Motion-Secondary: NACE REYNOLDS VS. ROBIN AMELIA SHEEHAN ET AL

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
Preview
                                CANDO PF WN Ee

WWNNNNNNNNN NKR BRP BRP BRB ee
FP SOECANI DAK BONHKF COCOA NINDRGTAKR WHR OS

 

 

Jacob Harker (State Bar No. 261262)
LAW OFFICES OF JACOB HARKER
268 Bush St. #3732

San Francisco, CA 94104

Tel: (415) 624-7602

Fax: (415) 684-7757

Email: jacob@ harkercounsel.com

Daniel L. Balsam (State Bar No. 260423)
THE LAW OFFICES OF DANIEL BALSAM
2601C Blanding Avenue #271

Alameda, CA 94501

Tel: (415) 869-2873

Fax: (415) 869-2873

Email: legal@ danbalsam.com

Attomeys for Plaintiff NACE REY NOLDS

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN FRANCISCO (UNLIMITED JURISDICTION)

NACE REYNOLDS;

Plaintiff,
v.

ROBIN AMELIA SHEEHAN, et al;

Defendants.

And Related Action

_) Trial Date:

ELECTRONICALLY
FILED

Superior Court of California}
County of San Francisco

12/06/2021
Clerk of the Court

BY: YOLANDA TABO-RAMIREZ

Deputy Cle!

) Case No.: CGC-21-594238, cons. with

) CGC-21-594246

)

) DECLARATION OF DANIEL BALSAM
) IN SUPPORT OF PLAINTIFF'S

) OPPOSITION TO HEIT DEFENDANTS’
) MOTION TO QUASH SERVICE OF

) SUMMONS AND COMPLAINT AND TO
) DISMISS COMPLAINT

)

) Date: December 17, 2021

) Time: 9:00 am

) Department: 302

) Action Filed: August 2, 2021

Not Set

 

I, Daniel L. Balsam declare:

1. Jaman attorney duly licensed to practice law in all courts of the State of California and an
attorney of record for Plaintiff Nace Reynolds in Reynolds v. Sheehan (CGC-21-

1

 

BALSAM DECL. ISO PLAINTIFF’ S OPPO. TO
HEIT DEFENDANTS’ MOTION TO QUASH AND DISMISSCANDO PF WN Ee

WWNNNNNNNNN NKR BRP BRP BRB ee
FP SOECANI DAK BONHKF COCOA NINDRGTAKR WHR OS

10.

594238/594246). I make this Declaration based upon personal knowledge. I could and
would testify competently as to the matters contained in this Declaration.

Exhibit A is a true and correct copy of Heit Law Group PC’s filing with the California
Secretary of State. Exhibit B is a true and correct copy of Brian Heit’s information publicly
available on the California Secretary of State’s website.

Exhibit C is a true and correct copy of part of VirtualPostMail’s webpage

 

https: //www. virtualpostmail.com/locations/walnut-ca.
My co-counsel Jacob Harker and I knew - before I arranged for service on the Heit
Defendants at 340 South Lemon Avenue, Walnut, CA 91789 - that that address is
VirtualPostMail (a commercial mail receiving agency (“CMRA”)), which is why we knew
that we could effect service on the Heit Defendants at that address.
On November 16, 2021, I visited the homepage of Heit Defendants’ website
www.heitlawgroup.com and also the webpage www.heitlawgroup.com/take-action and I
discovered that there was no publicly-viewable content there. Exhibit D is a true and correct
screenshot of what I saw on November 16, 2021. I went back to those webpages on several
more dates through and including December 6, 2021, and I saw the same message.
On September 27, 2021, I emailed Proofs of Service on Heit Law Group PC in both pre-
consolidated A ction to Defendants’ Counsel Ed Sasaki, and he acknowledged receipt.
Exhibit E is a true and correct copy of this email exchange.
On October 18, 2021 at 11:25 am, I emailed Proofs of Service on Brian Heit in both pre-
consolidated A ction to Defendants’ Counsel Ed Sasaki, and he acknowledged receipt.
Exhibit F is a true and correct copy of this email exchange.
On October 18, 2021 at 2:56 pm, Eva Chavez of Cha Law Ethics served the Heit
Defendants’ Motion to Quash and Dismiss by email on me and Harker. Exhibit G is a true
and correct copy of this email.
On September 24, 2021, I asked Sasaki if he was authorized to accept service of process on
behalf of the Heit Defendants (and other Defendants) in the Reynolds Actions. Sasaki
responded that he had not yet asked them for authorization, but he would. Weeks later, on
October 15, Sasaki had still not responded to my question.
My process server initially provided incorrect Proofs of Service on Heit Law Group PC in
both pre-consolidation Actions, which I filed on September 27, 2021. See Register of

2

 

 

 

BALSAM DECL. ISO PLAINTIFF’ S OPPO. TO
HEIT DEFENDANTS’ MOTION TO QUASH AND DISMISSCANDO PF WN Ee

WWNNNNNNNNN NKR BRP BRP BRB ee
FP SOECANI DAK BONHKF COCOA NINDRGTAKR WHR OS

11.

12.

13.

14.

15.

Actions. My process server then provided Amended Proofs of Service, which I filed on
October 28, 2021. Exhibit H is true and correct filestamped copies of the Amended Proofs
of Service on Heit Law Group PC in both pre-consolidation Actions.

Exhibit I is true and correct filestamped copies of the Proofs of Service on Brian Heit in
both pre-consolidation Actions.

Exhibit ] is a true and correct copies of Notice of Unavailability that Sasaki served on behalf
of the Heit Defendants (and other Defendants) in both pre-consolidation Actions on October
25 and November 12, 2021.

Exhibit K is a true and correct copy of part of the webpage at https: //www.regus.com/en-
us/united-states/california/burbank/4100-west-alameda-avenue-3483, showing that 4100 W.
Alameda Avenue, Suite 300, Burbank, CA 91505 is a Regus Executive Suite.

Exhibit L is a true and correct copy of part of the the webpage at https: //downtown
santacruz.com/go/heit-family-dentistry showing that 903 Cedar Street, Santa Cruz, CA

95060 is “Heit Family Dentistry.”

Exhibit M is a true and correct copy of the United States Postal Service form “Request for
Change of Address or Boxholder Information Needed for Service of Legal Process.”

I declare under penalty of perjury under the laws of the State of California that the foregoing and

attachments are true and correct.

THE LAW OFFICES OF DANIEL BALSAM

Date:_ December 6, 2021 BY: 06 k

 

DANIEL L. BALSAM
Attomeys for Plaintiff Nace Reynolds

3

 

 

 

BALSAM DECL. ISO PLAINTIFF’ S OPPO. TO
HEIT DEFENDANTS’ MOTION TO QUASH AND DISMISSEXHIBIT ABusiness Search - Business Entities - Business Programs | Califomia Sec...

Document Type

SI-COMPLETE

SI-COMPLETE

AMENDMENT

AMENDMENT

REGISTRATION

1of2

ntity Detail

and reflects work processed
eived dates of filings currently
images are available online.

PROFESSIONAL

07/14/2016
CALIFORNI.
DOMESTIC
ACTIVE
BRIAN MOR
340 SOUTH
WALNUT C
340 SOUTH
WALNUT C
340 SOUTH
WALNUT C

eginning five months before

Jf File Date
01/28/2021

06/26/2019
09/10/2018
07/09/2018

07/14/2016

1 California Secretary of State’:

ier," the agent for service of p
2114 for information relating

a name, refer to Name Avail
formation on ordering a copy
status reports, certified copies
‘h or to request a more extensi\

 

https://businesssearch.sos.ca.gov/CBS/Detail

2/25/2021, 10:34 AMEXHIBIT BBrian Morgan Heit #302474 - Attomey Licensee Search https://apps.calbar.ca.gov/attomey/Licensee/Detail/302474.

 

) The State Bar of California

Brian Morgan Heit #302474
License Status: Active

Address: 340 S Lemon Ave # 8933, Walnut, CA 91789-2706
Phone: 310-744-5227 | Fax: Not Available
Email: Not Available | Website: Not Available

More about This Attorney «
CLA Sections: None
The California Lawyers Association (CLA) is an independent organization and is not part of the State Bar of California.

Self-Reported Practice Areas:

Note: The State Bar does not verify the accuracy of this content and makes no warranties regarding experience or
competence in practice areas. The State Bar encourages those seeking legal help to search Certified Specialists, use
Certified Lawyer Referral Services, search through LawHelpCA.org, and use the State Bar's online public information to
complement this information.

¢ Intellectual Property

Additional Languages Spoken:

By the attorney: None reported

By staff: None reported

Law School: Univ of Miami SOL; Coral Gables FL

All changes of license status due to nondisciplinary administrative matters and disciplinary actions.

Date License Status ® Discipline e Administrative Action @
Present Active
2/3/2015 Admitted to the State Bar of California

Additional Information:
¢ About the disciplinary system

Copyright © 2021 The State Bar of California

e000

lof1 10/19/2021, 10:29AMEXHIBIT C12/6/21, 4:20 PM California Virtual Mailbox - Locations | VirtualPostMail - VPM.

. ae . Contact -
{GP \pRroducts v Solutions v_ Pricing v Locations v Resources v Us [J

A Commercial
Address for Your
Business and
Personal Mail in
California

Get Started GC)

 

Le
op:

About Walnut, CA
Walnut is a suburban city in the Ca | ifornia 9 . 50%

eastern part of Los Angeles
County. The city was one of the top
50 best places to live in the US and

https://www.virtualpostmail.com/locations/walnut-ca V812/6/21, 4:20 PM

{GP pProducts vy Solutions v Pricing vy Locations v Resources v

Ure turgese wer WUSHIoCL NL.

https://www.virtualpostmail.com/locations/walnut-ca

California Virtual Mailbox - Locations | VirtualPostMail - VPM.

ALIQEIeS

wy Vv
Cortez Park
ALNUT VALLEY

South San

» Jose Hills

&) Costco Wholesale

 

Rowland
Gosgle

wder

nyon

Contact
Us

 

15.570

> =MtSanar uve

Antonio
College

  
               
 

H Mart Diamond Bar Ng

RMap data ©2021

2/8EXHIBIT D€ > SG B OC B hitps://wwwheitlawgroup.com w &

@ Facebook Ej Amazon © Clickup ij SF Court [| Court Dates @ 1eFile Sos ‘ Whois.com fil whoxy ~% BofA

Private Site

This site is currently private. If you're the owner or contributor, log in.

Gp scuaresrace

- > C BB OC B https//www.heitlawgroup.com/take-action &

@ Facebook Ej Amazon © Clickup ij SF Court [| Court Dates @ 1eFile Sos ‘ Whois.com fil whoxy ~% BofA

Private Site

This site is currently private. If you're the owner or contributor, log in.

Gp scuaresraceEXHIBIT EEd Sasaki [ed@chalawethics.com] Sent: Mon 9/27/2021 11:31 AM

Dan Balsam; ‘Jacob Harker’
Jean Cha; Eva Chaver
‘Subject: FW: (Helt, Sheehan, Feaver) Nace Reynolds -- MONDAY 9:30 a.m. Meet and Confer TC

Attachments: ") Reynolds 1 v S&F and Heit - Service Package on Sheehan - POS (signed).pdF (630 KB);
© Reynolds 1 v S&F and Heit - Service Package on Heit Law Group - POS (signed) pdF (115 KB);
©) Reynolds 2 v Heit and S&F - Service Package on Heit Law Group - POS (signed).pdf (115 KB);
© Reynolds 2 v Heit and S&F - Service Package on Sheehan - POS (signed).pdf (643 KB)

 

Dear Dan,
Thank you very much for your prompt response. Your kindness and professional courtesy are much appreciated.

Sincerely,
Ed

From: Dan Balsam 
Sent: Monday, September 27, 2021 11:14 AM

To: Ed Sasaki 

Ce: Jean Cha ; Eve Chavez ; ‘Jacob Harker'


Subject: RE: (Heit, Sheehan, Feaver) Nace Reynolds -- MONDAY 9:30 a.m. Meet and Confer TC

Ed,
See attached POSs for all Ds served to date in the two Reynolds actions in San Francisco.

- DanEXHIBIT FSent: Mon 10/18/2021 11:25 AM
To:
Ge:
‘Subject: RE: (Heit) Nace Reynolds BRIAN HEIT.
Attachments: © Reynolds 4 v S&F and Heit - Service Package on Brian Heit - POS (signed).pdf (109 KB);
©) Reynolds 2 v Helt and S&F - Service Package on Brian Heit - POS (signed).pdf (126 KB)

 

‘Sure, Ed.

- Dan

 

From: Ed Sasaki [mailto:ed@chalawethics.com]
Sent: Sunday, October 17, 2021 9:31 AM

To: Dan Balsam; Jacob Harker

Subject: (Heit) Nace Reynolds BRIAN HEIT

Dear Dan and Jacob,

Would you please send me copies of the Proofs of Service on BRIAN HEIT in Nace Reynolds 1 & 2?

| believe the service dates were on or about 9/30/21 and 10/05/21.

Senior Attorney
CHA LAW ETHICS

1100 W. Town & Country Rd., Ste. 1250
Orange, CA 92868

Office (714) 242-8588

Cell (559) 213-5605
ed@chalawethics.com

300 Spectrum Center Drive, Suite 472
Irvine, CA 92618EXHIBIT GEva Chavez [eva@chalawethics.com] Sent: Mon 10/18/2021 2:56 PM

‘Jacob Harker’; Dan Balsam
ce: Jean Cha; Ed Sasaki
Subject: Reynolds v Sheehan, et al., CGC-21-594238 & CGC-21-594246

 

Dear Counsel,

Please follow the link below for service copies of specially appearing Defendants Brian Heit and Heit Law Group's Notice
Of Motion and Motion to Quash Service of Summons and Complaint and to Dismiss Complaint Memorandum of Points
and Authorities Declarations of Edwin Sasaki and Brian Heit, in the matters Nace Reynolds v Robin Sheehan, et al., SFSC
Case No. CGC-21-594238 and Nace Reynolds v Robin Sheehan, et al., SFSC Case No. CGC-21-594246

™ OC - Nace Reynolds MTQ

Aller clicking Une link you will be prompled Lo enter @ code Ural will be senil lo this email. The code may go le your Junk
folder. If you have any difficulty accessing the documents please contact me at your earliest convenience.

Thank you,

Eva Chavez

Legal Secretary/ Law Clerk

CHA LAW ETHICS

1100 W. Town & Country Rd., Ste. 1250
Orange, CA 92868

Office (714) 242-8588
eva@chalawethics.com

Confidentiality Notice: Do not read this e-mail if you are not the intended recipient. This e-mail transmission, any documents, files or previous e-mail
messages attached to it may contain confidential information that is legally privileged. If you are not the intended recipient, you are hereby notified
that any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is prohibited. If you have
received this transmission in error, please destroy the original transmission and its attachments without reading or saving them in any matter and
contact (714) 242-8588, Thank you.EXHIBIT HPOS-010

 

ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address)
DANIEL L. BALSAM | SBN: 260423

LAW OFFICES OF DANIEL BALSAM

2601C BLANDING AVENUE #271 ALAMEDA, CA 94501

TELEPHONE NO.: (415) 869-2873 | FAX NO. |£-MAIL ADDRESS (Optional): legal@ danbalsam.com
ATTORNEY FOR (Name): Plaintf:

 

SAN FRANCISCO SUPERIOR COURT
STREET ADDRESS: 400 MC ALLISTER ST.
MAILING ADDRESS:

CITY AND zip cope: SAN FRANCISCO, CA 94102
BRANCH NAME: CIVIL DIVISION

FOR COURT USE ONLY

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

10/28/2021
Clerk of the Court
BY: EDNALEEN ALEGRE
Deputy Clerk

 

PLAINTIFF: NACE REYNOLDS, AN INDIVIDUAL CASE NUMBER
DEFENDANT: ROBIN AMELIA SHEEHAN, AN INDIVIDUAL, ET AL. CGC-21-594238

 

Ret. No, oF File No.

AMENDED PROOF OF SERVICE OF SUMMONS.

 

 

 

 

(Separate proof of service is required for each party served.)

1. At the time of service | was at least 18 years of age and not a party to this action.
2. | served copies of:
a Summons
b. Complaint
c Alternative Dispute Resolution (ADR) package
d. C1 Civil Case Cover Sheet (served in complex cases only)
e. Cross-complaint
f. other JUDICIAL MEDIATION PROGRAM; BLANK CASE MANAGEMENT STATEMENT; NOTICE TO PLAINTIFF
3. a. Party served (specify name of party as shown on documents served):
HEIT LAW GROUP PC, A CALIFORNIA PROFESSIONAL CORPORATION
b. 4 Person (other than the party in item 3a) served on behalf of an entity or as an authorized agent (and not a person under
item 5b on whom substituted service was made) (specify name and relationship to the party named in item 3a):
CLERK IVY K. - AUTHORIZED TO ACCEPT - AGENT FOR SERVICE - SHIPPING CLERK -
Age: 30 Weight: 120 Hair: BLACK Sex: Female
Height: 5'7 Eyes: Race: ASIAN
4. Address where the party was served: 340 S Lemon Ave #8933
Walnut, CA 91789

5. | Seryed the party
a. by personal service. | personally delivered the documents listed in item 2 to the party or person authorized to
receive service of process for the party (1) on (date): 9/15/2021 (2) at (time): 10:17 AM

0 by substituted service. On (date): at (time): | left the documents listed in item 2 with or
in the presence of (name and title or relationship to person indicated in item 3b):

(1) [1 (business) a person at least 18 years of age apparently in charge at the office or usual place of business of the
person to be served. | informed him of her of the general nature of the papers.

(2) LJ (home) a competent member of the household (at least 18 years of age) at the dwelling house or usual place of
abode of the party. | informed him or her of the general nature of the papers.

(3) L (physical address unknown) a person at least 18 years of age apparently in charge at the usual mailing address
of the person to be served, other than a United States Postal Service post office box. | informed him of her of the
general nature of the papers.

(4) CJ | thereafter mailed (by first-class, postage prepaid) copies of the documents to the person to be served at the
place where the copies were left (Code Civ. Proc., §415.20). | mailed the documents on
(date): from (city): or [_] a declaration of mailing is attached.

(6) O | attach a declaration of diligence stating actions taken first to attempt personal service.

Page 1 of2

Form Approved for Mandatory Use Code of Civil Procedure, § 417.10

5545 few. fanvary 3007) PROOF OF SERVICE OF SUMMONS POSO10-1/174120APETITIONER: NACE REYNOLDS, AN INDIVIDUAL CASE NUMBER:

CGC-21-594238
RESPONDENT: ROBIN AMELIA SHEEHAN, AN INDIVIDUAL, ET AL.

 

 

 

 

c. LJ by mail and acknowledgment of receipt of service. | mailed the documents listed in item 2 to the party, to the address
shown in item 4, by first-class mail, postage prepaid,

(1) on (date): (2) from (city):
(3) C1 with two copies of the Notice and Acknowledgment of Receipt and a postage-paid return envelope addressed to me
(Attach completed Notice and Acknowledgement of Receipt.) (Code Civ. Proc., § 415.30.)
(4) O to an address outside California with return receipt requested. (Code Civ. Proc., § 415.40.)
d. [by other means (specify means of service and authorizing code section)

C1 Additional page describing service is attached.
6. The "Notice to the Person Served" (on the summons) was completed as follows:

. LE] as an individual defendant.
as the person sued under the fictitious name of (specify):

a

b,

c. A as occupant.

d. On behalf of (specify): HEIT LAW GROUP PC, A CALIFORNIA PROFESSIONAL CORPORATION
under the following Code of Civil Procedure section:

416.10 (corporation) (J 415.95 (business organization, form unknown)
[1 416.20 (defunct corporation) (1 416.60 (minor)
[1 416.30 (joint stock company/association) Y 416.70 (ward or conservatee)
[1 416.40 (association or partnership) 416.90 (authorized person)
[1 416.50 (public entity) 415.46 (occupant)
other: B&P 17538.45

7. Person who served papers
a. Name: ERIC WILKINS - J PL PROCESS SERVICE, LLC
b. Address: 14482 BEACH BLVD. STE X WESTMINSTER, CA 92683
c. Telephone number: (866) 754-0520
d. The fee for service was: $ 87.00
e. lam:

(1) L] nota registered California process server.

(2) 4 exempt from registration under Business and Professions Code section 22350(b).
(3) registered California process server: 4

(i) (J owner LJ employee independent contractor.

(ii) Registration No.: 2012208220

(iii) County: LOS ANGELES

8. 4 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
or

9. ] tam a California sheriff or marshal and | certify that the foregoing is true and correct.

Date: 10/21/2021

JPL PROCESS SERVICE, LLC

14482 BEACH BLVD. STE X

WESTMINSTER, CA 92683 | (866) 754-0520
a

 

 

 

pan"

ERIC WILKINS »

(NAME OF PERSON WHO SERVED PAPERS/SHERIFF OR MARSHAL) .

™

 

POS-010 [Rev anuary 1, 2007] PROOF OF SERVICE OF SUMMONS Page 20f2
POS-010/174120APOS-010

 

ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address)
DANIEL L. BALSAM | SBN: 260423

LAW OFFICES OF DANIEL BALSAM

2601C BLANDING AVENUE #271 ALAMEDA, CA 94501

TELEPHONE NO.: (415) 869-2873 | FAX NO. |£-MAIL ADDRESS (Optional): legal@ danbalsam.com
ATTORNEY FOR (Name): Plaintf:

 

SAN FRANCISCO SUPERIOR COURT
STREET ADDRESS: 400 MC ALLISTER ST.
MAILING ADDRESS:

CITY AND zip cope: SAN FRANCISCO, CA 94102
BRANCH NAME: CIVIL DIVISION

FOR COURT USE ONLY

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

10/28/2021
Clerk of the Court
BY: EDNALEEN ALEGRE
Deputy Clerk

 

PLAINTIFF: NACE REYNOLDS, AN INDIVIDUAL CASE NUMBER
DEFENDANT: BRIAN MORGAN HEIT,, AN INDIVIDUAL, ET AL CGC-21-594246

 

Ret. No, oF File No.

AMENDED PROOF OF SERVICE OF SUMMONS.

 

 

 

 

(Separate proof of service is required for each party served.)

1. At the time of service | was at least 18 years of age and not a party to this action.
2. | served copies of:
a Summons
b. Complaint
c Alternative Dispute Resolution (ADR) package
d. C1 Civil Case Cover Sheet (served in complex cases only)
e. Cross-complaint
f. other JUDICIAL MEDIATION PROGRAM; BLANK CASE MANAGEMENT STATEMENT; NOTICE TO PLAINTIFF
3. a. Party served (specify name of party as shown on documents served):
HEIT LAW GROUP PC, A CALIFORNIA PROFESSIONAL CORPORATION
b. 4 Person (other than the party in item 3a) served on behalf of an entity or as an authorized agent (and not a person under
item 5b on whom substituted service was made) (specify name and relationship to the party named in item 3a):
CLERK - IVY K. - AUTHORIZED TO ACCEPT - AGENT FOR SERVICE - SHIPPING CLERK
Age: 30 Weight: 120 Hair: BLACK Sex: Female
Height: 5'7 Eyes: Race: ASIAN
4. Address where the party was served: 340 S Lemon Ave #8933
Walnut, CA 91789

5. | Seryed the party
a. by personal service. | personally delivered the documents listed in item 2 to the party or person authorized to
receive service of process for the party (1) on (date): 9/15/2021 (2) at (time): 10:17 AM

0 by substituted service. On (date): at (time): | left the documents listed in item 2 with or
in the presence of (name and title or relationship to person indicated in item 3b):

(1) [1 (business) a person at least 18 years of age apparently in charge at the office or usual place of business of the
person to be served. | informed him of her of the general nature of the papers.

(2) LJ (home) a competent member of the household (at least 18 years of age) at the dwelling house or usual place of
abode of the party. | informed him or her of the general nature of the papers.

(3) L (physical address unknown) a person at least 18 years of age apparently in charge at the usual mailing address
of the person to be served, other than a United States Postal Service post office box. | informed him of her of the
general nature of the papers.

(4) CJ | thereafter mailed (by first-class, postage prepaid) copies of the documents to the person to be served at the
place where the copies were left (Code Civ. Proc., §415.20). | mailed the documents on
(date): from (city): or [_] a declaration of mailing is attached.

(6) O | attach a declaration of diligence stating actions taken first to attempt personal service.

Page 1 of2

Form Approved for Mandatory Use Code of Civil Procedure, § 417.10

5545 few. fanvary 3007) PROOF OF SERVICE OF SUMMONS POSO10-1/174120BPETITIONER: NACE REYNOLDS, AN INDIVIDUAL CASE NUMBER:

CGC-21-594246
RESPONDENT: BRIAN MORGAN HEIT,, AN INDIVIDUAL, ET AL.

 

 

 

 

c. LJ by mail and acknowledgment of receipt of service. | mailed the documents listed in item 2 to the party, to the address
shown in item 4, by first-class mail, postage prepaid,

(1) on (date): (2) from (city):
(3) C1 with two copies of the Notice and Acknowledgment of Receipt and a postage-paid return envelope addressed to me
(Attach completed Notice and Acknowledgement of Receipt.) (Code Civ. Proc., § 415.30.)
(4) O to an address outside California with return receipt requested. (Code Civ. Proc., § 415.40.)
d. [by other means (specify means of service and authorizing code section)

C1 Additional page describing service is attached.
6. The "Notice to the Person Served" (on the summons) was completed as follows:

. LE] as an individual defendant.
as the person sued under the fictitious name of (specify):

a

b,

c. A as occupant.

d. On behalf of (specify): HEIT LAW GROUP PC, A CALIFORNIA PROFESSIONAL CORPORATION
under the following Code of Civil Procedure section:

416.10 (corporation) (J 415.95 (business organization, form unknown)
[1 416.20 (defunct corporation) (1 416.60 (minor)
[1 416.30 (joint stock company/association) Y 416.70 (ward or conservatee)
[1 416.40 (association or partnership) 416.90 (authorized person)
[1 416.50 (public entity) 415.46 (occupant)
other: B&P 17538.45

7. Person who served papers
a. Name: ERIC WILKINS - J PL PROCESS SERVICE, LLC
b. Address: 14482 BEACH BLVD. STE X WESTMINSTER, CA 92683
c. Telephone number: (866) 754-0520
d. The fee for service was: $ 87.00
e. lam:

(1) L] nota registered California process server.

(2) 4 exempt from registration under Business and Professions Code section 22350(b).
(3) registered California process server: 4

(i) (J owner LJ employee independent contractor.

(ii) Registration No.: 2012208220

(iii) County: LOS ANGELES

8. 4 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
or

9. ] tam a California sheriff or marshal and | certify that the foregoing is true and correct.

Date: 10/21/2021

JPL PROCESS SERVICE, LLC

14482 BEACH BLVD. STE X

WESTMINSTER, CA 92683 | (866) 754-0520
a

  

pew"

ERIC WILKINS »

(NAME OF PERSON WHO SERVED PAPERS/SHERIFF OR MARSHAL) .

™

 

POS-010 [Rev anuary 1, 2007] PROOF OF SERVICE OF SUMMONS Page 20f2
POS-010/174120BEXHIBIT IPOS-01

 

"ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY
DANIEL L. BALSAM | SBN: 260423

LAW OFFICES OF DANIEL BALSAM

2601C BLANDING AVENUE #271 ALAMEDA, CA 94501

TELEPHONE NO.; (415) 869-2873 | FAX NO, |E-MAIL ADDRESS (Optional): legal@danbalsam.com

 

 

ATTORNEY FOR (Name): : NACE REYNOLDS ELECTRONICALLY
SAN FRANCISCO SUPERIOR COURT F ILE D .
Superior Court of California,
STREET ADDRESS: 400 MC ALLISTER ST. County of San Francisco
MAILING ADDRESS: 40/29/2021
cTy AND ziP cove: SAN FRANCISCO, CA 94102 Clerk of the Court
BRANCH NAME: CIVIL DIVISION BY: YOLANDA TABO-RAMIREZ
Deputy Clerk
PLAINTIFF: NACE REYNOLDS, AN INDIVIDUAL CASE NUMBER:
DEFENDANT: ROBIN AMELIA SHEEHAN, AN INDIVIDUAL, ET AL. CGC-21-594238

 

Raf. No, oF File No.

PROOF OF SERVICE OF SUMMONS

 

 

 

 

(Separate proof of service is required for each party served.)

1. At the time of service | was at least 18 years of age and not a party to this action.
2. I served copies of:

a. summons

b. Complaint

c. WF alternative Dispute Resolution (ADR) package

d.LJ Civil Case Cover Sheet (served in complex cases only)
e.L1 Cross-complaint

f

other NOTICE TO PLAINTIFF; STIPULATION TO ALTERNATIVE DISPUTE RESOLUTION (ADR); JUDICIAL MEDIATION
PROGRAM; BLANK CASE MANAGEMENT STATEMENT

3. a. Party served (specify name of party as shown on documents served):
BRIAN MORGAN HEIT, AN INDIVIDUAL

b.L1 Person (other than the party in item 3a) served on behalf of an entity or as an authorized agent (and not a person under
item 5b on whom substituted service was made) (specify name and relationship to the party named in item 3a):
4. Address where the party was served: 340 S Lemon Ave # 8933
Walnut, CA 91789

5. | served the party

a.L] by personal service. | personally delivered the documents listed in item 2 to the party or person authorized to
receive service of process for the party (1) on (date): (2) at (time):

b. wy by substituted service. On (date): 10/5/2021 at (time): 10:05 AM | left the documents listed in item 2 with or
in the presence of (name and title or relationship to person indicated in item 3b):
REGGIE P. - PERSON MOST IN CHARGE - SHIPPING CLERK - VIRTUAL MAIL CENTER
Age: 30 Weight: 180 Hair: BLACK Sex: Male
Height: 5'8 Eyes: Race: HISPANIC

(1) LF) (business) a person at least 18 years of age apparently in charge at the office or usual place of business of the
person to be served. | informed him of her of the general nature of the papers.

(2) F1 (home) a competent member of the household (at least 18 years of age) at the dwelling house or usual place of
abode of the party. | informed him or her of the general nature of the papers.

(3) Wf (physical address unknown) a person at least 18 years of age apparently in charge at the usual mailing
address of the person to be served, other than a United States Postal Service post office box. | informed him of
her of the general nature of the papers.

(4) 71 | thereafter mailed (by first-class, postage prepaid) copies of the documents to the person to be served at the
place where the copies were left (Code Civ. Proc., §415.20). | mailed the documents on
(date): 10/5/2021 from (city): WESTMINSTER, CA or L] a declaration of mailing is attached.

(5) © tattacha declaration of diligence stating actions taken first to attempt personal service

Page 1 of2
Form Approved for Mandatory Use Code of Civil Procedure, § 417.10

dust Counc of Calfomig PROOF OF SERVICE OF SUMMONS POS010-1/175111A.PETITIONER: NACE REYNOLDS, AN INDIVIDUAL CASE NUMBER:

CGC-21-594238
RESPONDENT: ROBIN AMELIA SHEEHAN, AN INDIVIDUAL, ET AL.

 

 

 

 

c.L] by mail and acknowledgment of receipt of service. | mailed the documents listed in item 2 to the party, to the address
shown in item 4, by first-class mail, postage prepaid,
(1) on (date): (2) from (city):
3a with two copies of the Notice and Acknowledgment of Receipt and a postage-paid return envelope addressed to me.
(Attach completed Notice and Acknowledgement of Receipt.) (Code Civ. Proc., § 415.30.)
(4)L1 to an address outside California with return receipt requested. (Code Civ. Proc., § 415.40.)
40 by other means (specify means of service and authorizing code section):

C1 Additional page describing service is attached.
6. The "Notice to the Person Served" (on the summons) was completed as follows:

a. as anindividual defendant.
b. as the person sued under the fictitious name of (specify):
c.L] as occupant.
4.11 on behalt of (specify):
under the following Code of Civil Procedure section:

(1 416.10 (corporation) [1 415.95 (business organization, form unknown)
[1] 416.20 (defunct corporation) 416.60 (minor)
[1 416.30 (joint stock company/association) L_] 416.70 (ward or conservatee)
(1 416.40 (association or partnership) [1] 416.90 (authorized person)
1 416.50 (public entity) [1] 415.46 (occupant)
C1 other:

7. Person who served papers
a. Name: ERIC WILKINS - JPL PROCESS SERVICE, LLC
b. Address: 14482 BEACH BLVD. STE X WESTMINSTER, CA 92683
c. Telephone number: (866) 754-0520
d. The fee for service was: $ 70.00
e. lam:

(2) [) exempt from registration under Business and Professions Code section 22350(b).
(3) © registered California process server: ;
i) Oy ‘owner employee [Mf independent contractor.

(
(ii) Registration No.: 2012208220
(iii) County: LOS ANGELES

(1) E not a registered California process server.

8. &f Ideclare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
or

9.1 tama California sheriff or marshal and | certify that the foregoing is true and correct.

Date: 10/6/2021

JPL PROCESS SERVICE, LLC
14482 BEACH BLVD. STE X
WESTMINSTER, CA 92683 | (866) 754-0520

    

 

Eee
ERIC WILKINS » G penn

(NAME OF PERSON WHO SERVED PAPERS/SHERIFF OR MARSHAL) ee

 

POSO10 Rev January 1.2007] PROOF OF SERVICE OF SUMMONS pos ootveitia"ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY
DANIEL L. BALSAM | SBN: 260423,

LAW OFFICES OF DANIEL BALSAM

2601C BLANDING AVENUE #271 ALAMEDA, CA 94501

TELEPHONE NO.; (415) 869-2873 | FAX NO, |E-MAIL ADDRESS (Optional): legal@danbalsam.com
ATTORNEY FOR (Name): : NACE REYNOLDS

 

SAN FRANCISCO SUPERIOR COURT
sTREET ADDRESS: 400 MC ALLISTER ST.
MAILING ADDRESS:
CITY AND ziP cope: SAN FRANCISCO, CA 94102
BRANCH NAME: CIVIL DIVISION
PLAINTIFF/PETITIONER: NACE REYNOLDS, AN INDIVIDUAL (CASE NUMBER:

DEFENDANT/RESPONDENT: ROBIN AMELIA SHEEHAN, AN INDIVIDUAL, ET AL. CGC-21-594238

 

 

Raf. No, oF File No.

DECLARATION OF DILIGENCE

 

 

 

 

|, ERIC WILKINS , declare: | am a Registered Process Server and was retained to serve process in the above-referenced matter
on the following person or entity: BRIAN MORGAN HEIT, AN INDIVIDUAL as follows:
Documents:

Summons; Complaint; Alternative Dispute (ADR) package; NOTICE TO PLAINTIFF; STIPULATION TO ALTERNATIVE DISPUTE
RESOLUTION (ADR); JUDICIAL MEDIATION PROGRAM; BLANK CASE MANAGEMENT STATEMENT;

| attempted personal service on the following dates and times with the following results:

Date Time Location Results

10/5/2021 10:05 AM Business THIS IS A VIRTUAL MAILING CENTER, SUBJECT RECEIVES MAIL AT
THE LOCATION.

340 S Lemon Ave # 8933, Walnut, CA 917892706

10/5/2021 10:05 AM Other Substituted service on: BRIAN MORGAN HEIT, AN INDIVIDUAL; 340 S
Lemon Ave # 8933, Walnut, CA 91789; by serving: REGGIE P. -
PERSON MOST IN CHARGE - SHIPPING CLERK - VIRTUAL MAIL
CENTER, HISPANIC Male 30 180 BLACK 5'8 .

10/5/2021 Mailed copy of documents to: BRIAN MORGAN HEIT, AN INDIVIDUAL.
340 S Lemon Ave # 8933, Walnut, CA 91789

Fee for Service: $ 70.00
County: LOS ANGELES

 

Registration No.: | declare under penalty of perjury that the foregoing is true
JPL PROCESS SERVICE, LLC and correct and that this declaration was executed on
14482 BEACH BLVD. STE X . 10/6/2021.

WESTMINSTER, CA 92683 cL

(866) 754-0520 .

Ge VL
ERIC WILKINS

Signature:

   

 

AFFIDAVIT OF REASONABLE DILIGENCE

Order#: 1751114,POS-01

 

"ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY
DANIEL L. BALSAM | SBN: 260423

LAW OFFICES OF DANIEL BALSAM

2601C BLANDING AVENUE #271 ALAMEDA, CA 94501

TELEPHONE NO.; (415) 869-2873 | FAX NO, |E-MAIL ADDRESS (Optional): legal@danbalsam.com

 

 

ATTORNEY FOR (Name}: ELECTRONICALLY
SAN FRANCISCO SUPERIOR COURT F ILE D .
Superior Court of California,
STREET ADDRESS: 400 MC ALLISTER ST. County of San Francisco
MAILING ADDRESS: 40/29/2021
cTy AND ziP cove: SAN FRANCISCO, CA 94102 Clerk of the Court
BRANCH NAME: CIVIL DIVISION BY: YOLANDA TABO-RAMIREZ
Deputy Clerk
PLAINTIFF: NACE REYNOLDS, AN INDIVIDUAL CASE NUMBER:
DEFENDANT: BRIAN MORGAN HEIT, AN INDIVIDUAL, ET AL. CGC-21-594246

 

Raf. No, or File No.

PROOF OF SERVICE OF SUMMONS

 

 

 

 

(Separate proof of service is required for each party served.)

1. At the time of service | was at least 18 years of age and not a party to this action.
2. I served copies of:

a. summons

b. Complaint

c. WF alternative Dispute Resolution (ADR) package

d.LJ Civil Case Cover Sheet (served in complex cases only)
e.L1 Cross-complaint

f

other JUDICIAL MEDIATION PROGRAM; BLANK CASE MANAGEMENT STATEMENT; NOTICE TO PLAINTIFF;
STIPULATION TO ALTERNATIVE DISPUTE RESOLUTION (ADR)

3. a. Party served (specify name of party as shown on documents served):
BRIAN MORGAN HEIT, AN INDIVIDUAL

b.L1 Person (other than the party in item 3a) served on behalf of an entity or as an authorized agent (and not a person under
item 5b on whom substituted service was made) (specify name and relationship to the party named in item 3a):
4. Address where the party was served: 340 S Lemon Ave # 8933
Walnut, CA 91789

5. | served the party

a.L] by personal service. | personally delivered the documents listed in item 2 to the party or person authorized to
receive service of process for the party (1) on (date): (2) at (time):

b. wy by substituted service. On (date): 9/30/2021 at (time): 10:06 AM | left the documents listed in item 2 with or
in the presence of (name and title or relationship to person indicated in item 3b):
IVY K - PERSON MOST IN CHARGE - SHIPPING CLERK
Age: 30 Weight: 120 Hair: BLACK Sex: Female
Height: 5°6 Eyes: Race: ASIAN

(1) LF) (business) a person at least 18 years of age apparently in charge at the office or usual place of business of the
person to be served. | informed him of her of the general nature of the papers.

(2) F) (home) a competent member of the household (at least 18 years of age) at the dwelling house or usual place of
abode of the party. | informed him or her of the general nature of the papers.

(3) Wf (physical address unknown) a person at least 18 years of age apparently in charge at the usual mailing
address of the person to be served, other than a United States Postal Service post office box. | informed him of
her of the general nature of the papers.

(4) 71 | thereafter mailed (by first-class, postage prepaid) copies of the documents to the person to be served at the
place where the copies were left (Code Civ. Proc., §415.20). | mailed the documents on
(date): 9/30/2021 from (city): WESTMINSTER, CA or L] a declaration of mailing is attached.

(5) © ‘attach a declaration of diligence stating actions taken first to attempt personal service

Page 1 of 2
Form Approved for Mandatory Use Code of Civil Procedure, § 417.10

justia Counc of Calforig PROOF OF SERVICE OF SUMMONS POS010-1/175060CPETITIONER: NACE REYNOLDS, AN INDIVIDUAL CASE NUMBER:

CGC-21-594246
RESPONDENT: BRIAN MORGAN HEIT, AN INDIVIDUAL, ET AL.

 

 

 

 

c.L] by mail and acknowledgment of receipt of service. | mailed the documents listed in item 2 to the party, to the address
shown in item 4, by first-class mail, postage prepaid,
(1) on (date): (2) from (city):
3a with two copies of the Notice and Acknowledgment of Receipt and a postage-paid return envelope addressed to me.
(Attach completed Notice and Acknowledgement of Receipt.) (Code Civ. Proc., § 415.30.)
(4)L1 to an address outside California with return receipt requested. (Code Civ. Proc., § 415.40.)
40 by other means (specify means of service and authorizing code section):

C1 Additional page describing service is attached.
6. The "Notice to the Person Served" (on the summons) was completed as follows:

a. as anindividual defendant.
b. as the person sued under the fictitious name of (specify):
c.L] as occupant.
4.11 on behalt of (specify):
under the following Code of Civil Procedure section:

(1 416.10 (corporation) [1 415.95 (business organization, form unknown)
[1] 416.20 (defunct corporation) 1 416.60 (minor)
1 416.30 (joint stock company/association) [_] 416.70 (ward or conservatee)
(1 416.40 (association or partnership) [1] 416.90 (authorized person)
1 416.50 (public entity) [415.46 (occupant)
C1 other:

7. Person who served papers
a. Name: ERIC WILKINS - JPL PROCESS SERVICE, LLC
b. Address: 14482 BEACH BLVD. STE X WESTMINSTER, CA 92683
c. Telephone number: (866) 754-0520
d. The fee for service was: $ 70.00
e. lam:

(2) 1} exempt from registration under Business and Professions Code section 22350(b).
(3) 4 registered California process server: ;
i) 5 owner employee om independent contractor.

(
(ii) Registration No.: 2012208220
(iii) County: LOS ANGELES

(1) E not a registered California process server.

8. &f Ideclare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
or

9.1 tama California sheriff or marshal and | certify that the foregoing is true and correct.

Date: 10/4/2021

JPL PROCESS SERVICE, LLC
14482 BEACH BLVD. STE X
WESTMINSTER, CA 92683 | (866) 754-0520

 

ERIC WILKINS. _ » G pen

(NAME OF PERSON WHO SERVED PAPERS/SHERIFF OR MARSHAL) ce

 

 

POS-010 Rev January 1.2007] PROOF OF SERVICE OF SUMMONS pos otoltraoeoe"ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) FOR COURT USE ONLY
DANIEL L. BALSAM | SBN: 260423.

LAW OFFICES OF DANIEL BALSAM

2601C BLANDING AVENUE #271 ALAMEDA, CA 94501

TELEPHONE NO.; (415) 869-2873 | FAX NO, |E-MAIL ADDRESS (Optional): legal@danbalsam.com
ATTORNEY FOR (Name):

 

SAN FRANCISCO SUPERIOR COURT
sTREET ADDRESS: 400 MC ALLISTER ST.
MAILING ADDRESS:
CITY AND zIP cope: SAN FRANCISCO, CA 94102
BRANCH NAME: CIVIL DIVISION
PLAINTIFF/PETITIONER: NACE REYNOLDS, AN INDIVIDUAL (CASE NUMBER:

DEFENDANT/RESPONDENT: BRIAN MORGAN HEIT, AN INDIVIDUAL, ET AL. CGC-21-594246

 

 

Raf. No, or File No.

DECLARATION OF DILIGENCE

 

 

 

 

|, ERIC WILKINS , declare: | am a Registered Process Server and was retained to serve process in the above-referenced matter
on the following person or entity: BRIAN MORGAN HEIT, AN INDIVIDUAL as follows:
Documents:

Summons; Complaint; Alternative Dispute (ADR) package; JUDICIAL MEDIATION PROGRAM; BLANK CASE MANAGEMENT.
STATEMENT; NOTICE TO PLAINTIFF; STIPULATION TO ALTERNATIVE DISPUTE RESOLUTION (ADR);

| attempted personal service on the following dates and times with the following results:

Date Time Location Results

9/30/2021 10:06 AM Not Physical THIS LOCATION IS A VIRTUAL POSTAL MAIL CENTER. DOCUMENTS
WERE LEFT WITH SHIPPING CLERK - IVY K. - PERSON MOST IN
CHARGE.
340 S Lemon Ave # 8933, Walnut, CA 917892706

9/30/2021 10:06 AM Other Substituted service on: BRIAN MORGAN HEIT, AN INDIVIDUAL; 340 S

Lemon Ave # 8933, Walnut, CA 91789; by serving: IVY K - PERSON
MOST IN CHARGE - SHIPPING CLERK, ASIAN Female 30 120 BLACK
56.

9/30/2021 Mailed copy of documents to: BRIAN MORGAN HEIT, AN INDIVIDUAL.
340 S Lemon Ave # 8933, Walnut, CA 91789

Fee for Service: $ 70.00
County: LOS ANGELES

 

Registration No.: | declare under penalty of perjury that the foregoing is true
JPL PROCESS SERVICE, LLC and correct and that this declaration was executed on
14482 BEACH BLVD. STE X . 10/4/2021.

WESTMINSTER, CA 92683 cL 1c]

(866) 754-0520

   
  

Z. va
ERIC WILKINS

Ff Signature:

 

AFFIDAVIT OF REASONABLE DILIGENCE

Order#: 175060CEXHIBIT JCo ON DoT FF wD eB

VN YY NYY NY NY DY SB BB BB Be Be Be eB Be
er A TF BH KF SGC BH DoF DWH SE SS

 

 

Jean Cha (SBN: 228137)

jean@ chalawethics.com

Ed Sasaki (SBN: 158930)

ed@ chalawethics.com

CHA LAW ETHICS

1100 W. Town & Country Rd., Suite 1250
Orange, California 92868

Telephone: (714) 242-8588

Fax: (657) 235-8588

Attomeys for Defendants,

ROBIN SHEEHAN, JAKE FEAVER,
SHEEHAN LAW GROUP PC,
SHEEHAN & FEAVER PC,

BRIAN MORGAN HEIT, AND
HEIT LAW GROUP PC

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN FRANCISCO — UNLIMITED CIVIL

NACE REY NOLDS, an individual;

Plaintiff,
v.

ROBIN AMELIA SHEEHAN, an individual;
MATTHEW JACOB FEAVER, and
individual; SHEEHAN LAW GROUP PC, a
(former) professional corporation;
SHEEHAN & FEAVER PC, a California
professional corporation;

BRIAN MORGAN HEIT, an individual;
HEIT LAW GROUP PC, a professional
corporation; and DOES 1-10;

Defendants.

 

Case Nos. CGC-21-594238 (“Reynolds 1”)
and CGC-21-594246 (“Reynolds 2”)

NOTICE OF UNAVAILABILITY OF
COUNSEL FOR DEFENDANTS-—

ROBIN AMELIA SHEEHAN,
MATTHEW JACOB FEAVER,
SHEEHAN LAW GROUP PC,
SHEEHAN & FEAVER PC,
BRIAN MORGAN HEIT, AND
HEIT LAW GROUP PC

Action Filed:

August 2, 2021
Trial Date: None Set

PLEASE TAKE NOTICE that from November 15, 2021 through November 19, 2021,

Edwin N. Sasaki, attorney for the Defendants named in the caption above, will be out of the office

and unavailable for any purpose whatsoever, including but not limited to, receiving notices of any

kind, responding to ex parte applications, or appearing at depositions or in court.

 

NOTICE OF UNAVAILABILITY OF COUNSELCo ON DoT FF wD eB

VN YY NYY NY NY DY SB BB BB Be Be Be eB Be
er A TF BH KF SGC BH DoF DWH SE SS

Mr. Sasaki is the primary attorney responsible for the handling of this matter for these
Defendants. The only exception is that, if necessary, Mr. Sasaki will be appearing remotely on
November 17, 2021, for the hearing on the Heit Defendants’ Motion to Quash Service of the
Summons and Complaint. However, he will be appearing ex parte to ask the Court to continue that
hearing date.

PLEASE TAKE FURTHER NOTICE THAT intentionally scheduling a conflicting
proceeding in bad faith or without good cause, with full knowledge of the unavailability of opposing
counsel, is sanctionable conduct. This notice is given pursuant to the case of Tenderloin Housing
Clinic v. Sparks (1992) 8 Cal. App.4" 299, 307.

DATED: October 25, 2021 CHA LAW ETHICS

By: Eda WW, Dooady po

Jean Cha, Esq.

Ed Sasaki, Esq.

Attomeys for Defendants,

ROBIN SHEEHAN, JAKE FEAVER,
SHEEHAN LAW GROUP PC,
SHEEHAN & FEAVER PC,

BRIAN MORGAN HEIT, and HEIT LAW
GROUP PC

2

 

 

 

NOTICE OF UNAVAILABILITY OF COUNSELCo ON DoT FF wD eB

VN YY NYY NY NY DY SB BB BB Be Be Be eB Be
er A TF BH KF SGC BH DoF DWH SE SS

 

 

PROOF OF SERVICE

Nace Reynolds v Robin Sheehan, et al.
San Francisco Superior Court Case Nos. CGC-21-594238 and CGC-21-594246

I declare that I am over the age of eighteen (18) and not a party to this action. 1 am employed
in the County of Orange, State of California. My business address is 1100 W Town & Country Rd,
Suite 1250, Orange, California 92868.

On October 25, 2021, I served true copies of the following document(s) described as:
NOTICE OF UNAVAILABILITY OF COUNSEL
FOR DEFENDANTS ROBIN AMELIA SHEEHAN, MATTHEW JACOB FEAVER,

SHEEHAN LAW GROUP PC, SHEEHAN & FEAVER PC, BRIAN MORGAN HEIT, AND
HEIT LAW GROUP PC

on all interested parties in this action:
[X] BY EMAILING a true copy of each document, TO E-MAIL RECIPIENTS as follows:

 

Jacob Harker, Esq. Daniel Balsam, Esq.

268 Bush Street, #3732 2601C Blanding Avenue, #271

San Francisco, CA 94104 Alameda, CA 94501

jacob@ harkercounsel.com galt det paleam.cura
calbar@ danbalsam.com

 

 

 

 

(X) | BY ELECTRONIC SERVICE: Pursuant to a court order or an agreement of the parties
to accept electronic service, or the parties listed above have agreed to accept service of the
aforementioned documents electronically in this action. I caused such documents to be emailed from
eva@ chalawethics.com. On October 25, 2021, I transmitted the above-referenced documents via
electronic mail to the above listed email addresses. I did not receive, within a reasonable time after
the transmission, any electronic message or other indication that the transmission was unsuccessful.

I declare under penalty of perjury under the laws of the State of California that the above is
true and correct. Executed October 25, 2021 at San Diego, California.

____/s/Eva Chavez
Eva Chavez

 

PROOF OF SERVICE10
ul
12
13
14
15
16
7
18
19
20
21
22
23
24
25
26
27
28

 

 

Jean Cha (SBN: 228137)
jean@chalawethics.com

Ed Sasaki (SBN: 158930)
ed@chalawethics.com

CHA LAW ETHICS

1100 W. Town & Country Rd., Suite 1250
Orange, California 92868

Telephone: (714) 242-8588

Fax: (657) 235-8588

Attorneys for Defendants,

ROBIN SHEEHAN, JAKE FEAVER,
SHEEHAN LAW GROUP PC,
SHEEHAN & FEAVER PC,

BRIAN MORGAN HEIT, AND
HEIT LAW GROUP PC

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN FRANCISCO —- UNLIMITED CIVIL

NACE REYNOLDS, an individual;

Plaintiff,
Vv.

ROBIN AMELIA SHEEHAN, an individual;
MATTHEW JACOB FEAVER, and
individual; SHEEHAN LAW GROUP PC, a
(former) professional corporation;
SHEEHAN & FEAVER PC, a California
professional corporation;

BRIAN MORGAN HEIT, an individual;
HEIT LAW GROUP PC, a professional
corporation; and DOES 1-10;

Defendants.

 

Case Nos. CGC-21-594238 (“Reynolds 1”)
and CGC-21-594246 (“Reynolds 2”)

AMENDED NOTICE OF
UNAVAILABILITY OF COUNSEL
FOR DEFENDANTS —

ROBIN AMELIA SHEEHAN,
MATTHEW JACOB FEAVER,
SHEEHAN LAW GROUP PC,
SHEEHAN & FEAVER PC,
BRIAN MORGAN HEIT, AND
HEIT LAW GROUP PC

Action Filed:
Trial Date:

August 2, 2021
None Set

PLEASE TAKE NOTICE that from November 13, 2021 through November 24, 2021,

Edwin N. Sasaki, attorney for the Defendants named in the caption above, will be out of the office

and unavailable for any purpose whatsoever, including but not limited to, receiving notices of any

kind, responding to ex parte applications, or appearing at depositions or in court.

 

AMENDED NOTICE OF UNAVAILABILITY OF COUNSEL10
ul
12
13
14
15
16
7
18
19
20
21
22
23
24
25
26
27
28

 

 

Mr. Sasaki is the primary attorney responsible for the handling of both matters for the Heit
Defendants. And he is the primary attorney responsible for the handling of Reynolds 1 for the
Sheehan and Feaver Defendants, until such time as the Court may approve the parties’ Stipluation
and enter an Order Consolidating Reynolds 1 and 2.

PLEASE TAKE FURTHER NOTICE THAT intentionally scheduling a conflicting
proceeding in bad faith or without good cause, with full knowledge of the unavailability of opposing
counsel, is sanctionable conduct. This notice is given pursuant to the case of Tenderloin Housing

Clinic v. Sparks (1992) 8 Cal. App.4 299, 307.
DATED: November 12, 2021 CHA LAW ETHICS

By: :
Jean Cha, Esq.

Ed Sasaki, Esq.

Attorneys for Defendants,

ROBIN SHEEHAN, JAKE FEAVER,
SHEEHAN LAW GROUP PC,
SHEEHAN & FEAVER PC,

BRIAN MORGAN HEIT, and HEIT LAW
GROUP PC

2
AMENDED NOTICE OF UNAVAILABILITY OF COUNSEL10
ul
12
13
14
15
16
7
18
19
20
21
22
23
24
25
26
27
28

 

 

PROOF OF SERVICE

Nace Reynolds v Robin Sheehan, et al.
San Francisco Superior Court Case Nos. CGC-21-594238 and CGC-21-594246

I declare that I am over the age of eighteen (18) and not a party to this action. I am employed
in the County of Orange, State of California. My business address is 1100 W Town & Country Rd,
Suite 1250, Orange, California 92868.

On November 12, 2021, I served true copies of the following document(s) described as:
AMENDED NOTICE OF UNAVAILABILITY OF COUNSEL FOR DEFENDANTS —

ROBIN AMELIA SHEEHAN, MATTHEW JACOB FEAVER, SHEEHAN LAW GROUP
PC, SHEEHAN & FEAVER PC, BRIAN MORGAN HEIT, AND HEIT LAW GROUP PC

on all interested parties in this action:

[x] BY EMAILING a true copy of each document, TO E-MAIL RECIPIENTS as follows:

 

Jacob Harker, Esq. Daniel Balsam, Esq.

268 Bush Street, #3732 2601C Blanding Avenue, #271
San Francisco, CA 94104 Alameda, CA 94501
jacob@harkercounsel.com legal@danbalsam.com

calbar@danbalsam.com

 

Alex Graft, Esq.

Kendall Layne, Esq.

Nancy Lew-Pham

333 Bush Street, Suite 1100

San Francisco, CA 94104
Kendall.Layne@LewisBrisbois.com
Alex.Graft@lewisbrisbois.com
Nancy.Lew-Pham@lewisbrisbois.com

 

 

 

 

(X) BY ELECTRONIC SERVICE: Pursuant to a court order or an agreement of the parties
to accept electronic service, or the parties listed above have agreed to accept service of the
aforementioned documents electronically in this action. I caused such documents to be emailed from
eva@chalawethics.com. On November 12, 2021, I transmitted the above-referenced documents via
electronic mail to the above listed email addresses. I did not receive, within a reasonable time after
the transmission, any electronic message or other indication that the transmission was unsuccessful.

I declare under penalty of perjury under the laws of the State of California that the above is
true and correct. Executed November 12, 2021 at