Preview
CM-110
ATTORNEY OR PARTY INITHOUT ATTORNEY IName, State Bar number, and addmssj
FOR COURT USE ONLY
J.T. Wells Blaxter (SBN 190222), David P. Adams (SBN 312003)
Blaxter I
Blackman LLP
601 Montgomery Street, Suite 1110
San Francisco, CA 94111
TELEPHONE NO. (415) 500-7700 FAX NOfopbonalj
wblaxter@blaxterlaw.corn;
E-MAILADDREss foplionag dadamsgblaxterlaw.corn
Defendant Whole Foods Market California,
ATTQRNEY FQR IName) Inc.
sUPERIQR coURT QF GALIFQRNIA, coUNTY QF Sett ta Ci'Uz
sTREETADDREss 701 Ocean Street
MAILING ADDRESS
cITYAND zip coDESanta Cruz, CA 95060
BRANOH NAME Santa Cruz Courthouse
PLAINTIFF/PETITIQNER; Lena Elizabeth Brownridge
DEFENDANT/REsPQNDENT: Whole Foods Market California, Inc.
CASE MANAGEMENT STATEMENT CASE NUMBER
(Check one): H UNLIMITED CASE LIMITED CASE
21CV01900
(Amount demanded (Amount demanded is $ 25,000
exceeds $ 25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date; September 13, 2022 Time: 8.30 AM Dept.: 5 D IU Z Room:
Address of court (if different from the address above):
H Notice of Intent to Appear by Telephone, by (name)j J.T. Wells Blaxter
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. H This statement is submitted by party (name): Defendant Whole Foods Market California, Inc.
b. This statement is submitted jointly by parties (nsmes):
2. Complaint and cross-complaint (lo be answered by plaintiffs and cross-complsfnants only)
a. The complaint was filed on (date):
b. The cross-complaint, if any, was filed on (dale):
3. Service (to bs answered by plaintiffs end cross-complainsnts 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 nol)j
(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 date by which
they mey be served):
4. Description of case
a. Type of case in Zl complaint cross-complaint (Describe, including causes of action):
This is a personal injury case in which Plaintiff alleges premises liability and negligence causes of action.
PaceIof 3
Form Adopted for Mandatory Use
J d mal Counal of California CASE MANAGEMENT STATEMENT Cal Rules of Court,
rules 3 720-3 730
CM-110 [Rev July I, 2011)
[
A
'":""
c
www courts ca go
LraIN l,l u
CM-110
PLAINTIFF/PETITIONER: Lena Elizabeth Brownridge CASE NUMBER
t DEFENDANT/RESPONDENT: Whole Foods Market California,
b.
Inc.
21CV01900
Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages claimed, inc/udkng medical expenses to date (ind/cate source and amount), estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. /f equitable relief is sought,
descn'be the nature cf the relief)
On August 20, 2019, Plaintiff allegedly slipped and fell while shopping at Whole Foods Market in Santa Cruz,
California. Plaintiff alleges resultinginjuries to her neck, low back and right shoulder in addition to vertigo. Plaintiff
seeks damages for hospital and medical expenses, wage loss, possible future wage loss, loss of earning capacity
and general damages.
(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 H a jury trial a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a. The trial has been set for (date):
b. Ej 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 (spec//y dates and explain reasons for unavai/ability):
Trials: 1/23/23; 1/27/23; 1/30/23, 2/6/23; 2/24/23; 2/27/23; 5/16/23; 5/30/23; 5/31/23; 8/14/23; 9/24/23
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. H days (spec/fy number): 5
b. hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trialH by the attorney or party listedinthe 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 inAttachment 8.
Preference
This case is entitled to preference (spec/fy 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 partiesrepresented by counsel: Counsel Ej has has not provided the ADR information package identified
inrule 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 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
CivilProcedure 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 (spec//y exemption):
CM-110 IRov July 1, 2011l
CASE MANAGEMENT STATEMENT POBO 2 Of 5
0 gelxel.
I e.
Q)
1
[Am
CM-110
PLAINTIFF/PETITIONER: Lena Elizabeth Brownridge CASE NUMBER
l
DEFENDANT/RESPONDENT: Whole Foods Market California, Inc.
21CV01900
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 a/I 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 oi the parlies'DR
processes (check a/i that apply): stipulation):
Ej Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement
Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (dale):
Settlement conference completed on (dale):
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
(4) Nonbinding judicial
Judicial arbitration scheduled for (date)r
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Pnvate arbitration not yet scheduled
(5) Binding private
Private arbitration scheduled for (date):
arbitration
Agreed to complete private arbitration by (daie):
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 [Reu July \, 201fl page 3 of 3
CASE MANAGEMENT STATEMENT
(=--: '-"::-"-O)
CM-110
t
CASE NUMBER
PLAINTIFF/PETITIQNER: Lena Elizabeth Brownridge
21CV01900
DEFENDANT/REsPQNDENT: Whole Foods Market California, Inc.
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Q 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:
P Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate willbe filed by (name party):
14. Bifurcation
The party or parties intend to file a motion for an order bifurcating, severiing, or coordinating the following issues or causes of
action (speci/y moving party, type of motion,and reasons):
15. Other motions
The parly or parties expect to file the following motions before trial (specify mov/ng party, type of motion, and issues):
16. Discovery
a. The party or parties have completed all discovery.
b H The following discovery will be completed by the date specified (describe a// anticipated discovery)/
~Part Description Date
Defendant Written discovery October 2022
Defendant Plaintiffs deposition November 2022
Defendant Expert witness discovery per code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 IReu July 1, 2011I
CASE MANAGEMENT STATEMENT Page 4 of 5
CM-110
Lena Elizabeth
t Brownridge
PLAINTIFF/PETITIQNER. CASE NUMBER
21CV01900
DEFENDANT/REsPQNDENT: Whole Foods Market California, Inc.
17. Economic litigation
a. This is a l(m(ted 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. 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 specifica/ly why economic litigation procedures relating lo discovery or trial
should nof apply io 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. Meet and confer
a. El The party or parties have met and conferred with all parties on
allsubjects required by rule 3.724 of the California Rules of
Court (if nof, explain):
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):
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 authonty to enter into stipulations on these issues at the time of
the case management conference, including the written authonty of the party where required.
Date. August 29, 2022
J.T. Wells Blaxter
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev July I, 20( II
CASE MANAGEMENT STATEMENT Page 0 ei
0
('=:'---"'-"-e)
PROOF OF SERVICE
I am employed in the City and County of San Francisco, State of California. I am over the age of 18
and not a party to the within action; my business address is: BLAXTER I
BLACKMAN LLP, 601
Montgomery Street, Suite 1110, San Francisco, California 94111.
On August 29, 2022, I served the following document(s):
4
~ DEFENDANT WHOLE FOODS MARKET CALIFORNIA, INC.'S CASK
MANAGEMENT STATEMENT
The foregoing documents were served by the following means:
7 (BY U.S. MAIL) I enclosed the documents in a sealed envelope or package addressed to the
person(s) listed below and placed the envelope for collection and mailing following our
8 ordinary business practices. I am "readily familiar" with the firm's practice for collection
and processing correspondence for mailing. Under that practice, it would be deposited with
the U.S. Postal Service on that same day with postage thereon fully prepaid at San
Francisco, California in the ordinary course of business.
10
(BY OVERNIGHT DELIVERY) I enclosed the documents in an envelope or package
11 provided by an overnight delivery carrier to the person(s) listed below at the corresponding
address(es). I placed the envelope or package for collection and overnight delivery at an
12 office or regularly utilized pick-up location utilized by the overnight carrier.
13 (BY EMAIL) I caused the documents to be sent to the person(s) listed below at the
corresponding email address(es). I did not receive, within a reasonable time after the
14 transmission, any electronic message or other indication that the transmission was
unsuccessful.
15
(BY E-SERVICE) I E-served the above-described document(s) using One Legal to the
person(s) listed below at the corresponding email(s) provided by Plaintiff s counsel. I did
not receive, within a reasonable time after the transmission, any electronic message or other
17 indication that the transmission was unsuccessful.
18 (BY MESSENGER SERVICE) I served the documents by placing them in an envelope or
package addressed to the person(s) listed below at the corresponding address(es) and
19 providing them to a professional messenger service for delivery. A Declaration of
Messen p er is set forth below.
20
Executed on August 29, 2022, at San Francisco, California.
21
I declare under penalty of perjury under the laws of the State of California that the above is true and
correct. I declare that I am employed in the office of a member of the bar of this court at whose
direction the service was made.
23
Et'(na J. Hart
25
26
27
28 PROOF OF SERVICE
Case No. 21CV01900
SERVICE LIST
Dan L. Rainsbury
RAIN SBURY LAW GROUP
1024 Iron Point Road
Folsom, CA 95630
drainsbury@rainsburylaw.corn
Counsel for Plaintiff
LENA ELIZABETH BROWNRIDGE
10
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28 PROOF OF SERVICE
Case No. 21CV01900
Preview
CM-110 ATTORNEY OR PARTY INITHOUT ATTORNEY IName, State Bar number, and addmssj FOR COURT USE ONLY J.T. Wells Blaxter (SBN 190222), David P. Adams (SBN 312003) Blaxter I Blackman LLP 601 Montgomery Street, Suite 1110 San Francisco, CA 94111 TELEPHONE NO. (415) 500-7700 FAX NOfopbonalj wblaxter@blaxterlaw.corn; E-MAILADDREss foplionag dadamsgblaxterlaw.corn Defendant Whole Foods Market California, ATTQRNEY FQR IName) Inc. sUPERIQR coURT QF GALIFQRNIA, coUNTY QF Sett ta Ci'Uz sTREETADDREss 701 Ocean Street MAILING ADDRESS cITYAND zip coDESanta Cruz, CA 95060 BRANOH NAME Santa Cruz Courthouse PLAINTIFF/PETITIQNER; Lena Elizabeth Brownridge DEFENDANT/REsPQNDENT: Whole Foods Market California, Inc. CASE MANAGEMENT STATEMENT CASE NUMBER (Check one): H UNLIMITED CASE LIMITED CASE 21CV01900 (Amount demanded (Amount demanded is $ 25,000 exceeds $ 25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date; September 13, 2022 Time: 8.30 AM Dept.: 5 D IU Z Room: Address of court (if different from the address above): H Notice of Intent to Appear by Telephone, by (name)j J.T. Wells Blaxter INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. H This statement is submitted by party (name): Defendant Whole Foods Market California, Inc. b. This statement is submitted jointly by parties (nsmes): 2. Complaint and cross-complaint (lo be answered by plaintiffs and cross-complsfnants only) a. The complaint was filed on (date): b. The cross-complaint, if any, was filed on (dale): 3. Service (to bs answered by plaintiffs end cross-complainsnts 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 nol)j (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 date by which they mey be served): 4. Description of case a. Type of case in Zl complaint cross-complaint (Describe, including causes of action): This is a personal injury case in which Plaintiff alleges premises liability and negligence causes of action. PaceIof 3 Form Adopted for Mandatory Use J d mal Counal of California CASE MANAGEMENT STATEMENT Cal Rules of Court, rules 3 720-3 730 CM-110 [Rev July I, 2011) [ A '":"" c www courts ca go LraIN l,l u CM-110 PLAINTIFF/PETITIONER: Lena Elizabeth Brownridge CASE NUMBER t DEFENDANT/RESPONDENT: Whole Foods Market California, b. Inc. 21CV01900 Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, inc/udkng medical expenses to date (ind/cate source and amount), estimated future medical expenses, lost earnings to date, and estimated future lost earnings. /f equitable relief is sought, descn'be the nature cf the relief) On August 20, 2019, Plaintiff allegedly slipped and fell while shopping at Whole Foods Market in Santa Cruz, California. Plaintiff alleges resultinginjuries to her neck, low back and right shoulder in addition to vertigo. Plaintiff seeks damages for hospital and medical expenses, wage loss, possible future wage loss, loss of earning capacity and general damages. (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 H a jury trial a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a. The trial has been set for (date): b. Ej 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 (spec//y dates and explain reasons for unavai/ability): Trials: 1/23/23; 1/27/23; 1/30/23, 2/6/23; 2/24/23; 2/27/23; 5/16/23; 5/30/23; 5/31/23; 8/14/23; 9/24/23 Estimated length of trial The party or parties estimate that the trial will take (check one): a. H days (spec/fy number): 5 b. hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trialH by the attorney or party listedinthe 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 inAttachment 8. Preference This case is entitled to preference (spec/fy 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 partiesrepresented by counsel: Counsel Ej has has not provided the ADR information package identified inrule 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 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 CivilProcedure 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 (spec//y exemption): CM-110 IRov July 1, 2011l CASE MANAGEMENT STATEMENT POBO 2 Of 5 0 gelxel. I e. Q) 1 [Am CM-110 PLAINTIFF/PETITIONER: Lena Elizabeth Brownridge CASE NUMBER l DEFENDANT/RESPONDENT: Whole Foods Market California, Inc. 21CV01900 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 a/I 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 oi the parlies'DR processes (check a/i that apply): stipulation): Ej Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (dale): Settlement conference completed on (dale): 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 (4) Nonbinding judicial Judicial arbitration scheduled for (date)r arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Pnvate arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (daie): 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 [Reu July \, 201fl page 3 of 3 CASE MANAGEMENT STATEMENT (=--: '-"::-"-O) CM-110 t CASE NUMBER PLAINTIFF/PETITIQNER: Lena Elizabeth Brownridge 21CV01900 DEFENDANT/REsPQNDENT: Whole Foods Market California, Inc. 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Q 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: P Additional cases are described in Attachment 13a. b. A motion to consolidate coordinate willbe filed by (name party): 14. Bifurcation The party or parties intend to file a motion for an order bifurcating, severiing, or coordinating the following issues or causes of action (speci/y moving party, type of motion,and reasons): 15. Other motions The parly or parties expect to file the following motions before trial (specify mov/ng party, type of motion, and issues): 16. Discovery a. The party or parties have completed all discovery. b H The following discovery will be completed by the date specified (describe a// anticipated discovery)/ ~Part Description Date Defendant Written discovery October 2022 Defendant Plaintiffs deposition November 2022 Defendant Expert witness discovery per code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 IReu July 1, 2011I CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 Lena Elizabeth t Brownridge PLAINTIFF/PETITIQNER. CASE NUMBER 21CV01900 DEFENDANT/REsPQNDENT: Whole Foods Market California, Inc. 17. Economic litigation a. This is a l(m(ted 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. 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 specifica/ly why economic litigation procedures relating lo discovery or trial should nof apply io 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. Meet and confer a. El The party or parties have met and conferred with all parties on allsubjects required by rule 3.724 of the California Rules of Court (if nof, explain): 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): 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 authonty to enter into stipulations on these issues at the time of the case management conference, including the written authonty of the party where required. Date. August 29, 2022 J.T. Wells Blaxter (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev July I, 20( II CASE MANAGEMENT STATEMENT Page 0 ei 0 ('=:'---"'-"-e) PROOF OF SERVICE I am employed in the City and County of San Francisco, State of California. I am over the age of 18 and not a party to the within action; my business address is: BLAXTER I BLACKMAN LLP, 601 Montgomery Street, Suite 1110, San Francisco, California 94111. On August 29, 2022, I served the following document(s): 4 ~ DEFENDANT WHOLE FOODS MARKET CALIFORNIA, INC.'S CASK MANAGEMENT STATEMENT The foregoing documents were served by the following means: 7 (BY U.S. MAIL) I enclosed the documents in a sealed envelope or package addressed to the person(s) listed below and placed the envelope for collection and mailing following our 8 ordinary business practices. I am "readily familiar" with the firm's practice for collection and processing correspondence for mailing. Under that practice, it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at San Francisco, California in the ordinary course of business. 10 (BY OVERNIGHT DELIVERY) I enclosed the documents in an envelope or package 11 provided by an overnight delivery carrier to the person(s) listed below at the corresponding address(es). I placed the envelope or package for collection and overnight delivery at an 12 office or regularly utilized pick-up location utilized by the overnight carrier. 13 (BY EMAIL) I caused the documents to be sent to the person(s) listed below at the corresponding email address(es). I did not receive, within a reasonable time after the 14 transmission, any electronic message or other indication that the transmission was unsuccessful. 15 (BY E-SERVICE) I E-served the above-described document(s) using One Legal to the person(s) listed below at the corresponding email(s) provided by Plaintiff s counsel. I did not receive, within a reasonable time after the transmission, any electronic message or other 17 indication that the transmission was unsuccessful. 18 (BY MESSENGER SERVICE) I served the documents by placing them in an envelope or package addressed to the person(s) listed below at the corresponding address(es) and 19 providing them to a professional messenger service for delivery. A Declaration of Messen p er is set forth below. 20 Executed on August 29, 2022, at San Francisco, California. 21 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. 23 Et'(na J. Hart 25 26 27 28 PROOF OF SERVICE Case No. 21CV01900 SERVICE LIST Dan L. Rainsbury RAIN SBURY LAW GROUP 1024 Iron Point Road Folsom, CA 95630 drainsbury@rainsburylaw.corn Counsel for Plaintiff LENA ELIZABETH BROWNRIDGE 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE Case No. 21CV01900