On April 30, 2019 a
Party Discovery
was filed
involving a dispute between
Chandra Morgan-Meikle,
Larry Morgan,
Morgan, Larry,
Morgan-Meikle, Chandra,
Morgan, William,
William Morgan,
and
Henry Morales,
Morales, Henry,
Owl Inc.,
for
Unlimited Civil (Other Non-Personal Injury/Pro...)
in the District Court of Alameda County.
Preview
1 W. CHRISTIAN KRANKEMANN (SBN 220438)
KRANKEMANN LAW OFFICES P.C.
2 Attorneys At Law
420 E Street, Suite 100
3 Santa Rosa, California 95404
Telephone: (707) 524-2200
4 Facsimile: (866) 858-0100
5 Attorney for Plaintiffs
CHANDRA MORGAN-MEIKLE and LARRY MORGAN
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF ALAMEDA
10
P.C.
11 WILLIAM MORGAN, by and through his CASE NO.: HG19017006
successors in interest, CHANDRA
Telephone (707) 524-2200 | Facsimile (866) 858-0100
420 E Street, Suite 100 | Santa Rosa, California 95404
KRANKEMANN LAW OFFICES
12 MORGAN-MEIKLE and LARRY PROOF OF SERVICE
MORGAN, and CHANDRA MORGAN-
13 MEIKLE and LARRY MORGAN in their
individual capacities,
ATTORNEYS AT LAW
14
Plaintiffs,
15
vs.
16
OWL INC., HENRY MORALES, and DOES
17 1 through 20, inclusive,
18 Defendants.
19 ///
20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
28 ///
-1-
PROOF OF SERVICE
1 Morgan, William
Sonoma County Superior Court Case Number: HG19017006
2
PROOF OF SERVICE
3
I am a citizen of the United States. My business address is 420 E Street, Suite 100, Santa
4 Rosa, California 95404. I am employed in the County of Sonoma where this service occurs. I am
over the age of 18 years and not a party to this action.
5
On November 22, 2021, I served the following documents(s) described as:
6
SEE ATTACHED
7
8 ☐ BY UNITED STATES MAIL: I enclosed the documents in an envelope or package addressed
to the person(s) listed below and placed the envelope for collection and mailing, following our
ordinary business practices. I am readily familiar with this business’s practice for collecting and
9 processing documents for mailing. On the same day that documents are placed for collection and
mailing, they are deposited in the ordinary course of business with the United States Postal
Service, in a sealed envelope with postage fully prepaid.
10
☐ BY PERSONAL SERVICE: I served the documents by placing them in an envelope or package
P.C.
11 addressed to the person(s) listed below and provided them to a messenger for service.
☐ BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided
Telephone (707) 524-2200 | Facsimile (866) 858-0100
420 E Street, Suite 100 | Santa Rosa, California 95404
KRANKEMANN LAW OFFICES
12 by an overnight delivery carrier and addressed to the person(s) listed below. I placed the envelope
or package for collection and overnight delivery at an office or regularly utilized drop box of the
overnight delivery carrier.
13
☐ BY FAX: Based on an agreement of the parties to accept service by fax transmission, I faxed the
ATTORNEYS AT LAW
14 documents from (866) 858-0100 at ______am/pm to the person(s) listed below using the fax
machine number maintained and provided to me by person(s) listed below prior to 5:00 pm. No
error was reported by the fax machine that I used. A copy of the record of the fax transmission,
15 which I printed out, is attached.
16 ☒ BY ELECTRONIC SERVICE: Based on a court order or an agreement of the parties to accept
service by electronic transmission, I caused the documents to be sent to the person(s) listed below
at the electronic notification address listed below. I did not receive, within a reasonable time after
17 the transmission, any electronic message or other indication that the transmission was
unsuccessful.
18
on the person or person(s) below:
19 Hany Nicola
CLARK HILL
20 1055 West Seventh Street, 24th Floor
Los Angeles, CA 90017
21 hnicola@clarkhill.com
(Telephone) 213-891-9100
22
Attorneys for Defendants, HENRY MORALES,
23 and OWL, INC.
24
STATE: I declare under penalty of perjury under the laws of the State of
25 California that the above is true and correct.
26 Executed on November 22, 2021, at Santa Rosa, California.
27
______________________________________
28 ALINA ANDRES
-2-
PROOF OF SERVICE
1 1. PLAINTIFFS’ NOTICE OF MOTION AND MOTION TO COMPEL
DEFENDANT HENRY MORALES’S VERIFICATION OF HIS ORIGINAL AND
2 SUPPLEMENTAL RESPONSES TO PLAINTIFFS’ FORM INTERROGATORIES, SET ONE;
CODE-COMPLIANT RESPONSES TO PLAINTIFFS’ FORM INTERROGATORIES, SET ONE;
3 AND FOR MONETARY SANCTIONS AGAINST DEFENDANT HENRY MORALES AND
DEFENSE COUNSEL;
4
2. MEMORANDUM OF POINTS AND AUTHORITIES;
5
3. DECLARATION OF W. CHRISTIAN KRANKEMANN IN SUPPORT
6 THEREOF;
7 4. [PROPOSED] ORDER
8
9
10
P.C.
11
Telephone (707) 524-2200 | Facsimile (866) 858-0100
420 E Street, Suite 100 | Santa Rosa, California 95404
KRANKEMANN LAW OFFICES
12
13
ATTORNEYS AT LAW
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-3-
PROOF OF SERVICE
Document Filed Date
November 22, 2021
Case Filing Date
April 30, 2019
Category
Unlimited Civil (Other Non-Personal Injury/Pro...)
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Preview
1 W. CHRISTIAN KRANKEMANN (SBN 220438) KRANKEMANN LAW OFFICES P.C. 2 Attorneys At Law 420 E Street, Suite 100 3 Santa Rosa, California 95404 Telephone: (707) 524-2200 4 Facsimile: (866) 858-0100 5 Attorney for Plaintiffs CHANDRA MORGAN-MEIKLE and LARRY MORGAN 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF ALAMEDA 10 P.C. 11 WILLIAM MORGAN, by and through his CASE NO.: HG19017006 successors in interest, CHANDRA Telephone (707) 524-2200 | Facsimile (866) 858-0100 420 E Street, Suite 100 | Santa Rosa, California 95404 KRANKEMANN LAW OFFICES 12 MORGAN-MEIKLE and LARRY PROOF OF SERVICE MORGAN, and CHANDRA MORGAN- 13 MEIKLE and LARRY MORGAN in their individual capacities, ATTORNEYS AT LAW 14 Plaintiffs, 15 vs. 16 OWL INC., HENRY MORALES, and DOES 17 1 through 20, inclusive, 18 Defendants. 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// -1- PROOF OF SERVICE 1 Morgan, William Sonoma County Superior Court Case Number: HG19017006 2 PROOF OF SERVICE 3 I am a citizen of the United States. My business address is 420 E Street, Suite 100, Santa 4 Rosa, California 95404. I am employed in the County of Sonoma where this service occurs. I am over the age of 18 years and not a party to this action. 5 On November 22, 2021, I served the following documents(s) described as: 6 SEE ATTACHED 7 8 ☐ BY UNITED STATES MAIL: I enclosed the documents in an envelope or package addressed to the person(s) listed below and placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with this business’s practice for collecting and 9 processing documents for mailing. On the same day that documents are placed for collection and mailing, they are deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid. 10 ☐ BY PERSONAL SERVICE: I served the documents by placing them in an envelope or package P.C. 11 addressed to the person(s) listed below and provided them to a messenger for service. ☐ BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided Telephone (707) 524-2200 | Facsimile (866) 858-0100 420 E Street, Suite 100 | Santa Rosa, California 95404 KRANKEMANN LAW OFFICES 12 by an overnight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package for collection and overnight delivery at an office or regularly utilized drop box of the overnight delivery carrier. 13 ☐ BY FAX: Based on an agreement of the parties to accept service by fax transmission, I faxed the ATTORNEYS AT LAW 14 documents from (866) 858-0100 at ______am/pm to the person(s) listed below using the fax machine number maintained and provided to me by person(s) listed below prior to 5:00 pm. No error was reported by the fax machine that I used. A copy of the record of the fax transmission, 15 which I printed out, is attached. 16 ☒ BY ELECTRONIC SERVICE: Based on a court order or an agreement of the parties to accept service by electronic transmission, I caused the documents to be sent to the person(s) listed below at the electronic notification address listed below. I did not receive, within a reasonable time after 17 the transmission, any electronic message or other indication that the transmission was unsuccessful. 18 on the person or person(s) below: 19 Hany Nicola CLARK HILL 20 1055 West Seventh Street, 24th Floor Los Angeles, CA 90017 21 hnicola@clarkhill.com (Telephone) 213-891-9100 22 Attorneys for Defendants, HENRY MORALES, 23 and OWL, INC. 24 STATE: I declare under penalty of perjury under the laws of the State of 25 California that the above is true and correct. 26 Executed on November 22, 2021, at Santa Rosa, California. 27 ______________________________________ 28 ALINA ANDRES -2- PROOF OF SERVICE 1 1. PLAINTIFFS’ NOTICE OF MOTION AND MOTION TO COMPEL DEFENDANT HENRY MORALES’S VERIFICATION OF HIS ORIGINAL AND 2 SUPPLEMENTAL RESPONSES TO PLAINTIFFS’ FORM INTERROGATORIES, SET ONE; CODE-COMPLIANT RESPONSES TO PLAINTIFFS’ FORM INTERROGATORIES, SET ONE; 3 AND FOR MONETARY SANCTIONS AGAINST DEFENDANT HENRY MORALES AND DEFENSE COUNSEL; 4 2. MEMORANDUM OF POINTS AND AUTHORITIES; 5 3. DECLARATION OF W. CHRISTIAN KRANKEMANN IN SUPPORT 6 THEREOF; 7 4. [PROPOSED] ORDER 8 9 10 P.C. 11 Telephone (707) 524-2200 | Facsimile (866) 858-0100 420 E Street, Suite 100 | Santa Rosa, California 95404 KRANKEMANN LAW OFFICES 12 13 ATTORNEYS AT LAW 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -3- PROOF OF SERVICE