Case 4:20-cv-00981-YGR Document 32 Filed 07/01/20 Page 1 of 4 1 2 3 4 5 David W. Hughes (SBN 88738) LAUGHLIN, FALBO, LEVY & MORESI Mailing Address: One Capitol Mall, Suite 400 Sacramento, CA 95814 Physical Address: 1001 Galaxy Way, Suite 200 Concord, CA 94560 Telephone: (925) 499-4999 Facsimile: (925) 348-9710 6 7 Attorneys for Lien Claimant, COUNTY OF ALAMEDA 8 9 10 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA 11 12 13 14 ALAN STRICKLAND, an individual; and KELLY STRICKLAND, an individual, No: 4:20-cv-00981-YGR NOTICE OF AND APPLICATION FOR LIEN 15 Plaintiffs, 16 v. [California Labor Code §3856] 17 20 MASAI UJIRI, an individual; TORONTO RAPTORS, a business entity; MAPLE LEAF SPORTS & ENTERTAINMENT, a business entity; NATIONAL BASKETBALL ASSOCIATION, INC.; and DOES 1 through 100, inclusive, 21 Defendants. 18 19 and REQUEST FOR NOTICE 22 23 TO: ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 24 25 26 27 APPLICATION FOR LIEN COUNTY OF ALAMEDA, under California Labor Code section 3856 and on the following grounds, claims and applies for a first lien in the sum of $142,984.00 against any 28 -1Notice of and Application for Lien and Request for Notice Case Document 32 Filed 07/01/20 Page 2 of 4 settlement or judgment in this action and further claims and applies for a ?rst lien in the amount of any additional sums that may be paid as workers? compensation bene?ts to or on behalf of ALAN STRICKLAND before payment of any settlement or satisfaction of any judgment in this action: 1. On or about June 13, 2019, plaintiff in this action was employed by COUNTY OF ALAMEDA, and was injured in the course of that employment. At that time, lien claimant COUNTY OF ALAMEDA was self-insured for workers compensation in California and was obligated to pay workers compensation bene?ts to employees of COUNTY OF ALAMEDA, including plaintiff. 2. As a proximate result of the injuries sustained by plaintiff, and pursuant to the liability of lien claimant under the California workers? compensation laws, lien claimant has paid to and on behalf of plaintiff the sum of $142,984.00 as workers? compensation bene?ts. Please take further notice that the workers? compensation bene?ts may be continuing and that the lien may be increasing. Please contact lien claimant?s attorney for periodic updates on changes in the amount of the lien. Please take further notice that rights pursuant to Labor Code section 3857, 3858 and 3861 are not waived. REQUEST FOR NOTICE Lien claimant COUNTY OF ALAMEDA hereby requests that it be served, through its attorney noted above, with a copy of each pleading and paper ?led and/or served on your behalf in this action, as well as any Judgment or Notice of Settlement in the action, in order to allow lien claimant the opportunity to perfect its lien. DATED: July 1, 2020 LAUGHLIN, FALBO, LEVY MORESI LLP By: David W. Hughes Attorneys for Lien Claimant -2- Notice of and Application for Lien and Request for Notice Case 4:20-cv-00981-YGR Document 32 Filed 07/01/20 Page 3 of 4 1 PROOF OF SERVICE 2 Case 3 Case # : Court : : ALAN STRICKLAND , an individual; and KELLY STRICKLAND, an individual vs. MASAI UJIRI, , et al. 4:20-cv-00981-YGR United States District Court for the Northern District of California 4 6 I am a citizen of the United States, employed in the City of Concord. My business mailing address is One Capitol Mall, Suite 400, Sacramento CA, 95814. My business physical address is 1001 Galaxy Way, Suite 200, Concord CA, 94560. I am over the age of 18 years and not a party to the above entitled action. 7 On July 1, 2020, I served the following: 5 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 " NOITCE OF AND APPLICATION FOR LIEN and REQUEST FOR NOTICE X BY ELECTRONIC MAIL: I served a true and correct copy of the document(s) listed above via e-mail (Code Civil Procedure §1010.6(a) Cal.R.Ct. 2.251) to the following address(es): BY FACSIMILE: I served a true and correct copy of the document(s) listed above via Facsimile to the following facsimile number(s). Said transmission was reported complete and without errors. addressed as follows: Attorney for Plaintiff – Alan Strickland and Kelly Strickland David P. Mastagni, Esq, Grant A. Winter, Esq. Brett D. Beyler, Esq. Mastagni Holstedt, A.P.C. 1912 "I" Street Sacramento, CA 95811 Tele: (916) 446-4692 Fax: (916) 447-4614 Email: bbeyler@mastagni.com; gwinter@mastagni.com; dmastagni@mastagni.com Attorneys for Defendant – National Basketball Association Mark R. Conrad, Esq. Courtney C. Aasen, Esq Conrad & Metlitzky, LLP Four Embarcadero Center, Ste. 1400 San Francisco, CA 94111 Tele: (415)343-7100 Fax: (415)343-7101 Email: mconrad@conradmetlitzky.com; caasen@conradmetlitzky.com // // // // -1- Case Document 32 Filed 07/01/20 Page 4 of 4 Attornevs for Defendants ?Masai Uiiri, oranto Raptors and Maple Leaf Sports Entertainment Joseph W. Cotchett, Esq. Emanuel B. Townsend, Esq. Tamarah Prevost, Esq. Cotchett, Pitre McCarthy, LLP 840 Malcon Rd., Ste. 200 Burlingame, CA 94010 Tele: (650)697-6000 Fax: (650)697?0577 Email: iootchett@opmlegal.com; etownsend@cpmlegal.oom; tprevost@opmlegal.com I declare that I am employed in the office of a member of the bar of this Court, at whose direction the service was made. Executed July 1, 2020, at Concord, California. Yolanda Kirk