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170V321207
Santa Clara — Civil
SMetritSystem
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
William B. Look, Jr. Attorney at Law
P O Box 1381 Electronically Filed
Monterey CA 93942 by Superior Court of CA,
#066631
(County of Santa Clara,
TELEPHONE NO.: 8316599662 FAX NO. (Optiona)) lon 2/25/2020 3:28 PM
E-MAIL ADDRESS (Optional): |9Ok_mtr@yahoo.com Reviewed By: System System
ATTORNEY FOR (Name): Plaintiffs. Case #17CV321207
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Clara
Envelope: 4080955
sTREET ADRESS: 191 N. First St.
MAILING ADDRESS:
city ano zip cove: San Jose CA 951113
BRANCH NAME: Downtown
PLAINTIFF/PETITIONER: Jawdat Lahlouh, Nisreen Lahlouh
DEFENDANT/RESPONDENT: Ditech Financial, LLC et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): (71) UNLIMITED CASE [1] uimitep cAsE
(Amount demanded (Amount demanded is $25,000 17CV321207
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date:
March 12, 2020 Time: 10:00 am Dept.: 24 Div.: Room:
Address of court (if different from the address above): Old Courthouse
[] Notice of Intent to Appear by Telephone, by (name):
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. L¥] This statement is submitted by party (name): Plaintiffs
b. [_] This statement is submitted jointly by parties (names):
Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a The complaint was filed on (date): 12/28/2017
by 228) he cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
ax] 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
c. (1) LJ have not been served (specify names and explain why not):
(2) CI) have been served but have not appeared and have not been dismissed (specify names):
(3) Cc] have had a default entered against them (specify names):
The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served): NewRez LLC (CCP 473(a) amd. required)
4 Description of case
a Type of case in [¥] complaint Cc) cross-complaint (Describe, including causes of action):
Breach of settlement contract derived from prior action 113CV251320 in this county and subsequent unfair debt
collection activity by lenders’ collection agent (Ditech).
Page 1 of 5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court,
Judicial Council of California rules 3.720-3.730
(CM-110 [Rev. July 1, 2011] www.courts.ca.gov
www.accesslaw.com
CM-110
PLAINTIFF/PETITIONER: Jawdat Lahlouh, Nisreen Lahlouh
CASE NUMBER,
17CV321207
DEFENDANT/RESPONDENT: Ditech Financial, LLC et al.
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.
Gist of case is BofA dropped the ball three times in not timely recording a ‘deed in lieu’ after settling a Nevada wrongful
foreclosure case dating to 2007 and plaintiffs were prejudiced. This is the third lawsuit: original 2012 Nevada; 2013 this
county; and now third to enforce (JAMS) settlement of 2013 case 13CV251320, plus damages for unfair collection
activity post-settlement. In the interim since 2014, because BofA didn't record the ‘deed in lieu' promptly even after the
settlement in 13CV251320, the property was foreclosed in Nevada against plaintiffs over defaulted HOA assessments.
femal (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 LV) a jury trial Coa nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a [] The trial has been set for (date):
b. LV] 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. WwW days (specify number): 3
b. [1 hours (short causes) (specify):
Trial representation (fo be answered for each party)
The party or parties will be represented at trial [LV] by the attorney or party listed in the caption [] by the following:
a Attorney:
b. Firm:
c. Address:
d Telephone number: f. Fax number:
E-mail address:
mo 9 Party represented:
Additional representation is described in Attachment 8.
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 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel [¥] has [_] hasnot 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 [J] has L_] has not reviewed the ADR information package identified in rule 3.221
b. Referral to judicial arbitration or civil action mediation (if available).
(4) C9 This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) =a] 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 Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
(CM-170 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page2 of5
CM-110
PLAINTIFF/PETITIONER: Jawdat Lahlouh, Nisreen Lahlouh CASE NUMBER.
17CV321207
DEFENDANT/RESPONDENT: Ditech Financial, LLC et al.
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):
[eal Mediation session not yet scheduled
Ww Co Mediation session scheduled for (date):
(1) Mediation
Co 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. July 1, 2011] Page
3 of 5
CASE MANAGEMENT STATEMENT
CM-110
CASE NUMBER:
a PLAINTIFF/PETITIONER: Jawdat Lahlouh, Nisreen Lahlouh
170V321207
DEFENDANT/RESPONDENT: Ditech Financial, LLC et al.
11. Insurance
a [J insurance carrier, if any, for party filing this statement (name):
b, Reservation of rights: [-] Yes [E=3] 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.
[V7] Bankruptcy [__] Other (specify):
Status: In re Ditech Holding Corp., USB SD NY, 19-10412 JLG, pending motion for relief from stay.
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. [_] Amotion to [) consolidate [J coordinate will be filed by (name party):
14. Bifurcation
[V7] 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):
Bifurcation may be required to proceed if bankruptcy stay becomes permanent as to Ditech.
15. Other motions
[J The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
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
c. LZ] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Stayed pending resolution of bankruptcy stay issues.
CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5
CM-110
PLAINTIFF/PETITIONER: Jawdat Lahlouh, Nisreen Lahlouh CASE NUMBER:
= 17CV321207
DEFENDANT/RESPONDENT: Ditech Financial, LLC et al.
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. L__] 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
[7] The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
Motion for Relief from Stay was mooted by plan of reorganization; account was acquired by NewRez LLC, who is
successor in interest to Ditech, via Ch. 11 proceeding. Email is being returned by Severson firm; attempts to
prompt response unavailing as of date of filing; does not appear former attorney still with firm.
19. Meet and confer
a. L¥] 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):
Were meet and confer letters with Ditech's former counsel. No response from Bank of America's counsel.
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
No agreements were reached.
20. Total number of pages attached (if any):
lam 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.
tty
Date: February 25, 2020
William B. Look, Jr. »
(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. July1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5
PROOF OF SERVICE BY ELECTRONIC DELIVERY
I declare that I am employed in the County of Monterey, California. I am over the age of
eighteen years and not a party to the action herein. My business address is P. O. Box 1381, Monterey,
California 93942.
On Feb 25, 2020, I caused the above pleading entitled, Case Management
Statement on counsel for DEFENDANTS by automated electronic email service via a certified digital
filing service provider, to wit, Green Legal File, to the electronic email address of:
Will Aspinwall Esq.
Severson & Werson
One Embarcadero Center, Suite 2600
San Francisco, CA 94111
Main: (415) 398-3344
Direct: (415) 677-5683
waa@severson.com
Jonathan C. Cahill, Esq.
Wolf& Wyman
980 9th St., #2350
Sacramento CA 95814
(916 912-4600
jmbryan@wolfwyman.com
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct. Executed on Feb. 25, 2020, at Monterey, California.
a “a Y
Wi BE hook, dia.
Preview
170V321207 Santa Clara — Civil SMetritSystem ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY William B. Look, Jr. Attorney at Law P O Box 1381 Electronically Filed Monterey CA 93942 by Superior Court of CA, #066631 (County of Santa Clara, TELEPHONE NO.: 8316599662 FAX NO. (Optiona)) lon 2/25/2020 3:28 PM E-MAIL ADDRESS (Optional): |9Ok_mtr@yahoo.com Reviewed By: System System ATTORNEY FOR (Name): Plaintiffs. Case #17CV321207 SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Clara Envelope: 4080955 sTREET ADRESS: 191 N. First St. MAILING ADDRESS: city ano zip cove: San Jose CA 951113 BRANCH NAME: Downtown PLAINTIFF/PETITIONER: Jawdat Lahlouh, Nisreen Lahlouh DEFENDANT/RESPONDENT: Ditech Financial, LLC et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): (71) UNLIMITED CASE [1] uimitep cAsE (Amount demanded (Amount demanded is $25,000 17CV321207 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: March 12, 2020 Time: 10:00 am Dept.: 24 Div.: Room: Address of court (if different from the address above): Old Courthouse [] Notice of Intent to Appear by Telephone, by (name): INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. L¥] This statement is submitted by party (name): Plaintiffs b. [_] This statement is submitted jointly by parties (names): Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a The complaint was filed on (date): 12/28/2017 by 228) he cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) ax] 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 c. (1) LJ have not been served (specify names and explain why not): (2) CI) have been served but have not appeared and have not been dismissed (specify names): (3) Cc] have had a default entered against them (specify names): The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): NewRez LLC (CCP 473(a) amd. required) 4 Description of case a Type of case in [¥] complaint Cc) cross-complaint (Describe, including causes of action): Breach of settlement contract derived from prior action 113CV251320 in this county and subsequent unfair debt collection activity by lenders’ collection agent (Ditech). Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal. Rules of Court, Judicial Council of California rules 3.720-3.730 (CM-110 [Rev. July 1, 2011] www.courts.ca.gov www.accesslaw.com CM-110 PLAINTIFF/PETITIONER: Jawdat Lahlouh, Nisreen Lahlouh CASE NUMBER, 17CV321207 DEFENDANT/RESPONDENT: Ditech Financial, LLC et al. 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. Gist of case is BofA dropped the ball three times in not timely recording a ‘deed in lieu’ after settling a Nevada wrongful foreclosure case dating to 2007 and plaintiffs were prejudiced. This is the third lawsuit: original 2012 Nevada; 2013 this county; and now third to enforce (JAMS) settlement of 2013 case 13CV251320, plus damages for unfair collection activity post-settlement. In the interim since 2014, because BofA didn't record the ‘deed in lieu' promptly even after the settlement in 13CV251320, the property was foreclosed in Nevada against plaintiffs over defaulted HOA assessments. femal (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 LV) a jury trial Coa nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a [] The trial has been set for (date): b. LV] 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. WwW days (specify number): 3 b. [1 hours (short causes) (specify): Trial representation (fo be answered for each party) The party or parties will be represented at trial [LV] by the attorney or party listed in the caption [] by the following: a Attorney: b. Firm: c. Address: d Telephone number: f. Fax number: E-mail address: mo 9 Party represented: Additional representation is described in Attachment 8. 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 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel [¥] has [_] hasnot 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 [J] has L_] has not reviewed the ADR information package identified in rule 3.221 b. Referral to judicial arbitration or civil action mediation (if available). (4) C9 This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) =a] 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 Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): (CM-170 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page2 of5 CM-110 PLAINTIFF/PETITIONER: Jawdat Lahlouh, Nisreen Lahlouh CASE NUMBER. 17CV321207 DEFENDANT/RESPONDENT: Ditech Financial, LLC et al. 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): [eal Mediation session not yet scheduled Ww Co Mediation session scheduled for (date): (1) Mediation Co 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. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 CASE NUMBER: a PLAINTIFF/PETITIONER: Jawdat Lahlouh, Nisreen Lahlouh 170V321207 DEFENDANT/RESPONDENT: Ditech Financial, LLC et al. 11. Insurance a [J insurance carrier, if any, for party filing this statement (name): b, Reservation of rights: [-] Yes [E=3] 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. [V7] Bankruptcy [__] Other (specify): Status: In re Ditech Holding Corp., USB SD NY, 19-10412 JLG, pending motion for relief from stay. 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. [_] Amotion to [) consolidate [J coordinate will be filed by (name party): 14. Bifurcation [V7] 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): Bifurcation may be required to proceed if bankruptcy stay becomes permanent as to Ditech. 15. Other motions [J The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 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 c. LZ] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): Stayed pending resolution of bankruptcy stay issues. CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: Jawdat Lahlouh, Nisreen Lahlouh CASE NUMBER: = 17CV321207 DEFENDANT/RESPONDENT: Ditech Financial, LLC et al. 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. L__] 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 [7] The party or parties request that the following additional matters be considered or determined at the case management conference (specify): Motion for Relief from Stay was mooted by plan of reorganization; account was acquired by NewRez LLC, who is successor in interest to Ditech, via Ch. 11 proceeding. Email is being returned by Severson firm; attempts to prompt response unavailing as of date of filing; does not appear former attorney still with firm. 19. Meet and confer a. L¥] 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): Were meet and confer letters with Ditech's former counsel. No response from Bank of America's counsel. b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): No agreements were reached. 20. Total number of pages attached (if any): lam 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. tty Date: February 25, 2020 William B. Look, Jr. » (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. July1, 2011] CASE MANAGEMENT STATEMENT Page 5 of 5 PROOF OF SERVICE BY ELECTRONIC DELIVERY I declare that I am employed in the County of Monterey, California. I am over the age of eighteen years and not a party to the action herein. My business address is P. O. Box 1381, Monterey, California 93942. On Feb 25, 2020, I caused the above pleading entitled, Case Management Statement on counsel for DEFENDANTS by automated electronic email service via a certified digital filing service provider, to wit, Green Legal File, to the electronic email address of: Will Aspinwall Esq. Severson & Werson One Embarcadero Center, Suite 2600 San Francisco, CA 94111 Main: (415) 398-3344 Direct: (415) 677-5683 waa@severson.com Jonathan C. Cahill, Esq. Wolf& Wyman 980 9th St., #2350 Sacramento CA 95814 (916 912-4600 jmbryan@wolfwyman.com I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on Feb. 25, 2020, at Monterey, California. a “a Y Wi BE hook, dia.