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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY
Kevin R. Nimmons SBN: 261577
Reicker, Pfau, Pyle & McRoy LLP
1421 State Street, Suite B ELECTRONICALLY FILED
Santa Barbara, CA 93101 Superior Court of California
TELEPHONE NO: 805-966-2440 FAXNO, (Optiona): 805-966-3320 County of Santa Barbara
E-MAIL ADDRESS (Optionay: knimmons@rppmh.com Darrel E. Parker, Executive Officer
ATTORNEY FOR (Name) Andrew Waters and FCP Private, LLC 3/25/2021 5:20 PM
‘SUPERIOR COURT OF CALIFORNIA, COUNTY OFSANTA BARBARA By: Elizabeth Spann, Deputy
street appress:1 100 Anacapa Street
maiuinc avpressP.O. Box 21107
city ano zip cove: Santa Barbara, 93121-1107
BRANCH NAME: Santa Barbara - Anacapa Division
PLAINTIFF/PETITIONER: MARK SCHAUB, et al.
DEFENDANT/RESPONDENT: ANDREW WYLES WATERS, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE [5 uitep case 20CV02113
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date:April 9, 2021 Time:8:30 a.m. Dept.:4 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name):Kevin R. Nimmons, by Zoom
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
Party or parties (answer one):
a. [X] This statement is submitted by party (name): Defendants Andrew Wyles Waters and FCP Private, LLC
b. [_] 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. [-] The cross-complaint, if any, was filed on (date):
Service (to be answered by plaintiffs and cross-complainants only)
a Co al parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. [J The following parties named in the complaint or cross-complaint
(1) [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) [1 have had a default entered against them (specify names):
c. [-) 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 casein (X] complaint C4 cross-complaint (Describe, including causes of action):
Complaint: (1) Conversion; (2) Intentional Misrepresentation; (3) Concealment; and (4) Unjust Enrichment
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. July 1, 2011] www.courts.ca.gov
\Westiaw
Doc & Form Builder
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: MARK SCHAUB, et al.
20CV02113
DEFENDANT/RESPONDENT:
ANDREW WYLES WATERS, et al.
4. b. Provide a brief statement of the case, including any damages. (/f 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.)
Plaintiff Mark Schaub alleges that "by mistake" he transferred millions of dollars to Defendants' accounts and
Defendants refuse to return the money. Plaintiffs also allege fraud and unjust enrichment.
CI (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 a jury trial [Ca nonjury trial. (if more than one party, provide the name of each party
requesting a jury trial): Andrew Waters and FCP Private, LLC
Trial date
a [] The trial has been set for (date):
b. 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):
In 2021: April 5 - 9, June 25 - July 7, August 18 - 24, November 19 - 26, December 24 - 31
Estimated length of trial
The party or parties estimate that the trial will take (check one):
a days (specify number): 4
» CI hours (short causes) (specify):
Trial representation (to be answered for each party)
The party or parties will be represented at trial [EX] by the attorney or party listed in the caption [1 by the following:
a Attorney:
b. Firm:
©. Address:
d. Telephone number: f Fax number:
E-mail address:
oO
g. Party represented:
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 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel [5 thas 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 [5 has [1] has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
4) C4)
d
This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under ode 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 Courtor from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
(CM-110 (Rev. July 1, 2071] CASE MANAGEMENT STATEMENT Page 20f5
CM-110
PLAINTIFF/PETITIONER: MARK SCHAUB, et al. [CASE NUMBER:
DEFENDANT/RESPONDENT:
ANDREW WYLES WATERS, et al. 20CV02113
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 ail 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 al! that apply): stipulation):
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation
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
Private arbitration scheduled for (date):
(5) Binding private
arbitration
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 Rev. July1, 2017] Page
3 0f5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONERMARK SCHAUB, et al.
CASE NUMBER.
| 20CV02113
DEFENDANT/RESPONDENTANDREW WYLES WATERS, et al.
11. Insurance
a [J Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights) [__] Yes No
c. Co 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.
[1] Bankruptey [] other (specify):
Status:
13. Related cases, consolidation, and coordination
a [J There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
[1] Additional cases are described in Attachment 13a.
b. [_] Amotion to [) consolidate [) coordinate will be filed by (name party):
14. Bifurcation
[J 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):
Defendants plan to demurrer to the FAC and file a motion to strike. Defendants also plan to file a cross-complaint.
16. Discovery
a. [__] The party or parties have completed all discovery.
The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Descriptior Date
Defendants To be determined after the Court rules on demurrer and
motion to strike and the pleadings are set.
c. [__] The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
(CM-110 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page
4 of 5
CM-110
PLAINTIFF/PETITIONER:
MARK SCHAUB, et al. CASE NUMBER,
| 20CV02113
DEFENDANT/RESPONDENT:
ANDREW WYLES WATERS, et al.
17. Economic litigation
a. [_] 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 91 |-98 will apply to this case.
b. L__] 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
[The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
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. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify): Early settlement talks and mediation may be productive. Defendants request a CMADRESS
referral by the Court.
20. Total number of pages attached (if any):1 - Proof of Service
| 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 required.
Date: March 25, 2021
Kevin R. Nimmons »
Nh. Vi
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME)
» (SIGNATURE OF PARTY OR ATTORNEY)
[) Additional signatures are attached.
(OM-110 [Rev. July1, 2011] CASE MANAGEMENT STATEMENT Page ofS
PROOF OF SERVICE
I, the undersi that I am a citizen of the United States, over 18 years
of age, and|
nota to the wii action. I am employed the law firm of Reicker, Pfau, Pyle& McRoy
LLP, 1421 State Street, Ste. B, Santa Barbara, fomia 93101
On March 25, 2021, I served the within: DEFENDANTS' CASE MANAGEMENT
STATEMENT FOR THE CONFERENCE ON APRIL 9, 2021 onthe interested parties listed]
below, as follows:
Matthew Donald Umhofer
DianeH.
SPERTUS, LANDES & UMHOFER, LLP
1990 South Bundy Dr., Suite 705
Los es, Califomia 90025
Telephone: (310) 826-4700
Facsimile: (310) 826-471 1
jaw.com
10 Email: jane@: aw.com.
11
12 (X) (By Mail) I caused such document to be mailed in a sealed envelope, by first-class mail,
postage fully prepaid. I am “readily familiar” with this finm’s practice of collection and|
13 processing correspondence for It is deposited with the U.S. postal service on
that same day in the ordinary course of business. I am aware that on motion of party|
14 served, SEIV1Ce 1S invalid if the cancellation date or postage meter date is
more than one (1) day after the date of deposit for mailing as stated in this declaration.
15
() (By Personal Service) I caused such document to be delivered by hand.
16
() (By FAX) I caused such document to be sent via facsimile transmission to the above-
17 listed addressee(s) and FAX number(s). This transmission was reported as complete and)
without enor.
18
(X) ((By E-MAIL [CCP § 1010.6(a)(2)) On the date indicated on this Proof of Service, at
19 the time indicated on in the header of my electronic mail, I transmitted the foregoing}
document(s) lectronic mail to one or more of the recipients at each firm indicated on|
20 this Proof of ce. I caused the computerto print or maintain a record of the
electronic mail to the recipients named in this Proofof Service, a true and correct copy of
21 which has been retained by Reicker, Pfau, le & McRoy LLP in either hard copy or
electronic format in the ordinary course of and is available for inspection if
necessary.
(x) (State) I declare under penalty of perjury pursuantto the laws of the State of Califomia
that the foregoing is true and co
24
Executed March 25, 2021, at Santa Barbara, Califomia.
25
26 Cataene Cagper
Catrine Casper
27
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY Kevin R. Nimmons SBN: 261577 Reicker, Pfau, Pyle & McRoy LLP 1421 State Street, Suite B ELECTRONICALLY FILED Santa Barbara, CA 93101 Superior Court of California TELEPHONE NO: 805-966-2440 FAXNO, (Optiona): 805-966-3320 County of Santa Barbara E-MAIL ADDRESS (Optionay: knimmons@rppmh.com Darrel E. Parker, Executive Officer ATTORNEY FOR (Name) Andrew Waters and FCP Private, LLC 3/25/2021 5:20 PM ‘SUPERIOR COURT OF CALIFORNIA, COUNTY OFSANTA BARBARA By: Elizabeth Spann, Deputy street appress:1 100 Anacapa Street maiuinc avpressP.O. Box 21107 city ano zip cove: Santa Barbara, 93121-1107 BRANCH NAME: Santa Barbara - Anacapa Division PLAINTIFF/PETITIONER: MARK SCHAUB, et al. DEFENDANT/RESPONDENT: ANDREW WYLES WATERS, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE [5 uitep case 20CV02113 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date:April 9, 2021 Time:8:30 a.m. Dept.:4 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name):Kevin R. Nimmons, by Zoom INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. Party or parties (answer one): a. [X] This statement is submitted by party (name): Defendants Andrew Wyles Waters and FCP Private, LLC b. [_] 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. [-] The cross-complaint, if any, was filed on (date): Service (to be answered by plaintiffs and cross-complainants only) a Co al parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. [J The following parties named in the complaint or cross-complaint (1) [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) [1 have had a default entered against them (specify names): c. [-) 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 casein (X] complaint C4 cross-complaint (Describe, including causes of action): Complaint: (1) Conversion; (2) Intentional Misrepresentation; (3) Concealment; and (4) Unjust Enrichment 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. July 1, 2011] www.courts.ca.gov \Westiaw Doc & Form Builder CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: MARK SCHAUB, et al. 20CV02113 DEFENDANT/RESPONDENT: ANDREW WYLES WATERS, et al. 4. b. Provide a brief statement of the case, including any damages. (/f 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.) Plaintiff Mark Schaub alleges that "by mistake" he transferred millions of dollars to Defendants' accounts and Defendants refuse to return the money. Plaintiffs also allege fraud and unjust enrichment. CI (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 a jury trial [Ca nonjury trial. (if more than one party, provide the name of each party requesting a jury trial): Andrew Waters and FCP Private, LLC Trial date a [] The trial has been set for (date): b. 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): In 2021: April 5 - 9, June 25 - July 7, August 18 - 24, November 19 - 26, December 24 - 31 Estimated length of trial The party or parties estimate that the trial will take (check one): a days (specify number): 4 » CI hours (short causes) (specify): Trial representation (to be answered for each party) The party or parties will be represented at trial [EX] by the attorney or party listed in the caption [1 by the following: a Attorney: b. Firm: ©. Address: d. Telephone number: f Fax number: E-mail address: oO g. Party represented: 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 for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel [5 thas 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 [5 has [1] has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). 4) C4) d This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under ode 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 Courtor from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): (CM-110 (Rev. July 1, 2071] CASE MANAGEMENT STATEMENT Page 20f5 CM-110 PLAINTIFF/PETITIONER: MARK SCHAUB, et al. [CASE NUMBER: DEFENDANT/RESPONDENT: ANDREW WYLES WATERS, et al. 20CV02113 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 ail 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 al! that apply): stipulation): Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation 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 Private arbitration scheduled for (date): (5) Binding private arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 Rev. July1, 2017] Page 3 0f5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONERMARK SCHAUB, et al. CASE NUMBER. | 20CV02113 DEFENDANT/RESPONDENTANDREW WYLES WATERS, et al. 11. Insurance a [J Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights) [__] Yes No c. Co 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. [1] Bankruptey [] other (specify): Status: 13. Related cases, consolidation, and coordination a [J There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: [1] Additional cases are described in Attachment 13a. b. [_] Amotion to [) consolidate [) coordinate will be filed by (name party): 14. Bifurcation [J 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): Defendants plan to demurrer to the FAC and file a motion to strike. Defendants also plan to file a cross-complaint. 16. Discovery a. [__] The party or parties have completed all discovery. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Descriptior Date Defendants To be determined after the Court rules on demurrer and motion to strike and the pleadings are set. c. [__] The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): (CM-110 (Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: MARK SCHAUB, et al. CASE NUMBER, | 20CV02113 DEFENDANT/RESPONDENT: ANDREW WYLES WATERS, et al. 17. Economic litigation a. [_] 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 91 |-98 will apply to this case. b. L__] 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 [The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer 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. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): Early settlement talks and mediation may be productive. Defendants request a CMADRESS referral by the Court. 20. Total number of pages attached (if any):1 - Proof of Service | 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 required. Date: March 25, 2021 Kevin R. Nimmons » Nh. Vi (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) » (SIGNATURE OF PARTY OR ATTORNEY) [) Additional signatures are attached. (OM-110 [Rev. July1, 2011] CASE MANAGEMENT STATEMENT Page ofS PROOF OF SERVICE I, the undersi that I am a citizen of the United States, over 18 years of age, and| nota to the wii action. I am employed the law firm of Reicker, Pfau, Pyle& McRoy LLP, 1421 State Street, Ste. B, Santa Barbara, fomia 93101 On March 25, 2021, I served the within: DEFENDANTS' CASE MANAGEMENT STATEMENT FOR THE CONFERENCE ON APRIL 9, 2021 onthe interested parties listed] below, as follows: Matthew Donald Umhofer DianeH. SPERTUS, LANDES & UMHOFER, LLP 1990 South Bundy Dr., Suite 705 Los es, Califomia 90025 Telephone: (310) 826-4700 Facsimile: (310) 826-471 1 jaw.com 10 Email: jane@: aw.com. 11 12 (X) (By Mail) I caused such document to be mailed in a sealed envelope, by first-class mail, postage fully prepaid. I am “readily familiar” with this finm’s practice of collection and| 13 processing correspondence for It is deposited with the U.S. postal service on that same day in the ordinary course of business. I am aware that on motion of party| 14 served, SEIV1Ce 1S invalid if the cancellation date or postage meter date is more than one (1) day after the date of deposit for mailing as stated in this declaration. 15 () (By Personal Service) I caused such document to be delivered by hand. 16 () (By FAX) I caused such document to be sent via facsimile transmission to the above- 17 listed addressee(s) and FAX number(s). This transmission was reported as complete and) without enor. 18 (X) ((By E-MAIL [CCP § 1010.6(a)(2)) On the date indicated on this Proof of Service, at 19 the time indicated on in the header of my electronic mail, I transmitted the foregoing} document(s) lectronic mail to one or more of the recipients at each firm indicated on| 20 this Proof of ce. I caused the computerto print or maintain a record of the electronic mail to the recipients named in this Proofof Service, a true and correct copy of 21 which has been retained by Reicker, Pfau, le & McRoy LLP in either hard copy or electronic format in the ordinary course of and is available for inspection if necessary. (x) (State) I declare under penalty of perjury pursuantto the laws of the State of Califomia that the foregoing is true and co 24 Executed March 25, 2021, at Santa Barbara, Califomia. 25 26 Cataene Cagper Catrine Casper 27