Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 336353 FOR COURT USE ONLY
NAME: Mariah K. Fairley
FIRM NAME: Reed Smith LLP
STREET ADDRESS: 101 Second Street, Suite 1800
CITY: San Francisco STATE: CA ZIP CODE: 94105
TELEPHONE NO.: 415 543 8700 FAX NO.: 415 391 8269
EMAIL ADDRESS: mfairley@reedsmith.com
ATTORNEY FOR (name): G6 Hospitality LLC
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sonoma
STREET ADDRESS: 3055 Cleveland Avenue
MAILING ADDRESS: 3055 Cleveland Avenue
CITY AND ZIP CODE: Santa Rosa, CA 95403
BRANCH NAME: Civil Division
PLAINTIFF/PETITIONER: Cheryl Maier & John Maier
DEFENDANT/RESPONDENT: Jose Alvarez dba Pepe's Landscaping Company, et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE LIMITED CASE SCV-271402
(Amount demanded (Amount demanded is $35,000
exceeds $35,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 05/09/24 Time: 3:00 p.m. Dept.: 19 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Mariah K. Fairley
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. This statement is submitted by party (name): G6 Hospitality LLC, incorrectly sued as G6 Hospitality Property LLC
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. The following parties named in the complaint or cross-complaint
(1) have not been served (specify names and explain why not):
(2) have been served but have not appeared and have not been dismissed (specify names):
(3) have had a default entered against them (specify names):
c. The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of case in complaint cross-complaint (Describe, including causes of action):
Plaintiffs allege that Plaintiff Cheryl Maier sustained personal injury as a result of a automobile accident.
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California
CASE MANAGEMENT STATEMENT rules 3.720–3.730
CM-110 [Rev. January 1, 2024] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: Cheryl Maier & John Maier CASE NUMBER:
SCV-271402
DEFENDANT/RESPONDENT: Jose Alvarez dba Pepe's Landscaping Company, et al.
4. b. Provide a brief statement of the case, including any damages (if personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings; if equitable relief is sought, describe the nature of the relief):
Plaintiff Cheryl Maier was rear ended by Defendant Jose Alvarez and suffered injuries as a result of the automotive
accident. A Motion for Leave to File an Amended Complaint has been filed by Plaintiffs for a wrongful death and
survivor action.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request a jury triaI a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. The trial has been set for (date):
b. No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one)
a. days (specify number): 10-14
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. Email address: g. Party represented:
Additional representation is described in Attachment 8.
9. Preference
This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 of the California Rules of Court for information about the
processes available through the court and community programs in this case.
(1) For parties represented by counsel: Counsel has has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1 775 et seq. (specify exemption):
CM-110 [Rev. January 1, 2024] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Cheryl Maier & John Maier CASE NUMBER:
SCV-271402
DEFENDANT/RESPONDENT: Jose Alvarez dba Pepe's Landscaping Company, et al.
10. c. In the table below, indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to
participate in, or have already participated in (check all that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date): 11/30/2023
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for(date):
conference Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. January 1, 2024] Page 3 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Cheryl Maier & John Maier CASE NUMBER:
SCV-271402
DEFENDANT/RESPONDENT: Jose Alvarez dba Pepe's Landscaping Company, et al.
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes No
c. Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
Bankruptcy Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate wiII be filed by (name party):
14. Bifurcation
The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendant G6 Written Discovery Per Code
Defendant G6 Oral Discovery Per Code
Defendant G6 Expert Discovery Per Code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated
(specify):
CM-110 [Rev. January 1, 2024] Page 4 of 5
CASE MANAGEMENT STATEMENT
CM-110
PLAINTIFF/PETITIONER: Cheryl Maier & John Maier CASE NUMBER:
SCV-271402
DEFENDANT/RESPONDENT: Jose Alvarez dba Pepe's Landscaping Company, et al.
17. Economic litigation
a. This is a limited civil case (i.e., the amount demanded is $35,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
The briefing schedule for G6's Motion for Summary Judgment needs to be reset based on prior Stay and
Plaintiffs' pending Motion for Leave to File an Amended Complaint. Leave to file a supplemental and/or revised
Motion for Summary Judgment is appropriate in light of Plaintiffs' forthcoming Amended Complaint. Plaintiffs'
Motion for Leave to File and Amended Complaint is set for hearing on May 1, 2024.
19. Meet and confer
a. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of
Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any):
I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: 04/24/2024
Mariah K. Fairley
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev. January 1, 2024] Page 5 of 5
CASE MANAGEMENT STATEMENT
1 PROOF OF SERVICE
2 I am a resident of the State of California, over the age of eighteen years, and not a party to the
within action. My business address is 101 Second Street, Suite 1800, San Francisco, CA 94105. On
3 April 24, 2024, I served the following document(s) by the method indicated below:
4 CASE MANAGEMENT STATEMENT
5
by placing the document(s) listed above in a sealed envelope with postage thereon fully
6 prepaid, in the United States mail at San Francisco, California addressed as set forth below.
I am readily familiar with the firm’s practice of collection and processing of correspondence
7 for mailing. Under that practice, it would be deposited with the U.S. Postal Service on that
same day with postage thereon fully prepaid in the ordinary course of business. I am aware
8 that on motion of the party served, service is presumed invalid if the postal cancellation date
or postage meter date is more than one day after the date of deposit for mailing in this
9 Declaration.
10
by transmitting via email to the parties at the email addresses listed below:
A limited liability partnership formed in the State of Delaware
11
12 Richard Sax Jessyca S. Hoagland
Law Offices of Richard Sax Fiumara Law, PC
REED SMITH LLP
13 P.O. Box 1236 182 Farmers Lane, Suite 100A
Santa Rosa, CA 95402 Santa Rosa, CA 95405
14 Email: richard@rsaxlaw.com Email: jessyca@fiumara.com
15 Attorneys for Plaintiffs Attorneys for Plaintiffs
Peter Jon Hirsig
16 Caitlyn Harris
McNamara Ambacher Wheeler Hirsig & Gray
17 639 Kentucky Street
Fairfield, CA 94533-5530
18 Email: Peter.Hirsig@mcnamaralaw.com
Email: Caitlyn.Harris@mcnamaralaw.com
19 Email: heather.permison@mcnamaralaw.com
Email: bpiazza@mcnamaralaw.com
20
Attorneys for Defendant Jose Alvarez dba
21 Pepe’s Landscaping Company
22 I declare under penalty of perjury under the laws of the State of California that the above is
true and correct. Executed on April 24, 2024, at San Francisco, California.
23
24
25 April E. Henderson
26
27
28
–1–
DEFENDANT G6 HOSPITALITY LLC’S OBJECTIONS AND RESPONSES TO
PLAINTIFFS’ REQUEST FOR ADMISSION, SET ONE
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 336353 FOR COURT USE ONLY NAME: Mariah K. Fairley FIRM NAME: Reed Smith LLP STREET ADDRESS: 101 Second Street, Suite 1800 CITY: San Francisco STATE: CA ZIP CODE: 94105 TELEPHONE NO.: 415 543 8700 FAX NO.: 415 391 8269 EMAIL ADDRESS: mfairley@reedsmith.com ATTORNEY FOR (name): G6 Hospitality LLC SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sonoma STREET ADDRESS: 3055 Cleveland Avenue MAILING ADDRESS: 3055 Cleveland Avenue CITY AND ZIP CODE: Santa Rosa, CA 95403 BRANCH NAME: Civil Division PLAINTIFF/PETITIONER: Cheryl Maier & John Maier DEFENDANT/RESPONDENT: Jose Alvarez dba Pepe's Landscaping Company, et al. CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE SCV-271402 (Amount demanded (Amount demanded is $35,000 exceeds $35,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 05/09/24 Time: 3:00 p.m. Dept.: 19 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Mariah K. Fairley INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): G6 Hospitality LLC, incorrectly sued as G6 Hospitality Property LLC b. This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. The following parties named in the complaint or cross-complaint (1) have not been served (specify names and explain why not): (2) have been served but have not appeared and have not been dismissed (specify names): (3) have had a default entered against them (specify names): c. The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type of case in complaint cross-complaint (Describe, including causes of action): Plaintiffs allege that Plaintiff Cheryl Maier sustained personal injury as a result of a automobile accident. Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730 CM-110 [Rev. January 1, 2024] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: Cheryl Maier & John Maier CASE NUMBER: SCV-271402 DEFENDANT/RESPONDENT: Jose Alvarez dba Pepe's Landscaping Company, et al. 4. b. Provide a brief statement of the case, including any damages (if personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings; if equitable relief is sought, describe the nature of the relief): Plaintiff Cheryl Maier was rear ended by Defendant Jose Alvarez and suffered injuries as a result of the automotive accident. A Motion for Leave to File an Amended Complaint has been filed by Plaintiffs for a wrongful death and survivor action. (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request a jury triaI a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. The trial has been set for (date): b. No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the trial will take (check one) a. days (specify number): 10-14 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. Email address: g. Party represented: Additional representation is described in Attachment 8. 9. Preference This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 of the California Rules of Court for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel has has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1 775 et seq. (specify exemption): CM-110 [Rev. January 1, 2024] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Cheryl Maier & John Maier CASE NUMBER: SCV-271402 DEFENDANT/RESPONDENT: Jose Alvarez dba Pepe's Landscaping Company, et al. 10. c. In the table below, indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): 11/30/2023 Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for(date): conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. January 1, 2024] Page 3 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Cheryl Maier & John Maier CASE NUMBER: SCV-271402 DEFENDANT/RESPONDENT: Jose Alvarez dba Pepe's Landscaping Company, et al. 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes No c. Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Bankruptcy Other (specify): Status: 13. Related cases, consolidation, and coordination a. There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: Additional cases are described in Attachment 13a. b. A motion to consolidate coordinate wiII be filed by (name party): 14. Bifurcation The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant G6 Written Discovery Per Code Defendant G6 Oral Discovery Per Code Defendant G6 Expert Discovery Per Code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. January 1, 2024] Page 4 of 5 CASE MANAGEMENT STATEMENT CM-110 PLAINTIFF/PETITIONER: Cheryl Maier & John Maier CASE NUMBER: SCV-271402 DEFENDANT/RESPONDENT: Jose Alvarez dba Pepe's Landscaping Company, et al. 17. Economic litigation a. This is a limited civil case (i.e., the amount demanded is $35,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues The party or parties request that the following additional matters be considered or determined at the case management conference (specify): The briefing schedule for G6's Motion for Summary Judgment needs to be reset based on prior Stay and Plaintiffs' pending Motion for Leave to File an Amended Complaint. Leave to file a supplemental and/or revised Motion for Summary Judgment is appropriate in light of Plaintiffs' forthcoming Amended Complaint. Plaintiffs' Motion for Leave to File and Amended Complaint is set for hearing on May 1, 2024. 19. Meet and confer a. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: 04/24/2024 Mariah K. Fairley (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. January 1, 2024] Page 5 of 5 CASE MANAGEMENT STATEMENT 1 PROOF OF SERVICE 2 I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is 101 Second Street, Suite 1800, San Francisco, CA 94105. On 3 April 24, 2024, I served the following document(s) by the method indicated below: 4 CASE MANAGEMENT STATEMENT 5 by placing the document(s) listed above in a sealed envelope with postage thereon fully 6 prepaid, in the United States mail at San Francisco, California addressed as set forth below. I am readily familiar with the firm’s practice of collection and processing of correspondence 7 for mailing. Under that practice, it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I am aware 8 that on motion of the party served, service is presumed invalid if the postal cancellation date or postage meter date is more than one day after the date of deposit for mailing in this 9 Declaration. 10 by transmitting via email to the parties at the email addresses listed below: A limited liability partnership formed in the State of Delaware 11 12 Richard Sax Jessyca S. Hoagland Law Offices of Richard Sax Fiumara Law, PC REED SMITH LLP 13 P.O. Box 1236 182 Farmers Lane, Suite 100A Santa Rosa, CA 95402 Santa Rosa, CA 95405 14 Email: richard@rsaxlaw.com Email: jessyca@fiumara.com 15 Attorneys for Plaintiffs Attorneys for Plaintiffs Peter Jon Hirsig 16 Caitlyn Harris McNamara Ambacher Wheeler Hirsig & Gray 17 639 Kentucky Street Fairfield, CA 94533-5530 18 Email: Peter.Hirsig@mcnamaralaw.com Email: Caitlyn.Harris@mcnamaralaw.com 19 Email: heather.permison@mcnamaralaw.com Email: bpiazza@mcnamaralaw.com 20 Attorneys for Defendant Jose Alvarez dba 21 Pepe’s Landscaping Company 22 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on April 24, 2024, at San Francisco, California. 23 24 25 April E. Henderson 26 27 28 –1– DEFENDANT G6 HOSPITALITY LLC’S OBJECTIONS AND RESPONSES TO PLAINTIFFS’ REQUEST FOR ADMISSION, SET ONE