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ELECTRONICALLY FILED
SANTA BARBARA COUNTY COUNSEL Superior Court of California
RACHEL VAN MULLEM, County Counsel County of Santa Barbara
CALLIE KIM, Deputy County Counsel (SBN 257213) Darrel E. Parker, Executive Officer
105 East Anapamu Street, Suite 201 5/1/2024 4:59 PM
Santa Barbara, California 93101 By: Gabriel Moreno , Deputy
Telephone (805) 568-2950 / Fax (805) 568-2982
E-mail: ckim@countyofsb.org
Attorneys for Respondents
COUNTY OF SANTA BARBARA,
BOARD OF SUPERVISORS OF THE
COUNTY OF SANTA BARBARA,
LISA PLOWMAN, ROB HAZARD,
TRAVIS SEAWARDS, and
DAS WILLIAMS, FIRST DISTRICT SUPERVISOR
Exempt
from filing fees [Gov. Code, § 6103]
10
11 SUPERIOR COURT OF THE STATE OF CALIFORNIA
12 FOR THE COUNTY OF SANTA BARBARA
13 (ANACAPA DIVISION)
14
15 JANA ZIMMER, an individual and Case No.: 24CV00199
TRUSTEE OF THE SOLOMON-
16 ZIMMER LIVING TRUST,
NOTICE OF CONTINUANCE OF
17 Petitioner, HEARING RE MOTION TO STRIKE
vs. AND DEMURRER
18
COUNTY OF SANTA BARBARA,
19 BOARD OF SUPERVISORS OF
THE COUNTY OF SANTA
20 Writ filed: January 16, 2024
BARBARA, LISA PLOWMAN,
21 DIRECTOR OF PLANNING AND Judge: Hon. Colleen K. Sterne
DEVELOPMENT, ROB HAZARD, Dept. SB5 June 17, 2024 m
22 FIRE MARSHAL, TRAVIS Date:
SEAWARDS, DEPUTY DIRECTOR Time: 10:00 a.m.
23 OF PLANNING AND
DEVELOPMENT, DAS
24
WILLIAMS, FIRST DISTRICT
25 SUPERVISOR, DOES 1-25, in their
official and individual capacities,
26
Respondents.
27
28
SANTA BARBARA
COUNTY COUNSEL. -1-
105 E. Anapamu Street, #201
Santa Barbara, CA 93101, NOTICE OF CONTINUANCE OF HEARING RE MOTION TO STRIKE AND DEMURRER
(805) 568-2950
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
Respondents COUNTY OF SANTA BARBARA, BOARD OF SUPERVISORS OF THE
COUNTY OF SANTA BARBARA, LISA PLOWMAN, ROB HAZARD, TRAVIS
SEAWARDS, and DAS WILLIAMS, FIRST DISTRICT SUPERVISOR (collectively
“County”) hereby give notice that the Hon. Colleen Sterne, Judge of the Superior Court,
Department 5, Anacapa Division, continued the hearing on the County’s Demurrer and Motion
to Strike from April 29, 2024 to June 14, 2024 at 10:00 a.m., in Department 5 of the Anacapa
Division of the Santa Barbara County Superior Court, as stated in the attached Minute Order
which is attached hereto as Exhibit “A” and incorporated by this reference.
10
11 Respectfully submitted,
12 DATED: May 1, 2024 RACHEL VAN MULLEM
SANTA BARBARA COUNTY COUNSEL
13
°
14
By: Callie Kim,
15 Deputy County Cffinsel
Attorneys for R ondents
16 COUNTY OF SANTA BARBARA, BOARD OF
SUPERVISORS OF THE COUNTY OF SANTA
17 BARBARA, LISA PLOWMAN, ROB HAZARD,
TRAVIS SEAWARDS, and DAS WILLIAMS, FIRST
18 DISTRICT SUPERVISOR
19
20
21
22
23
24
25
26
27
28
SANTA BARBARA
COUNTY COUNSEL. -2-
105 E. Anapamu Street, #201
Santa Barbara, CA 93101, NOTICE OF CONTINUANCE OF HEARING RE MOTION TO STRIKE AND DEMURRER
(805) 568-2950
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24 EXHIBIT “A”
25 Minute Order dated April 29, 2024
Case No. 24CV00199
26
27
28
SANTA BARBARA
COUNTY COUNSEL. -3-
105 E. Anapamu Street, #201
Santa Barbara, CA 93101, NOTICE OF CONTINUANCE OF HEARING RE MOTION TO STRIKE AND DEMURRER
(805) 568-2950
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA BARBARA
Dated and Entered: 04/29/2024 Time: 10:00 AM
Judicial Officer: Colleen K Sterne
Deputy Clerk: Nichol Reigelman Dept: SB Dept 5
Deputy Sheriff: Raul Vasquez
Court Reporter: Shelley Cockrell Case No: 24CV00199
Jana Zimmer vs County of Santa Barbara et al
Parties Present:
None
NATURE OF PROCEEDINGS: Motion: Strike; and Demurrer
The matter was regularly called before the Court.
There were no appearances by any party.
The Court continued the matter as follows:
June 17, 2024 10:00 AM
Motion: Strike and Demurrer
SB Dept 5 - Sterne, Colleen K
DARREL E. PARKER, EXECUTIVE OFFICER Minutes Prepared by:
Nichol Reigelman , Deputy
‘SC-2411 (Revised July 1, 2013) MINUTE ORDER
PROOF OF SERVICE
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 May 1, 2024, I served a true copy of the within NOTICE OF CONTINUANCE
OF HEARING RE MOTION TO STRIKE AND DEMURRER on the Interested
Parties in this action by:
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
10
deposited with the United States Postal Service, after having been deposited and
11 processed for postage with the County of Santa Barbara Central Mail Room.
12 Andréa Marcus, Esq. Richard C. Solomon
13 133 E. De La Guerra St. #143 2640 Las Encinas Lane
Santa Barbara California 93101 Santa Barbara, CA, 93105
14 Email: andrea@andreamarcuslaw.com Email: resolomon42@gmail.com
15
x by e-mail or electronic transmission. I caused the document(s) to be sent from
16 e-mail address mheuve@countofsb.org to the persons at the e-mail addresses listed in
the below. I did not receive, within a reasonable time after the transmission, any
17 electronic message or other indication that the transmission was unsuccessful.
18
Andréa Marcus, andrea@andreamarcuslaw.com, Attorney for Plaintiff
19 Richard C. Solomon, rcsolomon42@gmail.com, Attorney for Plaintiff
20
(_] by depositing it in the United States Mail in a sealed envelope with postage
21 thereon fully prepaid to the following to the person(s) indicated below.
22 IX] (State) I declare, under penalty of perjury, that the above is true and correct.
23
Executed on May 1, 2024, at Santa Barbara, California.
24
Warleen
van dan Nuwel
25
Marleen van den Heuvel
26
COUNTY COUNSEL
County of Santa Barbara 27
105 East Anapamu Street
Sant bara, CA 93101
(805) 568-2950 28
PROOF OF SERVICE
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ELECTRONICALLY FILED SANTA BARBARA COUNTY COUNSEL Superior Court of California RACHEL VAN MULLEM, County Counsel County of Santa Barbara CALLIE KIM, Deputy County Counsel (SBN 257213) Darrel E. Parker, Executive Officer 105 East Anapamu Street, Suite 201 5/1/2024 4:59 PM Santa Barbara, California 93101 By: Gabriel Moreno , Deputy Telephone (805) 568-2950 / Fax (805) 568-2982 E-mail: ckim@countyofsb.org Attorneys for Respondents COUNTY OF SANTA BARBARA, BOARD OF SUPERVISORS OF THE COUNTY OF SANTA BARBARA, LISA PLOWMAN, ROB HAZARD, TRAVIS SEAWARDS, and DAS WILLIAMS, FIRST DISTRICT SUPERVISOR Exempt from filing fees [Gov. Code, § 6103] 10 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 FOR THE COUNTY OF SANTA BARBARA 13 (ANACAPA DIVISION) 14 15 JANA ZIMMER, an individual and Case No.: 24CV00199 TRUSTEE OF THE SOLOMON- 16 ZIMMER LIVING TRUST, NOTICE OF CONTINUANCE OF 17 Petitioner, HEARING RE MOTION TO STRIKE vs. AND DEMURRER 18 COUNTY OF SANTA BARBARA, 19 BOARD OF SUPERVISORS OF THE COUNTY OF SANTA 20 Writ filed: January 16, 2024 BARBARA, LISA PLOWMAN, 21 DIRECTOR OF PLANNING AND Judge: Hon. Colleen K. Sterne DEVELOPMENT, ROB HAZARD, Dept. SB5 June 17, 2024 m 22 FIRE MARSHAL, TRAVIS Date: SEAWARDS, DEPUTY DIRECTOR Time: 10:00 a.m. 23 OF PLANNING AND DEVELOPMENT, DAS 24 WILLIAMS, FIRST DISTRICT 25 SUPERVISOR, DOES 1-25, in their official and individual capacities, 26 Respondents. 27 28 SANTA BARBARA COUNTY COUNSEL. -1- 105 E. Anapamu Street, #201 Santa Barbara, CA 93101, NOTICE OF CONTINUANCE OF HEARING RE MOTION TO STRIKE AND DEMURRER (805) 568-2950 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: Respondents COUNTY OF SANTA BARBARA, BOARD OF SUPERVISORS OF THE COUNTY OF SANTA BARBARA, LISA PLOWMAN, ROB HAZARD, TRAVIS SEAWARDS, and DAS WILLIAMS, FIRST DISTRICT SUPERVISOR (collectively “County”) hereby give notice that the Hon. Colleen Sterne, Judge of the Superior Court, Department 5, Anacapa Division, continued the hearing on the County’s Demurrer and Motion to Strike from April 29, 2024 to June 14, 2024 at 10:00 a.m., in Department 5 of the Anacapa Division of the Santa Barbara County Superior Court, as stated in the attached Minute Order which is attached hereto as Exhibit “A” and incorporated by this reference. 10 11 Respectfully submitted, 12 DATED: May 1, 2024 RACHEL VAN MULLEM SANTA BARBARA COUNTY COUNSEL 13 ° 14 By: Callie Kim, 15 Deputy County Cffinsel Attorneys for R ondents 16 COUNTY OF SANTA BARBARA, BOARD OF SUPERVISORS OF THE COUNTY OF SANTA 17 BARBARA, LISA PLOWMAN, ROB HAZARD, TRAVIS SEAWARDS, and DAS WILLIAMS, FIRST 18 DISTRICT SUPERVISOR 19 20 21 22 23 24 25 26 27 28 SANTA BARBARA COUNTY COUNSEL. -2- 105 E. Anapamu Street, #201 Santa Barbara, CA 93101, NOTICE OF CONTINUANCE OF HEARING RE MOTION TO STRIKE AND DEMURRER (805) 568-2950 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 EXHIBIT “A” 25 Minute Order dated April 29, 2024 Case No. 24CV00199 26 27 28 SANTA BARBARA COUNTY COUNSEL. -3- 105 E. Anapamu Street, #201 Santa Barbara, CA 93101, NOTICE OF CONTINUANCE OF HEARING RE MOTION TO STRIKE AND DEMURRER (805) 568-2950 SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA BARBARA Dated and Entered: 04/29/2024 Time: 10:00 AM Judicial Officer: Colleen K Sterne Deputy Clerk: Nichol Reigelman Dept: SB Dept 5 Deputy Sheriff: Raul Vasquez Court Reporter: Shelley Cockrell Case No: 24CV00199 Jana Zimmer vs County of Santa Barbara et al Parties Present: None NATURE OF PROCEEDINGS: Motion: Strike; and Demurrer The matter was regularly called before the Court. There were no appearances by any party. The Court continued the matter as follows: June 17, 2024 10:00 AM Motion: Strike and Demurrer SB Dept 5 - Sterne, Colleen K DARREL E. PARKER, EXECUTIVE OFFICER Minutes Prepared by: Nichol Reigelman , Deputy ‘SC-2411 (Revised July 1, 2013) MINUTE ORDER PROOF OF SERVICE 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 May 1, 2024, I served a true copy of the within NOTICE OF CONTINUANCE OF HEARING RE MOTION TO STRIKE AND DEMURRER on the Interested Parties in this action by: 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 10 deposited with the United States Postal Service, after having been deposited and 11 processed for postage with the County of Santa Barbara Central Mail Room. 12 Andréa Marcus, Esq. Richard C. Solomon 13 133 E. De La Guerra St. #143 2640 Las Encinas Lane Santa Barbara California 93101 Santa Barbara, CA, 93105 14 Email: andrea@andreamarcuslaw.com Email: resolomon42@gmail.com 15 x by e-mail or electronic transmission. I caused the document(s) to be sent from 16 e-mail address mheuve@countofsb.org to the persons at the e-mail addresses listed in the below. I did not receive, within a reasonable time after the transmission, any 17 electronic message or other indication that the transmission was unsuccessful. 18 Andréa Marcus, andrea@andreamarcuslaw.com, Attorney for Plaintiff 19 Richard C. Solomon, rcsolomon42@gmail.com, Attorney for Plaintiff 20 (_] by depositing it in the United States Mail in a sealed envelope with postage 21 thereon fully prepaid to the following to the person(s) indicated below. 22 IX] (State) I declare, under penalty of perjury, that the above is true and correct. 23 Executed on May 1, 2024, at Santa Barbara, California. 24 Warleen van dan Nuwel 25 Marleen van den Heuvel 26 COUNTY COUNSEL County of Santa Barbara 27 105 East Anapamu Street Sant bara, CA 93101 (805) 568-2950 28 PROOF OF SERVICE