Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY
NAME: Gregory K. Sabo, #169760/David A. Napper, 271464
FIRM NAME: Chapman Glucksman
STREET ADDRESS: 11900 W. Olympic Boulevard, Suite 800
CITY: Los Angeles STATE: CA ZIP CODE: 90064
TELEPHONE NO.: (310) 207-7722 FAX NO.: (310) 207-6550
EMAIL ADDRESS: gsabo@cgdrlaw.com/dnapper@cgdrlaw.com/service@cgdrlaw.com
ATTORNEY FOR (name): Defs. PATRICIA WOLLUM and SUSAN REYNOLDS
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA
STREET ADDRESS: 1100 Anacapa Street
MAILING ADDRESS:
Santa Barbara, CA 93101
CITY AND ZIP CODE:
BRANCH NAME:Anacapa Division
PLAINTIFF/PETITIONER: MARK SELLARS
DEFENDANT/RESPONDENT: PATRICK LEAHY, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one):
X UNLIMITED CASE LIMITED CASE 20CV04132
(Amount demanded (Amount demanded is $35,000
exceeds $35,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: June 5, 2024 Time: 8:30 a.m. Dept.: 3 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): David A. Napper, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. X This statement is submitted by party (name): Patricia Wollum and Susan Reynolds
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to 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):
3. 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 the date by which
they may be served):
4. Description of case
a. Type of case in
X complaint cross-complaint (Describe, including causes of action):
The Third Amended Complaint alleges causes of action for Elder Abuse;
Financial Elder Abuse; Legal Malpractic; Breach of Fiduciary Duty;
Intentional Infliction of Emotional Distress and Negligence.
Page 1 of 5
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
0161-165
CM-110
PLAINTIFF/PETITIONER: MARK SELLARS CASE NUMBER:
20CV04132
DEFENDANT/RESPONDENT: PATRICK LEAHY, 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
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
This is an elder abuse case brought by Plaintiff Mark Sellars, the adult son of Rosemary Free Leahy ("Ms.
Free"), against Ms. Free's husband, Patrick Leahy, and others. Our clients, Patricia Wollum, and Susan
Reynolds, were homecare workers hired to help Ms. Free. They worked for Defendant Honor Home Care
Services California, Inc. Defendants dispute liability.
(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
X a jury trial a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. X The trial has been set for (date): 1/29/25
b. 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):
7/7/24; 7/9/24; 10/3/24; 11/12/24; 11/18/24; 12/6/24
7. Estimated length of trial
The party or parties estimate that the trial will take (check one)
a. X days (specify number): 3-5
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial X by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. Email address: g. Party represented:
Additional representation is described in Attachment 8.
9. 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 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 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 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 specified in Code of
Civil Procedure section 1141.11.
(3) X 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 in controvery exceeds $50,000
CM-110 [Rev. January 1, 2024] CASE MANAGEMENT STATEMENT Page 2 of 5
CM-110
PLAINTIFF/PETITIONER: MARK SELLARS CASE NUMBER:
20CV04132
DEFENDANT/RESPONDENT: PATRICK LEAHY, et al.
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):
X Mediation session not yet scheduled
(1) Mediation
X Mediation session scheduled for (date):
Agreed to complete mediation by (date):
Mediation completed on (date):
X Settlement conference not yet scheduled
(2) Settlement
X 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 (date):
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):
ADR session not yet scheduled
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. January 1, 2024] CASE MANAGEMENT STATEMENT Page 3 of 5
CM-110
PLAINTIFF/PETITIONER: MARK SELLARS CASE NUMBER:
20CV04132
DEFENDANT/RESPONDENT: PATRICK LEAHY, et al.
11. Insurance
a. X Insurance carrier, if any, for party filing this statement (name): RSUI Group Inc.
b. Reservation of rights: Yes No
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
X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motions in Limine; all other motions reserved
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
Defendants Written discovery per code
Defendants Depositions per code
Defendants Expert discovery per code
c. 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: MARK SELLARS CASE NUMBER:
20CV04132
DEFENDANT/RESPONDENT: PATRICK LEAHY, et al.
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 specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
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): 0
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: May 21, 2024
David A. Napper, Esq.
(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
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA
3 I am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action; my business address is 11900 W. Olympic Boulevard, Suite
4 800, Los Angeles, California 90064.
5
On May 21, 2024, I served the foregoing document described as CASE MANAGEMENT
6 STATEMENT on the parties in this action by placing a true copy(ies) or the original(s) thereof
enclosed in a sealed envelope(s) addressed as follows:
7
See Attached Service List
8
9
BY MAIL
10 I placed said document in an envelope addressed as shown on the service list. I am "readily
familiar" with the firm's practice of collection and processing correspondence for mailing
11 with the United States Postal Service. Under that practice, said correspondence will be
deposited with the United States Postal Service the same day in the ordinary course of
12 business. I sealed said envelope and placed it for collection and mailing on the date stated
below to the addressed stated on the attached service list, following the firm's ordinary
13 business practices, and,
14
ESERVICE. Transmitting a copy of the foregoing document(s) via internet/electronic
15 mail to a Court Approved e-filing/e-service portal ONELEGAL for service on all parties
in this case via their email addresses pursuant to the General Court Order authorizing e-
16 service of documents
17 ELECTRONIC MAIL By transmitting a copy of the foregoing document(s) via
internet/electronic mail from my email address kwindrim@cgdrlaw.com for service on all
18
parties in this case via their email addresses as shown below pursuant to [California Code
19 of Civil Procedure §1010.6(e) or pursuant to agreement between the parties].
20 STATE I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
21
22 Executed on May 21, 2024, at Los Angeles, California.
23
24 KERI WINDRIM
25
26
27
28
0161.165 1
PROOF OF SERVICE
1 SANTA BARBARA SUPERIOR COURT CASE NO. 20CV04132
2
Our File No. 0161.165
3
SERVICE LIST
4
David J. Tappeiner. SBN 243979 Attorney for Plaintiffs, Mark Sellars
5 RIMON LAW, P.C.
701 Anacapa Street, Suite B
6 Santa Barbara, CA 93101
Tel: (805) 892-7177; Fax: (805) 456-0415
7 david.tappeiner@rimonlaw.com
8 Patrick Leahy Defendant
PO Box 6882
9 Santa Maria, CA 93456-6882
patsprod@yahoo.com
10
R. Chris Kroes Attorneys for Defendants Channe Coles and
11 THE LAW OFFICES OF McCARTHY & Law Office of Channe Coles
12 KROES
125 East Victoria Street, Suite A
13 Santa Barbara, CA 93101
chris@mccarthykroes.com
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
0161.165 2
PROOF OF SERVICE
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY NAME: Gregory K. Sabo, #169760/David A. Napper, 271464 FIRM NAME: Chapman Glucksman STREET ADDRESS: 11900 W. Olympic Boulevard, Suite 800 CITY: Los Angeles STATE: CA ZIP CODE: 90064 TELEPHONE NO.: (310) 207-7722 FAX NO.: (310) 207-6550 EMAIL ADDRESS: gsabo@cgdrlaw.com/dnapper@cgdrlaw.com/service@cgdrlaw.com ATTORNEY FOR (name): Defs. PATRICIA WOLLUM and SUSAN REYNOLDS SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA STREET ADDRESS: 1100 Anacapa Street MAILING ADDRESS: Santa Barbara, CA 93101 CITY AND ZIP CODE: BRANCH NAME:Anacapa Division PLAINTIFF/PETITIONER: MARK SELLARS DEFENDANT/RESPONDENT: PATRICK LEAHY, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): X UNLIMITED CASE LIMITED CASE 20CV04132 (Amount demanded (Amount demanded is $35,000 exceeds $35,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: June 5, 2024 Time: 8:30 a.m. Dept.: 3 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): David A. Napper, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. X This statement is submitted by party (name): Patricia Wollum and Susan Reynolds b. This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to 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): 3. 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 the date by which they may be served): 4. Description of case a. Type of case in X complaint cross-complaint (Describe, including causes of action): The Third Amended Complaint alleges causes of action for Elder Abuse; Financial Elder Abuse; Legal Malpractic; Breach of Fiduciary Duty; Intentional Infliction of Emotional Distress and Negligence. Page 1 of 5 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 0161-165 CM-110 PLAINTIFF/PETITIONER: MARK SELLARS CASE NUMBER: 20CV04132 DEFENDANT/RESPONDENT: PATRICK LEAHY, 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 earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) This is an elder abuse case brought by Plaintiff Mark Sellars, the adult son of Rosemary Free Leahy ("Ms. Free"), against Ms. Free's husband, Patrick Leahy, and others. Our clients, Patricia Wollum, and Susan Reynolds, were homecare workers hired to help Ms. Free. They worked for Defendant Honor Home Care Services California, Inc. Defendants dispute liability. (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 X a jury trial a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. X The trial has been set for (date): 1/29/25 b. 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): 7/7/24; 7/9/24; 10/3/24; 11/12/24; 11/18/24; 12/6/24 7. Estimated length of trial The party or parties estimate that the trial will take (check one) a. X days (specify number): 3-5 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial X by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. Email address: g. Party represented: Additional representation is described in Attachment 8. 9. 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 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 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 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 specified in Code of Civil Procedure section 1141.11. (3) X 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 in controvery exceeds $50,000 CM-110 [Rev. January 1, 2024] CASE MANAGEMENT STATEMENT Page 2 of 5 CM-110 PLAINTIFF/PETITIONER: MARK SELLARS CASE NUMBER: 20CV04132 DEFENDANT/RESPONDENT: PATRICK LEAHY, et al. 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): X Mediation session not yet scheduled (1) Mediation X Mediation session scheduled for (date): Agreed to complete mediation by (date): Mediation completed on (date): X Settlement conference not yet scheduled (2) Settlement X 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 (date): 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): ADR session not yet scheduled (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. January 1, 2024] CASE MANAGEMENT STATEMENT Page 3 of 5 CM-110 PLAINTIFF/PETITIONER: MARK SELLARS CASE NUMBER: 20CV04132 DEFENDANT/RESPONDENT: PATRICK LEAHY, et al. 11. Insurance a. X Insurance carrier, if any, for party filing this statement (name): RSUI Group Inc. b. Reservation of rights: Yes No 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 X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Motions in Limine; all other motions reserved 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 Defendants Written discovery per code Defendants Depositions per code Defendants Expert discovery per code c. 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: MARK SELLARS CASE NUMBER: 20CV04132 DEFENDANT/RESPONDENT: PATRICK LEAHY, et al. 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 specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues 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): 0 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: May 21, 2024 David A. Napper, Esq. (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 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA 3 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is 11900 W. Olympic Boulevard, Suite 4 800, Los Angeles, California 90064. 5 On May 21, 2024, I served the foregoing document described as CASE MANAGEMENT 6 STATEMENT on the parties in this action by placing a true copy(ies) or the original(s) thereof enclosed in a sealed envelope(s) addressed as follows: 7 See Attached Service List 8 9 BY MAIL 10 I placed said document in an envelope addressed as shown on the service list. I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing 11 with the United States Postal Service. Under that practice, said correspondence will be deposited with the United States Postal Service the same day in the ordinary course of 12 business. I sealed said envelope and placed it for collection and mailing on the date stated below to the addressed stated on the attached service list, following the firm's ordinary 13 business practices, and, 14 ESERVICE. Transmitting a copy of the foregoing document(s) via internet/electronic 15 mail to a Court Approved e-filing/e-service portal ONELEGAL for service on all parties in this case via their email addresses pursuant to the General Court Order authorizing e- 16 service of documents 17 ELECTRONIC MAIL By transmitting a copy of the foregoing document(s) via internet/electronic mail from my email address kwindrim@cgdrlaw.com for service on all 18 parties in this case via their email addresses as shown below pursuant to [California Code 19 of Civil Procedure §1010.6(e) or pursuant to agreement between the parties]. 20 STATE I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 21 22 Executed on May 21, 2024, at Los Angeles, California. 23 24 KERI WINDRIM 25 26 27 28 0161.165 1 PROOF OF SERVICE 1 SANTA BARBARA SUPERIOR COURT CASE NO. 20CV04132 2 Our File No. 0161.165 3 SERVICE LIST 4 David J. Tappeiner. SBN 243979 Attorney for Plaintiffs, Mark Sellars 5 RIMON LAW, P.C. 701 Anacapa Street, Suite B 6 Santa Barbara, CA 93101 Tel: (805) 892-7177; Fax: (805) 456-0415 7 david.tappeiner@rimonlaw.com 8 Patrick Leahy Defendant PO Box 6882 9 Santa Maria, CA 93456-6882 patsprod@yahoo.com 10 R. Chris Kroes Attorneys for Defendants Channe Coles and 11 THE LAW OFFICES OF McCARTHY & Law Office of Channe Coles 12 KROES 125 East Victoria Street, Suite A 13 Santa Barbara, CA 93101 chris@mccarthykroes.com 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 0161.165 2 PROOF OF SERVICE