Preview
Electronically Filed
5/16/2023 2:50 PM
Superior Court of California
County of Stanislaus
Clerk of the Court
1 WENDY C. YORK, SBN 166864 By: Angela Mesa, Deputy
DANIEL JAY, SI3N 2158b0
2 VIRGINIA L. MARTUCCI, SBN 31b296
YC)RK LAW CORPQRATIQN
11 l 1 Exposition Blvd., Bldg. 500
4 Sacra~neniq California 95$1 S
Phone: (916) 643-2200
5 Fax; (916) b43-4680
6 Attorneys for Plaintiff LARRY DIGNES (Decedent) by anci through his Successors-In-Interest
SHETLA M. LOWE, an individual; LORI M. KIRCHERT, an individual
7
8 IN THE SUPERIOR COURT OF THE STATE (JF CALIFORNIA
9 IN A1V'D FQR THE CiDUNTY OF STANISLAUS
10
LARRY B. DIGNES (Decedent} by and through CASE NO.: CV-20-004Q57
II 11is Successors-In-Interest SHEILA M. LC}WE,
an individual; LORI M. KIRCHERT, an
i2 individual SUPPLEMENTAL DECLARATIQN OF
SHEILA LOWE IN SUPPO~tT OF
13 Plainriff, PLAiNTiI~FS' RENEWED MOTIUN TO
VS.
LIFT THE STAY AND AN (3RDER
14
COVENANT CARE CALIFORNIA, LLC dba ALLOCATING ARBITRATIQN COSTS
15 TURL(?CK NURSING ANI7 AND FEES T!~ DEFENDANTS OR
REHABILITATION GEI'+tTER; COVENANT REMAND THE CASE TO SUPERIOR
16 CARE, LLC, a Delaware Corporation; and COURT
DOGS i through 50, inclusive
17
Defendants. Date: May 23, 2023
' t8 Time: 8:30 a.in.
Dept: 24
19
Judge: Hon. Sonny S. Sandhu
20
Complaint filed: September 18, 2Q2Q
~a
22
23 I, SHEILA LOWS, do hereby declare and say tl~e following:
24 1. I have personal kno~vled~e of the facts stated in this Declaration and, if called, could
25 and would eolnpetently testify to these facts.
2G 2. I any one of the named Plaintiffs in the above-captioned matter, am over the age of 18
~~ years old, and am the daughter and successor-in-interest of Decedent LARRY B. DIGNES. I am not
?g
;00099932.1 ~ SUPPLEMENTAL D~CLARA't'IC1N OF SHEILA LOWE IN SUPPORT OF PLAINTIFFS"
RENEWED MOTION TO L1i~T THE? S"('AY AND nN ORDER AL~OCA"1'IVG A[2131TRf~'t'IOv COS`T'S AND
FEES TO DEFENDANTS OR REMAND THE CASE TO SL'PBRIOR COURT - 1
l a party to the dispute resolution agreement that was contained within my father's admix
2 agreement to Turlock Nursing and Rehabilitation Center, and my wrongfitl death action is curve
3 stayed in Superior Court.
4 3. My fathert- passed away on August 30, 2419.
5 4. On the date of my father's, he lead X3,941.83 in his only batik account. A true
6 correct copy of his bank statement dated September 5, 2019 is attached hereto as Exhibit "A."
7 I dectal-e under penalty of perjury under the laws of the State of California. that the foreg
8 is true atld correct. This Declaration was executed on May 15, 2023, in Turlock, California.
9
iQ ~, r _ ~~ ~,
~~ '~ SHEILA LOWS
I1
12
13
14
IS
16
17
18
19
20
2l
22 I
23
?4 ~
25
~~
?7
28
00099932.1 ~ SUPPLEMENTAL DECLARATION OF SHEILA LOWS IN SUPPORT OF PLAINTIFFS'
RE~L,WED MO'1'It)N TO LtPT THE STAY AND AN ORDER ALLOCATING ARBITRATiOV CASTS f1ND
FEES TO DF,FENDANTS OR REMAND THE CASF, TO SliPERIOR COURT - 2
EXHIBIT A
.. . r., ...
ells Farga ValueSM Checking
September 5, 2019 â– Page 1 of 3
Questions?
Available by phone 24 hours a day, 7 days a week:
LARRY B DIGNES
Telecommunications Relay Services calls accepted
SHEILA LOWE
1-800-TO-WELLS (1-800-869-3557)
TTY: 1-800-877-4833
En espanol: 1-$77-727-2932
A 1-800-288-2288 (6 am to 7 pm PT, M-F)
Online: welisfargo.com
Write: Wells Fargo Bank, N.A. (114)
P.O. Box 6995
Portland, OR 97228-6995
You and Wells Fargo Account options
Thank you for being a loyal Webs Fargo customer. We value your trust in our A check mark rn the box indicates you have these
company and look forward to continuing to serve you with your financial needs. convenient services with your account(s). Go to
wellsfargo.com or call the number above if you have
questions or if you would like to add new services.
Online Banking ~ Direct Deposit
Online Bill Pay ~✓ Auto Transfer/Payment
Online Statements ~ Overdraft Protection
Mobile Banking ~✓ Debit Card
My Spending Report ~ Overdraft Service
Activity summary
Beginning balance on 816 $3,142.73 LARRY B DIGNES
SHEILA LOWE
Deposits/Additions 1,647.66
Withdrawals/Subtractions - 1,731.15 California account terms and conditions apply
For Direct Deposit use
Ending balance on 915 $3,059.24
Overdraft Protection
This account is not currently covered by Overdraft Protection. If you would like more information regarding Overdraft Protection and eligibility requirements
please call the number listed on your statement or visit your Wells Fargo store.
~iia~
Sheet Seq = 0000722
Sheet 00001 of 00002
September 5, 2D19 a Page Z of 3
Transactran history
Gtteck Deposits/ ►Nrthdravraals✓ Errdmg daily
Date Number Descafptlon AdOttions 3ubtr3cdans balance
8R Security Systems Member Pay- N Latry Dignes 49.99 3,092.74
8113 Purchase authorized an 48Jt2 Sgm# Sps Mha 866-b81-fl735 CA 82.36 3010.38
8115 Purctrase authorize0 on t18l75 Farmers Ins BiH~n 877-327-6392 CA 101.21 2,909.17
8f19 Sears Payment Check Pymt 96.24
8199 AT&T Services Gheckpaym d$.10 2,764.83
vn ~8Y13 t}27 Ema~uei
Entting balance an 9J5 g~~~~•~4
Togts St,647.66 81,731.15
77re Ending hairy Balance demos gat reflect any pendlt~g witfidrawa~s or hotels an deposited funds that may have been autstarnfirx,} on your account wtre~ your
Transactions posted. tf you had insufltcient awai/aD~e tUnds when a lransactiorr posted, fees may have UeeR assessed_
^ Converted check:Cheek convened to an e~sctranic fiumat by your payee ar designated representative. Checks converted to electronic farrrraf can+rof be
returned, coprevorlmaged.
Summary of checks written (checks listed are also displayed rn the prec$ding Transaction history,!
Number Date Amount Number fk~ate Amount Number Date Amaunf
8/19 9624 812& 96.4fD 9i4 175.75
8/19 48.1D 9!3 d5.fld 9I5 72.OQ
.1 8t3Q 87.Q0 9/5 715.13 9/4 17.70
" Gap rn check seQuence.
Monthly service fee summary
Fot a complete list ofi fees antl detailed account info~rnatron~ see the Wens Fargo Account Fee and informatron Sores ule and Account Agreement appUcabfe to
your account (EasyPay Card Terms and Go~dttfans for prepaid cards) ar taik to a banker. Go to weflsiargo.ecxntteefaq for a link to these documents, ancf answers
to common monthly service fee questions.
Fee period 08/Q&12019 - 09lQ512019 Standard mctnnp~ly service #ee S9A0 Xou paid 50.a0
Haw to avoid the monthly service fee Minimum required This tee period
Have any ONE of the ioliowirrg account requieements
Minimum 4aily balance 51,50t}.0~ 52,6 4.83 Q
Tota! amount at quaiity+ing d~reet deposits $500.Dfl $9.647.66
Monthly service fee dlscauni{s} (applied when dox 1s checked)
Online Doty statements (S2.D0 discount) Q
vcrvc
September 5, 2019 â– Page 3 of 3
Worksheet to balance your account General statement policies for Wells Fargo Bank
Follow the steps below to reconcile your statement balance with your â– To dispute or report inaccuracies in information we have furnished to a
account register balance. Be sure that your register shows any interest Consumer Reporting Agency about your accounts. You have the right to
paid into your account and any service charges, automatic payments or dispute the accuracy of information that Welis Fargo Bank, N.A. has
ATM transactions withdrawn from your account during this statement furnished to a consumer reporting agency by writing to us at Overdraft
period. Collection and Recovery, P.O. Box 5058, Portland, OR 97208-5058. Please
~A Enter the ending balance on this statement. $ ~ describe the specific information that is inaccurate or in dispute and the
basis for the dispute along with supporting documentation. if you believe
List outstanding deposits and other the information furnished is the result of identity theft, please provide us
credits to your account that do not appear on with an identity theft report.
this statement. Enter the total in the column â– In case of errors or questions about your electronic transfers,
to the right. telephone us at the number printed on the front of this statement or write
us at Wells Fargo Bank, P.O. Box 6995, Portland, OR 97228-6995 as soon as
Description Amount
you can, if you think your statement or receipt is wrong or if you need more
information about a transfer on the statement or receipt. We must hear
from you no later than 60 days after we sent you the FIRST statement on
which the error or problem appeared.
1. Tell us your name and account number (if any).
2. Describe the error or the transfer you are unsure about, and explain as
clearly as you can why you believe it is an error or why you need more
Total $ ~ + $
information.
3. Tell us the dollar amount of the suspected error.
~C Add ~ and ~ to calculate the subtotal. _ $ ~
We will investigate your complaint and will correct any error promptly. if
~D List outstanding checks, withdrawals, and we take more than 10 business days to do this, we will credit your account
other debits to your account that do not appear for the amount you think is in error, so that you will have the use of the
on this statement. Enter the total in the column money during the time it takes us to complete our investigation.
to the right.
Number/Description Amount
Total $
~E Subtract ~D from OC to calculate the
adjusted ending balance. This amount should be
the same as the current balance shown in your L~J
O02010 Wells Fargo Bank: N.A. Ail ngMs reserved NMLSR D 399801 Membet FDIC. ~aoea
register. - $ ~
Sheet Seq = 0000723
Sheet 00002 of 00002
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
S California. My business address is 1 111 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 rs 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 Sectzon 1013a(3) or Fed.R.Civ.P.5(a) and 4.1; USDC (E.D. CA) L.R. 5-
10
135(a).)
~r
On May 16, 2023, I caused the within, SUPPLEMENTAL DECLARATION OF
12 SHEILA LOWE IN SUPPORT OF PLAINTIFFS' RENEWED MOTION TO LIFT
THE STAY AND AN ORDER ALLOCATING ARBITRATOR COSTS AND FEES TO
13 llEFENDANTS OR REMAND THE CASE TO SUPERIOR COURT, I caused the within,
to be served via:
14
XX ELECTRONIC SERVICE: Based on a Court order or on an agreement by the parties
15 accept service by e-mail or electronic transmission, I caused the document describ
above to be sent from e-mail my address (vmartucci cr,yorklawfirm.net) to the persons
16
the e-mail addresses) listed below.
17
John Supple, Esq.
18 Robert Deering, Esq.
J. Supple Law
l9 990 Fifth Avenue
San Rafael, CA 94901
20 Jsu~aple~ supplelaw.com
rdeerin~~,jsupplelaw.com
21
tdang.,_(a~j supplelaw.com
22 docket ~aj'sup~lelaw.com
mschroeder(c~jsupplelaw=cony
23 crichard~ja 'sup~lelaw.com
24
I declare that I am employed in the office of a member of the bar of this Court at whose
25 direction the service was made and that this Declaration i~ executed on May 16, 2023, at
Sacramento, California. I declare under penalty of perjury under the laws of the State of
26
California, that the foregoing is true and correct.
27
28
ne McF
{00065905.1} Proof Of Service - 1
Preview
Electronically Filed 5/16/2023 2:50 PM Superior Court of California County of Stanislaus Clerk of the Court 1 WENDY C. YORK, SBN 166864 By: Angela Mesa, Deputy DANIEL JAY, SI3N 2158b0 2 VIRGINIA L. MARTUCCI, SBN 31b296 YC)RK LAW CORPQRATIQN 11 l 1 Exposition Blvd., Bldg. 500 4 Sacra~neniq California 95$1 S Phone: (916) 643-2200 5 Fax; (916) b43-4680 6 Attorneys for Plaintiff LARRY DIGNES (Decedent) by anci through his Successors-In-Interest SHETLA M. LOWE, an individual; LORI M. KIRCHERT, an individual 7 8 IN THE SUPERIOR COURT OF THE STATE (JF CALIFORNIA 9 IN A1V'D FQR THE CiDUNTY OF STANISLAUS 10 LARRY B. DIGNES (Decedent} by and through CASE NO.: CV-20-004Q57 II 11is Successors-In-Interest SHEILA M. LC}WE, an individual; LORI M. KIRCHERT, an i2 individual SUPPLEMENTAL DECLARATIQN OF SHEILA LOWE IN SUPPO~tT OF 13 Plainriff, PLAiNTiI~FS' RENEWED MOTIUN TO VS. LIFT THE STAY AND AN (3RDER 14 COVENANT CARE CALIFORNIA, LLC dba ALLOCATING ARBITRATIQN COSTS 15 TURL(?CK NURSING ANI7 AND FEES T!~ DEFENDANTS OR REHABILITATION GEI'+tTER; COVENANT REMAND THE CASE TO SUPERIOR 16 CARE, LLC, a Delaware Corporation; and COURT DOGS i through 50, inclusive 17 Defendants. Date: May 23, 2023 ' t8 Time: 8:30 a.in. Dept: 24 19 Judge: Hon. Sonny S. Sandhu 20 Complaint filed: September 18, 2Q2Q ~a 22 23 I, SHEILA LOWS, do hereby declare and say tl~e following: 24 1. I have personal kno~vled~e of the facts stated in this Declaration and, if called, could 25 and would eolnpetently testify to these facts. 2G 2. I any one of the named Plaintiffs in the above-captioned matter, am over the age of 18 ~~ years old, and am the daughter and successor-in-interest of Decedent LARRY B. DIGNES. I am not ?g ;00099932.1 ~ SUPPLEMENTAL D~CLARA't'IC1N OF SHEILA LOWE IN SUPPORT OF PLAINTIFFS" RENEWED MOTION TO L1i~T THE? S"('AY AND nN ORDER AL~OCA"1'IVG A[2131TRf~'t'IOv COS`T'S AND FEES TO DEFENDANTS OR REMAND THE CASE TO SL'PBRIOR COURT - 1 l a party to the dispute resolution agreement that was contained within my father's admix 2 agreement to Turlock Nursing and Rehabilitation Center, and my wrongfitl death action is curve 3 stayed in Superior Court. 4 3. My fathert- passed away on August 30, 2419. 5 4. On the date of my father's, he lead X3,941.83 in his only batik account. A true 6 correct copy of his bank statement dated September 5, 2019 is attached hereto as Exhibit "A." 7 I dectal-e under penalty of perjury under the laws of the State of California. that the foreg 8 is true atld correct. This Declaration was executed on May 15, 2023, in Turlock, California. 9 iQ ~, r _ ~~ ~, ~~ '~ SHEILA LOWS I1 12 13 14 IS 16 17 18 19 20 2l 22 I 23 ?4 ~ 25 ~~ ?7 28 00099932.1 ~ SUPPLEMENTAL DECLARATION OF SHEILA LOWS IN SUPPORT OF PLAINTIFFS' RE~L,WED MO'1'It)N TO LtPT THE STAY AND AN ORDER ALLOCATING ARBITRATiOV CASTS f1ND FEES TO DF,FENDANTS OR REMAND THE CASF, TO SliPERIOR COURT - 2 EXHIBIT A .. . r., ... ells Farga ValueSM Checking September 5, 2019 ■Page 1 of 3 Questions? Available by phone 24 hours a day, 7 days a week: LARRY B DIGNES Telecommunications Relay Services calls accepted SHEILA LOWE 1-800-TO-WELLS (1-800-869-3557) TTY: 1-800-877-4833 En espanol: 1-$77-727-2932 A 1-800-288-2288 (6 am to 7 pm PT, M-F) Online: welisfargo.com Write: Wells Fargo Bank, N.A. (114) P.O. Box 6995 Portland, OR 97228-6995 You and Wells Fargo Account options Thank you for being a loyal Webs Fargo customer. We value your trust in our A check mark rn the box indicates you have these company and look forward to continuing to serve you with your financial needs. convenient services with your account(s). Go to wellsfargo.com or call the number above if you have questions or if you would like to add new services. Online Banking ~ Direct Deposit Online Bill Pay ~✓ Auto Transfer/Payment Online Statements ~ Overdraft Protection Mobile Banking ~✓ Debit Card My Spending Report ~ Overdraft Service Activity summary Beginning balance on 816 $3,142.73 LARRY B DIGNES SHEILA LOWE Deposits/Additions 1,647.66 Withdrawals/Subtractions - 1,731.15 California account terms and conditions apply For Direct Deposit use Ending balance on 915 $3,059.24 Overdraft Protection This account is not currently covered by Overdraft Protection. If you would like more information regarding Overdraft Protection and eligibility requirements please call the number listed on your statement or visit your Wells Fargo store. ~iia~ Sheet Seq = 0000722 Sheet 00001 of 00002 September 5, 2D19 a Page Z of 3 Transactran history Gtteck Deposits/ ►Nrthdravraals✓ Errdmg daily Date Number Descafptlon AdOttions 3ubtr3cdans balance 8R Security Systems Member Pay- N Latry Dignes 49.99 3,092.74 8113 Purchase authorized an 48Jt2 Sgm# Sps Mha 866-b81-fl735 CA 82.36 3010.38 8115 Purctrase authorize0 on t18l75 Farmers Ins BiH~n 877-327-6392 CA 101.21 2,909.17 8f19 Sears Payment Check Pymt 96.24 8199 AT&T Services Gheckpaym d$.10 2,764.83 vn ~8Y13 t}27 Ema~uei Entting balance an 9J5 g~~~~•~4 Togts St,647.66 81,731.15 77re Ending hairy Balance demos gat reflect any pendlt~g witfidrawa~s or hotels an deposited funds that may have been autstarnfirx,} on your account wtre~ your Transactions posted. tf you had insufltcient awai/aD~e tUnds when a lransactiorr posted, fees may have UeeR assessed_ ^ Converted check:Cheek convened to an e~sctranic fiumat by your payee ar designated representative. Checks converted to electronic farrrraf can+rof be returned, coprevorlmaged. Summary of checks written (checks listed are also displayed rn the prec$ding Transaction history,! Number Date Amount Number fk~ate Amount Number Date Amaunf 8/19 9624 812& 96.4fD 9i4 175.75 8/19 48.1D 9!3 d5.fld 9I5 72.OQ .1 8t3Q 87.Q0 9/5 715.13 9/4 17.70 " Gap rn check seQuence. Monthly service fee summary Fot a complete list ofi fees antl detailed account info~rnatron~ see the Wens Fargo Account Fee and informatron Sores ule and Account Agreement appUcabfe to your account (EasyPay Card Terms and Go~dttfans for prepaid cards) ar taik to a banker. Go to weflsiargo.ecxntteefaq for a link to these documents, ancf answers to common monthly service fee questions. Fee period 08/Q&12019 - 09lQ512019 Standard mctnnp~ly service #ee S9A0 Xou paid 50.a0 Haw to avoid the monthly service fee Minimum required This tee period Have any ONE of the ioliowirrg account requieements Minimum 4aily balance 51,50t}.0~ 52,6 4.83 Q Tota! amount at quaiity+ing d~reet deposits $500.Dfl $9.647.66 Monthly service fee dlscauni{s} (applied when dox 1s checked) Online Doty statements (S2.D0 discount) Q vcrvc September 5, 2019 ■Page 3 of 3 Worksheet to balance your account General statement policies for Wells Fargo Bank Follow the steps below to reconcile your statement balance with your ■To dispute or report inaccuracies in information we have furnished to a account register balance. Be sure that your register shows any interest Consumer Reporting Agency about your accounts. You have the right to paid into your account and any service charges, automatic payments or dispute the accuracy of information that Welis Fargo Bank, N.A. has ATM transactions withdrawn from your account during this statement furnished to a consumer reporting agency by writing to us at Overdraft period. Collection and Recovery, P.O. Box 5058, Portland, OR 97208-5058. Please ~A Enter the ending balance on this statement. $ ~ describe the specific information that is inaccurate or in dispute and the basis for the dispute along with supporting documentation. if you believe List outstanding deposits and other the information furnished is the result of identity theft, please provide us credits to your account that do not appear on with an identity theft report. this statement. Enter the total in the column ■In case of errors or questions about your electronic transfers, to the right. telephone us at the number printed on the front of this statement or write us at Wells Fargo Bank, P.O. Box 6995, Portland, OR 97228-6995 as soon as Description Amount you can, if you think your statement or receipt is wrong or if you need more information about a transfer on the statement or receipt. We must hear from you no later than 60 days after we sent you the FIRST statement on which the error or problem appeared. 1. Tell us your name and account number (if any). 2. Describe the error or the transfer you are unsure about, and explain as clearly as you can why you believe it is an error or why you need more Total $ ~ + $ information. 3. Tell us the dollar amount of the suspected error. ~C Add ~ and ~ to calculate the subtotal. _ $ ~ We will investigate your complaint and will correct any error promptly. if ~D List outstanding checks, withdrawals, and we take more than 10 business days to do this, we will credit your account other debits to your account that do not appear for the amount you think is in error, so that you will have the use of the on this statement. Enter the total in the column money during the time it takes us to complete our investigation. to the right. Number/Description Amount Total $ ~E Subtract ~D from OC to calculate the adjusted ending balance. This amount should be the same as the current balance shown in your L~J O02010 Wells Fargo Bank: N.A. Ail ngMs reserved NMLSR D 399801 Membet FDIC. ~aoea register. - $ ~ Sheet Seq = 0000723 Sheet 00002 of 00002 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 S California. My business address is 1 111 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 rs 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 Sectzon 1013a(3) or Fed.R.Civ.P.5(a) and 4.1; USDC (E.D. CA) L.R. 5- 10 135(a).) ~r On May 16, 2023, I caused the within, SUPPLEMENTAL DECLARATION OF 12 SHEILA LOWE IN SUPPORT OF PLAINTIFFS' RENEWED MOTION TO LIFT THE STAY AND AN ORDER ALLOCATING ARBITRATOR COSTS AND FEES TO 13 llEFENDANTS OR REMAND THE CASE TO SUPERIOR COURT, I caused the within, to be served via: 14 XX ELECTRONIC SERVICE: Based on a Court order or on an agreement by the parties 15 accept service by e-mail or electronic transmission, I caused the document describ above to be sent from e-mail my address (vmartucci cr,yorklawfirm.net) to the persons 16 the e-mail addresses) listed below. 17 John Supple, Esq. 18 Robert Deering, Esq. J. Supple Law l9 990 Fifth Avenue San Rafael, CA 94901 20 Jsu~aple~ supplelaw.com rdeerin~~,jsupplelaw.com 21 tdang.,_(a~j supplelaw.com 22 docket ~aj'sup~lelaw.com mschroeder(c~jsupplelaw=cony 23 crichard~ja 'sup~lelaw.com 24 I declare that I am employed in the office of a member of the bar of this Court at whose 25 direction the service was made and that this Declaration i~ executed on May 16, 2023, at Sacramento, California. I declare under penalty of perjury under the laws of the State of 26 California, that the foregoing is true and correct. 27 28 ne McF {00065905.1} Proof Of Service - 1