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  • JMK Golf, LLC vs. Alessi, BetseyCivil-Roseville document preview
  • JMK Golf, LLC vs. Alessi, BetseyCivil-Roseville document preview
  • JMK Golf, LLC vs. Alessi, BetseyCivil-Roseville document preview
  • JMK Golf, LLC vs. Alessi, BetseyCivil-Roseville document preview
  • JMK Golf, LLC vs. Alessi, BetseyCivil-Roseville document preview
  • JMK Golf, LLC vs. Alessi, BetseyCivil-Roseville document preview
  • JMK Golf, LLC vs. Alessi, BetseyCivil-Roseville document preview
  • JMK Golf, LLC vs. Alessi, BetseyCivil-Roseville document preview
						
                                

Preview

ELECTRONICALLY FILED Superior Court of California, ERIC O. JEPPSON (STATE BAR NO. 212287) County of Placer ANNABEL H. CHANG (STATE BAR NO. 267261) 11/02/2020 JEPPSON & GRIFFIN, LLP By: Laurel Sanders, Deputy Clerk 1478 Stone Point Drive, Suite 100 Roseville, CA 95661 Telephone: (916) 780-7008 Facsimile: (916) 780-7118 Attorneys for Defendant BETSEY ALESSI SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF PLACER 10 UNLIMITED CIVIL JURISDICTION 11 —000- 12 JMK GOLF, LLC, a California limited Case No. S-CV-0043612 liability company, 13 DECLARATION OF ANNABEL H. Plaintiff, CHANG IN SUPPORT OF DEFENDANT 14 BETSEY ALESSI’S CROSS-MOTION Vv. FOR DETERMINATION OF 15 PREVAILING PARTY, ATTORNEY’S 16 BETSEY ALESSI aka BETSEY M. ALESSI FEES AND TO STRIKE PLAINTIFF’S aka BETSEY MARIE ALESSI, and DOES 1 COSTS AND IN OPPOSITION TO 17 to 10, inclusive, PLAINTIFF’S MOTION FOR AWARD OF REASONABLE ATTORNEY’S FEES 18 Defendants. 19 Date: December 3, 2020 20 Time: 8:30 a.m. Dept.: 3 21 Judge: Hon. Michael W. Jones 22 I, Annabel H. Chang, declare as follows: 23 1 I am over the age of eighteen years and have personal knowledge of the matters 24 stated herein, except as to those matters based on information and belief and, as to those matters, 25 I believe them to be true. If called as a witness I would and could competently attest thereto. 26 2 I am one of the attorneys of record for defendant Betsey Alessi (“Ms. Alessi”) in 27 this action. 28 3 I have been a California licensed attorney since 2009, and in the past 11 years, have 1 AHC DECLARATION ISO DEFENDANT ALESSI’S CROSS-MOTION FOR ATTORNEY’S FEES AND TO STRIKE PLAINTIFF’S COSTS AND OPPOSITION TO PLAINTIFF’S MOTION FOR AWARD OF ATTORNEY’S FEES prepared numerous matters for bench and jury trial both in state and federal courts. My current hourly rate for this matter is $325 per hour. 4 The partner overseeing this matter, Eric Jeppson, has been a California licensed attorney since 2001, and in the past 19 years has prepared and tried numerous bench and jury trials. His current hourly rate for this matter is $425 per hour. 5 I am familiar with the hourly rates charged by comparable litigation firms in the greater Sacramento area and the hourly rates charged for this matter were comparable with rates charged by other attorneys in California in similar law firms with similar experience and expertise. 6 The legal fees and costs incurred in this action were necessary, reasonable and 10 included, but were not limited to: (a) review, analysis of and response to the complaint; (b) 11 analysis, strategy and preparation of pleadings related to opposing Plaintiff's numerous attachment 12 attempts, and appearing at hearings; (c) communicating with Plaintiffs counsel in efforts to 13 resolve this action; (d) a reasonable amount of client meetings and communications; (e) responding 14 to Plaintiff's discovery; and (f) preparation and appearance at trial. Attached as Exhibit A and 15 Exhibit B are a true and correct printouts showing a breakdown of the legal fees, billed and 16 unbilled, which have been incurred in this action. The printouts are from the two separate 17 accounting systems used by Jeppson & Griffin, LLP. 18 7 I have expended 10.1 hours of my time totaling $3,470 in fees for preparing this 19 instant attorney fees motion, including legal research drafting, reviewing the client files, reviewing 20 the pleadings on file, meeting/communicating with the client, and anticipate expending at least 21 another 4-5 hours to review any opposition hereto, preparing a reply, and attending and arguing 22 this motion, at least another $1,530 in attorney fees will be incurred. 23 8 In total, Ms. Alessi requests an award of attorney fees against plaintiffs in the 24 amount of $48,464.44 ($43,021.44 fees to date + $443 costs + approx. $5,000 motion). 25 I declare under the penalty of perjury under the laws of the State of California that the 26 foregoing is true and correct. 27 /// 28 2 AHC DECLARATION ISO DEFENDANT ALESSI’S CROSS-MOTION FOR ATTORNEY’S FEES AND TO STRIKE PLAINTIFF’S COSTS AND OPPOSITION TO PLAINTIFF’S MOTION FOR AWARD OF ATTORNEY’S FEES Dated this 2nd day of November 2020 at Roseville, California. JL Annabel H. Chang 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 AHC DECLARATION ISO DEFENDANT ALESSI’S CROSS-MOTION FOR ATTORNEY’S FEES AND TO STRIKE PLAINTIFF’S COSTS AND OPPOSITION TO PLAINTIFF’S MOTION FOR AWARD OF ATTORNEY’S FEES EXHIBIT A Hunt Jeppson & Griffin, LLP 1478 Stone Point Drive, Suite 100 Roseville, CA 95661 Ph: (916) 780-7008 Fax:(916) 780-7118 Betsey Alessi November 2, 2020 Attention DATE DESCRIPTION HOURS AMOUNT LAWYER Sep-23-19 Initial consult with client regarding responding 1.00 425.00 EOJ to lawsuit Oct-09-19 NO CHARGE: Internal discussion and case 0.20 0.00 MCG strategy. Oct-10-19 Review verified complaint and draft verified 1.80 585.00 MCG answer. Oct-11-19 Final review of verified answer and take to 1.30 422.50 MCG court house for filing. Oct-16-19 NO CHARGE: Phone call with opposing 0.20 0.00 MCG counsel regarding upcoming writ of attachment. Oct-18-19 Correspondence from opposing counsel 0.40 170.00 EOJ regarding petition for attachment Oct-21-19 Research regarding status of Petition and 0.30 127.50 EOJ strategy in handling lawsuit Oct-22-19 Telephone conference with client regarding 0.40 170.00 EOJ Petition for Attachment and strategy regarding the same NO CHARGE: Review complaint and 1.40 0.00 AHC research and analysis re opposing writ of attachment; Telephone call to client Oct-23-19 Prepare for conference call with client by 1.00 300.00 AHC drafting memo outlining opposition and exemption; Telephone conference with client; Telephone conferences with opposing counsel Invoice #: Settle Page 2 November 2, 2020 Oct-24-19 Finalize response to opposing counsel; 0.40 170.00 EOJ research regarding same Research and analysis re settlement and 1.60 480.00 AHC damages Oct-28-19 Telephone conference with opposing counsel; 0.80 240.00 AHC Analysis of mitigation Oct-29-19 Email correspondence from opposing counsel 0.30 127.50 EOJ regarding Stipulation to deal with Petition for Attachment Analysis re mitigation of damages; Research 1.60 480.00 AHC re opposition to attachment Oct-31-19 Research re release of attachment 0.50 150.00 AHC Nov-04-19 Prepare financial statement form and email to 0.80 240.00 AHC client; Prepare and send email to opposing counsel Nov-06-19 Prepare opposition to application for 4.00 1,200.00 AHC attachment Nov-08-19 Analysis re opposition to application, 0.50 0.00 AHC Nov-11-19 Analysis re alternative damages with new 0.30 90.00 AHC lease Nov-13-19 Review and analysis of plaintiff's reply in 0.90 270.00 AHC support of attachment; Check tentative Nov-14-19 Strategy and research regarding motion to 0.60 255.00 EOJ attach and responding accordingly Attend hearing re attachment; Analysis re 2.50 737.50 AHC hearing and next steps Nov-15-19 Telephone call with client re hearing and 2.30 0.00 AHC further credits; Research and analysis re 998 offer, abuse of process claim Nov-19-19 Research and conference with Annabel 0.80 340.00 EOJ regarding denial of motion to attach; Research and strategy regarding same Analysis re next steps 0.50 147.50 AHC Nov-22-19 Follow up call to client 0.20 59.00 AHC Nov-25-19 Conference with Annabel regarding a second 0.30 127.50 EOJ motion to attach from plaintiff; research regarding same Invoice #: Settle Page 3 November 2, 2020 Analysis re ex parte writ of attachment 2.70 796.50 AHC Nov-26-19 Further research regarding write of attachment 0.40 170.00 EOJ and strategy in handling Meeting with client 0.70 297.50 EOJ Appear at ex parte hearing; Analysis re case 2.00 590.00 AHC Dec-16-19 Research issues related to yet another 0.40 170.00 EOJ attachment motion; strategy regarding moving this case to the finish line Dec-17-19 Prepare opposition to attachment 0.90 265.50 AHC Dec-20-19 Finalize opposition to attachment 1.40 413.00 AHC Dec-26-19 Prepare draft demand letter 0.50 147.50 AHC Dec-30-19 Prepare demand letter and CCP 998 offer 1.60 472.00 AHC Dec-31-19 Interest Due on Amounts Outstanding for 30 0.00 144.43 EOJ Days or more. Jan-03-20 Review and analysis of plaintiff's reply for 0.80 236.00 AHC application; Research re same Jan-23-20 Telephone conference with AHC regarding 0.30 127.50 EOJ tentative ruling on hearing for Attachment Request by plaintiffto determine opposition and requesting oral argument Review tentative ruling and analysis re 0.50 147.50 AHC contesting ruling Jan-24-20 Prepare for and attend hearing on attachment 2.40 708.00 AHC Jan-27-20 Research results of Attachment Hearing and 0.30 127.50 EOJ strategy related to resolution Analysis re hearing and next steps; Call client 0.70 206.50 AHC and prepare and send follow up email Jan-28-20 Call with client re case status and set meeting; 0.70 0.00 AHC Prepare and send follow up email re same Jan-29-20 Meeting with client with update and approach 1.00 425.00 EOJ to strategy for remainder of case NO CHARGE: Meeting with client re case 1.00 0.00 AHC status and next steps Invoice #: Settle Page 4 November 2, 2020 Jan-31-20 Interest Due on Amounts Outstanding for 30 168.62 EOJ Days or more. Feb-04-20 Telephone conference with Michelle Marden 0.40 170.00 EOJ to obtain information and insight from her about opposing party and opposing counsel Feb-29-20 Interest Charge 201.20 EOJ Mar-10-20 Contact client regarding status of case and 0.20 59.00 AHC attachment Mar-20-20 Prepare letter to client re next steps 1.20 354.00 AHC Mar-31-20 Interest Charge 0.00 206.77 EOJ Totals 47.00 $13,918.02 DISBURSEMENTS Oct-10-19 Placer County Superior Court; Filing fee: 435.00 Answer Nov-06-19 Federal Express: overnight delivery to Richard 25.74 Gray Dec-24-19 Federal Express: overnight delivery to: The 25.68 Law Offices of Richard Gray Totals $486.42 Total Fees & Disbursements $14,404.44 Transferred from Trust $0.00 Previous Balance $14,404.44 Previous Payments $0.00 Balance Due Now $28,808.88 EXHIBIT B Client Activity Report (11/02/2020) Betsey Alessi 1857-001: Defend Complaint to collect unpaid rent (Eric Jeppson) Date Status User Description Note Quantity Price Total Billed Eric Altention to email correspondence from opposing counsel, ick 0.40 $425.00 $170.00 09/21/2020 Jeppson Gray, regarding proposed judgment Billed Eric Finalize proposed judgment and correspondence to opposing 0.30 $425.00 $127.50 09/18/2020 Jeppson counsel regarding same Billed Eric Attention to revisions to Proposed Judgment 0.30 $425.00 $127.50 09/17/2020 Jeppson Billed Annabel Prepare revisions to proposed judgment and draft email to R. Gray 0.50 $295.00 $147.50 09/17/2020 Chang Billed Eric Receive email correspondence from opposing counsel regarding 0.80 $425.00 $340.00 09/16/2020 Jeppson Proposed Judgment for our review; Billed Annabel Review proposed judgment from R. Gray; Research re requirements 1.20 $295.00 $354.00 09/16/2020 Chang re parties’ signatures to judgment; Prepare revisions to judgment Billed Annabel Review and analysis of revised statement of decision from court 0.50 $295.00 $147.50 09/14/2020 Chang Billed Eric Telephone conference with opposing counsel, Dick Gray, regarding 0.30 $425.00 $127.50 09/11/2020 Jeppson proposed judgment from court; Reveiw and research court's statement of decision regarding same Billed Annabel Review local rules to determine filing requirements; Analysis with E. 0.90 $295.00 $265.50 09/01/2020 Chang Jeppson re next steps; Prepare letter to judge re objections Billed Eric Attention to Court's Ruling and attorneys’ fees issue 0.80 $425.00 $340.00 09/01/2020 Jeppson Billed Barb Filing fees incurred filing letter with the Court regarding 1,00 $3.95 $3.95 09/01/2020 Taylor Administrative Oversight. Billed Barb Fees relating to the filing of Defendant's Objections to Plaintiffs 1.00 $3.95 $3.95, 08/26/2020 Taylor Objections to Proposed Statement of Decision Billed Eric Revise and finalize Objections to JMK’s objections to Proposed 0.40 $425.00 $170.00 08/25/2020 Jeppson Decision Billed Annabel Prepare objections to Plaintiff's objections to proposed statement of 2.60 $295.00 $767.00 08/25/2020 Chang decision; Review revisions and finalize objections 115 Billed Annabel Review plaintiff's objections to proposed statement of decision; 0.70 $295.00 $206.50 08/21/2020 Chang Research re procedure; Billed Eric Attention to objections filed by opposing counsel; research regarding 0.30 $425.00 $127.50 08/21/2020 Jeppson same Billed Eric Attention to objections plaintiff's counsel filed with court regarding 0.40 $425.00 $170.00 08/20/2020 Jeppson order and research regarding same; Strategy about closing out this case and filing attorneys fee motion Billed Annabel Review of court's judgment for prevailing party determination; 1.20 $295.00 $354.00 08/19/2020 Chang Analysis re motion for attorney fees Billed Annabel Review tentative decision from court; Prepare and send email to 1.00 $295.00 $295.00 08/13/2020 Chang client reporting; Analysis re timing for proposed judgment and motion for attorney fees Billed Eric Attention to correspondence from escrow company; telephone 1.20 $425.00 $510.00 08/10/2020 Jeppson conference with client; telephone message to Dick Gray and email correspondence regarding Release of Attachment Lien; Telephone conference with client regarding same Billed Annabel Prepare draft email re agreementto hold attachment proceeds in 0.40 $295.00 $118.00 08/10/2020 Chang trust Billed Annabel Prepare memo re attachment lien and payoff demand issue 2.10 $295.00 $619.50 08/09/2020 Chang Billed Eric Telephone conference with client and title company on the close of 0.40 $425.00 $170.00 08/07/2020 Jeppson her personal residence regarding payoff demand from plaintiff Billed Annabel NO CHARGE: Telephone call from client re sale of home, trial 0.30 $0.00 $0.00 07/28/2020 Chang update and liquor license sale Billed Eric Attend Trial 6.00 $425.00 $2,550.00 07/17/2020 Jeppson Billed Annabel Prepare trial brief, exhibit list, statement of case; Analysis with E. 5.40 $295.00 $1,593.00 07/16/2020 Chang Jeppson re mitigation issues; Research re mitigation credit for delayed replacement lease Billed Susan Review exhibits and prepare trial binders. 3.30 $125.00 $412.50 07/16/2020 Heu Billed Eric Prepare for trial 2.50 $425.00 $1,062.50 07/16/2020 Jeppson Billed Annabel Analysis with B. Taylor re remote appearance for trial 0.10 $295.00 $29.50 07/15/2020 Chang Billed Annabel Analysis re factual or legal issues remaining for trial and prepare 2.20 $295.00 $649.00 07/14/2020 Chang memo re same Billed Eric Attention to trial preparation 1.20 $425.00 $510.00 07/14/2020 Jeppson 2/5 Billed Eric Telephone conference with client regarding settlement; Continue 2.90 $425.00 $1,232.50 07/10/2020 Jeppson correspondence and negotiations with opposing counsel; Continue negotiations with replacement tenant for sale of liquor license. Billed Annabel Review and analysis of plaintiff's damages calculations for purposes 1.40 $295.00 $413.00 07/09/2020 Chang of settlement; Analysis with E. Jeppson re settlement; Research re mitigation of damages Billed Eric Telephone conference with Dick Gray negotiating settlement; 3.20 $425.00 $1,360.00 07/09/2020 Jeppson Research regarding same Billed Eric Attention to response letter for negotiating settlement; Telephone 1,80 $425.00 $765.00 07/08/2020 Jeppson conference with Rod Dennis, attorney for replacement tenant, regarding liquor license transfer Billed Annabel Review lease to confirm commission amounts; Analysis re difference 1.10 $295.00 $324.50 07/08/2020 Chang between leases; Revise response to R. Gray re settlement Billed Susan Continue batestamp and mark discovery document production to 0.20 $125.00 $25.00 07/08/2020 Heu identify with the specific request number to which to the documents respond Billed Annabel Analysis re trial-related deadlines and prepare notice to appear, 4.10 $295.00 $1,209.50 07/07/2020 Chang Review settlement response and prepare response to R. Gray Billed Eric Telephone conference with Tamara, general manager of 0.80 $425.00 $340.00 07/07/2020 Jeppson replacement tenant, regarding liquor license; Telephone conference with opposing counsel, Dick Gray, regarding negotiations to settle Billed Eric Attention to possible settlement and stipulations to avoid trial 1.40 $425.00 $595.00 07/06/2020 Jeppson readiness; Telephone conference with opposing counsel regarding same and negotiate resolution; research regarding same and strategy of trial readiness issues Billed Susan Batestamp and mark discovery document production to identify with 0.50 $125.00 $62.50 07/06/2020 Heu the specific request number to which to the documents respond Billed Annabel Further prepare memo on mitigation of damages, settlement, 2.90 $295.00 $855.50 07/06/2020 Chang damages calculation; Analysis with E. Jeppson re next steps; Call to ABC re portability of liquor license; Call with R. Gray re settlement Billed Annabel Finalize discovery responses for service to JMK 0.30 $295.00 $88.50 06/26/2020 Chang Billed Eric Attention to discovery responses and strategy of settling this case 0.40 $425.00 $170.00 06/25/2020 Jeppson Billed Annabel Finalize responses and verifications and email to client 1.30 $295.00 $383.50 06/25/2020 Chang Billed Annabel Further draft responses to form and special interrogatories, requests 4.80 $295.00 $1,416.00 06/24/2020 Chang for admission Billed Annabel Further draft responses to special and form interrogatories, requests 2.00 $295.00 $590.00 06/23/2020 Chang for admission, request for production of documents Billed Annabel Analysis with E. Jeppson re discovery, next steps; Check court 3.50 $295.00 $1,032.50 06/22/2020 Chang website re continuance; Draft responses to form and special interrogatories, requests for admission 3/5 Billed Eric Research regarding damages claim and how to work towards a 1.40 $425.00 $595.00 06/22/2020 Jeppson resolution in an attempt to find a resolution and take matter off calendar and settle Billed Eric NO CHARGE: Visit with client at her home to discuss status of case, 0.80 $0.00 $0.00 06/19/2020 Jeppson discovery responses and strategy moving forward Billed Eric Attention to matter regarding discovery and trial preparation 0.20 $425.00 $85.00 06/15/2020 Jeppson Billed Annabel Draft responses to special interrogatories 1,50 $295.00 $442.50 06/03/2020 Chang Billed Annabel Prepare and send email to OPC re extension of time for discovery 0.40 $295.00 $118.00 05/22/2020 Chang responses Billed Eric Follow up research and attention to matter for discovery and 0.20 $425.00 $85.00 05/18/2020 Jeppson determination of withdrawing from the case Billed Annabel Confirm Placer Court rules re trials and related deadlines; Respond 0.40 $295.00 $118.00 05/06/2020 Chang to B. Taylor's email re same Billed Annabel Prepare and send email to client; Follow up call 0.20 $295.00 $59.00 05/04/2020 Chang Billed Annabel Review discovery requests from plaintiff; Analysis re next steps and 1.30 $295.00 $383.50 04/24/2020 Chang attempt to contact client; Research re calculation of landlord's damages Billed Eric Balance carried forward from previous billing software 1.00 $14,404.44 $14,404.44 03/31/2020 Jeppson Billed Total: 77.70 hours, $39,622.34 Unbilled Annabel Prepare and finalize declaration in support of motion for attorney's 1.20 $295.00 $354.00 11/02/2020 Chang fees Unbilled Annabel Review and further revise motion for attorney's fees; Research re 1.10 $295.00 $324.50 10/30/2020 Chang same Unbilled Eric Attention to Motion for Attorney Fees 0.40 $425.00 $170.00 10/30/2020 Jeppson Unbilled Annabel Prepare motion and opposition re prevailing party attorney fees 1.90 $295.00 $560.50 10/29/2020 Chang Unbilled Annabel Prepare motion and opposition re prevailing party attorney fees 2.30 $295.00 $678.50 10/28/2020 Chang Unbilled Eric Attention to Motion for Attomeys' Fees 0.30 $425.00 $127.50 10/27/2020 Jeppson Unbilled Annabel Call with R. Gray re rescheduling motion hearing; Analysis re same 0.50 $295.00 $147.50 10/27/2020 Chang 4/5 Unbilled Annabel Prepare motion for attorney's fees 1.00 $295.00 $295.00 10/14/2020 Chang Unbilled Barb Drafted Costs Memorandum Worksheet and Summary. 0.50 $75.00 $37.50 10/13/2020 Taylor Unbilled Eric Attend hearing on OSC for Proposed Judgment 2.30 $425.00 $977.50 10/02/2020 Jeppson Unbilled Annabel Review court's tentative ruling re OSC and check court docket 0.30 $295.00 $88.50 10/01/2020 Chang Unbilled Total: 11.80 hours, $3,761.00 Matter Total: 89.50 hours, $43,383.34 Client Total: 89.50 hours, $43,383.34 Total: 89.50 hours, $43,383.34 5/5 PROOF OF SERVICE CASE TITLE: JMK Golf LLC v. Betsey Alessi, et al. Court: Placer County Superior Court CASE No.: S-CV-0043612 Iam a citizen of the United States, and I am employed in Placer County, State of California. My business address is 1478 Stone Point Drive, Suite 100, Roseville, CA 95661. I am over the age of 18 years and not a party to the above-entitled action. I am familiar with JEPPSON & GRIFFIN, LLP’S office practice whereby the mail is sealed, given the appropriate postage and placed in a designated mail collection area. Each day’s mail is collected and deposited in the U.S. mailbox after the close of each day’s business. On November 2, 2020, I served the following: DECLARATION OF ANNABEL H. CHANG IN SUPPORT OF DEFENDANT BETSEY ALESSI’S CROSS-MOTION FOR DETERMINATION OF PREVAILING PARTY, 10 ATTORNEY’S FEES AND TO STRIKE PLAINTIFF’S COSTS AND IN OPPOSITION TO PLAINTIFF’S MOTION FOR AWARD OF REASONABLE ATTORNEY’S FEES 1 Mon the party(ies) in this action by causing a true copy(ies) thereofto be placed in a sealed 12 envelope with postage thereon fully prepaid and deposited in the designated area for outgoing U.S. Mail addressed as follows: 13 14 on the party(ies) in this action by causing a true copy(ies) thereof to be delivered by hand as follows: 15 on the party(ies) in this action by causing a true copy(ies) thereof to be delivered by 16 Overnight Delivery in a sealed envelope(s) with receipts affixed thereto promising overnight delivery thereof addressed as follows: 17 18 on the party(ies) in this action by causing a true copy(ies) thereof to be delivered by electronic transmission at the email address below: 19 Richard H. Gray 20 Law Office of Richard H. Gray 1500 River Park Drive, Suite 115-B 21 Sacramento, CA 95815-4607 22 Ph: (916) 929-7730 F (916) 929-8967 23 Email: rhg@rgraylawoffice.com 24 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration is executed on November 2, 2020, at 25 Roseville, California. 26 Dinh typ 27 28 BARB TAYLOR PROOF OF SERVICE