Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Michael Shklovsky 255893
Anderson Zeigler, A Professional Corp.
50 Old Courthouse Square, 5th Floor
Santa Rosa, California 95404
TELEPHONE NO.: (707) 545-4910 FAX NO.(Optional): (707)544-0260
mshklovsky@andersonzeigler.com
E-MAIL ADDRESS:
ATTORNEY FOR (Name): Defendant Kelly Moffat
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sonoma
STREET ADDRESS: 3035 Cleveland Avenue
MAILING ADDRESS:
Santa
CITY AND ZIP CODE: Rosa, California 95402
BRANCH NAME: Empire College Annex
PLAINTIFF/PETITIONER: Sean Duggan
DEFENDANT/RESPONDENT: Lynn Duggan; Kelly Moffat
Duggan Family Limited Partnership; Does 1-25
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): X UNLIMITED CASE LIMITED CASE SCV-268905
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 3/24/2022 Time: 3:00 pm Dept.: 17 Div.: Room:
Address of court (if different from the address above):
X Notice of Intent to Appear by Telephone, by (name): Michael Shklovsky
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. X This statement is submitted by party (name): Nominal Defendant Kelly Moffat
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): July 27, 2021
b. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. X All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. The following parties named in the complaint or cross-complaint
(1) have not been served (specify names and explain why not):
(2) have been served but have not appeared and have not been dismissed (specify names):
(3) have had a default entered against them (specify names):
c. The following additional parties may be added (specify names, nature of involvement in case, and the date by which
they may be served):
4. Description of case
a. Type of case in X complaint cross-complaint (Describe, including causes of action):
Declaratory Relief (1st CA), Breach of Contract (2nd and 3rd CA),
Breach of Fiduciary Duty (4th and 5th CA).
Page 1 of 5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California
CEB Essential rules 3.720–3.730
CM-110 [Rev. September 1, 2021] www.courts.ca.gov
ceb.com HForms
CM-110
PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER:
SCV-268905
DEFENDANT/RESPONDENT: Lynn Duggan, Does 1-25
Duggan Family Limited Partnership; Kelly Moffat
4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff alleges that defendant Lynn Duggan sold a portion of his General Partner interest to
Kelly Moffat, a nominal defendant in this action, puportedly in violation of the Partnership
Agreement as Plaintiff alleges that this transfer has resulted in damages to, and imperilment
of, Plaintiff's Limited Partnet interest in the Duggan Family Partnership.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request X a jury trial a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. The trial has been set for (date):
b. X No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
October 1 to October 20 (Trial); November 1, 2022 to November 20, 2022 (Trial)
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. X days (specify number): five to nine days (5-9)
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial X by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
9. Preference
This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 of the California Rules of Court for information about the
processes available through the court and community programs in this case.
(1) For parties represented by counsel: Counsel X has has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) X This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
Amount exceeds $50,000.00
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5
CEB Essential
ceb.com 3Forms
CM-110
PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER:
SCV-268905
DEFENDANT/RESPONDENT: Lynn Duggan, Does 1-25
Duggan Family Limited Partnership; Kelly Moffat
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):
X Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation X
Agreed to complete mediation by (date):
Mediation completed on (date):
X Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference
X
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
X Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation X
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
arbitration
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5
ICEB Essential
.
ceb com 3Forms
CM-110
PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER:
SCV-268905
DEFENDANT/RESPONDENT: Lynn Duggan, Does 1-25
Duggan Family Limited Partnership; Kelly Moffat
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b.
c.
Reservation of rights:
=1
1 Yes
=1 No
Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
= 1 Bankruptcy
Status:
Other (specify):
13. Related cases, consolidation, and coordination
a. There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
Additional cases are described in Attachment 13a.
b. A motion to consolidate
=1
1 coordinate will be filed by (name party):
14. Bifurcation
The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motion for Summary Judgment and/or Summary Adjuducation.
16. Discovery
a. The party or parties have completed all discovery.
b. X The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Def. Kelly Moffat written discovery per code
Def. Kelly Moffat depositions per code
Def. Kelly Moffat expert discovery per code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5
CEB Essential
ceb.com 3Forms
CM-110
PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER:
SCV-268905
DEFENDANT/RESPONDENT: Lynn Duggan, Does 1-25
Duggan Family Limited Partnership; Kelly Moffat
17. Economic litigation
a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
X The party or parties request that the following additional matters be considered or determined at the case management
conference (specify): This action was stayed pending resolution of
defendant's motion for posting of litigation bond. The
Court denied defendant's request on February 24, 2022.
19. Meet and confer
a. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of
Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any):
I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: DocuSigned by :
Michael Shklovsky
(TYPE OR PRINT NAME)
*
k
> ^iduxii
l
^ idcLfollcOj
371A6C90 A 97241C .
(SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
a Additional signatures are attached.
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5
CEB Essential
.
ceb com 3Forms
PROOF OF SERVICE
I am a citizen of the United States and a resident of Sonoma County, California. I
am over the age of 18 years and not a party to the within action. My business address is 50
Old Courthouse Sq., 5th Fl., Santa Rosa, CA 95404. My electronic service address is
jcook@andersonzeigler.com.
On March 7, 2022, I served the within CASE MANAGEMENT STATEMENT as
follows:
3 BY MAIL I served the above-referenced documents by sending said
document(s) by U.S. Postal Service to the address set forth herein.
BY FEDERAL EXPRESS
By placing said document(s) in a sealed envelope with postage thereon (or
Federal Express charges) fully prepaid, for collection and mailing, addressed
as follows:
SEE ATTACHED SERVICE LIST
BY PERSONAL SERVICE
By causing said document(s) to be delivered to the offices of the addressee as
set forth herein.
BY EMAIL TRANSMISSION
I electronically served the above-referenced documents by sending said
document(s) by email transmission to the email address set forth herein.
BY FACSIMILE TRANSMISSION
By sending said document(s) by facsimile transmission to the facsimile
number set forth herein.
COURTESY COPY BY EMAIL
By sending a courtesy copy of said document(s) to the email address set forth
herein.
I am readily familiar with this firm’s practice of collection and processing
correspondence for mailing/Federal Express. It is deposited with the U.S. Postal Service
or Federal Express depository on that same day in the ordinary course of business. I am
aware that on motion of a party served, service is presumed invalid if postal cancellation
date or postage meter date is more than one day after date of deposit for mailing.
I declare under penalty of perjury under the laws of the State of California and the
United States that the foregoing is true and correct. Executed on March 7, 2022, at Santa
Rosa, California.
Jenna Cook
SERVICE LIST
BY EMAIL:
Attorney for Plaintiff Sean Duggan
Lisa C. McCurdy, Esq.
Joy Chen, Esq.
Greenberg Traurig
1840 Century Park East, Suite 1900
Los Angeles, CA 90067-2121
Tel: 310-586-6512
mccurdyl@gtlaw.com
chenjoy@gtlaw.com
Attorney for Lynn Duggan
Anne Frassetto Olsen
NOLAND, HAMERLY. ETIENNE & HOSS
A Professional Corporation
333 Salinas Street
P.O. Box 2510
Salinas, CA 93902
Tel: 831 424-1414 ext. 210
aolsen@nheh.com
Attorneys for The Duggan Family Limited Partnership
Marshall E. Bluestone, Esq.
BLUESTONE ZUNINO & HAMILTON, LLP
50 Old Courthouse Square, Suite 401
Santa Rosa, CA 95404
Tel: 707 526-4250
marshall@bzhlegal.com
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Michael Shklovsky 255893 Anderson Zeigler, A Professional Corp. 50 Old Courthouse Square, 5th Floor Santa Rosa, California 95404 TELEPHONE NO.: (707) 545-4910 FAX NO.(Optional): (707)544-0260 mshklovsky@andersonzeigler.com E-MAIL ADDRESS: ATTORNEY FOR (Name): Defendant Kelly Moffat SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sonoma STREET ADDRESS: 3035 Cleveland Avenue MAILING ADDRESS: Santa CITY AND ZIP CODE: Rosa, California 95402 BRANCH NAME: Empire College Annex PLAINTIFF/PETITIONER: Sean Duggan DEFENDANT/RESPONDENT: Lynn Duggan; Kelly Moffat Duggan Family Limited Partnership; Does 1-25 CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): X UNLIMITED CASE LIMITED CASE SCV-268905 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 3/24/2022 Time: 3:00 pm Dept.: 17 Div.: Room: Address of court (if different from the address above): X Notice of Intent to Appear by Telephone, by (name): Michael Shklovsky INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. X This statement is submitted by party (name): Nominal Defendant Kelly Moffat b. This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): July 27, 2021 b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. X All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. The following parties named in the complaint or cross-complaint (1) have not been served (specify names and explain why not): (2) have been served but have not appeared and have not been dismissed (specify names): (3) have had a default entered against them (specify names): c. The following additional parties may be added (specify names, nature of involvement in case, and the date by which they may be served): 4. Description of case a. Type of case in X complaint cross-complaint (Describe, including causes of action): Declaratory Relief (1st CA), Breach of Contract (2nd and 3rd CA), Breach of Fiduciary Duty (4th and 5th CA). Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California CEB Essential rules 3.720–3.730 CM-110 [Rev. September 1, 2021] www.courts.ca.gov ceb.com HForms CM-110 PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER: SCV-268905 DEFENDANT/RESPONDENT: Lynn Duggan, Does 1-25 Duggan Family Limited Partnership; Kelly Moffat 4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff alleges that defendant Lynn Duggan sold a portion of his General Partner interest to Kelly Moffat, a nominal defendant in this action, puportedly in violation of the Partnership Agreement as Plaintiff alleges that this transfer has resulted in damages to, and imperilment of, Plaintiff's Limited Partnet interest in the Duggan Family Partnership. (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request X a jury trial a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. The trial has been set for (date): b. X No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): October 1 to October 20 (Trial); November 1, 2022 to November 20, 2022 (Trial) 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. X days (specify number): five to nine days (5-9) b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial X by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: Additional representation is described in Attachment 8. 9. Preference This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 of the California Rules of Court for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel X has has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) X This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): Amount exceeds $50,000.00 CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5 CEB Essential ceb.com 3Forms CM-110 PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER: SCV-268905 DEFENDANT/RESPONDENT: Lynn Duggan, Does 1-25 Duggan Family Limited Partnership; Kelly Moffat 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): X Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation X Agreed to complete mediation by (date): Mediation completed on (date): X Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference X Agreed to complete settlement conference by (date): Settlement conference completed on (date): X Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation X Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5 ICEB Essential . ceb com 3Forms CM-110 PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER: SCV-268905 DEFENDANT/RESPONDENT: Lynn Duggan, Does 1-25 Duggan Family Limited Partnership; Kelly Moffat 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. c. Reservation of rights: =1 1 Yes =1 No Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. = 1 Bankruptcy Status: Other (specify): 13. Related cases, consolidation, and coordination a. There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: Additional cases are described in Attachment 13a. b. A motion to consolidate =1 1 coordinate will be filed by (name party): 14. Bifurcation The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Motion for Summary Judgment and/or Summary Adjuducation. 16. Discovery a. The party or parties have completed all discovery. b. X The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Def. Kelly Moffat written discovery per code Def. Kelly Moffat depositions per code Def. Kelly Moffat expert discovery per code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5 CEB Essential ceb.com 3Forms CM-110 PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER: SCV-268905 DEFENDANT/RESPONDENT: Lynn Duggan, Does 1-25 Duggan Family Limited Partnership; Kelly Moffat 17. Economic litigation a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues X The party or parties request that the following additional matters be considered or determined at the case management conference (specify): This action was stayed pending resolution of defendant's motion for posting of litigation bond. The Court denied defendant's request on February 24, 2022. 19. Meet and confer a. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: DocuSigned by : Michael Shklovsky (TYPE OR PRINT NAME) * k > ^iduxii l ^ idcLfollcOj 371A6C90 A 97241C . (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) a Additional signatures are attached. CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5 CEB Essential . ceb com 3Forms PROOF OF SERVICE I am a citizen of the United States and a resident of Sonoma County, California. I am over the age of 18 years and not a party to the within action. My business address is 50 Old Courthouse Sq., 5th Fl., Santa Rosa, CA 95404. My electronic service address is jcook@andersonzeigler.com. On March 7, 2022, I served the within CASE MANAGEMENT STATEMENT as follows: 3 BY MAIL I served the above-referenced documents by sending said document(s) by U.S. Postal Service to the address set forth herein. BY FEDERAL EXPRESS By placing said document(s) in a sealed envelope with postage thereon (or Federal Express charges) fully prepaid, for collection and mailing, addressed as follows: SEE ATTACHED SERVICE LIST BY PERSONAL SERVICE By causing said document(s) to be delivered to the offices of the addressee as set forth herein. BY EMAIL TRANSMISSION I electronically served the above-referenced documents by sending said document(s) by email transmission to the email address set forth herein. BY FACSIMILE TRANSMISSION By sending said document(s) by facsimile transmission to the facsimile number set forth herein. COURTESY COPY BY EMAIL By sending a courtesy copy of said document(s) to the email address set forth herein. I am readily familiar with this firm’s practice of collection and processing correspondence for mailing/Federal Express. It is deposited with the U.S. Postal Service or Federal Express depository on that same day in the ordinary course of business. I am aware that on motion of a party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing. I declare under penalty of perjury under the laws of the State of California and the United States that the foregoing is true and correct. Executed on March 7, 2022, at Santa Rosa, California. Jenna Cook SERVICE LIST BY EMAIL: Attorney for Plaintiff Sean Duggan Lisa C. McCurdy, Esq. Joy Chen, Esq. Greenberg Traurig 1840 Century Park East, Suite 1900 Los Angeles, CA 90067-2121 Tel: 310-586-6512 mccurdyl@gtlaw.com chenjoy@gtlaw.com Attorney for Lynn Duggan Anne Frassetto Olsen NOLAND, HAMERLY. ETIENNE & HOSS A Professional Corporation 333 Salinas Street P.O. Box 2510 Salinas, CA 93902 Tel: 831 424-1414 ext. 210 aolsen@nheh.com Attorneys for The Duggan Family Limited Partnership Marshall E. Bluestone, Esq. BLUESTONE ZUNINO & HAMILTON, LLP 50 Old Courthouse Square, Suite 401 Santa Rosa, CA 95404 Tel: 707 526-4250 marshall@bzhlegal.com