Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Allison Lawrence 290770 Louis Barella 118003
Tyson & Mendes, LLP
371 Bel Marin Keys Blvd., Suite 100
Novato, CA 94949
TELEPHONE NO.: (628) 253-5070 FAX NO.(Optional): (415) 785-3165
E-MAIL ADDRESS: alawrence@tysonmendes.com
ATTORNEY FOR (Name): Defendant McMillan Electric
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Alameda
STREET ADDRESS: 24405 Amador Street
MAILING ADDRESS:
Hayward, CA 94544
CITY AND ZIP CODE:
BRANCH NAME:Hayward Hall of Justice
PLAINTIFF/PETITIONER: XL Insurance
DEFENDANT/RESPONDENT: Manuel Iniguez Palacios, McMillan Electric
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one):
X UNLIMITED CASE LIMITED CASE HG21110630
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: January 21, 2022 Time: 2:00 p.m Dept.: 514 Div.: Room:
Address of court (if different from the address above):
X Notice of Intent to Appear by Telephone, by (name): Louis R. Barella
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. X This statement is submitted by party (name): McMillan Electric
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):
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):
(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 the date by which
they may be served):
4. Description of case
a. Type of case in
X complaint cross-complaint (Describe, including causes of action):
Negligence
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. September 1, 2021] www.courts.ca.gov
21-2461 XL
CM-110
PLAINTIFF/PETITIONER: XL Insurance CASE NUMBER:
HG21110630
DEFENDANT/RESPONDENT: Manuel Iniguez Palacios, McMillan Electric
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.)
Plaintiff is seeking reimbursement for workers compensation benefits
paid on behalf of its insured's employee. Defendant disputes
liability and the claimed damages.
(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
X a jury trial 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. X 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): The underlying workers compensation case has not resolved.
Discovery is continuing. Mr. Palacios has not appeared as well
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
See attached list.
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. X 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 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 of the California Rules of Court for information about the
processes available through the court and community programs in this case.
(1) For parties represented by counsel: Counsel X 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 of 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. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5
21-2461 XL
CM-110
PLAINTIFF/PETITIONER: XL Insurance CASE NUMBER:
HG21110630
DEFENDANT/RESPONDENT: Manuel Iniguez Palacios, McMillan Electric
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):
X Mediation session not yet scheduled
(1) Mediation
X Mediation session scheduled for (date):
Agreed to complete mediation by (date):
Mediation completed on (date):
X Settlement conference not yet scheduled
(2) Settlement
X Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
(3) Neutral evaluation Neutral evaluation scheduled for (date):
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
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5
21-2461 XL
CM-110
PLAINTIFF/PETITIONER: XL Insurance CASE NUMBER:
HG21110630
DEFENDANT/RESPONDENT: Manuel Iniguez Palacios, McMillan Electric
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 will 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
X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motions in Limine
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
Defendant Written Discovery July 2022
Defendant Subpoena Records Ongoing
Defendant Depositions of parties and witnesses September 2022
Defendant Expert Discovery tbd
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5
21-2461 XL
CM-110
PLAINTIFF/PETITIONER: XL Insurance CASE NUMBER:
HG21110630
DEFENDANT/RESPONDENT: Manuel Iniguez Palacios, McMillan Electric
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
X The party or parties request that the following additional matters be considered or determined at the case management
conference (specify): Defendant is in the process of locating Mr. Palacios to
confirm if he was served with the complaint.
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: January 7, 2022
Louis R. Barella
(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. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5
21-2461 XL
Unavailable Dates per Paragraph 6.c. to Case Management Conference Statement
Allison Lawrence
Trial Case Associate Venue
1/24/2022 Spicer v. W.A Rasic San Bernardino
1/26/2022 Kloythanomsup v. Borg JKS San Francisco
2/8/2022 Ruiz v. Casey LRB Stanislaus
3/14/2022 Corgiat v. Petco JKS Fresno
3/24/2023 Papion v. Little TRS Alameda
3/28/2022 Zand v. Mendoza JKS Santa Clara
3/28/2022 Jolley v. The Whiting Turner Contracting CLC Alameda
Co.
4/1/2022 Hairston v. Ameron Pole Products, LLC JKS Alameda
4/18/2022 Adams v. SJWC AKW/JKS Santa Clara
6/16/2023 Burnett v. BMW/CBC Clearbrook (Beck LRB Alameda
v. Burnett)
6/20/2022 Rodriguez v. Jasper Hall San Francisco
7/11/2022 Blackwell v. Tesla JKS Alameda
8/1/2022 Jobe v. Conco LRB Alameda
8/22/2022 Oregon Mutual v. Whistler TRS Alameda
8/8/2022 Lenz v. Petco Monterey
11/14/2022 Stephens v. Breves CLC Alameda
1/7/2022
XL Insurance v. Palacios, et al.
Alameda Superior Court Case No.: HG21110630
1 PROOF OF SERVICE
2
I declare that:
3
I am a citizen of the United States, employed in the County of Marin, California, over the
4
age of eighteen years, and not a party to the within cause. My business address is 371 Bel Marin
5 Keys Boulevard, Suite 100, Novato, CA 94949. I served the within:
6
CASE MANAGEMENT STATEMENT
7
8
_XX_ BY ELECTRONIC TRANSMISSION: My email address is
9 ljohnson@tysonmendes.com. I electronically transmitted via email the above listed
document(s) to the email address(es) set forth below on this date.
10
11 PARTIES SERVED: Plaintiffs
Katherine A. Sandoval
12 MATTHIESEN, WICKERT & LEHRER, S.C.
13 1851 E. First Street, Suite 1150
Santa Ana, CA 92705
14 800-637-9176
262-673-3766
15 ksandoval@mwl-law.com
cc: Paola Rodriguez
16
prodriguez@mwl-law.com
17
18
19 I certify and declare under penalty of perjury that the foregoing is true and correct and
that this declaration was executed on January 7, 2022, at Novato, California.
20
21
_________________________________
22 Laurel Johnson
23
24
25
26
27
28
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Allison Lawrence 290770 Louis Barella 118003 Tyson & Mendes, LLP 371 Bel Marin Keys Blvd., Suite 100 Novato, CA 94949 TELEPHONE NO.: (628) 253-5070 FAX NO.(Optional): (415) 785-3165 E-MAIL ADDRESS: alawrence@tysonmendes.com ATTORNEY FOR (Name): Defendant McMillan Electric SUPERIOR COURT OF CALIFORNIA, COUNTY OF Alameda STREET ADDRESS: 24405 Amador Street MAILING ADDRESS: Hayward, CA 94544 CITY AND ZIP CODE: BRANCH NAME:Hayward Hall of Justice PLAINTIFF/PETITIONER: XL Insurance DEFENDANT/RESPONDENT: Manuel Iniguez Palacios, McMillan Electric CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): X UNLIMITED CASE LIMITED CASE HG21110630 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: January 21, 2022 Time: 2:00 p.m Dept.: 514 Div.: Room: Address of court (if different from the address above): X Notice of Intent to Appear by Telephone, by (name): Louis R. Barella INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. X This statement is submitted by party (name): McMillan Electric 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): 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): (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 the date by which they may be served): 4. Description of case a. Type of case in X complaint cross-complaint (Describe, including causes of action): Negligence 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. September 1, 2021] www.courts.ca.gov 21-2461 XL CM-110 PLAINTIFF/PETITIONER: XL Insurance CASE NUMBER: HG21110630 DEFENDANT/RESPONDENT: Manuel Iniguez Palacios, McMillan Electric 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.) Plaintiff is seeking reimbursement for workers compensation benefits paid on behalf of its insured's employee. Defendant disputes liability and the claimed damages. (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 X a jury trial 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. X 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): The underlying workers compensation case has not resolved. Discovery is continuing. Mr. Palacios has not appeared as well c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): See attached list. 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. X 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 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 of the California Rules of Court for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel X 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 of 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. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5 21-2461 XL CM-110 PLAINTIFF/PETITIONER: XL Insurance CASE NUMBER: HG21110630 DEFENDANT/RESPONDENT: Manuel Iniguez Palacios, McMillan Electric 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): X Mediation session not yet scheduled (1) Mediation X Mediation session scheduled for (date): Agreed to complete mediation by (date): Mediation completed on (date): X Settlement conference not yet scheduled (2) Settlement X Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled (3) Neutral evaluation Neutral evaluation scheduled for (date): 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 (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5 21-2461 XL CM-110 PLAINTIFF/PETITIONER: XL Insurance CASE NUMBER: HG21110630 DEFENDANT/RESPONDENT: Manuel Iniguez Palacios, McMillan Electric 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 will 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 X The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Motions in Limine 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 Defendant Written Discovery July 2022 Defendant Subpoena Records Ongoing Defendant Depositions of parties and witnesses September 2022 Defendant Expert Discovery tbd c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5 21-2461 XL CM-110 PLAINTIFF/PETITIONER: XL Insurance CASE NUMBER: HG21110630 DEFENDANT/RESPONDENT: Manuel Iniguez Palacios, McMillan Electric 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 X The party or parties request that the following additional matters be considered or determined at the case management conference (specify): Defendant is in the process of locating Mr. Palacios to confirm if he was served with the complaint. 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: January 7, 2022 Louis R. Barella (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. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5 21-2461 XL Unavailable Dates per Paragraph 6.c. to Case Management Conference Statement Allison Lawrence Trial Case Associate Venue 1/24/2022 Spicer v. W.A Rasic San Bernardino 1/26/2022 Kloythanomsup v. Borg JKS San Francisco 2/8/2022 Ruiz v. Casey LRB Stanislaus 3/14/2022 Corgiat v. Petco JKS Fresno 3/24/2023 Papion v. Little TRS Alameda 3/28/2022 Zand v. Mendoza JKS Santa Clara 3/28/2022 Jolley v. The Whiting Turner Contracting CLC Alameda Co. 4/1/2022 Hairston v. Ameron Pole Products, LLC JKS Alameda 4/18/2022 Adams v. SJWC AKW/JKS Santa Clara 6/16/2023 Burnett v. BMW/CBC Clearbrook (Beck LRB Alameda v. Burnett) 6/20/2022 Rodriguez v. Jasper Hall San Francisco 7/11/2022 Blackwell v. Tesla JKS Alameda 8/1/2022 Jobe v. Conco LRB Alameda 8/22/2022 Oregon Mutual v. Whistler TRS Alameda 8/8/2022 Lenz v. Petco Monterey 11/14/2022 Stephens v. Breves CLC Alameda 1/7/2022 XL Insurance v. Palacios, et al. Alameda Superior Court Case No.: HG21110630 1 PROOF OF SERVICE 2 I declare that: 3 I am a citizen of the United States, employed in the County of Marin, California, over the 4 age of eighteen years, and not a party to the within cause. My business address is 371 Bel Marin 5 Keys Boulevard, Suite 100, Novato, CA 94949. I served the within: 6 CASE MANAGEMENT STATEMENT 7 8 _XX_ BY ELECTRONIC TRANSMISSION: My email address is 9 ljohnson@tysonmendes.com. I electronically transmitted via email the above listed document(s) to the email address(es) set forth below on this date. 10 11 PARTIES SERVED: Plaintiffs Katherine A. Sandoval 12 MATTHIESEN, WICKERT & LEHRER, S.C. 13 1851 E. First Street, Suite 1150 Santa Ana, CA 92705 14 800-637-9176 262-673-3766 15 ksandoval@mwl-law.com cc: Paola Rodriguez 16 prodriguez@mwl-law.com 17 18 19 I certify and declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed on January 7, 2022, at Novato, California. 20 21 _________________________________ 22 Laurel Johnson 23 24 25 26 27 28