Preview
EFS-020
ATTORNEY OR PARTY WITHOUT ATTORNEY: sate Bar No. 215416/130833 FOR COURT USE ONLY
NAME: Lael D. Andara/Jennifer E. Acheson
Firm Name: Ropers Majeski
street appress: 1001 Marshall Street, Suite 500
city: Redwood City state: CA ZIP CODE: 94063
TELEPHONE No.: 650-364-8200 FAX NO.:
E-mait Appress: lael.andara@ropers.com; jennifer.acheson@ropers.com
Arr WEY Fe SINCO TECHNOLOGIES
OLOGIES PTE LTD.
TE LTD
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Clara
Envelope: 5811233
street appress: 191 N. 1* Street
MAILING ADDRESS:
city AND zip coe: San Jose 95113
BRANCH NAME: CASE NUMBER:
PLAINTIFF/PETITIONER: SINCO TECHNOLOGIES PTE LTD.
16CV301867
DEFENDANT/RESPONDENT: XINGKE ELECTRONICS, et al.
JUDICIAL OFFICER:
Hon. Sunil R. Kulkarni
OTHER:
DEPT:
1
PROPOSED ORDER (COVER SHEET)
NOTE: This cover sheet is to be used to electronically file and submit to the court a proposed order. The proposed order sent
electronically to the court must be in PDF format and must be attached to this cover sheet. In addition, a version of the proposed
order in an editable word-processing format must be sent to the court at the same time as this cover sheet and the attached proposed
order in PDF format are filed.
1.Name of the party submitting the proposed order:
SINCO TECHNOLOGIES PTE LTD.
2. Title of the proposed order:
[PROPOSED] ORDER GRANTING PLAINTIFF SINCO TECHNOLOGIES PTE LTD'S MOTION TO STRIKE THIRD
AMENDED CROSS-COMPLAINT
3. The proceeding to which the proposed order relates is:
a. Description of proceeding: Motion Hearing
b. Date and time: TBD
c. Place: Dept. 1
4. The proposed order was served on the other parties in the case.
Jennifer E. Acheson
1 eae fe Madea,
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Page 1 of 2
4847-0317-8159.1
Form Adopted for Mandatory Use PROPOSED ORDER (COVER SHEET) Cal. Rules of Court,
Judicial Council of Califomia Tules 2.252, 3.1312
EFS.020 [Rev. February 1, 2017] (Electronic Filing) www.courts.ca.gov
Ame AlN
EFS-020
CASE NAME: CASE NUMBER:
SINCO V. SOON, et al. 16CV301867
PROOF OF ELECTRONIC SERVICE
PROPOSED ORDER
1. | am at least 18 years old and not a party to this action.
a. My residence or business address is (specify):
1001 Marshall Street, Redwood City, California 94063
b. My electronic service address is (specify):
morgan.macnerland@ropers.com
2. | electronically served the Proposed Order (Cover Sheet) with a proposed order in PDF format attached, and a proposed order in
an editable word-processing format as follows:
a. On (name of person served) (If the person served is an attorney, the party or parties represented should also be stated.):
See Proof of Service
b. To (electronic service address of person served):
See Proof of Service
c. On (date):
KlElectronic service of the Proposed Order (Cover Sheet) with the attached proposed order in PDF format and service of the
proposed order in an editable word-processing format on additional persons are described in an attachment.
| declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: February 9, 2021
. Mrsegan Moon ortand
Morgan MacNerland
(TYPE OR PRINT NAME OF DECLARANT) (SIGNATURE OF DECLARANT)
EFS-020 [Rev. February 1, 2017] PROPOSED ORDER (COVER SHEET) Page 2 of 2
4847-0317-8159.1
(Electronic Filing)
‘American LegalNet, I
ww or forkFl
TODD A. ROBERTS (SBN 129722)
LAEL D. ANDARA (SBN 215416
JENNIFER E. ACHESON (SBN 130833)
DANIEL E. GAITAN (SBN 326413)
ROPERS MAJESKI PC
1001 Marshall Street, Sth Floor
Redwood City, CA 94063
Telephone: 650.364.8200
Facsimile: 650.780.1701
Email: todd.roberts@ropers.com
lael.andara@ropers.com
jennifer.acheson@ropers.com
daniel.gaitan@ropers.com
Attorneys for Plaintiff and Cross-Defendant
SINCO TECHNOLOGIES PTE LTD
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 COUNTY OF SANTA CLARA
12
13 SINCO TECHNOLOGIES PTE LTD, Case No. 16CV301867
14 Plaintiff, [PROPOSED] ORDER GRANTING
NB PLAINTIFF SINCO TECHNOLOGIES
Ole 1 v PTE LTD'S MOTION TO STRIKE
THIRD AMENDED CROSS-
Li 16 XINGKE ELECTRONICS (DONGGUAN) COMPLAINT
CO., LTD.; XINGKE ELECTRONICS
os 17 (HONG KONG) CO., LTD.; SINCOO Date: TBD
Ok 18
ELECTRONICS TECHNOLOGY CO.,
LIMITED.; JINLONG MACHINERY &
Time:
Dept.:
TBD
1
Ye ELECTRONICS Co., LTD.; LIEW YEW Judge: Hon. Sunil R. Kulkarni
9 SOON aka MARK LIEW; SINCO
ELECTRONICS (DONGGUAN) CO., LTD. 37 Action Filed: 10/28/16
20 NG CHER YONG aka CY NG; MUI LIANG Trial Date: 8/16/21
TJOA; JIN SHAO PING; XU SHUGONG; Last CMC: 1/6/21
21 QUEK SEOW ENG and DOES 5 through 20, Next CMC: 5/6/21
inclusive, Original CC: TAB/19
22 FACC: 10/04/19
Defendants. SACC: 1/17/20
23 TACC: 1/8/21
24
AND RELATED CROSS-ACTION
25
26 On , 2021, plaintiff and cross-defendant SINCO TECHNOLOGIES PTE
27 LTD's (“SINCO’s”) timely noticed Motion to Strike portions of the Third Amended Cross-
28 Complaint filed January 8, 2021 by defendant and cross-complainant XINGKE ELECTRONICS
-1-
4824-5368-8017-1
[PROPOSED] ORDER GRANTING PLAINTIFF'S MOTION TO STRIKE THIRD AMENDED CROSS-
COMPLAINT
(DONGGUAN) CO., LTD.; LIEW YEW SOON aka MARK LIEW; NG CHER YONG aka CY
NG; and MUI LANG TJOA, aka ML TJOA, (“XINGKE”) came on regularly for hearing in the
above-entitled court. Appearances were made by Jennifer E. Acheson/Lael D. Andara, Ropers,
Majeski, Kohn and Bentley, for SINCO; and Jeffrey C.P. Wang, and Michael York, WHGC,
P.L.C. for XINGKE.
The Court, having reviewed the pleadings in support and in opposition to said motion, and
considered oral argument of counsel, and finding good cause therefor,
IT IS HEREBY ORDERED that SINCO’s Motion to Strike portions of the Third
Amended Cross-Complaint as follows:
10 Paragraph 14:...In order to preserve assets and to prevent waste,
dissipation, and loss of assets to the irreparable damage of Cross-
11 Complainants, it is necessary that the requested injunctive relief
herein prayed for be granted.
12
Paragraphs 45, 133, 134,135, 137, 138: ...agreements, oral or
13 written...
14 Prayer Paragraph 4: For punitive damages, pursuant to the
NB
California Civil Code § 3294, in an amount appropriate to punish
Ole 1 and set an example of Cross-Defendants, and each of them, and to
Li deter such conduct in the future, the exact amount of such punitive
16 damages subject to proof at the time of trial;
os 17 Prayer Paragraph 5: For the disgorgement of profits received by
Ok 18
Cross-Defendants, and each of them, from Cross-Complainants,
where the receipt of such profits can be traced to any act of fraud,
Ye fraudulent concealment, false promise, or breach of fiduciary duty;
9
Prayer Paragraph 6: For the imposition of a constructive trust
20 upon all profits and proceeds related to or arising out of the
operation of SinCo Singapore’s business that were derived from the
21 benefits received from Cross-Complainants presently in the
possession, custody or control of Cross-Defendants;
22
Prayer Paragraph 7: For equitable relief in the form of an
23 injunction prohibiting the illicit conduct described herein;
24 MH
25 MH
26 i
27 Mf
28 /
Ee
4824-5368-8017-1
[PROPOSED] ORDER GRANTING PLAINTIFF'S MOTION TO STRIKE THIRD AMENDED CROSS-
COMPLAINT
Prayer Paragraph 8: For attorney’s fees, expenses and costs
incurred in pursuing the claims asserted herein, against Cross-
Defendants and each of them, jointly and severally, as may be
provided by contract and/or law;..
IT IS SO ORDERED.
Date:
JUDGE OF THE SUPERIOR COURT
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-3-
4824-5368-8017-1
[PROPOSED] ORDER GRANTING PLAINTIFF'S MOTION TO STRIKE THIRD AMENDED CROSS-
COMPLAINT
CASE NAME: SINCO TECHNOLOGIES PTE LTD V. XINGKE ELECTRONICS
(DONGGUAN) CO., LTD., ET AL.
ACTION NO.: 16CV301867
PROOF OF SERVICE
METHOD OF SERVICE
O First Class Mail DO Facsimile Oo Messenger Service
O1 Overni ight Delivery I] E-Mail/Electronic Delivery
1. At the time of service I was over 18 years of age and not a party to this action.
2. My business address is 1001 Marshall Street, 5th Floor, Redwood City, California 94063,
County of San Mateo.
10 3. On February 9, 2021 I served the following documents:
11 [PROPOSED] ORDER GRANTING PLAINTIFF SINCO TECHNOLOGIES PTE
LTD'S MOTION TO STRIKE THIRD AMENDED CROSS-COMPLAINT
12
4. I served the documents on the persons at the address below (along with their fax numbers
13 and/or email addresses if service was by fax or email):
14
NB Jeffrey C.P. Wang Edwin K. Prather
Ole 1 Kathleen E. Alparce Prather Law Offices
Li John Giust 245 Fifth Street, Suite 103
16
Michael York San Francisco, California 94103
os 17 Jessica Crabbe Email: edwin@pratherlawoffices.com
Ok 18
WHGC, P.L.C.
1301 Dove Street, Suite 1050
Ye Newport Beach, CA 92660
9 Email: JeffreyWang@whgclaw.com
KathleenAlparce@whgclaw.com
20
JohnGiust@whgclaw.com
21 MichaelY ork@whgclaw.com
JessicaCrabbe@whgclaw.com
22 ElaineWu@WHGCLaw.com
FrontDesk@WHGCLaw.com
23
24 5. I served the documents by the following means:
25 a. O By United States mail: I enclosed the documents in a sealed envelope or package
addressed to the persons at the addresses specified in item 4 and placed the envelope for
26 collection and mailing, following our ordinary business practices. I am readily familiar with this
business’s practice for collecting and processing correspondence for mailing. On the same day
27 that correspondence is placed for collection and mailing, it is deposited in the ordinary course of
business with the United States Postal Service, in a sealed envelope with postage fully prepaid at
28 the address listed in Paragraph 2 above.
4824-5368-8017.1
PROOF OF SERVICE
b. O By overnight delivery: I enclosed the documents in an envelope or package
provided by an overnight delivery carrier and addressed to the persons at the addresses in item 4.
I placed the envelope or package for collection and overnight delivery at an office or a regularly
utilized drop box of the overnight delivery carrier.
Cc O By messenger: I served the documents by placing them in an envelope or
package addressed to the persons at the addresses listed in item 4 and providing them to a
messenger for service.
d. O By fax transmission: Based on an agreement between the parties and in
conformance with Rule 2.306, and/or as a courtesy, I faxed the documents to the persons at the
fax numbers listed in item 4. No error was reported by the fax machine that I used. A copy of
the record of the fax transmission is attached.
e O By email or electronic transmission: In compliance with Code of Civil Procedure
§1010.6, I sent the documents via my electronic service address
(morgan.macnerland@ropers.com) to the persons at the email addresses listed in item 4. I did
not receive, within a reasonable time after the transmission, any electronic message or other
10 indication that the transmission was unsuccessful.
11 f. By email or electronic transmission: In compliance with Code of Civil Procedure
§1010.6, via my electronic business address (morgan.macnerland@ropers.com), I caused the
12 document(s) listed above to be electronically served through One Legal for the above-entitled
case upon the parties listed in item 4. The file transmission was reported as complete and a copy
13 of the One Legal receipt will be maintained in our case file.
14 I declare under penalty of perjury under the laws of the State of California that the above
Or is true and correct.
Ole 15
Date: February 9, 2021
Li 16
of
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4824-5368-8017.1
PROOF OF SERVICE
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EFS-020 ATTORNEY OR PARTY WITHOUT ATTORNEY: sate Bar No. 215416/130833 FOR COURT USE ONLY NAME: Lael D. Andara/Jennifer E. Acheson Firm Name: Ropers Majeski street appress: 1001 Marshall Street, Suite 500 city: Redwood City state: CA ZIP CODE: 94063 TELEPHONE No.: 650-364-8200 FAX NO.: E-mait Appress: lael.andara@ropers.com; jennifer.acheson@ropers.com Arr WEY Fe SINCO TECHNOLOGIES OLOGIES PTE LTD. TE LTD SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Clara Envelope: 5811233 street appress: 191 N. 1* Street MAILING ADDRESS: city AND zip coe: San Jose 95113 BRANCH NAME: CASE NUMBER: PLAINTIFF/PETITIONER: SINCO TECHNOLOGIES PTE LTD. 16CV301867 DEFENDANT/RESPONDENT: XINGKE ELECTRONICS, et al. JUDICIAL OFFICER: Hon. Sunil R. Kulkarni OTHER: DEPT: 1 PROPOSED ORDER (COVER SHEET) NOTE: This cover sheet is to be used to electronically file and submit to the court a proposed order. The proposed order sent electronically to the court must be in PDF format and must be attached to this cover sheet. In addition, a version of the proposed order in an editable word-processing format must be sent to the court at the same time as this cover sheet and the attached proposed order in PDF format are filed. 1.Name of the party submitting the proposed order: SINCO TECHNOLOGIES PTE LTD. 2. Title of the proposed order: [PROPOSED] ORDER GRANTING PLAINTIFF SINCO TECHNOLOGIES PTE LTD'S MOTION TO STRIKE THIRD AMENDED CROSS-COMPLAINT 3. The proceeding to which the proposed order relates is: a. Description of proceeding: Motion Hearing b. Date and time: TBD c. Place: Dept. 1 4. The proposed order was served on the other parties in the case. Jennifer E. Acheson 1 eae fe Madea, (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Page 1 of 2 4847-0317-8159.1 Form Adopted for Mandatory Use PROPOSED ORDER (COVER SHEET) Cal. Rules of Court, Judicial Council of Califomia Tules 2.252, 3.1312 EFS.020 [Rev. February 1, 2017] (Electronic Filing) www.courts.ca.gov Ame AlN EFS-020 CASE NAME: CASE NUMBER: SINCO V. SOON, et al. 16CV301867 PROOF OF ELECTRONIC SERVICE PROPOSED ORDER 1. | am at least 18 years old and not a party to this action. a. My residence or business address is (specify): 1001 Marshall Street, Redwood City, California 94063 b. My electronic service address is (specify): morgan.macnerland@ropers.com 2. | electronically served the Proposed Order (Cover Sheet) with a proposed order in PDF format attached, and a proposed order in an editable word-processing format as follows: a. On (name of person served) (If the person served is an attorney, the party or parties represented should also be stated.): See Proof of Service b. To (electronic service address of person served): See Proof of Service c. On (date): KlElectronic service of the Proposed Order (Cover Sheet) with the attached proposed order in PDF format and service of the proposed order in an editable word-processing format on additional persons are described in an attachment. | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: February 9, 2021 . Mrsegan Moon ortand Morgan MacNerland (TYPE OR PRINT NAME OF DECLARANT) (SIGNATURE OF DECLARANT) EFS-020 [Rev. February 1, 2017] PROPOSED ORDER (COVER SHEET) Page 2 of 2 4847-0317-8159.1 (Electronic Filing) ‘American LegalNet, I ww or forkFl TODD A. ROBERTS (SBN 129722) LAEL D. ANDARA (SBN 215416 JENNIFER E. ACHESON (SBN 130833) DANIEL E. GAITAN (SBN 326413) ROPERS MAJESKI PC 1001 Marshall Street, Sth Floor Redwood City, CA 94063 Telephone: 650.364.8200 Facsimile: 650.780.1701 Email: todd.roberts@ropers.com lael.andara@ropers.com jennifer.acheson@ropers.com daniel.gaitan@ropers.com Attorneys for Plaintiff and Cross-Defendant SINCO TECHNOLOGIES PTE LTD 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 COUNTY OF SANTA CLARA 12 13 SINCO TECHNOLOGIES PTE LTD, Case No. 16CV301867 14 Plaintiff, [PROPOSED] ORDER GRANTING NB PLAINTIFF SINCO TECHNOLOGIES Ole 1 v PTE LTD'S MOTION TO STRIKE THIRD AMENDED CROSS- Li 16 XINGKE ELECTRONICS (DONGGUAN) COMPLAINT CO., LTD.; XINGKE ELECTRONICS os 17 (HONG KONG) CO., LTD.; SINCOO Date: TBD Ok 18 ELECTRONICS TECHNOLOGY CO., LIMITED.; JINLONG MACHINERY & Time: Dept.: TBD 1 Ye ELECTRONICS Co., LTD.; LIEW YEW Judge: Hon. Sunil R. Kulkarni 9 SOON aka MARK LIEW; SINCO ELECTRONICS (DONGGUAN) CO., LTD. 37 Action Filed: 10/28/16 20 NG CHER YONG aka CY NG; MUI LIANG Trial Date: 8/16/21 TJOA; JIN SHAO PING; XU SHUGONG; Last CMC: 1/6/21 21 QUEK SEOW ENG and DOES 5 through 20, Next CMC: 5/6/21 inclusive, Original CC: TAB/19 22 FACC: 10/04/19 Defendants. SACC: 1/17/20 23 TACC: 1/8/21 24 AND RELATED CROSS-ACTION 25 26 On , 2021, plaintiff and cross-defendant SINCO TECHNOLOGIES PTE 27 LTD's (“SINCO’s”) timely noticed Motion to Strike portions of the Third Amended Cross- 28 Complaint filed January 8, 2021 by defendant and cross-complainant XINGKE ELECTRONICS -1- 4824-5368-8017-1 [PROPOSED] ORDER GRANTING PLAINTIFF'S MOTION TO STRIKE THIRD AMENDED CROSS- COMPLAINT (DONGGUAN) CO., LTD.; LIEW YEW SOON aka MARK LIEW; NG CHER YONG aka CY NG; and MUI LANG TJOA, aka ML TJOA, (“XINGKE”) came on regularly for hearing in the above-entitled court. Appearances were made by Jennifer E. Acheson/Lael D. Andara, Ropers, Majeski, Kohn and Bentley, for SINCO; and Jeffrey C.P. Wang, and Michael York, WHGC, P.L.C. for XINGKE. The Court, having reviewed the pleadings in support and in opposition to said motion, and considered oral argument of counsel, and finding good cause therefor, IT IS HEREBY ORDERED that SINCO’s Motion to Strike portions of the Third Amended Cross-Complaint as follows: 10 Paragraph 14:...In order to preserve assets and to prevent waste, dissipation, and loss of assets to the irreparable damage of Cross- 11 Complainants, it is necessary that the requested injunctive relief herein prayed for be granted. 12 Paragraphs 45, 133, 134,135, 137, 138: ...agreements, oral or 13 written... 14 Prayer Paragraph 4: For punitive damages, pursuant to the NB California Civil Code § 3294, in an amount appropriate to punish Ole 1 and set an example of Cross-Defendants, and each of them, and to Li deter such conduct in the future, the exact amount of such punitive 16 damages subject to proof at the time of trial; os 17 Prayer Paragraph 5: For the disgorgement of profits received by Ok 18 Cross-Defendants, and each of them, from Cross-Complainants, where the receipt of such profits can be traced to any act of fraud, Ye fraudulent concealment, false promise, or breach of fiduciary duty; 9 Prayer Paragraph 6: For the imposition of a constructive trust 20 upon all profits and proceeds related to or arising out of the operation of SinCo Singapore’s business that were derived from the 21 benefits received from Cross-Complainants presently in the possession, custody or control of Cross-Defendants; 22 Prayer Paragraph 7: For equitable relief in the form of an 23 injunction prohibiting the illicit conduct described herein; 24 MH 25 MH 26 i 27 Mf 28 / Ee 4824-5368-8017-1 [PROPOSED] ORDER GRANTING PLAINTIFF'S MOTION TO STRIKE THIRD AMENDED CROSS- COMPLAINT Prayer Paragraph 8: For attorney’s fees, expenses and costs incurred in pursuing the claims asserted herein, against Cross- Defendants and each of them, jointly and severally, as may be provided by contract and/or law;.. IT IS SO ORDERED. Date: JUDGE OF THE SUPERIOR COURT 10 11 12 13 14 NB Ole 1 Li 16 os 17 Ok 18 Ye 9 20 21 22 23 24 25 26 27 28 -3- 4824-5368-8017-1 [PROPOSED] ORDER GRANTING PLAINTIFF'S MOTION TO STRIKE THIRD AMENDED CROSS- COMPLAINT CASE NAME: SINCO TECHNOLOGIES PTE LTD V. XINGKE ELECTRONICS (DONGGUAN) CO., LTD., ET AL. ACTION NO.: 16CV301867 PROOF OF SERVICE METHOD OF SERVICE O First Class Mail DO Facsimile Oo Messenger Service O1 Overni ight Delivery I] E-Mail/Electronic Delivery 1. At the time of service I was over 18 years of age and not a party to this action. 2. My business address is 1001 Marshall Street, 5th Floor, Redwood City, California 94063, County of San Mateo. 10 3. On February 9, 2021 I served the following documents: 11 [PROPOSED] ORDER GRANTING PLAINTIFF SINCO TECHNOLOGIES PTE LTD'S MOTION TO STRIKE THIRD AMENDED CROSS-COMPLAINT 12 4. I served the documents on the persons at the address below (along with their fax numbers 13 and/or email addresses if service was by fax or email): 14 NB Jeffrey C.P. Wang Edwin K. Prather Ole 1 Kathleen E. Alparce Prather Law Offices Li John Giust 245 Fifth Street, Suite 103 16 Michael York San Francisco, California 94103 os 17 Jessica Crabbe Email: edwin@pratherlawoffices.com Ok 18 WHGC, P.L.C. 1301 Dove Street, Suite 1050 Ye Newport Beach, CA 92660 9 Email: JeffreyWang@whgclaw.com KathleenAlparce@whgclaw.com 20 JohnGiust@whgclaw.com 21 MichaelY ork@whgclaw.com JessicaCrabbe@whgclaw.com 22 ElaineWu@WHGCLaw.com FrontDesk@WHGCLaw.com 23 24 5. I served the documents by the following means: 25 a. O By United States mail: I enclosed the documents in a sealed envelope or package addressed to the persons at the addresses specified in item 4 and placed the envelope for 26 collection and mailing, following our ordinary business practices. I am readily familiar with this business’s practice for collecting and processing correspondence for mailing. On the same day 27 that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid at 28 the address listed in Paragraph 2 above. 4824-5368-8017.1 PROOF OF SERVICE b. O By overnight delivery: I enclosed the documents in an envelope or package provided by an overnight delivery carrier and addressed to the persons at the addresses in item 4. I placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier. Cc O By messenger: I served the documents by placing them in an envelope or package addressed to the persons at the addresses listed in item 4 and providing them to a messenger for service. d. O By fax transmission: Based on an agreement between the parties and in conformance with Rule 2.306, and/or as a courtesy, I faxed the documents to the persons at the fax numbers listed in item 4. No error was reported by the fax machine that I used. A copy of the record of the fax transmission is attached. e O By email or electronic transmission: In compliance with Code of Civil Procedure §1010.6, I sent the documents via my electronic service address (morgan.macnerland@ropers.com) to the persons at the email addresses listed in item 4. I did not receive, within a reasonable time after the transmission, any electronic message or other 10 indication that the transmission was unsuccessful. 11 f. By email or electronic transmission: In compliance with Code of Civil Procedure §1010.6, via my electronic business address (morgan.macnerland@ropers.com), I caused the 12 document(s) listed above to be electronically served through One Legal for the above-entitled case upon the parties listed in item 4. The file transmission was reported as complete and a copy 13 of the One Legal receipt will be maintained in our case file. 14 I declare under penalty of perjury under the laws of the State of California that the above Or is true and correct. Ole 15 Date: February 9, 2021 Li 16 of Ok 17 18 Xe 9 20 21 22 23 24 25 26 27 28 4824-5368-8017.1 PROOF OF SERVICE