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E-FILED
DeMaria Law Firm, A.P.C. 5/3/2021 3:16 PM
Anthony N. DeMaria, #177894 Superior Court of California
ademaria@demarialawfirm.com County of Fresno
1690 W. Shaw Ave. Suite 220 By: A. Ramos, Deputy
Fresno, California 93711
Telephone:
m.gww
(559) 206-2410
Facsimile: (559) 570-0126
Attorneys for Defendant, State Center
Community College District
QOOVO
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY 0F FRESNO
10
ANITA REYES, Case No. 19CECGO3826
11
Plaintifi', STIPULATION REGARDING
12 NEUROPSYCHOLOGICAL EXAM 0F
v , PLAINTIFF ANITA REYES BY
13 DEFENDANT’S RETAINED DOCTOR
STATE CENTER COMMUNITY COLLEGE
14 DISTRICT, MADERA COMMUNITY
COLLEGE CENTER and DOES 1-20,
15
Defendant.
16
17
18
By and through their counsel, the parties hereto stipulate as follows regarding the
19 Defendant’s, STATE CENTER COMMUNITY COLLEGE DISTRICT, (“Defendant”),
20 neuropsychological examination of Plaintiff ANITA REYES (“Plaintiff”):
21 1.
'This stipulation is deemed to incorporate all provisions of California Civil Code of
22 Procedures § 2032.020 ct seq. and all case law interpreting said section.
23 2. The neuropsychological exam by Defendant’s retained doctor shall be performed by
24 Robert Asarnow, Ph.D., with a specialty in licensed clinical neuropsychology.
25 3. No representative other than Plaintiff and the examining neuropsychologist retained
26 be allowed to be present during the examination.
by Defendant shall
27 4. The date, time, and place for the neuropsychological exam by Defendant’s retained
28 expert shall be directed in a notice, at a locatiorllwithin 75 miles of Plaintiff’s residence. The
STIPULATION REGARDING NEUROPSYCHOLOGICAL EXAM 0F PLAINTIFF
ANITA REYES BY DEFENDANT'S RETAINED DOCTOR
tentative dates for the exam are May 24, 2021 and May 25, 2021 .
5. Plaintiff shall not be required to fill out patient information forms of any type
whatsoever, including but not limited to, “new patien ” forms, insurance forms, identification forms,
authorization for records, arbitration forms, waivers and releases and will not be asked to do so by
Dr. Asarnow
\OOOQO\U'I-§WNu—-
or his staff.This provision shall not be interpreted to include any questionnaires,
waivers, or related documents relating to COVID-l 9 clearance and precautions.
6. The medical professional’s office will not take any photographs, fingerprints, or
other identification information from Plaintiff, including, but not limited to license, social security
number, and home address.
7. The total exam may take up to eight (8) hours, over the course of two days, with
Plaintiff able to take reasonable and appropriate breaks as needed. Said breaks shall not count
against the eight (8) hours allotted for the exam. The examination will be a neuropsychological
examination addressing the injuries and damages the Plaintiff has placed at issue in this case. The
examination shall not delve into unrelated areas which are protected by Plaintiff’s Constitutional
rights. If at any time during the proceedings, Plaintiff feels in reasonable, good faith, that the
proceeding has become abusive, she will immediately notify her counsel or other designated
representative to try and
NNNNNNNNNv—br—a—AHt—au—a—np—nn—av—a
resolve the matter at that time. Plaintiff has the right to terminate the
proceeding and seek a protective order from the Court. If the parties are unable to resolve the issue,
should the Court order that the
OOflQM-thHOQOOQOMAWN—‘O
exam be reconvened, Defendants will have the fullremaining time
to complete the examination, but not any additional time.
8. The examination shall be a neuropsychological examination. The examination will
not include any other disciplines except neuropsychology. Dr. Asamow will be the only examiner
of Plaintiff (however, neuropsychological results may be scored and reviewed by a separate
neuropsychological test review and scoring service).
9. Dr. Asamow is not to question Plaintiffregarding her conversations with her counsel,
Eugenia Steele, Allegra Rineer, Tracy Horn, or any person affiliated with her counsel or counsel’s
office, The Torkzadeh Law Firm (TorkLaw). Further, Plaintiff is not to be questioned regarding her
counsel’s evaluation of Plaintifi’s claims against gefendants, nor is Plaintiffto be questioned about
STIPULATION REGARDING NEUROPSYCHOLOGICAL EXAM OF PLAINTIFF
ANITA REYES BY DEFENDANT’S RETAINED DOCTOR
any discussions Plaintiff has had with her counsel regarding such evaluations, as this would be an
invasion of the attorney-client and attorney work product privileges.
10. The purpose of this neuropsychological exam is to allow a trained psychologist to
evaluate Plaintiff’s neuropsychological condition, as Plaintiff has put her neuropsychological
condition and the sources of her alleged neuropsychological damages at issue in this present action
\OOOQQUI-hww—
by alleging ongoing damages.
11. Dr. Asarnow’s examination may only include the following, unless during the
examination it isdetermined that other, or alternative tests are needed for Dr. Asamow’s purposes,
at which time counsel should meet and confer as to the same, and seek a Court determination on
additional or alternative tests if they cannot agree:
(a) Clinical Interview
(b) Advanced Clinical Solutions Tests of Premorbid Function and Effort
(c) Beck Anxiety Inventory
(d) Beck Depression Inventory-Z
(e) California
NNNNNHHHHHI—tr—in—An—a—a
Verbal Learning Test-II
(f) Delis-Kaplan Executive Function System Subtests (D-KEFS)
(1) Trail Making
(2) Verbal Fluency
(3) Color-Word Interference
(4) Twenty Questions
(g) Detailed Assessment of Post-Traumatic Stress
(h) Minnesota Multiphasic Inventory 2-RF
(i) Purdue Pegboard
(i) Tapping Test
(k) Test of Memory Malingering
(1) Validity Indicatory Profile
(m) Wechsler Adult Intelligence Scale
- IV (WAIS-IV)
(n) Wechsler Memory Scale-IV (WMS-IV3)
STIPULATION REGARDING NEUROPSYCHOLOGICAL EXAM 0F PLAINTIFF
ANITA REYES BY DEFENDANT’S RETAINED DOCTOR
fl 12. A copy of the raw data generated and all test results regarding Plaintiff shall be
exchanged simultaneously with Plaintiff’s neuropsychological expert according to
neuropsychological guidelines within fourteen (14) days from the date of the examination.
13. Good cause for the examination exists in that Plaintiff has placed her mental
condition directly at issue in the above-captioned case.
\DOOQQUI-th
14. Plaintiff is entitled to record the exam by use of an auditory device if she so desires
and elects to bring one; no such device will be provided to her by Dr. Asarnow’s office. Dr. Asarnow
and his staff will accommodate all reasonable requests t0 accomplish this recording, including, but
not limited to taking any necessary breaks during the examination; taking a break if technical
difficulties arise; making available all other reasonable accommodations to allow the effective
recording of the neuropsychological examination as provided by Code of Civil Procedure §
2032.530.
15. Defendants shall provide Dr. Asamow with a copy of this stipulation to promptly
advise him that he must comply with the limitations imposed by this stipulation before his
examination of Plaintiff.
16. Defendants shall produce to Plaintiff’s counsel the written report(s) of Dr. Asamow
(and any related reports of psychological testing whether done by computer scoring, hand scoring,
NNNNNNNNNI—Iv—‘r—I—n—nmw—nn—AH
or anyone else) by email, overnight delivery, or personal delivery no later than 30 days afier the
receipt ofthe scored test data in keeping with California Code of Civil Procedure § 2032.610, which
OOQQU'I-fib-lNI—‘OWOOQONMAUJNo—IO
requires that “a detailed written report setting out the history examinations, findings, including the
results of alltests made, diagnoses, prognoses, and conclusions of the examiner” be provided to the
examined party within thirty (30) days of the exam, or within 15 days of trial, whichever is earlier.
Plaintiff reserves the right to and will move to exclude Robert Asamow, Ph.D. from testifying as to
any “prognoses, diagnoses and conclusions” that arc not timely in writing to Plaintiff in compliance
with Code of Civil Procedure §2034.270. Plaintiff shall provide all of Plaintiff’s damages retained
expert reports per Califomia Code of Civil Procedure §2034.270, and the failure to do so, or to
provide reports that do not include allopinions can and shall result in motions to exclude such later
opinions and testimony.
4
STIPULATION REGARDING NEUROPSYCHOLOGICAL EXAM OF PLAINTIFF
ANITA REYES BY DEFENDANT’S RETAINED DOCTOR
17. The teststaken by Plaintiff as part of the exam, along with any notes and/or written
reports and/or records, raw data maintained in any format, including electronic data, by Robert
Asarnow, Ph.D.
.pLaJN
are confidential medical records relating to Plaintiff’s mental health and shall not
be subj ect t0 distribution without the written authorization of Plaintiff to anyone except counsel for
Defendants, counsel’s experts or consultants, counsel’s staff, and the insurance carrier, who shall
treat these documents as confidential and subject to a protective order.
18. Plaintiff reserves the right to argue that any information acquired or learned, or any
\OOOQQM
evaluation made in violation of this agreement, will not be admissible evidence for any reason. The
parties further agree that the court may, upon motion at trial, strike, preclude, or limit any testimony
10 of the examiner as appropriate and Plaintiff is not waiving her right to such relief by agreeing to this
11 examination. The parties reserve the right to seek whatever sanctions they deem appropriate.
12 l9. This agreement represents the entire and complete scope of the agreement between
13 Plaintiff and Defendants for the Neuropsychological Examination of Plaintiff, Anita Reyes. No oral
14 or implied statements or representations are part of this agreement. This agreement may be modified
15 or changed only upon the express written statement of all parties to this agreement.
16 20. Nothing herein shall be construed as a waiver of Plaintiff’s privacy rights, medical
17 privacy rights, doctor patient privileges, psychotherapist patient privileges. Nothing herein shall be
l8 construed as a waiver of Plaintiff’s right to challenge the admissibility or appropriateness of any
19 opinion or contention.
20 IT IS SO STIPULATED.
W,
21
Dated: April 5_O, 2021 DeMaria Law Finn, A.P.c.
22
23
24 Bv:
Anthony N. DeMaria
25 S. Nicole Tucker, Provisionally Licensed Lawyer
Attorneys for Defendant, STATE CENTER
26 COMMUNITY COLLEGE DISTRICT
27
28
5
STIPULATION REGARDING NEUROPSYCHOLOGICAL EXAM 0F PLAINTIFF
ANITA REYES BY DEFENDANT’S RETAINED DOCTOR
Dated: April fl, 2021 The Torkzadeh Law Firm
Bv: WWW
‘fugenia L. Steele
”’1’”
Tracy R. Horn
\OOOQQUIAUJNH
Attorneys for Plaintiff, ANITA REYES
NNNNNNNNNHr‘HwHqu—lp—In—n
OOQGM-bDJN'—‘O©OOQ@MAMNHO
6
STIPULATION REGARDING NEUROPSYCHOLOGICAL EXAM 0F PLAINTIFF
ANITA REYES BY DEFENDANT’S RETAINED DOCTOR
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF FRESNO
At the time of service, I was over 18 years of age and not a party to this action. I am
employed in the County of Fresno, State of California. My business address is 1690 W. Shaw
Ave., Suite 220, Fresno, CA 9371 1.
On May 3, 2021, I served true copies of the following document(s) described as
STIPULATION REGARDING NEUROPSYCHOLOGICAL EXAM OF PLAINTIFF
ANITA REYES BY DEFENDANT’S RETAINED DOCTOR on the interested parties in this
action as follows:
Eugenia L. Steele
The Torkzadeh Law Firm
18650 MacArthur Blvd., Suite 300
Irvine, CA 92612
eu enia torklaw.com
allegra@t0rklaw.com
claudia@t01'klaw.com
XXX BY ELECTRONIC SERVICE: Based on a court order or an agreement 0f the
parties t0 accept electronic service, I caused the documents to be sent t0 the persons at the
electronic service addresses listed above. The electronic service address from which Iserved the
documents is tmaxwell@demarialawfim1.com.
XXX BY MAIL: I enclosed said document(s) in a sealed envelope or package addressed
to the persons at the address listed on the Service List and placed the envelope for 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 the
correspondence is placed from collection and mailing itis deposited in the ordinary course of
business with the United States Postal Service, in a sealed envelope with postage fully pre-paid.
I declare under penalty of perjury under the laws of the United States of America that the
20 foregoing is true and correct and that I am employed in the office 0f a member of the bar 0f this
Court at whose direction the service was made.
21
Executed on May 3, 2021, at Fresno, California.
22
23
24
CMVWQQQ
Teri Maxwell
Preview
E-FILED DeMaria Law Firm, A.P.C. 5/3/2021 3:16 PM Anthony N. DeMaria, #177894 Superior Court of California ademaria@demarialawfirm.com County of Fresno 1690 W. Shaw Ave. Suite 220 By: A. Ramos, Deputy Fresno, California 93711 Telephone: m.gww (559) 206-2410 Facsimile: (559) 570-0126 Attorneys for Defendant, State Center Community College District QOOVO SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY 0F FRESNO 10 ANITA REYES, Case No. 19CECGO3826 11 Plaintifi', STIPULATION REGARDING 12 NEUROPSYCHOLOGICAL EXAM 0F v , PLAINTIFF ANITA REYES BY 13 DEFENDANT’S RETAINED DOCTOR STATE CENTER COMMUNITY COLLEGE 14 DISTRICT, MADERA COMMUNITY COLLEGE CENTER and DOES 1-20, 15 Defendant. 16 17 18 By and through their counsel, the parties hereto stipulate as follows regarding the 19 Defendant’s, STATE CENTER COMMUNITY COLLEGE DISTRICT, (“Defendant”), 20 neuropsychological examination of Plaintiff ANITA REYES (“Plaintiff”): 21 1. 'This stipulation is deemed to incorporate all provisions of California Civil Code of 22 Procedures § 2032.020 ct seq. and all case law interpreting said section. 23 2. The neuropsychological exam by Defendant’s retained doctor shall be performed by 24 Robert Asarnow, Ph.D., with a specialty in licensed clinical neuropsychology. 25 3. No representative other than Plaintiff and the examining neuropsychologist retained 26 be allowed to be present during the examination. by Defendant shall 27 4. The date, time, and place for the neuropsychological exam by Defendant’s retained 28 expert shall be directed in a notice, at a locatiorllwithin 75 miles of Plaintiff’s residence. The STIPULATION REGARDING NEUROPSYCHOLOGICAL EXAM 0F PLAINTIFF ANITA REYES BY DEFENDANT'S RETAINED DOCTOR tentative dates for the exam are May 24, 2021 and May 25, 2021 . 5. Plaintiff shall not be required to fill out patient information forms of any type whatsoever, including but not limited to, “new patien ” forms, insurance forms, identification forms, authorization for records, arbitration forms, waivers and releases and will not be asked to do so by Dr. Asarnow \OOOQO\U'I-§WNu—- or his staff.This provision shall not be interpreted to include any questionnaires, waivers, or related documents relating to COVID-l 9 clearance and precautions. 6. The medical professional’s office will not take any photographs, fingerprints, or other identification information from Plaintiff, including, but not limited to license, social security number, and home address. 7. The total exam may take up to eight (8) hours, over the course of two days, with Plaintiff able to take reasonable and appropriate breaks as needed. Said breaks shall not count against the eight (8) hours allotted for the exam. The examination will be a neuropsychological examination addressing the injuries and damages the Plaintiff has placed at issue in this case. The examination shall not delve into unrelated areas which are protected by Plaintiff’s Constitutional rights. If at any time during the proceedings, Plaintiff feels in reasonable, good faith, that the proceeding has become abusive, she will immediately notify her counsel or other designated representative to try and NNNNNNNNNv—br—a—AHt—au—a—np—nn—av—a resolve the matter at that time. Plaintiff has the right to terminate the proceeding and seek a protective order from the Court. If the parties are unable to resolve the issue, should the Court order that the OOflQM-thHOQOOQOMAWN—‘O exam be reconvened, Defendants will have the fullremaining time to complete the examination, but not any additional time. 8. The examination shall be a neuropsychological examination. The examination will not include any other disciplines except neuropsychology. Dr. Asamow will be the only examiner of Plaintiff (however, neuropsychological results may be scored and reviewed by a separate neuropsychological test review and scoring service). 9. Dr. Asamow is not to question Plaintiffregarding her conversations with her counsel, Eugenia Steele, Allegra Rineer, Tracy Horn, or any person affiliated with her counsel or counsel’s office, The Torkzadeh Law Firm (TorkLaw). Further, Plaintiff is not to be questioned regarding her counsel’s evaluation of Plaintifi’s claims against gefendants, nor is Plaintiffto be questioned about STIPULATION REGARDING NEUROPSYCHOLOGICAL EXAM OF PLAINTIFF ANITA REYES BY DEFENDANT’S RETAINED DOCTOR any discussions Plaintiff has had with her counsel regarding such evaluations, as this would be an invasion of the attorney-client and attorney work product privileges. 10. The purpose of this neuropsychological exam is to allow a trained psychologist to evaluate Plaintiff’s neuropsychological condition, as Plaintiff has put her neuropsychological condition and the sources of her alleged neuropsychological damages at issue in this present action \OOOQQUI-hww— by alleging ongoing damages. 11. Dr. Asarnow’s examination may only include the following, unless during the examination it isdetermined that other, or alternative tests are needed for Dr. Asamow’s purposes, at which time counsel should meet and confer as to the same, and seek a Court determination on additional or alternative tests if they cannot agree: (a) Clinical Interview (b) Advanced Clinical Solutions Tests of Premorbid Function and Effort (c) Beck Anxiety Inventory (d) Beck Depression Inventory-Z (e) California NNNNNHHHHHI—tr—in—An—a—a Verbal Learning Test-II (f) Delis-Kaplan Executive Function System Subtests (D-KEFS) (1) Trail Making (2) Verbal Fluency (3) Color-Word Interference (4) Twenty Questions (g) Detailed Assessment of Post-Traumatic Stress (h) Minnesota Multiphasic Inventory 2-RF (i) Purdue Pegboard (i) Tapping Test (k) Test of Memory Malingering (1) Validity Indicatory Profile (m) Wechsler Adult Intelligence Scale - IV (WAIS-IV) (n) Wechsler Memory Scale-IV (WMS-IV3) STIPULATION REGARDING NEUROPSYCHOLOGICAL EXAM 0F PLAINTIFF ANITA REYES BY DEFENDANT’S RETAINED DOCTOR fl 12. A copy of the raw data generated and all test results regarding Plaintiff shall be exchanged simultaneously with Plaintiff’s neuropsychological expert according to neuropsychological guidelines within fourteen (14) days from the date of the examination. 13. Good cause for the examination exists in that Plaintiff has placed her mental condition directly at issue in the above-captioned case. \DOOQQUI-th 14. Plaintiff is entitled to record the exam by use of an auditory device if she so desires and elects to bring one; no such device will be provided to her by Dr. Asarnow’s office. Dr. Asarnow and his staff will accommodate all reasonable requests t0 accomplish this recording, including, but not limited to taking any necessary breaks during the examination; taking a break if technical difficulties arise; making available all other reasonable accommodations to allow the effective recording of the neuropsychological examination as provided by Code of Civil Procedure § 2032.530. 15. Defendants shall provide Dr. Asamow with a copy of this stipulation to promptly advise him that he must comply with the limitations imposed by this stipulation before his examination of Plaintiff. 16. Defendants shall produce to Plaintiff’s counsel the written report(s) of Dr. Asamow (and any related reports of psychological testing whether done by computer scoring, hand scoring, NNNNNNNNNI—Iv—‘r—I—n—nmw—nn—AH or anyone else) by email, overnight delivery, or personal delivery no later than 30 days afier the receipt ofthe scored test data in keeping with California Code of Civil Procedure § 2032.610, which OOQQU'I-fib-lNI—‘OWOOQONMAUJNo—IO requires that “a detailed written report setting out the history examinations, findings, including the results of alltests made, diagnoses, prognoses, and conclusions of the examiner” be provided to the examined party within thirty (30) days of the exam, or within 15 days of trial, whichever is earlier. Plaintiff reserves the right to and will move to exclude Robert Asamow, Ph.D. from testifying as to any “prognoses, diagnoses and conclusions” that arc not timely in writing to Plaintiff in compliance with Code of Civil Procedure §2034.270. Plaintiff shall provide all of Plaintiff’s damages retained expert reports per Califomia Code of Civil Procedure §2034.270, and the failure to do so, or to provide reports that do not include allopinions can and shall result in motions to exclude such later opinions and testimony. 4 STIPULATION REGARDING NEUROPSYCHOLOGICAL EXAM OF PLAINTIFF ANITA REYES BY DEFENDANT’S RETAINED DOCTOR 17. The teststaken by Plaintiff as part of the exam, along with any notes and/or written reports and/or records, raw data maintained in any format, including electronic data, by Robert Asarnow, Ph.D. .pLaJN are confidential medical records relating to Plaintiff’s mental health and shall not be subj ect t0 distribution without the written authorization of Plaintiff to anyone except counsel for Defendants, counsel’s experts or consultants, counsel’s staff, and the insurance carrier, who shall treat these documents as confidential and subject to a protective order. 18. Plaintiff reserves the right to argue that any information acquired or learned, or any \OOOQQM evaluation made in violation of this agreement, will not be admissible evidence for any reason. The parties further agree that the court may, upon motion at trial, strike, preclude, or limit any testimony 10 of the examiner as appropriate and Plaintiff is not waiving her right to such relief by agreeing to this 11 examination. The parties reserve the right to seek whatever sanctions they deem appropriate. 12 l9. This agreement represents the entire and complete scope of the agreement between 13 Plaintiff and Defendants for the Neuropsychological Examination of Plaintiff, Anita Reyes. No oral 14 or implied statements or representations are part of this agreement. This agreement may be modified 15 or changed only upon the express written statement of all parties to this agreement. 16 20. Nothing herein shall be construed as a waiver of Plaintiff’s privacy rights, medical 17 privacy rights, doctor patient privileges, psychotherapist patient privileges. Nothing herein shall be l8 construed as a waiver of Plaintiff’s right to challenge the admissibility or appropriateness of any 19 opinion or contention. 20 IT IS SO STIPULATED. W, 21 Dated: April 5_O, 2021 DeMaria Law Finn, A.P.c. 22 23 24 Bv: Anthony N. DeMaria 25 S. Nicole Tucker, Provisionally Licensed Lawyer Attorneys for Defendant, STATE CENTER 26 COMMUNITY COLLEGE DISTRICT 27 28 5 STIPULATION REGARDING NEUROPSYCHOLOGICAL EXAM 0F PLAINTIFF ANITA REYES BY DEFENDANT’S RETAINED DOCTOR Dated: April fl, 2021 The Torkzadeh Law Firm Bv: WWW ‘fugenia L. Steele ”’1’” Tracy R. Horn \OOOQQUIAUJNH Attorneys for Plaintiff, ANITA REYES NNNNNNNNNHr‘HwHqu—lp—In—n OOQGM-bDJN'—‘O©OOQ@MAMNHO 6 STIPULATION REGARDING NEUROPSYCHOLOGICAL EXAM 0F PLAINTIFF ANITA REYES BY DEFENDANT’S RETAINED DOCTOR PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF FRESNO At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of Fresno, State of California. My business address is 1690 W. Shaw Ave., Suite 220, Fresno, CA 9371 1. On May 3, 2021, I served true copies of the following document(s) described as STIPULATION REGARDING NEUROPSYCHOLOGICAL EXAM OF PLAINTIFF ANITA REYES BY DEFENDANT’S RETAINED DOCTOR on the interested parties in this action as follows: Eugenia L. Steele The Torkzadeh Law Firm 18650 MacArthur Blvd., Suite 300 Irvine, CA 92612 eu enia torklaw.com allegra@t0rklaw.com claudia@t01'klaw.com XXX BY ELECTRONIC SERVICE: Based on a court order or an agreement 0f the parties t0 accept electronic service, I caused the documents to be sent t0 the persons at the electronic service addresses listed above. The electronic service address from which Iserved the documents is tmaxwell@demarialawfim1.com. XXX BY MAIL: I enclosed said document(s) in a sealed envelope or package addressed to the persons at the address listed on the Service List and placed the envelope for 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 the correspondence is placed from collection and mailing itis deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully pre-paid. I declare under penalty of perjury under the laws of the United States of America that the 20 foregoing is true and correct and that I am employed in the office 0f a member of the bar 0f this Court at whose direction the service was made. 21 Executed on May 3, 2021, at Fresno, California. 22 23 24 CMVWQQQ Teri Maxwell