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_ [5205 Gordon Avenue
|| PLAINTIFF, IN PRO PER
Gautam Manandhar
BI Cerrito, California 94530
}(510)508-9510
SUPERIOR COURT OF THE STATE OF CALIF 'ORNIA.
FOR THE COUNTY OF CONTRA COSTA
Gautam Manandhar, ) Case No.: C15-02088
)
, Plaintiff, ) SECOND REQUEST FOR JUDICIAL
) NOTICE IN OPPOSITION TO IFPTE’S
v. ) MOTION FOR SUMMARY JUDGEMENT,
: ) OR ALTERNATIVELY, SUMMARY
(INTERNATIONAL FEDERATION OF ) ADJUDICATION OF ISSUES
PROFESSIONAL AND TECHNICAL )
ENGINEERS LOCAL 21, RICHMOND ) Date:
CHAPTER and DOES 1-10, ) Time:
) Judge: Honorable Jill Fannin.
| Defendants . ) Department: 21
Jo
Action Filed: Nov i) 26+9
Plaintiff respectfiilly requests that this Court take judicial notice of the following documents:
1, November 13, 2014 WARNING LETTER from California Public Employment Relations
Board (“PERB”) regarding unfair practice charge no. LA-CO-1624-E Santa Maria Joint
Union High Sctiool District filed against Santa Maria Joint Union High School District
Faculty Association. A true and correct copy of the WARNING LETTER is attached as
Exhibit 1.
1
SECOND REQUEST FOR JUDICIAL NOTICE IN OPPOSSITION TO IFPTE’S MOTION FOR
SUMMARY JUDGEMENT, OR ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES.The attached documents are records and reports of the administrative agency PERB pursuant
to California Evidence Code §§452 and 453 and California Rule of Court 3.1113¢1). I
California Evidence Code 452(c) states that judicial notice may be taken of “[o]fficial acts of |
| the legislative, executive, and judicial departments of the United States and of any state of the United
| States.” Official acts of the executive department include orders of administrative. agencies and their
reports and records. Taiheiyo Cement U.S.A., Inc. v. Franchise Tax Board (2012).204 Cal. App. 4®
1254, 267, fn.5, citing Rodas v. Spiegel (2001) 87 Cal. App. 4" 513, 518.
Dated: February 9, 2017 Respectfully Submitted,
onend.
autafa-Manardnar
Plaigaiff, In Pro Per
2
SECOND REQUEST FOR JUDICIAL NOTICE IN OPPOSSITION TO IFPTE’S MOTION FOR
SUMMARY JUDGEMENT, OR ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES |‘STATE-OF-CALIFORNIA
° @ e@
PUBLIC EMPLOYMENT RELATIONS BOARD Lo
‘Los Angeles Rogional Office
‘700 N. Central Ave., Suite 200
Glendale, CA 91203-3219
‘Telophone: (818)551-2809°
‘Fax: (818) 551-2820
November 13, 2014
Chelsea R. Olson, Attorney
Kronick Moskovitz Tiedemann & Girard .
733 Marsh Street, Suite 210
San Luis Obispo, CA 93401
Re: Santa Maria.Joint Union High School District v. Santa Maria Joint Union HighSchoot
District FacultyAssociation —
Unfair Practice Charge No. LA-CO-1624-E
WARNING LETTER
Dear Ms. Olson:
The above-referenced unfair practice charge was filed with the Public Employment Relations
Board (PERB or Board) on July 11, 2014, The Santa Maria Joint Union High School District
(District or Charging Party) alleges that the Santa Maria Joint Union High School District
Faculty Association (Association. or Respondent) violated section 3543.6(a) of the Educational’
Employment Relations Act (EERA or Act)! by causing or attempting to cause the District to.
commit an-unfair practice. 5
BACTS AS | ALLEGED :
The District and the Association are parties to a collective bargaining agreemient (CBA)
covering the.certificated.employee bargaining unit.
Mark Goodrian (Goodrnan) is the Association Chapter President.
Glenn Goldin (Goldin) is employed by the District at Santa Maria High School (SMHS) in its
special education department. His classtoom is based at SMHS, he is supervised and evaluated
by'the SMHS principal, he is paid through funding allocated for SMHS, he is part of the
SMHS special éducation department, attends department meetings and is identified on both
District and school documents as being:a member of the SMHS special education department. .
All District special education programs are open to all students in the Distfict. Like many
othér spécial education teachers, Goldin teaches special education students from all of the
District’s four comprehensive high schools.
EERA is codified at Government Code section 3540 et seq. PERB’s. Regulations are
codified at California Code:of Regulations, title 8, section 31001 et seq. The text of the EBRA
and PERB Regulations may be found-at www.perb.ca.gov.
EDMUND G: BROWNIR, Governor.LA-CO-1624-E
November 13, 2014
Page 2 :°
Goldin has been an outspoken critic of current Association leadership. During the 2013-2014
school year, Goldin ran against Goodman for Association Chapter President. Goldin lost the
election and Goodman remains Association Chapter President.
On or about April 2014, District departments solicited nominations and held elections for
department chairs at all four'comprehensive school sites throughout District. Pursuant to CBA,
Asticle 3.5.2, department chairs are to be elected by their respective constituencies at each.
school site and must be paid a 9-10.5% stipend by the District for performing department hie
duties, ©
Goldin was nominated to serve as co-chair of fthe SMHS special education department with
another SMHS special.education teacher, Matt Andrade (Andrade). In a preliminary election
on or about May 2014, Goldin and Andrade were unanimously selected: by their constituency
(the special education teachers at SMES).
On-or about April 15, 2014, the Association Election Committee determined that Goldin was
ineligible to be a department chair at SMHS on the basis that he is a District, rather than‘a site ©
employee, because he supports students from all four: comprehensive high schools.
In the special education department.at Righetti High School, where Goodman serves as
department chair, the special education teacher serving in the equivalent position as Goldin is
_ allowed to vote for department chair, .
The Association does not dispute Goldin’s ability to voie for the-depariment chair in the
special education department at SMHS but “illogically and in retaliation, disputes his
qualification to be the department chair.”
On or-about Apfil 23, 2014, the District notified Association that. Goldin was.a SMHS
employee and the Association did not have authority fo determine which District: employees.
are “District employees” and whicli employees are “site employees.” ‘There is no distinction
included in the CBA and it is the past practice to allow all department members at a school site.
to rim for department chair in his/her department if he/she so desires. The District further
stated that ifthe Association continued to refuse fo place Goldin on the ballot, it retained the
right to file an unfair practice against the Association because it was causing the District to
violate the Educational Employment Relations Act section 3543.5 by causing it to discriminate
or.otherwise interfere with, restrain, or coerce Goldin because of his exercise of protected
rights. .
Another election was held for the SMHS special education department chair. -. the Association
refused to place Goldin and Andrade on the ballot, Association members who are also
members of the SMHS. special education department nevertheless “wrote in” votes for Goldin
and Andrade and again selected them as co-chairs of the department. However, the .
Association réfused to “count” those votes and identified another employee as department
chair of SMHS. That employee, also an Association member, believes that Goldin and
Andrade were appropriately elected as department chairs,LA-CO-#624-E
- November 13, 2014
Page 3
On or about May 30, 2014, the District determined that it must recognize the validly elected
etiployees, Goldin.and Andrade, as'co-chairs of the SMHS special education department, It
notified Goldin and Andrade of that decision and'carbon copied appropriate Association
2 representsicives of that decision,.
On.or about-June 2, 2014, the: Association filed a grievance against the District maintaining the
District has “illegally” interfered with the Association’s role as “conductor of elections” and
that it retains authority to determine qualifications for department chai.
The Association has engaged in this course of action to retaliate against Goldin for engaging in
“protected activity.” Specifically, Goldin has attempted to participate in Association activities
including-running fot Association president and running for department chair.. These are -
employee rights protected by EERA and.the Association has retaliated against Goldin for
seeking election to Association office and-to deter other members of the Association
bargaining unit from seeking office. The Association is also attempting to force the District to
impose ‘adverse consequences upon Goldin ‘brough the loss:of. department co-chair status and
Joss of a paid stipend.
The Association is also attempting to use.the gricvatice 5 article to force the District to impose:
these adverse consequences on Goldin, :
The District asserts that “[b]y. the acts set forthi above, among other acts, the Association has .
violated Governnient Code section 3543.6(2) by causing or attempting to.cause the District to _
‘{i]mpose or threaten to impose reprisals on employees; to discriminate or threaten to
discriminate against employees, or otherwise to interfere with, restrain, or.coerce employees
because of their exercise of rights guaranteed by this chapter’ in violation of Government Code
section 3543.5(a).”
DISCUSSION
Under EERA, it is unlawful for an-employee organization to cause or attempt to cmise an
- employer to conimit an unfair practice. (Gov.-Code, § 3543.6, subd. (a).)- A Violation of this
provision may only be established by a clear showing of how and in what manner the =~
employee organization affirmatively acted to cause or attempt to cause the unfair practice,
(Fustin Unified School District (987) PERB. Decision No. 626.) ‘In addition, the facts must
establish a causal connection between the employer’s unlawful conduct and the employee
organization’s behavior. (State of California (Department of Personnel Administration) 1987) .
PERB Decision No. 609-S.)
The District alleges that the Association caused or-attempted to cause the District to violate the
Educational Employment Relations Act section 3543.5 by causing it to discriminate or
otherwise interfere with, restrain, or coerce Goldin. because of his exercise of protected rights. ©
However, the information. provided in the charge does not demonstrate that the District
engaged in an unfair practice or otherwise interfered with or retaliated against Goldin. It is
therefore not possible to establish, from thé facts presented, that the Association affirmativelyLA-CO-1624-E
November 13, 2014
Page 4
acted to-cause.or attempt to catise any unfair practice on the part of the District. Itis also
unclear that the Association acted affirmatively “to encourage or assist” the District in
interfering, discriminating or retaliating against Goldin, (California. Nurses Association
(O'Malley) (2004) PERB Decision No. 1651-H.) Also,to-the extent.the District may be
asserting rights-on behalf of Goldin,
such a claim.
unclear whether the District has standing to assért
For these reasons the charge, as presently written, does not state a prima facie case? Ef there
are. arly factual inaccuracies in this letter or additional facts that would correct the-deficiencies
explained above, Charging Party may amend the charge. The.amended charge should be.
prepared on a.standard PERB unfair practice charge form, clearly labeled First Amended
‘Charge, coittain all tle facts and allegations you wish to iake, and be signed under penalty of
perjury by an authorized agent of Charging Party, The amended charge must have the case
number written on the top right hand comer of the charge form. The amended charge must be
served on the Respondent’ s'representative and the: al proof of service must be filed with
PERB; Ifan amended charge or withdrawal is not filed-on or before November'24, 20143
PERB will dismiss your charge. If you have-any questions, please call-me at the above
telephone number,
Sincerely,
Mary Weiss 3
Senior Regional Attorney
MW
. In Eastside Union School District (1984) PERB Decision No. 466, the Board
explained that aprima facie case is established where the Board agent is able to make “a
determination that the facts as alleged in the charge state a legal cause of action and that the
charging party is capable of providing admissible evidence in support of the allegations.
Consequeiitly, where the. investigation results in receipt of conflicting allegations of fact or
contrary theories of law, fair proceedings, if not due process, demand that a complaint be
issued and the matter be-sent td formal hearing.” (Zbid.)
3 A document is “filed” on the date thé document is. actually received by PERB,
including if transinitted via facsimile or electronic mail. (PERB Regulation 32135.)I certify that I am over the age of 18 years and not a party to the within, action; that
my residence address is 309 Stanforth Ct, San Ramon, CA; and that on this date I served a
true copy of the document:
» DECLARATION OF SAMUEL CASAS IN OPPOSITION TO IFPTE'S MOTION
FOR SUMMARY JUDGEMENT, OR ALTERNATIVELY, SUMMARY
ADJUDICATION OF ISSUES
e SECOND REQUEST FOR JUDICIAL NOTICE IN OPPOSITION TO IFPTE’S
MOTION FOR SUMMARY JUDGEMENT, OR ALTERNATIVELY,
SUMMARY ADJUDICATION OF ISSUES
On February 9, 2017, I served the above referenced document in the following
Manner:
(——] By Certified Mail/Return Receipt Requested in a sealed eivelope, addressed as noted
below,, with. postage. fully prepaid and deposited at the US Post Office located in El
Cerrito, CA.
By US. Mail, by placing the document(s) listed above in a sealed envelope, addressed as
noted below, with postage fully prepaid and deposited at the US Post Office located in. San
Ramon, CA.
Ari Krantz
Leonard Carder, LLP
1330 Broadway, Suite# 1450
Oakland, CA 94612
] By Hand Delivery to Yolanda Skelton, Steward for International Federation of Professional
and Technical Engineers, Local 21 Richmond Chapter at 450 Civic Center Plaza, Richmond,
CA.94804.
(=) By Email, to the recipients at the address as noted below:
- akrantz@leonardcarder.com
I declate under penalty of perjury, under the Jaw of the State of California, that the
foregoing is true and correct.
Executed on Wednesday, February 9, 2017 at San Ramon, California..
* gi
fia Fleury
Preview
e _ [5205 Gordon Avenue || PLAINTIFF, IN PRO PER Gautam Manandhar BI Cerrito, California 94530 }(510)508-9510 SUPERIOR COURT OF THE STATE OF CALIF 'ORNIA. FOR THE COUNTY OF CONTRA COSTA Gautam Manandhar, ) Case No.: C15-02088 ) , Plaintiff, ) SECOND REQUEST FOR JUDICIAL ) NOTICE IN OPPOSITION TO IFPTE’S v. ) MOTION FOR SUMMARY JUDGEMENT, : ) OR ALTERNATIVELY, SUMMARY (INTERNATIONAL FEDERATION OF ) ADJUDICATION OF ISSUES PROFESSIONAL AND TECHNICAL ) ENGINEERS LOCAL 21, RICHMOND ) Date: CHAPTER and DOES 1-10, ) Time: ) Judge: Honorable Jill Fannin. | Defendants . ) Department: 21 Jo Action Filed: Nov i) 26+9 Plaintiff respectfiilly requests that this Court take judicial notice of the following documents: 1, November 13, 2014 WARNING LETTER from California Public Employment Relations Board (“PERB”) regarding unfair practice charge no. LA-CO-1624-E Santa Maria Joint Union High Sctiool District filed against Santa Maria Joint Union High School District Faculty Association. A true and correct copy of the WARNING LETTER is attached as Exhibit 1. 1 SECOND REQUEST FOR JUDICIAL NOTICE IN OPPOSSITION TO IFPTE’S MOTION FOR SUMMARY JUDGEMENT, OR ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES.The attached documents are records and reports of the administrative agency PERB pursuant to California Evidence Code §§452 and 453 and California Rule of Court 3.1113¢1). I California Evidence Code 452(c) states that judicial notice may be taken of “[o]fficial acts of | | the legislative, executive, and judicial departments of the United States and of any state of the United | States.” Official acts of the executive department include orders of administrative. agencies and their reports and records. Taiheiyo Cement U.S.A., Inc. v. Franchise Tax Board (2012).204 Cal. App. 4® 1254, 267, fn.5, citing Rodas v. Spiegel (2001) 87 Cal. App. 4" 513, 518. Dated: February 9, 2017 Respectfully Submitted, onend. autafa-Manardnar Plaigaiff, In Pro Per 2 SECOND REQUEST FOR JUDICIAL NOTICE IN OPPOSSITION TO IFPTE’S MOTION FOR SUMMARY JUDGEMENT, OR ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES |‘STATE-OF-CALIFORNIA ° @ e@ PUBLIC EMPLOYMENT RELATIONS BOARD Lo ‘Los Angeles Rogional Office ‘700 N. Central Ave., Suite 200 Glendale, CA 91203-3219 ‘Telophone: (818)551-2809° ‘Fax: (818) 551-2820 November 13, 2014 Chelsea R. Olson, Attorney Kronick Moskovitz Tiedemann & Girard . 733 Marsh Street, Suite 210 San Luis Obispo, CA 93401 Re: Santa Maria.Joint Union High School District v. Santa Maria Joint Union HighSchoot District FacultyAssociation — Unfair Practice Charge No. LA-CO-1624-E WARNING LETTER Dear Ms. Olson: The above-referenced unfair practice charge was filed with the Public Employment Relations Board (PERB or Board) on July 11, 2014, The Santa Maria Joint Union High School District (District or Charging Party) alleges that the Santa Maria Joint Union High School District Faculty Association (Association. or Respondent) violated section 3543.6(a) of the Educational’ Employment Relations Act (EERA or Act)! by causing or attempting to cause the District to. commit an-unfair practice. 5 BACTS AS | ALLEGED : The District and the Association are parties to a collective bargaining agreemient (CBA) covering the.certificated.employee bargaining unit. Mark Goodrian (Goodrnan) is the Association Chapter President. Glenn Goldin (Goldin) is employed by the District at Santa Maria High School (SMHS) in its special education department. His classtoom is based at SMHS, he is supervised and evaluated by'the SMHS principal, he is paid through funding allocated for SMHS, he is part of the SMHS special éducation department, attends department meetings and is identified on both District and school documents as being:a member of the SMHS special education department. . All District special education programs are open to all students in the Distfict. Like many othér spécial education teachers, Goldin teaches special education students from all of the District’s four comprehensive high schools. EERA is codified at Government Code section 3540 et seq. PERB’s. Regulations are codified at California Code:of Regulations, title 8, section 31001 et seq. The text of the EBRA and PERB Regulations may be found-at www.perb.ca.gov. EDMUND G: BROWNIR, Governor.LA-CO-1624-E November 13, 2014 Page 2 :° Goldin has been an outspoken critic of current Association leadership. During the 2013-2014 school year, Goldin ran against Goodman for Association Chapter President. Goldin lost the election and Goodman remains Association Chapter President. On or about April 2014, District departments solicited nominations and held elections for department chairs at all four'comprehensive school sites throughout District. Pursuant to CBA, Asticle 3.5.2, department chairs are to be elected by their respective constituencies at each. school site and must be paid a 9-10.5% stipend by the District for performing department hie duties, © Goldin was nominated to serve as co-chair of fthe SMHS special education department with another SMHS special.education teacher, Matt Andrade (Andrade). In a preliminary election on or about May 2014, Goldin and Andrade were unanimously selected: by their constituency (the special education teachers at SMES). On-or about April 15, 2014, the Association Election Committee determined that Goldin was ineligible to be a department chair at SMHS on the basis that he is a District, rather than‘a site © employee, because he supports students from all four: comprehensive high schools. In the special education department.at Righetti High School, where Goodman serves as department chair, the special education teacher serving in the equivalent position as Goldin is _ allowed to vote for department chair, . The Association does not dispute Goldin’s ability to voie for the-depariment chair in the special education department at SMHS but “illogically and in retaliation, disputes his qualification to be the department chair.” On or-about Apfil 23, 2014, the District notified Association that. Goldin was.a SMHS employee and the Association did not have authority fo determine which District: employees. are “District employees” and whicli employees are “site employees.” ‘There is no distinction included in the CBA and it is the past practice to allow all department members at a school site. to rim for department chair in his/her department if he/she so desires. The District further stated that ifthe Association continued to refuse fo place Goldin on the ballot, it retained the right to file an unfair practice against the Association because it was causing the District to violate the Educational Employment Relations Act section 3543.5 by causing it to discriminate or.otherwise interfere with, restrain, or coerce Goldin because of his exercise of protected rights. . Another election was held for the SMHS special education department chair. -. the Association refused to place Goldin and Andrade on the ballot, Association members who are also members of the SMHS. special education department nevertheless “wrote in” votes for Goldin and Andrade and again selected them as co-chairs of the department. However, the . Association réfused to “count” those votes and identified another employee as department chair of SMHS. That employee, also an Association member, believes that Goldin and Andrade were appropriately elected as department chairs,LA-CO-#624-E - November 13, 2014 Page 3 On or about May 30, 2014, the District determined that it must recognize the validly elected etiployees, Goldin.and Andrade, as'co-chairs of the SMHS special education department, It notified Goldin and Andrade of that decision and'carbon copied appropriate Association 2 representsicives of that decision,. On.or about-June 2, 2014, the: Association filed a grievance against the District maintaining the District has “illegally” interfered with the Association’s role as “conductor of elections” and that it retains authority to determine qualifications for department chai. The Association has engaged in this course of action to retaliate against Goldin for engaging in “protected activity.” Specifically, Goldin has attempted to participate in Association activities including-running fot Association president and running for department chair.. These are - employee rights protected by EERA and.the Association has retaliated against Goldin for seeking election to Association office and-to deter other members of the Association bargaining unit from seeking office. The Association is also attempting to force the District to impose ‘adverse consequences upon Goldin ‘brough the loss:of. department co-chair status and Joss of a paid stipend. The Association is also attempting to use.the gricvatice 5 article to force the District to impose: these adverse consequences on Goldin, : The District asserts that “[b]y. the acts set forthi above, among other acts, the Association has . violated Governnient Code section 3543.6(2) by causing or attempting to.cause the District to _ ‘{i]mpose or threaten to impose reprisals on employees; to discriminate or threaten to discriminate against employees, or otherwise to interfere with, restrain, or.coerce employees because of their exercise of rights guaranteed by this chapter’ in violation of Government Code section 3543.5(a).” DISCUSSION Under EERA, it is unlawful for an-employee organization to cause or attempt to cmise an - employer to conimit an unfair practice. (Gov.-Code, § 3543.6, subd. (a).)- A Violation of this provision may only be established by a clear showing of how and in what manner the =~ employee organization affirmatively acted to cause or attempt to cause the unfair practice, (Fustin Unified School District (987) PERB. Decision No. 626.) ‘In addition, the facts must establish a causal connection between the employer’s unlawful conduct and the employee organization’s behavior. (State of California (Department of Personnel Administration) 1987) . PERB Decision No. 609-S.) The District alleges that the Association caused or-attempted to cause the District to violate the Educational Employment Relations Act section 3543.5 by causing it to discriminate or otherwise interfere with, restrain, or coerce Goldin. because of his exercise of protected rights. © However, the information. provided in the charge does not demonstrate that the District engaged in an unfair practice or otherwise interfered with or retaliated against Goldin. It is therefore not possible to establish, from thé facts presented, that the Association affirmativelyLA-CO-1624-E November 13, 2014 Page 4 acted to-cause.or attempt to catise any unfair practice on the part of the District. Itis also unclear that the Association acted affirmatively “to encourage or assist” the District in interfering, discriminating or retaliating against Goldin, (California. Nurses Association (O'Malley) (2004) PERB Decision No. 1651-H.) Also,to-the extent.the District may be asserting rights-on behalf of Goldin, such a claim. unclear whether the District has standing to assért For these reasons the charge, as presently written, does not state a prima facie case? Ef there are. arly factual inaccuracies in this letter or additional facts that would correct the-deficiencies explained above, Charging Party may amend the charge. The.amended charge should be. prepared on a.standard PERB unfair practice charge form, clearly labeled First Amended ‘Charge, coittain all tle facts and allegations you wish to iake, and be signed under penalty of perjury by an authorized agent of Charging Party, The amended charge must have the case number written on the top right hand comer of the charge form. The amended charge must be served on the Respondent’ s'representative and the: al proof of service must be filed with PERB; Ifan amended charge or withdrawal is not filed-on or before November'24, 20143 PERB will dismiss your charge. If you have-any questions, please call-me at the above telephone number, Sincerely, Mary Weiss 3 Senior Regional Attorney MW . In Eastside Union School District (1984) PERB Decision No. 466, the Board explained that aprima facie case is established where the Board agent is able to make “a determination that the facts as alleged in the charge state a legal cause of action and that the charging party is capable of providing admissible evidence in support of the allegations. Consequeiitly, where the. investigation results in receipt of conflicting allegations of fact or contrary theories of law, fair proceedings, if not due process, demand that a complaint be issued and the matter be-sent td formal hearing.” (Zbid.) 3 A document is “filed” on the date thé document is. actually received by PERB, including if transinitted via facsimile or electronic mail. (PERB Regulation 32135.)I certify that I am over the age of 18 years and not a party to the within, action; that my residence address is 309 Stanforth Ct, San Ramon, CA; and that on this date I served a true copy of the document: » DECLARATION OF SAMUEL CASAS IN OPPOSITION TO IFPTE'S MOTION FOR SUMMARY JUDGEMENT, OR ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES e SECOND REQUEST FOR JUDICIAL NOTICE IN OPPOSITION TO IFPTE’S MOTION FOR SUMMARY JUDGEMENT, OR ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES On February 9, 2017, I served the above referenced document in the following Manner: (——] By Certified Mail/Return Receipt Requested in a sealed eivelope, addressed as noted below,, with. postage. fully prepaid and deposited at the US Post Office located in El Cerrito, CA. By US. Mail, by placing the document(s) listed above in a sealed envelope, addressed as noted below, with postage fully prepaid and deposited at the US Post Office located in. San Ramon, CA. Ari Krantz Leonard Carder, LLP 1330 Broadway, Suite# 1450 Oakland, CA 94612 ] By Hand Delivery to Yolanda Skelton, Steward for International Federation of Professional and Technical Engineers, Local 21 Richmond Chapter at 450 Civic Center Plaza, Richmond, CA.94804. (=) By Email, to the recipients at the address as noted below: - akrantz@leonardcarder.com I declate under penalty of perjury, under the Jaw of the State of California, that the foregoing is true and correct. Executed on Wednesday, February 9, 2017 at San Ramon, California.. * gi fia Fleury