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MARIAA. CARUANA, Esq., SBN 139901
LAW OFFICES OF JOHN A. BIARD
P.O. Box 64093 F | JF
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St. Paul, Minnesota 55164-0093 bao i
Physical Address: - ALAMEDA COUNTY
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401 Lennon Lane, Suite 125
Walnut Creek, California 94598 JUL © 2 2021
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Telephone No:(925) 945-449] nace
Facsimile No: (855) 668-5559 CLERK OF PIE SUPERIOR CO RT
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Attorneys for Defendant,
PPM TECHNOLOGIES HOLDINGS, LLC
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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
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10 IN AND FOR THE COUNTY OF ALAMEDA
11 LETICIA MONTES, Case No.: RG20082639
12 Plaintiff, ANSWER TO COMPLAINT
13 Vv.
14 PPM TECHNOLOGIES HOLDINGS, LLC ;
and DOES 1-100, Complaint filed: December 11, 2020
15
Defendants.
16
17
18 | Defendant PPM TECHNOLOGIES HOLDINGS, LLC (“this answering Defendant”), hereby
19 answers the unverified Complaint of Plaintiff LETICIA MONTES as follows:
20 GENERAL DENIAL
21 Pursuant to the provisions of Code of Civil Procedure §431.30, this answering Defendant
22 denies generally and specifically each and every allegation contained in each cause of action of the
23 Complaint and further denies that Plaintiff has been damaged.
24 FIRST AFFIRMATIVE DEFENSE
25 As and for a first separate and distinct affirmative defense to Plaintiff's Complaint on file
26 herein, Defendant alleges that at all times relevant herein, any injury, damage or loss sustained by
27 Plaintiff was within the course and scope of Plaintiff's employment, and was proximately caused by
28
Answer to Complaint
negligence of Plaintiffs employer(s) and co-worker(s). Said claims are therefore barred by California
Labor Code Section 3601, et seq.
to
SECOND AFFIRMATIVE DEFENSE
As and for a second separate and distinct affirmative defense to Plaintiff's Complaint on file
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herein, Defendant alleges that the acts and omissions of Plaintiff's employer or employers, and others,
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contributed to the alleged damages, mjury or loss complained of by Plaintiff. Defendant requests the
HR
Court to apply the principles of Witt v. Jackson (1961) 52 Cal.2d 57 and those subsequent cases
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modifying that decision so as to permit the Court or jury to apportion liability according to fault and to
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grant defendant a corresponding offset against any damages awarded to Plaintiff.
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10 THIRD AFFIRMATIVE DEFENSE
11 As and for a third separate and distinct affirmative defense to Plaintiff's Complaint on file
12 herein, Defendant alleges that Plaintiff, Plamtiff's employers, as well as others unreasonably and
13 unforeseeably misused and abused the product described in Plaintiff's Complaint. Such misuse and
14 abuse proximately caused and contributed to the injuries and damages sustained, if any there were.
15 Further, any such injuries were caused solely by and are attributable to the unreasonable, unforeseeable
16 and inappropriate purpose and improper use made of said product or material.
17 FOURTH AFFIRMATIVE DEFENSE
18 As and for a fourth separate and distinct affirmative defense to Plaintiff's Complaint on file
19 herein, Defendant alleges that Plaintiff and/or others modified, altered or changed the Defendant’s
20 products or materials referred to in the Complaint, if any. Such modification in any said products or
21 materials proximately caused the injuries, loss and damages of Plaintiff, if any.
22 FIFTH AFFIRMATIVE DEFENSE
23 As and for a fifth separate and distinct affirmative defense to Plaintiff's Complaint on file
24 herein, Defendant alleges that product or materials supplied by it, if any, to Plaintiff, or employers of
Plaintiff, or others, were not dangerous or defective, and that the conduct of the Plaintiff, the
26 employers of Plaintiff, and others created the alleged hazards or dangers, if any.
27 I!
28 If!
Answer to Complaint Page 2
SIXTH AFFIRMATIVE DEFENSE
As and for a sixth separate and affirmative defense to Plaintiff's Complaint on file herein,
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Defendant alleges that any injuries and damages sustained by Plaintiff, if any there were, were caused
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by the negligence, intentional acts or omissions of other persons or entities other than Defendant.
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| SEVENTH AFFIRMATIVE DEFENSE
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As and for a seventh separate and distinct affirmative defense to Plaintiff's Complaint on file
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herein, Defendant alleges the Complaint and each cause of action presented therein are barred. on the
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grounds that Defendant’s product or materials referred to in the Complaint, if any, were not a
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substantial factor in bringing about the injuries and damages complained of by Plaintiff.
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EIGHTH AFFIRMATIVE DEFENSE
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As and for an eighth separate and distinct affirmative defense to Plaintiff's Complaint on file
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herein, Defendant alleges that at all times relevant to matters alleged in the Complaint, Plaintiff was
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sufficiently knowledgeable, informed or trained, and knew or should have known of the potential
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danger associated with use and operation of the product and/or materials which are the subject of
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Plaintiff's Complaint, and Plaintiff's claims are, therefore, barred under the sophisticated user doctrine,
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pursuant to William Johnson v. American Standard, Inc. (2008) 43 Cal. 4" 56 and its progeny.
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| NINTH AFFIRMATIVE DEFENSE
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As and for a ninth separate and distinct affirmative defense to Plaintiff's Complaint on file
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herein, Defendant alleges that at all times relevant to matters alleged in the Complaint, plaintiff's
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employers, unions, and/or certain third parties yet to be identified, were knowledgeable and
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sophisticated users, purchasers and/or intermediaries of the product and/or materials at issue. Such
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persons and/or entities were in a better position to warn plaintiff of the possible risks associated with
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using the subject product and/or materials, and such persons’ and/or entities’ negligence in providing
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the products to plaintiff in a negligent, careless and reckless manner is a superseding cause of
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plaintiff's injuries, if any, pursuant to William Johnson v. American Standard, Inc. (2008) 43 Cal. 4"
56.
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Answer to Complaint / Page 3
TENTH AFFIRMATIVE DEFENSE
As and for a tenth separate and distinct affirmative defense to Plaintiff's Complaint on file
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herein, Plaintiff's recovery against Defendant is barred, diminished or reduced to the extent that there
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is no possibility of an alternate, safer design for the functionality of the products or materials
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referenced in the Complaint, and that the risk of danger, if any, is inherent in said product or materials.
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ELEVENTH AFFIRMATIVE DEFENSE
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As and for an eleventh separate and distinct affirmative defense to Plaintiff's Complaint on file
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herein, Defendant denies the existence of the dangerous condition as set forth in the Complaint. If,
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however, such dangerous condition did, in fact, exist, Defendant had no knowledge or adequate
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10 knowledge of it, having exercised reasonable care in inspecting its product(s) or material(s).
u TWELFTH AFFIRMATIVE DEFENSE
12 As and for a twelfth separate and distinct affirmative defense to Plaintiff's Complaint on file
13 herein, Defendant alleges that the alleged condition of the product(s) or materials set forth in the
14 Complaint did not constitute substantial risk of injury; but if any risk of injury did exist, it constituted
15 merely a minor, trivial or insignificant risk which did not create a dangerous condition in its product(s)
16 or material(s) and, therefore, Defendant is not liable for Plaintiff's alleged damages.
17 THIRTEENTH AFFIRMATIVE DEFENSE
18 As and for a thirteenth separate and distinct affirmative defense to Plaintiff's Complaint on file
19 herein, Plaintiff's recovery is barred, diminished or reduced to the extent that Plaintiff cannot show
20 that the product(s) or materials supplied by Defendant, if any, in all reasonable probability, was a
21 substantial factor in increasing the risk of bringing about the injuries or damages complained of by
22 Plaintiff.
23 FOURTEENTH AFFIRMATIVE DEFENSE
24 As a fourteenth and separate affirmative defense to said Complaint, this answering Defendant
alleges by way of a plea of comparative negligence that the Plaintiff and/or her agents, servants,
26 employees, and independent contractors were negligent in and about the matters and activities alleged
27 in said Complaint, that said negligence contributed to and was a proximate cause of Plaintiff's alleged
28 injuries and damages, if any, and that if the Plaintiff is entitled to recover damages against this
Answer to Complaint Page 4
answering Defendant, this answering Defendant prays that said recovery be diminished by reason of
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the Plaintiff's actions in proportion to the degree of fault attributable to the Plaintiff.
FIFTEENTH AFFIRMATIVE DEFENSE
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As an fifteenth separate affirmative defense to said Complaint, this answering Defendant
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alleges that the complaint, including each and every purported cause of action therein, is barred under
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the equitable doctrine of laches.
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SIXTEENTH AFFIRMATIVE DEFENSE
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As a sixteenth and separate affirmative defense to said Complaint, this answering Defendant is
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informed and believes and therefore alleges that the Complaint is barred by the applicable statute(s) of
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lumitations, which is/are contained in CCP §§335.1, 337, 337.1, 337.6, 337.15, 338, 339, 340 and 343,
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or other applicable statues.
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SEVENTEENTH AFFIRMATIVE DEFENSE
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As a seventeenth and separate affirmative defense to said Complaint, this answering Defendant
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asserts the proper measure of damages with regard to economic damages relating to medical expenses
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is the amount actually paid by Plaintiff’s insurer or other sources, in keeping with Howell v. Hamilton
UN
Meats, Inc. (2011) 52 Cal.4" 541.
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WHEREFORE, this answering Defendant prays judgment as follows:
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1. That Plaintiff take nothing by reason of this action;
2. For reasonable attorney's fees;
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3. For costs of suit incurred herein;
4. For such other and further relief as the Court may deem just and proper.
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REQUEST FOR TRIAL BY JURY
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Defendant herby requests a trial by jury.
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Dated: Jul 2, 2021 LAW OFFICES OF JOHN A. BIARD
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(Neg Of: ap
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MARIA A. CARUANA
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Attomeys for Defendant,
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PPM TECHNOLOGIES HOLDINGS, LLC
Answer to Complaint Page S
Leticia Montes v. PPM Technologies Holdings, LLC, et al.
Alameda County Superior Court # RG20082639
NY
PROOF OF SERVICE
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I am employed in the County of Contra Costa, State of California. I am over the age of 18 years
and not a party to the above-captioned matter. My business address is 401 Lennon Lane, Suite 125 in
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Walnut Creek, California 94598.
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On this date, I served the foregomg ANSWER TO COMPLAINT on the parties below by
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placing a true copy thereof in a sealed envelope and served same on the parties/counsel, addressed as
follows:
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ATTORNEYS FOR PLAINTIFF, LETICIA
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MONTES:
John E. Hill
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Luis Landeros
Law Offices of John E. Hill, A.P.C.
333 Hegenberger Road, Suite 500
Oakland, CA 94621
EM: johnhill@hill-law-offices.com
me
luislanderos@hill-law-offices.com
The following is the procedure in which service of this document was effected:
CL) | By Mail: by placing a true copy of the document(s) listed above, enclosed in a sealed.
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envelope, addressed as set forth below, for collection and mailing on the date and at the
business address shown above following our ordinary business practices. I am readily
familiar with this business’ practice for collection and processing of correspondence for
mailing with the United States Postal Service. On the same day that a sealed envelope is
placed for collection and mailing, it is deposited in the ordinary course of business with the
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United States Postal Service with postage fully prepaid.
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C) | By Facsimile: by having a true copy of the document(s) listed above transmitted by facsimile
to the person(s) at the facsimile number(s) set forth below before 5:00 p.m. The transmission
was reported as complete without error by a report issued by the transmitting facsimile
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machine.
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L] | By Personal Service: | caused each such envelope to be delivered by hand to the addressee(s)
noted above.
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KX | By Electronic Service ONLY: By personally transmitting a true copy of the document(s) via
an electronic mail account maintained at the law finn of Law Offices of John A. Biard to the
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e-mail address(es) above. The transmission(s) was reported as complete and without error.
L) | By Electronic Filing & Service: J am familiar with the business practice for electronic
HN
service. The above described document was filed and served electronically and the
transmission reported as complete and without error to the parties listed on the service list with
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[J File&Serve [JOne Legal (J Santa Clara County Superior Court’s efiling website. This
service complies with the Court’s order in this case.
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PROOF OF SERVICE
[] | By Overnight Mail. 1 caused to be served a true and correct copy of the above named
document(s) by placing the same in a sealed envelope with postage thereon fully prepaid to be
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placed for pickup by Federal Express in Walnut Creek, California.
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I, hereby declare, under penalty of perjury, under the laws of the State of California, that the
foregoing is true and correct and this document was executed at Walnut Creek, California on July 2, 2021.
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PROOF OF SERVICE
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| AA A | @ Yd __. _ 23515190 . MARIAA. CARUANA, Esq., SBN 139901 LAW OFFICES OF JOHN A. BIARD P.O. Box 64093 F | JF NN St. Paul, Minnesota 55164-0093 bao i Physical Address: - ALAMEDA COUNTY WwW 401 Lennon Lane, Suite 125 Walnut Creek, California 94598 JUL © 2 2021 > Telephone No:(925) 945-449] nace Facsimile No: (855) 668-5559 CLERK OF PIE SUPERIOR CO RT AN aa DH Attorneys for Defendant, PPM TECHNOLOGIES HOLDINGS, LLC SY Oo IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA Oo 10 IN AND FOR THE COUNTY OF ALAMEDA 11 LETICIA MONTES, Case No.: RG20082639 12 Plaintiff, ANSWER TO COMPLAINT 13 Vv. 14 PPM TECHNOLOGIES HOLDINGS, LLC ; and DOES 1-100, Complaint filed: December 11, 2020 15 Defendants. 16 17 18 | Defendant PPM TECHNOLOGIES HOLDINGS, LLC (“this answering Defendant”), hereby 19 answers the unverified Complaint of Plaintiff LETICIA MONTES as follows: 20 GENERAL DENIAL 21 Pursuant to the provisions of Code of Civil Procedure §431.30, this answering Defendant 22 denies generally and specifically each and every allegation contained in each cause of action of the 23 Complaint and further denies that Plaintiff has been damaged. 24 FIRST AFFIRMATIVE DEFENSE 25 As and for a first separate and distinct affirmative defense to Plaintiff's Complaint on file 26 herein, Defendant alleges that at all times relevant herein, any injury, damage or loss sustained by 27 Plaintiff was within the course and scope of Plaintiff's employment, and was proximately caused by 28 Answer to Complaint negligence of Plaintiffs employer(s) and co-worker(s). Said claims are therefore barred by California Labor Code Section 3601, et seq. to SECOND AFFIRMATIVE DEFENSE As and for a second separate and distinct affirmative defense to Plaintiff's Complaint on file fF herein, Defendant alleges that the acts and omissions of Plaintiff's employer or employers, and others, DH contributed to the alleged damages, mjury or loss complained of by Plaintiff. Defendant requests the HR Court to apply the principles of Witt v. Jackson (1961) 52 Cal.2d 57 and those subsequent cases aN modifying that decision so as to permit the Court or jury to apportion liability according to fault and to oa grant defendant a corresponding offset against any damages awarded to Plaintiff. oO 10 THIRD AFFIRMATIVE DEFENSE 11 As and for a third separate and distinct affirmative defense to Plaintiff's Complaint on file 12 herein, Defendant alleges that Plaintiff, Plamtiff's employers, as well as others unreasonably and 13 unforeseeably misused and abused the product described in Plaintiff's Complaint. Such misuse and 14 abuse proximately caused and contributed to the injuries and damages sustained, if any there were. 15 Further, any such injuries were caused solely by and are attributable to the unreasonable, unforeseeable 16 and inappropriate purpose and improper use made of said product or material. 17 FOURTH AFFIRMATIVE DEFENSE 18 As and for a fourth separate and distinct affirmative defense to Plaintiff's Complaint on file 19 herein, Defendant alleges that Plaintiff and/or others modified, altered or changed the Defendant’s 20 products or materials referred to in the Complaint, if any. Such modification in any said products or 21 materials proximately caused the injuries, loss and damages of Plaintiff, if any. 22 FIFTH AFFIRMATIVE DEFENSE 23 As and for a fifth separate and distinct affirmative defense to Plaintiff's Complaint on file 24 herein, Defendant alleges that product or materials supplied by it, if any, to Plaintiff, or employers of Plaintiff, or others, were not dangerous or defective, and that the conduct of the Plaintiff, the 26 employers of Plaintiff, and others created the alleged hazards or dangers, if any. 27 I! 28 If! Answer to Complaint Page 2 SIXTH AFFIRMATIVE DEFENSE As and for a sixth separate and affirmative defense to Plaintiff's Complaint on file herein, HNO Defendant alleges that any injuries and damages sustained by Plaintiff, if any there were, were caused WD by the negligence, intentional acts or omissions of other persons or entities other than Defendant. SP | SEVENTH AFFIRMATIVE DEFENSE DW As and for a seventh separate and distinct affirmative defense to Plaintiff's Complaint on file DN herein, Defendant alleges the Complaint and each cause of action presented therein are barred. on the NI grounds that Defendant’s product or materials referred to in the Complaint, if any, were not a CO substantial factor in bringing about the injuries and damages complained of by Plaintiff. oOo EIGHTH AFFIRMATIVE DEFENSE O&O As and for an eighth separate and distinct affirmative defense to Plaintiff's Complaint on file | herein, Defendant alleges that at all times relevant to matters alleged in the Complaint, Plaintiff was YN sufficiently knowledgeable, informed or trained, and knew or should have known of the potential WY danger associated with use and operation of the product and/or materials which are the subject of FL Plaintiff's Complaint, and Plaintiff's claims are, therefore, barred under the sophisticated user doctrine, WA pursuant to William Johnson v. American Standard, Inc. (2008) 43 Cal. 4" 56 and its progeny. BH | NINTH AFFIRMATIVE DEFENSE NHN As and for a ninth separate and distinct affirmative defense to Plaintiff's Complaint on file DW herein, Defendant alleges that at all times relevant to matters alleged in the Complaint, plaintiff's BO employers, unions, and/or certain third parties yet to be identified, were knowledgeable and DD sophisticated users, purchasers and/or intermediaries of the product and/or materials at issue. Such *§ persons and/or entities were in a better position to warn plaintiff of the possible risks associated with NO using the subject product and/or materials, and such persons’ and/or entities’ negligence in providing WD the products to plaintiff in a negligent, careless and reckless manner is a superseding cause of F&F plaintiff's injuries, if any, pursuant to William Johnson v. American Standard, Inc. (2008) 43 Cal. 4" 56. DW /it nN Hf Oo Answer to Complaint / Page 3 TENTH AFFIRMATIVE DEFENSE As and for a tenth separate and distinct affirmative defense to Plaintiff's Complaint on file N herein, Plaintiff's recovery against Defendant is barred, diminished or reduced to the extent that there W is no possibility of an alternate, safer design for the functionality of the products or materials Se referenced in the Complaint, and that the risk of danger, if any, is inherent in said product or materials. WO ELEVENTH AFFIRMATIVE DEFENSE HD As and for an eleventh separate and distinct affirmative defense to Plaintiff's Complaint on file ss herein, Defendant denies the existence of the dangerous condition as set forth in the Complaint. If, BO however, such dangerous condition did, in fact, exist, Defendant had no knowledge or adequate Oo 10 knowledge of it, having exercised reasonable care in inspecting its product(s) or material(s). u TWELFTH AFFIRMATIVE DEFENSE 12 As and for a twelfth separate and distinct affirmative defense to Plaintiff's Complaint on file 13 herein, Defendant alleges that the alleged condition of the product(s) or materials set forth in the 14 Complaint did not constitute substantial risk of injury; but if any risk of injury did exist, it constituted 15 merely a minor, trivial or insignificant risk which did not create a dangerous condition in its product(s) 16 or material(s) and, therefore, Defendant is not liable for Plaintiff's alleged damages. 17 THIRTEENTH AFFIRMATIVE DEFENSE 18 As and for a thirteenth separate and distinct affirmative defense to Plaintiff's Complaint on file 19 herein, Plaintiff's recovery is barred, diminished or reduced to the extent that Plaintiff cannot show 20 that the product(s) or materials supplied by Defendant, if any, in all reasonable probability, was a 21 substantial factor in increasing the risk of bringing about the injuries or damages complained of by 22 Plaintiff. 23 FOURTEENTH AFFIRMATIVE DEFENSE 24 As a fourteenth and separate affirmative defense to said Complaint, this answering Defendant alleges by way of a plea of comparative negligence that the Plaintiff and/or her agents, servants, 26 employees, and independent contractors were negligent in and about the matters and activities alleged 27 in said Complaint, that said negligence contributed to and was a proximate cause of Plaintiff's alleged 28 injuries and damages, if any, and that if the Plaintiff is entitled to recover damages against this Answer to Complaint Page 4 answering Defendant, this answering Defendant prays that said recovery be diminished by reason of NY the Plaintiff's actions in proportion to the degree of fault attributable to the Plaintiff. FIFTEENTH AFFIRMATIVE DEFENSE W As an fifteenth separate affirmative defense to said Complaint, this answering Defendant FP alleges that the complaint, including each and every purported cause of action therein, is barred under nD the equitable doctrine of laches. NH SIXTEENTH AFFIRMATIVE DEFENSE NN As a sixteenth and separate affirmative defense to said Complaint, this answering Defendant is Oo informed and believes and therefore alleges that the Complaint is barred by the applicable statute(s) of oO lumitations, which is/are contained in CCP §§335.1, 337, 337.1, 337.6, 337.15, 338, 339, 340 and 343, CO or other applicable statues. — meme SEVENTEENTH AFFIRMATIVE DEFENSE YN As a seventeenth and separate affirmative defense to said Complaint, this answering Defendant WY asserts the proper measure of damages with regard to economic damages relating to medical expenses BF is the amount actually paid by Plaintiff’s insurer or other sources, in keeping with Howell v. Hamilton UN Meats, Inc. (2011) 52 Cal.4" 541. Dn WHEREFORE, this answering Defendant prays judgment as follows: wn 1. That Plaintiff take nothing by reason of this action; 2. For reasonable attorney's fees; Oo ROH oO 3. For costs of suit incurred herein; 4. For such other and further relief as the Court may deem just and proper. K& DN REQUEST FOR TRIAL BY JURY YD KN Defendant herby requests a trial by jury. WOW NY BB NY Dated: Jul 2, 2021 LAW OFFICES OF JOHN A. BIARD NW NY (Neg Of: ap WO NY nN MARIA A. CARUANA NH Attomeys for Defendant, eo Ww PPM TECHNOLOGIES HOLDINGS, LLC Answer to Complaint Page S Leticia Montes v. PPM Technologies Holdings, LLC, et al. Alameda County Superior Court # RG20082639 NY PROOF OF SERVICE WY Fe I am employed in the County of Contra Costa, State of California. I am over the age of 18 years and not a party to the above-captioned matter. My business address is 401 Lennon Lane, Suite 125 in OW Walnut Creek, California 94598. Dn On this date, I served the foregomg ANSWER TO COMPLAINT on the parties below by NHN placing a true copy thereof in a sealed envelope and served same on the parties/counsel, addressed as follows: OA ATTORNEYS FOR PLAINTIFF, LETICIA Oo MONTES: John E. Hill eee Luis Landeros Law Offices of John E. Hill, A.P.C. 333 Hegenberger Road, Suite 500 Oakland, CA 94621 EM: johnhill@hill-law-offices.com me luislanderos@hill-law-offices.com The following is the procedure in which service of this document was effected: CL) | By Mail: by placing a true copy of the document(s) listed above, enclosed in a sealed. OO envelope, addressed as set forth below, for collection and mailing on the date and at the business address shown above following our ordinary business practices. I am readily familiar with this business’ practice for collection and processing of correspondence for mailing with the United States Postal Service. On the same day that a sealed envelope is placed for collection and mailing, it is deposited in the ordinary course of business with the RO United States Postal Service with postage fully prepaid. NYO C) | By Facsimile: by having a true copy of the document(s) listed above transmitted by facsimile to the person(s) at the facsimile number(s) set forth below before 5:00 p.m. The transmission was reported as complete without error by a report issued by the transmitting facsimile RD machine. DD L] | By Personal Service: | caused each such envelope to be delivered by hand to the addressee(s) noted above. KH KX | By Electronic Service ONLY: By personally transmitting a true copy of the document(s) via an electronic mail account maintained at the law finn of Law Offices of John A. Biard to the KN e-mail address(es) above. The transmission(s) was reported as complete and without error. L) | By Electronic Filing & Service: J am familiar with the business practice for electronic HN service. The above described document was filed and served electronically and the transmission reported as complete and without error to the parties listed on the service list with NO [J File&Serve [JOne Legal (J Santa Clara County Superior Court’s efiling website. This service complies with the Court’s order in this case. No PROOF OF SERVICE [] | By Overnight Mail. 1 caused to be served a true and correct copy of the above named document(s) by placing the same in a sealed envelope with postage thereon fully prepaid to be = placed for pickup by Federal Express in Walnut Creek, California. YN WY I, hereby declare, under penalty of perjury, under the laws of the State of California, that the foregoing is true and correct and this document was executed at Walnut Creek, California on July 2, 2021. FF Wg Pax Wn Denee Pousard Bn won Oo OS le KF NYO le F&FAWO mm DBIHD mm OO DOD RO RO K§ NY KO WY HN FP WN Un VN NHN NO nN NO oOo wo PROOF OF SERVICE