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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
Michael J. Gregg, Esq., SBN 321765
RoseWaldorf LLP
4100 W. Alameda Ave, Suite 300 PMB 1038
Burbank, CA 91505
TELEPHONE NO.: ( 518) 869-9200 FAX NO. (Optional): (518) 869-3334
E-MAIL ADDRESS: mgregg@rosewaldorf.com
ATTORNEY FOR (Name): Defendant FCA us LLC
SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY
STREET ADDRESS: 1200 Aguajito Road
MAILING ADDRESS:
CITY AND ZIP CODE: Monterey 93940
BRANCH NAME: Monterey Courthouse
PLAINTIFF/PETITIONER: Dean Graham
DEFENDANT/RESPONDENT: FCA US LLC
CASE MANAGEMENT STATEMENT CASE NUMBER:
{Check one): [KJ UNLIMITED CASE CJ LIMITED CASE 23CV001666
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: Januarv 9. 2024 Time: 10:00 a.m. Dept.: 15 Div.: Room:
Address of court (if different from the address above):
[KJ Notice of Intent to Appear by Telephone, by (name): Michael J. Gregg, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. [KJ This statement is submitted by party (name): FCA US LLC
b. D 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):
b. D The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. CJ All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. D The following parties named in the complaint or cross-complaint
(1) D have not been served (specify names and explain why not):
(2) D have been served but have not appeared and have not been dismissed (specify names):
(3) CJ have had a default entered against them (specify names):
c. D The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of case in [KJ complaint D
cross-complaint (Describe, including causes of action):
Complaint - Violation of the Song-Beverly Warranty Act
Page 1 ofS
Cal. Rules of Court,
Form Adopted for Mandatory Use
Judicial Council of California
CASE MANAGEMENT STATEMENT rules 3.720-3.730
CM-110 [Rev. September 1, 2021] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: Dean Graham CASE NUMBER:
DEFENDANT/RESPONDENT: FCA US LLC 23CV001666
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.)
This is a Lemon Law claim involving a 2022 RAM 2500. Plaintiff alleges violations of the Song-Beverly Warranty Act, including
breach of express and implied warranty. Plaintiff seeks actual damages; incidental and consequential damages; rescission of
the purchase agreement and restitution; civil penalties; prejudgment interest and attorney's fees and costs pursuant to the
Song-Beverly Act.
D (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 D a jury trial [KJ a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. D The trial has been set for (date):
b. [KJ 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):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. [KJ days (specify number): 3 - 5
b. D hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial [KJ by the attorney or party listed in the caption D by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
D Additional representation is described in Attachment 8.
9. Preference
D 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 of the California Rules of Court for information about the
processes available through the court and community programs in this case.
(1) For parties represented by counsel: Counsel [KJ has D 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 D hasD has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) D 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) D 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) D 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):
CM-110 IRev. September 1, 2021] Paga 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Dean Graham CASE NUMBER:
DEFENDANT/RESPONDENT: FCA US LLC 23CV001666
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):
CK] Mediation session not yet scheduled
D Mediation session scheduled for (date):
(1) Mediation CK]
D Agreed to complete mediation by (date):
D Mediation completed on (date):
CK] Settlement conference not yet scheduled
(2) Settlement D Settlement conference scheduled for(date):
CK]
conference D Agreed to complete settlement conference by (date):
D Settlement conference completed on (date):
D Neutral evaluation not yet scheduled
D Neutral evaluation scheduled for (date):
(3) Neutral evaluation D
D Agreed to complete neutral evaluation by (date):
D Neutral evaluation completed on (date):
D Judicial arbitration not yet scheduled
(4) Nonbinding judicial D D Judicial arbitration scheduled for (date):
arbitration D Agreed to complete judicial arbitration by (date):
D Judicial arbitration completed on (date):
D Private arbitration not yet scheduled
(5) Binding private D D Private arbitration scheduled for (date):
arbitration D Agreed to complete private arbitration by (date):
D Private arbitration completed on (date):
D ADR session not yet scheduled
D ADR session scheduled for (date):
(6) Other (specify): D
D Agreed to complete ADR session by (date):
D ADR completed on (date):
CM-110 IRev. September 1, 2021] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Dean Graham CASE NUMBER:
DEFENDANT/RESPONDENT: FCA US LLC 23CV001666
11. Insurance
a. D Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: D Yes D No
c. D 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.
D Bankruptcy D Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. D There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
D Additional cases are described in Attachment 13a.
b. D A motion to D consolidate D coordinate will be filed by (name party):
14. Bifurcation
D 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. Other motions
[X] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Defendant reserves the right to file a motion(s) for summary judgment and/or motion(s) in limine prior to trial.
16. Discovery
a. D The party or parties have completed all discovery.
b. [KJ The following discovery will be completed by the date specified (describe all anticipated discovery):
� Description Date
FCA US LLC Written Discovery February 2024
FCA US LLC Plaintitrs Deposition April 2024
FCA US LLC Vehicle Inspection May 2024
FCA US LLC Expert Disclosure Per Code
c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 IRev. September 1, 2021] Page4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Dean Graham CASE NUMBER:
DEFENDANT/RESPONDENT: FCA US LLC 23CV001666
17. Economic litigation
a. D 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. D 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
D 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. � 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):
The parties will meet and confer before the Case Management Conference.
b. D 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): _0 ____
I 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: December 22. 2023
Michael J. Gregg
(TYPE OR PRINT NAME)
► (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME)
► (SIGNATURE OF PARTY OR ATTORNEY)
D Additional signatures are attached.
CM-110 [Rev. September 1, 20211 Page 5 of 5
CASE MANAGEMENT STATEMENT
For your protection and privacy, please press the Clear
This Form button after you have printed the form. I Print this formJ I Save this form JI Clear this form
1 PROOF OF SERVICE
2 Dean Graham, an individual v. FCA US LLC, a Delaware limited liability company; and DOES 1
through 10, inclusive
3 Monterey County Superior Court, Case No. 23CV001666
4 I, the undersigned, am over the age of 18 and am not a party to the within action. My business
address is 501 New Karner Road, Albany, New York 12205. On the date below, I served the following
5 document(s) described as:
6 DEFENDANT FCA US LLC’S UPDATED CASE MANAGEMENT STATEMENT
7 To the following party or parties in this matter:
8 Nicolas M. Dillavou, Esq. Attorney for Plaintiff
Law Offices of Jon Jacobs
9 One Ridgegate Drive, Suite 245
Temecula, California 92590
10
Phone: (916) 663-6400
11 Fax: (916) 663-6500
Email: nic@lemonbuyback.com;
12 office@lemonbuyback.com;
lina@lemonbuyback.com;
13 lisa@lemonbuyback.com
14 ☐ BY PERSONAL SERVICE: I caused the foregoing document(s) to be personally delivered to the
above addressee(s) by One Legal, LLC via a registered process server pursuant to C.C.P. § 1011.
15
☐ BY U.S. MAIL: By enclosing the foregoing document(s) in a sealed envelope to the addressee(s)
16 above and, under the firm’s ordinary course of business, placing said envelope(s) for pick-up and
mailing pursuant to C.C.P. § 1013. I am readily familiar with the firm’s practice for collection and
17 processing of outgoing mail. Under that practice, the outgoing mail is deposited with the U.S. Postal
Service on the same day as collected, with postage fully prepaid.
18
☐ BY OVERNIGHT DELIVERY: I enclosed the foregoing documents in a sealed envelope or
19 package to the addressee(s) listed above and placed said envelope or package for pick-up for overnight
delivery via UPS under the firm’s ordinary course of business. I am familiar with the firm’s practice
20 of collecting and processing documents for overnight delivery via UPS. Under that practice, the
envelope or package would be deposited for pick up by an authorized UPS courier or driver that same
21 day and delivered to the addressee(s) the following business day pursuant to C.C.P. § 1013.
22 ☒ BY ELECTRONIC SERVICE/EMAIL: I electronically filed the document(s) with this Court
using the Court’s designated electronic filing service provider, which sent notification of that filing to
23 the person(s) listed above to accept service by electronic transmission, and/or I caused the
document(s) to be transmitted via electronic mail to the addressees as listed above pursuant to C.C.P. §
24 1010.6 and 1013(g), Cal. Rule of Court 2.251, and/or agreement or stipulation between the parties.
25 I declare under penalty of perjury under the laws of the State of California, that the foregoing is
true and correct.
26
27 Dated: December 22, 2023 Kristen Galarneau
Kristen Galarneau
28
PROOF OF SERVICE
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Michael J. Gregg, Esq., SBN 321765 RoseWaldorf LLP 4100 W. Alameda Ave, Suite 300 PMB 1038 Burbank, CA 91505 TELEPHONE NO.: ( 518) 869-9200 FAX NO. (Optional): (518) 869-3334 E-MAIL ADDRESS: mgregg@rosewaldorf.com ATTORNEY FOR (Name): Defendant FCA us LLC SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY STREET ADDRESS: 1200 Aguajito Road MAILING ADDRESS: CITY AND ZIP CODE: Monterey 93940 BRANCH NAME: Monterey Courthouse PLAINTIFF/PETITIONER: Dean Graham DEFENDANT/RESPONDENT: FCA US LLC CASE MANAGEMENT STATEMENT CASE NUMBER: {Check one): [KJ UNLIMITED CASE CJ LIMITED CASE 23CV001666 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: Januarv 9. 2024 Time: 10:00 a.m. Dept.: 15 Div.: Room: Address of court (if different from the address above): [KJ Notice of Intent to Appear by Telephone, by (name): Michael J. Gregg, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. [KJ This statement is submitted by party (name): FCA US LLC b. D 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): b. D The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. CJ All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. D The following parties named in the complaint or cross-complaint (1) D have not been served (specify names and explain why not): (2) D have been served but have not appeared and have not been dismissed (specify names): (3) CJ have had a default entered against them (specify names): c. D The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type of case in [KJ complaint D cross-complaint (Describe, including causes of action): Complaint - Violation of the Song-Beverly Warranty Act Page 1 ofS Cal. Rules of Court, Form Adopted for Mandatory Use Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720-3.730 CM-110 [Rev. September 1, 2021] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: Dean Graham CASE NUMBER: DEFENDANT/RESPONDENT: FCA US LLC 23CV001666 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.) This is a Lemon Law claim involving a 2022 RAM 2500. Plaintiff alleges violations of the Song-Beverly Warranty Act, including breach of express and implied warranty. Plaintiff seeks actual damages; incidental and consequential damages; rescission of the purchase agreement and restitution; civil penalties; prejudgment interest and attorney's fees and costs pursuant to the Song-Beverly Act. D (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 D a jury trial [KJ a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. D The trial has been set for (date): b. [KJ 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): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. [KJ days (specify number): 3 - 5 b. D hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial [KJ by the attorney or party listed in the caption D by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: D Additional representation is described in Attachment 8. 9. Preference D 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 of the California Rules of Court for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel [KJ has D 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 D hasD has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) D 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) D 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) D 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): CM-110 IRev. September 1, 2021] Paga 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Dean Graham CASE NUMBER: DEFENDANT/RESPONDENT: FCA US LLC 23CV001666 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): CK] Mediation session not yet scheduled D Mediation session scheduled for (date): (1) Mediation CK] D Agreed to complete mediation by (date): D Mediation completed on (date): CK] Settlement conference not yet scheduled (2) Settlement D Settlement conference scheduled for(date): CK] conference D Agreed to complete settlement conference by (date): D Settlement conference completed on (date): D Neutral evaluation not yet scheduled D Neutral evaluation scheduled for (date): (3) Neutral evaluation D D Agreed to complete neutral evaluation by (date): D Neutral evaluation completed on (date): D Judicial arbitration not yet scheduled (4) Nonbinding judicial D D Judicial arbitration scheduled for (date): arbitration D Agreed to complete judicial arbitration by (date): D Judicial arbitration completed on (date): D Private arbitration not yet scheduled (5) Binding private D D Private arbitration scheduled for (date): arbitration D Agreed to complete private arbitration by (date): D Private arbitration completed on (date): D ADR session not yet scheduled D ADR session scheduled for (date): (6) Other (specify): D D Agreed to complete ADR session by (date): D ADR completed on (date): CM-110 IRev. September 1, 2021] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Dean Graham CASE NUMBER: DEFENDANT/RESPONDENT: FCA US LLC 23CV001666 11. Insurance a. D Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: D Yes D No c. D 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. D Bankruptcy D Other (specify): Status: 13. Related cases, consolidation, and coordination a. D There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: D Additional cases are described in Attachment 13a. b. D A motion to D consolidate D coordinate will be filed by (name party): 14. Bifurcation D 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. Other motions [X] The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Defendant reserves the right to file a motion(s) for summary judgment and/or motion(s) in limine prior to trial. 16. Discovery a. D The party or parties have completed all discovery. b. [KJ The following discovery will be completed by the date specified (describe all anticipated discovery): � Description Date FCA US LLC Written Discovery February 2024 FCA US LLC Plaintitrs Deposition April 2024 FCA US LLC Vehicle Inspection May 2024 FCA US LLC Expert Disclosure Per Code c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 IRev. September 1, 2021] Page4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Dean Graham CASE NUMBER: DEFENDANT/RESPONDENT: FCA US LLC 23CV001666 17. Economic litigation a. D 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. D 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 D 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. � 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): The parties will meet and confer before the Case Management Conference. b. D 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): _0 ____ I 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: December 22. 2023 Michael J. Gregg (TYPE OR PRINT NAME) ► (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) ► (SIGNATURE OF PARTY OR ATTORNEY) D Additional signatures are attached. CM-110 [Rev. September 1, 20211 Page 5 of 5 CASE MANAGEMENT STATEMENT For your protection and privacy, please press the Clear This Form button after you have printed the form. I Print this formJ I Save this form JI Clear this form 1 PROOF OF SERVICE 2 Dean Graham, an individual v. FCA US LLC, a Delaware limited liability company; and DOES 1 through 10, inclusive 3 Monterey County Superior Court, Case No. 23CV001666 4 I, the undersigned, am over the age of 18 and am not a party to the within action. My business address is 501 New Karner Road, Albany, New York 12205. On the date below, I served the following 5 document(s) described as: 6 DEFENDANT FCA US LLC’S UPDATED CASE MANAGEMENT STATEMENT 7 To the following party or parties in this matter: 8 Nicolas M. Dillavou, Esq. Attorney for Plaintiff Law Offices of Jon Jacobs 9 One Ridgegate Drive, Suite 245 Temecula, California 92590 10 Phone: (916) 663-6400 11 Fax: (916) 663-6500 Email: nic@lemonbuyback.com; 12 office@lemonbuyback.com; lina@lemonbuyback.com; 13 lisa@lemonbuyback.com 14 ☐ BY PERSONAL SERVICE: I caused the foregoing document(s) to be personally delivered to the above addressee(s) by One Legal, LLC via a registered process server pursuant to C.C.P. § 1011. 15 ☐ BY U.S. MAIL: By enclosing the foregoing document(s) in a sealed envelope to the addressee(s) 16 above and, under the firm’s ordinary course of business, placing said envelope(s) for pick-up and mailing pursuant to C.C.P. § 1013. I am readily familiar with the firm’s practice for collection and 17 processing of outgoing mail. Under that practice, the outgoing mail is deposited with the U.S. Postal Service on the same day as collected, with postage fully prepaid. 18 ☐ BY OVERNIGHT DELIVERY: I enclosed the foregoing documents in a sealed envelope or 19 package to the addressee(s) listed above and placed said envelope or package for pick-up for overnight delivery via UPS under the firm’s ordinary course of business. I am familiar with the firm’s practice 20 of collecting and processing documents for overnight delivery via UPS. Under that practice, the envelope or package would be deposited for pick up by an authorized UPS courier or driver that same 21 day and delivered to the addressee(s) the following business day pursuant to C.C.P. § 1013. 22 ☒ BY ELECTRONIC SERVICE/EMAIL: I electronically filed the document(s) with this Court using the Court’s designated electronic filing service provider, which sent notification of that filing to 23 the person(s) listed above to accept service by electronic transmission, and/or I caused the document(s) to be transmitted via electronic mail to the addressees as listed above pursuant to C.C.P. § 24 1010.6 and 1013(g), Cal. Rule of Court 2.251, and/or agreement or stipulation between the parties. 25 I declare under penalty of perjury under the laws of the State of California, that the foregoing is true and correct. 26 27 Dated: December 22, 2023 Kristen Galarneau Kristen Galarneau 28 PROOF OF SERVICE