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CIN-110
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY
NAAIE'arshall E. Bluestone, Esq. 151632
FIRMNAME:Bluestone Faircloth and Olson, LLP
srREETADDREss 1825 Fourth Street
Santa Rosa
OITY: CA ZIPCODE: 95404
STATE:
TELEPHDNENo. (707) 526-4250 FAZNo (707) 526-0347
ADDREss: marshall Bb f o1 ega 1 . corn
EMAIL
ATTDRNEYFDR/name/. Duqqan Family Limited Partnership
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONONA
sTREETADDREss. 3055 Cleveland Ave
MAILING ADDRESS:
OITYANDzIPODDE: Santa Rosa, CA 95403
BRANcHNAME: Civil
PLAINTIFF/PETITIQNER: Sean Dug gan
DEFENDANT/RESPONDENT; Lynn Duggan and Duggan Family Limited
Partnership INominal Defendants)
CASE IIANAGEMENT STATEMENT CASE NUMBER
(Checkone): Q3 UNLIMITEDCASE C3 LIMITED CASE SCV —
268905
(Alnount demanded (Amount demanded is $ 35,000
exceeds $ 35,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 4/18/2024 Time: 32 00 pm Dept.: 17 Room:
Address of court (if diffe/ent from the address above):
~ Notice of Intent to Appear by Telephone, by (name)f
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. Q3 Thisstatementissubmittedbyparty(name)f Duggan Family Limited Partnership
b. ~ This statement is submitted jointly by parties (names)f
2. Complaint and crosswomplaint (to be answemd by plaintiffs snd cross-comp/ainanls only)
a. The complaint was filed on (date)f
b. ~ The cross-complaint, if any, was filed on (dste)/
3. Service (to be answerefi by plaintiffs snd cross-comp/ainsnts only)
a. Q3 All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. C3 The following parties named in the complaint or cross-complaint
(1) ~ have not been served (specify names and explain why not)f
(2) ~ 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. C3 The following additional parties may be added (specify names, nslurs of involvement in case, and the date by which
they msy be served)f
4. Description of case
a. Type of case in Q3
Complaint for declatory
complaint ~ relief,
cross-complaint (Descnbe, including causes of action):
breach of contract, and breach of
fiduciary duty
Page 1 of 3
Form Adopled for Mandaimy Uss CASE MANAGEMENT STATEIIENT Cal Rules of Courl,
Judicial Council of Caldomia
CNLI 10 IRes. Jsnusn/ I, 202S]
~CEEiIEaaenilal rules 3.720-3.730
ceb corn IMRorma www.courls. Ca.dos
Dnggan Family Limited Partnership
CIN-110
PLAINTIFF/PETITIQNER: Sean Duggan CASE
NUMBER'CV-268905
DEFENDANT/RESPONDENT: Lynn Duggan and Duggan Family Limited
Partnership {Nominal Defendants)
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 mlief)
The Duggan Family Limited partnetship was formed in November 1997 by the agreement of the limited
partnership. Plaintiff brings this action as a limited partner against defendant Lynn Duggan as a
general partner for breach of contract and breach of fiduciary duty in the handling of the
partnership. Defendants deny plaintiff's allegations.
~ (If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request Q3 a jury trial C3 a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a. ~
The trial has been set for (date):
b. Qg 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):
7/11/24-7/16/24 Trial, 8/5/24-8/16/24 Trial, 10/21/24-11/1/24 Trial,
11/18/24-11/22/24 Trial
Estimated length of trial
The party or parties estimate that the trial will take (check one)
a. IZ) days (specify number): 7
b. ~
Attorney:
hours(short causes) (specify):
Trial representation (to be answered for each pariy)
The party or parties will be represented at trial
a.
IZ3 by the attorney or party listed in the caption ~ by the following:
b. Firm:
c. Address:
d. Telephone number: f. Fax number.
e. Email address: g. Party represented:
C3 Additional representation is described in Attachment 8.
9. Pmference
~ This case is entitled to preference (specify code section j:
10. Alternative dispute resolution (ADR)
a. ADR informadon 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 of the California Rules of Court for information about the
processes available through the court and community programs in this case.
(1) For parties represented by counsel: Counsel gg 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 C3 has ~
has not reviewed the ADR information package identi5ed 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 of 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 Bpedffed 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-1 10 IRev. Jeeomy 1, 2024I
CASEINANAGEINENTSTATEINENT Poco 2 of S
WCEEII asseniiai
cebzom Igponmr
I
Duggan Family Limited Partnership
CM-110
PLAINTIFF/PETITIDNER: Sean Duggan CASE NUMBER.
SCV-268905
DEFENDANT/RESPONDENT; Lynn Duggan and Duggan Family Limited
Partnership (Nominal Defendants)
10. c. Inthe table below, 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 pmvide the spec/had informs/ion):
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'DR
processes (check a/I that app/y): siipuialion):
~ Mediation session not yet scheduled
(1) Mediation
~ Mediation session scheduled for (date):
~ Agreed to complete mediation by (date):
~ Mediation completed on (date):
C3 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
(3) Neutral evaluation
~ Neutral evaluation scheduled for (dale):
~ Agreed to complete neutral evaluation by {date):
~ Neutral evaluation completed on (date):
~ Judicial arbitration not yet scheduled
(4) Nonbinding judicial ~ Judicial arbitration scheduled for (dafe):
arbitration
~ Agreed to complete judicial arbitration by (dale):
~ Judicial arbitration completed on (dale):
C3 Private arbitration not yet scheduled
(5) Binding private ~ Private arbitration scheduled for (dale):
arbitration
~ Agreed to complete private arbitration by (date):
~ Private arbitralion completed on (date):
C3 ADR session not yet scheduled
(5) Other (specify): ~ ADR session scheduled for (date):
~ Agreed to complete ADR session by (dale):
~ ADR completed on (date):
CM.110 IRav Jfmuer 1, 2024I CASE MANAGEhllENT STATEMENT F404 2 ef S
S CEBI sssenuaf
ceb.corn I IBFefffer
ouggan Family Limited partnership
CII-110
PLAINTIFF/PETITIDNER: Sean Dug gan CASE NUMBER;
SCV-268905
DEFENDANT/RESPONDENT: Lynn Duggan and Duggan Family Limited
Partnership (Nominal Defendants)
11. Insurance
s.
b.
~
Insurance camer, if any, for party filing this statement (name):
Reservation of rights: ~ Yes ~ No
c. C3 Coverage issues will significantly affect resolution of this case (exp/ain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
~ Bankruptcy
Status:
~
Other (spec/fy):
consolidation, and coordination
~ cases,
13. Related
a. There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number.
(4) Status:
C3 Additional cases are described in Attachment 13a.
b. ~ A motion to ~ consolidate ~ coordinate will be Sled by (name part)).
14. Bifurcation
~ The party or parties intend to 5le a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (spec/fy moving party, type of motion, and reasons):
15. Other motions
~ The party or parties expect to 5le the following motions before trial (speci/y moving party, type of moron, and issues):
16. Discovery
a.
b.
~
C3
The party or parties have completed ag discovery.
The following discovery will be completed by the date speci5ed (describe a// anticipated discovery):
Para Descriotion ate
c. ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 IRon Jssuny 1. 2024l CASE 55ANAGE55ENT STATE55ENT Pago 4 of S
ssenilsl
QCEErf gipsnnfr
ceb.corn
ouggan Family Limited partnership
CM-110
PLAINTIFF/PETITIQNER: Sean Duggan CASE NUMBER
SCV-268905
DEFENDANT/RESPONDENT: Lynn Duggan and Duggan Family Limited
Partnership (Nominal Defendants)
17. Economic litigation
a. ~
This is a limited civil case (i.e., the amount demanded is $ 35,000 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 specifical/y why economic litigation procedures relating to discovery or trial
should not a pp/y to this case):
18. Otherissues
~ 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: 4/3/2024
IY)a r R FIR 1 1 F. R1» P R t nr) P
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
ITYPE OR PRINT NAME)
~
(SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-»0 IRev January I, 2024] CASE MANAGEMENT STATEMENT Page 5 of 5
IS C EEr I
Essential
ceh,corn FHFofmsI
Ouggan Family Limited Partnership
CERTIFICATE OF SERVICE
California.
I am employed in Sonoma County, I am over the age of 18 years and not a party
to the within action. My business address is 1825 4'" Street, Santa Rosa, CA 95404. On April 3,
2024, I served the following document(s):
DUGGAN FAMILY LIMITED PARTNERSHIPS CASE MANAGEMENT STMT.
by placing a true copy thereof enclosed is a sealed envelope and/or served in the manner
described below and addressed to:
Attornev for Defendant Lvnn Duaaan: Attornev for Plaintiff Sean Duaaan:
Anne Olsen Lisa McCurdy
Noland Hamerly Etienne and Hoss APC Greenberg Traurig, LLP
333 Salinas Street PO Box 2510 1840 Century Park East, Ste. 1900
Salinas, CA 93902 Los Angeles, CA 90067
Email: aolsen(Rnheh.corn Email: mccurdvl&atlaw.corn
Attornev for Defendant Kellv Moffat:
Michael Schklovsky
Anderson Zeigler, APC
50 Old Courthouse Square 5'" Floor
Santa Rosa, CA 95404
Email: mshklovskvSandersonzeinier.corn
BY U.S. MAIL: I caused such envelope to be deposited in the mail by placing the
envelope for collection and mailing following our ordinary business practices. I am
readily familiar with this business'ractice for collecting and processing correspondence
for mailing. On the same day that correspondence is placed for collection and mailing, it
is deposited in the ordinary course of business with the United States Postal Service in a
sealed envelope with postage fully prepaid. The name and address of each person/firm to
whom I mailed the documents is listed above.
BY HAND DELIVERY: I caused such envelope to be delivered by hand to the
addressee(s) designated above.
BY OVERNIGHT COURIER SERVICE: I caused such envelope to be delivered via
overnight courier services to the addressee(s) designated above.
BY FACSIMILE: I caused said document(s) to be transmitted to the facsimile number(s)
of the addressee(s) designated.
X BY E-MAIL: I transmitted electronically the listed documents(s) to the e-mail
address(es) of the addressee(s) set forth above.
Ideclare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct. Executed April 3, 2024, at Santa Rosa, California.
CERTIFICATE OF SERVICE
Preview
CIN-110 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY NAAIE'arshall E. Bluestone, Esq. 151632 FIRMNAME:Bluestone Faircloth and Olson, LLP srREETADDREss 1825 Fourth Street Santa Rosa OITY: CA ZIPCODE: 95404 STATE: TELEPHDNENo. (707) 526-4250 FAZNo (707) 526-0347 ADDREss: marshall Bb f o1 ega 1 . corn EMAIL ATTDRNEYFDR/name/. Duqqan Family Limited Partnership SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONONA sTREETADDREss. 3055 Cleveland Ave MAILING ADDRESS: OITYANDzIPODDE: Santa Rosa, CA 95403 BRANcHNAME: Civil PLAINTIFF/PETITIQNER: Sean Dug gan DEFENDANT/RESPONDENT; Lynn Duggan and Duggan Family Limited Partnership INominal Defendants) CASE IIANAGEMENT STATEMENT CASE NUMBER (Checkone): Q3 UNLIMITEDCASE C3 LIMITED CASE SCV — 268905 (Alnount demanded (Amount demanded is $ 35,000 exceeds $ 35,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 4/18/2024 Time: 32 00 pm Dept.: 17 Room: Address of court (if diffe/ent from the address above): ~ Notice of Intent to Appear by Telephone, by (name)f INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. Q3 Thisstatementissubmittedbyparty(name)f Duggan Family Limited Partnership b. ~ This statement is submitted jointly by parties (names)f 2. Complaint and crosswomplaint (to be answemd by plaintiffs snd cross-comp/ainanls only) a. The complaint was filed on (date)f b. ~ The cross-complaint, if any, was filed on (dste)/ 3. Service (to be answerefi by plaintiffs snd cross-comp/ainsnts only) a. Q3 All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. C3 The following parties named in the complaint or cross-complaint (1) ~ have not been served (specify names and explain why not)f (2) ~ 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. C3 The following additional parties may be added (specify names, nslurs of involvement in case, and the date by which they msy be served)f 4. Description of case a. Type of case in Q3 Complaint for declatory complaint ~ relief, cross-complaint (Descnbe, including causes of action): breach of contract, and breach of fiduciary duty Page 1 of 3 Form Adopled for Mandaimy Uss CASE MANAGEMENT STATEIIENT Cal Rules of Courl, Judicial Council of Caldomia CNLI 10 IRes. Jsnusn/ I, 202S] ~CEEiIEaaenilal rules 3.720-3.730 ceb corn IMRorma www.courls. Ca.dos Dnggan Family Limited Partnership CIN-110 PLAINTIFF/PETITIQNER: Sean Duggan CASE NUMBER'CV-268905 DEFENDANT/RESPONDENT: Lynn Duggan and Duggan Family Limited Partnership {Nominal Defendants) 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 mlief) The Duggan Family Limited partnetship was formed in November 1997 by the agreement of the limited partnership. Plaintiff brings this action as a limited partner against defendant Lynn Duggan as a general partner for breach of contract and breach of fiduciary duty in the handling of the partnership. Defendants deny plaintiff's allegations. ~ (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request Q3 a jury trial C3 a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a. ~ The trial has been set for (date): b. Qg 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): 7/11/24-7/16/24 Trial, 8/5/24-8/16/24 Trial, 10/21/24-11/1/24 Trial, 11/18/24-11/22/24 Trial Estimated length of trial The party or parties estimate that the trial will take (check one) a. IZ) days (specify number): 7 b. ~ Attorney: hours(short causes) (specify): Trial representation (to be answered for each pariy) The party or parties will be represented at trial a. IZ3 by the attorney or party listed in the caption ~ by the following: b. Firm: c. Address: d. Telephone number: f. Fax number. e. Email address: g. Party represented: C3 Additional representation is described in Attachment 8. 9. Pmference ~ This case is entitled to preference (specify code section j: 10. Alternative dispute resolution (ADR) a. ADR informadon 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 of the California Rules of Court for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel gg 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 C3 has ~ has not reviewed the ADR information package identi5ed 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 of 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 Bpedffed 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-1 10 IRev. Jeeomy 1, 2024I CASEINANAGEINENTSTATEINENT Poco 2 of S WCEEII asseniiai cebzom Igponmr I Duggan Family Limited Partnership CM-110 PLAINTIFF/PETITIDNER: Sean Duggan CASE NUMBER. SCV-268905 DEFENDANT/RESPONDENT; Lynn Duggan and Duggan Family Limited Partnership (Nominal Defendants) 10. c. Inthe table below, 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 pmvide the spec/had informs/ion): 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'DR processes (check a/I that app/y): siipuialion): ~ Mediation session not yet scheduled (1) Mediation ~ Mediation session scheduled for (date): ~ Agreed to complete mediation by (date): ~ Mediation completed on (date): C3 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 (3) Neutral evaluation ~ Neutral evaluation scheduled for (dale): ~ Agreed to complete neutral evaluation by {date): ~ Neutral evaluation completed on (date): ~ Judicial arbitration not yet scheduled (4) Nonbinding judicial ~ Judicial arbitration scheduled for (dafe): arbitration ~ Agreed to complete judicial arbitration by (dale): ~ Judicial arbitration completed on (dale): C3 Private arbitration not yet scheduled (5) Binding private ~ Private arbitration scheduled for (dale): arbitration ~ Agreed to complete private arbitration by (date): ~ Private arbitralion completed on (date): C3 ADR session not yet scheduled (5) Other (specify): ~ ADR session scheduled for (date): ~ Agreed to complete ADR session by (dale): ~ ADR completed on (date): CM.110 IRav Jfmuer 1, 2024I CASE MANAGEhllENT STATEMENT F404 2 ef S S CEBI sssenuaf ceb.corn I IBFefffer ouggan Family Limited partnership CII-110 PLAINTIFF/PETITIDNER: Sean Dug gan CASE NUMBER; SCV-268905 DEFENDANT/RESPONDENT: Lynn Duggan and Duggan Family Limited Partnership (Nominal Defendants) 11. Insurance s. b. ~ Insurance camer, if any, for party filing this statement (name): Reservation of rights: ~ Yes ~ No c. C3 Coverage issues will significantly affect resolution of this case (exp/ain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. ~ Bankruptcy Status: ~ Other (spec/fy): consolidation, and coordination ~ cases, 13. Related a. There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number. (4) Status: C3 Additional cases are described in Attachment 13a. b. ~ A motion to ~ consolidate ~ coordinate will be Sled by (name part)). 14. Bifurcation ~ The party or parties intend to 5le a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (spec/fy moving party, type of motion, and reasons): 15. Other motions ~ The party or parties expect to 5le the following motions before trial (speci/y moving party, type of moron, and issues): 16. Discovery a. b. ~ C3 The party or parties have completed ag discovery. The following discovery will be completed by the date speci5ed (describe a// anticipated discovery): Para Descriotion ate c. ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 IRon Jssuny 1. 2024l CASE 55ANAGE55ENT STATE55ENT Pago 4 of S ssenilsl QCEErf gipsnnfr ceb.corn ouggan Family Limited partnership CM-110 PLAINTIFF/PETITIQNER: Sean Duggan CASE NUMBER SCV-268905 DEFENDANT/RESPONDENT: Lynn Duggan and Duggan Family Limited Partnership (Nominal Defendants) 17. Economic litigation a. ~ This is a limited civil case (i.e., the amount demanded is $ 35,000 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 specifical/y why economic litigation procedures relating to discovery or trial should not a pp/y to this case): 18. Otherissues ~ 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: 4/3/2024 IY)a r R FIR 1 1 F. R1» P R t nr) P (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) ITYPE OR PRINT NAME) ~ (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-»0 IRev January I, 2024] CASE MANAGEMENT STATEMENT Page 5 of 5 IS C EEr I Essential ceh,corn FHFofmsI Ouggan Family Limited Partnership CERTIFICATE OF SERVICE California. I am employed in Sonoma County, I am over the age of 18 years and not a party to the within action. My business address is 1825 4'" Street, Santa Rosa, CA 95404. On April 3, 2024, I served the following document(s): DUGGAN FAMILY LIMITED PARTNERSHIPS CASE MANAGEMENT STMT. by placing a true copy thereof enclosed is a sealed envelope and/or served in the manner described below and addressed to: Attornev for Defendant Lvnn Duaaan: Attornev for Plaintiff Sean Duaaan: Anne Olsen Lisa McCurdy Noland Hamerly Etienne and Hoss APC Greenberg Traurig, LLP 333 Salinas Street PO Box 2510 1840 Century Park East, Ste. 1900 Salinas, CA 93902 Los Angeles, CA 90067 Email: aolsen(Rnheh.corn Email: mccurdvl&atlaw.corn Attornev for Defendant Kellv Moffat: Michael Schklovsky Anderson Zeigler, APC 50 Old Courthouse Square 5'" Floor Santa Rosa, CA 95404 Email: mshklovskvSandersonzeinier.corn BY U.S. MAIL: I caused such envelope to be deposited in the mail by placing the envelope for collection and mailing following our ordinary business practices. I am readily familiar with this business'ractice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service in a sealed envelope with postage fully prepaid. The name and address of each person/firm to whom I mailed the documents is listed above. BY HAND DELIVERY: I caused such envelope to be delivered by hand to the addressee(s) designated above. BY OVERNIGHT COURIER SERVICE: I caused such envelope to be delivered via overnight courier services to the addressee(s) designated above. BY FACSIMILE: I caused said document(s) to be transmitted to the facsimile number(s) of the addressee(s) designated. X BY E-MAIL: I transmitted electronically the listed documents(s) to the e-mail address(es) of the addressee(s) set forth above. Ideclare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed April 3, 2024, at Santa Rosa, California. CERTIFICATE OF SERVICE