Motion to Tax Costs in Salcedo et al. v. Cardoza et al.| Trellis.Law

On June 19, 2017 a Motion,Ex Parte was filed involving a dispute between Alvarez, Marisol A. Jeanette, Salcedo, Damian, Salcedo, Lexani, Salcedo, Michael Angelo, and Cardoza, Betty, for civil in the District Court of Fresno County.

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ACCIDENT, INJURY AND MEDICAL MALPRACTICE
ATTORNEYS OF CALIFORNIA, APC
Jeffrey D. Bohn, (SBN: 243870)
2445 Capitol Street, Suite 105
Fresno, alifornia 93721
Telephone: (559) 485-1212
Facsimile: (559) 485-1210 E-FILED
8/22/2018 3:03 PM
Attomey for Plaintiffs FRESNO COUNTY SUPERIOR COURT
By: |. Herrera, Deputy

SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF FRESNO
10

ll MICHAEL ANGELO SALCEDO, et al., ) CASE NO. 17CECG02063
12 Plaintiffs, NOTICE OF MOTION AND MOTION
vs. TO RECOVER COSTS OF PERSONAL
13 SERVICE, MEMORANDUM OF
JOE IGANCIO CARDOZA, et al, POINTS AND AUTHORITIES, AND
14 DECLARATION OF JEFFREY D.
Defendants. BOHN IN SUPPORT
15

16 Date: October 18, 2018
Time: 3:30 p.m.
17 Dept.: 403
18 Hon. Rosemary McGuire
19 TO PLAINTIFF AND HIS COUNSEL OF RECORD:
20 PLEASE TAKE NOTICE that at October 18, 2018 at 3:30 p.m., or as soon thereafter
21 as the matter may be heard, in Department 403 of the Fresno County Superior Court, 1130 “O”
22 Street, Fresno, California, Plaintiffs MICHAEL ANGELO SALCEDO; DAMIAN SALCEDO,
23 by and through his Guardain ad Litem, MICHAEL ANGELO SALCEDO; LEXANI

SALCEDO, by and through her Guardain ad Litem, MICHAEL ANGELO SALCEDO; and
25 JEANETTE ALVAREZ, will and hereby do, move for an order allowing Plaintiffs to recover
26 the costs incurred in personally serving the summons and FAC on Defendants JOE IGNACIO
27 CARDOZA and BETTY CARDOZA, pursuant to the provisions of Code of Civil Procedure
28 section 415.30

Notice of Motion and Motion to Recover Costs of Personal Service
The motion will be based upon this notice, the attached memorandum in support and
declarations of Jeffrey D. Bohn, the files and records in this action, and any further evidence

and argument that the Court may receive at or before the hearing.

Dated: August 22, 2018 ACCIDENT, INJURY AND MEDICAL MALPRACTICE
ATTORNEYS OF CALIFORNIA, APC

GHA __
Jeffrey D. Bohn, Esq.
Attorneys for Plaintiffs
10

122

2:21

23
23

Notice of Motion and Motion to Recover Costs of Personal Service
MEMORANDUM OF POINTS AND AUTHORITIES
I. INTRODUCTION
Plaintiffs properly served each of the Defendants, Joe Cardoza and Betty Cardoza, by
mail and acknowledgment of receipt. Both refused to acknowledge receipt of service. So,
Plaintiffs had to serve them personally, incurring the costs of hiring a registered process server.
Accordingly, Defendants, Joe Cardoza and Betty Cardoza, are liable for the costs of

service incurred after their refusal to acknowledge service by mail.
II. PROCEDURAL AND FACTUAL BACKGROUND
On June 19, 2017, Plaintiffs filed this action for personal injuries sustained in an auto
10 collision caused by Defendants’ negligence. (Bohn Decl., { 2.)
IL On July 20, 2018 Plaintiffs served Defendants Joe Cardoza and Betty Cardoza at their
12 residence at 1034 E. Griffith Way, Fresno, California, 93704, by both first class mail and
13 certified mail, postage prepaid, return receipt requested, a copy of the summons and First
14 Amended Complaint (“FAC”) in this action, two copies of the Notice and Acknowledgment of
15 Receipt of Summons forms and a self-addressed, postage prepaid return envelope. (Bohn Decl.,
16 {{| 4-5.) Based upon a Westlaw skip traced performed by Plaintiffs’ counsel, and cross-
17 referencing that information with the information on the traffic collision report prepared by law
18 enforcement, Plainrtiffs were informed and belived that the address to which the documents were
19 sent was, in fact, defendant’s residence address. (Id., at { 3.)
20 Using the certified mailing tracking numbers, Plaintiffs confirmed that the summons and
21 FAC mailed by certified mail were not claimed and were being retumed to the sender. (Bohn
22 Decl., 1 6.) However, Plaintiffs served the summons and FAC in compliance with Code of Civil
23 Procedure section 415.30 via first class mail. (/d., at J 4.)
24 Plaintiffs did not receive from Defendants Joe Cardoza or Betty Cardoza the executed
25 (Notice and Acknowledgment of Receipt within the period of than twenty days after mailing.
26 (Bohn Decl., 7.) Accordingly, in order to accomplish timely service, it was necessary for
27 Plaintiffs to hire a process server to personally serve Defendants Joe Cardoza and Betty Cardoza
28 ‘with another copy of the summons and FAC. (/d., at ] 8.)

Memorandum of Points and Authorities in Support of
Motion to Recover Costs of Personal Service
Personal service on Defendant Joe Cardoza was accomplished on August 18, 2018 by
Eddings Attorney Service. (Bohn Decl., { 9.) Substitute service was made on Defendant Betty
Cardoza on August 18, 2018 by Eddings Attorney Service. (Jbid.) On August 20, 2018,
Defendants Joe Cardoza and Betty Cardoza both answered the FAC. (Bohn Decl., ¥ 10.)
Plaintiff was charged the total sum of $59.25, which Plaintiff's counsel believes to be a
reasonable amount for the service, based on a decade of experience as an attorney. (Bohn Decl.,
| 11.) The filing fee for this motion to recover the service of process fees is $60.00. (Ibid.)
Postage cost for service of this motion is $1.42. (Ibid.)
III. LEGAL ARGUMENT
10 a. Service by Mail and Acknowledgement of Receipt is Permitted by Code of
WW Civil Procedure Section 415.30
12 Service by mail and acknowledgment of receipt pursuant to section 415.30 requires only
13 simply that Plaintiffs mail the defendant copies of the summons and complaint, with a request to
14 acknowledge receipt thereof. If the defendant signs the acknowledgment, it waives further
15 service of process.
16 If the defendant refuses, some other method of service must be utilized but the defendant
17 is liable for the costs incurred. (Code Civ. Proc. 415.30, subd. (d).)
18 b. Plaintiffs Complied with Code of Civil Procedure Section 415.30 to Properly
19 Effectuate Service by Mail and Acknowledgement of Receipt
20 Required to be mailed to defendant are: (1) a copy of the summons and complaint; (2)
21 two copies of the notice and acknowledgment form; and (3) a return envelope, postage prepaid,
22 addressed to the sender. (Code Civ. Proc., § 415.30, subd. (a).) Ordinary, first class mail of the
23 foregoing is sufficient, and the mailing need not be certified or registered or return-receipt-
24 equested. (Jbid.) The mailing address may include post office box as long as it is accompanied
25 by an acknowledgment of receipt, under § 415.30. (Transamerica Title Ins. Co. v. Hendrix
26 (1995) 34 Cal.App.4th 740, 745.)
27 The notice must apprise defendant that unless he or she signs and returns the
28 acknowledgment within 20 days, service will be made in some other manner, and defendant

Memorandum of Points and Authorities in Support of
Motion to Recover Costs of Personal Service
held liable for the extra expenses so incurred. (Code Civ. Proc. 415.30, subd. (b).) The
acknowledgment must simply evidence receipt of a copy of the summons and complaint. (Jbid.)
An official form Notice and Acknowledgment of Receipt has been adopted for mandatory use

by the Judicial Council. Use of the form automatically satisfies the above requirements. (Code
Civ. Proc. 415.30, subd. (e).)
Here, on July 20, 2018, Plaintiffs each mailed by first class mail and certified mail, return]
receipt requested, to Defendants Joe Cardoza and Betty Cardoza, at 1034 E. Griffith Way,

Fresno, California, 93704, (1) a copy of the summons and FAC; (2) two copies of the notice and
acknowledgment Judicial Council form; and (3) a return envelope, postage prepaid, addressed to
10 the sender. (Bohn Decl., { 2.)
i The certified mail packages were refused and unclaimed by Defendants. However, the
12 First Class mail packages were not returned to the sender. Neither defendant returned the notice
13 and acknowledgment Judicial Council form in the postage prepaid, return envelope, addressed
14 to Plaintiffs’ counsel.
15 Thereafter, Defendants were served at the same Griffith address by a registered
16 California process server, at Plaintiffs’ expense. Accordingly, the evidence supports a finding
17 that Defendants were properly served by mail with an acknowledgment of receipt.
18 c. Defendants Refused Acknowledgment and Are Therefore Liable for
19 Plaintiffs’ Costs of Service
20 If defendant fails to sign and return the acknowledgment, service is not complete and
21 will have to be made in some other manner. The notice form gives defendants the chance to
22 avoid the costs involved in effecting service by some other method. Therefore, if they fail to
23 sign and return the acknowledgment within 20 days after it is mailed, they become liable for
24 whatever costs plaintiff incurs in effecting service by some other method—regardless of the
25 outcome of the lawsuit. (Code Civ. Proc. 415.30, subd. (d).)
26 Nothing in the statute requires plaintiff to wait until the end of the case to obtain
27 reimbursement of service costs.
28

Memorandum of Points and Authorities in Support of
Motion to Recover Costs of Personal Service
The statute says plaintiff may obtain reimbursement on motion “with or without notice”

to the defendant; and the court shall order such reimbursement “except for good cause shown.”
(Code Civ. Proc. 415.30, subd. (d).)

Here, Defendants Joe Cardoza and Betty Cardoza failed to sign and return the

acknowledgment; so, service had to be made in another manner, i.e., personal service and

substitute service pursuant to Sections 415.10 and 415.20. Therefore, since Defendants failed to
sign and return their acknowledgment forms within 20 days after they were mailed, they have

become liable for costs that plaintiff incurred in effecting service by personal service.
IV.CONCLUSION
10 Based on the foregoing, Plaintiff respectfully requests that this Court award costs to
1 Plaintiffs, for the personal service of the summons and FAC on Defendants Joe Cardoza and
122
Betty Cardoza after their refusal to acknowledge service pursuant to Section 415.30, in the
13 amount of $120.67, which includes the service of process fee of $59.25, this motion’s filing fee
14 of $60.00, and this motion’s mailing cost of $1.42.
15

16 Dated: August 22, 2018 ACCIDENT, INJURY AND MEDICAL MALPRACTICE
ATTORNEYS OF CALIFORNIA, APC

4
17

Jeffrey D. Bohn, Esq.
19
Attorneys for Plaintiff
20

2.21

Memorandum of Points and Authorities in Support of
Motion to Recover Costs of Personal Service
DECLARATION OF JEFFREY D. BOHN
I, Jeffrey D. Bohn, declare:

1 I am a licensed attorney in the State of California and counsel of record for Plaintiffs
MICHAEL ANGELO SALCEDO, DAMIAN SALCEDO, MICHAEL ANGELO SALCEDO,
LEXANI SALCEDO, and JEANETTE ALVAREZ. I am familiar with the pleadings and
investigation of this case. I have personal knowledge of the facts set forth herein and, if
necessary, could and would competently testify thereto. As to those facts stated upon information|
and belief, I believe them to be true.

2. On June 19, 2017, I filed this action on behalf of Plaintiffs in connection with their
10 personal injuries sustained in an auto collision caused by Defendants’ negligence.
W 3. Based upon a Westlaw skip traced that I caused to be performed, and by cross-
12 referencing that information with the information on the traffic collision report prepared by law
13 enforcement, I am informed and belive that the residence address of Defendants Joe Cardoza and|
14 Betty Cardoza is 1034 E. Griffith Way, Fresno, California, 93704.
15 4. On July 20, 2018 I caused an attempt to serve Defendants Joe Cardoza and Betty Cardoza|
16 by first class mail, a copy of the summons and First Amended Complaint (“FAC”) in this action,
17 two copies of the Notice and Acknowledgment of Receipt of Summons forms and a self-
18 addressed, postage prepaid return envelope, at their residence at 1034 E. Griffith Way, Fresno,
19 California, 93704.
20 5. On July 20, 2018 I caused an attempt to serve Defendants Joe Cardoza and Betty Cardoza!
21 by certified mail, postage prepaid, return receipt requested, a copy of the summons and First
22 Amended Complaint (“FAC”) in this action, two copies of the Notice and Acknowledgment of
23 Receipt of Summons forms and a self-addressed, postage prepaid return envelope, at their
24 residence at 1034 E. Griffith Way, Fresno, California, 93704.
25 6. Using the certified mailing tracking numbers, I confirmed that the summons and FAC
26 mailed by certified mail were not claimed and were being returned to the sender. Attached hereto
27 as Exhibit 1 is a true and correct copy of the Certified Mail receipts and United States Postal
28 Service tracking status as to each Defendant.
1

Declaration of Jeffrey D. Bohn in Support of Motion
to Recover Costs of Personal Service
7 I did not receive from Defendants Joe Cardoza and Betty Cardoza the executed Notice
and Acknowledgment of Receipt within the period of twenty days after mailing.

8. In order to accomplish timely service, it was necessary for me to hire a process server to

personally serve Defendants Joe Cardoza and Betty Cardoza with another copy of the summons

and FAC at Plaintiffs’ expense.
9. Personal service on Defendant Joe Cardoza was accomplished on August 18, 2018 by
Eddings Attorney Service. Substitute service was made on Defendant Betty Cardoza on August

18, 2018 by Eddings Attorney Service. Attached hereto as Exhibit 2 are true and correct copies

of the proofs of service.
10 10. On August 20, 2018, Defendants Joe Cardoza and Betty Cardoza both answered the

11 FAC.
12 11. Plaintiffs were charged the total sum of $59.25, which I believe to be a reasonable
13 amount for the service, based on a decade of experience as an attorney. The filing fee for this
14 motion to recover the service of process fees is $60.00. Postage cost for service of this motion is
15 $1.42. Attached hereto as Exhibit 3 are true and correct copies of the invoices for service.
16 I declare under penalty of perjury under the laws of the State of California that the
17 foregoing is true and correct. Dated this 22nd day of August 2018.
18

20 By:
Jeffrey D. Bohn
221

22
2:

Declaration of Jeffrey D. Bohn in Support of Motion
to Recover Costs of Personal Service
10

28 Exhibit 1
3

Declaration of Jeffrey D. Bohn in Support of Motion
to Recover Costs of Personal Service
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28 Exhibit 2
4

Declaration of Jeffrey D. Bohn in Support of Motion
to Recover Costs of Personal ervice
POS:0'
‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State
Bar number, and address) FOR COURT
USE ONLY
JEFFREYD. BOHN, ESQ.
JEFFREY D. BOHN, ESQ.
2445 CAPITOL STREET, SUITE 105 FRESNO, CA 93721
‘TELEPHONE NO.: (559) 485-1212 | FAX NO. (559) 482-1210 | E-MAIL ADDRESS (Optional):
ATTORNEY FOR (Namo): Pisintiff Michael Angelo Salcedo, en individual

FRESNO COUNTY SUPERIOR COURT
sTReeT aopRess: 1130 “O" STREET
MAILING ADDRESS:
CITY AND zip CODE: FRESNO, CA 93721
BRANCH NAME: UNLIMITED
PLAINTIFF: Michael Angelo Salcedo, an individual CASE NUMBER:
DEFENDANT: Jce Ignacio Cardoza, Jr., an individual; et al 17CECG02063

Ret. No. oF Fie NO:
PROOF OF SERVICE OF SUMMONS 3593

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

. w Summons
Complaint
c.om Alternative Dispute Resolution (ADR) package
Civil Case Cover Sheet (served in complex cases only)
Cross-complaint
other: First Amended Complaint; Notice of Case Management Conference and Assignment of Judge For Ail Purposes;
Statement of Damages (Betty Cardoza / Marisol A. Jeanette Alvarez); Stateme! of Damages (Betty Cardoza /
Satcedo); Statement of Damages (Betty Cardoza / Damian Salcedo; et al); Statement of Damages (Betty Cardoza / Lexani
Salcedo; et al)
3. a. Party served:
Betty Cardoza, an individual

oO Person (other than the party in item 3a) served on behalf of an entity or as an authorized agent (and not a ee under
item 5b on whom substituted service was made) (specify name and relationship to the party named in
4. Address where the party was served: 1034 E Griffith Way
Fresno, CA 93704
5. | served the party
by personal service. | personally delivered the documents listed in item 2 to the party or person authorized to
teceive service of process for the party (1) on (date). (2) at (time).
bof by substituted service. On (date): 8/18/2018 at (time): 11:18 AM | left the documents listed in item 2 with or
in the presence of (name and titfe or relationship to person indicated in item 3b):
Joe Cardoza - Spouse
Age:
65 Race: Hispanic Sex: Male Height: 5-8 Weight: 160 Eyes: Hair: Gray

(1) C2 (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) w {home) a competent member of the houséhold (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) o (physical address unknown) a person at least 18 years of age apparently in charge at the usual malling
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) yw I 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). a declaration of mailing Is attached.
.
(©) tattacha declaration of diligence stating actions taken first to attempt personal service.
|
Pagoitof 2
Sea
POS-010 [Rev. Jamuary1, 2007] PROOF OF SERVICE OF SUMMONS
(Coda ef Civ Procedure,
§ 417.10
Posoto-vE2300%5
.
CASE NUMBER:
PETITIONER: Michael Angelo Salcedo, an individual
17CECG02063
RESPONDENT: Joe Ignacio Cardoza, Jr., an individual; et al

c. CJ 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):
a0 with two copies of the Notice and Acknowledgment of Receipt and a postage-paid retum envelope addressed to me.
(Attach completed Notice and Acknowledgement of Receipt.) (Code Civ. Proc., § 415.30.)
@O to an address outside California with return receipt requested. (Code Civ. Proc., § 415.40.)
aO by other means (specify means of service and authorizing code section):

oO Additional page describing service is attached.
The "Notice to the Person Served" (on the summons) was completed as follows:
al as an individual defendant.
60 as the person sued under the fictitious name of (specify):
«O as occupant.
a0 On behalf of (specify):
under the following Code of Civil Procedure section:
416.10 (corporation) QO 415.95 (business organization, form unknown)
Oo 416.20 (defunct corporation) QO 416.60 (minor)
Ol 416.30 (joint stock company/association) O 416.70 (ward or conservatee)
O 416.40 (association or partnership) 416.90 (authorized person)
OD 416.50 (public entity) 415.46 (occupant)
oO other:
Person who served papers
Name: Joe M. Zamilpa - Eddings Attorney Support Services, Inc.
Address: 1099 East Champlain Dr., Suite A-102 Fresno, CA 93720
Telephone number: (559) 222-2274
The fee for service was: $ 19.75
lam:

a)
a
not a registered California process server.
2) exempt from registration under Business and Professions Code section 22350(b).
(3) registered California process server:
i) owner employee om independent contractor.
(ii) Registration No.: $201710000017
(ii) County: Fresno

8. ow | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
or
9.10 1am a California sheriff or marshal and! certify that the foregoing is true and correct.

Date: 8/20/2018
Eddin. s Attorney Sup| ort Services, Inc.
te
1099 ‘ast Champlain
Fresno, CA 93720
oi
r., Suite A-102
(559) 222-2274
www.Eddings-Online.com

Joe M. Zamilpa
(NAME OF PERSON WHO SERVED PAPERS/SHERIFF OR MARSHAL) (SI (TURE)

POS-010 [Rev Januaty 1. 2007) Page 20f2
PROOF OF SERVICE OF SUMMONS
POS-01 ore230035
a
Eddings Attorney Support Services, Inc.
1099 East Champlain Dr., Suite A102
Fresno, CA 93720
Phone: (559) 222-2274 Fax: (559) 222-2348
ATTORNEY SERVICE www.Eddings-Online.com

Document Attach List
CLIENT: JEFFREY D. BOHN, ESQ.
CLIENT FILE #: 3693 DATE: August 20, 2018

SUBJECT: Betty Cardoza, an individual
SERVED: Joe Cardoza - Spouse

Summons; Alternative Dispute (ADR) package; First Amended Complaint; i
Notice of Case Management Conference and Assignment of Judge For All
Purposes; Statement of Damages (Betty Cardoza / Marisol A. Jeanette
Alvarez); Statement of Damages (Betty Cardoza / Michael Salcedo) ;
Statement of Damages (Betty Cardoza / Damian Salcedo; et al);
Statement of Damages (Betty Cardoza / Lexani Salcedo; et al);

Order: E230835D0CAH2010
‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stato Bar number, and adaress) * FOR COURT USE ONLY
L JEFFREY D. BOHN, ESQ.
JEFFREY D. BOHN, ESQ.
2445 CAPITOL STREET, SUITE 105 FRESNO, CA 93721
TELEPHONE NO (559) 485-1212 | FAX NO. (558) 482-1210 | E-MAIL ADDRESS (Optonal}
ATTORNEY FOR (Namo): Plaintitt: Michael Angelo Saicedo, an individual

FRESNO COUNTY SUPERIOR COURT
street appress 1130 "O" STREET
MAILING ADDRESS
CITY ano zip cope: FRESNO, CA 93721
BRANCH NAME: UNLIMITED
PLAINTIFF/PETITIONER: Michael Angelo Salcedo, an individual CASE NUMBER’
DEFENDANT/RESPONDENT: Joe Ignacio Cardoza, Jr., an individual; et al 17CECG02063

Ref, No. or File No.
DECLARATION OF DILIGENCE 3593

|, Joe M. Zamilpa , declare: | am a Registered Process Server and was retained to serve process in the above-referenced matter
on the following person or entity: Betty Cardoza, an individual as follows:
Documents:
See Documents on Attached List
| attempted personal service on the following dates and times with the following results:

Date Time Location Results
8/16/2018 4:45 PM Home No movement detected, No response at residence address - Joe M.
Zamilpa
1034 E Griffith Way, Fresno, CA 93704
8/17/2018 : 6:11 PM Home No response at residence address - Joe M. Zamilpa
1034 E Griffith Way, Fresno, CA 93704
8/18/2018 11:18 AM Home Substituted service on: Betty Cardoza, an individual; 1034 E Griffith
Way, Fresno, CA 93704; by serving: Joe Cardoza - Spouse, Hispanic
Male 65 150 Gray 5-8 .

Fee for Service: $ 19.75
County: Fresno
eS Registration No.: $201710000017 | declare under penalty of perjury that the foregoit is true
Eddings Attorney Support Services, Inc. and correct and that this declaration was executed on
1099 East Champlain Dr., Suite A-102 August 20, 2018.
Fresno, CA 93720
(559) 222-2274
Signature: J
Joe M. Zamil
|
AFFIDAVIT OF REASONABLE DILIGENCE
Order#: E230935
Attorney of Party wtnout Attomey ‘FOR COURT USE ONLY
JEFFREY D. BOHN, ESQ.
JEFFREY D. BOHN, ESQ.
2445 CAPITOL STREET, SUITE 105
FRESNO, CA 93721 MAIL ADDRESS (Optional)
TELEPHONE
No.: (559) 485-1212 FAX No. (Option) (559) 482-1210
Attomey for Plaintiff Michael Angelo Salcedo, an individual
Rat No. or Fila No.
3593
Insert name of Court, and Judicaal District and Branch Court
FRESNO COUNTY SUPERIOR COURT - UNLIMITED

Paint. Michael Angelo Salcedo, an individual
Defendant: Joe Ignacio Cardoza, Jr., an individual; et al

HEARING DATE: TIME: DEPT CASE NUMBER:
PROOF OF SERVICE 17CECG02063

4. | am over the age of 18 and not a party to this action. | am employed in the county where the mailing occured.

2. | served copies of the Summons; Alternative Dispute (ADR) package; First Amended Complaint; Notice of Case
Management Conference and Assignment of Judge For All Purposes; Statement of Damages (Betty Cardoza / Marisol A.
Jeanette Alvarez); Statement of Damages (Betty Cardoza / Michael Salcedo); Statement of Damages (Betty Cardozai/
Damian Salcedo; et al); Statement of Damages (Betty Cardoza / Lexani Salcedo; et al);

3. By placing a true copy thereof enclosed in a sealed envelope, with First Class postage thereon fully prepaid, in the United
States Mail at Fresno, California, addressed as follows:

a. Date of Mailing: August 20, 2018
b. Place of Mailing: Fresno, CA
c. Addressed as follows: Betty Cardoza, an individual
1034 E Griffith Way
Fresno, CA 93704

| am readily familiar with the firm's practice for collection and processing of documents for mailing. Under that practice, it
would be deposited within the United States Postal Service, on that same day, with postage thereon fully prepaid at Fresno,
California in the ordinary course of business.

Fee for Service: $ 19.75 | declare under penalty of perjury under the laws of
County: FRESNO the The State of California that the foregoing
Registration: S-238 information contained in the return of service and
woe Eddings Attorney Support Services, Inc. ‘statement of service fees is true and correct and that
1099 East Champlain Dr., Suite A-102 this declaration was executed on August 20, 2048
Fresno, CA 93720
(559) 222-2274
Ref: 3593
Signature:
JOSEPH CASSINERI MN

PROOF OF SERVICE BY MAIL
Order#: E230935/mailproof
Eddings Attorney Support Services, Inc.
1099 East Champlain Dr., Suite A-102
Fresno, CA 93720
Phone: (559) 222-2274 Fax: (559) 222-2348
Continued from Proof of Service
CLIENT: JEFFREY D. BOHN, ESQ.
CLIENT FILE #: 3593 DATE: August 20, 2018

SUBJECT: Betty Cardoza, an individual
SERVED: Joe Cardoza - Spouse

First Amended Complaint; Notice of Case Management Conference and
Assignment of Judge For All Purposes; Statement of Damages (Betty
Cardoza / Marisol A. Jeanette Alvarez); Statement of Damages (Betty
Cardoza / Michael Salcedo); Statement of Damages (Betty Cardoza /
Damian Salcedo; et al); Statement of Damages (Betty Cardoza / Lexani
Salcedo; et al)

Se
ATTORNEY SERVICE

Eddings Attorney Support Services, Inc. | 1099 East Champlain Dr., Suite A-102 | Fresno, CA 93720 | (559) 222-2274
ain
‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Noma, Stata Bar number, and address) ‘FOR COURT
USE ONLY
JEFFREY D. BOHN,
JEFFREY D. BOHN,
2445 CAPITOL STREET, SUITE 105 FRESNO, CA 93721
‘TELEPHONE NO.: (859) 485-1212 | FAX NO. (559) 482-1210 |E-MAIL ADDRESS (Optional):
ATTORNEYFOR (Name): Piaintif: Michael Angeto Salcedo, en individual

FRESNO COUNTY SUPERIOR COURT
STREET ADDRESS:
1130 "O" STREET
MAILING ADDRESS:
CITY AND zip cope: FRESNO, CA 93721
BRANCH NAME: UNLIMITED
PLAINTIFF: Michael Angelo Salcedo, an individual CASE NUMBER:
DEFENDANT: Joe Ignacio Cardoza, Jr., an individual; et al 17CECG02063

Ref. No. or Pile No:
PROOF OF SERVICE OF SUMMONS 3593

4. 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
Complaint
Alternative Dispute Resolution (ADR) package
Q Civil Case Cover Sheet (served in complex cases only)
Cross-complaint
f.to other: First Amended Complaint; Notice
of Case Conference and ere of Judge For All i
Statement of Damages (Joe Ignacio Cardoza/ Marisol A. Jeanette Al of Damages (Joe a pain Gerdoza Jr i
1 Michael Salcedo); Statement of Damages (Joe Ignacio Cardoza Jr. i Damian Satcedo; et al); Statement of (Joe
Ignacto Cardoza Jr. / Lexani Salcedo; et al}
3. a. Party served:
Joe Ignacio Cardoza, Jr., an individual
Age: 65 Race: Hispanic Sex: Mate Height: 5-8 Weight: 150 Eyes: Hair: Gray

.O Person (other than the party in item 3a) served on behalf of an entity or as an authorized agent (and nota 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: 1034 E Griffith Way
Fresno, CA 93704
5. I ser the party
by personal service. 1 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): 8/18/2018 (2) at (time): 11:20 AM.
b.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):
yi
(1) oO (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.
@O (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.
@O (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

Case Info

Judge

McGuire, Rosemary Track Judge’s New Case

Case No.

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Document Filed Date

August 22, 2018

Case Filing Date

June 19, 2017

County

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Motion,Ex Parte: Salcedo et al. v. Cardoza et al.

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