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DEFENDANT AND CROSS-COMPLAINANT WESTERN NATIONAL CONSTRUCTION'S NOTICE OFCOMPLIANCE WITH THE CASE MANAGEMENT ORDER RE: DEPOSIT OF EXPERT FILE

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GREEN & HALL, LLPMICHAEL J. PEPEK, State Bar No. 178238

mpepek@greenhall.comSAMUEL M. DANSKIN, State Bar No. 136044

sdanskin@greenhall.comMICHAEL A. ERLINGER, State Bar No. 216877

merlinger@greenhall.com1851 East First Street, 10th FloorSanta Ana, California 92705-4052Telephone: (714) 918-7000Facsimile: (714) 918-6996

Attorneys for WESTERN NATIONALCONSTRUCTION

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SANTA CLARA

CILKER APARTMENTS, LLC,

Plaintiff,

vs.

WESTERN NATIONAL CONSTRUCTION,et al.,

Defendants.

CASE NO. 113CV258281

DEFENDANT AND CROSS-COMPLAINANT WESTERN NATIONALCONSTRUCTION'S NOTICE OFCOMPLIANCE WITH THE CASEMANAGEMENT ORDER RE: DEPOSIT OFEXPERT FILE

DATE: June 6, 2016

JUDGE: Hon. Peter H. KirwanDEPT.: 1ACTION FILED: December 26, 2013TRIAL DATE: July 11, 2016

AND RELATED CROSS-ACTIONS

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

Defendant and Cross-Complainant Western National Construction (“Western”), in

compliance with the Case Management Order, has electronically deposited the expert files of Paul

Habibi to the document depository, located at Aiken & Welch, 1 Kaiser Plaza, Suite 250, Street,

Oakland California 94612.

Please note that Western objects to the Case Management Order to the extent it calls for

the deposit and production of documents and/or information protected by the attorney-client

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DEFENDANT AND CROSS-COMPLAINANT WESTERN NATIONAL CONSTRUCTION'S NOTICE OFCOMPLIANCE WITH THE CASE MANAGEMENT ORDER RE: DEPOSIT OF EXPERT FILE

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privilege and/or the attorney work product doctrine. Further, Western’s investigation and

discovery into the facts and circumstances involved in this matter is ongoing. To the extent such

investigation and discovery reveals information bearing upon Western’s response to the Case

Management Order, Western reserves the right to supplement and/or change its response.

Subject to and without waiving the foregoing objections, Western has produced all

relevant, responsive, non-privileged, non-publicly available documents within Western’s

possession, custody and control.

Attached as Exhibit "A" are the expert job files. The deposited documents are as follows:

Bates Range Description

WNC-GA 000001-000007 Habibi – CV

WNC-GA 000008 Documents Relied Upon

DATED: June 6, 2016 GREEN & HALL, LLP

Michael A. ErlingerAttorneys for WESTERN NATIONALCONSTRUCTION

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DEFENDANT AND CROSS-COMPLAINANT WESTERN NATIONAL CONSTRUCTION'S NOTICE OFCOMPLIANCE WITH THE CASE MANAGEMENT ORDER RE: DEPOSIT OF EXPERT FILE

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EXHIBIT "A"

Paul Habibi, CPA 149 South Barrington Avenue, Suite 705

Los Angeles, CA 90049 Telephone: (424) 256-6230

E-mail: Paul@GrayslakeAdvisors.com

SUMMARY PROFILE

Highly qualified and multi-faceted business professional and educator. Top-ranked, tenured lecturer at UCLA Anderson Graduate School of Management and UCLA School of Law, and successful real estate investor, developer and Certified Public Accountant (CPA). Extensive experience as expert witness, public speaker, consultant and Board member.

REPRESENTATIVE EXPERT WORK IN LITIGATION (ATTORNEY REFERENCES AVAILABLE)

Grayslake Advisors, LLC, Los Angeles, CA 2008-Present Principal and Founder • Provide expert testimony in matters related to real estate, securities, banking, finance, economics and

accounting (for more information, visit http://www.GrayslakeAdvisors.com) • Representative cases include:

Shasha v. Malkin Retained by Defendant Defendant’s Counsel: Dewey, Pegno & Kramarsky LLP American Arbitration Association Case No. 01-14-0001-6986 Represented defendants, the Malkin family and related entities, in a class action alleging the fraudulent and coerced conversion of ownership interests in the Empire State Building through a multi-billion dollar IPO that created Empire State Realty Trust, Inc., a publicly traded REIT (NYSE: ESRT) Art Cohen v. Donald J. Trump Retained by Plaintiff Plaintiff’s Counsel: Robbins, Geller, Rudman & Dowd LLP United States District Court, Southern District of California, Case No. 13-cv-2519-GPC-WVG Represented plaintiff in a civil RICO class action alleging a fraudulent educational scheme, Trump University, was employed by defendant Donald J. Trump to sell real estate seminars and mentorships and mislead student-victims under the Trump moniker

United States Securities and Exchange Commission v. Loomis Wealth Solutions, et al. Retained by Plaintiff Plaintiff’s Counsel: United States Securities and Exchange Commission (SEC) United States District Court, Eastern District of California, Case No. S-10-458 KJM KJN Represented the SEC, in a case involving fraud and misappropriation of funds by a fund manager who syndicated capital for the origination of $10 million of residential junior mortgages; evaluated 120 home equity lines of credit and appraisals, noting that none of the properties had a deed of trust recorded in favor of the funds, and that even if they had, the loan-to-value ratios would have exceeded fund maximums; also opined on the inadequacy of investor guaranties; obtained summary judgment

WNC-GA 000001

United States of America v. Lawrence “Lee” Loomis, et al. Retained by Plaintiff Plaintiff’s Counsel: United States Attorney’s Office United States District Court, Eastern District of California, Case No. 2:12-CR-00315-JAM Represented the United States Attorney’s Office and Federal Bureau of Investigation in a criminal case involving an alleged mortgage fraud conspiracy and large-scale Ponzi scheme in Northern California that victimized more than 100 people and caused more than $7 million of losses related to the sale of shares in a real estate investment program called the Naras Funds Rincon EV Realty, LLC, et al. v. CP Rincon Towers, Inc., et al. Retained by Plaintiff Plaintiff’s Counsel: David Boies of Boies, Schiller & Flexner LLP Superior Court, State of California, County of San Francisco, Case No. CGC 10-496887 Represented plaintiff, a multifamily property owner, in breach of contract, fraud and slander of title case against Maiden Lane Trust, Federal Reserve Bank of New York, BlackRock and Carmel Partners; evaluated potential refinancing/recapitalization alternatives that would have been available to plaintiff but for lender interference with the waterfall provisions of a $110 million senior bridge loan In re Estate Financial, Inc. Debtor/Thomas P. Jeremiassen, Ch. 11 Trustee v. Bryan Cave LLP, et al. Retained by Defendant Defendant’s Counsel: Gibson, Dunn & Crutcher LLP United States District Court, Central District of California, Case No. 9:08-bk-11457-PC Adversary Case No. 9-11-ap-01146-PC Represented defendant against bankruptcy trustee’s claims of professional negligence, breach of contract, and breach of fiduciary duty in connection with alleged damages of over $100 million to over 1,500 individual investors in Estate Financial, Inc. and Estate Financial Mortgage Fund

Noble, et al. v. Greenberg Traurig, LLP, Wells Fargo Capital Finance, Inc., et al. Retained by Defendant Defendant’s Counsel: Fenwick & West LLP and Williams & Connolly LLP Superior Court, State of California, County of Alameda, Case No. RG11593201 Represented defendant against class action alleging breach of fiduciary duty, securities fraud, and misrepresentation that allegedly resulted in a loss of $700 million of investor capital; valued portfolio of hard money loans and provided opinions relating to the risk profiles of real estate development projects Border Business Park, Inc. v. City of San Diego Retained by Defendant Defendant’s Counsel: Latham & Watkins LLP Superior Court, State of California, County of San Diego, Central, Case No. 692794 Represented defendant against claims of inverse condemnation and breach of contract in connection with the development agreement of a 312-acre industrial parcel at Otay Mesa in the City of San Diego; performed detailed analysis of debt burden and valuation of entire parcel over a 30-year horizon

D.T. Woodard, Inc., et al. v. United Parcel Service (UPS), et al. Retained by Defendant Defendant’s Counsel: Morrison & Foerster LLP

WNC-GA 000002

Superior Court, State of California, County of Los Angeles, Case No. BC294647 Represented defendant against class action alleging false statements and omission of material facts in the conversion from the Mail Boxes Etc. (MBE) to the UPS franchise model, and claims that MBE franchisees suffered irreparable financial harm as a result of reliance on defendant’s negligent and intentional misrepresentations

MJW Investments v. Sears Holding Company Retained by Defendant Defendant’s Counsel: Sheppard, Mullin, Richter & Hampton LLP Superior Court, State of California, County of Los Angeles, Case No. BC361451 JAMS Arbitration Case No. 1220040924 Represented defendant against claims of tortious interference and slander of title; performed residual land value analysis of historic 23-acre Sears development site in Boyle Heights district of Los Angeles

The Irvine Company LLC, et al. v. California Pacific Homes, Inc., et al. (multiple cases) Retained by Defendant Defendant’s Counsel: Lorber, Greenfield & Polito LLP, Newmeyer & Dillion LLP, et al. (1) Oak Glen Apartments: Superior Court, State of California, County of Orange, Case No. 30-2011-00438784-CU-CD-CXC (2) Quail Meadow Apartments: Superior Court, State of California, County of Orange, Case No. 30-2012-00577644-CU-CD-CXC (3) Sycamores at North Park Apartments: Superior Court, State of California, County of Santa Clara, Case No. 1-12-CV-234522 (4) Somerset Apartments: Superior Court, State of California, County of Orange, Case No. 30-2013-00637022-CU-CD-CXC (5) Serrano Apartments: Superior Court, State of California, County of Orange, Case No. 30-2012-00577644-CU-CD-CXC

Represented defendants in a series of actions related to alleged construction defects in several multifamily communities; rendered opinions in the areas of customs and practices in property management, financial performance, tax accounting, and economic damages Wilshire Vermont Housing Partners, L.P. v. Taisei Construction Corp., et al. Retained by Defendant Defendant’s Counsel: Lorber, Greenfield & Polito LLP, et al. Superior Court, State of California, County of Los Angeles, Case No. BC504178 Represented defendant against allegations of construction defects in a 449-unit apartment building over 36,486 square feet of retail in the Koreatown submarket of Los Angeles; performed damages analysis, valuation, and provided opinions related to the standard of care of a prudent landlord California First, L.P. v. California Department of General Services Retained by Plaintiff Plaintiff’s Counsel: Liner LLP Superior Court, State of California, County of San Francisco, Case No. CGC10-505436 Represented plaintiff, the winning bidder of the Golden State Portfolio transaction authorized by California Governor Schwarzenegger, in a breach of contract matter related to the $2.3 billion sale of 11 state-owned office buildings

WNC-GA 000003

Brehm Communities, et al. v. Hearthstone, Inc., et al. Retained by Defendant Defendant’s Counsel: DLA Piper LLP Superior Court, State of California, County of Riverside, Case No. RIC 1200532 JAMS Arbitration Case No. 1100070665 Represented defendant against claims of breach of contract in connection with Subdivision Development Agreements for the construction and delivery of numerous residential communities; provided opinions relating to the housing market during the Great Recession, cross-collateralization and offset provisions within investment partnerships, and customs and practices related to joint venture agreements

Watts, et al. v. The Bank of New York Mellon, et al. Retained by Defendant Defendant’s Counsel: Bryan Cave LLP Superior Court, State of California, County of Santa Barbara, Case No. 1385709 Represented defendant against claims of negligence, promissory estoppel and unfair competition in connection with the origination of a single-family mortgage loan and subsequent foreclosure proceeding Vayntrub v. Bank of America, N.A., et al. Retained by Defendant Defendant’s Counsel: Bryan Cave LLP Superior Court, State of California, County of Los Angeles, Case No. BC496253 Represented defendant against claims of negligence, promissory estoppel, and unfair competition in connection with the origination of a single-family mortgage loan and subsequent foreclosure proceeding Garfield Beach CVS, LLC v. Playa Runway, LP Retained by Plaintiff Plaintiff’s Counsel: Miller Starr Regalia, A Professional Law Corporation Superior Court, State of California, County of Los Angeles, Case No. SC124387

Represented plaintiff, CVS Pharmacy, in case alleging landlord’s failure to construct and deliver a loading dock and receiving area pursuant to project plans and specifications. Quantified economic damages to plaintiff under the remaining period of its long-term lease at Runway Playa Vista

PRDP Investments, Inc. v. Plano Riverwalk Development, Ltd, et al. Retained by Plaintiff Plaintiff’s Counsel: Wright & Close, LLP and Schlam, Stone & Dolan LLP County Court of Law of Dallas County, Texas, Case No. CC-14-02002-A

Represented plaintiff in action to seek redress for various breaches of contract and fiduciary duty related to the management and marketing of two contiguous parcels of unimproved land totaling 11.4 acres John Young v. Andrew Sun, et al. Retained by Plaintiff Plaintiff’s Counsel: Keller/Anderle LLP Superior Court, State of California, County of Orange, Case No. 30-2013-00659963-CU-NP-CXC

Represented plaintiff in claims of breach of contract and fiduciary duty in connection with a business partnership spanning several decades; performed valuation and accounting for multiple special

WNC-GA 000004

purpose entities to facilitate partnership dissolution; calculated misappropriation of assets

• Representative consulting (non-litigation) clients include: o Goldman Sachs o McKinsey & Company o Boston Consulting Group o Bain & Company o Bank of America/Merrill Lynch o Tiger Global Management o Yucaipa Companies o MSD Capital (Michael Dell) o Nationstar Mortgage Holdings, Inc. o Fortress Investment Group LLC o Highbridge Capital Management (JP Morgan Asset Management) o Davidson Kempner Capital Management o P. Schoenfeld Asset Management o Providence Equity Partners o EQT Partners (also currently engaged as Industrial Advisor to EQT Partners) o Shamrock Holdings o Cadian Capital Management o Canyon Capital Realty Advisors o Fred Alger Management, Inc. o Napier Park Global Capital (Citigroup alternative investment arm) o The Riverside Company o Roystone Capital Partners o Gulf Finance House, Dubai o TDM Asset Management, New Zealand o Cornerstone Research o Gerson Lehrman Group o DeMatteo Monness o Los Angeles Business Council o David Geffen School of Medicine at UCLA

PROFESSIONAL EXPERIENCE (NON-LITIGATION) UCLA Anderson Graduate School of Management, Los Angeles, CA 2004-Present UCLA School of Law, Los Angeles, CA Continuing Lecturer in Finance, Accounting, Real Estate and Law (earned lifetime tenure in 2012 at age of 39) • Teach Urban Real Estate Financing and Investing (Mgmt 278A); Entrepreneurial Real Estate Development

(Mgmt 279B); and, Affordable Housing Development (Mgmt 298D) at UCLA Anderson School • Teach Accounting and Financial Skills for Lawyers (Law 434) and Social Entrepreneurship, Housing and

Sustainability (Law 445) at UCLA School of Law • Consistently a top finalist for MBA Teacher of the Year, and while teaching undergraduates, was amongst

the top professors campus-wide on BruinWalk.com (earned #1 position several times) • Published several graduate business school case studies used regularly in the curriculum, including SLS

Hotels (SBE Entertainment), Campus El Segundo (Thomas Properties) and Ninth and Flower (CIM Group) Habibi Properties, LLC, Los Angeles, CA Principal, Real Estate Investment and Development 2000-Present • Manage all acquisition, financing, planning, development, marketing and asset management issues

WNC-GA 000005

• Acquire, rehabilitate and develop single- and multi-family properties throughout Southern California • Properties under ownership include over 2,000 multi-family units valued at over $600M • Launched Arrowhead Residential Funds I – VI, investing in distressed single-family assets in Kansas City,

MO; funds collectively own over 325 homes, delivering 13% annual unlevered yield to investors, net of fees • Own and manage 2,000 acres of almond, pistachio and citrus orchards in California’s San Joaquin Valley • Rated as one of 30 “Platinum” status multifamily real estate clients nationwide by JP Morgan Chase • Served as consultant to The KOR Group, leading the development of several projects throughout Los

Angeles, including Barker Block (297 units plus retail) and Eastern Columbia (147 units plus retail)

Banc of America Securities, LLC, San Francisco, CA Summer Associate, Investment Banking 2002 • Advised client senior management on corporate mergers, acquisitions, divestitures and restructurings • Built merger and LBO models, performed valuations and devised optimal structures for financial and tax

reporting, devised capitalization structures and stock option plans for high growth enterprises The Walt Disney Company, Burbank, CA Manager, Transaction Support Group/Mergers and Acquisitions 1999-2000 • Assessed feasibility and potential capital structure for $500M, 5,760 room Pop Century Hotel • Analyzed impact of Section 423 employee stock purchase plan on EPS, leading to adoption of plan • Led initiative to install change of control provision (“poison pill”) on Disney stock options, accelerated

vesting in the event of a merger/acquisition

Arthur Andersen LLP, San Francisco, CA Manager, Audit/Business Advisory Services (Financial Services, Banking and Real Estate) 1995-1999 • Promoted to Manager in 3 years and 9 months from date of hire, over one year ahead of Firm standard • Managed IPOs, leading clients through SEC compliance and Registration Statement (Form S-1) filings,

including technical guidance on accounting for stock-based compensation and revenue recognition • Led due diligence in $1.8B acquisition of William Wilson & Associates by Cornerstone Properties • Developed a standardized private equity, hedge fund and venture capital audit practice that increased office-

wide revenues by over 10%

EDUCATION AND CERTIFICATIONS

The Stephen M. Ross School of Business at the University of Michigan MBA with Highest Distinction, 2003 Awarded merit-based academic scholarship Beta Gamma Sigma Honor Society David T. Shelby Award for leadership of Wolverine Venture Fund

University of California at Santa Barbara BA, Business Economics and Accounting, 1995 Head Coach, Men’s Varsity Crew Pacific Coast Champion Oarsman, Men’s Varsity Lightweight Crew

U.S. National Team Development Camp, Men’s Lightweight Crew

Certified Public Accountant (CPA), State of California (active license #77773) Real Estate Salesperson, State of California Bureau of Real Estate (active license #01448788)

BOARD/ADVISORY MEMBERSHIPS WNC-GA 000006

• Industrial Advisor, EQT Partners (Swedish group of 18 private equity funds with over €29B capital) • Member, Board of Directors, Pacific Charter School Development (also Member of Audit Committee) • Member, Founding Board of Trustees, Beacon School for Boys (also Chairman of Finance Committee) • Member, Board of Directors, Local Construct • Member, Board of Directors, Real Estate Investment Advisory Council (REIAC) • Member, Think Tank, Kibel Green, Inc. • Member, Judging Committee, Gerald Loeb Award for Distinguished Business Journalism • Member, Transit Oriented Development and Workforce Housing Task Force, City of Los Angeles

(appointed by Los Angeles City Councilmember Gil Cedillo) • Advisor, Los Angeles Streetcar, Inc. – Led passage of $62.5M Community Facilities District via

72.9% affirmative vote in December 2012 election – featured on Los Angeles Times front page

MEDIA, PUBLICATIONS AND SPEAKING ENGAGEMENTS

• Moderated “Real Estate 2016: The Construction Boom” panel, U.C. Berkeley Haas School of Business • Authored “Easing L.A.’s Housing Crunch,” Op-Ed, Los Angeles Times, August 10, 2015 • Awarded Iranian-American Bar Association (IABA) “Excellence in Leadership Award,” 2015 • Featured Speaker, “Housing and California’s Future,” UCLA Anderson Forecast, 2015 • Authored “LA’s Next Frontier: Capturing Opportunities for New Housing, Economic Growth, and

Sustainable Development in LA River Communities,” centerpiece of the Los Angeles Business Council Sustainability Summit, 2015

• Moderated “Real Estate 2015: How Bullet Proof is Your Strategy” panel, U.C. Berkeley Haas School of Business

• Taught finance, tax accounting and land use training course to executives of Americold Logistics, a real estate investment trust (REIT) owned by Yucaipa Companies and Goldman Sachs, 2014

• Taught “New Professionals Track” to real estate and corporate attorneys at Crocker Symposium, 2014 • Taught “Business Law for Lawyers: Deal Structuring Seminar” at Crocker Symposium, 2013 • Delivered real estate lecture at McKinsey & Company Southern California luncheon, 2013 • Authored and presented “2013 Livable Communities Report: A Call to Action,” the centerpiece of the

Mayoral Housing, Transportation and Jobs Summit, 2013 • Delivered economic forecast at Genesis LA Board of Directors Retreat, 2013 • Authored and presented “Building Livable Communities: Enhancing Economic Competitiveness in Los

Angeles,” the centerpiece of the Mayoral Housing, Transportation and Jobs Summit, 2012 • Delivered keynote luncheon address at Crocker Symposium, 2012 • Delivered economic forecast at Sheppard Mullin Richter & Hampton Annual Retreats, 2011 and 2012 • Delivered keynote at Southern California Development Forum Annual Forecast, 2012 and 2013 • Delivered economic forecast at RealShare Los Angeles Apartments Conference, 2011 • Authored “L.A. Should Abandon Rent Control,” Op-Ed, Los Angeles Times, May 21, 2010 • Delivered keynote address at Shamrock Capital Advisors Annual Investor Meeting, 2010 • Delivered economic forecast at UCLA Anderson Alumni Weekend, 2008, 2009 • Widely interviewed as real estate expert on major television and radio programs including BBC World

News, NBC’s The Today Show, CNN, Bloomberg TV, CNBC, FOX News, CBS, ABC and NPR, as well as all major dailies including The Financial Times, Wall Street Journal, The New York Times, Los Angeles Times, Washington Post, Chicago Tribune and San Francisco Chronicle

• For web links to hundreds of national media mentions, see www.GrayslakeAdvisors.com/Press

WNC-GA 000007

CilkerApartmentsv.WesternNationalConstructionExpertFileofPaulHabibiDocumentsReliedUpon,June6,2016

DocumentTitle/Description BatesStart BatesEndCaseDocumentsWoodmontRealEstateDeposit WRES00001 WRES03082WoodmontRealEstate-CorrespondenceandAgreements PLT019609 PLT019656WoodmontRealEstate-CorrespondenceandNotes PLT019659 PLT019695OnePearlPlaceApartmentInformation PLT024616 PLT024625OnePearlPlaceInsuranceClaimNotes PLT024626 PLT024627Financialreports&rentrolls(redacted)-JulythroughSep2015 PLT033295 PLT033453VariousFinancialReportsandRentRolls PLT036719 PLT041325VariousFinancialReportsandRentRolls PLT032899 PLT033150AvelarFieldInvestigation&DefectAnalysisReport NOBATESDTScheduleandLocations PLT-RAA04675 PLT-RAA04680DTLocations PLT-RAA09609 PLT-RAA09621DTSchedule PLT-RAA19547 PLT-RAA19547

OtherExpertFilesChungExpertFile PLT-WDC00001 PLT-WDC08335SedwayExpertFile PLT-SC00001 PLT-SC10028BartholomewExpertFile WNC-BAI000001 WNC-BAI012667BartholomewSupplementalExpertFile WNC-BAI012668 WNC-BAI012935

DepositionsDepositionofLeeBartholomew,6/3/16(roughtranscript)&Ex.986DepositionofLucyChung,5/18/16,andExhibitsDepositionofLynnSedway,5/23/16(roughtranscript)andExhibitsDepositionofKelleyFein,1/29/16DepositionofRhondaSorochin,3/31/16DepositionofGerardoPadilla,1/28/16,andExhibits

WNC-GA 000008

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PROOF OF SERVICE

I am employed in the County of Orange, State of California. I am over the age of 18 andnot a party to the within action. My business address is 1851 East First Street, 10th Floor, SantaAna, CA 92705-4052.

On June 6, 2016, I served the within document(s) described as:

DEFENDANT AND CROSS-COMPLAINANT WESTERN NATIONALCONSTRUCTION'S NOTICE OF COMPLIANCE WITH THE CASE MANAGEMENTORDER RE: DEPOSIT OF EXPERT FILE

BY E-SERVICE: I electronically served the document(s) via Santa Clara CountySuperior Court's Electronic Filing System on the recipients designated on the transaction receiptlocated on the Santa Clara County Superior Court's Electronic Filing System website. [SeeTransaction Receipt on SCE Filing Website]

I declare under penalty of perjury under the laws of the State of California that theforegoing is true and correct.

Executed on June 6, 2016, at Santa Ana, California.

Sheila Ellis