On June 12, 2020 a
Motion-Secondary
was filed
involving a dispute between
Alum Rock Union Elementary School District,
Brco Constructors, Inc,
Del Terra Real Estate Services, Inc.,
Does 1 Through 10,
Fast-Track Construction Corporation, A California Corporation,
and
Del Terra Real Estate Services, Inc.,
Does 1 Through 10, Inclusive,
for (16) Unlimited Fraud
in the District Court of San Mateo County.
Preview
190V3541 89
Santa Clara —
Civil!
A. Rodriquez
Peter M. Rehon (SBN 100 123) Filed
Electronically
Rogelio M. Ruiz (SBN 148500) by Superior Court of CA,
F I L
‘
Steven M. Wheat (SBN 286974)
REHON &ROBERTS E D County
on
of Santa
1/9/2020 4:57
Clara,-
PM
A Professional Corporation SAN MATEO COUNTY ‘
Reviewed By: A. Rodriguez
830 The Alameda Case #1 9CV3541 80
-San Jose, CA 95126
'
JUN 1 2 20
'
Envelope: 3868558
Telephone: (408) 494-0900
-
c'e'k0f e periorCourt
Facsimile:(408)494-09o9
Email: n‘uiz@relionroberts§¥u1 - Exempt from ling fees
CLERK per Gov’t Code § 6103
swheat@rehonrobcrts.com
WV
.
Attorneys for Plaintiff I
a
ALUM ROCK UNION ELEMENTARY \
SCHOOL DISTRICT
10
SUPERIOR COURT 0F CALIFORNIA
'11
_ COUNTY OF"SAN’1‘A CLARA
(
12 UNLIMITED JURISDICTION 1
13
. 20C.1V024“6"6_
V.
14 ALUM ROCK UNION ELEMENTARY Case No. 19CV3541 80
SCHOOL DISTRICT,
15 r
PROOF OF SERVICE ’
Plaintiff,
16
1.7
V- ‘ Date: January 23, 2020
Time: 9:00 AM
1s DEL TERRA REAL ESTATE SERVICES, Judge: Hon. Sunil R. Kulkarni
INC., dba, DEL TERRA GROUP, a Dept; 8
19 California corporation, and DOES l
20‘
through 10, inclusive, Complaint Filed: August 29, 201 9
'
Trial Date: None Set
21 Defendants.
22
23
24
‘25
26
27
28
PROOF OF‘ SERVICE
I, the undersigned, declare that I am over the age ef eighteen (l 8) years and not a party to
the within cause; that I am employed in Santa C1ara,County and my business address is Rehon &
Rober/s, APC, 830 The Alameda, San Jose, CA 95126.
On January 09, 2,020, I served the following documents by the method(s) below:
A
1) ALUM ROCK UNIONELEMENTARY SCHOOL DISTRICT’ S
MEMORANDUM 0F POINTS AND AUTHORITIES IN OPPOSITION TO
DEFENDANT’S MOTION TO CHANGE VENUE;
2) DECLARATION OF ROGELIO RUIZ IN SUPPORT OF ALUM ROCK
UNION ELEMENTARY SCHOOL DISTRICT’S’OPPOSITION TO
DEFENDANT’S MOTION TO CHANGE VENUE; AND
3) DECLARATION OF KOLVIRA CHHENG IN SUPPORT OF ALUM ROCK
UNION'ELEMENTARY SCHOOL DISTRICT’S OPPOSITION TO
10
DEFENDANT’S MOTION TO CHANGE VENUE.
11'
BY ELECTRONIC MAIL: By electronically transmitting a copy of the document(s)
12 listed above via email to the addressee(s) as set forth below, in accordance with the
parties’ agreement to be served electronically pursuant to Code of Civil Procedu1e section
13 1010. 6- and Calitoinia Rule of Court 2. 260(a) or court order N0 error messages were
received after said transmission.
14
BY U. S. MAIL: By placing the document(s) listed above in a sealed envelope with
15
postage thereon fully prepaid, in the United States mail at San Jose, California addressed
l6 as set forth below. Iam readily familiar with the rm’ s practice of collection and
processing of correspondence for mailing. Under that practice, it would be
deposited
17 with the U. S. Postal Service on that same day with postage thereon fully prepaid1n the
ordinary course ot business
18
Attorneys for Defendant Del Terra Estate Services, Inc.
19
20
Rachel L. Fiset, Esq. .
Qv’
Erin C. Coleman, Esq. -
21 Zweiback, Fiset & Coleman, LLP
523 w. 6‘" Street, Suite 450
22 Los Angeles, CA 900 14
23 Email: Raclrel.set@zfclaw.com
24
Erin.colemanzfclawcom
I declare under penalty of perjury trnder the laws of the State of California that the
25
foregoing is true and correct. Executed on January 0.9, 0 0, at San Jose, California.
26
27
28 W AYN dom PY 0F THE ORIGINAL
EON FILE IN 19,1115 OFFICE WITH THE
2 EXECPTION OF THE COURT REDACTIONS
moor or SERVICE g
V JUN 1 0 20211
Clerk or the
SUPE
Coma
omcourrrv My DEPUTY
BY
Document Filed Date
June 12, 2020
Case Filing Date
June 12, 2020
Category
(16) Unlimited Fraud
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190V3541 89 Santa Clara — Civil! A. Rodriquez Peter M. Rehon (SBN 100 123) Filed Electronically Rogelio M. Ruiz (SBN 148500) by Superior Court of CA, F I L ‘ Steven M. Wheat (SBN 286974) REHON &ROBERTS E D County on of Santa 1/9/2020 4:57 Clara,- PM A Professional Corporation SAN MATEO COUNTY ‘ Reviewed By: A. Rodriguez 830 The Alameda Case #1 9CV3541 80 -San Jose, CA 95126 ' JUN 1 2 20 ' Envelope: 3868558 Telephone: (408) 494-0900 - c'e'k0f e periorCourt Facsimile:(408)494-09o9 Email: n‘uiz@relionroberts§¥u1 - Exempt from ling fees CLERK per Gov’t Code § 6103 swheat@rehonrobcrts.com WV . Attorneys for Plaintiff I a ALUM ROCK UNION ELEMENTARY \ SCHOOL DISTRICT 10 SUPERIOR COURT 0F CALIFORNIA '11 _ COUNTY OF"SAN’1‘A CLARA ( 12 UNLIMITED JURISDICTION 1 13 . 20C.1V024“6"6_ V. 14 ALUM ROCK UNION ELEMENTARY Case No. 19CV3541 80 SCHOOL DISTRICT, 15 r PROOF OF SERVICE ’ Plaintiff, 16 1.7 V- ‘ Date: January 23, 2020 Time: 9:00 AM 1s DEL TERRA REAL ESTATE SERVICES, Judge: Hon. Sunil R. Kulkarni INC., dba, DEL TERRA GROUP, a Dept; 8 19 California corporation, and DOES l 20‘ through 10, inclusive, Complaint Filed: August 29, 201 9 ' Trial Date: None Set 21 Defendants. 22 23 24 ‘25 26 27 28 PROOF OF‘ SERVICE I, the undersigned, declare that I am over the age ef eighteen (l 8) years and not a party to the within cause; that I am employed in Santa C1ara,County and my business address is Rehon & Rober/s, APC, 830 The Alameda, San Jose, CA 95126. On January 09, 2,020, I served the following documents by the method(s) below: A 1) ALUM ROCK UNIONELEMENTARY SCHOOL DISTRICT’ S MEMORANDUM 0F POINTS AND AUTHORITIES IN OPPOSITION TO DEFENDANT’S MOTION TO CHANGE VENUE; 2) DECLARATION OF ROGELIO RUIZ IN SUPPORT OF ALUM ROCK UNION ELEMENTARY SCHOOL DISTRICT’S’OPPOSITION TO DEFENDANT’S MOTION TO CHANGE VENUE; AND 3) DECLARATION OF KOLVIRA CHHENG IN SUPPORT OF ALUM ROCK UNION'ELEMENTARY SCHOOL DISTRICT’S OPPOSITION TO 10 DEFENDANT’S MOTION TO CHANGE VENUE. 11' BY ELECTRONIC MAIL: By electronically transmitting a copy of the document(s) 12 listed above via email to the addressee(s) as set forth below, in accordance with the parties’ agreement to be served electronically pursuant to Code of Civil Procedu1e section 13 1010. 6- and Calitoinia Rule of Court 2. 260(a) or court order N0 error messages were received after said transmission. 14 BY U. S. MAIL: By placing the document(s) listed above in a sealed envelope with 15 postage thereon fully prepaid, in the United States mail at San Jose, California addressed l6 as set forth below. Iam readily familiar with the rm’ s practice of collection and processing of correspondence for mailing. Under that practice, it would be deposited 17 with the U. S. Postal Service on that same day with postage thereon fully prepaid1n the ordinary course ot business 18 Attorneys for Defendant Del Terra Estate Services, Inc. 19 20 Rachel L. Fiset, Esq. . Qv’ Erin C. Coleman, Esq. - 21 Zweiback, Fiset & Coleman, LLP 523 w. 6‘" Street, Suite 450 22 Los Angeles, CA 900 14 23 Email: Raclrel.set@zfclaw.com 24 Erin.colemanzfclawcom I declare under penalty of perjury trnder the laws of the State of California that the 25 foregoing is true and correct. Executed on January 0.9, 0 0, at San Jose, California. 26 27 28 W AYN dom PY 0F THE ORIGINAL EON FILE IN 19,1115 OFFICE WITH THE 2 EXECPTION OF THE COURT REDACTIONS moor or SERVICE g V JUN 1 0 20211 Clerk or the SUPE Coma omcourrrv My DEPUTY BY