On May 10, 2019 a
Party Discovery
was filed
involving a dispute between
Msalam, Andrew,
Msalam, Ghassan,
Msalam, Jamie,
Msalam, Jamilah,
Msalam, Jimilah,
Msalam, Jonathan,
Msalam, Julnar,
Msalam, Khalil,
and
Arellano, Fred,
Arellano, Freddie A., Jr,
Aria Sarbeland Trust,
Does 4-20 Individually And In Their Official Capacities,
Does 7-20, Individually And In Their Official Capacities,
Gonzalez, Miguel,
Martha Fabiola Sarbeland Trust,
Sarbeland, Aria,
Sarbeland, Martha,
Sarbeland Trust,
for (26) Unlimited Other Real Property
in the District Court of San Mateo County.
Preview
L.M. PARMENTER, STATE BAR NO.176196
1 PARMENTER LAW OFFICES 3/21/2022
501 ‘B’ Street, Suite 200
2 San Rafael, CA 94901-3846
Tel/Fax: (415) 738-7901
3 Email: lmparmenter@lawpar.com
4 MANUEL A. JUAREZ, STATE BAR NO.200706
LAW OFFICES OF MANUEL A. JUAREZ
5 2143 Cedar Street, Suite 200
Berkeley, CA 94709
6 Tel/Fax: (510) 841-6164
Email: baylaw1@yahoo.com
7
Attorneys for Plaintiffs
8 KHALIL MSALAM, ET AL.
9
10
SUPERIOR COURT OF THE STATE OF CALIFORNIA
PARMENTER@LAWPAR.COM
11
501 B STREET, STE. 200, SAN RAFAEL, CA 94901
FOR THE COUNTY OF SAN MATEO
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PARMENTER LAW OFFICES
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14 KHALIL MSALAM, JULNAR MSALAM, Case No.: 19-CIV-02602
JAMILAH MSALAM, GHASSAN MSALAM,
15 JAMIE MSALAM, JONATHAN MSALAM] The Hon. Robert D. Foiles
TEL./FAX: (415) 738-7901
ANDREW MSALAM by his Guardian ad
16 Litem Jimilah Msalam, DECLARATION OF LIGIA M.
PARMENTER IN SUPPORT OF
17 Plaintiffs, PLAINTIFFS’ OPPOSITION TO
DEFENDANTS’ MOTION TO COMPEL
18 vs. THE FURTHER DEPOSITION OF
JULNAR MSALAM AND MINOR
19 ANDREW MSALAM; AND
ARIA SARBELAND, individually, in his PLAINTIFFS’ REQUEST FOR
20 official capacity and as Trustee of the Aria SANCTIONS
Sarbeland Trust, the Martha Fabiola Sarbeland
21 Trust, and the Sarbeland Trust; MARTHA [Concurrently filed with Plaintiffs’
SARBELAND, individually, in her official Objection to Defendants’ Motion to Compel
22 capacity and as Trustee of the Aria Sarbeland the Depositions.]
Trust, the Martha Fabiola Sarbeland Trust, and
23 the Sarbeland Trust; FREDDIE A. Date: April 8, 2022
ARELLANO, JR. individually, in his official Time: 9:00 a.m.
24 capacity, and DOES 4-20 individually and in Dept.: 21
their official capacities.
25 Action Filed: May 10, 2019
Trial Date: Not Set
26 Defendants.
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Case No.: 19-CIV-02606 DECLARATION OF LIGIA M. PARMENTER IN S UPPORT OF O PPOSITION TO
DEFENDANTS’ MOTION FOR A PROTECTIVE ORDER
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I, Ligia M. Parmenter, declare as follows:
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1. I am an attorney at law duly licensed to practice before this Court and all courts of the State
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of California. I am counsel of record for the Plaintiffs Khalil Msalam, et al. (“Plaintiffs”). By
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6 virtue of this representation, I have personal knowledge as to the facts stated herein and, if
7 called upon to do so, could and would competently testify thereto.
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2. I make this declaration in support of Declaration of Ligia M. Parmenter In Support of
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Plaintiffs’ Opposition To Defendants’ Motion To Compel The Further Deposition of Julnar
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Msalam And Minor Andrew Msalam; and Plaintiffs’ Request For Sanctions.
PARMENTER@LAWPAR.COM
11
501 B STREET, STE. 200, SAN RAFAEL, CA 94901
12 3. Mr. Ara Jabagchourian, Esquire, counsel for Ara Sarbeland and Martha Sarbeland, took the
PARMENTER LAW OFFICES
13 deposition of Plaintiff Julnar Msalam on November 4, 2021. Also present was the counsel for
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Freddie Arellano, Jr., Mr. Anthony Rodriguez, Esquire and Ms. Cynthia Anaya, Esquire.
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TEL./FAX: (415) 738-7901
4. Mr. Jabagchourian demanded to take the depositions of Julnar Msalam, Khalil Msalam and
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17 minor Plaintiff Andrew Msalam all on the same date and represented in open court that each of
18 the depositions would take two (2) hours and that he was “very fast”. In the spirit of good faith
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and to try and move this matter forward, I and Mr. Manuel Juarez complied with Mr.
20
Jabagchorian demands. Defense counsel has now admitted that the deposition of Julnar
21
Msalam is supposed to take over eight (8) hours.
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23 5. Throughout the deposition, Mr. Jabagchourian repeatedly interrupted and spoke over the
24 witness Julnar Msalam. Mr. Jabagchourian 's interruptions were so pervasive and disruptive that
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the court reporter had to interject more than once to instruct Mr. Jabagchourian not talk at the
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same time as others.
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Case No.: 19-CIV-02606 DECLARATION OF LIGIA M. PARMENTER IN S UPPORT OF O PPOSITION TO
DEFENDANTS’ MOTION FOR A PROTECTIVE ORDER
6. During Ms. Msalam’s deposition, Mr. Jabagchourian was argumentative and aggressive
1
2 throughout the deposition. He repeatedly raised his voice and tried to browbeat Julnar Msalam.
3 7. The efforts to intimidate and bully reached a shocking crescendo when I made a request to
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take a break before Mr. Jabagchourian asked another question. (Mr. Jabagchourian did not
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allow for any time to elapse before Plaintiff had finished responding and before asking another
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7 question, often times Mr. Jabagchourian interrupted the witness to ask another question.)
8 8. At this juncture, Mr. Jabagchourian, refused to allow for a break and he began mocking me
9 by demanding that I go off to use the “bathroom” while he continued questioning Julnar
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Msalam and I was in the “bathroom”.
PARMENTER@LAWPAR.COM
11
501 B STREET, STE. 200, SAN RAFAEL, CA 94901
9. Mr. Jabagchourian shouted that he was not going to be interrupted and demanded to know if
12
PARMENTER LAW OFFICES
13 my client Julnar Msalam also had to use the “bathroom” to which she responded yes.
14 10. Mr. Jabagchourian then chose to engage in threatening the Plaintiff and her counsel with
15 “prosecution” and calling Plaintiff and her counsel “liars”; that Plaintiff’s counsel was going
TEL./FAX: (415) 738-7901
16
to go “coach” the Plaintiff during the break to “lie”; and that he had “caught” the Plaintiff
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“lying”. This was all done while the court reporter continued to transcribe and is a part of the
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19 deposition record. The deposition was suspended after Mr. Jabagchourian erupted in the above
20 hostile outbursts and serious threats.
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11. The deposition was terminated pursuant to Code of Civil Procedure section 2025.470 to
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protect Ms. Msalam.
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24 12. Due to being unable to pursue any further efforts to meet and confer due to the fear of being
25 prosecuted, I immediately contacted the IDC department and requested a conference with the
26 Honorable Ernst Halperin.
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13. Mr. Jabagchourian continued his unreasonable demands at the Initial Discovery
28
Conferences. There Mr. Jabagchourian demanded that I not be permitted to confer with
3
Case No.: 19-CIV-02606 DECLARATION OF LIGIA M. PARMENTER IN S UPPORT OF O PPOSITION TO
DEFENDANTS’ MOTION FOR A PROTECTIVE ORDER
1 my client at the deposition and that any breaks will be set by him. In addition, where Mr.
2 Jabagchourian had claimed that he would be taking the depositions of Khalil Msalam,
3 Julnar Msalam and minor Plaintiff Andrew Msalam, on a single date and that each
4 deposition would take a two hours (2) period, Mr. Jabagchourian now demands an eight (8)
5 hour period for Julnar Msalam’s deposition. During the conference, Commissioner Ernst
6 A. Halerin noted Mr. Jabagchourian angry attitude and what appear to be further
7 harassment of the Plaintiff. Mr. Jabagchourian also refused to refrain from continuing to
8 ask Contention Questions at the deposition.
9 14. I prepared this Motion and the accompanying documents for Plaintiffs. I have been
10 practicing law in California for over 25 years. My hourly rate for matter such as this one is
PARMENTER@LAWPAR.COM
11 $500.00 per hour. This is a reasonable hourly rate for an attorney of my years of
501 B STREET, STE. 200, SAN RAFAEL, CA 94901
12 experience practicing in the Bay Area.
PARMENTER LAW OFFICES
13 15. This Opposition to the Motion brought by Defendants Ara Sarbeland, Martha Sarbeland
14 and their counsel has/will require a total of more than ten (8) hours of my time totaling
15 $4,000.00. I have spent more than eight (6) hours researching, preparing and drafting this
TEL./FAX: (415) 738-7901
16 opposition to the Defendants’ motion, declarations, and proposed order. I have spent over
17 two (2) hours reviewing the Defendants’ moving documents and will be required to spend
18 additional time in reviewing any reply that may be filed by the Defendants. I will also
19 spend more hours preparing for and attending the hearing of this motion. Moreover, I will
20 spend personal time filing this motion with the Court and serving copies. Therefore, an
21 award of cost and fees to Plaintiffs of at least $4,000.00 is requested in sanctions against
22 the Defendants Ara Sarbeland, Martha Sarbeland and their counsel.
23 //
24 //
25 //
26 //
27 //
28 //
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Case No.: 19-CIV-02606 DECLARATION OF LIGIA M. PARMENTER IN S UPPORT OF O PPOSITION TO
DEFENDANTS’ MOTION FOR A PROTECTIVE ORDER
I declare under penalty of perjury under the laws of the State of California that the
1
2 foregoing is true and correct and that this Declaration was executed on this 21st day of March,
3 2022, at San Rafael, California.
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7 L.M. Parmenter
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PARMENTER@LAWPAR.COM
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501 B STREET, STE. 200, SAN RAFAEL, CA 94901
12
PARMENTER LAW OFFICES
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TEL./FAX: (415) 738-7901
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Case No.: 19-CIV-02606 DECLARATION OF LIGIA M. PARMENTER IN S UPPORT OF O PPOSITION TO
DEFENDANTS’ MOTION FOR A PROTECTIVE ORDER
1
PROOF OF SERVICE
2
3 I, L.M. PARMENTER, am not a party to this action, I am over 18 years of age and am
the attorney for the Plaintiffs Khalil Msalam, et al. herein. I declare under penalty of
4
perjury that on the below-indicated date, I served the foregoing document
5
DECLARATION OF LIGIA M. PARMENTER IN SUPPORT OF PLAINTIFFS’
6 OPPOSITION TO DEFENDANTS’ MOTION TO COMPEL THE FURTHER
DEPOSITION OF JULNAR MSALAM AND MINOR ANDREW MSALAM; AND
7 PLAINTIFFS’ REQUEST FOR SANCTIONS
8 on the parties to this action by placing a true copy thereof in a sealed envelope or package
9 addressed to the person(s) at the address(es) as set forth below and caused said envelope or
package to be served in the following manner:
10
Mr. Ara Jabagchourian, Esquire Mr. Anthony E. Rodriguez, Esquire
PARMENTER@LAWPAR.COM
11 LAW OFFICES of ARA Ms. Cynthia Anaya, Esquire
501 B STREET, STE. 200, SAN RAFAEL, CA 94901
12 JABAGCHOURIAN, P.C. AER LEGAL, APC
PARMENTER LAW OFFICES
1650 S. Amphlett Blvd., Suite 216 Mountain View, California
13 San Mateo, CA 94402 Email: Email: ANTHONY@AERLEGAL.COM
ARA@ARAJLAW.COM Email. CYNTHIA@AERLEGAL.COM
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15 ☑ (By Electronic Mail) Pursuant to California Rules of Court, Rule 2.251(a); Code of
TEL./FAX: (415) 738-7901
Civil Procedure section 1010.6(e)(1)-(2); a court order; or an agreement of the parties
16 to accept service by e-mail or electronic transmission; I caused the afore document(s)
to be sent from e-mail address: (LMPARMENTER@LAWPAR.COM); to the
17 person(s)s at the e-mail address(es) listed above. I did not receive, within a reasonable
18 time after the transmission, any electronic message or other indication that the
transmission was unsuccessful.
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Executed in San Rafael, California on March 21, 2022.
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L.M. Parmenter
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Case No.: 19-CIV-02606 DECLARATION OF LIGIA M. PARMENTER IN S UPPORT OF O PPOSITION TO
DEFENDANTS’ MOTION FOR A PROTECTIVE ORDER
Preview
L.M. PARMENTER, STATE BAR NO.176196 1 PARMENTER LAW OFFICES 3/21/2022 501 ‘B’ Street, Suite 200 2 San Rafael, CA 94901-3846 Tel/Fax: (415) 738-7901 3 Email: lmparmenter@lawpar.com 4 MANUEL A. JUAREZ, STATE BAR NO.200706 LAW OFFICES OF MANUEL A. JUAREZ 5 2143 Cedar Street, Suite 200 Berkeley, CA 94709 6 Tel/Fax: (510) 841-6164 Email: baylaw1@yahoo.com 7 Attorneys for Plaintiffs 8 KHALIL MSALAM, ET AL. 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA PARMENTER@LAWPAR.COM 11 501 B STREET, STE. 200, SAN RAFAEL, CA 94901 FOR THE COUNTY OF SAN MATEO 12 PARMENTER LAW OFFICES 13 14 KHALIL MSALAM, JULNAR MSALAM, Case No.: 19-CIV-02602 JAMILAH MSALAM, GHASSAN MSALAM, 15 JAMIE MSALAM, JONATHAN MSALAM] The Hon. Robert D. Foiles TEL./FAX: (415) 738-7901 ANDREW MSALAM by his Guardian ad 16 Litem Jimilah Msalam, DECLARATION OF LIGIA M. PARMENTER IN SUPPORT OF 17 Plaintiffs, PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION TO COMPEL 18 vs. THE FURTHER DEPOSITION OF JULNAR MSALAM AND MINOR 19 ANDREW MSALAM; AND ARIA SARBELAND, individually, in his PLAINTIFFS’ REQUEST FOR 20 official capacity and as Trustee of the Aria SANCTIONS Sarbeland Trust, the Martha Fabiola Sarbeland 21 Trust, and the Sarbeland Trust; MARTHA [Concurrently filed with Plaintiffs’ SARBELAND, individually, in her official Objection to Defendants’ Motion to Compel 22 capacity and as Trustee of the Aria Sarbeland the Depositions.] Trust, the Martha Fabiola Sarbeland Trust, and 23 the Sarbeland Trust; FREDDIE A. Date: April 8, 2022 ARELLANO, JR. individually, in his official Time: 9:00 a.m. 24 capacity, and DOES 4-20 individually and in Dept.: 21 their official capacities. 25 Action Filed: May 10, 2019 Trial Date: Not Set 26 Defendants. 27 28 1 Case No.: 19-CIV-02606 DECLARATION OF LIGIA M. PARMENTER IN S UPPORT OF O PPOSITION TO DEFENDANTS’ MOTION FOR A PROTECTIVE ORDER 1 I, Ligia M. Parmenter, declare as follows: 2 3 1. I am an attorney at law duly licensed to practice before this Court and all courts of the State 4 of California. I am counsel of record for the Plaintiffs Khalil Msalam, et al. (“Plaintiffs”). By 5 6 virtue of this representation, I have personal knowledge as to the facts stated herein and, if 7 called upon to do so, could and would competently testify thereto. 8 2. I make this declaration in support of Declaration of Ligia M. Parmenter In Support of 9 Plaintiffs’ Opposition To Defendants’ Motion To Compel The Further Deposition of Julnar 10 Msalam And Minor Andrew Msalam; and Plaintiffs’ Request For Sanctions. PARMENTER@LAWPAR.COM 11 501 B STREET, STE. 200, SAN RAFAEL, CA 94901 12 3. Mr. Ara Jabagchourian, Esquire, counsel for Ara Sarbeland and Martha Sarbeland, took the PARMENTER LAW OFFICES 13 deposition of Plaintiff Julnar Msalam on November 4, 2021. Also present was the counsel for 14 Freddie Arellano, Jr., Mr. Anthony Rodriguez, Esquire and Ms. Cynthia Anaya, Esquire. 15 TEL./FAX: (415) 738-7901 4. Mr. Jabagchourian demanded to take the depositions of Julnar Msalam, Khalil Msalam and 16 17 minor Plaintiff Andrew Msalam all on the same date and represented in open court that each of 18 the depositions would take two (2) hours and that he was “very fast”. In the spirit of good faith 19 and to try and move this matter forward, I and Mr. Manuel Juarez complied with Mr. 20 Jabagchorian demands. Defense counsel has now admitted that the deposition of Julnar 21 Msalam is supposed to take over eight (8) hours. 22 23 5. Throughout the deposition, Mr. Jabagchourian repeatedly interrupted and spoke over the 24 witness Julnar Msalam. Mr. Jabagchourian 's interruptions were so pervasive and disruptive that 25 the court reporter had to interject more than once to instruct Mr. Jabagchourian not talk at the 26 same time as others. 27 28 2 Case No.: 19-CIV-02606 DECLARATION OF LIGIA M. PARMENTER IN S UPPORT OF O PPOSITION TO DEFENDANTS’ MOTION FOR A PROTECTIVE ORDER 6. During Ms. Msalam’s deposition, Mr. Jabagchourian was argumentative and aggressive 1 2 throughout the deposition. He repeatedly raised his voice and tried to browbeat Julnar Msalam. 3 7. The efforts to intimidate and bully reached a shocking crescendo when I made a request to 4 take a break before Mr. Jabagchourian asked another question. (Mr. Jabagchourian did not 5 allow for any time to elapse before Plaintiff had finished responding and before asking another 6 7 question, often times Mr. Jabagchourian interrupted the witness to ask another question.) 8 8. At this juncture, Mr. Jabagchourian, refused to allow for a break and he began mocking me 9 by demanding that I go off to use the “bathroom” while he continued questioning Julnar 10 Msalam and I was in the “bathroom”. PARMENTER@LAWPAR.COM 11 501 B STREET, STE. 200, SAN RAFAEL, CA 94901 9. Mr. Jabagchourian shouted that he was not going to be interrupted and demanded to know if 12 PARMENTER LAW OFFICES 13 my client Julnar Msalam also had to use the “bathroom” to which she responded yes. 14 10. Mr. Jabagchourian then chose to engage in threatening the Plaintiff and her counsel with 15 “prosecution” and calling Plaintiff and her counsel “liars”; that Plaintiff’s counsel was going TEL./FAX: (415) 738-7901 16 to go “coach” the Plaintiff during the break to “lie”; and that he had “caught” the Plaintiff 17 “lying”. This was all done while the court reporter continued to transcribe and is a part of the 18 19 deposition record. The deposition was suspended after Mr. Jabagchourian erupted in the above 20 hostile outbursts and serious threats. 21 11. The deposition was terminated pursuant to Code of Civil Procedure section 2025.470 to 22 protect Ms. Msalam. 23 24 12. Due to being unable to pursue any further efforts to meet and confer due to the fear of being 25 prosecuted, I immediately contacted the IDC department and requested a conference with the 26 Honorable Ernst Halperin. 27 13. Mr. Jabagchourian continued his unreasonable demands at the Initial Discovery 28 Conferences. There Mr. Jabagchourian demanded that I not be permitted to confer with 3 Case No.: 19-CIV-02606 DECLARATION OF LIGIA M. PARMENTER IN S UPPORT OF O PPOSITION TO DEFENDANTS’ MOTION FOR A PROTECTIVE ORDER 1 my client at the deposition and that any breaks will be set by him. In addition, where Mr. 2 Jabagchourian had claimed that he would be taking the depositions of Khalil Msalam, 3 Julnar Msalam and minor Plaintiff Andrew Msalam, on a single date and that each 4 deposition would take a two hours (2) period, Mr. Jabagchourian now demands an eight (8) 5 hour period for Julnar Msalam’s deposition. During the conference, Commissioner Ernst 6 A. Halerin noted Mr. Jabagchourian angry attitude and what appear to be further 7 harassment of the Plaintiff. Mr. Jabagchourian also refused to refrain from continuing to 8 ask Contention Questions at the deposition. 9 14. I prepared this Motion and the accompanying documents for Plaintiffs. I have been 10 practicing law in California for over 25 years. My hourly rate for matter such as this one is PARMENTER@LAWPAR.COM 11 $500.00 per hour. This is a reasonable hourly rate for an attorney of my years of 501 B STREET, STE. 200, SAN RAFAEL, CA 94901 12 experience practicing in the Bay Area. PARMENTER LAW OFFICES 13 15. This Opposition to the Motion brought by Defendants Ara Sarbeland, Martha Sarbeland 14 and their counsel has/will require a total of more than ten (8) hours of my time totaling 15 $4,000.00. I have spent more than eight (6) hours researching, preparing and drafting this TEL./FAX: (415) 738-7901 16 opposition to the Defendants’ motion, declarations, and proposed order. I have spent over 17 two (2) hours reviewing the Defendants’ moving documents and will be required to spend 18 additional time in reviewing any reply that may be filed by the Defendants. I will also 19 spend more hours preparing for and attending the hearing of this motion. Moreover, I will 20 spend personal time filing this motion with the Court and serving copies. Therefore, an 21 award of cost and fees to Plaintiffs of at least $4,000.00 is requested in sanctions against 22 the Defendants Ara Sarbeland, Martha Sarbeland and their counsel. 23 // 24 // 25 // 26 // 27 // 28 // 4 Case No.: 19-CIV-02606 DECLARATION OF LIGIA M. PARMENTER IN S UPPORT OF O PPOSITION TO DEFENDANTS’ MOTION FOR A PROTECTIVE ORDER I declare under penalty of perjury under the laws of the State of California that the 1 2 foregoing is true and correct and that this Declaration was executed on this 21st day of March, 3 2022, at San Rafael, California. 4 5 6 7 L.M. Parmenter 8 9 10 PARMENTER@LAWPAR.COM 11 501 B STREET, STE. 200, SAN RAFAEL, CA 94901 12 PARMENTER LAW OFFICES 13 14 15 TEL./FAX: (415) 738-7901 16 17 18 19 20 21 22 23 24 25 26 27 28 5 Case No.: 19-CIV-02606 DECLARATION OF LIGIA M. PARMENTER IN S UPPORT OF O PPOSITION TO DEFENDANTS’ MOTION FOR A PROTECTIVE ORDER 1 PROOF OF SERVICE 2 3 I, L.M. PARMENTER, am not a party to this action, I am over 18 years of age and am the attorney for the Plaintiffs Khalil Msalam, et al. herein. I declare under penalty of 4 perjury that on the below-indicated date, I served the foregoing document 5 DECLARATION OF LIGIA M. PARMENTER IN SUPPORT OF PLAINTIFFS’ 6 OPPOSITION TO DEFENDANTS’ MOTION TO COMPEL THE FURTHER DEPOSITION OF JULNAR MSALAM AND MINOR ANDREW MSALAM; AND 7 PLAINTIFFS’ REQUEST FOR SANCTIONS 8 on the parties to this action by placing a true copy thereof in a sealed envelope or package 9 addressed to the person(s) at the address(es) as set forth below and caused said envelope or package to be served in the following manner: 10 Mr. Ara Jabagchourian, Esquire Mr. Anthony E. Rodriguez, Esquire PARMENTER@LAWPAR.COM 11 LAW OFFICES of ARA Ms. Cynthia Anaya, Esquire 501 B STREET, STE. 200, SAN RAFAEL, CA 94901 12 JABAGCHOURIAN, P.C. AER LEGAL, APC PARMENTER LAW OFFICES 1650 S. Amphlett Blvd., Suite 216 Mountain View, California 13 San Mateo, CA 94402 Email: Email: ANTHONY@AERLEGAL.COM ARA@ARAJLAW.COM Email. CYNTHIA@AERLEGAL.COM 14 15 ☑ (By Electronic Mail) Pursuant to California Rules of Court, Rule 2.251(a); Code of TEL./FAX: (415) 738-7901 Civil Procedure section 1010.6(e)(1)-(2); a court order; or an agreement of the parties 16 to accept service by e-mail or electronic transmission; I caused the afore document(s) to be sent from e-mail address: (LMPARMENTER@LAWPAR.COM); to the 17 person(s)s at the e-mail address(es) listed above. I did not receive, within a reasonable 18 time after the transmission, any electronic message or other indication that the transmission was unsuccessful. 19 Executed in San Rafael, California on March 21, 2022. 20 21 22 23 L.M. Parmenter 24 25 26 27 28 6 Case No.: 19-CIV-02606 DECLARATION OF LIGIA M. PARMENTER IN S UPPORT OF O PPOSITION TO DEFENDANTS’ MOTION FOR A PROTECTIVE ORDER