Preview
22CV407258
Santa Clara — Civil
‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
CM,110
f Figming
Margot M. Parker (SBN 263205); Payam Malakouti (316640)
O'HAGAN MEYER Electronically Filed
21650 Oxnard St., Suite 530 by Superior Court of CA,
Woodland Hills, CA 91367
County of Santa Clara,
teLepHone no. (213) 306-1610 FAX NO. (Optionay: (213) 306-1615 ion 4/3/2023 4:26 PM
E-MAIL ADDRESS (Optiona): Mparker@ohaganmeyer.com
ATTORNEY FOR (Name): Defendants, PCRC, Malissa Jones, and Celia Benavides Reviewed By: R. Fleming
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Clara
ase #22CV407258
STREET ADDRESS: 191 North First Street Envelope: 11607399
MAILING ADDRESS:
CITY AND ZIP CODE, San Jose, CA 95113
BRANCH NAME: Downtown Superior Court
PLAINTIFF/PETITIONER: Chilone Payton
DEFENDANT/RESPONDENT: Tracy Rogers et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
22CV407258
(Check one): X UNLIMITED CASE Oo LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 04/18/2023 Time: 1:30 PM Dept.: 16 Div.: Room:
Address of court (if different from the address above):
Ed Notice of Intent to Appear by Telephone, by (name): Margot M. Parker; Payam Malakouti
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a This statement is submitted by party (name): PCRC, Malissa Jones, and Celia Benavides
b. (This statement is submitted jointly by parties (names):
Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a The complaint was filed on (date):
b. (1 The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
a 0 al parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. (11 The following parties named in the complaint or cross-complaint
(1) (1 have not been served (specify names and explain why not):
(2) (have been served but have not appeared and have not been dismissed (specify names):
(3) (have had a default entered against them (specify names):
c. Oo The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
Description of case
a Type
of case in [XJ] complaint 1 cross-compiaint (Describe, including causes of action):
1. Hostile Work Environment; 2. Discrimination in Violation of FEHA; 3. Retaliation in Violation of Labor Code §
1102.5; 4. Wrongful Termination; and 5. Failure to Take all Reasonable Steps to Prevent Harassment.
Page 1 of 5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California rules 3.720-3.730,
‘CM-110 [Rev. July 1, 2011] www.courts.ca.gov
Le;
CM-110
PLAINTIFF/PETITIONER: Chilone Payton CASE NUMBER:
22CV407258
|DEFENDANT/RESPONDENT: PCRC, Malissa Jones, and Celia Benavides
4 b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff alleges racial and gender discrimination, hostile work environment, failure to take reasonable steps to
prevent harassment, retaliation, and wrongful termination. Defendants deny all allegations entirely.
oO (If more space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request Ka jury trial 0 anoniury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a. (1 The trial has been set for (date):
b. EJ No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain): Defendants anticipate the case will be ready for trial within 12 months of the April 18 CMC.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
8/14/2023-8/25/2023; 9/19/2023-9/29/2023; 1/2/2024-1/12/2024; 2/5/2024-2/15/2024; 3/5/24-3/15/2024.
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. EX] days (specify number): 3-5
b O hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial 1 by the attorney or party listed in the caption C1 by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
Oo Additional representation is described in Attachment 8.
Preference
This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel KI has C1 has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party oO has C1 has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) [1 This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
20 Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
gO This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
M-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 of 5
Amer LegalNet, hi
www iWork
CM-110
PLAINTIFF/PETITIONER: Chilone Payton CASE NUMBER:
22CV407258
IDEFENDANT/RESPONDENT: Tracy Rogers et al.
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):
® Mediation session not yet scheduled
oO Mediation session scheduled for (date):
(1) Mediation
oO Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date)
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
arbitration
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
(M-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5
‘an Legal
ms ork
CM-110
bs PLAINTIFF/PETITIONER: Chilone Payton ‘CASE NUMBER:
22CV407258
IEFENDANT/RESPONDENT: Tracy Rogers et al.
ie Insurance
a Insurance carrier, if any, for party filing this statement (name): Arch Insurance
b. Reservation of rights: RX Yes 0 No
c. L]_ Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
1 Bankruptcy [] Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. 1 There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
(1 Additional cases are described in Attachment 13a.
b. 1 Amotion to Oo consolidate Oo coordinate will be filed by (name party):
14. Bifurcation
I The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
Defendants reserve the right to request bifurcation of liability and damages.
15. Other motions
Kl The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Defendants reserve the right to file a motion for summary judgment/adjudication.
16. Discovery
a. 0 The party or parties have completed all discovery.
b & The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Descriptio Date
Defendants’ Written Discovery February 2024
Defendants’ Depositions March 2024
Defendants’ Expert Discovery Per Code
c. 1 The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
(M-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5
Ame aN Inc.
www ork w.com
CM-110
PLAINTIFF/PETITIONER: Chilone Payton CASE NUMBER:
22CV407258
|DEFENDANT/RESPONDENT: Tracy Rogers et al.
17. Economic litigation
a C This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. C2 This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
[1 The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a Ed The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of
Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any):
| am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: April 3, 2023
Margot M. Parker VAM4 oi- VOA KL
(TYPE OR PRINT NAME) ( |ATURE OF PARTY OR ATTORNEY)
>
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
C0 Additional signatures are attached.
(OM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5
Ame in LegalNet,
www msWorkF
PROOF OF SERVICE
STATE OF CALIFORNIA )
) ss.
COUNTY OF LOS ANGELES )
I am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action. My business address is: 21650 Oxnard Street, Suite 530,
Woodland Hills, CA 91367.
On April 3, 2023, I served the foregoing document described as DEFENDANTS' CASE
MANAGEMENT STATEMEMENT in this action by placing a true copy thereof enclosed in a
sealed envelope addressed as follows:
SEE SERVICE LIST
10
I BY MAIL: I enclosed this document in a sealed envelope or package addressed to the
11 person(s) at the address(es) below and placed the envelope(s) for collection and mailing following
our ordinary business practices. I am readily familiar with this firm's practice for collecting and
12 processing correspondence for mailing. On the same day that correspondence is placed for collection
and mailing, it is deposited in the ordinary course of business with the United States Postal Service
13
in a sealed envelope with postage fully prepaid.
14
O BY FACSIMILE: I caused such documents to be delivered via facsimile to the offices of
15 the addressee(s) at the following facsimile number.
16
x BY ELECTRONIC MAIL: Based on a court order or an agreement of the parties to accept
service by electronic transmission, I caused the documents to be sent to the persons at the electronic
17
notification listed herein on this date. I did not receive within a reasonable time after the transmission,
18 any electronic message or other indication that the transmission was unsuccessful.
19 O BY OVERNIGHT DELIVERY: I served the foregoing document by Federal Express, an
express service carrier which provides overnight delivery, as follows. I placed true copies of the
20 foregoing document in sealed envelopes or packages designated by the express service carrier,
21 addressed to each interested party as set forth above, with fees for overnight delivery paid or provided
for.
22
O BY PERSONAL SERVICE: I caused the above-listed documents to be delivered by
23 hand to the address indicated on the below Service List.
24
& (STATE) I declare under penalty of perjury under the laws of the State of California that the
25 above is true and correct.
26 Executed on April 3, 2023, at Woodland Hills, California.
27
28 Erica Betkovics
1
PROOF OF SERVICE
SERVICE LIST
Chilone Payton v. Tracy Rogers, et al.
LASC Case No. 22CV407258
Jonathan D. Kent Attorneys for Plaintiff,
Kent Legal P.C. Chilone Payton
9595 Wilshire Blvd., Suite 900
Beverly Hills, CA 90212
lel: 310-300-4032
Email: jkent@kentlegalpc.com
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PROOF OF SERVICE
Preview
22CV407258 Santa Clara — Civil ‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY CM,110 f Figming Margot M. Parker (SBN 263205); Payam Malakouti (316640) O'HAGAN MEYER Electronically Filed 21650 Oxnard St., Suite 530 by Superior Court of CA, Woodland Hills, CA 91367 County of Santa Clara, teLepHone no. (213) 306-1610 FAX NO. (Optionay: (213) 306-1615 ion 4/3/2023 4:26 PM E-MAIL ADDRESS (Optiona): Mparker@ohaganmeyer.com ATTORNEY FOR (Name): Defendants, PCRC, Malissa Jones, and Celia Benavides Reviewed By: R. Fleming SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Clara ase #22CV407258 STREET ADDRESS: 191 North First Street Envelope: 11607399 MAILING ADDRESS: CITY AND ZIP CODE, San Jose, CA 95113 BRANCH NAME: Downtown Superior Court PLAINTIFF/PETITIONER: Chilone Payton DEFENDANT/RESPONDENT: Tracy Rogers et al. CASE MANAGEMENT STATEMENT CASE NUMBER: 22CV407258 (Check one): X UNLIMITED CASE Oo LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 04/18/2023 Time: 1:30 PM Dept.: 16 Div.: Room: Address of court (if different from the address above): Ed Notice of Intent to Appear by Telephone, by (name): Margot M. Parker; Payam Malakouti INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a This statement is submitted by party (name): PCRC, Malissa Jones, and Celia Benavides b. (This statement is submitted jointly by parties (names): Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a The complaint was filed on (date): b. (1 The cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) a 0 al parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. (11 The following parties named in the complaint or cross-complaint (1) (1 have not been served (specify names and explain why not): (2) (have been served but have not appeared and have not been dismissed (specify names): (3) (have had a default entered against them (specify names): c. Oo The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): Description of case a Type of case in [XJ] complaint 1 cross-compiaint (Describe, including causes of action): 1. Hostile Work Environment; 2. Discrimination in Violation of FEHA; 3. Retaliation in Violation of Labor Code § 1102.5; 4. Wrongful Termination; and 5. Failure to Take all Reasonable Steps to Prevent Harassment. Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California rules 3.720-3.730, ‘CM-110 [Rev. July 1, 2011] www.courts.ca.gov Le; CM-110 PLAINTIFF/PETITIONER: Chilone Payton CASE NUMBER: 22CV407258 |DEFENDANT/RESPONDENT: PCRC, Malissa Jones, and Celia Benavides 4 b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff alleges racial and gender discrimination, hostile work environment, failure to take reasonable steps to prevent harassment, retaliation, and wrongful termination. Defendants deny all allegations entirely. oO (If more space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request Ka jury trial 0 anoniury trial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a. (1 The trial has been set for (date): b. EJ No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): Defendants anticipate the case will be ready for trial within 12 months of the April 18 CMC. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 8/14/2023-8/25/2023; 9/19/2023-9/29/2023; 1/2/2024-1/12/2024; 2/5/2024-2/15/2024; 3/5/24-3/15/2024. Estimated length of trial The party or parties estimate that the trial will take (check one): a. EX] days (specify number): 3-5 b O hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial 1 by the attorney or party listed in the caption C1 by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: Oo Additional representation is described in Attachment 8. Preference This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel KI has C1 has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party oO has C1 has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) [1 This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. 20 Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. gO This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): M-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 of 5 Amer LegalNet, hi www iWork CM-110 PLAINTIFF/PETITIONER: Chilone Payton CASE NUMBER: 22CV407258 IDEFENDANT/RESPONDENT: Tracy Rogers et al. 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): ® Mediation session not yet scheduled oO Mediation session scheduled for (date): (1) Mediation oO Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date) Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): (M-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5 ‘an Legal ms ork CM-110 bs PLAINTIFF/PETITIONER: Chilone Payton ‘CASE NUMBER: 22CV407258 IEFENDANT/RESPONDENT: Tracy Rogers et al. ie Insurance a Insurance carrier, if any, for party filing this statement (name): Arch Insurance b. Reservation of rights: RX Yes 0 No c. L]_ Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. 1 Bankruptcy [] Other (specify): Status: 13. Related cases, consolidation, and coordination a. 1 There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: (1 Additional cases are described in Attachment 13a. b. 1 Amotion to Oo consolidate Oo coordinate will be filed by (name party): 14. Bifurcation I The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): Defendants reserve the right to request bifurcation of liability and damages. 15. Other motions Kl The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Defendants reserve the right to file a motion for summary judgment/adjudication. 16. Discovery a. 0 The party or parties have completed all discovery. b & The following discovery will be completed by the date specified (describe all anticipated discovery): Party Descriptio Date Defendants’ Written Discovery February 2024 Defendants’ Depositions March 2024 Defendants’ Expert Discovery Per Code c. 1 The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): (M-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5 Ame aN Inc. www ork w.com CM-110 PLAINTIFF/PETITIONER: Chilone Payton CASE NUMBER: 22CV407258 |DEFENDANT/RESPONDENT: Tracy Rogers et al. 17. Economic litigation a C This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. C2 This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues [1 The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a Ed The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): | am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: April 3, 2023 Margot M. Parker VAM4 oi- VOA KL (TYPE OR PRINT NAME) ( |ATURE OF PARTY OR ATTORNEY) > (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) C0 Additional signatures are attached. (OM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5 Ame in LegalNet, www msWorkF PROOF OF SERVICE STATE OF CALIFORNIA ) ) ss. COUNTY OF LOS ANGELES ) I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action. My business address is: 21650 Oxnard Street, Suite 530, Woodland Hills, CA 91367. On April 3, 2023, I served the foregoing document described as DEFENDANTS' CASE MANAGEMENT STATEMEMENT in this action by placing a true copy thereof enclosed in a sealed envelope addressed as follows: SEE SERVICE LIST 10 I BY MAIL: I enclosed this document in a sealed envelope or package addressed to the 11 person(s) at the address(es) below and placed the envelope(s) for collection and mailing following our ordinary business practices. I am readily familiar with this firm's practice for collecting and 12 processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service 13 in a sealed envelope with postage fully prepaid. 14 O BY FACSIMILE: I caused such documents to be delivered via facsimile to the offices of 15 the addressee(s) at the following facsimile number. 16 x BY ELECTRONIC MAIL: Based on a court order or an agreement of the parties to accept service by electronic transmission, I caused the documents to be sent to the persons at the electronic 17 notification listed herein on this date. I did not receive within a reasonable time after the transmission, 18 any electronic message or other indication that the transmission was unsuccessful. 19 O BY OVERNIGHT DELIVERY: I served the foregoing document by Federal Express, an express service carrier which provides overnight delivery, as follows. I placed true copies of the 20 foregoing document in sealed envelopes or packages designated by the express service carrier, 21 addressed to each interested party as set forth above, with fees for overnight delivery paid or provided for. 22 O BY PERSONAL SERVICE: I caused the above-listed documents to be delivered by 23 hand to the address indicated on the below Service List. 24 & (STATE) I declare under penalty of perjury under the laws of the State of California that the 25 above is true and correct. 26 Executed on April 3, 2023, at Woodland Hills, California. 27 28 Erica Betkovics 1 PROOF OF SERVICE SERVICE LIST Chilone Payton v. Tracy Rogers, et al. LASC Case No. 22CV407258 Jonathan D. Kent Attorneys for Plaintiff, Kent Legal P.C. Chilone Payton 9595 Wilshire Blvd., Suite 900 Beverly Hills, CA 90212 lel: 310-300-4032 Email: jkent@kentlegalpc.com 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 PROOF OF SERVICE