Preview
CM-11 A
ATTORNEY QR PARTY V4hTHOUT ATTORNEY (Name, Stafe Bar number, and address}.
pOR COURT USE ONLY
Anne Frassetto Olsen, Esq. SBN: 99680
NOLAND HAMERLY ETIENNE & HOSS
333 Salinas Street ~ P.O. Box 2510
Salinas, CA 93902
TELEPHONE NO.: 83 I -424-1414 Fnx rvo. ~oprro„er~: 831-424-1975
e-nnAi~ no~REss:
aolsen@nheh.com
ATTORNEY FOR (Name):DefCll(ja21t
L n Du an
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA
srRE~r ApoREss: 3055 Cleveland Avenue
MAiuNc a,00Ress:3055 Cleveland Avenue
CITY AND ZIP CODE:
S111t3 ROSa~ CA 95403
BRANCH NAME:
Law Courthouse
CIVLI 111CJ F81I111
PLAINTIFFiPETiTIONER: Sean Duggan
DEFENDANT/RESPONDENT: Lynn Duggan
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): ~ UNLIMITED CASE 0 LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less) SCV-268905
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: March 24, 2022 Time:3:00 p.m. Dept.: 1~ Div.: Room:
Address of court (if drfferenf from the address above):
[~ Notice of Intent to Appear by Telephone, by (name); Anne Frassetto Olsen, Esq.
~~~a ~ rcu~ ~ ~u~va: H~~ appucap~e poxes must pe cnecKen, and the specified information must be provided.
7. Party or parties (answer one):
a. ~ This statement is submitted by party (name): Defendant, Lynn Duggan
b. ~ This statement is submitted jointly by parties (names}:
2. Complaint and cross-complaint (fo be answered by plaintiffs and crass-complainants only)
a. The complaint was filed on (date):
b. 0 The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-comp/ainants on(y)
a. 0 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) 0 have had a default entered against them (specify names):
c. ~ The following additional parties may be added (specify names, nature ofinvolvemenf in case, and date by which
they maybe served):
4. Description of case
a. Type of casein ~ complaint ~ cross-complaint (Describe, including causes ofaction):
Declaratory Relief (l s` CA), Breach of Contract (2ND and 3`d CA), Breach of Fiduciary Duty (4t" and 5Th
CA).
Page t of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of Calrfornia
CASE MANAGEMENT STATEMENT rules 3.720-373tJ
CM-110 [Rev. September 1, 2027] www.conrts.ca.gov
WestWw0a & Fam Baader
CM-11 Q
PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER:
DEFENDANT/RESPONDENT: Lynn Duggan SCV-268905
4. b. Provide a brief statement of the case, including any damages. (/f persona! injury damages are soughf, specify the injury and
damages claimed, including medrea/ expenses to date ('indicate source and amount], esffmated future medics! expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief fs sought, describe the nature of the re!lef.)
Plaintiff alleges that Defendant Lynn Duggan sold a portion of his General Partner interest to Kelly Moffat, a nominal Defendant in
this action, purportedly in violation of the Partnership Agreement as Plaintiff alleges that this transfer has resulted in damages to, and
imperilment of, Plaintiffs Limited Partner 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 ~ a jury trial ~ a nonjury trial. (/f more than one party, provide the name of each party
requesting a jury friai):
6. Trial date
a. ~ The trial has been set for(date):
b. ~ 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
nof, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dafes and explain reasons for unavailabi/fty):
Counsel is unavailable until March 2023, due to previously scheduled hearings.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. ~ days (specify number): 5-9 Court Days
b. ~ hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial~ by the attorney or party listed in the caption 0 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
0 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 (~ has 0 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 0 has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) 0 This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under 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) ~] 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. (spacify exemption): am ount
exceeds X50,000.00.
CM-110 [Rev. September t, 2021 Page z of s
CASE MANAGEMENT STATEMENT
~i1~~F66~i1
PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER:
DEFENDANT/RESPONDENT: SCV-268905
Lynn Duggan
1d. 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 fhe specified information):
The parry 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 tha parties' ADR
processes (check all that apply): stipulation):
~ Mediation session not yet scheduled
Mediation session scheduled for (date):
(1}Mediation 0 0 Agreed to complete mediation by (date):
Mediation completed an (date):
Settlement conference not yet scheduled
(2) Settlement ~ 0 Settlement conference scheduled for (date):
conference ~ Agreed to complete settlement conference by (date):
0 Settlement conference completed on (date):
~ Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation 0
0 Agreed to complete neutral evaluation by (dafe):
Neutral evaluation completed on (dafe):
~ Judicial arbitration not yet scheduled
(4) Nonbinding judicial 0 0 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{dafe):
arbitration ~ Agreed to complete private arbitration by (date):
0 Private arbitration completed on (date):
0 ADR session not yet scheduled
~ 0 ADR session scheduled for (date):
(6) Other {spec/fY):
Agreed to complete ADR session by (date):
0 ADR completed on (date):
CM•110 (Rev. September 1, 2021] Page 3 of 6
CASE MANAGEMENT STATEMENT
(^_M_11(1
PLAINTIFFiPETiTiONER: Sean Duggan CASE NUMBER:
DEFENDANT/RESPONDENT: Lynn Duggan SCV-268905
11. insurance
a• ~ Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: 0 Yes 0 No
c. [~ Coverage issues will significantly affect resolution of this case
(explain):
12. Jurisdiction
Indicate any matters that may affect the courts jurisdiction or processing of this case and describe the status.
0 Bankruptcy 0 Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. 0 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 ~ coordinate will be filed by (name parfy):
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
~ The party or parties expect to file the following motions before trial
(specify moving party, fype of motion, and issues):
Motion far Suinniary Judgment and/or Summary Adjudication.
16. Discovery
a. ~ The party or parties have completed all discovery.
b. ~ The following discovery will be completed by the date specified (describe al/ anticipated discovery):
~P Description Date
Defendant Written Discovery September 2022
Defendant Deposition of Plaintiff and other potential witnesses October 2022
Defendant Expert Discovery Pursuant to trial date
c. 0 The following. discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. September 1, 2021] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER:
DEFENDANTIRESP0NDENT: Lynn Duggan SCV-268905
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 fitigatlon procedures relating fo discovery or fria!
should not apply to fhis case):
18. Other issues
~ 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 ail 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): pn~
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: March 9, 2022
Anne FrasGett~ Oisen, Fs~_
(TYPE OR PRINT NAME (SIGNATURE OF PARTY OR ATTORNEI~
(TYPE OR PRINT NAME (SIGNATURE OF PARTY OR ATTORNEI~
Additional signatures are attached.
CM-110 [Rev. September t, 2021] Page S of 5
CASE MANAGEMENT STATEMENT
1 PROOF OF SERVICE
(Code Civ. Prac. §§ 1013(a), 2015.5)
2
3 STATE OF CALIFORNIA )
4 COUNTY OF MONTEREY )
5
6 I am a citizen of the United States and a resident of Monterey County. I am over the age
of 18 years and not a party to the within entitled action; my business address is: 333 Salinas
7 Street, Post Office Box 2510, Salinas, CA 93902-2510.
8 On the date below, I served the attached documents) entitled: CASE MANAGEMENT
STATEMENT, on the following named persons) in said action at:
9
10 Marshall E. Bluestone, Esq.
BLUESTONE, ZUNINO &
x 11 HAMILTON, LLP
50 Old Courthouse Square, Suite 401
zZ IZ Santa Rosa, CA 95404
W<
~- -~
W F Tel. (707) 526-4250
y; ``
W z 13
J
tY'2
-~
~
Email: inarsl1a11(~bzhle~al.com
W O
14
A Lisa C. McCurdy, Esq.
Q.~ 15 Joy Chen, Esq.
0
z GREENBERG TRAUR.IG
L 1840 Century Park East, Suite 1900
Los Angeles, CA 90067-2121
17
Tel: (310) 586-6512
18 Email: mcct~rdvl(rz;;~tlaw.cam
19 Michael Shklovsky, Esq.
ANDERSON ZEIGLER
Za A Professional Corporation
50 Old Courthouse Square, Sty' Floor
21
Santa Rosa, CA 95404
22 Tel.: (707) 545-4910
tn~hk tovskvra),andersonzei gler.com
23
By court order or by agreement of the parties to accept service by electronic
24 transmission, I caused the documents) to be sent to the persons) at the email
addresses) listed above. I did not receive within a reasonable time after the
25 transmission, any electronic message or other indication that the transmission was
unsuccessful. (CCP § 1010.6; Cal. Rules of Court, Rule 2.251).
26
by personal service on the above-named persons) at the above stated address(es).
27
zg
30556\000\I48~942.I :12321 1
PROOF OF SERVICE
Sean Duggan v. Lynn Duggan, et al. 1 Case No. SCV-268905
1 by placing said copy(ies) in a sealed envelope(s), postage thereon fully prepaid,
and placed far collection and processing for mailing following the business's
2 ordinary practice with which I am readily familiar. On the same day
correspondence is placed for collection and mailing, it is deposited in the ordinary
3 course of business with the United States Postal Service at Salinas, California,
addressed as stated above.
4
by causing to be transmitted a true copy thereof to the above-named recipient via
5 the electronic mail address (parce@nheh.com), and no failure to deliver message
was received.
6
7' I declare, under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
8
Executed on March 9, 2022, at Salinas, California.
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30556\000\1487942.1:12321 2
PROOF OF SERVICE
Sean Duggan v. Lynn Duggan, et al. 1 Case No. SCV-268905
Preview
CM-11 A ATTORNEY QR PARTY V4hTHOUT ATTORNEY (Name, Stafe Bar number, and address}. pOR COURT USE ONLY Anne Frassetto Olsen, Esq. SBN: 99680 NOLAND HAMERLY ETIENNE & HOSS 333 Salinas Street ~ P.O. Box 2510 Salinas, CA 93902 TELEPHONE NO.: 83 I -424-1414 Fnx rvo. ~oprro„er~: 831-424-1975 e-nnAi~ no~REss: aolsen@nheh.com ATTORNEY FOR (Name):DefCll(ja21t L n Du an SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA srRE~r ApoREss: 3055 Cleveland Avenue MAiuNc a,00Ress:3055 Cleveland Avenue CITY AND ZIP CODE: S111t3 ROSa~ CA 95403 BRANCH NAME: Law Courthouse CIVLI 111CJ F81I111 PLAINTIFFiPETiTIONER: Sean Duggan DEFENDANT/RESPONDENT: Lynn Duggan CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): ~ UNLIMITED CASE 0 LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) SCV-268905 A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: March 24, 2022 Time:3:00 p.m. Dept.: 1~ Div.: Room: Address of court (if drfferenf from the address above): [~ Notice of Intent to Appear by Telephone, by (name); Anne Frassetto Olsen, Esq. ~~~a ~ rcu~ ~ ~u~va: H~~ appucap~e poxes must pe cnecKen, and the specified information must be provided. 7. Party or parties (answer one): a. ~ This statement is submitted by party (name): Defendant, Lynn Duggan b. ~ This statement is submitted jointly by parties (names}: 2. Complaint and cross-complaint (fo be answered by plaintiffs and crass-complainants only) a. The complaint was filed on (date): b. 0 The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-comp/ainants on(y) a. 0 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) 0 have had a default entered against them (specify names): c. ~ The following additional parties may be added (specify names, nature ofinvolvemenf in case, and date by which they maybe served): 4. Description of case a. Type of casein ~ complaint ~ cross-complaint (Describe, including causes ofaction): Declaratory Relief (l s` CA), Breach of Contract (2ND and 3`d CA), Breach of Fiduciary Duty (4t" and 5Th CA). Page t of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of Calrfornia CASE MANAGEMENT STATEMENT rules 3.720-373tJ CM-110 [Rev. September 1, 2027] www.conrts.ca.gov WestWw0a & Fam Baader CM-11 Q PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER: DEFENDANT/RESPONDENT: Lynn Duggan SCV-268905 4. b. Provide a brief statement of the case, including any damages. (/f persona! injury damages are soughf, specify the injury and damages claimed, including medrea/ expenses to date ('indicate source and amount], esffmated future medics! expenses, lost earnings to date, and estimated future lost earnings. If equitable relief fs sought, describe the nature of the re!lef.) Plaintiff alleges that Defendant Lynn Duggan sold a portion of his General Partner interest to Kelly Moffat, a nominal Defendant in this action, purportedly in violation of the Partnership Agreement as Plaintiff alleges that this transfer has resulted in damages to, and imperilment of, Plaintiffs Limited Partner 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 ~ a jury trial ~ a nonjury trial. (/f more than one party, provide the name of each party requesting a jury friai): 6. Trial date a. ~ The trial has been set for(date): b. ~ 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 nof, explain): c. Dates on which parties or attorneys will not be available for trial (specify dafes and explain reasons for unavailabi/fty): Counsel is unavailable until March 2023, due to previously scheduled hearings. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. ~ days (specify number): 5-9 Court Days b. ~ hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial~ by the attorney or party listed in the caption 0 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 0 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 (~ has 0 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 0 has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) 0 This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under 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) ~] 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. (spacify exemption): am ount exceeds X50,000.00. CM-110 [Rev. September t, 2021 Page z of s CASE MANAGEMENT STATEMENT ~i1~~F66~i1 PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER: DEFENDANT/RESPONDENT: SCV-268905 Lynn Duggan 1d. 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 fhe specified information): The parry 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 tha parties' ADR processes (check all that apply): stipulation): ~ Mediation session not yet scheduled Mediation session scheduled for (date): (1}Mediation 0 0 Agreed to complete mediation by (date): Mediation completed an (date): Settlement conference not yet scheduled (2) Settlement ~ 0 Settlement conference scheduled for (date): conference ~ Agreed to complete settlement conference by (date): 0 Settlement conference completed on (date): ~ Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation 0 0 Agreed to complete neutral evaluation by (dafe): Neutral evaluation completed on (dafe): ~ Judicial arbitration not yet scheduled (4) Nonbinding judicial 0 0 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{dafe): arbitration ~ Agreed to complete private arbitration by (date): 0 Private arbitration completed on (date): 0 ADR session not yet scheduled ~ 0 ADR session scheduled for (date): (6) Other {spec/fY): Agreed to complete ADR session by (date): 0 ADR completed on (date): CM•110 (Rev. September 1, 2021] Page 3 of 6 CASE MANAGEMENT STATEMENT (^_M_11(1 PLAINTIFFiPETiTiONER: Sean Duggan CASE NUMBER: DEFENDANT/RESPONDENT: Lynn Duggan SCV-268905 11. insurance a• ~ Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: 0 Yes 0 No c. [~ Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the courts jurisdiction or processing of this case and describe the status. 0 Bankruptcy 0 Other (specify): Status: 13. Related cases, consolidation, and coordination a. 0 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 ~ coordinate will be filed by (name parfy): 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 ~ The party or parties expect to file the following motions before trial (specify moving party, fype of motion, and issues): Motion far Suinniary Judgment and/or Summary Adjudication. 16. Discovery a. ~ The party or parties have completed all discovery. b. ~ The following discovery will be completed by the date specified (describe al/ anticipated discovery): ~P Description Date Defendant Written Discovery September 2022 Defendant Deposition of Plaintiff and other potential witnesses October 2022 Defendant Expert Discovery Pursuant to trial date c. 0 The following. discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. September 1, 2021] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Sean Duggan CASE NUMBER: DEFENDANTIRESP0NDENT: Lynn Duggan SCV-268905 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 fitigatlon procedures relating fo discovery or fria! should not apply to fhis case): 18. Other issues ~ 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 ail 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): pn~ 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: March 9, 2022 Anne FrasGett~ Oisen, Fs~_ (TYPE OR PRINT NAME (SIGNATURE OF PARTY OR ATTORNEI~ (TYPE OR PRINT NAME (SIGNATURE OF PARTY OR ATTORNEI~ Additional signatures are attached. CM-110 [Rev. September t, 2021] Page S of 5 CASE MANAGEMENT STATEMENT 1 PROOF OF SERVICE (Code Civ. Prac. §§ 1013(a), 2015.5) 2 3 STATE OF CALIFORNIA ) 4 COUNTY OF MONTEREY ) 5 6 I am a citizen of the United States and a resident of Monterey County. I am over the age of 18 years and not a party to the within entitled action; my business address is: 333 Salinas 7 Street, Post Office Box 2510, Salinas, CA 93902-2510. 8 On the date below, I served the attached documents) entitled: CASE MANAGEMENT STATEMENT, on the following named persons) in said action at: 9 10 Marshall E. Bluestone, Esq. BLUESTONE, ZUNINO & x 11 HAMILTON, LLP 50 Old Courthouse Square, Suite 401 zZ IZ Santa Rosa, CA 95404 W< ~- -~ W F Tel. (707) 526-4250 y; `` W z 13 J tY'2 -~ ~ Email: inarsl1a11(~bzhle~al.com W O 14 A Lisa C. McCurdy, Esq. Q.~ 15 Joy Chen, Esq. 0 z GREENBERG TRAUR.IG L 1840 Century Park East, Suite 1900 Los Angeles, CA 90067-2121 17 Tel: (310) 586-6512 18 Email: mcct~rdvl(rz;;~tlaw.cam 19 Michael Shklovsky, Esq. ANDERSON ZEIGLER Za A Professional Corporation 50 Old Courthouse Square, Sty' Floor 21 Santa Rosa, CA 95404 22 Tel.: (707) 545-4910 tn~hk tovskvra),andersonzei gler.com 23 By court order or by agreement of the parties to accept service by electronic 24 transmission, I caused the documents) to be sent to the persons) at the email addresses) listed above. I did not receive within a reasonable time after the 25 transmission, any electronic message or other indication that the transmission was unsuccessful. (CCP § 1010.6; Cal. Rules of Court, Rule 2.251). 26 by personal service on the above-named persons) at the above stated address(es). 27 zg 30556\000\I48~942.I :12321 1 PROOF OF SERVICE Sean Duggan v. Lynn Duggan, et al. 1 Case No. SCV-268905 1 by placing said copy(ies) in a sealed envelope(s), postage thereon fully prepaid, and placed far collection and processing for mailing following the business's 2 ordinary practice with which I am readily familiar. On the same day correspondence is placed for collection and mailing, it is deposited in the ordinary 3 course of business with the United States Postal Service at Salinas, California, addressed as stated above. 4 by causing to be transmitted a true copy thereof to the above-named recipient via 5 the electronic mail address (parce@nheh.com), and no failure to deliver message was received. 6 7' I declare, under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 8 Executed on March 9, 2022, at Salinas, California. 9 10 0 11 x W z W 3q 12 H "~ W < a ?; .~ z 13 a z N w ~ o 6 x 4 14 Q z a IS 0 z 16 17 18 19 20 21 22 23 24 25 26 27 28 30556\000\1487942.1:12321 2 PROOF OF SERVICE Sean Duggan v. Lynn Duggan, et al. 1 Case No. SCV-268905