Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
Daniel DeSantis, Esq. SBN: 299997/ Rebecca Rojas, Esq. (SBN: 272662)
Wilshire Law Firm
3055 Wilshire Blvd., 12th Floor
Los Angeles, CA 90010
TELEPHONE NO.:(213) 381-9988 (213) 381-9989
FAX NO. (Optional):
ddesantis@wilshirelawfirm.com
E-MAIL ADDRESS (Optional):
Plaintiff, Andres Anguiano-Vargas
ATTORNEY FOR (Name):
SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY
STREET ADDRESS:1200 Aguajito Road
1200 Aguajito Road
MAILING ADDRESS:
Monterey, CA 93940
CITY AND ZIP CODE:
BRANCH NAME:Monterey Branch
PLAINTIFF/PETITIONER: Andres Anguiano-Vargas
DEFENDANT/RESPONDENT: Keewatin Truck Service, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE LIMITED CASE 21 CV002800
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: April 05, 2022 Time: 9:00am Dept.: 14 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Rebecca Rojas, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. This statement is submitted by party (name): Andres Anguiano-Vargas
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): 09/01/2021
b. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. The following parties named in the complaint or cross-complaint
(1) have not been served (specify names and explain why not):
MICHAEL TUSTIN (due to difficulty locating)
(2) have been served but have not appeared and have not been dismissed (specify names):
(3) 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):
4. Description of case
a. Type of case in complaint cross-complaint (Describe, including causes of action):
Motor Vehicle Accident - Negligence
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California
CASE MANAGEMENT STATEMENT rules 3.720–3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: Andres Anguiano-Vargas CASE NUMBER:
DEFENDANT/RESPONDENT: Keewatin Truck Service, et al. 21 CV002800
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.)
This case arises from an incident on September 19, 2019. Plaintiff was traveling northbound on Vertin Ave. approaching the
intersection of Terven Ave. Defendants were also on northbound Vertin Ave. and attempted to make a wide left turn onto
Terven Ave., colliding into Plaintiff. Plaintiff was severely injured as a result of Defendants' negligence and suffered substantial
bodily injuries, including past medical expenses over $700k. Total damages are believed to exceed $3 million.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
a. The party or parties request a jury triaI a nonjury trial.(If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. The trial has been set for(date):
b. (if
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
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 7 days
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
9. 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 has 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 has has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) 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):
CM-110 [Rev. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Andres Anguiano-Vargas CASE NUMBER:
DEFENDANT/RESPONDENT: Keewatin Truck Service, et al. 21 CV002800
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
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
ADR session scheduled for (date):
(6) Other (specify):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. July 1, 2011] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Andres Anguiano-Vargas CASE NUMBER:
DEFENDANT/RESPONDENT: Keewatin Truck Service, et al. 21 CV002800
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes No
c. 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.
Bankruptcy 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. A motion to consolidate coordinate wiII be filed by (name party):
14. Bifurcation
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
(specify moving party, type of motion, and issues):
The party or parties expect to file the following motions before trial
16. Discovery
a. The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiff Written Discovery Per Code
Plaintiff Depositions Per Code
Plaintiff Expert Depositions Per Code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Andres Anguiano-Vargas CASE NUMBER:
DEFENDANT/RESPONDENT: Keewatin Truck Service, et al. 21 CV002800
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 90-98 will apply to this case.
b. 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):
Michael Tustin has not been served as Plaintiff has been unable to locate the correct Michael Tustin. Another Michael Tustin
was served with process on March 14, 2022, but based on information and belief, this was the incorrect Michael Tustin who is
believed to have caused the collision.
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. 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):
I 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: 3/21/2021
Rebecca Rojas, Esq.
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev. July 1, 2011] Page 5 of 5
CASE MANAGEMENT STATEMENT
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
3 I am employed in the County of Los Angeles, State of California. I am over the age of
18 and not a party to the within action. My business address is 3055 Wilshire Blvd., 12 th Floor,
4 Los Angeles, CA 90010.
5 On March 21, 2022 served the foregoing document(s) described as CASE
MANAGEMENT STATEMENT, on all interested parties in this action as set forth on the
6 attached service list in the following manner:
7  BY MAIL: I am familiar with this firm’s practice of collection and processing
correspondence for mailing. Under that practice it would be deposited with the United
8 States Postal Service on that same day with postage thereon fully prepaid at Los Angeles,
California in the ordinary course of business.
9
 BY FACSIMILE: In addition to service by mail as set forth above, a copy of said
10 document(s) was also delivered by facsimile transmission to the addressee(s) pursuant
to Code of Civil Procedure §1013(e).
11
 BY OVERNIGHT MAIL: I caused said document(s) to be picked up via FEDERAL
12 EXPRESS for delivery to the addressee(s) set forth on the attached service list on the
next business day.
WILSHIRE LAW FIRM, PLC
3055 Wilshire Blvd, 12th Floor
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Los Angeles, CA 90010-1137
 BY PERSONAL SERVICE: I caused said document(s) to be delivered via personal
14 delivery to the addressee(s) set forth on the attached service list.
15  BY ELECTRONIC SERVICE: Pursuant to the agreement of the parties, I caused
said document(s) to be delivered via electronic mail to the addressee(s) set forth on the
16 attached service list.
17
 STATE: I declare under penalty of perjury under the laws of the State of
18 California that the above is true and correct.
19  FEDERAL: I declare that I am employed in the office of the member of the bar of
this court at whose direction the service was made.
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Executed on March 21, 2022 at Los Angeles, California.
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SIMON LIANG
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PROOF OF SERVICE
SERVICE LIST
1
2 John Shaffery, Esq. Attorneys for Defendants
3 Kathleen N. Simers, Esq. KEEWATIN TRUCK SERVICE;
POOLE SHAFFERY AGRI-FRESH, INC.; AND
4 25350 Magic Mountain Parkway MICHAEL TUSTIN
2nd Floor
5 Santa Clarita, CA 91355
Tel: (661) 290-2991
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Fax: (661) 290-3338
7 Email: jshaffery@pooleshaffery.com
Email: KSimers@pooleshaffery.com
8 Email: nlyons@pooleshaffery.com
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3055 Wilshire Blvd, 12th Floor
Los Angeles, CA 90010-1137
WILSHIRE LAW FIRM, PLC
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NOTICE OF POSTING JURY FEES
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Daniel DeSantis, Esq. SBN: 299997/ Rebecca Rojas, Esq. (SBN: 272662) Wilshire Law Firm 3055 Wilshire Blvd., 12th Floor Los Angeles, CA 90010 TELEPHONE NO.:(213) 381-9988 (213) 381-9989 FAX NO. (Optional): ddesantis@wilshirelawfirm.com E-MAIL ADDRESS (Optional): Plaintiff, Andres Anguiano-Vargas ATTORNEY FOR (Name): SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY STREET ADDRESS:1200 Aguajito Road 1200 Aguajito Road MAILING ADDRESS: Monterey, CA 93940 CITY AND ZIP CODE: BRANCH NAME:Monterey Branch PLAINTIFF/PETITIONER: Andres Anguiano-Vargas DEFENDANT/RESPONDENT: Keewatin Truck Service, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE 21 CV002800 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: April 05, 2022 Time: 9:00am Dept.: 14 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Rebecca Rojas, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): Andres Anguiano-Vargas b. This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): 09/01/2021 b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. The following parties named in the complaint or cross-complaint (1) have not been served (specify names and explain why not): MICHAEL TUSTIN (due to difficulty locating) (2) have been served but have not appeared and have not been dismissed (specify names): (3) 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): 4. Description of case a. Type of case in complaint cross-complaint (Describe, including causes of action): Motor Vehicle Accident - Negligence Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730 CM-110 [Rev. July 1, 2011] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: Andres Anguiano-Vargas CASE NUMBER: DEFENDANT/RESPONDENT: Keewatin Truck Service, et al. 21 CV002800 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.) This case arises from an incident on September 19, 2019. Plaintiff was traveling northbound on Vertin Ave. approaching the intersection of Terven Ave. Defendants were also on northbound Vertin Ave. and attempted to make a wide left turn onto Terven Ave., colliding into Plaintiff. Plaintiff was severely injured as a result of Defendants' negligence and suffered substantial bodily injuries, including past medical expenses over $700k. Total damages are believed to exceed $3 million. (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial a. The party or parties request a jury triaI a nonjury trial.(If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. The trial has been set for(date): b. (if 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 not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 7 days b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: Additional representation is described in Attachment 8. 9. 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 has 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 has has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) 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): CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Andres Anguiano-Vargas CASE NUMBER: DEFENDANT/RESPONDENT: Keewatin Truck Service, et al. 21 CV002800 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 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 ADR session scheduled for (date): (6) Other (specify): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. July 1, 2011] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Andres Anguiano-Vargas CASE NUMBER: DEFENDANT/RESPONDENT: Keewatin Truck Service, et al. 21 CV002800 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes No c. 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. Bankruptcy 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. A motion to consolidate coordinate wiII be filed by (name party): 14. Bifurcation 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 (specify moving party, type of motion, and issues): The party or parties expect to file the following motions before trial 16. Discovery a. The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Plaintiff Written Discovery Per Code Plaintiff Depositions Per Code Plaintiff Expert Depositions Per Code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Andres Anguiano-Vargas CASE NUMBER: DEFENDANT/RESPONDENT: Keewatin Truck Service, et al. 21 CV002800 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 90-98 will apply to this case. b. 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): Michael Tustin has not been served as Plaintiff has been unable to locate the correct Michael Tustin. Another Michael Tustin was served with process on March 14, 2022, but based on information and belief, this was the incorrect Michael Tustin who is believed to have caused the collision. 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. 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): I 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: 3/21/2021 Rebecca Rojas, Esq. (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. July 1, 2011] Page 5 of 5 CASE MANAGEMENT STATEMENT 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 3 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action. My business address is 3055 Wilshire Blvd., 12 th Floor, 4 Los Angeles, CA 90010. 5 On March 21, 2022 served the foregoing document(s) described as CASE MANAGEMENT STATEMENT, on all interested parties in this action as set forth on the 6 attached service list in the following manner: 7  BY MAIL: I am familiar with this firm’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the United 8 States Postal Service on that same day with postage thereon fully prepaid at Los Angeles, California in the ordinary course of business. 9  BY FACSIMILE: In addition to service by mail as set forth above, a copy of said 10 document(s) was also delivered by facsimile transmission to the addressee(s) pursuant to Code of Civil Procedure §1013(e). 11  BY OVERNIGHT MAIL: I caused said document(s) to be picked up via FEDERAL 12 EXPRESS for delivery to the addressee(s) set forth on the attached service list on the next business day. WILSHIRE LAW FIRM, PLC 3055 Wilshire Blvd, 12th Floor 13 Los Angeles, CA 90010-1137  BY PERSONAL SERVICE: I caused said document(s) to be delivered via personal 14 delivery to the addressee(s) set forth on the attached service list. 15  BY ELECTRONIC SERVICE: Pursuant to the agreement of the parties, I caused said document(s) to be delivered via electronic mail to the addressee(s) set forth on the 16 attached service list. 17  STATE: I declare under penalty of perjury under the laws of the State of 18 California that the above is true and correct. 19  FEDERAL: I declare that I am employed in the office of the member of the bar of this court at whose direction the service was made. 20 Executed on March 21, 2022 at Los Angeles, California. 21 22 SIMON LIANG 23 24 25 26 27 28 PROOF OF SERVICE SERVICE LIST 1 2 John Shaffery, Esq. Attorneys for Defendants 3 Kathleen N. Simers, Esq. KEEWATIN TRUCK SERVICE; POOLE SHAFFERY AGRI-FRESH, INC.; AND 4 25350 Magic Mountain Parkway MICHAEL TUSTIN 2nd Floor 5 Santa Clarita, CA 91355 Tel: (661) 290-2991 6 Fax: (661) 290-3338 7 Email: jshaffery@pooleshaffery.com Email: KSimers@pooleshaffery.com 8 Email: nlyons@pooleshaffery.com 9 10 11 12 3055 Wilshire Blvd, 12th Floor Los Angeles, CA 90010-1137 WILSHIRE LAW FIRM, PLC 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 NOTICE OF POSTING JURY FEES