On December 12, 2019 a
Party Statement
was filed
involving a dispute between
Nph Medical Services,
Nph Medical Services, Inc,
and
Chico Healthcare And Wellness Centre, Lp,
Chico Healthcare & Wellness Centre, Llc,
Chico Heights Rehabilitation And Wellness, Lp,
Chico Heights Rehabilitation & Wellness Centre, Llc,
Chico Heights Wellness Gp, Llc,
Chico Wellness Gp, Llc,
Eureka Rehabilitation And Wellness Center, Lp,
Eureka Rehabilitation & Wellness Center, Llc,
Eureka Wellness, Gp, Llc,
Fortuna Rehabilitation And Wellness Center, Lp,
Fortuna Rehabilitation & Wellness Center, Llc,
Fortuna Wellness Gp, Llc,
Granada Rehabilitation And Wellness Center, Lp,
Granada Rehabilitation & Wellness Center, Llc,
Granada Wellness Gp, Llc,
Rechnitz, Schlomo,
Rockport Administrative Services, Llc,
Schlomo Rechnitz As Managing General Partner Of Chico Heights Wellness Gp, Llc, Eureka Wellness, Gp, Llc; Fortuna Wellness Gp, Llc; And Granada Wellness Gp, Llc,
Steven Stroll As Managing Member Of Rockport Administrative Services, Llc,
Stroll, Steven,
Windsor Redding Care Center, Llc,
for (06) Unlimited Breach of Contract/Warranty
in the District Court of Butte County.
Preview
CM—110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar number, and address): FOR COURT USE ONLY
SBN 054922
LES HAIT, ESQ.
LES HAIT LAW CORPORATION
762 East Ave., Chico, CA 95926 Superb! Gaunt of California
TELEPHONE N0;(530) 895-3352
F F
(530) 895-0401
FAX No. (Optional):
Gumtr- uf Bum
EMAILADDRESS (Optional): leshaitlaw@gmail.com I I
ATTORNEYFORWame): NPH MEDICAL SERVICES, Plaintiff L 12/29/2020 L
SUPERIOR COURT 0F CALIFORNIA, COUNTY OF BUTTE
STREETAOOREss;1775 Concord Ave. E E
MAILING ADDRESS: same D Ki Brief D
BRANCH NAME:
Chico, CA 95928
CITY AND ZIP CODE:
By
MV'FILED
my
North Butte County
PLAINTIFF/PETITIONER: NPH MEDICAL SERVICES Late Filed
DEFENDANT/RESPONDENT: ROCKPORT, et aI.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE E LIMITED CASE 190V03695
(Amount demanded (Amount demanded is $25,000
exceeds $25.000) or less)
A CASE MANAGEMENT CONFERENCE Isscheduled as follows:
Date: January 13, 2021 Time: 10:30 a.m. Dept: Mosbarger Div.: Civil Room: TBA
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Les Hail
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. Plaintiff, NPH MEDICAL
This statement is submitted by party (name): SERVICES
b. E This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
December 12, 201 9
b. E] The cross-complaint, if any, was led
on (dale):
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. [j The following parties named in the complaint or cross-complaint
(1) D 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) E have had a default entered against them (specify names):
c. D 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 0f 0859 In complaint E cross~complaint (Describe, including causes of action):
Breach of Contract and Common Counts, wherein Defendants failed to pay $452,354.50 principal, owed to
Plaintiff after requested and approved services were completed and invoiced to Defendants.
Page1of 5
Form Adopted for Mandatory Use
Judicial Council of California
CASE MANAGEMENT STATEMENT Cale Rules of Court,
rules 3720—1730
CMA1 1 0 (Rev. July 1, 201 1] www.courtscagov
CM-110
”SF-NUMBER:
-—
PLAINTtFF/PETITIONER: NPH MEDICAL SERVICES
190v03695
DEFENDANT/RESPONDENT: ROCKPORT. et al.
4. b. Provide a brief statement of the case, including any damages. (prersonal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
eamings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
This is a civii matter wherein the parties signed contracts, and Defendant facilities, managed by Defendant,
Rockport, were consistently paying Plaintiff for services they requested in writing, completed and invoiced. Then,
suddenly and without notice, Defendant facilities,managed by Defendant, Rockport, abruptly stopped paying
invoices. Defendants owe $452,354.50 of outstanding invoices.
E (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 triai a nonjury trial. (lfmore than one party, provide the name ofeach party
requesting a jury tn'al):
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 ling
of the complaint (if
not, explain):
It could be ready for trial in 6 months it we receive Defendants' cooperation.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
none at this time
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 2'3
b. hours (short causes) (specif:
8. Trial representation (to be answered for each party)
m
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
inAttachment 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 D 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 m has not reviewed theADR information package identifiedinrule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is sub'ect to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified
inCode of
Civil Procedure section 1141 .1 1.
(3){:3 This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM-110 (Rev. July
1,2011]
CASE MANAGEMENT STATEMENT Page Zof
CM-110
CASE NUMBER:
a PLAINTIFF/PETITIONER: NPH MEDICAL SERVICES
DEFENDANT/RESPONDENT: 190V03695
ROCKFORT, et a}.
10. c. ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
Indicate the
have already participated in (check all that apply and provide the specied
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 ADRindicate the status of the processes (attach a copy of the parties'ADR
processes (check all that apply):
stipulation):
BEBE]
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date):12/28/2020
DUDE
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):
BUDD
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):
DUDE
Judicial arbitration not yet scheduled
Judicial arbitration scheduled for (date):
(4) Nonbinding judicial
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
DUDE
Private arbitration not yet scheduled
Private arbitration scheduled for (date):
(5) Binding private
arbitration '
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
DUDE
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-11o (Rev. July
1, 201 1] Page3of 5
CASE MANAGEMENT STATEMENT
cm
CASENUMBER:
PLANTIFF/PETIT‘ONER: NPH MEDICAL SERVICES
1QCV03695
DEFENDANT/RESPONDENT: ROCKPORT, et al.
11. Insurance
a. E] Insurance carrier, if any, for party ling
this statement (name):
b. Reservation of rights: D Yes [:1 No
c. E Coverage issues wili 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.
[:3 Bankruptcy EV
Other (specify):
Status:
13. Relatedcases, consolidation, and coordination
a. E] There are companion. underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
D Additional casesare described in Attachment 1 3a.
b. E A motion to consolidate coordinate wili be filed by (name party):
14. Bifurcation
1:3 The party or parties intend to le
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 ofmotion, and issues):
Discovery motions, due to the complete non-cooperation of Defendants, for the production of records
supporting their claims in the Cross—Complaint.
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
Plaintiff Depositions with Production of Documents of February 2021
Defendants‘ representatives
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Plaintiff will need to propound extensive written discovery including depositions with document production on
’
representatives of each Defendant.
CM-110[Rev.July1,2011] CASE MANAGEMENT STATEMENT Page4of5
CM-110
PLAINTIFF/PETIT‘ONER: NPH MEDICAL SERVICES CASE ”UMBER:
190V03695
DEFENDANT/RESPONDENT: ROCKFORT: 9t al-
17. Economic litigation
a, E This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures
of Civil Procedure sections 90—98 will apply to this case.
in Code
b.D 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 specically
why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
m 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):
Mediation was conducted by Zoom on December 28, 2020, by Mediator, Melissa Aliotti, but was
unsuccessful.
20. Total number of pages attached (if any): 0
|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 2?? ,2020
Les Hait
(TYPE OR PRINT NAME) %IGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-WIREV-Ju'v 1-201” CASE MANAGEMENT STATEMENT WW
LAW OFFICE PROOF OF SERVICE
I am a citizen of the United States and employedm Butte County, I am over the age of
eighteen (18) years and not a party to the withi action, my business address is 762 East
Avenue, Chico, California 95926, I served the person(s) named below, at the address(es) set
forth, the within:
CASE MANAGEMENT STATEMENT
by placing a true copy thereof enclosed in a sealed envelope with postage fully
prepaid and either
(a) ______
depositing the sealed envelope with the United States Postal Service, or,
(b) _____
placing the envelope or box for collection and mailing on the date shown
below and at the place shown below following our ordinary business’ practice
for collecting and processing correspondence for mailing. On the same day that
correspondence is placed for collection and mailing, it is deposited in the
lO
ordinary course of business with the United States Postal Service in a sealed
ll envelope with postage fully prepaid.
by transmission Via Facsimile of a true, correct and complete copy of said
12 document(s) to the following parties on the date shown below at the fax number
designated below.
l3 X by transmission Via E-Mail of a true, correct and complete copy of said
document(s) to the following parties on the date shown below at the email
14
address provided by the party(ies).
15 ______
by personal delivery
l6 Name(s) and address(es) of person(s) served:
l7
Vinay Kohli
18 King 8: Spalding
633 West Fifth Street, Ste. 1600
l9 Los Angeles, CA 90071
Email: vkohli@kslaw.com
20 Cc: pnewler@kslaw.com
21
22 I declare under penalty of perjury under the laws of the State of C ifornia that
'
the foregoing is true and correct. Executed at Chico, California, on Dec 2020.
23
24
25
C WQMV
Claire Ramsey
26
27
28
LAW OFFICES OF
LES HAIT
A Prufessimml Corporation
762 EAST AVENUE
CHlCO, CALIFORNIA 95926 1
(530) 895—3352
PROOF OF SERVICE
Preview
CM—110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar number, and address): FOR COURT USE ONLY SBN 054922 LES HAIT, ESQ. LES HAIT LAW CORPORATION 762 East Ave., Chico, CA 95926 Superb! Gaunt of California TELEPHONE N0;(530) 895-3352 F F (530) 895-0401 FAX No. (Optional): Gumtr- uf Bum EMAILADDRESS (Optional): leshaitlaw@gmail.com I I ATTORNEYFORWame): NPH MEDICAL SERVICES, Plaintiff L 12/29/2020 L SUPERIOR COURT 0F CALIFORNIA, COUNTY OF BUTTE STREETAOOREss;1775 Concord Ave. E E MAILING ADDRESS: same D Ki Brief D BRANCH NAME: Chico, CA 95928 CITY AND ZIP CODE: By MV'FILED my North Butte County PLAINTIFF/PETITIONER: NPH MEDICAL SERVICES Late Filed DEFENDANT/RESPONDENT: ROCKPORT, et aI. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE E LIMITED CASE 190V03695 (Amount demanded (Amount demanded is $25,000 exceeds $25.000) or less) A CASE MANAGEMENT CONFERENCE Isscheduled as follows: Date: January 13, 2021 Time: 10:30 a.m. Dept: Mosbarger Div.: Civil Room: TBA Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Les Hail INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. Plaintiff, NPH MEDICAL This statement is submitted by party (name): SERVICES b. E This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): December 12, 201 9 b. E] The cross-complaint, if any, was led on (dale): 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. [j The following parties named in the complaint or cross-complaint (1) D 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) E have had a default entered against them (specify names): c. D 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 0f 0859 In complaint E cross~complaint (Describe, including causes of action): Breach of Contract and Common Counts, wherein Defendants failed to pay $452,354.50 principal, owed to Plaintiff after requested and approved services were completed and invoiced to Defendants. Page1of 5 Form Adopted for Mandatory Use Judicial Council of California CASE MANAGEMENT STATEMENT Cale Rules of Court, rules 3720—1730 CMA1 1 0 (Rev. July 1, 201 1] www.courtscagov CM-110 ”SF-NUMBER: -— PLAINTtFF/PETITIONER: NPH MEDICAL SERVICES 190v03695 DEFENDANT/RESPONDENT: ROCKPORT. et al. 4. b. Provide a brief statement of the case, including any damages. (prersonal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost eamings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) This is a civii matter wherein the parties signed contracts, and Defendant facilities, managed by Defendant, Rockport, were consistently paying Plaintiff for services they requested in writing, completed and invoiced. Then, suddenly and without notice, Defendant facilities,managed by Defendant, Rockport, abruptly stopped paying invoices. Defendants owe $452,354.50 of outstanding invoices. E (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 triai a nonjury trial. (lfmore than one party, provide the name ofeach party requesting a jury tn'al): 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 ling of the complaint (if not, explain): It could be ready for trial in 6 months it we receive Defendants' cooperation. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): none at this time 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 2'3 b. hours (short causes) (specif: 8. Trial representation (to be answered for each party) m 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 inAttachment 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 D 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 m has not reviewed theADR information package identifiedinrule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) This matter is sub'ect to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under ode of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified inCode of Civil Procedure section 1141 .1 1. (3){:3 This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-110 (Rev. July 1,2011] CASE MANAGEMENT STATEMENT Page Zof CM-110 CASE NUMBER: a PLAINTIFF/PETITIONER: NPH MEDICAL SERVICES DEFENDANT/RESPONDENT: 190V03695 ROCKFORT, et a}. 10. c. ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or Indicate the have already participated in (check all that apply and provide the specied 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 ADRindicate the status of the processes (attach a copy of the parties'ADR processes (check all that apply): stipulation): BEBE] Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date):12/28/2020 DUDE 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): BUDD 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): DUDE Judicial arbitration not yet scheduled Judicial arbitration scheduled for (date): (4) Nonbinding judicial arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): DUDE Private arbitration not yet scheduled Private arbitration scheduled for (date): (5) Binding private arbitration ' Agreed to complete private arbitration by (date): Private arbitration completed on (date): DUDE ADR session not yet scheduled ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CM-11o (Rev. July 1, 201 1] Page3of 5 CASE MANAGEMENT STATEMENT cm CASENUMBER: PLANTIFF/PETIT‘ONER: NPH MEDICAL SERVICES 1QCV03695 DEFENDANT/RESPONDENT: ROCKPORT, et al. 11. Insurance a. E] Insurance carrier, if any, for party ling this statement (name): b. Reservation of rights: D Yes [:1 No c. E Coverage issues wili 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. [:3 Bankruptcy EV Other (specify): Status: 13. Relatedcases, consolidation, and coordination a. E] There are companion. underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: D Additional casesare described in Attachment 1 3a. b. E A motion to consolidate coordinate wili be filed by (name party): 14. Bifurcation 1:3 The party or parties intend to le 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 ofmotion, and issues): Discovery motions, due to the complete non-cooperation of Defendants, for the production of records supporting their claims in the Cross—Complaint. 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 Plaintiff Depositions with Production of Documents of February 2021 Defendants‘ representatives c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): Plaintiff will need to propound extensive written discovery including depositions with document production on ’ representatives of each Defendant. CM-110[Rev.July1,2011] CASE MANAGEMENT STATEMENT Page4of5 CM-110 PLAINTIFF/PETIT‘ONER: NPH MEDICAL SERVICES CASE ”UMBER: 190V03695 DEFENDANT/RESPONDENT: ROCKFORT: 9t al- 17. Economic litigation a, E This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures of Civil Procedure sections 90—98 will apply to this case. in Code b.D 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 specically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues m 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): Mediation was conducted by Zoom on December 28, 2020, by Mediator, Melissa Aliotti, but was unsuccessful. 20. Total number of pages attached (if any): 0 |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 2?? ,2020 Les Hait (TYPE OR PRINT NAME) %IGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-WIREV-Ju'v 1-201” CASE MANAGEMENT STATEMENT WW LAW OFFICE PROOF OF SERVICE I am a citizen of the United States and employedm Butte County, I am over the age of eighteen (18) years and not a party to the withi action, my business address is 762 East Avenue, Chico, California 95926, I served the person(s) named below, at the address(es) set forth, the within: CASE MANAGEMENT STATEMENT by placing a true copy thereof enclosed in a sealed envelope with postage fully prepaid and either (a) ______ depositing the sealed envelope with the United States Postal Service, or, (b) _____ placing the envelope or box for collection and mailing on the date shown below and at the place shown below following our ordinary business’ practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the lO ordinary course of business with the United States Postal Service in a sealed ll envelope with postage fully prepaid. by transmission Via Facsimile of a true, correct and complete copy of said 12 document(s) to the following parties on the date shown below at the fax number designated below. l3 X by transmission Via E-Mail of a true, correct and complete copy of said document(s) to the following parties on the date shown below at the email 14 address provided by the party(ies). 15 ______ by personal delivery l6 Name(s) and address(es) of person(s) served: l7 Vinay Kohli 18 King 8: Spalding 633 West Fifth Street, Ste. 1600 l9 Los Angeles, CA 90071 Email: vkohli@kslaw.com 20 Cc: pnewler@kslaw.com 21 22 I declare under penalty of perjury under the laws of the State of C ifornia that ' the foregoing is true and correct. Executed at Chico, California, on Dec 2020. 23 24 25 C WQMV Claire Ramsey 26 27 28 LAW OFFICES OF LES HAIT A Prufessimml Corporation 762 EAST AVENUE CHlCO, CALIFORNIA 95926 1 (530) 895—3352 PROOF OF SERVICE