On May 10, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Paycheck, Louis,
Sarna, Punit K.,
and
Does 1-30, Inclusive,
Sarna, Puja,
Sarna, Punit K.,
for (06) Unlimited Breach of Contract/Warranty
in the District Court of San Mateo County.
Preview
8/22/2019
1 MATTHEW A. HAULK (SBN 272457)
RAGGHIANTI FREITAS LLP
1101 Fifth Avenue, Suite 100
San Rafael, California 94901
Telephone: (415) 453-9433
Facsimile: (415) 453-8269
4
Attorneys for Defendants
PUNIT K. SARNA and
PUJA SARNA
6
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
10 LOUIS PAYCHECK, CASE NO.: 19CIV02595
Plaintiff, PROOF OF SERVICE:
~ NOTICE OF MOTION FOR LEAVE TO FILE
12
vs. AMENDED CROSS-COMPLAINT AND
13 AMENDED ANSWER
PUNIT K. SARNA, et al., ~ MEMORANDUM OF POINTS AND
14 AUTHORITIES IN SUPPORT OF MOTION
Defendants. FOR LEAVE TO FILE AMENDED CROSS-
15 COMPLAINT AND AMENDED ANSWER
~ DECLARATION OF MATTHEW A. HAULK
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IN SUPPORT OF MOTION FOR LEAVE TO
FILE AMENDED CROSS-COMPLAINT
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AND AMENDED ANSWER
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DATE: October 9, 2019
TIME: 9:00 a.m.
DEPT.: 1, Courtroom 4C
20
JUDGE: Honorable Leland Davis, III
21
Complaint Filed: May 10, 2019
22 AND RELATED CROSS-ACTION. Trial Date: Not set.
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PROOF OF SERVICE
PROOF OF SERVICE
Paycheck v. Sama, et ak
San Mateo County Superior Court Case Noc 19CIV02595
4 1. At the time of service, I was at least 18 years of age and not a party to this legal action.
5 2. My business address is 1101 Fifth Avenue, Suite 100, San Rafael, CA 94901.
3. I served Copies of the Following Documents:
~ NOTICE OF MOTION FOR LEAVE TO FILE AMENDED CROSS-COMPLAINT AND
AMENDED ANSWER
~ MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR
LEAVE TO FILE AMENDED CROSS-COMPLAINT AND AMENDED ANSWER
~ DECLARATION OF MATTHEW A. HAULK IN SUPPORT OF MOTION FOR LEAVE
10
TO FILE AMENDED CROSS-COMPLAINT AND AMENDED ANSWER
12 4 Iserved the documents listedabove in Item 3 on the following persons at the addresses
listed:
13
Michael B. Allen
Grant H. Bal&er
Assaad M. Stephan
MICHAEL B. ALLEN LAW GROUP, INC.
16 66 Bovet Road, Suite 250
San Mateo, CA 94402
17 650-347-5000
T:
F: 650-340-6350
18
Attorneys for Plaintiff and Cross-Defendants
LOUIS PAYCHECK dba EUROPEAN ENTERPRISES,
SURETEC INDEMNITY COMPANY
20
5. a. By Personal Service. Ipersonally delivered the documents on the date shown below to
21 the persons at the addresses represented
listed above in Item 4. (1) For a party by an
attorney, delivery was made to the attorney or at the attorney's office by leaving the
22
documents in an envelope or package clearly labeled to identify the attorney being
23 served with a receptionist or an individual in charge of the office. (2) For a party
delivery was made to the party or by leaving the documents in the party's residence
24 between the hours of eight in the morning and six in the evening with some person
not less than 18 years of age.
25 By United States Mail. Ienclosed the documents in a sealed envelope or package, in
the mail at San Rafael, California, where Iam a resident or employee in the County of
26 Marin where the mailing occurred. Iaddressed the sealed envelope or package to the
persons at the addresses inItem 4 and (specify one):
27
(1) Deposited the sealed envelope in a United States Postal Service mailbox with
28
the postage fully prepaid on the date shown below
PROOF OF SERVICE
(2)X Placed the envelope For collection and mailing on the date shown below,
following our ordinary business practices and Iam readily familiar with this
business's practice for collecting and processing correspondence for mailing.
On the same day that correspondence is placed for collection and mailing, it
is deposited in the ordinary course of business with the United States Postal
Service, in a sealed envelope with postage fully prepaid.
c. By Overnight Delivery. Pursuant to California Rules of Court, Rule 8.25, Ienclosed the
documents on the date shown below in an envelope or package provided by an
overnight delivery carrier and addressed to the person at the addresses in Item 4.
placed the envelope or package f'r collection and overnight delivery at an office or a
regularly utilized drop box of the overnight delivery carrier.
d. By Messenger Service. I served the documents on the date shown below by placing
them in an envelope or package addressed to the person on the addresses listed in
Item 4 and providing them to a professional messenger service for service.
e. By Fax Transmission. Based on an agreement to accept service by Fax transmission, I
1'axed the documents on the date shown below to the fax numbers of persons listed in
Item 4. No error was reported by the fax machine that Iused
10 By Electronic Transmission. Based on a court order or an agreement of the parties to
accept electronic service, I caused the documents to be sent on the date shown below
to the persons at the electronic service address listed above in Item 4. I did not receive
within a reasonable time after the transmission any electronic message or other
12
indication that the transmission was unsuccessful.
13
Iserved the documents by the means described above on August 22, 2019
14 Ideclare under penalty of perjury that this document is signed in San Rafael, California
under the laws of the State of California and that the foregoing is true and correct.
15
16 Jennifer L.
August 22, 2019 Page, CCLS
17
Date (Type or Print Name) (gi~re oMDeclarant)
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PROOF OF SERVICE
Document Filed Date
August 22, 2019
Case Filing Date
May 10, 2019
Category
(06) Unlimited Breach of Contract/Warranty
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Preview
8/22/2019 1 MATTHEW A. HAULK (SBN 272457) RAGGHIANTI FREITAS LLP 1101 Fifth Avenue, Suite 100 San Rafael, California 94901 Telephone: (415) 453-9433 Facsimile: (415) 453-8269 4 Attorneys for Defendants PUNIT K. SARNA and PUJA SARNA 6 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO 10 LOUIS PAYCHECK, CASE NO.: 19CIV02595 Plaintiff, PROOF OF SERVICE: ~ NOTICE OF MOTION FOR LEAVE TO FILE 12 vs. AMENDED CROSS-COMPLAINT AND 13 AMENDED ANSWER PUNIT K. SARNA, et al., ~ MEMORANDUM OF POINTS AND 14 AUTHORITIES IN SUPPORT OF MOTION Defendants. FOR LEAVE TO FILE AMENDED CROSS- 15 COMPLAINT AND AMENDED ANSWER ~ DECLARATION OF MATTHEW A. HAULK 16 IN SUPPORT OF MOTION FOR LEAVE TO FILE AMENDED CROSS-COMPLAINT 17 AND AMENDED ANSWER 18 DATE: October 9, 2019 TIME: 9:00 a.m. DEPT.: 1, Courtroom 4C 20 JUDGE: Honorable Leland Davis, III 21 Complaint Filed: May 10, 2019 22 AND RELATED CROSS-ACTION. Trial Date: Not set. 23 24 25 26 27 28 PROOF OF SERVICE PROOF OF SERVICE Paycheck v. Sama, et ak San Mateo County Superior Court Case Noc 19CIV02595 4 1. At the time of service, I was at least 18 years of age and not a party to this legal action. 5 2. My business address is 1101 Fifth Avenue, Suite 100, San Rafael, CA 94901. 3. I served Copies of the Following Documents: ~ NOTICE OF MOTION FOR LEAVE TO FILE AMENDED CROSS-COMPLAINT AND AMENDED ANSWER ~ MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR LEAVE TO FILE AMENDED CROSS-COMPLAINT AND AMENDED ANSWER ~ DECLARATION OF MATTHEW A. HAULK IN SUPPORT OF MOTION FOR LEAVE 10 TO FILE AMENDED CROSS-COMPLAINT AND AMENDED ANSWER 12 4 Iserved the documents listedabove in Item 3 on the following persons at the addresses listed: 13 Michael B. Allen Grant H. Bal&er Assaad M. Stephan MICHAEL B. ALLEN LAW GROUP, INC. 16 66 Bovet Road, Suite 250 San Mateo, CA 94402 17 650-347-5000 T: F: 650-340-6350 18 Attorneys for Plaintiff and Cross-Defendants LOUIS PAYCHECK dba EUROPEAN ENTERPRISES, SURETEC INDEMNITY COMPANY 20 5. a. By Personal Service. Ipersonally delivered the documents on the date shown below to 21 the persons at the addresses represented listed above in Item 4. (1) For a party by an attorney, delivery was made to the attorney or at the attorney's office by leaving the 22 documents in an envelope or package clearly labeled to identify the attorney being 23 served with a receptionist or an individual in charge of the office. (2) For a party delivery was made to the party or by leaving the documents in the party's residence 24 between the hours of eight in the morning and six in the evening with some person not less than 18 years of age. 25 By United States Mail. Ienclosed the documents in a sealed envelope or package, in the mail at San Rafael, California, where Iam a resident or employee in the County of 26 Marin where the mailing occurred. Iaddressed the sealed envelope or package to the persons at the addresses inItem 4 and (specify one): 27 (1) Deposited the sealed envelope in a United States Postal Service mailbox with 28 the postage fully prepaid on the date shown below PROOF OF SERVICE (2)X Placed the envelope For collection and mailing on the date shown below, following our ordinary business practices and Iam readily familiar with this business's practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid. c. By Overnight Delivery. Pursuant to California Rules of Court, Rule 8.25, Ienclosed the documents on the date shown below in an envelope or package provided by an overnight delivery carrier and addressed to the person at the addresses in Item 4. placed the envelope or package f'r collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier. d. By Messenger Service. I served the documents on the date shown below by placing them in an envelope or package addressed to the person on the addresses listed in Item 4 and providing them to a professional messenger service for service. e. By Fax Transmission. Based on an agreement to accept service by Fax transmission, I 1'axed the documents on the date shown below to the fax numbers of persons listed in Item 4. No error was reported by the fax machine that Iused 10 By Electronic Transmission. Based on a court order or an agreement of the parties to accept electronic service, I caused the documents to be sent on the date shown below to the persons at the electronic service address listed above in Item 4. I did not receive within a reasonable time after the transmission any electronic message or other 12 indication that the transmission was unsuccessful. 13 Iserved the documents by the means described above on August 22, 2019 14 Ideclare under penalty of perjury that this document is signed in San Rafael, California under the laws of the State of California and that the foregoing is true and correct. 15 16 Jennifer L. August 22, 2019 Page, CCLS 17 Date (Type or Print Name) (gi~re oMDeclarant) 20 21 22 23 24 25 26 27 PROOF OF SERVICE