Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Namo, State Bar number, and address): FOR COURT USE ONLY
Jesse J. Maddox, Bar No. 219091 Nathan T. Jackson, Bar No. 285620
Liebert Cassidy Whitmore E-FILED
5250 North Palm Ave, Suite 310 9/15/2021 4:51 PM
Fresno, CA 93721 Superior Court of California
TELEPHONE No: 559.256.7800 FAX NO. (Optional): 559.449.4535, County of Fresno
E-mail appress: jmaddox@Icwlegal.com; njackson@Icwlegal.com By: K. Daves, Deputy
ATTORNEY FOR (Name): Board of Trustees of California State University
SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO
street appress: 1130 O Street
MAILING AppRess: 1130 O Street
city Ano zip cope: Fresno, 93721
BRANCH NAME:
PLAINTIFF/PETITIONER: A. SAMEH EL KHARBAWY
DEFENDANT/RESPONDENT: BOARD OF TRUSTEES OF CALIFORNIA STATE
UNIVERSITY, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER’
‘Check one): UNLIMITED CASE (1 suMIteD CASE 21CECG02214
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: September 30, 2021 Time: 3:30 p.m. Dept.: 402 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Nathan T.Jackson
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. EX This statement is submitted by party (name): Defendant Board of Trustees of California State University
b. [1 This statement is submitted jointly by parties (names):
Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. (1) The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
aQ All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
6 O The following parties named in the complaint or cross-complaint
(1) (have not been served (specify names and explain why not):
(2) [1 have been served but have not appeared and have not been dismissed (specify names):
(3) (shave had a default entered against them (specify names):
c. 1 The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
Description of case
a. Type of case in xX complaint O cross-complaint (Describe, including causes of action):
In this employment law action, Plaintiff alleges he was retaliated against for engaging in protected activities, and that
he was harassed, discriminated against, and retaliated against on the basis of his middle-eastern ancestry. He
also alleges he was denied equal pay on the basis of his race/national origin. Defendant denies all material
allegations and mantains that Plaintiff is entitled to no relief.
Page 1 of 5
Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal, Rules of Court,
Judicial Council of California rules 3.720-3.730
CM-110 [Rev. September 1, 2021] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: A. SAMEH EL KHARBAWY CASE NUMBER:
DEFENDANT/RESPONDENT: BOARD OF TRUSTEES OF CALIFORNIA STATE 21CECG02214
UNIVERSITY, 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.)
oO (If more space is needed, check this box and attach a page designated as Attachment 4b.)
Jury or nonjury trial
The party or parties request 1] a jury trial D anoniury trial. (If more than one party, provide the name of each party
requesting a jury trial):
Trial date
a. (1 The trial has been set for (date):
b. Bd 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):
Oct 13-29, 2021 (trial); Nov 8-9, 2021 (PERB hearing); Nov 15-25, 2021 (trial); Dec 1, 2021 (mediation); March 15-
31, 2022 (trial); April 19-27, 2022 (trial); July 8-19, 2022 (trial); Aug 15-24, 2022 (trial); Sept 12-23, 2022 (trial); Jan
9-23, 2023 (trial)
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a 1) days (specify number): 21-28
b. [1 hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial KX by the attorney or party listed in the caption OO by the following:
a Attorney:
b. Firm:
Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
g Additional representation is described in Attachment 8.
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 of the California Rules of Court for information about the
processes available through the court and community programs in this case.
(1) For parties represented by counsel: Counsel O has 0 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 0 has Chas not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) 0 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):
Rule 3.811(b)(8) [multiple causes of action and alleged damages in excess of $50,000]
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5
American LegalNet
www. rms WorkFl
CM-110
PLAINTIFF/PETITIONER: A. SAMEH EL KHARBAWY CASE NUMBER:
DEFENDANT/RESPONDENT: BOARD OF TRUSTEES OF CALIFORNIA STATE 21CECG02214
UNIVERSITY, 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 X 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
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5
CM-110
PLAINTIFF/PETITIONER: A. SAMEH EL KHARBAWY ‘CASE NUMBER:
DEFENDANT/RESPONDENT: BOARD OF TRUSTEES OF CALIFORNIA STATE 21CECG02214
UNIVERSITY, et al.
11. Insurance
a insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Oo Yes 0 No
c. 1 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.
oO Bankruptcy UO 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. 0 Amotion to oO consolidate 0 coordinate will be filed by (name party):
14, Bifurcation
(1 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
& The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Defendant expects to file several discovery-related motions, at least two separate anti-SLAPP motions for two
different defendants, a motion for judgment on the pleadings, demurrers and motions to strike once the the other
defendants are served, and a motion for summary judgment/summary adjudication.
16. Discovery
a 0 The party or parties have completed all discovery.
b. & The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Descriptio Date
Defendant Written Discovery June 2022
Defendant Expert Deposition(s) Per Code
Defendant Plaintiff's Deposition(s) June 2022
c. I The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
Plaintiff has refused to cooperate in the preparation of a protective order, despite the fact both parties have
asked for one for different reasons in the case.
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5
CM-110
PLAINTIFF/PETITIONER: A. SAMEH EL KHARBAWY CASE NUMBER.
DEFENDANT/RESPONDENT: BOARD OF TRUSTEES OF CALIFORNIA STATE 21CECG02214
UNIVERSITY, et al
17. Economic litigation
aQ 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
6.0 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
oO 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. &] 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. [1] __ 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): 0
| 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 requil
r(\.
Date: September 15, 2021
Nathan T. Jackson
t
(TYPE OR PRINT NAME) =n P OR ATTORNEY)
>
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
CD Additional signatures are attached
CM-110 [Rev. September1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5
Am eal nc
www
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF SACRAMENTO
1am employed in the County of Sacramento, State of California. I am over the age of 18
and not a party to the within action; my business address is: 400 Capitol Mall, Suite 1260,
Sacramento, CA 95814.
On September 15, 2021, I served the foregoing document(s) described as CASE
MANAGEMENT STATEMENT in the manner checked below on all interested parties in this
action addressed as follows:
Andrew Hillier
Paul Garcia
10 Hillier Law
600 W. Broadway, Suite 700
ll San Diego, CA 92101
telephone: 619.500.7906
12 facsimile: 619.839.3895
ees
BESs email: andrew@ahillierlaw.com;
Bes 13 paul@ahillierlaw.com
BQG<
>ELO 14
2 aa
a3 Mw (BY U.S. MAIL) I am “readily familiar” with the firm’s practice of collection and
15 processing correspondence for mailing. Under that practice it would be deposited with
geo
Soa the U.S. Postal Service on that same day with postage thereon fully prepaid at
5E8s 16 Sacramento, California, in the ordinary course of business. I am aware that on motion
of the party served, service is presumed invalid if postal cancellation date or postage
17 meter date is more than one day after date of deposit for mailing in affidavit.
18 (BY ELECTRONIC SERVICE) By electronically mailing a true and correct copy
through Liebert Cassidy Whitmore’s electronic mail system from
19 mwibbenhorst@Icwlegal.com to the email address(es) set forth above. I did not
receive, within a reasonable time after the transmission, any electronic message or
20 other indication that the transmission was unsuccessful.
21 Executed on September 15, 2021, at Sacramento, California.
22 I declare under penalty of perjury under the laws of the State of California that the
23 foregoing is true and correct.
24
Hau aue. Udibbees hewt
25 Mariana Wibbenhorst
26
27
28
1
Proof
of Service
9796027.1 FRO07-003
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Namo, State Bar number, and address): FOR COURT USE ONLY Jesse J. Maddox, Bar No. 219091 Nathan T. Jackson, Bar No. 285620 Liebert Cassidy Whitmore E-FILED 5250 North Palm Ave, Suite 310 9/15/2021 4:51 PM Fresno, CA 93721 Superior Court of California TELEPHONE No: 559.256.7800 FAX NO. (Optional): 559.449.4535, County of Fresno E-mail appress: jmaddox@Icwlegal.com; njackson@Icwlegal.com By: K. Daves, Deputy ATTORNEY FOR (Name): Board of Trustees of California State University SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO street appress: 1130 O Street MAILING AppRess: 1130 O Street city Ano zip cope: Fresno, 93721 BRANCH NAME: PLAINTIFF/PETITIONER: A. SAMEH EL KHARBAWY DEFENDANT/RESPONDENT: BOARD OF TRUSTEES OF CALIFORNIA STATE UNIVERSITY, et al. CASE MANAGEMENT STATEMENT CASE NUMBER’ ‘Check one): UNLIMITED CASE (1 suMIteD CASE 21CECG02214 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: September 30, 2021 Time: 3:30 p.m. Dept.: 402 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Nathan T.Jackson INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. EX This statement is submitted by party (name): Defendant Board of Trustees of California State University b. [1 This statement is submitted jointly by parties (names): Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. (1) The cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) aQ All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. 6 O The following parties named in the complaint or cross-complaint (1) (have not been served (specify names and explain why not): (2) [1 have been served but have not appeared and have not been dismissed (specify names): (3) (shave had a default entered against them (specify names): c. 1 The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): Description of case a. Type of case in xX complaint O cross-complaint (Describe, including causes of action): In this employment law action, Plaintiff alleges he was retaliated against for engaging in protected activities, and that he was harassed, discriminated against, and retaliated against on the basis of his middle-eastern ancestry. He also alleges he was denied equal pay on the basis of his race/national origin. Defendant denies all material allegations and mantains that Plaintiff is entitled to no relief. Page 1 of 5 Form Adopted for Mandatory Use CASE MANAGEMENT STATEMENT Cal, Rules of Court, Judicial Council of California rules 3.720-3.730 CM-110 [Rev. September 1, 2021] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: A. SAMEH EL KHARBAWY CASE NUMBER: DEFENDANT/RESPONDENT: BOARD OF TRUSTEES OF CALIFORNIA STATE 21CECG02214 UNIVERSITY, 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.) oO (If more space is needed, check this box and attach a page designated as Attachment 4b.) Jury or nonjury trial The party or parties request 1] a jury trial D anoniury trial. (If more than one party, provide the name of each party requesting a jury trial): Trial date a. (1 The trial has been set for (date): b. Bd 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): Oct 13-29, 2021 (trial); Nov 8-9, 2021 (PERB hearing); Nov 15-25, 2021 (trial); Dec 1, 2021 (mediation); March 15- 31, 2022 (trial); April 19-27, 2022 (trial); July 8-19, 2022 (trial); Aug 15-24, 2022 (trial); Sept 12-23, 2022 (trial); Jan 9-23, 2023 (trial) Estimated length of trial The party or parties estimate that the trial will take (check one): a 1) days (specify number): 21-28 b. [1 hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial KX by the attorney or party listed in the caption OO by the following: a Attorney: b. Firm: Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: g Additional representation is described in Attachment 8. 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 of the California Rules of Court for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel O has 0 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 0 has Chas not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) 0 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): Rule 3.811(b)(8) [multiple causes of action and alleged damages in excess of $50,000] CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5 American LegalNet www. rms WorkFl CM-110 PLAINTIFF/PETITIONER: A. SAMEH EL KHARBAWY CASE NUMBER: DEFENDANT/RESPONDENT: BOARD OF TRUSTEES OF CALIFORNIA STATE 21CECG02214 UNIVERSITY, 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 X 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 (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5 CM-110 PLAINTIFF/PETITIONER: A. SAMEH EL KHARBAWY ‘CASE NUMBER: DEFENDANT/RESPONDENT: BOARD OF TRUSTEES OF CALIFORNIA STATE 21CECG02214 UNIVERSITY, et al. 11. Insurance a insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Oo Yes 0 No c. 1 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. oO Bankruptcy UO 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. 0 Amotion to oO consolidate 0 coordinate will be filed by (name party): 14, Bifurcation (1 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 & The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Defendant expects to file several discovery-related motions, at least two separate anti-SLAPP motions for two different defendants, a motion for judgment on the pleadings, demurrers and motions to strike once the the other defendants are served, and a motion for summary judgment/summary adjudication. 16. Discovery a 0 The party or parties have completed all discovery. b. & The following discovery will be completed by the date specified (describe all anticipated discovery): Party Descriptio Date Defendant Written Discovery June 2022 Defendant Expert Deposition(s) Per Code Defendant Plaintiff's Deposition(s) June 2022 c. I The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): Plaintiff has refused to cooperate in the preparation of a protective order, despite the fact both parties have asked for one for different reasons in the case. CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: A. SAMEH EL KHARBAWY CASE NUMBER. DEFENDANT/RESPONDENT: BOARD OF TRUSTEES OF CALIFORNIA STATE 21CECG02214 UNIVERSITY, et al 17. Economic litigation aQ 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 6.0 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 oO 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. &] 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. [1] __ 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): 0 | 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 requil r(\. Date: September 15, 2021 Nathan T. Jackson t (TYPE OR PRINT NAME) =n P OR ATTORNEY) > (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) CD Additional signatures are attached CM-110 [Rev. September1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5 Am eal nc www PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SACRAMENTO 1am employed in the County of Sacramento, State of California. I am over the age of 18 and not a party to the within action; my business address is: 400 Capitol Mall, Suite 1260, Sacramento, CA 95814. On September 15, 2021, I served the foregoing document(s) described as CASE MANAGEMENT STATEMENT in the manner checked below on all interested parties in this action addressed as follows: Andrew Hillier Paul Garcia 10 Hillier Law 600 W. Broadway, Suite 700 ll San Diego, CA 92101 telephone: 619.500.7906 12 facsimile: 619.839.3895 ees BESs email: andrew@ahillierlaw.com; Bes 13 paul@ahillierlaw.com BQG< >ELO 14 2 aa a3 Mw (BY U.S. MAIL) I am “readily familiar” with the firm’s practice of collection and 15 processing correspondence for mailing. Under that practice it would be deposited with geo Soa the U.S. Postal Service on that same day with postage thereon fully prepaid at 5E8s 16 Sacramento, California, in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage 17 meter date is more than one day after date of deposit for mailing in affidavit. 18 (BY ELECTRONIC SERVICE) By electronically mailing a true and correct copy through Liebert Cassidy Whitmore’s electronic mail system from 19 mwibbenhorst@Icwlegal.com to the email address(es) set forth above. I did not receive, within a reasonable time after the transmission, any electronic message or 20 other indication that the transmission was unsuccessful. 21 Executed on September 15, 2021, at Sacramento, California. 22 I declare under penalty of perjury under the laws of the State of California that the 23 foregoing is true and correct. 24 Hau aue. Udibbees hewt 25 Mariana Wibbenhorst 26 27 28 1 Proof of Service 9796027.1 FRO07-003