On May 10, 2019 a
Motion-Secondary
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
12/11/2019
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
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Attorneys for Defendants
PUNIT K. SARNA and
PUJA SARNA
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
10 LOUIS PAYCHECK, CASE NO.: 19CIV02595
Plaintiff, P ROOF OF SERVI C E:
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~ Notice of Motion and Motion to Compel
Vs. Further Responses to Special
13 Interrogatories and Requests for Production
PUNIT K. SARNA, et al., ~ Memorandum of Points and Authorities in
14 Support of Motion to Compel Further
Defendants. Responses to Special Interrogatories and
15 Requests for Production
~ Declaration of Matthew A. Haulk in
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Support of Motion to Compel Further
17 Responses to Special Interrogatories and
Requests for Production
18 ~ Request for Judicial Notice in Support of
Motion to Compel Further Responses to
19 Special Interrogatories and Requests for
Production
20 ~ Separate Statement of Items in Dispute:
Requests for Production of Documents, Set
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One
22 ~ Separate Statement of Items in Dispute:
Special Interrogatories, Set One
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Complaint Filed: May 10, 2019
AND RELATED CROSS-ACTION. Trial Date: Not set.
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PROOF OF SERVICE
PROOF OF SERVICE
Paycheck v. Sama, et al.
San Mateo County Superior Court Case Nou 19CIV02595
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1. At the time of service, Iwas at least 18 years ofage 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 and Motion to Compel Further Responses to Special Interrogatories
and Requests for Production
~ Memorandum of Points and Authorities in Support of Motion to Compel Further
Responses to Special Interrogatories and Requests for Production
10
~ Declaration of Matthew A. Haulk in Support of Motion to Compel Further Responses
to Special Interrogatories and Requests for Production
~ Request for Judicial Notice in Support of Motion to Compel Further Responses to
Special Interrogatories and Requests For Production
12 ~ Separate Statement of Items in Dispute: Requests for Production of Documents, Set
One
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~ Separate Statement of Items in Dispute: Special Interrogatories, Set One
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15 4 Iserved the documents listedabove in Item 3 on the following persons at the addresses
listed:
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Richard M. Kelly
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Michael Mengarelli
18 KELLY LITIGATION GROUP, INC.
3 Lagoon Drive, Suite 225
Redwood City, CA 94065
T: 650-591-2282
20 F:
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E: rkelly@kellylitigationgroup.corn
Attorneys for Plaintiff and Cross-Defendants
22 LOUIS PAYCHECK dba EUROPEAN
ENTERPRISES and Cross-Defendant
23 SURETEC INDEMNITY COMPANY
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By Personal Service. I personally delivered the documents on the date shown below to
the persons at the addresses listed above in Item 4. (1) For a party represented by an
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attorney, delivery was made to the attorney or at the attorney's office by leaving the
26 documents in an envelope or package clearly labeled to identify the attorney being
served with a receptionist or an individual in charge of the office. (2) For a party
27 delivery was made to the party or by leaving the documents in the party's residence
between the hours of eight in the morning and six in the evening with some person
28 not less than 18 years of age.
PROOF OF SERVICE
b By United States Mail. Ienclosed the documents in a sealed envelope or package, in
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the mail at San Rafael, California, where I am a resident or employee in the County of
Marin where the mailing occurred. Iaddressed the sealed envelope or package to the
persons at the addresses in Item 4 and (specify one):
(1) Deposited the sealed envelope in a United States Postal Service mailbox with
the postage Fully prepaid on the date shown below
(2)x Placed the envelope for collection and mailing on the date shown below,
following our ordinary business practices and I am 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 for collection and overnight delivery at an office or a
regularly utilized drop box of the overnight delivery carrier.
10 d. By Messenger Service. Iserved 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
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faxed the documents on the date shown below to the fax numbers of persons listed in
13 Item 4. No error was reported by the fax machine that Iused
f. By Electronic Transmission. Based on a court order or an agreement of the parties to
14 accept electronic service, Icaused the documents to be sent on the date shown below
to the persons at the electronic service address listed above in Item 4. Idid not receive
15 within a reasonable time aFter the transmission any electronic message or other
I
indication that the transmission was unsuccessful.
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6., Iserved the documents by the means described above on December 11, 2019
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I declare under penalty of perjury that this document is signed in San Ra)ael, California
under the laws of the State of California and that the foregoing is true and correct.
~~
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December 11,
Date
2019 jennifer L Page, CCLS MCP
(Type or Print Name) (S(gnatuk of Declarant)0
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PROOF OF SERVICE
Document Filed Date
December 11, 2019
Case Filing Date
May 10, 2019
Category
(06) Unlimited Breach of Contract/Warranty
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12/11/2019 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, P ROOF OF SERVI C E: 12 ~ Notice of Motion and Motion to Compel Vs. Further Responses to Special 13 Interrogatories and Requests for Production PUNIT K. SARNA, et al., ~ Memorandum of Points and Authorities in 14 Support of Motion to Compel Further Defendants. Responses to Special Interrogatories and 15 Requests for Production ~ Declaration of Matthew A. Haulk in 16 Support of Motion to Compel Further 17 Responses to Special Interrogatories and Requests for Production 18 ~ Request for Judicial Notice in Support of Motion to Compel Further Responses to 19 Special Interrogatories and Requests for Production 20 ~ Separate Statement of Items in Dispute: Requests for Production of Documents, Set 21 One 22 ~ Separate Statement of Items in Dispute: Special Interrogatories, Set One 23 Complaint Filed: May 10, 2019 AND RELATED CROSS-ACTION. Trial Date: Not set. 25 26 27 28 PROOF OF SERVICE PROOF OF SERVICE Paycheck v. Sama, et al. San Mateo County Superior Court Case Nou 19CIV02595 3 1. At the time of service, Iwas at least 18 years ofage 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 and Motion to Compel Further Responses to Special Interrogatories and Requests for Production ~ Memorandum of Points and Authorities in Support of Motion to Compel Further Responses to Special Interrogatories and Requests for Production 10 ~ Declaration of Matthew A. Haulk in Support of Motion to Compel Further Responses to Special Interrogatories and Requests for Production ~ Request for Judicial Notice in Support of Motion to Compel Further Responses to Special Interrogatories and Requests For Production 12 ~ Separate Statement of Items in Dispute: Requests for Production of Documents, Set One 13 ~ Separate Statement of Items in Dispute: Special Interrogatories, Set One 14 15 4 Iserved the documents listedabove in Item 3 on the following persons at the addresses listed: 16 Richard M. Kelly 17 Michael Mengarelli 18 KELLY LITIGATION GROUP, INC. 3 Lagoon Drive, Suite 225 Redwood City, CA 94065 T: 650-591-2282 20 F: 21 E: rkelly@kellylitigationgroup.corn Attorneys for Plaintiff and Cross-Defendants 22 LOUIS PAYCHECK dba EUROPEAN ENTERPRISES and Cross-Defendant 23 SURETEC INDEMNITY COMPANY 24 By Personal Service. I personally delivered the documents on the date shown below to the persons at the addresses listed above in Item 4. (1) For a party represented by an 25 attorney, delivery was made to the attorney or at the attorney's office by leaving the 26 documents in an envelope or package clearly labeled to identify the attorney being served with a receptionist or an individual in charge of the office. (2) For a party 27 delivery was made to the party or by leaving the documents in the party's residence between the hours of eight in the morning and six in the evening with some person 28 not less than 18 years of age. PROOF OF SERVICE b By United States Mail. Ienclosed the documents in a sealed envelope or package, in 1 the mail at San Rafael, California, where I am a resident or employee in the County of Marin where the mailing occurred. Iaddressed the sealed envelope or package to the persons at the addresses in Item 4 and (specify one): (1) Deposited the sealed envelope in a United States Postal Service mailbox with the postage Fully prepaid on the date shown below (2)x Placed the envelope for collection and mailing on the date shown below, following our ordinary business practices and I am 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 for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier. 10 d. By Messenger Service. Iserved 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 12 faxed the documents on the date shown below to the fax numbers of persons listed in 13 Item 4. No error was reported by the fax machine that Iused f. By Electronic Transmission. Based on a court order or an agreement of the parties to 14 accept electronic service, Icaused the documents to be sent on the date shown below to the persons at the electronic service address listed above in Item 4. Idid not receive 15 within a reasonable time aFter the transmission any electronic message or other I indication that the transmission was unsuccessful. 16 6., Iserved the documents by the means described above on December 11, 2019 17 I declare under penalty of perjury that this document is signed in San Ra)ael, California under the laws of the State of California and that the foregoing is true and correct. ~~ 18 20 December 11, Date 2019 jennifer L Page, CCLS MCP (Type or Print Name) (S(gnatuk of Declarant)0 21 22 23 24 25 26 27 28 PROOF OF SERVICE