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CIRCUIT COURT OF THE STATE OF OREGON FOR LANE COUNTY
`
`ACE AMERICAN INSURANCE
`COMPANY; AGCS MARINE
`INSURANCE COMPANY; AMERICAN
`COMMERCE INSURANCE COMPANY:;
`AMERICAN FAMILY CONNECT
`PROPERTY AND CASUALTY
`INSURANCE COMPANY; AMERICAN
`FAMILY INSURANCE COMPANY;
`AMERICAN FAMILY MUTUAL
`INSURANCE COMPANY: S.L,
`AMERICAN GUARANTEE AND
`LIABILITY INSURANCE COMPANY;
`AMERICAN STRATEGIC INSURANCE
`CORP.; ARMED FORCES INSURANCE
`EXCHANGE; ARTISAN AND
`TRUCKERS CASUALTY COMPANY;
`BANKERS STANDARD INSURANCE
`COMPANY; CHURCH MUTUAL
`INSURANCE COMPANY; COMMERCE
`WEST INSURANCE COMPANY;
`COUNTRY MUTUAL INSURANCE
`COMPANY; COUNTRY PREFERRED
`INSURANCE COMPANY; ENUMCLAW
`PROPERTY & CASUALTY INSURANCE
`COMPANY; FEDERAL INSURANCE
`COMPANY; FIRST AMERICAN
`PROPERTY AND CASUALTY
`COMPANY; HOMESITE INSURANCE
`COMPANY OF THE MIDWEST;
`
`Page |
`Reference # 00495277 - Holiday Farms
`
`Case No. 22CV29054
`
`DECLARATION OF Abigail Williams
`
`SUMMONS; COMPLAINT 1.
`NEGLIGENCE - EWEB, 2. NEGLIGENCE
`- LEC, 3. GROSS NEGLIGENCE, 4.
`PUBLIC NUISANCE, 5. INVERSE
`CONDEMNATION - EWEB, 6. INVERSE
`CONDEMNATION - LEC
`
`ABC Legal Services, Inc.
`633 Yesler Way, Seattle, WA 98104
`Phone 206.521.9000 - Fax 206.224.3409
`
`
`
`
`
`
`
`
`
`MUTUAL OF ENUMCLAW INSURANCE
`COMPANY; OREGON MUTUAL
`INSURANCE COMPANY;
`PROGRESSIVE CLASSIC INSURANCE
`COMPANY; PROGRESSIVE DIRECT
`INSURANCE COMPANY;
`PROGRESSIVE NORTHWESTERN
`INSURANCE COMPANY;
`PROGRESSIVE UNIVERSAL
`INSURANCE COMPANY;
`PROGRESSIVE WEST INSURANCE
`COMPANY; RAINIER INSURANCE
`COMPANY; AND RED SHIELD
`INSURANCE COMPANY,
`
`Plaintiff,
`
`VS.
`
`EUGENE WATER & ELECTRIC BOARD,
`A OREGON REGISTERED ELECTRIC
`UTILITY AND OREGON
`CORPORATION, DBA EWEB; LANE
`ELECTRIC COOPERATIVE, INC., AN
`OREGON COOPERATIVE
`CORPORATION; AND DOES 1
`THROUGH 50, INCLUSIVE,
`
`Defendant.
`
`1. The undersigned hereby declares: That (s)he is now, and at all times herein mentioned,
`
`a citizen of the United States and resident of the State of Oregon, over the age of eighteen,
`
`not a party to nor interested in the above entitled action, and is competent to be a witness
`
`therein.
`
`2. 1am an independent contractor process server and was assigned by ABC Legal to
`
`serve the above captioned documents for ABC Legal tracking number 0093879943.
`
`3. On or about 9/27/2022 1 received the above captioned documents for service on
`
`Defendant EUGENE WATER & ELECTRIC BOARD DBA EWERB at the address of 4200
`
`Roosevelt Blvd., Eugene, OR 97402.
`
`Page 2
`
`Reference # 00495277 - Holiday Farms
`
`ABC Legal Services, Inc.
`633 Yesler Way, Seattle, WA 98104
`Phone 206.521.9000 - Fax 206.224.3409
`
`
`
`
`
`
`
`
`
`18
`
`19
`
`20
`
`23
`
`24
`
`25
`
`4. On Wed 09/28/2022 at 04:28 PM, I attempted service at the address of 4200 Roosevelt
`Blvd., Eugene, OR 97402. I delivered the documents to Kayla Haaby who indicated they
`were the person authorized to accept with identity confirmed by subject stating their name.
`The individual accepted service with direct delivery. The individual appeared to be a brown-
`haired white female contact 35-45 years of age, 5'-5'4" tall and weighing 200-240 Ibs with
`glasses.
`
`5. True and correct copies of the photographs I submitted at the time of service are
`attached hereto as EXHIBIT A.
`
`6. Thereafter, I signed a Certificate of Service. A true and correct copy is attached as
`EXHIBIT B.
`
`7. As a professional process server, my methods for service consistently remain the
`same. [ make every attempt to verify the identity of the person with whom I speak and that
`they are of suitable age, discretion, and understand that I am leaving legal documents with
`them, which I performed in this instance.
`
`8 When I arrived at the service address, the doors were locked so an individual met me
`at the door. I stated I had a delivery for EWEB and asked if Frank Lawson was available.
`The individual left to determine if Frank Lawson was still present, they returned after a few
`minutes and told me he had left for the day. I then asked for someone else who was able to
`accept service. The Administrative Assistant, Kayla Haaby, then came down to my location.
`I confirmed with Kayla Haaby that she was authorized to accept service. She confirmed that
`
`she was, then the above listed documents were served directly to her.
`
`Page 3 ABC Legal Services, Inc.
`
`Reference # 00495277 - Holiday Farms 633 Yesler Way, Seattle, WA 98104
`
`Phone 206.521.9000 - Fax 206.224.3409
`
`
`
`
`
`
`
`
`
`I declare under penalty of perjury under the laws of the State of Oregon that the foregoing is
`
`true and correct to the best of my knowledge on the date herein noted.
`
`Dated this X Cé day of December, 2022
`
`=k
`
`Abigail Williams
`
`Page 4 ABC Legal Services, Inc.
`Reference # 00495277 - Holiday Farms 633 Yesler Way. Seattle, WA 98104
`Phone 206.521.9000 - Fax 206.224.3409
`
`
`
`
`
`
`
`
`
`EXHIBIT A
`
`i
`|
`W
`:
`i
`
`
`
`
`
`
`
`
`
`EXHIBIT A
`
`
`
`
`
`
`
`
`
`EXHIBIT B
`
`IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR LANE COUNTY
`
`ACE AMERICAN INSURANCE COMPANY; AGCS
`MARINE INSURANCE COMPANY; AMERICAN
`COMMERCE INSURANCE COMPANY; AMERICAN
`FAMILY CONNECT PROPERTY AND CASUALTY
`INSURANCE COMPANY; AMERICAN FAMILY
`INSURANCE COMPANY; AMERICAN FAMILY MUTUAL
`INSURANCE COMPANY; S.l., AMERICAN GUARANTEE
`AND LIABILITY INSURANCE COMPANY; AMERICAN
`STRATEGIC INSURANCE CORP.; ARMED FORCES
`INSURANCE EXCHANGE; ARTISAN AND TRUCKERS
`CASUALTY COMPANY; BANKERS STANDARD
`INSURANCE COMPANY; CHURCH MUTUAL INSURANCE
`COMPANY; COMMERCE WEST INSURANCE COMPANY;
`COUNTRY MUTUAL INSURANCE COMPANY; COUNTRY
`PREFERRED INSURANCE COMPANY; ENUMCLAW
`PROPERTY & CASUALTY INSURANCE COMPANY;
`FEDERAL INSURANCE COMPANY; FIRST AMERICAN
`PROPERTY AND CASUALTY COMPANY; HOMESITE
`INSURANCE COMPANY OF THE MIDWEST; MUTUAL OF
`ENUMCLAW INSURANCE COMPANY; OREGON
`MUTUAL INSURANCE COMPANY; PROGRESSIVE
`CLASSIC INSURANCE COMPANY; PROGRESSIVE
`DIRECT INSURANCE COMPANY; PROGRESSIVE
`NORTHWESTERN INSURANCE COMPANY;
`PROGRESSIVE UNIVERSAL INSURANCE COMPANY;
`PROGRESSIVE WEST INSURANCE COMPANY; RAINIER
`INSURANCE COMPANY; AND RED SHIELD INSURANCE
`COMPANY
`Plaintiff/Petitioner
`
`VS.
`EUGENE WATER & ELECTRIC BOARD, A OREGON
`REGISTERED ELECTRIC UTILITY AND OREGON
`CORPORATION, DBA EWEB; LANE ELECTRIC
`COOPERATIVE, INC., AN OREGON COOPERATIVE
`CORPORATION; AND DOES 1 THROUGH 50, INCLUSIVE
`
`Defendant/Respondent
`
`Cause No.: 22CV29054
`Hearing Date:
`
`DECLARATION OF SERVICE OF
`
`SUMMONS; COMPLAINT 1. NEGLIGENCE - EWEB, 2. NEGLIGENCE
`- LEC, 3. GROSS NEGLIGENCE, 4. PUBLIC NUISANCE, 5. INVERSE
`CONDEMNATION - EWEB, 6. INVERSE CONDEMNATION - LEC
`
`The undersigned hereby declares: That s(he) is now and at all times herein mentioned was a resident of the State of
`Oregon, over the age of eighteen, not an officer of a plaintiff corporation, not a party to nor interested in the above entitled
`action, has the authority to serve pleadings in the State named below, and is competent to be a witness therein.
`
`ORIGINAL DECLARATION
`REF: 00495277 - Holiday Farms OF SERVICE
`
`s
`
`Tracking #: 0094094018 PDX FIL
`
`A
`
`
`
`
`
`
`
`
`
`EXHIBIT B
`
`On the 28th day of September, 2022 at 4:28 PM at the address of 4200 Roosevelt Blvd.,, Eugene, Lane, OR 97402;
`this declarant served the above described documents upon EUGENE WATER & ELECTRIC BOARD DBA EWEB cl/o
`Frank Lawson, CEO/General Manager, by then and there personally delivering 1 true and correct copy(ies) thereof, by
`then presenting to and leaving the same with Kayla Haaby, | delivered the documents to Kayla Haaby who indicated
`they were the person authorized to accept with identity confirmed by subject stating their name. The individual
`accepted service with direct delivery. The individual appeared to be a brown-haired white female contact 35-45
`years of age, 5'-5'4" tall and weighing 200-240 Ibs with glasses.
`
`No information was provided or discovered that indicates that the subjects served are members of the U.S. military.
`
`| hereby declare that the above statement is true to the best of my knowledge and belief, and that | understand it is made
`for use as evidence in court and is subject to penalty for perjury.
`
`Date: 09/29/2022
`
`Abigail Williams
`P.0. BOX 11822, EUGENE, OR 97440 541-554-9686
`
`Tracking #: 0094094018 PDX FIL
`
`ORIGINAL DECLARATION
`T BN
`
`
`
`
`
`
`
`
`

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