Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
MARC G. HYNES, ESQ. #049048
ATKINSON-FARASYN, LLP
5050 EL CAMINO REAL, SUITE 205
LOS ALTOS, CA 94022
TELEPHONE NO; (650) 967-6941 FAX NO.(Optional): (650) 967-1395,
E-MAIL ADDRESS (Optional)
ATTORNEY FOR (Name): Plaintiff
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA
STREET ADDRESS: 191 NORTH FIRST STREET
MAILING ADDRESS: 191 NORTH FIRST STREET
CITY AND ZIP CODE: SAN JOSE, CA 95113
BRANCH NAME:
PLAINTIFF/PETITIONER: REDWOOD VILLA
DEFENDANT/RESPONDENT: CITY OF MOUNTAIN VIEW, MOUNTAIN VIEW
RENTAL HOUSIG COMMITTEE, et al.
CASE MANAGEMENT STATEMENT ‘CASE NUMBER:
(Check one): @) UNLIMITED CASE (J Limitep CASE 18CV322991
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: December 17, 2019 Time: 10 a.m, Dept.: 8 Div.: Room:
Address of court (if different from the address above):
WL] Notice of Intent to Appear by Telephone, by (name): MARC G. HYNES
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a (W) This statement is submitted by party (name): REDWOOD VILLA, INC.
b. (C) This statement is submitted jointly by parties (names):
Complaint and cross-complaint (fo be answered by plaintiffs and cross-complainants only)
a The complaint was filed on (date): February 7, 2018
b. C1 The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
a. WY) All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. CD The following parties named in the complaint or cross-complaint
(1) (Cy have not been served (specify names and explain why not):
(2) (1 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. (CC) The following additional parties may be added (specify names, nature of involvement in case, and the date by which
they may be served):
Description of case
a Type of case in W) complaint CQ cross-complaint (Describe, including causes of action):
Page 1 of 5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal, Rules of Court,
Judicial Council of California CEB | Essential rules 3.720-3.730
(CM-110 (Rev. July 1, 2011] www.courts.ca.gov
cab.com | =|Forms"
Redwood Villa v. City Mtn View
CM-110
PLAINTIFF/PETITIONER:REDWOOD VILLA CASE NUMBER:
18CV322991
DEFENDANT/RESPONDENT: CITY OF MOUNTAIN VIEW, MOUNTAIN VIEW
HOUSING COMMITTEE and DOES 1 through 20, inclusive
4 b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff seeks a declaration from the court that defendant City of Mountain View's Rent Control Ordinance, Article
XVII to the Charter of the City of Mountain View imposing renta and eviction control on certain owners of real
property within the City, does not apply to Plaintiff's business located at 1981 Montecito Avenue in the City of
Mountain View - an 83-unit retirement community providing services for the benefit of senior citizens.
() (if more space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request C) ajury trial WZ) a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a CC) 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):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a W) days (specify number): three (3)
b () hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial W1 by the attorney or party listed in the caption C) by the following:
a Attorney:
b. Firm:
c. Address:
d Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
Q Additional representation is described in Attachment 8.
Preference
CJ 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 Whas (A 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 [2] has (1 has not reviewed the ADR information package identified in rule 3.221
Referral to judicial arbitration or civil action mediation (if available).
(1) (2) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) C2) 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) C) 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. July1, 2014] CASE MANAGEMENT STATEMENT Page 2 of 5
CEB || [elForms:
eb.com
Essential
Redwood Villa v. City Mtn View
CM-110
PLAINTIFF/PETITIONER:REDWOOD VILLA CASE NUMBER:
18CV322991
DEFENDANT/RESPONDENT: CITY OF MOUNTAIN VIEW, MOUNTAIN VIEW
HOUSING COMMITTEE and DOES 1 through 20, inclusive
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 ail 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):
W) Mediation session not yet scheduled
(CC) Mediation session scheduled for (date):
(1) Mediation
CC) Agreed to complete mediation by (date):
() Mediation completed on (date):
W) Settlement conference not yet scheduled
(2) Settlement CD Settlement conference scheduled for (date):
conference (Agreed to complete settlement conference by (date):
(1 Settlement conference completed on (date):
(C) Neutral evaluation not yet scheduled
(C) Neutral evaluation scheduled for (date):
(3) Neutral evaluation
() Agreed to complete neutral evaluation by (date):
(J Neutral evaluation completed on (date):
CC) Judicial arbitration not yet scheduled
(4) Nonbinding judicial (2) Judicial arbitration scheduled for (date):
arbitration (C) Agreed to complete judicial arbitration by (date):
(©) Judicial arbitration compteted on (date):
C0 Private arbitration not yet scheduled
(5) Binding private C) Private arbitration scheduled for (date):
arbitration
() Agreed to complete private arbitration by (date):
CC) Private arbitration completed on (date):
(1 ADR session not yet scheduled
(6) Other (specify): (2) ADR session scheduled for (date):
(CD Agreed to complete ADR session by (date):
(2 ADR completed on (date):
(CM-110 (Rev. July 1, 2014] CASE MANAGEMENT STATEMENT Page 3 of 5
Essential
cebaom | {2)Forms:
Redwood Villa v. City Mtn View
CM-110
PLAINTIFF/PETITIONER: REDWOOD VILLA CASE NUMBER:
18CV322991
DEFENDANT/RESPONDENT: CITY OF MOUNTAIN VIEW, MOUNTAIN VIEW RI
HOUSING COMMITTEE and DOES 1 through 20, inclusive
11. Insurance
a (J insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: OC) Yes C) No
c. 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.
CQ Bankruptcy CD Other (specify):
Status:
13. Related cases, consolidation, and coordination
a (1 There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
(2 Additional cases are described in Attachment 13a.
b. (2) Amotion to (2) consolidate C) coordinate will be filed by (name party):
14, Bifurcation
() The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
(2) The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues).
16. Discovery
a (J The party or parties have completed all discovery.
b. WJ The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiff Plaintiff may propound discovery in the future,
c. (Cd The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
(CM-110 (Rev, July
1, 2011] CASE MANAGEMENT STATEMENT Page
4 of 5
CEB’ Essential
ceb.com | jaForms Redwood Villa v. City Mtn View
CM-110
PLAINTIFF/PETITIONER: REDWOOD VILLA CASE NUMBER:
18CV322991
DEFENDANT/RESPONDENT: CITY OF MOUNTAIN VIEW, MOUNTAIN VIEW RI
HOUSING COMMITTEE and DOES 1 through 20, inclusive
17. Economic litigation
a. C2 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. (2) 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
(J 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 W) 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):
| am completely familiar with this case and will be fully prepared to discuss the status of di overy 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 req
Date: November 19, 2019.
MARC G. HYNES.
(TYPE OR PRINT NAME) fo OF PARTY OR ATTORNEY)
oD (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME)
oO (dgitfonal signatures are attached.
‘OM-+4110
(Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page
5 of 5
CEB
ceb.com | Essential
{e\Forms"
Redwood Villa v. City Mtn View
PROOF OF SERVICE BY MAIL
(C.C.P. Section 1013a, 2015.5)
Case Name REDWOOD VILLA v. CITY OF MOUNTAIN VIEW
Case No. 18CV322991
I am employed in the County of Santa Clara, State of California; I am over the age
of eighteen years and not a party to the within-entitled action. My business address is 5050 El
Camino Real, Suite 205, Los Altos, California 94022. I am readily familiar with the business’
practice for collection and processing of correspondence for mailing with the United States
10
Postal Service. On November 19, 2019, I served the within CASE MANAGEMENT
11
STATEMENT WITH NOTICE OF INTENT TO APPEAR BY TELEPHONE with first
12
class postage thereon fully prepaid, and placed for collection and mailing on the above-
13
14 referenced date at my place of business following ordinary business practices, and said
15 correspondence will be deposited with the United States Postal Service on the above-referenced
16 date in the ordinary course of business, addressed as follows:
17
18
CELIA W. LEE
19
JUSTIN D. BIGELOW
20 GOLDFARB & LIPMAN, LLP
21 1300 CLAY STREET, ELEVENTH FLOOR
OAKLAND, CA 94612
22
23
24 I declare under penalty of perjury under the laws of the State of California that the
25 foregoing is true and correct and that this was executed on November 19, 2019, at Los Altos,
26 California.
27
28 I Anu X. Ayo
29 Nancy L. Sugimoto
30
31
32
33
34
35
36
PROOF OF SERVICE BY MAIL
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY MARC G. HYNES, ESQ. #049048 ATKINSON-FARASYN, LLP 5050 EL CAMINO REAL, SUITE 205 LOS ALTOS, CA 94022 TELEPHONE NO; (650) 967-6941 FAX NO.(Optional): (650) 967-1395, E-MAIL ADDRESS (Optional) ATTORNEY FOR (Name): Plaintiff SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA STREET ADDRESS: 191 NORTH FIRST STREET MAILING ADDRESS: 191 NORTH FIRST STREET CITY AND ZIP CODE: SAN JOSE, CA 95113 BRANCH NAME: PLAINTIFF/PETITIONER: REDWOOD VILLA DEFENDANT/RESPONDENT: CITY OF MOUNTAIN VIEW, MOUNTAIN VIEW RENTAL HOUSIG COMMITTEE, et al. CASE MANAGEMENT STATEMENT ‘CASE NUMBER: (Check one): @) UNLIMITED CASE (J Limitep CASE 18CV322991 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: December 17, 2019 Time: 10 a.m, Dept.: 8 Div.: Room: Address of court (if different from the address above): WL] Notice of Intent to Appear by Telephone, by (name): MARC G. HYNES INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a (W) This statement is submitted by party (name): REDWOOD VILLA, INC. b. (C) This statement is submitted jointly by parties (names): Complaint and cross-complaint (fo be answered by plaintiffs and cross-complainants only) a The complaint was filed on (date): February 7, 2018 b. C1 The cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) a. WY) All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. CD The following parties named in the complaint or cross-complaint (1) (Cy have not been served (specify names and explain why not): (2) (1 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. (CC) The following additional parties may be added (specify names, nature of involvement in case, and the date by which they may be served): Description of case a Type of case in W) complaint CQ cross-complaint (Describe, including causes of action): Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal, Rules of Court, Judicial Council of California CEB | Essential rules 3.720-3.730 (CM-110 (Rev. July 1, 2011] www.courts.ca.gov cab.com | =|Forms" Redwood Villa v. City Mtn View CM-110 PLAINTIFF/PETITIONER:REDWOOD VILLA CASE NUMBER: 18CV322991 DEFENDANT/RESPONDENT: CITY OF MOUNTAIN VIEW, MOUNTAIN VIEW HOUSING COMMITTEE and DOES 1 through 20, inclusive 4 b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff seeks a declaration from the court that defendant City of Mountain View's Rent Control Ordinance, Article XVII to the Charter of the City of Mountain View imposing renta and eviction control on certain owners of real property within the City, does not apply to Plaintiff's business located at 1981 Montecito Avenue in the City of Mountain View - an 83-unit retirement community providing services for the benefit of senior citizens. () (if more space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request C) ajury trial WZ) a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a CC) 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): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Estimated length of trial The party or parties estimate that the trial will take (check one): a W) days (specify number): three (3) b () hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial W1 by the attorney or party listed in the caption C) by the following: a Attorney: b. Firm: c. Address: d Telephone number: f. Fax number: e. E-mail address: g. Party represented: Q Additional representation is described in Attachment 8. Preference CJ 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 Whas (A 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 [2] has (1 has not reviewed the ADR information package identified in rule 3.221 Referral to judicial arbitration or civil action mediation (if available). (1) (2) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) C2) 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) C) 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. July1, 2014] CASE MANAGEMENT STATEMENT Page 2 of 5 CEB || [elForms: eb.com Essential Redwood Villa v. City Mtn View CM-110 PLAINTIFF/PETITIONER:REDWOOD VILLA CASE NUMBER: 18CV322991 DEFENDANT/RESPONDENT: CITY OF MOUNTAIN VIEW, MOUNTAIN VIEW HOUSING COMMITTEE and DOES 1 through 20, inclusive 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 ail 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): W) Mediation session not yet scheduled (CC) Mediation session scheduled for (date): (1) Mediation CC) Agreed to complete mediation by (date): () Mediation completed on (date): W) Settlement conference not yet scheduled (2) Settlement CD Settlement conference scheduled for (date): conference (Agreed to complete settlement conference by (date): (1 Settlement conference completed on (date): (C) Neutral evaluation not yet scheduled (C) Neutral evaluation scheduled for (date): (3) Neutral evaluation () Agreed to complete neutral evaluation by (date): (J Neutral evaluation completed on (date): CC) Judicial arbitration not yet scheduled (4) Nonbinding judicial (2) Judicial arbitration scheduled for (date): arbitration (C) Agreed to complete judicial arbitration by (date): (©) Judicial arbitration compteted on (date): C0 Private arbitration not yet scheduled (5) Binding private C) Private arbitration scheduled for (date): arbitration () Agreed to complete private arbitration by (date): CC) Private arbitration completed on (date): (1 ADR session not yet scheduled (6) Other (specify): (2) ADR session scheduled for (date): (CD Agreed to complete ADR session by (date): (2 ADR completed on (date): (CM-110 (Rev. July 1, 2014] CASE MANAGEMENT STATEMENT Page 3 of 5 Essential cebaom | {2)Forms: Redwood Villa v. City Mtn View CM-110 PLAINTIFF/PETITIONER: REDWOOD VILLA CASE NUMBER: 18CV322991 DEFENDANT/RESPONDENT: CITY OF MOUNTAIN VIEW, MOUNTAIN VIEW RI HOUSING COMMITTEE and DOES 1 through 20, inclusive 11. Insurance a (J insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: OC) Yes C) No c. 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. CQ Bankruptcy CD Other (specify): Status: 13. Related cases, consolidation, and coordination a (1 There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: (2 Additional cases are described in Attachment 13a. b. (2) Amotion to (2) consolidate C) coordinate will be filed by (name party): 14, Bifurcation () The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions (2) The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues). 16. Discovery a (J The party or parties have completed all discovery. b. WJ The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Plaintiff Plaintiff may propound discovery in the future, c. (Cd The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): (CM-110 (Rev, July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5 CEB’ Essential ceb.com | jaForms Redwood Villa v. City Mtn View CM-110 PLAINTIFF/PETITIONER: REDWOOD VILLA CASE NUMBER: 18CV322991 DEFENDANT/RESPONDENT: CITY OF MOUNTAIN VIEW, MOUNTAIN VIEW RI HOUSING COMMITTEE and DOES 1 through 20, inclusive 17. Economic litigation a. C2 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. (2) 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 (J 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 W) 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): | am completely familiar with this case and will be fully prepared to discuss the status of di overy 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 req Date: November 19, 2019. MARC G. HYNES. (TYPE OR PRINT NAME) fo OF PARTY OR ATTORNEY) oD (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) oO (dgitfonal signatures are attached. ‘OM-+4110 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5 CEB ceb.com | Essential {e\Forms" Redwood Villa v. City Mtn View PROOF OF SERVICE BY MAIL (C.C.P. Section 1013a, 2015.5) Case Name REDWOOD VILLA v. CITY OF MOUNTAIN VIEW Case No. 18CV322991 I am employed in the County of Santa Clara, State of California; I am over the age of eighteen years and not a party to the within-entitled action. My business address is 5050 El Camino Real, Suite 205, Los Altos, California 94022. I am readily familiar with the business’ practice for collection and processing of correspondence for mailing with the United States 10 Postal Service. On November 19, 2019, I served the within CASE MANAGEMENT 11 STATEMENT WITH NOTICE OF INTENT TO APPEAR BY TELEPHONE with first 12 class postage thereon fully prepaid, and placed for collection and mailing on the above- 13 14 referenced date at my place of business following ordinary business practices, and said 15 correspondence will be deposited with the United States Postal Service on the above-referenced 16 date in the ordinary course of business, addressed as follows: 17 18 CELIA W. LEE 19 JUSTIN D. BIGELOW 20 GOLDFARB & LIPMAN, LLP 21 1300 CLAY STREET, ELEVENTH FLOOR OAKLAND, CA 94612 22 23 24 I declare under penalty of perjury under the laws of the State of California that the 25 foregoing is true and correct and that this was executed on November 19, 2019, at Los Altos, 26 California. 27 28 I Anu X. Ayo 29 Nancy L. Sugimoto 30 31 32 33 34 35 36 PROOF OF SERVICE BY MAIL