Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
LEWIS BRISBOIS BISGAARD & SMITH LLP
Graham M. Cridland, SB# 243646
2020 West El Camino Avenue, Suite 700
Sacramento, California 95833
TELEPHONE NO.: 916.564.5400 FAX NO. (Optional): 916.564.5444
E-MAIL ADDRESS: graham.cridland@lewisbrisbois.com
ATTORNEY FOR (Name): Defendants James Ford, Inc. et al.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO
STREET ADDRESS: 400 County Center
MAILING ADDRESS: 400 County Center
CITY AND ZIP CODE: Redwood City, CA 94063
BRANCH NAME:
PLAINTIFF/PETITIONER: ALIYA D'OYEN
DEFENDANT/RESPONDENT: JAMES FORD, INC., et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE LIMITED CASE 23-CIV-02087
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: May 15, 2024 Time: 9:00 a.m. Dept.: 23 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Graham M. Cridland
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):
b. This statement is submitted jointly by parties (names): James Ford, Inc., Jamie J. Jamison and Robert Jamison
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):
Plaintiff alleges violation of FEHA Gov't Code Sections 12940(a), 12945.2, 12940(h), 12940(j), 12940(K), 12940(m), 12940(n)
and wrongful termination.
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: ALIYA D'OYEN CASE NUMBER:
DEFENDANT/RESPONDENT: JAMES FORD, INC., et al. 23-CIV-02087
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.)
Aliya D'Oyen was an employee of James Ford, Inc., from September 10, 2020 to April 20, 2022. She alleges that she was
discriminated against, harassed, and retaliated against on the basis of an alleged disability. Defendant has answered the
Complaint and contends Ms. D'Oyen was not discriminated against, harassed, or retaliated against, but was terminated for poor
performance.
(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):
See Attachment 6.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Attorney will have Trial Calendar at the time of hearing.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 10
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: Charles S. Painter
b. Firm: Lewis Brisbois Bisgaard & Smith, LLP
c. Address: 2020 West El Camino Real, Sacramento, CA 95833
d. Telephone number: (916) 564-5400 f. Fax number: (916) 564-5444
e. E-mail address: charles.painter@lewisbrisbois.com g. Party represented: Defendants
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):
Based on the amount in controversy.
CM-110 [Rev. September 1, 2021] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: ALIYA D'OYEN CASE NUMBER:
DEFENDANT/RESPONDENT: JAMES FORD, INC., et al. 23-CIV-02087
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
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. September 1, 2021] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: ALIYA D'OYEN CASE NUMBER:
DEFENDANT/RESPONDENT: JAMES FORD, INC., et al. 23-CIV-02087
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name): Federated Mutual Insurance Company
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): Arbitration Agreement
Status: Arbitration was requested via motion and Defendant's motion was denied.
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):
Defendants anticipated filing a motion to bifurcate liability and damages and a motion to bifurcate damages and punitive
damages.
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 and/or Summary Adjudication
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
Defendants Written Discovery August 2024
Defendants Expert Witness Depositions Per Code
Defendants Depositions November 2024
Defendants Subpoena Records and Information Per Code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. September 1, 2021] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: ALIYA D'OYEN CASE NUMBER:
DEFENDANT/RESPONDENT: JAMES FORD, INC., et al. 23-CIV-02087
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):
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): 1
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: April 30, 2024
Graham M. Cridland
(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] Page 5 of 5
CASE MANAGEMENT STATEMENT
ATTACHMENT 6
This case will not be ready for trial within 12 months of its filing because this matter was filed
May 5, 2023, and by the time of the case management conference 12 months will already have
elapsed. In addition, due to the delay occasioned by the Defendant’s Motion to Compel
Arbitration and the denial of that motion, the parties are only beginning to conduct discovery. It
is anticipated the case will be ready for trial no earlier than July 2025.”
1 CALIFORNIA STATE COURT PROOF OF SERVICE
Aliya D'Oyen v. James Ford, Inc., et al.
2 San Mateo County Superior Court Case No. 23-CIV-02087
3 STATE OF CALIFORNIA, COUNTY OF SACRAMENTO
4 At the time of service, I was over 18 years of age and not a party to this action. My
business address is 2020 West El Camino Avenue, Suite 700, Sacramento, CA 95833.
5
On April 30, 2024, I served true copies of the following document(s): DEFENDANTS'
6 CASE MANAGEMENT STATEMENT
7 I served the documents on the following persons at the following addresses (including fax
numbers and e-mail addresses, if applicable):
8
SEE ATTACHED SERVICE LIST
9
The documents were served by the following means:
10
(BY E-MAIL OR ELECTRONIC TRANSMISSION) Based on a court order or an
11 agreement of the parties to accept service by e-mail or electronic transmission, I caused the
documents to be sent from e-mail address Stephanie.Judd@lewisbrisbois.com to the
12 persons at the e-mail addresses listed above. I did not receive, within a reasonable time
after the transmission, any electronic message or other indication that the transmission was
13 unsuccessful.
14 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
15
Executed on April 30, 2024, at Sacramento, California.
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Stephanie Judd
18 Stephanie Judd
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1 SERVICE LIST
Aliya D'Oyen v. James Ford, Inc., et al.
2 San Mateo County Superior Court Case No. 23-CIV-02087
3 Attorneys for Plaintiff Aliya D’Oyen
4 Kenneth Seligson
Kaitlin Martinez
5 Seligson Law
2219 Main Street, Suite 710
6 Santa Monica, CA 90405
Phone: 213.293.6692
7 Email: Ken@seligsonlaw.com
Kaitlin@Seligsonlaw.com
8 Jason Erlich
9 Erlich Law Firm, P.C.
180 Grand Avenue, Suite 1380
10 Oakland, CA 94612
Phone: 510.390.9140
11 Email: Jason@erlichlawfirm.com
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SERVICE VIA EMAIL
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Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY LEWIS BRISBOIS BISGAARD & SMITH LLP Graham M. Cridland, SB# 243646 2020 West El Camino Avenue, Suite 700 Sacramento, California 95833 TELEPHONE NO.: 916.564.5400 FAX NO. (Optional): 916.564.5444 E-MAIL ADDRESS: graham.cridland@lewisbrisbois.com ATTORNEY FOR (Name): Defendants James Ford, Inc. et al. SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO STREET ADDRESS: 400 County Center MAILING ADDRESS: 400 County Center CITY AND ZIP CODE: Redwood City, CA 94063 BRANCH NAME: PLAINTIFF/PETITIONER: ALIYA D'OYEN DEFENDANT/RESPONDENT: JAMES FORD, INC., et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE 23-CIV-02087 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 15, 2024 Time: 9:00 a.m. Dept.: 23 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Graham M. Cridland 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): b. This statement is submitted jointly by parties (names): James Ford, Inc., Jamie J. Jamison and Robert Jamison 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): Plaintiff alleges violation of FEHA Gov't Code Sections 12940(a), 12945.2, 12940(h), 12940(j), 12940(K), 12940(m), 12940(n) and wrongful termination. 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: ALIYA D'OYEN CASE NUMBER: DEFENDANT/RESPONDENT: JAMES FORD, INC., et al. 23-CIV-02087 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.) Aliya D'Oyen was an employee of James Ford, Inc., from September 10, 2020 to April 20, 2022. She alleges that she was discriminated against, harassed, and retaliated against on the basis of an alleged disability. Defendant has answered the Complaint and contends Ms. D'Oyen was not discriminated against, harassed, or retaliated against, but was terminated for poor performance. (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): See Attachment 6. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Attorney will have Trial Calendar at the time of hearing. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 10 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: Charles S. Painter b. Firm: Lewis Brisbois Bisgaard & Smith, LLP c. Address: 2020 West El Camino Real, Sacramento, CA 95833 d. Telephone number: (916) 564-5400 f. Fax number: (916) 564-5444 e. E-mail address: charles.painter@lewisbrisbois.com g. Party represented: Defendants 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): Based on the amount in controversy. CM-110 [Rev. September 1, 2021] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: ALIYA D'OYEN CASE NUMBER: DEFENDANT/RESPONDENT: JAMES FORD, INC., et al. 23-CIV-02087 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 ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. September 1, 2021] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: ALIYA D'OYEN CASE NUMBER: DEFENDANT/RESPONDENT: JAMES FORD, INC., et al. 23-CIV-02087 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): Federated Mutual Insurance Company 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): Arbitration Agreement Status: Arbitration was requested via motion and Defendant's motion was denied. 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): Defendants anticipated filing a motion to bifurcate liability and damages and a motion to bifurcate damages and punitive damages. 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 and/or Summary Adjudication 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 Defendants Written Discovery August 2024 Defendants Expert Witness Depositions Per Code Defendants Depositions November 2024 Defendants Subpoena Records and Information Per Code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. September 1, 2021] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: ALIYA D'OYEN CASE NUMBER: DEFENDANT/RESPONDENT: JAMES FORD, INC., et al. 23-CIV-02087 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): 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): 1 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: April 30, 2024 Graham M. Cridland (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] Page 5 of 5 CASE MANAGEMENT STATEMENT ATTACHMENT 6 This case will not be ready for trial within 12 months of its filing because this matter was filed May 5, 2023, and by the time of the case management conference 12 months will already have elapsed. In addition, due to the delay occasioned by the Defendant’s Motion to Compel Arbitration and the denial of that motion, the parties are only beginning to conduct discovery. It is anticipated the case will be ready for trial no earlier than July 2025.” 1 CALIFORNIA STATE COURT PROOF OF SERVICE Aliya D'Oyen v. James Ford, Inc., et al. 2 San Mateo County Superior Court Case No. 23-CIV-02087 3 STATE OF CALIFORNIA, COUNTY OF SACRAMENTO 4 At the time of service, I was over 18 years of age and not a party to this action. My business address is 2020 West El Camino Avenue, Suite 700, Sacramento, CA 95833. 5 On April 30, 2024, I served true copies of the following document(s): DEFENDANTS' 6 CASE MANAGEMENT STATEMENT 7 I served the documents on the following persons at the following addresses (including fax numbers and e-mail addresses, if applicable): 8 SEE ATTACHED SERVICE LIST 9 The documents were served by the following means: 10 (BY E-MAIL OR ELECTRONIC TRANSMISSION) Based on a court order or an 11 agreement of the parties to accept service by e-mail or electronic transmission, I caused the documents to be sent from e-mail address Stephanie.Judd@lewisbrisbois.com to the 12 persons at the e-mail addresses listed above. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was 13 unsuccessful. 14 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 15 Executed on April 30, 2024, at Sacramento, California. 16 17 Stephanie Judd 18 Stephanie Judd 19 20 21 22 23 24 25 26 27 28 1 SERVICE LIST Aliya D'Oyen v. James Ford, Inc., et al. 2 San Mateo County Superior Court Case No. 23-CIV-02087 3 Attorneys for Plaintiff Aliya D’Oyen 4 Kenneth Seligson Kaitlin Martinez 5 Seligson Law 2219 Main Street, Suite 710 6 Santa Monica, CA 90405 Phone: 213.293.6692 7 Email: Ken@seligsonlaw.com Kaitlin@Seligsonlaw.com 8 Jason Erlich 9 Erlich Law Firm, P.C. 180 Grand Avenue, Suite 1380 10 Oakland, CA 94612 Phone: 510.390.9140 11 Email: Jason@erlichlawfirm.com 12 SERVICE VIA EMAIL 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2