Square, Suite 401 Santa Rosa, CA 95404 Tel: 707 526-4250 marshalhdbzhlegal.com emilee@bfolegal.com