Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address).
Anne Frassetto Olsen, Esq.
FOR COURT USE ONLY
SBN: 99680
NOLAND HAMERLY ETIENNE & HOSS
333 Salinas Street | P.O. Box 2510
Salinas, CA 93902
‘TELEPHONE NO, 831-424-1414 FAX NO. (Optiona): 831-424-1975,
E-maiLaDpRess: aolsen@nheh.com
ATTORNEY FOR (Name): Defendant, Lynn Duggan
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA
STREET ADDRESS: 3055 Cleveland Avenue
MAILING ADDRESS: 3055 Cleveland Avenue
CITY AND ZIP CODE: Santa Rosa, CA 95403
BRANCH NAME: Civil and Family Law Courthouse
PLAINTIFF/PETITIONER:
Sean Duggan
DEFENDANT/RESPONDENT: Lynn Duggan, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): (XJ UNLIMITED CASE (] uMiteD case
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less) SCV-268905
|A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: April 18, 2024 Time:3:00 p.m. Dept.:17 Div.: Room:
\Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Lindsey Berg-James, Esq. & Michael Shklovsky, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. CX] This statement is submitted by party (name): Defendant, Lynn Duggan
5. (XX) This statementis submitted jointly by parties (names): Michael Shklovsky, Esq. c/o Defendant, Kelly Moffat
Complaint and cross-complaint (fo be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. [__] The cross-complaint, if any, was filed on (date):
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):
(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. [__] The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
Description of case
a Type of case in complaint [] cross-complaint (Describe, including causes of action):
Declaratory Relief (1 CA), Breach of Contract (2“? and 3“ CA), Breach of Fiduciary Duty (4 and 5™ CA).
Page 1 of 5
Fotm Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Cour,
Judicial Council of California rules 3.720-3,730
(CM-110 Rev. September 1, 2021] www courts.ca gov
‘WesttawDoc & For Bulder=
CM-110
PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER:
DEFENDANT/RESPONDENT: ynn
| Duggan, et al. SCV-268905
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 Defendant Lynn Duggan sold a portion of his interest to Defendant Kelly Moffat, purportedly in violation of the
Partnership Agreement as Plaintiff alleges that this transfer has resulted in damages to, and imperilment of, Plaintiff's Limited
Partner interest in the Duggan Family Partnership.
[] (if more space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request a jury trial [J 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. (X] 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):
¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Counsel is unavailable until July 2024, due to previously scheduled hearings.
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [X] days (specify number): 5-9 Court Days
b. [-] hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial [XX] by the attorney or party listed in the caption (J by the following:
a. Attorney:
b. Firm:
©. Address:
d. Telephone number: f. Fax number.
e. E-mail address: g. Party represented:
[_] Additional representation is described in Attachment 8.
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 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 [X ] has [J 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 [7] 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) [XX] 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): Amount exceeds $50,000.00.
(OM-110 Rev. September 1, 2021] Page
2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER:
DEFENDANT/RESPONDENT:] vy Duggan, et al. SCV-268905
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 aif that apply): stipulation):
[-_] Mediation session not yet scheduled
(—_] Mediation session scheduled for (date):
(1) Mediation CI [-_] Agreed to complete mediation by (date):
[J Mediation completed on (date):
(X] 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):
[J 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):
[J ADR session not yet scheduled
(_] ADR session scheduled for (date):
(6) Other (specify):
[) Agreed to complete ADR session by (date):
[J ADR completed on (date):
‘CM-110 [Rev. September 1, 2021] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER:
DEFENDANT/RESPONDENT: Lynn Duggan, et al. SCV-268905
14. Insurance
a. [__] Insurance carrier, if any, for party filing this statement (name).
b. Reservation of rights: [__] Yes [Ne
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 will 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
[39] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motion for Summary Judgment and/or Summary Adjudication.
16. Discovery
a. [_] The party or parties have completed all discovery.
b. [-X] The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendant Written Discovery Per Code
Defendant Deposition of Plaintiff and other potential witnesses Per Code
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. September 1, 2021] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER:
DEFENDANT/RESPONDENT: | ynn Duggan, et al. SCV-268905
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
[3X] The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
The sale of the shopping center is ongoing with an expected date of closing for in or about April 30, 2024.
19. Meet and confer
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): POS
| 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: April 3, 2024
Anne Frassetto Olsen, Esq.
> Jal Auvve Frasutte Olin
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Michael Shdtovalig, Esq, Dal Michael Stltoualay
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
[] Additional signatures are attached.
‘CM-110 [Rev, September 1, 2021] Page
5 of 5
CASE MANAGEMENT STATEMENT
PROOF OF SERVICE
(Code Civ. Proc. §§ 1013(a), 2015.5)
STATE OF CALIFORNIA )
COUNTY OF MONTEREY )
Tam a citizen of the United States and a resident of Monterey County. I am over the age
of 18 years and not a party to the within entitled action; my business address is: 333 Salinas
Street, Post Office Box 2510, Salinas, CA 93902-2510.
On the date below, I served the attached document(s) entitled: JOINT CASE
MANAGEMENT STATEMENT — LYNN DUGGAN & KELLY MOFFAT, on the following
named person(s) in said action at:
10
Marshall E. Bluestone, Esq. narshall@bfolegal.com
11 BLUESTONE, ZUNINO &
HAMILTON, LLP Staff:
12 1825 4" Street emilee@bfolegal.com
Santa Rosa, CA 95404
13
Tel. (707) 526-4250
14
Michael Shklovsky, Esq. mshklovsky@andersonzeigler.com
15 ANDERSON ZEIGLER
A Professional Corporation Office Staff:
16 50 Old Courthouse Square, 5 Floor jcook@andersonzeigler.com
Santa Rosa, CA 95404 sflores@andersonzeigler.com
17
Tel.: (707) 545-4910
18
Lisa C. McCurdy, Esq. mecurdyl@gtlaw.com
19 Layal L. Bishara, Esq. bisharal@gtlaw.com
GREENBERG TRAURIG
20 1840 Century Park East, Suite 1900 Legal Assistant:
Los Angeles, CA 90067-2121 sharifih@gtlaw.com
21
Tel: (310) 586-6512
22
Mitchell B. Greenberg, Esq. MGreenberg@abbeylaw.com
23 Daniel J. Wilson, Esq. DWilson@abbeylaw.com
WEITZENBERG, WARREN &
24 EMERY, PC
100 Stony Point Road, Suite 200
25
Santa Rosa, CA 95401
26 Telephone: (707) 542-5050
27
28
30556\000\1487942.1:4324
PROOF OF SERVICE
Sean Duggan v. Lynn Duggan, et al. \ Case No. SCV-268905
By court order or by agreement of the parties to accept service by electronic
transmission, I caused the document(s) to be sent to the person(s) at the email
address(es) listed above. I did not receive within a reasonable time after the
transmission, any electronic message or other indication that the transmission was
unsuccessful. (CCP § 1010.6; Cal. Rules of Court, Rule 2.251).
by personal service on the above-named person(s) at the above stated address(es).
by placing said copy(ies) in a sealed envelope(s), postage thereon fully prepaid,
and placed for collection and processing for mailing following the business's
ordinary practice 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 at Salinas, California,
addressed as stated above.
oO by causing to be transmitted a true copy thereof to the above-named recipient via
the electronic mail address (parce@nheh.com), and no failure to deliver message
was received.
10
11 I declare, under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Zz 12
“ag Executed on April 3, 2024, at Salinas, California.
2
ge
3 13
14
15 /al Patricia Pree
Patricia Arce
16
17
18
19
20
21
22
23
24
25
26
27
28
30556\000\1487942. 1:4324
PROOF OF SERVICE
Sean Duggan v, Lynn Duggan, et al. \ Case No. SCV-268905
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address). Anne Frassetto Olsen, Esq. FOR COURT USE ONLY SBN: 99680 NOLAND HAMERLY ETIENNE & HOSS 333 Salinas Street | P.O. Box 2510 Salinas, CA 93902 ‘TELEPHONE NO, 831-424-1414 FAX NO. (Optiona): 831-424-1975, E-maiLaDpRess: aolsen@nheh.com ATTORNEY FOR (Name): Defendant, Lynn Duggan SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA STREET ADDRESS: 3055 Cleveland Avenue MAILING ADDRESS: 3055 Cleveland Avenue CITY AND ZIP CODE: Santa Rosa, CA 95403 BRANCH NAME: Civil and Family Law Courthouse PLAINTIFF/PETITIONER: Sean Duggan DEFENDANT/RESPONDENT: Lynn Duggan, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): (XJ UNLIMITED CASE (] uMiteD case (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) SCV-268905 |A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: April 18, 2024 Time:3:00 p.m. Dept.:17 Div.: Room: \Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Lindsey Berg-James, Esq. & Michael Shklovsky, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. CX] This statement is submitted by party (name): Defendant, Lynn Duggan 5. (XX) This statementis submitted jointly by parties (names): Michael Shklovsky, Esq. c/o Defendant, Kelly Moffat Complaint and cross-complaint (fo be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. [__] The cross-complaint, if any, was filed on (date): 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): (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. [__] The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): Description of case a Type of case in complaint [] cross-complaint (Describe, including causes of action): Declaratory Relief (1 CA), Breach of Contract (2“? and 3“ CA), Breach of Fiduciary Duty (4 and 5™ CA). Page 1 of 5 Fotm Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Cour, Judicial Council of California rules 3.720-3,730 (CM-110 Rev. September 1, 2021] www courts.ca gov ‘WesttawDoc & For Bulder= CM-110 PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER: DEFENDANT/RESPONDENT: ynn | Duggan, et al. SCV-268905 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 Defendant Lynn Duggan sold a portion of his interest to Defendant Kelly Moffat, purportedly in violation of the Partnership Agreement as Plaintiff alleges that this transfer has resulted in damages to, and imperilment of, Plaintiff's Limited Partner interest in the Duggan Family Partnership. [] (if more space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request a jury trial [J 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. (X] 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): ¢. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Counsel is unavailable until July 2024, due to previously scheduled hearings. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [X] days (specify number): 5-9 Court Days b. [-] hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial [XX] by the attorney or party listed in the caption (J by the following: a. Attorney: b. Firm: ©. Address: d. Telephone number: f. Fax number. e. E-mail address: g. Party represented: [_] Additional representation is described in Attachment 8. 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 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 [X ] has [J 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 [7] 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) [XX] 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): Amount exceeds $50,000.00. (OM-110 Rev. September 1, 2021] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER: DEFENDANT/RESPONDENT:] vy Duggan, et al. SCV-268905 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 aif that apply): stipulation): [-_] Mediation session not yet scheduled (—_] Mediation session scheduled for (date): (1) Mediation CI [-_] Agreed to complete mediation by (date): [J Mediation completed on (date): (X] 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): [J 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): [J ADR session not yet scheduled (_] ADR session scheduled for (date): (6) Other (specify): [) Agreed to complete ADR session by (date): [J ADR completed on (date): ‘CM-110 [Rev. September 1, 2021] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER: DEFENDANT/RESPONDENT: Lynn Duggan, et al. SCV-268905 14. Insurance a. [__] Insurance carrier, if any, for party filing this statement (name). b. Reservation of rights: [__] Yes [Ne 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 will 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 [39] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Motion for Summary Judgment and/or Summary Adjudication. 16. Discovery a. [_] The party or parties have completed all discovery. b. [-X] The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant Written Discovery Per Code Defendant Deposition of Plaintiff and other potential witnesses Per Code 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. September 1, 2021] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER: DEFENDANT/RESPONDENT: | ynn Duggan, et al. SCV-268905 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 [3X] The party or parties request that the following additional matters be considered or determined at the case management conference (specify): The sale of the shopping center is ongoing with an expected date of closing for in or about April 30, 2024. 19. Meet and confer 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): POS | 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: April 3, 2024 Anne Frassetto Olsen, Esq. > Jal Auvve Frasutte Olin (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Michael Shdtovalig, Esq, Dal Michael Stltoualay (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) [] Additional signatures are attached. ‘CM-110 [Rev, September 1, 2021] Page 5 of 5 CASE MANAGEMENT STATEMENT PROOF OF SERVICE (Code Civ. Proc. §§ 1013(a), 2015.5) STATE OF CALIFORNIA ) COUNTY OF MONTEREY ) Tam a citizen of the United States and a resident of Monterey County. I am over the age of 18 years and not a party to the within entitled action; my business address is: 333 Salinas Street, Post Office Box 2510, Salinas, CA 93902-2510. On the date below, I served the attached document(s) entitled: JOINT CASE MANAGEMENT STATEMENT — LYNN DUGGAN & KELLY MOFFAT, on the following named person(s) in said action at: 10 Marshall E. Bluestone, Esq. narshall@bfolegal.com 11 BLUESTONE, ZUNINO & HAMILTON, LLP Staff: 12 1825 4" Street emilee@bfolegal.com Santa Rosa, CA 95404 13 Tel. (707) 526-4250 14 Michael Shklovsky, Esq. mshklovsky@andersonzeigler.com 15 ANDERSON ZEIGLER A Professional Corporation Office Staff: 16 50 Old Courthouse Square, 5 Floor jcook@andersonzeigler.com Santa Rosa, CA 95404 sflores@andersonzeigler.com 17 Tel.: (707) 545-4910 18 Lisa C. McCurdy, Esq. mecurdyl@gtlaw.com 19 Layal L. Bishara, Esq. bisharal@gtlaw.com GREENBERG TRAURIG 20 1840 Century Park East, Suite 1900 Legal Assistant: Los Angeles, CA 90067-2121 sharifih@gtlaw.com 21 Tel: (310) 586-6512 22 Mitchell B. Greenberg, Esq. MGreenberg@abbeylaw.com 23 Daniel J. Wilson, Esq. DWilson@abbeylaw.com WEITZENBERG, WARREN & 24 EMERY, PC 100 Stony Point Road, Suite 200 25 Santa Rosa, CA 95401 26 Telephone: (707) 542-5050 27 28 30556\000\1487942.1:4324 PROOF OF SERVICE Sean Duggan v. Lynn Duggan, et al. \ Case No. SCV-268905 By court order or by agreement of the parties to accept service by electronic transmission, I caused the document(s) to be sent to the person(s) at the email address(es) listed above. I did not receive within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. (CCP § 1010.6; Cal. Rules of Court, Rule 2.251). by personal service on the above-named person(s) at the above stated address(es). by placing said copy(ies) in a sealed envelope(s), postage thereon fully prepaid, and placed for collection and processing for mailing following the business's ordinary practice 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 at Salinas, California, addressed as stated above. oO by causing to be transmitted a true copy thereof to the above-named recipient via the electronic mail address (parce@nheh.com), and no failure to deliver message was received. 10 11 I declare, under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Zz 12 “ag Executed on April 3, 2024, at Salinas, California. 2 ge 3 13 14 15 /al Patricia Pree Patricia Arce 16 17 18 19 20 21 22 23 24 25 26 27 28 30556\000\1487942. 1:4324 PROOF OF SERVICE Sean Duggan v, Lynn Duggan, et al. \ Case No. SCV-268905