Preview
1 GEORGE E. WASHINGTON, State Bar 46281
PETER G. WASHINGTON, State Bar 230514
2 WASHINGTON k WASHINGTON
Attorneys at Law 6/10/2020
3 1600 Humboldt Road, Suite 2
Chico, California 95928
4 Telephone: (530) 345-0821
Facsimile: (530) 342-2242
5
BRUCE S. ALPERT, State Bar No. 75684
6 BUTTE COUNTY COUNSEL
25 County Center Drive, Suite 213
7 Oroville, California 95965
Telephone: (530) 538-7621
8
9 Attorneys for Defendants, COUNTY OF BUTTE and GIOVANNI LOCASCIO
10
IN THK SUPERIOR COURT OF THE STATE OF CALIFORNIA
12 IN AND FOR THE COUNTY OF BUTTE
13
14 ELIAS MEDRANO, ) CASE NO.: 20CV00626
)
Plaintiff, ) DEFENDANTS COUNTY OF BUTTE AND
) GIOVANNI LOCASCIO'S ANSWER TO
16 vs. ) PLAINTIFF'S COMPLAINT
)
17 BUTTE COUNTY; GIOVANNI LOCASCIO;)
and DOES 1 to 25, inclusive, ) DEMAND FOR JURY TRIAL
18 )
Defendants. )
19 )
20 COME NOW, Defendants, COUNTY OF BUTTE and GIOVANNI LOCASCIO, and answer
21 Plaintiff, ELIAS MEDRANO's Complaint on file herein, and admit, deny and allege as follows:
22 GENERAL DENIAL
23 Defendants generally and specifically deny each and every allegation and cause of action of the
24 unverified Complaint pursuant to the provisions of Code of Civil Procedure section 431.30(d) and
25 further specifically deny that Plaintiff has been damaged in the manner or amount alleged or in any
26 other manner or amount due to any wrongful act by or attributable to these answering Defendants.
27
28
DEFENDANTS'NSWER To PLAINTIFI'LIAS MEDRANO'S COMPLAINT
1
FIRST AFFIRMATIVE DEFENSE
2 AS AND FOR A FIRST, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these
answering Defendants allege that Plaintiff s Complaint and each and every cause of action thereof does
4 not state facts sufficient to constitute a cause of action against these answering Defendants.
5 SECOND AFFIRMATIVE DEFENSE
6 AS AND FOR A SECOND, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these
7 answering Defendants allege that as to each and every cause of action set forth herein, Plaintiff was at
8 all times mentioned in the Complaint, guilty of comparative negligence or fault.
THIRD AFFIRMATIVE DEFENSE
10 AS AND FOR A THIRD, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these
11 answering Defendants allege that as to each and every cause of action set forth herein, other persons
12 and entities, both named and unnamed, save and except these answering Defendants, were themselves
13 comparatively negligent, strictly liable, or otherwise at fault, and the liability, if any, of these
14 answering Defendants, should be diminished in direct proportion to the fault, if any, of those both
15 named and unnamed, including the Plaintiff, pursuant to Civil Code tj1431.
16 FOURTH AFFIRMATIVE DEFENSE
17 AS AND FOR A FOURTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these
18 answering Defendants allege that as to each and every cause of action set forth herein, the liability to
19 Plaintiff is barred or reduced proportionately by Plaintiff s own careless, negligent and willful conduct;
20 or by reason of Plaintiff's legal responsibility for similar such conduct of others, including Plaintiff s
21 agents, partners, or joint venturers, all of which proximately caused any damage claimed in this action.
22 FIFTH AFFIRMATIVE DEFENSE
23 AS AND FOR A FIFTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these
24 answering Defendants allege that as to each and every cause of action set forth herein, Defendants are
25 immune from liability pursuant to the provisions of California Government Code ) 810 er seq. and
26 other statutory and common law.
27
28
DEFENDANTS'NSWEII TO PLAINTIFF ELIAS MEDRANO'S COMPLAINT
1
SIXTH AFFIRMATIVE DFFENSE
2 AS AND FOR A SIXTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these
3 answering Defendants allege that as to each and every cause of action set forth herein, Plaintiff failed
4 to mitigate, minimize or avoid damages allegedly caused by Defendants and are therefore entitled to
5 have any such sum to which Plaintiff is entitled reduced by such sums as would have been mitigated,
6 minimized, or reduced.
7 SEVENTH AFFIRMATIVE DEFENSE
8 AS AND FOR A SEVENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE,
9 these answering Defendants allege that as to each and every cause of action set forth herein, Plaintiff s
10 claim is barred by the applicable statute of limitations, including, but not limited to, Code of Civil
11 Procedure )$ 335.1, 340, 340.5, 474, 583 and 538.250.
12 EIGHTH AFFIRMATIVE DEFENSE
13 AS AND FOR AN EIGHTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE,
14 these answering Defendants allege that, as to each and every cause of action set forth herein, Plaintiff s
15 claim is barred by failure to comply with the California Government Claims Act, California
16 Government Code f 900, et seq., including but not limited to Government Code 910(e),
I'111 911.2,
17 945.4, 945.6, and 950.2.
18 NINTH AFFIRMATIVE DEFENSE
19 AS AND FOR A NINTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these
20 answering Defendants allege that, as to each and every cause of action set forth herein, Plaintiffs
21 claim is barred by California Government Code 11815.2(b).
22 TENTH AFFIRMATIVE DEFENSE
23 AS AND FOR A TENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these
24 answering Defendants allege that, as to each and every cause of action set forth herein, Plaintiffs
25 claim is barred by California Government Code ( 820.2.
26
27
28
DKITKNDANTS'NSWER To PLAINTIFF EI,IAS MKDRANO'S CDMPLAINT
1
ELEVENTH AFFIRMATIVE DEFENSE
2 AS AND FOR AN ELEVENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE,
3 these answering Defendants allege that, as to each and every cause of action set forth herein, Plaintiff s
4 claim is barred by California Government Code tj820.8.
5 TWELFTH AFFIRMATIVE DEFENSE
6 AS AND FOR A TWELFTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE,
7 these answering Defendants allege that, as to each and every cause of action set forth herein, Plaintiff s
8 claim is barred by California Government Code f 820.4.
9 THIRTEENTH AFFIRMATIVE DEFENSE
10 AS AND FOR A THIRTEENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE,
11 these answering Defendants allege that, as to each and every cause of action set forth herein, Plaintiff s
12 claim is barred by California Government Code tj8655.
13 FOURTEENTH AFFIRMATIVE DEFENSE
14 AS AND FOR A FOURTEENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE,
15 these answering Defendants allege that, as to each and every cause of action set forth herein, Plaintiff
16 expressly assumed the risk of injury herein.
17 FIFTEENTH AFFIRMATIVE DEFENSE
18 AS AND FOR A FIFTEENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE,
19 these answering Defendants allege that as to each and every cause of action set forth herein, these
20 answering Defendants claim the benefits of Government Code )tj984 and 985 et seq.
21 SIXTEENTH AFFIRMATIVE DEFENSE
22 AS AND FOR A SIXTEENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE,
23 these answering Defendants allege that they are not legally responsible for the acts or omissions of
24 other unnamed Defendants.
25
26
27
28
DEI'ENDANTS'NSWER TO PLAINTIFF ELIAS NEDRANO'S COll1PLAINT
1
SEVENTEENTH AFFIRMATIVE DEFENSE
2 AS AND FOR A SEVENTEENTH, SEPARATE AND DISTINCT AFFIRMATIVE
3 DEFENSE, these answering Defendants allege that the Complaint and each and every cause of action
4 therein, is barred in whole or in part by the doctrines of waiver, estoppel, and/or consent.
5 EIGHTEENTH AFFIRMATIVE DEFENSE
6 AS AND FOR AN EIGHTEENTH, SEPARATE AND DISTINCT AFFIRMATIVE
7 DEFENSE, these answering Defendants allege that Plaintiff s Complaint and each and every cause of
8 action therein, is barred in whole or in part by the doctrine of laches.
9 NINETEENTH AFFIRMATIVE DEFENSE
10 AS AND FOR A NINETEENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE,
11 these answering Defendants allege that Plaintiffs Complaint and each and every cause of action
12 therein, is barred in whole or in part because Plaintiff has failed to exhaust all of his administrative
13 remedies.
14 TWENTIETH AFFIRMATIVE DEFENSE
15 AS AND FOR A TWENTIETH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE,
16 these answering Defendants allege that Plaintiff's Complaint and each and every cause of action
17 therein, is barred in whole or in part because the alleged conduct complained of was not a substantial
18 factor in causing Plaintiff s alleged injuries, if any.
19 TWENTY-FIRST AFFIRMATIVE DEFENSE
20 AS AND FOR A TWENTY-FIRST, SEPARATE AND DISTINCT AFFIRMATIVE
21 DEFENSE, these answering Defendants allege that they cannot fully anticipate all affirmative defenses
22 that may be applicable to this action based upon the conclusory terms used in the Complaint.
23 Accordingly, Defendants expressly reserve the right to assert additional defenses if and to the extent
24 that such affirmative defenses become applicable.
25 WHEREFORE, these answering Defendants pray as follows:
26 I. That Plaintiff take nothing by way of his Complaint;
27
28
DEFENDANTS'NSWER TO PLAINTIFF ELIAS MEDRANO'S COMPLAINT
For costs of suit, including without limitation, defense costs pursuant to
California Code of Civil Procedure It1038; and,
For such other relief as the Court may deem proper.
4 Date: June9,2020 NGTON
GEORGE E WASHINGTON
Attorneys for Defendants
COUNTY OF BUTTE and
GIOVANNI LOCASCIO
10
12
13
14
15
16
17
19
20
21
22
23
24
25
26
27
28
DEFENDANTS'NSWER To PLAINTIFF ELIAS MEDRANO'S COMPLAINT
I PROOF OF SERVICE
At the time of service hereinafter mentioned, I was, and am, a citizen of the United States and a
resident of the County of Butte. I am over the age of 18 years and not a party to the within action; my
3 business address is 1600 Humboldt Road, Suite 2, Chico, California 95928.
4 On the following date, I served the foregoing document described as:
5
DEFENDANTS COUNTY OF BUTTE AND GIOVANNI LOCASCIO'S ANSWER TO
6 PLAINTIFF'S COMPLAINT
7
on the parties below by placing a true copy thereof in a sealed envelope and served same on the
8 parties/counsel, addressed as follows:
10
Matthew R. Eason, Esq. Bruce S. Alpert, Esq.
Eason & Tambornini Butte County Counsel
1234 H Street, Suite 200 25 County Center Drive, Suite 210
Sacramento, California 95814 Oroville, Cali fornia 95965
12
0 (916) 438-1819 / F (916) 438-1820 (Co-Counsel)
(Attorney for Plaintiff)
13
14
The following is a procedure in which service of this document was affected:
15
XX U.S. Postal Service (by placing for collection and deposit in the United States mail a copy of
16
said document at Washington & Washington, 1600 Humboldt Road, Suite 2, Chico, Butte
County, California, in a sealed envelope, with postage fully prepaid). Iam familiar with the
17
practice of Washington & Washington for the collection of processing of correspondence for
mailing with the United States Postal Service. In accordance with the ordinary course of
18
business, the above-mentioned document would have been deposited with the United States
mail on the same day on which it was placed at Washington & Washington for deposit.
19
Overnight Delivery
20
Hand Delivery / Personal Service
21
E-mail Transmission
22
I declare under penalty of perjury unde State of that the foregoing is
true and correct.
23
Dated: June i4 2020
24
25 ~K +KNUTHSON
26
27
28
PROOF OF SERVICE
Preview
1 GEORGE E. WASHINGTON, State Bar 46281 PETER G. WASHINGTON, State Bar 230514 2 WASHINGTON k WASHINGTON Attorneys at Law 6/10/2020 3 1600 Humboldt Road, Suite 2 Chico, California 95928 4 Telephone: (530) 345-0821 Facsimile: (530) 342-2242 5 BRUCE S. ALPERT, State Bar No. 75684 6 BUTTE COUNTY COUNSEL 25 County Center Drive, Suite 213 7 Oroville, California 95965 Telephone: (530) 538-7621 8 9 Attorneys for Defendants, COUNTY OF BUTTE and GIOVANNI LOCASCIO 10 IN THK SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 IN AND FOR THE COUNTY OF BUTTE 13 14 ELIAS MEDRANO, ) CASE NO.: 20CV00626 ) Plaintiff, ) DEFENDANTS COUNTY OF BUTTE AND ) GIOVANNI LOCASCIO'S ANSWER TO 16 vs. ) PLAINTIFF'S COMPLAINT ) 17 BUTTE COUNTY; GIOVANNI LOCASCIO;) and DOES 1 to 25, inclusive, ) DEMAND FOR JURY TRIAL 18 ) Defendants. ) 19 ) 20 COME NOW, Defendants, COUNTY OF BUTTE and GIOVANNI LOCASCIO, and answer 21 Plaintiff, ELIAS MEDRANO's Complaint on file herein, and admit, deny and allege as follows: 22 GENERAL DENIAL 23 Defendants generally and specifically deny each and every allegation and cause of action of the 24 unverified Complaint pursuant to the provisions of Code of Civil Procedure section 431.30(d) and 25 further specifically deny that Plaintiff has been damaged in the manner or amount alleged or in any 26 other manner or amount due to any wrongful act by or attributable to these answering Defendants. 27 28 DEFENDANTS'NSWER To PLAINTIFI'LIAS MEDRANO'S COMPLAINT 1 FIRST AFFIRMATIVE DEFENSE 2 AS AND FOR A FIRST, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these answering Defendants allege that Plaintiff s Complaint and each and every cause of action thereof does 4 not state facts sufficient to constitute a cause of action against these answering Defendants. 5 SECOND AFFIRMATIVE DEFENSE 6 AS AND FOR A SECOND, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these 7 answering Defendants allege that as to each and every cause of action set forth herein, Plaintiff was at 8 all times mentioned in the Complaint, guilty of comparative negligence or fault. THIRD AFFIRMATIVE DEFENSE 10 AS AND FOR A THIRD, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these 11 answering Defendants allege that as to each and every cause of action set forth herein, other persons 12 and entities, both named and unnamed, save and except these answering Defendants, were themselves 13 comparatively negligent, strictly liable, or otherwise at fault, and the liability, if any, of these 14 answering Defendants, should be diminished in direct proportion to the fault, if any, of those both 15 named and unnamed, including the Plaintiff, pursuant to Civil Code tj1431. 16 FOURTH AFFIRMATIVE DEFENSE 17 AS AND FOR A FOURTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these 18 answering Defendants allege that as to each and every cause of action set forth herein, the liability to 19 Plaintiff is barred or reduced proportionately by Plaintiff s own careless, negligent and willful conduct; 20 or by reason of Plaintiff's legal responsibility for similar such conduct of others, including Plaintiff s 21 agents, partners, or joint venturers, all of which proximately caused any damage claimed in this action. 22 FIFTH AFFIRMATIVE DEFENSE 23 AS AND FOR A FIFTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these 24 answering Defendants allege that as to each and every cause of action set forth herein, Defendants are 25 immune from liability pursuant to the provisions of California Government Code ) 810 er seq. and 26 other statutory and common law. 27 28 DEFENDANTS'NSWEII TO PLAINTIFF ELIAS MEDRANO'S COMPLAINT 1 SIXTH AFFIRMATIVE DFFENSE 2 AS AND FOR A SIXTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these 3 answering Defendants allege that as to each and every cause of action set forth herein, Plaintiff failed 4 to mitigate, minimize or avoid damages allegedly caused by Defendants and are therefore entitled to 5 have any such sum to which Plaintiff is entitled reduced by such sums as would have been mitigated, 6 minimized, or reduced. 7 SEVENTH AFFIRMATIVE DEFENSE 8 AS AND FOR A SEVENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, 9 these answering Defendants allege that as to each and every cause of action set forth herein, Plaintiff s 10 claim is barred by the applicable statute of limitations, including, but not limited to, Code of Civil 11 Procedure )$ 335.1, 340, 340.5, 474, 583 and 538.250. 12 EIGHTH AFFIRMATIVE DEFENSE 13 AS AND FOR AN EIGHTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, 14 these answering Defendants allege that, as to each and every cause of action set forth herein, Plaintiff s 15 claim is barred by failure to comply with the California Government Claims Act, California 16 Government Code f 900, et seq., including but not limited to Government Code 910(e), I'111 911.2, 17 945.4, 945.6, and 950.2. 18 NINTH AFFIRMATIVE DEFENSE 19 AS AND FOR A NINTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these 20 answering Defendants allege that, as to each and every cause of action set forth herein, Plaintiffs 21 claim is barred by California Government Code 11815.2(b). 22 TENTH AFFIRMATIVE DEFENSE 23 AS AND FOR A TENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, these 24 answering Defendants allege that, as to each and every cause of action set forth herein, Plaintiffs 25 claim is barred by California Government Code ( 820.2. 26 27 28 DKITKNDANTS'NSWER To PLAINTIFF EI,IAS MKDRANO'S CDMPLAINT 1 ELEVENTH AFFIRMATIVE DEFENSE 2 AS AND FOR AN ELEVENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, 3 these answering Defendants allege that, as to each and every cause of action set forth herein, Plaintiff s 4 claim is barred by California Government Code tj820.8. 5 TWELFTH AFFIRMATIVE DEFENSE 6 AS AND FOR A TWELFTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, 7 these answering Defendants allege that, as to each and every cause of action set forth herein, Plaintiff s 8 claim is barred by California Government Code f 820.4. 9 THIRTEENTH AFFIRMATIVE DEFENSE 10 AS AND FOR A THIRTEENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, 11 these answering Defendants allege that, as to each and every cause of action set forth herein, Plaintiff s 12 claim is barred by California Government Code tj8655. 13 FOURTEENTH AFFIRMATIVE DEFENSE 14 AS AND FOR A FOURTEENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, 15 these answering Defendants allege that, as to each and every cause of action set forth herein, Plaintiff 16 expressly assumed the risk of injury herein. 17 FIFTEENTH AFFIRMATIVE DEFENSE 18 AS AND FOR A FIFTEENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, 19 these answering Defendants allege that as to each and every cause of action set forth herein, these 20 answering Defendants claim the benefits of Government Code )tj984 and 985 et seq. 21 SIXTEENTH AFFIRMATIVE DEFENSE 22 AS AND FOR A SIXTEENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, 23 these answering Defendants allege that they are not legally responsible for the acts or omissions of 24 other unnamed Defendants. 25 26 27 28 DEI'ENDANTS'NSWER TO PLAINTIFF ELIAS NEDRANO'S COll1PLAINT 1 SEVENTEENTH AFFIRMATIVE DEFENSE 2 AS AND FOR A SEVENTEENTH, SEPARATE AND DISTINCT AFFIRMATIVE 3 DEFENSE, these answering Defendants allege that the Complaint and each and every cause of action 4 therein, is barred in whole or in part by the doctrines of waiver, estoppel, and/or consent. 5 EIGHTEENTH AFFIRMATIVE DEFENSE 6 AS AND FOR AN EIGHTEENTH, SEPARATE AND DISTINCT AFFIRMATIVE 7 DEFENSE, these answering Defendants allege that Plaintiff s Complaint and each and every cause of 8 action therein, is barred in whole or in part by the doctrine of laches. 9 NINETEENTH AFFIRMATIVE DEFENSE 10 AS AND FOR A NINETEENTH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, 11 these answering Defendants allege that Plaintiffs Complaint and each and every cause of action 12 therein, is barred in whole or in part because Plaintiff has failed to exhaust all of his administrative 13 remedies. 14 TWENTIETH AFFIRMATIVE DEFENSE 15 AS AND FOR A TWENTIETH, SEPARATE AND DISTINCT AFFIRMATIVE DEFENSE, 16 these answering Defendants allege that Plaintiff's Complaint and each and every cause of action 17 therein, is barred in whole or in part because the alleged conduct complained of was not a substantial 18 factor in causing Plaintiff s alleged injuries, if any. 19 TWENTY-FIRST AFFIRMATIVE DEFENSE 20 AS AND FOR A TWENTY-FIRST, SEPARATE AND DISTINCT AFFIRMATIVE 21 DEFENSE, these answering Defendants allege that they cannot fully anticipate all affirmative defenses 22 that may be applicable to this action based upon the conclusory terms used in the Complaint. 23 Accordingly, Defendants expressly reserve the right to assert additional defenses if and to the extent 24 that such affirmative defenses become applicable. 25 WHEREFORE, these answering Defendants pray as follows: 26 I. That Plaintiff take nothing by way of his Complaint; 27 28 DEFENDANTS'NSWER TO PLAINTIFF ELIAS MEDRANO'S COMPLAINT For costs of suit, including without limitation, defense costs pursuant to California Code of Civil Procedure It1038; and, For such other relief as the Court may deem proper. 4 Date: June9,2020 NGTON GEORGE E WASHINGTON Attorneys for Defendants COUNTY OF BUTTE and GIOVANNI LOCASCIO 10 12 13 14 15 16 17 19 20 21 22 23 24 25 26 27 28 DEFENDANTS'NSWER To PLAINTIFF ELIAS MEDRANO'S COMPLAINT I PROOF OF SERVICE At the time of service hereinafter mentioned, I was, and am, a citizen of the United States and a resident of the County of Butte. I am over the age of 18 years and not a party to the within action; my 3 business address is 1600 Humboldt Road, Suite 2, Chico, California 95928. 4 On the following date, I served the foregoing document described as: 5 DEFENDANTS COUNTY OF BUTTE AND GIOVANNI LOCASCIO'S ANSWER TO 6 PLAINTIFF'S COMPLAINT 7 on the parties below by placing a true copy thereof in a sealed envelope and served same on the 8 parties/counsel, addressed as follows: 10 Matthew R. Eason, Esq. Bruce S. Alpert, Esq. Eason & Tambornini Butte County Counsel 1234 H Street, Suite 200 25 County Center Drive, Suite 210 Sacramento, California 95814 Oroville, Cali fornia 95965 12 0 (916) 438-1819 / F (916) 438-1820 (Co-Counsel) (Attorney for Plaintiff) 13 14 The following is a procedure in which service of this document was affected: 15 XX U.S. Postal Service (by placing for collection and deposit in the United States mail a copy of 16 said document at Washington & Washington, 1600 Humboldt Road, Suite 2, Chico, Butte County, California, in a sealed envelope, with postage fully prepaid). Iam familiar with the 17 practice of Washington & Washington for the collection of processing of correspondence for mailing with the United States Postal Service. In accordance with the ordinary course of 18 business, the above-mentioned document would have been deposited with the United States mail on the same day on which it was placed at Washington & Washington for deposit. 19 Overnight Delivery 20 Hand Delivery / Personal Service 21 E-mail Transmission 22 I declare under penalty of perjury unde State of that the foregoing is true and correct. 23 Dated: June i4 2020 24 25 ~K +KNUTHSON 26 27 28 PROOF OF SERVICE