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WOME
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Apr-06-2016 12:26 pm
Case Number: CGC-15-544243
Filing Date: Apr-06-2016 12:25
Filed by: JEAN YUEN
) Image: 05344154
REQUEST FOR CLERK'S/REPORTER'S TRANSCRIPT
HDM FURNITURE INDUSTRIES INC VS. VICTORIA L CARD ET AL
001005344154
Instructions:
Please place this sheet on top of the document to be scanned.APP-003
[ATTORNEY (name, State Bar number, end address): STATE BAR NO.:
ame: VICTORIAL. CARD
FIRM NAME:
STREET ADDRESS: P.O, BOX 502
erry: PETALUMA state; CA ZIP CODE: 94953 F | I E D
TELEPHONE NO: 415-710-9296 FAX NO. (if avaiable}: Some
HAL ADDRESS cravotebe San Francisco County Superior Court
JATTORNEY.FOR (name): IN PRO PER
APR ~.6 201
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO R a
street anoress: 400 MCALLISTER
CLERK OF FHE/COURT
MAILING ADDRESS: BY:
city Ano: zp cope: SAN FRANCISCO, CA 94104 * Deputy Clerk
PLAINTIFF/PETITIONER: VICTORIA L. CARD
DEFENDANT/RESPONDENT: HDM FURNITURE INDUSTRIES, INC
APPELLANT'S NOTICE DESIGNATING RECORD ON APPEAL SUPERIOR COURT CASE NUMBER:
(UNLIMITED CIVIL CASE) OGC-15-544243
RE: Appeal filed on (date): 03/30/2016. ‘COURT OF APPEAL CASE NUMBER (if known):
Notice: Please read form APP-001 before completing this form. This form must be filed in the superior court,
not in the Court of Appeal.
4. RECORD OF THE DOCUMENTS FILED IN THE SUPERIOR COURT .
| elect to use the following method of providing the Court of Appeal with a record of the documents filed in the superior court (check
a, b, ¢, d, ore and fill in any required information):
a. [4] A clerk's transcript under rule 8.122. (You must check (1) or (2) and fill out the clerk’s transcript section on page 2 of this
form.)
(1) [_] | will pay the superior court clerk for this transcript myself when | receive the clerk's estimate of the costs of this -
transcript. | understand that if | do not pay for this transcript, it will not be prepared and provided to the Court of
Appeal,
(2) [] [request that the clerk's transcript be provided to me at no cost because | cannot afford to pay this cost. | have
submitted the following document with this notice designating the record (check (a) or (b)):
(a) [__] An order granting a waiver of court fees and costs under rule 3.50 et seq.; or
(b) [CJ An application for a waiver of court fees and costs under rule 3.50 et seq. (Use Request to Waive Court
Fees (form FW-001} to prepare and file this application.)
b, [_] An appendix under rule 8.124.
c. | 2] The original superior court file under rule 8.128. (NOTE: Local rules in the Court of Appeal, First, Third, Fourth, and Fifth
i Appellate Districts, permit parties to stipulate to use the original superior court file instead of a clerk's transcript; you may
ye select this option if your appeal is in one of these districts and all the parties have stipulated to use the original superior
court file instead of a clerk's transcript in this case. Attach a copy of this stipulation.)
d. [77] An agreed statement under rule 8.134. (You must complete item 2b(2) below and attach fo your agreed statement copies
of all the documents that are required to be included in the clerk's transcript. These documents are listed in rule 8.134(a).)
e. [__] Asettled statement under rule 8.137. (You must complete item 2b(3} below and attach fo your proposed statement on
appeal copies of all the documents that are required to be included in the clerk’s transcript. These documents are listed in
_ rule 8.137(b)(3).)
2, RECORD OF ORAL PROCEEDINGS IN THE SUPERIOR COURT
1 elect to proceed:
a. [32] WITHOUT a record of the oral proceedings in the superior court. | understand that without a record of the oral
proceedings in the superior court, the Court of Appeal will not be able to consider what was said during those proceedings
we in determining whether an error was made in the superior court proceedings.
Page 1 of 4
Saueial Count of Gaon APPELLANT'S NOTICE DESIGNATING RECORD ON APPEAL, .,,_, So. fuse (Gout nossa
APP.003 (Rev. January 1, 2016] (Unlimited Civil Case) . www.courte.ce. govAPP-003
CASE NAME: ‘SUPERIOR COURT CASE NUMBER:
VICTORIA L. CARD VS, HDM FURNITURE INDUSTRIES, INC CGC -15 ~ 544243
wa abs [|] WITH the following record of the oral proceedings in the superior court:
N
net
J Ray {*_] Areporter's transcript under rule 8.130. (You must fill out the reporter's transcript section on page 3 of this form.) |
have (check all that apply):
(@) [1 Deposited the approximate cost of transcribing the designated praceedings with this notice as provided in
tule 8.130(b)(1).
(6) [[} Attached a copy of a Transcript Reimbursement Fund application filed under rule 8.130(c)(1).
(©) [] Attached the reporter's written walver of a deposit for (check either (i) or (ii):
() [) allof the designated proceedings.
(i) (J part of the designated proceedings.
(a) [1] Attached a certified transcript under rule 8 130(b)(3)(C).
(2) [[_} Anagreed statement. (Check and complete either (a) or (b) below.)
(a) [_] [have attached an agreed statement to this notice.
(b) [1] All the parties have agreed in writing (stipulated) to try to agree on a statement. (You must attach a copy of
this stipulation fo this notice.) | understand that, within 40 days after | file the notice of appeal, | must file
either the agreed statement or a notice indicating the parties were unable to agree on a statement and a new
notice designating the record on appeal.
@) [_] Asettied statement under rule 8.137. (You must attach the motion required under rule 8,137(a) to this form.)
3, RECORD OF AN ADMINISTRATIVE PROCEEDING TO BE TRANSMITTED TO THE REVIEWING COURT
[] | request that the clerk transmit to the reviewing court under rule 8,123 the record of the following administrative proceeding
that was admitted into evidence, refused, or lodged in the superior court (give the title and date or dates of the administrative
proceeding):
[ Title of Administrative Proceeding | [ Date or Dates |
4, NOTICE DESIGNATING CLERK'S TRANSCRIPT
{You must complete this section if you checked item 1a. above indicating that you elect to use a clerk's transcript as the record of
the documents filed in the superior court.)
a. Required documents. The clerk will automatically include the following items in the clerk's transcript, but you must provide the
date each document was filed or, if that is not available, the date the document was signed.
[ Document Title and Description 1 [ Date of Filing ]
(1) Notice of appeal 03/30/2016
(2) Notice designating record on appeal (this document) 04/06/2016
(3) Judgment or order appealed from 02/11/2016
(4) Notice of entry of judgment (if any) 02/11/2016
(8) Notice of intention to move for new trial or mation to vacate the judgment, for judgment
notwithstanding the verdict, or for reconsideration of an appealed order (if any) 03/01/2016
(6) Ruling on one or more of the items listed in (6) 02/11/2016.
(7) _ Register of actions or docket (if any)
APP-003 Rev. January 1, 2016] APPELLANT'S NOTICE DESIGNATING RECORD ON APPEAL Page 2.014
(Unlimited Civil Case)APP-003
‘SUPERIOR COURT CASE NUMBER:
CASE NAME:
VICTORIA L. CARD VS. HDM FURNITURE INDUSTRIES INC. CGC - 15 - 544243
4. NOTICE DESIGNATING CLERK'S TRANSCRIPT
b. Additional documents. (If you want any documents from the superior court proceeding in addition to the items listed in 4a.
above to be included in the clerk's transcript, you must identify those documents here.)
[Cee] | request that the clerk include the following decuments from the superior court proceeding in the transcript. (You must
identify each document you want included by its title and provide the date it was filed or, if that is not available, the date
the document was signed.)
LC Document Title and Description }I Date of Filing |
(8) Complain Feb-19-2015
() = Answer Mar-12-2015
(10)
(11)
(12)’
[_] See additional pages.
c. Exhibits to be inctuded in clerk's transcript
[J | request that the clerk include in the transcript the following exhibits that were admitted in evidence, refused, or lodged in
the superior court (for each exhibit, give the exhibit number, such as Plaintiffs #1 or Defendant's A, and a brief description
of the exhibit. Indicate whether or not the court admitted the exhibit into evidence):
[Exhibit Number _][ Description ] [Admitted (Yes/No) |
()
2)
3)
@)
6)
[£_] See additional pages.
5. NOTICE DESIGNATING REPORTER'S TRANSCRIPT
{You must complete this section if you checked item 2b(1) above indicating that you elect to use a reporter's transcript as the record
of the oral proceedings in the superior court. Please remember that you must pay for the cost of preparing the reporter's transcript.)
a, | request that the reporters provide (check one):
(1) [2] My copy of the reporter's transcript In paper format.
(2) [£] My copy of the reporter's transcript in computer-readable format.
(3) [£_] My copy of the reporter's transcript in paper format and a second copy in computer-readable format.
(Code Civ. Proc., § 271; Cal. Rules of Court, rule 8.130(f)(4).)
‘APP-008 [Rev. January , 20°6] APPELLANT'S NOTICE DESIGNATING RECORD ON APPEAL Pago 3 of 4
{Unlimited Civil Case)APP-003
CASE NAME: ‘SUPERIOR COURT CASE NUMBER:
VICTORIA L. CARD VS HDM FURNITURE INDUSTRIES INC. CGC -15 - 544243
5. b. Proceedings
Date:
| request that the following proceedings in the superior court be included in the reporter's transcript. (You must identify each
proceeding you want included by its date, the department in which it took place, a description of the proceedings—for example,
the examination of jurors, motions before trial, the taking of testimony, or the giving of jury instructions—the name of the court
reporter who recorded the proceedings, and whether a certified transcript of the designated proceeding was previously
prepared.)
[Bate [Department [Full/Partial Day| Description [Reporter's Name | Prev. prepared?
a Yes [] No
@) Yes [] No
(3) Yes [] No
A)
6)
©)
Yes [] No
Yes [-] No
Yes [] No
ooooanda
” Yes [] No
The proceedings designated in 5b [——] include [ae] donotinclude all of the testimony in the superior court,
If the designated proceedings DO NOT include all of the testimony, state the points that you intend to raise on appeal (rule
8.130(a)(2) provides that your appeal will be limited to these points unless, on motion, the reviewing court permits otherwise).
I Victoria L. Card in dispute case number CGC-15-544243. I have filed a motion with the court on 01/29/2016 asking
THE COURT PLAINTIFE’S PROPOSED ORDER FOR ENTRY OF JUDGMENT BE SET ASIDE AND VACATED.
Nevertheless, the Court ignored and. granted judgment entered for Plaintiff on 02/11/2016.
Plaintiff's false claims of ownership is fabricated, false and without a shred of evidence. In fact On August 1, 2014, HDM
Furniture Industries, Inc. went out of business as per its Chapter 11 liquidation filing under bankruptcy. Plaintiff's
complaint was filed on FEB 19, 2015 in San Francisco Superior Court. ] am hoping the appeals court will reconsider
setting aside and reversing the Judgment. The plaintiff's attempt is based on plain extortion tactics, fabricated evidence,
excessive and outrageous demands.
Respectfully Submit,
Victoria L. Card
04/06/2016
VICTORIA L. CARD > Vutrur Zw Card
CTYPE OR PRINT NAME) (SIGNATURE OF APPELLANT OR ATTORNEY)
‘APP-008 [Rev, January 1, 2016] APPELLANT'S NOTICE DESIGNATING RECORD ON APPEAL Page 4 of 4
_ (Unlimited Civil Case)PROOF OF SERVICE
The undersigned declares as follows:
Lam a citizen of the United States, over 18 years of age, reside in the County of
San Francisco State of California, and am not a party to the within cause of action. My business
address is 1977 Union Street San Francisco, CA.
On 04/06/2016 I served a copy of the document (s) described as: APPEALS
On all parties in this action as addressed below in the indicated manner:
STEVEN BOOSKA LAW OFFICE Case number: CGC-15- 544243
P.O. BOX 2169
OAKLAND, CA 94621
X (BY MALL) I placed said document(s) in a sealed envelope, with postage thereon fully
prepaid for first class mail, and placed such envelope in the United States mail at Sonoma
County, California..
(X)- (BY FAX) I caused said document to be faxed to the addressee(s) and then placed in the
United States Mail.
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct and that this declaration was executed on 04/06/2016
San Francisco California.
Michael Mott Signature
[Pleading Title] - 1
Preview
WOME SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Apr-06-2016 12:26 pm Case Number: CGC-15-544243 Filing Date: Apr-06-2016 12:25 Filed by: JEAN YUEN ) Image: 05344154 REQUEST FOR CLERK'S/REPORTER'S TRANSCRIPT HDM FURNITURE INDUSTRIES INC VS. VICTORIA L CARD ET AL 001005344154 Instructions: Please place this sheet on top of the document to be scanned.APP-003 [ATTORNEY (name, State Bar number, end address): STATE BAR NO.: ame: VICTORIAL. CARD FIRM NAME: STREET ADDRESS: P.O, BOX 502 erry: PETALUMA state; CA ZIP CODE: 94953 F | I E D TELEPHONE NO: 415-710-9296 FAX NO. (if avaiable}: Some HAL ADDRESS cravotebe San Francisco County Superior Court JATTORNEY.FOR (name): IN PRO PER APR ~.6 201 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO R a street anoress: 400 MCALLISTER CLERK OF FHE/COURT MAILING ADDRESS: BY: city Ano: zp cope: SAN FRANCISCO, CA 94104 * Deputy Clerk PLAINTIFF/PETITIONER: VICTORIA L. CARD DEFENDANT/RESPONDENT: HDM FURNITURE INDUSTRIES, INC APPELLANT'S NOTICE DESIGNATING RECORD ON APPEAL SUPERIOR COURT CASE NUMBER: (UNLIMITED CIVIL CASE) OGC-15-544243 RE: Appeal filed on (date): 03/30/2016. ‘COURT OF APPEAL CASE NUMBER (if known): Notice: Please read form APP-001 before completing this form. This form must be filed in the superior court, not in the Court of Appeal. 4. RECORD OF THE DOCUMENTS FILED IN THE SUPERIOR COURT . | elect to use the following method of providing the Court of Appeal with a record of the documents filed in the superior court (check a, b, ¢, d, ore and fill in any required information): a. [4] A clerk's transcript under rule 8.122. (You must check (1) or (2) and fill out the clerk’s transcript section on page 2 of this form.) (1) [_] | will pay the superior court clerk for this transcript myself when | receive the clerk's estimate of the costs of this - transcript. | understand that if | do not pay for this transcript, it will not be prepared and provided to the Court of Appeal, (2) [] [request that the clerk's transcript be provided to me at no cost because | cannot afford to pay this cost. | have submitted the following document with this notice designating the record (check (a) or (b)): (a) [__] An order granting a waiver of court fees and costs under rule 3.50 et seq.; or (b) [CJ An application for a waiver of court fees and costs under rule 3.50 et seq. (Use Request to Waive Court Fees (form FW-001} to prepare and file this application.) b, [_] An appendix under rule 8.124. c. | 2] The original superior court file under rule 8.128. (NOTE: Local rules in the Court of Appeal, First, Third, Fourth, and Fifth i Appellate Districts, permit parties to stipulate to use the original superior court file instead of a clerk's transcript; you may ye select this option if your appeal is in one of these districts and all the parties have stipulated to use the original superior court file instead of a clerk's transcript in this case. Attach a copy of this stipulation.) d. [77] An agreed statement under rule 8.134. (You must complete item 2b(2) below and attach fo your agreed statement copies of all the documents that are required to be included in the clerk's transcript. These documents are listed in rule 8.134(a).) e. [__] Asettled statement under rule 8.137. (You must complete item 2b(3} below and attach fo your proposed statement on appeal copies of all the documents that are required to be included in the clerk’s transcript. These documents are listed in _ rule 8.137(b)(3).) 2, RECORD OF ORAL PROCEEDINGS IN THE SUPERIOR COURT 1 elect to proceed: a. [32] WITHOUT a record of the oral proceedings in the superior court. | understand that without a record of the oral proceedings in the superior court, the Court of Appeal will not be able to consider what was said during those proceedings we in determining whether an error was made in the superior court proceedings. Page 1 of 4 Saueial Count of Gaon APPELLANT'S NOTICE DESIGNATING RECORD ON APPEAL, .,,_, So. fuse (Gout nossa APP.003 (Rev. January 1, 2016] (Unlimited Civil Case) . www.courte.ce. govAPP-003 CASE NAME: ‘SUPERIOR COURT CASE NUMBER: VICTORIA L. CARD VS, HDM FURNITURE INDUSTRIES, INC CGC -15 ~ 544243 wa abs [|] WITH the following record of the oral proceedings in the superior court: N net J Ray {*_] Areporter's transcript under rule 8.130. (You must fill out the reporter's transcript section on page 3 of this form.) | have (check all that apply): (@) [1 Deposited the approximate cost of transcribing the designated praceedings with this notice as provided in tule 8.130(b)(1). (6) [[} Attached a copy of a Transcript Reimbursement Fund application filed under rule 8.130(c)(1). (©) [] Attached the reporter's written walver of a deposit for (check either (i) or (ii): () [) allof the designated proceedings. (i) (J part of the designated proceedings. (a) [1] Attached a certified transcript under rule 8 130(b)(3)(C). (2) [[_} Anagreed statement. (Check and complete either (a) or (b) below.) (a) [_] [have attached an agreed statement to this notice. (b) [1] All the parties have agreed in writing (stipulated) to try to agree on a statement. (You must attach a copy of this stipulation fo this notice.) | understand that, within 40 days after | file the notice of appeal, | must file either the agreed statement or a notice indicating the parties were unable to agree on a statement and a new notice designating the record on appeal. @) [_] Asettied statement under rule 8.137. (You must attach the motion required under rule 8,137(a) to this form.) 3, RECORD OF AN ADMINISTRATIVE PROCEEDING TO BE TRANSMITTED TO THE REVIEWING COURT [] | request that the clerk transmit to the reviewing court under rule 8,123 the record of the following administrative proceeding that was admitted into evidence, refused, or lodged in the superior court (give the title and date or dates of the administrative proceeding): [ Title of Administrative Proceeding | [ Date or Dates | 4, NOTICE DESIGNATING CLERK'S TRANSCRIPT {You must complete this section if you checked item 1a. above indicating that you elect to use a clerk's transcript as the record of the documents filed in the superior court.) a. Required documents. The clerk will automatically include the following items in the clerk's transcript, but you must provide the date each document was filed or, if that is not available, the date the document was signed. [ Document Title and Description 1 [ Date of Filing ] (1) Notice of appeal 03/30/2016 (2) Notice designating record on appeal (this document) 04/06/2016 (3) Judgment or order appealed from 02/11/2016 (4) Notice of entry of judgment (if any) 02/11/2016 (8) Notice of intention to move for new trial or mation to vacate the judgment, for judgment notwithstanding the verdict, or for reconsideration of an appealed order (if any) 03/01/2016 (6) Ruling on one or more of the items listed in (6) 02/11/2016. (7) _ Register of actions or docket (if any) APP-003 Rev. January 1, 2016] APPELLANT'S NOTICE DESIGNATING RECORD ON APPEAL Page 2.014 (Unlimited Civil Case)APP-003 ‘SUPERIOR COURT CASE NUMBER: CASE NAME: VICTORIA L. CARD VS. HDM FURNITURE INDUSTRIES INC. CGC - 15 - 544243 4. NOTICE DESIGNATING CLERK'S TRANSCRIPT b. Additional documents. (If you want any documents from the superior court proceeding in addition to the items listed in 4a. above to be included in the clerk's transcript, you must identify those documents here.) [Cee] | request that the clerk include the following decuments from the superior court proceeding in the transcript. (You must identify each document you want included by its title and provide the date it was filed or, if that is not available, the date the document was signed.) LC Document Title and Description }I Date of Filing | (8) Complain Feb-19-2015 () = Answer Mar-12-2015 (10) (11) (12)’ [_] See additional pages. c. Exhibits to be inctuded in clerk's transcript [J | request that the clerk include in the transcript the following exhibits that were admitted in evidence, refused, or lodged in the superior court (for each exhibit, give the exhibit number, such as Plaintiffs #1 or Defendant's A, and a brief description of the exhibit. Indicate whether or not the court admitted the exhibit into evidence): [Exhibit Number _][ Description ] [Admitted (Yes/No) | () 2) 3) @) 6) [£_] See additional pages. 5. NOTICE DESIGNATING REPORTER'S TRANSCRIPT {You must complete this section if you checked item 2b(1) above indicating that you elect to use a reporter's transcript as the record of the oral proceedings in the superior court. Please remember that you must pay for the cost of preparing the reporter's transcript.) a, | request that the reporters provide (check one): (1) [2] My copy of the reporter's transcript In paper format. (2) [£] My copy of the reporter's transcript in computer-readable format. (3) [£_] My copy of the reporter's transcript in paper format and a second copy in computer-readable format. (Code Civ. Proc., § 271; Cal. Rules of Court, rule 8.130(f)(4).) ‘APP-008 [Rev. January , 20°6] APPELLANT'S NOTICE DESIGNATING RECORD ON APPEAL Pago 3 of 4 {Unlimited Civil Case)APP-003 CASE NAME: ‘SUPERIOR COURT CASE NUMBER: VICTORIA L. CARD VS HDM FURNITURE INDUSTRIES INC. CGC -15 - 544243 5. b. Proceedings Date: | request that the following proceedings in the superior court be included in the reporter's transcript. (You must identify each proceeding you want included by its date, the department in which it took place, a description of the proceedings—for example, the examination of jurors, motions before trial, the taking of testimony, or the giving of jury instructions—the name of the court reporter who recorded the proceedings, and whether a certified transcript of the designated proceeding was previously prepared.) [Bate [Department [Full/Partial Day| Description [Reporter's Name | Prev. prepared? a Yes [] No @) Yes [] No (3) Yes [] No A) 6) ©) Yes [] No Yes [-] No Yes [] No ooooanda ” Yes [] No The proceedings designated in 5b [——] include [ae] donotinclude all of the testimony in the superior court, If the designated proceedings DO NOT include all of the testimony, state the points that you intend to raise on appeal (rule 8.130(a)(2) provides that your appeal will be limited to these points unless, on motion, the reviewing court permits otherwise). I Victoria L. Card in dispute case number CGC-15-544243. I have filed a motion with the court on 01/29/2016 asking THE COURT PLAINTIFE’S PROPOSED ORDER FOR ENTRY OF JUDGMENT BE SET ASIDE AND VACATED. Nevertheless, the Court ignored and. granted judgment entered for Plaintiff on 02/11/2016. Plaintiff's false claims of ownership is fabricated, false and without a shred of evidence. In fact On August 1, 2014, HDM Furniture Industries, Inc. went out of business as per its Chapter 11 liquidation filing under bankruptcy. Plaintiff's complaint was filed on FEB 19, 2015 in San Francisco Superior Court. ] am hoping the appeals court will reconsider setting aside and reversing the Judgment. The plaintiff's attempt is based on plain extortion tactics, fabricated evidence, excessive and outrageous demands. Respectfully Submit, Victoria L. Card 04/06/2016 VICTORIA L. CARD > Vutrur Zw Card CTYPE OR PRINT NAME) (SIGNATURE OF APPELLANT OR ATTORNEY) ‘APP-008 [Rev, January 1, 2016] APPELLANT'S NOTICE DESIGNATING RECORD ON APPEAL Page 4 of 4 _ (Unlimited Civil Case)PROOF OF SERVICE The undersigned declares as follows: Lam a citizen of the United States, over 18 years of age, reside in the County of San Francisco State of California, and am not a party to the within cause of action. My business address is 1977 Union Street San Francisco, CA. On 04/06/2016 I served a copy of the document (s) described as: APPEALS On all parties in this action as addressed below in the indicated manner: STEVEN BOOSKA LAW OFFICE Case number: CGC-15- 544243 P.O. BOX 2169 OAKLAND, CA 94621 X (BY MALL) I placed said document(s) in a sealed envelope, with postage thereon fully prepaid for first class mail, and placed such envelope in the United States mail at Sonoma County, California.. (X)- (BY FAX) I caused said document to be faxed to the addressee(s) and then placed in the United States Mail. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed on 04/06/2016 San Francisco California. Michael Mott Signature [Pleading Title] - 1