On July 27, 2021 a
No Value
was filed
involving a dispute between
Duggan, Sean,
and
Duggan, Lynn,
Moffat, Kelly,
The Duggan Family Limited Partnership,
for 06: Unlimited Breach of Contract/Warranty
in the District Court of Sonoma County.
Preview
1 Lisa C. McCurdy (SBN 228755)
Joy Chen (SBN 316842)
2 GREENBERG TRAURIG, LLP
1840 Century Park East, Suite 1900
3 Los Angeles, California 90067-2121
Telephone: (310) 586-7700
4 Facsimile: (310) 586-7800
mccurdyl@gtlaw.com
5 chenjoy@gtlaw.com
6 Attorneys for Plaintiff SEAN DUGGAN,
individually and derivatively on behalf of
7 the Duggan Family Limited Partnership
8
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SONOMA
11
SEAN DUGGAN, an individual, on his CASE NO. SCV-268905
12 own behalf and derivatively on behalf of
the Duggan Family Limited Partnership; Assigned for all purposes to Hon. Arthur A. Wick,
13 Dept. 17
Plaintiff,
14 PROOF OF SERVICE
v.
15
LYNN DUGGAN, an individual; and DOES 1
16 through 25, inclusive, Date: February 16, 2022
Time: 3:00 p.m.
17 Defendants, Dept: 17
18 -and-
Action filed: July 27, 2021
19 THE DUGGAN FAMILY LIMITED Trial date: None set
PARTNERSHIP, a California Limited
20 Partnership,
21 Nominal Defendant.
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28
PROOF OF SERVICE
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
3 I am employed in the aforesaid county, State of California; I am over the age of 18 years and not
a party to the within action; my business address is 1840 Century Park East, Suite 1900, Los Angeles,
4 CA 90067-2121; my email address is cronkritec@gtlaw.com.
5 On the date given below, I served the following documents:
6 1. PLAINTIFF SEAN DUGGAN’S OPPOSITION TO DEFENDANT THE DUGGAN
FAMILY PARTNERSHIP’S MOTION FOR POSTING OF A BOND
7
8 2. DECLARATION OF LISA C. MCCURDY IN SUPPORT OF OPPOSITION TO
DEFENDANT THE DUGGAN FAMILY PARTNERSHIP’S MOTION FOR
9 POSTING OF A BOND
10 3. DECLARATION OF SEAN DUGGAN IN SUPPORT OF OPPOSITION TO
11 DEFENDANT THE DUGGAN FAMILY PARTNERSHIP’S MOTION FOR
POSTING OF A BOND
12
on the interested parties in this action as follows:
13
Anne Olsen
14 Noland, Hamerly, Etienne & Hoss, APC
333 Salinas Street, P.O. Box 2510
15 Salinas, CA 93902
16 Email: aolsen@nheh.com
17 Attorneys for Defendant Lynn Duggan
18 Marshall E. Bluestone
Bluestone Zunino & Hamilton, LLP
19 50 Old Courthouse Square, Ste. 401
20 Santa Rosa, CA 95404
Email: marshall@bzhlegal.com
21
Attorneys for Defendant Duggan Family Limited Partnership
22
Michael Schklovsky
23
Anderson Zeigler, APC
24 50 Old Courthouse Square, 5th Fl.
Santa Rosa, CA 95404
25 Email: mshklovsky@andersonzeigler.com
26 Attorneys for Defendant Kelly Moffat
27
28
PROOF OF SERVICE
1 (BY E-MAIL) I caused the above document(s) to be transmitted to the office(s) of the
2 addressee(s) listed above by electronic mail at the e-mail address(es) set forth above per
agreement and consent of the addressee(s). The document was served electronically and the
3 transmission was reported complete and without error.
4 (BY OVERNIGHT COURIER) I am readily familiar with the business practice of my place
of employment in respect to the collection and processing of times for delivery by overnight
5 courier. The foregoing sealed envelope was placed for collection and overnight delivery by UPS
6 this date consistent with the ordinary business practice of my employment, so that it will be
picked up this date with delivery charges fully prepaid at Los Angeles, California, and delivered
7 the following business day in the ordinary course of business.
8
9 (STATE) I declare under penalty of perjury under the laws of the State of California
that the foregoing is true and correct.
10
Executed on February 2, 2022, at Los Angeles, California.
11
12 ___________________________
Christine C. Cronkrite
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PROOF OF SERVICE
Document Filed Date
February 03, 2022
Case Filing Date
July 27, 2021
Category
06: Unlimited Breach of Contract/Warranty
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1 Lisa C. McCurdy (SBN 228755) Joy Chen (SBN 316842) 2 GREENBERG TRAURIG, LLP 1840 Century Park East, Suite 1900 3 Los Angeles, California 90067-2121 Telephone: (310) 586-7700 4 Facsimile: (310) 586-7800 mccurdyl@gtlaw.com 5 chenjoy@gtlaw.com 6 Attorneys for Plaintiff SEAN DUGGAN, individually and derivatively on behalf of 7 the Duggan Family Limited Partnership 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SONOMA 11 SEAN DUGGAN, an individual, on his CASE NO. SCV-268905 12 own behalf and derivatively on behalf of the Duggan Family Limited Partnership; Assigned for all purposes to Hon. Arthur A. Wick, 13 Dept. 17 Plaintiff, 14 PROOF OF SERVICE v. 15 LYNN DUGGAN, an individual; and DOES 1 16 through 25, inclusive, Date: February 16, 2022 Time: 3:00 p.m. 17 Defendants, Dept: 17 18 -and- Action filed: July 27, 2021 19 THE DUGGAN FAMILY LIMITED Trial date: None set PARTNERSHIP, a California Limited 20 Partnership, 21 Nominal Defendant. 22 23 24 25 26 27 28 PROOF OF SERVICE 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 3 I am employed in the aforesaid county, State of California; I am over the age of 18 years and not a party to the within action; my business address is 1840 Century Park East, Suite 1900, Los Angeles, 4 CA 90067-2121; my email address is cronkritec@gtlaw.com. 5 On the date given below, I served the following documents: 6 1. PLAINTIFF SEAN DUGGAN’S OPPOSITION TO DEFENDANT THE DUGGAN FAMILY PARTNERSHIP’S MOTION FOR POSTING OF A BOND 7 8 2. DECLARATION OF LISA C. MCCURDY IN SUPPORT OF OPPOSITION TO DEFENDANT THE DUGGAN FAMILY PARTNERSHIP’S MOTION FOR 9 POSTING OF A BOND 10 3. DECLARATION OF SEAN DUGGAN IN SUPPORT OF OPPOSITION TO 11 DEFENDANT THE DUGGAN FAMILY PARTNERSHIP’S MOTION FOR POSTING OF A BOND 12 on the interested parties in this action as follows: 13 Anne Olsen 14 Noland, Hamerly, Etienne & Hoss, APC 333 Salinas Street, P.O. Box 2510 15 Salinas, CA 93902 16 Email: aolsen@nheh.com 17 Attorneys for Defendant Lynn Duggan 18 Marshall E. Bluestone Bluestone Zunino & Hamilton, LLP 19 50 Old Courthouse Square, Ste. 401 20 Santa Rosa, CA 95404 Email: marshall@bzhlegal.com 21 Attorneys for Defendant Duggan Family Limited Partnership 22 Michael Schklovsky 23 Anderson Zeigler, APC 24 50 Old Courthouse Square, 5th Fl. Santa Rosa, CA 95404 25 Email: mshklovsky@andersonzeigler.com 26 Attorneys for Defendant Kelly Moffat 27 28 PROOF OF SERVICE 1 (BY E-MAIL) I caused the above document(s) to be transmitted to the office(s) of the 2 addressee(s) listed above by electronic mail at the e-mail address(es) set forth above per agreement and consent of the addressee(s). The document was served electronically and the 3 transmission was reported complete and without error. 4 (BY OVERNIGHT COURIER) I am readily familiar with the business practice of my place of employment in respect to the collection and processing of times for delivery by overnight 5 courier. The foregoing sealed envelope was placed for collection and overnight delivery by UPS 6 this date consistent with the ordinary business practice of my employment, so that it will be picked up this date with delivery charges fully prepaid at Los Angeles, California, and delivered 7 the following business day in the ordinary course of business. 8 9 (STATE) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 10 Executed on February 2, 2022, at Los Angeles, California. 11 12 ___________________________ Christine C. Cronkrite 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE