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CIV-110
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY
NAME: Renee Nordstrand, Esq. (SBN 139412) / Matthew Morrison, Esq. (SBN 280825)
FIRM NAME:NORDSTRANDBLACK PC
STREET ADDRESS: 33 West Mission Street, Suite 206
c1TY: Santa Barbara STATE: CA ZIP CODE: 93101
TELEPHONE NO.: (805) 962-2022 FAX NO.: (805) 962-5001
E-MAILADDRESS: rn@nblaw.us; mm@nblaw.us;
ATTORNEY FOR (name): Plaintiff
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA
STREET ADDRESS: 1100 Anacapa Street
MAILING ADDRESS:
c1TY AND z1P coDE: Santa Barbara, CA 93121
BRANCH NAME:
PLAINTIFF/PETITIONER: ROGELIO JULIAN
DEFENDANT/RESPONDENT: JOHN L. BUNCE, et al.
CASE NUMBER:
REQUEST FOR DISMISSAL 22CV04181
A conformed copy will not be returned by the clerk unless a method of return is provided with the document.
This form may not be used for dismissal of a derivative action or a class action or of any party or cause of action in a
class action. (Cal. Rules of Court, rules 3.760 and 3.770.)
1. TO THE CLERK: Please dismiss this action as follows:
a. (1) [K] With prejudice (2) CJ Without prejudice
b. (1) [K] Complaint (2) CJ Petition
(3) CJ Cross-complaint filed by (name): on (date):
(4) CJ Cross-complaint filed by (name): on (date):
(5) CJ Entire action of all parties and all causes of action
(6) CJ Other (specify):*
2. (Complete in all cases except family law cases.)
The court CJ did [KJ did not waive court fees and costs for a party in this case. (This information may be obtained from
the clerk. If courl fees and costs were waived, the declaration on the back of this form m st be comp! ted).
Date:Af(;I- I�
2024
Renee Nordstrand, Esq. / Matthew Morrison, Esq. .;.._►_: -·-N<-1£-----1-��_,a---=-___;;;:...._L,__--,;o,c:;__.3i.-_
(TYPE OR PRINT NAME OF [KJ ATTORNEY CJ PARTY WITHOUT ATTORNEY) ( IGNATURE)
*If dismissal requested is of specified parties only of specified causes of action only, or Attorney or party without attorney for:
of specified cross-complaints only, so state and identify the parties, causes of action, [KJ Plaintiff/Petitioner CJ Defendant/Respondent
or cross-complaints to be dismissed
CJ Cross-Complainant
3. TO THE CLERK: Consent to the above dismissal is hereby given.**
Date: May 2, 2024
Erika L. Sandler, Esq.
(TYPE OR PRINT NAME OF [KJ ATTORNEY CJ PARTY WITHOUT ATTORNEY) (SIGNATURE)
** If a cross-complaint - or Response (Family Law) seeking affirmative relief - is on Attorney or party without attorney for:
file, the attorney for cross-complainant (respondent) must sign this consent if required
by Code of Civil Procedure section 581 (i) or 0).
CJ Plaintiff/Petitioner CJ Defendant/Respondent
[KJ Cross-Complainant
4. CJ Dismissal entered as requested on (date):
5. CJ Dismissal entered on (date): as to only (name):
6. CJ Dismissal not entered as requested for the following reasons (specify):
7. a. CJ Attorney or party without attorney notified on (date):
b. CJ Attorney or party without attorney not notified. Filing party failed to provide
CJ a copy to be conformed CJ means to return conformed copy
Date: ---------- Clerk, by
------------------
, Deputy
Page1 of2
Form Adopted for Mandatory Use REQUEST FOR DISMISSAL Code of Civil Procedure, § 581 et seq.;
Judicial Council of California Gov. Code, § 68637(c); Cal. Rules of Court, rule 3.1390
CIV-110 [Rev. January 1, 2013] www.cowts.c.a.gQ\!'.
SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR COURT USE ONLY
COUNTY OF SANTA BARBARA
TITLE OF CASE (ABBREVIATED): Rogelio Julian v. John L. Bunce, et al.
ATTORNEY(S) NAME AND ADDRESS:
Kevin P. Kennedy, Esq. (SBN: 157019)
Erika L. Sandler, Esq. (SBN 237367) TELEPHONE (858) 267-4127
KENNEDY & SOUZA, APC FACSIMILE: (858) 267-4128
7964 Arjons Drive, Suite I
San Diego, California 92126
ATTORNEYS FOR: HEARING: DATE-TIME-DEPT CASE NUMBER
Defendant/Cross-Complainant, GIFFIN & 22CV04181
CRANE GENERAL CONTRACTORS LLC
DECLARATION OF SERVICE
I, Deena Thomas, the undersigned, declare:
I am and was at the time of service of the papers herein referred to, over the age of 18 years, and
not a party to the action; I am employed in the County of San Diego, California, within which county the
subject service occurred. My business address is 7964 Arjons Drive, Suite I, San Diego, CA 92126.
On May 2, 2024, I served the following document: REQUEST FOR DISMISSAL (Plaintiff’s
Complaint) on the parties in this action addressed as follows:
ATTORNEYS FOR PLAINTIFF: ATTORNEYS FOR DEFENDANT ANCHOR HEATING &
Renee J. Nordstrand and Matthew M. Morrison AIR CONDITIONING, INC.’S
33 W. Mission Street, Suite 206 Michael E. Gallagher, Esq.; Caroline B. Fawley, Esq.
Santa Barbara, CA 93101 EDLIN GALLAGHER HUIE + BLUM
Tel: (805) 962-2022; Fax: (805) 962-5001 515 S. Flower Street, Suite 1020
Email: info@nblaw.us; rn@nblaw.us; mm@nblaw.us; Los Angeles, CA 90071
secretary@nblaw.us; (213) 412-2661; fax (213) 652-1992
mgallagher@eghblaw.com; cfawley@eghblaw.com;
Jason P. Fowler and Jonathan W. Douglass dcaudillo@eghblaw.com
PARRIS Law Firm, 43364 10th Street West
Lancaster, CA 93534, (661) 949-2595
jason@parris.com; jdouglass@parris.com;
sjordan@parris.com; JWD_Eservice@parris.com;
BY E-MAIL/ELECTRONIC TRANSMISSION - [C.C.P. § 1010.6(a)(4)] [CRC 2.250 et seq.]
Based on an agreement or stipulation between all parties dated January 9, 2023, and/or pursuant
to California Rules of Court, Rule 2.251(c)(3), I caused the document(s) to be sent from e-mail
address dthomas@kennedysouza.com to the persons at the e-mail addresses listed above. I did
not receive, within a reasonable time after the transmission, any electronic message or other
indication that the transmission was unsuccessful.
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct and that this declaration was executed on May 2, 2024, at Williams, Arizona.
Deena M. Thomas
{01173919:1} DECLARATION OF SERVICE
From: Deena Thomas
To: info@nblaw.us; rn@nblaw.us; mm@nblaw.us; secretary@nblaw.us; jason@parris.com; jdouglass@parris.com;
sjordan@parris.com; JWD_Eservice@parris.com; mgallagher@eghblaw.com; cfawley@eghblaw.com; Desiree
Caudillo (Other)
Cc: 6295 Julian Rogelio
Subject: Julian v. Bunce
Date: Thursday, May 2, 2024 8:53:00 AM
Attachments: RFD CP.pdf
image001.png
image003.png
Counsel: Please see attached Request for Dismissal of Plaintiff’s Complaint being filed in this
matter today.
Deena M. Thomas, Legal Assistant to Erika L. Sandler, Esq., Partner
Kennedy & Souza|7964 Arjons Drive, Suite I, San Diego, CA 92126
T: (858) 267-4127 ext. 1119| F: (858) 267-4128 | dthomas@kennedysouza.com
San Diego | Los Angeles | San Francisco | Orange County | Fresno
This e-mail is subject to all applicable privileges including attorney-client and work-product and is
otherwise protected by law. Any unintended dissemination of this message is expressly not to be
considered an express or implied waiver of any applicable privilege. This e-mail is the property of
Kennedy & Souza, APC. If you received this message in error, please forward it to
dthomas@kennedysouza.com, disregard the message and delete it from your computer. Please call
(858) 267-4127 if you have any questions about the e-mail or this message.
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CIV-110 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY NAME: Renee Nordstrand, Esq. (SBN 139412) / Matthew Morrison, Esq. (SBN 280825) FIRM NAME:NORDSTRANDBLACK PC STREET ADDRESS: 33 West Mission Street, Suite 206 c1TY: Santa Barbara STATE: CA ZIP CODE: 93101 TELEPHONE NO.: (805) 962-2022 FAX NO.: (805) 962-5001 E-MAILADDRESS: rn@nblaw.us; mm@nblaw.us; ATTORNEY FOR (name): Plaintiff SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA STREET ADDRESS: 1100 Anacapa Street MAILING ADDRESS: c1TY AND z1P coDE: Santa Barbara, CA 93121 BRANCH NAME: PLAINTIFF/PETITIONER: ROGELIO JULIAN DEFENDANT/RESPONDENT: JOHN L. BUNCE, et al. CASE NUMBER: REQUEST FOR DISMISSAL 22CV04181 A conformed copy will not be returned by the clerk unless a method of return is provided with the document. This form may not be used for dismissal of a derivative action or a class action or of any party or cause of action in a class action. (Cal. Rules of Court, rules 3.760 and 3.770.) 1. TO THE CLERK: Please dismiss this action as follows: a. (1) [K] With prejudice (2) CJ Without prejudice b. (1) [K] Complaint (2) CJ Petition (3) CJ Cross-complaint filed by (name): on (date): (4) CJ Cross-complaint filed by (name): on (date): (5) CJ Entire action of all parties and all causes of action (6) CJ Other (specify):* 2. (Complete in all cases except family law cases.) The court CJ did [KJ did not waive court fees and costs for a party in this case. (This information may be obtained from the clerk. If courl fees and costs were waived, the declaration on the back of this form m st be comp! ted). Date:Af(;I- I� 2024 Renee Nordstrand, Esq. / Matthew Morrison, Esq. .;.._►_: -·-N<-1£-----1-��_,a---=-___;;;:...._L,__--,;o,c:;__.3i.-_ (TYPE OR PRINT NAME OF [KJ ATTORNEY CJ PARTY WITHOUT ATTORNEY) ( IGNATURE) *If dismissal requested is of specified parties only of specified causes of action only, or Attorney or party without attorney for: of specified cross-complaints only, so state and identify the parties, causes of action, [KJ Plaintiff/Petitioner CJ Defendant/Respondent or cross-complaints to be dismissed CJ Cross-Complainant 3. TO THE CLERK: Consent to the above dismissal is hereby given.** Date: May 2, 2024 Erika L. Sandler, Esq. (TYPE OR PRINT NAME OF [KJ ATTORNEY CJ PARTY WITHOUT ATTORNEY) (SIGNATURE) ** If a cross-complaint - or Response (Family Law) seeking affirmative relief - is on Attorney or party without attorney for: file, the attorney for cross-complainant (respondent) must sign this consent if required by Code of Civil Procedure section 581 (i) or 0). CJ Plaintiff/Petitioner CJ Defendant/Respondent [KJ Cross-Complainant 4. CJ Dismissal entered as requested on (date): 5. CJ Dismissal entered on (date): as to only (name): 6. CJ Dismissal not entered as requested for the following reasons (specify): 7. a. CJ Attorney or party without attorney notified on (date): b. CJ Attorney or party without attorney not notified. Filing party failed to provide CJ a copy to be conformed CJ means to return conformed copy Date: ---------- Clerk, by ------------------ , Deputy Page1 of2 Form Adopted for Mandatory Use REQUEST FOR DISMISSAL Code of Civil Procedure, § 581 et seq.; Judicial Council of California Gov. Code, § 68637(c); Cal. Rules of Court, rule 3.1390 CIV-110 [Rev. January 1, 2013] www.cowts.c.a.gQ\!'. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR COURT USE ONLY COUNTY OF SANTA BARBARA TITLE OF CASE (ABBREVIATED): Rogelio Julian v. John L. Bunce, et al. ATTORNEY(S) NAME AND ADDRESS: Kevin P. Kennedy, Esq. (SBN: 157019) Erika L. Sandler, Esq. (SBN 237367) TELEPHONE (858) 267-4127 KENNEDY & SOUZA, APC FACSIMILE: (858) 267-4128 7964 Arjons Drive, Suite I San Diego, California 92126 ATTORNEYS FOR: HEARING: DATE-TIME-DEPT CASE NUMBER Defendant/Cross-Complainant, GIFFIN & 22CV04181 CRANE GENERAL CONTRACTORS LLC DECLARATION OF SERVICE I, Deena Thomas, the undersigned, declare: I am and was at the time of service of the papers herein referred to, over the age of 18 years, and not a party to the action; I am employed in the County of San Diego, California, within which county the subject service occurred. My business address is 7964 Arjons Drive, Suite I, San Diego, CA 92126. On May 2, 2024, I served the following document: REQUEST FOR DISMISSAL (Plaintiff’s Complaint) on the parties in this action addressed as follows: ATTORNEYS FOR PLAINTIFF: ATTORNEYS FOR DEFENDANT ANCHOR HEATING & Renee J. Nordstrand and Matthew M. Morrison AIR CONDITIONING, INC.’S 33 W. Mission Street, Suite 206 Michael E. Gallagher, Esq.; Caroline B. Fawley, Esq. Santa Barbara, CA 93101 EDLIN GALLAGHER HUIE + BLUM Tel: (805) 962-2022; Fax: (805) 962-5001 515 S. Flower Street, Suite 1020 Email: info@nblaw.us; rn@nblaw.us; mm@nblaw.us; Los Angeles, CA 90071 secretary@nblaw.us; (213) 412-2661; fax (213) 652-1992 mgallagher@eghblaw.com; cfawley@eghblaw.com; Jason P. Fowler and Jonathan W. Douglass dcaudillo@eghblaw.com PARRIS Law Firm, 43364 10th Street West Lancaster, CA 93534, (661) 949-2595 jason@parris.com; jdouglass@parris.com; sjordan@parris.com; JWD_Eservice@parris.com; BY E-MAIL/ELECTRONIC TRANSMISSION - [C.C.P. § 1010.6(a)(4)] [CRC 2.250 et seq.] Based on an agreement or stipulation between all parties dated January 9, 2023, and/or pursuant to California Rules of Court, Rule 2.251(c)(3), I caused the document(s) to be sent from e-mail address dthomas@kennedysouza.com to the persons at the e-mail addresses listed above. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed on May 2, 2024, at Williams, Arizona. Deena M. Thomas {01173919:1} DECLARATION OF SERVICE From: Deena Thomas To: info@nblaw.us; rn@nblaw.us; mm@nblaw.us; secretary@nblaw.us; jason@parris.com; jdouglass@parris.com; sjordan@parris.com; JWD_Eservice@parris.com; mgallagher@eghblaw.com; cfawley@eghblaw.com; Desiree Caudillo (Other) Cc: 6295 Julian Rogelio Subject: Julian v. Bunce Date: Thursday, May 2, 2024 8:53:00 AM Attachments: RFD CP.pdf image001.png image003.png Counsel: Please see attached Request for Dismissal of Plaintiff’s Complaint being filed in this matter today. Deena M. Thomas, Legal Assistant to Erika L. Sandler, Esq., Partner Kennedy & Souza|7964 Arjons Drive, Suite I, San Diego, CA 92126 T: (858) 267-4127 ext. 1119| F: (858) 267-4128 | dthomas@kennedysouza.com San Diego | Los Angeles | San Francisco | Orange County | Fresno This e-mail is subject to all applicable privileges including attorney-client and work-product and is otherwise protected by law. Any unintended dissemination of this message is expressly not to be considered an express or implied waiver of any applicable privilege. This e-mail is the property of Kennedy & Souza, APC. If you received this message in error, please forward it to dthomas@kennedysouza.com, disregard the message and delete it from your computer. Please call (858) 267-4127 if you have any questions about the e-mail or this message.