Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Ryan S. Lean (CASB#272036) E-FILED
Keesal Young & Logan
400 Oceangate, Suite 1400 1/5/2021 2:49 PM
Superior Court of California
Long Beach, CA 90802 County of Fresno
TELEPHONE NO.: FAX NO. (Optional):
ryan.lean@kyl.com
E-MAIL ADDRESS (Optional):
By: L. Whipple, Deputy
ATTORNEY FOR (Name): MUFG
Union Bank, N.A., UnionBanc Investments Services
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Fresno LLC and Brooke Bordner
1130
STREET ADDRESS: O Street
MAILING ADDRESS:
Fresno,
CITY AND ZIP CODE: CA 93721
BRANCH NAME:B.F. Sisk Courthouse
PLAINTIFF/PETITIONER: Edmund V. Nolte, Jr.
DEFENDANT/RESPONDENT: UnionBanc Investment Services LLC;
MUFG Union Bank, N.A.; Brooke Bordner; et al.
CASE NUMBER:
CASE MANAGEMENT STATEMENT
(Check one): X UNLIMITED CASE LIMITED CASE 20CECG00024
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: January 20, 2021 Time: 1:30 p.m. Dept.: 402 Div.: Room:
Address of court (if different from the address above):
X Notice of Intent to Appear by Telephone, by (name): Ryan S. Lean
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. X This statement is submitted jointly by parties (names): MUFG Union Bank, N.A.; UnionBanc
Investment Services LLC and Brooke Bordner
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): January 3, 2020
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 X complaint cross-complaint (Describe, including causes of action):
Plaintiff alleges several causes of action, including negligence, against MUFG Union Bank, N.A., UnionBanc Investment
Services, LLC and Brooke Bordner (collectively, the "Union Bank Defendants") and other defendants arising from, inter alia,
the alleged withdrawal or surrender of annuity proceeds.
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]
CM-110
PLAINTIFF/PETITIONER: Edmund V. Nolte, Jr. CASE NUMBER:
DEFENDANT/RESPONDENT: UnionBanc Investment Services LLC; 20CECG00024
MUFG Union Bank, N.A.; Brooke Bordner; et al.
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.)
See 4(a). Plaintiff alleges damages according to proof.
(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 X 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. X 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):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Counsel will not be available the following weeks do to its trial calendar.
July 19-30, 2021; September 13-24, 2021; November 15-December 17, 2021.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number):
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial X 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 X 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):
CM-110 [Rev. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Edmund V. Nolte, Jr. CASE NUMBER:
DEFENDANT/RESPONDENT: UnionBanc Investment Services LLC; 20CECG00024
MUFG Union Bank, N.A.; Brooke Bordner; et al.
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):
(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
Judicial arbitration scheduled for (date):
(4) Nonbinding judicial
arbitration Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
X Private arbitration not yet scheduled
Private arbitration scheduled for (date):
(5) Binding private
arbitration
X Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
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-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Edmund V. Nolte, Jr. CASE NUMBER:
DEFENDANT/RESPONDENT: UnionBanc Investment Services LLC; 20CECG00024
MUFG Union Bank, N.A.; Brooke Bordner; et al.
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
x The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
The claims against the Union Bank Defendants are subject to a mandatory predispute arbitration agreement. These
defendants are meeting and conferring with Plaintiff regarding the refiling of those claims in arbitration and either the
dismissal or stay of these court proceedings as to those defendants.If Plaintiff does not voluntarily refile in arbitration,
the Union Bank Defendants intend to file a motion to compel arbitration.
16. Discovery
a. The party or parties have completed all discovery.
b. X The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
N/A in light of the
arbitration agreement.
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
CM-110
PLAINTIFF/PETITIONER: Edmund V. Nolte, Jr. CASE NUMBER:
DEFENDANT/RESPONDENT: UnionBanc Investment Services LLC; 20CECG00024
MUFG Union Bank, N.A.; Brooke Bordner; et al.
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. x 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: January 5, 2021
Ryan S. Lean
(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
Case Name: Edmund V. Nolte, Jr. v. Union Banc Investment Services, LLC et al.
Case No.: 20CECG00024
KYL File No.: 4824-23
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
3 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and
not a party to the within action; my business address is Keesal, Young & Logan, 400 Oceangate, Suite
4 1400, Long Beach, California 90802.
5 On January 5, 2021, I served the foregoing documents described as Case Management
Statement on the parties in this action by placing a true copy thereof enclosed in a sealed envelope
6 addressed as follows:
7 Eddie Ruiz (SBN 182202)
The Law Offices of Eddie Ruiz
8 2341 E. Ashlan Ave.
Fresno, CA 93726
9 Ph: 559-229-4900; Fax: 559-229-4990
Email: lawofficesofeddieruiz@yahoo.com
10 Attorneys for Edmund V. Nolte
11
12
BY ELECTRONIC TRANSMISSION: Pursuant to Cal. R. Ct. 2.251c, I caused the
13 document(s) to be served electronically on the above-named person(s) at the e-mail address(es)
exhibited therewith through One Legal Online Court Services.
14
Executed on January 5, 2021 at Long Beach, California.
15
I declare under penalty of perjury under the laws of the State of California and United States of
16 America that the foregoing is true and correct.
17 I declare that I am employed in the office of a member of the bar of this Court at whose
direction the service was made.
18
19
___________________________
20 D. KLESGES
21
22
23
24
25
26
27
28
-1-
Proof of Service
KYL4816-0641-9154.1
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Ryan S. Lean (CASB#272036) E-FILED Keesal Young & Logan 400 Oceangate, Suite 1400 1/5/2021 2:49 PM Superior Court of California Long Beach, CA 90802 County of Fresno TELEPHONE NO.: FAX NO. (Optional): ryan.lean@kyl.com E-MAIL ADDRESS (Optional): By: L. Whipple, Deputy ATTORNEY FOR (Name): MUFG Union Bank, N.A., UnionBanc Investments Services SUPERIOR COURT OF CALIFORNIA, COUNTY OF Fresno LLC and Brooke Bordner 1130 STREET ADDRESS: O Street MAILING ADDRESS: Fresno, CITY AND ZIP CODE: CA 93721 BRANCH NAME:B.F. Sisk Courthouse PLAINTIFF/PETITIONER: Edmund V. Nolte, Jr. DEFENDANT/RESPONDENT: UnionBanc Investment Services LLC; MUFG Union Bank, N.A.; Brooke Bordner; et al. CASE NUMBER: CASE MANAGEMENT STATEMENT (Check one): X UNLIMITED CASE LIMITED CASE 20CECG00024 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: January 20, 2021 Time: 1:30 p.m. Dept.: 402 Div.: Room: Address of court (if different from the address above): X Notice of Intent to Appear by Telephone, by (name): Ryan S. Lean 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. X This statement is submitted jointly by parties (names): MUFG Union Bank, N.A.; UnionBanc Investment Services LLC and Brooke Bordner 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): January 3, 2020 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 X complaint cross-complaint (Describe, including causes of action): Plaintiff alleges several causes of action, including negligence, against MUFG Union Bank, N.A., UnionBanc Investment Services, LLC and Brooke Bordner (collectively, the "Union Bank Defendants") and other defendants arising from, inter alia, the alleged withdrawal or surrender of annuity proceeds. 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] CM-110 PLAINTIFF/PETITIONER: Edmund V. Nolte, Jr. CASE NUMBER: DEFENDANT/RESPONDENT: UnionBanc Investment Services LLC; 20CECG00024 MUFG Union Bank, N.A.; Brooke Bordner; et al. 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.) See 4(a). Plaintiff alleges damages according to proof. (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 X 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. X 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): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Counsel will not be available the following weeks do to its trial calendar. July 19-30, 2021; September 13-24, 2021; November 15-December 17, 2021. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial X 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 X 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): CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Edmund V. Nolte, Jr. CASE NUMBER: DEFENDANT/RESPONDENT: UnionBanc Investment Services LLC; 20CECG00024 MUFG Union Bank, N.A.; Brooke Bordner; et al. 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): (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 Judicial arbitration scheduled for (date): (4) Nonbinding judicial arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): X Private arbitration not yet scheduled Private arbitration scheduled for (date): (5) Binding private arbitration X Agreed to complete private arbitration by (date): Private arbitration completed on (date): 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-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Edmund V. Nolte, Jr. CASE NUMBER: DEFENDANT/RESPONDENT: UnionBanc Investment Services LLC; 20CECG00024 MUFG Union Bank, N.A.; Brooke Bordner; et al. 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 x The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): The claims against the Union Bank Defendants are subject to a mandatory predispute arbitration agreement. These defendants are meeting and conferring with Plaintiff regarding the refiling of those claims in arbitration and either the dismissal or stay of these court proceedings as to those defendants.If Plaintiff does not voluntarily refile in arbitration, the Union Bank Defendants intend to file a motion to compel arbitration. 16. Discovery a. The party or parties have completed all discovery. b. X The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date N/A in light of the arbitration agreement. 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 CM-110 PLAINTIFF/PETITIONER: Edmund V. Nolte, Jr. CASE NUMBER: DEFENDANT/RESPONDENT: UnionBanc Investment Services LLC; 20CECG00024 MUFG Union Bank, N.A.; Brooke Bordner; et al. 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. x 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: January 5, 2021 Ryan S. Lean (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 Case Name: Edmund V. Nolte, Jr. v. Union Banc Investment Services, LLC et al. Case No.: 20CECG00024 KYL File No.: 4824-23 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 3 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is Keesal, Young & Logan, 400 Oceangate, Suite 4 1400, Long Beach, California 90802. 5 On January 5, 2021, I served the foregoing documents described as Case Management Statement on the parties in this action by placing a true copy thereof enclosed in a sealed envelope 6 addressed as follows: 7 Eddie Ruiz (SBN 182202) The Law Offices of Eddie Ruiz 8 2341 E. Ashlan Ave. Fresno, CA 93726 9 Ph: 559-229-4900; Fax: 559-229-4990 Email: lawofficesofeddieruiz@yahoo.com 10 Attorneys for Edmund V. Nolte 11 12 BY ELECTRONIC TRANSMISSION: Pursuant to Cal. R. Ct. 2.251c, I caused the 13 document(s) to be served electronically on the above-named person(s) at the e-mail address(es) exhibited therewith through One Legal Online Court Services. 14 Executed on January 5, 2021 at Long Beach, California. 15 I declare under penalty of perjury under the laws of the State of California and United States of 16 America that the foregoing is true and correct. 17 I declare that I am employed in the office of a member of the bar of this Court at whose direction the service was made. 18 19 ___________________________ 20 D. KLESGES 21 22 23 24 25 26 27 28 -1- Proof of Service KYL4816-0641-9154.1