Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
Christopher D . Sullivan, SBN 148083
DIAMOND MCCARTHY LLP
150 California Street, Suite 2200, San Francisco, CA 94111 ELECTRONICALLY
TELEPHONE NO.: (415) 692-5200 FAX NO. (Optional): (415) 263-9200 FILED
Superior Court of California,
E-MAIL ADDRESS (Optional): csullivan@diamondmccarthy.com County of San Francisco
AHORNEY FOR (Name): Plaintiff, LEGALIST, INC ., a Delaware corporation
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO 06/19/2020
STREET ADDRESS 400 McAllister Street Clerk of the Court
MAILING ADDRESS: BY: VANESSA WU
Deputy Clerk
CITY AND zIP cooE San Francisco, CA 94102
BRANCH NAME:
PLAINTIFF/PETITIONER: LEGALIST, INC., a Delaware corporation
DEFENDANT/RESPONDENT: RUSSEL MYRICK; ROM LEGAL GROUP
CASE MANAGEMENT STATEMENT CASE NUMBER
CGC-20-582932
(Check one): 0 UNLIMITED CASE c::::J LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is schedu led as follows:
Date: July 15, 2020 Time: 10:30 a.m. Dept.: 610 Div.: Room:
Address of court (if different from the address above):
[K] Notice of Intent to Appear by Telephone, by (name) : Christopher D. Sullivan
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. 0 This statement is submitted by party (name): LEGALIST, INC. , a Delaware corporation
b. D This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): February 13, 2020
b. CJ The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. D All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed .
b. D The following parties named in the complaint or cross-complaint
(1) D have not been served (specify names and explain why not):
(2) CE] have been served but have not appeared and have not been dismissed (specify names):
Defendants RUSSEL MYRICK, an individual, and RDM LEGAL Group, a California sole proprietorship
(3) D have had a default entered against them (specify names):
c. D The following additiona l 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 [K] complaint D cross-complaint (Describe, including causes of action):
Plaintiffs Complaint contains a sing le cause of action for breach of contract.
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. July 1, 2011] www. courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: LEGALIST, INC., a Delaware corporation CASE NUMBER:
CGC-20-582932
DEFENDANT/RESPONDENT: RUSSEL MYRICK; ROM LEGAL GROUP
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)
Plaintiffs Complaint alleges Defendants breached a December 6, 2018 written agreement pursuant to which Plaintiff provided
litigation funding to Defendants. Defendants failed to pay Plaintiff all amounts due under the parties' agreement. Plaintiff seeks
damages of $573,287.96 as of February 12, 2020, plus additional damages of $342.47 per day thereafter, plus prejudgment
interest of 4% per annum from December 5, 2019 until paid, plus attorneys' fees and costs .
D (If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
a. The party or parties request D a jury trial [I] a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. D The trial has been set for (date):
b. 00 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):
On March 17, 2020 , the Court issued an Order pursuant to CCP section 1281.8(d) staying this action pending arbitration .
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. D days (specify number):
b. CJ hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial [RJ by the attorney or party listed in the caption CJ by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
D Additional representation is described in Attachment 8.
9. Preference
D This case is entitled to preference (specify code section) :
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel 0 has D has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party CJ has CJ has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
( 1) CJ 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) CJ 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. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: LEGALIST, INC. , a Delaware corporation CASE NUMBER:
CGC-20-582932
DEFENDANT/RESPONDENT: RUSSEL MYRICK; ROM LEGAL GROUP
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):
D Mediation session not yet scheduled
D Mediation session scheduled for (date):
(1) Mediation D D Agreed to complete mediation by (date):
D Mediation completed on (date) :
D Settlement conference not yet scheduled
(2) Settlement D Settlement conference scheduled for(date) :
conference
D CJ Agreed to complete settlement conference by(date):
D Settlement conference completed on (date):
D Neutral evaluation not yet scheduled
D Neutral evaluation scheduled for (date):
(3) Neutral evaluation CJ D Agreed to complete neutral evaluation by (date):
D Neutral evaluation completed on (date):
D Judicial arbitration not yet scheduled
(4) Nonbinding judicial D D Judicial arbitration scheduled for (date) :
arbitration D Agreed to complete judicial arbitration by (date):
D Judicial arbitration completed on (date):
w Private arbitration not yet scheduled
(5) Binding private m CJ Private arbitration scheduled for (date) :
arbitration D Agreed to complete private arbitration by (date):
D Private arbitration completed on (date):
D ADR session not yet scheduled
D ADR session scheduled for (date):
(6) Other (specify): D D Agreed to complete ADR session by (date):
D ADR completed on (date):
CM-110 [Rev. Jul y 1, 2011) Page 3 of 6
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER : LEGALIST, INC., a Delaware corporation CASE NUMBER:
CGC-20-582932
DEFENDANT/RESPONDENT: RUSSEL MYRICK; ROM LEGAL GROUP
11. Insurance
a. CJ Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: D Yes D No
c. D Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
D Bankruptcy CJ Other (specify) :
Status:
13. Related cases, consolidation, and coordination
a. CJ There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
D Additional cases are described in Attachment 13a.
b. D A motion to D consolidate D coordinate will be filed by (name party):
14. Bifurcation
D The party or parties intend to file a motion for an order bifurcating , severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons) :
15. Other motions
D The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. D The party or parties have completed all discovery .
b. D The following discovery will be completed by the date specified (describe all anticipated discovery):
Description
c. D The following discovery issues , including issues regarding the discovery of electronically stored information, are
anticipated (specify) :
CM-110 [Rev. July 1, 2011] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: LEGALIST, INC., a Delaware corporation CASE NUMBER:
CGC-20-582932
DEFENDANT/RESPONDENT: RUSSEL MYRICK; RDM LEGAL GROUP
17. Economic litigation
a. D This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. D This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
~ The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
The parties' agreement contains an arbitration provision . Plaintiff filed a Demand for Arbitration with JAMS on May 15, 2020 .
JAMS has appointed an arbitrator and the parties are proceeding with arbitration.
19. Meet and confer
a. D 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. D After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any): _ _ _ __
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: June /f ,2020
Christopher D. Sullivan
(TYPE OR PRINT NAME) â–º (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) â–º (SIGNATURE OF PARTY OR ATTORNEY)
D Additional signatures are attached.
CM-110(Rev. July 1, 2011] Page 6 of6
CASE MANAGEMENT STATEMENT
1 PROOF OF SERVICE
2 I, Aiemee K. Low, am employed in the City and County of San Francisco, State of
3 California. I am over the age of eighteen years and not a party to the within entitled action. My
4 business is 150 California Street, Suite 2200, San Francisco, CA 94111, and my email address is
5 Aiemee.Low@diamondmccarthy.com. On June 19, 2020, and by agreement of the parties, I
6 served the following document(s) described as:
7 • Case Management Conference Statement
8 on the interested parties in this action by placing a true copy thereof enclosed in sealed
9 envelope(s) addressed as stated below:
10 Defendants
11 Russel Myrick Email: russel@rdmlg.com
7979 Ivanhoe Ave., Suite 200
12 La Jolla CA 92037
13 RDM Legal Group
7979 Ivanhoe Ave., Suite 200
14 La Jolla CA 92037
15
16 BY U.S. MAIL: I am readily familiar with my firm’s practice of collection and processing
correspondence for mailing with the United States Postal Service. Under that practice,
17 correspondence will be deposited with the U.S. Postal Service on this same day with
postage thereon fully prepaid at San Francisco, California, in the ordinary course of
18 business.
19 BY E-MAIL: Additionally, I caused said documents to be prepared in portable document
format (PDF) for e-mailing and served by electronic mail on June 19, 2020 as indicated
20 above. That the document was served electronically and the transmission was reported as
complete and without error.
21
22 I declare under penalty of perjury under the laws of the State of California that the above is
23 true and correct.
24 Executed on June 19, 2020, at San Francisco, California.
25
26 Aiemee Low
27
28
-3-
PROOF OF SERVICE
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Christopher D . Sullivan, SBN 148083 DIAMOND MCCARTHY LLP 150 California Street, Suite 2200, San Francisco, CA 94111 ELECTRONICALLY TELEPHONE NO.: (415) 692-5200 FAX NO. (Optional): (415) 263-9200 FILED Superior Court of California, E-MAIL ADDRESS (Optional): csullivan@diamondmccarthy.com County of San Francisco AHORNEY FOR (Name): Plaintiff, LEGALIST, INC ., a Delaware corporation SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO 06/19/2020 STREET ADDRESS 400 McAllister Street Clerk of the Court MAILING ADDRESS: BY: VANESSA WU Deputy Clerk CITY AND zIP cooE San Francisco, CA 94102 BRANCH NAME: PLAINTIFF/PETITIONER: LEGALIST, INC., a Delaware corporation DEFENDANT/RESPONDENT: RUSSEL MYRICK; ROM LEGAL GROUP CASE MANAGEMENT STATEMENT CASE NUMBER CGC-20-582932 (Check one): 0 UNLIMITED CASE c::::J LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is schedu led as follows: Date: July 15, 2020 Time: 10:30 a.m. Dept.: 610 Div.: Room: Address of court (if different from the address above): [K] Notice of Intent to Appear by Telephone, by (name) : Christopher D. Sullivan INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. 0 This statement is submitted by party (name): LEGALIST, INC. , a Delaware corporation b. D This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): February 13, 2020 b. CJ The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. D All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed . b. D The following parties named in the complaint or cross-complaint (1) D have not been served (specify names and explain why not): (2) CE] have been served but have not appeared and have not been dismissed (specify names): Defendants RUSSEL MYRICK, an individual, and RDM LEGAL Group, a California sole proprietorship (3) D have had a default entered against them (specify names): c. D The following additiona l 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 [K] complaint D cross-complaint (Describe, including causes of action): Plaintiffs Complaint contains a sing le cause of action for breach of contract. 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. July 1, 2011] www. courts.ca.gov CM-110 PLAINTIFF/PETITIONER: LEGALIST, INC., a Delaware corporation CASE NUMBER: CGC-20-582932 DEFENDANT/RESPONDENT: RUSSEL MYRICK; ROM LEGAL GROUP 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) Plaintiffs Complaint alleges Defendants breached a December 6, 2018 written agreement pursuant to which Plaintiff provided litigation funding to Defendants. Defendants failed to pay Plaintiff all amounts due under the parties' agreement. Plaintiff seeks damages of $573,287.96 as of February 12, 2020, plus additional damages of $342.47 per day thereafter, plus prejudgment interest of 4% per annum from December 5, 2019 until paid, plus attorneys' fees and costs . D (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial a. The party or parties request D a jury trial [I] a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. D The trial has been set for (date): b. 00 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): On March 17, 2020 , the Court issued an Order pursuant to CCP section 1281.8(d) staying this action pending arbitration . 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. D days (specify number): b. CJ hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial [RJ by the attorney or party listed in the caption CJ by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: D Additional representation is described in Attachment 8. 9. Preference D This case is entitled to preference (specify code section) : 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel 0 has D has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party CJ has CJ has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). ( 1) CJ 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) CJ 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. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: LEGALIST, INC. , a Delaware corporation CASE NUMBER: CGC-20-582932 DEFENDANT/RESPONDENT: RUSSEL MYRICK; ROM LEGAL GROUP 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): D Mediation session not yet scheduled D Mediation session scheduled for (date): (1) Mediation D D Agreed to complete mediation by (date): D Mediation completed on (date) : D Settlement conference not yet scheduled (2) Settlement D Settlement conference scheduled for(date) : conference D CJ Agreed to complete settlement conference by(date): D Settlement conference completed on (date): D Neutral evaluation not yet scheduled D Neutral evaluation scheduled for (date): (3) Neutral evaluation CJ D Agreed to complete neutral evaluation by (date): D Neutral evaluation completed on (date): D Judicial arbitration not yet scheduled (4) Nonbinding judicial D D Judicial arbitration scheduled for (date) : arbitration D Agreed to complete judicial arbitration by (date): D Judicial arbitration completed on (date): w Private arbitration not yet scheduled (5) Binding private m CJ Private arbitration scheduled for (date) : arbitration D Agreed to complete private arbitration by (date): D Private arbitration completed on (date): D ADR session not yet scheduled D ADR session scheduled for (date): (6) Other (specify): D D Agreed to complete ADR session by (date): D ADR completed on (date): CM-110 [Rev. Jul y 1, 2011) Page 3 of 6 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER : LEGALIST, INC., a Delaware corporation CASE NUMBER: CGC-20-582932 DEFENDANT/RESPONDENT: RUSSEL MYRICK; ROM LEGAL GROUP 11. Insurance a. CJ Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: D Yes D No c. D Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. D Bankruptcy CJ Other (specify) : Status: 13. Related cases, consolidation, and coordination a. CJ There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: D Additional cases are described in Attachment 13a. b. D A motion to D consolidate D coordinate will be filed by (name party): 14. Bifurcation D The party or parties intend to file a motion for an order bifurcating , severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons) : 15. Other motions D The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. D The party or parties have completed all discovery . b. D The following discovery will be completed by the date specified (describe all anticipated discovery): Description c. D The following discovery issues , including issues regarding the discovery of electronically stored information, are anticipated (specify) : CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: LEGALIST, INC., a Delaware corporation CASE NUMBER: CGC-20-582932 DEFENDANT/RESPONDENT: RUSSEL MYRICK; RDM LEGAL GROUP 17. Economic litigation a. D This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. D This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues ~ The party or parties request that the following additional matters be considered or determined at the case management conference (specify): The parties' agreement contains an arbitration provision . Plaintiff filed a Demand for Arbitration with JAMS on May 15, 2020 . JAMS has appointed an arbitrator and the parties are proceeding with arbitration. 19. Meet and confer a. D 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. D After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): _ _ _ __ 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: June /f ,2020 Christopher D. Sullivan (TYPE OR PRINT NAME) ► (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) ► (SIGNATURE OF PARTY OR ATTORNEY) D Additional signatures are attached. CM-110(Rev. July 1, 2011] Page 6 of6 CASE MANAGEMENT STATEMENT 1 PROOF OF SERVICE 2 I, Aiemee K. Low, am employed in the City and County of San Francisco, State of 3 California. I am over the age of eighteen years and not a party to the within entitled action. My 4 business is 150 California Street, Suite 2200, San Francisco, CA 94111, and my email address is 5 Aiemee.Low@diamondmccarthy.com. On June 19, 2020, and by agreement of the parties, I 6 served the following document(s) described as: 7 • Case Management Conference Statement 8 on the interested parties in this action by placing a true copy thereof enclosed in sealed 9 envelope(s) addressed as stated below: 10 Defendants 11 Russel Myrick Email: russel@rdmlg.com 7979 Ivanhoe Ave., Suite 200 12 La Jolla CA 92037 13 RDM Legal Group 7979 Ivanhoe Ave., Suite 200 14 La Jolla CA 92037 15 16 BY U.S. MAIL: I am readily familiar with my firm’s practice of collection and processing correspondence for mailing with the United States Postal Service. Under that practice, 17 correspondence will be deposited with the U.S. Postal Service on this same day with postage thereon fully prepaid at San Francisco, California, in the ordinary course of 18 business. 19 BY E-MAIL: Additionally, I caused said documents to be prepared in portable document format (PDF) for e-mailing and served by electronic mail on June 19, 2020 as indicated 20 above. That the document was served electronically and the transmission was reported as complete and without error. 21 22 I declare under penalty of perjury under the laws of the State of California that the above is 23 true and correct. 24 Executed on June 19, 2020, at San Francisco, California. 25 26 Aiemee Low 27 28 -3- PROOF OF SERVICE