California Restaurants, Inc. vs. BoothMotion to Compel Answers to InterrogatoriesCal. Super. - 4th Dist.January 28, 201510 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CONTI LAW Alexander L. Conti, Bar No. 155945 23 Corporate Plaza, Suite 150 Newport Beach, CA 92660 Tel: (949) 791-8555 Fax: (949) 791-8556 Email: aconti@conti-law.com Attorneys for Plaintiffs California Restaurants, Inc. Citrus City Grille Corona Corp. and Steve Tsirtsis ELECTRONICALLY FILED Superior Court of California, County of Orange 0410/2017 at 03:00:00 AW Clerk of the Superior Court By Danielle Jurado, Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE CALIFORNIA RESTAURANTS, INC., a California Corporation, and CITRUS CITY GRILLE CORONA CORP., a California Corporation, STEVE TSIRTSIS, individually and derivatively on behalf of C.C.G. RIVERSIDE, INC. a dissolved California Corporation, Plaintiffs, V. THERESA CONSTANZA BOOTH, an incompetent, by her conservator JOHN S. TOOTLE, and DOES 1-50, inclusive, Defendants. Case No. 30-2015-00768529 Hon. Walter Schwarm Reservation No. 72566932 PLAINTIFFS’ NOTICE OF MOTION AND MOTION FOR ORDER COMPELLING DEFENDANT TO RESPOND TO FORM INTERROGATORIES; DECLARATION OF ALEXANDER L. CONTI, ESQ. Hearing Date: May 30, 2017 Time: 1:30 p.m. Dept.: C19 Trial Date: September 29, 2017 PLAINTIFFS’ MOTION FOR ORDER THAT MATTERS BE DEEMED ADMITTED 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TO THIS HONORABLE COURT AND ALL PARTIES OF RECORD: PLEASE TAKE NOTICE THAT on May 30, 2017 at 1:30 p.m. or as soon thereafter as the matter may be heard, in Department 19 of the above-referenced Court located at 700 Civic Center Drive West, Santa Ana, California, 92701, plaintiffs will and hereby do move this Court for the following relief: (1) An Order compelling defendant to answer plaintiffs’ form interrogatories, sets 3 and 4, without objection. This motion is made pursuant to §2030.290 of the Code of Civil Procedure and is based on this notice of motion and motion, the accompanying memorandum of points and authorities, the accompanying declaration of Alexander L. Conti, Esq., the entire record and file in the instant matter and on such other and further matters that are properly before the Court at the hearing on the motion. Dated: April 8, 2017 CONTI LAW wi 50 7 [1K Alexander L. Conti Attorneys for Plaintiffs California Restaurants Inc., Citrus City Grill Corona Corporation and Steve Tsirtsis, individually and derivatively on behalf of C.C.G. Riverside, Inc. 1- PLAINTIFFS’ MOTION FOR ORDER THAT MATTERS BE DEEMED ADMITTED 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MEMORANDUM OF POINTS AND AUTHORITIES L INTRODUCTION This case arises out of accounting errors made by defendant’s deceased spouse Martin Booth resulting in damages and losses to plaintiffs’ businesses. Plaintiffs served form interrogatories, set three, on defendant on November 13, 2015 and served form interrogatories, set four, on defendant on December 1, 2015. [See Exs. A, B, C, D, E, F, G and H to Conti Decl.] Each set of form interrogatories is limited to form interrogatory 17.1 pertaining to the contemporaneously served requests for admission. (Those requests for admission are the subject of plaintiffs’ motion to compel set for hearing on May 16, 2017.) Responses were due on December 18, 2015 and January 4, respectively. Defendant failed to respond. [See Conti Decl. at 49 1-9.] On January 6, 2017, David S. Chon, Esq., the personal representative of the estate of Theresa Constanza Booth, was substituted as the defendant in this case in place of Theresa Constanza Booth and her conservator John S. Tootle, Esq. [See Minute Order attached as Ex. I to Conti Decl.]. No response was received by plaintiffs’ counsel to telephone calls and emails to Mr. Chon. [Conti Decl. at q 11.] II. THIS COURT SHOULD ORDER DEFENDANT TO ANSWER THE FORM INTERROGATORIES WITHOUT OBJECTION If a party to whom interrogatories are directed fails to respond at all the propounding party's remedy is to seek a court order compelling answers to the interrogatories. Code Civ. Proc. §2030.290(b). Failing to respond within the time limit waives all objections, including objections based on privilege or on the protection based on attorney work product. Code Civ. Proc. §2030.290(a). For failure to respond there is no requirement to meet and confer prior to filing a motion to compel. See Code Civ. Proc. §2030.290. The motion to compel may be heard even if tardy responses are served after the motion is filed. See Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 CA4th 390, 404. Unless the propounding party takes the matter off calendar, the court may determine whether the responses are legally sufficient and award sanctions for the failure to respond on time. Id. Here, defendant failed to respond to plaintiffs’ form interrogatories and waived all objections, including objections based on privilege and work product. The Court, therefore, should issue an Order directing defendant to answer all form interrogatories without objection. 2 PLAINTIFFS’ MOTION FOR ORDER THAT MATTERS BE DEEMED ADMITTED x 9 O 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 III. CONCLUSION Plaintiffs respectfully request that this Court grant this motion to compel and issue an Order directing defendant to answer the form interrogatories without objection. Dated: April 8, 2017 CONTI LAW By: AY ! 7 lout Alexander L. Conti Attorneys for Plaintiffs California Restaurants Inc., Citrus City Grill Corona Corporation and Steve Tsirtsis 3 PLAINTIFFS’ MOTION FOR ORDER THAT MATTERS BE DEEMED ADMITTED 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF ALEXANDER L. CONTI, ESQ. I, Alexander L. Conti, declare: I. am an attorney at law licensed to practice before all courts of the State of California and I am counsel for plaintiffs in this civil action. I have personal knowledge of the facts set forth in this declaration. 2. Attached to my declaration as exhibit A is a true and correct copy of plaintiff California Restaurants, Inc.’s form interrogatories, set three, to defendant served by mail on November 13, 2015. Responses were due on December 18, 2015 and no responses were received. 3. Attached to my declaration as exhibit B is a true and correct copy of plaintiff Citrus City Grille Corona Corp.’s form interrogatories, set three, to defendant served by mail on November 13, 2015. Responses were due on December 18, 2015 and no responses were received. 4. Attached to my declaration as exhibit C is a true and correct copy of plaintiff C.C.G. Riverside, Inc.’s form interrogatories, set three, to defendant served by mail on November 13, 2015. Responses were due on December 18, 2015 and no responses were received. 5. Attached to my declaration as exhibit D is a true and correct copy of the proof of service of form interrogatories, set three. 6. Attached to my declaration as exhibit E is a true and correct copy of plaintiff California Restaurants, Inc.’s form interrogatories, set four, to defendant served by mail on December 1, 2015. Responses were due on January 4, 2016 and no responses were received. I Attached to my declaration as exhibit F is a true and correct copy of plaintiff Citrus City Grille Corona Corp.’s form interrogatories, set four, to defendant served by mail on December 1, 2015. Responses were due on January 4, 2016 and no responses were received. 8. Attached to my declaration as exhibit G is a true and correct copy of plaintiff C.C.G. Riverside, Inc.’s form interrogatories, set four, to defendant served by mail on December 1, 2015. Responses were due on January 4, 2016 and no responses were received. 9. Attached to my declaration as exhibit H is a true and correct copy of the proof of service of form interrogatories, set four. 10. Attached to my declaration as exhibit I is a true and correct copy of the Court’s Minute Order of January 6, 2017. 4 PLAINTIFFS’ MOTION FOR ORDER THAT MATTERS BE DEEMED ADMITTED © NN S O 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 11, I telephoned and emailed counsel for defendant several times after January 6, 2017 to discuss the case but never received a response. I declare under penalty of perjury under the laws of the state of California that the foregoing is true and correct. Executed Saturday, April 08, 2017 at Newport Beach, California. Alexander L. Conti 252 PLAINTIFFS’ MOTION FOR ORDER THAT MATTERS BE DEEMED ADMITTED EXHIBIT A DISC-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Alexander L. Conti, Esq. (#155945) | CONTILAW 23 Corporate Plaza, Suite 150 Newport Beach, CA 92660 TELEPHONE NO.: 949-791-8555 FAX NO. (Optional): 949-791-8556 E-MAIL ADDRESS (Optional): aconti @conti-law.com ATTORNEY FOR (Name): Plaintiffs SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE SHORT TITLE OF CASE: California Restaurants, Inc. et al. v. Booth Asking Party: California Restaurants, Inc. Set No.: Three FORM INTERROGATORIES— GENERAL Answering Party: Theresa Booth by her Conservator John Tootle CASE NUMBER: 30-2015-00768529 Sec. 1. Instructions to All Parties (a) Interrogatories are written questions prepared by a party to an action that are sent to any other party in the action to be answered under oath. The interrogatories below are form interrogatories approved for use in civil cases. (b) For time limitations, requirements for service on other parties, and other details, see Code of Civil Procedure sections 2030.010-2030.410 and the cases construing those sections. (c) These form interrogatories do not change existing law relating to interrogatories nor do they affect an answering party's right to assert any privilege or make any objection. Sec. 2. Instructions to the Asking Party (a) These interrogatories are designed for optional use by parties in unlimited civil cases where the amount demanded exceeds $25,000. Separate interrogatories, Form Interrogatories— Limited Civil Cases (Economic Litigation) (form DISC-004), which have no subparts, are designed for use in limited civil cases where the amount demanded is $25,000 or less; however, those interrogatories may also be used in unlimited civil cases. (b) Check the box next to each interrogatory that you want the answering party to answer. Use care in choosing those interrogatories that are applicable to the case. (c) You may insert your own definition of INCIDENT in Section 4, but only where the action arises from a course of conduct or a series of events occurring over a period of time. (d) The interrogatories in section 16.0, Defendant's Contentions-Personal Injury, should not be used until the defendant has had a reasonable opportunity to conduct an investigation or discovery of plaintiff's injuries and damages. (e) Additional interrogatories may be attached. Sec. 3. Instructions to the Answering Party (a) An answer or other appropriate response must be given to each interrogatory checked by the asking party. (b) As a general rule, within 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. See Code of Civil Procedure sections 2030.260-2030.270 for details. (c) Each answer mustbe as complete and straightforward as the information reasonably available to you, including the information possessed by your attorneys or agents, 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 to 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. (9) Ifyou are asserting a privilege or making an objection to an interrogatory, you must specifically assert the privilege or state the objection in your written response. (h) Your answers to these interrogatories must be verified, dated, and signed. You may wish to use the following form at the end of your answers: I declare under penalty of perjury under the laws of the State of California that the foregoing answers are true and correct. (DATE) (SIGNATURE) Sec. 4. Definitions Words in BOLDFACE CAPITALS in these interrogatories are defined as follows: (a) (Check one of the following): [1 (1) INCIDENT includes the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding. Page 1 of 8 Form Approved for Optional Use J udicial Council of California DISC-001 [Rev. ] anuary 1, 2008] FORM INTERROGATORIES— GENERAL Code of Civil Procedure, §§ 2030.010-2030.410, 2033.710 www.courtinfo.ca.gov [] 16.3 Do you contend that the injuries or the extent of the injuries claimed by plaintiff as disclosed in discovery proceedings thus far in this case were not caused by the INCIDENT? If so, for each injury: (a) identify it; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [ ]16.4 Do you contend that any of the services furnished by any HEALTH CARE PROVIDER claimed by plaintiff in discovery proceedings thus far in this case were not due to the INCIDENT? If so: (a) identify each service; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [1165 Do you contend that any of the costs of services furnished by any HEALTH CARE PROVIDER claimed as damages by plaintiff in discovery proceedings thus far in this case were not necessary or unreasonable? If so: (a) identify each cost; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [] 16.6 Do you contend that any part of the loss of earnings or income claimed by plaintiff in discovery proceedings thus far in this case was unreasonable or was not caused by the INCIDENT? If so: (a) identify each part of the loss; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [ ]16.7 Do you contend that any of the property damage claimed by plaintiff in discovery Proceedings thus far in this case was not caused by the INCIDENT? If so: (a) identify each item of property damage; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. DISC-001 [] 16.8 Do you contend that any of the costs of repairing the property damage claimed by plaintiff in discovery proceedings thus far in this case were unreasonable? If so: (a) identify each cost item; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 1] 16.9 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT (for example, insurance bureau index reports) concerning claims for personal injuries made before or after the INCIDENT by a plaintiff in this case? If so, for each plaintiff state: (a) the source of each DOCUMENT; ) the date each claim arose; ) the nature of each claim; and ) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. (b (c (d 16.10 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT concerning the past or present physical, mental, or emotional condition of any plaintiff in this case from a HEALTH CARE PROVIDER not previously identified (except for expert witnesses covered by Code of Civil Procedure sections 2034.210-2034.310)? If so, for each plaintiff state: (a) the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER; (b) a description of each DOCUMENT; and (c) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. 17.0 Responses to Request for Admissions 17.1 Is your response to each request for admission served with these interrogatories an unqualified admission? If not, for each response that is notan unqualified admission: (a) state the number of the request; (b) state all facts upon which you base your response; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of those facts; and (d) identify all DOCUMENTS and other tangible things that support your response and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 18.0 [Reserved] 19.0 [Reserved] 20.0 How the Incident Occurred— Motor Vehicle [] 20.1 State the date, time, and place of the INCIDENT (closest street ADDRESS or intersection). [] 20.2 For each vehicle involved in the INCIDENT, state: (a) the year, make, model, and license number; (b) the name, ADDRESS, and telephone number of the driver; DISC-001 [Rev. January 1, 2008] FORM INTERROGATORIES— GENERAL Page 7 of 8 EXHIBIT B DISC-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Alexander L. Conti, Esq. (#155945) | CONTILAW 23 Corporate Plaza, Suite 150 Newport Beach, CA 92660 TELEPHONE NO.: 949-791-8555 FAX NO. (Optional): 949-791-8556 E-MAIL ADDRESS (Optional): aconti @conti-law.com ATTORNEY FOR (Name): Plaintiffs SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE SHORT TITLE OF CASE: California Restaurants, Inc. et al. v. Booth Asking Party: Citrus City Grille Corona Corp. Set No.: Three FORM INTERROGATORIES— GENERAL Answering Party: Theresa Booth by her Conservator John Tootle CASE NUMBER: 30-2015-00768529 Sec. 1. Instructions to All Parties (a) Interrogatories are written questions prepared by a party to an action that are sent to any other party in the action to be answered under oath. The interrogatories below are form interrogatories approved for use in civil cases. (b) For time limitations, requirements for service on other parties, and other details, see Code of Civil Procedure sections 2030.010-2030.410 and the cases construing those sections. (c) These form interrogatories do not change existing law relating to interrogatories nor do they affect an answering party's right to assert any privilege or make any objection. Sec. 2. Instructions to the Asking Party (a) These interrogatories are designed for optional use by parties in unlimited civil cases where the amount demanded exceeds $25,000. Separate interrogatories, Form Interrogatories— Limited Civil Cases (Economic Litigation) (form DISC-004), which have no subparts, are designed for use in limited civil cases where the amount demanded is $25,000 or less; however, those interrogatories may also be used in unlimited civil cases. (b) Check the box next to each interrogatory that you want the answering party to answer. Use care in choosing those interrogatories that are applicable to the case. (c) You may insert your own definition of INCIDENT in Section 4, but only where the action arises from a course of conduct or a series of events occurring over a period of time. (d) The interrogatories in section 16.0, Defendant's Contentions-Personal Injury, should not be used until the defendant has had a reasonable opportunity to conduct an investigation or discovery of plaintiff's injuries and damages. (e) Additional interrogatories may be attached. Sec. 3. Instructions to the Answering Party (a) An answer or other appropriate response must be given to each interrogatory checked by the asking party. (b) As a general rule, within 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. See Code of Civil Procedure sections 2030.260-2030.270 for details. (c) Each answer mustbe as complete and straightforward as the information reasonably available to you, including the information possessed by your attorneys or agents, 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 to 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. (9) Ifyou are asserting a privilege or making an objection to an interrogatory, you must specifically assert the privilege or state the objection in your written response. (h) Your answers to these interrogatories must be verified, dated, and signed. You may wish to use the following form at the end of your answers: I declare under penalty of perjury under the laws of the State of California that the foregoing answers are true and correct. (DATE) (SIGNATURE) Sec. 4. Definitions Words in BOLDFACE CAPITALS in these interrogatories are defined as follows: (a) (Check one of the following): [1 (1) INCIDENT includes the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding. Page 1 of 8 Form Approved for Optional Use J udicial Council of California DISC-001 [Rev. ] anuary 1, 2008] FORM INTERROGATORIES— GENERAL Code of Civil Procedure, §§ 2030.010-2030.410, 2033.710 www.courtinfo.ca.gov [] 16.3 Do you contend that the injuries or the extent of the injuries claimed by plaintiff as disclosed in discovery proceedings thus far in this case were not caused by the INCIDENT? If so, for each injury: (a) identify it; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [ ]16.4 Do you contend that any of the services furnished by any HEALTH CARE PROVIDER claimed by plaintiff in discovery proceedings thus far in this case were not due to the INCIDENT? If so: (a) identify each service; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [1165 Do you contend that any of the costs of services furnished by any HEALTH CARE PROVIDER claimed as damages by plaintiff in discovery proceedings thus far in this case were not necessary or unreasonable? If so: (a) identify each cost; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [] 16.6 Do you contend that any part of the loss of earnings or income claimed by plaintiff in discovery proceedings thus far in this case was unreasonable or was not caused by the INCIDENT? If so: (a) identify each part of the loss; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [ ]16.7 Do you contend that any of the property damage claimed by plaintiff in discovery Proceedings thus far in this case was not caused by the INCIDENT? If so: (a) identify each item of property damage; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. DISC-001 [] 16.8 Do you contend that any of the costs of repairing the property damage claimed by plaintiff in discovery proceedings thus far in this case were unreasonable? If so: (a) identify each cost item; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 1] 16.9 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT (for example, insurance bureau index reports) concerning claims for personal injuries made before or after the INCIDENT by a plaintiff in this case? If so, for each plaintiff state: (a) the source of each DOCUMENT; ) the date each claim arose; ) the nature of each claim; and ) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. (b (c (d 16.10 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT concerning the past or present physical, mental, or emotional condition of any plaintiff in this case from a HEALTH CARE PROVIDER not previously identified (except for expert witnesses covered by Code of Civil Procedure sections 2034.210-2034.310)? If so, for each plaintiff state: (a) the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER; (b) a description of each DOCUMENT; and (c) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. 17.0 Responses to Request for Admissions 17.1 Is your response to each request for admission served with these interrogatories an unqualified admission? If not, for each response that is notan unqualified admission: (a) state the number of the request; (b) state all facts upon which you base your response; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of those facts; and (d) identify all DOCUMENTS and other tangible things that support your response and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 18.0 [Reserved] 19.0 [Reserved] 20.0 How the Incident Occurred— Motor Vehicle [] 20.1 State the date, time, and place of the INCIDENT (closest street ADDRESS or intersection). [] 20.2 For each vehicle involved in the INCIDENT, state: (a) the year, make, model, and license number; (b) the name, ADDRESS, and telephone number of the driver; DISC-001 [Rev. January 1, 2008] FORM INTERROGATORIES— GENERAL Page 7 of 8 EXHIBIT C DISC-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Alexander L. Conti, Esq. (#155945) | CONTILAW 23 Corporate Plaza, Suite 150 Newport Beach, CA 92660 TELEPHONE NO.: 949-791-8555 FAX NO. (Optional): 949-791-8556 E-MAIL ADDRESS (Optional): aconti @conti-law.com ATTORNEY FOR (Name): Plaintiffs SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE SHORT TITLE OF CASE: California Restaurants, Inc. et al. v. Booth Asking Party: C. C. G. Riverside, Inc. Set No.: Three FORM INTERROGATORIES— GENERAL Answering Party: Theresa Booth by her Conservator John Tootle CASE NUMBER: 30-2015-00768529 Sec. 1. Instructions to All Parties (a) Interrogatories are written questions prepared by a party to an action that are sent to any other party in the action to be answered under oath. The interrogatories below are form interrogatories approved for use in civil cases. (b) For time limitations, requirements for service on other parties, and other details, see Code of Civil Procedure sections 2030.010-2030.410 and the cases construing those sections. (c) These form interrogatories do not change existing law relating to interrogatories nor do they affect an answering party's right to assert any privilege or make any objection. Sec. 2. Instructions to the Asking Party (a) These interrogatories are designed for optional use by parties in unlimited civil cases where the amount demanded exceeds $25,000. Separate interrogatories, Form Interrogatories— Limited Civil Cases (Economic Litigation) (form DISC-004), which have no subparts, are designed for use in limited civil cases where the amount demanded is $25,000 or less; however, those interrogatories may also be used in unlimited civil cases. (b) Check the box next to each interrogatory that you want the answering party to answer. Use care in choosing those interrogatories that are applicable to the case. (c) You may insert your own definition of INCIDENT in Section 4, but only where the action arises from a course of conduct or a series of events occurring over a period of time. (d) The interrogatories in section 16.0, Defendant's Contentions-Personal Injury, should not be used until the defendant has had a reasonable opportunity to conduct an investigation or discovery of plaintiff's injuries and damages. (e) Additional interrogatories may be attached. Sec. 3. Instructions to the Answering Party (a) An answer or other appropriate response must be given to each interrogatory checked by the asking party. (b) As a general rule, within 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. See Code of Civil Procedure sections 2030.260-2030.270 for details. (c) Each answer mustbe as complete and straightforward as the information reasonably available to you, including the information possessed by your attorneys or agents, 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 to 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. (9) Ifyou are asserting a privilege or making an objection to an interrogatory, you must specifically assert the privilege or state the objection in your written response. (h) Your answers to these interrogatories must be verified, dated, and signed. You may wish to use the following form at the end of your answers: I declare under penalty of perjury under the laws of the State of California that the foregoing answers are true and correct. (DATE) (SIGNATURE) Sec. 4. Definitions Words in BOLDFACE CAPITALS in these interrogatories are defined as follows: (a) (Check one of the following): [1 (1) INCIDENT includes the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding. Page 1 of 8 Form Approved for Optional Use J udicial Council of California DISC-001 [Rev. ] anuary 1, 2008] FORM INTERROGATORIES— GENERAL Code of Civil Procedure, §§ 2030.010-2030.410, 2033.710 www.courtinfo.ca.gov [] 16.3 Do you contend that the injuries or the extent of the injuries claimed by plaintiff as disclosed in discovery proceedings thus far in this case were not caused by the INCIDENT? If so, for each injury: (a) identify it; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [ ]16.4 Do you contend that any of the services furnished by any HEALTH CARE PROVIDER claimed by plaintiff in discovery proceedings thus far in this case were not due to the INCIDENT? If so: (a) identify each service; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [1165 Do you contend that any of the costs of services furnished by any HEALTH CARE PROVIDER claimed as damages by plaintiff in discovery proceedings thus far in this case were not necessary or unreasonable? If so: (a) identify each cost; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [] 16.6 Do you contend that any part of the loss of earnings or income claimed by plaintiff in discovery proceedings thus far in this case was unreasonable or was not caused by the INCIDENT? If so: (a) identify each part of the loss; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [ ]16.7 Do you contend that any of the property damage claimed by plaintiff in discovery Proceedings thus far in this case was not caused by the INCIDENT? If so: (a) identify each item of property damage; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. DISC-001 [] 16.8 Do you contend that any of the costs of repairing the property damage claimed by plaintiff in discovery proceedings thus far in this case were unreasonable? If so: (a) identify each cost item; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 1] 16.9 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT (for example, insurance bureau index reports) concerning claims for personal injuries made before or after the INCIDENT by a plaintiff in this case? If so, for each plaintiff state: (a) the source of each DOCUMENT; ) the date each claim arose; ) the nature of each claim; and ) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. (b (c (d 16.10 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT concerning the past or present physical, mental, or emotional condition of any plaintiff in this case from a HEALTH CARE PROVIDER not previously identified (except for expert witnesses covered by Code of Civil Procedure sections 2034.210-2034.310)? If so, for each plaintiff state: (a) the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER; (b) a description of each DOCUMENT; and (c) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. 17.0 Responses to Request for Admissions 17.1 Is your response to each request for admission served with these interrogatories an unqualified admission? If not, for each response that is notan unqualified admission: (a) state the number of the request; (b) state all facts upon which you base your response; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of those facts; and (d) identify all DOCUMENTS and other tangible things that support your response and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 18.0 [Reserved] 19.0 [Reserved] 20.0 How the Incident Occurred— Motor Vehicle [] 20.1 State the date, time, and place of the INCIDENT (closest street ADDRESS or intersection). [] 20.2 For each vehicle involved in the INCIDENT, state: (a) the year, make, model, and license number; (b) the name, ADDRESS, and telephone number of the driver; DISC-001 [Rev. January 1, 2008] FORM INTERROGATORIES— GENERAL Page 7 of 8 EXHIBIT D 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CONTI LAW Alexander L. Conti, Bar No. 155945 23 Corporate Plaza, Suite 150 Newport Beach, CA 92660 Tel: (949) 791-8555 Fax: (949) 791-8556 Email: aconti@conti-law.com Attorneys for Plaintiffs California Restaurants, Inc. Citrus City Grille Corona Corp. and Steve Tsirtsis SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE CALIFORNIA RESTAURANTS, INC, a Case No. 30-2015-000768529 California Corporation, and CITRUS CITY GRILLE CORONA CORP., a California ASSIGNED FOR ALL PURPOSES TO: Corporation, STEVE TSIRTSIS, derivatively on behalf of C.C.G. RIVERSIDE, INC. a dissolved | Hon. David T. MacEachen California Corporation, Plaintiffs, V. THERESA CONSTANZA BOOTH, an incompetent, by her conservator JOHN S. TOOTLE, and DOES 1-50, inclusive, Defendants. PROOF OF SERVICE PROOF OF SERVICE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF ORANGE I am employed in the County of Orange, State of California. I am over the age of 18 and not a party to the within action; my business address is Conti Law 23 Corporate Plaza, Suite 150 Newport Beach, CA 92660. On November 13, 2015, I served the foregoing document described as: FORM INTERROGATORIES, SET THREE on the following person(s) who is counsel for Defendant and Cross-Complainant in this case in the manner indicated: Jeffrey L. Malek John S. Tootle, Esq. David C. Chang LAW OFFICE OF JOHN S. TOOTLE MALEK & MALEK 777 Silver Spur Drive, Suite 102 3625 Del Amo Boulevard, Suite 350 Pasadena, California 90274 Torrance, California 90503 Email:johntootlelaw@gmail.com Facsimile: 310-371-7242 [X ] (BY MAIL) I am familiar with the practice of Conti Law for collection and processing of correspondence for mailing with the United States Postal Service. Correspondence so collected and processed is deposited with the United States Postal Service that same day in the ordinary course of business. On this date, a copy of said document was placed in a sealed envelope, with postage fully prepaid, addressed as set forth herein, and such envelope was placed for collection and mailing at Conti Law, Newport Beach, California, following ordinary business practices. [ 1] (BY OVERNIGHT MAIL) I am familiar with the practice of Conti Law for collection and processing of correspondence for delivery by overnight courier. Correspondence so collected and processed is deposited in a box or other facility regularly maintained by FedEx/Overnite Express that same day in the ordinary course of business. On this date, a copy of said document was placed in a sealed envelope designated by FedEx/Overnite Express with delivery fees paid or provided for, addressed as set forth herein, and such envelope was placed for delivery by FedEx/Overnite Express at Conti Law, Newport Beach, California, following ordinary business practices. [ 1 (BY FACSIMILE TRANSMISSION) On this date, at the time indicated on the transmittal sheet, attached hereto, I transmitted from a facsimile transmission machine, which telephone number is (949) 791-8556, the document described above and an unsigned copy of this declaration to the person, and at the facsimile transmission telephone numbers, set forth herein. The above-described transmission was reported as complete and without error by a properly issued transmission report issued by the facsimile transmission machine upon which the said transmission was made immediately following the transmission. [ X 1] (BY ELECTRONIC MAIL) (BY ELECTRONIC MAIL) On this date, pursuant to Rule 2.251 of the California Rules of Court, I caused a copy of said document to be transmitted via electronic mail to the e-mail addresses listed on the attached service list from my email address of aconti@conti- law.com at approximately 2:01 PM. [ 1 (BY HAND DELIVERY) I served the documents by providing them to Nationwide ASAP courier service for hand delivery. A separate proof of service will be prepared by the courier. I 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 November 13, 2015, at Newport Beach, California. Alexander L. Conti Alexander L. Conti 1- PROOF OF SERVICE EXHIBIT E DISC-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Alexander L. Conti, Esq. (#155945) | CONTILAW 23 Corporate Plaza, Suite 150 Newport Beach, CA 92660 TELEPHONE NO.: 949-791-8555 FAX NO. (Optional): 949-791-8556 E-MAIL ADDRESS (Optional): aconti @conti-law.com ATTORNEY FOR (Name): Plaintiffs SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE SHORT TITLE OF CASE: California Restaurants, Inc. et al. v. Booth Asking Party: California Restaurants, Inc. Set No.: KEXX Four FORM INTERROGATORIES— GENERAL Answering Party: Theresa Booth by her Conservator John Tootle CASE NUMBER: 30-2015-00768529 Sec. 1. Instructions to All Parties (a) Interrogatories are written questions prepared by a party to an action that are sent to any other party in the action to be answered under oath. The interrogatories below are form interrogatories approved for use in civil cases. (b) For time limitations, requirements for service on other parties, and other details, see Code of Civil Procedure sections 2030.010-2030.410 and the cases construing those sections. (c) These form interrogatories do not change existing law relating to interrogatories nor do they affect an answering party's right to assert any privilege or make any objection. Sec. 2. Instructions to the Asking Party (a) These interrogatories are designed for optional use by parties in unlimited civil cases where the amount demanded exceeds $25,000. Separate interrogatories, Form Interrogatories— Limited Civil Cases (Economic Litigation) (form DISC-004), which have no subparts, are designed for use in limited civil cases where the amount demanded is $25,000 or less; however, those interrogatories may also be used in unlimited civil cases. (b) Check the box next to each interrogatory that you want the answering party to answer. Use care in choosing those interrogatories that are applicable to the case. (c) You may insert your own definition of INCIDENT in Section 4, but only where the action arises from a course of conduct or a series of events occurring over a period of time. (d) The interrogatories in section 16.0, Defendant's Contentions-Personal Injury, should not be used until the defendant has had a reasonable opportunity to conduct an investigation or discovery of plaintiff's injuries and damages. (e) Additional interrogatories may be attached. Sec. 3. Instructions to the Answering Party (a) An answer or other appropriate response must be given to each interrogatory checked by the asking party. (b) As a general rule, within 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. See Code of Civil Procedure sections 2030.260-2030.270 for details. (c) Each answer mustbe as complete and straightforward as the information reasonably available to you, including the information possessed by your attorneys or agents, 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 to 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. (9) Ifyou are asserting a privilege or making an objection to an interrogatory, you must specifically assert the privilege or state the objection in your written response. (h) Your answers to these interrogatories must be verified, dated, and signed. You may wish to use the following form at the end of your answers: I declare under penalty of perjury under the laws of the State of California that the foregoing answers are true and correct. (DATE) (SIGNATURE) Sec. 4. Definitions Words in BOLDFACE CAPITALS in these interrogatories are defined as follows: (a) (Check one of the following): [1 (1) INCIDENT includes the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding. Page 1 of 8 Form Approved for Optional Use J udicial Council of California DISC-001 [Rev. ] anuary 1, 2008] FORM INTERROGATORIES— GENERAL Code of Civil Procedure, §§ 2030.010-2030.410, 2033.710 www.courtinfo.ca.gov [] 16.3 Do you contend that the injuries or the extent of the injuries claimed by plaintiff as disclosed in discovery proceedings thus far in this case were not caused by the INCIDENT? If so, for each injury: (a) identify it; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [ ]16.4 Do you contend that any of the services furnished by any HEALTH CARE PROVIDER claimed by plaintiff in discovery proceedings thus far in this case were not due to the INCIDENT? If so: (a) identify each service; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [1165 Do you contend that any of the costs of services furnished by any HEALTH CARE PROVIDER claimed as damages by plaintiff in discovery proceedings thus far in this case were not necessary or unreasonable? If so: (a) identify each cost; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [] 16.6 Do you contend that any part of the loss of earnings or income claimed by plaintiff in discovery proceedings thus far in this case was unreasonable or was not caused by the INCIDENT? If so: (a) identify each part of the loss; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [ ]16.7 Do you contend that any of the property damage claimed by plaintiff in discovery Proceedings thus far in this case was not caused by the INCIDENT? If so: (a) identify each item of property damage; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. DISC-001 [] 16.8 Do you contend that any of the costs of repairing the property damage claimed by plaintiff in discovery proceedings thus far in this case were unreasonable? If so: (a) identify each cost item; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 1] 16.9 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT (for example, insurance bureau index reports) concerning claims for personal injuries made before or after the INCIDENT by a plaintiff in this case? If so, for each plaintiff state: (a) the source of each DOCUMENT; ) the date each claim arose; ) the nature of each claim; and ) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. (b (c (d 16.10 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT concerning the past or present physical, mental, or emotional condition of any plaintiff in this case from a HEALTH CARE PROVIDER not previously identified (except for expert witnesses covered by Code of Civil Procedure sections 2034.210-2034.310)? If so, for each plaintiff state: (a) the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER; (b) a description of each DOCUMENT; and (c) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. 17.0 Responses to Request for Admissions 17.1 Is your response to each request for admission served with these interrogatories an unqualified admission? If not, for each response that is notan unqualified admission: (a) state the number of the request; (b) state all facts upon which you base your response; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of those facts; and (d) identify all DOCUMENTS and other tangible things that support your response and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 18.0 [Reserved] 19.0 [Reserved] 20.0 How the Incident Occurred— Motor Vehicle [] 20.1 State the date, time, and place of the INCIDENT (closest street ADDRESS or intersection). [] 20.2 For each vehicle involved in the INCIDENT, state: (a) the year, make, model, and license number; (b) the name, ADDRESS, and telephone number of the driver; DISC-001 [Rev. January 1, 2008] FORM INTERROGATORIES— GENERAL Page 7 of 8 EXHIBIT F DISC-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Alexander L. Conti, Esq. (#155945) | CONTILAW 23 Corporate Plaza, Suite 150 Newport Beach, CA 92660 TELEPHONE NO.: 949-791-8555 FAX NO. (Optional): 949-791-8556 E-MAIL ADDRESS (Optional): aconti @conti-law.com ATTORNEY FOR (Name): Plaintiffs SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE SHORT TITLE OF CASE: California Restaurants, Inc. et al. v. Booth Asking Party: Citrus City Grille Corona Corp. Set No.: RIX¥XX Four FORM INTERROGATORIES— GENERAL Answering Party: Theresa Booth by her Conservator John Tootle CASE NUMBER: 30-2015-00768529 Sec. 1. Instructions to All Parties (a) Interrogatories are written questions prepared by a party to an action that are sent to any other party in the action to be answered under oath. The interrogatories below are form interrogatories approved for use in civil cases. (b) For time limitations, requirements for service on other parties, and other details, see Code of Civil Procedure sections 2030.010-2030.410 and the cases construing those sections. (c) These form interrogatories do not change existing law relating to interrogatories nor do they affect an answering party's right to assert any privilege or make any objection. Sec. 2. Instructions to the Asking Party (a) These interrogatories are designed for optional use by parties in unlimited civil cases where the amount demanded exceeds $25,000. Separate interrogatories, Form Interrogatories— Limited Civil Cases (Economic Litigation) (form DISC-004), which have no subparts, are designed for use in limited civil cases where the amount demanded is $25,000 or less; however, those interrogatories may also be used in unlimited civil cases. (b) Check the box next to each interrogatory that you want the answering party to answer. Use care in choosing those interrogatories that are applicable to the case. (c) You may insert your own definition of INCIDENT in Section 4, but only where the action arises from a course of conduct or a series of events occurring over a period of time. (d) The interrogatories in section 16.0, Defendant's Contentions-Personal Injury, should not be used until the defendant has had a reasonable opportunity to conduct an investigation or discovery of plaintiff's injuries and damages. (e) Additional interrogatories may be attached. Sec. 3. Instructions to the Answering Party (a) An answer or other appropriate response must be given to each interrogatory checked by the asking party. (b) As a general rule, within 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. See Code of Civil Procedure sections 2030.260-2030.270 for details. (c) Each answer mustbe as complete and straightforward as the information reasonably available to you, including the information possessed by your attorneys or agents, 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 to 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. (9) Ifyou are asserting a privilege or making an objection to an interrogatory, you must specifically assert the privilege or state the objection in your written response. (h) Your answers to these interrogatories must be verified, dated, and signed. You may wish to use the following form at the end of your answers: I declare under penalty of perjury under the laws of the State of California that the foregoing answers are true and correct. (DATE) (SIGNATURE) Sec. 4. Definitions Words in BOLDFACE CAPITALS in these interrogatories are defined as follows: (a) (Check one of the following): [1 (1) INCIDENT includes the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding. Page 1 of 8 Form Approved for Optional Use J udicial Council of California DISC-001 [Rev. ] anuary 1, 2008] FORM INTERROGATORIES— GENERAL Code of Civil Procedure, §§ 2030.010-2030.410, 2033.710 www.courtinfo.ca.gov [] 16.3 Do you contend that the injuries or the extent of the injuries claimed by plaintiff as disclosed in discovery proceedings thus far in this case were not caused by the INCIDENT? If so, for each injury: (a) identify it; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [ ]16.4 Do you contend that any of the services furnished by any HEALTH CARE PROVIDER claimed by plaintiff in discovery proceedings thus far in this case were not due to the INCIDENT? If so: (a) identify each service; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [1165 Do you contend that any of the costs of services furnished by any HEALTH CARE PROVIDER claimed as damages by plaintiff in discovery proceedings thus far in this case were not necessary or unreasonable? If so: (a) identify each cost; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [] 16.6 Do you contend that any part of the loss of earnings or income claimed by plaintiff in discovery proceedings thus far in this case was unreasonable or was not caused by the INCIDENT? If so: (a) identify each part of the loss; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [ ]16.7 Do you contend that any of the property damage claimed by plaintiff in discovery Proceedings thus far in this case was not caused by the INCIDENT? If so: (a) identify each item of property damage; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. DISC-001 [] 16.8 Do you contend that any of the costs of repairing the property damage claimed by plaintiff in discovery proceedings thus far in this case were unreasonable? If so: (a) identify each cost item; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 1] 16.9 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT (for example, insurance bureau index reports) concerning claims for personal injuries made before or after the INCIDENT by a plaintiff in this case? If so, for each plaintiff state: (a) the source of each DOCUMENT; ) the date each claim arose; ) the nature of each claim; and ) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. (b (c (d 16.10 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT concerning the past or present physical, mental, or emotional condition of any plaintiff in this case from a HEALTH CARE PROVIDER not previously identified (except for expert witnesses covered by Code of Civil Procedure sections 2034.210-2034.310)? If so, for each plaintiff state: (a) the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER; (b) a description of each DOCUMENT; and (c) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. 17.0 Responses to Request for Admissions 17.1 Is your response to each request for admission served with these interrogatories an unqualified admission? If not, for each response that is notan unqualified admission: (a) state the number of the request; (b) state all facts upon which you base your response; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of those facts; and (d) identify all DOCUMENTS and other tangible things that support your response and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 18.0 [Reserved] 19.0 [Reserved] 20.0 How the Incident Occurred— Motor Vehicle [] 20.1 State the date, time, and place of the INCIDENT (closest street ADDRESS or intersection). [] 20.2 For each vehicle involved in the INCIDENT, state: (a) the year, make, model, and license number; (b) the name, ADDRESS, and telephone number of the driver; DISC-001 [Rev. January 1, 2008] FORM INTERROGATORIES— GENERAL Page 7 of 8 EXHIBIT G DISC-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Alexander L. Conti, Esq. (#155945) | CONTILAW 23 Corporate Plaza, Suite 150 Newport Beach, CA 92660 TELEPHONE NO.: 949-791-8555 FAX NO. (Optional): 949-791-8556 E-MAIL ADDRESS (Optional): aconti @conti-law.com ATTORNEY FOR (Name): Plaintiffs SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE SHORT TITLE OF CASE: California Restaurants, Inc. et al. v. Booth Asking Party: C. C. G. Riverside, Inc. Set No.: KI¥¥X Four FORM INTERROGATORIES— GENERAL Answering Party: Theresa Booth by her Conservator John Tootle CASE NUMBER: 30-2015-00768529 Sec. 1. Instructions to All Parties (a) Interrogatories are written questions prepared by a party to an action that are sent to any other party in the action to be answered under oath. The interrogatories below are form interrogatories approved for use in civil cases. (b) For time limitations, requirements for service on other parties, and other details, see Code of Civil Procedure sections 2030.010-2030.410 and the cases construing those sections. (c) These form interrogatories do not change existing law relating to interrogatories nor do they affect an answering party's right to assert any privilege or make any objection. Sec. 2. Instructions to the Asking Party (a) These interrogatories are designed for optional use by parties in unlimited civil cases where the amount demanded exceeds $25,000. Separate interrogatories, Form Interrogatories— Limited Civil Cases (Economic Litigation) (form DISC-004), which have no subparts, are designed for use in limited civil cases where the amount demanded is $25,000 or less; however, those interrogatories may also be used in unlimited civil cases. (b) Check the box next to each interrogatory that you want the answering party to answer. Use care in choosing those interrogatories that are applicable to the case. (c) You may insert your own definition of INCIDENT in Section 4, but only where the action arises from a course of conduct or a series of events occurring over a period of time. (d) The interrogatories in section 16.0, Defendant's Contentions-Personal Injury, should not be used until the defendant has had a reasonable opportunity to conduct an investigation or discovery of plaintiff's injuries and damages. (e) Additional interrogatories may be attached. Sec. 3. Instructions to the Answering Party (a) An answer or other appropriate response must be given to each interrogatory checked by the asking party. (b) As a general rule, within 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. See Code of Civil Procedure sections 2030.260-2030.270 for details. (c) Each answer mustbe as complete and straightforward as the information reasonably available to you, including the information possessed by your attorneys or agents, 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 to 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. (9) Ifyou are asserting a privilege or making an objection to an interrogatory, you must specifically assert the privilege or state the objection in your written response. (h) Your answers to these interrogatories must be verified, dated, and signed. You may wish to use the following form at the end of your answers: I declare under penalty of perjury under the laws of the State of California that the foregoing answers are true and correct. (DATE) (SIGNATURE) Sec. 4. Definitions Words in BOLDFACE CAPITALS in these interrogatories are defined as follows: (a) (Check one of the following): [1 (1) INCIDENT includes the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding. Page 1 of 8 Form Approved for Optional Use J udicial Council of California DISC-001 [Rev. ] anuary 1, 2008] FORM INTERROGATORIES— GENERAL Code of Civil Procedure, §§ 2030.010-2030.410, 2033.710 www.courtinfo.ca.gov [] 16.3 Do you contend that the injuries or the extent of the injuries claimed by plaintiff as disclosed in discovery proceedings thus far in this case were not caused by the INCIDENT? If so, for each injury: (a) identify it; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [ ]16.4 Do you contend that any of the services furnished by any HEALTH CARE PROVIDER claimed by plaintiff in discovery proceedings thus far in this case were not due to the INCIDENT? If so: (a) identify each service; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [1165 Do you contend that any of the costs of services furnished by any HEALTH CARE PROVIDER claimed as damages by plaintiff in discovery proceedings thus far in this case were not necessary or unreasonable? If so: (a) identify each cost; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [] 16.6 Do you contend that any part of the loss of earnings or income claimed by plaintiff in discovery proceedings thus far in this case was unreasonable or was not caused by the INCIDENT? If so: (a) identify each part of the loss; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. [ ]16.7 Do you contend that any of the property damage claimed by plaintiff in discovery Proceedings thus far in this case was not caused by the INCIDENT? If so: (a) identify each item of property damage; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. DISC-001 [] 16.8 Do you contend that any of the costs of repairing the property damage claimed by plaintiff in discovery proceedings thus far in this case were unreasonable? If so: (a) identify each cost item; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 1] 16.9 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT (for example, insurance bureau index reports) concerning claims for personal injuries made before or after the INCIDENT by a plaintiff in this case? If so, for each plaintiff state: (a) the source of each DOCUMENT; ) the date each claim arose; ) the nature of each claim; and ) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. (b (c (d 16.10 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT concerning the past or present physical, mental, or emotional condition of any plaintiff in this case from a HEALTH CARE PROVIDER not previously identified (except for expert witnesses covered by Code of Civil Procedure sections 2034.210-2034.310)? If so, for each plaintiff state: (a) the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER; (b) a description of each DOCUMENT; and (c) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. 17.0 Responses to Request for Admissions 17.1 Is your response to each request for admission served with these interrogatories an unqualified admission? If not, for each response that is notan unqualified admission: (a) state the number of the request; (b) state all facts upon which you base your response; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of those facts; and (d) identify all DOCUMENTS and other tangible things that support your response and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 18.0 [Reserved] 19.0 [Reserved] 20.0 How the Incident Occurred— Motor Vehicle [] 20.1 State the date, time, and place of the INCIDENT (closest street ADDRESS or intersection). [] 20.2 For each vehicle involved in the INCIDENT, state: (a) the year, make, model, and license number; (b) the name, ADDRESS, and telephone number of the driver; DISC-001 [Rev. January 1, 2008] FORM INTERROGATORIES— GENERAL Page 7 of 8 EXHIBIT H 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CONTI LAW Alexander L. Conti, Bar No. 155945 23 Corporate Plaza, Suite 150 Newport Beach, CA 92660 Tel: (949) 791-8555 Fax: (949) 791-8556 Email: aconti@conti-law.com Attorneys for Plaintiffs California Restaurants, Inc. Citrus City Grille Corona Corp. and Steve Tsirtsis SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE CALIFORNIA RESTAURANTS, INC, a Case No. 30-2015-000768529 California Corporation, and CITRUS CITY GRILLE CORONA CORP., a California ASSIGNED FOR ALL PURPOSES TO: Corporation, STEVE TSIRTSIS, derivatively on behalf of C.C.G. RIVERSIDE, INC. a dissolved | Hon. David T. MacEachen California Corporation, Plaintiffs, V. THERESA CONSTANZA BOOTH, an incompetent, by her conservator JOHN S. TOOTLE, and DOES 1-50, inclusive, Defendants. PROOF OF SERVICE PROOF OF SERVICE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF ORANGE I am employed in the County of Orange, State of California. Iam over the age of 18 and not a party to the within action; my business address is Conti Law 23 Corporate Plaza, Suite 150 Newport Beach, CA 92660. On December 1, 2015, I served the foregoing document described as: FORM INTERROGATORIES, SET FOUR on the following person(s) who is counsel for Defendant and Cross-Complainant in this case in the manner indicated: Jeffrey L. Malek John S. Tootle, Esq. David C. Chang LAW OFFICE OF JOHN S. TOOTLE MALEK & MALEK 777 Silver Spur Drive, Suite 102 3625 Del Amo Boulevard, Suite 350 Pasadena, California 90274 Torrance, California 90503 Email:johntootlelaw@gmail.com Facsimile: 310-371-7242 [X ] (BY MAIL) I am familiar with the practice of Conti Law for collection and processing of correspondence for mailing with the United States Postal Service. Correspondence so collected and processed is deposited with the United States Postal Service that same day in the ordinary course of business. On this date, a copy of said document was placed in a sealed envelope, with postage fully prepaid, addressed as set forth herein, and such envelope was placed for collection and mailing at Conti Law, Newport Beach, California, following ordinary business practices. [ 1] (BY OVERNIGHT MAIL) I am familiar with the practice of Conti Law for collection and processing of correspondence for delivery by overnight courier. Correspondence so collected and processed is deposited in a box or other facility regularly maintained by FedEx/Overnite Express that same day in the ordinary course of business. On this date, a copy of said document was placed in a sealed envelope designated by FedEx/Overnite Express with delivery fees paid or provided for, addressed as set forth herein, and such envelope was placed for delivery by FedEx/Overnite Express at Conti Law, Newport Beach, California, following ordinary business practices. [ 1 (BY FACSIMILE TRANSMISSION) On this date, at the time indicated on the transmittal sheet, attached hereto, I transmitted from a facsimile transmission machine, which telephone number is (949) 791-8556, the document described above and an unsigned copy of this declaration to the person, and at the facsimile transmission telephone numbers, set forth herein. The above-described transmission was reported as complete and without error by a properly issued transmission report issued by the facsimile transmission machine upon which the said transmission was made immediately following the transmission. [ X 1] (BY ELECTRONIC MAIL) (BY ELECTRONIC MAIL) On this date, pursuant to Rule 2.251 of the California Rules of Court, I caused a copy of said document to be transmitted via electronic mail to the e-mail addresses listed on the attached service list from my email address of aconti@conti- law.com at approximately 8:16 AM. [ 1 (BY HAND DELIVERY) I served the documents by providing them to Nationwide ASAP courier service for hand delivery. A separate proof of service will be prepared by the courier. I 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 December 1, 2015, at Newport Beach, Caliigmig, Alexander L. Cont Alexander L. Conti 1- PROOF OF SERVICE EXHIBIT I SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE CENTRAL JUSTICE CENTER MINUTE ORDER DATE: 01/06/2017 TIME: 09:00:00 AM DEPT: C19 JUDICIAL OFFICER PRESIDING: Walter Schwarm CLERK: Kimberley Gray REPORTER/ERM: BAILIFF/COURT ATTENDANT: Mandi D Destra CASE NO: 30-2015-00768529-CU-BT-CJC CASE INIT.DATE: 01/28/2015 CASE TITLE: California Restaurants, Inc. vs. Booth CASE CATEGORY: Civil - Unlimited CASE TYPE: Business Tort EVENT ID/DOCUMENT ID: 72472272 EVENT TYPE: Case Management Conference APPEARANCES Alexander L. Conti, from Conti Law, present for Plaintiff(s) telephonically. There are no appearances by any party. The Court has reviewed the Stipulation for Order of Substitution of Personal Representative or Estate of Theresa C. Booth and For Order Granting Leave to File Amended Complaint Naming Personal Representative as Defendant. Pursuant to the stipulation of the parties, Probate Code §9370 and for good cause shown the Court hereby orders as follows: 1. David S. Chon, Esq., the personal representative of the estate of Theresa Constanza Booth in the Booth Probate, be and hereby is substituted as the defendant in this case in place of Theresa Constanza Booth and her conservator John S. Tootle, Esq. 2. Leave to file a second amended complaint naming David S. Chon, Esq., personal representative of the estate of Theresa Constanza Booth, as the defendant in this action is GRANTED. The formal order was signed this date. Case Management Conference continued to 03/03/2017 at 09:00 AM in Department C19. Court orders Plaintiff to give notice. DATE: 01/06/2017 MINUTE ORDER Page 1 DEPT: C19 Calendar No. 5 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF ORANGE I am employed in the County of Orange, State of California. Iam over the age of 18 and not a party to the within action; my business address is Conti Law 23 Corporate Plaza, Suite 150 Newport Beach, CA 92660. On April 8, 2017, I served the foregoing document described as: PLAINTIFFS’ NOTICE OF MOTION AND MOTION FOR ORDER COMPELLING DEFENDANT TO RESPOND TO FORM INTERROGATORIES; DECLARATION OF ALEXANDER L. CONTI, ESQ. on the following person(s) who is counsel for Defendant and Cross-Complainant in this case in the manner indicated: David S. Chon THE LEGACY LAWYERS 1022 Slater Ave., Ste. 106 Fountain Valley, CA 92708 FAX: 714-963-3012 Email: dchon@thelegacylawyers.com [x ] (BY MAIL) I am familiar with the practice of Conti Law for collection and processing of correspondence for mailing with the United States Postal Service. Correspondence so collected and processed is deposited with the United States Postal Service that same day in the ordinary course of business. On this date, a copy of said document was placed in a sealed envelope, with postage fully prepaid, addressed as set forth herein, and such envelope was placed for collection and mailing at Conti Law, Newport Beach, California, following ordinary business practices. [ T (BY OVERNIGHT MAIL) I am familiar with the practice of Conti Law for collection and processing of correspondence for delivery by overnight courier. Correspondence so collected and processed is deposited in a box or other facility regularly maintained by FedEx/Overnite Express that same day in the ordinary course of business. On this date, a copy of said document was placed in a sealed envelope designated by FedEx/Overnite Express with delivery fees paid or provided for, addressed as set forth herein, and such envelope was placed for delivery by FedEx/Overnite Express at Conti Law, Corona Del Mar, California, following ordinary business practices. [ 1 (BY FACSIMILE TRANSMISSION) On this date, at the time indicated on the transmittal sheet, attached hereto, I transmitted from a facsimile transmission machine, which telephone number is (949) 791-8556, the document described above and an unsigned copy of this declaration to the person, and at the facsimile transmission telephone numbers, set forth herein. The above-described transmission was reported as complete and without error by a properly issued transmission report issued by the facsimile transmission machine upon which the said transmission was made immediately following the transmission. [ 1(BY ELECTRONIC MAIL) (BY ELECTRONIC MAIL) On this date, pursuant to Rule 2.251 of the California Rules of Court, I caused a copy of said document to be transmitted via electronic mail to the e-mail addresses listed on the attached service list through One Legal. [ T (BY HAND DELIVERY) I served the documents by providing them to Nationwide ASAP courier service for hand delivery. A separate proof of service will be prepared by the courier. I 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 April 8, 2017, at Newport Beach, California. Alexander L. Conti Alexander L. Conti 6 PLAINTIFFS’ MOTION FOR ORDER THAT MATTERS BE DEEMED ADMITTED
