DeclarationCal. Super. - 6th Dist.April 11, 201710 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EDWARD FONTAINE 863 GHARKEY STREET SANTA CRUZ, CA 95060 TELEPHONE: (669) 232-4902 PLAINTIFF IN PROPRIA PERSONNA I i F 'I L E SEP 12.2017 ALEX CALVO. CLERK BY MARTHA BOTERO D :2 TY. NT cum SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CRUZ EDWARD F ONTAINE, dba HP/CMD PROJECT, Plaintiff, V. JEFF STEVISON, MATT GERIG, JAMIL CAHUAS-SALAZAR, CALIFORNIA MARIJUANA DELIVERY, aka CMD (busmess entity unknown) and DOES 1 to 10, inclusive, Defendants, I, EDWARD FONTAJNE, declare as follows. 1. I am the plaintiff in the above entitled action. . 2. On July 10, 2017, I filed a Request for Dismissal Without Prejudice in this case. 3. I also filed a Request for Dismissal Without Prejudice in a companion case Superior Court Case Number 17CV00715. COMPLAINT FOR DAMAGES ’ ’ DECLARATION OF CASE No.: 17CV00985 EDWARD FONTAINE IN OPPOSITION TO DEFENDANTS’ MOTION FOR ATTORNEY’S FEES COSTS PURSUANT TO CCP Section 425.16; - . MEMORANDUM OF POINTS AND AUTHORITIES , Date: Se tember 20, 2017 Time: 8: 0 am. Dept: 4 4. I thereafter retained the Law Ofice of Reid P. Schantz, who drafted a new complaint naming the same party defendants with the same operative facts that Was filed on I August 11, 2017. Superior Court Case Number 17CV02144. A copy of the Summons and Complaint are attached hereto as Exhibit A. 5. The reason that I determined to dismiss my two cases against these defendants were that I Was representing myself and both Complaints were p00r1y drafted from a legal I perspective. I could not afford to retain an attorney at the time I prepared them, however, ,9 notwithstanding the drafting issues, the facts contained therein are accurate and my claims 10 ll .12 l3 14 15' 16 i7 18' 19 2o 21 22 23 2'4 25 126 27 28 against these defendants are completely meritorious. Thereby the new Summons and Complaint prepared by my attorney. 6. In reviewing the declaration of Jeff Stevison in support of special anti-slapp motion to strike attached to the special anti-slapp motion to strike I offer the follbwing comments: i a. Paragraph 3. Mr. Stevison responded to an ad that I placed pertaining to Proposition 215/420 property for rent and possible business opportunity. . Mr Cahaus-Salazar . and myself had been exploring partnerships to operate the Corralitos property'available to us with the potential to expand to another County property also under our control... - i b. Paragraph 8. Contrary to Mr Stevisons claim, the Santa Cruz property was not operational having partially dismantled at the end of 2015 for the purpose to be consolidated into the Corralitos property. I possessed the Corralitos property, infrastructure and systems to produce medical cannabis Ihave been a pioneer in the medical cannabis industry in California since'2007 when my health issues prompted me to explore alternatives to the anti seizure medications that I was being prescribed. Per Santa Cruz County Ordinance we ran 99 plants outdOOr in Corralitos and an indoor operation under my card and a member of our collective. c. Paragraph 10. Late September, Mr. Stevison in an e-mail to myself conveyed that CMD (California Marijuana Delivery) had partnered with a delivery service and needed product. With regard to my operations being 100 percent legal, the City of Santa Cruz has a hands off policy as to medical cannabis so long as you have your doctors recommendations. . H d. Paragraph 11. This is confirmed, howeverI shut down my operations as of December, 2015. e. Paragraph 12. The October agreement was a merger agreement between California Marijuana Delivery (CMD) and HighPure Manufacturing Company, Inc A copy of this agreement is attached hereto as Exhibit B.. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26' 27 28 f. Paragraphs 13 and 14. Mr. Stevison was fully aware of my identity in September before we entered into the merger agreement. I used the name Skip Ballesteri in the Craigslist ad so as not to disclose my locations to random people on the intemet. . g. Paragraph 16. Iran a very detailed, data driven operation based on my extensive manufacturing experience with eight years of documentation. Messers Stevison and Gerig had the opportuntty to fund the Corralitos project but decided to go with the fast and least expensive route to make the Santa Cruz location operational even with the risks that the Santa Cruz location was shut down with no production since December, 2015. Contrary to Mr. Stevisons claims, the Santa Cruz location was not growing or operational until CMD paid to get it up and running. ‘ h. Paragraph 17. I gave to Messrs Stevison and Gerig a solid business proposal and supporting documentation. CMD chose to go the fastest and cheapest approach with the Santa Cruz property with the understanding that we would transition to the Corralitos property as soon as possible. i ' i. Paragraph 18. Iprovided Messrs Stevison and Gerig with a solid business plan, historical data with excellent performance results. i j. Paragraph 19. The merger agreement was implemented in October, 2017. CMD was to cover all expenses for 120 days commencing October 10, 2016, with a $10,000.00 buy-in, together with a stock swap. _ k. Paragraph 20. The terms agreed to are set forth in the Merger Agreement, a copy of which rs attached hereto as Exhibit B. 1. Paragraph 21. The terms agreed to are set forth in the Merger Agreement set forth in Exhibit B. m. Paragraph 22. This allegation by Mr. Stevison is completely false. All expenditures were fully documented discussed and reviewed between myself and Messers Stevison and Gerig. Attached hereto as Exhibit C are the Income and Expense records for the months of October, November, and December 2016. n. Paragraph 23. While the payments by CMD initially included labor costs, 10 ll 12 l3 14 15 l6 l7 l8 19 20 21 22 23 24 25 26 27 28 CMD Was not paying the labor costs of Mr. Cahuas-Salazar in a timely manner. 0. Paragraph 24. This assertion by Mr. Stevison is not accurate. CMD began to pay Mr. Cahuas-Salazar directly in cash. ' p. Paragraph 26. In January, 2017 CMD paid $5,000.00 leaving numerous unpaid bills including PG&E. q. Paragraph 27. This statement by Mr. Stevison is untrue. The merger agreement provided that CMD would pay all costs for 120 days from October 10, 2016. The 120 days did not end until February 7, 2017. It was never agreed that a harvest in January would cover the remaining costs. I. Paragraph 28. This statement by Mr Stevison is untrue. On January 6, 2017, Messers Stevison and Gerig broke into my residence without my permission with the apparent intent to steal the cannabis product. In doing so they set off the burglar alarm and apparently slammed an open door on my dog’s leg causing it to be fractured. Mr. Stevison is fully aware that this is the reason our relationship was being terminated. 5. Paragraph 29. Discussions regarding reimbursement to CMD terminated when I discovered that due to the negligence of Mr. Cahus-Salazar and CMD it turned out that the cannabis product was contaminated with powdery mildew and mites. As a result the produce was unfit for medical consumption. t. Paragraphs 30 and 32. Ihave no problem with Mr. Stevison discussing my case against them with anyone. However, when Mr. Stevison on numerous occasions made allegations that I had stolen equipment or had stolen money from CMD which is completely false, Mr. Stevison has damaged my reputation, and this is not protected speech. I, Edward Fontaine declare under penalty under the laws of California that the foregoing is true and correct, except as to those matters stated on information and belief, and as to those matters I believe it to be true. Executed this 10th day of September, 2017, at Santa Cruz, California. Feta/Mat QB”; 71W- EDWARD FONTAINE 10 ll 12 l3 14 15 l6 l7 18 19 20 2 l" 22 23 24 25 26 27 28 POJNTS AND AUTHORITIES I did not dismiss my cases because they lacked merit or for any other reason other than both cases were poorly drafted from a legal prospective and I could not afford to retain the services of an attorney at thegytime. I have since retained the services of an attorney and refiled my case against the same defendants under the same operative facts. My case against defendants is completely meritorious as defendants have greviously breached their contract with me causing me personal and financial damages. The details of my claim against defendants are set forth in my Complaint for Damages attached hereto as as Exhibit A. Civil Code 45 defines libel as a false and unprivileged publication by writing, printing, picture, effigy, or other fixed representation to the eye, which exposes any person to hatred, contempt, ridicule, or obloquy, or which causes him to be shunned or avoided, or which has a tendency to injure him in his occupation. My Fifth Cause of Action, Libel Against Defendant Stevison alleges that Mr. Stevison in multiple text messages states that I had stolen $6,000.00 worth of our equipment. That I had stolen and was selling product that Stevison had paid for. That I had just taken their money. That I had stolen their money. That I was involved in an illegal operation 'and had stolen money from them. That I was lying through my teeth and was a fraud. These statements are completely untrue and under the circumstances are not protected speech. I have copies of these text messages and will produce them at trial. Code of Civil Procedure section 425.16(a) The Legislature finds and declares that there has been a disturbing increase in lawsuits brought primarily to chill the valid exercise of the constitutional rights of freedom of speech and petition for the redress of grievances. The Legislature finds and declares that it is the public interest to encourage continued participation in matters of public significance, and that this participation should not be chilled through abuse of the judicial process. Clearly libelous statements are not, and cannot be, a valid exercise of the constitutional rights of freedom of speech. The court in Coltrain v. Shewalter (1998) 66 Cal.App.4th 94 at 107 concludes: where 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 the plaintiff voluntarily dismisses an alleged SLAPP suit while a special motion to strike is pending, the trial court has the discretion to determine whether the defendant is the prevailing party for purposes of attomey’s fees under Code of Civil Procedure section 425.16, subdivision (c). In making that determination, the critical issue is which party realized its objectives in the litigation. Since the defendant’s goal is to make the plaintiff go away with its tail between its legs, ordinarily the prevailing party will be the defendant. The plaintiff, however, may try to show it actually dismissed because it had substantially achieved its goals through settlement or other means, because the defendant was insolvent, or for other reasons unrelated to the probability of success of the merits. The dismissal Without prejudice of my two cases against defendants were dismissed for reasons completely unrelated to the probability of success on the merits. Indeed, I have retained the services of an attorney and fully intend to proceed and prosecute my case against these defendants as they have caused me both personal and financial harm. For that reason I do not believe the court can make the finding that by dismissing my case that defendants were in any way a prevailing party. Defendants request for their attorney fees in this case should accordingly be denied. Redspecfully submitted, gum/.4 2mm Edward Fontaine SUMu’lOO 8 U ill? 51i N 3 FOR COURT use ONLY ‘ j (CITA CION Jul-prick“ L) Fl LED(SOLO PARA USO DE LA CORTE) 1 E NOTICE TO DEFENDANT: 8/11/2017 11:44 AM l (Air/soft; DEMAND/too .- I lH" .S l EVISON. :\/l.4\fl‘)l‘(31$Rl('i..lAMll ,(I-‘rlll'.:‘iS-S.-\l...\/..A\R. Alex Calvo, Clerk 1 1 C.L\I.JIFORNIA IyI/tIQIIUAnzt DELIVIIRI' :ikn (I.\-’lD(hiisrncss entity 383" mama BOtem unknown), DOES l to it), inclusive it? y’ ' ma Cruz . v‘ ' YOU ARE BEING SUED EiY PLAlNTlFF: // (/50e L0 ESTA DEMANDANDO EL DEMAND/fin! TE : ;;l:)\v\r".é\RD.EONTAINE. 111011131?l .\I'l;\3\')l ’I-fi\(?’l‘l_}Rl.-\i(j3 (.ft.).\rll’AXY. NC. a Calllornia corporation .i‘ NOTICE! You have been sued. The court may decide against you without your being heard unlv below. You have 30 CALENDAR DAYS after this summons and legal papers are served on you to tr e a written response at this court and have a copy served on the plaintiff. A letter or phone call will not protect you. Your wrrtten response must be in proper legal form if you want the court to hear your case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts Online Self-Help Center (www.courtinfo.ca.gov/'selflrelp), your county law library. or the courthouse nearest you. If you cannot pay the filing fee. ask 1 the court clerk for a fee waiver form. If you do not file your response on time. you may lose the case by default, and your wages, money, and property ' may be taken without further warning from the court. ' There are other legal requirements. You may want to call an attorney right away. if you do not know an attorney, you may want to call an attorney referral service. lf you cannot afford an attorney, you may be eligible for free legal sorvrces irorr a nonprofit legal services program. You can locate these nonprofit groups at the California Legal Sorvrces Web srte- (wwrv.lawhelpcalifornra.org), the California Courts Online Self-Help Center 1 (www.courtlnfo.cagov/se/lhelp), or by contacting your local court or county bar association. NOTE: The court has a statutory lien for waived fees and 1 costs on any settlement or arbitration award of $10,000 or rho-e in a civrl case. The court‘s lien must be paid before the court will dismiss the case. 'i [A VISO! La han demandado. Si no responde dentro de 30 dies. la corte puede decrdrr en su contra srn escuchar su version. Lea Ia informacion a i continuacion. Tiene 30 DIAS DE CALENDAR/O después de qua le entregiuen esr'a Circe/on y papa/es legs/es para presenter una respuesta por escrii‘o en ester , con‘e y hacer que se entregue una cop/a a! demands/rte. Una crzrra a any I/amada relefénlca no lo protege n. Su respuesta por escrlto tiene que esrar en formafo legal correclo si desea que procesen su case en la corre. Es posible que haya un fo'mu/an'o que usted pueda user para su respueste. ' Puede enconrrar estos formulririos de la corte y ma's lnformacfon en es] Centre de A yuda do [as Cortes de California (www.5ucorte.ca.gov), en la biblioteca de leyes de su condado 0 en la cone que le quede ma‘s cerca. Si no puede pagarlp c'uor‘a de presentaclén, plda al secretario de la corre > que la de' un formulario de exencion de page do cuoras. Si no prose/Ila su respuesn; a tie-mp0, puerde penier el caso por incumpllmiento y la corle le 3 podra' quilar su sueldo, dinero y bienes sin mas adverts/1cm. Hay otros requisites legales. Es recomendable que llama a rm abogado firmed/ammonia. Si no conoce a un abogado, puede llamara un servicio de 2 remisién a abogedos. Si no puede pager a un abogado. es pomp/e que crimp/a con los requisites pars obtener servicias legs/es gretuitos de un programa de servicios legales sm fines de Iucro. Puede enuanrrsr esros grupos sm fines de lucro en el sitio web de California Legal Services, (vmawhelpcaliforniaorg), en el Centre de Ayuda de las Cortes de California. (wmvsucortecagav) o panic-"dose en contacro con la cone 0 e/ colegio de abogados locales. A VISO: Por ley, is corte liene derecho er reclamar Ias cuofas y los castes exentos par importer un gravamen sobre cualquier recuperacion de 5:10.000 0' ma's de valor recibida media/rte un ocuerdo o una concesién de aror'traje en un caso cle derecho civil. Tiene que pager el gravamen de la cone antes de que la corre pueda desecnar el caso ass you respond within 30 days. Read the information l l i 2 l r Th d d ftl e rt" : ~ ‘ ‘ ‘ . ssE NUMBER (infinite? (1750652?c ,8‘ 0:2: 9’; SUPERIOR COURT or CALIFORNIA Nuclease/17CV02144 COUNTY 01: SA N'l‘A CRUZ, 701 Ocean Street. Santa ( 1117., (3.1 95060 1 The name. address, and telephone number of plaintiff's attorney, or plaintiff Without an attorney, is: (El nombre. la direccron y el nzimero de_ telélono del abogado de/ demands/rte. 0g} dementia/Ire que no tie/re abo ado, es); Reid P. Schantz, Esq.. .l33 Mrssron Street. Suite 230. Santa (.ruz. Lit 93060, Telephone: (8314 3-1986 .M" __._.a “3/7 5,; ’ . “ .. _ , .. a r .r /"‘ , epu‘ry $2355) 8/11/2017 ALEX‘J‘LVO “em /// ~11” )7 15 Adj-unto) {Secretarro} .fl- 7' (For proof of service of this summons, use Proof of Servme of Summons (form PCS-010).) H (Para prueba a’e enfrege de esta citation use 9/ formula/733 Proof of Servrce of Summers. (POMgflha Botero NOTICE TO THE PERSON SERVED: You are served 1. ._. l as an indiViclual defendant. . 2. r“ ] as the person sued under the fictitious name of (specrfy): 3_ l .3 on behalf of (spec/{w under: ~3 OF 416.10 (corporation) :3 GOP 416.60 (minor) l ____J CCP 416.20 (defunct corporation) . CCP 416.70 (conservatee) ’_ CCP 4116,40 (association or partnership) L J CCP 416.90 (authorized person) FA... r__J other .speclfy). ‘ 4. by personal delivery on (date) Page 1 of1 ‘ " ~-- Cone of CM! Procedure §§ 412 20. as", . rorm Adopted for Mandalay Use SU M M0 N5 . . . . .. Judrcral Council of California wr/t/.coartlnlo.r.a gov SUM-100 [Rev July 1. 2009] {Kn/i117” Pr. REID P. SCHANTZ, ESQ, SBN 112048. F'LED . 133 MISSION STREET, SUITE 2/118“??? 11C.l44kAM SANTA CRUZ, CA 95060 _ _xM a vo, er TELEPHONE: (831.) 425-1986 RM artha Botero .' ty Santa Cruz Co n3 :1 ATTORNEY FOR PLAINTIFF; lEID‘Il/AKD FONTAINE , / ' $6,n SU PERIOR COURT OF CALIFOKI‘QIA COUNTY OF SANTA CRUZ EDWARD FONTAlNE. HIGHPURE MANU FACTURIN G COMPANY, INC. a California corporation, CASE No.2 170V02144 Plaintiff, COMPLAINT FOR DAMAGES v. (Breach of Contract) 1 _ (Promise Made Without Intention JEEP STEVISON‘ to Perform) MATT GERIG, . (Misappropriaiion of Trade Secrets) JAMIL CAHUAS~SALAZAR, (Negligence) ' ' CALIFORNIA. MARIJUANA DELl‘JERY (Libel) aka CMD (busmess entity unknown) and DOES l to 10, inclusive, DEMAND FOR JURY TRIAL Defendants, Plaintiff, Edward F ontaine... individually and on behalf of Highpure Manufacturing; Company, lnc., alleges as follows: 1. Plaintiff, Edward. Fonraine, is an individual residing; in Santa. Cruz County, State of California, and is the sole shareholder ofthe stock oiTHiglrprn'e Manufacturing Company, Inc. (Hereinafter referred to as “Forrtaine”) 2. Plaintiff, Highpure Manufacturing Company, 1110., is, and at all times herein mentioned was, a corporation organized and existing under the laws of California, with its principal place of business in Santa Cruz County, State of California. (Hereinafter referred to as “Highpure”) 3. Defendant. Jeff Stevisori is an individual residing in the County of Santa Cruz. State of California. (Hereinafter referred to as “Stevison”) Defendant Stevison holds an unknown business interest in California Marijuana. Delivery aka CMD. 4. Defendant Matt. Geri g is an individual residing in the County of Santa Cruz, State .i l 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 of California. (Hereinafter referred to as “Gerig”) Defendant Gerig holds an unknown business interest in California Marijuana Delivery, aka CMD. 5. Defendant Jamil Cahuas-Salazar is an individual residing in the County of Santa Cruz, State of California. (Hereinafter referred to as “Cahuas-Salazar”) I 6. Defendant California Marijuana Delivery aka CMD is a business entity unknown with its principal place of business in the County of Santa Criz, State of California. 7. Plaintiff are ignorant of the true names and capacities of defendants sued herein as DOES l to 10, inclusive, and therefore sues these defendants by these fictitious names. Plaintiffs will amend this complaint to allege their true names and capacities when ascertained. Plaintiffs are informed and believe and thereon allege that each of the fictitiously named defendants are responsible in some manner for the occurrences herein alleged, and that plaintiffs’ damages as herein alleged were proximately caused by those defendants. 8. Plaintiffs are informed and believes and thereon alleges that at all times material to this complaint, defendants Stevison, Gerig, and Cahuas-Salazar, and each of the defendants fictitiously named in this complaint, in addition to acting for himself, or itself, and on his own behalf individually, is and was acting as the agent, servant, employee and representative of, and with the knowledge, consent, and permission of, and in conspiracy with, each and all of the defendants and within the course, scope and authority of that agency, service, employment, representation, and conspiracy. Plaintiffs further allege on information and belief that the acts of each of the defendants were fully ratified by each and all of the defendants. Specifically, and without limitations, plaintiffs allege on information and belief that the actions, failures 1:0 act, breaches, conspiracy, and misrepresentations alleged herein and attributed to one or more of the specific defendants were approved, ratified, and done with the cooperation and knowledge of each and all of the defendants. STATENIENT OF FACTS 9. Plaintiffs hereby incorporate paragraphs 1 through 8, inclusive, as set forth herein in full. l .l 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 . 10. In October, 2016, plaintiffs Fontaine and Highpure and defendants Stevison and Gerig-dba CMD mutually agreed to merge and form the entity HP/CMD project. » 11. For $10,000.00 cash, expenses covered for 120 days upon commencement through ramp up to full production and 33% stock in CMD, defendants Stevison and Gerig would receive a 40% interest in the HP/CMD entity. 12. 'A Merger Agreement was drafted, orally agreed to and confirmed although not executed. A copy is attached hereto as Exhibit A, and made a part hereof. 13. The project started off in good standing, however defendants Stevison and Gerig began to materially interfere in the operation of the enterpiise. 14. First, three weeks into the enterprise, defendants Stevison and Gerig dba CMD started paying PIP/CMD ’s contract labor defendant Cahuas-Salazar directly in cash, violating California Employment Laws, thus making him an employee of CMD creating related tax issues which also was the beginning of a conflict of interest between plaintiffs and defendants Stevison and Gerig, dba CMD. Defendant Cahuas-Salazar was paid $6,755.00 over a period starting October 10, 2016, through January 3, 2017. 15. Defendants Stevison and Gerig, dba CMD, thereafter requested that the licensed contractor that was tasked with the transition of the facility to full production be terminated and defendant Cahuas-Salazar take his place. 1 16. At this point it was becoming increasingly clear that defendant Cahuas-Salazar was not working for the best interests of HP/CMD but instead for defendants Stevison and Gerig, dba CMD. I 17 . In November defendants Stevison and Gerig, dba CMD, brought contaminated product into the HP/CMS operation, defendant Cahuas--Salazar did not follow proper protocol resulting in significant sections of the operation to become contaminated rendering the product not safe for human consumption. 18. As per the Merger Agreement the operation would be commenced in Santa Cruz and then transitioned to another facility located in Corralitos, California which could handle large volume production. Defendants Stevison and Gerig, dba CMD began purchasing 10 ll 12 l3 14 15 l6 l7 l8 19 2O 21 22 23 24 25 26 2% 28 equipment to be assembled for Corralitos. 19. In November, 2016 the HP/CMD project was invoiced $8,130.92 for equipment by defendant Gerig, some of which was never delivered to the HIP/CMD project and placed in storage at defendant Gerig’s residence. 20. On December 1, 2016, a three year lease for the Corralitos property was signed by plaintiff Fontaine on behalf of HP/CMD, and the first month’s rent in the amount of _ $2,800.00 and deposit in the amount of $5,600.00 was paid at the direction of defendant Gerig. , 21. Defendants Stevison and Gerig, dba CMD began to not pay invoices for time and materials as agreed in a timely manner. At the end of December, 2016 defendants Stevison and Gerig, dba C1Vfl) was in arrears $8,000.00. 22. In December, 2016, defendants Stevison and Gerig, dba CMD declared that they were no longer willing to proceed with the Corralitos operation in breach of the Merger Agreement. 23. In December, 2016, defendant Cahuas-Salazar negligently crashed the Santa Cruz operation electrical system causing damage to the electrical system infrastructure. This resulted in contaminated product not marketable for medical use. 24. On January 3, 2017 plaintiff Fontaine sought to turn over management of the operation to a previous contractor. This was met with resistance by defendants Stevison and Gerig, dba CMD and defendant Cahuas-Salazar refused to accept the proposal and terminated his relationship with HP/CMD. 25. In January, 2017, defendants Stevison and Gerig, dba CMD refused to pay the 7% sales tax mandated by the County of Santa Cruz. In addition there were conflicts regarding defendant Cahuas-Salazar’s relationship with defendants Stevison and Gerig, dba CMD, the damage to the Santa Cruz facility caused by defendant Cahuas-Salazar’s negligence and now quality issues with the product. 26. Defendants Stevison and Gerig, dba CMD decided to take tainted product to market. Plaintiff Fontaine did not agree as the product was unsafe for human consumption. 1o 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 27. On or about January 6, 2017, defendants Stevison and Gerig, dba CMD secretly and without the knowledge or consent of plaintiff Fontaine enlisted defendant Cahuas- Salazar to access plaintiff Fontaine’s residence, the location of the Santa Cruz operation. Plaintiff discovered that defendants Stevison, Gerig, and Cahuas-Salazar were in his residence when Stevison telephoned Plaintiff asking how to turn off the alarm system. Thereafter Plaintiff advised defendant Stevison to leave the premises immediately or Plaintiff would call the police. 28. Upon returning to his residence later that evening, Plaintiff found his front door ajar and found that one of his dogs had a broken front leg requiring veterinary hospitalization. A 29. As a result of the conduct of defendants, and each of them, Plaintiff terminated their relationship. 30. On or about January 23, 2017, Plaintiff discovered from Melidye Serino with the County of Santa Cruz that on December 7, 2016, defendants Stevison and Gerig, without the knowledge or consent of Plaintiff, changed the contact information on the business license applications that the Plaintiff had submitted on behalf of his business and the HP/CMD merger. Plaintiff is informed and belirves and thereon alleges that defendants Stevison and Gerig changed the contact information. in an effort to convert the license applications to their own use to the exclusion of Plaintiff. 31. Per the HP/CMD agreement, defendants Stevison, Gerig, and CMD were to pay all costs and expenses incurred from the commencement of the project beginning October 10, 2016 through 120 days. As of February 7, 2017, defendants Stevison, Gerig, and CMD owed the sum of $42,763.58 to the HP/CMD project to include, but not limited to, rents, materials, labor and accounting costs. 32. In addition, due to the negligence of defendant Cahaus-Salazar and CMD, and l each of them, in damaging the product in production, Plaintiff has suffered losses estimated l to be $39,255.66 in damaged product and $69,808.39 in lost revenue. 33. Plaintiff is informed and believes, and thereon alleges that defendants Stevison, i 1 _:_‘\_HA 10 ll 12 l3 14 15 l6 17 18 19 20 21 22 23 24 25 -26 27 28 Gerig, CMD, and Cahuas-Salazar conspired together to sabotage the PIP/CMD merger project, wrongfully appropriating Plaintiff s proprietary information and technology to their own use. FIRST CAUSE OF ACTION (Breach of Oral Contract as to defendants Stevison, Gerig, and CMD) 34. Plaintiffs hereby incorporate Paragraphs 1 through 33, inclusive, as set forth herein in full. 35. On or about November 3, 2016, plaintiffs F ontaine and HighPure Manufacturing, Inc., entered into an oral merger agreement, the terms of which are set forth in the written Merger Agreement attached hereto as Exhibit A, and made a part hereof. 36. Pursuant to this agreement defendants Stevison, Gerig, and CMD agreed to pay $10,000.00 plus all expenses incurred while the operation is ramped back to full production over 120 days commencing October 10, 2016. As of February 7, 2017, defendants Stevison, Gerig and CMD, and each of them, owed $42,763.58 to the project. 37. In breach of the agreement defendants Stevison, Gerig and CMD refuse, and continue to refuse to pay said sum. 38. Accordingly plaintiff Fontine and HiphPure Manufacturing, Inc., has been damaged in an amount according to proof at trial. WHEREFORE, Plaintiffs pray for judgment against defendants Stevison, Gerig, and CMD, and each of them as set forth below. SECOND CAUSE OF ACTION {false Made Without Intention to Perform as to defendants Stevison, Gerig, and 39. Plaintiffs hereby incorporate Paragraphs 1 through 38, inclusive, as set forth herein in full. 40. On or about November 3, 2016, defendants Stevison, Gerig, and CMD entered into an oral agreement with Plaintiffs pursuant to the terms in the written agreement attached hereto as Exhibit A, and made a part hereof. 41. At the time Defendants, and each of them, made these promises to Plaintiff, 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Defendants had no intention of performing them. 42. The promises were made by Defendants with the intent to induce Plaintiffs to pursue the project contemplated by the oral agreement and to induce Plaintiff to reveal proprietary information and technology to Defendants for their own use. 43. Plaintiffs, at the time the promises were made and at the time Plaintiffs took the actions as herein alleged, was ignorant of Defendants’ secret intention not to perform, and Plaintiffs could not, in the exercise of reasonable diligence, have discovered Defendants’ secret intention. In reliance on the promises of Defendants, Plaintiff proceeded to honor the terms of the oral agreement. plaintiff had known of the actual intention of Defendants, Plaintiffs would not have taken such action. 44. Defendants failed to abide by their promises breaching the oral agreement by refusing to further fund the project in the amount of $42,763.58, converted proprietary information and technology to their own use, and attempted to convert the HG/CMD license applications with the County of Santa Cruz to their own use. 45. As a proximate result of Defendants’ fraud and deceit and the facts herein alleged, Plaintifi's were induced to devote hundreds of hours of time and energy to further the project, and has received no profit or other compensation for the time and energy expended, by reason of which Plaintiffs have been damaged in an amount according to proof at trial. ' 46. In doing the acts herein alleged, Defendants, and each of them, acted with oppression, fraud, and malice, and Plaintiffs are entitled to punitive damages in an amount according to proof at trial. WHEREFORE Plaintiffs pray for judgment against defendaNTS Stevison, Gerig, and - CMD, and each of them as set forth below. ' THIRD C AUSE OF ACTION (MisaREDo priation of Trade Secrets and Technology as to defendants Stevison, Gerig, and C 47. Plaintiffs hereby incorporate Paragraphs 1 through 46, inclusive, as set forth herein in full. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 48. Plaintiffs were in possession of trade secrets consisting of formulations, reclamation processes, feeding schedules, and field notes developed over years. 49. Plaintiffs’ trade secrets had economic value in that the information was unique and not otherwise available. Plaintiffs made reasonable efforts to insure that the trade secrets remained a secret by keeping the information in Plaintiff” 5 personal possession. 50.. On or about November, 2016, or thereafter, and continuing to the present time, defendants Stevison, Gerig, and CMD, and each of them, misappropriated the above- . described trade secrets by, without the knowledge or consent of Plaintiffs, secretly copying the formulations, reclamation processes, feeding schedules, and field notes. In addition taking photographs of system videos. 51. As a proximate result of the misappropriation of Plaintiffs’ trade secrets, Plaintiffs have suffered actual damages in an amount to be submitted on proof at trial. As a further proximate result of the misappropriation, defendants Stevison, Gerig, and CMD were unjustly enriched which had a value in an amount to be submitted according to proof at trial. 52. The Plaintiffs are informed and believe and thereon alleges that the aforementioned acts of defendants, Stevison, Gerig, and CMD, and each of them, was willful and malicious in that said Defendants secretly misappropriated Plaintiffs’ trade secrets with the deliberate intent to injure Plaintiffs and to improve their own business. Plaintiffs are therefor entitled to punitive dmages in an amount to be submitted according to proof at trial. WHEREFORE Plaintiffs pray for judgment against defendants Stevison, Gerig, and CMD, and each of them, as set forth below. FOURTH CAUSE” OF ACTION (Negligence Against Cahuas-Salazar) 53. Plaintiffs hereby incorporate Paragraph 1 through 52, inclusive, as set forth herein in full. 54. On or about December, 2016, defendant Cahuasu-Salazar was placed in charge of the entire enterprise. On said date defendant Cahuas-Salazar was negligent in his duties in 'i ii 10 ll 12 13 l4 l5 l6 l7 l8 19 20 21 22 23 24 25 26 27 28 that he crashed the electrical system taking no measures to remedy the electrical system. 55 . As a proximate result of the negligence of defendant Cahuas-Salazar the product 1 became contaminated, not marketable for medical use, together with damage to the facilities ‘ infrastructure in an amount to be submitted according to proof at trial. WHEREFORE, Plaintiffs pray for judgment against defendant Cahuas-Salazar as set forth below. FIFTH CAUSE OF ACTION (Libel Against Defendant Stevison) 56. Plaintiffs hereby incorporate Paragraphs 1 through 55, inclusive, as set forth herein in full. . 57. Between February 10, 2017 and April 9, 2017, defendant Stevison published the following statements to clients and business associates of plaintiff Fontaine: a. On February 10 2017, defendant Stevison falsely stated via text to John Ellis that Plaintiff fired defendant Cahuas-Salazar and had taken $6,000.00 worth of “our” equipment; I b. On February 10, 2017, defendant Stevison admitted via text to John Ellis that defendant Stevison had been secretly recording Plaintiff, without Plaintiffs knowledge or approval; c. On February 21, 2017, defendant Stevison stated via text to John Ellis implying that Plaintiff had stolen and was selling product that defendant Stevison had paid for; d. On March 1, 2017, defendant Stevison stated via text to John Ellis implying that plaintiff was liable for criminal or civil actions; e. On March 14, 2017 defendant Stevison stated via text to John Ellis that Plaintiff had just taken their money; f. On Match 22, 2017, defendant Stevison stated via text to John Ellis that Plaintiff had said John Ellis was head of the Irish mafia in California; . g. On March 23, 2017, defendant Stevison stated via text to John Ellis that 10 ll 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff had stolen their money; h. On March 23, 2017,. defendant Stevison stated via text to John Ellis that Plaintiff is a liar, lying to John Ellis and manipulating him; i. On March 23, 2017, defendant Stevison stated via text to John Ellis that Plaintiff had done serious things to them; ‘ j. On March 24, 2017, defendant Stevison stated via text to John Ellis that Plaintiff was involved in an illegal operation, that Plaintiff had stolen money from Defendants, and is manipulating John Ellis into buying into the case; k. On March 25, 2017, defendant Stevison falsely stated via text to John Ellis that Plaintiff’s company HighPure Manufacturing Company was not in compliance; 1. On March 26, 2017, defendant Stevison stated via text to John Ellis that Plaintiff is a character testimony nightmare and that Plaintiff is a drinker running his mouth; m. On March 28, 2017 defendant Stevison stated via text to John Ellis that Mr. Ellis didn’t deserve to have his business affected by Plaintiff s actions; n. On March 30, 2017, defendant Stevison stated via text to John Ellis that Plaintiff was angry because the Defendants weren’t letting Plaintiff finish ripping them off and how Plaintiff could consider himself a man; 0. On March 30, 2017, defendant Stevison stated via text to John Ellis that Plaintiff is fucked; p. On March 30, 2017, defendant Stevison stated via text to John Ellis that Plaintiff was lying through his teeth and that Plaintiff is a fraud; 58. The statements made by defendant Stevison have injured Plaintiff in his occupation as the statements attacked Plaintiffs veracity as a business consultant in Santa Cruz County, as well as Plaintiff s veracity as the owner and manager of several companies in the community. The statements made by defendant Stevison further accuse Plaintiff of committing a crime of theft, accusing; Plaintiff of stealing funds and equipment from the HP/CMD project and created the impression that Plaintiff is willing to steal from Plaintifi‘s’ business associates and clients. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 59. Plaintiff is informed and believes, and therefore alleges that business associates and clients in the Santa Cruz County community and specifically John Ellis and Hippocrates Medical, Inc., understood that the statements were about Plaintiff as the statements were made of, concerning, and referred to Plaintiff specifically. I 60. The statements made by defendant Stevison about Plaintiff are false, and expose Plaintiff to hatred, contempt, ridicule, and obloquy, as Plaintiff did not steal money or equipment from Defendants or the I-IP/CMD project. 61. The statements made by defendant Stevison were made to members in the business community in Santa Cruz. County and Los Angeles County, California. 62. As a proximate result of the above-described statements by defendant Stevison, Plaintiff ha suffered the loss to his reputation, shame, mortification, and hurt feelings, all to his general damages. 63. As a further proximate result of the above-described statements made by defendant Stevison, Plaintiff has suffered the loss of three investors at $126,287.95, $100,000.00, and $10,000.00 respectively and including loss of business, in an amount to be submitted upon proof at trial. 64. The statements made by defendant Stevison were malicious, oppressive, and fraudulent, and thus Plaintiff seeks an award for exemplary and punitive damages in an amount to be submitted upon proof at trial. WHEREFORE Plaintiff prays for judgment against defendant Stevison as set forth below. - AS TO THE FIRST CAUSE OF ACTION FOR BREACH OF CONTRACT , PLAIN TIFFS PRAY FOR IUDGMEN T AGAINST DEFENDAN TS STEVISON, GERIG AND CMD, AND EACH OF THEM AS FOLLOWS: 1. For compensatory damages to be submitted upon proof at rrial; * 2. For costs of suit herein incurred; and 3. For such other and further relief as the court may deem proper. ’ AS TO THE SECOND CAUSE OF ACTION FOR PROMISE MADE WITHOUT INTENTION TO PERFORM, PLAINTIFFS. PRAY FOR JUDGMENT AGAINST DEFENDANTS STEVISON, GERIG, AND CMD, AND EACH OF THEM, AS 1 10 ll 12 l3 14 15 l6 17 18 19 20 21 22 23 24 25 26 27 28 FOLLOWS: 1. For general damages in an amount to be submitted upon proof at trial; 2. For special damages in an amount to be submitted upon proof at trial; 3. 'For punitive damages in an amount to be submitted upon proof at trial; 4. For costs of suit herein incurred; and 5. For such other and further relief as the court may deem proper. AS TO THE THIRD CAUSE OF ACTION FOR MISAPPROPRIATION OF TRADE SECRETS, PLAIN TIF FS PRAY FOR JUDGMENT AGAINST DEFENDAN TS STEVISON, GERIG, AND CMS, AND EACH OF THEM, AS FOLLOWS: 1. For general damages and the amount necessary to prevent the unjust enrichment of defendants in an amount to be submitted upon proof at trial; 2. For punitive damages in an amount to be submitted upon proof at trial; 3. For costs of suit herein incurred; and 4. For such other and further relief as the court may deem proper. AS TO THE FOURTH CAUSE OF ACTION FOR NEGLIGENCE, PLAINTIFFS PRAY FOR JUDGMENT AGAINST DEFENDANT JAMIL CAHUAS-SALAZAR AS FOLLOWS: 1. For general damages in an amount to be submitted upon proof at trial; 2. For damage to personal property in an amount to be submitted upon proof at trial; 3. For loss of earnings in an amount to be submitted upon proof at rrial; 4. For costs of suit herein incurred; and 5 For such other and further relief as the court may deem proper. AS TO THE FIFTH CAUSE OF ACTION FOR LIBEL, PLAIN TIFFS PRAY FOR JUDGMENT AGAIN ST AGAIN SE DEFENDANT STEVISON AS FOLLOWS: 1. For general damages in an amount to be submitted upon proof at trial; 2. For special damages in an amount to be submitted upon proof at trial; 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3. For punitive damages in an amount to be submitted upon proof at trial; 4. For costs of suit herein incurred; and 5. For such other and further relief as the court may deem proper. Dated August 1, 2017 EDW FONTAINE and HIGHPURE MANUFACTURJNG COMPANY, INC. VERIFICATION I, Edward Fontaine, declare: I am the plaintiff, and the officer for HighPure Manufacturing, Inc. ., a corporation organized and existin g under the laws of the State of California, which . is also the plaintiff 1n the above-entitled action, and I have been authorized to make " this verification on its behalf. I have read the foregoing complaint and know the contents thereof. I am informed and believe that the matters stated thereon are true and on that ground I allege that the matters stated therein are true. I declare under penalty of perjury under the laws of the State of California. that the foregoing is true and correct. Executed at Santa Cruz, California. ' gage/m1 %%@¢W EDWARD FONTAINE tixttit’arr ”A MERGER AQREEMEMT THlS MERGER AGREEMENT, between California Marijuana Delivery, aka CMD, and High Pure Manufacturing, preliminarily details the terms and conditions for the merger agreement of the two companies and to jointly manage operations based in Santa Cruz, CA and to facilitate expansion to Corralitos and Little Valley, California, including the delivery business established by CMD. THIS AGREEMENT, details the terms and conditions, that the parties: agree that CMD and High Pure Manufacturing will be jointly responsible for all compliance, management, finance, operations, construction, implementation, production, and distribution at said 3 operations currently under the direction of the Santa Cruz Mountain Collective dba Santa Cruz Remedies located in Santa Cruz, CA, the planned expansion .to Corralitos, and Little Valley, CA., including the delivery service established by CMD. The businesses will merge through a cash buy in, and stock swap of the two organizations. CMD will pay $10K, 10 thousand USD, plus all expenses incurred while the operation is ramped back to full production over 120 days commencing October 10, 2016 and 33% percent of CMD stock for 40% of High Pure Manufacturing stock, its good will and its contract with Santa Cruz ' Mountain Remedies. Valuation of High Pure Manufacturing based upon 2015 financial performance using known bUSiness valuation formulations including sales and EBlTDA calculations indicates a current value of $1.8M USD or $1200 per share of outstanding stock. There is 1500 shares of High Pure Manufacturing stock. CMD will be granted 600 shares of High Pure stock per the terms noted above. All parties agree that upon the mutual agreement, that compensation of parties will be shared per the terms of this agreement for time and materials, reimbursement for all expenses, investments, loans, purchases and travel related expenses in accordance with the terms of this merger agreement and the membership agreement of the Santa Cruz Mountain Collective dba Santa Cruz Mountain Remedies, Santa Cruz, CA. All parties agree that upon the mutual agreement, that any violation of the terms of the merger agreement and collective membership agreement is grounds for immediate termination of this agreement per both agreements . Page 1 of 2_Merger Agreement CMD and High Pure Manufacturing pr .-.r:...... _.. f/AH '3‘“ i If” n Ex H l is VT“ ”A?" i All parties agree to have meetings to review and evaluate the operations on a weekly, monthly}? quarterly, and year end time frame, the financial condition of the operations, including income and expense, profit and loss, current and future operating conditions and expectations. I Compensation to the parties will be made upon the mutual agreement of instrument of both parties in accordance with the merger agreement and collective membership agreement (see 1., Attachment). ' "l Additional terms and conditions may be added through addendums to THIS AGREEMENT, upon the mutual. agreement of both parties. Any legal or arbitration issues will be resolv'ed under the business laws established in the State of California. THIS AGREEMENT, is legal and binding effective this third3rd day of November 2016 ' Executed in Santa Cruz, California ' SignedX _ Date . l Jeff Stevison, CMD .l‘ 1 SignedX Date Matt Gerig, CMD SignedX Date Edward Fontaine, High Pure Manufacturing Signed)( Date Print Name Witness Page 2 of 2_Merger Agreement CMD and High Pure Manufacturing EKb+' {Ir/A“ Page Z 06: ’1...- MERGER AGREEMENT THlS MERGER AGREEMENT, between California Marijuana Delivery, aka CMD, and High Pure 11 l Manufacturing, preliminarily details the terms and conditions for the merger agreement of the two companies and to jointly manage operations based in Santa Cruz, CA and to facilitate expansron to Corraiitos and Little Valley, California, including the delivery business established by CMD. THIS AGREEMENT, details the terms and conditions, that the parties agree that CMD and High Pure Manufacturing will be jointly responsible for all compliance, management, finance, operations, construction, implementation, production, and distribution at said 3 operations currently under the direction of the Santa Cruz Mountain Collective dba Santa Cruz Remedies located in Santa Cruz, CA, the planned expansion to Corralitos, and Little Valley, CA., including the delivery service established by CMD. The businesses will merge through a cash buy in, and stock swap of the two organizations. CMD will pay S10K, 10 thousand USD, plus ali expenses incurred while the operation is ramped back to full production over 120 days commencing October 10, 2016 and 33% percent of CMD stock for 40% of High Pure Manufacturing stock, its good will and its contract with Santa Cruz Mountain Remedies. Valuation of High Pure Manufacturing based upon 2015 financial performance using known business valuation formulations including sales and EBITDA calculations indicates a current value of $1.8M USD or $1200 per share of outstanding stock. There is 1500 shares of High Pure Manufacturing stock. CiVl D will be granted 600 shares of High Pure stock per the terms noted above. All parties agree that upon the mutual agreement, that compensation of parties will be shared per the terms of this agreement for time and materials, reimbursement for all expenses, investments, loans, purchases and travel related expenses in accordance with the terms of this merger agreement and the membership agreement of the Santa Cruz Mountain Collective dba Santa Cruz Mountain Remedies, Santa Cruz, CA. All parties agree that upon the mutual agreement, that any viblation of the terms of the merger agreement and collective membership agreement is grounds for immediate termination of this agreement per both agreements . Page 1 of 2_Merger Agreement CMD and High Pure Manufacturing (EM/Eff Z3 l l l i Ii l ,l ' l in me All parties agree to have meetings: to review and evaluate the operations on a weekly, month quarterly, and year end time frame, the financial condition of the operations, including inco and expense, profit and loss, current and future operating conditions and expectations. Compensation to the parties will be made u parties in accordance with the merger as Attachment). l pon the mutual agreement of instrument of both .l greement and collective membership agreement (see i Additional terms and conditions may be added through addendum: to THIS AGREEMENT, upon ‘ the mutual agreement of both parties. l l Any legal or arbitration issues will be ‘ l l resolved under the business laws established in the State - of California. ' THIS AGREEMENT, is legal and binding effective this third3rd day of November 2016 ‘ Executed in Santa Cruz, California ' SlgnedX l Date i Jeff Stevlson, ClVlD l SignedX Date , l ~ I Matt Gerig, CMD : ' Date ? SignedX .l Edward Fontaine, High Pure Manufacturing El l Signedx [Irate ‘E Print Name VV-ltl'less . ,l Page 2 of 2_Merger Agreement CMD andl-ligh Pure Manufacturing ., i HP_CMD October 2016 Income'Statement for Period Ending October 31, 2016 Code Income 510 511 520 535 TI COGS 631 660 661 670 671 675 678 680 TCOGS OE 701 704 744 747 756 757 760- 761 772 786 800 806 807 808 809 816 825 831 832 845 846 847 Description Sales, Shipments Sales, Non-Taxable, Rec. Sales, Taxable, Rec. Sales Tax Collected, Rec. Sales, Scrap Product, Rec. , Total Income Cost of Goods Sold Purchase Materials Discounts -A/ R & A/P Productive Shop Taxes Payroll/Shop Insurance W/C Shop Contract Labor Packaging Supplies Shipping Expenses Out Total Cost of Goods Sold Gross Income (Loss) Operating Expenses OfficerfSalaries Office Salaries-Wages Accounting ADP Fees Bank Charges Credit Card Charges Computer Supplies ' Commissions Dues and Subscriptions Equipment Gas, Oil, Tires and Travel Insurance, Liability Insurance, Health Insurance, W/C Insurance, Dental Interest Janitorial, Maintenance, Laundry Legal Expenses License and Permits Office Supplies Outside-Services Payroll Service Costs Current Period {.010m $4,600.00 $2,235.00 . $_ 5. $6,835.00 $(6,835.00) .5_ $250.00 Current YTD 54,600.00 .$_ 5. s- $. $2,235.00 I I $6,835.00 I I $(6,835.00) ‘(h- I '(h- V)- ' l l $100.00 5. TOE OP 855 856 863 864 '870 874 880 881 882 900 901 '965 966 Rent Repairs Shop Supplies, General Small Tools, General Taxes-Payroll Telephone, Internet Utilities Waste Disposal Water ‘ Advertising and Promotion Security Total Operating Expense Operating Profit (Loss) Other Income (Expense) Interest Miscellaneous Total Other Income Net Income (Loss) Before Taxes Net Income (Loss) $5,375.83 $429.30 $843.98 56,241.00 s- 5. $107.66 5. $13,360.81 $(20,195.81) $(20,195.81) $(20,195.81) $5,375.83 $429.30 $843.98 $6,241.00 5. 5. $107.66 $- $13,360.81 $(20,195.81) $(20,195.81) $(20,195.81) 10/31/2016 _ lnvoice10311602 Los Gatos Financial Services Los Gatos Financial Services ' 481 N. Santa Cruz Ave. E N V Q E a E Suite 178 Los Gatos, CA 95030 CMD invoice :1: 10311602 Woodrow Ave E santa CWZ' CA 95060 1mmiee Date 10/31/"2016 Due Date 10/31/2016 ii item Description Unit Price Quantity Amo‘iunt Service Contract Labor 10/31/2016 _ 20.00 12.00 240.00 Service Supplies ' 218.80 1.00 21118.80 Service accounting/compliance 50.00 1.00 50.00 i i i ’ i i 53115131012513 508.80 'ii‘utafi 508.80 111111011511 13810 0.00 Efieianee Due $508.80 hfin'l/wwwamax nnm/nri nflmninn. nhn ' 1/1 Mmfi‘h: 024-0669; 2- O '\ é» Date Amouni~ Store t, . W Na K L9 W 9; ‘900 “View OE??- up/cmp a Descri {)k (4%. Max/mm (ML flaw WWW {:éx'écmsJ? [0/2“ /20tL Rwy L}, 3'73 %3. W? W StéS '1, "5'00“D L-flgmfi Ht LS 0‘ 00' UL-LZUWS 2% 90: 00 ‘i [5,. H25. 90 I‘M fiKfiMScVS 2 (w: 4v Mich/«(mg W/CMD (0/23 - (0/30 2‘. -l DUWK (xi 5’ \Qxa Pew-VS l2 2 2. 2!. ((32.20 22-22; 32> ‘ 5” L62 32-- ' 33.3: (@3203 _ I“ \‘ WV 4.. i J N 22700.\ / . Ma 00. 27W“ ’ iZJO 6 cv HWLh 53 2 1‘2 (3%?” ‘. i 1 1 \3 WK MK Wm Lodzwfi fibf'e” mfg . Qofio \e K 12.0 \‘2/0 3?» NW gaggimk W2...” .g-a \va Wflm kw) “Ma/16$; M..- .5 \H w W “W K-c 2M?“ “7 our; 6/3)- W‘fi: 43%! dd 5'm 20@@ 362636} 5’39” CW Mt: Rem [Oiooo 10009 %& ®ZJ%I %57b mmA Mg 3 75 CT ’3 (72% W4” Mmfi‘h: Date AmoumL Store Descri fion D 0 i O 00 \ ‘ W3 {(1 MD R HP__CMD November 2016 Income StatEment for Period Ending November 30, 2016 Code Income 510 511 520 535 Tl COGS. 631 660 661 670 671 675 678 680 TCOGS OE 701 704 744 747 756 757 760 761 772 786 800 806 ‘ 807 808 809 816 825 831 832 845 846 847 Description Current Period Sales, Shipments $- Sales, Non-Taxable, Rec. 5- Sales, Taxable, Rec. 5- Sales Tax Collected, Rec. $- Sales, Scrap Product, Rec. $- Total Income $- Cost of Goods Sold Purchase Materials $2,330.00 Discounts -A/R & A/ P $- Productive Shop $- Taxes Payroll/Shop $- lnsurance W/C Shop $- Contract Labor 7 $6,465.00 Packaging Supplies _ $- Shipping Expenses Out $- Total Cost of Goods Sold . $8,795.00 Gross Income (Loss) $(8,795.00) Operating Expenses Officer Salaries 5- Office Salaries-Wages - . Accounting $1,575.00 ADP Fees ' 5- Bank Charges $- Credit Card Charges $- Computer Supplies $- Commissions $- Dues and Subscriptions $- Equipment $8,130.92 Gas, Oil, Tires and Travel "$58.68 Insurance, Liability 5- lnsurance, Health _ $- lnsurance, W/C . $- lnsurance, Dental 5- lnterest- $- Janitorial, Maintenance, Laundry $- Legal Expenses $- License and Permits $1,614.00 OfficeSupplies $- Outside Services $- Payroll Service Costs $- Current YTD $8,700.00 5- 5. $15,630.00 $(15,630.00) s- 5- $1,825.00 $1,714.00 5- 3- s- TOE OP 855 856 863 864 870 874 880 881 882 900 901 965 966 Rent Repairs Shop Supplies, General Small Tools, General Taxes-Payroll Telephone, Internet Utilities Waste Disposal Water Advertising and Promotion Security Total Operating Expense Operating Profit (Loss) Other Income (Expense) Interest Miscellaneous Total Other Income Net Income (Loss) Before Taxes Net Income (Loss) $4,706.94 $3,022.28 $2,038.04 5- $- 5- $45.01 $- $373.17 $53.89 s- $21,617.93 $80,412.93) $(30,412.93) $(30,412.93) $10,082.77 $3,451.58 $2,882.02 $6,286.01 s- 5. $161.65 5. $34,605.67 $(50,235.67) $(50,235.67) $(50,235.67) 11/30/2016 invoice 11301601 Los Gatos Financial Services Los Gatos Financial Services 481 N. Santa Cruz Ave. Suite 178 Los Gatos, CA 95030 ClVlD l l Woodrow Ave invoice # 1130:1601 Santa ‘3e CA 95060 Invoice Date 11/30/1016 e Date 11/30/1016 l item Description Unit Friar-2 Quantity Amoifiz‘nt Service Contract Labor week 11/28/2016 thru 11/30/2016 20.00 45.00 9001.00 Service Contract Labor Repairs/Sarita Cruz 50.00 12.00 600' 00 Service Equipment 76.11 1.00 76 11 Service Repairs 13.68 1.00 13168 Service Promotions 53.80 1.00 531189 Service License 8L Permits 114.00 1.00 114.100 Service Gas, Oil, Tires, Travel 43.68 1.00 43/438 Service Accounting/Compliance 50.00 6.00 300.310 Subtetei 2, 101.316 'Fo1ai ' 2.101.3e Amemfi; Paid 0.00 .0313: race Due $2,101.36 http://WiMMawaxconflprlntlnvoicephp 1/1 11/28/2016 Invoice 11281601 Los Gatos Financiai Services Los Gatos Financial Services 481 N. Santa Cruz Ave. Suite 178 Los Gatos, CA 95030 CMD Woodrow Ave Santa Cruz, CA 95060 ENVQEfiE Envoice # 112811601 “invoice Date 11/28/2016 Due Date 11/28/2016 item Description Unit Price Quentin! {0130:0311 Service Contract Labor week of11/21/2016 . 20.00 61.50 12320.00 Service Contract Labor Repair/Greenhmise 50.00 22.50 1 1,126.00 Service Supplies , 378.70 1.00 378.70 Service Equipment 122.75 1.00 1212.75 Service Repeirs 59.11 1.00 59.11 Service Accounting/Compliance 50.00 3.00 15?).00 Summai 3,065.56 "iatai 3,065.56 Ameum Paid 0.00 Baienee Due $3,065.56 http://vmmuawaxcom/printlnwicephp 11/20/2016 Invoice 11211601 Los Gatos Financial Services Los Gatos Financial Services 481 N. Santa Cruz Ave. Suite 178 Los Gatos, CA 95030 INIVGICE CMD Invoice # 11211601 Woodrow Ave Santa Cruz, CA 95060 invoice Date 11/20/2016 Due Date 11/20/2016 item Description Unit Price Quantity Amount Service Contract Labor week of 11/14/2016 20.00 94.75 1,895.00 Service Contract Labor Repair/Greenhouse 50.00 17.00 850.00 Service SuppIies 686.34 1.00 686.34 Service Equipment 289.04 1.00 289.04 Service Repairs Greenhouse 408.60 1.00 408.60 Service Storage 331.11 1.00 3311.11- Service Water 246.95 1.00 24.13.95 Service Accounting/Compliance 50.00 6.00 300.00 eubrmai 5,007.04 ”rota? 5,0051704 fiimount ease 0.00 Ezaience Due $5,007.04 http://wmaynaxcom/printlnvoice.php 11/14/2016 Invoice 11141601 Los Gatos Financial Services Los Gatos Financial Services 481 N. Santa Cruz Ave. Suite 178 Los Gatos, CA 95030 IINVQCE CMD Invoice ;'¢ 111141601 Woodrow Ave . santa cmzl CA 95060 1mmice Date 11/14/2016 'i Due Date 11/14/2016 i l l item Description Unit Price Quantity Amiiount Service Contract Labor week of 11/07/2016 20.00 64.00 1,2§|.30.00 Service Supplies 540.30 1.00 5410.30 Service Equipment 29.99 1.00 219.99 Service Accounting/Compliance 50.00 2.50 125.00 Subtote§ 1 925.29 113131 1,915.29 li 151111011111 Paid p.00 1 Baflance Due $1,975.29 http://wwwawaxcoarintlnvoice.php 1/1 11/6/2016 Los Gatos Financial Services 481 N. Santa Cruz Ave. Suite 178 Los Gatos, CA 95030 Invoice 11061601 Los Gatos Financial Sem'cas l WVQHQE CMD Enveice # 11061601 Woodrow Ave . sama cruz' CA 95060 Enveice Date 11/06/2016 Due Date 11/06/2 )16 item Description Unit, Price Quantity Amount Service Contract Labor week of 11/1/2016 ‘ 20.00 58.00 1,160 00 Service Rent A 4375.83 1.00 4,37583 Service Repairs 25.00 1.00 25‘ 00 Service Supplies 432.70 1.00 432 70 Service Equpment 173.99 1.00 173199 Service Utilities 45.01 1.00 45.01 Service Water 126.22 1.00 126.22 Service Accounting/Compliance 50.00 14.00 700.00 3001mm 7,030.75 "fetal 7,038.75 Ammunt Paid 0.00 Balance Due $7,038.75 http://wmawaxcom/printlnvoice.php 1/1 11/29/2016 List of Invoices: Amaxcom 1.1n @f Inmficgg 11281601 CMD 11/28/2016 1 3,065.56 3,065.56 Viewed 11211601 CMD 11/20/2016 9 5,007,134 55,007.04 VieLed 11141601 CMD 11/14/2016 15 1,975.29 1,975.29 Vie. ed 11061601 CMD 11/06/2016 23 7,038.?5 7,038.75 Viewed 10311602 CMD 10/31/2016 29 - 508.80 508.80 Drafi 10311601 CMD 10/31/2016 29 3,119.50 3,119.50 Dra1 10241601 CMD 10/24/2016 36 5.182.820 5,182.80 Vie/wed 0.0 25,897.74 25,897.74 http:/MNmawaxconVShowlnwices.php?r=filter 11/30/2016 List of Invoices: Aynaxcom 1.1611 01" 1110101006 1 1301601 CMD‘ 11/30/2016 0 2,101.36 2,101.36 0161; 11281601 CMD 11/28/2016 :2 3,065.56 3,065.56 Viewed 11211601 CMD 11/20/2016 10 ' 5,007.04 5,007.04- ‘ Viewed 1 1141601 CMD 11/14/2016 111 1,075.20 1 1175.29 View ad 11061601 CMD . 11/06/2016 24 7,038.7 7,036.76 Viewjad 10311602 CMD 10/31/2016 30 606.60 508.80 015111 10311601 CMD 10/31/2016 30 3,119.50 3,119.60 Draft 10241601 CMD 10/24/2016 37 5,182.80 5,162.80 vsewéd 0.0 27,999.10 27,000.10 http://wwaynaxcorflshowlnwices.php?r=fiIter 11/20/2016 lnwice 11211601 Los Gatos Financial Services :15. fi?t§§ni?ac'lf.i§"A?/ZTWCES t N V 0 Q E Suite 178 ' Los Gatos, CA 95030 Svhggdrow Ave invoice # 11211601 santa cruz' CA 95060 invoice Date 11/20/2016 Due Date 11/20/2016 item Description Unie Price Qaantity. Arnol'unt Service Contract Labor week of 11/14/2016 20.00 94.75 1,895.00 Service Contract Labor Repair/Greenhouse 50.00 17.00 850.00 Service Supplies 686.34 1.00 686.34 Service Equipment 289.04 1.00 2819.04 Service Repairs Greenhouse 408.60 1.00 403.60 Service Storage 331.11 1.00 33S .11 Service Water 246.95 1.00 24£.9S Service Accounting/Compiiance 50.00 6.00 300.00 Smimtotai 5,00?" .04 “rates 5,007.04 Amount Paid 3.00 i8aiarme [me $5,007.04 http://iM/vwamaxcom/orintlnvoicenhn 1/1 HV/ C [M D Iz-é.» :1??? 3 32.17.: Ely-X? ’ (/IJ $65 , V Mgni'gi NWié/m 136K 20“? . Date Amount Store Descri' i! .0 o A AWN «SW1 (,2, 42.. Lad/2.. , \ 3 ‘ ‘ u L ,d Phase: MW LLCf” ' . Pfimfimfiz 6 C T ETA; _..._._ MGNTH NWEMffi‘fiéL 510M; MW WES WW “my ' m 3M 3W WK TC ( \ Defoe-434 ism/3 fld 3/3 :31; 5/5“ (9610 i 3 34.5 ._/ E? (”23/ EP 43/ 14: (5/ EC 2/ [3? Q/ LHVO \ 23 " Oi l0 \1 1'1. 13 3g “Sc. '2; 13:3 3’67 % \ EF: “1 (5:1 L 23.; was “9 3% ‘7 Tc)? “'0 3L; 10! m 34' £6 61;; EMS er \o gm/ jg \ nu; MD 65 MD a m 5 \‘7 1 v8, 50‘? 523 yd}! 95"!“ 21/) 947.22 2.53.53 3%, 5%? €525 ’i- 4.... \ $35 W” 5% ’ w '. 22. . 3,6 »l 1‘1 it? E: 2% MD g; \1 1® _ u L0 Wu M‘Efliififiéi ___Q.__.__~_._._.._.. .1“ ' ' "(2%“ g “ 3 ”m M 6 Pimi‘gfl: W___ h Lmé’F‘D - ' I Em: ....._..____.. MGNTH N ox/emfiw. 310M; MON TUES WED THU FRE SA? SUN k :33 i-«f 3 (9 _ WK ' W 5:5 E-F a: 4,, EF 2- , 3:31.15 H '7 55> 0‘} IO . 11 (L 3 EV: ms 23? 1m ~ 2J5 E? H EH“ \5 Hz» \7’ W) m 20 2-3 ”2?: :32: EFL 63$ {(3 "/1’ '/(‘5 ‘ Laiyw Swag! he? 2.01%? +Z.§@§O "/u/‘w A Klein h ' ~ ~- Lfmg 37% fl: ”6737983 “>13” 25w Labo&(((‘§€€€t\l($) 4900 00 , W - K v. Eek, H3y% fits-[H \%,L8V/ m w 98““ 3C.Z\ V198 '3><"50V CV "/l‘l/IW L.abofi ”MO" SUEE“é§ LHLL {(0 \_ 162-" 15 HP_CMD Santa Cruz_ December 2016 Income Statement for Period Ending December 31, 2016 Code Income 510 511 520 535 TI COGS 631 ‘660 661 670 671 675 678 680 TCOGS OE 701 704 744 747 756 757 760 761 772 786 800 806 807 808 809 816 825 831 832 845 846 847 Description Sales, Shipments Sales, Non-Taxable, Rec. Sales, Taxable, Rec. Sales Tax Collected, Rec. Sales, Scrap Product, Rec. Total Income Cost of Goods Sold Purchase Materials . Discounts -A/R & A/P Productive Shop Taxes Payroll/Shop Insurance W/C Shop Contract Labor Packaging Supplies Shipping Expenses Out Total Cost of Goods Sold Gross Income (Loss) Operating Expenses Officer Salaries _ Office Salaries-Wages Accounting ADP Fees Bank Charges Credit Card Charges Computer Supplies Commissions Dues and Subscriptions Equipment Gas, Oil, Tires and Travel Insurance, Liability Insurance, Health Insurance, W/C Insurance, Dental Interest Janitorial, Maintenance, Laundry Legal Expenses License and Permits Office Supplies Outside Services Payroll Service Costs Current Period 5;- $480.00 5. $_ $4,550.00 s- L 5. $4,550.00 $(4,070.00) ' s- S- $850.00 :5- S- s- $.. :5. f5- 5.. S- s- S- $_ 5; 3. $102.17 5- Current YTD $5,930.00 $' 5. s- 1 s- I $13,250.00 5. $- $20,180.00 $(19,700.00) . S- $. $2,675.00 5. $_ . 5- $8,143.96 $58.68 5. s- s- 5- 5- $102.17 _ 5- $1,714.00 TOE OP 855 356 863 864 870 874 880 881 882 900 901 965 966 Rent Repairs Shop Supplies, General Small Tools, General Taxes-Payroll Telephone, Internet Utilities Waste Disposal Water Advertising and Promotion Security Total Operating Expense Operating Profit (Loss) Other Income (Expense) Interest Miscellaneous Total Other Income Net Income (Loss) Before Taxes Net Income (Loss) $4,375.83 $1,890.71 $1,535.88 $4,430.88 S- $271.65 3. $’ $13,475.06 $(17,545.06) $(17,545.06) $(17,545.06) $14,458.60 $5,342.29 $4,417.90 $10,716.89 $_ $644.82 $161.65 S- $48,453.90 $(68,153.90) $(68,153.90) $(68,153.90) ‘3: TI M 6 \__OG “ .2» @gfiiflggi . kl L. q C Plcmfiafii: __.___________L . 51%: __.___.I mama-2 Becemom 9.011: ' MGM "WES WED mu 55% SM SUN I 2 -. :2- 3 LI 17 MD 7: J Mp '» MD WK ~ BF C2 E? 2% ET}: ‘7: " 2L5 3‘0 "‘3 3’6, % 3C3 . ‘5 5 (a . » 8» 5. . C? W W 3 T, E 5 :. C8 '30"?- 7 3C“? 336 wit: 2 If. t” 2‘“ .. , J 5 r. ‘ . ’9'? 2,»; 555 3"? 219125 a ”‘5 ”’5 EF '5, 2‘ n, T6213 fig?“ 3% 15 ‘ZW ll» L11 \8 21 T90 . ‘1' “c. 5 . 3 : ,5:- 25 t a: 22322» 5:255 E?» :5 EF L5 EARS 23 £51m 2‘7 igfl 3“; 1941K 223 2‘4 ' - $255 21,5 H H; "2:5? ,r 0:5 EF 55 5:225 55 2:5 EIFM; 2,3,; _ 2:: a7 :25 m. 3:» . 3c 3‘ 551 .2 5 E"; \ ‘3 Lt 0- - \ ‘.--~' Q Tin/Ha Loé‘ ' Wham: I L»__ . r: a ‘1 . 9 my) CDWWNKLX’OS Plfinfiedl ETA: ._"__ MQNTH Wacawxésm ; MGN mg WED THE W m" SUN! if WK ‘ 1 ' 3 5* 5‘ e '7 C22 0t \o \i‘\ a; ‘5 5: MD 3 ‘3 ' \7, \5 M (5 no n l?) a; g m 20 :11 r21 :23 m 25 :3”: 3 mo £2”? :29)» 2‘1 $0 3! \ Wrxprqi(/ Monfifii: 706m? NEW 2W Date Amount Store Descri 'on Mmfig‘n: Doi‘e Amouni' Store \‘2- z - 5.72. \2. .22 '. 0 n, g 3 a. (m 0 0f ‘9 Q ‘2’ >4 (M3, r\ SK 5 Descri Hon Mamhz IT><:LC;G> WkWéfl/ 510% Date Amount Store Descri 'on U- 2‘300 \7. ,5 12/6/2016 Invoice 12161601 Los Gatos Financial Services _ Los Gatos Financial Services 481 N. Santa Cruz Ave. Suite 178 Los Gatos, CA 95030 INVQECE CMD Invoice # 12161601 Woodrow Ave > santa cruz' CA 95060 Invoice Date 12/06/2016 Due Date 12/061/2016 liem fleecription Unit Price Quani‘iiy Minimum Service Contract Labor 12/1-12/3, 20113 20.00 34.50 690.00 Service Contract Labor Repairs/SC 50.00 17.00 800.00 Service SC Rent/Mortgage 4375 83 1.00 4,375.83 Service Supplies 589.88 1.00 509.88 Service Office Supplies/Printing 17.94 1.00 17.94 Service Repairs 508.47 1.00 508.47 Service Accounting/Compliance 50.00 3.00 150.00 / Subtetai 7,182.12 Tote? 7,182.12 11511130211 Paid 0.00 Beience flee $7,182.12 http://wwaynaxcom/printlnvoice.php 12/6/2016 Invoice 12061602 Los Gatos Financial Services Los Gatos Finaflciai Services 481 N. Santa Clruz Ave. E N v Q a C E Suite 178 . Los Gatos, CA 95030 ' CMD Envoiee 2% 12061602 Woodrow Ave . santa CWZ' CA 95060 Invoice Date 12/06/2016 Due Date 12/06/2016 I item fieecé'iption ijnii: Price Quantity Amoimt Service Corralitos Rent Share 1866.66 1.00 1,866.66 6156161321 1,866.66 T616? 1, 866. 66 Amaum 136161. 0.00 936166e flue $1,866.66 http:/Ammayriaxcoarintinwice.php 1/1 12/13/2016 Los Gatos Financial Services 481 N. Santa Cruz Ave. Suite 178 Los Gatos, CA 95030 Invoice 12121602 Los Gatos Financial Services ENVQECE CMD Emmiw $15 12121602 Woodrow Ave . 5am C‘Uzr CA 95060 Invoice-L mat-e 12/12/2016 flue @3126 12/13/2016 item ' Bassi'igatian iénit Prime Quantity iii-molten: Service Suppiies 550.00 1.00 550.00 | Saaisw‘ciami 55.0.00 ‘ii‘ca-itai 550.00 flimmmi Paid - ~ 0.00 fiaé‘aa‘me Base $550.00 1/1 http:/AMNwawaxcoarintinvoice.php 12/12/2016 Los Gatos Financial Services 481 N. Santa Cruz Ave. Suite 178 Los Gatos, CA 95030 Invoice 12121601 Los Gatos Financial Services :1 , I l l‘ 3 CMD Invnice ab 12121601 Woodrow Ave Santa Cruz, CA 95060 _ .. , mvoace Date 12/12/2016 one 0563 12/12/2;2016 ;i iiem Qeeerimiee Unit Price 00.311111“? Améunt Service Contract Labor Week of 12/4 20.00 55.00 1,100.00 Service Contract Labor Repairs/SC - 50.00 10.50 525.00 Service Contract Labor Advance/3a mil 20.00 6.00 12.10.00 I. Service Utilities 4430.88 1.00 4,430.88 Service Repairs 7.24 1.00 17.24 E Service Accounting/Compliance 50.00 3.50 175.00 Totai amount due is actualiy $5 558 :12 NOT ES: Invoice total forTime & Materiais for Week 12/4~12/31 20.16 is $6, 358 12 less $800. 00 paid to Jamil Cahuas- Salazar whic h included a $1.120 00 advance (6 hrs) on 34 hows paid ($ 680) ‘ l ’l I; 50013181 6 358.12 “161.31 6,358.12 15133313311131 1133153 50.00 Eegaraee Que $6,35:8.12 http://wvmawaxcom/printlnvoice.php l | l' i‘ I l l l l 'i ‘L l i 1/1 12/20/201 6 Los Gatos Financial Services ‘ 481 N. Santa Cruz Ave. Suite 178 Los Gatos, CA 95030 SCl\’lC__C M D lnwice 12191601 Los Gatos Financial Services revellee l i It ‘ti l l Enveiee # 12191601 863 Gharkey St. Santa Cruz, C 9506 n . r . A O invoice Date 12/19/2016 Due fleece 12/19/ij2016 |; | lirem Beecripfion Unis: Priee Quani‘iiy firmefiimt . [1 Service Contract Labor Week of 12/12/2016 20.00 57.00 1,140.00 l. Service Past due from invoice 1.2121601 1108.12 1.00 1,100.12 Service Accounting / Compliance 4.00 50.00 200.00 Total amount clue is actually $1868.12 due $1108.12 NOTES: Invoice total for Tirrie and Materials; for 12/12-12’18 2016 is $1340.00 iess $580.00 paid to Jail-nil Camus-Salazar. Total amount due is; $760.00 plus p' st I I | l I |. l l l. 2505300203 2,448.12 "03%.? 2, die-8|. .12 Karriomii: 0am 0| 00 Saiaime firmer $2,440.12 l l a |- l l. 1/1 http://vmmawaxcom/printlnvoicephp 12/25/2016 lnwice12251601 Los Gatos Financial Services .Los Gatos Financial Services 481 N. Santa Cruz Ave. Suite 178 Los Gatos, CA 95030 ENVQEQE ii 12251601 SCMCJZMD Inveiee $5 863 Gharkey 51'. saw ””2' CA 95060 Invoice flate 12/25/2016 me Date 12/25/2016 item Deecripfien Unit Price Quantity Amelfimnt Service Contract Labor Week of 12/19/2016 20.00 45.00 900.00 l Service Supplies 395.70 1.00 395.70 Service Maintenance 102.17 1.00 102.17 Service Water‘ 271.135 1.00 221.65 Service Accounting / Compliance 50.00 4.50 225.00 gummmi 1,894.52 “Mimi - 1,894.52 111111111111. Paid 0.00 “winner: {Que $21,894.52 1/1 http://vwmaynaxcom/printlnwice.php w MLé/K‘ v71”; :NHQS /ULO\,~ V\. ¥MCwl LL " I ‘ [0237' A 4 A: 225 1/2/2017 Los Gatos Financial Services 481 N. Santa Cruz Ave. Suite 178 Los Gatos, CA 95030 SCMC~CMD~ 863 Gharkey St. Santa Cruz, CA 95060 inwice 12311601 Los Gatos Financial Services QNVQEQE invoice # 12311601 invoice Date 12/31/2016 Due Date 01/02/2017 item Deecriplian Uni-1: Firiee .lkmmimt Service Contract Labor Week 12/26 2000 700.00 Sen/ice Accounting / Compliance 50.00 100.00 NOTES: Invoice'totai forTime and Materiaie for 12/26 ~ 12/31 .2016 is $800.00 less $620.00 paid to Jamil Cahuas-Saiazar. Total amount due is $180.00 Suifie‘l‘el 800. 00 Total 800.00 filmeum 2331M 0.00 Ealence lame $800.00 http://wmmawaxcom/printlnvoice.php 1/1 1/2/2017 _Los Gatos Financial Services 481 N. Santa Cruz Ave. Suite 178 Los Gatos, CA 95030 invoice 12261601 Los Gatos Financial Services ENVQECE Jamil Cahuas-Salazar invoice 25¢ 12261601 SCMC Member santa cruz' CA 95060 Enveice Bate 12/26/2016 Due Bate 12/26/2016 item Description Unit Price Quantity Amount Product SCMC Gorilla Glue #4 Teens 15.00 - 32.00 480.00 Suleim'tai 480.00 T013331 480.00 Aimee/ant View 0.00 Ealance Due $480.00 http:/Ammmawaxcoarintlmoicephp 1/1 m» ‘ LGJJD‘KL % _ Mir @ (a) "jaw (Q * 150‘” ‘ 10 ll 12 l3 14 15 l6 l7 l8 19 20 21' 22 23 24 25 26 27 28' PROOF OF SERVICE BY U. S MAIL I, the undersigned, “state that I am a citizen of the United States and employed in the County of Santa Cruz, State of California; that I am over the age of eighteen years "and not a party to the within action; that my business address is 133 Mission Street, Suite 230, santa Cruz, California; that on the date set out below, I served a true copy of the following: - DECLARATION OF EDWARD FONTAINE 1N OPPOSITION . TO DEFENDANTS’MOTION FOR ATTORNEY’S FEES AND COSTS PURSUANT TO CCP Section 425.16; MEMORANDUMOF POINTS AND AUTHORITIES ' on the persons listed below, by placing said copy enclosed in a sealed envelope with postage thereon fully prepaid, in the Federal Express office located at Santa Cruz, California, addressed as follows: JOHN C. BOHREN, ESQ. BOHREN LAW OFFICES 555 West Beech Street, Suite 510 San Diego, CA 92101 Executed at Santa Cruz, California, this 12th day of September, 2017. I declare under penalty of perjury that the foregoing is true and correct. ‘ / 61
