Preview
1 Helene Wasserman, Bar No. 130134
hwasserman@littler.com
2 Shannon R. Boyce, Bar No. 229041
sboyce@littler.com
3 Melissa Velez, Bar No. 316714
mvelez@littler.com
4 LITTLER MENDELSON P.C.
2049 Century Park East
5 5th Floor
Los Angeles, California 90067.3107
6 Telephone: 310.553.0308
Fax No.: 310.553.5583
7
Attorneys for Defendant
8 TRADER JOE'S COMPANY
9
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
FOR THE COUNTY OF SANTA BARBARA
11
12
VICTORIA TICE, as an individual and on Case No. 20CV00892
13 behalf of all others similarly situated,
DECLARATION OF SHANNON R.
14 Plaintiff, BOYCE IN SUPPORT OF DEFENDANT
TRADER JOE’S COMPANY’S
15 v. OPPOSITION TO PLAINTIFF’S
MOTION TO COMPEL FURTHER
16 TRADER JOE’S COMPANY, a California RESPONSES TO SPECIAL
corporation; and DOES 1 through 50, inclusive, INTERROGATORIES, SET 3
17
Defendant. ASSIGNED FOR ALL PURPOSES TO
18 JUDGE THOMPAS P. ANDERLE, DEPT 3
19 Date: February 8, 2022
Time: 10:00 am
20 Dept: 3
21 Trial Date: February 14, 2023
Complaint Filed: February 14, 2021
22
23
24
25
26
27
28
LITTLER MEND ELSO N P.C.
2049 C entury Park East
5th Floor
Los Angeles, CA 90067.3107
310.553.0308
BOYCE DECL. ISO OPPOSITION TO MOTION TO COMPEL FURTHER RESPON
1 DECLARATION OF SHANNON R. BOYCE
2 I, SHANNON R. BOYCE, hereby declare as follows:
3 1. I am an attorney with the law firm of Littler Mendelson, a Professional Corporation,
4 attorneys for Trader Joe’s Company in the above captioned matter and I am duly authorized to
5 practice law before the state of California. I submit this declaration in support of Defendant’s Reply
6 in support of its Motion to Strike Plaintiff’s Representative PAGA Claim. The following facts are
7 true and correct of my own personal knowledge, and if called and sworn as a witness, I could and
8 would competently testify thereto.
9 2. As one of the attorneys of record on this case, I am familiar with the files, pleadings
10 and facts in this case and could and would competently testify to the following facts based upon
11 my own personal knowledge or information and belief. Moreover, as an attorney with Littler
12 Mendelson’s Century City office, I am familiar with the firm’s filing and record-keeping
13 procedures.
14 3. Following the Parties’ informal discovery conference with the Court, I continued
15 my meet and confer discussions with counsel for Plaintiff, Max Gavron. We discussed the
16 possibility of production of the data from Comdata with no crew member names attached, but Mr.
17 Gavron would only agree to this approach if Trader Joe’s otherwise agreed to waive its due process
18 right to individually examine each witness at trial. Unwilling to waive Trader Joe’s due process
19 rights, I sought clarification as to how Plaintiff intends to subpoena the records from Comdata. In
20 particular, I sought clarification as to whether Plaintiff intends to issue a notice to consumer to each
21 former crew member to give them an opportunity to object to subpoena of their financial
22 information. Mr. Gavron noted that that the prior time he went through this exercise, he was in
23 federal court where there is no such notice requirement. He therefore indicated that he would
24 investigate the issue and get back to me.
25 4. My initial discussion with Mr. Gavron regarding issuance of a notice to consumer
26 to former crew members occurred in mid-December. On January 13, 2022, I followed up with Mr.
27 Gavron to continue our dialogue and again seek clarification on his proposed subpoena process.
28 Attached hereto as Exhibit A is a true and correct copy of my correspondence to Mr. Gavron dated
LITTLER MEND ELSO N P.C.
Attorneys at Law
2.
2049 C entury Park East
5th Floor
Los Angeles, CA 90067.3107
310.553.0308
BOYCE DECL. ISO OPPOSITION TO MOTION TO COMPEL FURTHER RESPONSES
1 January 13, 2022.
2 5. After receiving no response to my January 13, 2022 email, I again followed up on
3 January 18, 2022. Attached hereto as Exhibit B is a true and correct copy of my correspondence to
4 Mr. Gavron dated January 18, 2022.
5 6. Mr. Gavron responded to my January 18, 2022 email the following day, in which he
6 indicated that he would be out of the office the remainder of the week. He asked about my
7 availability to meet and confer further the week of January 24, 2022. I informed him of the time
8 sensitivity of the issue given Defendant’s deadline to oppose the instant motion, and asked whether
9 he could provide a response via email. I received no response. Attached hereto as Exhibit C is a
10 true and correct copy of my correspondence to Mr. Gavron dated January 19, 2022.
11 7. On Monday, January 24, 2022, I telephoned Mr. Gavron’s office in a further attempt
12 to meet and confer. I was informed that Mr. Gavron was on other line, so I left a message. As of
13 the filing of the instant motion, I have not received a return call.
14 8. During the course of discovery in this matter, Trader Joe’s produced a sampling of
15 consent forms which included routing and/or account numbers on the bottom of the page. Crew
16 member names and contact information were redacted from these documents so as to protect their
17 privacy.
18 I declare under penalty of perjury under the laws of the United States of America and of the
19 State of California that the foregoing is true and correct.
20 Dated this 26th day of January 2022 at Los Angeles, California.
21
22
Shannon R. Boyce
23
24
25
26
27
28
LITTLER MEND ELSO N P.C.
Attorneys at Law
2.
2049 C entury Park East
5th Floor
Los Angeles, CA 90067.3107
310.553.0308
BOYCE DECL. ISO OPPOSITION TO MOTION TO COMPEL FURTHER RESPONSES
Exhibit A
P. 004
From: Boyce, Shannon
To: Max Gavron
Cc: Wasserman, Helene
Subject: Tice - Comdata Subpoena Process
Date: Thursday, January 13, 2022 4:05:40 PM
Attachments: image001.png
image002.png
Max – Prior to the holiday, we had a telephone discussion regarding your proposed process for
subpoenaing Comdata records, and whether you intend to issue a Notice to Consumer to aggrieved
employees whose records you’re seeking. At the time, I believe you said you were going to follow up
on the issue, as your prior experience was in Federal Court. Can you clarify how you propose to
issue your subpoena(s) to Comdata?
Thx.
Shannon Boyce
Office Managing Shareholder
310.712.7304 direct, 310.699.7349 mobile, 310.553.5583 fax
SBoyce@littler.com
Pronouns: She/Her
Labor & Employment Law Solutions | Local Everywhere
2049 Century Park East, 5th Floor, Los Angeles, CA 90067-3107
P. 005
Exhibit B
P. 006
From: Boyce, Shannon
To: Max Gavron
Cc: Wasserman, Helene
Subject: RE: Tice - Comdata Subpoena Process
Date: Tuesday, January 18, 2022 3:17:19 PM
Attachments: image001.png
image002.png
Max – following up on this. Can you clarify the proposed subpoena process?
Thx.
Shannon Boyce
Office Managing Shareholder
310.712.7304 direct, 310.699.7349 mobile, 310.553.5583 fax
SBoyce@littler.com
Pronouns: She/Her
Labor & Employment Law Solutions | Local Everywhere
2049 Century Park East, 5th Floor, Los Angeles, CA 90067-3107
From: Boyce, Shannon
Sent: Thursday, January 13, 2022 4:06 PM
To: Max Gavron
Cc: Wasserman, Helene
Subject: Tice - Comdata Subpoena Process
Max – Prior to the holiday, we had a telephone discussion regarding your proposed process for
subpoenaing Comdata records, and whether you intend to issue a Notice to Consumer to aggrieved
employees whose records you’re seeking. At the time, I believe you said you were going to follow up
on the issue, as your prior experience was in Federal Court. Can you clarify how you propose to
issue your subpoena(s) to Comdata?
Thx.
Shannon Boyce
Office Managing Shareholder
310.712.7304 direct, 310.699.7349 mobile, 310.553.5583 fax
SBoyce@littler.com
Pronouns: She/Her
P. 007
Labor & Employment Law Solutions | Local Everywhere
2049 Century Park East, 5th Floor, Los Angeles, CA 90067-3107
P. 008
Exhibit C
P. 009
From: Boyce, Shannon
To: Max Gavron
Cc: Wasserman, Helene
Subject: Re: Tice - Comdata Subpoena Process
Date: Wednesday, January 19, 2022 8:00:36 PM
Attachments: image001.png
image002.png
image001.png
image002.png
image001.png
image002.png
My opposition is due next Wednesday, so I have to draft my opp this week. Can you email
me a response as to your proposed process even though you’ll be out of the office?
Sent from my iPhone
On Jan 19, 2022, at 7:51 PM, Max Gavron wrote:
Shannon,
I am going to be out of the office tomorrow and Friday. Are you available to discuss
next week?
Thanks,
Max
From: Boyce, Shannon
Sent: Tuesday, January 18, 2022 3:17 PM
To: Max Gavron
Cc: Wasserman, Helene
Subject: RE: Tice - Comdata Subpoena Process
Max – following up on this. Can you clarify the proposed subpoena process?
Thx.
Shannon Boyce
Office Managing Shareholder
310.712.7304 direct, 310.699.7349 mobile, 310.553.5583 fax
SBoyce@littler.com
Pronouns: She/Her
P. 010
Labor & Employment Law Solutions | Local Everywhere
2049 Century Park East, 5th Floor, Los Angeles, CA 90067-3107
From: Boyce, Shannon
Sent: Thursday, January 13, 2022 4:06 PM
To: Max Gavron
Cc: Wasserman, Helene
Subject: Tice - Comdata Subpoena Process
Max – Prior to the holiday, we had a telephone discussion regarding your proposed
process for subpoenaing Comdata records, and whether you intend to issue a Notice to
Consumer to aggrieved employees whose records you’re seeking. At the time, I believe
you said you were going to follow up on the issue, as your prior experience was in
Federal Court. Can you clarify how you propose to issue your subpoena(s) to Comdata?
Thx.
Shannon Boyce
Office Managing Shareholder
310.712.7304 direct, 310.699.7349 mobile, 310.553.5583 fax
SBoyce@littler.com
Pronouns: She/Her
Labor & Employment Law Solutions | Local Everywhere
2049 Century Park East, 5th Floor, Los Angeles, CA 90067-3107
--------------------------
This email may contain confidential and privileged material for the sole use of the
intended recipient(s). Any review, use, distribution or disclosure by others is strictly
prohibited. If you are not the intended recipient (or authorized to receive for the
recipient), please contact the sender by reply email and delete all copies of this
message.
Littler Mendelson, P.C. is part of the international legal practice Littler Global, which
operates worldwide through a number of separate legal entities. Please visit
www.littler.com for more information.
P. 011
1 PROOF OF SERVICE
2
At the time of service, I was over 18 years of age and not a party to this action. I am
3
employed in the County of Los Angeles, State of California. My business address is 2049
4
Century Park East, Fifth Floor, Los Angeles, CA 90067.
5
6 On January 26, 2022, I served true copies of the following document(s) described as
7 DECLARATION OF SHANNON R. BOYCE IN SUPPORT OF DEFENDANT
TRADER JOE’S COMPANY’S OPPOSITION TO PLAINTIFF'S MOTION TO
8 COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET 3
9 the interested parties in this action as follows:
10 Larry W Lee William L. Marder
Max W. Gavron Polaris Law Group LLP
11 Diversity Law Group 501 San Benito St., Suite 200
12 515 S. Figueroa St., Suite 1250 Hollister, CA 95023
Los Angeles, CA 90071 Telephone: (831) 531-4214
13 Telephone: (213) 488-6555 Facsimile: (831) 634-0333
Facsimile: (213) 488-6554 Email: bill@polarislawgroup.com
14 lwlee@diversitylaw.com
mgavron@diversitylaw.com
15 Olympia@diversitylaw.com
16 Erika@diversitylaw.com
17
VIA ELECTRONIC SERVICE: Based on a court order or an agreement of the
18 parties to accept electronic service, including pursuant to Code of Civil Procedure
section 1010.6, which allows for service by e-mail or electronic transmission, I
19 caused the documents to be sent to the persons at the electronic service addresses
listed herein. My email address is mgerard@littler.com.
20
21 I declare under penalty of perjury under the laws of the State of California that the
22 foregoing is true and correct. Executed on January 26, 2022,at Los Angeles, California.
23
24
25 Mary Ann Gerard
26
4875-5001-3446.1 / 071820-1075
27
28
LITTLER MEND ELSO N P.C.
2049 C entury Park East
5th Floor
Los Angeles, CA 90067.3107
310.553.0308
BOYCE DECL. ISO OPPOSITION TO MOTION TO COMPEL FURTHER RESPONSES
P. 012
Preview
1 Helene Wasserman, Bar No. 130134 hwasserman@littler.com 2 Shannon R. Boyce, Bar No. 229041 sboyce@littler.com 3 Melissa Velez, Bar No. 316714 mvelez@littler.com 4 LITTLER MENDELSON P.C. 2049 Century Park East 5 5th Floor Los Angeles, California 90067.3107 6 Telephone: 310.553.0308 Fax No.: 310.553.5583 7 Attorneys for Defendant 8 TRADER JOE'S COMPANY 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SANTA BARBARA 11 12 VICTORIA TICE, as an individual and on Case No. 20CV00892 13 behalf of all others similarly situated, DECLARATION OF SHANNON R. 14 Plaintiff, BOYCE IN SUPPORT OF DEFENDANT TRADER JOE’S COMPANY’S 15 v. OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER 16 TRADER JOE’S COMPANY, a California RESPONSES TO SPECIAL corporation; and DOES 1 through 50, inclusive, INTERROGATORIES, SET 3 17 Defendant. ASSIGNED FOR ALL PURPOSES TO 18 JUDGE THOMPAS P. ANDERLE, DEPT 3 19 Date: February 8, 2022 Time: 10:00 am 20 Dept: 3 21 Trial Date: February 14, 2023 Complaint Filed: February 14, 2021 22 23 24 25 26 27 28 LITTLER MEND ELSO N P.C. 2049 C entury Park East 5th Floor Los Angeles, CA 90067.3107 310.553.0308 BOYCE DECL. ISO OPPOSITION TO MOTION TO COMPEL FURTHER RESPON 1 DECLARATION OF SHANNON R. BOYCE 2 I, SHANNON R. BOYCE, hereby declare as follows: 3 1. I am an attorney with the law firm of Littler Mendelson, a Professional Corporation, 4 attorneys for Trader Joe’s Company in the above captioned matter and I am duly authorized to 5 practice law before the state of California. I submit this declaration in support of Defendant’s Reply 6 in support of its Motion to Strike Plaintiff’s Representative PAGA Claim. The following facts are 7 true and correct of my own personal knowledge, and if called and sworn as a witness, I could and 8 would competently testify thereto. 9 2. As one of the attorneys of record on this case, I am familiar with the files, pleadings 10 and facts in this case and could and would competently testify to the following facts based upon 11 my own personal knowledge or information and belief. Moreover, as an attorney with Littler 12 Mendelson’s Century City office, I am familiar with the firm’s filing and record-keeping 13 procedures. 14 3. Following the Parties’ informal discovery conference with the Court, I continued 15 my meet and confer discussions with counsel for Plaintiff, Max Gavron. We discussed the 16 possibility of production of the data from Comdata with no crew member names attached, but Mr. 17 Gavron would only agree to this approach if Trader Joe’s otherwise agreed to waive its due process 18 right to individually examine each witness at trial. Unwilling to waive Trader Joe’s due process 19 rights, I sought clarification as to how Plaintiff intends to subpoena the records from Comdata. In 20 particular, I sought clarification as to whether Plaintiff intends to issue a notice to consumer to each 21 former crew member to give them an opportunity to object to subpoena of their financial 22 information. Mr. Gavron noted that that the prior time he went through this exercise, he was in 23 federal court where there is no such notice requirement. He therefore indicated that he would 24 investigate the issue and get back to me. 25 4. My initial discussion with Mr. Gavron regarding issuance of a notice to consumer 26 to former crew members occurred in mid-December. On January 13, 2022, I followed up with Mr. 27 Gavron to continue our dialogue and again seek clarification on his proposed subpoena process. 28 Attached hereto as Exhibit A is a true and correct copy of my correspondence to Mr. Gavron dated LITTLER MEND ELSO N P.C. Attorneys at Law 2. 2049 C entury Park East 5th Floor Los Angeles, CA 90067.3107 310.553.0308 BOYCE DECL. ISO OPPOSITION TO MOTION TO COMPEL FURTHER RESPONSES 1 January 13, 2022. 2 5. After receiving no response to my January 13, 2022 email, I again followed up on 3 January 18, 2022. Attached hereto as Exhibit B is a true and correct copy of my correspondence to 4 Mr. Gavron dated January 18, 2022. 5 6. Mr. Gavron responded to my January 18, 2022 email the following day, in which he 6 indicated that he would be out of the office the remainder of the week. He asked about my 7 availability to meet and confer further the week of January 24, 2022. I informed him of the time 8 sensitivity of the issue given Defendant’s deadline to oppose the instant motion, and asked whether 9 he could provide a response via email. I received no response. Attached hereto as Exhibit C is a 10 true and correct copy of my correspondence to Mr. Gavron dated January 19, 2022. 11 7. On Monday, January 24, 2022, I telephoned Mr. Gavron’s office in a further attempt 12 to meet and confer. I was informed that Mr. Gavron was on other line, so I left a message. As of 13 the filing of the instant motion, I have not received a return call. 14 8. During the course of discovery in this matter, Trader Joe’s produced a sampling of 15 consent forms which included routing and/or account numbers on the bottom of the page. Crew 16 member names and contact information were redacted from these documents so as to protect their 17 privacy. 18 I declare under penalty of perjury under the laws of the United States of America and of the 19 State of California that the foregoing is true and correct. 20 Dated this 26th day of January 2022 at Los Angeles, California. 21 22 Shannon R. Boyce 23 24 25 26 27 28 LITTLER MEND ELSO N P.C. Attorneys at Law 2. 2049 C entury Park East 5th Floor Los Angeles, CA 90067.3107 310.553.0308 BOYCE DECL. ISO OPPOSITION TO MOTION TO COMPEL FURTHER RESPONSES Exhibit A P. 004 From: Boyce, Shannon To: Max Gavron Cc: Wasserman, Helene Subject: Tice - Comdata Subpoena Process Date: Thursday, January 13, 2022 4:05:40 PM Attachments: image001.png image002.png Max – Prior to the holiday, we had a telephone discussion regarding your proposed process for subpoenaing Comdata records, and whether you intend to issue a Notice to Consumer to aggrieved employees whose records you’re seeking. At the time, I believe you said you were going to follow up on the issue, as your prior experience was in Federal Court. Can you clarify how you propose to issue your subpoena(s) to Comdata? Thx. Shannon Boyce Office Managing Shareholder 310.712.7304 direct, 310.699.7349 mobile, 310.553.5583 fax SBoyce@littler.com Pronouns: She/Her Labor & Employment Law Solutions | Local Everywhere 2049 Century Park East, 5th Floor, Los Angeles, CA 90067-3107 P. 005 Exhibit B P. 006 From: Boyce, Shannon To: Max Gavron Cc: Wasserman, Helene Subject: RE: Tice - Comdata Subpoena Process Date: Tuesday, January 18, 2022 3:17:19 PM Attachments: image001.png image002.png Max – following up on this. Can you clarify the proposed subpoena process? Thx. Shannon Boyce Office Managing Shareholder 310.712.7304 direct, 310.699.7349 mobile, 310.553.5583 fax SBoyce@littler.com Pronouns: She/Her Labor & Employment Law Solutions | Local Everywhere 2049 Century Park East, 5th Floor, Los Angeles, CA 90067-3107 From: Boyce, Shannon Sent: Thursday, January 13, 2022 4:06 PM To: Max Gavron Cc: Wasserman, Helene Subject: Tice - Comdata Subpoena Process Max – Prior to the holiday, we had a telephone discussion regarding your proposed process for subpoenaing Comdata records, and whether you intend to issue a Notice to Consumer to aggrieved employees whose records you’re seeking. At the time, I believe you said you were going to follow up on the issue, as your prior experience was in Federal Court. Can you clarify how you propose to issue your subpoena(s) to Comdata? Thx. Shannon Boyce Office Managing Shareholder 310.712.7304 direct, 310.699.7349 mobile, 310.553.5583 fax SBoyce@littler.com Pronouns: She/Her P. 007 Labor & Employment Law Solutions | Local Everywhere 2049 Century Park East, 5th Floor, Los Angeles, CA 90067-3107 P. 008 Exhibit C P. 009 From: Boyce, Shannon To: Max Gavron Cc: Wasserman, Helene Subject: Re: Tice - Comdata Subpoena Process Date: Wednesday, January 19, 2022 8:00:36 PM Attachments: image001.png image002.png image001.png image002.png image001.png image002.png My opposition is due next Wednesday, so I have to draft my opp this week. Can you email me a response as to your proposed process even though you’ll be out of the office? Sent from my iPhone On Jan 19, 2022, at 7:51 PM, Max Gavron wrote: Shannon, I am going to be out of the office tomorrow and Friday. Are you available to discuss next week? Thanks, Max From: Boyce, Shannon Sent: Tuesday, January 18, 2022 3:17 PM To: Max Gavron Cc: Wasserman, Helene Subject: RE: Tice - Comdata Subpoena Process Max – following up on this. Can you clarify the proposed subpoena process? Thx. Shannon Boyce Office Managing Shareholder 310.712.7304 direct, 310.699.7349 mobile, 310.553.5583 fax SBoyce@littler.com Pronouns: She/Her P. 010 Labor & Employment Law Solutions | Local Everywhere 2049 Century Park East, 5th Floor, Los Angeles, CA 90067-3107 From: Boyce, Shannon Sent: Thursday, January 13, 2022 4:06 PM To: Max Gavron Cc: Wasserman, Helene Subject: Tice - Comdata Subpoena Process Max – Prior to the holiday, we had a telephone discussion regarding your proposed process for subpoenaing Comdata records, and whether you intend to issue a Notice to Consumer to aggrieved employees whose records you’re seeking. At the time, I believe you said you were going to follow up on the issue, as your prior experience was in Federal Court. Can you clarify how you propose to issue your subpoena(s) to Comdata? Thx. Shannon Boyce Office Managing Shareholder 310.712.7304 direct, 310.699.7349 mobile, 310.553.5583 fax SBoyce@littler.com Pronouns: She/Her Labor & Employment Law Solutions | Local Everywhere 2049 Century Park East, 5th Floor, Los Angeles, CA 90067-3107 -------------------------- This email may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply email and delete all copies of this message. Littler Mendelson, P.C. is part of the international legal practice Littler Global, which operates worldwide through a number of separate legal entities. Please visit www.littler.com for more information. P. 011 1 PROOF OF SERVICE 2 At the time of service, I was over 18 years of age and not a party to this action. I am 3 employed in the County of Los Angeles, State of California. My business address is 2049 4 Century Park East, Fifth Floor, Los Angeles, CA 90067. 5 6 On January 26, 2022, I served true copies of the following document(s) described as 7 DECLARATION OF SHANNON R. BOYCE IN SUPPORT OF DEFENDANT TRADER JOE’S COMPANY’S OPPOSITION TO PLAINTIFF'S MOTION TO 8 COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET 3 9 the interested parties in this action as follows: 10 Larry W Lee William L. Marder Max W. Gavron Polaris Law Group LLP 11 Diversity Law Group 501 San Benito St., Suite 200 12 515 S. Figueroa St., Suite 1250 Hollister, CA 95023 Los Angeles, CA 90071 Telephone: (831) 531-4214 13 Telephone: (213) 488-6555 Facsimile: (831) 634-0333 Facsimile: (213) 488-6554 Email: bill@polarislawgroup.com 14 lwlee@diversitylaw.com mgavron@diversitylaw.com 15 Olympia@diversitylaw.com 16 Erika@diversitylaw.com 17 VIA ELECTRONIC SERVICE: Based on a court order or an agreement of the 18 parties to accept electronic service, including pursuant to Code of Civil Procedure section 1010.6, which allows for service by e-mail or electronic transmission, I 19 caused the documents to be sent to the persons at the electronic service addresses listed herein. My email address is mgerard@littler.com. 20 21 I declare under penalty of perjury under the laws of the State of California that the 22 foregoing is true and correct. Executed on January 26, 2022,at Los Angeles, California. 23 24 25 Mary Ann Gerard 26 4875-5001-3446.1 / 071820-1075 27 28 LITTLER MEND ELSO N P.C. 2049 C entury Park East 5th Floor Los Angeles, CA 90067.3107 310.553.0308 BOYCE DECL. ISO OPPOSITION TO MOTION TO COMPEL FURTHER RESPONSES P. 012