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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and addmssi FOR COURT USE ONLY
RICHARD )N. FREEMAN, JR., SBN: 50533
Richad Freeman Law Offices
703 Second Street, Suite 350 Santa Rosa, CA 95404
TELEPHONE No (707) 757-8206 FAX NO (Optronai/ (707) 921-7329
E-MAIL ADDRESS (Op(tonal/ rfreemanattarney@SOniC.net
AnoRNEYFDR/name/ Defendants & Cross-Complainants Cookman & Topping
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA
sTREETADDREss 600 Administration Drive
MAILING ADDRESS
clTY AND ziP coDE Santa Rosa CA 95403
BRANCH NAME
PLAINTIFF/PETITIONER. HARMONY HOME INMPROVEMENTS, INC
DEFENDANT/RESPONDENT KEVIN COOKMAN & KELLY TOPPING
CASE MANAGEMENT STATEMENT CASE NUMBER
(Check one): MY'NLIMITED CASE
(Amount demanded
W Lll!/IITED CASE SCV-272568
(Amount demanded is $ 25,000
exceeds $ 25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows
Date: 11-2-23 Time. 3:00 p.m. Dept. 17 Div Room;
Address of court(if different from the address abave):
3035 Cleveland Ave, Santa Rosa, CA 95403
Notice of Intent to Appear by Telephone, by (name)( Richard Freeman
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one).
~Y'his
a.
b. ~ statement is submitted by party (name): Defendants and Cross-Complainants Cookman
This statement is submitted jointly by parties (names).
8 Topping
2. Complaint and cross-complaint (to be answered by pteintiffs and cross-comp/ainants on/y)
a. The complaint was filed on (date):
b. ~V The cross-complaint, if any, was filed on (date): May 5, 2023
3.
a.
b.
~
Service (to be answered by plaintiffs and cross-comp/ainants on/y)
~ ~ All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
The following parties named in the complaint or cross-complaint
(I) have not been served (specify names and explain why not)(
~ (2)
None except Harmony Homes, Inc,. through Counsel; Amended Cross-Complaint being filed
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
RECISSION, FRAUD; Negligent Misrepresenation; Negligence, Money had
(Describe, including causes of action):
& Received; Recover on
Contractor's Bond;
Page 1 of 5
Form Adopted for Mandatory Use
Judraal Counoi of Cat fo n a CASE MANAGEMENT STATEIIENT Cai Rules of Court,
rules 3 720-3 730
cM-110 [Re July I 2011(
www coups ca goy
CM-110
CASE NUMBER
PLAINTIFF/PETITIONER; HARMONY HOME INMPROVEMENTS, INC
SCV-272568
DEFENDANT/RESPONDENT: KEVIN COOKMAN & KELLY TOPPING
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)
Cross-Complaints were rebuilding home and contracted for various work for their Manufactured Home, bought
from Clayton Homes, with Plaintiff who they were encouraged to use. Despite representations of the Plaintiff and
Clayton, Plaintiff was negligent in his construction activities and both Clayton and Plaintiff misrepresented how
they would do their work. Plaintiffs failed to preperly complete work her billed for and damaged the home.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request Mv a jury trial
requesting a jury tn'al).
M
a nonjury trial. (If more than one party, provide the name of each party
a.
b ~v
~
Trial date
The trial has been set for (dale)i
No tnal date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (If
nof, explain):
Cross-Complaint against additional new parties
c. Dates on which parties or attorneys will not be available for trial (specify dates end explain reasons for unavailability):
Trials sporadically set through July, 2024
Estimated length of trial
The party or parties estimate that the trial will take (check one):
~v'ays
a.
b. ~ (specify number): 7
hours (short causes) (specify).
Trial representation (to be answered for each party)
The party or parties will be represented at trial
a. Attorney:
~ by the attorney or party listed in the caption ~ by the following
b. Firm.
c. Address.
d. Telephone number: f. Fax number:
e. E-mail address.
g. Party represented
Additional representation is described in Attachment 8
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 CZ C3
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 hasM Cl
has not reviewed the ADR information package identified in rule 3.221.
b.
(1) ~
Referral to judicial arbitration or civil action mediation (if available).
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
Civil Procedure section 1141.11
case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
(3) ~ This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
Damages are in excess of statutory amounts.
CM 110 [Ruy July 1, 2011] Pllgff 2 oi 5
CASE MANAGEMENT STATEMENT
CIN-110
PLAINTIFF/PETITIONER: HARMONY HOME INMPROVEMENTS, INC CASE NUMBER
EFENDANT/RESPONDENT: KEVIN COOKMAN & KELLY TOPPING SCV-272568
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 a/I 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 partimpate 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'DR
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):
C&Q Settlement conference not yet scheduled
(2) Settlement C3 Settlement conference scheduled for
(date)'greed
conference
to complete settlement conference by (dale):
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 Pnvate 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 [Rey July 1, 201 it Page 3 of 0
CASE MANAGEMENT STATEIIENT
CNI-110
CASE NUMBER
PLAINTIFF/PETITIONER HARMONY HOME INMPROVEMENTS, INC
SCV-272568
DEFENDANT/RESPONDENT. KEVIN COOKMAN & KELLY TOPPING
11
a. ~
Insurance
Insurance carrier, if any, for party fikng this statement (name):
H H
b
c. ~
Reservation of rights; Yes No
Coverage issues will significantly affect resolution of this case (exp/a/n):
12 Judisdiction
~
Indicate any matters that may affect the court's jurisdiction or processing of this case and descnbe the status
Status:
Bankruptcy W
Other (specrfy):
13 Related
~ cases, consolidation, and coordination
There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court
(3) Case number:
b
~
H
(4) Status:
Additional cases are described in Attachment 13a
A motion to C3 consohdate H coordinate will 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 ofmotion, andissues):
a.
b.
~
16. Discovery
~
The party or parties have completed all discovery.
The following discovery will be completed by the date specified (describe all anticipated discovery):
Para Descriotion Date
Defendants/Cross-Complaintants Written Discovery tbd
Defendants/Cross-Complaintants Depositions tbd
~ The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 IRev July 2011]
1
CASE MANAGEMENT STATEMENT Page 4 of 5
CM-110
PLAINTIFF/PETITIONER: HARMONY HOME INMPROVEMENTS, INC CASE
NUMBER'CV-272568
pgFENpp,NTIR68PONpFNIT KEVIN COOKMAN & KELLY TOPPING
17.
a. ~
Economic litigation
This is a limited civil case (i.e., the amount demanded is $ 25,000 or less) and the economic litigation procedures in Code
b, ~ of Civil Procedure sections 90-98 will apply to this case.
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 fo discovery or tnal
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):
Continue CMC for 60 days to allow for service of First Amended Cross-Complaint on new parties and
Appearances
19. Meet and confer
a. ~v'he 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):
am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
I
as well as other issues raised by this statement, and will possess the authonty to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the pa
Date: October 10, 2023
Richard W. Freeman, Jr.
(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 I, 2011) PeseSet5
CASE MANAGEMENT STATEMENT
PROOF OF SERVICE
I am employed in the County of Sonoma, State of California. I am over the age of 18 years
and not a party to the within action. My business address is 50 Santa Rosa Avenue, Suite 400,
Santa Rosa, CA 95404. On October 10, 2023 I served the FIRST AMENDED CROSS-
COMPLAINT; and CMC STATEMENT on the parties to this action by serving:
6 STEVEN J. BLEASDELL (Bar No. 191522)
BEYERS COSTIN SIMON
7 A Professional Corporation
200 Fourth Street, Suite 400
8 P.O. Box 878
9
Santa Rosa, CA 95402-0878
Tel: 707.547.2000
10 Fax: 707.526.2746
sbleasdell@beyerscostin.corn
11
// BY U.S. MAIL: I placed each such sealed envelope, with postage thereon fully prepaid for
12 first-class mail, for collection and mailing at the address above, following
ordinary business
practices. I am readily familiar with the practice for processing of correspondence, said practice
13
being that in the ordinary course of business, correspondence is deposited in the United States
14 Postal Service the same day as it is placed for processing.
15 // BY PERSONAL SERVICE: I caused each such envelope to be delivered by hand to the
addressee(s) noted above.
16
17 // BY FACSIMILE: I caused the said document(s) to be transmitted by fax to the persons
listed above. The transmission(s) was reported as completed and without error and was properly
18 issued by the transmitting facsimile machine.
19
// BY FEDERAL EXPRESS/OVERNIGHT MAIL: I caused the above-described
20 document(s) to be served by Federal Express or via overnight delivery to the offices of the
addressee(s).
21
22 /x/ BY EMAIL OR ELECTRONIC TRANSMISSION: I caused the documents to be sent to
the persons at the e-mail addresses listed above. No electronic message or other indication that the
23 transmission was unsuccessful was received within a reasonable time after the transmission.
24 Ideclare under penalty of perjury und of the State of California that the
foregoing is true and correct.
25
26
Dated: October 10, 2023
27 Richard Freeman
28
POS
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CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and addmssi FOR COURT USE ONLY RICHARD )N. FREEMAN, JR., SBN: 50533 Richad Freeman Law Offices 703 Second Street, Suite 350 Santa Rosa, CA 95404 TELEPHONE No (707) 757-8206 FAX NO (Optronai/ (707) 921-7329 E-MAIL ADDRESS (Op(tonal/ rfreemanattarney@SOniC.net AnoRNEYFDR/name/ Defendants & Cross-Complainants Cookman & Topping SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA sTREETADDREss 600 Administration Drive MAILING ADDRESS clTY AND ziP coDE Santa Rosa CA 95403 BRANCH NAME PLAINTIFF/PETITIONER. HARMONY HOME INMPROVEMENTS, INC DEFENDANT/RESPONDENT KEVIN COOKMAN & KELLY TOPPING CASE MANAGEMENT STATEMENT CASE NUMBER (Check one): MY'NLIMITED CASE (Amount demanded W Lll!/IITED CASE SCV-272568 (Amount demanded is $ 25,000 exceeds $ 25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows Date: 11-2-23 Time. 3:00 p.m. Dept. 17 Div Room; Address of court(if different from the address abave): 3035 Cleveland Ave, Santa Rosa, CA 95403 Notice of Intent to Appear by Telephone, by (name)( Richard Freeman INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one). ~Y'his a. b. ~ statement is submitted by party (name): Defendants and Cross-Complainants Cookman This statement is submitted jointly by parties (names). 8 Topping 2. Complaint and cross-complaint (to be answered by pteintiffs and cross-comp/ainants on/y) a. The complaint was filed on (date): b. ~V The cross-complaint, if any, was filed on (date): May 5, 2023 3. a. b. ~ Service (to be answered by plaintiffs and cross-comp/ainants on/y) ~ ~ All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. The following parties named in the complaint or cross-complaint (I) have not been served (specify names and explain why not)( ~ (2) None except Harmony Homes, Inc,. through Counsel; Amended Cross-Complaint being filed 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 RECISSION, FRAUD; Negligent Misrepresenation; Negligence, Money had (Describe, including causes of action): & Received; Recover on Contractor's Bond; Page 1 of 5 Form Adopted for Mandatory Use Judraal Counoi of Cat fo n a CASE MANAGEMENT STATEIIENT Cai Rules of Court, rules 3 720-3 730 cM-110 [Re July I 2011( www coups ca goy CM-110 CASE NUMBER PLAINTIFF/PETITIONER; HARMONY HOME INMPROVEMENTS, INC SCV-272568 DEFENDANT/RESPONDENT: KEVIN COOKMAN & KELLY TOPPING 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) Cross-Complaints were rebuilding home and contracted for various work for their Manufactured Home, bought from Clayton Homes, with Plaintiff who they were encouraged to use. Despite representations of the Plaintiff and Clayton, Plaintiff was negligent in his construction activities and both Clayton and Plaintiff misrepresented how they would do their work. Plaintiffs failed to preperly complete work her billed for and damaged the home. (If more space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request Mv a jury trial requesting a jury tn'al). M a nonjury trial. (If more than one party, provide the name of each party a. b ~v ~ Trial date The trial has been set for (dale)i No tnal date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (If nof, explain): Cross-Complaint against additional new parties c. Dates on which parties or attorneys will not be available for trial (specify dates end explain reasons for unavailability): Trials sporadically set through July, 2024 Estimated length of trial The party or parties estimate that the trial will take (check one): ~v'ays a. b. ~ (specify number): 7 hours (short causes) (specify). Trial representation (to be answered for each party) The party or parties will be represented at trial a. Attorney: ~ by the attorney or party listed in the caption ~ by the following b. Firm. c. Address. d. Telephone number: f. Fax number: e. E-mail address. g. Party represented Additional representation is described in Attachment 8 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 CZ C3 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 hasM Cl has not reviewed the ADR information package identified in rule 3.221. b. (1) ~ Referral to judicial arbitration or civil action mediation (if available). 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 Civil Procedure section 1141.11 case to judicial arbitration and agrees to limit recovery to the amount specified in Code of (3) ~ This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): Damages are in excess of statutory amounts. CM 110 [Ruy July 1, 2011] Pllgff 2 oi 5 CASE MANAGEMENT STATEMENT CIN-110 PLAINTIFF/PETITIONER: HARMONY HOME INMPROVEMENTS, INC CASE NUMBER EFENDANT/RESPONDENT: KEVIN COOKMAN & KELLY TOPPING SCV-272568 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 a/I 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 partimpate 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'DR 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): C&Q Settlement conference not yet scheduled (2) Settlement C3 Settlement conference scheduled for (date)'greed conference to complete settlement conference by (dale): 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 Pnvate 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 [Rey July 1, 201 it Page 3 of 0 CASE MANAGEMENT STATEIIENT CNI-110 CASE NUMBER PLAINTIFF/PETITIONER HARMONY HOME INMPROVEMENTS, INC SCV-272568 DEFENDANT/RESPONDENT. KEVIN COOKMAN & KELLY TOPPING 11 a. ~ Insurance Insurance carrier, if any, for party fikng this statement (name): H H b c. ~ Reservation of rights; Yes No Coverage issues will significantly affect resolution of this case (exp/a/n): 12 Judisdiction ~ Indicate any matters that may affect the court's jurisdiction or processing of this case and descnbe the status Status: Bankruptcy W Other (specrfy): 13 Related ~ cases, consolidation, and coordination There are companion, underlying, or related cases. (1) Name of case: (2) Name of court (3) Case number: b ~ H (4) Status: Additional cases are described in Attachment 13a A motion to C3 consohdate H coordinate will 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 ofmotion, andissues): a. b. ~ 16. Discovery ~ The party or parties have completed all discovery. The following discovery will be completed by the date specified (describe all anticipated discovery): Para Descriotion Date Defendants/Cross-Complaintants Written Discovery tbd Defendants/Cross-Complaintants Depositions tbd ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 IRev July 2011] 1 CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: HARMONY HOME INMPROVEMENTS, INC CASE NUMBER'CV-272568 pgFENpp,NTIR68PONpFNIT KEVIN COOKMAN & KELLY TOPPING 17. a. ~ Economic litigation This is a limited civil case (i.e., the amount demanded is $ 25,000 or less) and the economic litigation procedures in Code b, ~ of Civil Procedure sections 90-98 will apply to this case. 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 fo discovery or tnal 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): Continue CMC for 60 days to allow for service of First Amended Cross-Complaint on new parties and Appearances 19. Meet and confer a. ~v'he 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): am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, I as well as other issues raised by this statement, and will possess the authonty to enter into stipulations on these issues at the time of the case management conference, including the written authority of the pa Date: October 10, 2023 Richard W. Freeman, Jr. (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 I, 2011) PeseSet5 CASE MANAGEMENT STATEMENT PROOF OF SERVICE I am employed in the County of Sonoma, State of California. I am over the age of 18 years and not a party to the within action. My business address is 50 Santa Rosa Avenue, Suite 400, Santa Rosa, CA 95404. On October 10, 2023 I served the FIRST AMENDED CROSS- COMPLAINT; and CMC STATEMENT on the parties to this action by serving: 6 STEVEN J. BLEASDELL (Bar No. 191522) BEYERS COSTIN SIMON 7 A Professional Corporation 200 Fourth Street, Suite 400 8 P.O. Box 878 9 Santa Rosa, CA 95402-0878 Tel: 707.547.2000 10 Fax: 707.526.2746 sbleasdell@beyerscostin.corn 11 // BY U.S. MAIL: I placed each such sealed envelope, with postage thereon fully prepaid for 12 first-class mail, for collection and mailing at the address above, following ordinary business practices. I am readily familiar with the practice for processing of correspondence, said practice 13 being that in the ordinary course of business, correspondence is deposited in the United States 14 Postal Service the same day as it is placed for processing. 15 // BY PERSONAL SERVICE: I caused each such envelope to be delivered by hand to the addressee(s) noted above. 16 17 // BY FACSIMILE: I caused the said document(s) to be transmitted by fax to the persons listed above. The transmission(s) was reported as completed and without error and was properly 18 issued by the transmitting facsimile machine. 19 // BY FEDERAL EXPRESS/OVERNIGHT MAIL: I caused the above-described 20 document(s) to be served by Federal Express or via overnight delivery to the offices of the addressee(s). 21 22 /x/ BY EMAIL OR ELECTRONIC TRANSMISSION: I caused the documents to be sent to the persons at the e-mail addresses listed above. No electronic message or other indication that the 23 transmission was unsuccessful was received within a reasonable time after the transmission. 24 Ideclare under penalty of perjury und of the State of California that the foregoing is true and correct. 25 26 Dated: October 10, 2023 27 Richard Freeman 28 POS