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CM-015
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Benjamin W. Blaisdell (SBN 218604)
Law Offices of John A. Biard
Physical: 11070 White Rock Rd., Ste. 200, Rancho Cordova CA 95670
Mailing: P.O. Box 64093, St. Paul, MN 55164-0093
TELEPHONE NO.: (916) 638-6610 FAX NO. (Optional): (855) 631-5920
E-MAIL ADDRESS (Optional): bblaisde@travelers.com
ATTORNEY FOR (Name): Plaintiff, Travelers Property Casualty Co. of America
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CRUZ
STREET ADDRESS: 701 Ocean Street, Room 110
MAILING ADDRESS: 701 Ocean Street
CITY AND ZIP CODE: Santa Cruz, CA 95060
BRANCH NAME: Civil Division
CASE NUMBER:
PLAINTIFF/PETITIONER: Travelers Property Casualty Company of America
24CV00517
DEFENDANT/RESPONDENT: Allied Concrete Pumping, LLC JUDICIAL OFFICER:
Hon. Timothy Schmal
DEPT.:
NOTICE OF RELATED CASE 10
Identify, in chronological order according to date of filing, all cases related to the case referenced above.
1. a. Title: Generaro Sanchez v. Allied Concrete Pumping, LLC, et al.
b. Case number: 23CV001983
c. Court: same as above
other state or federal court (name and address):
d. Department:
e. Case type: limited civil unlimited civil probate family law other (specify):
f. Filing date: 08.17.2023
g. Has this case been designated or determined as "complex?" Yes No
h. Relationship of this case to the case referenced above (check all that apply):
involves the same parties and is based on the same or similar claims.
arises from the same or substantially identical transactions, incidents, or events requiring the determination of
the same or substantially identical questions of law or fact.
involves claims against, title to, possession of, or damages to the same property.
is likely for other reasons to require substantial duplication of judicial resources if heard by different judges.
Additional explanation is attached in attachment 1h
i. Status of case:
pending
dismissed with without prejudice
disposed of by judgment
2. a. Title:
b. Case number:
c. Court: same as above
other state or federal court (name and address):
d. Department:
Page 1 of 3
Form Approved for Optional Use Cal. Rules of Court, rule 3.300
Judicial Council of California NOTICE OF RELATED CASE www.courtinfo.ca.gov
CM-015 [Rev. July 1, 2007]
CM-015
PLAINTIFF/PETITIONER: Travelers Property Casualty Company of America CASE NUMBER:
24CV00517
DEFENDANT/RESPONDENT: Allied Concrete Pumping, LLC
2. (continued)
e. Case type: limited civil unlimited civil probate family law other (specify):
f. Filing date:
g. Has this case been designated or determined as "complex?" Yes No
h. Relationship of this case to the case referenced above (check all that apply):
involves the same parties and is based on the same or similar claims.
arises from the same or substantially identical transactions, incidents, or events requiring the determination of
the same or substantially identical questions of law or fact.
involves claims against, title to, possession of, or damages to the same property.
is likely for other reasons to require substantial duplication of judicial resources if heard by different judges.
Additional explanation is attached in attachment 2h
i. Status of case:
pending
dismissed with without prejudice
disposed of by judgment
3. a. Title:
b. Case number:
c. Court: same as above
other state or federal court (name and address):
d. Department:
e. Case type: limited civil unlimited civil probate family law other (specify):
f. Filing date:
g. Has this case been designated or determined as "complex?" Yes No
h. Relationship of this case to the case referenced above (check all that apply):
involves the same parties and is based on the same or similar claims.
arises from the same or substantially identical transactions, incidents, or events requiring the determination of
the same or substantially identical questions of law or fact.
involves claims against, title to, possession of, or damages to the same property.
is likely for other reasons to require substantial duplication of judicial resources if heard by different judges.
Additional explanation is attached in attachment 3h
i. Status of case:
pending
dismissed with without prejudice
disposed of by judgment
4. Additional related cases are described in Attachment 4. Number of pages attached: ______
Date: 03.19.24
Benjamin W. Blaisdell
(TYPE OR PRINT NAME OF PARTY OR ATTORNEY) (SIGNATURE OF PARTY OR ATTORNEY)
CM-015 [Rev. July 1, 2007] Page 2 of 3
NOTICE OF RELATED CASE
CM-015
Travelers Property Casualty Company of America
PLAINTIFF/PETITIONER:
CASE NUMBER:
DEFENDANT/RESPONDENT: Allied Concrete Pumping, LLC 24CV00517
PROOF OF SERVICE BY FIRST-CLASS MAIL
NOTICE OF RELATED CASE
(NOTE: You cannot serve the Notice of Related Case if you are a party in the action. The person who served the notice must
complete this proof of service. The notice must be served on all known parties in each related action or proceeding.)
1. I am at least 18 years old and not a party to this action. I am a resident of or employed in the county where the mailing took
place, and my residence or business address is (specify):
SEE ATTACHED PROOF
2. I served a copy of the Notice of Related Case by enclosing it in a sealed envelope with first-class postage fully
prepaid and (check one):
a. deposited the sealed envelope with the United States Postal Service.
b. placed the sealed envelope for collection and processing for mailing, following this business's usual practices,
with which I am readily familiar. On the same day correspondence is placed for collection and mailing, it is
deposited in the ordinary course of business with the United States Postal Service.
3. The Notice of Related Case was mailed:
a. on (date):
b. from (city and state):
4. The envelope was addressed and mailed as follows:
a. Name of person served: c. Name of person served:
Street address: Street address:
City: City:
State and zip code: State and zip code:
b. Name of person served: d. Name of person served:
Street address: Street address:
City: City:
State and zip code: State and zip code:
Names and addresses of additional persons served are attached. (You may use form POS-030(P).)
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date:
(TYPE OR PRINT NAME OF DECLARANT) (SIGNATURE OF DECLARANT)
CM-015 [Rev. July 1, 2007] Page 3 of 3
NOTICE OF RELATED CASE
Travelers v. Allied Concrete Pumping, LLC, et al.
Santa Cruz County Superior Court, Case No. 24CV00517 (Related to Case No. 23CV01983)
PROOF OF SERVICE
1
2 I am employed in the County of Sacramento. I am over the age of eighteen years and not a party
to the within entitle action; my business address is Law Offices of John A. Biard, 11070 White Rock
3 Road, Suite 200, Rancho Cordova, California 95670.
4
On the date below, I served a copy of the following document(s) described as Notice of Related
5 Action on the interested party(ies) in this action as follows:
6 ATTORNEYS FOR PLAINTIFF GENARO ATTORNEYS FOR DEFENDANTS ALLIED
SANCHEZ: CONCRETE PUMPING, LLC AND ROLANO
7 OCHOA VALEZ:
Jeffrey L. Tade
8 Law Offices of Jeffrey L. Tade Will Kronenberg
9 1611 Bunker Hill Way, Suite 190 David E. Ruezga
Salinas, CA 93906 Kronenberg Law PC
10 Tel.: 831.753.0493 1 Kaiser Plaza, Suite 1675
EM: jeff@tadelaw.com Oakland, CA 94612
11 Tel.: 510.254.6767
Fax: 510.788.4092
12 Related Case No. 23CV01983 EM: wkronenberg@krolaw.com;
druezga@krolaw.com;
13 amarion@krolaw.com
14
Related Case No. 23CV01983
15
BY MAIL: By placing a true copy thereof enclosed in a sealed envelope(s) addresses as above
16 or on the service list, and placing each for collection and mailing on that date following
17 ordinary business practices. I am “readily familiar” with the business’ practice for collecting
and processing correspondence for mailing. On the same day that correspondence is placed
18 for collection and mailing, it is deposited in the ordinary course of business with the U.S. Postal
Service in Sacramento, California, in a sealed envelope with postage fully prepaid
19
BY OVERNIGHT DELIVERY: I enclosed the document(s) in an envelope or package
20 provided by an overnight delivery carrier and addressed as above or on the service list. I placed
the envelope or package for collection and overnight delivery at an office or a regularly utilized
21 drop box of the overnight delivery carrier.
22 BY FACSIMILE: Based on an agreement of the parties to accept service by fax transmission,
I faxed the document(s) to the person(s) at the fax number(s) listed above or on the service list
23 on the date above at approximately ________ a.m./p.m. The telephone number of the sending
24 facsimile machine was (855) 631-5920. The sending facsimile machine issued a transmission
reporting confirming that the transmission was complete and without error. A copy of that
25 report(s) is/are attached.
26 BY E-MAIL OR ELECTRONIC TRANSMISSION: Based on a court order or an
agreement of the parties to accept service by e-mail or electronic transmission, I caused the
27 document(s) to be sent from asotuela@travelers.com to the person(s) at the e-mail address(es)
listed above or on the service list.
28
PROOF OF SERVICE
Travelers v. Allied Concrete Pumping, LLC, et al.
Santa Cruz County Superior Court, Case No. 24CV00517 (Related to Case No. 23CV01983)
1 XX ONLY BY ELECTRONIC TRANSMISSION. Only by e-mailing the document(s) to the
person(s) at the e-mail address(es) listed. As stated by this office on or about March 18, 2020,
2 this office began working remotely because of a declared National Emergency due to the
COVID19 pandemic. This office will serve all documents in this case via electronic mail
3 pursuant to Cal. Civil Code of Procedure § 1010.6. No electronic message or other indication
4 that the transmission was unsuccessful was received within a reasonable time after the
transmission. We will provide a physical copy upon request only.
5 BY PERSONAL SERVICE: I caused the above documents to be hand delivered to the
6 party(ies) listed above or on the service list.
XX STATE: I declare under penalty of perjury under the laws of the State of California that the
7 foregoing is true and correct.
8 FEDERAL: I declare that I am employed in the office of a member of the bar of this Court
at whose direction the service was made. I declare under penalty of perjury under the laws of
9 the United State of America that the foregoing is true and correct.
10
Executed on Tuesday, March 19, 2024, at Rancho Cordova, California.
11
________________________________________
12
Ana Marie Sotuela/Harprit K. Sanghera
13
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PROOF OF SERVICE
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CM-015 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Benjamin W. Blaisdell (SBN 218604) Law Offices of John A. Biard Physical: 11070 White Rock Rd., Ste. 200, Rancho Cordova CA 95670 Mailing: P.O. Box 64093, St. Paul, MN 55164-0093 TELEPHONE NO.: (916) 638-6610 FAX NO. (Optional): (855) 631-5920 E-MAIL ADDRESS (Optional): bblaisde@travelers.com ATTORNEY FOR (Name): Plaintiff, Travelers Property Casualty Co. of America SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CRUZ STREET ADDRESS: 701 Ocean Street, Room 110 MAILING ADDRESS: 701 Ocean Street CITY AND ZIP CODE: Santa Cruz, CA 95060 BRANCH NAME: Civil Division CASE NUMBER: PLAINTIFF/PETITIONER: Travelers Property Casualty Company of America 24CV00517 DEFENDANT/RESPONDENT: Allied Concrete Pumping, LLC JUDICIAL OFFICER: Hon. Timothy Schmal DEPT.: NOTICE OF RELATED CASE 10 Identify, in chronological order according to date of filing, all cases related to the case referenced above. 1. a. Title: Generaro Sanchez v. Allied Concrete Pumping, LLC, et al. b. Case number: 23CV001983 c. Court: same as above other state or federal court (name and address): d. Department: e. Case type: limited civil unlimited civil probate family law other (specify): f. Filing date: 08.17.2023 g. Has this case been designated or determined as "complex?" Yes No h. Relationship of this case to the case referenced above (check all that apply): involves the same parties and is based on the same or similar claims. arises from the same or substantially identical transactions, incidents, or events requiring the determination of the same or substantially identical questions of law or fact. involves claims against, title to, possession of, or damages to the same property. is likely for other reasons to require substantial duplication of judicial resources if heard by different judges. Additional explanation is attached in attachment 1h i. Status of case: pending dismissed with without prejudice disposed of by judgment 2. a. Title: b. Case number: c. Court: same as above other state or federal court (name and address): d. Department: Page 1 of 3 Form Approved for Optional Use Cal. Rules of Court, rule 3.300 Judicial Council of California NOTICE OF RELATED CASE www.courtinfo.ca.gov CM-015 [Rev. July 1, 2007] CM-015 PLAINTIFF/PETITIONER: Travelers Property Casualty Company of America CASE NUMBER: 24CV00517 DEFENDANT/RESPONDENT: Allied Concrete Pumping, LLC 2. (continued) e. Case type: limited civil unlimited civil probate family law other (specify): f. Filing date: g. Has this case been designated or determined as "complex?" Yes No h. Relationship of this case to the case referenced above (check all that apply): involves the same parties and is based on the same or similar claims. arises from the same or substantially identical transactions, incidents, or events requiring the determination of the same or substantially identical questions of law or fact. involves claims against, title to, possession of, or damages to the same property. is likely for other reasons to require substantial duplication of judicial resources if heard by different judges. Additional explanation is attached in attachment 2h i. Status of case: pending dismissed with without prejudice disposed of by judgment 3. a. Title: b. Case number: c. Court: same as above other state or federal court (name and address): d. Department: e. Case type: limited civil unlimited civil probate family law other (specify): f. Filing date: g. Has this case been designated or determined as "complex?" Yes No h. Relationship of this case to the case referenced above (check all that apply): involves the same parties and is based on the same or similar claims. arises from the same or substantially identical transactions, incidents, or events requiring the determination of the same or substantially identical questions of law or fact. involves claims against, title to, possession of, or damages to the same property. is likely for other reasons to require substantial duplication of judicial resources if heard by different judges. Additional explanation is attached in attachment 3h i. Status of case: pending dismissed with without prejudice disposed of by judgment 4. Additional related cases are described in Attachment 4. Number of pages attached: ______ Date: 03.19.24 Benjamin W. Blaisdell (TYPE OR PRINT NAME OF PARTY OR ATTORNEY) (SIGNATURE OF PARTY OR ATTORNEY) CM-015 [Rev. July 1, 2007] Page 2 of 3 NOTICE OF RELATED CASE CM-015 Travelers Property Casualty Company of America PLAINTIFF/PETITIONER: CASE NUMBER: DEFENDANT/RESPONDENT: Allied Concrete Pumping, LLC 24CV00517 PROOF OF SERVICE BY FIRST-CLASS MAIL NOTICE OF RELATED CASE (NOTE: You cannot serve the Notice of Related Case if you are a party in the action. The person who served the notice must complete this proof of service. The notice must be served on all known parties in each related action or proceeding.) 1. I am at least 18 years old and not a party to this action. I am a resident of or employed in the county where the mailing took place, and my residence or business address is (specify): SEE ATTACHED PROOF 2. I served a copy of the Notice of Related Case by enclosing it in a sealed envelope with first-class postage fully prepaid and (check one): a. deposited the sealed envelope with the United States Postal Service. b. placed the sealed envelope for collection and processing for mailing, following this business's usual practices, with which I am readily familiar. On the same day correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service. 3. The Notice of Related Case was mailed: a. on (date): b. from (city and state): 4. The envelope was addressed and mailed as follows: a. Name of person served: c. Name of person served: Street address: Street address: City: City: State and zip code: State and zip code: b. Name of person served: d. Name of person served: Street address: Street address: City: City: State and zip code: State and zip code: Names and addresses of additional persons served are attached. (You may use form POS-030(P).) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: (TYPE OR PRINT NAME OF DECLARANT) (SIGNATURE OF DECLARANT) CM-015 [Rev. July 1, 2007] Page 3 of 3 NOTICE OF RELATED CASE Travelers v. Allied Concrete Pumping, LLC, et al. Santa Cruz County Superior Court, Case No. 24CV00517 (Related to Case No. 23CV01983) PROOF OF SERVICE 1 2 I am employed in the County of Sacramento. I am over the age of eighteen years and not a party to the within entitle action; my business address is Law Offices of John A. Biard, 11070 White Rock 3 Road, Suite 200, Rancho Cordova, California 95670. 4 On the date below, I served a copy of the following document(s) described as Notice of Related 5 Action on the interested party(ies) in this action as follows: 6 ATTORNEYS FOR PLAINTIFF GENARO ATTORNEYS FOR DEFENDANTS ALLIED SANCHEZ: CONCRETE PUMPING, LLC AND ROLANO 7 OCHOA VALEZ: Jeffrey L. Tade 8 Law Offices of Jeffrey L. Tade Will Kronenberg 9 1611 Bunker Hill Way, Suite 190 David E. Ruezga Salinas, CA 93906 Kronenberg Law PC 10 Tel.: 831.753.0493 1 Kaiser Plaza, Suite 1675 EM: jeff@tadelaw.com Oakland, CA 94612 11 Tel.: 510.254.6767 Fax: 510.788.4092 12 Related Case No. 23CV01983 EM: wkronenberg@krolaw.com; druezga@krolaw.com; 13 amarion@krolaw.com 14 Related Case No. 23CV01983 15 BY MAIL: By placing a true copy thereof enclosed in a sealed envelope(s) addresses as above 16 or on the service list, and placing each for collection and mailing on that date following 17 ordinary business practices. I am “readily familiar” with the business’ practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed 18 for collection and mailing, it is deposited in the ordinary course of business with the U.S. Postal Service in Sacramento, California, in a sealed envelope with postage fully prepaid 19 BY OVERNIGHT DELIVERY: I enclosed the document(s) in an envelope or package 20 provided by an overnight delivery carrier and addressed as above or on the service list. I placed the envelope or package for collection and overnight delivery at an office or a regularly utilized 21 drop box of the overnight delivery carrier. 22 BY FACSIMILE: Based on an agreement of the parties to accept service by fax transmission, I faxed the document(s) to the person(s) at the fax number(s) listed above or on the service list 23 on the date above at approximately ________ a.m./p.m. The telephone number of the sending 24 facsimile machine was (855) 631-5920. The sending facsimile machine issued a transmission reporting confirming that the transmission was complete and without error. A copy of that 25 report(s) is/are attached. 26 BY E-MAIL OR ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the parties to accept service by e-mail or electronic transmission, I caused the 27 document(s) to be sent from asotuela@travelers.com to the person(s) at the e-mail address(es) listed above or on the service list. 28 PROOF OF SERVICE Travelers v. Allied Concrete Pumping, LLC, et al. Santa Cruz County Superior Court, Case No. 24CV00517 (Related to Case No. 23CV01983) 1 XX ONLY BY ELECTRONIC TRANSMISSION. Only by e-mailing the document(s) to the person(s) at the e-mail address(es) listed. As stated by this office on or about March 18, 2020, 2 this office began working remotely because of a declared National Emergency due to the COVID19 pandemic. This office will serve all documents in this case via electronic mail 3 pursuant to Cal. Civil Code of Procedure § 1010.6. No electronic message or other indication 4 that the transmission was unsuccessful was received within a reasonable time after the transmission. We will provide a physical copy upon request only. 5 BY PERSONAL SERVICE: I caused the above documents to be hand delivered to the 6 party(ies) listed above or on the service list. XX STATE: I declare under penalty of perjury under the laws of the State of California that the 7 foregoing is true and correct. 8 FEDERAL: I declare that I am employed in the office of a member of the bar of this Court at whose direction the service was made. I declare under penalty of perjury under the laws of 9 the United State of America that the foregoing is true and correct. 10 Executed on Tuesday, March 19, 2024, at Rancho Cordova, California. 11 ________________________________________ 12 Ana Marie Sotuela/Harprit K. Sanghera 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE