BC593971

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Shaun Setareh (SBN 204514) shaun@setarehlaw .com

Thomas Segal (SBN 222791) thomas@setarehlaw .com

Farrah Grant, (SBN 293898) farrah@setarehlaw. com

SET AREH LAW GROUP 9454 Wilshire Boulevard, Suite 907 Beverly Hills, California 90212 Tel: (310) 888-7771 , Fax: (310) 888-0109

8 Attorneys for Plaintiff, ARMANDO JUAREZ

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

ARMANDO JUAREZ, on behalf of himself, all others similarly situated, and the general public

Plaintiffs,

vs.

SIMON ' S ELECTRICAL CORP., a California corporation; SIMON RUBIN, an individual; and DOES 2-50, inclusive,

Def endants.

) Case No. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

NOTICE OF LODGING OF EXECUTED SETTLEMENT AGREEMENT

____________________________)

NOTICE OF LODGIN G OF EXECUTED SETTLEMENT AGREEMENT

TO EACH PARTY AND EACH ATTORNEY OF RECORD IN THIS ACTION: 1

2 Please take notice that Plaintiff is lodging the fully executed settlement agreement in the

3 above-entitled action, attached as "Exhibit 1."

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7 Dated: November 8, 2017

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SETAREH LAW GROUP

BY ~"z/;-SHAUN SET AREH, THOMAS SEGAL, FARRAH GRANT, Attorneys for Plaintiff, ARMANDO JUAREZ

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NOTICE OF LODGING OF EXECUTED SETTLEMENT AGREEMENT

EXHIBIT ''1''

STIPULATION OF SETTLEMENT

This Stipulation of Settlement ("Settlement" or "Settlement Agreement") is reached by and between Plaintiff Armando Juarez ('·Plaintiff'), individually and on behalf of all members of the Settlement Class, defined below, and Defendants Simons Electrical Corp. ("SEC") and Simon Rubin (collectively ·'Defendants") (Plaintiff and Defendants are referred to herein collectively as the '"Parties"). Plaintiff and the Settlement Class are represented by Shaun Setareh ofSetareh Law Group (''Class Counsel"). Defendants are represented by Jeremy Osher of Boren, Osher & Luftman, LLP.

Plaintiff Annando Juarez filed a Complaint against Defendants in Los Angeles Superior Court on September 11 , 2015, in the matter entitled Armando Juarez v. Simon 's Electrical Corp., Case No. BC593971 , ( .. Complaint"). The Complaint and subsequent First Amended Complaint ("FAC") (collectively the "Lawsuit" ) alleged that Defendants: (i) failed to provide non-exempt employees with all timely and legally-compliant meal periods; (ii) failed to authorize and permit non-exempt employees to take all required rest periods for each four-hour work period, or major portion thereof; (iii) failed to pay all hourly and overtime wages to non-exempt employees; (iv) failed to issue accurate wage statements to non-exempt employees; (v) failed to indemnify non­exempt employees for necessary business-related expenses and costs; and (vi) failed to pay non­exempt employees all wages owed at the time of their separation from employment. As a result of the foregoing violations, Plaintiff contended that Defendants were also liable to Plaintiff and the Settlement Class (defined below) because they engaged in unlawful business practices. Plaintiff further alleged that Defendants were liable for civil penalties pursuant to the Private Attorneys General Act of 2004 ("PAGA"), California Labor Code Sections 2698 et seq. as a result ofthe aforementioned violations of the California Labor Code.

Given the uncertainty of litigation, Plaintiff and Defendants wish to settle both individually and on behalf of the Settlement Class. Accordingly, Plaintiff and Defendants agree as follows:

1. Settlement Class. For the purposes of this Settlement Agreement only, Plaintiff and Defendants stipulate to cet1ification of the following Settlement Class:

All current and former hourly, non-exempt SEC employees who worked for SEC in California at any time from September 1 1, 2011 through the date of preliminary approval of the Settlement Agreement.

The Parties agree that certification for purpose of settlement is not an admission that class certification is proper under Section 382 of the Code of Civil Procedure. If for any reason this Settlement Agreement is not approved or is terminated, in whole or in part, this conditional agreement to class certification will be inadmissible and will have no effect in this matter or in any claims brought on the same or similar allegations, and the parties shall revert to the respective positions they held prior to entering into the Settlement.

2. Releases by Settlement Class Members and Plaintiff. Plaintiff and every member of the Settlement Class who does not opt-out of the Settlement will fully release and discharge Defendants (including Simon Rubin individually) and all of their past, present and/or future, direct and/or indirect, officers, directors, members, managers, employees, agents,

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representatives, attorneys, insurers, partners, investors, shareholders, administrators, parent companies, subsidiaries, affiliates, divisions, predecessors, successors, assigns, and joint venturers (collectively the .. Released Parties"), as follows:

A. Settlement Class members will release all claims that were alleged and those claims that could have been alleged based on the facts in the operative complaint (the "Released Claims"). The period of the Release shall run from September 11 , 201 I through the date of preliminary approval of the Settlement Agreement (the ·'Class Period"). The res judicata effect of the judgment will be the same as that ofthe Release.

B. In light of Plaintiffs Class Representative Service Award (described below), Plaintiff has also agreed to release, in addition to the Released Claims described above, all claims, whether known or unknown, under federal law or state law against the Released Parties. Plaintiff understands that this release includes unknown claims and that they are, as a result, waiving all rights and benefits afforded by Section 1542 of the California Civil Code, which provides:

A general release does not extend to claims which the creditor does not know or suspect to exist in his or her favor at the time of executing the release, which if known by him or her must have materially affected his or her settlement with the debtor.

3. Maximum Settlement Amount. As consideration, Defendants agree to pay a maximum amount ("'Maximum Settlement Amount") of Four Hundred Thousand Dollars and Zero Cents ($400,000.00) in full and complete settlement of this matter:

A. The Parties have agreed to engage CPT Group, Inc. as the "Settlement Administrator" to administer this Settlement.

B. The Maximum Settlement Amount shall be deposited with the Settlement Administrator within sixty (60) calendar days after the Final Approval Date (which, for this purpose shall be defined as the date on which the Court enters an Order granting final approval) or, solely in the event that there are any objections to the settlement (the filing of an objection being a prerequisite to the filing of an appeal), the later of: (I) the last date on which any appeal might be filed or (2) the successful resolution of any appeal(s) - including expiration of any time to seek reconsideration or further review.

C. The Maximum Settlement Amount includes:

(I) All payments to members of the Settlement Class;

(2) All costs of settlement administration, which are anticipated to be no greater than Twelve Thousand Dollars and Zero Cents ($12,000.00);

(3) Up to Five Thousand Dollars and Zero Cents ($5,000.00) for Plaintiff as a Class Representative Service Award, in recognition of Plaintiffs

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contributions to the Lawsuit and their service to the Settlement Class as well as the general release of claims described above. Defendants will not oppose this request. Even in the event that the Court reduces or does not approve the requested Class Representative Service Award, Plaintiff shall not have the right to revoke this Settlement, and it will remain binding;

(4) Up to One Hundred Thirty-Three Thousand, Three Hundred Thirty-Three Dollars and Thi1ty-Three Cents ($133,333.33) in attorneys' fees (one-third of the Maximum Settlement Amount), plus actual costs and expenses related to the Lawsuit as supported by declaration which will not exceed $15,000.00. Defendants will not oppose this request. Even in the event that the Court reduces or does not approve the requested attorneys ' fees and costs, Plaintiffs counsel shall not have the right to revoke this settlement, and it will remain binding; and

(5) Twenty-Five Thousand Dollars and Zero Cents ($25,000.00) of the Maximum Settlement Amount has been set aside by the Parties as PAGA civil penalties. Per Labor Code § 2699(i), seventy-five percent (75%) of such penalties, or Eighteen Thousand, Seven Hundred Fifty Dollars and Zero Cents ($18,750.00) will be payable to the Labor & Workforce Development Agency ("L WDA''), and the remaining twenty-five percent (25%), or Six Thousand, Two Hundred Fifty Dollars and Zero Cents ($6,250.00), will be payable to certain Settlement Class members as the "PAGA Amount," as described below.

D. Defendants· required FICA and other payroll taxes resulting from the payment of Settlement Shares to Settlement Class members ('·Employer Taxes'').

4. 4. Payment to Class Members. Settlement Class members will be mailed checks directly with no need to submit a claim form.

A. The Notice Packet shall list the estimated Settlement Share for each respective Settlement Class member based on that Settlement Class member's total number of workweeks within the Class Period. The Notice Packet will include a Spanish translation of the notice.

B. The Settlement Administrator shall determine the eligibility for, and the amount of, any Settlement Shares using Defendants' records under the tem1s of this Agreement. Settlement Class members wi11 have the opp01tunity, should they disagree with Defendants' records regarding their number of workweeks worked stated on their Notice Packet, to provide documentation and/or an explanation to show a different result. If there is a dispute, the Settlement Administrator will consult with the Parties to detennine whether an adjustment is warranted. If an agreement regarding the dispute cannot be reached, then the Parties will submit the dispute to the Court for final ruling at the time of Final Approval of the Settlement Agreement.

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5. Settlement Shares will be determined and paid as follows:

A. The Settlement Administrator shall first deduct from the Maximum Settlement Amount the amounts approved by the Court for Class Counsel· s attorneys· fees, Class Counsers costs and expenses, Plaintiffs Class Representative Service Award, the Settlement Administrator's fees and expenses for administration, the LWDA's share of PAGA penalties, and the Employer Taxes. The remaining amount shall be known as the "Net Settlement Fund."

B. Defendants shall provide the Settlement Administrator with the total number of eligible workweeks worked by all Settlement Class members during the Class Period within ten (I 0) calendar days of the date of preliminary approval. The Settlement Administrator will divide the number of workweeks worked by each individual Settlement Class member by the total number of workweeks worked by all Settlement Class members in the Class Period who do not opt out, resulting in a payment ratio for each individual Settlement Class member ("Payment Ratio").

1. Seventy percent (70%) of the Net Settlement Fund will be available to Settlement Class members and shall be calculated by multiplying each Settlement Class member·s Payment Ratio by 70% of the Net Settlement Fund.

11. Waiting Time Amount: Twenty percent (20%) of the Net Settlement Fund shall be designated as the '·Waiting Time Amount.'. Each Settlement Class member who separated their employment from Defendants at any time from September 11 , 2012 through the date of preliminary approval shall receive an additional amount equal to their Payment Ratio multiplied by the Waiting Time Amount.

111. Wage Statement Amount: Ten percent ( 1 0%) of the Net Settlement Fund shall be designated as the "Wage Statement Amount.'. Each Settlement Class member who was employed by Defendants at any time from September 11 , 20 I 4 through the date of preliminary approval shall receive an additional amount equal to their Payment Ratio multiplied by the Wage Statement Amount.

tv. PAGA Amount: Six Thousand, Two Hundred Fifty Dollars and Zero Cents ($6,250.00) of the Maximum Settlement Amount has been designated as the '·PAGA AmounC. Each Settlement Class member who was employed by Defendants at any time from September 1 I, 2014 through the date of preliminary approval shall receive an additional amount equal to their Payment Ratio multiplied by the PAGA Amount

C. Within fourteen (14) calendar days following the deposit of the Maximum Settlement Amount with the Settlement Administrator by Defendants, the Settlement Administrator will calculate Settlement Share amounts and provide the same to the Patiies for review and approval. Pursuant to the Final Approval

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Order, the Settlement Administrator will prepare and mail Settlement Shares to Settlement Class members. The Settlement Administrator shall simultaneously submit the necessary reports associated with the Employer Taxes to Defendants' counsel.

D. For purposes of calculating applicable taxes and withholdings for the Settlement Class members, each Settlement Share shall be allocated as follows: one third (33.33%) as wages and two thirds (66.66%) as penalties and interest. The Settlement Administrator will be responsible for issuing to participating Settlement Class members an IRS Fonn W-2 for amounts deemed '·wages" and an IRS Form 1099 for the portions allocated as penalties and interest. Notwithstanding the treatment of the payments to each Settlement Class member above, none of the payments called for by this Settlement Agreement, including the wage portion, are to be treated as earnings, wages, pay or compensation for purposes of any applicable benefit or retirement plan, unless required by such plans.

E. Checks issued to Settlement Class members will be valid for 180 days from the date the Settlement Administrator mails them. Any funds payable to Settlement Class members whose checks were not cashed within 180 days after mailing wi ll escheat to the state Department of Industrial Relations in the name of the Settlement Class member.

F. Neither Plaintiff nor Defendants shall bear any liability for lost or stolen checks, forged signatures on checks, or unauthorized negotiation of checks. Unless responsible by its own acts of omission or commission, the same is true for the Settlement Administrator.

6. Attorneys' Fees and Costs. Defendants will not object to a request for a total award of attorneys· fees of up to one-third of the Maximum Settlement Amount, which is One Hundred Thirty-Three Thousand, Three Hundred Thirty-Three Dollars and Thirty-Three Cents ($ 133,333.33), plus actual costs and expenses as supported by declaration, not to exceed $15,000.00.

7. These amounts will cover any and all work performed and any and all costs incutTed in connection with this litigation, including without limitation: all work perfonned and all costs incurred to date; and all work to be perf01med and costs to be incurred in connection with obtaining the Cout1·s approval of this Settlement Agreement, including any objections raised and any appeals necessitated by those objections. Class Counsel will be issued an IRS Form I 099 by the Settlement Administrator when it pays the fee and cost award approved by the Com1, which amount shall be paid to Class Counsel on the same date that Settlement Shares are mailed to participating Settlement Class members.

8. Class Representative Service Award. Defendants will not object to a request for Class Representative Service Award of up to Five Thousand Dollars and Zero Cents ($5,000.00) to Plaintiff for his time and risks in prosecuting this case and his service to the Settlement Class as well as a general release of claims. This award will be in addition to Plaintiffs Settlement Share

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as a Settlement Class member, and shall be reported on an IRS Form 1 099 by the Settlement Administrator, and shall be paid to Plaintiff on the same date that Settlement Shares are mailed to participating Settlement Class members.

9. Settlement Administrator. Defendants will not object to the appointment of CPT Group, Inc. as Settlement Administrator, nor to Class Counsel seeking permission to pay up to Twelve Thousand Dollars and Zero Cents ($12,000.00); for its services from the Maximum Settlement Amount. The Settlement Administrator shall be responsible for sending notices and for calculating Settlement Shares and preparing all checks and mailings. The Settlement Administrator shall be authorized to pay itself from the Maximum Settlement Amount by Class Counsel only after all Settlement Shares have been mailed to all participating Settlement Class members.

I 0. Preliminary Approval. Upon execution of this Settlement Agreement, Plaintiff shaii apply to the Court for the entry of an Order:

A. Conditionally certifying the Settlement Class for purposes of this Settlement Agreement;

B. Appointing Shaun Setareh of Setareh Law Group as Class Counsel;

C. Appointing Armando Juarez as Class Representative for the Settlement Class;

D. Approving CPT Group, Inc. as Settlement Administrator;

E. Preliminarily approving this Settlement Agreement and its tenns as fair, reasonable, and adequate;

F. Approving the fonn and content of the Class Notice and directing the mailing of same; and

G. Scheduling a Final Approval hearing.

11 . Notice to Settlement Class. Following preliminary approval , the Settlement Class shall be notified as follows:

A. Within ten (I 0) calendar days after entry of an order preliminarily approving this Settlement, Defendants will provide the Settlement Administrator, in electronic fonnat, with the names, last known addresses, and social security numbers of all potential Settlement Class members, as weii as the dates of employment and the number of workweeks worked by each potential Settlement Class member during the Class Period.

B. Within ten (1 0) calendar days from receipt of this information, the Settlement Administrator shall (i) run the names of aii potential Settlement Class members through the National Change of Address ("NCOA '') database to determine any updated addresses for potential Settlement Class members, (ii) update the addresses of any Settlement Class member for whom an updated address was

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found through the NCOA search, and (iii) mail the Notice Packet to each potential Settlement Class member at his or her last known address or at the updated address found through the NCOA search, and retain proof of mailing.

C. Requests for Exclusion. Any Settlement Class member who wishes to opt-out of the Settlement must complete and mail a Request for Exclusion (defined below) to the Settlement Administrator within sixty (60) calendar days of the date of the initial mailing of the Notice Packets (the ·'Response Deadline").

1. The Notice Packet shall state that Settlement Class members who wish to exclude themselves from the Settlement must submit a Request for Exclusion by the Response Deadline. The Request for Exclusion must: ( 1) contain the name, address, telephone number and last four digits of the Social Security number of the Settlement Class member; (2) contain a statement that the Settlement Class member wishes to be excluded from the Settlement; (3) be signed by the Settlement Class member; and (4) be postmarked by the Response Deadline and mailed to the Settlement Administrator at the address specified in the Class Notice. If the Request for Exclusion does not contain the infonnation listed in (I )-(3), it will not be deemed valid for exclusion from this Settlement, except a Request for Exclusion not containing a Class Member·s telephone number and/or last four digits of the Social Security number will be deemed valid. The date of the postmark on the Request for Exclusion shall be the exclusive means used to determine whether a Request for Exclusion has been timely submitted. Any Settlement Class member who requests to be excluded from the Settlement Class will not be entitled to any recovery under this Settlement and will not be bound by the tenns of this Settlement or have any right to object, appeal or comment thereon.

11. If more than ten percent (1 0%) of the Settlement Class members validly opt­out of the Settlement, Defendants may, at their discretion, elect to revoke this Settlement Agreement and stipulation to class certification by communicating that decision to both the Settlement Administrator and Class Counsel within five (5) business days after the Settlement Administrator first reports to the Parties that more than I 0% of Settlement Class members have validly opted­out; provided however, that Defendants will be responsible for any costs and fees incurred by the Settlement Administrator in connection with the Settlement.

111. The Parties and their counsel agree not to take any action to encourage any Settlement Class member to opt-out of and/or object to the Settlement.

D. Objections. Settlement Class members who do not opt-out may object to the Settlement as explained in the Class Notice by mailing a written objection to the Settlement Administrator (who shall serve all objections as received on Class Counsel and Defendants' counsel , as well as file all such objections with the Court, no later than two (2) business days after receipt). Defendants' counsel and Class Counsel shall file any responses to objections no later than the deadline to

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file the Motion for Final Approval. To be valid, any objection must: (J) contain the objecting Settlement Class member' s full name and current address, as well as contact infonnation for any attorney representing the objecting Settlement Class member for purposes of the objection; (2) include all objections and the factual and legal basis for same; (3) include any and all supporting papers, briefs, written evidence, declarations, and/or other evidence; and (4) be postmarked no later than the Response Deadline. A Settlement Class member who wishes to object but who fails to comply with the objection procedures set forth herein shall be deemed not to have objected. The Parties shall not be responsible for any fees, costs, or expenses incurred by any Settlement Class member and/or his or her counsel related any objections to the Settlement and/or appeals arising therefrom.

E. Any Notice Packets returned to the Settlement Administrator as non-deliverable on or before the Response Deadline shall be re-mailed to the forwarding address affixed thereto. If no forwarding address is provided, the Settlement Administrator shall make reasonable efforts, including utilizing a "skip trace,'· to obtain an updated mailing address within five (5) business days of receiving the returned Notice Packet. If an updated mailing address is identified, the Settlement Administrator shall resend the Notice Packet to the Settlement Class member promptly, and in any event within three (3) business days of obtaining the updated address. Settlement Class members to whom Notice Packets are re-sent after having been returned as undeliverable to the Settlement Administrator shall have forty-five (45) calendar days from the date of re-mailing to mail a Request for Exclusion or Objection or dispute. Notice Packets that are re-sent shall infonn the recipient of this adjusted deadline. If a Settlement Class member's Notice Packet is returned to the Settlement Administrator more than once as non-deliverable, then an additional Notice Packet shall not be mailed. Nothing else shall be required of, or done by, the Parties, Class Counsel , or Defendants· counsel to provide notice of the Settlement.

12. Final Approval. Following preliminary approval and the close of the petiod for filing requests for exclusion, objections, or disputes under this Settlement Agreement, Plaintiff shall apply to the Court for entry of an Order:

A. Granting final approval to the Settlement Agreement and adjudging its tenns to be fair, reasonable, and adequate;

B. Approving Plaintiffs and Class Counser s applications for attorneys' fees , costs, Class Representative Service Award, settlement administration costs, and the LWDA 's share ofPAGA penalties; and

C. Enteringjudgment pursuant to California Rule of Court 3.769.

D. Notice of final judgment will be given to the class via the claims administrator's website.

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13. Non-Admission of Liability. Nothing in this Agreement shall operate or be construed as an admission of any liability or that class certification is appropriate in any context other than this Settlement Agreement. Each of the Parties has entered into this Settlement Agreement to avoid the burden and expense of further litigation. Pursuant to California Evidence Code Section 1152, this Settlement Agreement is inadmissible in any proceeding, except a proceeding to approve, interpret, or enforce this Settlement Agreement. If Final Approval does not occur, the Patiies agree that this Settlement Agreement is void, but remains protected by California Evidence Code Section 1152.

14. Waiver and Amendment. The Parties may not waive, amend, or modifY any provision of this Settlement Agreement except by a written agreement signed by all of the Parties, and subject to any necessary Court approval. A waiver or amendment of any provision of this Settlement Agreement will not constitute a waiver of any other provision.

15. Notices. All notices, demands, and other communications to be provided concerning this Settlement Agreement shall be in writing and delivered by receipted delivery and by e-mail at the addresses set forth below, or such other addresses as either Party may designate in writing from time to time:

if to Defendants:

if to Plaintiff:

Jeremy Osher, Boren, Osher & Luftman, LLP, 222 N Sepulveda Blvd #2222, El Segundo, California 90245, josher@bollaw.com

Shaun Setareh, Setareh Law Group, 9454 Wilshire Blvd #907, Beverly Hills, California 90212, shaun@setarehlaw .com

16. Entire Agreement. This Settlement Agreement contains the entire agreement between the Parties with respect to the transactions contemplated hereby, and supersedes all negotiations, presentations, warranties, commitments, offers, contracts and writings prior to the date hereof relating to the subject matters hereof.

17. No Construction Against the Drafter. Each party has cooperated in the drafting and preparation of this Settlement Agreement. Hence, in any construction to be made of this Settlement Agreement, the same shall not be construed against any party on the basis that the party was the drafter.

18. Counterparts. This Settlement Agreement may be executed by one or more of the Parties on any number of separate counterparts and delivered electronically, and all of said counterparts taken together shall be deemed to constitute one and the same instrument.

19. Disputes as to Settlement Agreement. Any dispute between the Parties as to the remaining tenns of the Settlement Agreement shall be decided by the Court.

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Nov 0317. 12:34p Simons Electric

DATED:

DATED:

DATED:

DATED: tl-} ·f'=(-

DATED:

310-837-5777 p.1

SIMONS ELECTRICAL CORP.

By: ~\~~ B~~ Defendant ~

Its: ~~~

SIMON RUBIN

ARMANDO JUAREZ

By: ___ __________ _

Plaintiff and Settlement Class Representative

APPROVED AS TO FORM: --- ...- - - ·- ..

BOREN,p81:fER&·-z;;~MAN, LLP

By: Shaun Selareh Attorneys for Plaintiff

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DocuSign Envelope 10: 8AA2DEFF-8B56-4B4F-9E98-06C3560E96A6

DATED: SIMONS ELECTRICAL CORP.

By: _____________ ~--Defendant

Its: ________________ _

DATED: SIMON RUBTN

By: _______________ _ Defendant

DATED: 11/7/2017 ARMANDO JUAREZ

B-r-~-~-g~-db_Y' __________________ _

Y~fffflfflaWeJSettlement Class Representative

APPROVED AS TO FORM:

DATED:

DATED:

BOREN, OSHER & LUFTMAN, LLP

By: ____________ ___ Jeremy Osher Attorneys for Defendants

SE~=LAWGRDU By:7_,£.__---:::::=--..:::::::::.--------

S etareh Attorneys for Plaintiff

PagelOoflO

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State of California, County ofLos Angeles

PROOF OF SERVICE

1. I am a citizen of the United States and am employed in the County of Los Angeles, State of California. I am over the age of 18 years, and not a party to the within action. My business address is 9454 Wilshire Boulevard, Ste. 90/", Beverly Hills, CA 90212.

2. described as:

On the Wednesday. November 08, 2017, l served the foregoing document

NOTICE OF LODGING OF 'EXECUTED SETTLEMENT AGREEMENT

II (X) BY ELECTRONIC SERVICE

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Pursuant to the Court's January 22, 2016 Order authorizing Electronic Service, the above-named documents have been electronically served on counsel of record by transmission on Case Anywhere sy~tem on the date below. The transmission of these documents to Case Anywhere system was reported complete and a copy of the Case Anywhere transaction receipt will be maintained along with the original document(s) and proof of service in our office ..

I declare under penalty of pet:jury under the laws of the State of California that the above is true and correct.

Executed on Wednesday, November 08, 21)1 7, at Bev..::rly