Preview
1 Bradford G. Hughes, Esq., SBN 247141
Erin Chance, Esq., SBN 331431
2 CLARK HILL LLP
555 South Flower Street, 24th Floor
3 Los Angeles, CA 90071
Telephone: (213) 891-9100
4 Facsimile: (213) 488-1178
BHughes@ClarkHill.com
5 EChance@ClarkHill.com
6 Attorneys for Defendant
FREEDOM MEDICAL TRANSPORTATION, LLC
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF MONTEREY
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11 ROBERT MOSQUEDA, an individual, Case No. 22CV002878
12 Plaintiff, DEFENDANT FREEDOM MEDICAL
TRANSPORTATION, LLC’S ANSWER TO
13 v. PLAINTIFF’S COMPLAINT FOR
DAMAGES AND DEMAND FOR JURY
14 FREEDOM MEDICAL TRANSPORTATION, TRIAL
LLC, a corporation; GABRIELA GONZALEZ
15 BLAS, an individual; and DOES 1 through 50, Assigned to: Hon. Carrie M. Panetta
inclusive, Dept.: 14
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Defendants. Complaint Filed: September 27, 2022
17 Trial Date: Not Set
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20 Defendant FREEDOM MEDICAL TRANSPORTATION, LLC’S, (“Defendant”) answers
21 Plaintiff ROBERT MOSQUEDA’S (“Plaintiff”) Complaint, as follows:
22 GENERAL DENIAL
23 1. Pursuant to the provisions of section 431.30(d) of the California Code of Civil
24 Procedure, answering defendant denies each, every and all of the allegations in the Complaint, and
25 all of it, and deny that plaintiff has or will sustain damage in the sum or sums alleged, or in any other
26 sum, or sums at all.
27 2. Further answering plaintiff's Complaint, each and every cause of action contained in it,
28 and all of it, answering defendant denies that plaintiff has or will sustain any injury, damage or loss, if
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DEFENDANT FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO PLAINTIFF’S COMPLAINT FOR
DAMAGES AND DEMAND FOR JURY TRIAL
1 any, by reason of any act or omission on the part of this.
2 FIRST AFFIRMATIVE DEFENSE
3 3. The Complaint, each and every cause of action contained in it, and all of it, fails to
4 state facts sufficient to constitute a cause of action against the answering Defendant.
5 SECOND AFFIRMATIVE DEFENSE
6 4. Defendant is informed and believes, and on that basis allege, that Plaintiff’s claims are
7 barred in whole or in part by the doctrine of waiver.
8 THIRD AFFIRMATIVE DEFENSE
9 5. Plaintiff’s own conduct, or the conduct of other entities and individuals, whether or not
10 parties to this action, caused or contributed to Plaintiff’s alleged injuries and damages. This conduct
11 comparatively reduces any percentage of liability attributed to the answering Defendant, if it should
12 be found that the Defendant is liable, which the answering Defendant expressly denies.
13 FOURTH AFFIRMATIVE DEFENSE
14 6. That immediately prior to the occurrence of the incident referred to in the Complaint
15 herein, the Plaintiff failed to use and exercise caution for their own protection and safety in that,
16 among other things, Plaintiff freely and voluntarily placed themselves in a position so as to be
17 exposed to a likelihood of injury, and that at the time and place of said accident, Plaintiff was fully
18 aware of the dangers incident thereto and continued to freely and voluntarily expose themselves to
19 same, and thereby assumed the risk thereof, and in having assumed the risk, is therefore barred by the
20 assumption of the risk for any recovery herein or the applicable abatement of such recovery, if any,
21 herein.
22 FIFTH AFFIRMATIVE DEFENSE
23 7. That if Plaintiff sustained any injuries or damages as a result of the accident or
24 incident complained of herein, then Plaintiff proximately caused, aggravated, and/or failed to take
25 proper action to reduce and/or mitigate said injuries and damages.
26 SIXTH AFFIRMATIVE DEFENSE
27 8. The answering Defendant’s conduct was not a substantial factor in causing Plaintiff’s
28 alleged injuries, and/or public policy(ies) otherwise limit Defendant’s liability for the alleged injuries,
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DEFENDANT FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO PLAINTIFF’S COMPLAINT FOR
DAMAGES AND DEMAND FOR JURY TRIAL
1 which liability Defendant denies. Accordingly, the answering Defendant’s conduct was not a
2 proximate cause of Plaintiff’s alleged injuries, and Defendant cannot be held liable for such.
3 SEVENTH AFFIRMATIVE DEFENSE
4 9. The answering Defendant is informed and believes, and thereon allege, that the
5 injuries and damages alleged to have been suffered by Plaintiff in the Complaint herein, if any, were
6 proximately caused or contributed to by the acts or omissions of third parties other than the answering
7 Defendant. It is thus necessary that the proportion or degree of negligence or fault of each of said
8 persons or entities, whether parties to this action or not, be judicially determined and that any
9 judgment that might be rendered against the answering Defendant be reduced in proportion to the
10 degree of fault attributed to each and every third person or entity found liable to Plaintiff herein. As
11 against each such third person or entity, whether served or not served in this action, whose acts or
12 omissions are found to have proximately caused or contributed in any fashion to the injuries, if any,
13 alleged to have been suffered by Plaintiff herein, the answering Defendant reserves the right to cross
14 complain and/or move for judgment against each such person or entity.
15 EIGHTH AFFIRMATIVE DEFENSE
16 10. In the event that the answering Defendant is found to be liable, which supposition is
17 denied and merely stated for the purpose of this affirmative defense, the answering Defendant
18 contend that their liability, if any, for non-economic damages shall be several, and not joint, pursuant
19 to the Fair Responsibility Act of 1986, section 1431 et seq., of the California Civil Code, so that the
20 answering Defendant shall be liable, if at all, only for that amount of non-economic damages
21 allocated to the Defendant by the trier of fact, if any, in direct proportion to the percentage of fault, if
22 any, assessed against the Defendant, and a separate judgment rendered against each Defendant in that
23 amount for non-economic damages, if any.
24 NINTH AFFIRMATIVE DEFENSE
25 11. That any damages sustained by Plaintiff was the result of a superseding intervening
26 causation by an independent and unforeseeable force which broke the claim of causation.
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DEFENDANT FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO PLAINTIFF’S COMPLAINT FOR
DAMAGES AND DEMAND FOR JURY TRIAL
1 TENTH AFFIRMATIVE DEFENSE
2 12. Answering Defendant is informed and believes, and thereon allege, that at the time of
3 the accident Plaintiff was not insured and/or could not establish financial responsibility as required by
4 the financial responsibility laws of the State of California. Therefore, pursuant to the provisions of
5 California Civil Code section 3333.4, Plaintiff is barred from recovering any non-economic damages.
6 ELEVENTH AFFIRMATIVE DEFENSE
7 13. Plaintiff failed to exercise reasonable and ordinary care, caution, or prudence in his
8 safety in order to avoid the alleged incident. The resulting injuries and damages, if any, sustained by
9 Plaintiff was proximately caused and contributed to by the negligence of Plaintiff.
10 TWELFTH AFFIRMATIVE DEFENSE
11 14. Answering Defendant is informed and believes, and on that basis allege, that Plaintiff,
12 by Plaintiff’s acts and conduct, is estopped from alleging any and all claims as asserted in the
13 Complaint.
14 THIRTEENTH AFFIRMATIVE DEFENSE
15 15. Answering Defendant is informed and believe, and on that basis allege, that Plaintiff’s
16 claims are barred in whole or in part by the doctrine of waiver.
17 FOURTEENTH AFFIRMATIVE DEFENSE
18 16. The Answering Defendant was acting with reasonable care and were suddenly and
19 unexpectedly confronted by an emergency that the Defendant did not cause. As a result of being
20 faced with this sudden emergency, the Defendant was forced to act without time to avoid the
21 impending danger, and as such, was not negligent.
22 FIFTEENTH AFFIRMATIVE DEFENSE
23 17. The Answering Defendant, acting with reasonable care, were suddenly and
24 unexpectedly faced with danger and confronted by an emergency that the Defendant did not cause.
25 As a result of being faced with this sudden emergency, the Defendant was forced to act without time
26 to avoid the impending danger, and as such, were not negligent.
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DEFENDANT FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO PLAINTIFF’S COMPLAINT FOR
DAMAGES AND DEMAND FOR JURY TRIAL
1 SIXTEENTH AFFIRMATIVE DEFENSE
2 18. Defendant reserves the right to raise additional affirmative defenses and to
3 supplement those asserted herein upon discovery of further information regarding the claims and
4 upon further investigation.
5 WHEREFORE, the answering Defendant prays:
6 1. That Plaintiff takes nothing;
7 2. For the costs of suit; and
8 3. For such other and further relief as to this Court seems just and proper
9 Dated: November 17, 2022 CLARK HILL LLP
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By:
,j(2,-,
Bradford G. Hughes
Erin Chance
Attorneys for Defendant
13 FREEDOM MEDICAL TRANSPORTATION, LLC
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DEFENDANT FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO PLAINTIFF’S COMPLAINT FOR
DAMAGES AND DEMAND FOR JURY TRIAL
1 DEMAND FOR JURY TRIAL
2 Defendant FREEDOM MEDICAL TRANSPORTATION, LLC hereby requests trial of this
3 matter by jury.
4 Dated: November 17, 2022 CLARK HILL LLP
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By:
7 Bradford G. Hughes
Erin Chance
8 Attorneys for Defendant
FREEDOM MEDICAL TRANSPORTATION, LLC
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DEFENDANT FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO PLAINTIFF’S COMPLAINT FOR
DAMAGES AND DEMAND FOR JURY TRIAL
1 PROOF OF SERVICE
Robert Mosqueda v. Gabriela Gonzalez Blas, et al.
2 Monterey Superior Court No. 22CV002878
3 I am employed in Los Angeles County. I am over the age of 18 and not a party to this action.
My business address is 555 South Flower Street, 24th Floor, Los Angeles, California 90071.
4
On November 17, 2022, I served the foregoing document, described as DEFENDANT
5 FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO PLAINTIFF’S
COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL in this action by placing
6
El the original of the document
7 IZ1 true copies of the document
8 in separate sealed envelopes to the following addresses:
9 Cathy Pantelic, Esq.
Omega Law Group, PC
10 8350 Wilshire Boulevard, Third Floor
Beverly Hills, CA 90211
11 (310) 526-8383 /Fax (310) 526-8263
Emails: cp@omegalaw.com
12 eservice@omegalaw.com
jf@omegalaw.com
13 Attorneys for Plaintiff
Robert Mosqueda
14
IZ1 BY U.S. MAIL I deposited such envelope in the mail at Los Angeles, California. The envelopes
15 were mailed with postage thereon fully prepaid.
I am readily familiar with Clark Hill’s practice of collection and processing correspondence for
16 mailing. Under that practice, documents are deposited with the U.S. Postal Service on the same day
which is stated in the proof of service, with postage fully prepaid at Los Angeles, California in the
17 ordinary course of business. I am aware that on motion of party served, service is presumed invalid if
the postal cancellation date or postage meter date is more than one day after the date stated in this
18 proof of service.
19 El BY FEDERAL EXPRESS I am familiar with the firm's practice of collecting and processing
correspondence for delivery via Federal Express. Under that practice, it would be picked up by
20 Federal Express on that same day at Los Angeles, California and delivered to the parties as listed on
this Proof of Service the following business morning.
21 Z BY E-MAIL TO COUNSEL: I caused the above-referenced document to be transmitted via e mail from
cnakauchi@clarkhill.com to the parties as listed on this Proof of Service.
22
23
El BY FACSIMILE I caused the above-referenced document to be transmitted via facsimile to the
parties as listed on this Proof of Service.
24 IZ STATE I declare under penalty of perjury under the laws of the state of California, that the above
is true and correct.
25 Executed on November 17, 2022 at Los Angeles, California.
26
/s/ Carol Ann T. Nakauchi
27 Carol Ann T. Nakauchi
28
Preview
1 Bradford G. Hughes, Esq., SBN 247141 Erin Chance, Esq., SBN 331431 2 CLARK HILL LLP 555 South Flower Street, 24th Floor 3 Los Angeles, CA 90071 Telephone: (213) 891-9100 4 Facsimile: (213) 488-1178 BHughes@ClarkHill.com 5 EChance@ClarkHill.com 6 Attorneys for Defendant FREEDOM MEDICAL TRANSPORTATION, LLC 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF MONTEREY 10 11 ROBERT MOSQUEDA, an individual, Case No. 22CV002878 12 Plaintiff, DEFENDANT FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO 13 v. PLAINTIFF’S COMPLAINT FOR DAMAGES AND DEMAND FOR JURY 14 FREEDOM MEDICAL TRANSPORTATION, TRIAL LLC, a corporation; GABRIELA GONZALEZ 15 BLAS, an individual; and DOES 1 through 50, Assigned to: Hon. Carrie M. Panetta inclusive, Dept.: 14 16 Defendants. Complaint Filed: September 27, 2022 17 Trial Date: Not Set 18 19 20 Defendant FREEDOM MEDICAL TRANSPORTATION, LLC’S, (“Defendant”) answers 21 Plaintiff ROBERT MOSQUEDA’S (“Plaintiff”) Complaint, as follows: 22 GENERAL DENIAL 23 1. Pursuant to the provisions of section 431.30(d) of the California Code of Civil 24 Procedure, answering defendant denies each, every and all of the allegations in the Complaint, and 25 all of it, and deny that plaintiff has or will sustain damage in the sum or sums alleged, or in any other 26 sum, or sums at all. 27 2. Further answering plaintiff's Complaint, each and every cause of action contained in it, 28 and all of it, answering defendant denies that plaintiff has or will sustain any injury, damage or loss, if 1 DEFENDANT FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO PLAINTIFF’S COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL 1 any, by reason of any act or omission on the part of this. 2 FIRST AFFIRMATIVE DEFENSE 3 3. The Complaint, each and every cause of action contained in it, and all of it, fails to 4 state facts sufficient to constitute a cause of action against the answering Defendant. 5 SECOND AFFIRMATIVE DEFENSE 6 4. Defendant is informed and believes, and on that basis allege, that Plaintiff’s claims are 7 barred in whole or in part by the doctrine of waiver. 8 THIRD AFFIRMATIVE DEFENSE 9 5. Plaintiff’s own conduct, or the conduct of other entities and individuals, whether or not 10 parties to this action, caused or contributed to Plaintiff’s alleged injuries and damages. This conduct 11 comparatively reduces any percentage of liability attributed to the answering Defendant, if it should 12 be found that the Defendant is liable, which the answering Defendant expressly denies. 13 FOURTH AFFIRMATIVE DEFENSE 14 6. That immediately prior to the occurrence of the incident referred to in the Complaint 15 herein, the Plaintiff failed to use and exercise caution for their own protection and safety in that, 16 among other things, Plaintiff freely and voluntarily placed themselves in a position so as to be 17 exposed to a likelihood of injury, and that at the time and place of said accident, Plaintiff was fully 18 aware of the dangers incident thereto and continued to freely and voluntarily expose themselves to 19 same, and thereby assumed the risk thereof, and in having assumed the risk, is therefore barred by the 20 assumption of the risk for any recovery herein or the applicable abatement of such recovery, if any, 21 herein. 22 FIFTH AFFIRMATIVE DEFENSE 23 7. That if Plaintiff sustained any injuries or damages as a result of the accident or 24 incident complained of herein, then Plaintiff proximately caused, aggravated, and/or failed to take 25 proper action to reduce and/or mitigate said injuries and damages. 26 SIXTH AFFIRMATIVE DEFENSE 27 8. The answering Defendant’s conduct was not a substantial factor in causing Plaintiff’s 28 alleged injuries, and/or public policy(ies) otherwise limit Defendant’s liability for the alleged injuries, 2 DEFENDANT FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO PLAINTIFF’S COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL 1 which liability Defendant denies. Accordingly, the answering Defendant’s conduct was not a 2 proximate cause of Plaintiff’s alleged injuries, and Defendant cannot be held liable for such. 3 SEVENTH AFFIRMATIVE DEFENSE 4 9. The answering Defendant is informed and believes, and thereon allege, that the 5 injuries and damages alleged to have been suffered by Plaintiff in the Complaint herein, if any, were 6 proximately caused or contributed to by the acts or omissions of third parties other than the answering 7 Defendant. It is thus necessary that the proportion or degree of negligence or fault of each of said 8 persons or entities, whether parties to this action or not, be judicially determined and that any 9 judgment that might be rendered against the answering Defendant be reduced in proportion to the 10 degree of fault attributed to each and every third person or entity found liable to Plaintiff herein. As 11 against each such third person or entity, whether served or not served in this action, whose acts or 12 omissions are found to have proximately caused or contributed in any fashion to the injuries, if any, 13 alleged to have been suffered by Plaintiff herein, the answering Defendant reserves the right to cross 14 complain and/or move for judgment against each such person or entity. 15 EIGHTH AFFIRMATIVE DEFENSE 16 10. In the event that the answering Defendant is found to be liable, which supposition is 17 denied and merely stated for the purpose of this affirmative defense, the answering Defendant 18 contend that their liability, if any, for non-economic damages shall be several, and not joint, pursuant 19 to the Fair Responsibility Act of 1986, section 1431 et seq., of the California Civil Code, so that the 20 answering Defendant shall be liable, if at all, only for that amount of non-economic damages 21 allocated to the Defendant by the trier of fact, if any, in direct proportion to the percentage of fault, if 22 any, assessed against the Defendant, and a separate judgment rendered against each Defendant in that 23 amount for non-economic damages, if any. 24 NINTH AFFIRMATIVE DEFENSE 25 11. That any damages sustained by Plaintiff was the result of a superseding intervening 26 causation by an independent and unforeseeable force which broke the claim of causation. 27 28 3 DEFENDANT FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO PLAINTIFF’S COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL 1 TENTH AFFIRMATIVE DEFENSE 2 12. Answering Defendant is informed and believes, and thereon allege, that at the time of 3 the accident Plaintiff was not insured and/or could not establish financial responsibility as required by 4 the financial responsibility laws of the State of California. Therefore, pursuant to the provisions of 5 California Civil Code section 3333.4, Plaintiff is barred from recovering any non-economic damages. 6 ELEVENTH AFFIRMATIVE DEFENSE 7 13. Plaintiff failed to exercise reasonable and ordinary care, caution, or prudence in his 8 safety in order to avoid the alleged incident. The resulting injuries and damages, if any, sustained by 9 Plaintiff was proximately caused and contributed to by the negligence of Plaintiff. 10 TWELFTH AFFIRMATIVE DEFENSE 11 14. Answering Defendant is informed and believes, and on that basis allege, that Plaintiff, 12 by Plaintiff’s acts and conduct, is estopped from alleging any and all claims as asserted in the 13 Complaint. 14 THIRTEENTH AFFIRMATIVE DEFENSE 15 15. Answering Defendant is informed and believe, and on that basis allege, that Plaintiff’s 16 claims are barred in whole or in part by the doctrine of waiver. 17 FOURTEENTH AFFIRMATIVE DEFENSE 18 16. The Answering Defendant was acting with reasonable care and were suddenly and 19 unexpectedly confronted by an emergency that the Defendant did not cause. As a result of being 20 faced with this sudden emergency, the Defendant was forced to act without time to avoid the 21 impending danger, and as such, was not negligent. 22 FIFTEENTH AFFIRMATIVE DEFENSE 23 17. The Answering Defendant, acting with reasonable care, were suddenly and 24 unexpectedly faced with danger and confronted by an emergency that the Defendant did not cause. 25 As a result of being faced with this sudden emergency, the Defendant was forced to act without time 26 to avoid the impending danger, and as such, were not negligent. 27 28 4 DEFENDANT FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO PLAINTIFF’S COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL 1 SIXTEENTH AFFIRMATIVE DEFENSE 2 18. Defendant reserves the right to raise additional affirmative defenses and to 3 supplement those asserted herein upon discovery of further information regarding the claims and 4 upon further investigation. 5 WHEREFORE, the answering Defendant prays: 6 1. That Plaintiff takes nothing; 7 2. For the costs of suit; and 8 3. For such other and further relief as to this Court seems just and proper 9 Dated: November 17, 2022 CLARK HILL LLP 10 11 12 By: ,j(2,-, Bradford G. Hughes Erin Chance Attorneys for Defendant 13 FREEDOM MEDICAL TRANSPORTATION, LLC 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 DEFENDANT FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO PLAINTIFF’S COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL 1 DEMAND FOR JURY TRIAL 2 Defendant FREEDOM MEDICAL TRANSPORTATION, LLC hereby requests trial of this 3 matter by jury. 4 Dated: November 17, 2022 CLARK HILL LLP 5 6 By: 7 Bradford G. Hughes Erin Chance 8 Attorneys for Defendant FREEDOM MEDICAL TRANSPORTATION, LLC 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 6 DEFENDANT FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO PLAINTIFF’S COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL 1 PROOF OF SERVICE Robert Mosqueda v. Gabriela Gonzalez Blas, et al. 2 Monterey Superior Court No. 22CV002878 3 I am employed in Los Angeles County. I am over the age of 18 and not a party to this action. My business address is 555 South Flower Street, 24th Floor, Los Angeles, California 90071. 4 On November 17, 2022, I served the foregoing document, described as DEFENDANT 5 FREEDOM MEDICAL TRANSPORTATION, LLC’S ANSWER TO PLAINTIFF’S COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL in this action by placing 6 El the original of the document 7 IZ1 true copies of the document 8 in separate sealed envelopes to the following addresses: 9 Cathy Pantelic, Esq. Omega Law Group, PC 10 8350 Wilshire Boulevard, Third Floor Beverly Hills, CA 90211 11 (310) 526-8383 /Fax (310) 526-8263 Emails: cp@omegalaw.com 12 eservice@omegalaw.com jf@omegalaw.com 13 Attorneys for Plaintiff Robert Mosqueda 14 IZ1 BY U.S. MAIL I deposited such envelope in the mail at Los Angeles, California. The envelopes 15 were mailed with postage thereon fully prepaid. I am readily familiar with Clark Hill’s practice of collection and processing correspondence for 16 mailing. Under that practice, documents are deposited with the U.S. Postal Service on the same day which is stated in the proof of service, with postage fully prepaid at Los Angeles, California in the 17 ordinary course of business. I am aware that on motion of party served, service is presumed invalid if the postal cancellation date or postage meter date is more than one day after the date stated in this 18 proof of service. 19 El BY FEDERAL EXPRESS I am familiar with the firm's practice of collecting and processing correspondence for delivery via Federal Express. Under that practice, it would be picked up by 20 Federal Express on that same day at Los Angeles, California and delivered to the parties as listed on this Proof of Service the following business morning. 21 Z BY E-MAIL TO COUNSEL: I caused the above-referenced document to be transmitted via e mail from cnakauchi@clarkhill.com to the parties as listed on this Proof of Service. 22 23 El BY FACSIMILE I caused the above-referenced document to be transmitted via facsimile to the parties as listed on this Proof of Service. 24 IZ STATE I declare under penalty of perjury under the laws of the state of California, that the above is true and correct. 25 Executed on November 17, 2022 at Los Angeles, California. 26 /s/ Carol Ann T. Nakauchi 27 Carol Ann T. Nakauchi 28