Preview
CM-HO
ATTORNEY OR PARTY ATTORNEY (Name. State Bar number. and addmss}.
WE THOUT
FO COURT ”SE 0””
Law Ofce of Stephan R. Wattenberg
Stephan R. Waenberg Esq. 183914 Claire E. Greene. Esq. 286091
PO Box 657
Cau bf California
Forest Ranch CA 95942
F Suparll‘
F
m no. {optional}.- CW”? 0f Bum
TELEPHONE Na. (530) 342-8930 | I
EMA}: ADDRESS{OpmnaI;:
stwattny@pacbell.net L 11/16/2020 L
Plaintiffs
ATTORNEY FOR (Name):
SUPERiOR COURT OF CAUFORNIA, COUNTY OF BUTTE E E
cm
1775 Concord Ave.
SWEET ADDRESS.-
anLmG Aoossss:
CA 95926
AN:- zt? CODE: Chico,
BRANCHNAME; Unlimited Civil
D
By t, lubed?
WY
é%Br‘IE-r
FILED
7
D
PLAINTIFFIPETITIONER: Roland Martin Frame and Donna Frame
DEFENDANTIRESPONDENT: Perfection Pools and Spas. Inc.
CASE MANAGEMENT STATEMENT CASE NUMBER;
(Check one): E UNLIMITED CASE
(Amount demanded
Q LIMITED CASE
(Amount demanded Is $25000
205W)?“
exceeds $25,000) or Iess)
A CASE MANAGEMENT CONFERENCE is scheduIed as follows:
Date: December 9, 2020 Time: 10:30 am Dept: TBA Div; Room;
Address of court (if different from the address above):
E Notice of Intent to Appear by Telephone, by (name): Stephan R. Wattenberg
INSTRUCTIONS: Al! applicable boxes must be checked, and the specified information must be provided.
1, Party or parties (answer one):
a. E This statement is submitted by party (name): Roiand Martin Frame and Donna Frame
b. E This statement is submitted jointly by parties
(names):
2. Com piaint and cross-campiaint (to be answered by plaintiffs and crass-camplainants only)
a. The complaint was led on (date):
b. [:3 The cross-complaint. if any, was
led on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. E All parties named in the complaint and cross-complaint have been served. have appeared, or have been dismissed.
b. E The following parties named in the complaint or cross-complaint
(1) have not been served (specify names and explain why not):
(2) E have been served but have not appeared and have not been dismissed (specify names):
(3) [:3 have had a default entered against them (specify names):
c. EB The following additional parties may be added (specify names, nature of involvement in case, and date by which
be
they may served):
4. Description of case
a. Type of case in E complaint m cross-complaint (Describe, including causes of action):
Breach of Implied Warranty (Cal. Civ Code § 1292 etsq) Claim against Contractors Bond.
Page1of 5
Fm m-m'EU-‘mmm‘mw
Jude's! Council oi Calrlomia
CM-i 10 (Rev. July 1. 201 I;
CASE MANAGEMENT STATEMENT “gag;
www ccurrs
cagov
CM-1 10
PLAINTIFF/PETITIONER: Roland Marn Frame and Donna Frame CASE uuuaER:
ZOO/00754
DEFENDANT/RESPONDENT: Perfection Pools and Spas,
Inc.
4. b. Provide a brief statement of the case‘ including any damages(lfpersonal 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 eamings. If equitable relief is sought, describe the nature of the relief.)
The Solar System was not installed in a workmanlike manner because it did and does not produce the agreed amount of
connected to the EnpahselEnlighten Network.
electricity! it was not it did not and does not deliver electricity lo PG&E in a
Perfection
consistent manner and Perfection Perfection failed to bring the system into compliance with the sale warranties.
Pools and Spas, refused to make requested and necessary repairs.
E (if more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury ornonjury trial
a. E
The party or parties request a jury trial E (if more than one party, provide the name of each party
a nonjury trial.
requesting ajury trial):
6. Trial date
a. E The trial has been setter(date):
b. DE 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}:
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
7. Estimated tength of trial
The party or parties estimate that the trial will take (check one):
a. [E days (specify number): 1«2
b. hours (short causes) {specify}:
8. Trial representation (to be answered for each party)
E
The party or parties will be represented at trial E
by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: t. Fax number:
e. E-mailaddress: g. Party represented;
m 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: CounselE has has not provided the ADR information package identied
in rule 3.221 to the client and reviewed ADR options with the client.
(2) D
For self-represented parties: Party has [j has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1)E or to civil action
This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1 141.11
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2)E in Code of
Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specied
Civil Procedure section 1141.1 1.
(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):
“m’”m” Page 2 M5
CASE MANAGEMENT STATEMENT
CM-1 10
PLAINTIFF/PETITIONER: Roland Martin Frame and Donna Frame CASE NUMBER.-
ZOO/00754
DEFENDANTIRESPONDENT: Perfection Peels and Spas, Inc.
10. c. Indicate the ADR process or processes that the party or parties are wining to participate in, have agreed to panicipate in. or
have atready participated in (check all that apply and provide the specied
information):
The party or parties completing have agreed to
If the party or parties completing this form in the case
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):
E Mediatian session not yet scheduled
D Mediation session scheduled for (date):
(1) Mediation
E] Agreed to complete mediation by (dale):
m Mediation completed on (date):
C] Settlement conference not yet scheduled
(2) Settlement E Settlement conference scheduled forldate):
conference E Agreed to complete setttement conference by(date):
a Settlement conference completed primate):
E Neutral evaluation not yet scheduled
m {j Neutral evaluation scheduled for(dale):
(3) Neutral evaluation
S Agreed to complete neutral evaluation by (date):
E Neutral evaluation completed on (date):
E Judicial arbitration not yet scheduled
(4) Nonbmdmg judicia, C: D Judicial arbitration scheduled for
(date):
arbitration a Agreed to complete judicial arbitration by
(date):
E Judicial arbitration completed on (date):
t iPrivate arbitration not yet scheduled
(5) Binding private m [j Private arbitration scheduled for
(date):
arbitration E Agreed to complete private arbitration by
(date):
[j Private arbitration completed on(date):
E ADR session not yet scheduled
D E ADR session scheduled tor (data):
(a) Other (specify):
E Agreed to complete ADR session by (date):
m ADR completed on (date):
CM-HO [Rev My
1,20H] PageJ o! 5
CASE MANAGEMENT STATEMENT
CM-NO
PLAINTIFFIPETITIONER: Rotand Martin Frame and Donna Frame CASE NUMBER:
20CV00754
DEFENDANT/RESPONDENT: Perfection Pools and Spas. inc.
11.Insuranca
a. a Insurance carrier, if any, for pany filing this statement (name):
b. Reservation ofrights:m Yes D No
c‘ E Coverage issues will signicantlyaffect resolution of this case
(explain):
12.Jurisdiction
Indicate any matters that may affect the court's iurisdiction or processing of this case and describe the status.
D Bankruptcy m Other (specii):
Status:
13.Reiated cases, consolidation, and coordination
a. a There are companion, underlying, or rotated cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
[j Additional cases are described in Attachment 133.
b. [j A motion to m consolidate D coordinate will beied by (name party):
14. Bifurcation
[j a motion for an order bifurcating. severing. or coordinating the following issues or causes of
The party or parties intend to le
action (specify moving party, type of motion, and reasons):
15. Other motions
E The party or parties expect to
le (special moving party, type of motion. and issues):
the foliowing motions before trial
16.Discovery
a. G The party or parties have completed all disoovery.
b. E The following discovery will be completed by the date specied(describe all anticipated discovery):
Earl! Qesedpjim gate
Roland Martin and Donna Frame Written Discovery/Depositions March 2021
c. B The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
1“” “ 2“” manners
CASE MANAGEMENT STATEMENT
CM-1 10
Rotand Martin Fzame and Danna Frame ELF-SE NUMBER.
PLAINTIFFIPETITIONER:
20CV00754
DEFENDANTIRESPDNDENT: Pedecon Poms and Spas.énc.
1-7Economic litigation
k a ?mount demanded is 525.000 or Iess) and the economic titigation procedures in Code
a. E This is a limited cm! case (Le,
1:51.;
z
of Civil Procedure sections 90-98 wéil apply to this sass
b, Proce‘jures 0" ’0’ addi‘ima'
This is a limrted CM! case and a motion :a withdraw the case from the economic Inigaon
willbe led checked,
(if explain why
specificaliy economic procedures
litigation relating {a discovery or triai
discovery
shouid no: apply ta this case}:
18. Otherissues
[:3 The party or parties request that the following additional matters be considered or determined a: {he case management
conference (specify):
Meet and confer
‘19.
3.7 24. of the Califcmla Rules
a 5
x The party or parties have met and conferred with all parties on an subjects required by ruie
-;
I
of Cour‘l {if nol. explain):
on the following
the parties agree
b. {:3 After meeting and conferring as required by rule 3.724 of the California Rules of Court.
(speciv);
23. Total number of pages attached (if any):
and alternative dispute resolution,
am completely familiar with this case and will be fully prepare d to discuss the status of discovery
i
and willpossess the toenter into on these issues at the time Ot
stipulations
as we“ as other issues raised by this statement. authority
the case management conference. including the written authority o‘ the party where required.
Date: November rr.202D
"
/
Steupnan R
u ,Wat‘nnberd
[vi _
{TIDE GE DEW? “EMF"
' i:
-' "I
1441/ g/jT/
"I ""($‘GNATUQE'
—
o: ennw
_.
._
.
on Awoau'r‘...
gives ct: pew? mug; sarGN-usea: PAH“ AHOHHE‘Q
c-r-r
m Additional signatures are attached.
page s ct a
cud-.of'nguyz20H)
CASE MANAGEMENT STATEMENT
PROOF OF SERVICE - CCP 1013, 2015.5
Case Name: Roland Martin Frame, Donna Frame vs. Perfection Pools and Spas, Inc.
Case No.1 20CV00754
I declare that I am employed in the County of Butte, State ofCaiifomia. Iam over the
age ofeighteen years and not a party to the within action; my business address is 1074 East
Avenue? Suite C, Chico, California 95926.
On November 16, 2020? l served a true copy of the within CASE MANAGEMENT
STATEMENT on. the parties below named in said cause in the following manner:
X VIA REGULAR MAIL by placing a true copy thereof enclosed in a sealed envelope
with postage thereon fully prepaid which is delivered to the U.S. Post Ofce in Chico,
California, on the same day, addressed as set forth below.
VIA FEDERAL EXPRESS by placing a true copy thereofenclosed in a sealed
envelope, prepaid, deposited with the Federal Express carrier/box at Chico, California,
addressed as set forth below.
VIA PERSONAL SERVICE, delivering by hand and leaving a true copy with the
person and/or ofce staff at the address shown below.
VIA EMAIL at the date and place herein by sending a true copy to diacobsfgjap c-
laweom in the service list.
Carlos A. Sosa Boby Dale Sims, Jr.
Law Ofces of l-lausman 8e Sosa LLP Gregory Estabrook
20750 Venture Blvd, Suite 105 2261 Lava Ridge Court
Woodland Hills, CA 91364—6646 Roseville, CA 95661
I declare under penalty of perj ury that the foregoing is true and correct, and that this
declaration was executed on November 16, 2020 at Chico, California 95926.
MargLQ__l_____
I
Stephan R. Wattenberg, Esq.
Preview
CM-HO ATTORNEY OR PARTY ATTORNEY (Name. State Bar number. and addmss}. WE THOUT FO COURT ”SE 0”” Law Ofce of Stephan R. Wattenberg Stephan R. Waenberg Esq. 183914 Claire E. Greene. Esq. 286091 PO Box 657 Cau bf California Forest Ranch CA 95942 F Suparll‘ F m no. {optional}.- CW”? 0f Bum TELEPHONE Na. (530) 342-8930 | I EMA}: ADDRESS{OpmnaI;: stwattny@pacbell.net L 11/16/2020 L Plaintiffs ATTORNEY FOR (Name): SUPERiOR COURT OF CAUFORNIA, COUNTY OF BUTTE E E cm 1775 Concord Ave. SWEET ADDRESS.- anLmG Aoossss: CA 95926 AN:- zt? CODE: Chico, BRANCHNAME; Unlimited Civil D By t, lubed? WY é%Br‘IE-r FILED 7 D PLAINTIFFIPETITIONER: Roland Martin Frame and Donna Frame DEFENDANTIRESPONDENT: Perfection Pools and Spas. Inc. CASE MANAGEMENT STATEMENT CASE NUMBER; (Check one): E UNLIMITED CASE (Amount demanded Q LIMITED CASE (Amount demanded Is $25000 205W)?“ exceeds $25,000) or Iess) A CASE MANAGEMENT CONFERENCE is scheduIed as follows: Date: December 9, 2020 Time: 10:30 am Dept: TBA Div; Room; Address of court (if different from the address above): E Notice of Intent to Appear by Telephone, by (name): Stephan R. Wattenberg INSTRUCTIONS: Al! applicable boxes must be checked, and the specified information must be provided. 1, Party or parties (answer one): a. E This statement is submitted by party (name): Roiand Martin Frame and Donna Frame b. E This statement is submitted jointly by parties (names): 2. Com piaint and cross-campiaint (to be answered by plaintiffs and crass-camplainants only) a. The complaint was led on (date): b. [:3 The cross-complaint. if any, was led on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. E All parties named in the complaint and cross-complaint have been served. have appeared, or have been dismissed. b. E The following parties named in the complaint or cross-complaint (1) have not been served (specify names and explain why not): (2) E have been served but have not appeared and have not been dismissed (specify names): (3) [:3 have had a default entered against them (specify names): c. EB The following additional parties may be added (specify names, nature of involvement in case, and date by which be they may served): 4. Description of case a. Type of case in E complaint m cross-complaint (Describe, including causes of action): Breach of Implied Warranty (Cal. Civ Code § 1292 etsq) Claim against Contractors Bond. Page1of 5 Fm m-m'EU-‘mmm‘mw Jude's! Council oi Calrlomia CM-i 10 (Rev. July 1. 201 I; CASE MANAGEMENT STATEMENT “gag; www ccurrs cagov CM-1 10 PLAINTIFF/PETITIONER: Roland Marn Frame and Donna Frame CASE uuuaER: ZOO/00754 DEFENDANT/RESPONDENT: Perfection Pools and Spas, Inc. 4. b. Provide a brief statement of the case‘ including any damages(lfpersonal 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 eamings. If equitable relief is sought, describe the nature of the relief.) The Solar System was not installed in a workmanlike manner because it did and does not produce the agreed amount of connected to the EnpahselEnlighten Network. electricity! it was not it did not and does not deliver electricity lo PG&E in a Perfection consistent manner and Perfection Perfection failed to bring the system into compliance with the sale warranties. Pools and Spas, refused to make requested and necessary repairs. E (if more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury ornonjury trial a. E The party or parties request a jury trial E (if more than one party, provide the name of each party a nonjury trial. requesting ajury trial): 6. Trial date a. E The trial has been setter(date): b. DE 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}: c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated tength of trial The party or parties estimate that the trial will take (check one): a. [E days (specify number): 1«2 b. hours (short causes) {specify}: 8. Trial representation (to be answered for each party) E The party or parties will be represented at trial E by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: t. Fax number: e. E-mailaddress: g. Party represented; m 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: CounselE has has not provided the ADR information package identied in rule 3.221 to the client and reviewed ADR options with the client. (2) D For self-represented parties: Party has [j has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1)E or to civil action This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1 141.11 mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2)E in Code of Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specied Civil Procedure section 1141.1 1. (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): “m’”m” Page 2 M5 CASE MANAGEMENT STATEMENT CM-1 10 PLAINTIFF/PETITIONER: Roland Martin Frame and Donna Frame CASE NUMBER.- ZOO/00754 DEFENDANTIRESPONDENT: Perfection Peels and Spas, Inc. 10. c. Indicate the ADR process or processes that the party or parties are wining to participate in, have agreed to panicipate in. or have atready participated in (check all that apply and provide the specied information): The party or parties completing have agreed to If the party or parties completing this form in the case 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): E Mediatian session not yet scheduled D Mediation session scheduled for (date): (1) Mediation E] Agreed to complete mediation by (dale): m Mediation completed on (date): C] Settlement conference not yet scheduled (2) Settlement E Settlement conference scheduled forldate): conference E Agreed to complete setttement conference by(date): a Settlement conference completed primate): E Neutral evaluation not yet scheduled m {j Neutral evaluation scheduled for(dale): (3) Neutral evaluation S Agreed to complete neutral evaluation by (date): E Neutral evaluation completed on (date): E Judicial arbitration not yet scheduled (4) Nonbmdmg judicia, C: D Judicial arbitration scheduled for (date): arbitration a Agreed to complete judicial arbitration by (date): E Judicial arbitration completed on (date): t iPrivate arbitration not yet scheduled (5) Binding private m [j Private arbitration scheduled for (date): arbitration E Agreed to complete private arbitration by (date): [j Private arbitration completed on(date): E ADR session not yet scheduled D E ADR session scheduled tor (data): (a) Other (specify): E Agreed to complete ADR session by (date): m ADR completed on (date): CM-HO [Rev My 1,20H] PageJ o! 5 CASE MANAGEMENT STATEMENT CM-NO PLAINTIFFIPETITIONER: Rotand Martin Frame and Donna Frame CASE NUMBER: 20CV00754 DEFENDANT/RESPONDENT: Perfection Pools and Spas. inc. 11.Insuranca a. a Insurance carrier, if any, for pany filing this statement (name): b. Reservation ofrights:m Yes D No c‘ E Coverage issues will signicantlyaffect resolution of this case (explain): 12.Jurisdiction Indicate any matters that may affect the court's iurisdiction or processing of this case and describe the status. D Bankruptcy m Other (specii): Status: 13.Reiated cases, consolidation, and coordination a. a There are companion, underlying, or rotated cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: [j Additional cases are described in Attachment 133. b. [j A motion to m consolidate D coordinate will beied by (name party): 14. Bifurcation [j a motion for an order bifurcating. severing. or coordinating the following issues or causes of The party or parties intend to le action (specify moving party, type of motion, and reasons): 15. Other motions E The party or parties expect to le (special moving party, type of motion. and issues): the foliowing motions before trial 16.Discovery a. G The party or parties have completed all disoovery. b. E The following discovery will be completed by the date specied(describe all anticipated discovery): Earl! Qesedpjim gate Roland Martin and Donna Frame Written Discovery/Depositions March 2021 c. B The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): 1“” “ 2“” manners CASE MANAGEMENT STATEMENT CM-1 10 Rotand Martin Fzame and Danna Frame ELF-SE NUMBER. PLAINTIFFIPETITIONER: 20CV00754 DEFENDANTIRESPDNDENT: Pedecon Poms and Spas.énc. 1-7Economic litigation k a ?mount demanded is 525.000 or Iess) and the economic titigation procedures in Code a. E This is a limited cm! case (Le, 1:51.; z of Civil Procedure sections 90-98 wéil apply to this sass b, Proce‘jures 0" ’0’ addi‘ima' This is a limrted CM! case and a motion :a withdraw the case from the economic Inigaon willbe led checked, (if explain why specificaliy economic procedures litigation relating {a discovery or triai discovery shouid no: apply ta this case}: 18. Otherissues [:3 The party or parties request that the following additional matters be considered or determined a: {he case management conference (specify): Meet and confer ‘19. 3.7 24. of the Califcmla Rules a 5 x The party or parties have met and conferred with all parties on an subjects required by ruie -; I of Cour‘l {if nol. explain): on the following the parties agree b. {:3 After meeting and conferring as required by rule 3.724 of the California Rules of Court. (speciv); 23. Total number of pages attached (if any): and alternative dispute resolution, am completely familiar with this case and will be fully prepare d to discuss the status of discovery i and willpossess the toenter into on these issues at the time Ot stipulations as we“ as other issues raised by this statement. authority the case management conference. including the written authority o‘ the party where required. Date: November rr.202D " / Steupnan R u ,Wat‘nnberd [vi _ {TIDE GE DEW? “EMF" ' i: -' "I 1441/ g/jT/ "I ""($‘GNATUQE' — o: ennw _. ._ . on Awoau'r‘... gives ct: pew? mug; sarGN-usea: PAH“ AHOHHE‘Q c-r-r m Additional signatures are attached. page s ct a cud-.of'nguyz20H) CASE MANAGEMENT STATEMENT PROOF OF SERVICE - CCP 1013, 2015.5 Case Name: Roland Martin Frame, Donna Frame vs. Perfection Pools and Spas, Inc. Case No.1 20CV00754 I declare that I am employed in the County of Butte, State ofCaiifomia. Iam over the age ofeighteen years and not a party to the within action; my business address is 1074 East Avenue? Suite C, Chico, California 95926. On November 16, 2020? l served a true copy of the within CASE MANAGEMENT STATEMENT on. the parties below named in said cause in the following manner: X VIA REGULAR MAIL by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid which is delivered to the U.S. Post Ofce in Chico, California, on the same day, addressed as set forth below. VIA FEDERAL EXPRESS by placing a true copy thereofenclosed in a sealed envelope, prepaid, deposited with the Federal Express carrier/box at Chico, California, addressed as set forth below. VIA PERSONAL SERVICE, delivering by hand and leaving a true copy with the person and/or ofce staff at the address shown below. VIA EMAIL at the date and place herein by sending a true copy to diacobsfgjap c- laweom in the service list. Carlos A. Sosa Boby Dale Sims, Jr. Law Ofces of l-lausman 8e Sosa LLP Gregory Estabrook 20750 Venture Blvd, Suite 105 2261 Lava Ridge Court Woodland Hills, CA 91364—6646 Roseville, CA 95661 I declare under penalty of perj ury that the foregoing is true and correct, and that this declaration was executed on November 16, 2020 at Chico, California 95926. MargLQ__l_____ I Stephan R. Wattenberg, Esq.