Preview
Mark T. Coffin, State Bar No. 168571 ELECTRONICALLY FILED
ScottA. Jaske, State Bar No. PL-461842 Superior Court of California
MARK T. COFFIN, P.C. County of Santa Barbara
21 E. Carrillo Street, Suite 240 Darrel E. Parker, Executive Officer
Santa Barbara, California 93101 6/16/2021 1:28 PM
Telephone: (805) 248-7118 By: Sasha Nasir, Deputy
Facsimile: (866) 567-4028
Email: mtc@markcoffinlaw.com
Email: scott@ markcoffinlaw.com
Attomeys for Plaintiff DAVID G. BERTRAND and DOROTHY CHURCHILL-JOHNSON
SUPERIOR COURT OF CALIFORNIA
FOR THE COUNTY OF SANTA BARBARA
10
11 DAVID G. BERTRAND, an Individual, Case No. 19CV02429
DOROTHY CHURCHILL-JOHNSON, an
12 Individual, NOTICE OF ENTRY OF ORDER ON
13 PLAINTIFFS’ ORDER FOR E-
Plaintiff,
SERVICE IN LIEU OF PERSONAL
14 vs. SERVICE OF STATEMENT OF
DAMAGES AND PRESERVATION OF
15 JESSICA BERRY, an Individual, and DOES 1 PUNITIVE DAMAGES ON
through 100, Inclusive, DEFENDANT JESSICA BERRY
16
Defendants.
17
Assigned for all purposes to the Honorable
18 Colleen K. Sterne
19 Dept: 5
Complaint Date: May 7, 2019
20 Trial Date: TBA
21
22
23
24
25
26
27
28 1
NOTICE OF ENTRY OF ORDER ON PLAINTIFFS’ ORDER FOR E-SERVICE IN LIEU OF PERSONAL SERVICE
OF STATEMENT OF DAMAGES AND PRESERVATION OF PUNITIVE DAMAGES ON DEFENDANT JESSICA
BERRY
TO DEFENDANT JESSICA BERRY:
Please take notice that on Tuesday, June 15, 2021, the Court in the above-entitled matter
entered an Order. Attached hereto as Exhibit “A” is a true and correct copy of the Court’s Order.
DATED: June 16, 2021 MARK T. COFFIN, P.C.
By:
Mark T. Coffin, Esq.
Scott A. Jaske, PL Esq.
Attorneys for Plaintiffs DAVID G. BERTRAND
and DOROTHY CHURCHILL-JOHNSON
10
ll
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28 2
NOTICE OF ENTRY OF ORDER ON PLAINTIFFS’ ORDER FOR E-SERVICE IN LIEU OF PERSONAL SERVICE,
OF STATEMENT OF DAMAGES AND PRESERVATION OF PUNITIVE DAMAGES ON DEFENDANT JESSICA:
BERRY
10
11
12
EXHIBIT A
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
EXHIBITA
Pursuant to CRC 2.259 this document has been electronically filed by the
Superior Court of California, County of Santa Barbara, on 5/28/2021
Mark T. Coffin, State Bar No. 168571
Scott A. Jaske, State Bar No. PL-461842 FILED
MARK T. COFFIN, P.C. SUPERIOR COURT of CALIFORNIA
COUNTY of SANTA BARBARA
21 E. Carrillo Street, Suite 240
Santa Barbara, California 93101 06/15/2021
Telephone: (805) 248-7118 Darrel E. Parker, Executive Officer
BY_ Sisto, Sarah
Facsimile: (866) 567-4028
Deputy Clerk
Email: mtc@markcoffinlaw.com
Email: scott@markcoffinlaw.com
Attorneys for Plaintiff DAVID G. BERTRAND and DOROTHY CHURCHILL-JOHNSON
SUPERIOR COURT OF CALIFORNIA
FOR THE COUNTY OF SANTA BARBARA
10
11 DAVID G. BERTRAND, an Individual, Case No. 19CV02429
DOROTHY CHURCHILL-JOHNSON, an
12 Individual, PLAINTIFFS’ |RROROSEBFORDER
13 FOR E-SERVICE IN LIEU OF
Plaintiff,
PERSONAL SERVICE OF
14 vs. STATEMENT OF DAMAGES AND
PRESERVATION OF PUNITIVE
15 JESSICA BERRY, an Individual, and DOES 1 DAMAGES ON DEFENDANT JESSICA
through 100, Inclusive, BERRY, PURSUANT TO APRIL 19,
16
2021 HEARING
Defendants.
17
[Filed and Served Concurrently with
18 - Declaration of Mark T. Coffin]
19 Assigned for all purposes to the Honorable
Colleen K. Sterne
20
Dept: 5
21 Complaint Date: May 7, 2019
Trial Date: TBA
22
23
24
25
26
2,
28 1
PLAINTIFFS’ [PROPOSED] ORDER FOR E-SERVICE IN LIEU OF PERSONAL SERVICE OF STATEMENT OF
DAMAGES AND PRESERVATION OF PUNITIVE DAMAGES ON DEFENDANT JESSICA BERRY, PURSUANT
TO APRIL 19, 2021 HEARING
On April 19, 2021, in Department 5 of the above-captioned Court, the Trial Setting
Conference for Santa Barbara Superior Court Case Numbers: 20CV03259 and 20CV03231 was
held. Based on the moving and opposing papers, oral argument at the hearing, and for GOOD
CAUSE SHOWN, it is Ordered that:
1 Plaintiffs DAVID G. BERTRAND and DOROTHY CHURCHILL-JOHNSON are allowed
to electronically serve Defendant JESSICA BERRY in lieu of personal service, with
Plaintiffs’ Statement of Damages and Preservation of Punitive Damages, for purposes of
compliance with Code of Civil Procedure section 425.11 et seq., in Santa Barbara Superior
Court Case Number 19CV02429.
10 Defendant Jessica Berry will establish a new P.O. Box address to serve as her address of
11 record for the Santa Barbara Superior Court.
12
13 IT IS SO ORDERED.
SF
14
06/15/2021
15 DATED:
16 Honorable Colleen K. Sterne
17
18
19
20
21
22
23
24
25
26
27
28 2
PLAINTIFFS’ [PROPOSED] ORDER FOR E-SERVICE IN LIEU OF PERSONAL SERVICE OF STATEMENT OF
DAMAGES AND PRESERVATION OF PUNITIVE DAMAGES ON DEFENDANT JESSICA BERRY, PURSUANT
TO APRIL 19, 2021 HEARING
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA
I am employed in the County of Santa Barbara, State of California. I am over the age of 18
years and not a party to this action. My business address is 21 E. Carrillo Street, Suite 240, Santa
Barbara, California 93101. On June 16, 2021, I served the foregoing documents described as
NOTICE OF ENTRY OF ORDER ON PLAINTIFFS’ ORDER FOR E-SERVICE IN LIEU
OF PERSONAL SERVICE OF STATEMENT OF DAMAGES AND PRESERVATION OF
PUNITIVE DAMAGES ON DEFENDANT JESSICA BERRY, on the interested parties in this
action:
Address Party
Jessica Berry
JESSICA BERRY, in pro per.
10 234 S. Figueroa St., #1640
Los Angeles, CA 90012
Il T: 805-453-0106
E: Berryjessica037/@gmail.com
12
13
14
15
16
* BY U.S. MAIL: This document was served by United States mail through the US Postal
Service. I enclosed the document in a sealed envelope or package addressed to the person(s)
at the address(es) above and placed the envelope(s) for collection and mailing, following our
ordinary business practices. [ am readily familiar with this firm’s practice of collecting and
17 processing correspondence for mailing. On the same day that correspondence is placed for
collection and mailing, it is deposited in the ordinary course of business with the United
18 States Postal Service at Santa Barbara, California, in a sealed envelope with postage fully
paid.
19
VIA EMAIL: I served the documents above on all parties via electronic mail, to the
20 addresses as listed on the attached service list, following my employer’s business practice for
collection and processing of correspondence. Such electronic transmission was reported as
21 complete and without error on this date.
22 (State) I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
23
24 Executed on June 16, 2021, at Santa Barbara, California.
cat
25 v
26
Scott A. Jaske
27
28 3
NOTICE OF ENTRY OF ORDER ON PLAINTIFFS’ ORDER FOR E-SERVICE IN LIEU OF PERSONAL SERVICE,
OF STATEMENT OF DAMAGES AND PRESERVATION OF PUNITIVE DAMAGES ON DEFENDANT JESSICA
BERRY
Preview
Mark T. Coffin, State Bar No. 168571 ELECTRONICALLY FILED ScottA. Jaske, State Bar No. PL-461842 Superior Court of California MARK T. COFFIN, P.C. County of Santa Barbara 21 E. Carrillo Street, Suite 240 Darrel E. Parker, Executive Officer Santa Barbara, California 93101 6/16/2021 1:28 PM Telephone: (805) 248-7118 By: Sasha Nasir, Deputy Facsimile: (866) 567-4028 Email: mtc@markcoffinlaw.com Email: scott@ markcoffinlaw.com Attomeys for Plaintiff DAVID G. BERTRAND and DOROTHY CHURCHILL-JOHNSON SUPERIOR COURT OF CALIFORNIA FOR THE COUNTY OF SANTA BARBARA 10 11 DAVID G. BERTRAND, an Individual, Case No. 19CV02429 DOROTHY CHURCHILL-JOHNSON, an 12 Individual, NOTICE OF ENTRY OF ORDER ON 13 PLAINTIFFS’ ORDER FOR E- Plaintiff, SERVICE IN LIEU OF PERSONAL 14 vs. SERVICE OF STATEMENT OF DAMAGES AND PRESERVATION OF 15 JESSICA BERRY, an Individual, and DOES 1 PUNITIVE DAMAGES ON through 100, Inclusive, DEFENDANT JESSICA BERRY 16 Defendants. 17 Assigned for all purposes to the Honorable 18 Colleen K. Sterne 19 Dept: 5 Complaint Date: May 7, 2019 20 Trial Date: TBA 21 22 23 24 25 26 27 28 1 NOTICE OF ENTRY OF ORDER ON PLAINTIFFS’ ORDER FOR E-SERVICE IN LIEU OF PERSONAL SERVICE OF STATEMENT OF DAMAGES AND PRESERVATION OF PUNITIVE DAMAGES ON DEFENDANT JESSICA BERRY TO DEFENDANT JESSICA BERRY: Please take notice that on Tuesday, June 15, 2021, the Court in the above-entitled matter entered an Order. Attached hereto as Exhibit “A” is a true and correct copy of the Court’s Order. DATED: June 16, 2021 MARK T. COFFIN, P.C. By: Mark T. Coffin, Esq. Scott A. Jaske, PL Esq. Attorneys for Plaintiffs DAVID G. BERTRAND and DOROTHY CHURCHILL-JOHNSON 10 ll 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 NOTICE OF ENTRY OF ORDER ON PLAINTIFFS’ ORDER FOR E-SERVICE IN LIEU OF PERSONAL SERVICE, OF STATEMENT OF DAMAGES AND PRESERVATION OF PUNITIVE DAMAGES ON DEFENDANT JESSICA: BERRY 10 11 12 EXHIBIT A 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXHIBITA Pursuant to CRC 2.259 this document has been electronically filed by the Superior Court of California, County of Santa Barbara, on 5/28/2021 Mark T. Coffin, State Bar No. 168571 Scott A. Jaske, State Bar No. PL-461842 FILED MARK T. COFFIN, P.C. SUPERIOR COURT of CALIFORNIA COUNTY of SANTA BARBARA 21 E. Carrillo Street, Suite 240 Santa Barbara, California 93101 06/15/2021 Telephone: (805) 248-7118 Darrel E. Parker, Executive Officer BY_ Sisto, Sarah Facsimile: (866) 567-4028 Deputy Clerk Email: mtc@markcoffinlaw.com Email: scott@markcoffinlaw.com Attorneys for Plaintiff DAVID G. BERTRAND and DOROTHY CHURCHILL-JOHNSON SUPERIOR COURT OF CALIFORNIA FOR THE COUNTY OF SANTA BARBARA 10 11 DAVID G. BERTRAND, an Individual, Case No. 19CV02429 DOROTHY CHURCHILL-JOHNSON, an 12 Individual, PLAINTIFFS’ |RROROSEBFORDER 13 FOR E-SERVICE IN LIEU OF Plaintiff, PERSONAL SERVICE OF 14 vs. STATEMENT OF DAMAGES AND PRESERVATION OF PUNITIVE 15 JESSICA BERRY, an Individual, and DOES 1 DAMAGES ON DEFENDANT JESSICA through 100, Inclusive, BERRY, PURSUANT TO APRIL 19, 16 2021 HEARING Defendants. 17 [Filed and Served Concurrently with 18 - Declaration of Mark T. Coffin] 19 Assigned for all purposes to the Honorable Colleen K. Sterne 20 Dept: 5 21 Complaint Date: May 7, 2019 Trial Date: TBA 22 23 24 25 26 2, 28 1 PLAINTIFFS’ [PROPOSED] ORDER FOR E-SERVICE IN LIEU OF PERSONAL SERVICE OF STATEMENT OF DAMAGES AND PRESERVATION OF PUNITIVE DAMAGES ON DEFENDANT JESSICA BERRY, PURSUANT TO APRIL 19, 2021 HEARING On April 19, 2021, in Department 5 of the above-captioned Court, the Trial Setting Conference for Santa Barbara Superior Court Case Numbers: 20CV03259 and 20CV03231 was held. Based on the moving and opposing papers, oral argument at the hearing, and for GOOD CAUSE SHOWN, it is Ordered that: 1 Plaintiffs DAVID G. BERTRAND and DOROTHY CHURCHILL-JOHNSON are allowed to electronically serve Defendant JESSICA BERRY in lieu of personal service, with Plaintiffs’ Statement of Damages and Preservation of Punitive Damages, for purposes of compliance with Code of Civil Procedure section 425.11 et seq., in Santa Barbara Superior Court Case Number 19CV02429. 10 Defendant Jessica Berry will establish a new P.O. Box address to serve as her address of 11 record for the Santa Barbara Superior Court. 12 13 IT IS SO ORDERED. SF 14 06/15/2021 15 DATED: 16 Honorable Colleen K. Sterne 17 18 19 20 21 22 23 24 25 26 27 28 2 PLAINTIFFS’ [PROPOSED] ORDER FOR E-SERVICE IN LIEU OF PERSONAL SERVICE OF STATEMENT OF DAMAGES AND PRESERVATION OF PUNITIVE DAMAGES ON DEFENDANT JESSICA BERRY, PURSUANT TO APRIL 19, 2021 HEARING PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA I am employed in the County of Santa Barbara, State of California. I am over the age of 18 years and not a party to this action. My business address is 21 E. Carrillo Street, Suite 240, Santa Barbara, California 93101. On June 16, 2021, I served the foregoing documents described as NOTICE OF ENTRY OF ORDER ON PLAINTIFFS’ ORDER FOR E-SERVICE IN LIEU OF PERSONAL SERVICE OF STATEMENT OF DAMAGES AND PRESERVATION OF PUNITIVE DAMAGES ON DEFENDANT JESSICA BERRY, on the interested parties in this action: Address Party Jessica Berry JESSICA BERRY, in pro per. 10 234 S. Figueroa St., #1640 Los Angeles, CA 90012 Il T: 805-453-0106 E: Berryjessica037/@gmail.com 12 13 14 15 16 * BY U.S. MAIL: This document was served by United States mail through the US Postal Service. I enclosed the document in a sealed envelope or package addressed to the person(s) at the address(es) above and placed the envelope(s) for collection and mailing, following our ordinary business practices. [ am readily familiar with this firm’s practice of collecting and 17 processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United 18 States Postal Service at Santa Barbara, California, in a sealed envelope with postage fully paid. 19 VIA EMAIL: I served the documents above on all parties via electronic mail, to the 20 addresses as listed on the attached service list, following my employer’s business practice for collection and processing of correspondence. Such electronic transmission was reported as 21 complete and without error on this date. 22 (State) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 23 24 Executed on June 16, 2021, at Santa Barbara, California. cat 25 v 26 Scott A. Jaske 27 28 3 NOTICE OF ENTRY OF ORDER ON PLAINTIFFS’ ORDER FOR E-SERVICE IN LIEU OF PERSONAL SERVICE, OF STATEMENT OF DAMAGES AND PRESERVATION OF PUNITIVE DAMAGES ON DEFENDANT JESSICA BERRY