Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
Nick C. Geannacopulos (SBN 114822) Tiffany Tran Madison (SBN 294213)
Seyfarth Shaw LLP Seyfarth Shaw LLP
560 Mission Street, 31st Floor 400 Capitol Mall, Suite 2350
San Francisco, CA 94105 Sacramento, CA 95814
TELEPHONE NO.: 415-397-2823 / 916-448-0159 FAX NO. (Optional):
E-MAIL ADDRESS (Optional):
MATHEWS READYMIX, LLD and NICHOLAS STEINBERG
ATTORNEY FOR (Name): 12/21/2020
SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE
STREET ADDRESS: 1775 Concord Avenue
MAILING ADDRESS:
Chico, CA
CITY AND ZIP CODE: 95928
BRANCH NAME:North Butte County Courthouse
PLAINTIFF/PETITIONER: JAIME COTA
DEFENDANT/RESPONDENT: NICHOLAS STEINBERG; MATHEWS READYMIX,
LLC
CASE MANAGEMENT STATEMENT CASE NUMBER:
20CV00853
(Check one): UNLIMITED CASE LIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: January 6, 2021 Time: 10:30 a.m. Dept.: 10 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Tiffany Tran Madison
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. This statement is submitted by party (name):
b. This statement is submitted jointly by parties (names): Nicholas Steinberg and Mathews Readymix, LLC
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. 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
(1) have not been served (specify names and explain why not):
(2) have been served but have not appeared and have not been dismissed (specify names):
(3) have had a default entered against them (specify names):
c. 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 complaint cross-complaint (Describe, including causes of action):
Plaintiff alleges he experienced discrimination, harassment and retaliation in the workplace. Plaintiff also alleges
he did not receive meal or rest periods and that he was entitled to a prevailing wage.
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California
CASE MANAGEMENT STATEMENT rules 3.720–3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
67246394v.1 American LegalNet, Inc.
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CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: JAIME COTA
20CV00853
DEFENDANT/RESPONDENT: NICHOLAS STEINBERG; MATHEWS READYMIX, LLC
LLC
4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff alleges he experienced race/ancestry and disability discrimination and harassment, and that he was
retaliated against for reporting the alleged harassment and discrimination. Plaintiff seeks compensatory damages,
emotional distress damages, punitive damages, and attorney’s fees and costs. Plaintiff also alleges he did not
receive meal or rest periods and that he was entitled to a prevailing wage and seeks unpaid meal and rest period
premiums and unpaid wages. Defendants deny Plaintiff’s allegations and that Plaintiff is entitled to any relief.
whatsoever.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request a jury trial a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. The trial has been set for (date):
b. No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain): Due to the COVID-19 pandemic, Defendants believe this case will require more than 12 months
to be ready for trial.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 8-10
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial 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. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
9. 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 has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is subject 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
Civil Procedure section 1141.11.
(3) 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):
Cal. Rules of Court 3.811 subsections (a)(2) and (b)(8).
CM-110 [Rev. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
67246394v.1 American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: JAIME COTA
20CV00853
DEFENDANT/RESPONDENT: NICHOLAS STEINBERG; MATHEWS READYMIX, LLC
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):
Mediation session not yet scheduled
Mediation session scheduled for (date): January 22, 2021
(1) Mediation
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
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
67246394v.1 American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: JAIME COTA
20CV00853
DEFENDANT/RESPONDENT: NICHOLAS STEINBERG; MATHEWS READYMIX, LLC
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes 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.
Bankruptcy Other (specify):
Status:
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. A motion to consolidate coordinate wiII be filed by (name party):
14. Bifurcation
The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motions to compel discovery and motion for summary judgment, if warranted, and motions in limine.
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
Defendants Plaintiff’s Deposition March 2021
Defendants Further Written Discovery April 2021
Defendants Expert Discovery Per Code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011] Page 4 of 5
CASE MANAGEMENT STATEMENT
67246394v.1 American LegalNet, Inc.
www.FormsWorkFlow.com
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: JAIME COTA
20CV00853
DEFENDANT/RESPONDENT: NICHOLAS STEINBERG; MATHEWS READYMIX, LLC
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. 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
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. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of
Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any):
I am 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.
Date: December 21, 2020
Tiffany Tran Madison
(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. July 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
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1 PROOF OF SERVICE
2 I am a resident of the State of California, over the age of eighteen years, and not a party to the
within action. My business address is 400 Capitol Mall, Suite 2350, Sacramento, California 95814-
3 4428. On December 21, 2020 served the within document(s):
4 DEFENDANT MATHEWS READYMIX, LLC AND NICHOLAS STEINBERG’S CASE
MANAGEMENT STATEMENT
5
by placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid,
6 in the United States mail at Sacramento, California, addressed as set forth below.
7 by personally delivering the document(s) listed above to the person(s) at the address(es) set forth
below.
8
by placing the document(s) listed above, together with an unsigned copy of this declaration, in a
9 sealed envelope or package provided by an overnight delivery carrier with postage paid on
account and deposited for collection with the overnight carrier at Sacramento, California,
10 addressed as set forth below.
11 by transmitting the document(s) listed above, electronically, via the e-mail addresses set forth
below.
12
Nicole B. Reimer Attorneys for Plaintiff
13 Reimer Law, PC
313 Walnut Street, Suite 120
14 Tel: (530) 898-1111
Chico, CA 95928
15 nbreimer.esq.@gmail.com
16
I am readily familiar with the firm's practice of collection and processing correspondence for
17 mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day with
postage thereon fully prepaid in the ordinary course of business. I am aware that on motion of the party
18 served, service is presumed invalid if postal cancellation date or postage meter date is more than one day
after date of deposit for mailing in affidavit.
19
I declare under penalty of perjury under the laws of the State of California that the above is true
20 and correct.
21 Executed on December 21, 2020, at Sacramento, California.
22
23
Crystal Holman
24
25
26
27
28
PROOF OF SERVICE
64500968v.1
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CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Nick C. Geannacopulos (SBN 114822) Tiffany Tran Madison (SBN 294213) Seyfarth Shaw LLP Seyfarth Shaw LLP 560 Mission Street, 31st Floor 400 Capitol Mall, Suite 2350 San Francisco, CA 94105 Sacramento, CA 95814 TELEPHONE NO.: 415-397-2823 / 916-448-0159 FAX NO. (Optional): E-MAIL ADDRESS (Optional): MATHEWS READYMIX, LLD and NICHOLAS STEINBERG ATTORNEY FOR (Name): 12/21/2020 SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE STREET ADDRESS: 1775 Concord Avenue MAILING ADDRESS: Chico, CA CITY AND ZIP CODE: 95928 BRANCH NAME:North Butte County Courthouse PLAINTIFF/PETITIONER: JAIME COTA DEFENDANT/RESPONDENT: NICHOLAS STEINBERG; MATHEWS READYMIX, LLC CASE MANAGEMENT STATEMENT CASE NUMBER: 20CV00853 (Check one): UNLIMITED CASE LIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: January 6, 2021 Time: 10:30 a.m. Dept.: 10 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Tiffany Tran Madison INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): b. This statement is submitted jointly by parties (names): Nicholas Steinberg and Mathews Readymix, LLC 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. 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 (1) have not been served (specify names and explain why not): (2) have been served but have not appeared and have not been dismissed (specify names): (3) have had a default entered against them (specify names): c. 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 complaint cross-complaint (Describe, including causes of action): Plaintiff alleges he experienced discrimination, harassment and retaliation in the workplace. Plaintiff also alleges he did not receive meal or rest periods and that he was entitled to a prevailing wage. Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov 67246394v.1 American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: JAIME COTA 20CV00853 DEFENDANT/RESPONDENT: NICHOLAS STEINBERG; MATHEWS READYMIX, LLC LLC 4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff alleges he experienced race/ancestry and disability discrimination and harassment, and that he was retaliated against for reporting the alleged harassment and discrimination. Plaintiff seeks compensatory damages, emotional distress damages, punitive damages, and attorney’s fees and costs. Plaintiff also alleges he did not receive meal or rest periods and that he was entitled to a prevailing wage and seeks unpaid meal and rest period premiums and unpaid wages. Defendants deny Plaintiff’s allegations and that Plaintiff is entitled to any relief. whatsoever. (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request a jury trial a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. The trial has been set for (date): b. No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): Due to the COVID-19 pandemic, Defendants believe this case will require more than 12 months to be ready for trial. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 8-10 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial 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. E-mail address: g. Party represented: Additional representation is described in Attachment 8. 9. 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 has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) This matter is subject 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 Civil Procedure section 1141.11. (3) 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): Cal. Rules of Court 3.811 subsections (a)(2) and (b)(8). CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT 67246394v.1 American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: JAIME COTA 20CV00853 DEFENDANT/RESPONDENT: NICHOLAS STEINBERG; MATHEWS READYMIX, LLC 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): Mediation session not yet scheduled Mediation session scheduled for (date): January 22, 2021 (1) Mediation 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 (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT 67246394v.1 American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: JAIME COTA 20CV00853 DEFENDANT/RESPONDENT: NICHOLAS STEINBERG; MATHEWS READYMIX, LLC 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes 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. Bankruptcy Other (specify): Status: 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. A motion to consolidate coordinate wiII be filed by (name party): 14. Bifurcation The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Motions to compel discovery and motion for summary judgment, if warranted, and motions in limine. 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 Defendants Plaintiff’s Deposition March 2021 Defendants Further Written Discovery April 2021 Defendants Expert Discovery Per Code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT 67246394v.1 American LegalNet, Inc. www.FormsWorkFlow.com CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: JAIME COTA 20CV00853 DEFENDANT/RESPONDENT: NICHOLAS STEINBERG; MATHEWS READYMIX, LLC 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. 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 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. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): I am 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. Date: December 21, 2020 Tiffany Tran Madison (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. July 1, 2011] Page 5 of 5 CASE MANAGEMENT STATEMENT 67246394v.1 American LegalNet, Inc. www.FormsWorkFlow.com 1 PROOF OF SERVICE 2 I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is 400 Capitol Mall, Suite 2350, Sacramento, California 95814- 3 4428. On December 21, 2020 served the within document(s): 4 DEFENDANT MATHEWS READYMIX, LLC AND NICHOLAS STEINBERG’S CASE MANAGEMENT STATEMENT 5 by placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid, 6 in the United States mail at Sacramento, California, addressed as set forth below. 7 by personally delivering the document(s) listed above to the person(s) at the address(es) set forth below. 8 by placing the document(s) listed above, together with an unsigned copy of this declaration, in a 9 sealed envelope or package provided by an overnight delivery carrier with postage paid on account and deposited for collection with the overnight carrier at Sacramento, California, 10 addressed as set forth below. 11 by transmitting the document(s) listed above, electronically, via the e-mail addresses set forth below. 12 Nicole B. Reimer Attorneys for Plaintiff 13 Reimer Law, PC 313 Walnut Street, Suite 120 14 Tel: (530) 898-1111 Chico, CA 95928 15 nbreimer.esq.@gmail.com 16 I am readily familiar with the firm's practice of collection and processing correspondence for 17 mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I am aware that on motion of the party 18 served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. 19 I declare under penalty of perjury under the laws of the State of California that the above is true 20 and correct. 21 Executed on December 21, 2020, at Sacramento, California. 22 23 Crystal Holman 24 25 26 27 28 PROOF OF SERVICE 64500968v.1