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WILLIAM CLINKENBEARD,
CATHY ANDERSON,
State Bar No.
State Bar No. 146458
102526
“um” “ ‘ ""‘W‘ "0L
CLINKENBEARD, RAMSEY, SPACKMAN & CLARK, LLP V
g
DEC _
Post Office Box 21007 fl 2013
Santa Barbara, California 93121 Dam! I.
a G
g
Executive
r.
Teleahone: (805) 965-0043 .y FIN_.
Facsmlle: (805) 965-8894 n. =
_
~
'I
J
Attorn
\OWNIQIII-hUNn—a
s for Defendant CHRIS HULME, individually m-
and De endant CLEARVIEW INDUSTRIES, INC.
(erroneously sued herein as Chris Hulme , individually and /
m—
dba Clearview Industries, con.
' '
Inc.)
‘7 -
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SANTA BARBARA 5'21 b ’
ANACAPA DIVISION
PATSY MOLER CASE NO. 1417847
Complaint filed 07/01/13
Assigned: Hon. James Herman
Plaintiff, Dept. 6
v. NOTICE OF MOTION AND
MOTION TO COMPEL FURTHER
CHRIS HULME, individuall and dba RESPONSES TO SPECIAL
CLEARVIEW INDUSTRIE INC., and INTERROGATORIES, SET ONE;
DOES DECLARATION OF WILLIAM
,
1 to 10, inclusive,
NNNNN—Iv—ee—ev—nn—s—as—an—ns—ne—a
CLINKENBEARD;
MEMORANDUM OF POINTS &
AUTHORITIES
Defendants.
D ate: J an 8 , 2014
Time: 9:30:33.
/ Dept: 6
PLEASE TAKE NOTICE that on January 8, 2014 at 9:30 am. or as soon thereafter as
may be heard in Dept. 6 of the above-entitled court, defendants CHRIS HULME, individually
and Defendant CLEARVIEW INDUSTRIES, INC. (erroneously sued herein as Chris Hulme .
individually and dba Clearview Industries, Inc.) will and hereby do move the court for an order
requiring plaintifi' Patsy Moler to provide further responses to certain special interrogatories, set
one. The interrogatories, which were served on August 20, 2013, seek information‘that is
relevant and non-privileged. Despite efl'orts to meet and confer and extensions of time in which
N to respond, no supplemental responses to special interrogatories Nos. 27 and 28 have been
received.
.
1
Nle ofMon'ona Motion to Compel Further Responses to Special Internet-tome. Set One. Deal afCllnksnbe-M. Memo ofP‘IdA'a
This motion is based upon this Notice. the attached Memorandum of Points and
Authorities, the concurrently-submitted Separate Statement of Items in Dispute, the exhibits and
declaration of William Cllnkenbeard submitted herewith, the court’s file, and such other and
flirther evidence as may be ofiered at the hearing in this matter.
Dated: December 3, 2013.
OMQOMAUNH CLINKENBEARD, RAMSEY, SPACKMAN& CLARK, LLP
13% (’fi
CATHY ANDBR 0N
Attorneys for Defendant CHRISTOPHER HULME,
individually and Defendant CLEARVIEW INDUSTRIES,
INC. (erroneously sued herein as Chris Hulrne,
individually and dba Clem-view Industries. Inc.)
ND—‘D—‘D—‘D—‘D—‘e—‘I—‘I—‘e—‘H
gfiaui’mfifioomqatuamNHo
/\
2
Mar Responses
Nu: of Motion a Motion to Cempel lnmromorlu.
to Special Memo ofP'lM'l.
Set One. Deal effllnkmbeard.
fl 0.
ant:
1, William Clinkenbeard, declare:
qomhuN—a
I am an attorney licensed to practice before the Courts of the State of California, and am a
law firm of Clinkenbeard, Ramsey, Spackman & I am familiar with
W
partner in the Clark, LLC.
the factual and procedural history of this case, and I have personal knowledge of the facts
asserted herein. If called upon to testify, I could and would testify as follows:
1. Plaintiff Patsy Moler has filed this lawsuit against defendants Chris Hulme and
Clearview Industries, Inc., in connection with work performed by the defendants at plaintiffs
residential property. The complaint contains causes for alleged breach of contract, fraud,
conversion and unjust enrichment. Plaintiff further claims that defendant Clearview Industries,
Inc. is an alter ego of defendant Chris Hulme.
2. On August 20, 2013, defendants propounded special interrogatories, set one. A
true and correct copy of these interrogatories are submitted as Exhibit A. Plaintiff‘s counsel
requested, and was given, several extensions of time to respond to the special interrogatories, up
to and including October 18, 2013. A true and correct copy of the written confirmation of this
extension issubmitted as Exhibit B.
Nun-----
3. Plaintiff served responses on October 18, 2013. Many. of the responses received
were incomplete, evasive, conclusory, or otherwise deficient. A true and correct copy of these
responses are submitted herewith as Exhibit C.
4. Defense counsel faxed a letter to plaintiff‘s counsel on October 29, 2013,
attempting to informally resolve the issues presented. Plaintiff was requested to provide firrther
responses, to he received by defense counsel, on or before November 8, 2013. A true and correct
copy of this letter is submitted herewith as Exhibit D.
5. Plaintiff requested and was granted additional time to provide supplemental
responses, up to and including November 15, 2013. A true and correct copy of the confirming
email is submitted herewith as Exhibit E. On November 14, 2013, plaintiff's counsel requested
additional time. A true and correct copy of this email, and defense counsel's response denying
3
Ntc ofMotlonItMarlontoCompll Further Responses to Memo ofP'etA'l.
Special lntenogstorlee. Set One. Dec! ofCllnkanbeud.
fl 0.
this request, and Mr. Ring’s response, issubmitted as Exhibit F.
6. On November 19, 2013, plaintifi‘s counsel advised in writing that the
supplemental responses were being reviewed and verified and would hopefully be provided by
the end of the week. A true and correct copy of this email is submitted as Exhibit 0.
Supplemental responses were received on November 21, 2013.
\DMQOMAUN—n
A true and correct copy of
plaintiff's supplemental responses are submitted as Exhibit B.
7. However, no supplemental responses to special interrogatories Nos. 27 and 28
were provided, nor was there any explanation from plaintiffs counsel as to why no flirther
responses were given to these two special interrogatories. The deadline to file a motion to
compel necessitated the filing of the within motion. These interrogatories seek fundamental
information regarding plaintiffs claimed economic damages, specifically, itemization of
amounts paid based on defendants' alleged misrepresentations, and itemization of amounts paid
which plaintifi' for alleged "inflated" billing. The information sought by this motion is not
privileged, and is relevant to the subject matter of this litigation on which plaintiff relies in
support of her claims; and damages.
ND—‘o—no—‘I—lt—‘D—‘D—‘D—lh‘b—fi
Ideclare under penalty of perjury under the laws of the state of California that the
foregoing is true and correct. Executed this 3" day of December, 2013, at Santa Barbara,
California.
S
aiS’RSRSSBo‘oooqouauwmo
William Clinkenlleard
4
Me of Motion a Motion to Come] Further Responses to Speolsl Interrogation. Set One. Dec! ofClInkanburd. Memo ofP'IM‘s.
5
Plaintiff Patsy Molar has filed this lawsuit against defendants Chris Hulme and
Clearview Industries, Inc., in connection with work performed by the defendants at plaintiff‘s
residential property. The complaint contains causes for alleged breach of contract, fraud,
conversion and unjust enrichment Plaintifi‘ firrther claims that defendant Clear-view Industries,
Inc. is
\oooxro‘uusau
an alter ego of defendant Chris Huhne.
Despite several extensions of time to respond, plaintifi' has not yet provided full and
complete substantive responses to special interrogatories nos. 27 and 28 (see separate statement
of items in dispute). It istherefore necessary for defendants to seek court intervention.
I.
Code of Civil Procedure section 2030.010 provides:
(a) Any party may obtain discovery within the ace s delimited by
Chapters 2 (commencing with Section 2017.010) an 3 (commencing
with Section 2017.710), and subject to the restrictions set forth in
Chapter 5 (commencing with Section 2019.010), by propounding to
any other party to the action written interrogatories to be answered
under oath.
(b) An interrogatory may relate to whether another party is making a
nnnnkuuH—rHHH
certain contention, or to the facts, witnesses, and writin on which
a contention is based. Arr interrogatory is not objections 1e because
an answer to it involves an o inion or contention that relates to fact
or the agplication of law to or would be based on information
gggugwnw-oomqo‘uhunuo
act,
obtaine or legal theories developed in anticipation of litigation or in
preparation for trial.
A party may obtain discovery regarding any matter, not privileged, that is relevant to the
subject matter involved. (Code Civ. Pro. §2017.010). Information should be regarded as relevant
to the subject matter if it might reasonably assist a party in evaluating a case, preparing for trial,
or facilitating settlement thereof (Llpton v. Superior Court (1996) 48 Cal.App.4t.h 1599, 1611;
Stewart v. Colonial Western Agency, Inc. (2001) 87 Cal.App.4th1006, 1013). Discovery statutes
are to be liberally construed in favor of disclosure unless discovery requests are clearly improper
(Colonial Life &Acc. Ins. Co. v. Sup. Ct. (1982) 31 Cal.3d 785, 790).
In this case, plaintifi‘ ofl'ers no justification for failing/refusing to provide a
straightforward response to special interrogatories nos. 27 and 28, which seek to ascertain all
5
Nta ofMotlnaa Motion to Comps! Further Responses to Special Interrupted“. Set One. Dscl ofCllnkarbesrd. Memo of Pun.
' O.
amounts which plaintiff claims were paid based upon mis-representations, or based upon
“inflated” bills. Such discovery is clearly within the permissible realms of discovery (Code Civ.
Pro. § 2017.010). Moving defendants are prejudiced by the inability to evaluate plaintifi‘s
claims, either for settlement purposes, or to prepare their defense regarding such claims at trial.
IL
\OWQQIIIAs—n
Code of Civil Procedure section 2030.300 provides:
(a) On receipt of a response to interrogatories, the propoundin
party may move for an order compelling a further response if e
propounding party deems that any of the following apply:
(1) An answer to a particular interrogatory is evasive or incomplete.
O 0 II t
(3) An objection to an interrogatory is without merit or too general.
As is more particularly set forth in the concurrently-filed Separate Statement of
interrogatories in dispute, the interrogatories seek information that is relevant and not privileged.
Plaintifi‘ has not served supplemental or amended responses, despite having ample time in which
NHHD—ll—‘e—le—ID—‘e—le—‘D—fi
to do so. Defendants are entitled to firnher, verified responses to each interrogatory, without
objection.
111.
Defendants seek a Court order compelling plaintiff to provide further responses to Special
gfigflfiBnfioomqo-uaun~o
lnterrogatories, Nos. 27 and 28, without obj ection, within ten days of the hearing on this motion.
Dated: December 3, 2013. CLINKENBBARD, RAMSEY, SPACKMAN& CLARK, LLP
‘
\
N B
8 fin g
Attorneys for Defen ant CHRISTOPHER HULME,
individually and Defendant CLEARVIEW INDUSTRIES.
INC. (erroneously sued herein as Chris Hulme ,
lndlvldually and dba Clearview Industries. Inc.)
6
Nb ofMotion It Motion to Comps! Further Responses to Special MMWHI. Set On. Dec! ofClaunbeam. Memo ofP'IAA‘I.
' O.
O V. C.
am employed in the County of Santa Bar I am over the
I
13 and not a to the within oction: my buoinooo
State of Californle.
oo in: .0. Box 21007. Some Bar at? a.
CA 93121-1 07 3930 Stoto Street. Suite 200. Sento Barbere. A 93103.
On the doto lot forth below. I oorved tho forofiinfidocumont doocribed oo: NOTICE OF
MOTION AND MOTION TO COMPEL PURT R SPONSES TO SPECIAL
IN'I'ERROGATORIES SET ONE: DECLARATION OF WILLIAM CLINKENDEARD;
onxlouebun
MEMORANDUM 01" POINTS e
M
AUTHORITIES on the lntorooted portieo in this oction by
plocing true copy(loo) thereof encloood in oealed onvolopo(o) addrooood as follow:
g.
a Aooociotoo
. :1.
Mlchool P. Rin
1234 Same Bar ara Street
Sonte Barbara. CA 93101
mm
Tel: (805) 564-2333
Moll) I not "readily fomilior" with the flrm'o prootico of collection and cell
for meilin . Under thet proctico. it would be dopooltod with tho .S.pc1not‘al
oervico on that oorno doy th pclto o thereon fully propeid Firlt Claoo at Sante Barbero.
Colifornle in the ordinary ccuroo of uolnou. I am aware that. on motion ofparty oorvod. oervico
lo prooumod invalid if portal cancollation doto or pcttege motor dete io more then one doy after
the doto of depooit for melling in affldovit.
cauaod of the pogeo ofthe above-entitled document to be com to the
E!SW
email) I ell
onto) noted above vie email at tho following orneil oddrouoo:
NNNHD—lD—ll—l—IHHHHH
(Dy Electronic Tronofor-Eax) I couood all of tho p or of tho obovo-ontltlod document
Wife
lent to the roclpiont(o) noted above via electronic tr (ibcoirnllo) ot tho FAX number
I vo.
(Dy Electronic Trenton-email) I cauood all of the page! of tho above-entitled document
EB
aaauxunnoo-noueun_o
rent to the reclpient(o) noted obcve vie electronic trenofer emeil at the emell oddroloed
_
ovo.
(By Federal Exprou/Ovornight Mail) I ceuood the above-described document to be
_
oorvod on the intereoted portioo noted above by Federal Exprooa/Ovornlght Moll.
(Dy Poroonol Service) Idelivered ouch onvelopo(a) by hond to the addrouoo above.
I declare under penelty of perjury. under the low: ofthe Stote of Colli‘crnio thot tho
foregoing lo true and correct. - I
Dated: December 4. 2013.
I on lento mhmutolpooial hmuoubumalmun
7
MonoeffiM'e.
Preview
fl 0. L ,@ _ wmfigkgauronnm F WILLIAM CLINKENBEARD, CATHY ANDERSON, State Bar No. State Bar No. 146458 102526 “um” “ ‘ ""‘W‘ "0L CLINKENBEARD, RAMSEY, SPACKMAN & CLARK, LLP V g DEC _ Post Office Box 21007 fl 2013 Santa Barbara, California 93121 Dam! I. a G g Executive r. Teleahone: (805) 965-0043 .y FIN_. Facsmlle: (805) 965-8894 n. = _ ~ 'I J Attorn \OWNIQIII-hUNn—a s for Defendant CHRIS HULME, individually m- and De endant CLEARVIEW INDUSTRIES, INC. (erroneously sued herein as Chris Hulme , individually and / m— dba Clearview Industries, con. ' ' Inc.) ‘7 - SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA BARBARA 5'21 b ’ ANACAPA DIVISION PATSY MOLER CASE NO. 1417847 Complaint filed 07/01/13 Assigned: Hon. James Herman Plaintiff, Dept. 6 v. NOTICE OF MOTION AND MOTION TO COMPEL FURTHER CHRIS HULME, individuall and dba RESPONSES TO SPECIAL CLEARVIEW INDUSTRIE INC., and INTERROGATORIES, SET ONE; DOES DECLARATION OF WILLIAM , 1 to 10, inclusive, NNNNN—Iv—ee—ev—nn—s—as—an—ns—ne—a CLINKENBEARD; MEMORANDUM OF POINTS & AUTHORITIES Defendants. D ate: J an 8 , 2014 Time: 9:30:33. / Dept: 6 PLEASE TAKE NOTICE that on January 8, 2014 at 9:30 am. or as soon thereafter as may be heard in Dept. 6 of the above-entitled court, defendants CHRIS HULME, individually and Defendant CLEARVIEW INDUSTRIES, INC. (erroneously sued herein as Chris Hulme . individually and dba Clearview Industries, Inc.) will and hereby do move the court for an order requiring plaintifi' Patsy Moler to provide further responses to certain special interrogatories, set one. The interrogatories, which were served on August 20, 2013, seek information‘that is relevant and non-privileged. Despite efl'orts to meet and confer and extensions of time in which N to respond, no supplemental responses to special interrogatories Nos. 27 and 28 have been received. . 1 Nle ofMon'ona Motion to Compel Further Responses to Special Internet-tome. Set One. Deal afCllnksnbe-M. Memo ofP‘IdA'a This motion is based upon this Notice. the attached Memorandum of Points and Authorities, the concurrently-submitted Separate Statement of Items in Dispute, the exhibits and declaration of William Cllnkenbeard submitted herewith, the court’s file, and such other and flirther evidence as may be ofiered at the hearing in this matter. Dated: December 3, 2013. OMQOMAUNH CLINKENBEARD, RAMSEY, SPACKMAN& CLARK, LLP 13% (’fi CATHY ANDBR 0N Attorneys for Defendant CHRISTOPHER HULME, individually and Defendant CLEARVIEW INDUSTRIES, INC. (erroneously sued herein as Chris Hulrne, individually and dba Clem-view Industries. Inc.) ND—‘D—‘D—‘D—‘D—‘e—‘I—‘I—‘e—‘H gfiaui’mfifioomqatuamNHo /\ 2 Mar Responses Nu: of Motion a Motion to Cempel lnmromorlu. to Special Memo ofP'lM'l. Set One. Deal effllnkmbeard. fl 0. ant: 1, William Clinkenbeard, declare: qomhuN—a I am an attorney licensed to practice before the Courts of the State of California, and am a law firm of Clinkenbeard, Ramsey, Spackman & I am familiar with W partner in the Clark, LLC. the factual and procedural history of this case, and I have personal knowledge of the facts asserted herein. If called upon to testify, I could and would testify as follows: 1. Plaintiff Patsy Moler has filed this lawsuit against defendants Chris Hulme and Clearview Industries, Inc., in connection with work performed by the defendants at plaintiffs residential property. The complaint contains causes for alleged breach of contract, fraud, conversion and unjust enrichment. Plaintiff further claims that defendant Clearview Industries, Inc. is an alter ego of defendant Chris Hulme. 2. On August 20, 2013, defendants propounded special interrogatories, set one. A true and correct copy of these interrogatories are submitted as Exhibit A. Plaintiff‘s counsel requested, and was given, several extensions of time to respond to the special interrogatories, up to and including October 18, 2013. A true and correct copy of the written confirmation of this extension issubmitted as Exhibit B. Nun----- 3. Plaintiff served responses on October 18, 2013. Many. of the responses received were incomplete, evasive, conclusory, or otherwise deficient. A true and correct copy of these responses are submitted herewith as Exhibit C. 4. Defense counsel faxed a letter to plaintiff‘s counsel on October 29, 2013, attempting to informally resolve the issues presented. Plaintiff was requested to provide firrther responses, to he received by defense counsel, on or before November 8, 2013. A true and correct copy of this letter is submitted herewith as Exhibit D. 5. Plaintiff requested and was granted additional time to provide supplemental responses, up to and including November 15, 2013. A true and correct copy of the confirming email is submitted herewith as Exhibit E. On November 14, 2013, plaintiff's counsel requested additional time. A true and correct copy of this email, and defense counsel's response denying 3 Ntc ofMotlonItMarlontoCompll Further Responses to Memo ofP'etA'l. Special lntenogstorlee. Set One. Dec! ofCllnkanbeud. fl 0. this request, and Mr. Ring’s response, issubmitted as Exhibit F. 6. On November 19, 2013, plaintifi‘s counsel advised in writing that the supplemental responses were being reviewed and verified and would hopefully be provided by the end of the week. A true and correct copy of this email is submitted as Exhibit 0. Supplemental responses were received on November 21, 2013. \DMQOMAUN—n A true and correct copy of plaintiff's supplemental responses are submitted as Exhibit B. 7. However, no supplemental responses to special interrogatories Nos. 27 and 28 were provided, nor was there any explanation from plaintiffs counsel as to why no flirther responses were given to these two special interrogatories. The deadline to file a motion to compel necessitated the filing of the within motion. These interrogatories seek fundamental information regarding plaintiffs claimed economic damages, specifically, itemization of amounts paid based on defendants' alleged misrepresentations, and itemization of amounts paid which plaintifi' for alleged "inflated" billing. The information sought by this motion is not privileged, and is relevant to the subject matter of this litigation on which plaintiff relies in support of her claims; and damages. ND—‘o—no—‘I—lt—‘D—‘D—‘D—lh‘b—fi Ideclare under penalty of perjury under the laws of the state of California that the foregoing is true and correct. Executed this 3" day of December, 2013, at Santa Barbara, California. S aiS’RSRSSBo‘oooqouauwmo William Clinkenlleard 4 Me of Motion a Motion to Come] Further Responses to Speolsl Interrogation. Set One. Dec! ofClInkanburd. Memo ofP'IM‘s. 5 Plaintiff Patsy Molar has filed this lawsuit against defendants Chris Hulme and Clearview Industries, Inc., in connection with work performed by the defendants at plaintiff‘s residential property. The complaint contains causes for alleged breach of contract, fraud, conversion and unjust enrichment Plaintifi‘ firrther claims that defendant Clear-view Industries, Inc. is \oooxro‘uusau an alter ego of defendant Chris Huhne. Despite several extensions of time to respond, plaintifi' has not yet provided full and complete substantive responses to special interrogatories nos. 27 and 28 (see separate statement of items in dispute). It istherefore necessary for defendants to seek court intervention. I. Code of Civil Procedure section 2030.010 provides: (a) Any party may obtain discovery within the ace s delimited by Chapters 2 (commencing with Section 2017.010) an 3 (commencing with Section 2017.710), and subject to the restrictions set forth in Chapter 5 (commencing with Section 2019.010), by propounding to any other party to the action written interrogatories to be answered under oath. (b) An interrogatory may relate to whether another party is making a nnnnkuuH—rHHH certain contention, or to the facts, witnesses, and writin on which a contention is based. Arr interrogatory is not objections 1e because an answer to it involves an o inion or contention that relates to fact or the agplication of law to or would be based on information gggugwnw-oomqo‘uhunuo act, obtaine or legal theories developed in anticipation of litigation or in preparation for trial. A party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved. (Code Civ. Pro. §2017.010). Information should be regarded as relevant to the subject matter if it might reasonably assist a party in evaluating a case, preparing for trial, or facilitating settlement thereof (Llpton v. Superior Court (1996) 48 Cal.App.4t.h 1599, 1611; Stewart v. Colonial Western Agency, Inc. (2001) 87 Cal.App.4th1006, 1013). Discovery statutes are to be liberally construed in favor of disclosure unless discovery requests are clearly improper (Colonial Life &Acc. Ins. Co. v. Sup. Ct. (1982) 31 Cal.3d 785, 790). In this case, plaintifi‘ ofl'ers no justification for failing/refusing to provide a straightforward response to special interrogatories nos. 27 and 28, which seek to ascertain all 5 Nta ofMotlnaa Motion to Comps! Further Responses to Special Interrupted“. Set One. Dscl ofCllnkarbesrd. Memo of Pun. ' O. amounts which plaintiff claims were paid based upon mis-representations, or based upon “inflated” bills. Such discovery is clearly within the permissible realms of discovery (Code Civ. Pro. § 2017.010). Moving defendants are prejudiced by the inability to evaluate plaintifi‘s claims, either for settlement purposes, or to prepare their defense regarding such claims at trial. IL \OWQQIIIAs—n Code of Civil Procedure section 2030.300 provides: (a) On receipt of a response to interrogatories, the propoundin party may move for an order compelling a further response if e propounding party deems that any of the following apply: (1) An answer to a particular interrogatory is evasive or incomplete. O 0 II t (3) An objection to an interrogatory is without merit or too general. As is more particularly set forth in the concurrently-filed Separate Statement of interrogatories in dispute, the interrogatories seek information that is relevant and not privileged. Plaintifi‘ has not served supplemental or amended responses, despite having ample time in which NHHD—ll—‘e—le—ID—‘e—le—‘D—fi to do so. Defendants are entitled to firnher, verified responses to each interrogatory, without objection. 111. Defendants seek a Court order compelling plaintiff to provide further responses to Special gfigflfiBnfioomqo-uaun~o lnterrogatories, Nos. 27 and 28, without obj ection, within ten days of the hearing on this motion. Dated: December 3, 2013. CLINKENBBARD, RAMSEY, SPACKMAN& CLARK, LLP ‘ \ N B 8 fin g Attorneys for Defen ant CHRISTOPHER HULME, individually and Defendant CLEARVIEW INDUSTRIES. INC. (erroneously sued herein as Chris Hulme , lndlvldually and dba Clearview Industries. Inc.) 6 Nb ofMotion It Motion to Comps! Further Responses to Special MMWHI. Set On. Dec! ofClaunbeam. Memo ofP'IAA‘I. ' O. O V. C. am employed in the County of Santa Bar I am over the I 13 and not a to the within oction: my buoinooo State of Californle. oo in: .0. Box 21007. Some Bar at? a. CA 93121-1 07 3930 Stoto Street. Suite 200. Sento Barbere. A 93103. On the doto lot forth below. I oorved tho forofiinfidocumont doocribed oo: NOTICE OF MOTION AND MOTION TO COMPEL PURT R SPONSES TO SPECIAL IN'I'ERROGATORIES SET ONE: DECLARATION OF WILLIAM CLINKENDEARD; onxlouebun MEMORANDUM 01" POINTS e M AUTHORITIES on the lntorooted portieo in this oction by plocing true copy(loo) thereof encloood in oealed onvolopo(o) addrooood as follow: g. a Aooociotoo . :1. Mlchool P. Rin 1234 Same Bar ara Street Sonte Barbara. CA 93101 mm Tel: (805) 564-2333 Moll) I not "readily fomilior" with the flrm'o prootico of collection and cell for meilin . Under thet proctico. it would be dopooltod with tho .S.pc1not‘al oervico on that oorno doy th pclto o thereon fully propeid Firlt Claoo at Sante Barbero. Colifornle in the ordinary ccuroo of uolnou. I am aware that. on motion ofparty oorvod. oervico lo prooumod invalid if portal cancollation doto or pcttege motor dete io more then one doy after the doto of depooit for melling in affldovit. cauaod of the pogeo ofthe above-entitled document to be com to the E!SW email) I ell onto) noted above vie email at tho following orneil oddrouoo: NNNHD—lD—ll—l—IHHHHH (Dy Electronic Tronofor-Eax) I couood all of tho p or of tho obovo-ontltlod document Wife lent to the roclpiont(o) noted above via electronic tr (ibcoirnllo) ot tho FAX number I vo. (Dy Electronic Trenton-email) I cauood all of the page! of tho above-entitled document EB aaauxunnoo-noueun_o rent to the reclpient(o) noted obcve vie electronic trenofer emeil at the emell oddroloed _ ovo. (By Federal Exprou/Ovornight Mail) I ceuood the above-described document to be _ oorvod on the intereoted portioo noted above by Federal Exprooa/Ovornlght Moll. (Dy Poroonol Service) Idelivered ouch onvelopo(a) by hond to the addrouoo above. I declare under penelty of perjury. under the low: ofthe Stote of Colli‘crnio thot tho foregoing lo true and correct. - I Dated: December 4. 2013. I on lento mhmutolpooial hmuoubumalmun 7 MonoeffiM'e.