2DCA-08 CERTIFICATE OF COMPLIANCE Counsel of Record hereby certifies that pursuant to Rule 8.204(c)(1) or 8.360(b)(1) of the California Rules of Court, the enclosed brief of__________________ is produced using 13-point Roman type including footnotes and contains approximately___________ words, which is less than the total words permitted by the rules of court. Counsel relies on the word count of the computer program used to prepare this brief. Dated: ___________ Signed: ____________________________ Print Name: ________________________ Attorney(s) for: _____________________ American LegalNet, Inc. www.FormsWorkFlow.com