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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (N e, Stale Bar names, and add J. FOR COURT USE ONLY
Nancy Hersh (SBN 49091) Montana Baker (SBN 319491)
Hersh and Harsh
601 Van Ness Ave., Ste, 2080, San Francisco, CA 94102 ELECTRONICALLY
TELEPHONE No: (415) 441 "5544 FAX No (Optional(: (41 5) 441 -7586
FILED
E.MAIL ADDRESS Superior Court of California,
County of San Francisco
plaintiffs Claudious and Patrick Williams Rodriguez
(OPfronai)'TTCRNEYFoR(Names
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San FranCISCO 03/16/2020
sTREET ADDREss: 400 McAllister Street Clerk of the Court
MAILING ADDREss. 400 McAllister Street BY: MADONNA CARANTO
Deputy Clerk
cITYANDzIPODDEr San Francisco, CA 94102
BRANCH NAME
PLAINTIFF/PETITIQNER: Claudious and Patrick Williams Rodriguez
OEFENDAINTiREspoNDENE Danielle Lane, M.D., et al.
~
CASE MANAGEMENT STATEMENT CASE NUMBER
(Check one)i (AIFj UNLIMITED CASE LIMITED CASE CGC-19-580309
(Amount demanded (Amount demanded is $ 25,000
exceeds $ 25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: April 1, 2020 Time: 10:30 a.m. Dept.: 610 Divx Room
Address of court (if different from the address above).
~ Notice of Intent to Appear by Telephone, by (name)( Montana Baker
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party parties (answer one):
or
b. ~
a. tsiyj This statement is submitted by party (name)l Plaintiffs claudious and Patrick williams Rodriguez
This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint ((o be answered by plaintiffs and cross-comp(ainants only)
b. ~
a. The complaint was filed on (date)( October 28, 2019
The cross-complaint, if any, was filed on (date)l
3. Service (to be answered by plaintiffs and cross-complainants only)
b. ~
a. LiE All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
The following parties named in the complaint or cross-complaint
(1) M
have not been served (specify names and explain why not):
(2) ~ have been served but have not appeared and have not been dismissed (specify names):
(3) ~ " have had a default entered against them (specify names):
c. ~ The following additional parties may be added (specify names, nature of involvement
they may he served):
in case, and date by which
4. Description of case
a Type of case in GLl complaint cross-complaint ~
(Describe, including causes of action):
Negligence, Failure to Obtain Informed Consent; Breach of Contract; Intentional Misrepresentation; Negligent
Misrepresentation; Fraudulent Concealment; Violations of Business and Professions Code 17200, et seq.
Pa eI ofa
FonnAdoptedfo M d tory U e CASEIIIIANAGEMENTSTATEMENT CIR Is IC rt,
Judroai Cou I I fom a
C I rules 3.120 — 3.130
CM-110 [Rev. July I, 2011( www noune oa 0 or
CM-110
CASE NUMBER.
PLAINTIFF/pETITIONER: Claudious and Patrick Williams Rodriguez
CGC-19-580309
DEFENDANT/RESPONDENT: Danielle Lane, M.D., et al.
b. Provide a brief statement of the case, including any damages. (If personal Injury damages are sought, specify the injury end
damages claimed, including medical expenses to date (indicate source and amount), estimated future medical expenses, lost
earnings to date, and estimated fulure lost earnings. If equitable relief is sought, describe the nature of the relief)
Plaintiffs engaged Defendants for fertility services, care snd treatment in order to conceive a child using a gestationei carrier.
Defendants concealed from Pisintms that the geststionsl carrier they had chosen could not act as a gestational carrier due to her pregnancy
Plaintiffs'estational
history. Based on Defendants'1srepresentations, Plaintiffs moved forward with fertility treatment with their gestetionai earner.
Defendants'egligent
carrier suffered a miscarriage and Plaintiffs'uffered severe emotional distress and economic damages due to
and intentional conduct.
space is needed, check this box and attach a page designated as Altachment 4b.)
(If more
Jury or nonjury trial
The party or parties request [i'll a jury trial
requesting a jury trial):
~
a nonjury trial. (If more than one party, provide the name of each party
Trial date
a.
b. ~
C3 The trial has been setfor (dste):
No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
c. Dates on which parties or attorneys will not be available for trial (speciyy dates and explain reasons for unavailability):
See Attachment.
Estimated length of trial
a.
b.
~
The party or parties estimate that the trial will take (check one):
~ days (specify number): 7-14 days
hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial
a. Attorney:
~ by the attorney or party listed in the caption ~ by the following:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
Preference
This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel (BZI has ~
has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party H C3
has not reviewed the ADR information package identified in rule 3.221.
has
(1) ~
b. Referral to judicial arbitration or civil action mediation (if available).
This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) ~ Plaintitf elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) ~ This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
It has a value in excess of the limits.
CM-1 10 [Rev July 1, 2011] Rag 2o1B
CASE MANAGEMENT STATEMENT
CM-110
CASE
PLAINTIFF/PETITIONER: Claudious and Patrick Williams Rodriguez NUMBER'GC-1
9-580309
EFENDANT/RESPONDENT: Danielle Lane, M.D., et al.
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check alf thai apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties'DR
processes (check all lhat apply)r stipulation):
[X3 Mediation session not yet scheduled
Mediation session scheduled for (date)r
(1) Mediation
Agreed to complete mediation by (dste):
Mediation completed on (dste):
Settlement conference not yet scheduled
Settlement conference scheduled for (date):
(2) Settlement
conference
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date)i
(4) Nonbinding judicial
arbitration Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Pdivate arbitration not yet scheduled
Private arbitration scheduled for (date):
(5) Binding pdivate
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 1R u July 1,2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
CASE NUMBER.
PLAINTIFFIPETITloNER: Claudious and Patrick Williams Rodriguez
CGC-19-580309
DEFENDANT/RESPONDENT; Danielle Lane, M,Du et al.
11. Insurance
a. ~ Insurance carrier, if any, for party filing this statement (name):
C3 H
b.
c. ~
Reservation of rights: Yes No
Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
~
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
Status:
Bankruptcy M
Other (specify):
13. Related
a ~ cases, consolidation, and coordination
There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
b.
~
C]
(4) Status:
A motion to consolidate ~
Additional cases are described in Attachment 13a.
H coordinate will be filed by (name party):
14.
~Bifurcation
The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
~
15. Other motions
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16.
a. ~
Discovery
The party or parties have completed all discovery.
b. (MFj The following discovery will be completed by the date specified (describe a/I anticipated discovery):
Para ~Descri tion Date
Plaintiff Written Discovery Ongoing
Plaintiff Deposition of Non Experts Ongoing
Plaintiff Deposition of Expert Witnesses Per Code
Plaintiff Deposition of Defendants/Defendants Agents Ongoing
c ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-1 10 IReu. July 1, 2011i P 0 4o15
CASEINANAGEMENTSTATEINENT
Cliil-1 1 0
CASE NUMBER
PLAINTIFF/PETITIQNER: Claudious and Patrick Williams Rodriguez
CGC-1 9-580309
OEFENOPNTIRFspoivoFNTI Danleile Lane, M.D., et al.
a. ~
17. Economic litigation
This is a limited civil case (i.e., the amount demanded is $ 25,000 or less) and the economic litigation procedures in Code
b ~
of Civil Procedure sections 90-98 will apply to this case.
This is a limited avil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply ia this case):
18.
~
Otherissues
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify)
19. INeet
a. ~ and confer
The party or parties have met and conferred with all parties an all subjects required by rule 3.724 of the California Rules
of Court (if not, explain):
The parties have discussed this case and intend to meet and confer further prior to any conference.
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any): 1
Iam completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: March 16, 2020
Montana Baker
ITYPE OR PRINT NAME) (SIGNATURE OF PARTY R ATTO
nYPE OR PRINT NAME)
~ (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
OM-115 IR July I, 2511] P 5 5515
Y.
CASE MANAGEMENT STATEMENT
PROOF OF SERVICE
I, SARAI CI-IICAS, declare:
I am employed in the City and County of San Francisco, California. I am over the
age of 18 years and not a party to thewithin cause; my business address is 601 Van Ness
Avenue, Suite 2080, San Francisco, California 94102-6396.
On IVlarch 16,2020,1 served: PLAINTIFFS'ASE MANAGEMENT
STATEMENT
in said action by placing a true copy thereof, enclosed in a sealed envelope addressed as
follows:
10
John Supple, Esq
Rob Deering, Esq.
Madeleire Lough-Stevens, Esq.
12 J Supple Law, PC
13 990 Fifth Avenue
San Rafael, CA 94901
14 Telephone: 415-366-5533
Fax: 415-480-6301
15 jst~t& 1c(w+sttptllelavv.corn
16 mlou+h-stevens@ su
phylllelalv.coul
17 Attorneys for Defendants
18
X (BY lMAIL) I am readily fanuhar with this business's practice for collecting and
19 processing corresponclence for mailing. On the same day that correspondence is
placed for collection and mailing, it is deposited in the ordinary course of business
20 with the United States Postal Service in a sealed envelope with postage fully prepaid
21 in San Francisco, California.
22 declare under penalty of perjury that the above is true and correct. Executed on
I
March 16, 2020, at San Francisco, California.
SARAI CHICAS
27
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (N e, Stale Bar names, and add J. FOR COURT USE ONLY Nancy Hersh (SBN 49091) Montana Baker (SBN 319491) Hersh and Harsh 601 Van Ness Ave., Ste, 2080, San Francisco, CA 94102 ELECTRONICALLY TELEPHONE No: (415) 441 "5544 FAX No (Optional(: (41 5) 441 -7586 FILED E.MAIL ADDRESS Superior Court of California, County of San Francisco plaintiffs Claudious and Patrick Williams Rodriguez (OPfronai)'TTCRNEYFoR(Names SUPERIOR COURT OF CALIFORNIA, COUNTY OF San FranCISCO 03/16/2020 sTREET ADDREss: 400 McAllister Street Clerk of the Court MAILING ADDREss. 400 McAllister Street BY: MADONNA CARANTO Deputy Clerk cITYANDzIPODDEr San Francisco, CA 94102 BRANCH NAME PLAINTIFF/PETITIQNER: Claudious and Patrick Williams Rodriguez OEFENDAINTiREspoNDENE Danielle Lane, M.D., et al. ~ CASE MANAGEMENT STATEMENT CASE NUMBER (Check one)i (AIFj UNLIMITED CASE LIMITED CASE CGC-19-580309 (Amount demanded (Amount demanded is $ 25,000 exceeds $ 25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: April 1, 2020 Time: 10:30 a.m. Dept.: 610 Divx Room Address of court (if different from the address above). ~ Notice of Intent to Appear by Telephone, by (name)( Montana Baker INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party parties (answer one): or b. ~ a. tsiyj This statement is submitted by party (name)l Plaintiffs claudious and Patrick williams Rodriguez This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint ((o be answered by plaintiffs and cross-comp(ainants only) b. ~ a. The complaint was filed on (date)( October 28, 2019 The cross-complaint, if any, was filed on (date)l 3. Service (to be answered by plaintiffs and cross-complainants only) b. ~ a. LiE All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. The following parties named in the complaint or cross-complaint (1) M have not been served (specify names and explain why not): (2) ~ have been served but have not appeared and have not been dismissed (specify names): (3) ~ " have had a default entered against them (specify names): c. ~ The following additional parties may be added (specify names, nature of involvement they may he served): in case, and date by which 4. Description of case a Type of case in GLl complaint cross-complaint ~ (Describe, including causes of action): Negligence, Failure to Obtain Informed Consent; Breach of Contract; Intentional Misrepresentation; Negligent Misrepresentation; Fraudulent Concealment; Violations of Business and Professions Code 17200, et seq. Pa eI ofa FonnAdoptedfo M d tory U e CASEIIIIANAGEMENTSTATEMENT CIR Is IC rt, Judroai Cou I I fom a C I rules 3.120 — 3.130 CM-110 [Rev. July I, 2011( www noune oa 0 or CM-110 CASE NUMBER. PLAINTIFF/pETITIONER: Claudious and Patrick Williams Rodriguez CGC-19-580309 DEFENDANT/RESPONDENT: Danielle Lane, M.D., et al. b. Provide a brief statement of the case, including any damages. (If personal Injury damages are sought, specify the injury end damages claimed, including medical expenses to date (indicate source and amount), estimated future medical expenses, lost earnings to date, and estimated fulure lost earnings. If equitable relief is sought, describe the nature of the relief) Plaintiffs engaged Defendants for fertility services, care snd treatment in order to conceive a child using a gestationei carrier. Defendants concealed from Pisintms that the geststionsl carrier they had chosen could not act as a gestational carrier due to her pregnancy Plaintiffs'estational history. Based on Defendants'1srepresentations, Plaintiffs moved forward with fertility treatment with their gestetionai earner. Defendants'egligent carrier suffered a miscarriage and Plaintiffs'uffered severe emotional distress and economic damages due to and intentional conduct. space is needed, check this box and attach a page designated as Altachment 4b.) (If more Jury or nonjury trial The party or parties request [i'll a jury trial requesting a jury trial): ~ a nonjury trial. (If more than one party, provide the name of each party Trial date a. b. ~ C3 The trial has been setfor (dste): No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (speciyy dates and explain reasons for unavailability): See Attachment. Estimated length of trial a. b. ~ The party or parties estimate that the trial will take (check one): ~ days (specify number): 7-14 days hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial a. Attorney: ~ by the attorney or party listed in the caption ~ by the following: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: Additional representation is described in Attachment 8. Preference This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel (BZI has ~ has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party H C3 has not reviewed the ADR information package identified in rule 3.221. has (1) ~ b. Referral to judicial arbitration or civil action mediation (if available). This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) ~ Plaintitf elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) ~ This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): It has a value in excess of the limits. CM-1 10 [Rev July 1, 2011] Rag 2o1B CASE MANAGEMENT STATEMENT CM-110 CASE PLAINTIFF/PETITIONER: Claudious and Patrick Williams Rodriguez NUMBER'GC-1 9-580309 EFENDANT/RESPONDENT: Danielle Lane, M.D., et al. 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check alf thai apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties'DR processes (check all lhat apply)r stipulation): [X3 Mediation session not yet scheduled Mediation session scheduled for (date)r (1) Mediation Agreed to complete mediation by (dste): Mediation completed on (dste): Settlement conference not yet scheduled Settlement conference scheduled for (date): (2) Settlement conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled Judicial arbitration scheduled for (date)i (4) Nonbinding judicial arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Pdivate arbitration not yet scheduled Private arbitration scheduled for (date): (5) Binding pdivate arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 1R u July 1,2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CASE NUMBER. PLAINTIFFIPETITloNER: Claudious and Patrick Williams Rodriguez CGC-19-580309 DEFENDANT/RESPONDENT; Danielle Lane, M,Du et al. 11. Insurance a. ~ Insurance carrier, if any, for party filing this statement (name): C3 H b. c. ~ Reservation of rights: Yes No Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction ~ Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Status: Bankruptcy M Other (specify): 13. Related a ~ cases, consolidation, and coordination There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: b. ~ C] (4) Status: A motion to consolidate ~ Additional cases are described in Attachment 13a. H coordinate will be filed by (name party): 14. ~Bifurcation The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): ~ 15. Other motions The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. a. ~ Discovery The party or parties have completed all discovery. b. (MFj The following discovery will be completed by the date specified (describe a/I anticipated discovery): Para ~Descri tion Date Plaintiff Written Discovery Ongoing Plaintiff Deposition of Non Experts Ongoing Plaintiff Deposition of Expert Witnesses Per Code Plaintiff Deposition of Defendants/Defendants Agents Ongoing c ~ The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-1 10 IReu. July 1, 2011i P 0 4o15 CASEINANAGEMENTSTATEINENT Cliil-1 1 0 CASE NUMBER PLAINTIFF/PETITIQNER: Claudious and Patrick Williams Rodriguez CGC-1 9-580309 OEFENOPNTIRFspoivoFNTI Danleile Lane, M.D., et al. a. ~ 17. Economic litigation This is a limited civil case (i.e., the amount demanded is $ 25,000 or less) and the economic litigation procedures in Code b ~ of Civil Procedure sections 90-98 will apply to this case. This is a limited avil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply ia this case): 18. ~ Otherissues The party or parties request that the following additional matters be considered or determined at the case management conference (specify) 19. INeet a. ~ and confer The party or parties have met and conferred with all parties an all subjects required by rule 3.724 of the California Rules of Court (if not, explain): The parties have discussed this case and intend to meet and confer further prior to any conference. b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 1 Iam completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: March 16, 2020 Montana Baker ITYPE OR PRINT NAME) (SIGNATURE OF PARTY R ATTO nYPE OR PRINT NAME) ~ (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. OM-115 IR July I, 2511] P 5 5515 Y. CASE MANAGEMENT STATEMENT PROOF OF SERVICE I, SARAI CI-IICAS, declare: I am employed in the City and County of San Francisco, California. I am over the age of 18 years and not a party to thewithin cause; my business address is 601 Van Ness Avenue, Suite 2080, San Francisco, California 94102-6396. On IVlarch 16,2020,1 served: PLAINTIFFS'ASE MANAGEMENT STATEMENT in said action by placing a true copy thereof, enclosed in a sealed envelope addressed as follows: 10 John Supple, Esq Rob Deering, Esq. Madeleire Lough-Stevens, Esq. 12 J Supple Law, PC 13 990 Fifth Avenue San Rafael, CA 94901 14 Telephone: 415-366-5533 Fax: 415-480-6301 15 jst~t& 1c(w+sttptllelavv.corn 16 mlou+h-stevens@ su phylllelalv.coul 17 Attorneys for Defendants 18 X (BY lMAIL) I am readily fanuhar with this business's practice for collecting and 19 processing corresponclence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business 20 with the United States Postal Service in a sealed envelope with postage fully prepaid 21 in San Francisco, California. 22 declare under penalty of perjury that the above is true and correct. Executed on I March 16, 2020, at San Francisco, California. SARAI CHICAS 27