Notice Entry of OrderCal. Super. - 6th Dist.September 14, 2021KOOOVON 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 21 CV388736 Santa Clara - Civil MATTHEW R. EASON, ESQ. (SBN 160148) KYLE K. TAMBORNINI, ESQ. (SBN 160538) ERIN M. SCHARG, ESQ. (SBN 28531 1) EASON & TAMBORNINI, A LAW CORPORATION 1234 H STREET, SUITE 200 SACRAMENTO, CA 958 14 (916) 438-1819 FACSIMILE (916) 438-1 820 Attorneys for Petitioner, DRB CAPITAL, LLC SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA In Re: I. M. PLEASE TAKE NOTICE that an order approving transfer of structured settlement payment rights was entered in the above referenced matter Within the above captioned county and judicial district. A true and correct copy is attached hereto. Dated: December 20, 2021 1 Case No.: NOTICE OF ENTRY OF ORDER ON PETITION FOR APPROVAL OF TRANSFER OF STRUCTURED SETTLEMENT PAYMENT RIGHTS R. Fleming Electronically Filed by Superior Court of CA, County of Santa Clara, on 12l20l2021 2:21 PM Reviewed By: R. Fleming Case #21CV388736 Envelope: 7901427 21CV388736 Eason & TamborniniA Matthew R. Eason, ESQ. Counsel for Petitioner, DRB Capital, LLC NOTICE OF ENTRY OF ORDER ON PETITION FOR APPROVAL OF TRANSFER OF STRUCTURED SETTLEMENT PAYMENT RIGHTS omqmmku~_ NNNNNNNNN-_-._.-. -._. muampr-oowuam:;;~o MATTHEW R. EASON. ESQ. (SBN 160148) 1???“ 5 EL (,3: KYLE K. TAMBORNINI. ESQ. (SBN 160538) of?” $ .m 5m. EASON & TAMBORNINL A Law Corporation i 1234 H Slrcct, Suilc 200 Sacramento, CA 95814 (916) 438-1819 Facsimile (9| 6) 438-1 820 Attorneys for Petitioner DRB CAPITAL, LLC SUPERIOR COURT 0F CALIFORNIA COUNTY OF SANTA CLARA In Re: l. M. Case No. 21CV388736 ORDER FOR APPROVAL FOR TRANSFER OF STRUCTURED SETTLEMENT PAYMENT RIGHTS BY AND BETWEEN I.M., PAYEE AND DRB CAPITAL, TRANSFEREE, PURSUANT TO CALIFORNIA INSURANCE CODE § 10134, ET SEQ. DATE: Dcccm ber l6, 2021 TIME: 9:00 a.m. DEPT.: 7 WHEREAS, pursuant to California Insurance Code Sections § 10134. g! fl. (the "Act"). this cause came before lhc Court upon thc Petition, filed by counsel for the Transferee. for Court approval of a Transfer of Structured Settlement Payment Rights of the Payee lo the Transferec pursuant to a Transfer Agrccmcnl (the "'l‘ransfcr“); ORDER FOR APPROVAL FOR TRANSFER 0F S'l'RUC'l‘URED SETTLEMENT PAYMENT RIGHTS CASE NO. 2|CV388736 PAGE l OF 6 1:} E6 l7 18 19 2t} 2i 22 23 24 25 26 27 23 WHEREAS. DRE Capiluf. [J.L‘ (“'I‘ransl‘crcc“). LM. zu'kla Irene Malina afkfa I. Molina alkIa Irene N. Molina a/k/a Irene Ncila Molina (‘fPayce").Willon RI: Annuity Service Corpamlion f/kfa Transamérica Annuity Scrvicc Carporation (“Structured Sculcmcnl Obligm“), as 0mm u!" the structured settlement annuity No. 87097210017. (the "Annuity“; and ‘l’mnsamcricn Lift: Insurance Company. successor by merger with 'l‘ransmncricu Occidental Life insurance Company (“Annuity Issuer“), us issuer oi” the Annuity (lhu Structured Settlement Obligor and Annuity issuer arc somcfimcs collectively referred to as mu: “Companics") have cnicrcd into a Stipulation 0f the: Parties (the “Stipulation“}, a fullykcxcculcd copy ol‘which i3 attached and inccrporatcd herein by reference as. Exhibit A; WHEREAS, unless otherwise defined hcrein, capitalized terms shall have thc meanings set farm in 111‘: Act or in the Stipulation,_ as may be applicable. NOW, therefore, upcm the Court having jurisdiction (war (Hi3 matter and after notice, hearing and tegtimuny by the Payee, cithcr in person, by affidavit, or telephonicafly, {he Court makes the following findings: l. ’Fhe Transfer is fair and reamz-lable and in {he best iaterest 9f {he Payae, taking into account the welfare and support 0f Payee‘s Dependents, if any. I 2. The Payee has been. adviged in writing by the Transferec t0 seek Independent Prof'essianal Advice regarding the Transfer and has either received that advice 0r knowingly waived, in writing, the epportunizy to receive the advicek 3, The ’Transferec hafi complied with the notification requireméms pursuant to Section 10139,S(f}(2) of the Act; the Transfcrcc has provided the Payee. with a désclesure fem that compiies with Section 10136 oI' the. Act; and the Transfer Agreement compfies with Sections £0136 and IOEHS ofthc Act. ORDER FOR APPROVAL FOR TRANSFER 0F STRUCTURED SE’I‘TLEM EN’I‘ I’AVMENT RIG HTS CASE NO. 23(29388736 PAGE 2 0F 6 awmqamhmmfi mwmm~hmmmawm~ammguwz 4. The 'I‘ransf‘cr docs not contravene any applicable federal or state siatutc 0r lhc ardcr of any court. other government authority. or responsible administrative authority. Without limiting, the fbrcgoing, the Payee represents that this Order docs nol contravene the following prior transfer ordcr(s) (“Prior Ordcr(s)"): 0 Case No. ZICVJ’ISZI‘) w Stipulation and Order of the Court cnlcrcd in lhc Superior Court, Santa Clara Couniyg California on 0r about May 18‘ 202k '- Casc No. 19CV35’7354 - Stipuiafion and Order of thc Court entered in the Superior Court, Santa Clara County, California on (3r about December 12, 2019 i Case No. 19CV342732 - Slipuialion and Order 0f the Court entered in tht: Superior Court, Santa Clara County, California on or abcut April 4, 2.019; I- Case No. ISCV335906 - Stipulation and Order of the Court entered in the Superior Court, Santa Clara County, California on 0r about December 6, ZOEB; t Case Na. 18CV325362 - Stipulation and Order of thi: Court entered in the Superior Court, Santa Clara County, California on or about May 22, 20 l 8. 5. The Payee understands the terms 0f the Transfer Agreement, inciuding the terms set forth in the disclosure statement required by Section 10 I 36 of the Act‘ 6. The Payee. anderstands and docs not wish to exercise the Payéc's right to caucei the Trans fer Agreement. 7. The Payee is properly before the Court and has cnnfirmesd to the Court‘s satisfaciisn that she is a resident of this state and entitled to avail hcrscll‘ of the Act. 8. The Stipulation Es hereby APPROVED. Based on the foregoing findings, it is hereby ORDERED, ADJUDGED, and DECREED: GREEK Ff)?! Al’i‘ROVAL F013. TRANSFER 0F S7I'RUC‘E‘UREI) SET’I‘LEMEN'I‘ I’A‘Yfi-IEN'I" RIGHTS CASE NO. 2 l CV333736 PAGE. 3 OI? 6 Gcmwmmaafim_ I. The 'i‘rzmsfcr by the Payee m the 'l'ransl‘crcc and ils assignecs, 0F the 'l‘mnsl‘crrcd I’aynmnl(s), as defined below. is hereby APPROVED as provided in Section 1089.5 ufthc. Act. No approval is given as 10 lhc "l'rzmsfcr ofzmy other Structured Sclllcmcnl Payment Rights. Notwilhsmmling anything to the contrary elsewhere, only lhc following Annuity p:1ymcn11(s) (collectively, tin} “’l‘mnsfcrrcd Payment(s)"), m-wil: t Iii‘c-contingcnt monthly payments OFS4,038.60' each, beginning February 15, 2045 through and including, January I5. 2059, increasing 3.0% annually every January shall be sent by the Companies to {11c ’I‘mnsfcrcc at thc Following address: DRILB Capital, LLC, ALL. Dept f3 0200, PO Box 85000}, Orlando, FL 32885-0200. Thc monthly payments described by Transform: in lhcir Transfcr‘Agrccmcnt may vary from lhc actual monthly payments scheduled t0 be paid under the Annuity becausc of rounding. The Companies shall he entitled 10 round up or down within $1.00 for each payment as shall be. determined by the Companies Er: their sale discretion. 2. ’I‘ransf‘ercc and Payee, for themselves and. far their respective dimmers, shareholders, efficers, agents, employees, servants, successors, heirs, beneficiaries. contingent beneficiaries, executors, administrators, and assigns, and any parent, subsidiagy. or affiiiate thereof, anti their directors, shareholders, officers, agents, empleyees, servants. successors. and assigns. pasz and present (the “Reieasors‘fi, hereby remiss, miease‘ and forever discharge the Companies and thair respeciive directors, sharchclders, officsrs, agents; employees, servants. successors, and assign; and any parent, subsidiary, or affiliate thereof, and their directors, shareholders, efficers, agents. amploycca, servants, successors, and. assigns, past and present (the “Cumpanies Releasaes"). of and I 'E‘ranai‘eree refs renew the amount of the T‘rz:nalb11*enl ?ayn‘mm ta he $4,038.61 each month increasing 3 0% annually each January. However. the ncluui amount uvaflublc fur the Transferred Pnymenm is 31.038150 catch munth inereamng 3 0% afinu‘iiiy eat}, Janumj.‘ gm pnruea hereby agree 11nd llckumwleclge Um: lhu- actual.'E‘rmmfvrred ?uyment amounts rm: to be m the amount of $4,038.50 increuamg 33% annually each January. ORDER FOR APPROVAL FOR 'l’RANSFER 0F STRUCTURE!) SETI‘LEMEN'!‘ PAYMENT RIGii‘E'S C&Sli N0. IICVJSSVSQ PAGE 4 OF 6 QOGOMOKmh-«HN- Nmmmwmmmmflm ._+....- ......_...... From any and uli manner 0F aczions nnd causes 0f action, suits. debts. dues. accounts“ bands. covenants. contracts. agremncnl; judgments. scllluncnls. dmnugcs. claims‘ and demands whatsoever. in iuw or in equity. in connection with. refuted to. or arising out of any claim or allegation that was 0r could have bccn asserted in connection with, rciatcd t0, or arising out oi" the Transfer Agreement. the “[‘rzmsl‘crrcd Paymenfis), the Proposed 'I“ransfcr, any Rcassignmcm or the pfirtics‘ Stipulation. which the Releasors haw: or had from the beginning 0f lhc world through the dale m" this Order, except far claims ol‘ the: Relcasors against {he Companies Rcicasccs lo enforce Companies Releasccs‘ obligations to the Rclcamrs. il‘ any, under lhc partics‘ Stipulation and this Order. 3. Pursuant to the Act, to tho extent that the Transfer Agreement or any documents related to this transaction contain any of the prohibited previsions iistcd En §10138 of 11m Act, these provisions shall be void. €52. Pursuant ti} the Act, dESputes under the Transfer Agreement. including any cIaim that the Payee has breached the Transfer Agreement, shall be determined under the laws of this state, and neither the Transferee ner any other party is autherizcd w confessjudgmcnt er ccnscsm t0 entry ofjudgmcnt against Payee. S. Transferec and its successors anda’or assigns shad}. jointly and severally. defend. indemnify and hold harmless the Structured S’cttiemcnt Obligor and. the Annuity [s-suizr frOm any liability, including, without iimilatiom reasonable costs and armrrzcys‘ fees. arising from compliance by the: Companies with this Order or from any disclosures made in or related Lo this Order. 6. Pursuant t0 Insurance Code Section 13139.50). {he Court retains jurisdictiefl £0 interpret and monitor the implementation ol‘ the '1"r:msl'cr Agrccnwnt as justice requires. including the ncit paymcnz 0|” $80,732.45 by the ’I‘rmw‘sfcree to the Payee. ORDER FOR APPROVAL FOR TRANSFER OF S'i’RUCTURED SETTLEMENT l‘AYMEN’F RlG HTS CASE NO. 21C\"388?36 PACE 5 0|!" 6 OOWVOM&MN_ NNNNNNNNN__.___.._.____. °°\l0~U'-wa-o~ooo\xo\uu3>w~- 7. 26 usc §539L non. CTOPHEH G. RUDY” Dated lhis /6 This Order shall cnnslilulc a final “()uulil'lcd 0rdcr" within lhc meaning of day or 202 I. ORDER FOR APPROVAL FOR TRANSFER OI" S'l'RllC'l'URFJ) Sl-I'I'I‘IJ-IAIIZNI' PAYMENT RIGHTS CASE NO. 2|(‘\’3837Jb l'AGI". 6 0F 6 EXHIBIT A STIPULATION 0F THE PARTIES This stipulation ofthc parties (“Stipulation“) is cnlcrcd inlo :15 OFthis 16'“ day 0F December, 202]. by DRB Capital. LLC (“'l‘runsi‘crcc“), (“Assigncc”), LM. afkfa {rune Molina afk/u l. Molina afkfa h‘cnc N. Molina nfldu Irene Ncilu Molina (“l’z:ycc"),Willon Re Annuity Service Corporation 17km Transamcricn Annuity Service Corpuralion (“Structured Settlement Obligor"), as owner OFIhe structured settlement annuity No. 870972TOOIZ (the “Annuity“) 21nd 'I‘ransamcrica Lil‘c Insurance Company, successor by mcrgcr‘ with ’I‘ransamcrica‘ Occidental Life Insurance Company (“Annuity Issuer"), a3 issuer 0F the Annuity (the: Structured Settlement Obligor and Annuity Issuer arc semctimes callectiveiy referred {a as the “Cmnpanics“). RECI’I‘ALS WIrlEREAS, pursuant to California Insurance Code Sections § £0134, 6t seq. (the “Act"), this cause came before the Court upon the petition (the ”Petition" or the “‘Applicatien"), filed by counsel for Transferec, for Court approval of a Transfer of Structured Settlement Payment Rights of‘ the Payae to Transferee and its successors andfor assigns (the: “Transfer"); WHEREAS, the Companies have not objected to {he proposed Transfer; WHEREAS, the proposed Transfer, after a notice. hearing 21nd testimony by the Payee. either in' person, by affidavit, or telephonically, shall be approved in a final court order 0r order Ufa reaponsibie administrative authority (the ”Court”) based on express findings by such Ceurz‘ or rBSponsible administrative authority (the “Ordcr“); WHEREAS, unless otherwise defined herfiin, capitalized terms shall have the meanings set forth in the Act or the Order, as may be applicable. S'rwum'mow 0!? Tum: PARTIES Page 1 urs m, glmgsgm NOW THEREFORE, in consideration of the mutual covenants and promises herein contained, and for other good and valuable consideration, intending lo be legally bound hereby, the parties hereto stipulate and agree lo the following: I. The Recitals arc incorporated herein by reference and made a part oflhis Stipulation. 2. Payee and Transferee represent and warrant lo the Court and Companies that: A. Payee represents and warrants that, notwithstanding anything lo the contrary in the Petition or elsewhere, it has not transferred or assigned and shall not transfor or assign the Transferred Payment(s) to any other entity or person. ll. Transferee provided the Payee a written disclosure statement which meets all of the requirements prescribed by the Act. C. Prior lo the date set by the Court for the scheduled hearing on the Petition filed under the Act, the Transferee filed with the Court and served on all Interested Parties a noti.ce of the proposed Transfer and the Petition for its authorization, which included all of the requirements of the Act. D. The Payee has been advised in writing by the Transferee to seek independent professional advice regarding the Transfer and has either received such advice or has knowingly waived such advice in writing. E. The Payee has established that the Transfer is in the best interest of the Payee, taking into account the welfare and support of the Payee's Dependents, if any. F. The Transfer complies with the requirements of the Act, does not contravene any applicable federal or state statute or responsible administrative authority or other government authority and the Payee represents that the current transfer does not contravene any prior court orders. G. The Transfer Agreement does not authorize Transferee or any other party to confess judgment or consent to entry of judgment against Payee. H. Except as expressly provided for in this Stipulation, the Transferred Payment(s) are not subject to the claims of any person or entity. I. The Transferred Payment(s) being transferred have not been sold, pledged or alienated in any way and the Payee releases any and all STIPULATION OF THE PARTIES Pnge 2 of 8 NO. 2 t C\'388736 security interest that the Payee may have in the Transferred Paymcnt(s). J. Payee has con finned receipt of the disclosure statement, as evidenced by the Payee's signature on the copy or the disclosure statement. K. Payee is not required by u court order, judgment, or decree to pay child support or alimony. L. Payee has never filed or had filed against the Payee a petition in bankruptcy under the Federal Bankruptcy Code. 3. The Translcrcc and its successors, shall defend, indemnify and hold harmless (collectively, the "Indemnity") the Companies from any claims, liability or damages, including, but not limited to, reasonable costs and attorneys' fees, arising from or in connection with (a) any disclosures made in or related to this Stipulation or the Order; and (b) compliance by the Companies with this Stipulation and the Order. 4. In order to induce Companies to enter into this stipulation and accept Transferee's indemnification and hold harmless covenants contained herein, Transferee hereby represents that, as of this date: A. Transferee has members' equity in excess or thirty-five million dollars ($35,000,000) as evidenced by a report prepared by the nationally-recognized public accounting finn Grant Thornton LLP ("GT"). A copy of the report and GT's concurrence is attached as Exhibit "B." B. Transferee's financial statements are periodically audited by a nationally-recognized public accounting firm, which issues an unqualified opinion of such financial statements. GT provided an unqualified opinion of the most recent financial statements for the year ending in December 20 I 5. C. Transferee is a member in good standing of the National Association of Settlement Purchasers ("NASP") and is in material compliance with all NASP membership criteria and adheres to NASP's statement of best practices. D. Transferee has comprehensive commercial general liability insurance coverage of $1,000,000 per occurrence, $2,000,000 in the aggregate, with an excess umbrella of $5,000,000. STIPULATION OF TIIE PARTrns Page J of8 NO. 21CV388736 E. Transferee has fidelity inslitulion bond coverage of $1,000,000.00. F. Transferee has cybcr liability coverage of $1,000,000.00. G. Transferee has errors and omissions coverage of $1,000,000.00. H. Transl'crec is licensed/registered as a purchaser of structured settlement payments and in good standing in the Stale of West Virginia and the State of Maine. 5. Notwithstanding anything to the contrary elsewhere, disputes under the Transfer Agreement, including any claim that the Payee hus breached the Transfer Agreement, shall be determined under the laws of this stntc, and neither the Transferee nor any other party is authorized to confess judgment or consent to entry of judgment against Payee. 6. For good and valuable consideration, and intending to be legally bound hereby, Transferee and Payee, for themselves and for their respective directors, shareholders, officers, agents, employees, servants, successors, heirs, bencliciarics, contingent beneficiaries, executors, administrators, and assigns, and any parent, subsidiary, or affiliate thereof, and their directors, shareholders, officers, agents, employees, servants, successors, and assigns, past and present (the "Releasors"), hereby remise, release, and forever discharge the Companies and their respective directors, shareholders, officers, agents, employees, servants, successors, and assigns, and any parent, subsidiary, or affiliate thereof, and their directors, shareholders, officers, agents, employees, servants, successors, and assigns, past and present (the "Companies Releasees"), of and from any and all manner of actions and causes of action, suits, debts, dues, accounts, bonds, covenants, contracts, agreements, judgments, settlements, damages, claims, and demands whatsoever, in law or in equity, in connection with, related to, or arising out of, any claim or allegation that was or could have been asserted in connection with, related to, or arising out of the Transfer Agreement, the Transferred Payment(s), the Proposed Transfer, any Reassignment, or this Stipulation (including but not limited to the administrative fee referred to herein), which the Releasers have or had from the STIPULATION OFTIIE PARTIES Page 4 of8 NO. 21 CV388736 beginning of the world through the dale of this Stipulation, except for claims of the Releasors against the Companies Releasees to enforce the Companies Releasees' obligations to the Rcleasors, if any, under this Stipulation. 7. Compliance with the requirements and fulfillment of the conditions set forth in the Act and applicable law shall be solely the responsibility of the Transferee and its successors in the Transfer of the Transferred Paymcnt(s), and lhc Companies shall nol bear any responsibility for, or any liability arising from, non-compliance with those requirements or failure lo fulfill those requirements or conditions. Without limiting the foregoing, the Companies may rely on the entry of the Order in making the specified Transferred Payment(s). 8. The Companies are entering into this Stipulation strictly and solely in reliance upon the Court's approval and upon the representations, warranties and agreements of the Transferee, its successors, and Payee and any other person or entity signing hereunder, and only for the purpose of reflecting that the Companies have no objection to its terms, if approved by the Court at the hearing set for this matter. Further, each of the parties acknowledges that each has had the opportunity to participate in the preparation of this Stipulation and the Order and, as such, no rule of construction shall apply which might construe this Stipulation and/or the Order in favor of or against any party hereto. 9. The Transferee and its successors and the Payee agree that the terms of this Stipulation and the Order are based exclusively upon the facts, representations, and circumstances of this particular case. Nothing in this Stipulation or in the Order shall preclude the Companies from contesting any other proposed transfer of Structured Settlement payment rights, whether on the basis of applicable law, service of process or otherwise. The Order is to be entered without prejudice to the rights of the Companies, and without findings regarding the enforceability of any non-assignment provision(s) contained in the Structured Settlement Agreement or related STIPULATION 01<' THE PARTIES Page 5 of8 NO. 21 CV388736 documents; provided, however, that the Transfer of the Transferred Payment(s) shall be valid and enforceable against the parties hereto and their successors. Neither this Stipulation, the Order or the Companies' lack of opposition to this mi1ttcr, shall serve as precedent or evidence in any way nor be cited in any matter (except in connection with enforcement of the terms of this Stipulation and the Order). This Stipulation and the Order shall not constitute an admission or acknowledgement by the parties that the Uniform Commercial Code docs or does not apply to the transaction at issue. Nothing contained in this Stipulation or the Order shall be deemed to afford the Payee or the Transferee or its successors any rights of ownership or control of the Annuity or shall otherwise affect the exclusive ownership and control of the Annuity by the Structured Settlement Obligor. I 0. The Transferee requests that the Transferred Payment(s) be sent by the Companies to the address for the Transferee provided for in the Order (the "Designated Address"), or such other address as the Transferee or its successors may designate upon written notice to the Companies. Payee hereby consents to the Structured Settlement Obligor and Annuity Issuer making the Transferred Payment(s) payable to the Transferee or its successors. In no event shall the Companies be required to divide or split any of the Transferred Payment(s) between two or more transferees. Further, any such change of address by the Transferee of its rights to the Transferred Payment(s) shall in no way relieve the Transferee or its successor of their obligations hereunder. 11. Until Annuity Issuer has received and processed a fully-executed, certified or court filed-stamped copy of the Order and Stipulation, Annuity Issuer will continue to make the Transferred Payments to Payee. 12. Because the Companies are only obligated to make the Transferred Payment(s) if Payee is alive at the time each such payment becomes due, the Transferee shall provide written certification that Payee is still alive to the Annuity Issuer, as may be reasonably requested. Without limiting the foregoing, the Transferee shall provide the Annuity Issuer a quarterly certificate in STIPULATION OF TUE PARTIES Page 6 of8 NO. 21CV388736 January, April, July and October of each year, beginning on January I, 2045 confirming lhal Payee is alive. The Annuity Issuer agrees that satisfactory proof that the Payee is alive may, al the election of Lite Transferee, be provided by: (i) a search performed by a recognized search company (such as the Berwyn Group) that docs not produce a death certificate for the Payee or a response from the Social Security Administration, or any successor agency, either directly or through a recognized search company (such as the Berwyn Group) that there is no record of death of the Payee; or (ii) a statement from the Transferee that they have seen or spoken with the Payee and can thus confirm that the Payee is alive. The Trunsfcrcc and the Annuity Issuer shall provide written notice of Payee's death to each other immediately upon learning that Payee has died. In any event, any payments made by the Companies or their successors and/or assigns after the death of Payee shall be returned to the Companies by Transferee, and its successors and/or assigns. 13. This Stipulation and the Order shall be read in conjunction with the Prior Order(s) and the payments transferred as described in the Order shall be in addition to payments transferred pursuant to the Prior Order(s). I 4. The Transferee shall also pay or cause to be paid a $I, I 00.00 administrative fee to the Annuity Issuer in connection with its review and processing of the Petition. 15. This Stipulation is subject to approval by the Order of the Court. Counsel for the Transferee shall mail certified copies of the Order, including any exhibits and this Stipulation to the interested parties. This Stipulation may be executed in any number of counterparts, each of which, when executed and delivered shall be deemed to be an original, and all of which, when taken together, shall constitute one and the same. Signatures received by facsimile or telecopy shall be deemed originals. 16. The persons signing below represent and warrant that they have authority to execute this Stipulation. Such signatures shall be binding upon the parties and shall inure to the benefit of STIPULATION OF THE PARTIES Pngc 7 of8 NO. 21 CV388736 the £73115“ 110mm “mi ”“31" 1'931)‘?‘31"'° dmcmi‘fi‘ Shai'ChUMCI'S, of'l'iccrfi, agents. cn’lploycm. servants successors, heirs, executors. adn‘linisll‘amrs. and permitted assigns. IN WITNESS Wl-IEREOF, the parties have executed this Stipulation by their duly auihorizcd representatives. AGREED T0 IN FORM AND SUBSTANCE: AYE}; The undersigned have no obj cations to the foregoing: \ M ANNUITY ISSUER, by its authorized\ representative m. a/k/a Iréfie Mstilfa‘wE/a 1. Molina a/k/a Irene N. Molina afk/a Irene Neita Molina ’ 9395 Durango Lane! Gilroy, CA 95020 Rik' Forfferself LORI KRALL. Director 0f Wilton Reassurance Company TRANSFEREE, by their authorized Annuity Issuer’s attorncy-inwf‘act representative, STRUCTURE!) SETTLEMENT OBLIGOR, fjfi/mfl‘zfl-a by'its authorized representative, Name: Kurt Mandy I Title; Structured Associate Counsel ' CV9} LORI KRALL, Director STATE: OF CALIFORNIA COUNTY OR CITY OF On thisW day of" Lam", 202.1, [.M. a/kfr: Irene Molina. alkfa l. Molina aflda Irene N. Molina aIk/a Irene. Ncita M ling knewn to me t0 bc the person whose name is subscribed to this instrun’mnt, pcrseqai-iy appaarcd befhre me and acknowledged to me. that she has read this instrument and that the “mfirumcnt has been executed by her. Please 56‘s Mm Mi Notary Public srwludvrmw 0F 'I'HE mn'ruas Page 8. org 340. 21“”33’?” A notary public or other officer completlng this certificateverlfles only the Identity atthe Individual who signed the "document to which this certificate ls attached, and not the trummlness. accuracy. or validity of that dacument. State of California }County of Sanka (Luna 0n Dace Mar H: 2074 before me. (' \awfim E‘ (asfidfivw; Ndfirk 3492M Date Here InsertName and Titre af th‘eJOfi’Icler personally appeared Ivama M 0 Mina. W Name(s) ofSignerfs} who proved ta me on the basis of satisfaatory evidence to be the persanta) whose: name(s) isiau: subscribed to the within Instrument and acknowledged to me thatWshefthey executed the game in'his/her/thelr authcrlzed capacityfles). and that by Wherltheir signatures] an the anument the person(a), or the entity upon behaif of whlch the person(a) acted. executed the Instrument. t certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing gum“ E. gmlwfls paragraph ls true and correct. “fgéué’lgfa'fggfymh g WITNESS my hand and nfflcta! seal. Cammissiuri :‘r 2352350 My Comm. Expires Mar 20. 2025 ./Signature ?fl-J //:“WmW W Mace Notwy Sea! and/ar Stamp Above Signature of Natal]; Pubilc QPTIONAL Comp!eting this Information can deter alteration ofthe dacumenr ar fiaudulent reattachment 0f this farm rt) an unintended document vescrlptlon “Attached fiocumant Tltie 0r Typa of bacument: 34-1 WmLL‘on s. 09Mme ?flr Has DOCument aata: Decgmbflr‘ ‘VI ‘ ’20 ?4 \ Numbarafpages: :22: Signerts) Other Than Named Above: “m” Capacityues} Claimed by mamas). Signer’s Name: ”33m " " "M0“ ‘ mM u Corporate Officer - Titlets): m Partner -- U Limited m General Signer's Name: t1 Corporate Officer m Tlfle(s}: m ?armerm £11 Limited E3 Genera! fifitndivldual u Attorney 1n Fact t} individual n Attamey In Fact £3 Trustee [:1 Guardian or Cansemtor :1 Trustee [:5 Guardian or Conservator t: Other: m Other: signer is Representing: Signer Is Representing: '1.“ ||||||-'- k 'n n'S'o 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE I, FRANCESCA CASIQUE, hereby declare and state that: I am over the age of eighteen years, employed in the County of Sacramento, California, and not a party to the Within action. My business address is 1234 H Street, Suite 200, Sacramento, California. On December 20, 2021, I served the Within: NOTICE OF ENTRY OF ORDER ON PETITION FOR APPROVAL OF TRANSFER OF STRUCTURED SETTLEMENT PAYMENT RIGHTS on the following by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Payee: Annuity Issuer: Irene Molina Transamerica Life Insurance Company, 9395 Durango Lane successor by merger With Transamerica Gilroy, CA 95020 6400 C Street SW Cedar Rapids, IA 52499 Structured Settlement Coordinator Annuifl Obligor: Department 0f Justice Wilton Re Annuity Service Corporation California Attorney General’s Office 4840 N. River B1Vd., NE Suite 4 Attn: Consumer Law Section Cedar Rapids, IA 52411 455 Golden Gate Ave., #1 1000 San Francisco, CA 94102-7004 [X] (BY MAIL) I caused such envelopes With postage fully prepaid to be placed in the United States mail at Sacramento, California. [ ] (BY UNITED PARCEL SERVICE) I caused such envelope(s) to be placed in the UPS Express repository at Sacramento, California, Which provides for next business day delivery. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed December 20, 2021, at Sacramento, California. FRANCESCA CASIQUEU 2 NOTICE OF ENTRY OF ORDER ON PETITION FOR APPROVAL OF TRANSFER OF STRUCTURED SETTLEMENT PAYMENT RIGHTS