On November 26, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Runyon, Nathan Peter,
and
Does 1-50, Inclusive,
Ng, Kaiser,
Payward, Inc., A California Corporation,
for civil
in the District Court of San Francisco County.
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Attorney or Party without Attorney: For Court Use Only
Kimberly Pallen, (SBN: 288605)
WITHERS BERGMAN, LLP
1925 Century Park East
Los Angeles, CA 90067
Telephone No: 310-277-9930 ELECTRONICALLY
Attorney For:Defendants Payward, Inc., a
Ref. No. or File No.:
F I L E D
Superior Court of California,
California Corporation d/b/a/ Kraken, County of San Francisco
and Kaiser Ng, an individual
06/11/2021
Insert name of Court, and Judicial District and Branch Court: Clerk of the Court
SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO BY: ERNALYN BURA
Deputy Clerk
Plaintiff:NATHAN PETER RUNYON, an individual
Defendant: PAYWARD, INC., a California Corporation d/b/a KRAKEN, et al.
PROOF OF SERVICE Hearing Date: Time: Dept/Div: Case Number:
CGC-19-581099
1. At the time of service I was at least 18 years of age and not a party to this action.
2. I served copies of the SEE ATTACHED LIST OF DOCUMENTS
3. a. Party served: Claire Cochran, Esq., Natalie Xifo, Esq.
LAW OFFICES OF CLAIRE COCHRAN, PC
b. Person served: Jacel M., Employee
4. Address where the party was served: 100 Pine Street, Suite 1250, San Francisco, CA 94111
5. I served the party:
a. By personal service. I personally delivered the documents listed in item 2 to the party or person authorized to receive
process for the party (1) on: Fri, May 28 2021 (2) at: 11:37 AM , to the person(s) indicated above in the manner as provided
in 1011 CCP.
Recoverable cost Per CCP 1033.5(a)(4)(B)
6. Person Who Served Papers:
a. David Cipres (2015-00013398, San Francisco) d. The Fee for Service was:
b. FIRST LEGAL e. I am: A Registered California Process Server
1517 W. Beverly Blvd.
LOS ANGELES, CA 90026
c. (213) 250-1111
7. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
06/11/2021
(Date) (Signature)
Judicial Council Form PROOF OF 5744051
Rule 2.150.(a)&(b) Rev January 1, 2007 SERVICE (4670075)
SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO
NATHAN PETER RUNYON, an individual
Vs.
PAYWARD, INC., a California Corporation d/b/a KRAKEN, et al.
CASE NO.: CGC-19-581099
_________________________________________________
Publicly Filed Redacted MSA Courtesy Copies (Zip File A)
1. DEFENDANTS’ MOTION FOR SUMMARY ADJUDICATION (PUBLIC REDACTED VERSION)
2. DECLARATION OF KAISER NG IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY
ADJUDICATION (PUBLIC REDACTED VERSION)
3. DECLARATION OF CHRISTOPHER N. LAVIGNE IN SUPPORT OF DEFENDANTS’ MOTION FOR
SUMMARY ADJUDICATION (PUBLIC REDACTED VERSION)
4. DEFENDANTS’ SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF MOTION
FOR SUMMARY ADJUDICATION (PUBLIC REDACTED VERSION)
5. PROOF OF SERVICE
Filed Conditionally Under Seal Unredacted MSA Courtesy Copies (Zip File B)
1. DEFENDANTS’ MOTION FOR SUMMARY ADJUDICATION (CONDITIONALLY SEALED UNREDACTED
VERSION)
2. DECLARATION OF KAISER NG IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY
ADJUDICATION (CONDITIONALLY SEALED UNREDACTED VERSION)
3. DECLARATION OF CHRISTOPHER N. LAVIGNE IN SUPPORT OF DEFENDANTS’ MOTION FOR
SUMMARY ADJUDICATION (CONDITIONALLY SEALED UNREDACTED VERSION)
4. DEFENDANTS’ SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF MOTION
FOR SUMMARY ADJUDICATION (CONDITIONALLY SEALED UNREDACTED VERSION)
Motion to File Exhibit I To the Ng Declaration Under Seal (Zip File C)
1. DEFENDANTS’ NOTICE OF MOTION AND MOTION TO FILE EXHIBIT I TO THE DECLARATION OF
KAISER NG IN SUPPORT OF SUMMARY ADJUDICATION UNDER SEAL; MEMORANDUM OF POINTS
AND AUTHORITIES
2. DECLARATION OF KAISER NG IN SUPPORT OF DEFENDANTS’ MOTION TO FILE EXHIBIT I TO THE
DECLARATION OF KAISER NG IN SUPPORT OF SUMMARY ADJUDICATION UNDER SEAL
3. [PROPOSED] ORDER GRANTING DEFENDANTS’ MOTION TO FILE EXHIBIT I TO THE DECLARATION
OF KAISER NG IN SUPPORT OF SUMMARY ADJUDICATION UNDER SEAL
4. PROOF OF SERVICE
Document Filed Date
June 11, 2021
Case Filing Date
November 26, 2019
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Attorney or Party without Attorney: For Court Use Only Kimberly Pallen, (SBN: 288605) WITHERS BERGMAN, LLP 1925 Century Park East Los Angeles, CA 90067 Telephone No: 310-277-9930 ELECTRONICALLY Attorney For:Defendants Payward, Inc., a Ref. No. or File No.: F I L E D Superior Court of California, California Corporation d/b/a/ Kraken, County of San Francisco and Kaiser Ng, an individual 06/11/2021 Insert name of Court, and Judicial District and Branch Court: Clerk of the Court SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO BY: ERNALYN BURA Deputy Clerk Plaintiff:NATHAN PETER RUNYON, an individual Defendant: PAYWARD, INC., a California Corporation d/b/a KRAKEN, et al. PROOF OF SERVICE Hearing Date: Time: Dept/Div: Case Number: CGC-19-581099 1. At the time of service I was at least 18 years of age and not a party to this action. 2. I served copies of the SEE ATTACHED LIST OF DOCUMENTS 3. a. Party served: Claire Cochran, Esq., Natalie Xifo, Esq. LAW OFFICES OF CLAIRE COCHRAN, PC b. Person served: Jacel M., Employee 4. Address where the party was served: 100 Pine Street, Suite 1250, San Francisco, CA 94111 5. I served the party: a. By personal service. I personally delivered the documents listed in item 2 to the party or person authorized to receive process for the party (1) on: Fri, May 28 2021 (2) at: 11:37 AM , to the person(s) indicated above in the manner as provided in 1011 CCP. Recoverable cost Per CCP 1033.5(a)(4)(B) 6. Person Who Served Papers: a. David Cipres (2015-00013398, San Francisco) d. The Fee for Service was: b. FIRST LEGAL e. I am: A Registered California Process Server 1517 W. Beverly Blvd. LOS ANGELES, CA 90026 c. (213) 250-1111 7. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 06/11/2021 (Date) (Signature) Judicial Council Form PROOF OF 5744051 Rule 2.150.(a)&(b) Rev January 1, 2007 SERVICE (4670075) SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO NATHAN PETER RUNYON, an individual Vs. PAYWARD, INC., a California Corporation d/b/a KRAKEN, et al. CASE NO.: CGC-19-581099 _________________________________________________ Publicly Filed Redacted MSA Courtesy Copies (Zip File A) 1. DEFENDANTS’ MOTION FOR SUMMARY ADJUDICATION (PUBLIC REDACTED VERSION) 2. DECLARATION OF KAISER NG IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY ADJUDICATION (PUBLIC REDACTED VERSION) 3. DECLARATION OF CHRISTOPHER N. LAVIGNE IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY ADJUDICATION (PUBLIC REDACTED VERSION) 4. DEFENDANTS’ SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF MOTION FOR SUMMARY ADJUDICATION (PUBLIC REDACTED VERSION) 5. PROOF OF SERVICE Filed Conditionally Under Seal Unredacted MSA Courtesy Copies (Zip File B) 1. DEFENDANTS’ MOTION FOR SUMMARY ADJUDICATION (CONDITIONALLY SEALED UNREDACTED VERSION) 2. DECLARATION OF KAISER NG IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY ADJUDICATION (CONDITIONALLY SEALED UNREDACTED VERSION) 3. DECLARATION OF CHRISTOPHER N. LAVIGNE IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY ADJUDICATION (CONDITIONALLY SEALED UNREDACTED VERSION) 4. DEFENDANTS’ SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF MOTION FOR SUMMARY ADJUDICATION (CONDITIONALLY SEALED UNREDACTED VERSION) Motion to File Exhibit I To the Ng Declaration Under Seal (Zip File C) 1. DEFENDANTS’ NOTICE OF MOTION AND MOTION TO FILE EXHIBIT I TO THE DECLARATION OF KAISER NG IN SUPPORT OF SUMMARY ADJUDICATION UNDER SEAL; MEMORANDUM OF POINTS AND AUTHORITIES 2. DECLARATION OF KAISER NG IN SUPPORT OF DEFENDANTS’ MOTION TO FILE EXHIBIT I TO THE DECLARATION OF KAISER NG IN SUPPORT OF SUMMARY ADJUDICATION UNDER SEAL 3. [PROPOSED] ORDER GRANTING DEFENDANTS’ MOTION TO FILE EXHIBIT I TO THE DECLARATION OF KAISER NG IN SUPPORT OF SUMMARY ADJUDICATION UNDER SEAL 4. PROOF OF SERVICE