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CIV-141
ATTORNEY OR PARTY WITHOUT ATTORNEY: 249357
STATE BAR NO: FOR COURT USE ONLY
NAME: RACHEL VAN MULLEM, COUNTY COUNSEL; JENNIFER J. LEE, DEPUTY
FIRM NAME: COUNTY OF SANTA BARBARA, OFFICE OF COUNTY COUNSEL
STREET ADDRESS: 105 E. ANAPAMU ST., SUITE 201
CITY: SANTA BARBARA STATE: CA ZIP CODE: 93101
TELEPHONE NO.: (805) 568-2950 FAX NO.: (805) 568-2982
E-MAIL ADDRESS: JENLEE@COUNTYOFSB.ORG
ATTORNEY FOR (Name): DEFENDANT, JAMIE CATHLEEN GREEN
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA
STREET ADDRESS: 1100 ANACAPA ST.
MAILING ADDRESS:
CITY AND ZIP CODE: SANTA BARBARA 93101
BRANCH NAME: ANACAPA
PLAINTIFF/PETITIONER: NICOLE EMILY JORDAN
DEFENDANT/RESPONDENT: ROGERS, SHEFFIELD & CAMPBELL, ET AL.
CASE NUMBER:
DECLARATION OF DEMURRING OR MOVING PARTY
IN SUPPORT OF AUTOMATIC EXTENSION 23CV02702
1. (Name of party): DEFENDANT, JAMIE CATHLEEN GREEN was served with
D✖ a complaint D✖ an amended complaint D a cross-complaint
D an answer D other (specify):
in the above-titled action.
2. For a demurrer or motion to strike, a responsive pleading is due on (date): February 7, 2024
DECLARATION
I intend to file a demurrer, motion to strike, or motion for judgment on the pleadings in this action. Before I can do so, I am required to
meet and confer with the party who filed the pleading that I am responding to at least five days before the date when the responsive
pleading is due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the
pleadings may be filed (if I am filing a motion for judgment on the pleadings). We have not been able to meet and confer. I have not
previously requested an automatic extension of time. Therefore, on timely filing and serving a declaration that meets the requirements
of Code of Civil Procedure sections 430.41, 435.5, or 439, I am entitled to an automatic 30-day extension of time within which to file a
responsive pleading or motion for judgment on the pleadings.
I made a good faith attempt to meet and confer with the party who filed the pleading at least five days before the date the responsive
pleading was due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the
pleadings may be filed (if I am filing a motion for judgment on the pleadings). I was unable to meet with that party because
(the reasons why the parties could not meet and confer are stated):
D✖ below D on form MC-031, Attached Declaration
Plaintiff's counsel and I need additional time to research the issues raised in anticipation of a subsequent demurrer and motion to
strike. Our meet and confers were continued several times, and although we spoke about this case on 2/6/2024, additinoal time
would allow the parties to resolve some disputes.
I declare under penalty of perjury under the laws of the State of California that the information above is true and correct.
Date: February 6, 2024
Jennifer J. Lee
(NAME OF PARTY OR ATTORNEY FOR PARTY) (SIGNATURE
(SIG
S NATU
TU
URE OF PARTY OR ATT
ATTORNEY FOR PARTY)
Page 1 of 1
Form Approved for Optional Use
Judicial Council of California
DECLARATION OF DEMURRING OR MOVING PARTY Code of Civil Procedure,
§§ 430.41, 435.5, 439
CIV-141 [Rev. January 1, 2019] www.courts.ca.gov
IN SUPPORT OF AUTOMATIC EXTENSION
For your protection and privacy, please press the Clear
This Form button after you have printed the form. _
Print_ _] I___Save
this form _this_ ___.
form Clear this form
PROOF OF SERVICE
1 (C.C.P. §§ 1013(a), 2015.5)
2 STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA
3
I am a citizen of the United States and a resident of the county aforesaid; I am over the age of
4 eighteen years and not a party to the within entitled action; my business address is 105 East
Anapamu Street, Santa Barbara, California.
5
On February 7, 2024, I served a true copy of the within DECLARATION OF
6 DEMURRING OR MOVING PARTY IN SUPPORT OF AUTOMATIC EXTENSION
on the Interested Parties in this action:
7
â–¡ by mail to the person(s) indicted below. I am familiar with the practice of the Office of
8 Santa Barbara County Counsel for the collection and processing of correspondence for
9 mailing with the United States Postal Service. In accordance with the ordinary course of
business, the above-mentioned document would have been deposited with the United States
10 Postal Service, after having been deposited and processed for postage with the County of
Santa Barbara Central Mail Room.
11
SEE SERVICE LIST
12
13
14
â–¡ via Federal Express delivery services company to the person(s) indicated below.
15
16
l:8J by e-mail or electronic transmission. I caused the document(s) to be sent from e-mail
address dsjovold@countyofsb.org, to the persons at the e-mail addresses listed in the below. I
did not receive, within a reasonable time after the transmission, any electronic message or
17
other indication that the transmission was unsuccessful.
18 Tamineh Roshanian, Attorneys for Plaintiff: tami@roshanianpayman.com
Kenny C. Brooks and Michael McCarthy, Attorneys for Defendants, Rogers Sheffield
19 & Campbell, LLP and Sheila Price (as Representative of the estate of Homer
Sheffield): kbrooks@nemecek-cole.com and mstoecker@nemecek-cole.com
20
21
l:8J (State) I declare, under penalty of perjury, that the above is true and correct.
22
â–¡ (Federal) I declare that I am employed in the office of a member of the
23 Bar of this Court at whose direction the service was made.
24 Executed on February 7, 2024 at Santa Barbara, California.
25
26 _______________________
COUNTY COUNSEL
D’Ann Sjovold
County of Santa Barbara 27
105 East Anapamu Street
Santa Barbara, CA 93101
(805) 568-2950
28
1.
PROOF OF SERVICE
SERVICE LIST
1
2
Tamineh Roshanian
3 Roshanian Payman, PC
30721 Russell Ranch Road, Suite 140
4 Westlake Village, CA 91362-7383
(818) 330-5162
5 tami@roshanianpayman.com
Attorneys for Plaintiff
6
7 Kenny C. Brooks
Michael McCarthy
8 NEMECEK & COLE
A Professional Corporation
9 16255 Ventura Boulevard, Suite 300
Encino, California 91436-2300
10
(818) 788-9500
11 kbrooks@nemecek-cole.com
mstoecker@nemecek-cole.com
12 Attorneys for Defendants,
Rogers Sheffield & Campbell, LLP and
13 Sheila Price (as Representative of the estate
14 of Homer Sheffield)
15
16
17
18
19
20
21
22
23
24
25
26
COUNTY COUNSEL
County of Santa Barbara 27
105 East Anapamu Street
Santa Barbara, CA 93101
(805) 568-2950
28
2.
PROOF OF SERVICE
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CIV-141 ATTORNEY OR PARTY WITHOUT ATTORNEY: 249357 STATE BAR NO: FOR COURT USE ONLY NAME: RACHEL VAN MULLEM, COUNTY COUNSEL; JENNIFER J. LEE, DEPUTY FIRM NAME: COUNTY OF SANTA BARBARA, OFFICE OF COUNTY COUNSEL STREET ADDRESS: 105 E. ANAPAMU ST., SUITE 201 CITY: SANTA BARBARA STATE: CA ZIP CODE: 93101 TELEPHONE NO.: (805) 568-2950 FAX NO.: (805) 568-2982 E-MAIL ADDRESS: JENLEE@COUNTYOFSB.ORG ATTORNEY FOR (Name): DEFENDANT, JAMIE CATHLEEN GREEN SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA STREET ADDRESS: 1100 ANACAPA ST. MAILING ADDRESS: CITY AND ZIP CODE: SANTA BARBARA 93101 BRANCH NAME: ANACAPA PLAINTIFF/PETITIONER: NICOLE EMILY JORDAN DEFENDANT/RESPONDENT: ROGERS, SHEFFIELD & CAMPBELL, ET AL. CASE NUMBER: DECLARATION OF DEMURRING OR MOVING PARTY IN SUPPORT OF AUTOMATIC EXTENSION 23CV02702 1. (Name of party): DEFENDANT, JAMIE CATHLEEN GREEN was served with D✖ a complaint D✖ an amended complaint D a cross-complaint D an answer D other (specify): in the above-titled action. 2. For a demurrer or motion to strike, a responsive pleading is due on (date): February 7, 2024 DECLARATION I intend to file a demurrer, motion to strike, or motion for judgment on the pleadings in this action. Before I can do so, I am required to meet and confer with the party who filed the pleading that I am responding to at least five days before the date when the responsive pleading is due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the pleadings may be filed (if I am filing a motion for judgment on the pleadings). We have not been able to meet and confer. I have not previously requested an automatic extension of time. Therefore, on timely filing and serving a declaration that meets the requirements of Code of Civil Procedure sections 430.41, 435.5, or 439, I am entitled to an automatic 30-day extension of time within which to file a responsive pleading or motion for judgment on the pleadings. I made a good faith attempt to meet and confer with the party who filed the pleading at least five days before the date the responsive pleading was due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the pleadings may be filed (if I am filing a motion for judgment on the pleadings). I was unable to meet with that party because (the reasons why the parties could not meet and confer are stated): D✖ below D on form MC-031, Attached Declaration Plaintiff's counsel and I need additional time to research the issues raised in anticipation of a subsequent demurrer and motion to strike. Our meet and confers were continued several times, and although we spoke about this case on 2/6/2024, additinoal time would allow the parties to resolve some disputes. I declare under penalty of perjury under the laws of the State of California that the information above is true and correct. Date: February 6, 2024 Jennifer J. Lee (NAME OF PARTY OR ATTORNEY FOR PARTY) (SIGNATURE (SIG S NATU TU URE OF PARTY OR ATT ATTORNEY FOR PARTY) Page 1 of 1 Form Approved for Optional Use Judicial Council of California DECLARATION OF DEMURRING OR MOVING PARTY Code of Civil Procedure, §§ 430.41, 435.5, 439 CIV-141 [Rev. January 1, 2019] www.courts.ca.gov IN SUPPORT OF AUTOMATIC EXTENSION For your protection and privacy, please press the Clear This Form button after you have printed the form. _ Print_ _] I___Save this form _this_ ___. form Clear this form PROOF OF SERVICE 1 (C.C.P. §§ 1013(a), 2015.5) 2 STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA 3 I am a citizen of the United States and a resident of the county aforesaid; I am over the age of 4 eighteen years and not a party to the within entitled action; my business address is 105 East Anapamu Street, Santa Barbara, California. 5 On February 7, 2024, I served a true copy of the within DECLARATION OF 6 DEMURRING OR MOVING PARTY IN SUPPORT OF AUTOMATIC EXTENSION on the Interested Parties in this action: 7 □ by mail to the person(s) indicted below. I am familiar with the practice of the Office of 8 Santa Barbara County Counsel for the collection and processing of correspondence for 9 mailing with the United States Postal Service. In accordance with the ordinary course of business, the above-mentioned document would have been deposited with the United States 10 Postal Service, after having been deposited and processed for postage with the County of Santa Barbara Central Mail Room. 11 SEE SERVICE LIST 12 13 14 □ via Federal Express delivery services company to the person(s) indicated below. 15 16 l:8J by e-mail or electronic transmission. I caused the document(s) to be sent from e-mail address dsjovold@countyofsb.org, to the persons at the e-mail addresses listed in the below. I did not receive, within a reasonable time after the transmission, any electronic message or 17 other indication that the transmission was unsuccessful. 18 Tamineh Roshanian, Attorneys for Plaintiff: tami@roshanianpayman.com Kenny C. Brooks and Michael McCarthy, Attorneys for Defendants, Rogers Sheffield 19 & Campbell, LLP and Sheila Price (as Representative of the estate of Homer Sheffield): kbrooks@nemecek-cole.com and mstoecker@nemecek-cole.com 20 21 l:8J (State) I declare, under penalty of perjury, that the above is true and correct. 22 □ (Federal) I declare that I am employed in the office of a member of the 23 Bar of this Court at whose direction the service was made. 24 Executed on February 7, 2024 at Santa Barbara, California. 25 26 _______________________ COUNTY COUNSEL D’Ann Sjovold County of Santa Barbara 27 105 East Anapamu Street Santa Barbara, CA 93101 (805) 568-2950 28 1. PROOF OF SERVICE SERVICE LIST 1 2 Tamineh Roshanian 3 Roshanian Payman, PC 30721 Russell Ranch Road, Suite 140 4 Westlake Village, CA 91362-7383 (818) 330-5162 5 tami@roshanianpayman.com Attorneys for Plaintiff 6 7 Kenny C. Brooks Michael McCarthy 8 NEMECEK & COLE A Professional Corporation 9 16255 Ventura Boulevard, Suite 300 Encino, California 91436-2300 10 (818) 788-9500 11 kbrooks@nemecek-cole.com mstoecker@nemecek-cole.com 12 Attorneys for Defendants, Rogers Sheffield & Campbell, LLP and 13 Sheila Price (as Representative of the estate 14 of Homer Sheffield) 15 16 17 18 19 20 21 22 23 24 25 26 COUNTY COUNSEL County of Santa Barbara 27 105 East Anapamu Street Santa Barbara, CA 93101 (805) 568-2950 28 2. PROOF OF SERVICE