Complaint,Petition: Rodney Abbott, et al vs. Ronald Paul Britschgi, et al

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                                1    Todd A. Jones (Bar No. 198024)
          Gregory K. Federico (Bar No. 242184)
     2    ARCHER NORRIS
          A Professional Law Corporation
     3    655 University Avenue, Suite 225                               OCT 3 1 2008
          Sacramento, California 95825
     4    Telephone:     916.646.2480
          Facsimile:     916.646.5696                             By:.     D. JC'INSON
                                                                           DEPUTY 1 CLERK
     5
          Attorneys for Defendants and Cross-Complainants
     6    RICHARD KIRK RUYBALID, individually, and
          dba CA CONSTRUCTION
     7
     8                                      SUPERIOR COURT OF CALIFORNIA
     9                                        COUNTY OF SACRAMENTO
    10
    11    RODNEY ABBOTT and FLORENTINE                   Case No. 07AS04450
          ABBOTT,
    12                                                   RICHARD K. RUYBALID, individually and
                              Plaintiffs,                dba CA CONSTRUCTION'S SECOND
    13                                                   AMENDMENT TO CROSS-COMPLAINT,
                   V.                                    SUBSTITUTING TRUE NAMES FOR
    14                                                   FICTITIOUSLY NAMED CROSS-
          RONALD PAUL BRITSCHGI, et al.,                 DEFENDANTS
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                              Defendants.                Action Filed: September 24, 2007
    16,
          RICHARD KIRK RUYBALID,
          individually and d/b/a CA
    18.   CONSTRUCTION,
    19                        Cross-Complainants,
    20             V.

    21    RONALD PAUL BRITSCHGI,
          individually and d/b/a BRITSCHGI
    22    CONSTRUCTION, and MOES 1 through
          100,
    23
                              Cross-Defendants.
    24
    25             COMES NOW Cross-Complainant RICHARD K. RUYBALID, individually and dba CA
          CONSTRUCTION (hereinafter "CA CONSTRUCTION") and amends its Cross-Complaint on

    27    file herein as follows:                                                           »«^
                   CA CONSTRUCTION hereby names fictitious MOES as follows and inserts those
:   28
          NIC341/720048-1

                  CA CONSTRUCTION'S SECOND AMENDMENT TO CROSS-COMPLAINT, SUBSTITUTING
                          TRUE NAMES FOR FICTITIOUSLY NAMED CROSS-DEFENDANTS
 1   names in the Cross-Complaint on file at every location where said fictitiously named Cross-
 2   Defendants appear:
 3            MOE 2 - FLORENTINE ABBOTT
 4            MOE 3-RODNEY ABBOTT
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 6   Dated: October 30, 2008                          ARCHER NORMS s—N
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                                                                         ^V_)
                                                                         &~^_^
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                                                      Gregory K. Federico
 9                                                    Attorneys for Cross-Complainants
                                                      RICHARD KIRK RUYBALID, individually,
10                                                    and dba CA CONSTRUCTION
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     NIC341/720048-1

              CA CONSTRUCTION'S SECOND AMENDMENT TO CROSS-COMPLAINT, SUBSTITUTING
                      TRUE NAMES FOR FICTITIOUSLY NAMED CROSS-DEFENDANTS
 1                                        PROOF OF SERVICE
 2   Name of Action: Abbott v. Britschgi, et al.
     Court and Action No: Sacramento County Superior No. 07AS04450
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             I, Marie Cantrell, declare that I am over the age of 18 years and not a party to this action
 4   or proceeding. My business address is 655 University Avenue, Suite 225, Sacramento, California
     95825. On October 30, 2008,1 caused the following document(s) to be served:
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                       RICHARD KIRK RUYBALD) INDIVIDUALLY AND DBA CA
 6                 CONSTRUCTION'S SECOND AMENDMENT TO CROSS-COMPLAINT,
                   SUBSTITUTING TRUE NAMES FOR FICTITIOUSLY NAMED CROSS-
 7                                     DEFENDANTS

 8     rj£| by placing a true copy of the documents listed above, enclosed in a sealed envelope,
            addressed as set forth below, for collection and mailing on the date and at the business
 9          address shown above following our ordinary business practices. I am readily familiar
10          with this business' practice for collection and processing of correspondence for
            mailing with the United States Postal Service. On the same day that a sealed envelope
11          is placed for collection and mailing, it is deposited in the ordinary course of business
            with the United States Postal Service with postage fully prepaid.
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       I I by having a true copy of the document(s) listed above transmitted by facsimile to the
13         person(s) at the facsimile number(s) set forth below before 5:00 p.m. The transmission
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           was reported as complete without error by a report issued by the transmitting facsimile
           machine.
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       I""] by placing a true copy of the document(s) listed above, in a box or other facility
16          regularly maintained by UPS, an express service carrier, or delivered to a courier or
            driver authorized by the express service carrier to receive documents, in an envelope
17          designated by the express service carrier, with delivery fees paid or provided for,
            addressed as set forth below.
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19                                  [SEE ATTACHED SERVICE LIST]
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21          I declare under penalty of perjury that the foregoing is true and correct. Executed on
     October 30, 2008, at Sacramento, California.
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                                                                        arie Cantrell
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     NIC341/608293-1

                                             PROOF OF SERVICE
 1
 2    Florentine Abbott                         Plaintiffs, In Pro Per
      Rodney Abbott
 3    8601 Rolling Green Way                   Tel: (916)747-1146
      Fair Oaks, CA 95628                      Fax:(916)967-2379
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      Craig N. Lundgren                         Counsel for RONALD PAUL BRITSCHGI,
 5    Law Offices of Craig N. Lundgren          INDIVIDUALLY AND DBA BRITSCHGI
      424 Second Street, Suite A                CORPORATION
 6    Davis, CA 95616
                                                Tel: (530)792-8800
 7                                              Fax: (530) 297-5077

 8    Richard D. Sopp                           Counsel for CADRE DESIGN GROUP, INC.
      Maloney, Wheatley, Sopp & Brooks
 9    1004 River Rock Drive, Suite 245          Tel: (916)988-3857
      Folsom, CA 95630                          Fax: (916) 988-5296
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     NIC341/608293-1

                                         SERVICE LIST