Notice Lien ClaimantCal. Super. - 6th Dist.April 15, 2019\OOOQQU‘I-bUJNr-t NNNNNNNNNHh-Ir-it-AHHHa-ir-H OOQONm-hWNHowmflQUl-bUJNr-‘O 1QCV346322 Santa Clara - Civil Randol h S. Hicks, Esq. - SBN 83627 Daniel ghevtsov, Es . - SBN 299971 CODDINGTON, ?I A Professional Corporation, Lawyers 555 Twin Dolphin Drive, Suite 300 Redwood City, CA 94065-2133 Te1.: 650.592.5400 Fax: 650.592.5027 ATTORNEYS FOR Defendant Jorge Mero ICKS & DANFORTH Electronically Filed by Superior Court of CA, County of Santa Clara, on 3/1 0/2021 11:03 AM Reviewed By: L. Quach-Marc Case #1 9CV346322 Envelope: 6002998 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA CARLOS ALFONZO GARIBAY, Plaintiff, VS. JORGE MERO; CARLOS TOSCANO dba TOSCANO TRUCKING; and DOES 1 to 10, Defendants. Case No. 19CV346322 NOTICE OF LIEN AND ASSIGNMENT THEREOF TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that HDI Global Insurance Company has a claim of first lien, pursuant to California Labor Code sections 3852 through 3864, upon any settlement or judgment rendered herein in favor of Plaintiff Carlos Alfonzo Garibay (“Plaintiff”) in the amount of $133,167.56 for workers compensation benefits paid to and on behalf of Plaintiff as follows: Medical Expenses: $47,729.03 Indemnity Payments: $85,438.53 Plus, interest thereon according to law, plus any amounts for which payments 0r obligations for payments arise prior to Satisfaction ofjudgment. Notice of Lien and Assignment Thereof Case No: 19CV346322 753095 éllana \OWQO‘UIAUJNr-a NNNNNNNNNr-Ir-in-HHHHHHH OONQUI$UJNHOWOOQONUIAWNHO PLEASE TAKE FURTHER NOTICE that that lien claimant HDI Global Insurance Company hereby assigns said claim of first lien in the amount of $133,167.56 to Defendants Carlos Garibay and Carlos Toscano dba Toscano Trucking in exchange for consideration paid to lien claimant HDI Global Insurance Company Dated: z’lo’zi CODDINGTON, HICKS & DANFORTH By Randol h S. Hicks Daniel hevtsov Attorne s for Defendant Jorge ero Dated: 3/9/2021 SAMUELSON, WILSON & ROE By: Charles R. Roe Attorneys for Defendant Carlos Toscano dba Toscano Trucking Notice of Lien and Assigmnent Thereof Case No: 19CV346322 753095 .bbJN \DOOVQUI 10 11 12 13 14 15 16 l7 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE 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 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 Eva@chdlamers.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 March 10, 2021, I served a copy of each of the documents listed below by placing said copies for processing as indicated herein. NOTICE OF LIEN AND ASSIGNMENT THEREOF United States Mail: The correspondence or documents were placed in sealed, labeled envelopes With postage thereon fully prepaid on the above date laced for collection and mailing at my place 0f business to be deposited with the .S. Postal ISDerVice at Redwood City, California on this same date in the ordinary course of usmess. Overnight Delivery: The corres ondence or documents were placed in sealed, labeled ackaging for overnight de 'Very, with Federal Express, with all charges to be paid y my employer on the above date for collection at m place of business to be depos1ted 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, 0n 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 to a facsimile machine maintained by the arty or attorney to be served at the facsimile machine telephone number rovi ed b said party or attorney, on this same date in the ordinary course of usiness. firm transmission was reported as complete and Without error, and a' record of th'e transmission was properly issued by the transmitting facsimile machine. XX Electropic Transmission: The correspondence or documents were transmitted electromcally to the electromc address set forth below. \DOONONKII-hbde-t NNNNNNNNNHHp-duflt-tl-dmb-Io-AH OOQQMhWNHOWWQQM-BWNHO State. The recipient has filed and served notice that he or she accepts electronic service; the recipient 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 rinted 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 Rule of Court R e 2.257(a). Federal. The recipient of this electronic service has consented to this method of service in writing, a copy of which is on file and available for inspection in my employer’s office. I have recelved no indication the electronic transmissmn did not reach the recipient. PERSONS OR PARTIES SERVED: Attomcys ['01- Plaintiff Attomeys forDefendant Carlos Toscano dba Toscano Trucking jonathan Brand, Esq. Nicolis Peters, Esq. Charles R. Roe, Esq. BRAND PETERS LLP Samuelson, Wilson & Roe 1777 Botelho Drive, Suite 220 210 North Fourth Street, Suite 201 Walnut Creek, CA 94596 San Jose, CA 95112 Telephone: (925) 295-1670 Telephone: (408) 790-5320 Facsimile: (925) 296-0390 Facsimile: (408) 295-5799 Mailbox5@,jb-law.com crr@swr-law.com mailbox9@jb-law.com mxl@swr-1aw.com cpeters@jb~law.cgm 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 ex ted or\1 March 10, 2021.g~ Eva Oliveira Court: Superior Court afCa/zfarm'a, Santa Clam Couny/ Action No: 19CV346322 Case Name: Garibg; v. Mera