Party Statement: James Raymond vs Jacob John Songer

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                                1 Michael C. Parme (Bar No. 261719)
     mparme@hbblaw.com
 2 Stevie B. Baris (Bar No. 287708)
     sbaris@hbblaw.com
 3 HAIGHT BROWN & BONESTEEL LLP
     edocs@hbblaw.com
 4 402 West Broadway, Suite 1850
   San Diego, CA 92101
 5 Telephone: 619.595.5583
   Facsimile: 619.595.7873
 6
   Attorneys for Defendant JACOB JOHN
 7 SONGER dba INFERNO GUARD
 8
 9                   SUPERIOR COURT OF THE STATE OF CALIFORNIA
10                                     COUNTY OF NAPA
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12 JAMES RAYMOND,                                    Case No. 21CV001225
   an individual,
13                                                   DEFENDANT’S STATEMENT OF
                  Plaintiff,                         THE CASE
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          v.                                         Date:    August 28, 2023
15                                                   Time:    8:30 a.m.
   JACOB JOHN SONGER, an individual,                 Dept.:   A
16 dba INFERNO GUARD and DOES 1
   through 50, inclusive,                            Action Filed:      August 24, 2021
17                                                   Trial Date:        August 28, 2023
                  Defendants.
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19            Plaintiff JAMES RAYMOND (“Plaintiff”) alleges that on January 21, 2021
20 Defendant JACOB JOHN SONGER dba INFERNO GUARD (“Defendant”) unlawfully
21 entered upon the Plaintiff’s property located at 101 Oak Street in Saint Helena, California
22 (the “subject property”) and cut down multiple trees located on the subject property.
23 Plaintiff alleges he has suffered damages as a result of the Defendant’s conduct.
24 Defendant admits that he made an honest mistake in entering upon the subject property,
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     NW08-0000074                                1
     14672030.1                 DEFENDANT’S STATEMENT OF THE CASE
 1 but denies that his conduct was the cause of the alleged damages because the trees had
 2 previously been destroyed by fire. Defendant further denies the existence and extent of the
 3 claimed damages.
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 5 DATED: August 23, 2023                 HAIGHT BROWN & BONESTEEL LLP
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                                          By:          /s/ Michael Parme
 8                                              Michael Parme
 9                                              Stevie B. Baris
                                                Attorneys for Defendant
10                                              JACOB JOHN SONGER dba
                                                INFERNO GUARD
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     NW08-0000074                               2
     14672030.1               DEFENDANT’S STATEMENT OF THE CASE
 1                                     PROOF OF SERVICE
 2                              James Raymond v. Jacob John Songer
 3                                      Case No. 21CV001225
 4 STATE OF CALIFORNIA, COUNTY OF SAN DIEGO
 5       At the time of service, I was over 18 years of age and not a party to this action. I
   am employed in the County of San Diego, State of California. My business address is 402
 6 West Broadway, Suite 1850, San Diego, CA 92101.
 7         On August 25, 2023, I served true copies of the following document(s) described as
   DEFENDANT’S STATEMENT OF THE CASE on the interested parties in this action
 8 as follows:
 9    Michael W. Rupprecht, Esq.                    T: 707-252-9000 / F: 707-252-0729
      GVM LAW, LLP                                    MRupprecht@gvmlaw.com
10    1000 Main Street, Suite 300                     Cathy@gvmlaw.com
      Napa, CA 94559
11                                                  Attorneys for Plaintiff, JAMES
                                                    RAYMOND
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           BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
13 document(s) to be sent from e-mail address czacevich@hbblaw.com to the persons at the
   e-mail addresses listed in the Service List. I did not receive, within a reasonable time after
14 the transmission, any electronic message or other indication that the transmission was
   unsuccessful.
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           I declare under penalty of perjury under the laws of the State of California that the
16 foregoing is true and correct.
17            Executed on August 25, 2023, at San Diego, California.
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21                                                 Christina Zacevich

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     NW08-0000074
     14674876.1                         PROOF OF SERVICE