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= CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address} FOR COURT USE ONLY
E>. Michele Ballard Miller (SBN 104198); Mary L. Guilfoyle (SBN 143308)
aa) |— Gregory F. Fortescue (SBN 249133)
MILLER LAW GROUP, PC
111 Sutter Street, Suite 700, San Francisco, CA 94104
qa. TELEPHONE NO: (415) 464-4300 FAX NO. (Optiona): (415) 464-4336 FILED
(emanean) : :
E-MAIL ADDRESS (Optionan. MDOM@millerlawgroup.com; gff@millerlawgroup.com Al AMB
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=—_,
FE) ATTORNEY
FOR (Name Defendants DA COUNTY
\ J SUPERIOR COURT OF CALIFORNIA, COUNTY OF ALAMEDA ;
(am street Aooress: 24405 Amador Street ; MAY 0 9 2011
MAILING ADDRESS: CLERK OF >
city anpzip cove. Hayward, CA 94544 By 9) pe SUPERIOR COURT
BRANCH Name: Hayward Hall of Justice En TESS,
PLAINTIFF/PETITIONER: ROBIN BONGON Deputy
DEFENDANT/RESPONDENT: KAISER FOUNDATION HOSPITALS, INC., et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE [_-] LIMITED CASE » RG10495979
(Amount demanded {Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: May 23, 2011 Time: 3:00 p.m. Dept.: 512 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Gregory F. Fortescue
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. amy or parties (answer one):
| This statement is submitted by party (name):
b [¥] This statement is submitted jointly by parties (names): Kaiser Foundation Hospitals, Kaiser Foundation Health Plan
and Ron Navarra
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. LJ The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
[] oan parties named in the complaint and cross-complaint have been served, or 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):
(2) [__] have been served but have not appeared and have not been dismissed (specify names):
(3) [2] have had a default entered against them (specify names):
c. C_] The following additional parties may be added (specify names, nature of involvement in case, and the date by which
. they may be served):
4. Description of case
a. Type ofcasein (¥ ] complaint LJ cross-complaint (Describe, including causes of action):
Plaintiff alleges: (1) Gender discrimination and harassment; (2) FEHA retaliation; (3) disability discrimination; (4)
CFRA retaliation; (5) violation of Labor Code 1102.5; and (6) violation of Art.1, sec. 8 of the Calif. Constitution.
: : Page 10f 4
Form Adopted for Mandatory Use ‘ Cal. Rules of Court
Judicial Counal of Calfomia CASE MANAGEMENT STATEMENT cules 3.720-3,70
CM-110 (Rev. January 1, 2009] www.courtinfo.ca.gov
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CM-110
PLAINTIFF/PETITIONER: ROBIN BONGON CASE NUMBER:
|DEFENDANT/RESPONDENT: KAISER FOUNDATION HOSPITALS, INC., et al. RG10495979
4. b. Provide a brief statement of the case, including any damages. (ff 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
eamings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiff alleges claims under the California Fair Employment & Housing Act ("FEHA") for discrimination (based on
gender and disability), sex harassment/hostile work environment, and retaliation. Plaintiff also asserts claims for
retaliation under the California Family Rights Act ("CFRA"), violation of California Labor Code section 1102.5, and
violation of article 1, section 8 of the California Constitution. Plaintiff seeks compensatory and punitive damages.
Defendants deny any and all of Plaintiff's claims and deny that Plaintiff was harmed in any sum or at all.
["_] (if more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request [a jury trial a nonjury trial. (lf 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. Ly] 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):
9/27/11-10/7/11 (trial on 9/27/11); 10/24/11-11/18/11 (trials on 10/24/11 and 11/7/11); 1/17/12-2/29/12 (trials on
1/17/12, 2/3/12 and 2/14/12); and 5/21/12-6/1/12 (trial on 5/21/12).
7. Estimated length of trial .
The party or parties estimate that the trial will take (check one):
a. days (specify number): 5-7 ‘
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 follawing:
Attorney:
omepange
Firm:
Address:
Telephone number:
Fax number.
E-mail address:
. 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. Counsel nas [__] hasnot provided the ADR information package identified in rule 3.221 to the client and has
reviewed ADR options with the client.
b. [_] All parties have agreed to a form of ADR. ADR will be completed by (date):
c. L__] The case has gone to an ADR process (indicate status):
CM-110 [Rev. January 1, 2009] . Page 2 of 4
CASE MANAGEMENT STATEMENT
‘
a7
CM-110
PLAINTIFF/PETITIONER: ROBIN BONGON CASE NUMBER:
-DEFENDANT/RESPONDENT: KAISER FOUNDATION HOSPITALS, INC., et al. RG10495979
10.d. The party or parties are willing to participate in (check all that apply):
(1) Mediation
(2) LJ Nonbinding judicial arbitration under Code of Civil Procedure section 1141.12 (discovery to close 15 days before
arbitration under Cal. Rules of Court, rule 3.822) ;
(3) (._] Nonbinding judicial arbitration under Code of Civil Procedure section 1141.12 (discovery to remain open until 30 days
before trial; order required under Cal. Rules of Court, rule 3.822)
(4) (_] Binding judicial arbitration
(5) (__} Binding private arbitration
(6) (__] Neutral case evaluation
(7) Other (specify):
Defendants willing to mediate if parties can agree to split the fee.
e. ([__] This matter is subject to mandatory judicial arbitration because the amount in controversy does not exceed
the statutory limit.
f [1] 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. .
g. L_] This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court (specify exemption):
11. Settlement conference ;
The party or parties are willing to participate in an early settlement conference (specify when):
If necessary, after the court rules upon Defendants’ motion for summary judgment/summary adjudication.
12. Insurance ;
a. {__] Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: [__] Yes [_] No
« [_) Coverage issues will significantly affect resolution of this case (explain):
13. Jurisdiction .
Indicate any matters that may affect the court's jurisdiction or processing of this case, and describe the status.
[-_] Bankruptey [__] Other (specify):
Status:
14. 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 14a.
b. [._]Amotionto {([_] consolidate [__] coordinate will be filed by (name party):
15. 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):
Defendants intend to seek bifurcation of punitive damages from the liability phase of trial.
16. Other motions
The party or parties expect to file the follawing motions before trial (specify moving party, type of motion, and issues).
Discovery motions as needed; motion for summary judgment or summary adjudication; pretrial motions.
Page 3 of 4
CM-110 (Rev. January1, 2003] ' CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: ROBIN BONGON CASE NUMBER:
. RG10495979
[DEFENDANT/RESPONDENT: KAISER FOUNDATION HOSPITALS, INC., et al.
17. 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
Defendant Written Discovery (RFPs, Interrogatories, RFAs). July 2011
Defendant Percipient Witness Depositions. June-August 2011
Defendant Possible Third-Party Subpoenas. July-Sept. 20114
Defendant Expert Discovery. October 2011
c. The following discovery issues are anticipated (specify):
Pursuant to this Court's order, the parties are scheduled to meet and confer by phone on May 9, 2011 to
discuss outstanding discovery issues including production of privileged investigation reports, third-party
personnel files, Plaintiffs relevant psychiatric and OB/GYN records, among other items. If the parties cannot
reach appropriate stipulations on these matters, Defendants anticipate filing motions to compel and for
protective orders.
18. 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 through 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):
19. Other issues .
[] The party or parties request that the following additional matters be considered or determined at the case management ©
conference (specify): ;
20. Meet and confer
a. L¥_] 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):
21. Total number of pages attached (if any):
| am completely familiar with this case and will be fully prepared to discuss the status of discovery and ADR, 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: May 9, 2011
Gregory F. Fortescue > Cc! —_— S——
(TYPE OR PRINT NAME) "(SIGNATUREOF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME}
> {SIGNATURE OF PARTY OR ATTORNEY)
[__] Additional signatures are attached.
Page 4of 4
CM-10 [Rev. January 1, 2008) CASE MANAGEMENT STATEMENT
PROOF OF SERVICE
=
_l, Cheryl Bower, declare that | am employed at Miller Law Group, A Professional
PDP
Corporation, whose address is 111 Sutter Street, Suite 700, San Francisco, CA 94104; | am
over the age of eighteen (18) years and am not a party to this action. On the below date, by
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the method noted below, | served the following document(s):
FF
CASE MANAGEMENT STATEMENT
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on the interested parties in this action by placing a true and correct copy thereof, enclosed
in a sealed envelope addressed as follows:
NO
Marylon M. Boyd, Esq. Andrea Rosa, Esq.
LAW OFFICES OF MARYLON M. BOYD THE ROSA LAW GROUP
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2201 Broadway Street, Suite 815 5050 Laguna Blvd., Suite 112-580
Oakland, CA 94612 Elk Grove, CA 95758
Tel: (510) 663-8772 . Tel: (916) 647-9425
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Fax: (510) 663-8781 Fax: (916) 647-9425
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Email: lawofficeofmarylonboyd@yahoo.com Email: andrea.rosa@therosalawgqroup.com
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Attorney for Plaintiff: Robin Bongon _ Attorney for Plaintiff: Robin Bongon
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Xd BY MAIL: By placing a true copy thereof enclosed in a sealed envelope with
postage thereon fully prepaid, in the ordinary course of business for collection and
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CORPORATION
CALIFORNIA
mailing on this date at Miller Law Group, 111 Sutter Street, San Francisco, California.
MILLER Law Group
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| declare that | am readily familiar with the business practice of Miller Law Group for
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collection and processing of correspondence for mailing with the United States Postal
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FRANCISCO,
PROFESSIONAL
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Service and that the correspondence would be deposited with the United States
Postal Service that same day in the ordinary course of business.
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BY OVERNIGHT DELIVERY: By placing the document(s) listed above in a sealed
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envelope(s) and consigning it/them to an express mail or overnight courier for
guaranteed delivery on the next business day following the date of consignment to
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the address(es) set forth above. A copy of the consignment slip is attached to the
last page of this proof of service.
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| declare under penalty of perjury under the laws of the State of California that the
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foregoing is true and correct.
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Executed on May 9, 2011 at San Francisco, California.
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PROOF OF SERVICE
Case No. RG10495979
Preview
@ — @ PA eo me = CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address} FOR COURT USE ONLY E>. Michele Ballard Miller (SBN 104198); Mary L. Guilfoyle (SBN 143308) aa) |— Gregory F. Fortescue (SBN 249133) MILLER LAW GROUP, PC 111 Sutter Street, Suite 700, San Francisco, CA 94104 qa. TELEPHONE NO: (415) 464-4300 FAX NO. (Optiona): (415) 464-4336 FILED (emanean) : : E-MAIL ADDRESS (Optionan. MDOM@millerlawgroup.com; gff@millerlawgroup.com Al AMB c =—_, FE) ATTORNEY FOR (Name Defendants DA COUNTY \ J SUPERIOR COURT OF CALIFORNIA, COUNTY OF ALAMEDA ; (am street Aooress: 24405 Amador Street ; MAY 0 9 2011 MAILING ADDRESS: CLERK OF > city anpzip cove. Hayward, CA 94544 By 9) pe SUPERIOR COURT BRANCH Name: Hayward Hall of Justice En TESS, PLAINTIFF/PETITIONER: ROBIN BONGON Deputy DEFENDANT/RESPONDENT: KAISER FOUNDATION HOSPITALS, INC., et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE [_-] LIMITED CASE » RG10495979 (Amount demanded {Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 23, 2011 Time: 3:00 p.m. Dept.: 512 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Gregory F. Fortescue INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. amy or parties (answer one): | This statement is submitted by party (name): b [¥] This statement is submitted jointly by parties (names): Kaiser Foundation Hospitals, Kaiser Foundation Health Plan and Ron Navarra 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. LJ The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) [] oan parties named in the complaint and cross-complaint have been served, or 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): (2) [__] have been served but have not appeared and have not been dismissed (specify names): (3) [2] have had a default entered against them (specify names): c. C_] The following additional parties may be added (specify names, nature of involvement in case, and the date by which . they may be served): 4. Description of case a. Type ofcasein (¥ ] complaint LJ cross-complaint (Describe, including causes of action): Plaintiff alleges: (1) Gender discrimination and harassment; (2) FEHA retaliation; (3) disability discrimination; (4) CFRA retaliation; (5) violation of Labor Code 1102.5; and (6) violation of Art.1, sec. 8 of the Calif. Constitution. : : Page 10f 4 Form Adopted for Mandatory Use ‘ Cal. Rules of Court Judicial Counal of Calfomia CASE MANAGEMENT STATEMENT cules 3.720-3,70 CM-110 (Rev. January 1, 2009] www.courtinfo.ca.gov ir } CTE | com [fe ry G @ CM-110 PLAINTIFF/PETITIONER: ROBIN BONGON CASE NUMBER: |DEFENDANT/RESPONDENT: KAISER FOUNDATION HOSPITALS, INC., et al. RG10495979 4. b. Provide a brief statement of the case, including any damages. (ff 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 eamings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiff alleges claims under the California Fair Employment & Housing Act ("FEHA") for discrimination (based on gender and disability), sex harassment/hostile work environment, and retaliation. Plaintiff also asserts claims for retaliation under the California Family Rights Act ("CFRA"), violation of California Labor Code section 1102.5, and violation of article 1, section 8 of the California Constitution. Plaintiff seeks compensatory and punitive damages. Defendants deny any and all of Plaintiff's claims and deny that Plaintiff was harmed in any sum or at all. ["_] (if more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request [a jury trial a nonjury trial. (lf 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. Ly] 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): 9/27/11-10/7/11 (trial on 9/27/11); 10/24/11-11/18/11 (trials on 10/24/11 and 11/7/11); 1/17/12-2/29/12 (trials on 1/17/12, 2/3/12 and 2/14/12); and 5/21/12-6/1/12 (trial on 5/21/12). 7. Estimated length of trial . The party or parties estimate that the trial will take (check one): a. days (specify number): 5-7 ‘ 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 follawing: Attorney: omepange Firm: Address: Telephone number: Fax number. E-mail address: . 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. Counsel nas [__] hasnot provided the ADR information package identified in rule 3.221 to the client and has reviewed ADR options with the client. b. [_] All parties have agreed to a form of ADR. ADR will be completed by (date): c. L__] The case has gone to an ADR process (indicate status): CM-110 [Rev. January 1, 2009] . Page 2 of 4 CASE MANAGEMENT STATEMENT ‘ a7 CM-110 PLAINTIFF/PETITIONER: ROBIN BONGON CASE NUMBER: -DEFENDANT/RESPONDENT: KAISER FOUNDATION HOSPITALS, INC., et al. RG10495979 10.d. The party or parties are willing to participate in (check all that apply): (1) Mediation (2) LJ Nonbinding judicial arbitration under Code of Civil Procedure section 1141.12 (discovery to close 15 days before arbitration under Cal. Rules of Court, rule 3.822) ; (3) (._] Nonbinding judicial arbitration under Code of Civil Procedure section 1141.12 (discovery to remain open until 30 days before trial; order required under Cal. Rules of Court, rule 3.822) (4) (_] Binding judicial arbitration (5) (__} Binding private arbitration (6) (__] Neutral case evaluation (7) Other (specify): Defendants willing to mediate if parties can agree to split the fee. e. ([__] This matter is subject to mandatory judicial arbitration because the amount in controversy does not exceed the statutory limit. f [1] 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. . g. L_] This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court (specify exemption): 11. Settlement conference ; The party or parties are willing to participate in an early settlement conference (specify when): If necessary, after the court rules upon Defendants’ motion for summary judgment/summary adjudication. 12. Insurance ; a. {__] Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: [__] Yes [_] No « [_) Coverage issues will significantly affect resolution of this case (explain): 13. Jurisdiction . Indicate any matters that may affect the court's jurisdiction or processing of this case, and describe the status. [-_] Bankruptey [__] Other (specify): Status: 14. 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 14a. b. [._]Amotionto {([_] consolidate [__] coordinate will be filed by (name party): 15. 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): Defendants intend to seek bifurcation of punitive damages from the liability phase of trial. 16. Other motions The party or parties expect to file the follawing motions before trial (specify moving party, type of motion, and issues). Discovery motions as needed; motion for summary judgment or summary adjudication; pretrial motions. Page 3 of 4 CM-110 (Rev. January1, 2003] ' CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: ROBIN BONGON CASE NUMBER: . RG10495979 [DEFENDANT/RESPONDENT: KAISER FOUNDATION HOSPITALS, INC., et al. 17. 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 Defendant Written Discovery (RFPs, Interrogatories, RFAs). July 2011 Defendant Percipient Witness Depositions. June-August 2011 Defendant Possible Third-Party Subpoenas. July-Sept. 20114 Defendant Expert Discovery. October 2011 c. The following discovery issues are anticipated (specify): Pursuant to this Court's order, the parties are scheduled to meet and confer by phone on May 9, 2011 to discuss outstanding discovery issues including production of privileged investigation reports, third-party personnel files, Plaintiffs relevant psychiatric and OB/GYN records, among other items. If the parties cannot reach appropriate stipulations on these matters, Defendants anticipate filing motions to compel and for protective orders. 18. 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 through 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): 19. Other issues . [] The party or parties request that the following additional matters be considered or determined at the case management © conference (specify): ; 20. Meet and confer a. L¥_] 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): 21. Total number of pages attached (if any): | am completely familiar with this case and will be fully prepared to discuss the status of discovery and ADR, 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: May 9, 2011 Gregory F. Fortescue > Cc! —_— S—— (TYPE OR PRINT NAME) "(SIGNATUREOF PARTY OR ATTORNEY) (TYPE OR PRINT NAME} > {SIGNATURE OF PARTY OR ATTORNEY) [__] Additional signatures are attached. Page 4of 4 CM-10 [Rev. January 1, 2008) CASE MANAGEMENT STATEMENT PROOF OF SERVICE = _l, Cheryl Bower, declare that | am employed at Miller Law Group, A Professional PDP Corporation, whose address is 111 Sutter Street, Suite 700, San Francisco, CA 94104; | am over the age of eighteen (18) years and am not a party to this action. On the below date, by }H the method noted below, | served the following document(s): FF CASE MANAGEMENT STATEMENT oO on the interested parties in this action by placing a true and correct copy thereof, enclosed in a sealed envelope addressed as follows: NO Marylon M. Boyd, Esq. Andrea Rosa, Esq. LAW OFFICES OF MARYLON M. BOYD THE ROSA LAW GROUP oO 2201 Broadway Street, Suite 815 5050 Laguna Blvd., Suite 112-580 Oakland, CA 94612 Elk Grove, CA 95758 Tel: (510) 663-8772 . Tel: (916) 647-9425 0 Fax: (510) 663-8781 Fax: (916) 647-9425 oO = Email: lawofficeofmarylonboyd@yahoo.com Email: andrea.rosa@therosalawgqroup.com = lk Attorney for Plaintiff: Robin Bongon _ Attorney for Plaintiff: Robin Bongon = DN WHO = Xd BY MAIL: By placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, in the ordinary course of business for collection and FR = CORPORATION CALIFORNIA mailing on this date at Miller Law Group, 111 Sutter Street, San Francisco, California. MILLER Law Group aT | declare that | am readily familiar with the business practice of Miller Law Group for _ collection and processing of correspondence for mailing with the United States Postal DD FRANCISCO, PROFESSIONAL = Service and that the correspondence would be deposited with the United States Postal Service that same day in the ordinary course of business. N = SAN BY OVERNIGHT DELIVERY: By placing the document(s) listed above in a sealed A DO = envelope(s) and consigning it/them to an express mail or overnight courier for guaranteed delivery on the next business day following the date of consignment to Oo — the address(es) set forth above. A copy of the consignment slip is attached to the last page of this proof of service. Dd i] |= | declare under penalty of perjury under the laws of the State of California that the No foregoing is true and correct. PO no Executed on May 9, 2011 at San Francisco, California. WO i) fF ho oO ho Cheryl Boyer OO Ro vn bo oO No PROOF OF SERVICE Case No. RG10495979