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kwikl'zg° 241 071 269 RAYMOND C. PROSPERO (SBN 238087) 17.0. Box 2950 CORONA, CA 92878 TELEPHONE: (951) 454-9145 EMAIL: RCPROSPERO@YMAIL.COM F/LED RESPONDENT, In Pro Per 1;‘ UELIC MAY 25 20

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STATE BAR COURT OF CALIFO RK:§"3l§ouRT sA/ve.sLZ§s

LOS ANGELES DIVISION SBC, — I‘! —V— 302-99

Case Nos. 10-O—08238, et al. (S198705) 11.049314, et a1. (S208460)

In the Matter of

RAYMOND C. PROSPERO VERIFIED PETITION or MEMBER OF SEN #233087 THE STATE BAR RAYMOND C. PROSPERO PURSUANT TO STANDARD 1.2(c)(1); MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION IN SUPPORT THEREOF

A Member of The State Bar

(No Hearing Requested)

Member of the State Bar RAYMOND C. PROSPERO petitions this Court for an order relieving Raymond of his actual suspension. Raymond was disciplined twice. Both times stemmed from misconduct which took place in or around 2010 and prior years. Much of his misconduct was attributed to his alcoholism. Raymond has remained continuously clean and sober since June 30, 2010 to present. Raymond Prospero has accepted responsibility for his misconduct and has made complete restitution. Raymond has worked hard to rebuild his life and to make up for his past mistakes. He has completed seventy-four (74) hours of formal continuing legal education, complied with all the terms of his probation, including completing restitution.

PROCEDURAL HISTORY Case Nos. 10-0—08232; et al. and 1]-0-19312; et al. An Order suspending Raymond Prospero’s ability to practice law in the State of California

was filed and entered with the State Bar Coun effective June 16, 2012, Case No. l0—O—O2838. A

VERIFIED PETITION OF MEMBER OF THE STATE BAR RAYMONDC.PROSPERO PAGE 1 of 13

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second Order based on e\'e11ts that happened during the same timeframe was filed and entered effective May 12, 2013, Case No. ll—O~l9314 (collectively and herein referenced as the “Orders”). The discipline levied against Raymond arose from actions in or around 2010 and prior years. Raymond was disciplined for, inter alia, lack of attention to clients and client files, failure to perform legal services competently, poor communication with clients, failing to protect and promote client interests, and to return fees where appropriate.

Raymond does not try to minimize his misconduct. He knows that his behavior and actions were unbecoming of a lawyer and the discipline was justified. In fact, Raymond readily agreed and stipulated to the discipline imposed and he has accepted full responsibility for his past actions.

Prior to the Orders being entered, Respondent went on voluntary inactive status and has not

actively practiced law since February 2011. Raymond’s abuse of alcohol was a major contributing factor to his misconduct. The June 16, 2012 order specifically acknowledges this and made sobriety a condition of Raymond’s probation‘. Recognizing his alcohol dependency, Raymond sought treatment and has continuously been sober since June 30, 2010. Since that time, he has

continued to work his recovery program to maintain his sobriety, as well as to establish rehabilitation.

RAYMOND PROSPERO’S CONDUCT HAS BEEN EXEMPLARY SINCE HIS LAST INSTANCE OF MISCONDUCT For purposes of this petition, Raymond Prospero’s rehabilitation from his prior misconduct

is measured by his exemplaxy conduct from the point of his last instance of misconduct for which he was disciplined. See, Matter of Murphy (1997) 3 Cal State Bar Ct Rptr. 571, 577.

Raymond was disciplined for misconduct which occurred in or around 2010 and prior years.

Raymond’s probation matter commenced on June 16, 2012, the effective date of the Supreme Court’s Order.

Raymond Prospero timely filed his Rule of Court 9.20 compliance declaration. Raymond Prospero has submitted all required quanerly probation repons?

' See Order, Case No. 10-O-08238, et al., pp. 4 and 7. 2 Office of Probation contends that the 2 final quanerly repons were submitted late. Respondem

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previously filed a Motion to Modify on January 9, 2015 to address these late filings.

VERIFIED PETITION OF MEMBER OF THE STATE BAR RAYMOND C. PROSPERO PAGE 2 of 13

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Raymond Prospero has submitted all of the required monthly Alcoholics Anonymous, Celebrate Recovery and The Other Bar attendance reports pursuant to the Stipulations. He has been continuously sober since June 30, 2010.

Raymond Prospero passed the Multi—State Professional Responsibility Examination and proof of passage has been provided to the State Bar.

On May 16, 2013, Raymond Prospero passed the State Bar Ethics School exam. On May 2, 2014, Raymond Prospero passed the State Bar Client Trust Accounting School

exam.

Raymond Prospero received letters on both matters dated January 11, 2017 from the Office of Probation (“OP”) that stated “...there are no further conditions requiring our monitoring efforts;

therefore, we will close the Office of Probation '5 file on this matter.” Raymond Prospero received a letter dated August 9, 2018 from the Client Security Fund

confirming that all amounts owed to the fund have been paid in full. Raymond Prospero has completed all restitution payments. Raymond Prospero petitioned the State Bar Court and obtained orders dated February 6,

2016 for a payment plan for the remaining disciplinary costs. The Orders set forth, in addition to restitution, that Respondent is to reimburse the State Bar for any disciplinary costs associated with

these matters. The remaining disciplinary costs are to be paid over the course of the next two State Bar billing cycles and are included as part of his annual billing statement. It should be noted that

as of to date, Raymond has not missed a payment‘ Raymond’s five (5) character witnesses also illuminate the exemplary quality of his conduct

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from June 30, 2010, his sobriety date, to the present.

Virtually all of these character witnesses attest to Rayn-1ond’s continued sobriety and/or his outstanding contributions to society. Included are character letters from Greg Dorst, who is a former lawyer and is an expert in the field of addiction. Mr. Dorst is currently the Southern California consultant for The Other Bar and has extensive experience dealing with attorneys in the recovery community. Another letter is from James Heiting, a practicing lawyer and Past President of the State Bar of California, 2005-2006. Mr. I-{citing was on the Board of Governors for the State Bar of California from 2002 through his tenure as State Bar President in 2006. Another character letter is from David Saunders, a lawyer and partner in the oldest and wel1—respected law firm in the

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City of Corona. His firm, Clayson, Bainer and Saunders, was founded in 1910. In addition to being

VERIFIED PETITION OF MEMBER OF THE STATE BAR RAYMOND C. PROSPERO PAGE 3 of 13

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a practicing lawyer, Mr. Saunders is involved in the local Rotary Club and can attest of Raymond’s outstanding service to the community. The remaining character letters are from practicing lawyers who have known Raymond for several years and have vdtnessed his character transformation firstv hand.

Raymond’s moral transformation has been remarkable. Although he is not proud of his past misconduct, he has strived to learn from and make up for his past transgressions. In addition to

completing restitution and the terms of his probation, one of the ways Raymond has tried to “right his wrongs” is to try to live his life as a living amends, by strix ing to serve others, give back to his

community and live a decent life. Raymond does not take this second chance for granted. He has worked hard to rebuild his life from rock—bottom and what Raymond has been able to accomplish in that span of time is a testament to his steadfast commitment to his sobriety and effort to live an

exemplary life.

Currently, Raymond serves on the Board of Directors of Lifestream a non-profit blood bank, which serves over eighty (80) medical facilities in California. Raymond has served on the Board since 2012. Lifestream is an affiliate member organization of Vitalant, a health organization with an annual operating budget of approximately $1 billion do1la.rs.3 In addition to

his general duties on the Board, Raymond also serves on LifeStream’s Executive Committee. Raymond has also served two (2) terms on the Board of Directors for his Rotary group (and

is about to serve a third term), which is part of an international non-profit organization whose mission is to serve the community and abroad.‘ Specifically, for the past several years Raymond has been tasked with helping the next generation and has chaired his club’s Rotary Youth Scholarship Awards (RYLA) and PRYDE (Personal Rotary Youth Development Experience) programs where he is responsible for working with local middle and high school students.

Raymond, along with faculty advisers, helps mentor the students and encourages community service through local charitable organizations. Each year, his Rotary club provides scholarships to a select few students which enable them to attend local youth leadership camps. Raymond has been in charge of this scholarship process, including the interviewing and selection of scholarship recipients for the past several yeaxs. Raymond has been an active Rotary member since 2011.

3 www.vitalant.org, \wvw.1sLream.org 4 www.rotary.org

VERIFIED PETITION OF MEMBER OF THE STATE BAR RAYMOND C. PROSPERO PAGE 4 of 13

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Since 2017, Raymond serves on the Board of Visitors for California Baptist University (CBU), a private Christian university in Riverside, California. CBU is accredited by the Western Association of Schools and Colleges and was recently ranked as one of the best regional universities by U.S. News and World Report.5

All of these positions of leadership require nomination by his peers. There is no doubt that Raymond Prospero is a changed person. His leadership, character and contributions have earned him the respect of his peers, including local business and civic leaders. In 2018 the Corona City Council and Corona Chamber of Commerce recognized Raymond as one of their “40 under 40: Best and Brightest”, a highly coveted award bestowed on a select group of local citizens under the age of forty (40) for their positive contributions to the business and local communities. Raymond was recognized by the Corona City Council and Mayor as “. . .an exemplary leader in our community who has set the standard flor excellence through his service, dedication and commitment." See, Exhibit 1.

This recognition is no easy feat; Corona is a city of approximately 152,374 citizens and has a significant business and financial footprint in the region.‘ When you include the neighboring city and county seat of Riverside, the region‘s population totals over 475,000. Of this large region, Raymond was one of a select few who was nominated by his peers and selected to receive this honor. In fact, as a result of receiving this award, Raymond received a Certificate of Special Congressional Recognition from U.S. Representative Ken Calvert for his “oulstanding and invaluable service to the community.” See, Exhibit 1.

Raymond was also recognized by California State Senator Richard Roth, California Assembly members Melissa Melendez and Sabrina Cervantes. See, Exhibit I.

There are other instances in which Raymond serves quietly and receives no outside recognition. Because of his involvement in the recovery community, Raymond has been called upon many times to assist and guide people who are new to sobriety and/or need help going through the twelve (12) steps of recovery. Because of the confidential nature of Alcoholics Anonymous (and other 12 step programs), many times the only people that are aware of service he provides are the person seeking help and Raymond himself. Many of Raymond’s character let1ers

5 https://www.usnews.com/best—colleges/califomia—baptist—university-1 125 6 www.census.gov

VERIFIED PETITION OF MEMBER OF THE STATE BAR RAYMOND C. PROSPERO PAGE 5 of 13

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also attest to his continuous involvement in the recovery community, specifically Alcoholics Anonymous and The Other Bar.

RAYMOND PROSPERO MEETS THE REQUIREMENTS OF STANDARD 1.2(c)(1)

Raymond Prospero has proven by a preponderance of the evidence his rehabilitation, his moral fitness to practice law, and his present learning and ability in the general law. He ought to be relieved of actual suspension.

Standard 1.2(c)(1) provides: “Actual suspension for two years or more requires proof, satisfactory to the State Bar Court, of rehabilitation, fitness to practice, and present learning and ability in the general law before a member may be relieved of the actual suspension.”

“The petitioner has the burden of proving by a preponderance of the evidence that the petitioner has satisfied the conditions of standard 1.2(c)(1).” Rule of Procedure, rule 5.404,

In Matter ofMurphy (1997) 3 Cal State Bar Ct Rptr. 571, 580-581, the State Bar Coun held that rehabilitation under Standard 1.4(c)(ii) requires proof to a preponderance of the evidence of:

1. Compliance with the terms of probation, and 2. Exemplary conduct from the time of the last instance of misconduct, such that the Court

may determine that the misconduct having led to discipline will not be repeated. This case compares favorably against Matter of Murphy, supra, the seminal State Bar Court

case on 1.4(c)(1) petitions. The petitioner in Murphy had been disciplined three times: the first garnered a 3-year actual suspension and 5 yeaxs probation; the second received another yea:’s probation for failing to timely file a Rule of Court 955 compliance declaration, and misconduct in yet another client matter; and the third received another one-year actual suspension and an additional two—years probation, for probation violations. The petitioner in Murphy failed to cooperate with the State Bar’s investigations.

The Murphy court granted the petition for relief from suspension on the following facts: Murphy was a recovering alcoholic who had been clean and sober for 6 years at the time the Review Depamnent ruled on the matter. Murphy participated in AA and The Other Bar, had made full restitution to the victim of his misappropriation, had completed 52 hours of continuing legal

; education, and had presented 13 good character declarations in support of his petition.

VERIFIED PETITION OF MEMBER OF THE STATE BAR RAYMOND C. PROSPERO PAGE 6 of 13~

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Raymond Prospero’s facts are better. Raymond Prospero was disciplined two (2) timcs, (not three (3) as in Murphy), Raymond never failed to cooperate with the State Bars investigations of him, and complied with the terms of his probation. Raymond is almost 9 years clean and sober at the time he filed this petition, and has completed over seventy-four (74) hours of continuing

legal education. Raymond has made full restitution. Although Raymond does not present as many character references as Murphy, of the five (5) character references submitted with his petition, four (4) are from practicing attorneys, including a Past President of the State Bar of California.

Raymond also includes for consideration the recognition recently received from the Corona City Council, a United States Congressman, California State Senator and two (2) California State

Assembly members.

1. Raymond Prospero has completed the terms of his probation.

The Officc of Probation provided letters on January 1 1, 2017 stating that all probation

conditions have been met‘ The Client Security Fund (CSF) provided a letter dated August 9, 2018

that all amounts due to the CSF have been paid. All restitution outside of the CSF has been paid directly to the complainants and proof of payments have been provided to the State Bar.

Thus, the laudatory goals of State Bar probation have been fulfilled through Raymond Prospero’s compliance: public protection and rehabilitation of the respondent attorney. See, Matter

afMars/1 (1990) 1 Cal. State Bar Ct. Rptr. 291, 299.

2. Raymond Prospero’s conduct has been exemplary.

Raymond Prospero is a recovering alcoholic, and his active alcoholism was a causal factor of the misconduct underlying his discipline. Thus, he is required to demonstrate two types of rehabilitation, while other respondents who are not so afflicted with this disease, do not. Raymond must show that he his rehabilitated from his active alcoholism. Every respondent must demonstrate

3 rehabilitation and moral fitness by showing overall rehabilitation from their misconduct, see, In re 2 Bellicini (2006) 4 Cal. State Bar Ct. Rptr. 883, 892-893. Raymond Prospero has fully demonstrated his recovery from alcoholism because he is almost 9 years sober and because

Raymond “presented evidence of his ongoing, extensive involvement with and participation in AA, [and] the Other Bar, all of which provide additional outside support to assist petitioner vsith his efforts to maintain sobriety." Bellicini, supra, at 892.

VERIFIED PETITION OF MEMBER OF THE STATE BAR PAGE 7 of 13 RAYMOND C. PROSPERO

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Raymond Prospcro has established his overall rehabilitation. First, Raymond has complied with all of his probation terms. See, Matter of Murphy, supra.

Raymond Prospero has also made complete restitution pursuant to the Stipulations. It is of

diminished importance that restitution in this regard was a condition of Raymond’s probation, “We note that the Supreme Coun has given favorable consideration to restitution even in circumstances involving external pressures to pay such as court orders and agreements with victims.” Bellicini,

supra, at 891.

Raymond’s five (5) character witnesses also attested to his good character. One of these letters is from a Past President of the State Bar of California. Raymond was also recognized for his contributions to society by civic leaders in the highest forms of Federal and State government,

including a sitting United States Congressman, a California State Senator and two (2) current

California State Assembly members. Great weight should especially be given to the character

letter written by James Heiting. Mr. Heiting served as the California State Bar President in 2005-

2006 and served on the State Bar’s Board of Governors from 2002 through 2006. He is familiar with the high ethical standards for attorneys that the State Bar seeks to uphold and has provided his

personal recommendation for Raymond’s reinstatement and confidence in Raymond’s ability to practice law.

“Favorable testimony from members of the bar and members of the public of high repute is entitled to considerable weight.” Bellicini, supra, at 890. Character testimony from attomeys is valuable given their “strong interest in maintaining the honest administration of justice”, see, Matter of Brown (1993) 2 Cal. State Bar CL Rptr‘ 309, 319.

Raymond’s five (5) character witnesses are sufficient to establish his good moral character in this regard. Each of them knew the nature of his prior misconduct and each can attest to his moral character. Indeed, the State Bar Court has given significant mitigation credit for good character, on a higher clear and convincing standard of proof, with only three (3) character

‘ witnesses, see, Matter of Davis (2003) 4 Cal. State Bar Ct. Rptr. 576, 588. And see, Marter of Miller (1993) 2 Cal. State Bar Ct. Rptr. 423, 431 (5 character witnesses sufficient to establish good moral character in reinstatement proceeding based on higher clear and convincing standard).

//I

VERIFIED PETITION OF MEMBER OF THE STATE BAR PAGE 8 of 13 RAYMOND C. PROSPERO

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~ 3. Raymond Prospero has established present learning and ability in the general law.

Raymond Prospero has submitted proof of completion for over seventy—four (74) hours of continuing legal education; a portion of that continuing legal education was on recovery and ethics- rclated issues. The latter fact demonstrates Raymond‘s commitment to his personal sobriety, and his commitment to behaving well as a sober attorney. Raymond has also kept abreast of legal matters by maintaining his connections in the legal community. Once a week, Raymond meets with practicing lawyers at The Other Bar. Although the primary purpose of these meetings is continuous recovery, attendees ofien discuss current legal issues amongst their colleagues and peers. Four (4) of the character letters written on Raymond’s behalf are from practicing lawyers, who not only attest to his good moral character, but Ihey also state their confidence in Raymond’s ability to practice law. This, along with the seventy—four (74) hours of continuing education is more

than sufficient to support a finding that Raymond Prospero has demonstrated his present learning and ability in the general law by a preponderance of the evidence.

In In re Bellicini, supra, at page 889, the State Bar Court accepted the State Bar’s

agreement, that only 24 hours of continuing legal education had established that pctitioner’s

prescnt learning and ability in the general law under the higher clear and convincing standard: “The hearingjudge found that pethioncr had demonstrated by clear and convincing evidence that he possesses the requisite ability and learning in the general law. Petitioner passed the Professional Responsibility Examination in August 2003, he recently completed approximately 24 hours of continuing legal education covering a wide variety of topics such as business law, employment law,jury instructions, and client trust accounting, and he subscribed to a legal newspaper. The State Ba: does not contest petitioner's present ability and learning in the general law, and upon our independent review of the record, we find no reason to question his legal abilities.”

Indeed, the State Bar Court in Matter of Murphy, supra, accepted 52 hours of continuing education as satisfactory. Raymond Prospero has seventy—four (74) hours of continuing legal education, far exceeding the findings in both Bellicini and Murphy.

CONCLUSION For the foregoing reasons, Member of the State Bar RAYMOND C. PROSPERO, prays for

relief from actual suspension pursuant to Standard 1.2(c)(1).

VERIFIED PETITION OF MEMBER OF THE STATE BAR RAYMOND C. PROSPERO PAGE 9 of 13~

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VERIFIED PETITION OF MEMBER OF THE STATE BAR RAYMOND C. PROSPERO

PAGE 10 of 13

VERIFICATION

I, RAYMOND PR°5-“SW? Petitioner, declare under penalty of per] ury that the foregoing, including all

attachments and/or addenda, is true and correct and that this declaration is executed at, CORONA, CA

(enter city, state). on MAY 24. 2019 (enter date).

RAYMOND PROSPERO

Petitioner (print or type naméi A V

Petitionefs Counsel (print or type name)

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~~ Signature of Petitioner's Counsel S natureofP‘et\iQner )

Form effective November 18. 2016

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DECLARATION OF RAYMOND C. PROSPERO IN SUPPORT OF VERIFIED PETITION

1, Raymond C. Prospero, hereby declare and state as follows:

1.

2.

VERIFIED PETITION OF MEMBER OF THE STATE BAR

I am the Respondent in Case Nos. 10-0-02838, et al. and ll-O-19314, et al.

An Order suspending Respondenfis ability to practice law was filed and entered with the State Bar Court effective June 16, 2012, Case No. 10-O—02838. A second Order based on events that happened in the same timeframe was filed and entered on May 12, 2013, Case No. 11-O-19314 (collectively and herein referenced as the “Orders”). The discipline levied

in these matters arose from in or around 2010. A copy of the Orders is attached hereto as Exhibit “A”.

. Respondent passed the State Bar Ethics School exam on May 16, 2013 and State Bar Client Trust Accounting School exam on May 3, 2014. Proof of completion are attached hereto and collectively as Exhibit “B”.

Respondent has received letters from the Office of Probations dated January 11, 2017 that

all probations conditions have been met. Copies of the letters are attached as Exhibit “C”.

. Respondent received a letter dated August 9, 2018 from the Client Security Fund that all _

amounts owed to the fund have been paid. A copy of the letter is attached hereto as Exhibit .:D.,_

. Respondent has completed all other restitution under the Orders. Copies of the proof of

payments provided to the State Bar are attached as Exhibit “E”.

. Respondent obtained orders dated February 6, 2016 for a payment plan for the remaining

disciplinary costs. Respondent has not missed a payment and has two (2) payments remaining pursuant to the order. A copy of the February 6, 2016 orders is attached as Exhibit “F”.

. Respondent completed seventy-four (74) hours of continuing legal education, including

ethics, Proof of completion are attached as Exhibit “G”, In an effort to avoid having a

seventy (70) page exhibit attached to this Motion consisting of all of the individual

PAGE 11 of 13 RAYMOND C. PROSPERO

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I certificates, Respondent provided a summary confirmation of the courses completed from

2 the continuing education providers. Respondent can provide all of the individual cenificatcs

3 of completion, if needed.

4 9. Respondent obtained five (5) letters from practicing lawyers and his peers attesting to his

5 good moral character. Included are character letters from Greg Dorst, Southcm California

6 consultant for The Other Bar who has extensive experience dealing with attorneys in the

7 recovery community and James Heiting, a practicing lawyer and Past President of the State

8 Bar of California (2005-2006). Respondent is currently employed as an executive

(Senior Vice President) at a public1y—traded company, not in the legal field. Because of this, 9

he has redacted the company name in the letters. Respondent does not want to inadvertently 10 bring negative attention 10 the company name as that is a condition of employment. Many of 11 the character witnesses know Respondent both personally and professionally and in the

12 letters refer to his good professional reputation (in addition to his good moral character).

13 These letters are collectively attached hereto as Exhibit “I-I".

14 10. Respondent was recognized by the Corona City Council and Corona Chamber of 15 Commerce one of their "40 under 40: Best and Brightest” for his leadership, service and

16 contributions to the community. Respondent was also recognized by United States

17 Congressman Ken Calvert, California State Senator Richard Roth, California Assembly

18 members Melissa Melendez and Sabrina Cervantes. Copies of these awards and letters of

19 recognition are collectively attached hereto as Exhibit “1”.

20 11. Respondent currently serves on the Board of Directors and Executive Committee for

21 Lifestrearn and sits on the Board of Visitors for California Baptist University. Respondent

2 is about to begin his third term on the Board of Directors for his Rotary group. All of these

leadership positions require nomination by his peers.

12. Respondent is remorseful for his past misconduct and is ashamed of this past chapter of his

25 life. Since then he has strived daily towards rehabilitation, trying to become a better

26‘ person, both personally and professionally. He does not take his sobriety, nor this second

27 chance for granted. Respondent is grateful to the State Bar and the State Bar Court for its

consideration of this Motion.

VERIFIED PETITION OF MEMBER OF THE STATE BAR RAYMOND C. PROSPERO

PAGE 12 of 13

PROOF OF SERVICE C.C.P. §1013, 2015.5

STATE OF CALIFORNIA: ss.

COUNTY OF RIVERSIDE

I am over the age of 18; my mailing address is PO. Box 2950, Corona, CA 92878.

On 5'1 ‘4 '‘J,I served the foregoing documents described as:

VERIFIED PETITION PURSUANT TO STANDARD 1.2(C)(1); MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION IN SUPPORT THEREOF addressed as follows:

Office of the Chief Trial Counsel State Bar of California 845 South Figueroa Street Los Angeles, CA 90017

[)4 (BY OVERNIGHT MAIL) I deposited such envelope in the mail at Corona, California. The envelope was mailed with postage thereon fully prepaid. I am "readily familiar" with firm's practice of collection and processing correspondence for mailing. It is deposited with U.S. Postal Service on that same day in the ordinary course of business. I am aware that on motion of party served, service is presumed invalid if postal cancellation date or postage meterdate is more than 1

day after date of deposit for mailing in affidavit.

[] (BY PERSONAL SERVICE) I delivered such envelope by hand to the addressee.

[ ] (BY FACSIMILE TRANSMITTAL) I sent by facsimile the above document on to the above listed facsimile machine number. The facsimile machine I used complied with C,C.P. §1013(e) and Rule 2003(3). and no error was reported by the machine.

[XX] (State) I declare under penalty of perjury under the laws of the State of California that the above is true and correct.

5'-2“i‘l3 Executed on , at Corona, California.

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