Declaration In SupportCal. Super. - 6th Dist.August 30, 2017KDOOQO‘sUI-h-UJNr-I NNMNNNNNNv-‘r-dr-tr-Ir-dt-tr-th-tr-th-i OOQONM-bWNHOCOOflONm-bWNHO Electronically Filed Kathryn c. Klaus, Esq. - SBN 205923 by Superlor Court of CA, Rebecca D. Martino, Esq. - SBN 236094 County Of Santa Clara, Solomon Pantuch, Esq. - SBN 309458 on 9/5/2019 4:14 PM A PfOfeSSional corporation, Lawyers case #1 7cv31 6966 555 Twm Dolphm Dnve, Sulte 300 Envelope: 3354634 Redwood City, CA 94065-2133 Te1.: 650.592.5400 Fax: 650.592.5027 ATTORNEYS FOR Defendant Khanh Quoc Bui IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA DMITRY MAIZEL, Case No. 17CV316966 Plaintiff, DECLARATION OF SOLOMON vs. PANTUCH IN SUPPORT OF DEFENDANT’S MOTION TO COMPEL KHANH QUOC BUI, and DOES 1 - 10, FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE Defendants. PROPOUNDED TO PLAINTIFF Date: October 10, 2019 Time: 9:00 a.m. Dept: 19 Hon. Peter H. Kirwan I, Solomon Pantuch, hereby declare: 1. I am an attorney duly licensed t0 practice before all courts in the State of California, and am an Associate at Coddington, Hicks & Danforth, attorneys of record for defendant Khanh Quoc Bui. I make this declaration from my own personal knowledge, and if called t0 d0 so, can and would testify t0 each fact set forth herein. This declaration is submitted in support of defendant’s motion to compel further responses from plaintiff Dmitty Maizel (“plaintiff”) to defendant’s Special Interrogatories, Set One. The following are facts 1 Declaration of Solomon Pantuch in Support of Motion to Compel Further Responses to Special Interrogatories Case No: 17CV316966 622027 \OOOQONKthwat-t NNNNNNNNNp-no-‘r-«v-tr-‘r-tv-tr-dr-Ah-t OOQONM-hwwt-dooooflmm-bwmv-lo within my personal knowledge and, if called as a Witness herein, I can and Will competently testify thereto. 2. On December 5, 2018, my office served Special Interrogatories, Set One, on plaintiff. Plaintiff’s responses t0 defendant’s Special Interrogatories, Set One, was due on January 9, 2019. Attached hereto as Exhibit 1 is a true and correct copy 0f the Special Interrogatories, Set One served on plaintiff Drnitry Maizel. 3. On January 29, 2019, my office sent plaintiff a letter requesting that he provide responses to Special Interrogatories so that defendant does not have to move to compel. Attached hereto as Exhibit 2 is a true and correct copy of the January 29, 2019 letter. 4. On July 22, 2019, my office received plaintiff’s responses to the Special Interrogatories, but the responses were deficient, evasive and not code compliant. Attached hereto as Exhibit 3 is a true and correct copy of plaintist responses to Special Interrogatories. 5. On July 29, 2019, my office sent plaintiff a letter indicating that he had failed to provide substantive code compliant responses to the Special Interrogatories, and that he had until August 23, 2019 to provide responses. Attached hereto as Exhibit 4 is a true and correct copy 0f the July 29, 2019 letter. 6. T0 this day, I have not received further responses t0 the Special Interrogatories, Set One. 7. I spent a total of 3 hours researching and preparing defendant’s motion t0 compel. My hourly rate for this matter is $180. I anticipate that it will take an additional 1 hour 0fmy time to prepare a Reply to plaintiff’s opposition. Also, it will take about 30 minutes to prepare for the hearing on the motion. Lastly, any appearance on said motion will take about _3_O_ _r11i_n_uL§§. The insurance carrier that has retained my office 0n behalf of defendant will have t0 incur a total of $900 (5 hours x $180). /// /// /// 2 Declaration of Solomon Pantuch in Support of Motion to Compel Further Responses to Special Interrogatories Case No: 17CV316966 622027 \OOONONUI-PUJN 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I declare under penalty of perjury under the laws of the State 0f California, that the foregoing is true and correct. Executed this 5th day 0f September 2019, at Redwood City, CA 94065. fl/ ’Solomon Pantuch 3 Declaration of Solomon Pantuch in Support of Motion to Compel Further Responses to Special Interrogatories Case No: 17CV316966 622027 EXHIBIT 1 ©0O\JO\Ul-bUJN|-a [\Jr-dHt-tp-dr-dr-Ir-tr-Ir-aa-I OKOOOQmLh-war-‘G 22 23 24 25 26 27 28 Kathryn C. Klaus, Es . -- SBN 205923 Rebecca D. Martino, s . - SBN 236094 CODDINGTON, HE KS & DANFORTH A Professional Corporation, Lawyers ' 555 Twin Dolphin Drive, Suite 300 Redwood City, CA 94065-2133 Tel.: 650.592.5400 Fax: 650.592.5027 ATTORNEYS FOR Defendants CSAA Insurance Exchange and Khanh Quoc Bui IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA DMITRY MAIZEL, Case No. 17CV316966 Plaintiff, SPECIAL INTERROGATORIES, vs. SET ONE CSAA INSURANCE EXCHANGE; KHANH QUOC BUI, and DOES 1 - 10, Defendants. PROPOUNDING PARTY: Defendants CSAA Insurance Exchange and Khanh Quoc Bui RESPONDING PARTY: Plaintiff Dmitty Maize] SET NUMBER: One I. INSTRUCTIONS (a) In superior court actions, an answer or other appropriate response must be given to each interrogatory requested by the asking party. (b) As a general rule, within thirty (30) days after you are served with these interrogatories, you must serve your responses on the asking party and serve copies of your responses on all other parties to the action who have appeared. Sec Code of Civil Procedure § 2030.260 for details. Special Interrogatoties, Set One Case No: 17CV316966 U14>UJN KO m \l Ox 10 11 12 13 14 15 16 17 18 19 20 21 22 23 25' 26 27 2'8 (c) Each answer must be as complete and straightforward as the information reasonably available to you permits. If an interrogatory cannot be answered completely, answer it to the extent possible. (d) If you do not have enough personal knowledge to fully answer an interrogatory, say so, but make a reasonable and good faith effort to get the information by asking other persons or organizations, unless the information is equally available to the asking party. (e) Whenever an interrogatory may be answered by referring to a document, the document may be attached as an exhibit to the response and referred to in the response. If the document has more than one page, refer to the page and section where the answer t0 the interrogatory can be found. (f) Whenever an address and telephone number for the same person are requested in more than one interrogatory, you are required to furnish them in answering only the first interrogatory asking for that information. (g) Your answers to these interrogatories must be verified, dated and signed. You may wish to use the following form at the end 0f your answers: “I declare under penalty of perjury under the laws of the State 0f California that the foregoing answers are true and correct.” (Date) (Signature) Shcciyallmerrogétories, Set One C238 No: 17CV31 6966 \oooummhwww Np-Ar-dv-tv-Ar-iI-lI-dt-AHr-t CKOOOfiQM-PWNr-ao 22 23 24 25 26 27 28 II. INTERROGATORIES Special Intermgatory No. 1: At the time 0f the INCIDENT (INCIDENT, as used herein, means the circumstances and events surrounding the alleged accident, injury, or other occurrence giving rise to this action or proceeding) that underlies this lawsuit, were you eligible for Medicare Part A (Hospital Insurance), Part B (Medical Insurance), Part C (Medicare Advantage Plan Coverage) and/or Part D (Prescription Drug Coverage)? Special Interrogatory No. Z: Are YOU (YOU and YOUR, as used herein, means you, your agents, employees, attorneys and anyone else acting on your behalf) currently enrolled in Medicare Part A (Hospital Insurance), Part B (Medical Insurance), Part C (Medicare Advantage Plan Coverage) and/or Part D (Prescription Drug Coverage)? Special Int-exrogatory No. 3: If the answer to Special Interrogatory No. 2 is in the affirmative, please provide the date on which YOU first became. entitled to receive such benefits. Special Interrogatory No. 4: If the answer to Special Interrogatory No. 2 is in the affirmative, please provide YOUR Medicare Health Insurance Claim Number (HICN). Special Interrogatory No. 5: If the answer to Special Interrogatory N0. 2 is in the affirmative, please provide YOUR Social Security Number (SSN). Special Interrogatory No. 6: If the answer to Special Interrogatory No. 2 is in the affirmative, please provide the amounts of any payments made by Medicare on YOUR behalf t0 date for care and treatment ' of the injuries being claimed in this lawsuit. Special Interrogatory No. 7: Have YOU or anyone YOU know, including, but not limited to, YOUR attorneys, put Medicare on notice of this lawsuit and YOUR claim for damages? 3 Special Interrogatoties, Set One Case No: 17CV316966 \DOOQQLI’l-hWNp-A t-¢ a-I u-t 3-- v-A u-A n-n n-‘ p-«A p-i \O 0° \J ON U"! c9» DJ N b-* O 20 Special Interrogatory No. 8:: If the answer to Special Interrogatory No.7 is yes, please provide the date that Medicare was placed on notice. Special Interrogawry No.9: Have YGU or anyone YOU know, including, but not limited to, YGUR attorneys, received from Medicare any notice of lien claim for this particular lawsuit? Special Interrogamry No. 10: At the time of the incident that underlies this lawsuit, were YOU eligible for Medi-Cal? Special Interrogatoty No. 11: Are YOU currently a Medi-Cal recipient? Special Entertogatory No. 12: If the answer to Special Interrogatory No.11 is in the affirmative, please state YOUR Medi-Cal number. Special Interrogatory N0. 13: If the answer to Special Interrogatory No. 11 is in the affirmative, please state the amount of payments made by Medi-Cal on YOUR behalf to date for the care and treatment 0f injuries being claimed in this lawsuit. Special Interrogatory No. 14-: Have YOU or any ofYGUR representatives put Medi-Cal on notice of this lawsuit and YOUR claim for damages? Special interrogatory No. 15: If the answer to Special Interrogatory No. 14 is yes, please provide the date that Medi- Cal was placed on notice. Special Interrogatory No: 16: Have YOU or anyone YOU know, including, but nOt limited to, YGUR attorneys, received from Medi-Cal any notice of lien claim for this particular lawsuit? Special Interrogatories, Set One Case No: 17CV316966 \oooqoxu‘a-wmn- NNNM’NMNNN- muambwmwoogzaazag:3 Special Intertogatoty No. 17: Have YOU had a PRIMARY CARE PROVIDER (PRIMARY CARE PROVIDER as used herein, means primary care provider, primary care physician, general medical doctor, general practitioner, or any other person who you regularly or routinely received or receive medical treatment or care fiom) for the past ten years? Special Interrogatory Non 18: Please state the name of each PRIMARY CARE PROVIDER that YOU received medical treatment from in the past ten years. Special Interrogatory No. 19: Please state the address of each PRIMARY CARE PROVIDER thatYOU received medical treatment from in the past ten years. Dated: December 5, 2018 ON, HICKS & DANFORTH /\/ M RQEecéKD. Martino Attorneys for Defendants CSAA Insurance Exchange and Khanh Quoc Bui Special Intenogatoties, Sgt One Case No: 17CV316966 huh.) \DOOQONUI 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 26 27 28 PRQOF OF SERWCE California Code of Civil Procedure sections 1011, 1013, 1013a, 2015.5 California Rule of Court rule 2.251 Federal Rule of Civil Procedure Rule 5(b) I, the undersigned, declare that I am employed in the County of San Mateo, State of California. I am over the age 0f eighteen (1 8) years and not a party to the within action. My business address is 555 Twin Dolphin Drive, Suite 300, Redwood City, California 94065. My electronic mail address is gprasadechdlamersxgm. I am readily familiar With my employer’s business practice for collection and processing of correspondence and documents for mailing with the United States Postal Scrvicc, mailing via overnight delivery, transmission by facsimile machine, and delivery by hand. On December 5, 2018, I served a copy of each of the documents listed below by placing said copies for processing as indicated herein. SPECIAL INTERROGATORIES, SET ONE X United States Mail: The correspondence or documents were placed in sealed, labeled envelopes with postage thereon fully prepaid on the above date placed for collection and mailing at my place of business to be deposited with the U.S. Postal Service at Redwood City, California on this same date in the ordinary course of business. Overnight Delivery: The corres ondence or documents were placed in sealed, labeled ackaging for overni ht de 'Vcry, with Federal Express, with all charges to be paid y my employer on tie above date for collection at m place 0f business to be deposited in a facility regularly maintained by the overni t delivery carrier, or delivered to a courier or driver authorized by the overnight dc 'Vcry carrier to receive such packages, on this date in the ordinary course of business. Hand Delivery: The correspondence or documents were placed in sealed, labeled envelopes and served by personal delivery to the party or attorney indicated herein, or if upon attorney, by leaving the labeled envelopes with a receptionist or other person having charge of the attorney’s office. Facsimile Transmission: The corres ondence or documents were placed for transmission from 650) 592-5027 at Re wood City, California, and were transmitted t0 a facsimile mac 'ne maintained by the arty or attorney t0 be served at the facsimile machine telephone number rovifed EX said party or attorney, on this same date in the ordinary course of usiness. -he transmission was reported as complete and without error, and a record of the transmission was properly issued by the transmitu'ng facsimile machine. Electronic Transmission: The correspondence or documents were transmitted electromcally to the elecfiomc address set forth below. \OOOHQUI-hLoJN 10 11 12 13 14- 15 16 17 18 19 20 21 22 23 24 25‘ 26 27 28 State. The recipient has filed and served notice that he or she accepts electronic service; the reapient has electronically filed a document With the court; and/or the Court has mandated that the parties serve documents through its Court approved vendor. The tinted form of this document bearing the original signature is on file and available or inspection at the request of the court or an party to the action or roceeding in Which it is filed, in the manner provided in Cali ornia Ruic of Court R c 2.257(3). Federal. The recipient of this electronic service has consented t0 this method 0f service in writing, a copy of which is on file and avallable for inspection in my employer’s office. I have recelved no 1nd1cat10n the electromc ttansrnisslon did not reach the recipient. PERSONS OR PARTIES SERVED: Zn Pm Per Dmitry Maizel 280 Los Palmos Way San Jose, CA 95119 Telephone: (41 5) 203-6210 Facsmfile: E-mail: I certify (or declare) under penalty of perjury under the laws of the State of California that f . , ,, Kfiita Prasad the foregoing is true and correct and that this declaratio/gywas CXWDecember 5, 2018. Court: Superior Cotm‘ ofCa/tfimz'aflanta Clara Canny! Action No: 77CV376966 Case Name: Maize] v. Buz' EXHIBIT 2 CODDINGTON HRCKS & DANFURTH Rebecco D. Martino rmorfino@chdluwyers.com january 29, 2019 Dmitry‘Maizel 280 Los Palmos Way San Jose, CA 95119 Re: Maizel v. Bui Dear Mr. Maizel: On December 5, 2018, our office served you with special interrogatories, requests for production of documents and form interrogatories. Your responses were due on January 9, 2019. To date, we have not received said responses. Given the lack of responses, all objections have been waived by you. Please provide our office with written discovery responses by February 1‘11, 2919 so that we can avoid the necessity of having t0 move to compel. Ifyou have any questions, please do not hesitate to contact me. Very truly yours, f) zW)%%@/% Rebecca D. Martino RDMzkt www.chdlawyers.com EXHIBIT 3 SHORT TiTLE: Dmitry Maizel vs Khanh Quoc Bui CASE "UMBER: 17CV3 1 6966 AMSvs/ersjro Specx’al lm-éea/Vogq-Lon‘eg; $9.4;- One 2 “i. No 3 2. _ N0 4 3 ‘3 NO£ appriicaHe 5 {a No 6 11. Yes 7 12. 3&5’09930Efiézai 8 15. WE“ ‘01 A&RVMMQJ 1:42? 9 m, No 1o 15’, N c£ aN-{I‘wbie 11 {6' No 12 41 Ihéevmi’éjcenéij 13 13. Curhewé szaéhevih-e K- 34“” “0:447 MD 14 Pvavious :MLOEEH; Tonnes gawk; , MD 15 e)Robewl: Hora MALE) MD 16 '13 vml’quua-w'me K. 5%Yelkfl4‘g 17 1563 Sioalc MW!) .Sm‘ée 3:53 1s 3cm Framgsco , CA 9L, :52. 19 20 b‘) R0 bare Tamas garéa 21 BASO Cahiorm‘a 5+, Sm‘k ZOO 22 San ?Vahm‘sw) CA 3 5-: H 8 23 C) Robw£ HOW wi£ 2 24 lilac Mow park Ave) Suilce- 210 25 Sq“ 305e, CA $5723 25 22mm? for verified pleading) The items on this page stated on information and belief are (specifyitem numbers, noiline ers: 27 This page may be used with any Judicial Councuform orany otherpaperfiled withthe court. Page 1 “$$$$$on Attach to JuéiciafggdiangfifiisgmrCour: Paper caczm.so1 MC-ozo [New Jammy 1, 1987) SHORT TITLE: Dmitry Maizel vs Khanh Quoc Bui . . u . r . . CASE "UMBER _ 17CV3 16966 1 AMSWfi-VS £0 SPQCMN IM‘LEVyogq-i-orl‘qg) SQJL OhQ 3 I aflectm mum 13‘1“an ”'9 P‘WWE; under £1” 1m»; o4: Hie gage 0; callwomm +ha£ 45kg {ovegot‘uj angular; aye 5 -(-,VL{Q_ cw”! COVVeC-Ei 7 Dcd-ef June. 2.0) ZOlj Dmfiéiyj Mm'zal a ‘/% 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 (Required for verified pleading) The items on this page stated on information and belief are (specifi/ item numbers, notline numbers): 27 This page may be used with any Judicial Council form or any other paper filed with the court Page .9. Form Approved by me ADDITIONAL PAGE Judi'lC 'lafcm ‘ ' ' ' Mcng‘gmgvf‘fmwafiggn Attach to Judlclai Council Form or Other Court Paper CRC 201, 501 EXHIBIT 4 CODbENGTON HICKS & DANFORTH Rebecca D. Martino martino@chdiawyers.com July 29, 2019 BY EMAIL AND U.s. MAIL Dmitry Maizel 280 Los Palmos Way San Jose, CA 951 19 formusor ahoo.com Re: Maizel v. Bui Dear Mr. Maizel: I am in receipt of your responses to defendant Bui’s Form Interrogatories, Special Interrogatoxies and Request for Production of Documents. Your responses to written discovery are deficient. Accordingly, I take this opportunity to meet and confer pursuant to Code 0f Civil Procedure in an attempt to avoid having t0 file another motion to compel. Responses to Form Ingcrrogatories Pursuant to Code of Civil Procedure § 2030.210, “the party to whom interrogatories have been propounded shall respond in writing under oath separately to each interrogatory by any 0f the following: (1) an answer containing information sought t0 be discovered; (2) an exercise of the party’s option to produce writings; (3) an objection to the particular interrogatory. . .” Your responses to Form Interrogatories 6.2 to 6.7, 7.1 to 7.3, 8.2 to 8.8 and 9.1 to 9J2 do t_lgt comply With Code of Civil Procedure § 2030.21 O. By responding to the aforementioned Form Interrogatories with “To be determined later,” you have n_o_t provided www.chdlawyers.com Coddingmn, Hicks & Danfarth Dmitry Maizel July 29, 2019 Page 2 an answer that contains any substantive information defendant Bui is requesting. Defendant cannot evaluate this case and your alleged damages if you are not going to be candid as t0 your allegations. The motor vehicle accident at issue in this case occurred 0n August 30, 2015. You filed your complaint on August 30, 2017. You have had ample time Lo collect the information requested and provide evidence of same. Defendan; is entitled to all information that ou have in our custod ossession an control related to our alle ed injuries, propgrgz damage, loss of incomg and other damages;ou allege occurred as a result of the accident. Moreover, you mention in your responses to Form Interrogatory 12.3, a recorded statement between defendant Bui and Geico, however you failed t0 produce the statement. Defendant is entitled to any such documents that relate to the case. Also, in response to Form Interrogatory No. 12.4, you mention two video cameras at the intersection. If you have those videos in your possession, defendant is entitled to a copy 0f the Videos. Similarly, in your responses to Form Interrogatories 12.5 and 12.6, you mention a diagram of the accident and a police report you filed. Defendant is entitled to those documents and they must be produced by you immediately. You have had several years to gather the documents you refer to. Responges to Spgcial lnterrogatories Your response to Special Interrogatory 13 does not answer the question asked and is therefore evasive. Defendant is entitled to know what medical expenses have been paid by Medj-Cal to date. Additionally, defendant is entitled to the specific amounts paid by Medi- Cal on your behalf as Medi-Cal Will assert a lien on any settlement proceeds that you receive in this action. Accordingly, if you have not already done so, you are obligated to place Medi- Cal on notice of this lawsuit. Responses to Regue§t for Production 0f Documents Pursuant t0 Code 0f Civil Procedure § 2031.210, “the party t0 whom a demand for inspection, copying. . .has been directed shall respond separately t0 each item 0r category of item by any of the following: (1) a statement that the party will comply with the particular demand. .. (2) a representation that the party lacks the ability to comply with the demand for inspection. . .” Caddingtan, Hicks & Danforth Dmitty Maizel July 29, 2019 Page 3 You have failed t0 provida an’y statements regarding whether or not you will comply With the Request for Production of Documents. A separate response to each request for production of documents has not been provided. Although you produced a number of documents, defendant still does not have all medical records that pertain to your alleged injuries. The only medical records you produced were from World of Health that evidence the sum of $6,091 owed to the chiropractor. Accordingly, it appears that World of Health is the only medical facility where you treated for your alleged injuries“ Your production of income for several years does not answer the question regarding what your alleged wage loss is as a result of this lawsuit. Arc you claiming lost wages regarding your work as a D]? It is not Defendant’s duty to guess as to what your alleged damages are. If you do not provide the requested information, it only prolongs the lawsuit. Please provide amended responses to Special Interrogatories and Form Interrogatories as requested above. Also, please provide responses to defendant’s Request for Production of Documents. Ifwe are not in receipt 0f all documents and amended responses by Auggst 23;! 2&9, we will file a motion to compel further responses. Please be advised that we will also request monetary sanctions for your failure to provide the requested information. You have had ample time to secure the documents and provide us with code compliant responses. RDM:hap \OOOQQUI-PUJNH NNNNNNNNNr-Ah-IHt-AHHr-th-Ap-tn-a OOQONUI-PUJNHOKOOOQQUI-PUJNV-‘O PROOF QF SERVICE California Code of Civil Procedure sections 1011, 1013, 1013a, 2015.5 California Rule of Court rule 2.251 Federal Rule 0f Civil Procedure Rule 5(b) I, the undersigned, declare that I am employed in the County 0f San Mateo, State of California. I am over the age of eighteen (1 8) years and not a party to the within action. My business address is 555 Twin Dolphin Drive, Suite 300, Redwood City, California 94065. My electronic mail address is Evflchdlawyers.com. I am readily familiar with my employer’s business practice for collection and processing of correspondence and documents for mailing with the United States Postal Service, mailing via overnight delivery, transmission by facsimile machine, and delivery by hand. On September 5, 2019, I served a copy of each of the documents listed below by placing said copies for processing as indicated herein. DECLARATION OF SOLOMON PANTUCH IN SUPPORT OF DEFENDANT’S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, PROPOUNED TO PLAINTIFF XX United States Mail: The correspondence or documents were placed in sealed, labeled envelopes with postage thereon fully prepaid on the above date placed for collection and mailing at my lace of business to be deposited with the U.S. Postal Service at Redwood City, Cfiiforma on this same date in the ordinary course of business. Overnight Delivery: The corres ondence 0r documents were placed in sealed, labeled ackaging for overnight defivery, with Federal Express, with all charges to be paid y my employer 0n the above date for collection at m place 0f business t0 be deposited in a facility regularly maintained by the overni t delivery carrier, or delivered to a courier or driver authorized by the overnight defivery carrier to receive such packages, on this date in the ordinary course of business. Hand Delivery: The correspondence 0r documents were placed in sealed, labeled envelopes and served by personal delivery t0 the party or attorney indicated herein, 0r if upon attorney, by leaving the labeled envelopes with a receptionist or other person having charge of the attorney’s office. Facsimile Transmission: The correscfondence or documents were placed for transmission from (650) 592-5027 at Re wood City, California, and were transmitted to a facsimile machine maintained by the arty or attorney t0 be served at the facsimile machine telephone number rovi ed b said party 0r attorney, on this same date in the ordinary course of usiness. ”R1716 transmission was reported as complete and without error, and a record of the transmission was properly issued by the transmitting facsimile machine. Electronic Transmission: The correspondence or documents were transmitted electromcally t0 the electromc address set forth below. \OOONQLIl-b 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 State. The recipient has filed and served notice that he 0r she accepts electronic service; the reclpient has electronically filed a document with the court; and/or the Court has mandated that the parties serve documents through its Court approved vendor. The tinted form of this document bearing the original signature is on file and available or ins ection at the request of the court or any party to the action 0r roceeding in Which 1t is filed, in the manner provided in California Rule of Court Ru e 2.257(a). Federal. The recipient of this electronic service has consented to this method of service in writing, a cop of which is on file and available for inspection in my employer’s office. I have recewed no indication the electronic transmissmn did not reach the recipient. PERSONS OR PARTIES SERVED: In Pro Pet Dmitry Maizel 280 Los Palmos Way San Jose, CA 95119 Telephone: (41 5) 203-6210 formusor ahoo.com I certify (or declare) under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed on September 5, 2019. Eva Oliveita Court: Superior Court 0fCalzfamia, 55mm Clara Cazmg/ Action No: 77CV376966 Case Name: Maize] I). Bm'