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 05/10/2021
Clerk of the Court
5 Telephone: 415.872.3200 BY: EDWARD SANTOS
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 At the time of service, I was over 18 years of age and not a party to this action. I am
22 employed in the County of San Diego, State of California. My business address is 101 West
23 Broadway, Suite 1000, San Diego, CA 92101.
24 On May 10, 2021, I caused to be served true copies of the following document(s)
25 described as:
26  DEFENDANTS PAYWARD, INC. D/B/A KRAKEN’S AND KAISER NG’S
REPLY TO EMPLOYEE 5’S AND NATHAN PETER RUNYON’S
27 OPPOSITION TO MOTION TO COMPEL DEPOSITION OF WITNESS
AND FOR SANCTIONS;
28
W ITHERS
B ERGMAN LLP
PROOF OF SERVICE
1 ï‚· DECLARATION OF CHRISTOPHER LAVIGNE IN SUPPORT OF
DEFENDANTS’ REPLY TO EMPLOYEE 5’S AND NATHAN PETER
2 RUNYON’S OPPOSITION TO MOTION TO COMPEL DEPOSITION OF
3 WITNESS AND FOR SANCTIONS.
4 on the interested parties in this action as follows:
5 Claire Cochran, Esq. Attorneys for Plaintiff Nathan Peter Runyon
Natalie Xifo, Esq.
6 Maya Sørensen, Esq.
Law Offices of Claire Cochran, PC
7 100 Pine Street, Suite 1250
San Francisco, CA 94111
8 Email: claire@clairecochran.com;
natalie@clairecochranlegal.com;
9 maya@clairecochranlegal.com
10 Brendan M. Ford, Esq. Attorney for Third-Party Witness
Partner, Ford & Diulio PC
11 650 Town Center Drive, Suite 760
Costa Mesa, California 92626
12 Email: BFord@FordDiulio.com
13
BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
14 document(s) to be sent from e-mail address barbara.lodovice@withersworldwide.com to the
persons at the e-mail addresses above. I did not receive, within a reasonable time after the
15 transmission, any electronic message or other indication that the transmission was unsuccessful.
16 I declare under penalty of perjury under the laws of the State of California that the foregoing
17 is true and correct.
18 Executed on May 10, 2021, at San Diego, California.
19
20
Barbara Lodovice
21
22
23
24
25
26
27
28
W ITHERS
B ERGMAN LLP 2
PROOF OF SERVICE
Document Filed Date
May 10, 2021
Case Filing Date
November 26, 2019
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Preview
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 05/10/2021 Clerk of the Court 5 Telephone: 415.872.3200 BY: EDWARD SANTOS 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 At the time of service, I was over 18 years of age and not a party to this action. I am 22 employed in the County of San Diego, State of California. My business address is 101 West 23 Broadway, Suite 1000, San Diego, CA 92101. 24 On May 10, 2021, I caused to be served true copies of the following document(s) 25 described as: 26  DEFENDANTS PAYWARD, INC. D/B/A KRAKEN’S AND KAISER NG’S REPLY TO EMPLOYEE 5’S AND NATHAN PETER RUNYON’S 27 OPPOSITION TO MOTION TO COMPEL DEPOSITION OF WITNESS AND FOR SANCTIONS; 28 W ITHERS B ERGMAN LLP PROOF OF SERVICE 1  DECLARATION OF CHRISTOPHER LAVIGNE IN SUPPORT OF DEFENDANTS’ REPLY TO EMPLOYEE 5’S AND NATHAN PETER 2 RUNYON’S OPPOSITION TO MOTION TO COMPEL DEPOSITION OF 3 WITNESS AND FOR SANCTIONS. 4 on the interested parties in this action as follows: 5 Claire Cochran, Esq. Attorneys for Plaintiff Nathan Peter Runyon Natalie Xifo, Esq. 6 Maya Sørensen, Esq. Law Offices of Claire Cochran, PC 7 100 Pine Street, Suite 1250 San Francisco, CA 94111 8 Email: claire@clairecochran.com; natalie@clairecochranlegal.com; 9 maya@clairecochranlegal.com 10 Brendan M. Ford, Esq. Attorney for Third-Party Witness Partner, Ford & Diulio PC 11 650 Town Center Drive, Suite 760 Costa Mesa, California 92626 12 Email: BFord@FordDiulio.com 13 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the 14 document(s) to be sent from e-mail address barbara.lodovice@withersworldwide.com to the persons at the e-mail addresses above. I did not receive, within a reasonable time after the 15 transmission, any electronic message or other indication that the transmission was unsuccessful. 16 I declare under penalty of perjury under the laws of the State of California that the foregoing 17 is true and correct. 18 Executed on May 10, 2021, at San Diego, California. 19 20 Barbara Lodovice 21 22 23 24 25 26 27 28 W ITHERS B ERGMAN LLP 2 PROOF OF SERVICE