On May 10, 2019 a
Party Discovery
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
7/27/2020
MATTHEW A. HAULK (SBN: 272457)
1
RAGGHIANTI FREITAS LLP
2 1101 Fifth Avenue, Suite 100
San Rafael, California 94901
3 Telephone: (415) 453-9433
Facsimile: (415) 453-8269
4
Attorneys for Defendants
5 PUNIT K. SARNA and
PUJA SARNA
6
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 COUNTY OF SAN MATEO
9 LOUIS PAYCHECK, CASE NO.: 19CIV02595
10
Plaintiff, PROOF OF SERVICE:
11 • DEFENDANT’S REPLY TO PLAINTIFF’S
vs. OPPOSITION TO DEFENDANT’S
12 MOTION TO COMPEL FURTHER
PUNIT K. SARNA, et al., RESPONSES TO SPECIAL
13 INTERROGATORIES AND PRODUCTION
Defendants. OF DOCUMENTS
14
• SUPPLEMENTAL DECLARATION OF
15 MATTHEW A. HAULK IN SUPPORT OF
MOTION TO COMPEL FURTHER
16 RESPONSES TO SPECIAL
INTERROGATORIES AND PRODUCTION
17 OF DOCUMENTS
18
DATE: August 3, 2020
19 TIME: 9:00 a.m.
DEPT.: 4, Courtroom 8B
20 JUDGE: Honorable Nancy L. Fineman
21
Complaint Filed: May 10, 2019
22 Trial Date: August 3, 2020
23 AND RELATED CROSS-ACTION.
24
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-1-
PROOF OF SERVICE
1 PROOF OF SERVICE
Paycheck v. Sarna, et al.
2
San Mateo County Superior Court Case No.: 19CIV02595
3
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.
6 3. I served Copies of the Following Documents:
7
• DEFENDANT’S REPLY TO PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION
8 TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES AND
PRODUCTION OF DOCUMENTS
9 • SUPPLEMENTAL DECLARATION OF MATTHEW A. HAULK IN SUPPORT OF
MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES
10
AND PRODUCTION OF DOCUMENTS
11
12 4. I served the documents listed above in Item 3 on the following persons at the addresses
listed:
13
Richard M. Kelly
14
Michael Mengarelli
15 KELLY LITIGATION GROUP, INC.
306 Lorton Avenue
16 Burlingame, CA 94010
T: 650-591-2282
17 F: 650-591-2292
E: rkelly@kellylitigationgroup.com
18
Attorneys for Plaintiff and Cross-Defendants
19 LOUIS PAYCHECK dba EUROPEAN
ENTERPRISES and Cross-Defendant
20 SURETEC INDEMNITY COMPANY
21 5. a. 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
22
attorney, delivery was made to the attorney or at the attorney’s office by leaving the
23 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
24 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
25 not less than 18 years of age.
b. By United States Mail. I enclosed the documents in a sealed envelope or package, in
26 the mail at San Rafael, California, where I am a resident or employee in the County of
Marin where the mailing occurred. I addressed the sealed envelope or package to the
27
persons at the addresses in Item 4 and (specify one):
28
-2-
PROOF OF SERVICE
(1) Deposited the sealed envelope in a United States Postal Service mailbox with
1 the postage fully prepaid on the date shown below
2
(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
3 business’s practice for collecting and processing correspondence for mailing.
On the same day that correspondence is placed for collection and mailing, it
4 is deposited in the ordinary course of business with the United States Postal
Service, in a sealed envelope with postage fully prepaid.
5 c. By Overnight Delivery. Pursuant to California Rules of Court, Rule 8.25, I enclosed the
documents on the date shown below in an envelope or package provided by an
6 overnight delivery carrier and addressed to the person at the addresses in Item 4. I
placed the envelope or package for collection and overnight delivery at an office or a
7
regularly utilized drop box of the overnight delivery carrier.
8 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
9 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
10 faxed 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 I used
11 f.X 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
12
to the persons at the electronic service address listed above in Item 4. I did not receive
13 within a reasonable time after the transmission any electronic message or other
indication that the transmission was unsuccessful.
14 6. I served the documents by the means described above on July 22, 2020
15 I declare 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.
16
17
July 27, 2020 Jennifer L. Page, CCLS/Paralegal
18 Date (Type or Print Name) (Signature of Declarant)
19
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28
-3-
PROOF OF SERVICE
Document Filed Date
July 27, 2020
Case Filing Date
May 10, 2019
Category
(06) Unlimited Breach of Contract/Warranty
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Preview
7/27/2020 MATTHEW A. HAULK (SBN: 272457) 1 RAGGHIANTI FREITAS LLP 2 1101 Fifth Avenue, Suite 100 San Rafael, California 94901 3 Telephone: (415) 453-9433 Facsimile: (415) 453-8269 4 Attorneys for Defendants 5 PUNIT K. SARNA and PUJA SARNA 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF SAN MATEO 9 LOUIS PAYCHECK, CASE NO.: 19CIV02595 10 Plaintiff, PROOF OF SERVICE: 11 • DEFENDANT’S REPLY TO PLAINTIFF’S vs. OPPOSITION TO DEFENDANT’S 12 MOTION TO COMPEL FURTHER PUNIT K. SARNA, et al., RESPONSES TO SPECIAL 13 INTERROGATORIES AND PRODUCTION Defendants. OF DOCUMENTS 14 • SUPPLEMENTAL DECLARATION OF 15 MATTHEW A. HAULK IN SUPPORT OF MOTION TO COMPEL FURTHER 16 RESPONSES TO SPECIAL INTERROGATORIES AND PRODUCTION 17 OF DOCUMENTS 18 DATE: August 3, 2020 19 TIME: 9:00 a.m. DEPT.: 4, Courtroom 8B 20 JUDGE: Honorable Nancy L. Fineman 21 Complaint Filed: May 10, 2019 22 Trial Date: August 3, 2020 23 AND RELATED CROSS-ACTION. 24 25 26 27 28 -1- PROOF OF SERVICE 1 PROOF OF SERVICE Paycheck v. Sarna, et al. 2 San Mateo County Superior Court Case No.: 19CIV02595 3 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. 6 3. I served Copies of the Following Documents: 7 • DEFENDANT’S REPLY TO PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION 8 TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES AND PRODUCTION OF DOCUMENTS 9 • SUPPLEMENTAL DECLARATION OF MATTHEW A. HAULK IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES 10 AND PRODUCTION OF DOCUMENTS 11 12 4. I served the documents listed above in Item 3 on the following persons at the addresses listed: 13 Richard M. Kelly 14 Michael Mengarelli 15 KELLY LITIGATION GROUP, INC. 306 Lorton Avenue 16 Burlingame, CA 94010 T: 650-591-2282 17 F: 650-591-2292 E: rkelly@kellylitigationgroup.com 18 Attorneys for Plaintiff and Cross-Defendants 19 LOUIS PAYCHECK dba EUROPEAN ENTERPRISES and Cross-Defendant 20 SURETEC INDEMNITY COMPANY 21 5. a. 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 22 attorney, delivery was made to the attorney or at the attorney’s office by leaving the 23 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 24 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 25 not less than 18 years of age. b. By United States Mail. I enclosed the documents in a sealed envelope or package, in 26 the mail at San Rafael, California, where I am a resident or employee in the County of Marin where the mailing occurred. I addressed the sealed envelope or package to the 27 persons at the addresses in Item 4 and (specify one): 28 -2- PROOF OF SERVICE (1) Deposited the sealed envelope in a United States Postal Service mailbox with 1 the postage fully prepaid on the date shown below 2 (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 3 business’s practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it 4 is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid. 5 c. By Overnight Delivery. Pursuant to California Rules of Court, Rule 8.25, I enclosed the documents on the date shown below in an envelope or package provided by an 6 overnight delivery carrier and addressed to the person at the addresses in Item 4. I placed the envelope or package for collection and overnight delivery at an office or a 7 regularly utilized drop box of the overnight delivery carrier. 8 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 9 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 10 faxed 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 I used 11 f.X 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 12 to the persons at the electronic service address listed above in Item 4. I did not receive 13 within a reasonable time after the transmission any electronic message or other indication that the transmission was unsuccessful. 14 6. I served the documents by the means described above on July 22, 2020 15 I declare 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. 16 17 July 27, 2020 Jennifer L. Page, CCLS/Paralegal 18 Date (Type or Print Name) (Signature of Declarant) 19 20 21 22 23 24 25 26 27 28 -3- PROOF OF SERVICE