Preview
MAY A L L H U R L E Y P.C.
FllEQ/EU
DQBSED
JOHN P. BRISCOE (SBN: 273690)
2 ibriscoe(g),mavallaw.com APR 1 8 2022
2453 Grand Canal Boulevard
3
Stockton, California 95207-8253 By:. H. PEMFLTQN
Deputy Clerk
4 Telephone: (209) 477-3833
Facsimile: (209) 473-4818
5
Attorneys for Plaintiff David Ridge
6
7 SUPERIOR COURT OF T H E STATE OF CALIFORNIA
8 IN AND FOR T H E COUNTY OF SACRAMENTO
9 DAVID RIDGE, an individual, Case No.: 34-2019-00265393
10 NOTICE OF MOTION AND MOTION
Plaintiff,
11 TO COMPEL FURTHER RESPONSES
vs. TO SPECIAL INTERROGATORIES, SET
12 T H R E E ; REQUEST FOR MONETARY
THE CALIFORNIA HIGHWAY PATROL; SANCTIONS
13 and DOES 1-100, inclusive.
Date: May 10, 2022
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Defendants. Time: 1:30 p.in.
15 Dept.: 53
Res.: 2636452
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19 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
20 Notice is hereby given that on May 10, 2022 at 1:30 p.m. in Department 53 of the above-
21 entitled Court, pursuant to Code of Civil Procedure section 2030.300, Plaintiff David Ridge
22 ("Ridge") will and does hereby move for an order compelling Defendant California Highway
23 Patrol ("Defendant" or "CHP") to strike objections and provide further and complete responses
24 to Special Interrogatories, Set Three. Ridge further moves this Court to impose a monetary
25 sanction against Defendant and counsel therefor (James Curran), jointly and severally, in the
26 amount of $5,200 in accordance with pertinent provisions of the Civil Discovery Act (Code of
27 Civil Procedure sections 2023.010 et 5e^..and 2030.300, subd. (d)).
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Notice of Motion and Motion to Compel Further Responses to Special Interrogatories, Set Three; Request for
Monetary Sanctions
Page 1 of 3
This motion is made on the grounds that CHP and its attorneys have bent over backwards
2 to conceal the names and contact information of percipient witnesses. In this employment action,
3 Ridge alleges that he requested a reasonable accommodation for his back and related injuries by
4 way of an external load-bearing vest (in lieu of the heavy leather duty belt on which CHP
5 officers typically carry a heavy load of personal equipment). CHP insists this was not a
6 reasonable accommodation for Ridge because it constituted a deviation from the standard
7 uniform and poses vague "safety, appearance, and operational" concerns. In other words, CHP
8 says that the external load-bearing vest was not a reasonable accommodation for Ridge because
9 it is not, and never has been, a reasonable item for any patrol officer to wear as a general
10 matter. It has thus placed its own Uniform Policy at issue.
11 Through discovery. Ridge obtained an email from one Officer Erik Mallory ("Mallory"),
12 an active-duty CHP officer and pilot who strongly disagrees with CHP's "no-vest" policy,
13 chiefly on the quite-substantiated fact that wearing a heavy load of personal equipment on a duty
14 belt tends to lead to cumulative lower body injuries. Mallory was deposed, and—doubtless to the
15 chagrin of CHP and its attorneys—freely testified that he believes CHP's no-vest policy is inane,
16 and cosmetic in purpose (i.e., much as Ridge was informed, the leadership simply prefers the
17 look of the belt, rampant ergonomic injuries—which have been recognized by the Legislature—
18 notwithstanding). Mallory, fervently believing that the weight-bearing vest would result in fewer
19 lower back injuries to CHP officers, took it upon himself to send out an unofficial survey to
20 hundreds of CHP officers. Per Officer Mallory, out of437 responses, 385 active-duty CHP
21 officers affirmatively responded and said that they would pay for their own weight-bearing
22 vests if it was approved as a uniform item. Most of these officers also freely attested that they
23 currently have back stress while wearing a duty belt, and that they believe that external load
24 bearing vests would benefit the CHP and its employees. Based on this overwhelming indictment,
25 it is clear that these persons are percipient witnesses as to whether CHP's inflexible "no-vest"
26 policy is a reasonable one. Since CHP has invoked that policy as a reason as to why it could not
27 permit Ridge to wear a vest as a reasonable accommodation, this subject is a relevant one and
28
Notice of Motion and Motion to Compel Further Responses to Special Interrogatories, Set Three; Request for
Monetary Sanctions
Page 2 of 3
subject to discovery, and thus the employees who voluntarily responded to this survey are
2 percipient witnesses.
3 This motion is made pursuant to Code of Civil Procedure section 2030.300, and is based
4 on this Notice, the Memorandum of Points and Authorities, the Separate Statement of Discovery
5 Matters in Dispute, the Declaration of John P. Briscoe and exhibits thereto, and on such further
6 evidence as may be submitted upon reply and at hearing. In accordance with Code of Civil
7 Procedure sections 2016.040 and 2030.300, the undersigned attempted to meet and confer with
8 counsel for CHP, James Curran, but Mr. Curran refused to provide full and complete responses
9 to the interrogatories. Thus, this motion is necessary.
10 ///
11 DATED: April 7, 2022 MAY ALL HURLEY P.C.
12 By
JOHN P. BRISCOE
13 Attorneys for Plaintiff
14 DAVID RIDGE
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Notice of Motion and Motion to Compel Further Responses to Special Interrogatories, Set Three; Request for
Monetary Sanctions
Page 3 of 3 •
Ridge V. California Highway Patrol, et al.
Sacramento County Superior Court Case No. 34-2019-00265393
PROOF OF SERVICE
2
I, the undersigned, certify and declare as follows:
3 1 am over the age of eighteen years and not a party to this action. My business address is 2453
Grand Canal Boulevard, Stockton, Califomia 95207 that is located in the county where the mailing
4 and/or delivery below took place.
5 On April 7, 2022, 1 served the following document:
6 NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL
INTERROGATORIES, SET THREE; REQUEST FOR MONETARY SANCTIONS
7
addressed to:
8
James F. Curran
9 Deputy Attomey General
P.O. Box 944255
10 Sacramento, CA 94244-2550 .
James.Curran@doj.ca.gov
II
• BUSINESS PRACTICE TO ENTRUST DEPOSIT TO OTHERS: I am readily familiar with
12 the business practice at my place of business for collection and processing of correspondence for
mailing with the United States Postal Service. Correspondence so collected and processed is
13 deposited with the United States Postal Service that same day in the ordinary course of business.
On the date specified below, at my place of business at Stockton, Califomia a copy of the document
14 described above was placed for deposit in the United States Postal Service in a sealed envelope,
with postage fully prepaid addressed to the individuals and/or entities mentioned above; and that
15 envelope was placed for collection and mailing on that date following ordinary business practice.
16 • BY EXPRESS SERVICE CARRIER: On the date specified below, ! directed to be deposited in a
box or other facility regularly maintained by Federal Express or delivered to a courier or driver
17 authorized by said express service carrier to receive documents, a copy of the document mentioned
above, in an envelope designed by the said express service carrier, with delivery fees paid or
18 provided for, addressed to the individuals and/or entities mentioned above.
19 EI BY EMAIL: In accordance with Code of Civil Procedure, Section 1010.6, on the date specified
below, I caused a copy of the document(s) described above to be sent to the person(s) at the e-mail
20 address(es) listed above. My business e-mail address is lrilev@mavallaw.com. I did not receive,
within a reasonable time after the transmission, any electronic message or other indication that the
21 transmission was unsuccessful.
22 I certify and declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
23
Executed on April 7, 2022, at Stockton, California.
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25
LINDSAY RILE
26
27
PROOF OF SERVICE
28
I MAYALL HURLEY P.C.
JOHN P. BRISCOE (SBN: 273690)
2 ibriscoe@mavallaw.com
2453 Grand Canal Boulevard
3 Stockton, California 95207-8253
4 Telephone: (209) 477-3833
Facsimile: (209)473-4818
5
Attorneys for Plaintiff David Ridge
6
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 IN AND FOR THE COUNTY OF SACRAMENTO
9 DAVID RIDGE, an individual. Case No.: 34-2019-00265393
10 Plaintiff, [PROPOSED] ORDER GRANTING
II MOTION TO COMPEL FURTHER
vs. RESPONSES TO SPECIAL
12 INTERROGATORIES, SET THREE;
THE CALIFORNIA HIGHWAY PATROL; REQUEST FOR MONETARY
13 and DOES 1-100, inclusive, SANCTIONS
14 Defendants. Date: May 10,2022
15 Time: 1:30 p.m.
Dept.: 53
16 Res.: 2636452
17
18
19
20
21 Plaintiff David Ridge's Motion to Compel Further Responses to Special Interrogatories, Set
22 Three; Request for Monetary Sanctions came on regularly for hearing on May 10, 2022 at 1:30
23 p.m. in Department 53 of the above-entitled Court. Appearances by counsel are reflected in the
24 Court's file.
25 Having read and considered the papers and evidence supporting and opposing Plaintiffs
26 motion, having heard and considered the argument of counsel at the hearing, and good cause
appearing therefor:
TTT 28
[proposed] Order Granting Plaintiffs Motion to Compel Further Responses to Special Interrogatories, Set Three;
equest for Monetary Sanctions
83 age I of2
IT IS HEREBY ORDERED that Plaintiffs motion is granted as requested. Defendant
2 California Highway Patrol shall strike all objections to Special Interrogatories, Set Three, Nos. 9
3 and 10, and shall serve further, direct, and complete responses within fifteen calendar days of
4 notice of entry of this Order.
5 IT IS FURTHER ORDERED that. Plaintiff is awarded $5,200 in monetary sanctions as
6 against Defendant California Highway Patrol and counsel therefor, James Curran, jointly and
7 severally. This shall be paid in full within fifteen calendar days of notice of entry of this order.
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9 DATED:
Judge of the Superior Court
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[Proposed] Order Granting Plaintiffs Motion to Compel Further Responses to Special Interrogatories, Set Three;
Request for Monetary Sanctions
Page 2 of2
Ridge V. California Highway Patrol, el. al.
Sacramento County Superior Court Case No. 34-2019-00265393
1
PROOF OF SERVICE
2
I, the undersigned, certify and declare as follows:
3 1 am over the age of eighteen years and not a party to this action. My business address is 2453
Grand Canal Boulevard, Stockton, Califomia.95207 that is located in the county where the mailing
4 and/or delivery below took place.
5 On April 7, 2022, 1 served the following document:
6 [PROPOSED] ORDER GRANTING MOTION TO COMPEL FURTHER RESPONSES TO
SPECIAL INTERROGATORIES, SET THREE; REQUEST FOR MONETARY SANCTIONS
7
addressed to:
8
James F. Curran
9 Deputy Attomey General
P.O. Box 944255
10 Sacramento, CA 94244-2550
James.Curran@doi.ca.gov
11
• BUSINESS PRACTICE TO ENTRUST DEPOSIT TO OTHERS: I am readily familiar with
12 the business practice at my place of business for collection and processing of correspondence for
mailing with the United States Postal Service. Correspondence so collected and processed is
13 deposited with the United States Postal Service that same day in the ordinary course of business.
On the date specified below, at my place of business at Stockton, Califomia a copy of the document
14 described above was placed for deposit in the United States Postal Service in a sealed envelope,
with postage fully prepaid addressed to the individuals and/or entities mentioned above; and that
15 envelope was placed for collection and mailing on that date following ordinary business practice.
16 • BY EXPRESS SERVICE CARRIER: On the date specified below, I directed to be deposited in a
box or other facility regularly maintained by Federal Express or delivered to a courier or driver
17 authorized by said express service carrier to receive documents, a copy of the document mentioned
above, in an envelope designed by the said express service carrier, with delivery fees paid or
18 provided for, addressed to the individuals and/or entities mentioned above.
19 0 BY EMAIL: In accordance with Code of Civil Procedure, Section 1010.6, on the date specified
below, I caused a copy of the document(s) described above to be sent to the person(s) at the e-mail
20 address(es) listed above. My business e-mail address is lrilev@mavallaw.com. I did not receive,
within a reasonable time after the transmission, any electronic message or other indication that the
21 transmission was unsuccessful.
22 1 certify and declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
23
Executed on April 7, 2022, al Stockton, California.
24
25
LINDSA^Y RILE
26
27
PROOF OF SERVICE
28
Preview
MAY A L L H U R L E Y P.C. FllEQ/EU DQBSED JOHN P. BRISCOE (SBN: 273690) 2 ibriscoe(g),mavallaw.com APR 1 8 2022 2453 Grand Canal Boulevard 3 Stockton, California 95207-8253 By:. H. PEMFLTQN Deputy Clerk 4 Telephone: (209) 477-3833 Facsimile: (209) 473-4818 5 Attorneys for Plaintiff David Ridge 6 7 SUPERIOR COURT OF T H E STATE OF CALIFORNIA 8 IN AND FOR T H E COUNTY OF SACRAMENTO 9 DAVID RIDGE, an individual, Case No.: 34-2019-00265393 10 NOTICE OF MOTION AND MOTION Plaintiff, 11 TO COMPEL FURTHER RESPONSES vs. TO SPECIAL INTERROGATORIES, SET 12 T H R E E ; REQUEST FOR MONETARY THE CALIFORNIA HIGHWAY PATROL; SANCTIONS 13 and DOES 1-100, inclusive. Date: May 10, 2022 14 Defendants. Time: 1:30 p.in. 15 Dept.: 53 Res.: 2636452 16 17 18 19 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 20 Notice is hereby given that on May 10, 2022 at 1:30 p.m. in Department 53 of the above- 21 entitled Court, pursuant to Code of Civil Procedure section 2030.300, Plaintiff David Ridge 22 ("Ridge") will and does hereby move for an order compelling Defendant California Highway 23 Patrol ("Defendant" or "CHP") to strike objections and provide further and complete responses 24 to Special Interrogatories, Set Three. Ridge further moves this Court to impose a monetary 25 sanction against Defendant and counsel therefor (James Curran), jointly and severally, in the 26 amount of $5,200 in accordance with pertinent provisions of the Civil Discovery Act (Code of 27 Civil Procedure sections 2023.010 et 5e^..and 2030.300, subd. (d)). 28 Notice of Motion and Motion to Compel Further Responses to Special Interrogatories, Set Three; Request for Monetary Sanctions Page 1 of 3 This motion is made on the grounds that CHP and its attorneys have bent over backwards 2 to conceal the names and contact information of percipient witnesses. In this employment action, 3 Ridge alleges that he requested a reasonable accommodation for his back and related injuries by 4 way of an external load-bearing vest (in lieu of the heavy leather duty belt on which CHP 5 officers typically carry a heavy load of personal equipment). CHP insists this was not a 6 reasonable accommodation for Ridge because it constituted a deviation from the standard 7 uniform and poses vague "safety, appearance, and operational" concerns. In other words, CHP 8 says that the external load-bearing vest was not a reasonable accommodation for Ridge because 9 it is not, and never has been, a reasonable item for any patrol officer to wear as a general 10 matter. It has thus placed its own Uniform Policy at issue. 11 Through discovery. Ridge obtained an email from one Officer Erik Mallory ("Mallory"), 12 an active-duty CHP officer and pilot who strongly disagrees with CHP's "no-vest" policy, 13 chiefly on the quite-substantiated fact that wearing a heavy load of personal equipment on a duty 14 belt tends to lead to cumulative lower body injuries. Mallory was deposed, and—doubtless to the 15 chagrin of CHP and its attorneys—freely testified that he believes CHP's no-vest policy is inane, 16 and cosmetic in purpose (i.e., much as Ridge was informed, the leadership simply prefers the 17 look of the belt, rampant ergonomic injuries—which have been recognized by the Legislature— 18 notwithstanding). Mallory, fervently believing that the weight-bearing vest would result in fewer 19 lower back injuries to CHP officers, took it upon himself to send out an unofficial survey to 20 hundreds of CHP officers. Per Officer Mallory, out of437 responses, 385 active-duty CHP 21 officers affirmatively responded and said that they would pay for their own weight-bearing 22 vests if it was approved as a uniform item. Most of these officers also freely attested that they 23 currently have back stress while wearing a duty belt, and that they believe that external load 24 bearing vests would benefit the CHP and its employees. Based on this overwhelming indictment, 25 it is clear that these persons are percipient witnesses as to whether CHP's inflexible "no-vest" 26 policy is a reasonable one. Since CHP has invoked that policy as a reason as to why it could not 27 permit Ridge to wear a vest as a reasonable accommodation, this subject is a relevant one and 28 Notice of Motion and Motion to Compel Further Responses to Special Interrogatories, Set Three; Request for Monetary Sanctions Page 2 of 3 subject to discovery, and thus the employees who voluntarily responded to this survey are 2 percipient witnesses. 3 This motion is made pursuant to Code of Civil Procedure section 2030.300, and is based 4 on this Notice, the Memorandum of Points and Authorities, the Separate Statement of Discovery 5 Matters in Dispute, the Declaration of John P. Briscoe and exhibits thereto, and on such further 6 evidence as may be submitted upon reply and at hearing. In accordance with Code of Civil 7 Procedure sections 2016.040 and 2030.300, the undersigned attempted to meet and confer with 8 counsel for CHP, James Curran, but Mr. Curran refused to provide full and complete responses 9 to the interrogatories. Thus, this motion is necessary. 10 /// 11 DATED: April 7, 2022 MAY ALL HURLEY P.C. 12 By JOHN P. BRISCOE 13 Attorneys for Plaintiff 14 DAVID RIDGE 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Notice of Motion and Motion to Compel Further Responses to Special Interrogatories, Set Three; Request for Monetary Sanctions Page 3 of 3 • Ridge V. California Highway Patrol, et al. Sacramento County Superior Court Case No. 34-2019-00265393 PROOF OF SERVICE 2 I, the undersigned, certify and declare as follows: 3 1 am over the age of eighteen years and not a party to this action. My business address is 2453 Grand Canal Boulevard, Stockton, Califomia 95207 that is located in the county where the mailing 4 and/or delivery below took place. 5 On April 7, 2022, 1 served the following document: 6 NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE; REQUEST FOR MONETARY SANCTIONS 7 addressed to: 8 James F. Curran 9 Deputy Attomey General P.O. Box 944255 10 Sacramento, CA 94244-2550 . James.Curran@doj.ca.gov II • BUSINESS PRACTICE TO ENTRUST DEPOSIT TO OTHERS: I am readily familiar with 12 the business practice at my place of business for collection and processing of correspondence for mailing with the United States Postal Service. Correspondence so collected and processed is 13 deposited with the United States Postal Service that same day in the ordinary course of business. On the date specified below, at my place of business at Stockton, Califomia a copy of the document 14 described above was placed for deposit in the United States Postal Service in a sealed envelope, with postage fully prepaid addressed to the individuals and/or entities mentioned above; and that 15 envelope was placed for collection and mailing on that date following ordinary business practice. 16 • BY EXPRESS SERVICE CARRIER: On the date specified below, ! directed to be deposited in a box or other facility regularly maintained by Federal Express or delivered to a courier or driver 17 authorized by said express service carrier to receive documents, a copy of the document mentioned above, in an envelope designed by the said express service carrier, with delivery fees paid or 18 provided for, addressed to the individuals and/or entities mentioned above. 19 EI BY EMAIL: In accordance with Code of Civil Procedure, Section 1010.6, on the date specified below, I caused a copy of the document(s) described above to be sent to the person(s) at the e-mail 20 address(es) listed above. My business e-mail address is lrilev@mavallaw.com. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the 21 transmission was unsuccessful. 22 I certify and declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 23 Executed on April 7, 2022, at Stockton, California. 24 25 LINDSAY RILE 26 27 PROOF OF SERVICE 28 I MAYALL HURLEY P.C. JOHN P. BRISCOE (SBN: 273690) 2 ibriscoe@mavallaw.com 2453 Grand Canal Boulevard 3 Stockton, California 95207-8253 4 Telephone: (209) 477-3833 Facsimile: (209)473-4818 5 Attorneys for Plaintiff David Ridge 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 IN AND FOR THE COUNTY OF SACRAMENTO 9 DAVID RIDGE, an individual. Case No.: 34-2019-00265393 10 Plaintiff, [PROPOSED] ORDER GRANTING II MOTION TO COMPEL FURTHER vs. RESPONSES TO SPECIAL 12 INTERROGATORIES, SET THREE; THE CALIFORNIA HIGHWAY PATROL; REQUEST FOR MONETARY 13 and DOES 1-100, inclusive, SANCTIONS 14 Defendants. Date: May 10,2022 15 Time: 1:30 p.m. Dept.: 53 16 Res.: 2636452 17 18 19 20 21 Plaintiff David Ridge's Motion to Compel Further Responses to Special Interrogatories, Set 22 Three; Request for Monetary Sanctions came on regularly for hearing on May 10, 2022 at 1:30 23 p.m. in Department 53 of the above-entitled Court. Appearances by counsel are reflected in the 24 Court's file. 25 Having read and considered the papers and evidence supporting and opposing Plaintiffs 26 motion, having heard and considered the argument of counsel at the hearing, and good cause appearing therefor: TTT 28 [proposed] Order Granting Plaintiffs Motion to Compel Further Responses to Special Interrogatories, Set Three; equest for Monetary Sanctions 83 age I of2 IT IS HEREBY ORDERED that Plaintiffs motion is granted as requested. Defendant 2 California Highway Patrol shall strike all objections to Special Interrogatories, Set Three, Nos. 9 3 and 10, and shall serve further, direct, and complete responses within fifteen calendar days of 4 notice of entry of this Order. 5 IT IS FURTHER ORDERED that. Plaintiff is awarded $5,200 in monetary sanctions as 6 against Defendant California Highway Patrol and counsel therefor, James Curran, jointly and 7 severally. This shall be paid in full within fifteen calendar days of notice of entry of this order. 8 9 DATED: Judge of the Superior Court 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 [Proposed] Order Granting Plaintiffs Motion to Compel Further Responses to Special Interrogatories, Set Three; Request for Monetary Sanctions Page 2 of2 Ridge V. California Highway Patrol, el. al. Sacramento County Superior Court Case No. 34-2019-00265393 1 PROOF OF SERVICE 2 I, the undersigned, certify and declare as follows: 3 1 am over the age of eighteen years and not a party to this action. My business address is 2453 Grand Canal Boulevard, Stockton, Califomia.95207 that is located in the county where the mailing 4 and/or delivery below took place. 5 On April 7, 2022, 1 served the following document: 6 [PROPOSED] ORDER GRANTING MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET THREE; REQUEST FOR MONETARY SANCTIONS 7 addressed to: 8 James F. Curran 9 Deputy Attomey General P.O. Box 944255 10 Sacramento, CA 94244-2550 James.Curran@doi.ca.gov 11 • BUSINESS PRACTICE TO ENTRUST DEPOSIT TO OTHERS: I am readily familiar with 12 the business practice at my place of business for collection and processing of correspondence for mailing with the United States Postal Service. Correspondence so collected and processed is 13 deposited with the United States Postal Service that same day in the ordinary course of business. On the date specified below, at my place of business at Stockton, Califomia a copy of the document 14 described above was placed for deposit in the United States Postal Service in a sealed envelope, with postage fully prepaid addressed to the individuals and/or entities mentioned above; and that 15 envelope was placed for collection and mailing on that date following ordinary business practice. 16 • BY EXPRESS SERVICE CARRIER: On the date specified below, I directed to be deposited in a box or other facility regularly maintained by Federal Express or delivered to a courier or driver 17 authorized by said express service carrier to receive documents, a copy of the document mentioned above, in an envelope designed by the said express service carrier, with delivery fees paid or 18 provided for, addressed to the individuals and/or entities mentioned above. 19 0 BY EMAIL: In accordance with Code of Civil Procedure, Section 1010.6, on the date specified below, I caused a copy of the document(s) described above to be sent to the person(s) at the e-mail 20 address(es) listed above. My business e-mail address is lrilev@mavallaw.com. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the 21 transmission was unsuccessful. 22 1 certify and declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 23 Executed on April 7, 2022, al Stockton, California. 24 25 LINDSA^Y RILE 26 27 PROOF OF SERVICE 28