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DocuSign Envelope ID: 5338032A—E7E0—4176—948E—EBBBOAED4AAO
GARRY COHEN, State Bar No. 177859
E? E K4 E E}
JASON CHEUNG., State Bar No. 306704 SAN MATEO COUNTY
THE COHEN LAW OFFICE, PC -
1720 S. Amphlett Blvd, Suite 258 DEC 0 5 2017
San Mateo, CA 94402
Telephone: (650) 592~8600
Fax: (650) 592—2019 By .
Attorneys for Petitioner
Rick Podesta
SUPERIOR COURT OF CALEFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
in re the Marie C. Podesta Revocable Trust Case No.2 16-PRO—005 1 g
10
(2007) and the Marital Sub-Tiust (Cretlit
11 gflggg‘argfig agdgghe J01m and Marie FETITIONER RICK PODESTA’S OFFER TO
COMPROMISE PURSUANT TO CALIF.
l2 CODE OF CIVIL PROCEDURE §998 RE:
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Rmk Podesta» RICK PODESTA’S PETITION To
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, . ENFORCE SETTLEMENT AGREEMENT
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Petmonel _
and Beneficm} AND COMPEL DISTRIBUTION OF
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\\ INCOME; REQUEST FOR SURCHARGE
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163E: .555
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FILED NOVEMBER 6, 2017
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TO RESPONDENTS WAYNE PODESTA AND GARY PODESTA, AND TO
19 DAVID UCCELLI, THEIR ATTORNEY OF RECORD:
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21
Petitioner and Beneficiary Rick Podesta offers to have an award taken against
22
Respondents, Wayne Podesta and Garry Podesta, in the above-entitled action for the sum of
23
1/6‘h
Sixty—Five Thousand ($65,000.00) Dollars as the total amount due Rick Podesta for his
24
25 share of the undistributed net income of the ab eve-mentioned trusts pursuant the Stipulated
26 Order filed herein on July 21, 2017; each paity to bear their own costs and attorney’s fees.
27
If you accept this offer, please date and Sign the acceptance below, and file the offer and
28 1
CASE NO. 16~PRO-005] 8
PETl'l‘lONER RICK PODESTA‘S OFFER TO COMPROMISE PURUSANT TO CALIF. CODE OF CIVIL PROCEDURE §998 RE: RICK
PODESTA’S PETITION TO ENFORCE SETTLEMENT AGREEMENT AND COMPEL DISTRIBUTION OF INCOME; REQUEST FOR
SURCl-IARGE
DocuSign Envelope lD: 5338C32A—E7E0-4176-948E-EBBBDAED4AAO
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acceptance in the above-entitled action prior to trial or within 30 days after the offer is made,
Whichever occurs first, or else it will be deemed Withdrawn.
Dated:
November g ,2017 ,M/hw
:{L/ai
GARRY C55HEN, Attorney for Petitioner
[Docusigned by:
____§_§EA5§DEZAES.____'—-
966
RICK PODESTA, Petitioner
NOTICE OF ACCEPTANCE OF OFFER T0 COMPROMISE
10
11
TO PETITIONER, RICK PODESTA, AND TO GARRY COHEN, HIS
12
ATTORNEY OF RECORD:
13
NOTICE IS HEREBY GIVEN that Respondents Wayne and Garry Podesta, accepts the
14
15 offer made by Petitioner to have an award taken against Respondents and for Petitioner, Rick
Pedesta, in the above—entitled action for the sum of Sixty-Five Thousand ($65,000.00)
Dollars,
16
each patty to bear their own costs and attorney’s fees.
MM
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18
19
Dated: // ’ 12 ,2017
WE$ITAttorney for Reépondent
20
21
Dated: ”,2 7 ,2017 gjaL/M, PM
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WAYNE PODESTA, Respondent
23
24 Dated: //- .72 ,2017 (227
GARY PODESTA, Respondent
25
26
28 2
CASE NO. IG-PRO-OOSIS
CODE OF CIVIL PROCEDURE §998 RE: RICK
PETITIONER RICK PODESTA’S OFFER TO COM?ROMISE PURUSANT TO CALIF.
OF INCOME; REQUEST FOR
PODESTA’S PETITION TO ENFORCE SETTLEMENT AGREEMENT AND COMPEL DISTRIBUTION
SURCI’IARGE
DocuSign Envelope 1D: 5338032A-E7E0—4176—948E-EBBBOAED4AAO
‘x/
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PROOF OF SERVICE
I am employed in the County of San Mateo, State of California. I am over the age of
eighteen years and not a party to this action. My business address is:
1720 South Amphlett Boulevard, Suite 258
San Mateo, California 94402
On the date specified below, I caused the following documents to be served:
PETITIONER RICK PODESTA’S OFFER T0 COMI’ROMISE PURUSANT TO CALIF.
CODE OF CIVIL PROCEDURE §998 RE: RICK PODESTA’S PETITION TO
ENFORCE SETTLEMENT AGREEMENT AND COMPEL DISTRIBUTION OF
INCOME; REQUEST FOR SURCHARGE FILED NOVENIBER 6, 2017
10 (X) (BY MAIL) I am employed in the County where the mailing described below occurred, and
am readily familiar with the business practice for collection and processing of correspondence for
ll mailing with the United States Postal Services. I placed a true copy thereof [to which was attached a
copy of this document(s)] in a sealed envelope(s) with postage thereon fully prepaid. The envelope(s]
will be deposited with the United States Postal Service on this day in the ordinary course of business
13
in San Mateo, California, following ordinary business practices.
14 ( ) (BY EMAIL) Based on court order or agreement of the party(ies) to accept service by e—mail.
I caused the document(s) to be sent to the person(s) at the email address(es) listed below. I did not
15 unsuccessful.
receive any message or indication that the transmission was
16
) (BY PERSONAL SERVICE) I caused such envelope(s) to be delivered by hand to the
(
I7 addressee(s) listed below.
18
David P. Uccelli
I9
Law Offices of David P. Uccelli
20 520 South El Camino Real, Suite 830
San Mateo, California 944024721
21
I, Shelby Vance, declare under penalty of perjury that the foregoing is true and correct.
Executed on November 32 , ”2017 at San Mateo, California. , ‘
S
O m/]/\V/
by Vance,
I
CASE NO. I6—PRO-00518
PETITIONER RICK PODESTA’S OFFER TO COMPROMISE PURUSANT TO CALIF. CODE OF CIVIL PROCEDURE §998 RE: RICK
PODESTA’S PETITION TO ENFORCE SETTLEMENT AGREEMENT AND COMPEL DISTRIBUTION OF INCOME; REQUEST FOR
S URC HARGE
PROOF OF SERVICE
I am employed in the County of San Mateo, State of California. I am over the age of 18
years and not a party to the within action. My business address is 520 S. El Camino Real, Suite
830, San Mateo, California 94402-1721.
On December 4, 2017, I caused the following document(s) entitled:
01-w
RESPONDENTS WAYNE and GARY PODESTA’S NOTICE OF
ACCEPTANCE OF OFFER TO COMPROMISE
\]O\
to be served on the party(ies) or its (their) attorney(s) of record in this action listed below
by the following means:
[xx ] BY MAIL. By placing each envelope (with postage affixed thereto) in the US. Mail at
the Law Office of David P. Uccelli, 520 S. El Camino Real, Suite 830, San Mateo,
10 California, addressed as shown below. Iam readily familiar with this firm’ s practice for
collection and processing of correspondence for mailing with the U. S. Postal Service, and
11 in the ordinary course, of business, correspondence would be deposited with the U. S.
Postal Service the same hplaCed for Collection and processing.
was
12
day it
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[ ] BY HAND- DELIVERY By causing a true copy thereof, enclosed in a sealed envelope,
13 to be delivered by hand'to the address(‘es) shown below.
14 [ ] BY OVERNIGHT DELIVERY. By placing with Federal Express for delivery a true
copy thereof, enclosed 1n a sealed envelope, with delivery charges to be billed to the Law
15 Office Of David P. Uccelli, addressed as ShoWn below.
16 [ ] BY FACSIMILE TRANSMISSION. By transmitting a true copy thereof by facsimile
transmission from facsimile number (650) 342-95 60 to the interest party(ies) or their
17 attorney ofreCord to said action at the facsimile number(s) shown below.
18
19 _‘\‘ ‘Ga'rryCohen, Esq ‘ ?' ~
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The CohenL‘aw Office ">‘ 1'
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23 I declare under penalty of perjury under the laws of the State of California that the
foregoing is tr‘ue- and Correct . "
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Executed on December 4", 2017 at san Mateo, California.
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If; . blag/a
Doris A. Burke
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28
Preview
DocuSign Envelope ID: 5338032A—E7E0—4176—948E—EBBBOAED4AAO GARRY COHEN, State Bar No. 177859 E? E K4 E E} JASON CHEUNG., State Bar No. 306704 SAN MATEO COUNTY THE COHEN LAW OFFICE, PC - 1720 S. Amphlett Blvd, Suite 258 DEC 0 5 2017 San Mateo, CA 94402 Telephone: (650) 592~8600 Fax: (650) 592—2019 By . Attorneys for Petitioner Rick Podesta SUPERIOR COURT OF CALEFORNIA IN AND FOR THE COUNTY OF SAN MATEO in re the Marie C. Podesta Revocable Trust Case No.2 16-PRO—005 1 g 10 (2007) and the Marital Sub-Tiust (Cretlit 11 gflggg‘argfig agdgghe J01m and Marie FETITIONER RICK PODESTA’S OFFER TO COMPROMISE PURSUANT TO CALIF. l2 CODE OF CIVIL PROCEDURE §998 RE: , . Rmk Podesta» RICK PODESTA’S PETITION To 13 , . ENFORCE SETTLEMENT AGREEMENT _ . ! 14 Petmonel _ and Beneficm} AND COMPEL DISTRIBUTION OF -22 ___, < —- \\ INCOME; REQUEST FOR SURCHARGE . 163E: .555 15 FILED NOVEMBER 6, 2017 3%; 993 We, ,0 Compromise } ' 883794 16 ' E W C°de°fCW°“"d““W 17 l lllllllllllllllllll llllllll | . I 18 TO RESPONDENTS WAYNE PODESTA AND GARY PODESTA, AND TO 19 DAVID UCCELLI, THEIR ATTORNEY OF RECORD: 2o 21 Petitioner and Beneficiary Rick Podesta offers to have an award taken against 22 Respondents, Wayne Podesta and Garry Podesta, in the above-entitled action for the sum of 23 1/6‘h Sixty—Five Thousand ($65,000.00) Dollars as the total amount due Rick Podesta for his 24 25 share of the undistributed net income of the ab eve-mentioned trusts pursuant the Stipulated 26 Order filed herein on July 21, 2017; each paity to bear their own costs and attorney’s fees. 27 If you accept this offer, please date and Sign the acceptance below, and file the offer and 28 1 CASE NO. 16~PRO-005] 8 PETl'l‘lONER RICK PODESTA‘S OFFER TO COMPROMISE PURUSANT TO CALIF. CODE OF CIVIL PROCEDURE §998 RE: RICK PODESTA’S PETITION TO ENFORCE SETTLEMENT AGREEMENT AND COMPEL DISTRIBUTION OF INCOME; REQUEST FOR SURCl-IARGE DocuSign Envelope lD: 5338C32A—E7E0-4176-948E-EBBBDAED4AAO \»./ I k , /, acceptance in the above-entitled action prior to trial or within 30 days after the offer is made, Whichever occurs first, or else it will be deemed Withdrawn. Dated: November g ,2017 ,M/hw :{L/ai GARRY C55HEN, Attorney for Petitioner [Docusigned by: ____§_§EA5§DEZAES.____'—- 966 RICK PODESTA, Petitioner NOTICE OF ACCEPTANCE OF OFFER T0 COMPROMISE 10 11 TO PETITIONER, RICK PODESTA, AND TO GARRY COHEN, HIS 12 ATTORNEY OF RECORD: 13 NOTICE IS HEREBY GIVEN that Respondents Wayne and Garry Podesta, accepts the 14 15 offer made by Petitioner to have an award taken against Respondents and for Petitioner, Rick Pedesta, in the above—entitled action for the sum of Sixty-Five Thousand ($65,000.00) Dollars, 16 each patty to bear their own costs and attorney’s fees. MM 17 18 19 Dated: // ’ 12 ,2017 WE$ITAttorney for Reépondent 20 21 Dated: ”,2 7 ,2017 gjaL/M, PM W 22 WAYNE PODESTA, Respondent 23 24 Dated: //- .72 ,2017 (227 GARY PODESTA, Respondent 25 26 28 2 CASE NO. IG-PRO-OOSIS CODE OF CIVIL PROCEDURE §998 RE: RICK PETITIONER RICK PODESTA’S OFFER TO COM?ROMISE PURUSANT TO CALIF. OF INCOME; REQUEST FOR PODESTA’S PETITION TO ENFORCE SETTLEMENT AGREEMENT AND COMPEL DISTRIBUTION SURCI’IARGE DocuSign Envelope 1D: 5338032A-E7E0—4176—948E-EBBBOAED4AAO ‘x/ \ . V . PROOF OF SERVICE I am employed in the County of San Mateo, State of California. I am over the age of eighteen years and not a party to this action. My business address is: 1720 South Amphlett Boulevard, Suite 258 San Mateo, California 94402 On the date specified below, I caused the following documents to be served: PETITIONER RICK PODESTA’S OFFER T0 COMI’ROMISE PURUSANT TO CALIF. CODE OF CIVIL PROCEDURE §998 RE: RICK PODESTA’S PETITION TO ENFORCE SETTLEMENT AGREEMENT AND COMPEL DISTRIBUTION OF INCOME; REQUEST FOR SURCHARGE FILED NOVENIBER 6, 2017 10 (X) (BY MAIL) I am employed in the County where the mailing described below occurred, and am readily familiar with the business practice for collection and processing of correspondence for ll mailing with the United States Postal Services. I placed a true copy thereof [to which was attached a copy of this document(s)] in a sealed envelope(s) with postage thereon fully prepaid. The envelope(s] will be deposited with the United States Postal Service on this day in the ordinary course of business 13 in San Mateo, California, following ordinary business practices. 14 ( ) (BY EMAIL) Based on court order or agreement of the party(ies) to accept service by e—mail. I caused the document(s) to be sent to the person(s) at the email address(es) listed below. I did not 15 unsuccessful. receive any message or indication that the transmission was 16 ) (BY PERSONAL SERVICE) I caused such envelope(s) to be delivered by hand to the ( I7 addressee(s) listed below. 18 David P. Uccelli I9 Law Offices of David P. Uccelli 20 520 South El Camino Real, Suite 830 San Mateo, California 944024721 21 I, Shelby Vance, declare under penalty of perjury that the foregoing is true and correct. Executed on November 32 , ”2017 at San Mateo, California. , ‘ S O m/]/\V/ by Vance, I CASE NO. I6—PRO-00518 PETITIONER RICK PODESTA’S OFFER TO COMPROMISE PURUSANT TO CALIF. CODE OF CIVIL PROCEDURE §998 RE: RICK PODESTA’S PETITION TO ENFORCE SETTLEMENT AGREEMENT AND COMPEL DISTRIBUTION OF INCOME; REQUEST FOR S URC HARGE PROOF OF SERVICE I am employed in the County of San Mateo, State of California. I am over the age of 18 years and not a party to the within action. My business address is 520 S. El Camino Real, Suite 830, San Mateo, California 94402-1721. On December 4, 2017, I caused the following document(s) entitled: 01-w RESPONDENTS WAYNE and GARY PODESTA’S NOTICE OF ACCEPTANCE OF OFFER TO COMPROMISE \]O\ to be served on the party(ies) or its (their) attorney(s) of record in this action listed below by the following means: [xx ] BY MAIL. By placing each envelope (with postage affixed thereto) in the US. Mail at the Law Office of David P. Uccelli, 520 S. El Camino Real, Suite 830, San Mateo, 10 California, addressed as shown below. Iam readily familiar with this firm’ s practice for collection and processing of correspondence for mailing with the U. S. Postal Service, and 11 in the ordinary course, of business, correspondence would be deposited with the U. S. Postal Service the same hplaCed for Collection and processing. was 12 day it ' [ ] BY HAND- DELIVERY By causing a true copy thereof, enclosed in a sealed envelope, 13 to be delivered by hand'to the address(‘es) shown below. 14 [ ] BY OVERNIGHT DELIVERY. By placing with Federal Express for delivery a true copy thereof, enclosed 1n a sealed envelope, with delivery charges to be billed to the Law 15 Office Of David P. Uccelli, addressed as ShoWn below. 16 [ ] BY FACSIMILE TRANSMISSION. By transmitting a true copy thereof by facsimile transmission from facsimile number (650) 342-95 60 to the interest party(ies) or their 17 attorney ofreCord to said action at the facsimile number(s) shown below. 18 19 _‘\‘ ‘Ga'rryCohen, Esq ‘ ?' ~ ' ‘ The CohenL‘aw Office ">‘ 1' '.12111‘ 11:..1‘111. 1720S.’ AmphlettBlVd 2o ' - ‘1“. 1’ “A" 3‘ 2' [SanMateo CA94402 Ste. 258 . “ , ’ 21 . '.-l .. ' '- 1 -.:i,‘.'.".‘.‘.i: .I‘..=.. .. '\‘11'_; .,‘\ ' ’ ' :" ‘ . .. .. . . 22 23 I declare under penalty of perjury under the laws of the State of California that the foregoing is tr‘ue- and Correct . " W'.1‘il."z‘(' ' .1...I .:‘- 24 . 1 1 1, Executed on December 4", 2017 at san Mateo, California. 25 26 27 If; . blag/a Doris A. Burke 7W / 28