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WILLIAM C. LAST, JR. (SBN 83588)
PATRICK J. WHITEHORN (SBN 225927)
LAST & FAORO
$20 South El Camino Real, Suite 430
San Mateo, California 94402 FILED _-
Telephone: (650) 696-8350
‘accimile: 5 J 5 Superior Court of California,
Facsimile: (650) 696-8365 Couniy of SamPrancteso
11/28/2017
. Clerk of the Court
Attorneys for Gregory Fishman. BY:JEFFREY LEE
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR SAN FRANCISCO COUNTY
UNLIMITED JURISDICTION
GREGORY FISHMAN Case No.: CGC-17-557162
Plaintiff DECLARATION OF PATRICK J.
WHITEHORN IN RESPONSE TO ORDER
é TO SHOW CAUSE
vs.
CAMBRIDGE STAFFING SOLUTIONS, LLC., a
California limited liability company; ALEX SINO,
an Individual and manager of Cambridge Staffing
Solutions, LLC; LIDIA KIRITCHENKO, an
Individual and manager of Cambridge Staffing
Solutions, LLC; and DOES 1 through 50,
inclusive,
Defendants.
1, Patrick J. Whitehorn, in response to the Order to Show Cause Re: Dismissal, state and declare
as follows:
Ll. I have been a member in good standing of the State Bar of California since 2003, and I
am an associate in the law firm of Last & Faoro, counsel for Plaintiff Gregory Fishman. The following
facts are within my personal knowledge and, if called as a witness herein, 1 can and will competently
testify thereto.
I
Declaration of Patrick J. Whitehorn In Response to Order to Show Cause2. On February 17, 2017, 1 caused to be filed, on behalf of Plaintiff, a complaint against
Cambridge Staffing Solutions, LLC; and Alex Sino. That complaint sought to enforce Plaintiff's rights
as a member of Cambridge Staffing Solutions, LLC to access to financial and tax records of the
company, for breach of the Obligation of Good Faith and Fair Dealing, and for an Accounting.
Documents were provided to Plaintiff by Defendants, which partially resolved the claims in the lawsuit
while simultancously raising additional claims and causes of action against Defendants Cambridge
Staffing Solutions, LLC; and Alex Sino as well as Lidia Kiritchenko.
3. On June 28, 2017, I caused to be filed, on behalf of Plaintiff, a First Amended
Compiaint against Cambridge Staffing Solutions, LLC; Alex Sino; and Lidia Kiritchenko. This
Amended Complaint removes the cause of action for failure to provide corporate records, and adds new
causes of action against Cambridge Staffing Solutions, LLC; and Alex Sino; and adds Lidia
Kiritchenko as a defendant.
4, On July 10, 2017 I sent a Notices and Acknowledgements of Receipt to counsel for
Cambridge Staffing Solutions for each of the defendants. True and Correct copies of the Notice and
Acknowledgement of Receipt for Cambridge Staffing Solutions, LLC; Alex Sino; and Lidia
Kiritchenko are attached hereto as Exhibits “A,” “B,” and “C” respectively.
5. I have not received signed copies of the Notices and Acknowledgements of Receipt
from counsel for Cambridge Staffing Solutions. Having not received signed Notices and
Acknowledgements of Receipt, I have sent the First Amended Complaint to D&T Legal Services to be
served on the Defendants.
6. Defendant Alex Sino was served by Substitute Service on November 3, 2017. The Proof
of Service of Summons for Defendant Sino was filed on November 17, 2017. A true and correct copy
of the file-endorsed proof of service is attached as Exhibit “D.” According to the Affidavit of
Reasonable Diligence attached to the Proof of Service, D&T Legal Services made four attempts at
service prior to gaining access to serve Defendant Sino.
7. A true and correct copy of the file-endorsed Affidavit of Reasonable Diligence for
service on Lidia Kiritchenko as Manager of Cambridge Staffing Solutions and as an Individual is
attached as Exhibit “E.” D&T Legal Services has made five attempts at serving Lidia Kiritchenko.
2
Declaration of Patrick J. Whitehorn In Response to Order to Show Cause —ww
oD wm NI KD OH he
The process server has been informed by the Concierge at the Kiritchenko residence that Defendant
Kiritchenko is a full-time occupant of the building, but that she is out of town. Plaintiff is stiil
attempting to serve Defendant Kiritchenko in both her individual capacity and on behalf of Defendant
Cambridge Staffing Solutions.
8. As Defendant Sino was served by Substitute Service on November 3, 2017, his Answer
is due on December 13, 2017.
9. As Defendant Sino’s Answer is not due until December 13, 2017, and Plaintiff's process
server is still attempting service on the other defendants, the undersigned respectfully requests that the
court continue the Order to Show Cause without dismissing the action for a period of 60 days to allow
for Defendant Sino’s Answer to be filed or his default taken, and for continued attempts at service on
Defendants Kiritchenko and Cambridge Staffing Solutions. Plaintiff's counsel appreciates the courtesy
extended by the Court.
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct to the best of my knowledge, information and belief.
Executed this 28"" day of November, 2017, at San Mateo, California.
lorneys for Gregory Fishman
3
Declaration of Patrick J. Whitehorn In Response to Order to Show CauseEXHIBIT APOS-015
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stato Bar number and FOR COURT USE ONLY
William C. Last. Jr. (083588) Patrick J. Whitehorn (225927)
LAST & FAORO.
520 S. El Camino Real, Ste 430
San Mateo. CA 94402
tetePHoNe No (650) 696-8350 Faxno iOmmnar (650) 696-8365
E-+WAN ADDRESS /Optona))
arronvey FoR imaro). Gregory Fishman, Plaintiff.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
STAEET ADDRESS. 40 McAllister Street
MAILING ADDRESS
crvanozP COPE San Francisco 94102
SrANcUNAYE Civic Center Courthouse
PLAINTIFFIPETITIONER: Gregory Fishman
DEFENDANTIRESPONDENT: Cambridge Staffing Solutions, LLC, et al.
CASE NUMBER
NOTICE AND ACKNOWLEDGMENT OF RECEIPT—CIVIL CGC-17-557162
TO (insert name of party being served): Cambridge Staffing Solutions. LLC. a California limited liability company
NOTICE
The summons and other documents identified below are being served pursuant to section 415.30 of the California Code of Civil
Procedure. Your failure to complete this form and return it within 20 days from the date of mailing shown below may subject you
(or the party on whose behalf you are being served) te llabilily for the payment of any expenses incurred in serving a summons
‘on you in any other manner penmitied by law.
Ifyou are being served on behalf of a corporation, an unincorporated association (including a partnership), or olher entity, this,
form must be signed by you In the name of such entity or by a person authorized lo receive service of process on behalf of such
entity. In all other cases, this form must be signed by you personally or by a person authorized by you to acknowledge receipt of
summons. if you relum this form to the sender, service of a summons is deemed complete on the day you sign the
acknowledgment of receipt below, Z
Date of mailing: July 10, 2017
Patrick J. Whitehorn od fe
(PYPE OR PRINT NAME} Lo IN THIS CASE)
ACKNOWLEDGMENT OFARECEIPT
‘This acknowledges receipl of (to be completed by sender before mailing):
1 Ci A copy of the summons and of the complaint.
2, CE]. Other (specify):
Summons First Amended Complaint; First Amended Complaint; Case Management Order dated
July 3, 2017 Continuing Case Management Conference; SF ADR Program Information Package;
Judicial Mediation Program; Expedited Jury Trial Information Sheet; Blank form Stipulation to
ADR; Blank form Case Management Statement; Early Settlement Program flyer
(To be completed ay recipient):
Date this form is signed:
TF¥PE OR PRINT YOUR RARE AND AME OF ENTITY FAW Ao EE OF SOY ACIDIOUM EDGE RECERT VETTE
Page tof
For Nate eee NOTICE AND ACKNOWLEDGMENT OF RECEIPT — CIVIL sae LOR aD
POSOIS (Row January + 2005] seme courtinia c@ acy
Lexisherisk duiomated Calformus Jadiclit Counett Forms,EXHIBIT BPOS-015
[ATTORNEY OR PARTY WITHOUT ATTORNEY (Wome State for rumber and edim3s) FOR COURT USE ONLY
|_William C. Last, Jr, (083588) Patrick J. Whitehorn (225927)
LAST & FAORO
520 S. E] Camino Real, Ste 430
San Mateo. CA 94402
velzrHonewo (650) 696-8350 Faxtia (optenas (650) 696-8365
Estat ADORESS (Qpeanan
ATTORNEY FOR ome) Grepory Fishman, Plaintiff
‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
Streer aporess 400 McAllister Street
MAILING ADDRESS
cee nines San Francisco. 94102
Civic Center Courthouse
PLAINTIFFPETITIONER Gregory Fishman
DEFENDANTRESPONDENT Cambridge Staffing Solutions, LLC. et al.
CASE NUMBER
NOTICE AND ACKNOWLEDGMENT OF RECEIPT—CIVIL CGC+17-557162
TO (insert name of party being served): Alex Sino. an Individual and manager of Cambridge Staffing Solutions. LLC
NOTICE
The summons and other documents identified below are being served pursuant to section 415.30 of the Califomia Code of Civil
Procedure. Your failure to complete this form and return il within 20 days from the date of mailing shown below may subject you
{or the party on whose behalf you are being served) to Ilability for the payment of any expenses incurred in serving a summons
‘on you in any other manner permitted by law.
if you are being served on behalf of a corporation, an unincorporated association {including a partnership), or other entity, this
farm must be signed by you in the name of such enlity or by a person authorized to receive service of process on behalf of such
entity. in ali other cases, this form must be signed by you personally or by 4 person authorized by you to acknowledge receipt of
summans. If you return this form te the sender, service of a summons is deemed complete on the day you sign the
acknowledgment of receipt below.
Date af mailing: July 10, 2017
Patrick J. Whitehom
TYPE OR PRINT MANE
‘This acknowledges receipt of (ta be completed by sender before
1. 1 Acopy of the summons and of the complaint.
2: Olher (specify)
Summons First Amended Complaint; First Amended Complaint; Case Management Order dated
July 3, 2017 Continuing. Case Management Conference; SF ADR Program Information Package;
Judicial Mediation Program; Expedited Jury Trial Information Sheet; Blank form Stipulation to
ADR; Blank form Case Management Statement; Early Settlement Program flyer
{To be completed by recipient):
Date this form is signed
TYPE OW PRINT YOUR NAKEE Alb NAME OF LITOTY 1° ANY
“(SIGNATURE OF PERSON ACKNOWL EOGWG RECEIPT vaTH TITLE IF
(ON WHOSE BEHALF THIS FORM IS SIGNED) ACKNOWLEDGMENT IS MADE ON BEHALF OF ANOTHER PERSON OR ENTITY?
Page vel
Fe iCatete NOTICE AND ACKNOWLEDGMENT OF RECEIPT — CIVIL ote ase a
POS-O15 [Rov Jamusty 5 2005}
enw courinlo ca pov
Lex News Automated Calforma Suchicial Coumed FormsEXHIBIT CPOS-015
ATTORNEY OR PARTY WITHOUT ATTORNEY (Nama, Stale Gar number FOR COURT USE ONLY
|_William C. Last, Jr. (083588) Patrick J. Whitehorn (2: 25927)
| LAST & FAORO
520 §. El Camino Real, Ste 430
San Mateo, CA 94402
erepone no. (650) 696-8350. FAXNO (Opterst, (650) 696-8365
E-MAN, ADDRESS {Qpeona)
arronney FOR Memo) Gregory Fishman, Plaintiff’
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
Syaeey anone®s 400 McAllister Street
MAILING ADDRESS
CITY Ano ZiP CODE,
San Francisco 94102
BRACKMANE Civic Center Courthouse
PLAINTIFF/PETITIONER Gregory Fishman
DEFENDANTIRESPONDENT Cambridge Staffing Solutions, LLC. et al.
‘CASE HUMBER
NOTICE AND ACKNOWLEDGMENT OF RECEIPT—CIVIL CGC-17-557162
TO (insert name of party being served}: Lidia Kiritchenko, an Individual and manager of Cambridge Staffing Solutions. LLC
NOTICE
The suramons and other documents identified below are being served pursuant to section 415.30 of the California Cada of Civ
Procedure. Your failure to complete this form and return it within 20 days from the date of mailing shown below may subject you
(or the party on whose behalf you are being served) to liabilily for the payment of any expenses incurred In serving a summons
on you in any other manner permitted by law.
if you are being served on behalf of a corporation, an unincorporated association (including 2 parinership), or other antity, this
form must be signed by you in the name of such entity or by a person authorized (o receive service of process on behalf of such
entity. In all other cases. this form must be signed by you personally or by a person authorized by you to acknowledge receipt of
summons. If you retum this form te the sender, service of a summons is deemed complete on the day you siggy he
acknowledgment of receipt below.
Date of mailing: July 10. 2017
Patrick J. Whitehom
(TYPE OR PRINT NAME)
ACKNOWLEDGMENT OF RECEIPT
This acknowledges receipl of (to be complated by sender before mailing)
4. [2] A copy of the summons and of the complaint,
2, CX] Other (specify):
Summons First Amended Complaint: First Amended Complaint; Case Management Order dated
July 3, 2017 Continuing Case Management Conference; SF ADR Program Information Package;
Judicial Mediation Program; Expedited Jury Trial Information Sheet; Blank form Stipulation to
ADR; Blank form Case Management Statement; Early Settlement Program flyer
{To be completed by recipient):
Date this form is signed:
(HVPE OA PA fi YOUR NAME AND NAME OF ENTITY ARV. ATURE OF PERSON ACO EDGING RECEIPT WATH TIRE
ON WHOSE BEHALF THIS FORMS SGHED} ‘ACEI WS MADE ON BEHALF OF PERSON OR ENTITY)
Poge tof}
Fare Rapaadtor andar Uae NOTICE AND ACKNOWLEDGMENT OF RECEIPT — CIVIL Camera roceaes
POS .A15 [Rev Jaruary 12005) voew cocrbala ca gow
Letts Weta dtomnated Calffarma Judketal Counce ForiisEXHIBIT Daitarty oF Faxiy withoad aorep
‘WILLIAM C LAST, JR, Bar #82588
Fee Ceaet Use Only
a ELECTRON
$20 5 EL CAMINO REAL, ONICALLY
SUETE 430 FILED
SAN MATEO, CA 94402 Superior Court of Califor:
Fetephusne No: 630-496-8330 County of San Francisco!
[ietRew Res
11/17/2017
Clerk of the Court]
BY:-EDWARD SANTOS
Deputy Clark
PAX Ke; 630-696-8365
aucraey for: Piaintitt
frvars name of Conry, ond Aafctal Dikweiet aad Branch Comet:
SAN FRANCISCO COUNTY SUPERIOR. COURT.
Peiedsf GREGORY FISHMAN
. CAMRIDGE STAFFING SOLUTIONS. LLC. ct al.
PROOF OF SERVICE |iieorteg Dawe: [Taree IDepyDie: Brewer:
SUMMONS AND AMENDED CGC-17-5571862,
7, At the time of service Lwas ot least 18 years of age and not a party to t's action.
2. xerved copies of de SUMMONS AND AMENDED COMPLAINT ORDER CONTINUING CASE MANAGEMENT
CONFERENCE, ADR PROGRAM INFORMATION PACKAGE.
5, a. Pary served: ALEX SIMO, an individual and manager of Combeldge Staffing Solutlons, LLC
4. Addéress where the paryy was served: ‘724. NERTH DR
BOCA RATON, FE 33487
3S. } served the party:
bby substifuted service. On: Fri, Nov. 03, 2017 at: 6:36PM by keaving the caples with or in the presence of
MRS. SINO, CO-OCCUPANT
2) tHlomeyComperot Member of the Household aver 18, 1 fafermed bim or her of the general nature of the paptrt,
@)-A desleration of mailing fe attached,
(5) tanach.a declaration of diligence stating actions taken first to attempt personal service,
& Thm "Notice tothe Person Sarved (om the Summons) was completed as follaws;
‘e.g an individual defendant, and
on behalf oft ond manager of Cambridge Stalling Solutions, LLC
Under OCP 416.90 (authorized person)
2 Paxson Who Served Papers:
2. MICHAEL GONBOES
Recavereble Cost Fer CCP NS-St0X SKE
The Fee for Service was: $183.00
P.O, Box 8383 &. Lan (2) segitlered Celifomia process server
Walnut Grook, GA 94596 ( Indcpendent Contractor
4025) 947-1221 () Registration Ne: 19ED
fax (928) B47~1378 48 County: ‘OUT OF STATE
‘GNeein ee
8. 1 dectare under penalty of perjury under the laws of the State of California that the foregoing ts fene and correct
‘Pate: Tue, Nov. 07, WIT j 2 fo
subRQRE RAE RRERG a7
ond STEP SERRE Sao 2D[Attorney at Party withous Attorney.
WILLIAM C LAST, JR, Bar #83588
LAST & FAORO
$20 § EL CAMINO REAL,
SUITE 430
SAN MATEO, CA 94402
Telephone No. 630-696-8350
FAX: No: 650-696-8365
Far Court Uie Only
Ref No or File No:
|Avomney for: Plaintiff
insert name of Court, and Juchclal District and Branch Court-
SAN FRANCISCO COUNTY SUPERIOR COURT
Piaintiff’ GREGORY FISHMAN
Defendant. CAMRIDGE STAFFING SOLUTIONS, LLC, etal.
AFFIDAVIT OF Hearing Date Time: Depi/Div: [Case Number:
REASONABLE DILIGENCE CGC-17-557 162
1.1, MICHAEL. GONEDES, and any employee or independent contractors retained by D&T LEGAL SERVICES are and were on
the dates mentioned herein over the age of eighteen years and not a party to this action. Personal service was attempted on
Defendant ALEX SINO, an individual and manager of Cambridge Staffing Solutions, LLC as follows:
Documents:
SUMMONS AND AMENDED COMPLAINT ORDER CONTINUING CASE MANAGEMENT
CONFERENCE, ADR PROGRAM INFORMATION PACKAGE.
Day
Mon
Mon
Wed
Tho
Dai
10/30/17
100/17
HAA?
1/027
Page Number 1
Date: Tue, Nov. 07,2017
Time
12:00pm
9:13pm
8:38pm
7:59am,
Location
Home
Home
Home
Home
Results
THIS RESIDENCE IS A MANSION THAT {S GATED. PER A FEMALE
THROUGH THE INTERCOM, THE SUBJECT IS NOT HOME. Attempt made by:
MICHAEL GONEDES. Attempt at: 7241 NE 8TH DR. BOCA RATON, FL.
33487,
PER THE SAME FEMALE THROUGH THE INTERCOM, THE SUBJECT IS.
NOT HOME. SHE WILL NOT LET ME THROUGH THE GATE IF THE
SUBJECT IS NOT HOME. Attempt made by: MICHAEL. GONEDES. Atternpt at
7241 NE 8TH DR BOCA RATON, FL 33487,
NO ANSWER ON THE INTERCOM. LIGHTS ARE ALL ON INSIDE. Attempt
made by: MICHAEL GONEDES. Attempt at: 7241 NE 8TH DR BOCA RATON,
FL 33487.
NO ANSWER ON THE INTERCOM. NO CARS SEEN. Attempt made by:
MICHAEL GONEDES. Attempt at: 724] NE 8TH DR BOCA RATON, FL
33487.
Jastf, 78487
AFFIDAVIT OF REASONABLE DILIGENCE[asaayer Fargo tia
WILLIAM CLAST, JR, Bar #83588
LAST & FAORO
| 320 EL CAMINO REAL,
SUITE 430
SAN MATEO, CA 94402
LTeliphanr Sez 650-056-8350 FAA: Nia: 650-696-8365
Noor PeRaS
Accorency for: Plaine tt
rama 6f Cour’, ard Avdicial Dosvict cad Brarch Geir:
SAN FRANCISCO COUNTY SUPERIOR COURT
Pianig. GREGORY FISHMAN
locfndine CAMRIDGE STAFFING SOLUTIONS, LLC, ot ol.
AFFIDAVIT OF Hearing Desa Tae: DepeTie: [Cose Number:
REASONABLE DILIGENCE I CGC-17-557162
Day aie ih ‘Ceeation__ | Resutis
En Tas? 6:30pm Home ‘ABLE TO GAINENTRY, MRS. SING ADVISED THROUGH THE CLOSED
DOOR THAT SHE DID RESIDE HERE AND THAT ALEX WAS AWAY SOT
‘NEEDED TO GO. AWAY. TASKED MRS. SINO THAT SHE OPEN THE DOOR
‘AND ACCEPT SERVICE JN HAND SUT EHE REFUSED, 1 THEN READ OUT
LOUD IN A LOUD VOICE WAAT THE DOCUMENTS WHERE ABOUT.
‘THEN ANNOUNCED SERVICE AND DROP SERVED THE DOCUMENTS AT
‘THE DOOR, THERE WAS A SILVER MERCEDES LICE BAFC32 FRESENT,
“Adleenpt made by: MICHAEL GONRDRS. Aslempt at: 2241 NE RTH DR. BOCA
BATON, FL 33487.
Fai 1103/07 6:36pm Home Substituted Service on: ALEX SINO, an individual and manager of Cembsldge
Staffing Solutions, LLC Home - 724} NE STH DR BOCA RATON, FL 33487 by
Sorving: party in Item 3.0. Competent Member of the Houschald over 18 ty leaving
3 copy of the dacuavent(s) with: MRS, SIND, COOCCUPANT. Served by:
MICHAEL GONEDES
Tus LRIAT Matted eapy of Documents to: ALEX SINO, aa individual and mansger of
‘Cambridge Staffing Schtions, LLC
3. Person Execsting Hecoversble Coats Per COP ROSI-440}1018)
a. MICHAEL GONEDES & The Fee for service wax: $183.00
b, DQT LEGAL SERVICES e fom: (3) vegistered California process atrver
2i46N MAIN STREET, SUFTE A, Reglswation #792 {Independent Coatrector
P.O, Box 5383 Gi) Regtsranton Na: isto
WALNUT CREEK, CA 94596 Gig Counsy: OUT OF STATE
¢. (925) 947-1221, FAX (925) 947-1375
Dato: Tue, Nov. 07, 2017
‘4. Ldeoimre under penaity of pecury under the laws of tse State of Callforrita that the foregoing js te ee
Page Number 2
Aca. cOWEDED
asst 78887
AFFIDAVIT OR REASONASLE DILIGENCEAttorney or Party without Attorney
WILLIAM C LAST, JR, Bar #83588
LAST & FAORO
For Court Use Only
By Mail
520 S EL CAMINO REAL,
SUITE 430
SAN MATEO, CA 94402
Telephone No, 650-696-8350 FAX No: €50-696-8365
Ref No or Fide No.
\Atrorney for: Plaintilt
Riser? name of Courl, and Judicial Disivict and Branch Cover
SAN FRANCISCO COUNTY SUPERIOR COURT.
Plaintiff GREGORY FISHMAN
Defendam, CAMRIDGE STAFFING SOLUTIONS, LLC, et al.
PROOF OF SERVICE Hearing Date: Time. Depi/Div: Case Number:
CGC-17-557162
Lam over the age of 18 and not « party to this action. Tam employed in the county where the mailing occurred.
2. [served copies of the SUMMONS AND AMENDED COMPLAINT ORDER CONTINUING CASE MANAGEMENT
CONFERENCE, ADR PROGRAM INFORMATION PACKAGE.
3. By placing a true copy ofeach document in the United States mail, in a sealed envelope by First Class mail with postage prepaid
as follows:
a. Date of Mailin;
b. Place of Mail
Tue., Nov, 07,2017
WALNUT CREEK, CA 94596
c. Addressed as follows: ALEX SINO, an individual and manager of Cambridge Staffing Solutions, LLC
7241 NE 8TH DR
BOCA RATON, FL 33487
4. lam readily familiar with the business practice for collection and processing of correspondence as deposited with the U.S. Postal
Service on Tue., Nov. 07, 2017 in the ordinary course of business.
5. Person Serving:
Recoverable Cost Per CCP 1033.5(a)(4(B)
a. DAMON PULIDO d. | The Fee for Service was: . $183.00
b. D&T LEGAL SERVICES: ¢, Lam: (3) registered California process server
2146 N MAIN STREET, SUITE A, Registration # 792 (i) Independent Contractor
P.O. Box 5383 ii) RegistrationNo.: 849
WALNUT CREEK, CA 94596 (ii) County:
c. (925) 947-1221, FAX (925) 947-1375 (ti) Expiration Date: Fri, Oct.
Contra Costa
2019
& {declare under penalty of perjury under the laws of the State of California that the foregoing ts true and correct.
Date: Tue, Nov. 07, 2017 aT +,
a
Iudicial Council Form POS-010 PROOF. OF SERVICE
pe See eg taase t 2007 COR OFT
WAMON PULIDOS aay neaatEXHIBIT EAtearney oF Party wei Aerie t For Conti Use Ory
WILLIAM CLAST, JR, Bar #83588 !
LAST & FAORO.
520 S$ EL CAMINO REAL, ELECTRONICALLY
SUITE 430 ;
SAN MATEO, CA 94402 - e r L ED
650+ Fo: 650-696-8' uperior Court Fria,
Telephone No! 650-696-8350 FAX NO; 659-696-8365 mor NaereN reer or kan Pominee ia,
Astormay for: Paint 11/17/2017
Insert name of Court, and Judiceal District end Branch Courl Clerk of the Court
SAN FRANCISCD COUNTY SUPERIOR COURT. BY:MADONNA CARANTO
Piamrig: GREGORY FISHMAN Ocputy Stork
Dsfendent: CAMBRIDGE STAFFING SOLUTIONS, LLC. et al.
ANFIDAVIT OF tearag Dave: Time: DapitDie, Case Neenber:
REASONABLE DILVIENCE CGE-17-587162
1, FRANK TRUILLO, aud any employee or independent contractors retained by D&T LEGAL SERVICES are and were on the
dates mentioued herein over the age of eighteen years and nat a party to this action. Personal service was attempted on Defendant
LIDIA KIRITCHENKO, an individual and manager of Cambridge Staffing Solutions, LLC as follows:
2. Documents: SUMMONS AND AMENDED COMPLAINT ORDER CONTINUING CASE MANAGEMENT
CONFERENCE, ADR PROGRAM INFORMATION PACKAGE,
Day Date Time Location Results
Fr LORWIT 8.33pm Home NO ANSWER. PER THE CONCIERGE WHO CONFIRMED THE RESIDENCY
BUT STATED SHE COMES AND GOES. THEY HARDLY SEE TIER. Atempi
made by: FRANK TRUJILLO. Attempt at; 15901 COLLINS AVE APT 3807
Sunny Istes Beach, FL 33160.
Sac 10/28/17 10:30am. Home NO ANSWER. Anempt made by: FRANK TRUJILLO. Auempt at. 1590%
COLLINS AVE APT 3807. Sunny Isles Beach, FL 33160.
‘Te 1031/17 7:05am Home NO ANSWER. Atempt made by: FRANK TRUJILLO. Attempt at; 15901
COLLINS AVE APT 3807 Sunny Isles Beach, FL 33160.
Thao LA6NT 1120am Home NO ANSWER. PER THE MORNING CONCIERGE THE SUBJECT IS STILL
OUT OF TOWN. HE STATED HE KNOWS HER VERY WELI. AND SHE
HASNT COME BACK YET BECAUSE HE WOULD KNOW. HE WOULD SEE
TIER IN THE LOBBY OFTEN. HE THINKS SHE'S COMING BACK FOR
CHRISTMAS. HE ALSO STATED THEY ARE NOT SEASONAL OWNERS,
THEY LIVE HERE. Attempt made by: FRANK TRUJILLO, Registration
#CPS#1284 OUT OF STATE County, Attempt at; 15901 COLLINS AVE APT
3807 Sunny Isles Beach, FL. 33160.
Page Number 1
Date: Fri, Nov. $7, 2017 fost. 78483
AFFIDAVIT OF REASONABLE DILIGENCEitirmey or Party walkout Aitarney Par Court Use Oni
WILLIAM C LAST, JR, Bar #83588.
LAST & FAORO
$20 S EL CAMINO REAL,
SUITE 430
SAN MATEO, CA 94402
Telephone Na: 650-696-8350 FAX Ke, 650-696-8365
i Na ar PIE TS.
Attorney for Plaintift
Foert name of Court. and Judicial District oud ranch Court
SAN FRANCISCO COUNTY SUPERIOR COURT.
Planng GREGORY FISHMAN
Defendant CAMRIDGE STAFFING SOLUTIONS, LLC, et al.
AFFIDAVIT OF |Aearing Date: Tiare: Dep Div: Case Neonbvr
REASONABLE DILIGENCE CGC-17-S57162
(Day Date. Time [| Location | Results }
Fn HATAT 10:00am Home Recurmed Not Served on: LIDIA KIRITCHENKO, an individual and manager of
Cambridge Staffing Solutions, LLC Home - 5901 COLLINS AVE APT 3807
Sunny Isles Beach, FL 33160
3. Person Exeeuting ‘Recoverable Costs Per CCP 1033.5(u}(4)(R)
a, FRANK TRUHLLO a. The Fee far service was: $170.00
b. D&T LEGAL SERVICES e. fam: (3) registered California process server
2146 N MAIN STREET, SUITE A, Registration # 792 (} Independent Contractor
P.O. Box 5383 Registration No: ces41284
WALNUT CREEK, CA 94596 County: OUT OF STATE,
©. (925) 947-1221, FAX (925) 9AF-1375
4. I declare under penalty of perjury under the laws of the State of California that the foregoing is nd correct
Date: Fri, Nov. 17,2017 (Dy
Page Number 2
{FRANK TRONLEO)
Angi 78483
AFFIDAVIT OF REASONABLE DILIGENCEoD mI NH Fe YY =
noo
13
PROOF OF SERVICE
I, the undersigned, declare that 1 am employed in the City and County of San Mateo,
California. 1am over the age of eighteen years and not a party to the within action. My business address
is 520 S. El Camino Real, Ste 430, San Mateo, California 94402.
On the indicated below, I served the within document(s), entitled:
DECLARATION OF PATRICK J. WHITEHORN IN RESPONSE
TO ORDER TO SHOW CAUSE
on each party(ies) addressed as follows:
XXX
0 BY MAIL: by placing a true copy of each document listed above in a sealed envelope
addressed to the parties listed above and depositing it with the U.S. Postal Service on the date
shown below.
oO BY HAND: I caused each such envelope to be delivered by hand to the addressee(s) listed
above via same day messenger service.
o BY E-MAIL: I caused a true copy to be transmitted via e-mail to the addressee(s) listed above
at the e-mail noted after the party’s address.
0 BY OVERNIGHT DELIVERY: by delivering each document to an authorized courier
authorized by the express service carrier to receive documents in an envelope designated by
the express service carrier with delivery fees prepaid or provided for and addressed as above-
shown.
0 BY FACSIMILE: I caused a true copy to be transmitted via facsimile to the addressee(s)
listed above at the Fax number noted after the party’s address.
I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct.
Executed on November 28, 2017
TAL Chrarne
Lynne Casanova
Proof of Service
Preview
WILLIAM C. LAST, JR. (SBN 83588) PATRICK J. WHITEHORN (SBN 225927) LAST & FAORO $20 South El Camino Real, Suite 430 San Mateo, California 94402 FILED _- Telephone: (650) 696-8350 ‘accimile: 5 J 5 Superior Court of California, Facsimile: (650) 696-8365 Couniy of SamPrancteso 11/28/2017 . Clerk of the Court Attorneys for Gregory Fishman. BY:JEFFREY LEE Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR SAN FRANCISCO COUNTY UNLIMITED JURISDICTION GREGORY FISHMAN Case No.: CGC-17-557162 Plaintiff DECLARATION OF PATRICK J. WHITEHORN IN RESPONSE TO ORDER é TO SHOW CAUSE vs. CAMBRIDGE STAFFING SOLUTIONS, LLC., a California limited liability company; ALEX SINO, an Individual and manager of Cambridge Staffing Solutions, LLC; LIDIA KIRITCHENKO, an Individual and manager of Cambridge Staffing Solutions, LLC; and DOES 1 through 50, inclusive, Defendants. 1, Patrick J. Whitehorn, in response to the Order to Show Cause Re: Dismissal, state and declare as follows: Ll. I have been a member in good standing of the State Bar of California since 2003, and I am an associate in the law firm of Last & Faoro, counsel for Plaintiff Gregory Fishman. The following facts are within my personal knowledge and, if called as a witness herein, 1 can and will competently testify thereto. I Declaration of Patrick J. Whitehorn In Response to Order to Show Cause2. On February 17, 2017, 1 caused to be filed, on behalf of Plaintiff, a complaint against Cambridge Staffing Solutions, LLC; and Alex Sino. That complaint sought to enforce Plaintiff's rights as a member of Cambridge Staffing Solutions, LLC to access to financial and tax records of the company, for breach of the Obligation of Good Faith and Fair Dealing, and for an Accounting. Documents were provided to Plaintiff by Defendants, which partially resolved the claims in the lawsuit while simultancously raising additional claims and causes of action against Defendants Cambridge Staffing Solutions, LLC; and Alex Sino as well as Lidia Kiritchenko. 3. On June 28, 2017, I caused to be filed, on behalf of Plaintiff, a First Amended Compiaint against Cambridge Staffing Solutions, LLC; Alex Sino; and Lidia Kiritchenko. This Amended Complaint removes the cause of action for failure to provide corporate records, and adds new causes of action against Cambridge Staffing Solutions, LLC; and Alex Sino; and adds Lidia Kiritchenko as a defendant. 4, On July 10, 2017 I sent a Notices and Acknowledgements of Receipt to counsel for Cambridge Staffing Solutions for each of the defendants. True and Correct copies of the Notice and Acknowledgement of Receipt for Cambridge Staffing Solutions, LLC; Alex Sino; and Lidia Kiritchenko are attached hereto as Exhibits “A,” “B,” and “C” respectively. 5. I have not received signed copies of the Notices and Acknowledgements of Receipt from counsel for Cambridge Staffing Solutions. Having not received signed Notices and Acknowledgements of Receipt, I have sent the First Amended Complaint to D&T Legal Services to be served on the Defendants. 6. Defendant Alex Sino was served by Substitute Service on November 3, 2017. The Proof of Service of Summons for Defendant Sino was filed on November 17, 2017. A true and correct copy of the file-endorsed proof of service is attached as Exhibit “D.” According to the Affidavit of Reasonable Diligence attached to the Proof of Service, D&T Legal Services made four attempts at service prior to gaining access to serve Defendant Sino. 7. A true and correct copy of the file-endorsed Affidavit of Reasonable Diligence for service on Lidia Kiritchenko as Manager of Cambridge Staffing Solutions and as an Individual is attached as Exhibit “E.” D&T Legal Services has made five attempts at serving Lidia Kiritchenko. 2 Declaration of Patrick J. Whitehorn In Response to Order to Show Cause —ww oD wm NI KD OH he The process server has been informed by the Concierge at the Kiritchenko residence that Defendant Kiritchenko is a full-time occupant of the building, but that she is out of town. Plaintiff is stiil attempting to serve Defendant Kiritchenko in both her individual capacity and on behalf of Defendant Cambridge Staffing Solutions. 8. As Defendant Sino was served by Substitute Service on November 3, 2017, his Answer is due on December 13, 2017. 9. As Defendant Sino’s Answer is not due until December 13, 2017, and Plaintiff's process server is still attempting service on the other defendants, the undersigned respectfully requests that the court continue the Order to Show Cause without dismissing the action for a period of 60 days to allow for Defendant Sino’s Answer to be filed or his default taken, and for continued attempts at service on Defendants Kiritchenko and Cambridge Staffing Solutions. Plaintiff's counsel appreciates the courtesy extended by the Court. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct to the best of my knowledge, information and belief. Executed this 28"" day of November, 2017, at San Mateo, California. lorneys for Gregory Fishman 3 Declaration of Patrick J. Whitehorn In Response to Order to Show CauseEXHIBIT APOS-015 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stato Bar number and FOR COURT USE ONLY William C. Last. Jr. (083588) Patrick J. Whitehorn (225927) LAST & FAORO. 520 S. El Camino Real, Ste 430 San Mateo. CA 94402 tetePHoNe No (650) 696-8350 Faxno iOmmnar (650) 696-8365 E-+WAN ADDRESS /Optona)) arronvey FoR imaro). Gregory Fishman, Plaintiff. SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO STAEET ADDRESS. 40 McAllister Street MAILING ADDRESS crvanozP COPE San Francisco 94102 SrANcUNAYE Civic Center Courthouse PLAINTIFFIPETITIONER: Gregory Fishman DEFENDANTIRESPONDENT: Cambridge Staffing Solutions, LLC, et al. CASE NUMBER NOTICE AND ACKNOWLEDGMENT OF RECEIPT—CIVIL CGC-17-557162 TO (insert name of party being served): Cambridge Staffing Solutions. LLC. a California limited liability company NOTICE The summons and other documents identified below are being served pursuant to section 415.30 of the California Code of Civil Procedure. Your failure to complete this form and return it within 20 days from the date of mailing shown below may subject you (or the party on whose behalf you are being served) te llabilily for the payment of any expenses incurred in serving a summons ‘on you in any other manner penmitied by law. Ifyou are being served on behalf of a corporation, an unincorporated association (including a partnership), or olher entity, this, form must be signed by you In the name of such entity or by a person authorized lo receive service of process on behalf of such entity. In all other cases, this form must be signed by you personally or by a person authorized by you to acknowledge receipt of summons. if you relum this form to the sender, service of a summons is deemed complete on the day you sign the acknowledgment of receipt below, Z Date of mailing: July 10, 2017 Patrick J. Whitehorn od fe (PYPE OR PRINT NAME} Lo IN THIS CASE) ACKNOWLEDGMENT OFARECEIPT ‘This acknowledges receipl of (to be completed by sender before mailing): 1 Ci A copy of the summons and of the complaint. 2, CE]. Other (specify): Summons First Amended Complaint; First Amended Complaint; Case Management Order dated July 3, 2017 Continuing Case Management Conference; SF ADR Program Information Package; Judicial Mediation Program; Expedited Jury Trial Information Sheet; Blank form Stipulation to ADR; Blank form Case Management Statement; Early Settlement Program flyer (To be completed ay recipient): Date this form is signed: TF¥PE OR PRINT YOUR RARE AND AME OF ENTITY FAW Ao EE OF SOY ACIDIOUM EDGE RECERT VETTE Page tof For Nate eee NOTICE AND ACKNOWLEDGMENT OF RECEIPT — CIVIL sae LOR aD POSOIS (Row January + 2005] seme courtinia c@ acy Lexisherisk duiomated Calformus Jadiclit Counett Forms,EXHIBIT BPOS-015 [ATTORNEY OR PARTY WITHOUT ATTORNEY (Wome State for rumber and edim3s) FOR COURT USE ONLY |_William C. Last, Jr, (083588) Patrick J. Whitehorn (225927) LAST & FAORO 520 S. E] Camino Real, Ste 430 San Mateo. CA 94402 velzrHonewo (650) 696-8350 Faxtia (optenas (650) 696-8365 Estat ADORESS (Qpeanan ATTORNEY FOR ome) Grepory Fishman, Plaintiff ‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO Streer aporess 400 McAllister Street MAILING ADDRESS cee nines San Francisco. 94102 Civic Center Courthouse PLAINTIFFPETITIONER Gregory Fishman DEFENDANTRESPONDENT Cambridge Staffing Solutions, LLC. et al. CASE NUMBER NOTICE AND ACKNOWLEDGMENT OF RECEIPT—CIVIL CGC+17-557162 TO (insert name of party being served): Alex Sino. an Individual and manager of Cambridge Staffing Solutions. LLC NOTICE The summons and other documents identified below are being served pursuant to section 415.30 of the Califomia Code of Civil Procedure. Your failure to complete this form and return il within 20 days from the date of mailing shown below may subject you {or the party on whose behalf you are being served) to Ilability for the payment of any expenses incurred in serving a summons ‘on you in any other manner permitted by law. if you are being served on behalf of a corporation, an unincorporated association {including a partnership), or other entity, this farm must be signed by you in the name of such enlity or by a person authorized to receive service of process on behalf of such entity. in ali other cases, this form must be signed by you personally or by 4 person authorized by you to acknowledge receipt of summans. If you return this form te the sender, service of a summons is deemed complete on the day you sign the acknowledgment of receipt below. Date af mailing: July 10, 2017 Patrick J. Whitehom TYPE OR PRINT MANE ‘This acknowledges receipt of (ta be completed by sender before 1. 1 Acopy of the summons and of the complaint. 2: Olher (specify) Summons First Amended Complaint; First Amended Complaint; Case Management Order dated July 3, 2017 Continuing. Case Management Conference; SF ADR Program Information Package; Judicial Mediation Program; Expedited Jury Trial Information Sheet; Blank form Stipulation to ADR; Blank form Case Management Statement; Early Settlement Program flyer {To be completed by recipient): Date this form is signed TYPE OW PRINT YOUR NAKEE Alb NAME OF LITOTY 1° ANY “(SIGNATURE OF PERSON ACKNOWL EOGWG RECEIPT vaTH TITLE IF (ON WHOSE BEHALF THIS FORM IS SIGNED) ACKNOWLEDGMENT IS MADE ON BEHALF OF ANOTHER PERSON OR ENTITY? Page vel Fe iCatete NOTICE AND ACKNOWLEDGMENT OF RECEIPT — CIVIL ote ase a POS-O15 [Rov Jamusty 5 2005} enw courinlo ca pov Lex News Automated Calforma Suchicial Coumed FormsEXHIBIT CPOS-015 ATTORNEY OR PARTY WITHOUT ATTORNEY (Nama, Stale Gar number FOR COURT USE ONLY |_William C. Last, Jr. (083588) Patrick J. Whitehorn (2: 25927) | LAST & FAORO 520 §. El Camino Real, Ste 430 San Mateo, CA 94402 erepone no. (650) 696-8350. FAXNO (Opterst, (650) 696-8365 E-MAN, ADDRESS {Qpeona) arronney FOR Memo) Gregory Fishman, Plaintiff’ SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO Syaeey anone®s 400 McAllister Street MAILING ADDRESS CITY Ano ZiP CODE, San Francisco 94102 BRACKMANE Civic Center Courthouse PLAINTIFF/PETITIONER Gregory Fishman DEFENDANTIRESPONDENT Cambridge Staffing Solutions, LLC. et al. ‘CASE HUMBER NOTICE AND ACKNOWLEDGMENT OF RECEIPT—CIVIL CGC-17-557162 TO (insert name of party being served}: Lidia Kiritchenko, an Individual and manager of Cambridge Staffing Solutions. LLC NOTICE The suramons and other documents identified below are being served pursuant to section 415.30 of the California Cada of Civ Procedure. Your failure to complete this form and return it within 20 days from the date of mailing shown below may subject you (or the party on whose behalf you are being served) to liabilily for the payment of any expenses incurred In serving a summons on you in any other manner permitted by law. if you are being served on behalf of a corporation, an unincorporated association (including 2 parinership), or other antity, this form must be signed by you in the name of such entity or by a person authorized (o receive service of process on behalf of such entity. In all other cases. this form must be signed by you personally or by a person authorized by you to acknowledge receipt of summons. If you retum this form te the sender, service of a summons is deemed complete on the day you siggy he acknowledgment of receipt below. Date of mailing: July 10. 2017 Patrick J. Whitehom (TYPE OR PRINT NAME) ACKNOWLEDGMENT OF RECEIPT This acknowledges receipl of (to be complated by sender before mailing) 4. [2] A copy of the summons and of the complaint, 2, CX] Other (specify): Summons First Amended Complaint: First Amended Complaint; Case Management Order dated July 3, 2017 Continuing Case Management Conference; SF ADR Program Information Package; Judicial Mediation Program; Expedited Jury Trial Information Sheet; Blank form Stipulation to ADR; Blank form Case Management Statement; Early Settlement Program flyer {To be completed by recipient): Date this form is signed: (HVPE OA PA fi YOUR NAME AND NAME OF ENTITY ARV. ATURE OF PERSON ACO EDGING RECEIPT WATH TIRE ON WHOSE BEHALF THIS FORMS SGHED} ‘ACEI WS MADE ON BEHALF OF PERSON OR ENTITY) Poge tof} Fare Rapaadtor andar Uae NOTICE AND ACKNOWLEDGMENT OF RECEIPT — CIVIL Camera roceaes POS .A15 [Rev Jaruary 12005) voew cocrbala ca gow Letts Weta dtomnated Calffarma Judketal Counce ForiisEXHIBIT Daitarty oF Faxiy withoad aorep ‘WILLIAM C LAST, JR, Bar #82588 Fee Ceaet Use Only a ELECTRON $20 5 EL CAMINO REAL, ONICALLY SUETE 430 FILED SAN MATEO, CA 94402 Superior Court of Califor: Fetephusne No: 630-496-8330 County of San Francisco! [ietRew Res 11/17/2017 Clerk of the Court] BY:-EDWARD SANTOS Deputy Clark PAX Ke; 630-696-8365 aucraey for: Piaintitt frvars name of Conry, ond Aafctal Dikweiet aad Branch Comet: SAN FRANCISCO COUNTY SUPERIOR. COURT. Peiedsf GREGORY FISHMAN . CAMRIDGE STAFFING SOLUTIONS. LLC. ct al. PROOF OF SERVICE |iieorteg Dawe: [Taree IDepyDie: Brewer: SUMMONS AND AMENDED CGC-17-5571862, 7, At the time of service Lwas ot least 18 years of age and not a party to t's action. 2. xerved copies of de SUMMONS AND AMENDED COMPLAINT ORDER CONTINUING CASE MANAGEMENT CONFERENCE, ADR PROGRAM INFORMATION PACKAGE. 5, a. Pary served: ALEX SIMO, an individual and manager of Combeldge Staffing Solutlons, LLC 4. Addéress where the paryy was served: ‘724. NERTH DR BOCA RATON, FE 33487 3S. } served the party: bby substifuted service. On: Fri, Nov. 03, 2017 at: 6:36PM by keaving the caples with or in the presence of MRS. SINO, CO-OCCUPANT 2) tHlomeyComperot Member of the Household aver 18, 1 fafermed bim or her of the general nature of the paptrt, @)-A desleration of mailing fe attached, (5) tanach.a declaration of diligence stating actions taken first to attempt personal service, & Thm "Notice tothe Person Sarved (om the Summons) was completed as follaws; ‘e.g an individual defendant, and on behalf oft ond manager of Cambridge Stalling Solutions, LLC Under OCP 416.90 (authorized person) 2 Paxson Who Served Papers: 2. MICHAEL GONBOES Recavereble Cost Fer CCP NS-St0X SKE The Fee for Service was: $183.00 P.O, Box 8383 &. Lan (2) segitlered Celifomia process server Walnut Grook, GA 94596 ( Indcpendent Contractor 4025) 947-1221 () Registration Ne: 19ED fax (928) B47~1378 48 County: ‘OUT OF STATE ‘GNeein ee 8. 1 dectare under penalty of perjury under the laws of the State of California that the foregoing ts fene and correct ‘Pate: Tue, Nov. 07, WIT j 2 fo subRQRE RAE RRERG a7 ond STEP SERRE Sao 2D[Attorney at Party withous Attorney. WILLIAM C LAST, JR, Bar #83588 LAST & FAORO $20 § EL CAMINO REAL, SUITE 430 SAN MATEO, CA 94402 Telephone No. 630-696-8350 FAX: No: 650-696-8365 Far Court Uie Only Ref No or File No: |Avomney for: Plaintiff insert name of Court, and Juchclal District and Branch Court- SAN FRANCISCO COUNTY SUPERIOR COURT Piaintiff’ GREGORY FISHMAN Defendant. CAMRIDGE STAFFING SOLUTIONS, LLC, etal. AFFIDAVIT OF Hearing Date Time: Depi/Div: [Case Number: REASONABLE DILIGENCE CGC-17-557 162 1.1, MICHAEL. GONEDES, and any employee or independent contractors retained by D&T LEGAL SERVICES are and were on the dates mentioned herein over the age of eighteen years and not a party to this action. Personal service was attempted on Defendant ALEX SINO, an individual and manager of Cambridge Staffing Solutions, LLC as follows: Documents: SUMMONS AND AMENDED COMPLAINT ORDER CONTINUING CASE MANAGEMENT CONFERENCE, ADR PROGRAM INFORMATION PACKAGE. Day Mon Mon Wed Tho Dai 10/30/17 100/17 HAA? 1/027 Page Number 1 Date: Tue, Nov. 07,2017 Time 12:00pm 9:13pm 8:38pm 7:59am, Location Home Home Home Home Results THIS RESIDENCE IS A MANSION THAT {S GATED. PER A FEMALE THROUGH THE INTERCOM, THE SUBJECT IS NOT HOME. Attempt made by: MICHAEL GONEDES. Attempt at: 7241 NE 8TH DR. BOCA RATON, FL. 33487, PER THE SAME FEMALE THROUGH THE INTERCOM, THE SUBJECT IS. NOT HOME. SHE WILL NOT LET ME THROUGH THE GATE IF THE SUBJECT IS NOT HOME. Attempt made by: MICHAEL. GONEDES. Atternpt at 7241 NE 8TH DR BOCA RATON, FL 33487, NO ANSWER ON THE INTERCOM. LIGHTS ARE ALL ON INSIDE. Attempt made by: MICHAEL GONEDES. Attempt at: 7241 NE 8TH DR BOCA RATON, FL 33487. NO ANSWER ON THE INTERCOM. NO CARS SEEN. Attempt made by: MICHAEL GONEDES. Attempt at: 724] NE 8TH DR BOCA RATON, FL 33487. Jastf, 78487 AFFIDAVIT OF REASONABLE DILIGENCE[asaayer Fargo tia WILLIAM CLAST, JR, Bar #83588 LAST & FAORO | 320 EL CAMINO REAL, SUITE 430 SAN MATEO, CA 94402 LTeliphanr Sez 650-056-8350 FAA: Nia: 650-696-8365 Noor PeRaS Accorency for: Plaine tt rama 6f Cour’, ard Avdicial Dosvict cad Brarch Geir: SAN FRANCISCO COUNTY SUPERIOR COURT Pianig. GREGORY FISHMAN locfndine CAMRIDGE STAFFING SOLUTIONS, LLC, ot ol. AFFIDAVIT OF Hearing Desa Tae: DepeTie: [Cose Number: REASONABLE DILIGENCE I CGC-17-557162 Day aie ih ‘Ceeation__ | Resutis En Tas? 6:30pm Home ‘ABLE TO GAINENTRY, MRS. SING ADVISED THROUGH THE CLOSED DOOR THAT SHE DID RESIDE HERE AND THAT ALEX WAS AWAY SOT ‘NEEDED TO GO. AWAY. TASKED MRS. SINO THAT SHE OPEN THE DOOR ‘AND ACCEPT SERVICE JN HAND SUT EHE REFUSED, 1 THEN READ OUT LOUD IN A LOUD VOICE WAAT THE DOCUMENTS WHERE ABOUT. ‘THEN ANNOUNCED SERVICE AND DROP SERVED THE DOCUMENTS AT ‘THE DOOR, THERE WAS A SILVER MERCEDES LICE BAFC32 FRESENT, “Adleenpt made by: MICHAEL GONRDRS. Aslempt at: 2241 NE RTH DR. BOCA BATON, FL 33487. Fai 1103/07 6:36pm Home Substituted Service on: ALEX SINO, an individual and manager of Cembsldge Staffing Solutions, LLC Home - 724} NE STH DR BOCA RATON, FL 33487 by Sorving: party in Item 3.0. Competent Member of the Houschald over 18 ty leaving 3 copy of the dacuavent(s) with: MRS, SIND, COOCCUPANT. Served by: MICHAEL GONEDES Tus LRIAT Matted eapy of Documents to: ALEX SINO, aa individual and mansger of ‘Cambridge Staffing Schtions, LLC 3. Person Execsting Hecoversble Coats Per COP ROSI-440}1018) a. MICHAEL GONEDES & The Fee for service wax: $183.00 b, DQT LEGAL SERVICES e fom: (3) vegistered California process atrver 2i46N MAIN STREET, SUFTE A, Reglswation #792 {Independent Coatrector P.O, Box 5383 Gi) Regtsranton Na: isto WALNUT CREEK, CA 94596 Gig Counsy: OUT OF STATE ¢. (925) 947-1221, FAX (925) 947-1375 Dato: Tue, Nov. 07, 2017 ‘4. Ldeoimre under penaity of pecury under the laws of tse State of Callforrita that the foregoing js te ee Page Number 2 Aca. cOWEDED asst 78887 AFFIDAVIT OR REASONASLE DILIGENCEAttorney or Party without Attorney WILLIAM C LAST, JR, Bar #83588 LAST & FAORO For Court Use Only By Mail 520 S EL CAMINO REAL, SUITE 430 SAN MATEO, CA 94402 Telephone No, 650-696-8350 FAX No: €50-696-8365 Ref No or Fide No. \Atrorney for: Plaintilt Riser? name of Courl, and Judicial Disivict and Branch Cover SAN FRANCISCO COUNTY SUPERIOR COURT. Plaintiff GREGORY FISHMAN Defendam, CAMRIDGE STAFFING SOLUTIONS, LLC, et al. PROOF OF SERVICE Hearing Date: Time. Depi/Div: Case Number: CGC-17-557162 Lam over the age of 18 and not « party to this action. Tam employed in the county where the mailing occurred. 2. [served copies of the SUMMONS AND AMENDED COMPLAINT ORDER CONTINUING CASE MANAGEMENT CONFERENCE, ADR PROGRAM INFORMATION PACKAGE. 3. By placing a true copy ofeach document in the United States mail, in a sealed envelope by First Class mail with postage prepaid as follows: a. Date of Mailin; b. Place of Mail Tue., Nov, 07,2017 WALNUT CREEK, CA 94596 c. Addressed as follows: ALEX SINO, an individual and manager of Cambridge Staffing Solutions, LLC 7241 NE 8TH DR BOCA RATON, FL 33487 4. lam readily familiar with the business practice for collection and processing of correspondence as deposited with the U.S. Postal Service on Tue., Nov. 07, 2017 in the ordinary course of business. 5. Person Serving: Recoverable Cost Per CCP 1033.5(a)(4(B) a. DAMON PULIDO d. | The Fee for Service was: . $183.00 b. D&T LEGAL SERVICES: ¢, Lam: (3) registered California process server 2146 N MAIN STREET, SUITE A, Registration # 792 (i) Independent Contractor P.O. Box 5383 ii) RegistrationNo.: 849 WALNUT CREEK, CA 94596 (ii) County: c. (925) 947-1221, FAX (925) 947-1375 (ti) Expiration Date: Fri, Oct. Contra Costa 2019 & {declare under penalty of perjury under the laws of the State of California that the foregoing ts true and correct. Date: Tue, Nov. 07, 2017 aT +, a Iudicial Council Form POS-010 PROOF. OF SERVICE pe See eg taase t 2007 COR OFT WAMON PULIDOS aay neaatEXHIBIT EAtearney oF Party wei Aerie t For Conti Use Ory WILLIAM CLAST, JR, Bar #83588 ! LAST & FAORO. 520 S$ EL CAMINO REAL, ELECTRONICALLY SUITE 430 ; SAN MATEO, CA 94402 - e r L ED 650+ Fo: 650-696-8' uperior Court Fria, Telephone No! 650-696-8350 FAX NO; 659-696-8365 mor NaereN reer or kan Pominee ia, Astormay for: Paint 11/17/2017 Insert name of Court, and Judiceal District end Branch Courl Clerk of the Court SAN FRANCISCD COUNTY SUPERIOR COURT. BY:MADONNA CARANTO Piamrig: GREGORY FISHMAN Ocputy Stork Dsfendent: CAMBRIDGE STAFFING SOLUTIONS, LLC. et al. ANFIDAVIT OF tearag Dave: Time: DapitDie, Case Neenber: REASONABLE DILVIENCE CGE-17-587162 1, FRANK TRUILLO, aud any employee or independent contractors retained by D&T LEGAL SERVICES are and were on the dates mentioued herein over the age of eighteen years and nat a party to this action. Personal service was attempted on Defendant LIDIA KIRITCHENKO, an individual and manager of Cambridge Staffing Solutions, LLC as follows: 2. Documents: SUMMONS AND AMENDED COMPLAINT ORDER CONTINUING CASE MANAGEMENT CONFERENCE, ADR PROGRAM INFORMATION PACKAGE, Day Date Time Location Results Fr LORWIT 8.33pm Home NO ANSWER. PER THE CONCIERGE WHO CONFIRMED THE RESIDENCY BUT STATED SHE COMES AND GOES. THEY HARDLY SEE TIER. Atempi made by: FRANK TRUJILLO. Attempt at; 15901 COLLINS AVE APT 3807 Sunny Istes Beach, FL 33160. Sac 10/28/17 10:30am. Home NO ANSWER. Anempt made by: FRANK TRUJILLO. Auempt at. 1590% COLLINS AVE APT 3807. Sunny Isles Beach, FL 33160. ‘Te 1031/17 7:05am Home NO ANSWER. Atempt made by: FRANK TRUJILLO. Attempt at; 15901 COLLINS AVE APT 3807 Sunny Isles Beach, FL 33160. Thao LA6NT 1120am Home NO ANSWER. PER THE MORNING CONCIERGE THE SUBJECT IS STILL OUT OF TOWN. HE STATED HE KNOWS HER VERY WELI. AND SHE HASNT COME BACK YET BECAUSE HE WOULD KNOW. HE WOULD SEE TIER IN THE LOBBY OFTEN. HE THINKS SHE'S COMING BACK FOR CHRISTMAS. HE ALSO STATED THEY ARE NOT SEASONAL OWNERS, THEY LIVE HERE. Attempt made by: FRANK TRUJILLO, Registration #CPS#1284 OUT OF STATE County, Attempt at; 15901 COLLINS AVE APT 3807 Sunny Isles Beach, FL. 33160. Page Number 1 Date: Fri, Nov. $7, 2017 fost. 78483 AFFIDAVIT OF REASONABLE DILIGENCEitirmey or Party walkout Aitarney Par Court Use Oni WILLIAM C LAST, JR, Bar #83588. LAST & FAORO $20 S EL CAMINO REAL, SUITE 430 SAN MATEO, CA 94402 Telephone Na: 650-696-8350 FAX Ke, 650-696-8365 i Na ar PIE TS. Attorney for Plaintift Foert name of Court. and Judicial District oud ranch Court SAN FRANCISCO COUNTY SUPERIOR COURT. Planng GREGORY FISHMAN Defendant CAMRIDGE STAFFING SOLUTIONS, LLC, et al. AFFIDAVIT OF |Aearing Date: Tiare: Dep Div: Case Neonbvr REASONABLE DILIGENCE CGC-17-S57162 (Day Date. Time [| Location | Results } Fn HATAT 10:00am Home Recurmed Not Served on: LIDIA KIRITCHENKO, an individual and manager of Cambridge Staffing Solutions, LLC Home - 5901 COLLINS AVE APT 3807 Sunny Isles Beach, FL 33160 3. Person Exeeuting ‘Recoverable Costs Per CCP 1033.5(u}(4)(R) a, FRANK TRUHLLO a. The Fee far service was: $170.00 b. D&T LEGAL SERVICES e. fam: (3) registered California process server 2146 N MAIN STREET, SUITE A, Registration # 792 (} Independent Contractor P.O. Box 5383 Registration No: ces41284 WALNUT CREEK, CA 94596 County: OUT OF STATE, ©. (925) 947-1221, FAX (925) 9AF-1375 4. I declare under penalty of perjury under the laws of the State of California that the foregoing is nd correct Date: Fri, Nov. 17,2017 (Dy Page Number 2 {FRANK TRONLEO) Angi 78483 AFFIDAVIT OF REASONABLE DILIGENCEoD mI NH Fe YY = noo 13 PROOF OF SERVICE I, the undersigned, declare that 1 am employed in the City and County of San Mateo, California. 1am over the age of eighteen years and not a party to the within action. My business address is 520 S. El Camino Real, Ste 430, San Mateo, California 94402. On the indicated below, I served the within document(s), entitled: DECLARATION OF PATRICK J. WHITEHORN IN RESPONSE TO ORDER TO SHOW CAUSE on each party(ies) addressed as follows: XXX 0 BY MAIL: by placing a true copy of each document listed above in a sealed envelope addressed to the parties listed above and depositing it with the U.S. Postal Service on the date shown below. oO BY HAND: I caused each such envelope to be delivered by hand to the addressee(s) listed above via same day messenger service. o BY E-MAIL: I caused a true copy to be transmitted via e-mail to the addressee(s) listed above at the e-mail noted after the party’s address. 0 BY OVERNIGHT DELIVERY: by delivering each document to an authorized courier authorized by the express service carrier to receive documents in an envelope designated by the express service carrier with delivery fees prepaid or provided for and addressed as above- shown. 0 BY FACSIMILE: I caused a true copy to be transmitted via facsimile to the addressee(s) listed above at the Fax number noted after the party’s address. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on November 28, 2017 TAL Chrarne Lynne Casanova Proof of Service