On November 26, 2019 a
Proof of Service
was filed
involving a dispute between
Runyon, Nathan Peter,
and
Does 1-50, Inclusive,
Ng, Kaiser,
Payward, Inc., A California Corporation,
for civil
in the District Court of San Francisco County.
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1 Kimberly Pallen (SBN 288605)
kimberly.pallen@withersworldwide.com
2 Christopher N. LaVigne (NYBN 4811121) ELECTRONICALLY
(admitted Pro Hac Vice)
3 christopher.lavigne@withersworldwide.com F I L E D
Superior Court of California,
Withers Bergman LLP County of San Francisco
4 505 Sansome Street, 2nd Floor
San Francisco, California 94111 05/27/2021
Clerk of the Court
5 Telephone: 415.872.3200 BY: SANDRA SCHIRO
Facsimile: 415.549 2480 Deputy Clerk
6
Attorneys for Defendants Payward, Inc., a
7 California Corporation d/b/a Kraken; and Kaiser
Ng, an individual
8
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SAN FRANCISCO
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12 NATHAN PETER RUNYON, an individual, Case No. CGC-19-581099
13 Plaintiff, PROOF OF SERVICE
14 v.
The Hon. Ethan P. Schulman, Dept. 302
15 PAYWARD, INC., a California Corporation
d/b/a KRAKEN; and Kaiser NG, an Action Filed: November 26, 2019
16 individual; and DOES 1 through 10, inclusive, Trial Date: September 13, 2021
17 Defendants.
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W I THER S
B ERGMA N LLP
PROOF OF SERVICE
1 At the time of service, I was over 18 years of age and not a party to this action. I am
2 employed in the County of Los Angeles, State of California. My business address is 1925 Century
3 Park East, Suite 400, Los Angeles, CA 90067.
4 On May 27, 2021, I caused to be served true copies of the following document(s)
5 described as:
6  DEFENDANTS’ NOTICE OF MOTION AND MOTION TO FILE EXHIBIT
I TO THE DECLARATION OF KAISER NG IN SUPPORT OF SUMMARY
7 ADJUDICATION UNDER SEAL; MEMORANDUM OF POINTS AND
8 AUTHORITIES
 DECLARATION OF KAISER NG IN SUPPORT OF DEFENDANTS’
9 MOTION TO FILE EXHIBIT I TO THE DECLARATION OF KAISER NG
10 IN SUPPORT OF SUMMARY ADJUDICATION UNDER SEAL
 [PROPOSED] ORDER GRANTING DEFENDANTS’ MOTION TO FILE
11 EXHIBIT I TO THE DECLARATION OF KAISER NG IN SUPPORT OF
12 SUMMARY ADJUDICATION UNDER SEAL
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on the interested parties in this action as follows:
14
SEE ATTACHED SERVICE LIST
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BY ELECTRONIC SERVICE: : I served the document(s) on the persons listed in
16 the Service List as noted by submitting an electronic version of the document(s) to One Legal, LLC,
through the user interface at www.onelegal.com..
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BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
18 document(s) to be sent from e-mail address herbert.nacion@withersworldwide.com to the persons
at the e-mail addresses above. I did not receive, within a reasonable time after the transmission, any
19 electronic message or other indication that the transmission was unsuccessful.
20 I declare under penalty of perjury under the laws of the State of California that the foregoing
21 is true and correct.
22 Executed on May 27, 2021, at Los Angeles, California.
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24 Herbert Nacion
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W I THER S
B ERGMA N LLP 2
PROOF OF SERVICE
1 SERVICE LIST
2 Claire Cochran, Esq. Attorneys for Plaintiff Nathan Peter Runyon
Natalie Xifo, Esq.
3 Law Offices of Claire Cochran, PC
100 Pine Street, Suite 1250
4 San Francisco, CA 94111
Email: claire@clairecochranlegal.com ;
5 natalie@clairecochranlegal.com;
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W I THER S
B ERGMA N LLP 3
PROOF OF SERVICE
Document Filed Date
May 27, 2021
Case Filing Date
November 26, 2019
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1 Kimberly Pallen (SBN 288605) kimberly.pallen@withersworldwide.com 2 Christopher N. LaVigne (NYBN 4811121) ELECTRONICALLY (admitted Pro Hac Vice) 3 christopher.lavigne@withersworldwide.com F I L E D Superior Court of California, Withers Bergman LLP County of San Francisco 4 505 Sansome Street, 2nd Floor San Francisco, California 94111 05/27/2021 Clerk of the Court 5 Telephone: 415.872.3200 BY: SANDRA SCHIRO Facsimile: 415.549 2480 Deputy Clerk 6 Attorneys for Defendants Payward, Inc., a 7 California Corporation d/b/a Kraken; and Kaiser Ng, an individual 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN FRANCISCO 11 12 NATHAN PETER RUNYON, an individual, Case No. CGC-19-581099 13 Plaintiff, PROOF OF SERVICE 14 v. The Hon. Ethan P. Schulman, Dept. 302 15 PAYWARD, INC., a California Corporation d/b/a KRAKEN; and Kaiser NG, an Action Filed: November 26, 2019 16 individual; and DOES 1 through 10, inclusive, Trial Date: September 13, 2021 17 Defendants. 18 19 20 21 22 23 24 25 26 27 28 W I THER S B ERGMA N LLP PROOF OF SERVICE 1 At the time of service, I was over 18 years of age and not a party to this action. I am 2 employed in the County of Los Angeles, State of California. My business address is 1925 Century 3 Park East, Suite 400, Los Angeles, CA 90067. 4 On May 27, 2021, I caused to be served true copies of the following document(s) 5 described as: 6  DEFENDANTS’ NOTICE OF MOTION AND MOTION TO FILE EXHIBIT I TO THE DECLARATION OF KAISER NG IN SUPPORT OF SUMMARY 7 ADJUDICATION UNDER SEAL; MEMORANDUM OF POINTS AND 8 AUTHORITIES  DECLARATION OF KAISER NG IN SUPPORT OF DEFENDANTS’ 9 MOTION TO FILE EXHIBIT I TO THE DECLARATION OF KAISER NG 10 IN SUPPORT OF SUMMARY ADJUDICATION UNDER SEAL  [PROPOSED] ORDER GRANTING DEFENDANTS’ MOTION TO FILE 11 EXHIBIT I TO THE DECLARATION OF KAISER NG IN SUPPORT OF 12 SUMMARY ADJUDICATION UNDER SEAL 13 on the interested parties in this action as follows: 14 SEE ATTACHED SERVICE LIST 15 BY ELECTRONIC SERVICE: : I served the document(s) on the persons listed in 16 the Service List as noted by submitting an electronic version of the document(s) to One Legal, LLC, through the user interface at www.onelegal.com.. 17 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the 18 document(s) to be sent from e-mail address herbert.nacion@withersworldwide.com to the persons at the e-mail addresses above. I did not receive, within a reasonable time after the transmission, any 19 electronic message or other indication that the transmission was unsuccessful. 20 I declare under penalty of perjury under the laws of the State of California that the foregoing 21 is true and correct. 22 Executed on May 27, 2021, at Los Angeles, California. 23 24 Herbert Nacion 25 26 27 28 W I THER S B ERGMA N LLP 2 PROOF OF SERVICE 1 SERVICE LIST 2 Claire Cochran, Esq. Attorneys for Plaintiff Nathan Peter Runyon Natalie Xifo, Esq. 3 Law Offices of Claire Cochran, PC 100 Pine Street, Suite 1250 4 San Francisco, CA 94111 Email: claire@clairecochranlegal.com ; 5 natalie@clairecochranlegal.com; 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 W I THER S B ERGMA N LLP 3 PROOF OF SERVICE