Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NuMBER: 280385 FOR COURT USE ONLY
name: Brian Pettit.Sr. Deputy
Firmname: Santa Barbara County Counsel
street appress: 105 E. Anapamu Street, Suite 201
cry: Santa Barbara state: CA zip cove: 93101
TeLePHone No: 805-568-2950 Faxno: 805-568-2982
email aporess: bpettit@countyofsb.org
ATTORNEY FOR (name): County of Santa Barbara
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA
STREET ADDRESS: 1100 Anacapa Street
MAILING ADDRESS:
city aND zip cove: Santa Barbara, CA 93101
BRANCH NAME: Anacapa
PLAINTIFF/PETITIONER: Casa Blanca Beach Estates Owners Association
DEFENDANT/RESPONDENT: State of California, County of Santa Barbara, et al.,
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): I sUNLIMITED CASE (1 simitep cAseE 23CV00947
(Amount demanded (Amount demanded is $35,000
exceeds $35,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: May 10, 2024 Time: 8:30 a.m. Dept.: 4 Div.: Room:
Address of court (if different from the address above):
[1 Notice of Intent to Appear by Telephone, by (name):
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. EX] This statement is submitted by party (name): County of Santa Barbara
b. [1 This statement is submitted jointly by parties (names):
Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. [1] The cross-complaint, if any, was filed on (date):
Service (fo be answered by plaintiffs and cross-complainants only)
a O All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. oO The following parties named in the complaint or cross-complaint
(1) (11 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):
O 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 EJ complaint Oi cross-complaint (Describe, including causes of action):
Civil action alleging 15 causes of action, including two for declaratory relief against the County.
Page1 of5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal, Rules of Court,
Judicial Council of California rules 3.720-3 730
CM-110 [Rev. January 1, 2024) www courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: Casa Blanca Beach Estates Owners Association CASE NUMBER:
23CV00947
DEFENDANT/RESPONDENT: State of California, County of Santa Barbara, et al.
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
eamings to date, and estimated future lost eamings; if equitable relief is sought, describe the nature of the relief):
Plaintiff alleges breach of contract and constitutional claims against State Lands Commission in connection with a
lease for coastal rock revetment's occupation of state lands. Plaintiff also seeks declaratory relief against all
defendants concerning plaintiff's obligations under the lease.
Oo (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 DD a jury trial a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a. [1 The trial has been set for (date):
b. EJ 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):
Estimated length of trial
The party or parties estimate that the trial will take (check one)
a &l days (specify number): 3-5
60 hours (short causes) (specify):
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 (1 by the following:
a Attorney:
b. Firm:
©. Address:
d Telephone number: f. Fax number:
e. Email address: g. Party represented:
(1 Additional representation is described in Attachment 8.
Preference
(1 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 0 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 o has not reviewed the ADR information package identified in rule 3.221.
Referral to judicial arbitration or civil action mediation (if available).
(1) [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.
@o 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.
@eO 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 1 775 et seq. (specify exemption):
CM-110 (Rev. January 1, 2024) CASE MANAGEMENT STATEMENT Page 2 of 5
CM-110
PLAINTIFF/PETITIONER: Casa Blanca Beach Estates Owners Association ‘CASE NUMBER:
DEFENDANT/RESPONDENT: State of California, County of Santa Barbara
23CV00947
10.c. In the 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 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):
(J Mediation session not yet scheduled
(1) Mediation session scheduled for (date):
(1) Mediation Q (2) Agreed to complete mediation by (date):
(1 Mediation completed on (date):
C1 Settlement conference not yet scheduled
(2) Settlement (1 Settlement conference scheduled for(date):
conference Oo Agreed to complete settlement conference by (date):
C2 Settlement conference completed on (date):
2 Neutral evaluation not yet scheduled
(1 Neutral evaluation scheduled for (date):
(3) Neutral evaluation
LD Agreed to complete neutral evaluation by (date):
(2 Neutral evaluation completed on (date):
oO Judicial arbitration not yet scheduled
(4) Nonbinding judicial (2 Judicial arbitration scheduled for (date):
arbitration oO Agreed to complete judicial arbitration by (date):
(2) Judicial arbitration completed on (date):
(1 Private arbitration not yet scheduled
(5) Binding private C1 Private arbitration scheduled for (date):
arbitration (1 Agreed to complete private arbitration by (date):
(1 Private arbitration completed on (date):
oO ADR session not yet scheduled
(6) Other (specify): (7 ADR session scheduled for (date):
(1 Agreed to complete ADR session by (date):
(1 ADR completed on (date):
(CM-110 [Rev. January 1, 2024) CASE MANAGEMENT STATEMENT Page 3 of 5
CM-110
PLAINTIFF/PETITIONER: Casa Blanca Beach Estates Owners Association CASE NUMBER:
23CV00947
DEFENDANT/RESPONDENT: State of California, County of Santa Barbara
11. Insurance
aO Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: 0 Yes (1 No
c. [1 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.
1 Bankruptcy CO Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. [1 There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
QO Additional cases are described in Attachment 13a.
b. [1] Amotion to O consolidate 1 coordinate will be filed by (name party):
14. Bifurcation
1 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
KK The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Pending discovery, County may file motion for summary adjudication for the two causes of action directed against
the County.
16. Discovery
a Oo The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Descriptio! Date
County of Santa Barbara Written Discovery Per Code
c. [1 The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated
(specify):
CM-110 (Rev. January 1, 2024] CASE MANAGEMENT STATEMENT Page
4 of 5
CM-110
PLAINTIFF/PETITIONER: Casa Blanca Beach Estates Owners Association CASE NUMBER:
23CV00947
DEFENDANT/RESPONDENT: State of California, County of Santa Barbara
17. Economic litigation
a. [1 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.
6O 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
(1 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. KJ 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. [1 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):
| 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.
» Kan Mee.
Date: April 23, 2024
Brian Pettit
(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. January 1, 2024) CASE MANAGEMENT STATEMENT Page 5 of 5
PROOF OF SERVICE
(C.C.P. §§ 1013(a), 2015.5)
STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA
Iam a citizen of the United States and a resident of the county aforesaid; I am over the
age of eighteen years and not a party to the within entitled action; my business address
is 105 East Anapamu Street, Santa Barbara, California.
On April 23, 2024, I served a true copy of the within CASE MANAGEMENT
STATEMENT on the Interested Parties in this action:
O by mail to the person(s) indicted below. I am familiar with the practice of the
Office of Santa Barbara County Counsel for the collection and processing of
correspondence for mailing with the United States Postal Service. In accordance with
the ordinary course of business, the above-mentioned document would have been
deposited with the United States Postal Service, after having been deposited and
processed for postage with the County of Santa Barbara Central Mail Room.
SEE ATTACHED
PROOF OF SERVICE LIST
O via Federal Express delivery services company to the person(s) indicated
below.
x by e-mail or electronic transmission. I caused the document(s) to be sent from
e-mail address mheuvel@countyofsb.org, to the persons at the e-mail addresses listed
on the attached Proof of Service List. I did not receive, within a reasonable time after
the transmission, any electronic message or other indication that the transmission was
unsuccessful.
XI (State) I declare, under penalty of perjury, that the above is true and correct.
0 (Federal) I declare that Iam employed in the office ofa member of the
Bar of this Court at whose direction the service was made.
Executed on April 23, 2024 at Santa Barbara, California.
Warlern
van don Newel
Marleen van den Heuvel
1
PROOF OF SERVICE
PROOF OF SERVICE SERVICE LIST
Lisa A. Weinberg, Esq. Rob Bonta, Attorney General of California
Gaines & Stacey LLP Roxanne Carter, Deputy Attorney General
5280 Canoga Avenue, Suite 300 Joseph Isenstadt, Deputy Attorney General
Woodland Hills, CA 93167 California Department of Justice
lweinberg@gaineslaw.com 600 West Broadway, Suite 1800
San Diego, CA 93101
Attorney for Plaintiff, Casa Blanca oxy.carter@doj.ca.gov
Beach Estates Owners’ Association
Attorney for Defendant, California State
Lands Commission
James Ballantine, Esq. Jamee Jordan Patterson,
329 E. Anapamu Street Supervising Senior Staff Attorney
Santa Barbara, CA 93101 Office of the Attorney General
jpb@ballantinelaw.com 600 West Broadway Suite 1800
San Diego CA 92101
Jamee.Patterson@doj.g
Attorney for Plaintiff, Casa Blanca
Beach Estates Owners’ Association Attorney for Defendant, California Coastal
Commission
2
PROOF OF SERVICE
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NuMBER: 280385 FOR COURT USE ONLY name: Brian Pettit.Sr. Deputy Firmname: Santa Barbara County Counsel street appress: 105 E. Anapamu Street, Suite 201 cry: Santa Barbara state: CA zip cove: 93101 TeLePHone No: 805-568-2950 Faxno: 805-568-2982 email aporess: bpettit@countyofsb.org ATTORNEY FOR (name): County of Santa Barbara SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA STREET ADDRESS: 1100 Anacapa Street MAILING ADDRESS: city aND zip cove: Santa Barbara, CA 93101 BRANCH NAME: Anacapa PLAINTIFF/PETITIONER: Casa Blanca Beach Estates Owners Association DEFENDANT/RESPONDENT: State of California, County of Santa Barbara, et al., CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): I sUNLIMITED CASE (1 simitep cAseE 23CV00947 (Amount demanded (Amount demanded is $35,000 exceeds $35,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 10, 2024 Time: 8:30 a.m. Dept.: 4 Div.: Room: Address of court (if different from the address above): [1 Notice of Intent to Appear by Telephone, by (name): INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. EX] This statement is submitted by party (name): County of Santa Barbara b. [1 This statement is submitted jointly by parties (names): Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. [1] The cross-complaint, if any, was filed on (date): Service (fo be answered by plaintiffs and cross-complainants only) a O All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. oO The following parties named in the complaint or cross-complaint (1) (11 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): O 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 EJ complaint Oi cross-complaint (Describe, including causes of action): Civil action alleging 15 causes of action, including two for declaratory relief against the County. Page1 of5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal, Rules of Court, Judicial Council of California rules 3.720-3 730 CM-110 [Rev. January 1, 2024) www courts.ca.gov CM-110 PLAINTIFF/PETITIONER: Casa Blanca Beach Estates Owners Association CASE NUMBER: 23CV00947 DEFENDANT/RESPONDENT: State of California, County of Santa Barbara, et al. 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 eamings to date, and estimated future lost eamings; if equitable relief is sought, describe the nature of the relief): Plaintiff alleges breach of contract and constitutional claims against State Lands Commission in connection with a lease for coastal rock revetment's occupation of state lands. Plaintiff also seeks declaratory relief against all defendants concerning plaintiff's obligations under the lease. Oo (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 DD a jury trial a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a. [1 The trial has been set for (date): b. EJ 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): Estimated length of trial The party or parties estimate that the trial will take (check one) a &l days (specify number): 3-5 60 hours (short causes) (specify): 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 (1 by the following: a Attorney: b. Firm: ©. Address: d Telephone number: f. Fax number: e. Email address: g. Party represented: (1 Additional representation is described in Attachment 8. Preference (1 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 0 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 o has not reviewed the ADR information package identified in rule 3.221. Referral to judicial arbitration or civil action mediation (if available). (1) [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. @o 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. @eO 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 1 775 et seq. (specify exemption): CM-110 (Rev. January 1, 2024) CASE MANAGEMENT STATEMENT Page 2 of 5 CM-110 PLAINTIFF/PETITIONER: Casa Blanca Beach Estates Owners Association ‘CASE NUMBER: DEFENDANT/RESPONDENT: State of California, County of Santa Barbara 23CV00947 10.c. In the 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 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): (J Mediation session not yet scheduled (1) Mediation session scheduled for (date): (1) Mediation Q (2) Agreed to complete mediation by (date): (1 Mediation completed on (date): C1 Settlement conference not yet scheduled (2) Settlement (1 Settlement conference scheduled for(date): conference Oo Agreed to complete settlement conference by (date): C2 Settlement conference completed on (date): 2 Neutral evaluation not yet scheduled (1 Neutral evaluation scheduled for (date): (3) Neutral evaluation LD Agreed to complete neutral evaluation by (date): (2 Neutral evaluation completed on (date): oO Judicial arbitration not yet scheduled (4) Nonbinding judicial (2 Judicial arbitration scheduled for (date): arbitration oO Agreed to complete judicial arbitration by (date): (2) Judicial arbitration completed on (date): (1 Private arbitration not yet scheduled (5) Binding private C1 Private arbitration scheduled for (date): arbitration (1 Agreed to complete private arbitration by (date): (1 Private arbitration completed on (date): oO ADR session not yet scheduled (6) Other (specify): (7 ADR session scheduled for (date): (1 Agreed to complete ADR session by (date): (1 ADR completed on (date): (CM-110 [Rev. January 1, 2024) CASE MANAGEMENT STATEMENT Page 3 of 5 CM-110 PLAINTIFF/PETITIONER: Casa Blanca Beach Estates Owners Association CASE NUMBER: 23CV00947 DEFENDANT/RESPONDENT: State of California, County of Santa Barbara 11. Insurance aO Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: 0 Yes (1 No c. [1 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. 1 Bankruptcy CO Other (specify): Status: 13. Related cases, consolidation, and coordination a. [1 There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: QO Additional cases are described in Attachment 13a. b. [1] Amotion to O consolidate 1 coordinate will be filed by (name party): 14. Bifurcation 1 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 KK The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Pending discovery, County may file motion for summary adjudication for the two causes of action directed against the County. 16. Discovery a Oo The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Descriptio! Date County of Santa Barbara Written Discovery Per Code c. [1 The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 (Rev. January 1, 2024] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: Casa Blanca Beach Estates Owners Association CASE NUMBER: 23CV00947 DEFENDANT/RESPONDENT: State of California, County of Santa Barbara 17. Economic litigation a. [1 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. 6O 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 (1 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. KJ 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. [1 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): | 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. » Kan Mee. Date: April 23, 2024 Brian Pettit (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. January 1, 2024) CASE MANAGEMENT STATEMENT Page 5 of 5 PROOF OF SERVICE (C.C.P. §§ 1013(a), 2015.5) STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA Iam a citizen of the United States and a resident of the county aforesaid; I am over the age of eighteen years and not a party to the within entitled action; my business address is 105 East Anapamu Street, Santa Barbara, California. On April 23, 2024, I served a true copy of the within CASE MANAGEMENT STATEMENT on the Interested Parties in this action: O by mail to the person(s) indicted below. I am familiar with the practice of the Office of Santa Barbara County Counsel for the collection and processing of correspondence for mailing with the United States Postal Service. In accordance with the ordinary course of business, the above-mentioned document would have been deposited with the United States Postal Service, after having been deposited and processed for postage with the County of Santa Barbara Central Mail Room. SEE ATTACHED PROOF OF SERVICE LIST O via Federal Express delivery services company to the person(s) indicated below. x by e-mail or electronic transmission. I caused the document(s) to be sent from e-mail address mheuvel@countyofsb.org, to the persons at the e-mail addresses listed on the attached Proof of Service List. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. XI (State) I declare, under penalty of perjury, that the above is true and correct. 0 (Federal) I declare that Iam employed in the office ofa member of the Bar of this Court at whose direction the service was made. Executed on April 23, 2024 at Santa Barbara, California. Warlern van don Newel Marleen van den Heuvel 1 PROOF OF SERVICE PROOF OF SERVICE SERVICE LIST Lisa A. Weinberg, Esq. Rob Bonta, Attorney General of California Gaines & Stacey LLP Roxanne Carter, Deputy Attorney General 5280 Canoga Avenue, Suite 300 Joseph Isenstadt, Deputy Attorney General Woodland Hills, CA 93167 California Department of Justice lweinberg@gaineslaw.com 600 West Broadway, Suite 1800 San Diego, CA 93101 Attorney for Plaintiff, Casa Blanca oxy.carter@doj.ca.gov Beach Estates Owners’ Association Attorney for Defendant, California State Lands Commission James Ballantine, Esq. Jamee Jordan Patterson, 329 E. Anapamu Street Supervising Senior Staff Attorney Santa Barbara, CA 93101 Office of the Attorney General jpb@ballantinelaw.com 600 West Broadway Suite 1800 San Diego CA 92101 Jamee.Patterson@doj.g Attorney for Plaintiff, Casa Blanca Beach Estates Owners’ Association Attorney for Defendant, California Coastal Commission 2 PROOF OF SERVICE