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1 Claire E. Cochran (SBN 222529)
Natalie A. Xifo (SBN 280930) ELECTRONICALLY
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LAW OFFICES OF CLAIRE COCHRAN, P.C.
100 Pine Street, Suite 1250
F I L E D
3 Superior Court of California,
San Francisco, CA 94111 County of San Francisco
4 Telephone: (415) 580-6019 03/12/2021
Facsimile: (415) 745-3301 Clerk of the Court
BY: EDNALEEN ALEGRE
5 Deputy Clerk
6 Attorneys for Plaintiff
NATHAN PETER RUNYON
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF SAN FRANCISCO
10 [UNLIMITED JURISDICTION]
11 Case No. CGC-19-581099
NATHAN PETER RUNYON
12 DECLARATION OF AIMEE LEROUX
Plaintiff, RE CONFIRMATION OF PROPER EX
13 PARTE NOTICE
v.
14 [Filed Concurrently with Memorandum of
Points and Authorities; Declaration of Claire
15 PAYWARD, INC., a California Corporation E. Cochran, Esq. and Proposed Order]
d/b/a KRAKEN; and KAISER NG an individual Ex Parte Hearing Date: March 15, 2021
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and DOES 1-50, inclusive Time: 11:00 a.m.
17 Dept.: 302
Defendants.
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Date Action Filed: November 26, 2019
19 Trial Date: July 12, 2021
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DECLARATION OF AIMEE LEROUX RE CONFIRMATION OF PROPER EX PARTE NOTICE
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DECLARATION OF AIMEE LEROUX
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I, AIMEE LEROUX., declare as follows:
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1. I am a licensed paralegal and employed at the law firm Law Offices of Claire
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Cochran, P.C. (“LOCC”), who are the attorneys of record for Plaintiff NATHAN PETER
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RUNYON (“Plaintiff”) in the within civil proceeding. If called upon as a witness, I could and
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would competently testify to the following:
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2. This declaration is submitted to confirm proper ex parte notice of Plaintiff’s Ex
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Parte Application For Order Shortening Time For Plaintiff Nathan Peter Runyon’s Notice Of
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Motion To Appoint A Special Master.
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3. On March 12, 2021, at 8:53 a.m. I provided ex parte notice to Christopher
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LaVigne and Kimberly Pallen, attorneys of record for the Defendant, Payward Inc. d/b/a
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Kraken, and Kaiser Ng, via email. Specifically, ex parte notice was provided that that Claire
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Cochran or her associate of the Law Offices of Claire Cochran would be appearing in
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Department 302, of the San Francisco Courthouse located at 400 McAllister Street, CA on
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Friday, March 15, 2021 at 11:00 a.m. requesting the Court grant an Order Shortening Time for
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Plaintiff’s Notice of Motion and Motion to Appoint a Special Master in Runyon v. Payward et
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al, case #: CGC-19-581099. A true and correct copy of the ex parte notice transmitted to Mr.
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LaVigne and Ms. Pallen on March 12, 2021 at 8:53 a.m. is attached hereto as Exhibit “A.”
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I declare under penalty of perjury under the laws of the State of California that the foregoing is
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true and correct.
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Executed on March 12, 2021, at San Francisco California.
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AIMEE LEROUX
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Page | 1
DECLARATION OF AIMEE LEROUX RE CONFIRMATION OF PROPER EX PARTE NOTICE
Exhibit A
3/12/2021 The Law Offices of Claire Cochran Mail - Ex Parte Notice - Runyon v. Payward Inc., et al CGC-19-581099
Aimee Leroux
Ex Parte Notice - Runyon v. Payward Inc., et al CGC-19-581099
1 message
Aimee Leroux Fri, Mar 12, 2021 at 8:53 AM
To: Christopher.LaVigne@withersworldwide.com, Kimberly.Pallen@withersworldwide.com, Lalindra.Sanichar@withersworldwide.com
Cc: Claire Cochran , Natalie Xifo , Maya Sørensen
Dear Mr.LaVigne,
This email is ex parte notice that Claire Cochran or her associate, of The Law Offices of Claire Cochran on Mr. Runyon’s behalf will be appearing, via CourtCall, ex parte on March 15, 2021 at 11:00 a.m. in Department 302 of the San Francisco
Courthouse located at 400 McAllister Street, CA requesting the Court grant an Order Shortening Time for Plaintiff’s Notice of Motion and Motion to Appoint a Special Master in Runyon v. Payward, Inc. et al Case No. CGC-19-581099.
Plaintiff’s supporting papers will be emailed today before noon.
Thank you,
--
Aimee J Leroux
American Bar Association Certificated Paralegal
The Law Offices of Claire Cochran
100 Pine Street, Ste 1250
San Francisco, California 94111
Phone: (415) 580-6019
www.clairecochranlegal.com
This email and any files transmitted with it may contain confidential information that is legally privileged and is intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any
disclosure, copying, dissemination, distribution, or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this email in error please notify the sender by reply email and destroy the original transmission and its attachments without reading or saving them in
any manner.
https://mail.google.com/mail/u/0?ik=b95d05795c&view=pt&search=all&permthid=thread-a%3Ar276554687461957604&simpl=msg-a%3Ar-812326652… 1/1
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1 Claire E. Cochran (SBN 222529) Natalie A. Xifo (SBN 280930) ELECTRONICALLY 2 LAW OFFICES OF CLAIRE COCHRAN, P.C. 100 Pine Street, Suite 1250 F I L E D 3 Superior Court of California, San Francisco, CA 94111 County of San Francisco 4 Telephone: (415) 580-6019 03/12/2021 Facsimile: (415) 745-3301 Clerk of the Court BY: EDNALEEN ALEGRE 5 Deputy Clerk 6 Attorneys for Plaintiff NATHAN PETER RUNYON 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SAN FRANCISCO 10 [UNLIMITED JURISDICTION] 11 Case No. CGC-19-581099 NATHAN PETER RUNYON 12 DECLARATION OF AIMEE LEROUX Plaintiff, RE CONFIRMATION OF PROPER EX 13 PARTE NOTICE v. 14 [Filed Concurrently with Memorandum of Points and Authorities; Declaration of Claire 15 PAYWARD, INC., a California Corporation E. Cochran, Esq. and Proposed Order] d/b/a KRAKEN; and KAISER NG an individual Ex Parte Hearing Date: March 15, 2021 16 and DOES 1-50, inclusive Time: 11:00 a.m. 17 Dept.: 302 Defendants. 18 Date Action Filed: November 26, 2019 19 Trial Date: July 12, 2021 20 21 22 23 24 25 26 27 28 DECLARATION OF AIMEE LEROUX RE CONFIRMATION OF PROPER EX PARTE NOTICE 1 DECLARATION OF AIMEE LEROUX 2 I, AIMEE LEROUX., declare as follows: 3 1. I am a licensed paralegal and employed at the law firm Law Offices of Claire 4 Cochran, P.C. (“LOCC”), who are the attorneys of record for Plaintiff NATHAN PETER 5 RUNYON (“Plaintiff”) in the within civil proceeding. If called upon as a witness, I could and 6 would competently testify to the following: 7 2. This declaration is submitted to confirm proper ex parte notice of Plaintiff’s Ex 8 Parte Application For Order Shortening Time For Plaintiff Nathan Peter Runyon’s Notice Of 9 Motion To Appoint A Special Master. 10 3. On March 12, 2021, at 8:53 a.m. I provided ex parte notice to Christopher 11 LaVigne and Kimberly Pallen, attorneys of record for the Defendant, Payward Inc. d/b/a 12 Kraken, and Kaiser Ng, via email. Specifically, ex parte notice was provided that that Claire 13 Cochran or her associate of the Law Offices of Claire Cochran would be appearing in 14 Department 302, of the San Francisco Courthouse located at 400 McAllister Street, CA on 15 Friday, March 15, 2021 at 11:00 a.m. requesting the Court grant an Order Shortening Time for 16 Plaintiff’s Notice of Motion and Motion to Appoint a Special Master in Runyon v. Payward et 17 al, case #: CGC-19-581099. A true and correct copy of the ex parte notice transmitted to Mr. 18 LaVigne and Ms. Pallen on March 12, 2021 at 8:53 a.m. is attached hereto as Exhibit “A.” 19 I declare under penalty of perjury under the laws of the State of California that the foregoing is 20 true and correct. 21 Executed on March 12, 2021, at San Francisco California. 22 23 24 AIMEE LEROUX 25 26 27 28 Page | 1 DECLARATION OF AIMEE LEROUX RE CONFIRMATION OF PROPER EX PARTE NOTICE Exhibit A 3/12/2021 The Law Offices of Claire Cochran Mail - Ex Parte Notice - Runyon v. Payward Inc., et al CGC-19-581099 Aimee Leroux Ex Parte Notice - Runyon v. Payward Inc., et al CGC-19-581099 1 message Aimee Leroux Fri, Mar 12, 2021 at 8:53 AM To: Christopher.LaVigne@withersworldwide.com, Kimberly.Pallen@withersworldwide.com, Lalindra.Sanichar@withersworldwide.com Cc: Claire Cochran , Natalie Xifo , Maya Sørensen Dear Mr.LaVigne, This email is ex parte notice that Claire Cochran or her associate, of The Law Offices of Claire Cochran on Mr. Runyon’s behalf will be appearing, via CourtCall, ex parte on March 15, 2021 at 11:00 a.m. in Department 302 of the San Francisco Courthouse located at 400 McAllister Street, CA requesting the Court grant an Order Shortening Time for Plaintiff’s Notice of Motion and Motion to Appoint a Special Master in Runyon v. Payward, Inc. et al Case No. CGC-19-581099. Plaintiff’s supporting papers will be emailed today before noon. Thank you, -- Aimee J Leroux American Bar Association Certificated Paralegal The Law Offices of Claire Cochran 100 Pine Street, Ste 1250 San Francisco, California 94111 Phone: (415) 580-6019 www.clairecochranlegal.com This email and any files transmitted with it may contain confidential information that is legally privileged and is intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, dissemination, distribution, or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this email in error please notify the sender by reply email and destroy the original transmission and its attachments without reading or saving them in any manner. https://mail.google.com/mail/u/0?ik=b95d05795c&view=pt&search=all&permthid=thread-a%3Ar276554687461957604&simpl=msg-a%3Ar-812326652… 1/1