On April 25, 2024 a
Party Statement
was filed
involving a dispute between
and
in the District Court of Santa Barbara County.
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247177
Robert B. Forouzandeh
Reicker, Pfau, Pyle & McRoy LLP
1421 State Street, Suite B
Santa Barbara CA 93101
805-966-2440 805-966-3320
rforouzandeh@rppmh.com
Defendant Sandpiper Property Management
SANTA BARBARA
1100 Anacapa Street
P.O. Box 21107
Santa Barbara, 93121-1107
Santa Barbara - Anacapa Division
Stacy R. Kelly
Sandpiper Property Management
X
24CV00084
May 10, 2024 8:30am 4
X Robert B. Forouzandeh (Via Zoom)
X Sandpiper Property Management
X Complaint: 1)
Negligence; 2) Breach of Contract; 3) Breach of Implied Warranty of Habitability; 4) Nuisance; 5) Negligent and
Willful Inflection of Emotional Duress; and 6) Constructive Eviction
Stacy R. Kelly
Sandpiper Property Management 24CV00084
Plaintiff is a tenant of Defendant. Plaintiff's Complaint fails to state any recognizable claims. There is a currently pending UD action.
Defendant is currently in default due to excusable neglect because it believed the owner's insurance carrier was defending the case.
Defendant has been in negotiation with Plaintiff for a global settlement of this case and the UD case. If no resolution occurs, Defendant will
bring a motion to set aside the default and proceed with defending the case.
X
X
Vacation: 4/22-4/26/2024; Depo: 5/1/2024; Depo: 5/3-5/6/2024; Mediation: 5/14/2024; Vacation: 5/16-5/17/2024; MSC: 5/31/2024; Depo: 6/21/2024;
TCC: 6/28/2024 (3-14 days); Mediation: 7/8/2024; Vacation: 8/1-8/12/2024; MSC: 11/1/2024; Trial: 11/27-12/6/2024
X 3
Stacy R. Kelly
Sandpiper Property Management 24CV00084
X
X
X
X
Stacy R. Kelly
Sandpiper Property Management 24CV00084
X
Sandpiper Property Management, Inc. v. Stacy Kelly, et al.
Santa Barbara Anacapa Division
24CV00822
Settlement being discussed
X
Defendant will file a motion to set aside the default if a global settlement is not entered in the related
unlawful detainer case.
X
Defendant Written Discovery September 2024
Defendant Lay Depositions February 2025
Defendant Expert Discovery Per Code
Stacy R. Kelly
Sandpiper Property Management 24CV00084
X
April 25, 2024
Robert B. Forouzandeh
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA
3 I, the undersigned, say that I am a citizen of the United States, over 18 years of age, and
not a party to the within action. I am employed by the law firm of Reicker, Pfau, Pyle & McRoy
4 LLP, 1421 State Street, Suite B, Santa Barbara, California 93101.
5 On April 25, 2024, I served the within: CASE MANAGEMENT STATEMENT on the
interested parties as follows:
6
Stacy Kelly Plaintiff
7 850 Highlands Drive, Unit 4
Santa Barbara, CA 93109
8
(X) (By Mail) I caused such document to be mailed in a sealed envelope, by first-class mail,
9 postage fully prepaid. I am “readily familiar” with this firm’s practice of collection and
processing correspondence for mailing. It is deposited with the U.S. postal service on
10 that same day in the ordinary course of business. I am aware that on motion of party
served, service is presumed invalid if the postal cancellation date or postage meter date is
11 more than one (1) day after the date of deposit for mailing as stated in this declaration.
12 ( ) (By Personal Service) I caused such document to be delivered by hand.
13 ( ) (By FAX) I caused such document to be sent via facsimile transmission to the above-
listed addressee(s) and FAX number(s). This transmission was reported as complete and
14 without error.
15 ( ) (By E-MAIL [CCP § 1010.6(a)(2)]) On the date indicated on this Proof of Service, at
the time indicated on in the header of my electronic mail, I transmitted the foregoing
16 document(s) by electronic mail to one or more of the recipients at each firm indicated on
this Proof of Service. I caused the computer to print or maintain a record of the
17 electronic mail to the recipients named in this Proof of Service, a true and correct copy of
which has been retained by Reicker, Pfau, Pyle & McRoy LLP in either hard copy or
18 electronic format in the ordinary course of business and is available for inspection if
necessary.
19
(X) (State) I declare under penalty of perjury pursuant to the laws of the State of California
20 that the foregoing is true and correct.
21 Executed on April 25, 2024, at Santa Barbara, California.
22
_______________________________
23 Nolan O'Malley
Legal Assistant
24
25
26
27
28
Document Filed Date
April 25, 2024
Case Filing Date
April 25, 2024
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247177 Robert B. Forouzandeh Reicker, Pfau, Pyle & McRoy LLP 1421 State Street, Suite B Santa Barbara CA 93101 805-966-2440 805-966-3320 rforouzandeh@rppmh.com Defendant Sandpiper Property Management SANTA BARBARA 1100 Anacapa Street P.O. Box 21107 Santa Barbara, 93121-1107 Santa Barbara - Anacapa Division Stacy R. Kelly Sandpiper Property Management X 24CV00084 May 10, 2024 8:30am 4 X Robert B. Forouzandeh (Via Zoom) X Sandpiper Property Management X Complaint: 1) Negligence; 2) Breach of Contract; 3) Breach of Implied Warranty of Habitability; 4) Nuisance; 5) Negligent and Willful Inflection of Emotional Duress; and 6) Constructive Eviction Stacy R. Kelly Sandpiper Property Management 24CV00084 Plaintiff is a tenant of Defendant. Plaintiff's Complaint fails to state any recognizable claims. There is a currently pending UD action. Defendant is currently in default due to excusable neglect because it believed the owner's insurance carrier was defending the case. Defendant has been in negotiation with Plaintiff for a global settlement of this case and the UD case. If no resolution occurs, Defendant will bring a motion to set aside the default and proceed with defending the case. X X Vacation: 4/22-4/26/2024; Depo: 5/1/2024; Depo: 5/3-5/6/2024; Mediation: 5/14/2024; Vacation: 5/16-5/17/2024; MSC: 5/31/2024; Depo: 6/21/2024; TCC: 6/28/2024 (3-14 days); Mediation: 7/8/2024; Vacation: 8/1-8/12/2024; MSC: 11/1/2024; Trial: 11/27-12/6/2024 X 3 Stacy R. Kelly Sandpiper Property Management 24CV00084 X X X X Stacy R. Kelly Sandpiper Property Management 24CV00084 X Sandpiper Property Management, Inc. v. Stacy Kelly, et al. Santa Barbara Anacapa Division 24CV00822 Settlement being discussed X Defendant will file a motion to set aside the default if a global settlement is not entered in the related unlawful detainer case. X Defendant Written Discovery September 2024 Defendant Lay Depositions February 2025 Defendant Expert Discovery Per Code Stacy R. Kelly Sandpiper Property Management 24CV00084 X April 25, 2024 Robert B. Forouzandeh 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA 3 I, the undersigned, say that I am a citizen of the United States, over 18 years of age, and not a party to the within action. I am employed by the law firm of Reicker, Pfau, Pyle & McRoy 4 LLP, 1421 State Street, Suite B, Santa Barbara, California 93101. 5 On April 25, 2024, I served the within: CASE MANAGEMENT STATEMENT on the interested parties as follows: 6 Stacy Kelly Plaintiff 7 850 Highlands Drive, Unit 4 Santa Barbara, CA 93109 8 (X) (By Mail) I caused such document to be mailed in a sealed envelope, by first-class mail, 9 postage fully prepaid. I am “readily familiar” with this firm’s practice of collection and processing correspondence for mailing. It is deposited with the U.S. postal service on 10 that same day in the ordinary course of business. I am aware that on motion of party served, service is presumed invalid if the postal cancellation date or postage meter date is 11 more than one (1) day after the date of deposit for mailing as stated in this declaration. 12 ( ) (By Personal Service) I caused such document to be delivered by hand. 13 ( ) (By FAX) I caused such document to be sent via facsimile transmission to the above- listed addressee(s) and FAX number(s). This transmission was reported as complete and 14 without error. 15 ( ) (By E-MAIL [CCP § 1010.6(a)(2)]) On the date indicated on this Proof of Service, at the time indicated on in the header of my electronic mail, I transmitted the foregoing 16 document(s) by electronic mail to one or more of the recipients at each firm indicated on this Proof of Service. I caused the computer to print or maintain a record of the 17 electronic mail to the recipients named in this Proof of Service, a true and correct copy of which has been retained by Reicker, Pfau, Pyle & McRoy LLP in either hard copy or 18 electronic format in the ordinary course of business and is available for inspection if necessary. 19 (X) (State) I declare under penalty of perjury pursuant to the laws of the State of California 20 that the foregoing is true and correct. 21 Executed on April 25, 2024, at Santa Barbara, California. 22 _______________________________ 23 Nolan O'Malley Legal Assistant 24 25 26 27 28