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Tiffany T. Chung (SBN 275981)
LAW OFFICES 0F TIFFANY CHUNG copsmo .
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800 w. 6th Street, Suite 800
Los Angeles, CA 9001 7
230w Couge
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Tel; 3 10—363—0327 0W0 Eygoflt-
Fax: 888-402-2078 ”'3?
AUG 0 7
E ma1'1; t'ffanyCc
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8y 2023
Attorneys for MARLON SIMS MCQEO.
Plaintiff,
I
iEH, '\
DEPUTY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 FOR THE COUNTY OF SAN BERNARDINO
ll
MARLON SIMS, an individual; CASE NO: C1v332301210
13 Pla'm‘ff‘
DECLARATION RE: DUE DILIGENCE
14 PURSUANT To CCP §§415.10-415.50
VS-
AND DECLARATION IN SUPPORT 0F
15 APPLICATION AND ORDER FOR
MANOJ CHIB, an individual; AAYAN PUBLICATION
16
CARGO, INC., a California Corporation; and
DOES through 20, inclusive,
l
17
Defendants'
Complaint Filed: JANUARY 5, 2023
18
19
20 I, TIFFANY T. CHUNG, declare as follows:
21 l. I am an attorney at law duly admitted to practice before this court. I am one ofthe attorneys
22 0f record for Plaintiff named herein. If called as a witness, I could and would competently testify to
23 the facts which support and pertain to this declaration.
24 2. The defendants are Manoj Chib. an individual and Aayan Cargo, Inc., a business located in
25 San Bemardino County. Defendant Aayan Cargo Inc.. was personally served on March 22, 2023.
26 No answer has been filed and no communication has been received from Defendant Aayan Cargo
27 Inc. On May 31, 2023, Plaintiff filed a request for entry 0f default against Defendant Aayan Cargo
28 Inc.
I
DECLARATION RE: DUE DILIGENCE
3. Defendant, Manoj Chib was thc driver involved in the trucking accident on January 24, 2021
that caused significant injuries to Plaintiff. It is bclicvcd that Defendant, Manoj Chib was working at
the time ofthe incident and employed by Aayan Cargo, Inc. Plaintiff brings this application
requesting service by publication for Defendant, Manoj Chib.
4. The address listed 0n the traffic collision report and Defendant Chib’s driver’s license is
2301 W. Belmont Avenue. Fresno. California. Given this initial information, Plaintiff‘s counsel
filed an action in the County 0f Fresno, California. During the attempts for service in the Fresno
action, it bccamc clear that Defendant Chib was no longer residing in the Fresno area. Multiple
attempts for service were made at this address and were unsuccessful. (See Ex. “A”)
10 5. A background search then revealed two addresses in San Bernardino County. One at 14520
11 Village Dr, Apt 1 l 1 Fontana, CA 92337-0198 and another at 1 186 Chestnut Ln. Apt 202 Corona,
12 CA 92881-6438, both of which arc near Defendant Aayan Cargo’s office in San chardino County.
13 6. On December 20, 2022 attempted service was madc to thc address in Corona, California and
14 was unsuccessful. (See Ex. “8“)
15 7. Further research was found that Defendant Chib created a California corporation, “Chib
16 Transport Inc” on September 16, 2022 with its principal address located at the Fontana address. (See
Ex. “C")
l8 8. Thereafter, Plaintiff‘s counsel dismissed thc Fresno County case, and filed this instant action
l9 in San Bemardino County as it appeared t0 be the proper venue for defendants. It must be noted that
20 Defendant Aayan Cargo, Inc., never answered the Fresno case even after having been properly
21 served.
22 9. After the filing 0fthe instant Summons and Complaint. service 0n Defendant Chib was
23 attempted at the address in Fontana and Plaintiff‘s counsel was informed that Defendant Chib n0
24 longer resides there. (See Ex. “D”)
25 10. In the same background search another address: 12007 103rd Ave # 1, South Richmond Hill
26 NY, 1 1419-2125 was found. Another attempt for service was made at this address and was also
27 unsuccessful. (See Ex. “E”)
28 I l. Currently, Defendant. Aayan Cargo refuses t0 answer the complaint and is in default.
2
DECLARATION RE. DUE [)lLKiENCE
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\a V Tiffany T. Chung (SBN 275981) LAW OFFICES 0F TIFFANY CHUNG copsmo . l. 800 w. 6th Street, Suite 800 Los Angeles, CA 9001 7 230w Couge ”espoflfqga~ga,, Tel; 3 10—363—0327 0W0 Eygoflt- Fax: 888-402-2078 ”'3? AUG 0 7 E ma1'1; t'ffanyCc a), h ung 1 ega 1. com I 8y 2023 Attorneys for MARLON SIMS MCQEO. Plaintiff, I iEH, '\ DEPUTY SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN BERNARDINO ll MARLON SIMS, an individual; CASE NO: C1v332301210 13 Pla'm‘ff‘ DECLARATION RE: DUE DILIGENCE 14 PURSUANT To CCP §§415.10-415.50 VS- AND DECLARATION IN SUPPORT 0F 15 APPLICATION AND ORDER FOR MANOJ CHIB, an individual; AAYAN PUBLICATION 16 CARGO, INC., a California Corporation; and DOES through 20, inclusive, l 17 Defendants' Complaint Filed: JANUARY 5, 2023 18 19 20 I, TIFFANY T. CHUNG, declare as follows: 21 l. I am an attorney at law duly admitted to practice before this court. I am one ofthe attorneys 22 0f record for Plaintiff named herein. If called as a witness, I could and would competently testify to 23 the facts which support and pertain to this declaration. 24 2. The defendants are Manoj Chib. an individual and Aayan Cargo, Inc., a business located in 25 San Bemardino County. Defendant Aayan Cargo Inc.. was personally served on March 22, 2023. 26 No answer has been filed and no communication has been received from Defendant Aayan Cargo 27 Inc. On May 31, 2023, Plaintiff filed a request for entry 0f default against Defendant Aayan Cargo 28 Inc. I DECLARATION RE: DUE DILIGENCE 3. Defendant, Manoj Chib was thc driver involved in the trucking accident on January 24, 2021 that caused significant injuries to Plaintiff. It is bclicvcd that Defendant, Manoj Chib was working at the time ofthe incident and employed by Aayan Cargo, Inc. Plaintiff brings this application requesting service by publication for Defendant, Manoj Chib. 4. The address listed 0n the traffic collision report and Defendant Chib’s driver’s license is 2301 W. Belmont Avenue. Fresno. California. Given this initial information, Plaintiff‘s counsel filed an action in the County 0f Fresno, California. During the attempts for service in the Fresno action, it bccamc clear that Defendant Chib was no longer residing in the Fresno area. Multiple attempts for service were made at this address and were unsuccessful. (See Ex. “A”) 10 5. A background search then revealed two addresses in San Bernardino County. One at 14520 11 Village Dr, Apt 1 l 1 Fontana, CA 92337-0198 and another at 1 186 Chestnut Ln. Apt 202 Corona, 12 CA 92881-6438, both of which arc near Defendant Aayan Cargo’s office in San chardino County. 13 6. On December 20, 2022 attempted service was madc to thc address in Corona, California and 14 was unsuccessful. (See Ex. “8“) 15 7. Further research was found that Defendant Chib created a California corporation, “Chib 16 Transport Inc” on September 16, 2022 with its principal address located at the Fontana address. (See Ex. “C") l8 8. Thereafter, Plaintiff‘s counsel dismissed thc Fresno County case, and filed this instant action l9 in San Bemardino County as it appeared t0 be the proper venue for defendants. It must be noted that 20 Defendant Aayan Cargo, Inc., never answered the Fresno case even after having been properly 21 served. 22 9. After the filing 0fthe instant Summons and Complaint. service 0n Defendant Chib was 23 attempted at the address in Fontana and Plaintiff‘s counsel was informed that Defendant Chib n0 24 longer resides there. (See Ex. “D”) 25 10. In the same background search another address: 12007 103rd Ave # 1, South Richmond Hill 26 NY, 1 1419-2125 was found. Another attempt for service was made at this address and was also 27 unsuccessful. (See Ex. “E”) 28 I l. Currently, Defendant. Aayan Cargo refuses t0 answer the complaint and is in default. 2 DECLARATION RE. DUE [)lLKiENCE