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1 Todd A. Jones (Bar No. 198024)
tjones@archemorris.com
2 Gregory K. Federico (Bar No. 242184)
gfederico@archemorris.com
3 ARCHERNORRIS
A Professional Law Corporation
4 301 University Avenue, Suite 110
Sacramento, Califomia 95825-5537
5 Telephone: 916.646.2480
Facsimile: 916.646.5696
6
Attomeys for Defendants
7 RICHARD KIRK RUYBALID, individually, and
dba CA CONSTRUCTION
8
9 SUPERIOR COURT OF CALIFORNIA
10 COUNTY OF SACRAMENTO
11
12 RODNEY ABBOTT and FLORENTINE CaseNo. 07AS04450
ABBOTT,
13 AMENDED PROOF OF SERVICE RE:
PlaintifTs, DEFENDANT CA CONSTRUCTION'S
14 NOTICE OF MOTION AND MOTION
V. FOR AN ORDER COMPELLING
15 PLAINTIFFS FLORENTINE AND
RONALD PAUL BRITSCHGI, et al., RODNEY ABBOTT TO OBTAIN A BOND
16 ON APPEAL; MEMORANDUM OF
Defendants. POINTS & AUTHORITIES; REQUEST
17 FOR JUDICIAL NOTICE;
DECLARATION OF GREGORY K. t^-^
18 FEDERICO IN SUPPORT THEREOE;:>^^<&
[PROPOSED] ORDER ^
19
Action Filed: September 24, 2007
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Date: August 12, 201
21 Time: 9:00 a.m.
Dept: 43
22 Judge: Honorable Brian Van Camp'j Q
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AND ALL RELATED CROSS-ACTIONS.
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26 III
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III
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III
NIC341/1191826-1
AMENDED PROOF OF SERVICE RE: NOTICE OF MOTION AND MOTION FOR AN ORDER COMPELLING
PLAINTIFFS TO OBTAIN A BOND
1 PROOF OF SERVICE
2 Name of Action: Rodney Abbott, et al. v. Ronald Paul Britschgi, et al.
Sacraniento County Superior Court Case No.: 07AS04450
3
I, Cindy A. Ingland, declare that I am over the age of 18 years and not a party to this
4 action or proceeding. My business address is 301 University Avenue, Suite 110, Sacramento,
Califomia 95825. On July 15,2011,1 caused the following document(s) to be served:
5 SEE ATTACHED
6
7
By placing a true copy of the documents listed above, enclosed in a sealed envefope,
^ addressed as set forth below, for collection and mailing on the date and at the business
9 address shovwi above following our ordinary business practices. I am readily familiar
with this business' practice for collection and processing of correspondence for
20 mailing with the United States Postal Service. On the same day that a sealed envelope
is placed for collection and mailing, it is deposited in the ordinary course of business
11 with the United States Postal Servico with postage fully prepaid.
12 By having a true copy of the document(s) listed above transmitted by facsimile to the
person(s) at the facsimile number(s) set forth below before 5:00 p.m. The transmission
^^ was reported as complete v«thout error by a report issued by the transmitting facsimile
14 machine.
j5 | ~ j By placing a true copy of the document(s) listed above, in a box or other facility
regularly maintained by UPS, an express service carrier, or delivered to a courier or
16 driver authorized by the express service carrier to receive documents, in an envelope
designated by the express service carrier, with delivery fees paid or provided for,
^^ addressed as set forth below.
Q bv having personal deliverv bv FIRST LEGAL SUPPORT SERVICES a tme copy of
the document(s) listed above, enclosed in a sealed envelope, to the person(s) and at thv'
address(es) set forth below.
20
by having personally delivered a true copy of the document(s) listed above, enclosed in
21 ' ' a sealed envelope, to the person(s) and at the address(es) set forth below.
22
[SEE ATTACHED SERVICE LIST]
23 „
I declare under penalty of perjury that the foregoing is true and correct. Executed on July
24 15, 2011, at Sacramento, Califomia.
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N1C341/608293-I
PROOF OF SERVICE
1 1) NOTICE OF MOTION AND MOTION FOR AN ORDER COMPELLING
PLAINTIFFS FLORENTINE AND RODNEY ABBOTT TO OBTAIN A BOND ON
2 APPEAL
3 2) MEMORANDUM OF POINTS & AUTHORITIES IN SUPPORT OF MOTION
FOR AN ORDER COMPELLING PLAINTIFFS FLORENTINE AND RODNEY
4 ABBOTT TO OBTAIN A BOND QN APPEAL
5 3) DECLARATION OF GREGORY K. FEDERICO IN SUPPORT OF MOTION FOR
AN ORDER COMPELLING PLAINTIFFS FLORENTINE AND RODNEY
6 ABBOTT TO OBTAIN A BOND ON APPEAL
7 4) REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION FOR AN
ORDER COMPELLING PLAINTIFFS FLORENTINE AND RODNEY ABBOTT
8 TO OBTAIN A BOND A BOND ON APPEAL
9 5) [PROPOSED] ORDER GRANTING MOTION FOR AN ORDER COMPELLING
PLAINTIFFS FLORENTINE AND RODNEY ABBOTT TO OBTAIN A BOND ON
10 APPEAL
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N I C J 4 1/608293-1 2
SERVICE LIST
1. Service List
2
Stephanie Finelli PLAINTIFFS
3 Law Offices of Stephanie J. Finelli
1007 Seventh Street, Suite 500 Tel: (916) 443-2144
4 Sacramento, CA 95814 Fax: (916) 443-1511
E-mail: sfinelli700@yahoo.com
5 [Sen/ed by Mail on July 15, 2011]
6 Rodney and Florentine Abbott PLAINTIFF IN PRO PER
8601 Rolling Green Way
7 Fair Oaks, CA 95628
[Hand-Delivered on July 19, 2011]
8
Richard D. Sopp Counsel for CADRE DESIGN GROUP, INC,
9 Wheatley Sopp LLP
1004 River Rock Drive, Suite 245 Tel: (916) 988-3857
10 Folsom, CA 95630 Fax; (916) 988-5296
[Served by Mail on Juiy 15, 2011] Email: rds@mwsblaw.com
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12 Mark Smith In Pro Per
3557 Val Verde Road
13 Loomis, CA 95650
[Served by Mail on July 15, 2011]
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NIC341/608293-1
SERVICE LIST
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1 Todd A. Jones (Bar No. 198024) tjones@archemorris.com 2 Gregory K. Federico (Bar No. 242184) gfederico@archemorris.com 3 ARCHERNORRIS A Professional Law Corporation 4 301 University Avenue, Suite 110 Sacramento, Califomia 95825-5537 5 Telephone: 916.646.2480 Facsimile: 916.646.5696 6 Attomeys for Defendants 7 RICHARD KIRK RUYBALID, individually, and dba CA CONSTRUCTION 8 9 SUPERIOR COURT OF CALIFORNIA 10 COUNTY OF SACRAMENTO 11 12 RODNEY ABBOTT and FLORENTINE CaseNo. 07AS04450 ABBOTT, 13 AMENDED PROOF OF SERVICE RE: PlaintifTs, DEFENDANT CA CONSTRUCTION'S 14 NOTICE OF MOTION AND MOTION V. FOR AN ORDER COMPELLING 15 PLAINTIFFS FLORENTINE AND RONALD PAUL BRITSCHGI, et al., RODNEY ABBOTT TO OBTAIN A BOND 16 ON APPEAL; MEMORANDUM OF Defendants. POINTS & AUTHORITIES; REQUEST 17 FOR JUDICIAL NOTICE; DECLARATION OF GREGORY K. t^-^ 18 FEDERICO IN SUPPORT THEREOE;:>^^<& [PROPOSED] ORDER ^ 19 Action Filed: September 24, 2007 20 Date: August 12, 201 21 Time: 9:00 a.m. Dept: 43 22 Judge: Honorable Brian Van Camp'j Q 23 24 AND ALL RELATED CROSS-ACTIONS. 25 26 III 27 III 28 III NIC341/1191826-1 AMENDED PROOF OF SERVICE RE: NOTICE OF MOTION AND MOTION FOR AN ORDER COMPELLING PLAINTIFFS TO OBTAIN A BOND 1 PROOF OF SERVICE 2 Name of Action: Rodney Abbott, et al. v. Ronald Paul Britschgi, et al. Sacraniento County Superior Court Case No.: 07AS04450 3 I, Cindy A. Ingland, declare that I am over the age of 18 years and not a party to this 4 action or proceeding. My business address is 301 University Avenue, Suite 110, Sacramento, Califomia 95825. On July 15,2011,1 caused the following document(s) to be served: 5 SEE ATTACHED 6 7 By placing a true copy of the documents listed above, enclosed in a sealed envefope, ^ addressed as set forth below, for collection and mailing on the date and at the business 9 address shovwi above following our ordinary business practices. I am readily familiar with this business' practice for collection and processing of correspondence for 20 mailing with the United States Postal Service. On the same day that a sealed envelope is placed for collection and mailing, it is deposited in the ordinary course of business 11 with the United States Postal Servico with postage fully prepaid. 12 By having a true copy of the document(s) listed above transmitted by facsimile to the person(s) at the facsimile number(s) set forth below before 5:00 p.m. The transmission ^^ was reported as complete v«thout error by a report issued by the transmitting facsimile 14 machine. j5 | ~ j By placing a true copy of the document(s) listed above, in a box or other facility regularly maintained by UPS, an express service carrier, or delivered to a courier or 16 driver authorized by the express service carrier to receive documents, in an envelope designated by the express service carrier, with delivery fees paid or provided for, ^^ addressed as set forth below. Q bv having personal deliverv bv FIRST LEGAL SUPPORT SERVICES a tme copy of the document(s) listed above, enclosed in a sealed envelope, to the person(s) and at thv' address(es) set forth below. 20 by having personally delivered a true copy of the document(s) listed above, enclosed in 21 ' ' a sealed envelope, to the person(s) and at the address(es) set forth below. 22 [SEE ATTACHED SERVICE LIST] 23 „ I declare under penalty of perjury that the foregoing is true and correct. Executed on July 24 15, 2011, at Sacramento, Califomia. 25 26 27 28 N1C341/608293-I PROOF OF SERVICE 1 1) NOTICE OF MOTION AND MOTION FOR AN ORDER COMPELLING PLAINTIFFS FLORENTINE AND RODNEY ABBOTT TO OBTAIN A BOND ON 2 APPEAL 3 2) MEMORANDUM OF POINTS & AUTHORITIES IN SUPPORT OF MOTION FOR AN ORDER COMPELLING PLAINTIFFS FLORENTINE AND RODNEY 4 ABBOTT TO OBTAIN A BOND QN APPEAL 5 3) DECLARATION OF GREGORY K. FEDERICO IN SUPPORT OF MOTION FOR AN ORDER COMPELLING PLAINTIFFS FLORENTINE AND RODNEY 6 ABBOTT TO OBTAIN A BOND ON APPEAL 7 4) REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION FOR AN ORDER COMPELLING PLAINTIFFS FLORENTINE AND RODNEY ABBOTT 8 TO OBTAIN A BOND A BOND ON APPEAL 9 5) [PROPOSED] ORDER GRANTING MOTION FOR AN ORDER COMPELLING PLAINTIFFS FLORENTINE AND RODNEY ABBOTT TO OBTAIN A BOND ON 10 APPEAL 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 N I C J 4 1/608293-1 2 SERVICE LIST 1. Service List 2 Stephanie Finelli PLAINTIFFS 3 Law Offices of Stephanie J. Finelli 1007 Seventh Street, Suite 500 Tel: (916) 443-2144 4 Sacramento, CA 95814 Fax: (916) 443-1511 E-mail: sfinelli700@yahoo.com 5 [Sen/ed by Mail on July 15, 2011] 6 Rodney and Florentine Abbott PLAINTIFF IN PRO PER 8601 Rolling Green Way 7 Fair Oaks, CA 95628 [Hand-Delivered on July 19, 2011] 8 Richard D. Sopp Counsel for CADRE DESIGN GROUP, INC, 9 Wheatley Sopp LLP 1004 River Rock Drive, Suite 245 Tel: (916) 988-3857 10 Folsom, CA 95630 Fax; (916) 988-5296 [Served by Mail on Juiy 15, 2011] Email: rds@mwsblaw.com 11 12 Mark Smith In Pro Per 3557 Val Verde Road 13 Loomis, CA 95650 [Served by Mail on July 15, 2011] 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NIC341/608293-1 SERVICE LIST