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SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Jan-29-2014 3:20 pm
Case Number: CGC-13-531852
Filing Date: Jan-29-2014 3:20
Filed by: WESLEY G. RAMIREZ
Juke Box: 001 Image: 04359197
DECLARATION
IBARRA PROFESSIONAL LAW CORPORATION VS. ELENA DENING
001004359197
Instructions:
Please place this sheet on top of the document to be scanned.Crisostomo G. Ibarra (SBN: 103480)
Ibarra Professional Law Corporation
459 Fulton Street, Suite 109 :
San Francisco, CA 94102 F dade. D
Tel No. (415) 398-5329
Fax No. (415) 398- 6831 JAN 23201
Attorney for Plaintiff CLERK
Ibarra Professional Law Corporation BY:
SUPERIOR COURT OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO
Case No. CGC-13-531852
IBARRA PROFESSIONAL LAW
CORPORATION,
DECLARATION OF COUNSEL IN
Plaintiff, RESPONSE TO 02-04-14 ORDER TO
SHOW CAUSE
vs.
Date: 02-04-14
ELENA DENING, Time: 10:30 A.M.
Dept. 610
Defendant. Judge: The Hon. Cynthia M. Lee
I, Crisostomo G. Ibarra, declare:
1. I am the attorney for the above Plaintiff.
2. S&R Services, a licensed professional process server was engaged in June 2013 tol
effect service of process on defendant Elena Dening.
3. Attempts on service were made on 06/07, 10, 17, 18, 2013 and on 07/08, and
07/11, 13, 19, 22, 25, 28 and 30, 2013. The process server was informed that defendant had
moved. Attached as Exhibit “A” is a true and correct copy of the email dated 07/22/2013 from
S&R Services.
4. Further attempts were made on 08/09/2013, but the address was bad.
5. Plaintiff seeks a 90-day continuance to locate defendant and have service effected.
DECLARATION OF COUNSEL IN RESPONSE TO 02-04-14 ORDER TO SHOW CAUSE 1—_
6. Otherwise, Plaintiff would seek an order for publication of Summons, in that
defendant was observed this summer 2013 to still be in San Francisco, California.
7. Attached hereto as Exhibit “B” is a true and correct copy of the Invoice Number
CRIBA.69732.
8. Attached hereto as Exhibit “C” is a true and correct copy of the Affidavit of
Reasonable Diligence dated 08/09/2013.
9. In December 2013 and January 2014, the court records were viewed to ascertain
Defendant’s last known address. The record showed that such is at 27 Diaz Street in San
Francisco, California. However, the licensed process server was sent to that address previously
and was informed Defendant was no longer there and had left no forwarding address.
I declare under penalty of perjury that the above it true and correct. Executed in San
C3
Crisostomo G. Ibarra
Attorney for Plaintiff
IBARRA PLC
Francisco, CA on January 29, 2014.
DECLARATION OF COUNSEL IN RESPONSE TO 02-04-14 ORDER TO SHOW CAUSE 2Mail :: Inbox: ELENA DENING[069732] ©}
Toft
https: //ibarraple.conMQ>6/cpsess53677 16729/horde/imp/message.ph...
From: orders@served-u.com
To: annia.velasquez@ibarraplc.com
Subject: ELENA DENING[069732]
Information Provided By: S&R Services
This E-Mail Is To Provide Status Only. Do NOT Use For An Invoice or Proof
STATUS REPORT - Service In Progress On:, on: ELENA DENING
INVOICE #: 69732, Deposit $55.00
Case #: CGC-13-531852
Court: SAN FRANCISCO COUNTY SUPERIOR COURT
Title: IBARRA PROFESSIONAL LAW CORPORATION Vs. ELENA DENING
SUMMONS (AND) COMPLAINT CIVIL CASE COVER SHEET;ADR INFORMATION PACKAGE; BLANK STIPULATION
TO ADR;, by serving: +
Attempt #1, Date: 06/07/13, Time: 12:30pm, Location: Home
Results: NO ANSWER. QUIET INSIDE. Attempt made by: CAESAR RAILEY. Attempt at: 27 DIAZ
AVENUE San Francisco CA 94132.
Attempt #2, Date: 06/10/13, Time: 8:05pm, Location: Home
Results: PER FEMALE VOICE (HAD HISPANIC/SPANISH ACCENT) THE SUBJECT IS UNKNOWN. SHE
REFUSED TO OPEN THE DOOR OR ANSWER FURTHER QUESTIONS. Attempt made by: CAESAR RAILEY.
Attempt at: 27 DIAZ AVENUE San Francisco CA 94132.
Attempt #3, Date: 06/17/13, Time: 10:00am, Location: Home
Results: PER CLIENT ATTEMPT AT THE WORK ADDRESS. Attempt made by: TIFFANY JENSEN. Attempt
at: 27 DIAZ AVENUE San Francisco CA 94132.
Attempt #4, Date: 06/18/13, Time: 9:50am, Location: Business
Results: SECURITY STATED THEY NEED TO KNOW WHAT DEPARTMENT THE SUBJECT IS IN. HE CHECKED
HIS LIST AND DATABASE, THE SUBJECT IS NOT LISTED AS AN EMPLOYEE. Attempt made by: andy
Esquer, Registration #1009 San Francisco County. Attempt at: CITY AND COUNTY OF SAN
FRANCISCO 1650 MISSION STREET San Francisco CA 94103.
Attempt #5, Date: 07/08/13, Time: 9:00am, Location: Business
Results: PER CLIENT ATTEMPT AT: 3101 MISSION STREET, APT. #502, SAN FRANCISCO CA 94110.
Attempt made by: TIFFANY JENSEN. Attempt at: CITY AND COUNTY OF SAN FRANCISCO 1650
MISSION STREET San Francisco CA 94103.
Attempt #6, Date: 07/11/13, Time: 7:08pm, Location: Home
Results: NO ANSWER AT FRONT DOOR. NAME IS NOT LISTED ON DIRECTORY. Attempt made by:
CAESAR RAILEY. Attempt at: 3101 MISSION STREET, APT. 502 San Francisco CA 94110.
Attempt #7, Date: 07/13/13, Time: 10:05am, Location: Home
Results: NO ANSWER AT FRONT DOOR. Attempt made by: CAESAR RAILEY. Attempt at: 3101
MISSION STREET, APT. 502 San Francisco CA 94110.
Attempt #8, Date: 07/19/13, Time: 12:35pm, Location: Home
Results: NO ANSWER AT FRONT DOOR. Attempt made by: CAESAR RAILEY. Attempt at: 3101
MISSION STREET, APT. 502 San Francisco, CA 94110.
Attempt #9, Date: 07/22/13, Time: 6:10pm, Location: Home
Results: NO ANSWER AT FRONT DOOR. Attempt made by: CAESAR RAILEY. Attempt at: 3101
MISSION STREET, APT. 502 San Francisco, CA 94110.
Note #1, Date: 07/15/13, Time: 11:13am - THIS IS A STATUS UPDATE, WE ARE STILL ATTEMPTING
SERVICE. THANK YOU!
[10.07] [] (69732. 59692) (b11)Tiffany Jensenre
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CRISOSTOMO G. IBARRA
IBARRA PROFESSIONAL LAW CORPORATION
459 FULTON STREET #109
San Francisco CA 94102
Friday August 09, 2013 INVOICE CRIBA.69732
Case #: CGC-13-531852
Court: SAN FRANCISCO COUNTY SUPERIOR COURT
Title: IBARRA PROFESSIONAL LAW CORPORATION vs. ELENA DENING
Documents: SUMMONS (AND) COMPLAINT; CIVIL CASE COVER SHEET;ADR INFORMATION
PACKAGE; BLANK STIPULATION TO ADR;
Date Description Amount
08/09/13 Returned Not Served: ELENA DENING, AT Home 3101 MISSION STREET,
01:00PM APT. 502 San Francisco, CA 94110, Returned By: CAESAR RAILEY.
06/04/13 Deposit On Services Check Number: 3348, Thank You! -55.00
08/09/13 ATTEMPT SERVICE/BAD ADDRESS 55.00
08/09/13. ATTEMPT SERVICE/BAD ADDRESS 55.00
PLEASE PAY FROM THIS INVOICE 55.00
903 Sneath Lane, Suite 227, San Bruno, CA 94066,
Telephone: (650) 794-1923, FAX: (650) 989-4182, Tax ID: 26-4161879
AI 40 one(Attorney or Party without Attorney: © ° For Court Use Only
CRISOSTOMO G. IBARRA, Bar #103480
IBARRA PROFESSIONAL LAW CORPORATION
459 FULTON STREET #109
San Francisco, CA 94102
Telephone No: 415-398-5329 FAX: No: 415-398-6831
(Ref. No or File No.>
Attorney for: Plaintiff
[insert name of Court, and Judicial District and Branch Court:
SAN FRANCISCO COUNTY SUPERIOR COURT
Plaintiff: TBARRA PROFESSIONAL LAW CORPORATION
Defendant ELENA DENING.
AFFIDAVIT OF |Hearing Date: Time: DepwDiv: Case Number:
REASONABLE DILIGENCE CGC-13-531852
1, I, CAESAR RAILEY, and any employee or independent contractors retained by S&R Services are and were on the dates
mentioned herein over the age of eighteen years and not a party to this action. Personal service was attempted on Defendant
ELENA DENING as follows:
2. Documents: SUMMONS (AND) COMPLAINT; CIVIL CASE COVER SHEET;ADR INFORMATION
PACKAGE;BLANK STIPULATION TO ADR;.
[Day Date Time | Location | Results ]
Fri 06/07/13. 12:30pm += Home NO ANSWER. QUIET INSIDE. Attempt made by: CAESAR RAILEY. Attempt
at: 27 DIAZ AVENUE San Francisco CA 94132.
Mon 06/10/13 8:05pm Home PER FEMALE VOICE (HAD HISPANIC/SPANISH ACCENT) THE SUBJECT IS
UNKNOWN. SHE REFUSED TO OPEN THE DOOR OR ANSWER FURTHER
QUESTIONS. Attempt made by: CAESAR RAILEY. Attempt at: 27 DIAZ
AVENUE San Francisco CA 94132.
Mon 06/17/13 10:00am Home PER CLIENT ATTEMPT AT THE WORK ADDRESS. Attempt made by:
TIFFANY JENSEN. Attempt at: 27 DIAZ AVENUE. San Francisco CA 94132.
Tue 06/18/13 9:50am Business SECURITY STATED THEY NEED TO KNOW WHAT DEPARTMENT THE
SUBJECT IS IN. HE CHECKED HIS LIST AND DATABASE, THE SUBJECT
IS NOT LISTED AS AN EMPLOYEE. Attempt made by: Andy Esquer,
Registration #1009 San Francisco County. Attempt at: CITY AND COUNTY OF
SAN FRANCISCO 1650 MISSION STREET San Francisco CA 94103.
Mon 07/08/13 9:00am —_ Business PER CLIENT ATTEMPT AT: 3101 MISSION STREET, APT. #502, SAN
FRANCISCO CA 94110. Attempt made by: TIFFANY JENSEN. Attempt at: CITY
AND COUNTY OF SAN FRANCISCO 1650 MISSION STREET San Francisco
CA 94103.
Page Number 1
\ Date: Fri, Aug. 09, 2013 AFFIDAVIT OF REASONABLE DILIGENCE criba.69732|Attorney or Party without Attorney:
San Francisco, CA 94102
Telephone No: 415-398-5329
CRISOSTOMO G. IBARRA, Bar #103480
IBARRA PROFESSIONAL LAW CORPORATION
459 FULTON STREET #109
FAX: No: 415-398-6831
For Court Use Only
(Ref. No or File No.:
Attorney for: Plaintiff
Insert name of Court, and Judicial District and Branch Court:
SAN FRANCISCO COUNTY SUPERIOR COURT
Plaintiff: TRARRA PROFESSIONAL LAW CORPORATION
|Defendant-BLENA-DENING
AFFIDAVIT OF Hearing Date: Time: Dept/Div: Case Number:
REASONABLE DILIGENCE CGC-13-531852
(Day Date Time [ Location [Results
Thu = 07/11/13 7:08pm Home NO ANSWER AT FRONT DOOR. NAME IS NOT LISTED ON DIRECTORY.
Attempt made by: CAESAR RAILEY. Attempt at: 3101 MISSION STREET, APT.
502 San Francisco CA 94110.
Sat 07/13/13. 10:05am Home NO ANSWER AT FRONT DOOR. Attempt made by: CAESAR RAILEY. Attempt
at: 3101 MISSION STREET, APT. 502 San Francisco CA 94110.
Fri 07/19/13 12:35pm ~— Home NO ANSWER AT FRONT DOOR. Attempt made by: CAESAR RAILEY. Attempt
at: 3101 MISSION STREET, APT. 502 San Francisco, CA 94110.
Mon 07/22/13 6:10pm Home NO ANSWER AT FRONT DOOR. Attempt made by: CAESAR RAILEY. Attempt
at: 3101 MISSION STREET, APT. 502 San Francisco, CA 94110.
Thu 07/25/13 8:26pm Home COULD NOT GAIN ACCESS. WAITED 10 MINUTES. Attempt made by:
CAESAR RAILEY. Attempt at: 3101 MISSION STREET, APT. 502 San
Francisco, CA 94110.
Sun 07/28/13. 11:58am = Home PER MALE OCCUPANT, THIS IS THE M. MELKIN RESIDENCE. THE
SUBJECT IS UNKNOWN. SPOKE TO THE MANAGER WHO CONFIRMED
THE SUBJECT MOVED. NO FORWARDING KNOWN. Attempt made by:
CAESAR RAILEY. Attempt at: 3101 MISSION STREET, APT. 502 San
Francisco, CA 94110.
Tue 07/30/13 10:00am Home SERVICE PLACED ON A ONE WEEK HOLD PENDING A RESPONSE FROM
Page Number 2
THE CLIENT. CLIENT SENT HOLD NOTIFICATION.; Attempt made by:
TIFFANY JENSEN. Attempt at: 3101 MISSION STREET, APT. 502 San
Francisco, CA 94110.[Attorney or Party without Atiorney: © For Court Use Only
CRISOSTOMO G. IBARRA, Bar #103480 .
‘| IBARRA PROFESSIONAL LAW CORPORATION
459 FULTON STREET #109
San Francisco, CA 94102
Telephone No: 415-398-5329 FAX: No: 415-398-6831
Ref. No or File No.:
[Attorney for: Plaintiff
Unsert name of Court, and Judicial District and Branch Court:
SAN FRANCISCO COUNTY SUPERIOR COURT
Plaintiff: TBARRA PROFESSIONAL LAW CORPORATION
| Defondart-BLENA-DENING
AFFIDAVIT OF [Hearing Date: Time: Dept/Div: Case Number:
REASONABLE DILIGENCE CGC-13-531852
[Day Date Time | Location [Results ]
Fri 08/09/13. 10:00am =~ Home SERVICE HOLD EXPIRED. CANCEL & RETURN.; Attempt made by:
TIFFANY JENSEN. Attempt at: 3101 MISSION STREET, APT. 502 San
Francisco, CA 94110.
Fri 08/09/13 1:00pm Home Returned Not Served on: ELENA DENING Home - 3101 MISSION STREET,
APT. 502 San Francisco, CA 94110
3. Person Executing Recoverable Costs Per CCP 1033.5(a(4)(B)
a. CAESAR RAILEY @. The Fee for service was: $110.00
b. S&R Services e.lam: (3) registered California process server
903 Sneath Lane, Suite 227 (j) Independent Contractor
San Bruno, CA 94066 (ii) Registration No.: 1030
©. (650) 794-1923, FAX (650) 989-4182 (iii) County: Alameda
4. I declare under penalty of perjury under the laws of the State of California that the, ing is ‘correct.
Date: Fri, Aug. 09, 2013
Page Number 3
AFFIDAVIT OF REASONABLE DILIGENCE(CAESAR RAILEY)
eriba.69732