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1 Todd A. Jones (BarNo. 198024)
tj ones@archemorris.com
2 Gregory K. Federico (BarNo. 242184)
gfederico@archemorris .com
3 ARCHERNORRIS
A Professional Law Corporation
4 655 University Avenue, Suite 225
Sacramento, Califomia 95825-6747
5 Telephone: 916.646.2480
Facsimile: 916.646.5696
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Attomeys for Defendant
7 R4C0RP, INC., a Cahfomia Corporation
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SUPERIOR COURT OF CALIFORNIA
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COUNTY OF SACRAMENTO
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RODNEY ABBOTT and FLORENTINE CaseNo. 07AS04450
12 ABBOTT,
DECLARATION OF RICHARD K.
13 Plaintiffs, RUYBALID IN SUPPORT OF
DEFENDANT R4CORP., INC.'S MOTION
14 TO QUASH/STRIKE/DISMISS SERVICE
OF AMENDED SUMMONS AND DOE
15 RONALD PAUL BRITSCHGI, et al.. AMENDMENT
16 Defendants. Date: October 29,2010
Time: 2:00 p.m.
17 Dept: 53
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19 Action Filed: September 24,2007
20 AND RELATED CROSS-ACTIONS.
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I, Richard Kirk Ruybalid, declare as follows:
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1. I am currently the sole corporate officer for Defendant R4C0RP., INC., which is
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located at 9332 Fair Oaks Boulevard in Fair Oaks, Califomia. The matters stated in this
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declaration are tme to my own personai knowledge, and ifcalled upon to testify, I could and
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would testify competentiy thereto.
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2. I am a resident of Sacramento County.
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NIC549/974783-!
DECLARATION OF RUYBALID IN SUPPORT OF R4C0RP., INC.'S MOTION TO QUASH/STRIKE SERVICE
OF DOE AMENDMENT
1 3. On March 21,2006,1 formed R4C0JIP., INC. hyfiiing Articles of Incorporation
2 with the Califomia Secretary of State, Attached hereto as Exhibit "A" is a trae and "corfect copy
3 oftiifeMarch 21,2006 Articles of Incorporation for R4C0RP., .INC.
4 4- On October 25,2Q05, Plaintiff FLORENTINE and RODNEY ABBOTT
5 (hereinBfter '^PLAINTIFFS") and Defendant RICHARD K. ROYBALID dba CA
6 CONSTRUCTION (hereinafler "CA CONSTRUCTION") entered into a contiact for constmction
7 services at PLAINTIFFS' home located at S601 Rolling Green Way in Fair Oaks, Sacramento
8 County, CaUfomia. R4C0RP, INC. was hot a party to the contract between PLAINTIFFS and
9 CA CONSTRUCTION.
10 5. R4C0RP, INC. did not enter into any other contracts with PJLAINTIFFS, or any of
11 the other p.arfies, which are the subject of this action.
12 6. R4C0RP, INC. performed no .duties or services under any of the contracts that are
13 the subject ofthis action.
14 7. Nani Keeshan is currently a part-time bookkeeper for R4CORP.5 INC. She works
15 at R4C0RP., INC. two (2) days a Week,
16 8, I ara informed and believetiiatNani Keeshan was served with PLAINTIFFS'
17 Amended Summons, Amendment to Second Amended Complaint, and Second Amended
18 Complaint on May 11, 2010 while working as the part-time bookkeeper for R4C0RP., TNC.
19 9. Nani .Keeshan is not currently and never has been the office manager for
20 R4CORP., INC.
21 10. Nani Keeshan is not currently ahd never has been an officer of R4C0RP,, INC.
22 11. Nani Keeshan is not currently and never has been the authorized agent for service
23 of process for R4CORP., TNC.
24 12. Pursuant to the Articles of Incorporation on file with the Califomia Secretary of
25 State, I am the sole coiporate officer for R4C0RP., INC. I am the only authorized agent for
26 service of process for R4C0RP., INC.
27 1 3 . 1 have never authorized Nani Keeshan to accept service of process on behalf of
28 R4C0RP., INC.
N;C54?/974783-i 2
DECLARATION OF RUYBALID IN SUPPORT OF R4C0RP., INC'S MOTION TO QUASH/STRIKE SERVICE
OF DOE AMENDMENT
1 14. I have never been personally served with PLAINTIFFS' Amended Summons,
2 Amendment to Second Amended Coniplaint, and Second Amended Complaint as the authorized
3 agent for service of process for R4C0RP., INC.
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5 I declare under penalty of perjtiry under the laws ofthe State .ofCalifomia tiiat the
6 foregoing is trae and correct. Executed this Qf day of June, 2010, at Sacraroento, California.
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N1C549/974783-I
DECLARATION OF RUYBALID IN SUPPORT OF R4C0RP. FNC'S MOTION TO QUASH/STRIKE SERVICE
OF DOE AMENDMENT
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1 Todd A. Jones (BarNo. 198024) tj ones@archemorris.com 2 Gregory K. Federico (BarNo. 242184) gfederico@archemorris .com 3 ARCHERNORRIS A Professional Law Corporation 4 655 University Avenue, Suite 225 Sacramento, Califomia 95825-6747 5 Telephone: 916.646.2480 Facsimile: 916.646.5696 6 Attomeys for Defendant 7 R4C0RP, INC., a Cahfomia Corporation 8 SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF SACRAMENTO 10 11 RODNEY ABBOTT and FLORENTINE CaseNo. 07AS04450 12 ABBOTT, DECLARATION OF RICHARD K. 13 Plaintiffs, RUYBALID IN SUPPORT OF DEFENDANT R4CORP., INC.'S MOTION 14 TO QUASH/STRIKE/DISMISS SERVICE OF AMENDED SUMMONS AND DOE 15 RONALD PAUL BRITSCHGI, et al.. AMENDMENT 16 Defendants. Date: October 29,2010 Time: 2:00 p.m. 17 Dept: 53 18 19 Action Filed: September 24,2007 20 AND RELATED CROSS-ACTIONS. 21 22 I, Richard Kirk Ruybalid, declare as follows: 23 1. I am currently the sole corporate officer for Defendant R4C0RP., INC., which is 24 located at 9332 Fair Oaks Boulevard in Fair Oaks, Califomia. The matters stated in this 25 declaration are tme to my own personai knowledge, and ifcalled upon to testify, I could and 26 would testify competentiy thereto. 27 2. I am a resident of Sacramento County. 28 NIC549/974783-! DECLARATION OF RUYBALID IN SUPPORT OF R4C0RP., INC.'S MOTION TO QUASH/STRIKE SERVICE OF DOE AMENDMENT 1 3. On March 21,2006,1 formed R4C0JIP., INC. hyfiiing Articles of Incorporation 2 with the Califomia Secretary of State, Attached hereto as Exhibit "A" is a trae and "corfect copy 3 oftiifeMarch 21,2006 Articles of Incorporation for R4C0RP., .INC. 4 4- On October 25,2Q05, Plaintiff FLORENTINE and RODNEY ABBOTT 5 (hereinBfter '^PLAINTIFFS") and Defendant RICHARD K. ROYBALID dba CA 6 CONSTRUCTION (hereinafler "CA CONSTRUCTION") entered into a contiact for constmction 7 services at PLAINTIFFS' home located at S601 Rolling Green Way in Fair Oaks, Sacramento 8 County, CaUfomia. R4C0RP, INC. was hot a party to the contract between PLAINTIFFS and 9 CA CONSTRUCTION. 10 5. R4C0RP, INC. did not enter into any other contracts with PJLAINTIFFS, or any of 11 the other p.arfies, which are the subject of this action. 12 6. R4C0RP, INC. performed no .duties or services under any of the contracts that are 13 the subject ofthis action. 14 7. Nani Keeshan is currently a part-time bookkeeper for R4CORP.5 INC. She works 15 at R4C0RP., INC. two (2) days a Week, 16 8, I ara informed and believetiiatNani Keeshan was served with PLAINTIFFS' 17 Amended Summons, Amendment to Second Amended Complaint, and Second Amended 18 Complaint on May 11, 2010 while working as the part-time bookkeeper for R4C0RP., TNC. 19 9. Nani .Keeshan is not currently and never has been the office manager for 20 R4CORP., INC. 21 10. Nani Keeshan is not currently ahd never has been an officer of R4C0RP,, INC. 22 11. Nani Keeshan is not currently and never has been the authorized agent for service 23 of process for R4CORP., TNC. 24 12. Pursuant to the Articles of Incorporation on file with the Califomia Secretary of 25 State, I am the sole coiporate officer for R4C0RP., INC. I am the only authorized agent for 26 service of process for R4C0RP., INC. 27 1 3 . 1 have never authorized Nani Keeshan to accept service of process on behalf of 28 R4C0RP., INC. N;C54?/974783-i 2 DECLARATION OF RUYBALID IN SUPPORT OF R4C0RP., INC'S MOTION TO QUASH/STRIKE SERVICE OF DOE AMENDMENT 1 14. I have never been personally served with PLAINTIFFS' Amended Summons, 2 Amendment to Second Amended Coniplaint, and Second Amended Complaint as the authorized 3 agent for service of process for R4C0RP., INC. 4 5 I declare under penalty of perjtiry under the laws ofthe State .ofCalifomia tiiat the 6 foregoing is trae and correct. Executed this Qf day of June, 2010, at Sacraroento, California. 7 8 9 10 li n 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 N1C549/974783-I DECLARATION OF RUYBALID IN SUPPORT OF R4C0RP. FNC'S MOTION TO QUASH/STRIKE SERVICE OF DOE AMENDMENT