Preview
CM-110
andaddress)
ATTORNEY OR PARTY WITHOUTATTORNEY (Name, Slaie Bar number, FOR COURT USE ONLY
Kathleen A. McCormac (Bar () 159012)
MCCORMAC & ASSOCIATES
2858 Diamond Street
San Francisco, CA 94131
TELEPHQNE No 585-1 733
(4 I 5) 585 I 722 FAx No (oplionali
(4 I 5)
EJBAIL ADDREss (opaonall
Julie COulOmbe, Plaintiff
ATTQRNEY FDR (Namei
sUPERIQR coURT QF cALIFQRNIA, coUNTY QF Butte 8/19/2019
sTREETADoREss 1775 Concord Ave.
MAILING ADDRESS
Chico, CA 95928
CITY AND ZIP CODE
BRANCH NAME
PLAINTIFF/PETITIQNER: Julie Coulombe
DEFENDANT(REsr oNDENT:Butte County Probation
CASE MANAGEMENT STATEMENT CASE NUMBER
(Check one): CX] UNLIMITED CASE C] LIMITED CASE
(Amount demanded (Amount demanded is $ 25,000 18CV02884
exceeds $ 25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: September 9, 2019 Time: I:30 p.m. Dept.: Divz Room:
Address of court (if different from the address above):
~x Notice of Intent to Appear by Telephone, by (name)i Kathleen A. McCormac
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
t. Party or parties (answer one):
a.
b. ~
~x This statement is submitted by party (name): Julie Coulombe,
This statement is submitted jointly by parties (nsmes):
Plaintiff
2 Complaint and cross-complaint (to be answered by p(ainliffs and cross-complainants only)
a.
b. ~
The complaint was filed on (date): September 4, 2018
The cross-complaint, if any, was filed on (date):
3. Service (lo be answered by plaintiffs and cross-comp(a(nants only)
a.
b. ~
~x Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
The following parties named in the complaint or cross-complaint
(I) M have not been served (specify names and explain why no()i
(2) ~ have been served but have not appeared and have not been dismissed (spec(fy names):
(3) ~ have had a default entered against them (specify names).
c. ~ The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of case in ~X complaint cross-complaint (Descn'be, including causes of actionj:
Plaintiff claims that Defendant Butte County Probation, discnminated against her based on sex in violation ol'he California Fair Employment
and Housing Act ("FEHAe). In addition Defendant Butte County probation, retaliated against plainiff, causing a hostile environment with
failure to prevent discrimination. Mrs. Coulombe claims lost wages, lost bcnetits, general damages and attorney's fees and costs.
Page 1 of
5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal Rules of Coun,
Judioal Council of California rules 3 720-3 730
CM 110 [Rev July I, 2011( www courts ca gov
(exisivexisde Xuronrdred Co(iforma dudrcrd( Councd Forms
CM-110
CASE NUMBER
PLAINTIFF/PETITIONER: Julie Coulombe
DEFENDANT/RESPONDENT: Butte County Probation 18CV02884
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 Io date, and estimated future lost earnings.
If equitable relief is sought, descnbe the nature of the relief)
Plaintiff claims that Defendant Butte County Probation, discriminated against her based on sex in violation
of the California Fair Employment and Housing Act (aFEHAa). )n addition Defendant Butte County
Probation, retaliated against Plainiff, causing a hostile environment with failure to prevent discrimination.
Mrs. Coulombe claims lost wages, lost benefits, general damages and attorney's fees and costs.
(If morespace is needed, check this box and attach a page designated as Affachment 4b.)
Jury or nonjury trial
The party or parties request CX] a jury trial
Julie Coulombe, Plaintiff
requesting e jury trial):
H a nonjury trial. (If more than one party, provide the name of each party
a.
b.
~
Trial date
~X
The trial has been set for (date):
No trial date has been set. This case will be ready for trial within 12 months of the date of the fikng of the complaint (if
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and exp(ain reasons for unavailability):
Estimated length of trial
The party or parties estimate that the trial will take (check one)
a.
b. ~
~X days (specify number): 5-7
hours (shon causes) (specify):
Trial representation (lo be answered for each party)
The party or parties will be represented at trial
a. Attorney:
~x by the attorney or party hated in the caption ~ by the following
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. 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 CZ has Cl has not provided the ADR information package identified
in rule 3.221to the client and reviewed ADR options with the client.
(2) For self-represented parties: PartyCZ has M has not reviewed the ADR information package identified in rule
3.221.
b.
(1) ~
Referral to judicial arbitration or civil action mediation (if available).
This matter is subiect to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) ~ Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
CivilProcedure section 1141.11.
(3) ~x 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):
Pursuant to CRC 1600.5(h), Plaintiffs'amages in this matter exceed $ 50,000.00.
CM-110 IR v July 1,20111 Page of 5
CASE MANAGEMENT STATEMENT 2
LexfsNexfsfgf ef ~ fofnafed Caifjornfa dndfnaI Counsel
I'oefns
CM-110
PLAINTIFF/PETITIONER: CASE NUMBER
Jujjc ( pujpmbc
EFENDANT/REsPQN DENT 18CV02884
Bttttc Cpttnty prpbatjp
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 a/l 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'DR
processes (check all that apply): stipulation):
~X Mediation session not yet scheduled
C3 Mediation session scheduled for (dale):
(1) Mediation
Agreed to complete mediation by (dafe):
Mediation completed on (dale).
C3 Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (dale):
Settlement conference completed on (dale):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (dafe):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (dale):
Neutral evaluation completed on (dale):
Judicial arbitration not yet scheduled
Nonbinding judicial Judicial arbitration scheduled for (dafe):
(4)
arbitration
Agreed to complete judicial arbitration by (dale):
Judicial arbitration completed on (date):
Pnvate arbitration not yet scheduled
Binding private Private arbitration scheduled for (dale):
(5)
arbitration
Agreed to complete private arbitration by (dale):
Private arbitration completed on (dale):
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (dale):
ADR completed on (date):
CM-110IROO J ly1,2011l Pege 3 of 5
CASE MANAGEMENT STATEMENT
LexfsNexfsgg Auiowafed Caf&fornfa Judicial Couned Forms
CM-110
PLAINTIFF/PETITIONER. Julie Coulombe CASE NUMBER
DEFENDANT/REsPQNDENT: Butte County Probation 18CV02884
11.
a. ~
Insurance
Insurance carrier, if any, for parly filing this statement (name):
H H
b.
c. ~
Reservation of rights: Yes No
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.
Status:
Bankruptcy C3 Other (specify):
13.
~
Related cases, consolidation, and coordination
There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court
(3) Case number:
b.
~
~
(4) Status:
A motion to ~
Additional cases are described in Attachment 13a.
consolidate ~ coordinate (name party):
will be filed by
~
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)'5.
Other motions
The party or parties expect to file the following motions before tnal (specify moving party, type of motion, and issues):
16.
a.
b.
~
Discovery
~ The party or parties have completed all discovery.
The following discovery will be completed by the date specified (describe a/I anticipated discovery):
~Part Descriotion ~Dat
Plaintiff Initial Written Discovery October 2018
Plaintiff Percipient Witness Depositions November 2019
Defendant Percipient Witness Depositions (taken) March - July 2019
c ~x The following discovery issues,including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Expert Witness Deposition and Follow up Written Discovery all according to C.C.P
CM-110 IRev July
201 1I Pege4 of 0
1,
CASE MANAGEMENT STATEMENT
Lexfstvexfsggsf uioioaied Catiforufa dudfefat Couooil Forms
CM-110
PLAINTIFF/PETITIONER: Jul ie Coulombe CASE NUMBER
IIICIV04025
DEFENDANT/REsPQNDENT: Butte County Probation
17.
a.~
Economic litigation
case (i.e., the amount demanded is $ 25,000 or less) and the economic litigation procedures in Code
This is a limited civil
b. ~ of Civil Procedure sections 90-98 will apply to this case.
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 re/ating to discovery or trial
should not apply to this case):
18.
~
Other issues
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a. ~X 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)i
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):
Iam 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 authonty of the party where required.
2019
~W
Date: August 19,
Kathleen A. McCormac terr)arras
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME)
~ (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached
CM-110 [Rey July I, 201()
CASE MANAGEMENT STATEMENT Peaeser S
texrsNexrsSBXrrror«ared Calrfor«ra arrCrerai Co««ert For«rs
PROOF OF SERVICE
C.C.P. 1013(a), 2015.5
Fit'I
Iam a citizen of the United States and am employed in the County of San Francisco. I am
over the age of eighteen years and not a party to the within entitled action. My business address is
2858 Diamond Street, San Francisco, California, 94131.
On August 19, 2019, I served the attached documents:
PLAINTIFF'S CASE MANAGEMENT STATEMENT
10 X By placing a copy thereof in an envelope, postage fully prepaid, in the United States Mail at
San Francisco, California, addressed to the parties listed below.
12
tI By facsimile to the parties listed below.
13
a By Overnight delivery (Federal Express) to the parties listed below.
14
a By hand, in person to the parties listed below.
15
16 William E. Carny
PORTER SCOTT
17 350 University Ave., Ste. 200
Sacramento, CA 95825
18
19
Ideclare under penalty of perjury under the laws of the State of California that the foregoing
20
is true and correct and that this Declaration is execute anclsco,
21
California.
22
23
24
25
26
27
28
PROOF OF SERVICE
Preview
CM-110 andaddress) ATTORNEY OR PARTY WITHOUTATTORNEY (Name, Slaie Bar number, FOR COURT USE ONLY Kathleen A. McCormac (Bar () 159012) MCCORMAC & ASSOCIATES 2858 Diamond Street San Francisco, CA 94131 TELEPHQNE No 585-1 733 (4 I 5) 585 I 722 FAx No (oplionali (4 I 5) EJBAIL ADDREss (opaonall Julie COulOmbe, Plaintiff ATTQRNEY FDR (Namei sUPERIQR coURT QF cALIFQRNIA, coUNTY QF Butte 8/19/2019 sTREETADoREss 1775 Concord Ave. MAILING ADDRESS Chico, CA 95928 CITY AND ZIP CODE BRANCH NAME PLAINTIFF/PETITIQNER: Julie Coulombe DEFENDANT(REsr oNDENT:Butte County Probation CASE MANAGEMENT STATEMENT CASE NUMBER (Check one): CX] UNLIMITED CASE C] LIMITED CASE (Amount demanded (Amount demanded is $ 25,000 18CV02884 exceeds $ 25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: September 9, 2019 Time: I:30 p.m. Dept.: Divz Room: Address of court (if different from the address above): ~x Notice of Intent to Appear by Telephone, by (name)i Kathleen A. McCormac INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. t. Party or parties (answer one): a. b. ~ ~x This statement is submitted by party (name): Julie Coulombe, This statement is submitted jointly by parties (nsmes): Plaintiff 2 Complaint and cross-complaint (to be answered by p(ainliffs and cross-complainants only) a. b. ~ The complaint was filed on (date): September 4, 2018 The cross-complaint, if any, was filed on (date): 3. Service (lo be answered by plaintiffs and cross-comp(a(nants only) a. b. ~ ~x Allparties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. The following parties named in the complaint or cross-complaint (I) M have not been served (specify names and explain why no()i (2) ~ have been served but have not appeared and have not been dismissed (spec(fy names): (3) ~ have had a default entered against them (specify names). c. ~ The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type of case in ~X complaint cross-complaint (Descn'be, including causes of actionj: Plaintiff claims that Defendant Butte County Probation, discnminated against her based on sex in violation ol'he California Fair Employment and Housing Act ("FEHAe). In addition Defendant Butte County probation, retaliated against plainiff, causing a hostile environment with failure to prevent discrimination. Mrs. Coulombe claims lost wages, lost bcnetits, general damages and attorney's fees and costs. Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal Rules of Coun, Judioal Council of California rules 3 720-3 730 CM 110 [Rev July I, 2011( www courts ca gov (exisivexisde Xuronrdred Co(iforma dudrcrd( Councd Forms CM-110 CASE NUMBER PLAINTIFF/PETITIONER: Julie Coulombe DEFENDANT/RESPONDENT: Butte County Probation 18CV02884 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 Io date, and estimated future lost earnings. If equitable relief is sought, descnbe the nature of the relief) Plaintiff claims that Defendant Butte County Probation, discriminated against her based on sex in violation of the California Fair Employment and Housing Act (aFEHAa). )n addition Defendant Butte County Probation, retaliated against Plainiff, causing a hostile environment with failure to prevent discrimination. Mrs. Coulombe claims lost wages, lost benefits, general damages and attorney's fees and costs. (If morespace is needed, check this box and attach a page designated as Affachment 4b.) Jury or nonjury trial The party or parties request CX] a jury trial Julie Coulombe, Plaintiff requesting e jury trial): H a nonjury trial. (If more than one party, provide the name of each party a. b. ~ Trial date ~X The trial has been set for (date): No trial date has been set. This case will be ready for trial within 12 months of the date of the fikng of the complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and exp(ain reasons for unavailability): Estimated length of trial The party or parties estimate that the trial will take (check one) a. b. ~ ~X days (specify number): 5-7 hours (shon causes) (specify): Trial representation (lo be answered for each party) The party or parties will be represented at trial a. Attorney: ~x by the attorney or party hated in the caption ~ by the following b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. 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 CZ has Cl has not provided the ADR information package identified in rule 3.221to the client and reviewed ADR options with the client. (2) For self-represented parties: PartyCZ has M has not reviewed the ADR information package identified in rule 3.221. b. (1) ~ Referral to judicial arbitration or civil action mediation (if available). This matter is subiect to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) ~ Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of CivilProcedure section 1141.11. (3) ~x 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): Pursuant to CRC 1600.5(h), Plaintiffs'amages in this matter exceed $ 50,000.00. CM-110 IR v July 1,20111 Page of 5 CASE MANAGEMENT STATEMENT 2 LexfsNexfsfgf ef ~ fofnafed Caifjornfa dndfnaI Counsel I'oefns CM-110 PLAINTIFF/PETITIONER: CASE NUMBER Jujjc ( pujpmbc EFENDANT/REsPQN DENT 18CV02884 Bttttc Cpttnty prpbatjp 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 a/l 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'DR processes (check all that apply): stipulation): ~X Mediation session not yet scheduled C3 Mediation session scheduled for (dale): (1) Mediation Agreed to complete mediation by (dafe): Mediation completed on (dale). C3 Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (dale): Settlement conference completed on (dale): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (dafe): (3) Neutral evaluation Agreed to complete neutral evaluation by (dale): Neutral evaluation completed on (dale): Judicial arbitration not yet scheduled Nonbinding judicial Judicial arbitration scheduled for (dafe): (4) arbitration Agreed to complete judicial arbitration by (dale): Judicial arbitration completed on (date): Pnvate arbitration not yet scheduled Binding private Private arbitration scheduled for (dale): (5) arbitration Agreed to complete private arbitration by (dale): Private arbitration completed on (dale): ADR session not yet scheduled ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (dale): ADR completed on (date): CM-110IROO J ly1,2011l Pege 3 of 5 CASE MANAGEMENT STATEMENT LexfsNexfsgg Auiowafed Caf&fornfa Judicial Couned Forms CM-110 PLAINTIFF/PETITIONER. Julie Coulombe CASE NUMBER DEFENDANT/REsPQNDENT: Butte County Probation 18CV02884 11. a. ~ Insurance Insurance carrier, if any, for parly filing this statement (name): H H b. c. ~ Reservation of rights: Yes No 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. Status: Bankruptcy C3 Other (specify): 13. ~ Related cases, consolidation, and coordination There are companion, underlying, or related cases. (1) Name of case: (2) Name of court (3) Case number: b. ~ ~ (4) Status: A motion to ~ Additional cases are described in Attachment 13a. consolidate ~ coordinate (name party): will be filed by ~ 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)'5. Other motions The party or parties expect to file the following motions before tnal (specify moving party, type of motion, and issues): 16. a. b. ~ Discovery ~ The party or parties have completed all discovery. The following discovery will be completed by the date specified (describe a/I anticipated discovery): ~Part Descriotion ~Dat Plaintiff Initial Written Discovery October 2018 Plaintiff Percipient Witness Depositions November 2019 Defendant Percipient Witness Depositions (taken) March - July 2019 c ~x The following discovery issues,including issues regarding the discovery of electronically stored information, are anticipated (specify): Expert Witness Deposition and Follow up Written Discovery all according to C.C.P CM-110 IRev July 201 1I Pege4 of 0 1, CASE MANAGEMENT STATEMENT Lexfstvexfsggsf uioioaied Catiforufa dudfefat Couooil Forms CM-110 PLAINTIFF/PETITIONER: Jul ie Coulombe CASE NUMBER IIICIV04025 DEFENDANT/REsPQNDENT: Butte County Probation 17. a.~ Economic litigation case (i.e., the amount demanded is $ 25,000 or less) and the economic litigation procedures in Code This is a limited civil b. ~ of Civil Procedure sections 90-98 will apply to this case. 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 re/ating to discovery or trial should not apply to this case): 18. ~ Other issues The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. ~X 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)i 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): Iam 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 authonty of the party where required. 2019 ~W Date: August 19, Kathleen A. McCormac terr)arras (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) ~ (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached CM-110 [Rey July I, 201() CASE MANAGEMENT STATEMENT Peaeser S texrsNexrsSBXrrror«ared Calrfor«ra arrCrerai Co««ert For«rs PROOF OF SERVICE C.C.P. 1013(a), 2015.5 Fit'I Iam a citizen of the United States and am employed in the County of San Francisco. I am over the age of eighteen years and not a party to the within entitled action. My business address is 2858 Diamond Street, San Francisco, California, 94131. On August 19, 2019, I served the attached documents: PLAINTIFF'S CASE MANAGEMENT STATEMENT 10 X By placing a copy thereof in an envelope, postage fully prepaid, in the United States Mail at San Francisco, California, addressed to the parties listed below. 12 tI By facsimile to the parties listed below. 13 a By Overnight delivery (Federal Express) to the parties listed below. 14 a By hand, in person to the parties listed below. 15 16 William E. Carny PORTER SCOTT 17 350 University Ave., Ste. 200 Sacramento, CA 95825 18 19 Ideclare under penalty of perjury under the laws of the State of California that the foregoing 20 is true and correct and that this Declaration is execute anclsco, 21 California. 22 23 24 25 26 27 28 PROOF OF SERVICE