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ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address)
FOR COURT USEONLY
Wendy C. York, SBN 166864/Virginia Martucci,SBN 316296 Electronically Filed
York Law Corporation
1111 Exposition Boulevard
10/12/2023 12:10 PM
Building 500 Superior Court of California
Sacramento, CA 95815 County of Stanislaus
TELEPHONENO.: 916 - 643 - ZZ00 FAxNo.(optionaq: 916-643-4680 Clerk of the Court
EMAIL ADDRESS (Optiona/): By: Narelly Garcia, Deputy
ATTORNEY FOR Name: Attorne for Plaintiffs
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Stanislaus
STREET ADDRESS: H0Z 10th Street
MAILING ADDRESS:
CITY AND ZIPCODE:MOCl2StO~ CA 95354
BRANCH NAME:
PLAINTIFF/PETITIONER:Larry B. Dignes, et al.
DEFENDANT/RESPONDENT: Covenant Care California, LLC, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): m UNLIMITED CASE Q LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less) CV-20-004057
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: October 30, 2023 Time:8:30 a.m. Dept.: 24 Div.: Room:
Address of court (if different from the address above):
m Notice of Intent to Appear by Telephone, by (name): Virginia Martucci
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. m This statement is submitted by party (name): Plaintiffs, Larry B. Dignes, et al .
b. Q This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): September 18, 2020
b. Q The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. m All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. Q The following parties named in the complaint or cross-complaint
(1) Q have not been served (specify names and expla/n why nof):
(2) Q have been served but have not appeared and have not been dismissed (specify names):
(3) Q have had a default entered against them (specify names):
c. Q The following additional parties may be added (specify names, nature of Involvement in case, and date by which
they maybe served):
4. Description of case
a. Type of case in m complaint ~ cross-complaint (Describe, including causes of action):
Negligence; Elder Abuse/Neglect; Negligent Misrepresentation; Negligent Hiring,
Training and Retention; Violation of Patient's Bill of Rights; Wrongful Death.
Pa e1of5
Form Adopted for Mandatory Use
CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California
CM-110 [Rev. July 1, 2011] rules 3720-3.730
CM-110
PLAINTIFF/PETITIONER: arry ignes, E' d
CASE NUMBER:
DEFENDANT(RESPONDENT:Covenant Care California, LLC, et a1.
CV-20-004057
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 amountJ, estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. if equitable relief is sought, describe the nature of the relief,)
This elder/neglect case arises from Defendants' failures to supervise, manage,
support, operate and properly staff and train their Turlock Nursing & Rehabilitation
Center facility. As a result of Defendants` neglect, Decedent LARRY B. DIGNES
contracted C. Difficile infection, from which he died.
Q (If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request m a jury trial Q a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. [~ The trial has been set for (date):
b. m 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):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
12/4/23, 2/20/24, 4/8/24, 5/21/24, 5/28/24, 9/10/24, 10/7/24, 11/11/24 and 2/4/25
are dates that Trials are already scheduled in other matters.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. m days (specify number): 15-20
b. Q hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial m by the attorney or party listed in the caption Q by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
Q Additional representation is described in Attachment 8.
9. Preference
Q 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 Q has m 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 Q has Q has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) Q 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.
(2) Q 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.
(3) m 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): The amount exceeds
the jurisdictional limit.
GM-110 ~Kev. July 1, 2011]
CASE MANAGEMENT STATEMENT Pace z of s
arry ignes, e a CM-110
PLAINTIFF/PETITIONER: CASE NUMBER:
DEFENDANT/RESPONDENT:Covenant Care California, LLC, et al.
CV-20-004057
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 al/ 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 alt that apply): stipulafron):
Q Mediation session not yet scheduled
m Q Mediation session scheduled for (dafe):
(1) Mediation
0 Agreed to complete mediation by (dafe):
m Mediation completed on (dafe): March 20, 2023
m Settlement conference not yet scheduled
(2) Settlement m Q Settlement conference scheduled for (date):
conference
~ Agreed to complete settlement conference by (date):
Q Settlement conference completed on (date):
Q Neutral evaluation not yet scheduled
Q Neutral evaluation scheduled for (dafe):
(3) Neutral evaluation Q
Q Agreed to complete neutral evaluation by (date):
Q Neutral evaluation completed on (date):
Q Judicial arbitration not yet scheduled
(4) Nonbinding Judicial ~ Q Judicial arbitration scheduled for (date):
arbitration 0 Agreed to complete judicial arbitration by (date):
Q Judicial arbitration completed on (date):
m Private arbitration not yet scheduled
(5) Binding private Q Private arbitration scheduled for (date):
arbitration ~ Q Agreed to complete private arbitration by (date):
Q Private arbitration completed on (date):
Q ADR session not yet scheduled
Q ADR session scheduled for (date):
(6) Other (specify): Q
Q Agreed to complete ADR session by (date):
Q ADR completed on (date):
CM-110 (Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: arry lgnes, e a CASE NUMBER:
DEFENDANT/RESPONDENT:Covenant Care California, LLC, et al.
CV-20-004057
11. Insurance
a. Q Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Q Yes Q No
c. Q 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.
Q Bankruptcy m Other (specify): The Court stayed this matter and ordered the parties to
Status: arbitration, which is pending,
13. Related cases, consolidation, and coordination
a. Q There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
Q Additional cases are described in Attachment 13a.
b. Q A motion to Q consolidate Q coordinate will be filed by (name party):
14. Bifurcation
Q 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):
15. Qther motions
Q The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. Q The party or parties have completed all discovery.
b. m The following discovery will be completed by the date specified (describe all anticipated discovery):
Partv Description Date
Plaintiffs Form Rogs., Spec. Rogs., RFPDs and
RFAs 11/2023
Plaintiffs Depositions
1/2024
Plaintiffs Expert Discovery Per Code
c. m The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Discovery has not occurred because this case has been pending with the arbitrator
for nearly two years. Arbitration has not yet been set in this matter. Defendants
recently were ordered to pay all arbitration costs. They paid initiating fees on
10/11/23.
CM-170 [Rev. July 1, 2011
CASE MANAGEMENT STATEMENT Page4of5
arry
CM -11(
PLAINTIFFIPETITI0NER: Dignes, et a CASE NUMBER:
DEFENDANT/RESPONDENT: Covenant Care California, LLC, et al.
CV-20-004057
17. Economic litigation
a. Q 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. Q 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 specif(cally why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
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. Q 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 dis very and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter int stipulations o~ese i the time of
the case management conference, including the written authority of the party where requ'red. ,---~ ~ ,,~ ~
Date: October 11, 2023
Virginia Martucci 1 ~~ ~ ~'~
(TYPE OR PRINT NAME) (SIGN T RE OF PA ~Y OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Q Additional signatures are attached.
GM-19U ~Kev. JUIy 1, 2011)
CASE MANAGEMENT STATEMENT -- Pase s ots
COURT: Stanislaus County Superior Court
CASE NO. CV-20-004057
2
CASE NAME: Dignes v. Covenant Care California, LLC, et al.
3
PROOF OF SERVICE
4
I am a citizen of the United States, employed in the County of Sacramento, State of
5 California. My business address is 1111 Exposition Boulevard, Building 500, Sacramento CA
95815. I am over the age of 18 years and not a party to the above-entitled action.
6
7 I am readily familiar with York Law Corporation's practice for collection and
processing of correspondence for mailing with the United States Postal Service. Pursuant to
8 said practice, each document is placed in an envelope, the envelope is sealed, the appropriate
postage is placed thereon, and the sealed envelope is placed in the office mail receptacle. Each
9 day's mail is collected and deposited in a U.S. mailbox at or before the close of each day's
business. (CCP Section 1013a(3) or Fed.R.Civ.P.S(a) and 4.1; USDC (E.D. CA) L.R. 5-
to
135(a).)
1t
On October 12, 2023, I caused the within, CASE MANAGEMENT STATEMENT, I
12 caused the within, to be served via:
13 XX ELECTRONIC SERVICE: Based on a Court order or on an agreement by the parties
accept service by e-mail or electronic transmission, I caused the document descri~
14 above to be sent from e-mail my address (vmaz-tucci(a,yorklawfirm.net) to the persons
the e-mail addresses) listed below.
15
i6 John Supple, Esq.
Robert Deering, Esq.
17 J. Supple Law
990 Fifth Avenue
18 San Rafael, CA 94941
Jsupple(cr~,j supplelaw.com
19 rdeerin~(a~j suppielaw.cam
20 tdan~(a~jsupplelaw.com
docket(cz~,,a su~plelaw.com
21 mschroeder(a,jsupplelaw.cam
crichard jsupplelaw.com
22
23 I declare that I am employed in the office of a member of the bar of this Court at whose
direction the service was made and that this Declaration is executed on October 12, 2023, at
24 Sacramento, California. I declare under penalty of perjury under the laws of the State of
California, that the foregoing is true and correct.
25
26 //
~.
27 i'tine McFadden
28
{000659Q5.1} Proof Of Service - i
Preview
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USEONLY Wendy C. York, SBN 166864/Virginia Martucci,SBN 316296 Electronically Filed York Law Corporation 1111 Exposition Boulevard 10/12/2023 12:10 PM Building 500 Superior Court of California Sacramento, CA 95815 County of Stanislaus TELEPHONENO.: 916 - 643 - ZZ00 FAxNo.(optionaq: 916-643-4680 Clerk of the Court EMAIL ADDRESS (Optiona/): By: Narelly Garcia, Deputy ATTORNEY FOR Name: Attorne for Plaintiffs SUPERIOR COURT OF CALIFORNIA, COUNTY OF Stanislaus STREET ADDRESS: H0Z 10th Street MAILING ADDRESS: CITY AND ZIPCODE:MOCl2StO~ CA 95354 BRANCH NAME: PLAINTIFF/PETITIONER:Larry B. Dignes, et al. DEFENDANT/RESPONDENT: Covenant Care California, LLC, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): m UNLIMITED CASE Q LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) CV-20-004057 A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: October 30, 2023 Time:8:30 a.m. Dept.: 24 Div.: Room: Address of court (if different from the address above): m Notice of Intent to Appear by Telephone, by (name): Virginia Martucci INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. m This statement is submitted by party (name): Plaintiffs, Larry B. Dignes, et al . b. Q This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): September 18, 2020 b. Q The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. m All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. Q The following parties named in the complaint or cross-complaint (1) Q have not been served (specify names and expla/n why nof): (2) Q have been served but have not appeared and have not been dismissed (specify names): (3) Q have had a default entered against them (specify names): c. Q The following additional parties may be added (specify names, nature of Involvement in case, and date by which they maybe served): 4. Description of case a. Type of case in m complaint ~ cross-complaint (Describe, including causes of action): Negligence; Elder Abuse/Neglect; Negligent Misrepresentation; Negligent Hiring, Training and Retention; Violation of Patient's Bill of Rights; Wrongful Death. Pa e1of5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California CM-110 [Rev. July 1, 2011] rules 3720-3.730 CM-110 PLAINTIFF/PETITIONER: arry ignes, E' d CASE NUMBER: DEFENDANT(RESPONDENT:Covenant Care California, LLC, et a1. CV-20-004057 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 amountJ, estimated future medical expenses, lost earnings to date, and estimated future lost earnings. if equitable relief is sought, describe the nature of the relief,) This elder/neglect case arises from Defendants' failures to supervise, manage, support, operate and properly staff and train their Turlock Nursing & Rehabilitation Center facility. As a result of Defendants` neglect, Decedent LARRY B. DIGNES contracted C. Difficile infection, from which he died. Q (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request m a jury trial Q a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. [~ The trial has been set for (date): b. m 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): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 12/4/23, 2/20/24, 4/8/24, 5/21/24, 5/28/24, 9/10/24, 10/7/24, 11/11/24 and 2/4/25 are dates that Trials are already scheduled in other matters. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. m days (specify number): 15-20 b. Q hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial m by the attorney or party listed in the caption Q by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: Q Additional representation is described in Attachment 8. 9. Preference Q 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 Q has m 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 Q has Q has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) Q 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. (2) Q 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. (3) m 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): The amount exceeds the jurisdictional limit. GM-110 ~Kev. July 1, 2011] CASE MANAGEMENT STATEMENT Pace z of s arry ignes, e a CM-110 PLAINTIFF/PETITIONER: CASE NUMBER: DEFENDANT/RESPONDENT:Covenant Care California, LLC, et al. CV-20-004057 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 al/ 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 alt that apply): stipulafron): Q Mediation session not yet scheduled m Q Mediation session scheduled for (dafe): (1) Mediation 0 Agreed to complete mediation by (dafe): m Mediation completed on (dafe): March 20, 2023 m Settlement conference not yet scheduled (2) Settlement m Q Settlement conference scheduled for (date): conference ~ Agreed to complete settlement conference by (date): Q Settlement conference completed on (date): Q Neutral evaluation not yet scheduled Q Neutral evaluation scheduled for (dafe): (3) Neutral evaluation Q Q Agreed to complete neutral evaluation by (date): Q Neutral evaluation completed on (date): Q Judicial arbitration not yet scheduled (4) Nonbinding Judicial ~ Q Judicial arbitration scheduled for (date): arbitration 0 Agreed to complete judicial arbitration by (date): Q Judicial arbitration completed on (date): m Private arbitration not yet scheduled (5) Binding private Q Private arbitration scheduled for (date): arbitration ~ Q Agreed to complete private arbitration by (date): Q Private arbitration completed on (date): Q ADR session not yet scheduled Q ADR session scheduled for (date): (6) Other (specify): Q Q Agreed to complete ADR session by (date): Q ADR completed on (date): CM-110 (Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: arry lgnes, e a CASE NUMBER: DEFENDANT/RESPONDENT:Covenant Care California, LLC, et al. CV-20-004057 11. Insurance a. Q Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Q Yes Q No c. Q 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. Q Bankruptcy m Other (specify): The Court stayed this matter and ordered the parties to Status: arbitration, which is pending, 13. Related cases, consolidation, and coordination a. Q There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: Q Additional cases are described in Attachment 13a. b. Q A motion to Q consolidate Q coordinate will be filed by (name party): 14. Bifurcation Q 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): 15. Qther motions Q The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. Q The party or parties have completed all discovery. b. m The following discovery will be completed by the date specified (describe all anticipated discovery): Partv Description Date Plaintiffs Form Rogs., Spec. Rogs., RFPDs and RFAs 11/2023 Plaintiffs Depositions 1/2024 Plaintiffs Expert Discovery Per Code c. m The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): Discovery has not occurred because this case has been pending with the arbitrator for nearly two years. Arbitration has not yet been set in this matter. Defendants recently were ordered to pay all arbitration costs. They paid initiating fees on 10/11/23. CM-170 [Rev. July 1, 2011 CASE MANAGEMENT STATEMENT Page4of5 arry CM -11( PLAINTIFFIPETITI0NER: Dignes, et a CASE NUMBER: DEFENDANT/RESPONDENT: Covenant Care California, LLC, et al. CV-20-004057 17. Economic litigation a. Q 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. Q 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 specif(cally why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues 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. Q 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 dis very and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter int stipulations o~ese i the time of the case management conference, including the written authority of the party where requ'red. ,---~ ~ ,,~ ~ Date: October 11, 2023 Virginia Martucci 1 ~~ ~ ~'~ (TYPE OR PRINT NAME) (SIGN T RE OF PA ~Y OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Q Additional signatures are attached. GM-19U ~Kev. JUIy 1, 2011) CASE MANAGEMENT STATEMENT -- Pase s ots COURT: Stanislaus County Superior Court CASE NO. CV-20-004057 2 CASE NAME: Dignes v. Covenant Care California, LLC, et al. 3 PROOF OF SERVICE 4 I am a citizen of the United States, employed in the County of Sacramento, State of 5 California. My business address is 1111 Exposition Boulevard, Building 500, Sacramento CA 95815. I am over the age of 18 years and not a party to the above-entitled action. 6 7 I am readily familiar with York Law Corporation's practice for collection and processing of correspondence for mailing with the United States Postal Service. Pursuant to 8 said practice, each document is placed in an envelope, the envelope is sealed, the appropriate postage is placed thereon, and the sealed envelope is placed in the office mail receptacle. Each 9 day's mail is collected and deposited in a U.S. mailbox at or before the close of each day's business. (CCP Section 1013a(3) or Fed.R.Civ.P.S(a) and 4.1; USDC (E.D. CA) L.R. 5- to 135(a).) 1t On October 12, 2023, I caused the within, CASE MANAGEMENT STATEMENT, I 12 caused the within, to be served via: 13 XX ELECTRONIC SERVICE: Based on a Court order or on an agreement by the parties accept service by e-mail or electronic transmission, I caused the document descri~ 14 above to be sent from e-mail my address (vmaz-tucci(a,yorklawfirm.net) to the persons the e-mail addresses) listed below. 15 i6 John Supple, Esq. Robert Deering, Esq. 17 J. Supple Law 990 Fifth Avenue 18 San Rafael, CA 94941 Jsupple(cr~,j supplelaw.com 19 rdeerin~(a~j suppielaw.cam 20 tdan~(a~jsupplelaw.com docket(cz~,,a su~plelaw.com 21 mschroeder(a,jsupplelaw.cam crichard jsupplelaw.com 22 23 I declare that I am employed in the office of a member of the bar of this Court at whose direction the service was made and that this Declaration is executed on October 12, 2023, at 24 Sacramento, California. I declare under penalty of perjury under the laws of the State of California, that the foregoing is true and correct. 25 26 // ~. 27 i'tine McFadden 28 {000659Q5.1} Proof Of Service - i