2/5/2025
Jim and Dave,
I found the response to the mandatory settlement hearing to have been both interesting and disturbing. The mis quote of dollar amounts for jobs was bizarre. The declaration that reports didn't show evidence when we never did discovery and no reports were provided was a misrepresentation .
We'll try to keep things straight on this sight for others so everyone can follow along better.
b
Complaints
Original view
First Amended (DRAFT) view (34 pages) as of 2/3/2025 Meet and Confer Letter (Sent) and email (sent) and email (sent)
First Amended (DRAFT) view current for future reference only given complaint will be/was dismssed
Exhibits for 1st amended complaint
SPQ view (5 pages) page 2 items 6D
Emails view (6 pages) Forstein and Woodbury
Texts view (6 pages) Forstein and Woodbury
Payment Recs view (13 pages) Forstein to Woodbury
Quotes view (2 pages) 9/7/2020 - interior
view (2 pages) 9/8/2020 - exterior
view (2 pages) 9/27/2020 - garage
view (2 pages) 11/1/2020 - pool house ext
Photos view (2 pages) 2 of 6 from Forstein 2 pages
view (2 pages) email congrats on cover up
Bond Co view (10 pages) Woodbury response 1
view (3 pages) Woodbury response 2
view (3 pages) Email between BC and Svetlana
Statutes view (4 pages) CIV 1708 et seq
view (4 pages) BPC 7109 et seq
Filings for Settlement Conference
Motion to Show Cause gDoc pdf
Plaintiffs Settlement Conference Stmt gDoc pdf
Proposed Amended Complaint gDoc pdf
Defendants Statement pdf
Plaintiffs Response to Defendant Statement gDoc pdf
Voicemail left for Holly on 2/11/2025 audio
* - Attorney Jim Fitzpatrick left this voicemail for Holly 30 minutes before the settlement conference. Can you imagine a Defense Attorney doing his due diligence to see if one of the people filing the lawsuit knew they had filed it 30 minutes before a settlement conference? Can you imagine doing that after you had been serving someone other than her with her documents and then having had complained to the court she was not participating in the hearings as required? Can you imagine thinking we had been bluffing at that level for 8 months?
Dismissal Documents
Declaration to accomany Dismissal gDoc Draft as of 2/18/2025
Dismissal Document pdf