Preview
- Do NOT FILE WITH THE COURT- ("V-050
-UNLESS YOU ARE APPLYING FOR A DEFAULT JUDGMENT UNDER CODE OF CIVIL PROCEDURE § 585 -
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name and Addra TELEPHONE NO.‘ FOR COURT USE ONLY
Mark Coffin (SBN 168571) Scott Jaske (PL-461842) 805-248-71 18
MARK T. COFFIN, P. C.
21 E. Carrillo Street, Suite 240
Santa Barbara, CA 93101 ELECTRONICALLY FILED
Plaintiffs,
ATTORNEY FOR (name): DAVID BERTRAND, ct al Superior Court of California
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA County of Santa Barbara
STREET ADDRESS:1100 Anacapa Street Darrel E. Parker, Executive Officer
MAILING ADDRESS.
1100 Anacapa Street
Santa Barbara, CA 93101
cnv AND zip cons:
9/16/2021 9:44 AM
BRANCH NAME:ANACAPA Division By: Terri Chavez, Deputy
PLAINTIFF: DAVID G. BERTRAND, et a1.
DEFENDANT: JESSICA BERRY
CASE NUMBER:
STATEMENT OF DAMAGES
(Personal Injury or Wrongful Death) 19CV02429
To (name of one defendant only): JESSICA BERRY
Plaintiff (name of one prainmr only): DOROTHY CHURCHILL-JOHNSON
seeks damages in the above-entitled action. as follows:
AMOUNT
1.General damages
a.[:1 Pain. suffering, and inconvenience $ 100,000.00
b. Emotional distress $ 100,000.00
c.E] Loss of consortium $ 0.00
d.[:1 Loss of sociey and companionship (wrongful death actions only) $ 0.00
e.:1 Other (specify) 3 0.00
f.[:1 Other (specify) $ 0.00
9.El Continued on Attachment 1.9.
2.Special damages
a.El Medical expenses (to date) 3 0.00
b. [:1 Future medical expenses (present value) $ 000
c. [:1 Loss of earnings (to date) $ 0.00
d. I:] Loss of future earning capacity (present value) $
0-00
e. Property damage $ 0.00
f.1:] Funeral expenses (wrongful death actions only) $ 0.00
9. El Future contributions (present value) (wrongful death actions only) $ 0.00
h. I: Value of personal service, advice, or training (wrongful death actions only) $ 0.00
i. Other (specify) Defamation $ 150,000.00
i- III Other (specify) Unjust Enrichment and Quantum Meruit $ 50,000-00
k. Continued on Attachment 2.k.
3. 250,000.00
Punitive damages: Plaintiff reserves the right to seek punitive damages in the amount of (specify). $
when pursuing a judgment in the suit filed against you.
Date: April 19, 2021
Mark T. Coffin, Attorney for Plaintiffs
(TYPE on pnmr NAME) ( GNATU NTIFF on ATTORNEY FOR PLAINTIFF)
(Proof of service on reverse) on
Plan 1
STATEMENT OF DAMAGES C°d° 0' 0"“ 55 425~“- 425-115
Form Ad
ted for Mandatory'Use
Judicia Council of California wwwlcourfinfoeagov
ClV-OSO (Rev. January 1, 20071 (Personal Injury or Wrongful Death)
ClV-050
_ PLAINTIFF: DAVID G. BERTRAND, ct ai.
CASE NUMBER:
19CV02429
DEFENDANT: JESSICA BERRY
PROOF OF SERVICE
have the person who served
(After having the other party served as described below, with any of the documents identified in item
1,
the documents complete this Proof of Service. Plaintiff cannot serve these papers.)
1. served the
E E
I
a. Statement of Damages Other (specify):
b. on (name):
E
c. by serving defendant E other (name and title or relationship to person served):
d. E by delivery E at home Eat business
(1) date:
(2) time:
(3) address:
e. E by mailing
(1) date:
(2) place:
2. Manner of service (check proper box):
a. E Personal service. By personally delivering copies. (CCP § 415.10)
b. E Substituted service on corporation, unincorporated association (Including partnership), or public entity. By
leaving, during usual office hours. copies in the office of the person served with the person who apparently was in
charge and thereafter mailing (by first-class mail, postage prepaid) copies to the person served at the place where the
copies were left. (CCP § 415.20(a))
c. E Substituted service on natural person, minor, conservatee, or candidate. By leaving copies at the dwelling house,
usual place of abode, or usual place of business of the person served in the presence of a competent member of the
household or a person apparently in charge of the office or place of business, at least 18 years of age, who was
informed of the general nature of the papers. and thereafter mailing (by first-class mail. postage prepaid) copies to the
person served at the place where the mpies were left. (CCP § 415.20(b)) (Attach separate declaration or affidavit
stating acts relied on to establish reasonable diligence in first attempting personal service.)
d. E Mail and acknowledgment service. By mailing (by first— class mail or airmail, postage prepaid) copies to the person
sewed. together with two copies of the form of notice and acknowledgment and a return envelope, postage prepaid,
addressed to the sender. (CCP § 415.30) (Attach completed acknowledgment of receipt.)
e. E Certified or registered mail service. By mailing to an address outside California (by first-class mail, postage prepaid.
requiring a return receipt) copies to the person served. (CCP § 415.40) (Attach signed return receipt or other
evidence of actual delivery to the person served.)
f. E Other (specify code section):
additional page is attached.
3. At the time of service l was at least 18 years of age and not a party to this action.
4. Fee for service: $
5. Person serving:
a. California sheriff, marshal, or constable f. Name, address and telephone number and. if applicable.
b. Registered Californiaprocess server county of registration and number.
c. Employee or independent contractorof aregistered
California process server
d. D Not a registered California process server
e. Exempt from registration under Bus. 8. Prof. Code
§ 22350(b)
ldeclare under penalty of perjury under the laws of the (For Callfomla sheriff, marshal, or constable use only)
State of California that the foregoing is true and correct. lcertify that the foregoing is true and corred.
Date: Date:
(SIGNATURE) (SlGNATURE)
°'V°S°"‘"'J'"“‘“’"’°°" or SERVICE
PROOF ammwmusasiméil:
(Statement of Damages)
CASE NUMBER:
SHORT TITLE: BERTRAND v. BERRY
— STATEMENT OF DAMAGES - ATTACHMENT 2 19CV02429
STATEMENT OF DAMAGES - SPECIAL DAMAGES - CONTINUED
K. Rental Premises $50,000.00
L. Attorney Fees per Welfare and Institutions Code section l_5610.63(a) $90,000.00
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item numbers, not line
26 (Required for verified pleading) The items on this page stated on information and belief are (specify
numbers):
27
This page may be used with any Judicial Council form or any other paper filed with the court. Pug. 3 0f3
Form Approved by mo ADDITIONAL PAGE
CRC 201. 501
Mid" °°“"°" °' “mm" Attach to Judlclal Council Form or Other Court Paper
M9020 [New January
1, 1987]
PROOF OF SERVICE
1234567009
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 sewed the foregoing documents described as
PLAINTIFF DOROTHY CHURCHILL-JOHNSON’S STATEMENT OF DAMAGES, on the
interested parties in this action:
Address Party
Jessica Berry
234 S. Figueroa St., #1640
JESSICA BERRY, in pro per.
Los Angeles, CA 90012
10 T: 805-453-0106
E: Bemjessica03 7@gmail.com
11
12
l3
14 BY U.S. MAIL: This document was served by United States mail through the US Postal
M Service. I enclosed the document in a sealed envelope or package addressed to the person(s)
15 at the address(es) above and placed the envelope(s) for collection and mailing, following our
ordinary business practices. I am readily familiar with this firm’s practice of collecting and
l6 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
l7 States Postal Service at Santa Barbara, California, in a sealed envelope with postage fully
paid.
18
VIA EMAIL: I served the documents above on all parties via electronic mail, to the
19
w 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
20 complete and without error on this date.
21 (State) I declare under penalty of perjury under the laws of the State of Califomia that the
foregoing is true and correct.
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23 Executed on June 16, 2021 , at Santa Barbara, California.
24
25 Quit
Sc‘o'ttA. Jaske
5L1.
" ’
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PLAINTIFF DOROTHY CHURCHILL-JOHNSON’S STATEMENT 0F DAMAGES
Preview
- Do NOT FILE WITH THE COURT- ("V-050 -UNLESS YOU ARE APPLYING FOR A DEFAULT JUDGMENT UNDER CODE OF CIVIL PROCEDURE § 585 - ATTORNEY OR PARTY WITHOUT ATTORNEY (Name and Addra TELEPHONE NO.‘ FOR COURT USE ONLY Mark Coffin (SBN 168571) Scott Jaske (PL-461842) 805-248-71 18 MARK T. COFFIN, P. C. 21 E. Carrillo Street, Suite 240 Santa Barbara, CA 93101 ELECTRONICALLY FILED Plaintiffs, ATTORNEY FOR (name): DAVID BERTRAND, ct al Superior Court of California SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BARBARA County of Santa Barbara STREET ADDRESS:1100 Anacapa Street Darrel E. Parker, Executive Officer MAILING ADDRESS. 1100 Anacapa Street Santa Barbara, CA 93101 cnv AND zip cons: 9/16/2021 9:44 AM BRANCH NAME:ANACAPA Division By: Terri Chavez, Deputy PLAINTIFF: DAVID G. BERTRAND, et a1. DEFENDANT: JESSICA BERRY CASE NUMBER: STATEMENT OF DAMAGES (Personal Injury or Wrongful Death) 19CV02429 To (name of one defendant only): JESSICA BERRY Plaintiff (name of one prainmr only): DOROTHY CHURCHILL-JOHNSON seeks damages in the above-entitled action. as follows: AMOUNT 1.General damages a.[:1 Pain. suffering, and inconvenience $ 100,000.00 b. Emotional distress $ 100,000.00 c.E] Loss of consortium $ 0.00 d.[:1 Loss of sociey and companionship (wrongful death actions only) $ 0.00 e.:1 Other (specify) 3 0.00 f.[:1 Other (specify) $ 0.00 9.El Continued on Attachment 1.9. 2.Special damages a.El Medical expenses (to date) 3 0.00 b. [:1 Future medical expenses (present value) $ 000 c. [:1 Loss of earnings (to date) $ 0.00 d. I:] Loss of future earning capacity (present value) $ 0-00 e. Property damage $ 0.00 f.1:] Funeral expenses (wrongful death actions only) $ 0.00 9. El Future contributions (present value) (wrongful death actions only) $ 0.00 h. I: Value of personal service, advice, or training (wrongful death actions only) $ 0.00 i. Other (specify) Defamation $ 150,000.00 i- III Other (specify) Unjust Enrichment and Quantum Meruit $ 50,000-00 k. Continued on Attachment 2.k. 3. 250,000.00 Punitive damages: Plaintiff reserves the right to seek punitive damages in the amount of (specify). $ when pursuing a judgment in the suit filed against you. Date: April 19, 2021 Mark T. Coffin, Attorney for Plaintiffs (TYPE on pnmr NAME) ( GNATU NTIFF on ATTORNEY FOR PLAINTIFF) (Proof of service on reverse) on Plan 1 STATEMENT OF DAMAGES C°d° 0' 0"“ 55 425~“- 425-115 Form Ad ted for Mandatory'Use Judicia Council of California wwwlcourfinfoeagov ClV-OSO (Rev. January 1, 20071 (Personal Injury or Wrongful Death) ClV-050 _ PLAINTIFF: DAVID G. BERTRAND, ct ai. CASE NUMBER: 19CV02429 DEFENDANT: JESSICA BERRY PROOF OF SERVICE have the person who served (After having the other party served as described below, with any of the documents identified in item 1, the documents complete this Proof of Service. Plaintiff cannot serve these papers.) 1. served the E E I a. Statement of Damages Other (specify): b. on (name): E c. by serving defendant E other (name and title or relationship to person served): d. E by delivery E at home Eat business (1) date: (2) time: (3) address: e. E by mailing (1) date: (2) place: 2. Manner of service (check proper box): a. E Personal service. By personally delivering copies. (CCP § 415.10) b. E Substituted service on corporation, unincorporated association (Including partnership), or public entity. By leaving, during usual office hours. copies in the office of the person served with the person who apparently was in charge and thereafter mailing (by first-class mail, postage prepaid) copies to the person served at the place where the copies were left. (CCP § 415.20(a)) c. E Substituted service on natural person, minor, conservatee, or candidate. By leaving copies at the dwelling house, usual place of abode, or usual place of business of the person served in the presence of a competent member of the household or a person apparently in charge of the office or place of business, at least 18 years of age, who was informed of the general nature of the papers. and thereafter mailing (by first-class mail. postage prepaid) copies to the person served at the place where the mpies were left. (CCP § 415.20(b)) (Attach separate declaration or affidavit stating acts relied on to establish reasonable diligence in first attempting personal service.) d. E Mail and acknowledgment service. By mailing (by first— class mail or airmail, postage prepaid) copies to the person sewed. together with two copies of the form of notice and acknowledgment and a return envelope, postage prepaid, addressed to the sender. (CCP § 415.30) (Attach completed acknowledgment of receipt.) e. E Certified or registered mail service. By mailing to an address outside California (by first-class mail, postage prepaid. requiring a return receipt) copies to the person served. (CCP § 415.40) (Attach signed return receipt or other evidence of actual delivery to the person served.) f. E Other (specify code section): additional page is attached. 3. At the time of service l was at least 18 years of age and not a party to this action. 4. Fee for service: $ 5. Person serving: a. California sheriff, marshal, or constable f. Name, address and telephone number and. if applicable. b. Registered Californiaprocess server county of registration and number. c. Employee or independent contractorof aregistered California process server d. D Not a registered California process server e. Exempt from registration under Bus. 8. Prof. Code § 22350(b) ldeclare under penalty of perjury under the laws of the (For Callfomla sheriff, marshal, or constable use only) State of California that the foregoing is true and correct. lcertify that the foregoing is true and corred. Date: Date: (SIGNATURE) (SlGNATURE) °'V°S°"‘"'J'"“‘“’"’°°" or SERVICE PROOF ammwmusasiméil: (Statement of Damages) CASE NUMBER: SHORT TITLE: BERTRAND v. BERRY — STATEMENT OF DAMAGES - ATTACHMENT 2 19CV02429 STATEMENT OF DAMAGES - SPECIAL DAMAGES - CONTINUED K. Rental Premises $50,000.00 L. Attorney Fees per Welfare and Institutions Code section l_5610.63(a) $90,000.00 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 item numbers, not line 26 (Required for verified pleading) The items on this page stated on information and belief are (specify numbers): 27 This page may be used with any Judicial Council form or any other paper filed with the court. Pug. 3 0f3 Form Approved by mo ADDITIONAL PAGE CRC 201. 501 Mid" °°“"°" °' “mm" Attach to Judlclal Council Form or Other Court Paper M9020 [New January 1, 1987] PROOF OF SERVICE 1234567009 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 sewed the foregoing documents described as PLAINTIFF DOROTHY CHURCHILL-JOHNSON’S STATEMENT OF DAMAGES, on the interested parties in this action: Address Party Jessica Berry 234 S. Figueroa St., #1640 JESSICA BERRY, in pro per. Los Angeles, CA 90012 10 T: 805-453-0106 E: Bemjessica03 7@gmail.com 11 12 l3 14 BY U.S. MAIL: This document was served by United States mail through the US Postal M Service. I enclosed the document in a sealed envelope or package addressed to the person(s) 15 at the address(es) above and placed the envelope(s) for collection and mailing, following our ordinary business practices. I am readily familiar with this firm’s practice of collecting and l6 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 l7 States Postal Service at Santa Barbara, California, in a sealed envelope with postage fully paid. 18 VIA EMAIL: I served the documents above on all parties via electronic mail, to the 19 w 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 20 complete and without error on this date. 21 (State) I declare under penalty of perjury under the laws of the State of Califomia that the foregoing is true and correct. 22 23 Executed on June 16, 2021 , at Santa Barbara, California. 24 25 Quit Sc‘o'ttA. Jaske 5L1. " ’ 26 27 28 4 PLAINTIFF DOROTHY CHURCHILL-JOHNSON’S STATEMENT 0F DAMAGES