Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
Von Ryan Reyes, Esq. [SBN 205186]; Jonathan C. Pai [SBN 335603]
Foran Glennon
1741 Technology Drive, Suite 250
San Jose, CA 95110
TELEPHONE NO.: 669-317-4288 FAX NO. (Optional): 312-863-5099
E-MAIL ADDRESS (Optional): vreyes@fgppr.com/jpai@fgppr.com
ATTORNEY FOR (Name): Defendants Paul Latala and Latala Homes, Inc.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CRUZ
STREET ADDRESS: 701 Ocean Street
MAILING ADDRESS:
CITY AND ZIP CODE: Santa Cruz, 95060
BRANCH NAME:
PLAINTIFF/PETITIONER: Candace Dekkert
DEFENDANT/RESPONDENT: Paul Latala and Latala Homes, Inc.
CASE MANAGEMENT STATEMENT CASE NUMBER:
20CV02691
(Check one): UNLIMITED CASE LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: March 28, 2024 Time: 8:30 a.m. Dept.: 10 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Von Ryan Reyes/ Jonathan C. Pai
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. This statement is submitted by party (name): Defendants Paul Latala and Latala Homes, Inc.
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): December 24, 2020
b. The cross-complaint, if any, was filed on (date): 04/12/2022
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. The following parties named in the complaint or cross-complaint
(1) have not been served (specify names and explain why not):
Dominika Pietryga; J C Lath & Plastering - bad address.
(2) have been served but have not appeared and have not been dismissed (specify names):
Tuan Anh Phan; McAfee Construction Inc.
(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 (Describe, including causes of action):
Breach of Contract and Construction Defect
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California
CASE MANAGEMENT STATEMENT rules 3.720–3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: Candace Dekkert CASE NUMBER:
20CV02691
DEFENDANT/RESPONDENT: Paul Latala and Latala Homes, Inc.
4. 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.)
Plaintiff alleges that her residence has excessive moisture in a crawl space and inadequate drainage.
Plaintiff has discovered alleged deck defects, window defects and other defective conditions (including mold).
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
a. The party or parties request a jury triaI a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. The trial has been set for (date):
b. No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
5/06/24; 6/3/24; 6/10/24; 8/15/24; 8/19/24; 8/26/24; 9/09/24; 9/23/24; 4/8/24; 2/10/25; 5/27/25; 7/21/25 - previously scheduled
Trials; 7/29/24 - 8/8/24 and 11/21/24 - 12/2/24 - Vacation dates.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 15
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption by the following:
a. Attorney: Nora Boardman
b. Firm: Law offices of John A. Hauser
c. Address: P.O. Box 2282, Brea, CA 92822-2282
d. Telephone number: f. Fax number:
e. E-mail address: nora.boardman@thehartford.com g. Party represented: Def.Paul Latala and Latala Homes, Inc.
Additional representation is described in Attachment 8.
9. 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 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 has has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) 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 case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM-110 [Rev. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Candace Dekkert CASE NUMBER:
20CV02691
DEFENDANT/RESPONDENT: Paul Latala and Latala Homes, Inc.
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 all 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 participate 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' ADR
processes (check all that apply): stipulation):
Mediation session not yet scheduled
Mediation session scheduled for (date): 10/18/2023
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference Agreed to complete settlement conference by (date):
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 Private 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 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Candace Dekkert CASE NUMBER:
20CV02691
DEFENDANT/RESPONDENT: Paul Latala and Latala Homes, Inc.
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name): RLI Insurance Company
b. Reservation of rights: Yes No
c. Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
Bankruptcy Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate wiII 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 of motion, and issues):
16. Discovery
a. The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendant Written Discovery December 2023
Defendant Percipient Depositions August 2024
Defendant Expert Discovery Per Code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Candace Dekkert CASE NUMBER:
20CV02691
DEFENDANT/RESPONDENT: Paul Latala and Latala Homes, Inc.
17. Economic litigation
a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. 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 to discovery or trial
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):
19. Meet and confer
a. The 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):
I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: March 11, 2024
Von Ryan Reyes, Esq.
(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 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
PROOF OF SERVICE
1
[C.C.P. §§ 1010.6, 1013, 1013b, 2015.5; Cal. Rules of Court, Rules 2.251, 2.257]
2 Dekkert v. Latala, et al.
3 Pursuant to C.C.P. § 1013b, subd. (a)(1)&(3), I, the undersigned, declare (A) my
business address is 1741 Technology Drive, San Jose, California 95110; (B) I am employed in
4 the Contra Costa County, California, the county where the electronic service occurs; (C) I am
5 over the age of 18 years and not a party to this action; (D) I am readily familiar with the
business’ practice for filing electronically; and (E) that the document(s) identified below will
6 be electronically served on the date below in the ordinary course of business following ordinary
business practices.
7
8 On the date listed below, I caused a true copy of the following document(s) to be
served in this action upon the person(s) set forth below, by the method indicated.
9
DOCUMENT SERVED: CASE MANAGEMENT STATEMENT
10
11 SERVED ON:
12 Plaintiff in Pro Per Co-Counsel for Paul Latala and Latala
13 Homes
Candace Dekkert Nora A. Boardman, Esq.
14 208 Forest Avenue Law Offices of Jill A. Wood
Santa Cruz, CA 95062-2215 One Point Drive, 6th Floor
15 Brea, CA 92821
Phone: (831) 457-0219
16 E-mail: dulcitacruz@sbcglobal.net
Mailing address: PO Box 2282
17 Brea, CA 92822
[X] Served by U.S MAIL ONLY to:
18 Tel: (714) 571-0407
19 208 Forest Avenue Fax: (877) 369-5799
Santa Cruz, CA 95062-2215 Direct: (714) 371-2740
20 Email: nora.boardman@thehartford.com
Jessica.Avalos@thehartford.com
21 LawOfficesHauser@thehartford.com
22 Crystal.Coleman@thehartford.com
CaliforniaLawOffice@thehartford.com
23
Xavier Sanchez Construction In Pro Per Tuan Anh Phan
24
Tuan Anh Phan
25 Jeffrey Stewart, Esq. 94N 3rd Street
Law Offices of Karen M. Johnson Brooklyn, NY 11249
26 17771 Cowan, Ste 260 Email: josephtuananhphan@protonmail.com
Irvine, CA 92614
27
Tel: (949) 590-4065
28 Fax: (949) 774-4241
Email: Jeffrey.stewart@amtrustgroup.com
1
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/ X / (BY ELECTRONIC SERVICE) Based on a court order or an agreement of the
2 parties to accept service by electronic transmission, I caused the documents to be sent to the
persons at the electronic notification addresses listed below. OR: The above-described
3 document(s) will be delivered electronically through the Court’s electronic filing system.
4 / X/ MAIL - I placed sealed, postage prepaid envelopes in the United States mail in said
5 city, addressed as follows:
Candace Dekkert ONLY
6 208 Forest Avenue
Santa Cruz, CA 95062-2215
7
[ ] CERTIFIED MAIL - I caused it to be served via certified mail to the following
8 addresses and/or individuals:
9
I declare under penalty of perjury, under the laws of the State of California, that the
10 foregoing is true and correct.
11 Executed at San Jose, California on March 11, 2024.
12
Karen Okasaki_______________
13
KAREN OKASAKI
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Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Von Ryan Reyes, Esq. [SBN 205186]; Jonathan C. Pai [SBN 335603] Foran Glennon 1741 Technology Drive, Suite 250 San Jose, CA 95110 TELEPHONE NO.: 669-317-4288 FAX NO. (Optional): 312-863-5099 E-MAIL ADDRESS (Optional): vreyes@fgppr.com/jpai@fgppr.com ATTORNEY FOR (Name): Defendants Paul Latala and Latala Homes, Inc. SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CRUZ STREET ADDRESS: 701 Ocean Street MAILING ADDRESS: CITY AND ZIP CODE: Santa Cruz, 95060 BRANCH NAME: PLAINTIFF/PETITIONER: Candace Dekkert DEFENDANT/RESPONDENT: Paul Latala and Latala Homes, Inc. CASE MANAGEMENT STATEMENT CASE NUMBER: 20CV02691 (Check one): UNLIMITED CASE LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: March 28, 2024 Time: 8:30 a.m. Dept.: 10 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Von Ryan Reyes/ Jonathan C. Pai INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): Defendants Paul Latala and Latala Homes, Inc. b. This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): December 24, 2020 b. The cross-complaint, if any, was filed on (date): 04/12/2022 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. The following parties named in the complaint or cross-complaint (1) have not been served (specify names and explain why not): Dominika Pietryga; J C Lath & Plastering - bad address. (2) have been served but have not appeared and have not been dismissed (specify names): Tuan Anh Phan; McAfee Construction Inc. (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 (Describe, including causes of action): Breach of Contract and Construction Defect Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: Candace Dekkert CASE NUMBER: 20CV02691 DEFENDANT/RESPONDENT: Paul Latala and Latala Homes, Inc. 4. 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.) Plaintiff alleges that her residence has excessive moisture in a crawl space and inadequate drainage. Plaintiff has discovered alleged deck defects, window defects and other defective conditions (including mold). (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial a. The party or parties request a jury triaI a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. The trial has been set for (date): b. No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 5/06/24; 6/3/24; 6/10/24; 8/15/24; 8/19/24; 8/26/24; 9/09/24; 9/23/24; 4/8/24; 2/10/25; 5/27/25; 7/21/25 - previously scheduled Trials; 7/29/24 - 8/8/24 and 11/21/24 - 12/2/24 - Vacation dates. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 15 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption by the following: a. Attorney: Nora Boardman b. Firm: Law offices of John A. Hauser c. Address: P.O. Box 2282, Brea, CA 92822-2282 d. Telephone number: f. Fax number: e. E-mail address: nora.boardman@thehartford.com g. Party represented: Def.Paul Latala and Latala Homes, Inc. Additional representation is described in Attachment 8. 9. 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 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 has has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) 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 case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Candace Dekkert CASE NUMBER: 20CV02691 DEFENDANT/RESPONDENT: Paul Latala and Latala Homes, Inc. 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 all 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 participate 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' ADR processes (check all that apply): stipulation): Mediation session not yet scheduled Mediation session scheduled for (date): 10/18/2023 (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date): 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 Private 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 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Candace Dekkert CASE NUMBER: 20CV02691 DEFENDANT/RESPONDENT: Paul Latala and Latala Homes, Inc. 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): RLI Insurance Company b. Reservation of rights: Yes No c. Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Bankruptcy Other (specify): Status: 13. Related cases, consolidation, and coordination a. There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: Additional cases are described in Attachment 13a. b. A motion to consolidate coordinate wiII 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 of motion, and issues): 16. Discovery a. The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant Written Discovery December 2023 Defendant Percipient Depositions August 2024 Defendant Expert Discovery Per Code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Candace Dekkert CASE NUMBER: 20CV02691 DEFENDANT/RESPONDENT: Paul Latala and Latala Homes, Inc. 17. Economic litigation a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. 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 to discovery or trial 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): 19. Meet and confer a. The 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): I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: March 11, 2024 Von Ryan Reyes, Esq. (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 1, 2011] Page 5 of 5 CASE MANAGEMENT STATEMENT PROOF OF SERVICE 1 [C.C.P. §§ 1010.6, 1013, 1013b, 2015.5; Cal. Rules of Court, Rules 2.251, 2.257] 2 Dekkert v. Latala, et al. 3 Pursuant to C.C.P. § 1013b, subd. (a)(1)&(3), I, the undersigned, declare (A) my business address is 1741 Technology Drive, San Jose, California 95110; (B) I am employed in 4 the Contra Costa County, California, the county where the electronic service occurs; (C) I am 5 over the age of 18 years and not a party to this action; (D) I am readily familiar with the business’ practice for filing electronically; and (E) that the document(s) identified below will 6 be electronically served on the date below in the ordinary course of business following ordinary business practices. 7 8 On the date listed below, I caused a true copy of the following document(s) to be served in this action upon the person(s) set forth below, by the method indicated. 9 DOCUMENT SERVED: CASE MANAGEMENT STATEMENT 10 11 SERVED ON: 12 Plaintiff in Pro Per Co-Counsel for Paul Latala and Latala 13 Homes Candace Dekkert Nora A. Boardman, Esq. 14 208 Forest Avenue Law Offices of Jill A. Wood Santa Cruz, CA 95062-2215 One Point Drive, 6th Floor 15 Brea, CA 92821 Phone: (831) 457-0219 16 E-mail: dulcitacruz@sbcglobal.net Mailing address: PO Box 2282 17 Brea, CA 92822 [X] Served by U.S MAIL ONLY to: 18 Tel: (714) 571-0407 19 208 Forest Avenue Fax: (877) 369-5799 Santa Cruz, CA 95062-2215 Direct: (714) 371-2740 20 Email: nora.boardman@thehartford.com Jessica.Avalos@thehartford.com 21 LawOfficesHauser@thehartford.com 22 Crystal.Coleman@thehartford.com CaliforniaLawOffice@thehartford.com 23 Xavier Sanchez Construction In Pro Per Tuan Anh Phan 24 Tuan Anh Phan 25 Jeffrey Stewart, Esq. 94N 3rd Street Law Offices of Karen M. Johnson Brooklyn, NY 11249 26 17771 Cowan, Ste 260 Email: josephtuananhphan@protonmail.com Irvine, CA 92614 27 Tel: (949) 590-4065 28 Fax: (949) 774-4241 Email: Jeffrey.stewart@amtrustgroup.com 1 1 / X / (BY ELECTRONIC SERVICE) Based on a court order or an agreement of the 2 parties to accept service by electronic transmission, I caused the documents to be sent to the persons at the electronic notification addresses listed below. OR: The above-described 3 document(s) will be delivered electronically through the Court’s electronic filing system. 4 / X/ MAIL - I placed sealed, postage prepaid envelopes in the United States mail in said 5 city, addressed as follows: Candace Dekkert ONLY 6 208 Forest Avenue Santa Cruz, CA 95062-2215 7 [ ] CERTIFIED MAIL - I caused it to be served via certified mail to the following 8 addresses and/or individuals: 9 I declare under penalty of perjury, under the laws of the State of California, that the 10 foregoing is true and correct. 11 Executed at San Jose, California on March 11, 2024. 12 Karen Okasaki_______________ 13 KAREN OKASAKI 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2