Proof of Service: BIG WASHINGTON, LLC VS FRY ET AL

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                                1    William L. Alexander (State Bar Number 126607)
                      Elizabeth Estrada (State Bar Number 232302)
                 2    Alexander & Associates, PLC
                 3    1925 G Street
                      Bakersfield, CA      93301
                 4    Phone: (661) 316-7888
                      Email: walexander@alexander-law.com; service@alexander-law.com
                 5
                 6     Attorneys for defendants Thomas H. Fry and Ruth M. Fry
                       as Trustees of the T&R Fry Family Trust
                 7
                 8                            SUPERIOR COURT OF THE STATE OF CALIFORNIA

                 9                              COUNTY OF KERN – METROPOLITAN DIVISION

                10     BIG WASHINGTON, LLC, a California                          )  Case No.     BCV-17-102341 BCB
                       Limited Liability Company,                                 )
                11                                                                )  PROOF OF SERVICE
                                                        Plaintiff,                )  (C.C.P. §1013a, 2015.5)
                12                                                                )
                13     vs.                                                        )
                                                                                  )
                14     BENHONG (AMERICA) RECYCLING CO.                            )
                       LTD, a California Limited Liability Company;               )
                15     and THOMAS H. FRY and RUTH M. FRY as                       )
                16     Trustees of the T & R FRY FAMILY TRUST;                    )
                       and DOES 1 – 100, inclusive,                               )
                17                                                                )
                                                        Defendants.               )
                18                                                                )
                19                                                                )

                20              I am employed in the County of Kern, State of California.           I am over the age of 18 and not a party
                       to the within action; my business address is 1925 G Street, Bakersfield, California.
                21
                22     On November 30, 2022, I served the foregoing document(s) entitled:

                23         •   DEFENDANTS’ FIRST AMENDED EXHIBIT LIST;
                24         •   DEFENDANTS’ AMENDED PROPOSED JURY INSTRUCTIONS;
                25
                           •   DEFENDANT’S MOTION IN LIMINE 9 and DECLARATION OF ELIZABETH
                26             ESTRADA IN SUPPORT RE: EXCLUSION OF EVIDENCE RELATING TO
                               COMPLAINTS OR CONSENT DECREES FILED AND/OR ENTERED IN THE CASE
                27             OF LOS ANGELES WATERKEEPER V. COMMUNITY RECYCLING AND
                28             RESOURCE RECOVERY, INC.;


     Alexander & Associates
                                                                                   1
       Attorneys at Law
        1925 G Street
     Bakersfield, CA 93301
       (661) 316-7888

                                                                        PROOF OF SERVICE
                 1         •    DEFENDANT’S MOTION IN LIMINE 10 and DECLARATION OF ELIZABETH
                                ESTRADA IN SUPPORT RE: EXCLUSION OF ANY TESTIMONY BY ALAN
                 2
                                HICKMAN OR REFERENCE TO ALAN HICKMAN; AND EXCLUSION OF ANY
                 3              EXPERT TESTIMONY BY BEN EILENBERG;

                 4         •    DEFENDANT’S MOTION IN LIMINE 11 and DECLARATION OF ELIZABETH
                                ESTRADA IN SUPPORT RE: EXCLUSION OF EVIDENCE RELATING TO FRY VS.
                 5
                                COMMISSION OF INTERNAL REVENUE SERVICE;
                 6
                           •    DEFENDANTS’ REPLY IN SUPPORT OF MOTION IN LIMINE 1: EXCLUSION OF
                 7              EVIDENCE THAT CALCOT DID NOT CONSENT TO STORAGE OF THE PLASTIC
                                ON THE PROPERTY;
                 8
                 9         •    DEFENDANTS’ REPLY IN SUPPORT OF MOTION IN LIMINE 3:                                     BIFURCATION
                                OF TRIAL;
                10
                11         •    DEFENDANTS’ REPLY IN SUPPORT OF MOTION IN LIMINE 6: LIMITING
                                REFERENCE TO THE PLASTIC AS ONLY “THE PLASTIC” OR “THE
                12              AGRICULTURAL PLASTIC”;
                13         •   DEFENDANTS’ REPLY IN SUPPORT OF MOTION IN LIMINE 7: EXCLUSION OF
                14             EVIDENCE RELATING TO ANY ACTIONS OR PROCEEDINGS BROUGHT BY ANY
                               GOVERNMENTAL AGENCY AGAINST DEFENDANTS;
                15
                           •    DEFENDANTS’ REPLY IN SUPPORT OF MOTION IN LIMINE 8: COURT’S
                16              DETERMINATION OF CONSENT AS A MATTER OF LAW;
                17
                           •    DEFENDANTS’ OPPOSITION TO MOTION IN LIMINE #3;
                18
                           •    DEFENDANTS’ OPPOSITION TO PLAINTIFFS’ MOTION FOR SITE VISIT;
                19
                20         •    DEFENDANTS’ COMMON MEMORANDUM OF POINTS AND AUTHORITIES
                                IN RELATION TO ALL MOTIONS IN LIMINE;
                21
                           •    MEMORANDUM OF POINTS AND AUTHORITIES RE: PROPOSED JURY
                22
                                INSTRUCTIONS; and
                23
                           •    BRIEF RE: JUDICIAL ADMISSION CONTAINED IN FILED PLEADINGS; USE OF
                24              PLEADINGS FOR IMPEACHMENT
                25
                       /  /  /
                26
                       /  /  /
                27
                       /  /  /
                28

     Alexander & Associates
                                                                                   2
       Attorneys at Law
        1925 G Street
     Bakersfield, CA 93301
       (661) 316-7888

                                                                        PROOF OF SERVICE
                 1     on interested parties in this action as follows:
                 2              Richard B Jacobs, Esq.                                Attorneys for Plaintiff, BIG WASHINGTON, LLC
                 3              LAW OFFICE OF RICHARD JACOBS
                                13512 Hatteras Street
                 4              Van Nuys, CA 91401-4517
                                Email:   richardjacobslaw@gmail.com
                 5
                 6     [   ]    BY MAIL: Pursuant to C.C.P. §1013(a).            By placing (     ) the original or (X) a true copy thereof
                                enclosed in a sealed envelope.        I am readily familiar with the firm’s practice of collection and
                 7              processing of documents for mailing.         Under that practice it would be deposited with the United
                                State Postal Service on that same day with postage thereon fully prepaid at Bakersfield, California
                 8              in the ordinary course of business.
                 9
                      [X]      BY   E-MAIL      OR   ELECTRONIC         TRANSMISSION:            Pursuant   to  C.C.P   §1010.6,   subsection
                10             (e)(1), I  caused   the document(s)     to  be emailed    to the  person(s)   at the  email   address(es)     as
                               indicated   above.    No   electronic    message     or  other   indication    that  the   transmission     was
                11             unsuccessful was received within a reasonable time after the transmission.
                12
                       [   ]    (BY PERSONAL SERVICE), pursuant to C.C.P. §1011, by placing a true copy thereof enclosed
                13              in  an  envelope    and  caused    such   envelope    to be  delivered    by  hand   to  the  office(s)  of  the
                                addresses(s).
                14
                       [   ]    (BY OVERNIGHT COURIER), pursuant to C.C.P. §1013(c)(d), I caused such envelope with
                15              delivery fees prepaid to be sent by GENERAL LOGISTICS SYSTEMS, INC. (GSL).
                16
                                Executed on November 30, 2022, at Bakersfield, California.
                17
                       [X]      (STATE)           I declare under penalty of perjury under the laws of the State of California that
                18                                the above is true and correct.
                19
                       [   ]    (FEDERAL)         I declare that I am employed in the office of a member of the bar of this court at
                20                                whose direction the service was made.
                21
                22                                                                             /s/ Rocki L. Parnell /s/
                                                                                                   ROCKI L. PARNELL
                23
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     Alexander & Associates
                                                                                   3
       Attorneys at Law
        1925 G Street
     Bakersfield, CA 93301
       (661) 316-7888

                                                                        PROOF OF SERVICE