Defendant Woodalls Reply In Support of Antislapp MotionReplyCal. Super. - 4th Dist.October 1, 201930-2019-0 S M I T H LC 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 7 0 7 lectronically Filed by Superior Court of California, County of Orange, 07/20/2020 07:50:00 PM. 101730-CU-BC-CJC - ROA #245 - DAVID H. YAMASAKI, Clerk of the Court By e Clerk, Deputy Clerk. John S. Clifford, State Bar No. 172263 Michael H. Cooper, State Bar No. 272124 SMITH LC 4 Park Plaza, Suite 1050 Irvine, CA 92614 Telephone: (949) 416-5000 Facsimile: (949) 416-5555 Email: jclifford@smith-lc.com Email: mcooper@smith-lc.com Attorneys for Defendant JULIE A. WOODALL SUPERIOR COURT OF CALIFORNIA COUNTY OF ORANGE - CENTRAL JUSTICE CENTER TIMOTHY J. WOODALL, an individual, CASE NO: 30-2019-01101730-CU-NC-CJC Plaintiff, JUDGE: Hon. Gregory H. Lewis VS. DEPT: (C26 JULIE A. WOODALL, an individual, DEFENDANT JULIE A. WOODALL’S RONNIE DEAN ECHAVARRIA, SR., an REPLY IN SUPPORT OF HER ANTI- individual and doing business as SLAPP - SPECIAL MOTION TO STRIKE - ALLEGIANT PI; and ALLEGIANT PI, (form | PLAINTIFF’S FIRST AMENDED of entity unknown); and DOES 1 through 100, | COMPLAINT inclusive [Concurrently Filed with Defendant’s Written Defendants. Objections to Plaintiff’s Evidence and Proposed Order; Notice of Joinder to Opposition to Request for Judicial Notice] DATE: July 27, 2020 TIME: 10:30 a.m. DEPT: C26 RESERVATION NO.: 73167607 Complaint Filed: October 1, 2019 Trial Date: Not Set TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD: Defendant Julie Woodall (“Defendant”) submits this Reply to Plaintiff’s opposition to her special motion to strike pursuant to California Code of Civil Procedure §425.16, et. seq. which is now set for hearing on July 27, 2020. 1 DEFENDANT JULIE A. WOODALL’S REPLY IN SUPPORT OF HER ANTI-SLAPP - SPECIAL MOTION TO STRIKE - PLAINTIFF’S FIRST AMENDED COMPLAINT S M I T H LC 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MEMORANDUM OF POINTS AND AUTHORITIES I. INTRODUCTION Plaintiff’s conduct in this litigation, culminating in an opposition that is nearly indecipherable without a glossary of abbreviations, appears calculated to gain an advantage for Plaintiff in his pending divorce with Defendant! and makes a mockery of the legislative mandate that California Code of Civil Procedure §425.16, et. seq. act as a fast and efficient means of avoiding the costs and delays of litigation that chill the exercise of constitutionally protected rights. Braun v. Chronicle Publishing Co. (1997) 52 Cal. App.4th 1036, 1042. As our Appellate Court has stated, “[t]he point of the anti-SLAPP statute is that you have a right not to be dragged through the courts because you exercised your constitutional rights.” People ex rel. Lockyer v. Brar (2004) 115 Cal. App.4th 1315, 1317 [emphasis added]. Plaintiff’s complaint was filed on October 1, 2019, and this motion was filed on November 14,2019, with an original hearing date of February 3™, 2020. Unfortunately, Plaintiff has chosen to file at least nine (9) ex parte applications and noticed motions during the pendency, resulting in the hearing of the instant motion being significantly delayed while causing Defendant’s costs to increase exponentially. As the Court is aware, Plaintiff's First Amended Complaint (“FAC”) alleges 11 causes of action and a 12" claim for injunctive relief; the first 10 causes of action are predicated on an alleged promise to keep a secret? for the rest of Defendant’s life (the “secret” or “CI”) and the 11% cause of action alleges defamatory comments. Nothing in Plaintiff’s opposition papers changes the reality that all of the causes of action in the challenged FAC arise out of protected activity (prong 1 of the required analysis) and Plaintiff cannot show a probability of prevailing on a single one of his claims (prong 2 of the analysis); accordingly, Plaintiff’s FAC must be stricken in its entirety. Additionally, as mandated by the Anti-SLAPP statute, Defendant must be awarded her attorneys’ fees and costs incurred in the filing and prosecution of this motion. !' See related case of Woodall v. Woodall, O.C.S.C. Case No. 18D004647. 2 The alleged secret is set forth, unsealed and un-redacted, in multiple documents in the Court’s file including the moving papers and Plaintiff’s FAC at paragraph 26. This alleged secret will be referred to as “the secret” or “CI” in this Reply. DEFENDANT JULIE A. WOODALL’S REPLY IN SUPPORT OF HER ANTI-SLAPP - SPECIAL MOTION TO STRIKE - PLAINTIFF’S FIRST AMENDED COMPLAINT S M I T H LC 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 II. ANALYSIS - FIRST PRONG: PLAINTIFF’S CAUSES OF ACTION ARISE FROM PROTECTED ACTIVITY Notwithstanding Plaintiff’s Opposition, the Anti-SLAPP analysis is designed to be simple. It rests on two prongs: (1) A defendant must make “a threshold showing that the challenged cause of action is one arising from protected activity” and (2) the statute then “places the burden on [the] 299 plaintiff to establish ‘that there is a probability that the plaintiff will prevail on the claim’. See Navellier v. Sletten (2002) 29 Cal.4™ 82, 88; see also Colt v. Freedom Commc ns, Inc. (2003) 109 Cal. App.4™ 1551, 1557, Code of Civ. Proc. §425.16(b)(1). Defendant’s motion satisfies the first prong of the Anti-SLAPP analysis as set forth below. (A) Marriage Does Not Waive Anti-SLAPP Protections. If understood correctly, Plaintiff seems to be asking this Court to find that the marital relationship between the parties creates a binding contract which somehow precludes one spouse from ever disclosing topics which were discussed during the marriage. Opposition Pg. 3, line 27 to Pg. 4, line 2. This is not an accurate statement of California law. Spousal communications are governed by marital and spousal privileges set forth in the California Evidence Code. However, none of these privileges are applicable in this case as neither spouse is testifying against each other and Plaintiff is suing his former spouse, which waives the privilege under California Evidence Code §§912 and 972(a). None of the speech alleged to be tortious in causes of action 1-11 of the FAC loses its protected status as a result of the fact that Plaintiff was married to Defendant. (B) Plaintiff has not Provided any Evidence of a Valid Contract to Restrict Speech - Making the Alleged Statements Protected Under Prong 1 of the Analysis Causes of action 1-10 are premised on the claimed promise to keep the secret. Plaintiff simply cannot produce any corroborating evidence of a valid and enforceable contract. As stated in the motion, Plaintiff must show there was “mutual assent” between the contracting parties, in addition to general elements of offer, acceptance, and consideration. Weddington Productions, Inc. v. Flick (1998) 60 Cal. App.4th 793, 811. Additionally, as there is no writing signed by the defendant confirming this alleged promise, the contract as alleged, violates California’s Statute of Frauds and cannot be enforced. 3 DEFENDANT JULIE A. WOODALL’S REPLY IN SUPPORT OF HER ANTI-SLAPP - SPECIAL MOTION TO STRIKE - PLAINTIFF’S FIRST AMENDED COMPLAINT S M I T H LC 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 i) Sufficiency of Contract is a Question of Law The determination of “[w]hether a contract is sufficiently definite to be enforceable is a question of law for the court.” Ladas v. Cal. State Automobile Assn. (1993) 19 Cal.App.4th 761, 770, fn2. Plaintiff has produced no evidence, other than his testimony, that a contract was formed, and his testimony should be viewed with some skepticism as the alleged facts regarding the promise seem to be evolving. For example, as set forth on page 17, lines 22-25 of the moving papers, Plaintiff’s sworn testimony has previously been “I reminded her of this on occasion . . . and she always told me that the secret was safe with her.” Now, Plaintiff's opposition claims that “during every year from 2001-2018 . . . J (Defendant) repeated to T J’s promise.” Defendant denies any agreement and Plaintiff has not provided sufficient evidence that a contract was entered into. As a matter of law, the Court should find that the alleged evidence of a contract is legally insufficient to support a finding that Defendant is not protected under the Statute. (ii) The Statute of Frauds Invalidates Plaintiff’s Claimed Agreement Even if the Court were to find sufficient evidence regarding the existence of an agreement, such a contracts, it must be memorialized in writing under the common law statute of frauds which is now codified in Civil Code §1624. The statute of frauds invalidates all contracts which do not comply. The statute specifically states, in pertinent part, as follows: The following contracts are invalid, unless they, or some note or memorandum thereof, are in writing and subscribed by the party to be charged or by the party's agent: (1) An agreement that by its terms is not to be performed within a year from the making thereof. Civil Code §1624(a)(1) [emphasis added]. California law is well settled that oral agreements that cannot be performed within a year are invalid if they are not memorialized in writing. The requirement for a writing sufficient to satisfy the statute of frauds includes agreements to refrain from certain conduct. See Summerhays v. Scheu (1935) 10 Cal.App.2d 574, 576-577 (An oral agreement involving the owner of an invention to refrain from use of the invention is within statute, because it was not performable within one year.). 4 DEFENDANT JULIE A. WOODALL’S REPLY IN SUPPORT OF HER ANTI-SLAPP - SPECIAL MOTION TO STRIKE - PLAINTIFF’S FIRST AMENDED COMPLAINT S M I T H LC 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff specifically alleges that the purported oral agreement was to last in perpetuity. Plaintiff himself has testified, via declaration, that the terms of the alleged agreement include a prohibition on conduct for the rest of Defendant’s life. This testimony is as follows: e “Iwould tell her my... [Confidential Information], provided that [Plaintiff] promise to never repeat or disclose the CI to any person, no matter the reason or circumstance.” Tim Woodall Decl., dated July 9, 2020 at 93, Pg. 16, lines 9-12 [emphasis added]. eo “Iwas willing to tell [Plaintiff] the [Confidential Information] if we entered into an agreement which provided that if I told her the CI, [Plaintiff] would never disclose the CI to anyone else at any time or under any circumstance for any reason.” Tim Woodall Decl., dated July 9, 2020 at 93, Pg. 16, lines 16-18 [emphasis added]. eo “I stated to [Plaintiff] that I wanted to tell her my . . . [Confidential Information], provided that she promise to never, for the rest of her life, repeat or disclose this confidential information to any other person no matter what the reason or circumstance.” Tim Woodall Decl., dated July 9, 2020 at 94, Pg. 16, lines 24-27 [emphasis added]. e “I also told [Plaintiff] that if she could not keep this secret for the rest of her life, that I would not fault her for it, but I would not tell her the [Confidential Information] if she felt she could not keep the secret.” Tim Woodall Decl., dated July 9, 2020 at 4, Pg. 17, lines 4-6 [emphasis added]. eo “[Plaintiff further stated to me that she agreed to keep the [Confidential Information] secret, and that she would never disclose the [Confidential Information]to anybody for the rest of her life, no matter what the circumstance or for any reason.” Tim Woodall Decl., dated July 9, 2020 at 95, Pg. 17, lines 14-16 [emphasis added]. Plaintiff has been consistent that this oral agreement was for a permanent, lifetime injunction on Defendant’s conduct. See Complaint and FAC 915, Pg. 5, lines 25-27. Plaintiff’s intent regarding the promise or his expectations are irrelevant; the agreement was never memorialized in writing or signed by Ms. Woodall as required by the California’s Statute of Frauds. Accordingly, the agreement is invalid and unenforceable as a matter of law and the claim that Defendant has lost her Anti-SL APP rights and protections for causes of action 1-10 is without merit. 111 5 DEFENDANT JULIE A. WOODALL’S REPLY IN SUPPORT OF HER ANTI-SLAPP - SPECIAL MOTION TO STRIKE - PLAINTIFF’S FIRST AMENDED COMPLAINT S M I T H LC 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 (C) Retaining a Private Investigator, and the Subject Service Agreement, is not Illegal and the Litigation Privilege Protects the Speech in Question. Plaintiff next contends that the first prong of the Anti- SLAPP statute is not met because somehow the agreement between Defendants Echavarria and Ms. Woodall is illegal. Plaintiff’s contention, however, illustrates a profound misunderstanding of facts and applicable law. It is undisputed that Plaintiff filed for divorce on June 1, 2018 and that Defendant had retained counsel, Hughes & Hughes, to represent her in the dissolution matter. In connection with the dissolution case, Defendant retained a private investigator, Co- Defendant Ronnie Echavarria. Assuming arguendo, that Defendant Echavarria somehow acted outside of the scope of his licensure, such an act would not make the underlying agreement for services in the dissolution matter illegal and would not destroy the litigation and work product privileges enjoyed by Ms. Woodall. Plaintiff’s theory that Echavarria is in potential jeopardy of a misdemeanor or discipline with his licensing agency and that as a result, Defendant is guilty as an accomplice is nonsense, without any legal or factual support, and should be disregarded by the Court. Defendant retained a private investigator in connection with her divorce proceedings in which she is represented by counsel. Plaintiff has now commenced this lawsuit against Defendant for the statements that she made to her investigator. Such statements are protected activity as contemplated by the Anti-SLAPP statute and the first prong of the Anti-SLAPP statute is met. Because Defendant has established that her challenged acts and speech alleged to be tortious (see causes of action 1-10) are all “protected activities,” and because Plaintiff has not, and 1™ cause of action are anything cannot, demonstrated that the comments alleged in support of the 1 other than protected opinion, Defendant has met her burden for the first prong of the Anti-SLAPP statute, requiring that the Court now consider the second prong of the Anti-SLAPP analysis. III. ANALYSIS - SECOND PRONG: PLAINTIFF CANNOT ESTABLISH A REASONABLE PROBABILITY OF SUCCESS ON HIS CLAIMS Because Defendant has satisfied the first prong of the Anti-SLAPP analysis, the burden shifts to Plaintiff to demonstrate, with admissible evidence, that he is likely to prevail on his claims. As stated in the moving papers, a plaintiff may not simply rely on allegations in a 6 DEFENDANT JULIE A. WOODALL’S REPLY IN SUPPORT OF HER ANTI-SLAPP - SPECIAL MOTION TO STRIKE - PLAINTIFF’S FIRST AMENDED COMPLAINT S M I T H LC 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 complaint. Simmons v. Allstate Ins. (1995) 92 Cal. App 4th 1068, 1073. Plaintiff’s burden is substantial as it is tested by the same standard applied to motions for summary judgment, nonsuit, or directed verdict. See Matson v. Dvorak (1995) 40 Cal.App.4th 539, 548. If a plaintiff fails to carry his evidentiary burden, the court must strike his claim. Cal. Civ. Proc. Code §425.16(b)(1). In addition to the factual improbability of success on a claim based on an alleged promise to keep a childhood secret, Defendant’s motion raises specific legal defenses that Plaintiff’s Opposition has not overcome. While long and confusing, the Opposition has not demonstrated “a probability of prevailing” and does not provide the Court with admissible evidence sufficient to satisfy Plaintiff’s burden of demonstrating a probability of prevailing on the merits. See Defendant’s concurrently filed evidentiary objections to Plaintiff’s evidence. Accordingly, the Court should find that the second prong of the Anti-SLAPP analysis is satisfied for the following reasons: (A) The Litigation Privilege Destroys Plaintiff’s Probability of Prevailing Plaintiff cannot establish a probability of prevailing as California Civil Code §47(b) makes the challenged statements privileged. Contrary to Plaintiff’s argument in the Opposition, the litigation privilege applies to any communication “(1) made in judicial or quasi-judicial proceedings; (2) by litigants or other participants authorized by law; (3) to achieve the objects of the litigation; and (4) that [has] some connection or logical relation to the action.” Silberg v. Anderson (1990) 50 Cal.3d 205, 212. To illustrate the broadness of the litigation privilege, it also extends to communications made, and steps taken, before or after a trial or other proceeding, but only if such statements otherwise satisfy the criteria set forth in Silberg. Rusheen v. Cohen (2006) 37 Cal.4th 1048, 1057. As it pertains to Anti-SLAPP litigation, there are numerous cases holding that the litigation privilege is a bar to Plaintiff's probability of succeeding on the merits of its claim when analyzing the second prong of an Anti-SLAPP motion. See Laker v. Board of Trustees of Cal. State Univ. (2019) 32 Cal.App.5th 745 (plaintiff could not prevail on defamation claim or retaliation claim based on defamatory statements because claims relied entirely on statements made during official proceedings authorized by law, which are absolutely protected under Civil Code §47(b)(3)); Kenne 7 DEFENDANT JULIE A. WOODALL’S REPLY IN SUPPORT OF HER ANTI-SLAPP - SPECIAL MOTION TO STRIKE - PLAINTIFF’S FIRST AMENDED COMPLAINT S M I T H LC 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 v. Stennis (2014) 230 Cal.App.4th 953, 972 (defendants’ filing of civil harassment petitions could not form basis of malicious prosecution suit as matter of law; similarly, defendants’ filing of allegedly false police reports was protected by litigation privilege and therefore precluded any probability of success on plaintiff's claims for defamation and intentional infliction of emotional distress). Plaintiff’s version of the litigation privilege is too narrow and the analysis provided to the Court is incomplete. For example, Plaintiff first claims that the statements (both the confidential information and defamatory statements) were not made in any judicial proceedings - despite the fact that at least some of the statements were made in a deposition proceeding which he compelled. A deposition can only be considered a judicial or legal proceeding under the privilege statute. See Moore v. Conliffe (1994) 7 Cal.4th 634, 653 (“litigation privilege” protects from defamation liability a person who made an allegedly defamatory statement while testifying as witness at deposition taken in private, contractual arbitration). (B) Plaintiff Cannot Overcome the Attorney-Client Privilege. Plaintiff next contends that Defendant breached the alleged oral agreement by disclosing the Confidential Information and Defamatory Statements to her retained private investigator and family law lawyer. Plaintiff’s position has no support under California law. Again, the purpose of the attorney-client communication is to promote the freedom of consultation between a lawyer and the client and to encourage full disclosure and discussion of the facts, without fear that subsequent disclosure can be compelled without the client’s consent. Fisher v. U.S. (1976) 425 U.S. 391, 403; People v. Meredith (1981) 29 Cal.3d 682, 690. To further this policy, California Courts have extended the attorney-client communication privilege to retained investigators. Fireman's Fund Ins. Co. v. Superior Court (2011) 196 Cal. App.4th 1263, 1275 (Attorney-client privilege precluded property insurer’s attorney from being compelled to answer deposition question to disclose her “discussions” with an investigator retained by her firm regarding “how to pay” $1,000 to a witness in an investigation of insured’s property damage claims, if the answer implicated attorney's legal opinions regarding the witness.) /11 8 DEFENDANT JULIE A. WOODALL’S REPLY IN SUPPORT OF HER ANTI-SLAPP - SPECIAL MOTION TO STRIKE - PLAINTIFF’S FIRST AMENDED COMPLAINT S M I T H LC 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The mere fact that Defendant, Ms. Woodall, told her attorney, or a retained private investigator assisting in her case, is sufficient to make the information subject to the attorney- client privilege. Plaintiff’s attempts to conflate the alleged statements to the private investigator from Julie Woodall with the private investigator’s alleged statement to third parties and does not change the analysis or the result. Plaintiff’s claim can only be for alleged statements to the private investigator, which are privileged. Plaintiff cannot prevail on his claims against Defendant Julie Woodall and the instant Anti-SLAPP motion should be granted. (C) The Alleged Defamatory Statements Are Nothing More Than Opinion Finally, for his 11" cause of action to survive, Plaintiff must satisfy the second prong of the analysis by showing that Defendant’s statements contain or imply “a provable falsehood” or a “provable false assertion of fact.” Overhill Farms Inc. v. Lopez (2010) 190 Cal. App.4th 1248, 1261. Statements of opinion are constitutionally protected. Summit Bank v. Rogers (2012) 206 Cal.App.4th 669, 695-696. Even “’rhetorical hyperbole,” ‘vigorous epithet[s],” ‘lusty and imaginative expressions of . .. contempt,” and language used ‘in a loose, figurative sense’ have all been accorded constitutional protection.” Ferlauto v. Hamsher (1999) 74 Cal. App.4th 1394, 1401. The alleged defamatory statements in the Complaint and identical (save redactions) FAC are located at: (a) Complaint and FAC 926, Pg. 8, lines 26-27; (b) Complaint and FAC 926, Pg. 8, lines 27-28; (c¢) Complaint and FAC 926, Pg. 8, line 28 to Pg. 9, line 1; (d) Complaint and FAC 926, Pg. 9, line 1; and (e) was a potential child molester Complaint and FAC 926, Pg. 9, line 2. These statements are not definitive statements of fact and are nothing more than Defendant’s opinions. Based on these reasons, Plaintiff cannot demonstrate a probability of prevailing on his causes of action and Defendant’s Anti-SLAPP motion must be granted. IV. ATTORNEYS’ FEES FOR ALL COSTS INCURRED IN BRINGING THIS MOTION Fees to a prevailing defendant for all costs, including attorneys’ fees, are required to be awarded. Conversely, and contrary to Plaintiff's prayer, A plaintiff is not entitled to attorneys’ fees after defeating a defendant’s Anti-SLAPP motion, unless the plaintiff can show that defendant’s motion was frivolous or intended to cause unnecessary delay. Haneline Pac. Props., 9 DEFENDANT JULIE A. WOODALL’S REPLY IN SUPPORT OF HER ANTI-SLAPP - SPECIAL MOTION TO STRIKE - PLAINTIFF’S FIRST AMENDED COMPLAINT S M I T H LC 10 11 12 13 14 15 16 17 18 19 20 21 2) 23 24 25 26 27 28 LLC v. May (2008) 167 Cal.App.4th 311, 320 (no fees awarded to prevailing plaintiff that failed to develop argument that anti-SLAPP motion was “frivolous” or intended to cause “unnecessary delay”). No such claims is, or could be, made by Defendant. Given the extraordinary expenses incurred as a result of Plaintiffs litigation strategy in this| matter, Defendant will bring a noticed motion to establish the necessity and amount of these fees after the Court rules on her motion. V. CONCLUSION Plaintiff’s allegations against Defendant all arise from Defendant’s protected activity and Plaintiff has not, and cannot, meet his burden to show a probability of prevailing on the merits. As such, Defendant’s Anti-SLAPP motion should be granted. Dated: July 20, 2020 SMITH LC _ <9 ‘ a os By: Zl SA ar Zi ~d JOHN _S/ CLIFFORD MICHAEL H. COOPER Attorneys for Defendant JULIE A. WOODALL 10 DEFENDANT JULIE A. WOODALL’S REPLY IN SUPPORT OF HER ANTI-SLAPP - SPECIAL MOTION TO STRIKE - PLAINTIFF’S FIRST AMENDED COMPLAINT S M I T H LC 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE Woodall v. Woodall Case No. 30-2019-01101730-CU-BC-CJC I, the undersigned, declare that I am over the age of 18 years, employed in the County of Orange, and not a party to the within action. My business address is 4 Park Plaza, Suite 1050, Irvine, CA 92614. On July 20, 2020, I affected electronic service of the following: DEFENDANT JULIE A. WOODALL’S REPLY IN SUPPORT OF HER ANTI- SLAPP - SPECIAL MOTION TO STRIKE - PLAINTIFF’S FIRST AMENDED COMPLAINT on all interested parties in this action listed below: Douglas D. Honig Law Office of Douglas S. Honig Attorney for Plaintiff 501 Civic Center Drive West Santa Ana, CA 92701 TIMOTHY J. WOODALL Phone: 714-973-1191 Fax: 714-973-1253 Email: Dougl2honig@aol.com German A. Marcucci Farid Zakaria Ropers, Majeski, Kohn & Bentley Attorneys for Defendant 445 South Figueroa Street, Suite 3000 RONNIE DEAN ECHAVARRIA SR., Los Angeles, CA 90071-1619 individually and dba ALLEGIANT PI Phone: 213-312-2000 Fax: 213-312-2001 Email: german.marcucci@rmkb.com farid.zakaria@ropers.com Additional Emails: Elizabeth Avila - elizabeth.avila@ropers.com Tameron Watts - tameron.watts@ropers.com Anthony Arriola - anthony.arriola@ropers.com Calendar LAO - calendar-lao@ropers.com And by sending a courtesy copy addressed as follows: Steven E. Briggs Attorney for Petitioner in Law Offices of Steven E. Briggs Case No. 18D004647 2700 Newport Boulevard, Suite 172 TIMOTHY J. WOODALL Newport Beach, CA 92663 Phone: 949-673-7410 Email: sebriggs@pacbell.net Lauren Rubalcaba Attorney for Respondent in Lisa Hughes Case No. 18D004647 Hughes and Hughes, LLP JULIE WOODALL 660 West First Street Tustin, CA 92780 Phone: 714-538-5200 Email: Iruvalcaba@hughesandhughesca.com bhughes@hughesandhughesca.com 11 DEFENDANT JULIE A. WOODALL’S REPLY IN SUPPORT OF HER ANTI-SLAPP - SPECIAL MOTION TO STRIKE - PLAINTIFF’S FIRST AMENDED COMPLAINT S M I T H LC 10 11 12 13 14 15 16 17 18 19 20 21 2) 23 24 25 26 27 28 By Email or Electronic Transmission: As authorized by California Rules of Court Appendix I, Emergency Rules Related to COVID-9, Rule 12, and/or an agreement of the parties to accept service by email or electronic transmission, I caused the document(s) to be sent from email address aragone@smith-lc.com to the persons at the email addresses listed above. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on July 20, 2020, in Irvine, California. (3 Lu gOS, ean Anngtte S. Ragonet_ 12 DEFENDANT JULIE A. WOODALL’S REPLY IN SUPPORT OF HER ANTI-SLAPP - SPECIAL MOTION TO STRIKE - PLAINTIFF’S FIRST AMENDED COMPLAINT
