Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
William A. Lapcevic (SBN 238893)
DIBENEDETTO LAPCEVIC & DRAA, LLP
1101 Pacific Ave. Suite 320
Santa Cruz, CA 95060
TELEPHONE NO.: (831) 325-2674 FAX NO.(Optional): (831) 477-7617
wal@dld-law.com
E-MAIL ADDRESS:
ATTORNEY FOR (Name): Pltf JEFFREY F. RYAN
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Mateo 3/8/2022
STREET ADDRESS: 400 County Center
MAILING ADDRESS:
CITY AND ZIP CODE:Redwood City, CA 94063
BRANCH NAME: Civil
PLAINTIFF/PETITIONER: JEFFREY F. RYAN
DEFENDANT/RESPONDENT: WILLIAM CARLOS LEET
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): ‰X UNLIMITED CASE ‰ LIMITED CASE 21-CIV-04391
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: March 21, 2022 Time: 9:00 AM Dept.: 4 34 Div.: Room:
Address of court (if different from the address above):
‰X Notice of Intent to Appear by Telephone, by (name): William A. Lapcevic
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. ‰X This statement is submitted by party (name): Plaintiff JEFFREY F. RYAN
b. ‰ This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): August 17, 2021
b. ‰X The cross-complaint, if any, was filed on (date): September 15, 2021
3. Service (to be answered by plaintiffs and cross-complainants only)
a. ‰ All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. ‰ The following parties named in the complaint or cross-complaint
(1) ‰ 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 in case, and the date by which
they may be served):
4. Description of case
a. Type of case in ‰X complaint ‰ cross-complaint (Describe, including causes of action):
Breach of Contract and Declaratory Relief
Page 1 of 5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California rules 3.720–3.730
CM-110 [Rev. September 1, 2021] www.courts.ca.gov
00471- RYAN
CM-110
PLAINTIFF/PETITIONER: JEFFREY F. RYAN CASE NUMBER:
21-CIV-04391
DEFENDANT/RESPONDENT: WILLIAM CARLOS LEET
4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
This matter arises out of a dispute related to the division of proceeds from a contingency fee legal agreement.
Plaintiff alleges Breach of Contract and Declaratory Relief; while cross-complainant alleges Fraud,
UCL Violation and Breach of Contract.
‰ (If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request ‰ a jury trial ‰X a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. ‰ The trial has been set for (date):
b. ‰X 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 (specify dates and explain reasons for unavailability):
September 6- September 21, 2022 (San Joaquin Trial),
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. ‰X days (specify number): 3-5
b. ‰ hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial ‰X by the attorney or party listed in the caption ‰ by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
‰ Additional representation is described in Attachment 8.
9. 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 of the California Rules of Court for information about the
processes available through the court and community programs in this case.
(1) For parties represented by counsel: Counsel ‰X 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 ‰ has ‰ has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) ‰ This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) ‰ Plaintiff
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):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5
00471- RYAN
CM-110
PLAINTIFF/PETITIONER: JEFFREY F. RYAN CASE NUMBER:
21-CIV-04391
DEFENDANT/RESPONDENT: WILLIAM CARLOS LEET
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 all that 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' ADR
processes (check all that apply): stipulation):
‰X Mediation session not yet scheduled
(1) Mediation ‰X ‰ Mediation session scheduled for (date):
‰ Agreed to complete mediation by (date):
‰ Mediation completed on (date):
‰X Settlement conference not yet scheduled
(2) Settlement
‰X ‰ Settlement conference scheduled for (date):
conference
‰ Agreed to complete settlement conference by (date):
‰ Settlement conference completed on (date):
‰X Neutral evaluation not yet scheduled
(3) Neutral evaluation ‰X ‰ Neutral evaluation scheduled for (date):
‰ Agreed to complete neutral evaluation by (date):
‰ Neutral evaluation completed on (date):
‰ Judicial arbitration not yet scheduled
(4) Nonbinding judicial ‰ ‰ Judicial arbitration scheduled for (date):
arbitration
‰ Agreed to complete judicial arbitration by (date):
‰ Judicial arbitration completed on (date):
‰ Private arbitration not yet scheduled
(5) Binding private ‰ ‰ Private arbitration scheduled for (date):
arbitration
‰ Agreed to complete private arbitration by (date):
‰ Private arbitration completed on (date):
‰ ADR session not yet scheduled
(6) Other (specify): ‰ ‰ ADR session scheduled for (date):
‰ Agreed to complete ADR session by (date):
‰ ADR completed on (date):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5
00471- RYAN
CM-110
PLAINTIFF/PETITIONER: JEFFREY F. RYAN CASE NUMBER:
21-CIV-04391
DEFENDANT/RESPONDENT: WILLIAM CARLOS LEET
11. Insurance
a. ‰ Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: ‰ Yes ‰ No
c. ‰ 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.
‰ Bankruptcy ‰ Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. ‰ There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
‰ Additional cases are described in Attachment 13a.
b. ‰ A motion to ‰ consolidate ‰ 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
‰X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
There is currently a Demurrer and Motion to Strike pending. Plaintiff will be filing a Motion for
Summary Judgment.
16. Discovery
a. ‰ The party or parties have completed all discovery.
b. ‰X The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiff Written Discovery June, 2022
Plaintiff Depositions September, 2022
Plaintiff Expert Witnesses Per Code
c. ‰X The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Due to the dispute arising out of an underlying legal proceeding; Plaintiff anticipates discovery issues related
attorney client privilege.
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5
00471- RYAN
CM-110
PLAINTIFF/PETITIONER: JEFFREY F. RYAN CASE NUMBER:
21-CN-04391
DEFENDANT/RESPONDENT: WILLIAM CARLOS LEET
17. Economic litigation
a. D This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. D This is a limited civil 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 to this case):
18. Other issues
D The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a. W The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of
Court (if not, explain):
b. D 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):
I am 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 8, 2022
Wi))jam A I ,apcevic
._0_.1 _ __
(TYPE OR PRINT NAME)
(TYPE OR PRINT NAME) •--------
D
(SIGNATURE OF PARTY OR ATIORNEY)
(SIGNATURE OF PARTY OR ATIORNEY)
Additional signatures are attached.
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5
•cEB"
ceb.com
I0Forms·
Essential
00471- RYAN
1 Case Name: Jeffrey F. Ryan v. William Carlos Leet
2 Case No.: 21-CV-04391
File No.:
3 PROOF OF SERVICE - CCP §1013a, 2015.5
4 I certify and declare as follows:
5
I am over the age of 18 years, and not a party to this action. My business address is
6 1101 Pacific Avenue, Suite 320, Santa Cruz, California 95060, and my email address is
dgerard@dld-law.com.
7
On the date set forth below, I served a copy of the within document:
8
PLAINTIFF JEFFREY RYAN'S CASE MANAGEMENT STATEMENT FOR CASE
9
MANAGEMENT CONFERENCE ON MARCH 31, 2022
10
on the parties in this action, by the following means:
11
X (BY MAIL) My business address is 1101 Pacific Avenue, Suite 320, Santa Cruz,
12
California 95060, which is located in the County where the mailing described took place.
13 I am readily familiar with the business practice at my place of business for collection and
processing of correspondence for mailing with the United States Postal Service.
14 Correspondence so collected and processed is deposited with the United States Postal
15
Service that same day in the ordinary course of business.
X (BY E-MAIL) My email address is dgerard@dld-law.com. I caused each such doc [ :nt
16 listed above to be delivered
mutual agreement under C.
by electronic
.
mail
10.6(e).
to the addressee(s) noted belo , pe\
17
I declare under penalty of p ·ury under the laws o the tate of California tH t the
18 foregoing is true and correct, and that t ·s declaratio was do March 8, 2022, at anta
Cruz, California.
19
20
21 PLEASE SEE ATTACHED LIST FOR NAMES AND ADDRESSES OR FAX NUMBERS OF
EACH PARTY SERVED:
22
Peter DelVecchio
23 LEETLAW
24 210 N. 4th Street, #201
San Jose, CA, 95112
25 pmd@leetlaw.com
Attorney for Defendant WILLIAM CARLOS LEET
26
27
28
CASE NO. 21-CV-04391
PROOF OF SERVICE
Page 1 ofl
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY William A. Lapcevic (SBN 238893) DIBENEDETTO LAPCEVIC & DRAA, LLP 1101 Pacific Ave. Suite 320 Santa Cruz, CA 95060 TELEPHONE NO.: (831) 325-2674 FAX NO.(Optional): (831) 477-7617 wal@dld-law.com E-MAIL ADDRESS: ATTORNEY FOR (Name): Pltf JEFFREY F. RYAN SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Mateo 3/8/2022 STREET ADDRESS: 400 County Center MAILING ADDRESS: CITY AND ZIP CODE:Redwood City, CA 94063 BRANCH NAME: Civil PLAINTIFF/PETITIONER: JEFFREY F. RYAN DEFENDANT/RESPONDENT: WILLIAM CARLOS LEET CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): ‰X UNLIMITED CASE ‰ LIMITED CASE 21-CIV-04391 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: March 21, 2022 Time: 9:00 AM Dept.: 4 34 Div.: Room: Address of court (if different from the address above): ‰X Notice of Intent to Appear by Telephone, by (name): William A. Lapcevic INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. ‰X This statement is submitted by party (name): Plaintiff JEFFREY F. RYAN b. ‰ This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): August 17, 2021 b. ‰X The cross-complaint, if any, was filed on (date): September 15, 2021 3. Service (to be answered by plaintiffs and cross-complainants only) a. ‰ All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. ‰ The following parties named in the complaint or cross-complaint (1) ‰ 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 in case, and the date by which they may be served): 4. Description of case a. Type of case in ‰X complaint ‰ cross-complaint (Describe, including causes of action): Breach of Contract and Declaratory Relief Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California rules 3.720–3.730 CM-110 [Rev. September 1, 2021] www.courts.ca.gov 00471- RYAN CM-110 PLAINTIFF/PETITIONER: JEFFREY F. RYAN CASE NUMBER: 21-CIV-04391 DEFENDANT/RESPONDENT: WILLIAM CARLOS LEET 4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) This matter arises out of a dispute related to the division of proceeds from a contingency fee legal agreement. Plaintiff alleges Breach of Contract and Declaratory Relief; while cross-complainant alleges Fraud, UCL Violation and Breach of Contract. ‰ (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request ‰ a jury trial ‰X a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. ‰ The trial has been set for (date): b. ‰X 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 (specify dates and explain reasons for unavailability): September 6- September 21, 2022 (San Joaquin Trial), 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. ‰X days (specify number): 3-5 b. ‰ hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial ‰X by the attorney or party listed in the caption ‰ by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: ‰ Additional representation is described in Attachment 8. 9. 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 of the California Rules of Court for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel ‰X 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 ‰ has ‰ has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) ‰ This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) ‰ Plaintiff 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): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5 00471- RYAN CM-110 PLAINTIFF/PETITIONER: JEFFREY F. RYAN CASE NUMBER: 21-CIV-04391 DEFENDANT/RESPONDENT: WILLIAM CARLOS LEET 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 all that 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' ADR processes (check all that apply): stipulation): ‰X Mediation session not yet scheduled (1) Mediation ‰X ‰ Mediation session scheduled for (date): ‰ Agreed to complete mediation by (date): ‰ Mediation completed on (date): ‰X Settlement conference not yet scheduled (2) Settlement ‰X ‰ Settlement conference scheduled for (date): conference ‰ Agreed to complete settlement conference by (date): ‰ Settlement conference completed on (date): ‰X Neutral evaluation not yet scheduled (3) Neutral evaluation ‰X ‰ Neutral evaluation scheduled for (date): ‰ Agreed to complete neutral evaluation by (date): ‰ Neutral evaluation completed on (date): ‰ Judicial arbitration not yet scheduled (4) Nonbinding judicial ‰ ‰ Judicial arbitration scheduled for (date): arbitration ‰ Agreed to complete judicial arbitration by (date): ‰ Judicial arbitration completed on (date): ‰ Private arbitration not yet scheduled (5) Binding private ‰ ‰ Private arbitration scheduled for (date): arbitration ‰ Agreed to complete private arbitration by (date): ‰ Private arbitration completed on (date): ‰ ADR session not yet scheduled (6) Other (specify): ‰ ‰ ADR session scheduled for (date): ‰ Agreed to complete ADR session by (date): ‰ ADR completed on (date): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5 00471- RYAN CM-110 PLAINTIFF/PETITIONER: JEFFREY F. RYAN CASE NUMBER: 21-CIV-04391 DEFENDANT/RESPONDENT: WILLIAM CARLOS LEET 11. Insurance a. ‰ Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: ‰ Yes ‰ No c. ‰ 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. ‰ Bankruptcy ‰ Other (specify): Status: 13. Related cases, consolidation, and coordination a. ‰ There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: ‰ Additional cases are described in Attachment 13a. b. ‰ A motion to ‰ consolidate ‰ 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 ‰X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): There is currently a Demurrer and Motion to Strike pending. Plaintiff will be filing a Motion for Summary Judgment. 16. Discovery a. ‰ The party or parties have completed all discovery. b. ‰X The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Plaintiff Written Discovery June, 2022 Plaintiff Depositions September, 2022 Plaintiff Expert Witnesses Per Code c. ‰X The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): Due to the dispute arising out of an underlying legal proceeding; Plaintiff anticipates discovery issues related attorney client privilege. CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5 00471- RYAN CM-110 PLAINTIFF/PETITIONER: JEFFREY F. RYAN CASE NUMBER: 21-CN-04391 DEFENDANT/RESPONDENT: WILLIAM CARLOS LEET 17. Economic litigation a. D This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. D This is a limited civil 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 to this case): 18. Other issues D The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. W The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. D 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): I am 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 8, 2022 Wi))jam A I ,apcevic ._0_.1 _ __ (TYPE OR PRINT NAME) (TYPE OR PRINT NAME) •-------- D (SIGNATURE OF PARTY OR ATIORNEY) (SIGNATURE OF PARTY OR ATIORNEY) Additional signatures are attached. CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5 •cEB" ceb.com I0Forms· Essential 00471- RYAN 1 Case Name: Jeffrey F. Ryan v. William Carlos Leet 2 Case No.: 21-CV-04391 File No.: 3 PROOF OF SERVICE - CCP §1013a, 2015.5 4 I certify and declare as follows: 5 I am over the age of 18 years, and not a party to this action. My business address is 6 1101 Pacific Avenue, Suite 320, Santa Cruz, California 95060, and my email address is dgerard@dld-law.com. 7 On the date set forth below, I served a copy of the within document: 8 PLAINTIFF JEFFREY RYAN'S CASE MANAGEMENT STATEMENT FOR CASE 9 MANAGEMENT CONFERENCE ON MARCH 31, 2022 10 on the parties in this action, by the following means: 11 X (BY MAIL) My business address is 1101 Pacific Avenue, Suite 320, Santa Cruz, 12 California 95060, which is located in the County where the mailing described took place. 13 I am readily familiar with the business practice at my place of business for collection and processing of correspondence for mailing with the United States Postal Service. 14 Correspondence so collected and processed is deposited with the United States Postal 15 Service that same day in the ordinary course of business. X (BY E-MAIL) My email address is dgerard@dld-law.com. I caused each such doc [ :nt 16 listed above to be delivered mutual agreement under C. by electronic . mail 10.6(e). to the addressee(s) noted belo , pe\ 17 I declare under penalty of p ·ury under the laws o the tate of California tH t the 18 foregoing is true and correct, and that t ·s declaratio was do March 8, 2022, at anta Cruz, California. 19 20 21 PLEASE SEE ATTACHED LIST FOR NAMES AND ADDRESSES OR FAX NUMBERS OF EACH PARTY SERVED: 22 Peter DelVecchio 23 LEETLAW 24 210 N. 4th Street, #201 San Jose, CA, 95112 25 pmd@leetlaw.com Attorney for Defendant WILLIAM CARLOS LEET 26 27 28 CASE NO. 21-CV-04391 PROOF OF SERVICE Page 1 ofl