Preview
CM-110
ATTORNEY OR PARTY W ITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
Tiffany Ng (SBN: 301436)
Buchalter, APC
425 Market Street, Suite 2900
San Francisco, CA 94105
415.227.0900
TELEPHONE NO.: FAX NO. (Optional):
tng@buchalter.com
E-MAIL ADDRESS:
ATTORNEY FOR (Name): Defendant, Santa Cruz County Bank
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CRUZ
STREET ADDRESS: 701 Ocean Street
MAILING ADDRESS:
CITY AND ZIP CODE: Santa Cruz, CA 95060
BRANCH NAME:
PLAINTIFF/PETITIONER: Erik
M. Rollain & Deana Rollain, Trustees, et al.
DEFENDANT/RESPONDENT: Scott Myers-Lipton, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE LIMITED CASE
23CV02116
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: March 28, 2024 Time: 8:30 a.m. Dept.: 5 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Tiffany Ng
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. This statement is submitted by party (name): Defendant Santa Cruz County Bank
b. 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. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. The following parties named in the complaint or cross-complaint
(1) have not been served (specify names and explain why not):
(2) have been served but have not appeared and have not been dismissed (specify names):
(3) have had a default entered against them (specify names):
c. 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 complaint cross-complaint (Describe, including causes of action): This is an
easement dispute with plaintiff alleging claims for: (1) quiet title, (2) reformation of deed, (3) declaratory relief, and
(4) quiet title - easement by estoppel.
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
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: Erik
M. Rollain & Deana Rollain, Trustees, et al. CASE NUMBER:
DEFENDANT/RESPONDENT: Scott Myers-Lipton, et al. 23CV02116
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.)
Plaintiff alleges that the defendant-borrower supposedly violated an easement granting certain rights to plaintiff.
Defendant Santa Cruz County Bank is the lender of a loan made to the defendant-borrower and the loan is secured
against the subject property. Defendant Santa Cruz County Bank denies all allegations and understands that it is
being named as a necessary party in this lawsuit.
(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 a jury triaI 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. 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):
5/15/2024 - 9/30/2024 (medical reasons)
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. days (specify number): 3
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
9. 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 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 has 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 has has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) 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) 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) 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 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5
CM-110
PLAINTIFF/PETITIONER: Erik
M. Rollain & Deana Rollain, Trustees, et al. CASE NUMBER:
DEFENDANT/RESPONDENT: Scott Myers-Lipton, et al. 23CV02116
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
Mediation session scheduled for (date):
(1) Mediation
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. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5
CM-110
PLAINTIFF/PETITIONER: Erik
M. Rollain & Deana Rollain, Trustees, et al. CASE NUMBER:
DEFENDANT/RESPONDENT: Scott Myers-Lipton, et al. 23CV02116
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes No
c. 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.
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:
Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate wiII be filed by (name party):
14. Bifurcation
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):
16. Discovery
a. The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendant SCCB Written Discovery Sept. 2024
Defendant SCCB Depositions Dec. 2024
Defendant SCCB Expert Discovery Per CCP
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5
CM-110
PLAINTIFF/PETITIONER: Erik
M. Rollain & Deana Rollain, Trustees, et al. CASE NUMBER:
DEFENDANT/RESPONDENT: Scott Myers-Lipton, et al. 23CV02116
17. Economic litigation
a. 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. 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
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
Defendant Santa Cruz County Bank does not oppose to any mediation or settlement conference but understands
that it is being named as a necessary party in this lawsuit and does not plan to subsatntively participate in any
mediation or settlement conference.
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):
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):
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: 3/18/2024
Tiffany Ng �
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
�
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5
1 PROOF OF SERVICE
2 I am employed in the County of Sacramento, State of California. I am over the age of 18
3 and not a party to the within action. My business address is at BUCHALTER, A Professional
4 Corporation, 500 Capital Mall, Suite 1900, Sacramento, CA 95814.
5 On the date set forth below, I served the foregoing document described as:
6 SANTA CRUZ COUNTY BANK’S CASE MANAGEMENT STATEMENT
7
on all other parties and/or their attorney(s) of record to this action as follows:
8
9 Edward L. Chun Attorneys for Plaintiffs Erik M. Rollain and
Khrystsina Kisel Deana Rollain, Trustees of the Rollian
10 Penrose Chun & Gorman LLP Family Trust, dated April 21, 2022
1200 Pacific Avenue, Suite 260
11 Santa Cruz, CA 95060
12 Emails: echun@pcg-llp.com
kkisel@ocg-llp.com
13
Ronald Rossi Attorneys for Defendants Scott Myers-Lipton
14 Ruby Palomares and Diane Myers-Lipton
Rossi, Hamerslough Reischl & Chuck
15 1960 The Alameda, Suite 200
San Jose, CA 95126
16 Emails: ron@rhrc.net
ruby@rhrc.net
17
18 � BY EMAIL On March 19, 2024, I caused the above-referenced document(s) to be sent in
electronic PDF format as an attachment to an email addressed to the person(s) on whom such
19 document(s) is/are to be served at the email address(es) shown above, as last given by that person(s)
or as obtained from an internet website(s) relating to such person(s), and I did not receive an email
20 response upon sending such email indicating that such email was not delivered.
21 I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct to the best of my knowledge. Executed on March 19, 2024, at Sacramento,
22
California.
23
24 Alyssa Kern
(Signature)
25
26
27
28
BUCHALTER
A P R O F E S S I ON A L C OR P OR A T I O N
S A N F R AN C I S C O
1
PROOF OF SERVICE - CASE NO. 20TRCV00253
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CM-110 ATTORNEY OR PARTY W ITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Tiffany Ng (SBN: 301436) Buchalter, APC 425 Market Street, Suite 2900 San Francisco, CA 94105 415.227.0900 TELEPHONE NO.: FAX NO. (Optional): tng@buchalter.com E-MAIL ADDRESS: ATTORNEY FOR (Name): Defendant, Santa Cruz County Bank SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CRUZ STREET ADDRESS: 701 Ocean Street MAILING ADDRESS: CITY AND ZIP CODE: Santa Cruz, CA 95060 BRANCH NAME: PLAINTIFF/PETITIONER: Erik M. Rollain & Deana Rollain, Trustees, et al. DEFENDANT/RESPONDENT: Scott Myers-Lipton, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE 23CV02116 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: March 28, 2024 Time: 8:30 a.m. Dept.: 5 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Tiffany Ng INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): Defendant Santa Cruz County Bank b. 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. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. The following parties named in the complaint or cross-complaint (1) have not been served (specify names and explain why not): (2) have been served but have not appeared and have not been dismissed (specify names): (3) have had a default entered against them (specify names): c. 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 complaint cross-complaint (Describe, including causes of action): This is an easement dispute with plaintiff alleging claims for: (1) quiet title, (2) reformation of deed, (3) declaratory relief, and (4) quiet title - easement by estoppel. Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, 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: Erik M. Rollain & Deana Rollain, Trustees, et al. CASE NUMBER: DEFENDANT/RESPONDENT: Scott Myers-Lipton, et al. 23CV02116 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.) Plaintiff alleges that the defendant-borrower supposedly violated an easement granting certain rights to plaintiff. Defendant Santa Cruz County Bank is the lender of a loan made to the defendant-borrower and the loan is secured against the subject property. Defendant Santa Cruz County Bank denies all allegations and understands that it is being named as a necessary party in this lawsuit. (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 a jury triaI 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. 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): 5/15/2024 - 9/30/2024 (medical reasons) 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. days (specify number): 3 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: Additional representation is described in Attachment 8. 9. 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 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 has 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 has has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) 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) 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) 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 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5 CM-110 PLAINTIFF/PETITIONER: Erik M. Rollain & Deana Rollain, Trustees, et al. CASE NUMBER: DEFENDANT/RESPONDENT: Scott Myers-Lipton, et al. 23CV02116 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 Mediation session scheduled for (date): (1) Mediation 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. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5 CM-110 PLAINTIFF/PETITIONER: Erik M. Rollain & Deana Rollain, Trustees, et al. CASE NUMBER: DEFENDANT/RESPONDENT: Scott Myers-Lipton, et al. 23CV02116 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes No c. 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. 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: Additional cases are described in Attachment 13a. b. A motion to consolidate coordinate wiII be filed by (name party): 14. Bifurcation 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): 16. Discovery a. The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant SCCB Written Discovery Sept. 2024 Defendant SCCB Depositions Dec. 2024 Defendant SCCB Expert Discovery Per CCP c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: Erik M. Rollain & Deana Rollain, Trustees, et al. CASE NUMBER: DEFENDANT/RESPONDENT: Scott Myers-Lipton, et al. 23CV02116 17. Economic litigation a. 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. 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 The party or parties request that the following additional matters be considered or determined at the case management conference (specify): Defendant Santa Cruz County Bank does not oppose to any mediation or settlement conference but understands that it is being named as a necessary party in this lawsuit and does not plan to subsatntively participate in any mediation or settlement conference. 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): 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): 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: 3/18/2024 Tiffany Ng � (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) � (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5 1 PROOF OF SERVICE 2 I am employed in the County of Sacramento, State of California. I am over the age of 18 3 and not a party to the within action. My business address is at BUCHALTER, A Professional 4 Corporation, 500 Capital Mall, Suite 1900, Sacramento, CA 95814. 5 On the date set forth below, I served the foregoing document described as: 6 SANTA CRUZ COUNTY BANK’S CASE MANAGEMENT STATEMENT 7 on all other parties and/or their attorney(s) of record to this action as follows: 8 9 Edward L. Chun Attorneys for Plaintiffs Erik M. Rollain and Khrystsina Kisel Deana Rollain, Trustees of the Rollian 10 Penrose Chun & Gorman LLP Family Trust, dated April 21, 2022 1200 Pacific Avenue, Suite 260 11 Santa Cruz, CA 95060 12 Emails: echun@pcg-llp.com kkisel@ocg-llp.com 13 Ronald Rossi Attorneys for Defendants Scott Myers-Lipton 14 Ruby Palomares and Diane Myers-Lipton Rossi, Hamerslough Reischl & Chuck 15 1960 The Alameda, Suite 200 San Jose, CA 95126 16 Emails: ron@rhrc.net ruby@rhrc.net 17 18 � BY EMAIL On March 19, 2024, I caused the above-referenced document(s) to be sent in electronic PDF format as an attachment to an email addressed to the person(s) on whom such 19 document(s) is/are to be served at the email address(es) shown above, as last given by that person(s) or as obtained from an internet website(s) relating to such person(s), and I did not receive an email 20 response upon sending such email indicating that such email was not delivered. 21 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct to the best of my knowledge. Executed on March 19, 2024, at Sacramento, 22 California. 23 24 Alyssa Kern (Signature) 25 26 27 28 BUCHALTER A P R O F E S S I ON A L C OR P OR A T I O N S A N F R AN C I S C O 1 PROOF OF SERVICE - CASE NO. 20TRCV00253