Motion-Secondary: Rodney Abbott, et al vs. Ronald Paul Britschgi, et al

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 1   Todd A. Jones (BarNo. 198024)
     tj ones@archemorris .com
2    J. Michaei McGuire (Bar No. 117618)
     mmcguire@archemorr is .com
 3   Gregory K. Federico (BarNo. 242184)                          ILED/ENDORSED
     gfederico@archemorris.com
4    ARCHERNORRIS
     A Professional Law Corporation
 5   655 University Avenue, Suite 225
     Sacramento, Cahfomia 95825-6747
 6   Telephone:     916.646.2480
     Facsimile:     916.646.5696
 7
     Attomeys for Defendant
 8   R4C0RP, INC., a Califomia Corporation
 9
                                        SUPERIOR COURT OF CALIFORNL\
10
                                          COUNTY OF SACRAMENTO
11

12
     RODNEY ABBOTT and FLORENTINE                      CaseNo. 07AS04450
13   ABBOTT,
                                                       DECLARATION OF NANI KEESHAN IN
14                        Plaintiffs,                  SUPPORT OF DEFENDANT R4C0RP.,
                                                       INC.'S MOTION TO QUASH/STRIKE
15                                                     SERVICE OF DOE AMENDMENT

16   RONALD PAUL BRITSCHGI, et al.,                    Date: October 29, 2010
                                                       Time: 2:00 p.m.
17                        Defendants.                  Dept: 53

18

19                                                     Action Filed: September 24,2007

20   AND RELATED CROSS-ACTIONS.

21

22            I, Nani Keeshan, declare as follows:

23            1.       I am currently a part-time bookkeeper for Defendant R4C0RP., INC., which is

24   located at 9332 Fair Oaks Boulevard in Fair Oaks, Califomia. I currently work at R4C0RP., INC.

25   two (2) days a week. I am also employed as a part-time bookkeeper for a company named Aloha

26   Roofing in North Highlands, Califomia. I currently work at Aloha Roofing three (3) days a week.

27   The matters stated in this declaration are trae to my own personal knowledge, and ifcalled upon

28   to testify, I could and would testify competentiy thereto.
     NIC549/974757-1

       DECLARATION OF NANI KEESHAN IN SUPPORT OF R4C0RP., INC 'S MOTION TO QUASH/STRIKE
                                SERVICE OF DOE AMENDMENT
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           1             2.        I am a resident of Sacramento County.
          2              3.        On May 11, 2010,1 was served with Plaintiffs FLORENTINE ABBOTT and
          3     RODNEY ABBOTT'S (hereinafler "PLAINTIFFS") Amended Summons, Amendment to Second
          4     Amended Complaint, and Second Amended Complaint while performing my duties as the part-
          5     time bookkeeper at R4C0RP., INC.

          6              4.        I am not cunrently tiic office manager for R4C0RP., INC.
          7              5.        I am not currently and never bave been an officer of R4C0RP., INC.
          8              6.        I am not currently and never have been tiie authorized agent for service of process
          9     forR4CORP.,INC.
         10              7.        Richard K. Ruybahd, the sole corporate officer for R4C0RP., INC., ha.<} not
         11     authorized me to accept service of process on behalf of R4C0RP., TNC. at any point in time.
         12              8.        Prior to being served witii PLAINTIFFS' Amended Summons, Amendment to
         13     Second Amended Complaint, and Second Amended Complaint, the process server asked me
         14     whether thc office T was working in was the ofRce fbr R4C0RP., INC T indicated it was the
         15     ofSce for R4C0RP., INC. Thereafter, I was served witii the documents by the process server.
         16     The process server did not ask me any other questions, including who the agent for service of
         17     ptocess for R4C0RP., INC. was or whetiier I was the agent fbr service of process for R4C0RP.,
         18     INC.

         19
         20              I declare uoder penalty ofperjury under the laws ofthe State of CaUfornia that the

         21     foregoing is tme and correct. Executed tiiis /(fday of .Tune, 2010, at Sacramento, Califomia.

         22
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         24                                                       NANI

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                N1C549/974757-I

                   DECLARATION OF NANI KEESHAN IN SUPPORT OF R4C0RP., INC'S MOTION TO QUASH/STRJKE
                                            SERVICE OF DOE AMENDMENT