declaration of mani sheik in response to order to show cause

Cal. Super. - 1st Dist.November 4, 2021

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of Mani Sheik in Response to Order to Show Cause Mani Sheik (SBN 245487) SHEIK LAW, INC. 526 Third St., Suite A San Rafael, CA 94901 Tel: (415) 205-8490 Fax: (415) 796-0875 Email: mani@sheiklaw.us Attorneys for Plaintiffs NATHAN SCHATZ FAMILY TRUST, ZACHARY NATHAN, and ANDREA SCHATZ SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO NATHAN SCHATZ FAMILY TRUST, a California Trust; ZACHARY NATHAN, as Trustee of NATHAN SCHATZ FAMILY TRUST and individually; and ANDREA SCHATZ, as Trustee of NATHAN SCHATZ FAMILY TRUST and individually, Plaintiffs, v. AEM FOOD & BEVERAGE, INC., a California Corporation; DOSA FOOD & BEVERAGE, INC., a Delaware Corporation; DOSA HOLDINGS, INC., dba DOSA RESTAURANT GROUP, a Delaware Corporation; EMILY MITRA, an individual; ANJAN MITRA, an individual; and DOES 1 through 25, inclusive, Defendants. Case No.: CGC-20-584100 Declaration of Mani Sheik in Response to Order to Show Cause Complaint Filed: 4-8-20 ELECTRONICALLY F I L E D Superior Court of California, County of San Francisco 11/18/2020 Clerk of the Court BY: VANESSA WU Deputy Clerk 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of Mani Sheik in Response to Order to Show Cause 1 I, Mani Sheik, declare under penalty of perjury that the following facts are true and correct to the best of my information and belief: 1. I am an attorney duly licensed to practice law before all the courts of the State of California, and am the attorney for all Plaintiffs in this action. I am making this declaration in response to the Court’s Order to Show Cause. If called as a witness, I would and could competently testify to the following facts based on my personal knowledge. 2. This action was filed on April 8, 2020. (All dates listed herein are in 2020 unless otherwise stated.) 3. The complaint names five defendants. Two defendants are individuals-Emily Mitra and Anjan Mitra (collectively, “the Mitras”). And three defendants are entities that, on information and belief, the Mitras own, control, and operate-AEM Food & Beverage, Inc. (“AEM”), Dosa Food & Beverage, Inc. (“Dosa Food”), and Dosa Holdings, Inc. (“Dosa Holdings” and, collectively, the “Entity Defendants”). 4. I am informed and belief that the Mitras either are going through a divorce or have gone through a divorce, such that they no longer live in the same location. 5. On April 23, I received from the third-party vendor I hired to effectuate the filing the conformed copies of the Summons, Complaint, and other supporting case initiating documents. 6. That same day, April 23, I attempted to effectuate service on the Entity Defendants through Notice and Acknowledgment of Receipt of Service. I mailed the appropriate papers, including a self-addressed, postage prepaid envelope in which the defendant could return the attached Notice and Acknowledgment of Receipt, to the agents for service of process for each of the Entity Defendants. Attached as Exhibits 1-3 are true and correct copies of the cover letters I sent to each of the Entity Defendants. 7. The Entity Defendants thus had twenty day, or until May 13, to sign and return the Acknowledgement forms, which would have effectuated service. None of the Entity Defendants timely returned a signed Acknowledgement, however. 8. On May 14, I emailed the Mitras to ask that they cause their agents to return the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of Mani Sheik in Response to Order to Show Cause 2 Acknowledgments promptly. Attached as Exhibit 4 is a true and correct copy of this email only (the attachments are not included here). 9. In my email, I also asked that the Mitras accept, as individual defendants, service of Summons, Complaint, and other supporting documents (which I had attached), with an effective date of May 14. (Id.) 10. Later that evening (of May 14), I received an email from Richard Zuromski, who introduced himself as “counsel to AEM Food & Beverage, Inc.” only and asking to begin settlement discussions. Mr. Zuromski also attached a signed Acknowledgment form for AEM. Attached as Exhibit 5 is a true and correct copy of this email and its attachment, but redacted to remove the confidential settlement communication therein. 11. The next day, May 15, I sought to clarify with Mr. Zuromski whether he represented just AEM or all five defendants. Mr. Zuromski replied “For now I just represent AEM. I’ll have to check with my client about the other parties. I will get back to you as soon as I find out.” Attached as Exhibit 6 is a true and correct copy of this email chain, redacted to remove the confidential settlement communication therein. 12. On June 2 Mr. Zuromski sent me an email in which he said: “I am authorized to accept service on behalf of Emily Mitra only. You will have to serve the Dosa entities through their registered agents and I cannot represent Mr. Mitra.” Over the next days, Mr. Zuromski and I agreed that both AEM’s and Ms. Mitra’s response to the complaint would be due by June 19. Attached as Exhibit 7 is a true and correct copy of this email chain. 13. With Mr. Zuromski’s entry into the case in mid-May (first on behalf of AEM only and, as of June 2, on behalf of Ms. Mitra too), the parties began to discuss the possibility of settlement and the terms under which settlement can be reached. (See id.) These discussions lasted into mid-July, and it appeared to me that the parties could resolve their dispute. The proposed settlement would have bound all parties, including the defendants that had not yet answered and the defendants that had not been served. As a result of these discussions and my belief (and hope) that we could reach an early resolution, and because I understood that Mr. Zuromski was communicating with at least Ms. Mitra (who, I understood, was communicating 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of Mani Sheik in Response to Order to Show Cause 3 with Mr. Mitra), I did not pursue service of the complaint on the other defendants throughout the negotiation of the possible settlement. 14. Indeed, though Mr. Zuromski and I had initially agreed that AEM’s and Ms. Mitra’s response to the complaint would be due by June 19, the parties’ ongoing settlement talks continued to push back that deadline, as it seemed settlement was imminent. 15. But, unfortunately, the parties were unable to reach a settlement. 16. On July 7, I informed Mr. Zuromski that Plaintiffs would be moving for default against AEM and Ms. Mitra since they had not filed an answer in a timely manner. After further communications with Mr. Zuromski, I agreed that AEM and Ms. Mitra would have until July 9 “but no further” to respond to the complaint. (I am not attaching the emails here because they are so embedded with the parties’ settlement communications that the email would not read very easily if attached.) 17. On July 10, having not received service of an answer despite having extended the deadline only to July 9, I emailed Mr. Zuromski to provide him formal written notice of Plaintiffs’ intent to file for default against AEM and Ms. Mitra. Attached as Exhibit 8 is a true and correct copy of this email. I then began to work on the papers needed to file for default and a default judgment against those defendants. 18. Also on July 10, I caused to be filed the proofs of service of the summons and complaint on AEM and Ms. Mitra. I realize I should have filed these earlier but refrained from doing so because I sincerely and reasonably believed the parties would be able to resolve this dispute without any defendant needing to answer. 19. On July 13, as I was working on and finalizing the default papers, I was served with AEM’s and Ms. Mitra’s answers. (See Docket) 20. On July 20, I contacted Mr. Zuromski to determine if he represented any of the other defendants. I asked because though Mr. Zuromski had previously said he only represented AEM, he later also came to represent Ms. Mitra, so I wanted to see if he now also represented any other defendant(s). Mr. Zuromski replied he did not. Attached as Exhibit 9 is a true and correct copy of this email chain. That turned out to be incorrect (though I do not believe and am 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of Mani Sheik in Response to Order to Show Cause 4 not suggesting that Mr. Zuromski was deliberately misleading me when he wrote this.) 21. On August 13, with no resolution of the case likely in the near future, I hired a third-party process server to attempt to serve personally on Dosa Food, Dosa Holdings, and Mr. Mitra the Summons, Complaint, and other supporting documents. I provided the third-party process server the last known mailing address I had for Mr. Mitra, which is in San Francisco. 22. On August 19, Dosa Food’s agent was personally served. That means Dosa Food’s deadline to reply to the complaint was September 18. Attached as Exhibit 10 is the Proof of Service on Dosa Food. 23. Also on August 19, Dosa Holdings’ agent was served via substitute service. That means Dosa Holdings’ deadline to reply to the complaint was September 28. Attached as Exhibit 11 is the Proof of Service on Dosa Holdings. 24. I am informed and believe that, from August 20 to September 9, the third-party process server attempted to serve Mr. Mitra personally over multiple occasions but was unable to do so. I was informed that the gates at the address given were locked and/or closed, and no one appeared to be home on any of the occasions the server was dispatched-which spanned as early as 8 a.m. and as late as after 7 p.m. Given this, and that the current Covid restrictions would likely have meant at least someone should be in the residence if the address was correct, I sought to confirm Mr. Mitra’s address before attempting another service. I was finally able to confirm Mr. Mitra’s address (which was the address I had provided the third-party process server) and re-hired the server to effectuate personal service on Mr. Mitra. 25. On or about September 21, Mr. Zuromski informed me that he now represented Dosa Holdings (but not, at that time, Dosa Food) and asked for an extension of the deadline for Dosa Holdings to respond to the complaint, until October 5. I agreed to the extension as a courtesy even though I understood Dosa Holdings’ true owners, the Mitras, had known about the case for several months by that time (and, indeed, Ms. Mitra had already filed an answer). Attached as Exhibit 12 is a true and correct copy of this email chain. 26. On October 2, I emailed Mr. Zuromski to see if (like with Ms. Mitra and Dosa Holdings previously) he now, and finally, represented Dosa Food and to provide him formal 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of Mani Sheik in Response to Order to Show Cause 5 written notice of Plaintiffs’ intent to file for default against Dosa Food. Attached as Exhibit 13 is a true and correct copy of this email. I then began to work on the papers needed to file for default and a default judgment against Dosa Food. 27. The next business day, October 5, I again communicated with Mr. Zuromski, several times, about the state of the summons and complaint on the Entity Defendants and my exasperation with how the defendants were dragging out the process of responding to the complaint, often going to the very brink of default. I explained this was particularly problematic with regard to the Entity Defendants since they were sent Notice and Acknowledgment of Receipt of Service forms as far back as April 23. Mr. Zuromski stated that he was unaware of such forms having ever been sent to Dosa Food and Dosa Holdings-though they clearly had been and though he had signed a similar Acknowledgment for AEM on May 14. 28. After making calls to his clients, Mr. Zuromski called me back later the same day to say he would now represent Dosa Food and asked to have Dosa Food’s response date extended. Having already extended deadlines for all other defendants (except Mr. Mitra, who had not replied to any of my communications), I provided a brief extension and asked that the Dosa Food answer be filed by October 7. 29. On October 5, Dosa Holdings filed its answer. 30. On October 7, Dosa Food filed its answer. 31. In short, the four defendants that Mr. Zuromski now represents took nearly five months to file their answers in this case. All four defendants missed at least one deadline to respond to the complaint in a timely manner, and three of the four had to be provided formal notice of intent to file for default before filing an answer. 32. On October 12, the third-party server was finally able to effectuate personal service on Mr. Mitra, after several attempts. Attached as Exhibit 14 is a true and correct copy of the Proof of Service on Mr. Mitra. Mr. Mitra’s response to the Complaint was thus due on November 11. 33. On October 15, I caused to be filed with this Court a Proof of Service on Mr. Mitra. (See Docket) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of Mani Sheik in Response to Order to Show Cause 6 34. Mr. Mitra did not file any responsive pleading by November 11, as required. 35. Having not received further communication from Mr. Mitra or an attorney claiming to represent him (and, in fact, having never received any communication to that point from Mr. Mitra over eight months despite direct correspondence to him), having no service from Mr. Mitra of a responsive pleading, and the Court’s docket showing no such responsive pleading being filed as of November 11, I emailed Mr. Mitra in the morning of November 16 to inform him that I would file a notice of default if he did not reply to me or file an answer by the end of that day. Attached as Exhibit 15 is a true and correct copy of that email only (the attachment is not included here). 36. Despite multiple direct communications-via US and electronic mail-over many months, I did not hear from Mr. Mitra at all between the filing of this action and the filing of a notice of default against him. 37. On November 17, with the time for Mr. Mitra to respond to the Complaint having run and having not heard from him, including in response to my November 16 email, I filed a notice of default with the Court Clerk against Mr. Mitra. That request remains pending with the Court Clerk as of the filing of this declaration. If and when approved, I intend to file for default judgment against Mr. Mitra. 38. After I filed the request for default, Mr. Mitra replied to my email, stating: “Please lmk what you would like to do.” I responded that the notice of default had already been filed. Attached as Exhibit 16 is a true and correct copy of that email chain only (the attachment is not included here). I note, however, that Mr. Mitra did not offer any explanation for why he had not reply to the complaint in a timely manner (or at all in the past eight months). Nor did he say he would soon file a response, ask for additional time, or state that he had engaged counsel to represent him. This email is the sole communication I have had with Mr. Mitra in this entire time. 39. It was never my intent or desire to have the service of process in this case take as long as it has. To the contrary, I was hoping for a quick and simple service, which is why I initiated the process of service on the entity Defendants the very day I received the conformed 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of Mani Sheik in Response to Order to Show Cause 7 copies of the documents (April 23). Unfortunately, however, the defendants seemed to drag out service, by agreeing to Mr. Zuromski’s representation in piecemeal and by repeatedly missing deadlines. And Mr. Mitra never even responded to the complaint. Indeed, I had to provide formal notice of intent to file for default to four of the five defendants in this case-and actually request a default against one (Mr. Mitra). For perspective, I have only provided such notice of intent to file default against two other defendants in my entire career, and never had to file such a document. 40. I am informed and believe these significant delays are due in part to the very acrimonious nature of the Mitras’ divorce. This is information that I have only come to learn recently. Had I known how acrimonious the divorce was, I would have taken a different approach to serving the documents. But any delays on my end were entirely unintentional. 41. I apologize to the Court for the unintentional delays in effectuating service. I am happy to state, however, that all defendants have now been served and four of the five have filed answered, with notice of default pending against the fifth. In fact, four of the five defendants had been served by the time the Court issued its Order to Show Cause, and the fifth (Mr. Mitra) was served within days of the Order (with the service processor having been hired before the Order was issued). I declare under penalty of perjury pursuant to the laws of the California that the foregoing is true and correct. Executed on November 18, 2020, in San Rafael, California. By: Mani Sheik EXHIBIT 1 1 Sheik Law, Inc. 333 WEST PORTAL AVE., SUITE A SAN FRANCISCO, CA 94127 PH: 415-205-8490 MANI@SHEIKLAW.US Via U.S. Mail April 23, 2020 Brandon Smith In His Capacity as Agent for Service of Process for AEM Food & Beverage, Inc. 140 Geary St., 7th Floor San Francisco, CA 94108 Re: Nathan Schatz Family Trust, et al. v. AEM Food & Beverage, Inc., et al. Case No. CGC-20-584100; San Francisco County Superior Court Dear Mr. Smith, Pursuant to the California Code of Civil Procedure section 415.30, this letter effectuates service of the attached documents on AEM Food & Beverage, Inc. in the above case: - Summons - Complaint - Civil Case Cover Sheet - Notice of Case Management Conference - Alternative Dispute Resolution Information Package - Notice and Acknowledgment of Receipt form (two copies) Also attached is a self-addressed, postage prepaid envelope which you can use to return the attached Notice and Acknowledgment of Receipt. Please contact me if you have any questions. I look forward to your prompt return of the Notice. Sincerely, Mani Sheik EXHIBIT 2 1 Sheik Law, Inc. 333 WEST PORTAL AVE., SUITE A SAN FRANCISCO, CA 94127 PH: 415-205-8490 MANI@SHEIKLAW.US Via U.S. Mail April 23, 2020 National Registered Agents, Inc. In Its Capacity as Agent for Service of Process for DOSA Food & Beverage, Inc. 818 West Seventh St., Suite 930 Los Angeles, CA 90017 Re: Nathan Schatz Family Trust, et al. v. AEM Food & Beverage, Inc., et al. Case No. CGC-20-584100; San Francisco County Superior Court Dear Sir or Madam, Pursuant to the California Code of Civil Procedure section 415.30, this letter effectuates service of the attached documents on DOSAFood & Beverage, Inc. in the above case: - Summons - Complaint - Civil Case Cover Sheet - Notice of Case Management Conference - Alternative Dispute Resolution Information Package - Notice and Acknowledgment of Receipt form (two copies) Also attached is a self-addressed, postage prepaid envelope which you can use to return the attached Notice and Acknowledgment of Receipt. Please contact me if you have any questions. I look forward to your prompt return of the Notice. Sincerely, Mani Sheik EXHIBIT 3 1 Sheik Law, Inc. 333 WEST PORTAL AVE., SUITE A SAN FRANCISCO, CA 94127 PH: 415-205-8490 MANI@SHEIKLAW.US Via U.S. Mail April 23, 2020 Camilo Echavarria c/o DWT California, Inc. In His/Its Capacity as Agent for Service of Process for Dosa Holdings Inc., d/b/a Dosa Restaurant Group 865 S. Figueroa St., Suite 2400 Los Angeles, CA 90017 Re: Nathan Schatz Family Trust, et al. v. AEM Food & Beverage, Inc., et al. Case No. CGC-20-584100; San Francisco County Superior Court Dear Mr. Echavarria, Pursuant to the California Code of Civil Procedure section 415.30, this letter effectuates service of the attached documents on Dosa Holdings Inc., d/b/a Dosa Restaurant Group in the above case: - Summons - Complaint - Civil Case Cover Sheet - Notice of Case Management Conference - Alternative Dispute Resolution Information Package - Notice and Acknowledgment of Receipt form (two copies) Also attached is a self-addressed, postage prepaid envelope which you can use to return the attached Notice and Acknowledgment of Receipt. Please contact me if you have any questions. I look forward to your prompt return of the Notice. Sincerely, Mani Sheik EXHIBIT 4 From: Mani Sheik To: emily@dosasf.com; anjan@dosasf.com Bcc: mani@sheiklaw.us Subject: Nathan Schatz Family Trust v. AEM Food & Beverage -- Attempted Service of Summons, Complaint, and Supporting Documents Date: Thursday, May 14, 2020 10:02:42 AM Attachments: Nathan Schatz - Cover letter effectuating service by acknowledgment of receipt -- to Dosa Holdings -- 4-23- 20.pdf Nathan Schatz - Cover letter effectuating service by acknowledgment of receipt -- to Dosa Food and Bev -- 4-23- 20.pdf Nathan Schatz - Cover letter effectuating service by acknowledgment of receipt -- to AEM Food and Bev -- 4-23- 20.pdf Nathan Schatz v. AEM - Complaint -- 4-8-20.pdf Nathan Schatz v. AEM - Summons to Anjan Mitra.pdf Nathan Schatz v. AEM - Summons to Emily Mitra.pdf Nathan Schatz v. AEM - Civil Case Cover Sheet-- conformed - 4-8-20.pdf Nathan Schatz v. AEM - Notice re CMC hearing -- 4-8-20.pdf Nathan Schatz v. AEM - ADR Packet -- 4-8-20.pdf Dear Ms. and Mr. Mitra, If you have retained counsel (which I have not been informed of yet and the Court’s docket does not reflect), please forward this email to your counsel and ask that he/she respond to this email. As the attached documents reflect, service by Notice and Acknowledgment of Receipt of the summons, complaint, and supporting document was effectuated on April 23, 2020, on the various defendant companies (which I understand you ultimately own and control). The deadline for those defendants to sign and return the Acknowledgment of Receipt has expired and I have not received any of the Acknowledgments. I am reaching out to ask that you cause your agents to return the Acknowledgments promptly to avoid defendants’ having to pay additional, and unnecessary, costs related to service. See Cal. Code Civ. Proc. § 415.30 (if the Acknowledgment form is “not returned within 20 days from mailing, defendant will be liable for reasonable costs in being served by another permitted method”). If I do not receive the signed Acknowledgment forms by the end of the day tomorrow, plaintiffs will need to attempt service via other, more expensive means, for which costs defendants will be responsible. Additionally, also attached are copies of the complaint, summons (one for each of you), civil case cover sheet, Notice of Case Management Conference, and ADR packet. In an effort to minimize the costs of service (which, again, defendants will ultimately be responsible for should plaintiffs prevail at trial), I ask that you accept service of these documents. Please let me know if you accept this service (with an effective date of today) or if Plaintiffs will be forced to effectuate personal service on you. I look forward to your prompt response. Thank you, Mani Sheik Sheik Law, Inc. 333 West Portal Ave., Suite A San Francisco, CA 94127 1-415-205-8490 www.sheiklaw.us EXHIBIT 5 From: Richard Zuromski To: mani@sheiklaw.us Subject: Schatz/AEM - Settlement Communication Date: Thursday, May 14, 2020 9:31:33 PM Attachments: Notice and Acknowledgment of Receipt of Complaint.pdf **Confidential Settlement Communication** Mr. Sheik, I am counsel to AEM Food & Beverage, Inc. I was in the process of preparing a response to your letter dated March 11 regarding the loan made to my client by your client Nathan Schatz Family Trust when I learned that you have now filed suit against my client. I’m sure this can be resolved short of legal action for payment on a note. Please reach out to me if you would like to discuss this in more detail. Regards, Richard Zuromski Counsel for AEM Food & Beverage, Inc. Richard J. Zuromski, Jr. Zuromski Law Offices 446 Old County Road Suite 100-115 Pacifica, California 94044 San Francisco Office: 555 California Street Suite 4925 San Francisco, CA 94104 (415) 659-1966 (phone) (415) 659-1950 (fax) rzuromski@zuromski.com www.zuromskilaw.com CFO for AEM Food and Beverage IncEmily Mitra CFO for AEM Food and Beverage Inc. x x Notice of case management conference Civil Case Cover Sheet ADR Packet EXHIBIT 6 From: Richard Zuromski To: mani@sheiklaw.us Subject: RE: Schatz/AEM - Settlement Communication Date: Friday, May 15, 2020 3:01:31 PM Hi Mani. For now I just represent AEM. I’ll have to check with my client about the other parties. I will get back to you as soon as I find out. Regards, Richard From: Mani Sheik Sent: Friday, May 15, 2020 2:47 PM To: 'Richard Zuromski' Subject: RE: Schatz/AEM - Settlement Communication Dear Richard, Thank you for your email. It is nice to meet you and I look forward to working with you. I will respond in full to your email soon, but for now I wanted to confirm whether you represent just AEM Food & Beverage, Inc., as your signature line below suggests, or all five defendants. If you represent all five defendants, can you please confirm that service has been effectuated as against all five (and effectuated as of yesterday, per your email below) or whether plaintiffs will still need to expend the time and resources to serve the other four defendants (the two remaining entity defendants and each individual defendant). If you only represent AEM, can you please put me in touch with the attorney(s) for the other defendants, or will they be proceeding pro per? Thank you, Mani From: Richard Zuromski Sent: Thursday, May 14, 2020 9:31 PM To: mani@sheiklaw.us Subject: Schatz/AEM - Settlement Communication **Confidential Settlement Communication** Mr. Sheik, I am counsel to AEM Food & Beverage, Inc. I was in the process of preparing a response to your letter dated March 11 regarding the loan made to my client by your client Nathan Schatz Family Trust when I learned that you have now filed suit against my client. I’m sure this can be resolved short of legal action for payment on a note. Please reach out to me if you would like to discuss this in more detail. Regards, Richard Zuromski Counsel for AEM Food & Beverage, Inc. Richard J. Zuromski, Jr. Zuromski Law Offices 446 Old County Road Suite 100-115 Pacifica, California 94044 San Francisco Office: 555 California Street Suite 4925 San Francisco, CA 94104 (415) 659-1966 (phone) (415) 659-1950 (fax) rzuromski@zuromski.com www.zuromskilaw.com EXHIBIT 7 From: Richard Zuromski To: mani@sheiklaw.us Subject: RE: My wifi just went out Date: Thursday, June 4, 2020 11:01:46 AM Thank you. I’ll calendar accordingly. From: Mani Sheik Sent: Thursday, June 04, 2020 10:55 AM To: 'Richard Zuromski' Subject: RE: My wifi just went out Sorry, not sure what month I was looking at when I said a Sunday. Yes, June 19 is acceptable for both. Thanks, Mani From: Richard Zuromski Sent: Thursday, June 4, 2020 10:36 AM To: mani@sheiklaw.us Subject: RE: My wifi just went out Right now AEM’s is due on Friday June 12. June 14 is a Sunday. How about both are due on Friday June 19? From: Mani Sheik Sent: Thursday, June 04, 2020 10:03 AM To: 'Richard Zuromski' Subject: RE: My wifi just went out Hi Richard, Thanks for the confirmation on the date of service. I agree we should try to simplify things, but I don’t want to continue to drag this case out by extending deadlines. Your clients have sat with this complaint for more than a month and a half as it is. So we can say both responses can be filed the day AEM’s is due, June 14, if you’d like. Best, Mani From: Richard Zuromski Sent: Thursday, June 4, 2020 9:48 AM To: mani@sheiklaw.us Subject: RE: My wifi just went out Yes, service of the complaint and summons was effectuated on Ms. Mitra as of June 2, 2020, with the response currently due on July 2, 2020. To make this easy (and hopefully we will have settled by then), can I ask that we also make AEM’s response due the same day? Regards, Richard From: Mani Sheik Sent: Thursday, June 04, 2020 9:18 AM To: 'Richard Zuromski' Subject: RE: My wifi just went out Thank you for the update Richard. Then can we agree that service effectuated on Ms. Mitra as of June 2 for calendaring and Proof of Service purposes? Mani From: Richard Zuromski Sent: Tuesday, June 2, 2020 4:40 PM To: mani@sheiklaw.us Subject: RE: My wifi just went out Mani, Things change as we speak. I am authorized to accept service on behalf of Emily Mitra only. You will have to serve the Dosa entities through their registered agents and I cannot represent Mr. Mitra. Regards, Richard From: Mani Sheik Sent: Tuesday, June 02, 2020 2:55 PM To: 'Richard Zuromski' Subject: RE: My wifi just went out Hi Richard, It was nice speaking with you today, and good to connect finally. To confirm, you agreed to let me know by 5pm today whether you will accept service on behalf of any other defendant. As we discussed, for those defendants on whose behalf you are not authorized to accept service, I will need to effectuate service in some other manner, which will only increase the costs and fees your clients will need to pay back to my clients. Thanks, Mani From: Richard Zuromski Sent: Tuesday, June 2, 2020 1:12 PM To: mani@sheiklaw.us Subject: RE: My wifi just went out Let’s talk at 1:30. I’ll call you then. From: Mani Sheik Sent: Tuesday, June 02, 2020 1:11 PM To: 'Richard Zuromski' Subject: RE: My wifi just went out Hi Richard, How about 1:30 or 2? Mani From: Richard Zuromski Sent: Tuesday, June 2, 2020 11:19 AM To: mani@sheiklaw.us Subject: RE: My wifi just went out Trying to use my new wifi extender. Can I call you at 11:30? From: Mani Sheik Sent: Tuesday, June 02, 2020 10:06 AM To: 'Richard Zuromski' Subject: RE: My wifi just went out Hi Richard, We should talk. When are you free today? Mani From: Richard Zuromski Sent: Friday, May 29, 2020 9:08 AM To: mani@sheiklaw.us Subject: RE: My wifi just went out They are working on it, supposedly should be done in the next 2 hours. I’ll just call you once they are done. Richard From: Mani Sheik Sent: Thursday, May 28, 2020 5:57 PM To: 'Richard Zuromski' Subject: RE: My wifi just went out Hi Richard, No problem. I have been having spotty wifi throughout the COVID pandemic, so fully commiserate. Let’s try to talk tomorrow. Best, Mani From: Richard Zuromski Sent: Thursday, May 28, 2020 4:12 PM To: mani@sheiklaw.us Subject: My wifi just went out I thought there was something strange about the call I missed. Wifi is out. I’m trying to remedy the problem and will call you back as soon as I do. Richard Richard J. Zuromski, Jr. Zuromski Law Offices 446 Old County Road Suite 100-115 Pacifica, California 94044 San Francisco Office: 555 California Street Suite 4925 San Francisco, CA 94104 (415) 659-1966 (phone) (415) 659-1950 (fax) rzuromski@zuromski.com www.zuromskilaw.com EXHIBIT 8 From: Mani Sheik To: "Richard Zuromski" Bcc: mani@sheiklaw.us Subject: Schatz/AEM -- Notice of Intent to File for Default against AEM and Emily Mitra Date: Friday, July 10, 2020 12:35:12 PM Importance: High Dear Richard, Having not heard from you since my email on Wednesday, and with the passing of the July 9 extension my clients provided within which time AEM and Emily Mitra should have filed a responsive pleading but failed to so do, Plaintiffs will be filing for default . Best, Mani Sheik Law, Inc. 333 West Portal Ave., Suite A San Francisco, CA 94127 1-415-205-8490 www.sheiklaw.us EXHIBIT 9 From: Richard Zuromski To: mani@sheiklaw.us Subject: RE: DOSA entities Date: Monday, July 20, 2020 4:14:35 PM Hi Mani. No, I’m not representing any of the other entities or Mr. Mitra individually and I don’t know if they have retained counsel. Regards, Richard From: Mani Sheik Sent: Monday, July 20, 2020 4:03 PM To: 'Richard Zuromski' Subject: DOSA entities Hi Richard, I hope you had a nice weekend. I noticed that the answer you filed last week did not answer for the other two (DOSA) entities. Are you their attorney as well? If not, please provide the contact information for their counsel. Also, who is Anjan Mitra’s attorney? Best, Mani EXHIBIT 10 PROOF OF SERVICE OF SUMMONS Form Adopted for Mandatory Use Judicial Council of California POS-010 [Rev. Jan 1, 2007] POS-010 PROOF OF SERVICE OF SUMMONS ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLAINTIFF/PETITIONER: DEFENDANT/RESPONDENT: CASE NUMBER: ATTORNEY FOR (Name): TELEPHONE NO.: Code of Civil Procedure, § 417.10 Ref. No. or File No.: AEM FOOD & BEVERAGE, INC., et al. NATHAN SCHATZ FAMILY TRUST, et al. 1. At the time of service I was a citizen of the United States, at least 18 years of age and not a party to this action. BY FAX 2. I served copies of: Summons, Complaint, Civil Case Cover Sheet, Notice of Case Assignment, Alternative Dispute Resolution Information Package, Notice of Case Assignment 3. a. Party served: b. Person Served: Jessie Gastelum - National Registered Agents, Inc. - Person Authorized to Accept Service of Process 818 West Seventh St., Suite 9304. Address where the party was served: Los Angeles, CA 900175. I served the party a. by personal service. I personally delivered the documents listed in item 2 to the party or person authorized to receive service of process for the party (1) on (date): (2) at (time): 6. The "Notice to the Person Served" (on the summons) was completed as follows: d. on behalf of: 7. Person who served papers a. Name: b. Address: c. Telephone number: d. The fee for service was: $ e I am: (3) registered California process server. (i) Employee or independent contractor. (ii) Registration No.: (iii) County: 8. I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct. Date: (NAME OF PERSON WHO SERVED PAPERS) (SIGNATURE) Mani Sheik, 245487 Sheik Law, Inc. 333 West Portal Ave., Suite A San Francisco, CA 94127 (415) 205-8490 Plaintiff Superior Court of California, San Francisco County 400 McAllister Street San Francisco, CA 94102 CGC-20-584100 DOSA FOOD & BEVERAGE, INC., a Delaware Corporation 08/19/2020 10:20AM DOSA FOOD & BEVERAGE, INC., a Delaware Corporation under: CCP 416.10 (corporation) Paul Garcia One Legal - P-000618-Sonoma 1400 North McDowell Blvd, Ste 300 Petaluma, CA 94954 415-491-0606 80.00 2012070781 LOS ANGELES 08/26/2020 Paul Garcia 15046424OL# EXHIBIT 11 PROOF OF SERVICE OF SUMMONS Form Adopted for Mandatory Use Judicial Council of California POS-010 [Rev. July 1, 2004] POS-010 PROOF OF SERVICE OF SUMMONS ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLAINTIFF/PETITIONER: DEFENDANT/RESPONDENT: CASE NUMBER: ATTORNEY FOR (Name): TELEPHONE NO.: Code of Civil Procedure, § 417.10 Ref. No. or File No.: Mani Sheik, 245487 Sheik Law, Inc. 333 West Portal Ave., Suite A San Francisco, CA 94127 (415) 205-8490 Plaintiff CGC-20-584100 BY FAX1. At the time of service I was a citizen of the United States, at least 18 years of age and not a party to this action. Summons, Complaint, Civil Case Cover Sheet, Notice of Case Assignment, Alternative Dispute Resolution Information Package, Notice of Case Assignment 3. a. Party served: DOSA HOLDINGS, INC., dba DOSA RESTAURANT GROUP, a Delaware Corporation LOS ANGELES 2012070781 Paul Garcia NATHAN CHATZ FAMILY TRUST, et al. AEM FOOD & BEVERAGE, INC., et al. b. Person Served: Camilo Echavarria - Person Authorized to Accept Service of Process 08/26/2020 4. Address where the party was served: 865 S. Figueroa St., Suite 2400 Los Angeles, CA 90017 5. I served the party at (time): 6. The "Notice to the Person Served" (on the summons) was completed as follows: 8. I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct. b. by substituted service. On (date): 08/19/2020 10:45AM I left the documents listed in item 2 with or in the presence of: Jack Sanchez - Person In Charge Of Office (1) (business) a person at least 18 years of age apparently in charge at the office or usual place of business of the person to be served. I informed him or her of the general nature of the papers. DOSA HOLDINGS, INC., dba DOSA RESTAURANT GROUP, a Delaware Corporation $ 2. I served copies of: Person who served papers7. a. Name: e. I am: d. The fee for service was: c. Telephone number: b. Address: (3) registered California process server. (ii) Registration No. (iii) County (i) Employee or independent contractor. Date: (SIGNATURE)(NAME OF PERSON WHO SERVED PAPERS) d. on behalf of: under: CCP 416.10 (corporation) (4) A declaration of mailing is attached. [ ev. Jan 1, 2007] Paul Garcia One Legal - P-000618-Sonoma 1400 North McDowell Blvd, Ste 300 Petaluma, CA 94954 415-491-0606 111.25 Superior Court of California, San Francisco County 400 McAllister Street San Francisco, CA 94102 OL# 15046469 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name and Address): TELEPHONE NO.: FOR COURT USE ONLY ATTORNEY FOR (Name): Ref. No. or File No. Insert name of court, judicial district or branch court, if any: PLAINTIFF: DEFENDANT: PROOF OF SERVICE BY MAIL Mani Sheik, 245487 (415) 205-8490 Sheik Law, Inc. 333 West Portal Ave., Suite A Plaintiff San Francisco-McAllister 400 McAllister Street San Francisco, CA 94102 NATHAN CHATZ FAMILY TRUST, et al. AEM FOOD & BEVERAGE, INC., et al. CGC-20-584100 BY FAX I am a citizen of the United States, over the age of 18 and not a party to the within action. My business address is 1400 N. McDowell Blvd, Petaluma, CA 94954. On 08/27/2020, after substituted service under section CCP 415.20(a) or 415.20(b) or FRCP 4(e)(2)(B) or FRCP 4(h)(1)(B) was made (if applicable), I mailed copies of the: Summons, Complaint, Civil Case Cover Sheet, Notice of Case Assignment, Alternative Dispute Resolution Information Package, Notice of Case Assignment DOSA HOLDINGS, INC., dba DOSA RESTAURANT GROUP, a Delaware Corporation Camilo Echavarria 865 S. Figueroa St., Suite 2400 Los Angeles, CA 90017 I am readily familiar with the firm's practice for collection and processing of documents for mailing. Under that practice, it would be deposited within the United States Postal Service, on that same day, with postage thereon fully prepaid, in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one (1) day after date of deposit for mailing in affidavit. Fee for Service: $ Cesar Lopez I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct and that this declaration was executed on 08/26/2020 at Petaluma, California. to the person to be served at the place where the copies were left by placing a true copy thereof enclosed in a sealed envelope, with First Class postage thereon fully prepaid, in the United States Mail at Petaluma, California, addressed as follows: 111.25 CASE NUMBER: OL# 15046469 One Legal - P-000618-Sonoma 1400 North McDowell Blvd, Ste 300 Petaluma, CA 94954 San Francisco, CA 94127 EXHIBIT 12 From: Richard Zuromski To: mani@sheiklaw.us Subject: Response of Dosa Holdings, Inc. Date: Monday, September 21, 2020 4:42:01 PM Hi Mani. Just confirming our agreement that Dosa Holdings, Inc. has until October 5, 2020 in which to respond to your complaint in the Schatz v. AEM Food & Beverage matter, CGC-20-584100. Regards, Richard Richard J. Zuromski, Jr. Zuromski Law Offices 446 Old County Road Suite 100-115 Pacifica, California 94044 San Francisco Office: One Market Plaza Thirty-Sixth Floor San Francisco, CA 94105 (415) 293-7966 (phone) (415) 293-8001 (fax) rzuromski@zuromski.com www.zuromskilaw.com EXHIBIT 13 From: Mani Sheik To: "Richard Zuromski" Bcc: mani@sheiklaw.us Subject: Schatz et al. v. AEM et al. -- notice of intent to seek default against Dosa Food & Beverage, Inc. Date: Friday, October 2, 2020 9:15:16 AM Hi Richard, I am following up on my earlier communications with you regarding defendant DOSA FOOD & BEVERAGE, INC. (“Dosa Food”). As I explained earlier, Dosa Food was properly served on August 19. When we last spoke, you said that you do not represent Dosa Food. But you had earlier said that you may be representing Dosa Food. As a courtesy, I have waited an additional amount of time to see if Dosa Foods will make an appearance in this case. But Dosa Food’s time to respond to the complaint has now run and they are in default. I am providing this courtesy notice to you because I am not aware of any other counsel in this case, including counsel for Dosa Food, and because of your previous statements that you may be representing Dosa Food. Unless I hear from you or other counsel who actually represent Dosa Food by the end of today, I will need to institute proceedings to secure a default judgment against Dosa Food. Best, Mani Sheik Law, Inc. 526 Third St., Suite A San Rafael, CA 94901 415-205-8490 EXHIBIT 14 PROOF OF SERVICE OF SUMMONS Form Adopted for Mandatory Use Judicial Council of California POS-010 [Rev. Jan 1, 2007] POS-010 PROOF OF SERVICE OF SUMMONS ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLAINTIFF/PETITIONER: DEFENDANT/RESPONDENT: CASE NUMBER: ATTORNEY FOR (Name): TELEPHONE NO.: Code of Civil Procedure, § 417.10 Ref. No. or File No.: AEM FOOD & BEVERAGE., ET AL NATHAN SCHATZ FAMILY TRUST., ET AL 1. At the time of service I was a citizen of the United States, at least 18 years of age and not a party to this action. BY FAX 2. I served copies of: Complaint, Summons, Civil Case Cover Sheet, Notice, Notice--ADR packet 3. a. Party served: b. Person Served: party in item 3a 160 St. Germain4. Address where the party was served: San Francisco, CA 941145. I served the party a. by personal service. I personally delivered the documents listed in item 2 to the party or person authorized to receive service of process for the party (1) on (date): (2) at (time): 6. The "Notice to the Person Served" (on the summons) was completed as follows: a. as an individual defendant. 7. Person who served papers a. Name: b. Address: c. Telephone number: d. The fee for service was: $ e I am: (3) registered California process server. (i) Employee or independent contractor. (ii) Registration No.: (iii) County: 8. I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct. Date: (NAME OF PERSON WHO SERVED PAPERS) (SIGNATURE) Mani Sheik, 245487 Sheik Law, Inc. 526 Third St., Suite A San Rafael, CA 94901 (415) 205-8490 Plaintiff Superior Court of California, San Francisco County 400 McAllister Street San Francisco, CA 94102 CGC-20-584100 Anjan Mitra 10/12/2020 9:41AM Priscila Carmona One Legal - P-000618-Sonoma 1400 North McDowell Blvd, Ste 300 Petaluma, CA 94954 415-491-0606 130.00 521 San Mateo 10/14/2020 Priscila Carmona 15308746OL# 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Proof of Service PROOF OF SERVICE I, Mani Sheik, certify that: I am over the age of eighteen years and not a party to this action. I am employed in the County of Marin. My business address is 526 Third St., Suite A, San Rafael, CA 94901. On October 15, 2020, I served the following document(s) in the following manner on the parties below, through their attorneys of record: Proof of Service of Summons on Anjan Mitra [X] Electronic Service: by prior agreement, and pursuant to Judicial Council of California temporary Emergency Rule #12, I emailed the above document(s) to the following counsel of record in this matter Attorneys for AEM Food & Beverage, Inc., Dosa Food & Beverage, Inc., Dosa Holdings, Inc., and Emily Mitra Richard J. Zuromski, Jr., Esq. Zuromski Law Offices One Market Plaza, 36th Floor San Francisco, CA 94105 Date: October 15, 2020 By: Mani Sheik EXHIBIT 15 From: Mani Sheik To: anjan@dosasf.com Cc: "Richard Zuromski" Subject: URGENT -- Nathan Schatz , et al. v. AEM, et al. -- Notice of Impending Default Judgment Date: Monday, November 16, 2020 11:12:59 AM Attachments: Nathan Schatz v. AEM - POS for Anjan Mitra with POS -- 10-15-20.pdf Dear Mr. Mitra, I am writing you regarding the above matter, as I have not been informed that you are represented by any counsel. You were personally served with the summons, complaint, and supporting papers for this case on October 14, 2020 (a courtesy copy of this service is attached here). Your time to respond to the complaint has now run and I have yet to receive either a responsive pleading or even any communication from you or anyone representing you, and the docket does not reflect any appearance by you. I also note that I previously emailed you and Ms. Mitra-once on March 11, 2020 (i.e., before my clients filed suit) and again on May 14 (i.e., after they had filed this suit, and attaching papers effectuating service by acknowledgement and receipt on the entity defendants), and that you never replied to either of those emails. In other words, you have known about this lawsuit for many months now-indeed, since its inception and even before-and deliberately refused to engage in the litigation. At this point , you are in default and unless I hear from you or your counsel by the end of business today and receive a copy of an answer that is filed by today, my clients will proceed with having a default judgment entered against you. I have cc’d Ms. Mitra’s and the entity defendants’ counsel, Richard Zuromski, so he is aware of this communication. Sincerely, Mani Sheik Sheik Law, Inc. 526 Third St., Suite A San Rafael, CA 94901 415-205-8490 EXHIBIT 16 From: Mani Sheik To: "Anjan Mitra" Cc: "Richard Zuromski" Bcc: mani@sheiklaw.us Subject: RE: URGENT -- Nathan Schatz , et al. v. AEM, et al. -- Notice of Impending Default Judgment Date: Tuesday, November 17, 2020 10:47:59 AM Attachments: Nathan Schatz v AEM -- Sheik Dec iso Default for Anjan Mitra with Exhs. 1-4 -- 11-17-2020.pdf Nathan Schatz -- Entry of Default against Anjan Mitra -- Form Civ100 -- 11-17-20.pdf Dear Mr. Mitra, Unfortunately, since your time to respond to the complaint ran nearly a week ago and you did not file any responsive pleading (and since I believe you have been aware of this case for many months but refused to engage in the case, including by filing a timely response to the complaint), I already filed, this morning, the papers to request that the Court clerk enter your default in this case. A courtesy copy of the papers is attached here and is also being mailed to your address in San Francisco. Best, Mani From: Anjan Mitra Sent: Tuesday, November 17, 2020 10:31 AM To: mani@sheiklaw.us Cc: Richard Zuromski Subject: Re: URGENT -- Nathan Schatz , et al. v. AEM, et al. -- Notice of Impending Default Judgment Hi Mani - Sorry, I am no longer working with DOSA on a regular basis. Please lmk what you would like to do. Thanks, Anjan On Mon, Nov 16, 2020 at 11:13 AM Mani Sheik wrote: Dear Mr. Mitra, I am writing you regarding the above matter, as I have not been informed that you are represented by any counsel. You were personally served with the summons, complaint, and supporting papers for this case on October 14, 2020 (a courtesy copy of this service is attached here). Your time to respond to the complaint has now run and I have yet to receive either a responsive pleading or even any communication from you or anyone representing you, and the docket does not reflect any appearance by you. I also note that I previously emailed you and Ms. Mitra-once on March 11, 2020 (i.e., before my clients filed suit) and again on May 14 (i.e., after they had filed this suit, and attaching papers effectuating service by acknowledgement and receipt on the entity defendants), and that you never replied to either of those emails. In other words, you have known about this lawsuit for many months now-indeed, since its inception and even before-and deliberately refused to engage in the litigation. At this point , you are in default and unless I hear from you or your counsel by the end of business today and receive a copy of an answer that is filed by today, my clients will proceed with having a default judgment entered against you. I have cc’d Ms. Mitra’s and the entity defendants’ counsel, Richard Zuromski, so he is aware of this communication. Sincerely, Mani Sheik Sheik Law, Inc. 526 Third St., Suite A San Rafael, CA 94901 415-205-8490 -- Founder DOSA Instagram/dosasf Instagram/dosabydosa Facebook.com/dosasf Twitter.com/dosasf 415 642 3672 * 995 Valencia Street, SF | 415 441 3672 * 1700 Fillmore Street, SF | 510 285 6823 * 2301 Broadway, Oakland | 20955 Stevens Creek Blvd, Cupertino 2019 - 2007 Michelin Guide Bib Gourmand & Recommended 2018 - 23 Best Restaurants in the US - Thrillst 2018 - Best New Restaurant, Oakland Magazine 2017 Yelp Top 100 Places 2017 "21 Must-Try Dishes to Call Yourself a San Franciscan" Zagat 2016, 2011, 2009 Best Indian Readers Poll Winner - SF Weekly 2015 - 2012, 2007 - 2009 Best Indian, The Eat + Drink Awards - 7x7 Magazine 2014 - 2008 Best Indian, Bay Readers Poll - SF Bay Guardian 2012 - 2006 Top 100 Bay Area Restaurants - SF Chronicle 2012 Top 100 Bay Area Bars - SF Chronicle 2012 The 38 Essential San Francisco Restaurants - Eater SF 2010, 2008 Best Eats in San Francisco - SF Examiner 2009, 2007 Best Indian & Worth the Wait, Reader's Poll Winners - SF Mag The Top 10 (New) Restaurants of 2006 -Michael Bauer - SF Chronicle 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Proof of Service PROOF OF SERVICE I, Mani Sheik, certify that: I am over the age of eighteen years and not a party to this action. I am employed in the County of Marin. My business address is 526 Third St., Suite A, San Rafael, CA 94901. On November 18, 2020, I served the following document(s) in the following manner on the parties below: Declaration of Mani Sheik in Response to Order to Show Cause [X] First Class Mail: I caused such envelope with postage fully prepaid to be placed in the United States Mail at San Francisco, California. Anjan Mitra 160 St. Germain Ave. San Francisco, CA 94114 [X] Electronic Service: by prior agreement, and pursuant to Judicial Council of California temporary Emergency Rule #12, I emailed the above document(s) to the following counsel of record in this matter Richard J. Zuromski, Jr., Esq. Attorneys for AEM Food & Beverage, Inc., Zuromski Law Offices Dosa Food & Beverage, Inc., Dosa One Market Plaza, 36th Floor Holdings, Inc., and Emily Mitra San Francisco, CA 94105 Date: November 18, 2020 By: Mani Sheik