IN THIS ISSUE:
p.2 Children sexually assaulted
Confidential Settlement Dear Friends, Clients and Colleagues:
p.2 Collision causes broken For some of you the summer weather has been in full force for a while. We San
kneecap and exacerbates Franciscans are just now starting to emerge from the foggy months and looking
forward to August, September and October sunlight.
p.2 Cab runs red light, injuring In this edition, in part because of the summer season, we wanted to focus on
elderly couple two subjects.
First is adult supervision of child activities. Our legal brief section, Weapons
p.3 Jury verdict for woman
& Tactics, addresses the seriousness of supervision and how to pursue
injured when security gate
negligent supervision cases. The theory is applied in Case Results’ Doe I
brought down on her at ski
and Doe II v. The Roe Family.
$415,164 And second is our Safety First! section, where we explore the hazards
presented by propane and backyard barbecues.
WEAPONS & TACTICS
p.5 “You’ll shoot your eye out!” If you’ve read earlier editions of this newsletter, you’ll also notice we’ve included
Using Restatement of Torts some recent case results that are six-figure resolutions rather than the multimillion
§ 324A to Impose a Duty on dollar results we frequently cover. We wanted to publish a range of our cases to
Child Watchers demonstrate that we are proud to work on all types of employment, injury and
death cases. These cases, clients and their stories are no less important than any
SAFETY FIRST other issue our firm tackles.
p.5-6 Summertime Barbecues
and Propane Safety If you have a question about whether we can help with your claim or referral,
please give us a call to discuss it. We are here to help.
p.7 Professional, Social and All the best,
The attorneys and staff at Rouda Feder Tietjen & McGuinn
CASES WE BELIEVE IN.
PEOPLE WE CARE ABOUT.
p.8 Young woman uses $16 million
jury verdict to move forward
and help others
44 Montgomery Street
San Francisco, CA 94104
T. 415 398 5398
F. 415 398 8169
2 CASE HIGHLIGHTS
Children sexually assaulted by babysitter
Doe I and Doe II v. The Roe Family1
FACTS evening, leaving 12-year-old Roe alone with Doe I and Doe II.
In a case involving negligent supervision and negligent failure Roe sexually assaulted and molested the children, and threat-
to warn, the firm argued parental liability when 12-year-old ened serious harm if they told.
Roe sexually assaulted and molested his two neighbors Doe
LEGAL THEORIES AND STRATEGIES
I, age 4 1/2 and Doe II, age 2, while babysitting. The plaintiffs
Our firm was able to assert liability against Roe’s parents
and defendants had been neighbors for six years before the
and collect under a homeowner’s insurance policy. Mr. and
evening of the incident. Roe had been adopted at the age of
Mrs. Roe were vicariously liable to the plaintiffs under Civil
five from the State of California Foster Care System. Before
Code § 1714.1 for the conduct of their son Roe, up to a set
his adoption, Roe spent time with his biological mother, who
amount per victim per occurrence. The firm also asserted
had a family history that included sexual abuse. After he was
a direct negligence claim against Roe’s parents for failing
adopted, Roe did not receive any form of counseling.
to supervise the children as agreed, and leaving the young
When Roe turned 11, Roe’s parents suggested to several children unsupervised when it was foreseeable that harm
neighbors that Roe was available for babysitting. When Roe could occur given the children’s young ages. 2 We also
turned 12, one of the neighbors allowed Roe to babysit for her argued that Roe’s parents failed to warn the neighbors
young children, Doe I and Doe II. The agreement was made about Roe’s background. This included Roe’s own fetal
only after Roe’s mother agreed to remain home immediately alcohol syndrome background and his potential exposure
next-door while Roe was babysitting and to “check in” on to his mother’s family history of sexual abuse. Both issues
all of the children, given Roe’s age. When Roe returned to have been linked to sexually abusive conduct.
babysit on a second occasion, the parents of young Doe I
and Doe II believed that Roe’s mother would again remain
The case settled for a confidential amount.
at home. However, both of Roe’s parents went out for the
Ron Rouda and June Bashant represented the children.
Collision causes broken kneecap and exacerbates knee injuries
Jane Doe v. Defendant Driver
FACTS Jane was 53 years old at the time of the collision. Both
Jane Doe was driving westbound on Walnut Creek’s Treat knees hit the dashboard, fracturing her right kneecap and
Boulevard in the slow lane. Jane drove forward into the exacerbating pre-existing knee injuries.
intersection on a solid green light. As Jane moved into the
LEGAL THEORIES AND STRATEGIES
intersection, Defendant Driver, driving a large late-model
This was a damages-only case with less than $20,000 in
Oldsmobile 98, ran the red light and made a left turn from
medical expenses and no significant wage-loss component.
eastbound Treat Boulevard directly into the path of Jane
Our firm argued that the fractured kneecap was a significant
Doe’s car. The resulting collision caused Jane’s car to veer
injury. The defense argued that Jane made a very good recov-
to the right, hit a stopped car, and slam into a light pole.
ery and that she had significant pre-existing knee problems.
Defendant was 83 years old at the time of the crash. She
acknowledged her full responsibility for the collision and CASE RESULT
stopped driving after the collision. The case settled for $625,000.
John Feder represented Jane Doe.
Cab runs red light, injuring elderly couple
The Does v. Arrow Cab Co.
FACTS LEGAL THEORIES AND STRATEGIES
John and Jane Doe, an elderly couple, were driving on Pine Despite the cab driver’s statement that the brakes failed,
Street in San Francisco when an Arrow Cab ran a red light, Arrow Cab accepted legal responsibility for the incident. A
crashing into their car. Jane Doe was knocked unconscious motion for preference based on the Does’ age and health was
and suffered a neck injury. Her husband, in addition to being granted. The case settled at the beginning of expert discovery.
put in fear for his own life, witnessed his wife’s injuries. The
cab driver claimed that the cab’s brakes failed.
The case settled for policy limits of $575,000.
Cynthia McGuinn represented the Does.
CASE HIGHLIGHTS 3
Jury verdict for woman injured when security gate brought down on her at ski resort
Jane Doe v. Northstar-at-Tahoe
FACTS she was told to remove the neck brace, she started devel-
Jane Doe, a 33-year-old physical therapist from San Fran- oping other problems. These included visual disturbances,
cisco, was an avid snowboarder. She had a season pass at light sensitivity, headaches, right-sided numbness, dizziness
Northstar. On one of her visits, she finished snowboarding and exhaustion. Her doctors determined she did not have a
for the day before her friend. She waited on the deck of traumatic brain injury and a majority of them recommended
Northstar’s Mid-Mountain Lodge until the sun went behind a psychiatric consult. Doe felt her injuries were physical and
the mountain. She then moved inside, where she noticed declined any psychiatric or psychological care.
heat vents in front of a retail counter. She sat down on the
floor in front of the retail counter in a location where the Doe remained off work for two years after the incident. She
retail counter worker could not see her. then started working as an outpatient physical therapist
three days a week.
Shortly after she sat down, the retail counter worker closed
LEGAL THEORIES AND STRATEGIES
a manual overhead security gate. He closed the gate from
behind the retail counter and did not notice Doe. The gate The case was litigated in Placer County, where Northstar
struck Doe on top of her head. Ski patrol responded and Doe is located. Ms. Doe alleged that Northstar’s employee was
declined medical treatment. Her friend came and helped negligent in how he closed the gate. Northstar alleged that
her back to her rental cabin. She drove herself back to San (1) it was not liable as a matter of law because Doe had
Francisco the next day. signed a global liability release when she applied for her
season pass, (2) Doe was responsible for any harm she
Doe returned to work two days later. She had difficulty suffered because she was sitting in an unexpected location
performing her work and was told to return when she was and (3) at the most she suffered a bruise on her head. The
medically capable of doing so. She was treated by a primary court denied Northstar’s motion for summary judgment
care doctor who noted a bruise on her head and neck tender- on the release issue.
ness. An orthopedic surgeon who worked with Doe felt she
had a minimal disk protrusion because of the incident but
could not rule out that it may have pre-existed the incident. $691,941 total jury verdict, reduced by Doe’s 40% compara-
tive fault to $415,164. The case resolved shortly after trial
Doe was placed in a neck brace. Three months later when for the judgment plus prevailing party costs.
Miles B. Cooper, with Maryanne B. Cooper of Fix, LLP, represented Ms. Doe at trial. June Bashant took the majority
of expert depositions, including obtaining critical impeachment material on the defendant’s orthopedist and
We’ve been asked, “Why so many Does and Roes in your newsletters and website?” Sometimes the defendants require confidentiality as part of the
settlement. Other times our clients request that we keep their identities private. While it may at first blush appear to lack creativity to keep using Does
and Roes, the objective is clarity—to indicate that a specific write-up is confidential.
For more information on this theory, please see the related brief in the Weapons and Tactics section.
Miles and Maryanne Cooper, husband and wife, tried
not one but two cases together for the firm this year.
A prevailing party attorneys’ fees motion is pending in
the second case. The facts and outcome of that case
will be reported in the winter edition of Righting Wrongs.
The two met when they were lawyers at another firm.
While they worked at the same firm together, they had
not worked together on cases and had never been to
trial together before. “We figured if we could travel for
months with each other in developing countries, we
had some of the coping mechanisms necessary to get
through trial—patience, a sense of humor, and stamina
in adverse conditions,” said Miles. While Miles reports
that it worked, Maryanne, who runs her own firm, was
not interviewed for her side of the story.
4 WEAPONS & TACTICS
“You’ll shoot your eye out!”
Using Restatement of Torts § 324A to Impose a Duty on Child Watchers
Daniel Pleasant, ACP, CAS
Charlotte Langley agreed with Jane Barfield to watch Jane’s foster father’s adult son, the court stated that as a “general
eight-year-old son, Jason, at the Langleys’ home. Charlotte’s rule, a person who undertakes the control and supervision
nine-year-old son Joey phoned his friend Shane, also nine, of a child, even without compensation, has the duty to use
and told him to come over with his BB gun. While playing—you reasonable care to protect the child from injury.” 7
know what’s coming if you’ve ever seen A Christmas Story—
Shane shot Jason’s eye out. And in 1957, a New Jersey appellate court reversed a trial
court judgment of involuntary dismissal in an action by an
Saying it was “axiomatic” that “an action undertaken for the infant who was left with his grandmother under an arrange-
benefit of another, even gratuitously, must be performed in ment with his mother by which the grandmother would
accordance with an obligation to exercise reasonable care, babysit the child without pay while the mother was shopping.
the Florida Court of Appeal reversed the summary judgment The child was permitted to recover for injuries he sustained
the trial court had granted defendant Charlotte Langley on when he thrust his arm into an unattended running washing
the duty issue. 3 machine.8
This case illustrates the general rule that persons who Other courts have likewise recognized a duty for nonparental
undertake to watch over young children owe a duty to use supervisors of minors to use due care:
reasonable care. “However, the measure of duty of a person • The mother of an 11-year-old drowning victim sued the
undertaking control and supervision of a child to exercise owner of a swimming pool, alleging negligent supervi-
reasonable care for the safety of the child is to be gauged by sion and premises liability. The Georgia Court of Appeals
the standard of the average reasonable parent; such person held that summary judgment for the defendant should
is not an insurer of the safety of the child and has no duty to be reversed because there was a genuine issue of fact as
foresee and guard against every possible hazard.”4 to whether owner, as temporary custodian of child, was
No California case has affirmed this duty principle so precise- negligent in allowing child to swim in deep end of pool.
ly. But California has recognized Restatement of Torts (2d) The duty was to be gauged by the average-reasonable-
§ 324A. Cases citing that section establish that a volunteer parent standard.9
who, having no initial duty to do so, undertakes to provide • Parents of a 13-year-old child who was injured when
protective services to another, will be found to have a duty he poured gasoline on burning fire while playing with
to exercise due care in the performance of that undertaking neighbor’s son brought an action against landowners.
if one of two conditions is met: either (a) the volunteer’s The Indiana Court of Appeals held the complaint
failure to exercise such care increases the risk of harm to stated a cause of action for failure to supervise.10
the other person, or (b) the other person reasonably relies • A mother brought an action for the alleged wrongful death
upon the volunteer’s undertaking and suffers injury as a of her son who had gone with defendant, the father of
result. So when faced with an injury to a child while the child a friend of the son, on a fishing trip. The Georgia Court
is being watched by a nonparent, consider using Section of Appeals found that the defendant owed a duty to use
324A as a basis for imposing a duty on the child watcher. reasonable care [average-reasonable-parent standard]
Illustrating this tactic, in 1973, the Alabama Supreme Court in supervision.11
relied on Section 324A to impose a duty on a nonparent Rouda Feder Tietjen & McGuinn has experience in these types
caregiver. In that case, a volunteer babysitter on her own of cases. If you are faced with such a negligent-supervision
premises was found to have a duty of due care in supervising case, please feel free to contact us.
a one-and-a-half –year-old child who, while under her care
and control, pulled a skillet of hot grease off a counter onto
himself. The court buttressed its conclusion with decisions 3
Barfield v. Langley (Fla. App. 1983) 432 So.2d 748, 749.
from sister states that had considered this principle in 4
CJS, Negligence, § 475.
volunteer-babysitter cases. 5 5
Standifer v. Pate (Ala. 1973) 282 So.2d 261, 262-264.
Zalak v. Carroll (N.Y. 1965) 205 N.E.2d 313.
For example, the New York Court of Appeals upheld a
Whitney v. Southern Farm Bureau Casualty Insurance Co. (La. App.
judgment against the aunt and uncle who cared for the
1969) 225 So.2d 30 [finding duty, but no breach as a matter of law
four-year-old plaintiff while her mother was working. under facts presented].
The child sustained injuries when a swing set on which 8
Barbarisi v. Caruso (N.J. App. 1957) 135 A.2d 539, 541-542.
she was playing fell over on her.6 9
Hemphill v. Johnson (Ga. App. 1998) 497 S.E.2d 16.
Similarly, in a 1969 Louisiana Court of Appeal case involving 10
Johnson v. Pettigrew (Ind. App. 1992) 595 N.E.2d 747, 752.
the drowning death of a 12-year-old on a lake outing with his 11
Laite v. Baxter (Ga. App. 1972) 191 S.E.2d 531.
SAFETY FIRST! 5
Summertime Barbecues and Propane Safety
It’s a warm summer weekend and you are basking in the sun on your deck with your family, enjoying a
cold drink and the enticing smell of a sizzling steak on the barbeque. The last thought on your mind is
It shouldn’t be. According to a recent U.S. Consumer Product Safety Commission report, warm weather
activities such as hosting a barbeque led to product-related injuries of more than 3.7 million people in
the summer months of a single year—836,000 injuries more than the winter months that same year.
Barbecues with family and friends are great fun. Make sure to always be aware of safe handling practices for propane tanks.
The dangers of propane (Liquid Propane Gas) are vastly While the 1998 law required all propane cylinders under
understated and poorly understood. But with a few precau- 40 pounds to have an OPD, propane containers in excess
tionary steps, you can ensure a safe barbeque every time. of 40 pounds do not require an OPD. Larger cylinders are
Barbeques with family and friends are great fun, but make not typically used for barbeques, but they are often used in
sure you follow the safety tips below: other common applications, such as stoves, gas fireplaces,
welding, construction, pottery, and heating trailers, mobile
• Propane Containers homes and garages.
Most propane containers or cylinders weigh between 4
pounds and 40 pounds and contain an Overfill Protection Sadly, the propane industry successfully lobbied against
Device (OPD) that prevents the accidental overfilling of the installation of OPDs in propane cylinders over 40
propane. A propane cylinder is overfilled if it contains more pounds, so larger cylinders have an inherent danger of
than 80% liquid propane gas. Since 1998, all propane being overfilled if not filled with extreme caution (see the
cylinders in this weight range have been required to con- side panel for a study on 100-pound cylinders and their
tain an OPD. If you have an old propane cylinder, inspect unique hazards).
it carefully and you will see a date of manufacture. If your
cylinder was manufactured before 1998, discard it in a • Transportation of Propane Cylinders
safe fashion after venting all the propane. Using a propane Always transport your propane cylinder in an upright
container without an OPD is an accident waiting to happen. position. Your propane cylinder has a pressure relief valve
6 SAFETY FIRST!
Summertime Barbeques and Propane Safety (continued)
designed to vent propane vapor if excessive pressure builds keep extra propane cylinders on hand, store them in a
up inside the cylinder. Under normal circumstances with cool place away from any water heaters or other potential
a properly filled cylinder, the pressure relief valve, which sources of heat or ignition.
is typically set at 375 psi, will not open. The vapor inside
a cylinder would have to be heated to about 160 degrees • Use of Propane Cylinders
Fahrenheit to reach that pressure, and this would only After you are done barbequing, always turn off your valve
occur when the cylinder is exposed to extreme tempera- to your propane cylinder. Get in the habit of opening and
tures, such as exposure to fire. closing your propane valve after every use. Leaving your
propane valve open all the time runs the risk of propane
But the pressure relief valve only works if the propane escaping.
cylinder is in an upright position. If a propane cylinder is
lying horizontal and the pressure relief valve opens, liquid • If You Hear Your Propane Tank Hiss, Stay Away
propane gas will escape, not vapor. This fact is little known, If a propane container is overfilled, the pressure relief valve
and extremely significant, as liquid propane gas expands will open and vent propane vapor into the air. Without a
270 times when it reaches the atmosphere, and thus the nearby source of ignition, the propane valve will vent, and
potential for a catastrophic propane accident is much if properly working, close after it discharges the excess
greater if the cylinder is transported or stored horizontally. pressure. But if you ever hear your propane cylinder “hiss”
or “whistle,” stay away and keep clear. Do not try to inspect
If you are planning to take your propane cylinder to a gas or turn any valve on your cylinder—the danger is simply too
station or other place to be filled, try to go directly to the great. If the hissing continues for more than 30 seconds,
facility, get it filled and then return home. Do not let your call 911. It is better to be safe than sorry.
recently filled propane cylinder sit inside your car or trunk
for several hours on a hot day, as this is inviting danger. • Eliminate The Danger of Propane By Going To Natural Gas
Finally, if you are thinking of getting a new barbeque, go
• Inspection of Propane Cylinders and Equipment with one that can accommodate a natural gas line. The cost
Inspect your propane cylinders each year for dents, gouges, of running a natural gas line to your barbeque is only a few
corrosion, leaks or extreme rust. Also check your hoses on hundred dollars. You will save money in the long run, never
your grill for brittleness, leaks, holes or cracks. If you find have to deal with the potential dangers of propane, and
any of these problems, it is time to replace your equipment. never run out of fuel in the midst of a summer party.
• Storage of Propane Cylinders Bear in mind the above safety tips, and barbeque safely to
Always store your propane cylinder in an upright position, enjoy your summer.
and never store any filled cylinders in your home. If you
100-pound propane cylinder explodes and kills man
In Doe Family v. Durnall & Campora Propane, Inc., et al. and personal losses they suffered, the money cannot
(Righting Wrongs vol. I, Summer 2010; http://bit.ly/ make up for the life they lost. Don’t assume a propane
pE1p65), the Doe family lost a husband and father when filling station is safe just because they are in the propane
an improperly filled 100-pound propane tank exploded, business. Be aware of safe handling practices for tanks
causing severe burns that eventually killed Mr. Doe. and use particular caution when filling tanks on hot
While the firm was able to secure a $4.85 million summer days.
settlement for the family to make up for the economic
STAFF NEWS 7
PROFESSIONAL VOLUNTEER WORK
Cynthia McGuinn continues to be noted Support for San Francisco Trial Lawyers’
as one of the top 100 Northern California
Association’s Trial Advocacy Fellowship program
attorneys and top 50 Northern California
female attorneys as selected by Super Our firm was not only a financial backer but
Lawyers magazine, both honors she has held also host for the San Francisco Trial Law-
since 2006. In addition, she is the recipient yers’ Association’s Trial Advocacy Fellowship
of the American Board of Trial Advocates “Masters In Trial” program. The program seeks to introduce a
award which was presented to her in Chicago in June 2011. diverse group of law students to the plaintiffs’
The award was given for her work teaching trial skills to other bar. Four fellows from a pool of applicants are
lawyers at ABOTA programs throughout the country. selected and given stipends and the opportunity to work at
....................................................................................... three different consumer attorney firms in San Francisco over
Mandissa Logan recently joined the firm as
a paralegal. She moved to San Francisco in Our firm’s fellow, Magdalena Gruettner, grew up in communist
2010 and worked as a paralegal for litigation Poland. She is now about to enter her third year of law school
firms in New York and her native Georgia. at the University of San Francisco. Magdalena had opportuni-
She earned a J.D. from Emory University in ties to work with several members of the firm. She spent a
Atlanta, Georgia where she became deeply substantial portion of time with June Bashant, who had sev-
committed to plaintiffs’ advocacy. In her leisure time, Mandis- eral depositions and a mediation in an interesting employment
sa enjoys writing short fiction and trying new recipes in her case during Magdalena’s rotation at RFTM.
kitchen. She is also an avid reader and movie watcher. .......................................................................................
SOCIAL Tim Tietjen and his wife Cindy Tietjen
hosted an event at their Napa home to gather
Ron Rouda and his wife Sue Rouda attended the American eyeglasses and support for Lions In Sight, a
Board of Trial Advocates’ International Meeting in Bali, Thai- charitable organization dedicated to bringing
land and Cambodia, where Ron made a new acquaintance basic eye care and eyeglasses to people in
or two. need throughout the world.
Pro bono defense for consumer leads to dismissal
While we are a plaintiff’s firm, we sometimes
provide pro bono defense when consumers
find themselves on the wrong side of the
“v” in a case. This most frequently occurs
in eviction-defense cases where we assist
low-income or unempowered tenants faced
with losing their homes.
Recently Miles Cooper helped a young woman who was sued
by an insurance company for property damage. The woman,
a single mother who was working fulltime and taking care
Cynthia McGuinn was also scheduled to go on the trip with of two children, had sold her car. It was then involved in a
her husband John McGuinn, a trial lawyer with McGuinn Hills- collision. The purchaser failed to turn in the proper transfer
man & Palefsky. But she was working on a significant case that documents. As a result, the insurance company went after
she could not leave. While the timing and preparation required the young woman, suing her when she told them it was not
for the case prevented Cynthia and John from joining the pre- her car, nor was she driving when the incident occurred.
planned trip, the effort was worth it as the case resolved well
for a confidential sum. Her partner Miles Cooper and his wife When she came to us, she was facing a mounting pile of
were fortunate enough to be able to take their place, however. paper—the insurance company’s discovery requests—and the
potential of losing the case for not responding to the requests.
We helped her obtain the transfer record from the DMV. It
Sue and Ron also made the local Tiburon paper in May for supported her position that she had sold the car. We wrote a
their part in a duckling rescue. They noticed 11 ducklings letter to the insurance company’s lawyers and provided the
tumble into a storm drain while they were out for a walk. Sue documentation. While it took longer than one would hope
contacted the Humane Society while Ron kept a vigilant eye on (which is what we frequently notice about insurance com-
the ducklings. Soon a group had amassed. The ducklings were panies—but hey, they’re insurance companies) the company
rescued and returned to the nearby lagoon with their parents. dismissed the case against the young woman.
8 CASES WE BELIEVE IN. PEOPLE WE CARE ABOUT.
Young woman uses $16 million jury verdict to move forward and help others
Alice Mowatt has come a long way from the devastating
injuries she suffered as a pedestrian trying to cross a busy
Los Angeles thoroughfare. Alice was a young college student
visiting from England when she was struck by a car at nearly
50 mph. The City’s crosswalk possessed a hidden hazard—
it was placed at a crest in the hill in a 55-mph zone where
drivers were not able to see pedestrians until too late. Alice
suffered a host of injuries because of the impact, the worst
being a severe brain injury. John Feder and Ron Rouda tried
her case in Los Angeles in 2006 and a jury agreed that the
crosswalk was dangerous. The Court of Appeal also agreed
and Alice’s final judgment, with costs and interest, was $16
million. The City finally responded and removed the danger-
ous crosswalk, far too late for Alice.
Alice and her parents put the funds toward her recovery.
She got involved in The Silver Lining (http://bit.ly/r8ZIw5),
a London-based group that helps brain injury victims. As part
of The Silver Lining’s outreach, Alice will be going to South
Africa this summer to help children with brain injuries. While
Alice still suffers from some short-term memory problems,
she has found a job working part-time at a London newspaper.
If you want to see The Silver Lining’s short film about Alice
and her success go to http://bit.ly/n2eIeV.
Rouda Feder Tietjen & McGuinn’s Newsletter
Founded in 1980, Rouda Feder Tietjen & McGuinn focuses on catastrophic-injury, wrongful
death, and employment cases. We develop innovative strategies and solutions to complex
legal problems. Our firm welcomes referrals of serious personal injury, wrongful death, and
employment cases from our clients, colleagues, and friends. We gladly share referral fees in
accordance with the California Rules of Professional Conduct.
44 Montgomery Street
San Francisco, CA 94104
T. 415 398 5398
F. 415 398 8169