Preview
LD-P402
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slate bar number, and address): FOR COURT USE ONLY
Neil S. Steiner, Esq. SBN 98606
Steiner & Libo, Professional Corporation
433 N. Camden Drive Suite 730
ELECTRONICALLY
Beverly Hills, CA 90210
TELEPHONE NO.: 310-273-7778 310-273-7679
FAX NO. (Optional): F I L E D
Superior Court of California,
E-MAIL ADDRESS (Optional): steinlibo@aol.com
County of San Francisco
ATTORNEY FOR (Name): Cross-Complainant, Jared Boyd
NAME OF COURT: Superior Court of California County of San Francisco
04/21/2020
Clerk of the Court
STREET ADDRESS: 400 McAllister BY: MADONNA CARANTO
MAILING ADDRESS: 400 McAllister Deputy Clerk
CITY ANp ZIP CODE:San Francisco, CA 94102
BRANCH NAME: Unlimited Jurisdiction
SHORT TITLE: Chen v. Boyd
CROSS-COMPLAINANT: Jared Boyd
CROSS-DEFENDANT: Rona Chen and Roes 1 to 25, inclusive
El DOES 'I TO
CROSS-COMPLAINT — Personal Injury, Property Damage, Wrongful Death
El AMENDED (Number):
Causes of Action (check all that apply):
Apportionment of Fault ni Declaratory Relief
11 indemnification allOther (specify): Motor Vehicle and
General Negligence
Jurisdiction (check all that apply): CASE NUMBER:
ACTION IS A LIMITED CIVIL CASE ($25,000 or less) CGC-20 -582662
LK.] ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000)
It is Lxj is not reclassified as unlimited by this cross-complaint
I. CROSS-COMPLAINANT (name): Jared Boyd
alleges causes of action against CROSS-DEFENDANT (name): Rona Chen and Roes 1 to 25, inclusive
2, This pleading, including exhibits and attachments, consists of the following number of pages:Five
3. Each cross-complainant named above is a competent adult
a i except cross-complainant (name):
(3) Li a corporation qualified to do business in California
(2) Ian unincorporated entity (describe):
(3) f j a public entity (describe):
(4) 1 -la minor r an adult
(a) for whom a guardian or conservator of the estate or a guardian ad !item has been appointed
(b) other (specify):
(6) other (specify):
information about additional cross-complainants who are not competent adults is contained In Cross-Complaint —Attachment 3.
Pa e1of3
Form Approved for Optimal Use Code of Civil Procedure, 5 426.12
Judicial Council of California CROSS-COMPLAINT—Personal Injury, Soll
PLD-PI-0021Rev. January 1, 20071 Property Damage, Wrongful Death ug
Ltk
PLD-PI-002
1._SHORT TITLE: Chen V. Boyd.
4. Each cross-defendant named above is a natural person
CASE NUMBER:
CGC-20-582662
a. 1_,J except cross-defendant (name): b. except cross-defendant (name):
(1) 1 a business organization, form unknown (1) L j a business organization, form unknown
(2) [ a corporation (2) U a corporation
(3) 1 an unincorporated entity (describe): (3)Ei an unincorporated entity (describe):
(4) L_ J a publio entity (describe): (4) 1 I a public entity (describe):
(5) I other (specify): (5) other (specify):
I I Information about additional cross-defendants who are not natural persons is contained in Cross-Complaint—Attachment 4.
5. The true names and capacities of cross-defendants sued as Does are unknown to cross-complainant.
6 Ti Cross complainant is required to comply with a claims statute, and
a. has complied with applicable claims statutes, or
b. [ is excused from complying because (specify):
7. Cause of Action—IndemnifIcatIon
(NUMBER)
a. Cross-defendants were the agents, employees, co-ventures, partners, or in some manner agents or principals, or both,
for each other and were acting within the course and scope of their agency or employment
b. The principal action alleges among other things, conduct entitling plaintiff to compensatory damages against me.I contend
that I am not liable for events and occurrences described in plaintiffs complaint.
c. If I am found in some manner responsible to plaintiff or to anyone else as a result of the incidents and occurrences described
in plaintiffs complaint, my liability would be based solely upon a derivative form of liability not resulting from my conduct,
but only from an obligation Imposed upon me by law; therefore, I would be entitled to complete indemnity from each
cross-defendant.
S. Cause of Action—Apportionment of Fault
(NUMBER)
a. Each cross-defendant was responsible, in whole or in part, for the injuries, if any, suffered by plaintiff.
b. If l am judged liable to plaintiff, each cross-defendant should be required: (1) to pay a share of plaintiffs judgment which is
in proportion to the comparative negligence of that cross-defendant in causing plaintiff's damages; and (2) to reimburse me
for any payments I make to plaintiff in excess of my proportional share of ail cross-defendant& negligence.
PLD-P1•002 [Rev. January 1, 20071 Pago 2 of 3
CROSS-COMPLAINT—Personal Injury,
Property Damage, Wrongful Death
PLD-PI-002
1._SHORT TITLE:
9.
Chen v, Boyd
Cause of Action—Declaratory Relief
CASE NVMSER:
CGC-20-582662
(NUMBER)
An actual controversy exists between the parties concerning their respective rights and duties because cross-complainant
contends and cross-defendant disputes I as specified in Cross-Complaint—Attachment 9
as follows:
10. Cause of Action—(specify):
(NUMBER)
11. r---1The following additional causes of action are attached and the statements below apply to each (in each of the attachments,
"plaintiff" means "cross-complainant" and "defendant" means "cross-defendant,:
a. Ell Motor Vehicle
b. I General Negligence
C. Intentional Tort
d. Products Liability
e. Premises Liability
f. Other (specify):
12. CROSS-COMPLAINANT PRAYS for judgment for costs of suit; for such relief as is fair, just, and equitable; and for
a. rn total and complete indemnity for any Judgments rendered against me.
b judgment in a proportionate share from each cross-defendant.
c FT a judicial determination that cross-defendants were the legal cause of any injuries and damages sustained by plaintiff
and that cross-defendants indemnify me, either completely or partially, for any sums of money which may be recovered
against me by plaintiff.
d. IX compensatory damages
(1) (unlimited civil cases) according to proof.
(2) (limited civil cases) in the amount of:
$
e. other (specify):
13. 1 1 The paragraphs of this cross-complaint alleged on information and belief are as follows (specify paragraph numbers):
Date: April 16, 2020
Neil S, Steiner, Esq. spq
(TYPE OR PRINT NAME)
98606 Aid (SIGNATURE OF CROSS-COMPLAINANT OR ATTORNEY)
PLO-PI-002 [Rev. January 1, 2007) CROSS-COMPLAINT—Personal Injury, Page 3 of 3
Property Damage, Wrongful Death
PLp.pi-ooi
SHORT TITLF: Boyd v. Chen CASE NUMBER:
CGC-20-582662
First CAUSE OF ACTION—Motor Vehicle
(number)
ATTACHMENT TO L I Complaint n Cross - Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name): Cross-Complainant, Jared Boyd
MV-1. Plaintiff alleges the acts of defendants were negligent;
the acts were the legal (proximate) cause of injuries
and damages to plaintiff; the acts occurred
on (date): On. May 6, 2018
at (place): At or near Laguna Street and Fell Street in the City of San
Francisco and in the county of San Francisco
MV-2. DEFENDANTS
a. 1The defendants who operated a motor vehicle are (names):
Does to
11The defendants who employed the persons who operated a motor vehicle in the course of their employment
are (names):
goes to
The defendants who owned the motor vehicle which was operated with their permission are (names):
Does to
d. I The defendants who entrusted the motor vehicle are (names):
Does to
e. I xIThe defendants who were the agents and employees of the other defendants and acted within the scope
of the agency were (names):
Does 1 to 25, inclusive
f. x The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are
1 1 listed in Attachment MV-2f X as follows:
Cross-Complainant is ignorant of the true names and capacities of defendants sued herein as Roes 1 to 25, inclusive and therefore sue Cross-
is informed and believes therefore alleges that each of the defendants designated
Defendants by such fictitious names. Cross-Complainant
herein as a ROB is legally responsible in some manner for the events and happenings heroin referred to, and caused injury and damages
proximately thereby to Cross-Complainant. Cross-Complainant will amend this complaint to allege tell true names and capacities of said
Defendants when ascertained.
IX Does 1 to 25, Inclusive Page 1 of 1
Form Approved for Optional Use Code of CIA Procedure 425.12
Judicial Council of California CAUSE OF ACTION—Motor Vehicle
PL.D.P1-001(1) [Rev. January 1, 20071 Sofirt aIns-
ra„ us
PLD-PI-001(2)
SHORT TITLE: Boyd v. Chen CASE NUMBER:
CGC-20-582662
Second CAUSE OF ACTION—General Negligence Page Five
(number)
ATTACHMENT TO I Complaint X Cross - Complaint
(Use a separate cause of action form for each cause of action.)
GN-1. Plaintiff (name): Cross -Complainant, Jared Boyd
alleges that defendant (name): Cross -Def endant Rona Chen, an individual and Roes
to 25, inclusive
F 1 Does to
was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant
negligently caused the damage to plaintiff
on (date): May 6, 2018
at (place): at or near the Laguna Street and Fell Street intersections, in
the City of San Francisco and within the County of San Francisco
(description of reasons for liability):
Cross-Defendant, was negligently, carelessly, and recklessly, running within the
street so as to cause an accident which resulted in personal injuries and
property damages to Cross-Complainant, Jared Boyd, which is the subject matter
of the within cross-complaint.
Page101
Form Approved for Optional Use T al Code of Civil Procedure 425.12
Judicial Council of California
PLD-P I-001(2) (Rev. January 1, 2007)
CAUSE OF ACTION—General Negligence &plans-
Ca Plus
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA ))
) ss::
ss
3
COUNTY OF CONTRA COSTA ))
4
I am employed in the County of Contra Costa, State of California, I am over the age of
5 18 and not a party to the within action; my business address is 2300 Clayton Road,
Suite 430, Concord, CA 94520-2142.
6
On April 21, 2020, I served the foregoing document described as SUMMONS & CROSS-
7 COMPLAINT on the
COMPLAINT parties in this action by placing a true copy thereof enclosed in a sealed
envelope addressed as follows:
8
9 SEE ATTACHED SERVICE LIST
10 BY MAIL: I am "readily familiar" with the firm's practice of collection and processing
correspondence for mailing. Under that practice it would be deposited with U.S. postal
11 service on that same day with postage thereon fully prepaid at Concord, California, in
12 the ordinary course of business. I am aware that on motion of the party served, service
is presumed invalid if postal cancellation date or postage meter date is more than one
13 day after date of deposit for mailing in affidavit.
14 BY PERSONAL SERVICE: I caused such envelope to be delivered by hand to the
offices of the addressee.
15
16 BY OVERNIGHT MAIL: I arranged for such envelope to be delivered to the addressees
as listed on the service list.
17
BY FACSIMILE: In addition to regular mail, I sent this document via facsimile to the
18 numbers as listed on the service list and pursuant to CCP CCP §1013(e).
19 
IZI BY ELECTRONIC SERVICE: I sent this document via electronic transmission to the
offices of the addressees as listed on the service list and pursuant to CCP CCP §1010.6.
20
21

RI (State) I declare under penalty of perjury under the laws of the State of California that
the above is true and correct.
22
(Federal) I declare that I am employed in the office of a member of the bar of this court
23 at whose direction the service was made.
24 Executed on April 21, 2020, at Concord, California.
25
00,4,4 411,110.4,1
26 Cassidi M. Ryan
27
28
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PROOF OF SERVICE
1 SERVICE LIST
2
Ross McKissick, Esq.
3 Harris Personal Injury Lawyers, Inc.
ELECTRONICALLY SERVED TO:
4 ross@harrispersonalinjury.com
99 Osgood Place, Suite 100
5 San Francisco, CA 94133
(415) 495-0440/(415) 495-0444 (F)
6 Attorney for Plaintiff
RONA CHEN
7
Neil S. Steiner, Esq.
8 Steiner & Libo
ELECTRONICALLY SERVED TO:
9 jamesm@steinerlibo.com;steinlibo@aol.com
433 North Camden Drive, Suite 730
10 Beverly Hills, CA 90210
(310) 273-7778
11 Attorney for Cross-Complainant
JARED BOYD
12
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PROOF OF SERVICE
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LD-P402 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, slate bar number, and address): FOR COURT USE ONLY Neil S. Steiner, Esq. SBN 98606 Steiner & Libo, Professional Corporation 433 N. Camden Drive Suite 730 ELECTRONICALLY Beverly Hills, CA 90210 TELEPHONE NO.: 310-273-7778 310-273-7679 FAX NO. (Optional): F I L E D Superior Court of California, E-MAIL ADDRESS (Optional): steinlibo@aol.com County of San Francisco ATTORNEY FOR (Name): Cross-Complainant, Jared Boyd NAME OF COURT: Superior Court of California County of San Francisco 04/21/2020 Clerk of the Court STREET ADDRESS: 400 McAllister BY: MADONNA CARANTO MAILING ADDRESS: 400 McAllister Deputy Clerk CITY ANp ZIP CODE:San Francisco, CA 94102 BRANCH NAME: Unlimited Jurisdiction SHORT TITLE: Chen v. Boyd CROSS-COMPLAINANT: Jared Boyd CROSS-DEFENDANT: Rona Chen and Roes 1 to 25, inclusive El DOES 'I TO CROSS-COMPLAINT — Personal Injury, Property Damage, Wrongful Death El AMENDED (Number): Causes of Action (check all that apply): Apportionment of Fault ni Declaratory Relief 11 indemnification allOther (specify): Motor Vehicle and General Negligence Jurisdiction (check all that apply): CASE NUMBER: ACTION IS A LIMITED CIVIL CASE ($25,000 or less) CGC-20 -582662 LK.] ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) It is Lxj is not reclassified as unlimited by this cross-complaint I. CROSS-COMPLAINANT (name): Jared Boyd alleges causes of action against CROSS-DEFENDANT (name): Rona Chen and Roes 1 to 25, inclusive 2, This pleading, including exhibits and attachments, consists of the following number of pages:Five 3. Each cross-complainant named above is a competent adult a i except cross-complainant (name): (3) Li a corporation qualified to do business in California (2) Ian unincorporated entity (describe): (3) f j a public entity (describe): (4) 1 -la minor r an adult (a) for whom a guardian or conservator of the estate or a guardian ad !item has been appointed (b) other (specify): (6) other (specify): information about additional cross-complainants who are not competent adults is contained In Cross-Complaint —Attachment 3. Pa e1of3 Form Approved for Optimal Use Code of Civil Procedure, 5 426.12 Judicial Council of California CROSS-COMPLAINT—Personal Injury, Soll PLD-PI-0021Rev. January 1, 20071 Property Damage, Wrongful Death ug Ltk PLD-PI-002 1._SHORT TITLE: Chen V. Boyd. 4. Each cross-defendant named above is a natural person CASE NUMBER: CGC-20-582662 a. 1_,J except cross-defendant (name): b. except cross-defendant (name): (1) 1 a business organization, form unknown (1) L j a business organization, form unknown (2) [ a corporation (2) U a corporation (3) 1 an unincorporated entity (describe): (3)Ei an unincorporated entity (describe): (4) L_ J a publio entity (describe): (4) 1 I a public entity (describe): (5) I other (specify): (5) other (specify): I I Information about additional cross-defendants who are not natural persons is contained in Cross-Complaint—Attachment 4. 5. The true names and capacities of cross-defendants sued as Does are unknown to cross-complainant. 6 Ti Cross complainant is required to comply with a claims statute, and a. has complied with applicable claims statutes, or b. [ is excused from complying because (specify): 7. Cause of Action—IndemnifIcatIon (NUMBER) a. Cross-defendants were the agents, employees, co-ventures, partners, or in some manner agents or principals, or both, for each other and were acting within the course and scope of their agency or employment b. The principal action alleges among other things, conduct entitling plaintiff to compensatory damages against me.I contend that I am not liable for events and occurrences described in plaintiffs complaint. c. If I am found in some manner responsible to plaintiff or to anyone else as a result of the incidents and occurrences described in plaintiffs complaint, my liability would be based solely upon a derivative form of liability not resulting from my conduct, but only from an obligation Imposed upon me by law; therefore, I would be entitled to complete indemnity from each cross-defendant. S. Cause of Action—Apportionment of Fault (NUMBER) a. Each cross-defendant was responsible, in whole or in part, for the injuries, if any, suffered by plaintiff. b. If l am judged liable to plaintiff, each cross-defendant should be required: (1) to pay a share of plaintiffs judgment which is in proportion to the comparative negligence of that cross-defendant in causing plaintiff's damages; and (2) to reimburse me for any payments I make to plaintiff in excess of my proportional share of ail cross-defendant& negligence. PLD-P1•002 [Rev. January 1, 20071 Pago 2 of 3 CROSS-COMPLAINT—Personal Injury, Property Damage, Wrongful Death PLD-PI-002 1._SHORT TITLE: 9. Chen v, Boyd Cause of Action—Declaratory Relief CASE NVMSER: CGC-20-582662 (NUMBER) An actual controversy exists between the parties concerning their respective rights and duties because cross-complainant contends and cross-defendant disputes I as specified in Cross-Complaint—Attachment 9 as follows: 10. Cause of Action—(specify): (NUMBER) 11. r---1The following additional causes of action are attached and the statements below apply to each (in each of the attachments, "plaintiff" means "cross-complainant" and "defendant" means "cross-defendant,: a. Ell Motor Vehicle b. I General Negligence C. Intentional Tort d. Products Liability e. Premises Liability f. Other (specify): 12. CROSS-COMPLAINANT PRAYS for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a. rn total and complete indemnity for any Judgments rendered against me. b judgment in a proportionate share from each cross-defendant. c FT a judicial determination that cross-defendants were the legal cause of any injuries and damages sustained by plaintiff and that cross-defendants indemnify me, either completely or partially, for any sums of money which may be recovered against me by plaintiff. d. IX compensatory damages (1) (unlimited civil cases) according to proof. (2) (limited civil cases) in the amount of: $ e. other (specify): 13. 1 1 The paragraphs of this cross-complaint alleged on information and belief are as follows (specify paragraph numbers): Date: April 16, 2020 Neil S, Steiner, Esq. spq (TYPE OR PRINT NAME) 98606 Aid (SIGNATURE OF CROSS-COMPLAINANT OR ATTORNEY) PLO-PI-002 [Rev. January 1, 2007) CROSS-COMPLAINT—Personal Injury, Page 3 of 3 Property Damage, Wrongful Death PLp.pi-ooi SHORT TITLF: Boyd v. Chen CASE NUMBER: CGC-20-582662 First CAUSE OF ACTION—Motor Vehicle (number) ATTACHMENT TO L I Complaint n Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): Cross-Complainant, Jared Boyd MV-1. Plaintiff alleges the acts of defendants were negligent; the acts were the legal (proximate) cause of injuries and damages to plaintiff; the acts occurred on (date): On. May 6, 2018 at (place): At or near Laguna Street and Fell Street in the City of San Francisco and in the county of San Francisco MV-2. DEFENDANTS a. 1The defendants who operated a motor vehicle are (names): Does to 11The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): goes to The defendants who owned the motor vehicle which was operated with their permission are (names): Does to d. I The defendants who entrusted the motor vehicle are (names): Does to e. I xIThe defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): Does 1 to 25, inclusive f. x The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are 1 1 listed in Attachment MV-2f X as follows: Cross-Complainant is ignorant of the true names and capacities of defendants sued herein as Roes 1 to 25, inclusive and therefore sue Cross- is informed and believes therefore alleges that each of the defendants designated Defendants by such fictitious names. Cross-Complainant herein as a ROB is legally responsible in some manner for the events and happenings heroin referred to, and caused injury and damages proximately thereby to Cross-Complainant. Cross-Complainant will amend this complaint to allege tell true names and capacities of said Defendants when ascertained. IX Does 1 to 25, Inclusive Page 1 of 1 Form Approved for Optional Use Code of CIA Procedure 425.12 Judicial Council of California CAUSE OF ACTION—Motor Vehicle PL.D.P1-001(1) [Rev. January 1, 20071 Sofirt aIns- ra„ us PLD-PI-001(2) SHORT TITLE: Boyd v. Chen CASE NUMBER: CGC-20-582662 Second CAUSE OF ACTION—General Negligence Page Five (number) ATTACHMENT TO I Complaint X Cross - Complaint (Use a separate cause of action form for each cause of action.) GN-1. Plaintiff (name): Cross -Complainant, Jared Boyd alleges that defendant (name): Cross -Def endant Rona Chen, an individual and Roes to 25, inclusive F 1 Does to was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant negligently caused the damage to plaintiff on (date): May 6, 2018 at (place): at or near the Laguna Street and Fell Street intersections, in the City of San Francisco and within the County of San Francisco (description of reasons for liability): Cross-Defendant, was negligently, carelessly, and recklessly, running within the street so as to cause an accident which resulted in personal injuries and property damages to Cross-Complainant, Jared Boyd, which is the subject matter of the within cross-complaint. Page101 Form Approved for Optional Use T al Code of Civil Procedure 425.12 Judicial Council of California PLD-P I-001(2) (Rev. January 1, 2007) CAUSE OF ACTION—General Negligence &plans- Ca Plus 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA )) ) ss:: ss 3 COUNTY OF CONTRA COSTA )) 4 I am employed in the County of Contra Costa, State of California, I am over the age of 5 18 and not a party to the within action; my business address is 2300 Clayton Road, Suite 430, Concord, CA 94520-2142. 6 On April 21, 2020, I served the foregoing document described as SUMMONS & CROSS- 7 COMPLAINT on the COMPLAINT parties in this action by placing a true copy thereof enclosed in a sealed envelope addressed as follows: 8 9 SEE ATTACHED SERVICE LIST 10 BY MAIL: I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice it would be deposited with U.S. postal 11 service on that same day with postage thereon fully prepaid at Concord, California, in 12 the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one 13 day after date of deposit for mailing in affidavit. 14 BY PERSONAL SERVICE: I caused such envelope to be delivered by hand to the offices of the addressee. 15 16 BY OVERNIGHT MAIL: I arranged for such envelope to be delivered to the addressees as listed on the service list. 17 BY FACSIMILE: In addition to regular mail, I sent this document via facsimile to the 18 numbers as listed on the service list and pursuant to CCP CCP §1013(e). 19  IZI BY ELECTRONIC SERVICE: I sent this document via electronic transmission to the offices of the addressees as listed on the service list and pursuant to CCP CCP §1010.6. 20 21  RI (State) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 22 (Federal) I declare that I am employed in the office of a member of the bar of this court 23 at whose direction the service was made. 24 Executed on April 21, 2020, at Concord, California. 25 00,4,4 411,110.4,1 26 Cassidi M. Ryan 27 28 1 PROOF OF SERVICE 1 SERVICE LIST 2 Ross McKissick, Esq. 3 Harris Personal Injury Lawyers, Inc. ELECTRONICALLY SERVED TO: 4 ross@harrispersonalinjury.com 99 Osgood Place, Suite 100 5 San Francisco, CA 94133 (415) 495-0440/(415) 495-0444 (F) 6 Attorney for Plaintiff RONA CHEN 7 Neil S. Steiner, Esq. 8 Steiner & Libo ELECTRONICALLY SERVED TO: 9 jamesm@steinerlibo.com;steinlibo@aol.com 433 North Camden Drive, Suite 730 10 Beverly Hills, CA 90210 (310) 273-7778 11 Attorney for Cross-Complainant JARED BOYD 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 PROOF OF SERVICE