1 P. Dustin Bodaghi, Bar No.

271501
dbodaghi@littler.com
2 Tony Zhao, Bar No. 313328
tzhao@littler.com
3 LITTLER MENDELSON, P.C.
18565 Jamboree Road
4 Suite 800
Irvine, California 92612
5 Telephone: 949.705.3000
Fax No.: 949.724.1201
6
Attorneys for Respondent
7 PRIME HEALTHCARE MANAGEMENT, INC.
8
JAMS ARBITRATION
9

10
SALVADOR VENEGAS GONZALEZ, JR., Case No. 523-0000-172
11
Claimant, RESPONDENT’S RESPONSES TO
12 CLAIMANT’S INTERROGATORIES,
v. SET TWO
13
PRIME HEALTHCARE MANAGEMENT INC
14 (PHMI),

15 Respondent.

16

17
PROPOUNDING PARTY: Claimant SALVADOR VENEGAS GONZALEZ, JR.
18
RESPONDING PARTY: Respondent PRIME HEALTHCARE MANAGEMENT, INC.
19
SET NO.: TWO (2)
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LITTLER MENDELSON,
P.C.
18565 Jamboree Road
Suite 800
Irvine, CA 92612 RESPONDENT’S RESPONSES TO CLAIMANT’S INTERROGATORIES, SET TWO
949.705.3000
 1 TO CLAIMANT AND THEIR ATTORNEYS OF RECORD:
2 Respondent PRIME HEALTHCARE MANAGEMENT, INC. (“Respondent”) responds to
3 the second set of Interrogatories, served upon it by Claimant SALVADOR VENEGAS
4 GONZALEZ, JR. (“Claimant”) as follows:
5 GENERAL OBJECTIONS
6 Respondent objects to Claimant’s interrogatories as a whole, and to each interrogatory
7 contained therein, to the extent they request information that is protected from disclosure by the
8 attorney-client privilege, the attorney work product doctrine, and/or any other applicable privilege,
9 immunity, or protection.
10 Respondent objects to Claimant’s interrogatories as a whole, and to each interrogatory
11 contained therein, to the extent they request the disclosure of confidential, proprietary, or trade
12 secret information of Respondent.
13 Respondent objects to Claimant’s interrogatories as a whole, and to each interrogatory
14 contained therein, to the extent they seek information the release of which would be a violation of
15 any individual’s right of privacy under Article I, Section 1 of the California Constitution, and/or
16 any other constitutional, statutory, or common law protection of privacy rights.
17 Respondent has not completed its investigation relating to this action, has not completed
18 discovery in this action, and has not completed preparation for trial. As discovery proceeds, facts,
19 information, evidence, documents, and things may be discovered which are not set forth in these
20 responses but which may have been responsive to these interrogatories. The following responses
21 are based on the knowledge, information, and belief of Respondent at this time and are complete
22 as to the best knowledge of Respondent at this time. Further, Respondent prepared these responses
23 based on its good faith interpretation and understanding of the individual interrogatories, and these
24 responses are subject to correction for inadvertent errors or omissions, if any. These responses are
25 given without prejudice to subsequent revision or supplementation based upon any information,
26 evidence, and documentation which hereinafter may be discovered. Respondent reserves the right
27 to refer to, to conduct discovery with reference to, or to offer into evidence any and all facts,
28
LITTLER MENDELSON,
P.C.
Attorneys at Law 2
18565 Jamboree Road
Suite 800 RESPONDENT’S RESPONSES TO CLAIMANT’S INTERROGATORIES, SET TWO
Irvine, CA 92612
949.705.3000
 1 evidence, documents, and things developed during the course of discovery and trial preparation,
2 notwithstanding the reference to facts, evidence, documents, and things in these responses.
3 Respondent further objects to the sentence in red font in Claimant’s “Instructions to the
4 Answering Party” as being an improper interrogatory included in the Instructions, seeks to violate
5 the privacy and/or confidentiality of Respondent, its past and/or present employees, and/or other
6 third-party individuals who are not parties to this action under the Constitution of the United States
7 and the State of California as well as under common law privacy principles, and on the grounds
8 that it seeks information protected by the attorney-client privilege, the work product privilege,
9 and/or that were prepared in anticipation of litigation.
10 Respondent hereby responds as follows:
11 RESPONSES TO INTERROGATORIES
12 INTERROGATORY NO. 1:
13 Do you contend that the EMPLOYEE suffered any of the unlawful conduct alleged in the
14 complaint? If so:
15 a. state the name, ADDRESS, telephone number and employment position of each
16 PERSON whom you contend engaged in the unlawful conduct alleged to in the Complaint,
17 b. for each PERSON whom you content participated in the unlawful conduct alleged to in
18 the Complaint;
19 c. identify each characteristic (for example, gender, race, age, etc) on which you base your
20 contention;
21 d. state the name ADDRESS telephone number of each person with knowledge of those
22 facts; and e. identify all documents evidencing those facts.
23 RESPONSE TO INTERROGATORY NO. 1:
24 Respondent objects to this interrogatory on the ground that it is compound, overly broad,
25 unduly burdensome, and oppressive. Respondent objects to this interrogatory to the extent it seeks
26 information equally available to the Claimant. Respondent further objects on the grounds that this
27 interrogatory is vague and ambiguous as to the phrase “suffered,” “unlawful conduct,” and
28 “characteristic.” Respondent further objects to this interrogatory on the basis that it calls for a legal
LITTLER MENDELSON,
P.C.
Attorneys at Law 3
18565 Jamboree Road
Suite 800 RESPONDENT’S RESPONSES TO CLAIMANT’S INTERROGATORIES, SET TWO
Irvine, CA 92612
949.705.3000
 1 conclusion. Respondent objects to this interrogatory insofar as it seeks to violate the privacy and/or
2 confidentiality of Respondent, its past and/or present employees, and/or other third-party
3 individuals who are not parties to this action under the Constitution of the United States and the
4 State of California as well as under common law privacy principles. Respondent objects to this
5 interrogatory on the grounds that it seeks information protected by the attorney-client privilege, the
6 work product privilege, and/or that were prepared in anticipation of litigation.
7 Subject to and without waiving said objections, Respondent responds as follows:
8 Respondent does not contend that Claimant was subject to any of the unlawful conduct alleged in
9 this matter.
10 INTERROGATORY NO. 2:
11 Was any part of the parties' EMPLOYMENT relationship governed in whole or in part by
12 any any [sic] written rules guidelines, policies or procedures by the EMPLOYER? If so, for each
13 DOCUMENT containing the written rules, guidelines, policies or procedures:
14 a. state the date and title of the DOCUMENT and a general description of its contents.
15 b. Sate the manner in which the DOCUMENT was communicated to employees, and
16 c. state the manner in which the the [sic] employees acknowledge its contents.
17 RESPONSE TO INTERROGATORY NO. 2:
18 Respondent objects to this interrogatory to the extent it calls for a legal opinion.
19 Respondent additionally objects to this interrogatory on grounds that it is vague and ambiguous as
20 to the terms “governed,” “policies” and “procedures.” Respondent also objects to this interrogatory
21 to the extent it seeks information that is irrelevant to the subject matter of this action and not
22 reasonably calculated to lead to admissible evidence. Respondent objects to this interrogatory on
23 grounds that it calls for information or documentation protected by the work-product doctrine
24 and/or the attorney-client privilege. Respondent further objects to this interrogatory to the extent
25 it seeks the addresses and telephone numbers of third parties on the grounds that the information
26 sought is neither relevant to the subject matter of this action nor reasonably calculated to lead to
27 the discovery of admissible evidence and is privileged and confidential under the constitutional
28 rights of privacy.
LITTLER MENDELSON,
P.C.
Attorneys at Law 4
18565 Jamboree Road
Suite 800 RESPONDENT’S RESPONSES TO CLAIMANT’S INTERROGATORIES, SET TWO
Irvine, CA 92612
949.705.3000
 1 Subject to and without waiving said objections, Respondent responds as follows: Yes.
2 (a) Claimant’s employment was governed by Respondent’s Employee Handbook and
3 Respondent’s standalone policies, regarding anti-harassment, anti-discrimination and anti-
4 retaliation, and other of Respondent’s requirements.
5 (b)-(c) Claimant and other employees signed acknowledgments upon receiving the
6 Employee Handbook.
7 Respondent further refers Claimant to documents previously produced at PHMI 0000183-
8 0000204.
9 INTERROGATORY NO. 3:
10 Did the EMPLOYEE take time off work to get medical attention for injuries CAUSED by
11 a crime or abuse, receive services from a domestic violence shelter, program, rape crisis center or
12 victim services organization or agency as a result the crime or abuse, receive psychological
13 counseling or mental health services related to an experience of crime or abuse or participated in
14 safety planning and take other action to increase safety from future CRIME or abuse?
15 RESPONSE TO INTERROGATORY NO. 3:
16 Respondent objects to this interrogatory to the extent it seeks information equally and/or
17 better available to the Claimant. Respondent objects to this interrogatory on the ground that it is
18 compound, overly broad, unduly burdensome, and oppressive. Respondent further objects on the
19 grounds that this interrogatory is vague and ambiguous as to the phrases/terms “medical attention
20 for injuries,” “abuse,” “victim services organization or agency,” “mental health services,” and
21 “safety planning.” Respondent further objects to the terms “CAUSED” and “CRIME” as being
22 vague and undefined by Claimant.
23 Subject to and without waiving said objections, Respondent responds as follows: Based on
24 the information provided by Claimant to Respondent, he was granted a leave of absence from
25 October 19, 2022 through November 14, 2022 due to alleged domestic violence.
26 INTERROGATORY NO. 4:
27 Was there any communications between the EMPLOYEE (or the EMPLOYEE'S HEALTH
28 CARE PROVIDER, social worker or victims' advocate) and the EMPLOYER (PHMI) to take time
LITTLER MENDELSON,
P.C.
Attorneys at Law 5
18565 Jamboree Road
Suite 800 RESPONDENT’S RESPONSES TO CLAIMANT’S INTERROGATORIES, SET TWO
Irvine, CA 92612
949.705.3000
 1 off from work to obtain relief from a court, including obtaining a restraining order, to protect the
2 EMPLOYEE'S health, safety and welfare?
3 RESPONSE TO INTERROGATORY NO. 4:
4 Respondent objects to this interrogatory on the grounds that it exceeds the ten (10)
5 interrogatory limits forth in the arbitration agreement and the arbitrator’s Memorandum of
6 Preliminary Management Call #1 dated June 24, 2023 as Interrogatory Nos. 1 and 2 contain
7 subparts which in whole exceed the limits. Respondent objects to this interrogatory on the ground
8 that it is compound, overly broad, unduly burdensome, and oppressive. Respondent objects to this
9 interrogatory to the extent it seeks information equally available to the Claimant. Respondent
10 further objects on the grounds that this interrogatory is vague and ambiguous as to the phrase
11 “health, safety and welfare.” Respondent objects to this interrogatory on the grounds that it seeks
12 information protected by the attorney-client privilege, the work product privilege, and/or that were
13 prepared in anticipation of litigation. Respondent further objects to the phrase “HEALTH CARE
14 PROVIDER” as being vague and undefined by Claimant.
15 Subject to and without waiving said objections, Respondent responds as follows: Based on
16 the information provided by Claimant to Respondent, he was granted a leave of absence from
17 October 19, 2002 through November 14, 2022 for alleged domestic violence during which Claimant
18 advised Respondent that he had obtained a restraining order.
19 INTERROGATORY NO. 5:
20 Did the EMPLOYEE need any accommodation to perform any function of the Employee's
21 job position or need a transfer to another position as an accommodation? If so, describe the
22 accommodations needed.
23 RESPONSE TO INTERROGATORY NO. 5:
24 Respondent objects to this interrogatory on the grounds that it exceeds the ten (10)
25 interrogatory limits forth in the arbitration agreement and the arbitrator’s Memorandum of
26 Preliminary Management Call #1 dated June 24, 2023 as Interrogatory Nos. 1 and 2 contain
27 subparts which in whole exceed the limits. Respondent objects to this interrogatory on the ground
28 that it is compound, overly broad, unduly burdensome, and oppressive. Respondent objects to this
LITTLER MENDELSON,
P.C.
Attorneys at Law 6
18565 Jamboree Road
Suite 800 RESPONDENT’S RESPONSES TO CLAIMANT’S INTERROGATORIES, SET TWO
Irvine, CA 92612
949.705.3000
 1 interrogatory to the extent it seeks information equally available to the Claimant. Respondent
2 further objects on the grounds that this interrogatory is vague and ambiguous as to the phrase “need”
3 and “perform any function.” Respondent further objects to this interrogatory on the basis that it
4 calls for an expert opinion and a legal conclusion.
5 Subject to and without waiving said objections, Respondent responds as follows:
6 Respondent states that based on the information provided by Claimant to Respondent, he was
7 granted a leave of absence from October 19, 2022 through November 14, 2022 for alleged domestic
8 violence. No additional accommodations were requested by Claimant.
9 INTERROGATORY NO. 6:
10 What did the EMPLOYER consider doing to accommodate the EMPLOYEE? For each
11 accommodation considered:
12 a. describe the accommodation considered;
13 b. state whether the accommodation was offered to the EMPLOYEE;
14 c. state the Employee's response, or
15 d. if the accommodation was not offered, state all the reasons why this decision was made;
16 e. state the name address and phone number of each person who on be half [sic] of the the
17 [sic] made any decisions about what accommodating, if any, to make for the EMPLOYEE and
18 f. state the name and address and telephone number of each PERSON who on behalf of
19 the EMPLOYER made a reasonable on about what [sic]
20 RESPONSE TO INTERROGATORY NO. 6:
21 Respondent objects to this interrogatory on the grounds that it exceeds the ten (10)
22 interrogatory limits forth in the arbitration agreement and the arbitrator’s Memorandum of
23 Preliminary Management Call #1 dated June 24, 2023 as Interrogatory Nos. 1 and 2 contain
24 subparts which in whole exceed the limits. Respondent objects to this interrogatory on the ground
25 that it is compound, overly broad, unduly burdensome, and oppressive. Respondent further objects
26 on the grounds that this interrogatory is vague and ambiguous as to the phrase “consider” and
27 “reasons.” Respondent further objects to this interrogatory on the basis that it calls for an expert
28 opinion and a legal conclusion. Respondent objects to this interrogatory insofar as it seeks to violate
LITTLER MENDELSON,
P.C.
Attorneys at Law 7
18565 Jamboree Road
Suite 800 RESPONDENT’S RESPONSES TO CLAIMANT’S INTERROGATORIES, SET TWO
Irvine, CA 92612
949.705.3000
 1 the privacy and/or confidentiality of Respondent, its past and/or present employees, and/or other
2 third-party individuals who are not parties to this action under the Constitution of the United States
3 and the State of California as well as under common law privacy principles.
4 Subject to and without waiving said objections, Respondent responds as follows:
5 Respondent states that based on the information provided by Claimant to Respondent, he was
6 granted a leave of absence from October 19, 2022 through November 14, 2022 for alleged domestic
7 violence. No additional accommodations were requested by Claimant.
8 INTERROGATORY NO. 7:
9 Was the EMPLOYEE involved in a TERMINATION? If so:
10 a. state all reasons for the EMPLOEE'S TERMINATION,
11 b. STATE THE NAME, ADDRESS AND telephone number of each PERSON who
12 participated in the TERMINATION DECISION,
13 c. STATE THE NAME address AND TELEPHONE NUMBER OF each person WHO
14 PROVIDED ANY INFORMATION RELATED UPON INTHE [sic] termination DECISION,
15 and
16 d. identify all DOCUMENTS relied upon in the TERMINATION decision.
17 RESPONSE TO INTERROGATORY NO. 7:
18 Respondent objects to this interrogatory on the grounds that it exceeds the ten (10)
19 interrogatory limits forth in the arbitration agreement and the arbitrator’s Memorandum of
20 Preliminary Management Call #1 dated June 24, 2023 as Interrogatory Nos. 1 and 2 contain
21 subparts which in whole exceed the limits. Respondent objects to this interrogatory on the ground
22 that it is compound, overly broad, unduly burdensome, and oppressive. Respondent further objects
23 on the grounds that this interrogatory is vague and ambiguous as to the phrase “participated in.”
24 Respondent objects to this interrogatory insofar as it seeks to violate the privacy and/or
25 confidentiality of Respondent, its past and/or present employees, and/or other third-party
26 individuals who are not parties to this action under the Constitution of the United States and the
27 State of California as well as under common law privacy principles. Respondent objects to this
28
LITTLER MENDELSON,
P.C.
Attorneys at Law 8
18565 Jamboree Road
Suite 800 RESPONDENT’S RESPONSES TO CLAIMANT’S INTERROGATORIES, SET TWO
Irvine, CA 92612
949.705.3000
 1 interrogatory on the grounds that it seeks information protected by the attorney-client privilege, the
2 work product privilege, and/or that were prepared in anticipation of litigation.
3 Subject to and without waiving said objections, Respondent states as follows:
4 Yes.
5 (a) Pursuant to California Code of Civil Procedure section 2030.210(a)(2), Respondent
6 refers Claimant to the Separation of Employment previously produced at bates nos. PHMI
7 0000153-0000154, which contains responsive information.
8 (b) Payroll Director Denise Fleury, in consultation with Human Resources, made the
9 decision to terminate Claimant’s employment.
10 (c) Payroll Director Denise Fleury, Payroll Manager Amanda Maupin, and Payroll
11 Supervisor James Wee provided information about Claimant’s performance, which lead to his
12 termination.
13 (d) Respondent refers Claimant to the Separation of Employment, previously produced
14 at bates nos. PHMI 0000153-0000154, and prior Corrective Actions, previously produced at bates
15 nos. PHMI 0000017 and PHMI 0000021-0000022, which contain responsive information.
16 Respondent will further produce additional documents and communications regarding the reasons
17 for Claimant’s termination.
18 INTERROGATORY NO. 8:
19 At the termination meeting if representatives of the defendant employer demanded or
20 caused the claimant's termination, state exactly what was said to the claimant regarding the
21 claimant's termination by representatives of the defendant employer, identifying each comment or
22 conversation with the person speaking, and exactly what was said by the claimant in response.
23 RESPONSE TO INTERROGATORY NO. 8:
24 Respondent objects to this interrogatory on the grounds that it exceeds the ten (10)
25 interrogatory limits forth in the arbitration agreement and the arbitrator’s Memorandum of
26 Preliminary Management Call #1 dated June 24, 2023 as Interrogatory Nos. 1 and 2 contain
27 subparts which in whole exceed the limits. Respondent objects to this interrogatory on the ground
28 that it is compound, overly broad, unduly burdensome, and oppressive. Respondent objects to this
LITTLER MENDELSON,
P.C.
Attorneys at Law 9
18565 Jamboree Road
Suite 800 RESPONDENT’S RESPONSES TO CLAIMANT’S INTERROGATORIES, SET TWO
Irvine, CA 92612
949.705.3000
 1 interrogatory to the extent it seeks information equally available to the Claimant. Respondent
2 further objects on the grounds that this interrogatory is vague and ambiguous as to the phrase
3 “exactly what was said.” Respondent further objects to this interrogatory on the grounds that it calls
4 for a narrative, which would be better suited for a deposition.
5 Subject to and without waiving said objections, pursuant to California Code of Civil
6 Procedure section 2030.210(a)(2), Respondent refers Claimant to the Separation of Employment
7 previously produced at bates nos. PHMI 0000153-0000154, which contains responsive
8 information.
9 INTERROGATORY NO. 9:
10 Except for this action, in the past 10 years has any employee filed a civil action against the
11 EMPLOYER regarding his or her employment? If so, for each civil action:
12 a. state the name address and telephone number of each employee who filed the action;
13 b. state the court, names of the parties, and case number of the civil action;
14 c. state the name address and phone number of any attorney representing the
15 EMPLOYER; and
16 d. state weather the action has been resolved or is pending.
17 RESPONSE TO INTERROGATORY NO. 9:
18 Respondent objects to this interrogatory on the grounds that it exceeds the ten (10)
19 interrogatory limits forth in the arbitration agreement and the arbitrator’s Memorandum of
20 Preliminary Management Call #1 dated June 24, 2023 as Interrogatory Nos. 1 and 2 contain
21 subparts which in whole exceed the limits. Respondent objects to this interrogatory on the ground
22 that it seeks information that is neither relevant to the subject matter of this action no reasonably
23 calculated to lead to the discovery of admissible evidence. Respondent further objects that the
24 terms “against” and “Regarding his or her employment” are vague and ambiguous, and are
25 therefore unintelligible. Respondent objects to this interrogatory on the grounds that it is overly
26 broad, unduly burdensome, oppressive, and harassing. In addition, Respondent objects to this
27 interrogatory on the ground that disclosure of the information sought would violate the privacy
28 rights of third parties to this litigation under the Constitution of the United States and the State of
LITTLER MENDELSON,
P.C.
Attorneys at Law 10
18565 Jamboree Road
Suite 800 RESPONDENT’S RESPONSES TO CLAIMANT’S INTERROGATORIES, SET TWO
Irvine, CA 92612
949.705.3000
 1 California and under common law privacy principles. Respondent further objects to this
2 interrogatory to the extent it seeks information that is privileged and confidential pursuant to the
3 attorney-client privilege and the attorney work product doctrine. Respondent also objects to this
4 interrogatory on the grounds that it seeks a legal conclusion and assumes facts neither admitted nor
5 established. Respondent objects to this interrogatory because, to the extent it seeks public
6 information, the information is equally available to Claimant. [See Bunnell v. Sup. Ct. (1967) 254
7 Cal.App.2d 720, 723-7245; see also Alpine Mut. Water Co. v. Sup. Ct.(1968) 259 Cal.App.2d 45,
8 53 (interrogating party cannot force answering party to search public records to ascertain answers
9 to interrogatories); see generally Code Civ. Proc., § 2030.22, subd. (c).]
10 INTERROGATORY NO. 10:
11 Did payroll supervisor, James Wee, ever say to the EMPLOYEE “I love you, Sal”? And if
12 so:
13 a. state the name, address, telephone number and job title of each person who heard the
14 comment, and how often;
15 b. state the name address and phone number and job title of each person who participated
16 in the investigation of the allegation of the comment; and
17 c. state the name address telephone number and job title of each person who was
18 interviewed or who provided an oral or written statement as part of an investigation of the alleged
19 comment?
20 RESPONSE TO INTERROGATORY NO. 10:
21 Respondent objects to this interrogatory on the grounds that it exceeds the ten (10)
22 interrogatory limits forth in the arbitration agreement and the arbitrator’s Memorandum of
23 Preliminary Management Call #1 dated June 24, 2023 as Interrogatory Nos. 1 and 2 contain
24 subparts which in whole exceed the limits. Respondent objects to this interrogatory on the ground
25 that it is compound, overly broad, unduly burdensome, and oppressive. Respondent further objects
26 on the grounds that this interrogatory is vague and ambiguous as to the phrase “ever say.”
27 Respondent further objects to this interrogatory on the grounds that it calls for a narrative, which
28 would be better suited for a deposition.
LITTLER MENDELSON,
P.C.
Attorneys at Law 11
18565 Jamboree Road
Suite 800 RESPONDENT’S RESPONSES TO CLAIMANT’S INTERROGATORIES, SET TWO
Irvine, CA 92612
949.705.3000
 1 Subject to and without waiving said objection, Respondent states that it is not aware of any
2 formal complaint made by Claimant to Respondent’s Human Resources concerning Mr. Wee
3 making the comment “I love you, Sal.”
4
Dated: August 23, 2023
5 LITTLER MENDELSON, P.C.
6

7
P. Dustin Bodaghi
8 Tony Zhao
9 Attorneys for Respondent
PRIME HEALTHCARE MANAGEMENT,
10 INC.
11
4866-3590-9490.3 / 096475-1146
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LITTLER MENDELSON,
P.C.
Attorneys at Law 12
18565 Jamboree Road
Suite 800 RESPONDENT’S RESPONSES TO CLAIMANT’S INTERROGATORIES, SET TWO
Irvine, CA 92612
949.705.3000
 1 PROOF OF SERVICE
SALVADOR GONZALEZ V. PRIME HEALTHCARE MANAGEMENT INC.., et al .
2

3 I am employed in the County of Orange, State of California. I am over the age of 18,
and not a party to the within action. My business address is 18565 Jamboree Road, Suite 800,
4 Irvine, CA 92612-25654.

5 On August 23, 2023, I served the within documents described as: RESPONDENT’S
RESPONSES TO CLAIMANT’S INTERROGATORIES, SET TWO on the interested parties
6 by placing ☐ the original [or] ☒a true copy thereof ☐to interested parties as follows [or] ☒as
stated on the below service list:
7
Salvador Venegas Gonzalez Jr. Telephone: 909-461-7154
8 1356 W. Stoneridge Ct. Email: salgon@me.com
Unit 6
9 Ontario, CA 91762
10
as follows:
11

12 � BY MAIL (FRCP 5(b)(1)(C)): I enclosed the document(s) in a sealed envelope or

package addressed to the persons at the addresses above and (specify one):
13
� deposited the sealed envelope with the United States Postal Service, with the postage
14 fully prepaid.

15 � BY ELECTRONIC MAIL WHERE INDICATED: Pursuant to FRCP 5(b)(2)(E),

I served the foregoing document(s) described by emailing to it each of the
16 aforementioned electronic mail addresses and the transmission was reported as
complete and without error. My email address is Egranados@littler.com
17

18 I hereby certify that I am employed in the Office of a member of the Bar

19 of this Court at whose direction the service was made. Executed on August 23, 2023,
20 at Phoenix, Arizona..
21

22

23 /s/ Evangeline Granados

Evangeline Granados
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LITTLER MENDELSON, P.C.
18565 JAMBOREE ROAD
14.
SUITE 800
IRVINE, CA 92612
949.705.3000