Preview
19CV351266
Santa Clara — Civil
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY vy stem
TODD A. ROBERTS (SBN 129722) / MARTIN D. DIOLI (SBN 172775)
ROPERS MAJESKI PC Electronically Filed
1001 Marshall Street, Suite 500 lby Superior Court of CA,
Redwood City, CA 94063-2052 (County of Santa Clara,
TevepHone no. (650) 364-8200 FAX NO. (Optionay: (650) 780-1701 lon 10/26/2020 3:42 PM
E-MAIL ADDRESS (Optionay: todd. roberts@ropers.com
ATTORNEY FOR (Name): Plaintiff COLLIERS INTERNATIONAL, INC. Reviewed By: System System
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA ase #19CV351266
street aopress: 191 N. First Street Envelope: 5180127
MAILING ADDRESS:
city ano zip cove: San Jose, CA
BRANCH NAME:
PLAINTIFF/PETITIONER: COLLIERS INTERNATIONAL, INC.
DEFENDANT/RESPONDENT: GABRIEL E. ARECHAEDERRA
CASE MANAGEMENT STATEMENT CASE NUMBER:
19CV351266
(Check one): & UNLIMITED CASE [a] LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: November 10, 2020 Time: 11:00 a.m. Dept.: 20 Div.: Room:
Address of court (if different from the address above):
X Notice of Intent to Appear by Telephone, by (name): TODD A. ROBERTS
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a XJ This statement is submitted by party (name): Plaintiff, COLLIERS INTERNATIONAL, INC.
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): July 16, 2019
b. (1 The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
a XI al parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. (1 The following parties named in the complaint or cross-complaint
(1) Oo have not been served (specify names and explain why not):
(2) Oo have been served but have not appeared and have not been dismissed (specify names):
(3) Oo have had a default entered against them (specify names):
c. [ey 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 EX] complaint C1 cross-complaint (Describe, including causes of action):
Complaint for Breach of Contract and Money Had and Received.
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
CM-110
PLAINTIFF/PETITIONER: COLLIERS INTERNATIONAL, INC. CASE NUMBER:
19CV351266
|DEFENDANT/RESPONDENT: GABRIEL E. ARECHAEDERRA
4 b. Provide a brief statement of the case, including any damages. (/f 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 Colliers International seeks to collect on a promissory note signed by defendant Arechaederra,
one of its former brokers, in connection with the settlement of prior litigation. Arechaederra signed two
promissory notes, paid the secured note, but has failed and refused to pay on the second. Colliers
seeks payment of the amount stated in the note plus interest, and prevailing party attorney fees.
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 Ed a jury trial 0 a nonjury 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. X 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):
January 20, 2021; March 15, 2021; May 20, 21; January 24, 2022.
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. 1] days (specify number): 1-2 days
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 & has Chas 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 oO has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
a O 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 O 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) O 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):
M110 (Rev. July 1, 2014] CASE MANAGEMENT STATEMENT Page 2 of 5
American LegalN Inc,
www, FormsWork Ww.c
CM-110
PLAINTIFF/PETITIONER: COLLIERS INTERNATIONAL, INC. ‘CASE NUMBER:
19CV351266
[DEFENDANT/RESPONDENT: GABRIEL E. ARECHAEDERRA
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
fe] 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):
(CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5
rican LegalN
w FormsWork
CM-110
bs PLAINTIFF/PETITIONER: COLLIERS INTERNATIONAL, INC. ‘CASE NUMBER:
19CV351266
IEFENDANT/RESPONDENT: GABRIEL E. ARECHAEDERRA
11. Insurance
a Ol Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: 0 Yes 0 No
. O 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. 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
1 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
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motion for summary judgment.
16. Discovery
a. (1 The party or parties have completed all discovery.
b B&Q The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Descriptio! Date
Plaintiff Written discovery Per code
Plaintiff Depositions Per code
Plaintiff Expert Discovery Per code
c. L The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
(CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5
American Lé alN
‘www Form: ork
CM-110
PLAINTIFF/PETITIONER: COLLIERS INTERNATIONAL, INC. CASE NUMBER:
19CV351266
|DEFENDANT/RESPONDENT: GABRIEL E. ARECHAEDERRA
17. Economic litigation
a C1 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. (1 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
O 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 I 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): Stipulate to an early settlement conference.
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: October 26, 2020
TODD A. ROBERTS eg FC 2c L2—
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
>
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
C Additional signatures are attached.
(CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5
CASE NAME: Colliers International, Inc. V. Gabriel E. Arechaederra,
ACTION NO.: Case No.: 19CV351266, Santa Clara County Superior Court
PROOF OF SERVICE
1. At the time of service I was over 18 years of age and not a party to this action and a Citizen of
the United States.
2. My business address is 1001 Marshall Street, Suite 500, Redwood City, CA 94063-2052,
County of San Mateo.
3. On October 26, 2020 I served the following documents:
CASE MANAGEMENT CONFERENCE STATEMENT
4. I served the documents on the persons at the address below (along with their fax numbers
and/or email addresses if service was by fax or email):
10
Samantha D. Wolff Attorneys for Defendants
ll Candice P. Shih
HANSON BRIDGET LLP Tel: 415-777-3200 Fax: 415-541-9366
12
425 Market Street, 26th Floor Email: wolff@hansonbridgett.com
13 San Francisco, CA 94105 shih@hansonbridgett.com
14
5. served the documents by the following means:
Or 15
fk] ONLY BY ELECTRONIC TRANSMISSION. Only by e-mailing the document(s) to
Lik 16 the persons at the e-mail address(es) listed based on notice provided on March 23, 2020 that,
om
Ok
17
during the Coronavirus (COVID-19) pandemic, Ropers Majeski attorneys will be working
remotely, not able to send physical mail as usual, and are therefore using only electronic mails.
No electronic message or other indication that the transmission was unsuccessful was received
18 within a reasonable time after the transmission.
Xe
19 Iam employed in the office of a member of the bar of this court at whose direction the
service was made. I certify under penalty of perjury that the foregoing is true and correct.
20
Dated: October 26, 2020
21 Weve (st Boh
Donna Bautista
22 Type Name Signature
23
24
25
26
27
28
PROOF OF SERVICE
483 1-8067-5242.1
Preview
19CV351266 Santa Clara — Civil ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY vy stem TODD A. ROBERTS (SBN 129722) / MARTIN D. DIOLI (SBN 172775) ROPERS MAJESKI PC Electronically Filed 1001 Marshall Street, Suite 500 lby Superior Court of CA, Redwood City, CA 94063-2052 (County of Santa Clara, TevepHone no. (650) 364-8200 FAX NO. (Optionay: (650) 780-1701 lon 10/26/2020 3:42 PM E-MAIL ADDRESS (Optionay: todd. roberts@ropers.com ATTORNEY FOR (Name): Plaintiff COLLIERS INTERNATIONAL, INC. Reviewed By: System System SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA ase #19CV351266 street aopress: 191 N. First Street Envelope: 5180127 MAILING ADDRESS: city ano zip cove: San Jose, CA BRANCH NAME: PLAINTIFF/PETITIONER: COLLIERS INTERNATIONAL, INC. DEFENDANT/RESPONDENT: GABRIEL E. ARECHAEDERRA CASE MANAGEMENT STATEMENT CASE NUMBER: 19CV351266 (Check one): & UNLIMITED CASE [a] LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: November 10, 2020 Time: 11:00 a.m. Dept.: 20 Div.: Room: Address of court (if different from the address above): X Notice of Intent to Appear by Telephone, by (name): TODD A. ROBERTS INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a XJ This statement is submitted by party (name): Plaintiff, COLLIERS INTERNATIONAL, INC. 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): July 16, 2019 b. (1 The cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) a XI al parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. (1 The following parties named in the complaint or cross-complaint (1) Oo have not been served (specify names and explain why not): (2) Oo have been served but have not appeared and have not been dismissed (specify names): (3) Oo have had a default entered against them (specify names): c. [ey 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 EX] complaint C1 cross-complaint (Describe, including causes of action): Complaint for Breach of Contract and Money Had and Received. 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 CM-110 PLAINTIFF/PETITIONER: COLLIERS INTERNATIONAL, INC. CASE NUMBER: 19CV351266 |DEFENDANT/RESPONDENT: GABRIEL E. ARECHAEDERRA 4 b. Provide a brief statement of the case, including any damages. (/f 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 Colliers International seeks to collect on a promissory note signed by defendant Arechaederra, one of its former brokers, in connection with the settlement of prior litigation. Arechaederra signed two promissory notes, paid the secured note, but has failed and refused to pay on the second. Colliers seeks payment of the amount stated in the note plus interest, and prevailing party attorney fees. 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 Ed a jury trial 0 a nonjury 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. X 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): January 20, 2021; March 15, 2021; May 20, 21; January 24, 2022. Estimated length of trial The party or parties estimate that the trial will take (check one): a. 1] days (specify number): 1-2 days 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 & has Chas 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 oO has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). a O 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 O 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) O 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): M110 (Rev. July 1, 2014] CASE MANAGEMENT STATEMENT Page 2 of 5 American LegalN Inc, www, FormsWork Ww.c CM-110 PLAINTIFF/PETITIONER: COLLIERS INTERNATIONAL, INC. ‘CASE NUMBER: 19CV351266 [DEFENDANT/RESPONDENT: GABRIEL E. ARECHAEDERRA 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 fe] 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): (CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5 rican LegalN w FormsWork CM-110 bs PLAINTIFF/PETITIONER: COLLIERS INTERNATIONAL, INC. ‘CASE NUMBER: 19CV351266 IEFENDANT/RESPONDENT: GABRIEL E. ARECHAEDERRA 11. Insurance a Ol Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: 0 Yes 0 No . O 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. 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 1 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 The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Motion for summary judgment. 16. Discovery a. (1 The party or parties have completed all discovery. b B&Q The following discovery will be completed by the date specified (describe all anticipated discovery): Party Descriptio! Date Plaintiff Written discovery Per code Plaintiff Depositions Per code Plaintiff Expert Discovery Per code c. L The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): (CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5 American Lé alN ‘www Form: ork CM-110 PLAINTIFF/PETITIONER: COLLIERS INTERNATIONAL, INC. CASE NUMBER: 19CV351266 |DEFENDANT/RESPONDENT: GABRIEL E. ARECHAEDERRA 17. Economic litigation a C1 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. (1 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 O 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 I 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): Stipulate to an early settlement conference. 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: October 26, 2020 TODD A. ROBERTS eg FC 2c L2— (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) > (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) C Additional signatures are attached. (CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5 CASE NAME: Colliers International, Inc. V. Gabriel E. Arechaederra, ACTION NO.: Case No.: 19CV351266, Santa Clara County Superior Court PROOF OF SERVICE 1. At the time of service I was over 18 years of age and not a party to this action and a Citizen of the United States. 2. My business address is 1001 Marshall Street, Suite 500, Redwood City, CA 94063-2052, County of San Mateo. 3. On October 26, 2020 I served the following documents: CASE MANAGEMENT CONFERENCE STATEMENT 4. I served the documents on the persons at the address below (along with their fax numbers and/or email addresses if service was by fax or email): 10 Samantha D. Wolff Attorneys for Defendants ll Candice P. Shih HANSON BRIDGET LLP Tel: 415-777-3200 Fax: 415-541-9366 12 425 Market Street, 26th Floor Email: wolff@hansonbridgett.com 13 San Francisco, CA 94105 shih@hansonbridgett.com 14 5. served the documents by the following means: Or 15 fk] ONLY BY ELECTRONIC TRANSMISSION. Only by e-mailing the document(s) to Lik 16 the persons at the e-mail address(es) listed based on notice provided on March 23, 2020 that, om Ok 17 during the Coronavirus (COVID-19) pandemic, Ropers Majeski attorneys will be working remotely, not able to send physical mail as usual, and are therefore using only electronic mails. No electronic message or other indication that the transmission was unsuccessful was received 18 within a reasonable time after the transmission. Xe 19 Iam employed in the office of a member of the bar of this court at whose direction the service was made. I certify under penalty of perjury that the foregoing is true and correct. 20 Dated: October 26, 2020 21 Weve (st Boh Donna Bautista 22 Type Name Signature 23 24 25 26 27 28 PROOF OF SERVICE 483 1-8067-5242.1