On January 25, 2019 a
Proof of Service
was filed
involving a dispute between
California Fire Protection Coalition,
Del Toro Trejo, Juan Carlos,
Filed By: Fire Guard Corporation,
Fire Guard Corporation,
Shahangian, Bahman Brian,
and
California Department Of Forestry And Fire Protection,
California Office Of The State Fire Marshal,
Dennis Mathisen In His Official Capacity As State Fire Marshal,
Does 1-10,
Jeffery Schwartz In His Official Capacity As Deputy State Fire Marshall,
Mike Richwine In His Official Capacity As State Fire Marshal,
for (Civil Rights/Discrimination)
in the District Court of Sacramento County.
Preview
1 ROB BONTA
Attorney General of California
2 RUSSELL B. HiLDRETH
3
Supervising Deputy Attorney General
ANDREA M. KENDRICK State Bar No. 225688
F!LEO/EMOORSED
COURTNEY S. COVINGTON, State Bar No. 259723
4 Deputy Attorneys General SEP 2 8 2022
13001 Street, Suite 125
5 P.O. Box 944255 By:. E. Macdonald
Sacramento, CA 94244-2550 Deputy Clerk
6 Telephone: (916)210-7821
Fax: (916) 327-2319
7 E-mail: Andrea.Kendrick(^doj.ca.gov
8 Attorneys for Defendants Exempt from Filing Fees
Pursuant to Gov. Code § 6103
9
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
COUNTY OF SACRAMENTO
11
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13 FIRE GUARD CORPORATION;
BAHMAN BRIAN SHAHANGIAN, an Case No. 34-2019-00249221-CU-CR-GDS
14 individual; and CALIFORNIA FIRE
PROTECTION COALITION, a California DECLARATION OF SERVICE BY
15 Corporation; and JUAN CARLOS DEL ELECTRONIC MAIL AND
TORO TREJO, an individual, OVERNIGHT COURIER
16
Plaintiffs, Date: October 27, 2022
17 Time: 1:30 p.m.
Dept.: 53
18 Trial Date: December 18, 2023
Acfion Filed: January 25, 2019
19 CALIFORNIA DEPARTMENT OF
FORESTRY AND FIRE PROTECTION;
20 CALIFORNIA OFFICE OF THE STATE Reservation No.: 2663593
FIRE MARSHAL; MIKE RICHWINE, in
21 his official capacity as State Fire Marshal;
JEFFERY SCHWARTZ, in his official
22 capacity as Deputy State Fire Marshal; and
DOES 1 through 10, inclusive,
.23
Defendants.
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Declaration of Service by Electronic Mail and Overnight Courier (34-2019-00249221)
1 DECLARATION OF SERVICE BY E-MAIL AND OVERNIGHT COURIER
2 Case Name: Fire Guard Corporation, et al. v. California Department of Forestiy and
Fire Protection, et al.
3 No.: 34-2019-00249221-CU-CR-GDS
4 I declare:
5 I am employed in the Office of the Attorney General, which is the office of a member of the
California State Bar, at which member's direction this service is made. 1 am 18 years of age or
6 older and not a party to this matter; my business address is: 1300 I Street, Suite 125, P.O. Box
944255, Sacramento, CA 94244-2550. I am familiar with the business practice at the Office of
7 the Attomey General for collection and processing of correspondence for overnight mail with the
Federal Express. In accordance with that practice, correspondence placed in the internal mail
collection system at the Office of the Attorney General is deposited with the overnight courier
that same day in the ordinary course of business.
9
On September 28, 2022,1 served the following documents by transmitting a true copy via
10 electronic mail
11 • DEFENDANTS' NOTICE OF MOTION AND MOTION (A) TO COMPEL
PLAINTIFFS FIRE GUARD CORPORATION, BAHMAN BRIAN
12 SHAHANGIAN, AND JUAN CARLOS DEL TORO TREJO TO PROVIDE
13 RESPONSES TO (1) SPECIAL INTERROGATORIES (SET ONE), (2) FORM
INTERROGATORIES (SET ONE), AND (3) REQUESTS FOR PRODUCTION
14 OF DOCUMENTS (SET ONE); AND (B) FOR AN ORDER DEEMING
ADMITTED THE REQUESTS FOR ADMISSION (SET ONE)
15
• MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
16 DEFENDANTS' MOTION (A) TO COMPEL PLAINTIFFS FIRE GUARD
17 CORPORATION, BAHMAN BRIAN SHAHANGIAN, AND JUAN CARLOS
DEL TORO TREJO TO PROVIDE RESPONSES TO (1) SPECIAL
8 INTERROGATORIES (SET ONE), (2) FORM INTERROGATORIES (SET
ONE), AND (3) REQUESTS FOR PRODUCTION OF DOCUMENTS (SET
19 ONE); AND (B) FOR AN ORDER DEEMING ADMITTED THE REQUESTS
FOR ADMISSION (SET ONE)
21 • DECLARATION OF ANDREA M. KENDRICK IN SUPPORT OF
DEFENDANTS' MOTION (A) TO COMPEL PLAINTIFFS FIRE GUARD
22 CORPORATION, BAHMAN BRIAN SHAHANGIAN, AND JUAN CARLOS
DEL TORO TREJO TO PROVIDE RESPONSES TO (1) SPECIAL
23 INTERROGATORIES (SET ONE), (2) FORM INTERROGATORIES (SET
ONE), AND (3) REQUESTS FOR PRODUCTION OF DOCUMENTS (SET
24 ONE); AND (B) FOR AN ORDER DEEMING ADMITTED THE REQUESTS
25 FOR ADMISSION (SET ONE)
26 In addition, I placed a true copy thereof enclosed in a sealed envelope, in the internal mail
27 system of the Office of the Attorney General, for overnight delivery, addressed as follows:
28
2
Declaration of Service by Electronic Mail and Overnight Courier (34-2019-00249221)
1 Timothy V. Kassouni, Esq. Margaret Esquiroz, Esq.
KASSOUNI LAW esquiroz(a),pm.me
2 455 Capitol Mall, Suite 604 Attorney for Defendant California Fire
Sacramento, CA 95814 Protection Coalition
3 timothv@kassounilaw.com Via Electronic Mail only
Attorney for Plaintiffs
4 Fire Guard Corporation, Bahman Brian
Shahangian, and Juan Carlos Del Toro Trejo
5 Via Electronic Mail and Federal Express
Overnight
6
7 I declare under penalty of perjury under the laws of the State of California and the United Slates
of America the foregoing is true and correct and that thys declaration was executed on September
8 28, 2022, at Sacramento, Califomia.
9 Kristi Dykstra
Declarant Signature
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SA2019300028
11 36593655 docx
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Declaration of Service by Electronic Mail and Overnight Courier (34-2019-00249221)
Preview
1 ROB BONTA Attorney General of California 2 RUSSELL B. HiLDRETH 3 Supervising Deputy Attorney General ANDREA M. KENDRICK State Bar No. 225688 F!LEO/EMOORSED COURTNEY S. COVINGTON, State Bar No. 259723 4 Deputy Attorneys General SEP 2 8 2022 13001 Street, Suite 125 5 P.O. Box 944255 By:. E. Macdonald Sacramento, CA 94244-2550 Deputy Clerk 6 Telephone: (916)210-7821 Fax: (916) 327-2319 7 E-mail: Andrea.Kendrick(^doj.ca.gov 8 Attorneys for Defendants Exempt from Filing Fees Pursuant to Gov. Code § 6103 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SACRAMENTO 11 12 13 FIRE GUARD CORPORATION; BAHMAN BRIAN SHAHANGIAN, an Case No. 34-2019-00249221-CU-CR-GDS 14 individual; and CALIFORNIA FIRE PROTECTION COALITION, a California DECLARATION OF SERVICE BY 15 Corporation; and JUAN CARLOS DEL ELECTRONIC MAIL AND TORO TREJO, an individual, OVERNIGHT COURIER 16 Plaintiffs, Date: October 27, 2022 17 Time: 1:30 p.m. Dept.: 53 18 Trial Date: December 18, 2023 Acfion Filed: January 25, 2019 19 CALIFORNIA DEPARTMENT OF FORESTRY AND FIRE PROTECTION; 20 CALIFORNIA OFFICE OF THE STATE Reservation No.: 2663593 FIRE MARSHAL; MIKE RICHWINE, in 21 his official capacity as State Fire Marshal; JEFFERY SCHWARTZ, in his official 22 capacity as Deputy State Fire Marshal; and DOES 1 through 10, inclusive, .23 Defendants. 24 25 26 27 28 Declaration of Service by Electronic Mail and Overnight Courier (34-2019-00249221) 1 DECLARATION OF SERVICE BY E-MAIL AND OVERNIGHT COURIER 2 Case Name: Fire Guard Corporation, et al. v. California Department of Forestiy and Fire Protection, et al. 3 No.: 34-2019-00249221-CU-CR-GDS 4 I declare: 5 I am employed in the Office of the Attorney General, which is the office of a member of the California State Bar, at which member's direction this service is made. 1 am 18 years of age or 6 older and not a party to this matter; my business address is: 1300 I Street, Suite 125, P.O. Box 944255, Sacramento, CA 94244-2550. I am familiar with the business practice at the Office of 7 the Attomey General for collection and processing of correspondence for overnight mail with the Federal Express. In accordance with that practice, correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the overnight courier that same day in the ordinary course of business. 9 On September 28, 2022,1 served the following documents by transmitting a true copy via 10 electronic mail 11 • DEFENDANTS' NOTICE OF MOTION AND MOTION (A) TO COMPEL PLAINTIFFS FIRE GUARD CORPORATION, BAHMAN BRIAN 12 SHAHANGIAN, AND JUAN CARLOS DEL TORO TREJO TO PROVIDE 13 RESPONSES TO (1) SPECIAL INTERROGATORIES (SET ONE), (2) FORM INTERROGATORIES (SET ONE), AND (3) REQUESTS FOR PRODUCTION 14 OF DOCUMENTS (SET ONE); AND (B) FOR AN ORDER DEEMING ADMITTED THE REQUESTS FOR ADMISSION (SET ONE) 15 • MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF 16 DEFENDANTS' MOTION (A) TO COMPEL PLAINTIFFS FIRE GUARD 17 CORPORATION, BAHMAN BRIAN SHAHANGIAN, AND JUAN CARLOS DEL TORO TREJO TO PROVIDE RESPONSES TO (1) SPECIAL 8 INTERROGATORIES (SET ONE), (2) FORM INTERROGATORIES (SET ONE), AND (3) REQUESTS FOR PRODUCTION OF DOCUMENTS (SET 19 ONE); AND (B) FOR AN ORDER DEEMING ADMITTED THE REQUESTS FOR ADMISSION (SET ONE) 21 • DECLARATION OF ANDREA M. KENDRICK IN SUPPORT OF DEFENDANTS' MOTION (A) TO COMPEL PLAINTIFFS FIRE GUARD 22 CORPORATION, BAHMAN BRIAN SHAHANGIAN, AND JUAN CARLOS DEL TORO TREJO TO PROVIDE RESPONSES TO (1) SPECIAL 23 INTERROGATORIES (SET ONE), (2) FORM INTERROGATORIES (SET ONE), AND (3) REQUESTS FOR PRODUCTION OF DOCUMENTS (SET 24 ONE); AND (B) FOR AN ORDER DEEMING ADMITTED THE REQUESTS 25 FOR ADMISSION (SET ONE) 26 In addition, I placed a true copy thereof enclosed in a sealed envelope, in the internal mail 27 system of the Office of the Attorney General, for overnight delivery, addressed as follows: 28 2 Declaration of Service by Electronic Mail and Overnight Courier (34-2019-00249221) 1 Timothy V. Kassouni, Esq. Margaret Esquiroz, Esq. KASSOUNI LAW esquiroz(a),pm.me 2 455 Capitol Mall, Suite 604 Attorney for Defendant California Fire Sacramento, CA 95814 Protection Coalition 3 timothv@kassounilaw.com Via Electronic Mail only Attorney for Plaintiffs 4 Fire Guard Corporation, Bahman Brian Shahangian, and Juan Carlos Del Toro Trejo 5 Via Electronic Mail and Federal Express Overnight 6 7 I declare under penalty of perjury under the laws of the State of California and the United Slates of America the foregoing is true and correct and that thys declaration was executed on September 8 28, 2022, at Sacramento, Califomia. 9 Kristi Dykstra Declarant Signature 10 SA2019300028 11 36593655 docx 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of Service by Electronic Mail and Overnight Courier (34-2019-00249221)