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- DO NOT FILE WITH THE COURT- CIV-050
-UNLESS YOU ARE APPLYING FOR A DEFAULT JUDGMENT UNDER CODE OF CIVIL PROCEDURE § 585 -
TELEPHONE NO.: FOR COURT USE ONLY
J ATTORNEY OR PARTY WITHOUT ATTORNEY (Name and Adecress) 805-962-2022
Renee J. Nordstrand SBN 139412; Matthew iM. Morrison SBN 280825
NORDSTRANDBLACK PC
33 West Mission St., Suite 206
‘Santa Barbara, CA 93101
ATTORNEY
FOR (nama): Rogelio Julian
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Barbara
sTREET ADDRESS: 1100 Anacapa St.
MAILING ADDRESS:
jciry AND zip cove: Santa Barbara, CA 93101
BRANCH NAME: Anacapa Division
PLAINTIFF: Rogelio Julian
DEFENDANT: John L. Bunce, Elizabeth N. Bunce, et al.
STATEMENT OF DAMAGES ‘CASE NUMBER:
(Personal Injury or Wrongful Death) 22CV04181
To (name of one defendant only): John L. Bunce
Plaintiff (name of one plaintiff only): Rogelio Julian
seeks damages in the above-entitled action, as follows:
AMOUNT
1 General damages
a. [<] Pain, suffering, and inconvenience 1,000,000.00
b, [5€] Emotional distress. . 1,000,000.00
©. - [7] Loss of consortium
d. |. [J Loss of sociey and companionship (wrongful death actions only)
e. . [J Other (specify)
f. [_] Other (specify)
g. . [-_] Continued on Attachment 1.g.
Special damages
a Medical expenses (to date) 62,000.00
Future medical expenses (present value) 250,000.00
. [EE] Loss of earings (to date) . 80,500.00
. [3€] Loss of future earning capacity (present value) 432,000.00
. (J Property damage .....
[ Funeral expenses (wrongful death actions only) .....
g. . [=] Future contributions (present value) (wrongful death actions only)..
h. |. [_] Value of personal service, advice, or training (wrongful death actions only)
i. [-) Other (specify) z
J [J Other (specify)
k. [-_] Continued on Attachment 2.k.
3. [[_] Punitive damages: Plaintiff reserves the right to seek punitive damages in the amount of (specify)... $
when pursuing a judgment in the sult filed against you.
» Ma. Varia 6
Date: July 25, 2023
Matthew M. Morrison
(TYPE OR PRINT NAME) {SIGNATURE OF PLAINTIFF OR ATTORNEY
FOR PLAINTI
(Proof of service on reverse) Page 1 of 2
Form Adopted for Mandatory Use STATEMENT OF DAMAGES: Code of Civil Procedure, §§ 425.11, 425.115
sJudictal Council of Catifornia (Personal Injury or Wrongful Death) worw.courts.ca.gov
CIV-080 [Rev. January 1, 2007)
| n d epeli d ent
THE SANTA BARBAI RA
PROOF OF PUBLICATION This space is for the County Clerk's Filing Stamp
(2015.5 C.C.P)
STATE OF CALIFORNIA, ~ UBEIIOR CORT of CAL Fon
SEP
4 4 2023
County of Santa Barbara, Darrai E. P;
3Y.
| am a citizen of the United States and a resident of
the County aforesaid; | am over the age of eighteen
years, and not a party to or interested in the above-
entitled matter. | am the prinicipal clerk of the printer
of The Santa Barbara Independent, a newspaper of Proof of Publication of
general circulation, printed and published weekly, in
the City of Santa Barbara, County of Santa Barbara,
and which newspaper has been adjudged a news-
paper of general circulation by the Superior Court of " STATEMENT OF DAMAGES
the County of Santa Barbara, State of California. \ (Personal Injury or Wrongful
Death) PLAINTIFF: ROGELLO
JULIAN, Case, umber:
Case Number
Q2CV HY
; that the notice, of which the
22CV04181, DEFENDANT: JOHN
L, SUNCE, ELIZABETH N. BUNCE,
"ETAL,
Yo: Defendant: ELIZABETH,
annexed is a printed copy (set in type not smaller than
nonpareil), has been published in each regular and Prainiff:"ROGELIO JULIAN, seeks
damages in the above-entitled
entire issue of said newspaper and not in any { action, as follows:
4.General Damages a. ‘Pain,
supplement thereof on the following dates, to-wit: suffering and inconvenience
$1,000,000.00 b. Emotional
vo 0, IA DY, Bl distress $1,000,000.00 2.
Special damages 3. Medical
expences $62,000.00 b. Future
medical expenses (present valve)
$250,000.00 ¢. Loss of earnings
(to date) $80,500.00 d. Loss of
all in the year ee future earning capacity (present
‘value) $432,000.00 Date: July 25,
Superior Court of California,
County of Santa Barbara 1100
Anacapa St. Santa Barbara, CA
9321-1107 Anacapa
Published Aug 10, 17, 24, 51
023.
| certify (or declare) under penalty of perjure that the
foregoing is true and correct.
4
Histf
Dat eC Santa Barbar; California, this 3 day of
ae
AS
WL Dodd
| Signaturé
| N d épeli d ent
THE SANTA BARBAR, A
PROOF OF PUBLICATION
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA
1am employed in the County of Santa Barbara, State of California. I am over the age of
18 and not a party to the within action; my business address is 33 West Mission Street, Suite 206
Santa Barbara, California 93101
On December 20, 2023, I served upon the interested party (ies) in this action the
following described document(s): STATEMENT OF DAMAGES FOR JOHN L. BUNCE
WITH PROOF OF SERVICE BY PUBLICATION
X MAIL: by placing a true copy thereof enclosed in a sealed envelope(s), addressed as set
forth below. I am “readily familiar” with the firm’s practice of collection and processing
correspondence for mailing. Under that practice it would be deposited with the U.S. Postal
Service on that same day with postage thereon fully prepaid at Santa Barbara, California
in the ordinary course of business. I am aware that on motion of the party served, service
is presumed invalid if the postal cancellation date or postage meter date is more than one
day after the date of deposit for mailing in affidavit
PERSONAL DELIVERY: by delivering a true copy thereof by hand to the person or
office, as indicated, at the address (es) set forth below.
BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused such a document(s) to
be sent from e-mail address @nblaw.us to the persons at the e-mail addresses listed
below. I did not receive, within a reasonable time after the transmission, any electronic
message or other indication that the transmission was unsuccessful
MESSENGER: by causing a true copy thereof to be delivered via messenger service at
the address (es) set forth below.
SEE ATTACHED SERVICE LIST
(State) I declare under penalty of perjury under the laws of the State of California, that
the foregoing is true and correct.
Executed on December 20, 2023 at Santa Barbara, California.
Ai Maes
Matthew Morrison
SERVICE LIST
Rogelio Julian v. John L. Bunce, et al.
Attorneys for defendant Anchor Heating & Air Conditioning, Inc.
Michael E. Gallagher
Lisa M. Stevenson
Caroline B. Fawley
Eldin Gallagher Huie + Blum
515 South Flower Street, Suite 1020
Los Angeles, CA 90071
mgallagher@eghblaw.com
Istevenson@eghblaw.com
cfawley@eghblaw.com
nchetty@eghblaw.com
dcaudillo@eghblaw.com
Attorneys for defendant Giffin & Crane General Contractors LLC
Kevin P. Kennedy
Erika L. Sandler
KENNEDY & SOUZA, APC
7964 Arjons Drive, Suite I
San Diego, California 92126
(858) 267-4127; Fax (858) 267-4128
kkennedy@kennedysouza.com
esandler@kennedysouza.com
dthomas@kennedysouza.com
John L. Bunce
Elizabeth N. Bunce
4455 Via Bendita
Santa Barbara, CA 93110