Preview
CM-110
"ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address). FOR GOURT USE ONLY
Edward McCutchan (SBN 119376)
Sunderland | McCutchan, LLP
1083 Vine Street, Suite 907
Healdsburg, CA 95448
TeterHone No: (707) 433-0377 Fax No. (Optiona):(707) 433-0379
E-MAIL ADDRESS (Optionay: emccutchan@sunmclaw.com
ATTORNEY FOR (Namo): Defendants Foppiano, et al.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sonoma
street aooress: 600 Administration Drive
maine aooress: 600 Administration Drive
cry ano zipcone: Santa Rosa, CA 95403
srancunawe: Empire College Annex
PLAINTIFF/PETITIONER: Susan Foppiano Valera
DEFENDANT/RESPONDENT: Louis Foppiano, et al.
CASE MANAGEMENT STATEMENT CAS NUMBER:
(Check one): UNLIMITED CASE [1 umrrep case
(Amount demanded (Amount demanded is $25,000 | SCV-269355
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: May 19, 2022 Time; 3:00 p.m. Dept: 17 Div.: Room:
Address of court (if different from the address above):
3035 Cleveland Avenue, Suite 200, Santa Rosa, CA 95403
[2X] Notice of intent to Appear by Telephone, by (name):Edward McCutchan
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. [2%] This statement is submitted by party (name): Defendants, Louis Foppiano, et al.
b. [] This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be.answered by intiffs and cross-complainants only)
a. The complaint was filed on (date): ‘Sets 4 seat"
b. [--] The cross-complaint, if any, was filed on (date):
3. Service (fo be answered by plaintiffs and cross-complainants only)
a. CX al 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) [1 have not been served (specify names and explain why not):
(2) [1 have been served but have not appeared and have not been dismissed (specify names):
(3) [1 have had a default entered against them (specify names):
c. C-] The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type ofcase in [X] complaint [1 cross-complaint (Describe, including causes of action):
Partition by Sale of Real Property, Accounting (CCP §§ 872.010 et seq.)
Page tot 5
Frm Adcplod for Mangatony 82 CASE MANAGEMENT STATEMENT Ga Re of Cou,
‘CM-110 (Rev, July 4, 2011] www.courts.ca.govCM-110
CASE NUMBER:
SCV-269355
PLAINTIFF/PETITIONER: Valera
DEFENDANT/RESPONDENT: Foppiano, et al.
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 fo date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff, Susan Valera, who owns less than 50% of the subject property, wants to be bought out but
believes her fractionalized ownership of record is worth more than it actually is.
[1 (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 C2) ajury trial [32] a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Per Code, a jury trial does not apply in partition actions.
6. Trial date
a. [_] The trial has been set for (date):
b. [3S] 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):
Due to Covid 19 creating delays for the court and litigants.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
October 7-15, 2022. In trial on another matter.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. DX] days (specify number): ‘ays
b. [1] hours (short causes) (specify):
8. Trial representation (fo be answered for each party)
The party or parties will be represented at trial [3X] by the attorney or party listed in the caption [7] by the following:
a. Attorney:
b. Firm:
c, Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
(J Additional representation is described in Attachment 8.
9. Preference
[1 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 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel (3X has [71 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 (1 has [J has not reviewed the ADR information package identified in rule 3.221.
b, Referral to judicial arbitration or civil action mediation (if available).
(1) [2] This matter is subject to mandatory judicial arbitration under Cade 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) [3%] This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
HO Rev. uy 1, 204 CASE MANAGEMENT STATEMENT Page aotCM-110
[_ PLAINTIFF/PETITIONER: Valera
DEFENDANT/RESPONDENT: Foppiano, et al.
[CASE NUMBER:
SCV-269355
40. 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 alll that apply and provide the specified information):
The party or parties completing
this form are willing to
participate in the following ADR
processes (check all that apply):
If the party or parties completing this form in the case have agreed to
participate in or have already completed an ADR process or processes,
indicate the status of the processes (attach a copy of the parties' ADR
stipulation):
(1) Mediation
Mediation session not yet scheduled
Mediation session scheduled for (date):
Agreed to complete mediation by (date):
Mediation completed on (date):
(2) Settlement
conference
Settlement conference not yet scheduled
Settlement conference scheduled for (date):
Agreed to complete settlement conference by (date):
Settlement conference completed on (daie):
(3) Neutral evaluation
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
(4) Nonbinding judicial
arbitration
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date):
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed an (date):
(5) Binding private
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
OO00)c000;0000/0000;0008)0000
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
oO ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
‘CM-110 (Rev. July 1, 2011]
CASE MANAGEMENT STATEMENT
Page 3 of 5CM-110
PLAINTIFF/PETITIONER: Valera ‘CASE NUMBER:
DEFENDANT/RESPONDENT: Foppiano, et al. SCV-269355
11. Insurance
a. (_] Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: [J Yes [_] No
c. [_] 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.
[[] Bankruptcy [—] other (specify):
Status:
43. Related cases, consolidation, and coordination
a. [€] There are companion, underlying, or related cases.
(1) Name of case: Foppiano, et al. v. Valera, et al.
(2) Name of court: Mendocino County Superior Court
(3) Case number; 21CV00971 .
(4) Status: Ongoing partition and accounting.
[1] Additional cases are described in Attachment 13a.
b. Ll Amotionto [7] consolidate [_] coordinate will be filed by (name party):
14. Bifurcation
[J 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):
415, Other motions
(1) The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16, Discovery
a. [__] The party or parties have completed all discovery.
b. [3] The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendants Tnitial written discovery June 2022
Defendants Expert depositions February 2023
c. [__] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
M0 (Rev dy 4, 2071 CASE MANAGEMENT STATEMENT Page dotCM-110
PLAINTIFF/PETITIONER: Valera CASE NUMBER
DEFENDANTIRESPONDENT: Foppiano, et al. SCV-269355
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
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
Defendant believes that the one acre parcel should be sold with another contiguous parcel controlled
by the parties to maximize sale price.
19. Meet and confer
a. [X] The party or parties have met and conferred with all parties on all subjects required by tule 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):
| 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.
pate: April_ | F2022
Edward McCutchan
(TYPE OR PRINT NAME) (ronarune Br magsrSe ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
[) Additional signatures are attached.
CH-110 Rev, ly 4, 2047 CASE MANAGEMENT STATEMENT Pago SofPROOF OF SERVICE
(CCP sections 1011, 1012, 1012.5, 1013)
STATE OF CALIFORNIA _ )
) ss.
COUNTY OF SONOMA )
Iam a citizen of the United States and a resident of the County aforesaid; I am over the age of 18
years and not a party to the within action; my business address is: 1083 Vine Street, Suite 907,
Healdsburg, California 95448.
On this date April IZ 2022, I served the within DEFENDANTS’ CASE MANAGEMENT
CONFERENCE STATEMENT on the interested parties in said action, including a true copy
thereof, and served the same on the parties/counsel addressed as follows:
PLEASE SEE ATTACHED SERVICE LIST
The following is the procedure in which service of this document was affected:
U.S. Postal Service - placing such envelope(s) with postage thereon fully prepaid
in the designated area for outgoing mail in accordance with this office’s practice,
whereby the mail is deposited in a U.S. mailbox in the City of Healdsburg,
/. California, after the close of the day's business.
Electronic Mail - I transmitted such documents(s) to the addressees at the below
E-Mail addresses:
Facsimile - I transmitted such documents(s) to the addressee(s) at the following
facsimile number(s):
One Legal’s electronic service program. Using One Legal’s electronic
transmission program, a true and correct copy of the documents was served on all
counsel by e-mailing a copy to each addressee named below.
Personal Service - I caused to be delivered such envelope(s) to the addressee(s) at
the address(es) set forth below.
is executed at Healdsburg, California on April 2022.
EDWARD McCUTCHAN
I declare under penalty of perjury that the foregoing is true and correct and this document
DEFENDANTS’ CASE MANAGEMENT CONFERENCE STATEMENTSERVICE LIST
SUSAN FOPPIANO VALERA v. LOUIS M. FOPPIANO, ET AL.
Sonoma County Superior Court Case No. SCV-269355
Attorneys for Plaintiff: Susan Foppiano Valera, an individual
Carter Rich PC
Brian C. Carter, Esq.
Alexander . Rich, Esq.
Margarita S. Rice, Esq.
305 N. Main Street
P. O. Box 1709
Ukiah, CA 95482
Tel: (707) 462-6694
Fax: (707) 462-7839
DEFENDANTS’ CASE MANAGEMENT CONFERENCE STATEMENT
Preview
CM-110 "ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address). FOR GOURT USE ONLY Edward McCutchan (SBN 119376) Sunderland | McCutchan, LLP 1083 Vine Street, Suite 907 Healdsburg, CA 95448 TeterHone No: (707) 433-0377 Fax No. (Optiona):(707) 433-0379 E-MAIL ADDRESS (Optionay: emccutchan@sunmclaw.com ATTORNEY FOR (Namo): Defendants Foppiano, et al. SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sonoma street aooress: 600 Administration Drive maine aooress: 600 Administration Drive cry ano zipcone: Santa Rosa, CA 95403 srancunawe: Empire College Annex PLAINTIFF/PETITIONER: Susan Foppiano Valera DEFENDANT/RESPONDENT: Louis Foppiano, et al. CASE MANAGEMENT STATEMENT CAS NUMBER: (Check one): UNLIMITED CASE [1 umrrep case (Amount demanded (Amount demanded is $25,000 | SCV-269355 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 19, 2022 Time; 3:00 p.m. Dept: 17 Div.: Room: Address of court (if different from the address above): 3035 Cleveland Avenue, Suite 200, Santa Rosa, CA 95403 [2X] Notice of intent to Appear by Telephone, by (name):Edward McCutchan INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. [2%] This statement is submitted by party (name): Defendants, Louis Foppiano, et al. b. [] This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be.answered by intiffs and cross-complainants only) a. The complaint was filed on (date): ‘Sets 4 seat" b. [--] The cross-complaint, if any, was filed on (date): 3. Service (fo be answered by plaintiffs and cross-complainants only) a. CX al 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) [1 have not been served (specify names and explain why not): (2) [1 have been served but have not appeared and have not been dismissed (specify names): (3) [1 have had a default entered against them (specify names): c. C-] The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type ofcase in [X] complaint [1 cross-complaint (Describe, including causes of action): Partition by Sale of Real Property, Accounting (CCP §§ 872.010 et seq.) Page tot 5 Frm Adcplod for Mangatony 82 CASE MANAGEMENT STATEMENT Ga Re of Cou, ‘CM-110 (Rev, July 4, 2011] www.courts.ca.govCM-110 CASE NUMBER: SCV-269355 PLAINTIFF/PETITIONER: Valera DEFENDANT/RESPONDENT: Foppiano, et al. 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 fo date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff, Susan Valera, who owns less than 50% of the subject property, wants to be bought out but believes her fractionalized ownership of record is worth more than it actually is. [1 (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 C2) ajury trial [32] a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): Per Code, a jury trial does not apply in partition actions. 6. Trial date a. [_] The trial has been set for (date): b. [3S] 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): Due to Covid 19 creating delays for the court and litigants. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): October 7-15, 2022. In trial on another matter. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. DX] days (specify number): ‘ays b. [1] hours (short causes) (specify): 8. Trial representation (fo be answered for each party) The party or parties will be represented at trial [3X] by the attorney or party listed in the caption [7] by the following: a. Attorney: b. Firm: c, Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: (J Additional representation is described in Attachment 8. 9. Preference [1 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 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel (3X has [71 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 (1 has [J has not reviewed the ADR information package identified in rule 3.221. b, Referral to judicial arbitration or civil action mediation (if available). (1) [2] This matter is subject to mandatory judicial arbitration under Cade 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) [3%] This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): HO Rev. uy 1, 204 CASE MANAGEMENT STATEMENT Page aotCM-110 [_ PLAINTIFF/PETITIONER: Valera DEFENDANT/RESPONDENT: Foppiano, et al. [CASE NUMBER: SCV-269355 40. 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 alll that apply and provide the specified information): The party or parties completing this form are willing to participate in the following ADR processes (check all that apply): If the party or parties completing this form in the case have agreed to participate in or have already completed an ADR process or processes, indicate the status of the processes (attach a copy of the parties' ADR stipulation): (1) Mediation Mediation session not yet scheduled Mediation session scheduled for (date): Agreed to complete mediation by (date): Mediation completed on (date): (2) Settlement conference Settlement conference not yet scheduled Settlement conference scheduled for (date): Agreed to complete settlement conference by (date): Settlement conference completed on (daie): (3) Neutral evaluation Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): (4) Nonbinding judicial arbitration Judicial arbitration not yet scheduled Judicial arbitration scheduled for (date): Agreed to complete judicial arbitration by (date): Judicial arbitration completed an (date): (5) Binding private Private arbitration not yet scheduled Private arbitration scheduled for (date): OO00)c000;0000/0000;0008)0000 arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled oO ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): ‘CM-110 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5CM-110 PLAINTIFF/PETITIONER: Valera ‘CASE NUMBER: DEFENDANT/RESPONDENT: Foppiano, et al. SCV-269355 11. Insurance a. (_] Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: [J Yes [_] No c. [_] 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. [[] Bankruptcy [—] other (specify): Status: 43. Related cases, consolidation, and coordination a. [€] There are companion, underlying, or related cases. (1) Name of case: Foppiano, et al. v. Valera, et al. (2) Name of court: Mendocino County Superior Court (3) Case number; 21CV00971 . (4) Status: Ongoing partition and accounting. [1] Additional cases are described in Attachment 13a. b. Ll Amotionto [7] consolidate [_] coordinate will be filed by (name party): 14. Bifurcation [J 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): 415, Other motions (1) The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16, Discovery a. [__] The party or parties have completed all discovery. b. [3] The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendants Tnitial written discovery June 2022 Defendants Expert depositions February 2023 c. [__] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): M0 (Rev dy 4, 2071 CASE MANAGEMENT STATEMENT Page dotCM-110 PLAINTIFF/PETITIONER: Valera CASE NUMBER DEFENDANTIRESPONDENT: Foppiano, et al. SCV-269355 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 The party or parties request that the following additional matters be considered or determined at the case management conference (specify): Defendant believes that the one acre parcel should be sold with another contiguous parcel controlled by the parties to maximize sale price. 19. Meet and confer a. [X] The party or parties have met and conferred with all parties on all subjects required by tule 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): | 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. pate: April_ | F2022 Edward McCutchan (TYPE OR PRINT NAME) (ronarune Br magsrSe ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) [) Additional signatures are attached. CH-110 Rev, ly 4, 2047 CASE MANAGEMENT STATEMENT Pago SofPROOF OF SERVICE (CCP sections 1011, 1012, 1012.5, 1013) STATE OF CALIFORNIA _ ) ) ss. COUNTY OF SONOMA ) Iam a citizen of the United States and a resident of the County aforesaid; I am over the age of 18 years and not a party to the within action; my business address is: 1083 Vine Street, Suite 907, Healdsburg, California 95448. On this date April IZ 2022, I served the within DEFENDANTS’ CASE MANAGEMENT CONFERENCE STATEMENT on the interested parties in said action, including a true copy thereof, and served the same on the parties/counsel addressed as follows: PLEASE SEE ATTACHED SERVICE LIST The following is the procedure in which service of this document was affected: U.S. Postal Service - placing such envelope(s) with postage thereon fully prepaid in the designated area for outgoing mail in accordance with this office’s practice, whereby the mail is deposited in a U.S. mailbox in the City of Healdsburg, /. California, after the close of the day's business. Electronic Mail - I transmitted such documents(s) to the addressees at the below E-Mail addresses: Facsimile - I transmitted such documents(s) to the addressee(s) at the following facsimile number(s): One Legal’s electronic service program. Using One Legal’s electronic transmission program, a true and correct copy of the documents was served on all counsel by e-mailing a copy to each addressee named below. Personal Service - I caused to be delivered such envelope(s) to the addressee(s) at the address(es) set forth below. is executed at Healdsburg, California on April 2022. EDWARD McCUTCHAN I declare under penalty of perjury that the foregoing is true and correct and this document DEFENDANTS’ CASE MANAGEMENT CONFERENCE STATEMENTSERVICE LIST SUSAN FOPPIANO VALERA v. LOUIS M. FOPPIANO, ET AL. Sonoma County Superior Court Case No. SCV-269355 Attorneys for Plaintiff: Susan Foppiano Valera, an individual Carter Rich PC Brian C. Carter, Esq. Alexander . Rich, Esq. Margarita S. Rice, Esq. 305 N. Main Street P. O. Box 1709 Ukiah, CA 95482 Tel: (707) 462-6694 Fax: (707) 462-7839 DEFENDANTS’ CASE MANAGEMENT CONFERENCE STATEMENT