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ELECTRONICALLY
Lawrence D, Murray (SBN 77536)
MURRAY & ASSOCIATES FILED
1781 Union Street ‘Superior Sou of Canromia,
Sar Francisco, CA 94123 a 3015
Tel: (415) 673-0555 06 /' - 42 ——
Fax: (415) 928-4084 forkiot thes
Deputy Clerk
Attorney for Defendants: DAVID WONG,
MICHAEL ZEHNER, BRIAN SAVAGE,
SHEDRICK McDANIELS, and SAN FRANCISCO
DEPUTY SHERIFF’S FOUNDATION
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
JOHNA PECOT, THOMAS ARATA, RICH Case No, CGC — 10 -501168
OWYANG, STEPHEN TILTON, JOSEPH
LEAKE, and OSCAR TAYLOR, Individually MEMORANDUM OF POINTS AND
and on behalf of all other similarly situated AUTHORITIES IN SUPPORT OF
OPPOSITION TO MOTION FOR ORDER
Plaintiffs, COMPELLING ACKNOWLEDGMENT OF
v. SATISFACTION OF JUDGMENT
SAN FRANCISCO DEPUTY SHERIFF’S Date: June 17, 2015
ASSOCIATION, a California Nonprofit Time: 9:30 a.m.
Corporation, SAN FRANCISCO DEPUTY Dept: 302
SHERIFF’S FOUNDATION, a California
Nonprofit Corporation, DAVID WONG, an
individual, MICHAEL ZEHNER, an individual,
BRIAN SAVAGE, an individual, SHEDRICK.
MeDANIELS, an individual, and DOES 1-100,
Defendants.
A. Background
The individual defendants were successful in a SLAPP motion pursuant to Code of Civil
Procedure Sec. 425.16. This court awarded defendants fees in the amount of $20,000.00. (Murray Dec
2) The hearing on the fee motion occurred on Feb. 10, 2012. Plaintiffs were represented by Paul
Kranz and William Barns, as shown on the Court’s Minutes. (Murray Dec 3, Exhibit 1)
Not only did the Court address the amount due, but also when it was to be paid. The court
Pecot, et al. vs, SFDSA, et al.; San Francisco Superior Court No: CGC — 10 — 501168 Pagel
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ordered the payment of $20,000.00 by plaintiffs to defendants. The order specifically states that the
payment is to be paid by March 30, 2012. (Murray Dec § 4, Exhibit 2) Hence, as of March 30, 2012, the
obligation was reduced to an amount certain. By law, once the amount of the obligation is rendered
certain, interest commences. Civil Code § 3287 (a)
Either (a) by the terms of the court order, (b) by the rules related to interest on prejudgment
obligations and or (c) interest which commences on a judgment, interest on the $20,000 began to run
from the moment it was order and announced by the Court.
B. Plaintiffs Attempted To Thwart The Order By Refusing To Approve It As To Form
Efforts to secure the signature of the plaintiffs on the order after hearing were futile, On April
23, 2012, defendants’ attorney sent to plaintiffs’ counsel the proposed order for his review and approval
as to form. Plaintiffs’ counsel did not sign this proposed order. (Murray Dec J 5, Exhibit 3.)
A year and a half later, on September 4, 2013, defendants’ attorney again sent to plaintiffs’
counsel the proposed order for his review and approval as to form. Again, Plaintiffs’ counsel did not
sign this proposed order. (Murray Dec { 6, Exhibit 4.)
On September 30, 2013, Plaintiffs’ counsel sent the proposed Order to the court along with
copies of the letters sent to the Clerk of the Superior Court. (Murray Dec 9] 7 Exhibit 5)
On October 9, 2013, Judge Harold Kahn signed the Order. The Order was filed on October 9,
2013. (Murray Dec 8, Exhibit 5.) As is shown on the order itself, Mr. Kranz never signed the order
approving it as to form. (Murray Dec 7 Exhibit 1, page 2.)
Plaintiffs did not pay the $20,000.00 by March 30, 2012. Interest commenced to accumulate
from that date at the rate of $5.48 per day.
c Not That It Was Necessary, But Plaintiffs Had Actual Knowledge of The Obligation
Plaintiffs had two attorneys present at the hearing on defendants’ SLAPP fee motion on Feb. 10,
2012. (Murray Dec § 10, Exhibit 1.) Plaintiffs knew that the payment was due by March 30, 2012.
Even if there is no order on file, plaintiffs knew that there was an amount certain, $20,000, and that
payment was due by March 30, 2012. Even after the Order was filed, plaintiffs waited over nine months
to pay a portion of what was due at that time, and only after defendants recorded Abstracts of Judgment.
(Murray Dec 4] 10)
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Pecot, et al. vs. SFDSA, et al.; San Francisco Superior Court No: CGC — 10 — 501168 Page 2
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D. Calculation of Costs Associated With The Judgment/ Order for Payment of Money
Defendants obtained three Abstracts of Judgment at a cost of $25 each. (Murray Dec { 11)
Recording fees were paid as follows: San Francisco County: $40.00; San Mateo County:
$59.00; Alameda County: 90.00. Total costs are $264.00. (Murray Dec { 12)
E. Calculation of Principle, Costs and Interest Showed $24,883.64 Was Due On July 21, 2014
March 30, 2012 to July 21, 2014 consists of 843 days. (Murray Dec 13)
On July 21, 2014, the total amount due was $24,883.64, calculated is as follows:
SLAPP fees: $20,000.00
Interest: 843 days @ $5.48 per day: $4,619.64
Enforcement of Judgment costs: $264.00
KF Plaintiffs Have Not Fully Satisfied The Judgment, Hence Received A Partial Satisfaction
Plaintiff's paid $21,953.07 by cashier’s check on July 21,2014. The balance due as of July 22,
2014 is $2,930.57. Plaintiffs have not fully satisfied the judgment as order by the court, nor with
prejudgment and post judgment amounts calculated. (Murray Dec J 15) Hence, the partial satisfaction
of judgment which acknowledged the $21,953.07, as given by Defendants was proper.
G. And, There Is NO Final Judgment On The Issue Of Attorney Fees and Costs
Additionally, there is no final order on the motion for fees. The order is currently on appeal in
the Court of Appeal for the First District. Defendants have filed their brief setting out how the fees
awarded were not based on a lawful calculation. Paul Kranz, as the attorney for Plaintiffs has secured
various extensions but has not filed his brief in the Court of Appeal. Therefore, there is no final
judgment on the obligation for attorney fees and costs on the SLAPP motion can be fully satisfied.
(Murray Dec [ 16)
MW
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Pecot, et al. vs. SFDSA, et al.; San Francisco Superior Court No: CGC — 10 — 501168 Page 3
Points & Authorities iso Opp.Motion for Order Compelling Acknowledgment of Satisfaction of Judgment1
A. THE JUDGMENT IS SELF EXPLANATORY AND INTEREST ON THE OBLIGATION
COMMENCED ON MARCH 30, 2012.
Under the order, the amount of $20,000 was due as of March 30, 2012. (See Murray Dec, Exhibit
1) When the obligation was not paid and the obligation continues unsatisfied, interest accrues. Pursuant
to Civil Code Section 685.010.(a) “Interest accrues at the rate of 10 percent per annum on the principal
amount of a money judgment remaining unsatisfied.” Interest accrued on the order from the date it was
to be paid, March 30, 2012.
Additionally, when the amount is to be paid at a later date, in one or more installments, interest
begins when payments are due and not made on the date due. Civil Code Section 685.010 (b) The order]
was made at the hearing of February 12, 2012, with no payments due for 36 days, or until March 30,
2012. Under this provision, interest was due as of the date the installment was to be paid, or March 30.
Under the terms of the judgment and or under the terms of the payments due in one installment at]
a later date, interest began to run on March 30, 2012.
B. EVEN IF THE JUDGMENT DID NOT SPECIFY A DATE, PREJUDGMENT INTEREST
BEGINS ONCE THE AMOUNT IS CERTAIN, AS IT WAS UNDER THE JUDGMENT
Even if the order did not dictate a date for commencement of interest, where, as here, the amount
is known and certain, the obligation for interest commences on that date.
In California, parties entitled to recover on an obligation when it is “certain or capable of being
made certain by calculation” are also entitled to interest thereon from the time the right to recover arises.
Civil Code § 3287. This section reads as follows:
(a) A person who is entitled to recover damages certain, or capable of being made certain
by calculation, and the right to recover which is vested in the person upon a particular
day, is entitled also to recover interest thereon from that day, except when the debtor is
prevented by law, or by the act of the creditor from paying the debt. This section is
applicable to recovery of damages and interest from any debtor, including the state or any
county, city, city and county, municipal corporation, public district, public agency, or any
political subdivision of the state.
(b) Every person who is entitled under any judgment to receive damages based upon a
cause of action in contract where the claim was unliquidated, may also recover interest
thereon from a date prior to the entry of judgment as the court may, in its discretion,
fix, but in no event earlier than the date the action was filed.
Mh
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Pecot, et al. vs. SFDSA, et al.; San Francisco Superior Court No: CGC — 10 — 501168 Page 4
Points & Authorities iso Opp.Motion for Order Compelling Acknowledgment of Satisfaction of Judgment27
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The test for determining “certainty” is whether plaintiff actually knows the amount owed or
could have computed the amount from reasonably available information. See Children’s Hospital &
Med. Ctr. v. Bonta 97 Cal. App. 4th. 740, 774 (2002). “Damages are deemed certain or capable of
being made certain within the provisions of subdivision (a) of § 3287 where there is essentially no
dispute between the parties concerning the basis of computation of damages if any are recoverable but
where their dispute centers on the issue of liability giving rise to damage.” Esgro Central, Inc. v.
General Ins. Co. 20 Cal. App. 3d 1054, 1060 (1971).
The order announced from the bench and in the tentative left no room for dispute. The amount
was certain and interest commenced on March 30, 2012.
C. CONCLUSION: THE OBLIGATION WAS NOT SATISFIED ON JULY 2014, AND
THE PARTIAL SATISFACTION OF JUDGMENT IS PROPER
On July 21, 2014, the total amount due was $24,883.64. Of that, $21,953.07 was paid. Hence,
the issuance of a partial satisfaction of judgment for $21,953.07 was proper.
Plaintiffs lack a basis to complain where they have sought to thwart the entry of an order, knew
that the amount of $20,000 was due as of March 30, 2012, hence interest commences, and made only a
partial payment on the amount due.
June 3, 2015 Respectfully submitted
MICHAEL ZEHNER, BRIAN SAVAGE,
SHEDRICK McDANIELS, and SAN FRANCISCO
DEPUTY SHERIFF’S FOUNDATION
Pecct, et al. vs. SFDSA, et al.; San Francisco Superior Court No: CGC — 10 — 501168 Page 5
Points & Authorities iso Opp.Motion for Order Compelling Acknowledgment of Satisfaction of JudgmentPROOF OF SERVICE
Jam 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 1781 Union Street, San Francisco,
California 94123; (415) 673-0555. On this date, I served the following document(s):
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF OPPOSITION TO
MOTION FOR ORDER COMPELLING ACKNOWLEDGMENT OF SATISFACTION OF
JUDGMENT on the interested parties in this action as follows:
Attorney for Plaintiffs:
Paul L. Kranz
Law Office of Paul L. Kranz
499 14" Street, Suite 300
Oakland, CA 94516
Tel: (510) 839-1200
Fax: (510) 444-6698
Attorneys for Defendant San Francisco Deputy Sheriffs’ Association
Lara Cullinane-Smith
Shrem & Smith
11720 San Pablo Avenue #C
El Cerrito, CA 94530
Tel: (510) 919-3214
Fax: (510) 705-1854
lara@shremlaw.com
{xx} [BY MAIL] _ I caused envelope(s) with postage thereon fully prepaid to be placed in the United
States mail at San Francisco, California, addressed as shown above.
{xx] [BY PERSONAL SERVICE BY EMAIL] _ I caused such envelope(s) to be delivered by hand
to the above address(es).
[ ] [BY FAX] _ | caused the above entitled document(s) to be personally served on the above
shown parties by facsimile transmission on the date shown below by confirming the fax phone number
with the law office shown above then (a) transmitting it via the fax machine within this office, and (b)
receiving a receipt from the machine within this office confirming all documents sent were in fact
properly received.
I declare under penalty of perjury under the laws of the State of California that the above is true
and correct. Executed in San Francisco, California, on June 3, 2015.
Pecot, et al. vs. SFDSA, et al.; San Francisco Superior Court No: CGC -- 10 — 501168 Page 6
Points & Authorities iso Opp.Motion for Order Compelling Acknowledgment of Satisfgction of Judgment
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27 28 ELECTRONICALLY Lawrence D, Murray (SBN 77536) MURRAY & ASSOCIATES FILED 1781 Union Street ‘Superior Sou of Canromia, Sar Francisco, CA 94123 a 3015 Tel: (415) 673-0555 06 /' - 42 —— Fax: (415) 928-4084 forkiot thes Deputy Clerk Attorney for Defendants: DAVID WONG, MICHAEL ZEHNER, BRIAN SAVAGE, SHEDRICK McDANIELS, and SAN FRANCISCO DEPUTY SHERIFF’S FOUNDATION SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO JOHNA PECOT, THOMAS ARATA, RICH Case No, CGC — 10 -501168 OWYANG, STEPHEN TILTON, JOSEPH LEAKE, and OSCAR TAYLOR, Individually MEMORANDUM OF POINTS AND and on behalf of all other similarly situated AUTHORITIES IN SUPPORT OF OPPOSITION TO MOTION FOR ORDER Plaintiffs, COMPELLING ACKNOWLEDGMENT OF v. SATISFACTION OF JUDGMENT SAN FRANCISCO DEPUTY SHERIFF’S Date: June 17, 2015 ASSOCIATION, a California Nonprofit Time: 9:30 a.m. Corporation, SAN FRANCISCO DEPUTY Dept: 302 SHERIFF’S FOUNDATION, a California Nonprofit Corporation, DAVID WONG, an individual, MICHAEL ZEHNER, an individual, BRIAN SAVAGE, an individual, SHEDRICK. MeDANIELS, an individual, and DOES 1-100, Defendants. A. Background The individual defendants were successful in a SLAPP motion pursuant to Code of Civil Procedure Sec. 425.16. This court awarded defendants fees in the amount of $20,000.00. (Murray Dec 2) The hearing on the fee motion occurred on Feb. 10, 2012. Plaintiffs were represented by Paul Kranz and William Barns, as shown on the Court’s Minutes. (Murray Dec 3, Exhibit 1) Not only did the Court address the amount due, but also when it was to be paid. The court Pecot, et al. vs, SFDSA, et al.; San Francisco Superior Court No: CGC — 10 — 501168 Pagel Points & Authorities iso Opp.Motion for Order Compelling Acknowledgment of Satisfaction of Judgment27 28 ordered the payment of $20,000.00 by plaintiffs to defendants. The order specifically states that the payment is to be paid by March 30, 2012. (Murray Dec § 4, Exhibit 2) Hence, as of March 30, 2012, the obligation was reduced to an amount certain. By law, once the amount of the obligation is rendered certain, interest commences. Civil Code § 3287 (a) Either (a) by the terms of the court order, (b) by the rules related to interest on prejudgment obligations and or (c) interest which commences on a judgment, interest on the $20,000 began to run from the moment it was order and announced by the Court. B. Plaintiffs Attempted To Thwart The Order By Refusing To Approve It As To Form Efforts to secure the signature of the plaintiffs on the order after hearing were futile, On April 23, 2012, defendants’ attorney sent to plaintiffs’ counsel the proposed order for his review and approval as to form. Plaintiffs’ counsel did not sign this proposed order. (Murray Dec J 5, Exhibit 3.) A year and a half later, on September 4, 2013, defendants’ attorney again sent to plaintiffs’ counsel the proposed order for his review and approval as to form. Again, Plaintiffs’ counsel did not sign this proposed order. (Murray Dec { 6, Exhibit 4.) On September 30, 2013, Plaintiffs’ counsel sent the proposed Order to the court along with copies of the letters sent to the Clerk of the Superior Court. (Murray Dec 9] 7 Exhibit 5) On October 9, 2013, Judge Harold Kahn signed the Order. The Order was filed on October 9, 2013. (Murray Dec 8, Exhibit 5.) As is shown on the order itself, Mr. Kranz never signed the order approving it as to form. (Murray Dec 7 Exhibit 1, page 2.) Plaintiffs did not pay the $20,000.00 by March 30, 2012. Interest commenced to accumulate from that date at the rate of $5.48 per day. c Not That It Was Necessary, But Plaintiffs Had Actual Knowledge of The Obligation Plaintiffs had two attorneys present at the hearing on defendants’ SLAPP fee motion on Feb. 10, 2012. (Murray Dec § 10, Exhibit 1.) Plaintiffs knew that the payment was due by March 30, 2012. Even if there is no order on file, plaintiffs knew that there was an amount certain, $20,000, and that payment was due by March 30, 2012. Even after the Order was filed, plaintiffs waited over nine months to pay a portion of what was due at that time, and only after defendants recorded Abstracts of Judgment. (Murray Dec 4] 10) Mt Pecot, et al. vs. SFDSA, et al.; San Francisco Superior Court No: CGC — 10 — 501168 Page 2 Points & Authorities iso Opp.Motion for Order Compelling Acknowledgment of Satisfaction of Judgment27 28 D. Calculation of Costs Associated With The Judgment/ Order for Payment of Money Defendants obtained three Abstracts of Judgment at a cost of $25 each. (Murray Dec { 11) Recording fees were paid as follows: San Francisco County: $40.00; San Mateo County: $59.00; Alameda County: 90.00. Total costs are $264.00. (Murray Dec { 12) E. Calculation of Principle, Costs and Interest Showed $24,883.64 Was Due On July 21, 2014 March 30, 2012 to July 21, 2014 consists of 843 days. (Murray Dec 13) On July 21, 2014, the total amount due was $24,883.64, calculated is as follows: SLAPP fees: $20,000.00 Interest: 843 days @ $5.48 per day: $4,619.64 Enforcement of Judgment costs: $264.00 KF Plaintiffs Have Not Fully Satisfied The Judgment, Hence Received A Partial Satisfaction Plaintiff's paid $21,953.07 by cashier’s check on July 21,2014. The balance due as of July 22, 2014 is $2,930.57. Plaintiffs have not fully satisfied the judgment as order by the court, nor with prejudgment and post judgment amounts calculated. (Murray Dec J 15) Hence, the partial satisfaction of judgment which acknowledged the $21,953.07, as given by Defendants was proper. G. And, There Is NO Final Judgment On The Issue Of Attorney Fees and Costs Additionally, there is no final order on the motion for fees. The order is currently on appeal in the Court of Appeal for the First District. Defendants have filed their brief setting out how the fees awarded were not based on a lawful calculation. Paul Kranz, as the attorney for Plaintiffs has secured various extensions but has not filed his brief in the Court of Appeal. Therefore, there is no final judgment on the obligation for attorney fees and costs on the SLAPP motion can be fully satisfied. (Murray Dec [ 16) MW fii i Pecot, et al. vs. SFDSA, et al.; San Francisco Superior Court No: CGC — 10 — 501168 Page 3 Points & Authorities iso Opp.Motion for Order Compelling Acknowledgment of Satisfaction of Judgment1 A. THE JUDGMENT IS SELF EXPLANATORY AND INTEREST ON THE OBLIGATION COMMENCED ON MARCH 30, 2012. Under the order, the amount of $20,000 was due as of March 30, 2012. (See Murray Dec, Exhibit 1) When the obligation was not paid and the obligation continues unsatisfied, interest accrues. Pursuant to Civil Code Section 685.010.(a) “Interest accrues at the rate of 10 percent per annum on the principal amount of a money judgment remaining unsatisfied.” Interest accrued on the order from the date it was to be paid, March 30, 2012. Additionally, when the amount is to be paid at a later date, in one or more installments, interest begins when payments are due and not made on the date due. Civil Code Section 685.010 (b) The order] was made at the hearing of February 12, 2012, with no payments due for 36 days, or until March 30, 2012. Under this provision, interest was due as of the date the installment was to be paid, or March 30. Under the terms of the judgment and or under the terms of the payments due in one installment at] a later date, interest began to run on March 30, 2012. B. EVEN IF THE JUDGMENT DID NOT SPECIFY A DATE, PREJUDGMENT INTEREST BEGINS ONCE THE AMOUNT IS CERTAIN, AS IT WAS UNDER THE JUDGMENT Even if the order did not dictate a date for commencement of interest, where, as here, the amount is known and certain, the obligation for interest commences on that date. In California, parties entitled to recover on an obligation when it is “certain or capable of being made certain by calculation” are also entitled to interest thereon from the time the right to recover arises. Civil Code § 3287. This section reads as follows: (a) A person who is entitled to recover damages certain, or capable of being made certain by calculation, and the right to recover which is vested in the person upon a particular day, is entitled also to recover interest thereon from that day, except when the debtor is prevented by law, or by the act of the creditor from paying the debt. This section is applicable to recovery of damages and interest from any debtor, including the state or any county, city, city and county, municipal corporation, public district, public agency, or any political subdivision of the state. (b) Every person who is entitled under any judgment to receive damages based upon a cause of action in contract where the claim was unliquidated, may also recover interest thereon from a date prior to the entry of judgment as the court may, in its discretion, fix, but in no event earlier than the date the action was filed. Mh Ml Pecot, et al. vs. SFDSA, et al.; San Francisco Superior Court No: CGC — 10 — 501168 Page 4 Points & Authorities iso Opp.Motion for Order Compelling Acknowledgment of Satisfaction of Judgment27 28 The test for determining “certainty” is whether plaintiff actually knows the amount owed or could have computed the amount from reasonably available information. See Children’s Hospital & Med. Ctr. v. Bonta 97 Cal. App. 4th. 740, 774 (2002). “Damages are deemed certain or capable of being made certain within the provisions of subdivision (a) of § 3287 where there is essentially no dispute between the parties concerning the basis of computation of damages if any are recoverable but where their dispute centers on the issue of liability giving rise to damage.” Esgro Central, Inc. v. General Ins. Co. 20 Cal. App. 3d 1054, 1060 (1971). The order announced from the bench and in the tentative left no room for dispute. The amount was certain and interest commenced on March 30, 2012. C. CONCLUSION: THE OBLIGATION WAS NOT SATISFIED ON JULY 2014, AND THE PARTIAL SATISFACTION OF JUDGMENT IS PROPER On July 21, 2014, the total amount due was $24,883.64. Of that, $21,953.07 was paid. Hence, the issuance of a partial satisfaction of judgment for $21,953.07 was proper. Plaintiffs lack a basis to complain where they have sought to thwart the entry of an order, knew that the amount of $20,000 was due as of March 30, 2012, hence interest commences, and made only a partial payment on the amount due. June 3, 2015 Respectfully submitted MICHAEL ZEHNER, BRIAN SAVAGE, SHEDRICK McDANIELS, and SAN FRANCISCO DEPUTY SHERIFF’S FOUNDATION Pecct, et al. vs. SFDSA, et al.; San Francisco Superior Court No: CGC — 10 — 501168 Page 5 Points & Authorities iso Opp.Motion for Order Compelling Acknowledgment of Satisfaction of JudgmentPROOF OF SERVICE Jam 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 1781 Union Street, San Francisco, California 94123; (415) 673-0555. On this date, I served the following document(s): MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF OPPOSITION TO MOTION FOR ORDER COMPELLING ACKNOWLEDGMENT OF SATISFACTION OF JUDGMENT on the interested parties in this action as follows: Attorney for Plaintiffs: Paul L. Kranz Law Office of Paul L. Kranz 499 14" Street, Suite 300 Oakland, CA 94516 Tel: (510) 839-1200 Fax: (510) 444-6698 Attorneys for Defendant San Francisco Deputy Sheriffs’ Association Lara Cullinane-Smith Shrem & Smith 11720 San Pablo Avenue #C El Cerrito, CA 94530 Tel: (510) 919-3214 Fax: (510) 705-1854 lara@shremlaw.com {xx} [BY MAIL] _ I caused envelope(s) with postage thereon fully prepaid to be placed in the United States mail at San Francisco, California, addressed as shown above. {xx] [BY PERSONAL SERVICE BY EMAIL] _ I caused such envelope(s) to be delivered by hand to the above address(es). [ ] [BY FAX] _ | caused the above entitled document(s) to be personally served on the above shown parties by facsimile transmission on the date shown below by confirming the fax phone number with the law office shown above then (a) transmitting it via the fax machine within this office, and (b) receiving a receipt from the machine within this office confirming all documents sent were in fact properly received. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed in San Francisco, California, on June 3, 2015. Pecot, et al. vs. SFDSA, et al.; San Francisco Superior Court No: CGC -- 10 — 501168 Page 6 Points & Authorities iso Opp.Motion for Order Compelling Acknowledgment of Satisfgction of Judgment