On October 07, 2020 a
No Value
was filed
involving a dispute between
Dr. Ramson Mumba And Estrella Ramson Enterprises, Llc, A Texas Limited Liability Company, Directly And Derivatively On Behalf Of Texas Sugar North, Llc, A Delaware Limited Liability Company,
Texas Brick Maze, Llc, A Delaware Limited Liability Company,
Texas Cedar Ridge, Llc, A Delaware Limited Liability Company,
Texas Dove Cove, Llc, A Delaware Limited Liability Company,
Pacific Diversified Investments, Llc, A California Limited Liability Company,
Texas Sugar North, Llc, A Delaware Limited Liability Company,
and
Blue Fortress Holdings, Llc, A Wyoming Limited Liability Company,
Boulos, Najib,
Chartreuse Investments, Inc., A Texas Corporation,
Does 13 Through 20, Inclusive,
Does 1 Through 20, Inclusive,
Eastern Gate Investments, Llc, A Wyoming Limited Liability Company,
Estrella Ramson Enterprises, Llc,
First Round Investments, Llc, A Wyoming Limited Liability Company,
Guzman, Cesar,
Lugo, Estrella,
Mandeville Lancaster, Inc., A Texas Corporation,
Mumba, Ramson,
Pemberton, Jerome,
Rainhill Spring Investments, Llc, A Wyoming Limited Liability Company,
Snvb, Llc, A Texas Limited Liability Company,
Swaby, Donnet,
The Ramson Estates At Lomas, Llc, A Texas Limited Liability Company,
The Ramson Estates At Valencia, Llc, A Texas Limited Liability Company,
Umar Best, Llc, A Texas Limited Liability Company,
Westchase Holdings, Llc, A Wyoming Limited Liability Company,
for (16) Unlimited Fraud
in the District Court of San Mateo County.
Preview
BUCHALTER
1 A Professional Corporation
JEFFREY JUDD (SBN: 136358)
2 JULIAN (PETE) MACK (SBN: 104662)
RANDALL L. MANVITZ (SBN: 224498)
3 425 Market Street, Suite 2900
San Francisco, CA 94105-2491
4 Telephone: 415.227.0900
Fax: 415.227.0770
5 Email: jjudd@buchalter.com
pmack@buchalter.com; rmanvitz@buchalter.com
6
Attorneys for Plaintiffs
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 COUNTY OF SAN MATEO
9
PACIFIC DIVERSIFIED INVESTMENTS, LLC, a CASE NO. 20-CIV-04366
10 Delaware limited liability company; TEXAS SUGAR
NORTH, LLC, a Delaware limited liability company; [PROPOSED] ORDER GRANTING
11 TEXAS DOVE COVE, LLC, a Delaware limited MOTION FOR TERMINATING
liability company; TEXAS CEDAR RIDGE, LLC, a SANCTIONS AGAINST
12 Delaware limited liability company; and TEXAS DEFENDANT ESTRELLA LUGO
BRICK MAZE, LLC, a Delaware limited liability
13 company, Date: April 16, 2024
Time: 2:00 p.m.
Plaintiffs,
14 Dept.: 4
Judge: Hon. Nancy L. Fineman
vs.
15
RAMSON MUMBA, an individual; ESTRELLA
16 RAMSON ENTERPRISES, LLC, dba THE
RAMSON GROUP, a Texas limited liability
17 company; UMAR BEST, LLC, a Texas limited
liability company; EASTERN GATE
18 INVESTMENTS, LLC, a Wyoming limited liability
company; FIRST ROUND INVESTMENTS, LLC, a
19 Wyoming limited liability company; RAINHILL
SPRING INVESTMENTS, LLC, a Wyoming limited
20 liability company; BLUE FORTRESS HOLDINGS,
LLC, a Wyoming limited liability company;
21 ESTRELLA LUGO, an individual; THE RAMSON
ESTATES AT LOMAS, LLC, a Texas limited
22 liability company; THE RAMSON ESTATES AT
VALENCIA, LLC, a Texas limited liability company;
23 MANDEVILLE LANCASTER, INC., a Texas
corporation; DONNET SWABY, an individual;
24 JEROME PEMBERTON, an individual;
CHARTREUSE INVESTMENTS, INC., a Texas
25 corporation; WESTCHASE HOLDINGS, LLC, a
Wyoming limited liability company; CESAR
26 GUZMAN, an individual, and DOES 13 through 20,
inclusive,
27 Defendants.
28 AND RELATED CROSS-COMPLAINT
BUCHALTER
A PROFES SION AL CORPORAT ION
LOS ANG ELES
BN 82071562v1 1
[PROP] ORDER GRANTING MOTION FOR TERMINATING SANCTIONS AGAINST LUGO -- CASE
NO. 20-CIV-04366
1 This matter came on for hearing on April 16, 2024 on Plaintiffs’ Motion for Terminating
2 Sanctions Against Defendant Estrella Lugo. On April 15, 2024, the Court issued its Tentative
3 Ruling pursuant to California Rules of Court, Rule 3.1308 and Superior Court of California,
4 County of San Mateo, Local Rule 3.403. No party contested the ruling and the Court adopted its
5 tentative ruling, as follows:
6 The court GRANTS plaintiffs’ unopposed motion for terminating sanctions against
7 Estrella Lugo.
8 This court is familiar with the case because it has been the single assigned judge since the
9 case’s inception. On November 20, 2023, the court entered an order granting terminating
10 sanctions against co-defendant Ramson Mumba, Lugo’s spouse or former spouse based upon a
11 hearing held on October 31, 2023.
12 On April 25, 2022, Lugo in pro per filed her answer to the first amended complaint. She
13 did not include her telephone number or an email address. The court does not remember her ever
14 appearing at any hearing or conference. Mumba has represented to the court that Lugo does not
15 have an email address. On September 16, 2022, this court issued an order to show cause to
16 Mumba and Lugo to provide updated address because they no longer live at the address on their
17 answers. At the order to show cause hearing on November 30, 2022, Mumba stated that he was
18 living in his car and the court ordered that he accept email service. Lugo failed to appear and thus
19 the court and the other parties have no other address for her other than the address in the court’s
20 records based upon the address on Lugo’s answer. Lugo has never filed an updated address
21 Plaintiffs have properly served this motion by mail to the address in the court file for Lugo. They
22 also served her by email at Mumba’s email address, which at one time Mumba represented was
23 the email address which could be used to send documents to Lugo. Thus, the court finds that there
24 has been proper service.
25 This court has the power to grant terminating sanctions after considering the totality of the
26 circumstances, including but not limited to: (1) the willfulness of the party’s conduct; (2)
27 detriment to the propounding party; and (3) the number of formal and informal attempts to obtain
28 discovery. (Los Defensores, Inc. v. Gomez (2014) 223 Cal.App.4th 377, 390.) Where the
BUCHALTER
A PROFES SION AL CORPORAT ION
SAN FR ANCISCO
BN 82071562v1 2
[PROP] ORDER GRANTING MOTION FOR TERMINATING SANCTIONS AGAINST LUGO -- CASE
NO. 20-CIV-04366
1 violation is willful and preceded by a history of discovery abuses, and it is clear that less severe
2 sanctions would not result in compliance with discovery rules, this court is justified in imposing
3 terminating sanctions. (Ibid.)
4 Except for filing an answer, Lugo has failed to participate at all in this litigation, including
5 her failure to oppose motions, comply with court orders, and pay sanctions. The court file
6 contains the following orders sanctioning Lugo: September 28, 2022 order regarding her
7 deposition, responding to discovery and paying sanctions; October 25, 2022 order to show cause
8 minute order with November 30, 2022 written order; November 30, 2022 order compelling her
9 deposition; January 10, 2023 order granting sanctions against Lugo for failure to comply with
10 court orders; and May 25, 2023 order granting motion to compel responses and for monetary
11 sanctions. To this date, Lugo has failed to adhere to any of these orders. As such, the court finds
12 that any sanction less than a terminating sanction is not warranted.
13 This court in weighing the totality of the circumstances and exercising its discretion finds
14 that terminating sanctions are justified here. (Liberty Mutual Fire Ins. Co. v. LcL Administrators,
15 Inc. (2008) 163 Cal.App.4th 1093, 1096, 1099 [terminating sanctions warranted when months-
16 long lack of cooperation in providing straight-forward information, witnesses and documents to
17 support claim]; Reedy v. Bussell (2007) 148 Cal.App.4th 1272, 1291–1292 [defendants
18 recalcitrant in virtually every aspect of discovery and the obstinacy continued during trial]; see
19 also Doppes v. Bentley Motors, Inc. (2009) 174 Cal.App.4th 967, 995–996.) Despite court orders
20 and numerous meet and confer efforts by plaintiffs to obtain discovery from Lugo, Lugo has
21 refused to provide any discovery or participate in this case. Although she proceeds pro se, self-
22 represented litigants are held to the same standards that apply to licensed attorneys. (Harding v.
23 Collazo (1986) 177 Cal.App.3d 1044, 1056.)
24 The court has taken numerous incremental steps before imposing the terminating
25 sanctions. The court has already issued monetary sanctions, but they had no impact in having
26 Lugo comply with discovery requests. Terminating sanctions are typically a last resort to be used
27 sparingly. (Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 793.) In this case, this court is only
28 issuing the terminating sanctions after the imposition of other sanctions which have not have any
BUCHALTER
A PROFES SION AL CORPORAT ION
LOS ANG ELES
BN 82071562v1 3
[PROP] ORDER GRANTING MOTION FOR TERMINATING SANCTIONS AGAINST LUGO -- CASE
NO. 20-CIV-04366
1 effect. Lugo has engaged in a pattern and practice of not obeying court orders and not
2 participating in this case except for filing an answer.
3 This court thus concludes, after reviewing the record, considering the totality of the
4 circumstances and exercising its discretion, that Lugo’s repeated abuse of the discovery process,
5 even in defiance of court orders, are willful and calculated, and that no lesser sanction is
6 appropriate. This court is tailoring the sanction to the harm caused by the withholding of
7 discovery. What we have here is defendant’s persistent failure to share with the plaintiffs material
8 information about her defenses, which made it impossible for plaintiffs to prepare for trial,
9 causing the court to vacate a trial which was set to start on February 7, 2024, and the court’s
10 inability to hold a pretrial conference on January 8, 2024 because Lugo had not complied with
11 any of the requirements of the court’s pretrial order. (Collisson & Kaplan v. Hartunian (1994) 21
12 Cal.App.4th 1611, 1619 [upholding terminating sanctions when defendant failed to provide facts
13 underlying denial of liability with a trial date less than two months away].)
14 Accordingly, this court strikes the answer and affirmative defenses of defendant Lugo and
15 enters her default.
16 If the tentative ruling is uncontested, it shall become the order of the court. Thereafter,
17 counsel for plaintiffs shall prepare a written order consistent with the court's ruling for the court’s
18 signature, pursuant to California Rules of Court, rule 3.1312, and provide written notice of the
19 ruling to all parties who have appeared in the action, as required by law and the California Rules
20 //
21 //
22 //
23 //
24 //
25 //
26 //
27 //
28 //
BUCHALTER
A PROFES SION AL CORPORAT ION
LOS ANG ELES
BN 82071562v1 4
[PROP] ORDER GRANTING MOTION FOR TERMINATING SANCTIONS AGAINST LUGO -- CASE
NO. 20-CIV-04366
1 of Court. The court alerts the parties to revised Local Rule 3.403(b)(iv) (amended effective
2 January 1, 2024) regarding the wording of proposed orders.
3 IT IS SO ORDERED.
4 DATED: April ___, 2024
5 _________________________________________
HONORABLE NANCY L. FINEMAN
6 JUDGE OF THE SUPERIOR COURT
7 APPROVED AS TO FORM AND CONTENT:
8 DATED: April __, 2024
9 By:
RAMSON MUMBA
10
DATED: April __, 2024
11
By:
12 ESTRELLA LUGO
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
BUCHALTER
A PROFES SION AL CORPORAT ION
LOS ANG ELES
BN 82071562v1 5
[PROP] ORDER GRANTING MOTION FOR TERMINATING SANCTIONS AGAINST LUGO -- CASE
NO. 20-CIV-04366
1 PROOF OF SERVICE
2
I am employed in the County of San Francisco, State of California. I am over the age of
3 18 and not a party to the within action. My business address is at BUCHALTER, A Professional
Corporation, 425 Market Street, Suite 2900, San Francisco, California 94105.
4
On the date set forth below, I served the following document(s) described as:
5
[PROPOSED] ORDER GRANTING MOTION FOR TERMINATING
6 SANCTIONS AGAINST DEFENDANT ESTRELLA LUGO
7 as follows:
8
Via Email Only Via Email & US Mail Only
9
RAMSON MUMBA ESTRELLA LUGO
10 3335 Chartreuse Way 3335 Chartreuse Way
Houston, TX 77082 Houston, TX 77082
11 ramson@theramsongroup.com ramson@theramsongroup.com
12
BY EMAIL: On April 17, 2024, I personally electronically served from my electronic
13 address dfong@buchalter.com in “PDF” format, the document(s) described above, to the
individual(s) stated above to their known email/electronic addresses as shown above. The
14 transmission was reported as complete and without error. (CCP §1010.6; CRC §2.251, et seq.)
15 BY MAIL: I am readily familiar with the business’ practice for collection and processing
of correspondence for mailing with the United States Postal Service. The address(es) shown
16 above is(are) the same as shown on the envelope. The envelope was placed for deposit in the
United States Postal Service at Buchalter in San Francisco, California on April 17, 2024. The
17 envelope was sealed and placed for collection and mailing with first-class prepaid postage on this
date following ordinary business practices.
18
I declare under penalty of perjury under the laws of the State of California, United States
19 of America, that the foregoing is true and correct to the best of my knowledge; and that I am
employed in the office of a member of the bar of this court at whose direction the service was
20 made.
21 Executed on April 17, 2024, at San Francisco, California.
22
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25
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27
28
BUCHALTER
A PROFESSIONAL CORPORATION
SAN FRANCISCO
BN 82079590v1 1
PROOF OF SERVICE; CASE NO. 20-CIV-04366
Preview
BUCHALTER 1 A Professional Corporation JEFFREY JUDD (SBN: 136358) 2 JULIAN (PETE) MACK (SBN: 104662) RANDALL L. MANVITZ (SBN: 224498) 3 425 Market Street, Suite 2900 San Francisco, CA 94105-2491 4 Telephone: 415.227.0900 Fax: 415.227.0770 5 Email: jjudd@buchalter.com pmack@buchalter.com; rmanvitz@buchalter.com 6 Attorneys for Plaintiffs 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF SAN MATEO 9 PACIFIC DIVERSIFIED INVESTMENTS, LLC, a CASE NO. 20-CIV-04366 10 Delaware limited liability company; TEXAS SUGAR NORTH, LLC, a Delaware limited liability company; [PROPOSED] ORDER GRANTING 11 TEXAS DOVE COVE, LLC, a Delaware limited MOTION FOR TERMINATING liability company; TEXAS CEDAR RIDGE, LLC, a SANCTIONS AGAINST 12 Delaware limited liability company; and TEXAS DEFENDANT ESTRELLA LUGO BRICK MAZE, LLC, a Delaware limited liability 13 company, Date: April 16, 2024 Time: 2:00 p.m. Plaintiffs, 14 Dept.: 4 Judge: Hon. Nancy L. Fineman vs. 15 RAMSON MUMBA, an individual; ESTRELLA 16 RAMSON ENTERPRISES, LLC, dba THE RAMSON GROUP, a Texas limited liability 17 company; UMAR BEST, LLC, a Texas limited liability company; EASTERN GATE 18 INVESTMENTS, LLC, a Wyoming limited liability company; FIRST ROUND INVESTMENTS, LLC, a 19 Wyoming limited liability company; RAINHILL SPRING INVESTMENTS, LLC, a Wyoming limited 20 liability company; BLUE FORTRESS HOLDINGS, LLC, a Wyoming limited liability company; 21 ESTRELLA LUGO, an individual; THE RAMSON ESTATES AT LOMAS, LLC, a Texas limited 22 liability company; THE RAMSON ESTATES AT VALENCIA, LLC, a Texas limited liability company; 23 MANDEVILLE LANCASTER, INC., a Texas corporation; DONNET SWABY, an individual; 24 JEROME PEMBERTON, an individual; CHARTREUSE INVESTMENTS, INC., a Texas 25 corporation; WESTCHASE HOLDINGS, LLC, a Wyoming limited liability company; CESAR 26 GUZMAN, an individual, and DOES 13 through 20, inclusive, 27 Defendants. 28 AND RELATED CROSS-COMPLAINT BUCHALTER A PROFES SION AL CORPORAT ION LOS ANG ELES BN 82071562v1 1 [PROP] ORDER GRANTING MOTION FOR TERMINATING SANCTIONS AGAINST LUGO -- CASE NO. 20-CIV-04366 1 This matter came on for hearing on April 16, 2024 on Plaintiffs’ Motion for Terminating 2 Sanctions Against Defendant Estrella Lugo. On April 15, 2024, the Court issued its Tentative 3 Ruling pursuant to California Rules of Court, Rule 3.1308 and Superior Court of California, 4 County of San Mateo, Local Rule 3.403. No party contested the ruling and the Court adopted its 5 tentative ruling, as follows: 6 The court GRANTS plaintiffs’ unopposed motion for terminating sanctions against 7 Estrella Lugo. 8 This court is familiar with the case because it has been the single assigned judge since the 9 case’s inception. On November 20, 2023, the court entered an order granting terminating 10 sanctions against co-defendant Ramson Mumba, Lugo’s spouse or former spouse based upon a 11 hearing held on October 31, 2023. 12 On April 25, 2022, Lugo in pro per filed her answer to the first amended complaint. She 13 did not include her telephone number or an email address. The court does not remember her ever 14 appearing at any hearing or conference. Mumba has represented to the court that Lugo does not 15 have an email address. On September 16, 2022, this court issued an order to show cause to 16 Mumba and Lugo to provide updated address because they no longer live at the address on their 17 answers. At the order to show cause hearing on November 30, 2022, Mumba stated that he was 18 living in his car and the court ordered that he accept email service. Lugo failed to appear and thus 19 the court and the other parties have no other address for her other than the address in the court’s 20 records based upon the address on Lugo’s answer. Lugo has never filed an updated address 21 Plaintiffs have properly served this motion by mail to the address in the court file for Lugo. They 22 also served her by email at Mumba’s email address, which at one time Mumba represented was 23 the email address which could be used to send documents to Lugo. Thus, the court finds that there 24 has been proper service. 25 This court has the power to grant terminating sanctions after considering the totality of the 26 circumstances, including but not limited to: (1) the willfulness of the party’s conduct; (2) 27 detriment to the propounding party; and (3) the number of formal and informal attempts to obtain 28 discovery. (Los Defensores, Inc. v. Gomez (2014) 223 Cal.App.4th 377, 390.) Where the BUCHALTER A PROFES SION AL CORPORAT ION SAN FR ANCISCO BN 82071562v1 2 [PROP] ORDER GRANTING MOTION FOR TERMINATING SANCTIONS AGAINST LUGO -- CASE NO. 20-CIV-04366 1 violation is willful and preceded by a history of discovery abuses, and it is clear that less severe 2 sanctions would not result in compliance with discovery rules, this court is justified in imposing 3 terminating sanctions. (Ibid.) 4 Except for filing an answer, Lugo has failed to participate at all in this litigation, including 5 her failure to oppose motions, comply with court orders, and pay sanctions. The court file 6 contains the following orders sanctioning Lugo: September 28, 2022 order regarding her 7 deposition, responding to discovery and paying sanctions; October 25, 2022 order to show cause 8 minute order with November 30, 2022 written order; November 30, 2022 order compelling her 9 deposition; January 10, 2023 order granting sanctions against Lugo for failure to comply with 10 court orders; and May 25, 2023 order granting motion to compel responses and for monetary 11 sanctions. To this date, Lugo has failed to adhere to any of these orders. As such, the court finds 12 that any sanction less than a terminating sanction is not warranted. 13 This court in weighing the totality of the circumstances and exercising its discretion finds 14 that terminating sanctions are justified here. (Liberty Mutual Fire Ins. Co. v. LcL Administrators, 15 Inc. (2008) 163 Cal.App.4th 1093, 1096, 1099 [terminating sanctions warranted when months- 16 long lack of cooperation in providing straight-forward information, witnesses and documents to 17 support claim]; Reedy v. Bussell (2007) 148 Cal.App.4th 1272, 1291–1292 [defendants 18 recalcitrant in virtually every aspect of discovery and the obstinacy continued during trial]; see 19 also Doppes v. Bentley Motors, Inc. (2009) 174 Cal.App.4th 967, 995–996.) Despite court orders 20 and numerous meet and confer efforts by plaintiffs to obtain discovery from Lugo, Lugo has 21 refused to provide any discovery or participate in this case. Although she proceeds pro se, self- 22 represented litigants are held to the same standards that apply to licensed attorneys. (Harding v. 23 Collazo (1986) 177 Cal.App.3d 1044, 1056.) 24 The court has taken numerous incremental steps before imposing the terminating 25 sanctions. The court has already issued monetary sanctions, but they had no impact in having 26 Lugo comply with discovery requests. Terminating sanctions are typically a last resort to be used 27 sparingly. (Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 793.) In this case, this court is only 28 issuing the terminating sanctions after the imposition of other sanctions which have not have any BUCHALTER A PROFES SION AL CORPORAT ION LOS ANG ELES BN 82071562v1 3 [PROP] ORDER GRANTING MOTION FOR TERMINATING SANCTIONS AGAINST LUGO -- CASE NO. 20-CIV-04366 1 effect. Lugo has engaged in a pattern and practice of not obeying court orders and not 2 participating in this case except for filing an answer. 3 This court thus concludes, after reviewing the record, considering the totality of the 4 circumstances and exercising its discretion, that Lugo’s repeated abuse of the discovery process, 5 even in defiance of court orders, are willful and calculated, and that no lesser sanction is 6 appropriate. This court is tailoring the sanction to the harm caused by the withholding of 7 discovery. What we have here is defendant’s persistent failure to share with the plaintiffs material 8 information about her defenses, which made it impossible for plaintiffs to prepare for trial, 9 causing the court to vacate a trial which was set to start on February 7, 2024, and the court’s 10 inability to hold a pretrial conference on January 8, 2024 because Lugo had not complied with 11 any of the requirements of the court’s pretrial order. (Collisson & Kaplan v. Hartunian (1994) 21 12 Cal.App.4th 1611, 1619 [upholding terminating sanctions when defendant failed to provide facts 13 underlying denial of liability with a trial date less than two months away].) 14 Accordingly, this court strikes the answer and affirmative defenses of defendant Lugo and 15 enters her default. 16 If the tentative ruling is uncontested, it shall become the order of the court. Thereafter, 17 counsel for plaintiffs shall prepare a written order consistent with the court's ruling for the court’s 18 signature, pursuant to California Rules of Court, rule 3.1312, and provide written notice of the 19 ruling to all parties who have appeared in the action, as required by law and the California Rules 20 // 21 // 22 // 23 // 24 // 25 // 26 // 27 // 28 // BUCHALTER A PROFES SION AL CORPORAT ION LOS ANG ELES BN 82071562v1 4 [PROP] ORDER GRANTING MOTION FOR TERMINATING SANCTIONS AGAINST LUGO -- CASE NO. 20-CIV-04366 1 of Court. The court alerts the parties to revised Local Rule 3.403(b)(iv) (amended effective 2 January 1, 2024) regarding the wording of proposed orders. 3 IT IS SO ORDERED. 4 DATED: April ___, 2024 5 _________________________________________ HONORABLE NANCY L. FINEMAN 6 JUDGE OF THE SUPERIOR COURT 7 APPROVED AS TO FORM AND CONTENT: 8 DATED: April __, 2024 9 By: RAMSON MUMBA 10 DATED: April __, 2024 11 By: 12 ESTRELLA LUGO 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BUCHALTER A PROFES SION AL CORPORAT ION LOS ANG ELES BN 82071562v1 5 [PROP] ORDER GRANTING MOTION FOR TERMINATING SANCTIONS AGAINST LUGO -- CASE NO. 20-CIV-04366 1 PROOF OF SERVICE 2 I am employed in the County of San Francisco, State of California. I am over the age of 3 18 and not a party to the within action. My business address is at BUCHALTER, A Professional Corporation, 425 Market Street, Suite 2900, San Francisco, California 94105. 4 On the date set forth below, I served the following document(s) described as: 5 [PROPOSED] ORDER GRANTING MOTION FOR TERMINATING 6 SANCTIONS AGAINST DEFENDANT ESTRELLA LUGO 7 as follows: 8 Via Email Only Via Email & US Mail Only 9 RAMSON MUMBA ESTRELLA LUGO 10 3335 Chartreuse Way 3335 Chartreuse Way Houston, TX 77082 Houston, TX 77082 11 ramson@theramsongroup.com ramson@theramsongroup.com 12 BY EMAIL: On April 17, 2024, I personally electronically served from my electronic 13 address dfong@buchalter.com in “PDF” format, the document(s) described above, to the individual(s) stated above to their known email/electronic addresses as shown above. The 14 transmission was reported as complete and without error. (CCP §1010.6; CRC §2.251, et seq.) 15 BY MAIL: I am readily familiar with the business’ practice for collection and processing of correspondence for mailing with the United States Postal Service. The address(es) shown 16 above is(are) the same as shown on the envelope. The envelope was placed for deposit in the United States Postal Service at Buchalter in San Francisco, California on April 17, 2024. The 17 envelope was sealed and placed for collection and mailing with first-class prepaid postage on this date following ordinary business practices. 18 I declare under penalty of perjury under the laws of the State of California, United States 19 of America, that the foregoing is true and correct to the best of my knowledge; and that I am employed in the office of a member of the bar of this court at whose direction the service was 20 made. 21 Executed on April 17, 2024, at San Francisco, California. 22 23 24 25 26 27 28 BUCHALTER A PROFESSIONAL CORPORATION SAN FRANCISCO BN 82079590v1 1 PROOF OF SERVICE; CASE NO. 20-CIV-04366