Complaint Amendment To New Party

Cal. Super. - 6th Dist.April 1, 2021

SHARON L. HIGHTOWER, ESQ. - S.B.N. 129874 LAURA MALKOFSKY, ESQ. - S.B.N. 142536 ERICKSEN ARBUTHNOT 210 North Fourth Street, Suite 350 San Jose, CA 95112 Telephone: (408) 286-0880 Facsimile: (408) 286-0337 shivhtower@ericksenarbuthnot.corn Attorneys for Aquatek Plumbing, Inc. 8 9 10 11 12 SUPERIOR COURT OF CALIFORIA, COUNTY OF SANTA CLARA UNLIMITED JURISDICTION VERA FOX, individually and CASE NO 21CV381448 HERBERT FOX, individually, Plaintiffs, V. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 AQUATEK PLUMBING, INC., et al., Defendants. AMERICAN MANAGEMENT SERVICES, INC., a California Corporation; et al. Cross-Complainants, V. AQUATEK PLUMBING, INC., a California Corporation, ROES 1-20, Cross-Defendants. AQUATEK PLUMBING, INC., Cross-Complainant, V. AMERICAN MANAGEMENT SERVICES, INC., BLOSSOM HILL ESTATES NO. 2 HOMEOWNERS ASSOCIATION, FOES 1-10., Cross-Defendants. Complaint Filed: 9/23/19 Trial: TBD AMENDMENT TO CROSS-COMPLAINT FOR INDEMNITY, CONTRIBUTION AND DECLARATORY RELIEF OF AQUATEK PLUMBING TO NAME FOE I AMENDMENT TO CROSS-COMPLAINT Electronically Filed by Superior Court of CA, County of Santa Clara, on 2/14/2022 5:17 PM Reviewed By: Y. Chavez Case #21CV381448 Envelope: 8287520 21CV381448 Santa Clara - Civil Y. Chavez Upon the filing of the cross-complaint, Cross-Complainant Aquatek Plumbing, Inc. ("AQUATEK"), being ignorant of the true name of the following Cross-defendant and having designated the cross-defendants in the Cross-Complaint by fictitious names, hereby identifies Foe I by the true name as follov s: FOE I; Hugo Werle DATED: February 14, 2022 ERICKSEN ARBUTHNOT 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SHARON L. HIGHTOWER, ESQ. Attorney for Aquatek Plumbing, Inc. AMENDMENT TO CROSS-COMPLAINT 1 2 3 4 5 CASE NAME: FOX v. AQUATEK PLUMBING, et al. ACTION NO: 21CV381448 PROOF OF SERVICE I declare that I am employed in the County of Santa Clara, California. I am over the age of eighteen (18) years and not a party to the within cause; my business address is 210 No. Fourth Street, Suite 350, San Jose, CA 95112. 6 7 I served the attached: Amendment ro Cross-Complaint on the interested parties in said cause, using the following method: 10 11 12 13 14 15 17 18 19 20 21 22 23 24 25 26 // // /XX/ PLAINTIFF COUNSEL: John C. Stein James P. Collins The Boccardo Law Firm Ill W. St. Johns St, Ste. 400 San Jose, CA 95113 (408) 298-5678 stein boccardo.corn jcollins@boccardo.corn (BY MAIL) I placed each sealed envelope, with postage thereon fully prepaid for first-class mail, for collection and mailing at San Jose, California, following ordinary business practices. I am readily familiar with the practice of ERICKSEN ARBUTHNOT for the processing of correspondence, said practice being that in the ordinary course of business, correspondence is deposited in the United States Postal Service the same day as it is placed for processing. (BY PERSONAL SERVICE) I caused each such envelope to be delivered by hand to the addressee(s) noted below. (BY FEDERAL EXPRESS) The foregoing document was placed in a sealed envelope provided by Federal Express/UPS, designated as overnight (delivery by next business day) with delivery fees paid or provided for and addressed as stated below. I deposited such envelope in the Federal Express/UPS collection box at 210 North Fourth Street, San Jose, California. (BY FACSIMILE) I caused the said document to be transmitted by facsimile machine to the facsimile number indicated after the address(es) noted below. Such transmission was verified as complete and without error. (BY ELECTRONIC SERVICE) Based on a court order or an agreement of the parties to accept service by electronic transmission, I caused the documents to be sent to the persons at the electronic notification addresses listed below. OR: The above-described document(s) will be delivered electronically through the Court's electronic filing system. /XX / (ELECTRONIC SERVICE VIA ONE LEGAL) Based on a court order or an agreement of the parties to accept service by electronic transmission, I caused the above-entitled document to be served through One Legal at www.oneleaal.corn addressed to all parties appearing on the electronic service list for the above-entitled case. The service transmission was reported as complete and a copy One Legal Receipt Page/ Confirmation will be filed, deposited or maintained with the original document in this office, All parties that do not appear on the electronic service list will be sent a copy by US Mail. 27 28 AMENDMENT TO CROSS-COMPLAINT 10 ATTORNEY FOR DEFENDANT AMERICAN MANAGEMENT SERVICES, INC. Seymour Bernard Everett 111 Samantha E.Dorey Everett Dorey LLP 18300 Von Karman Ave, Ste 900 Irvine, CA 92612-1054 Phone: 949-771-9244 i Fax: 949-377-3110 Email: severettSeverettdorev.corn sdorey@everettdorey.corn I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was executed on February 14, 2022, at San Jose, California. ~u~P~ l Mh~~ JENNIFER L. SHARPS, 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 AMENDMENT TO CROSS-COMPLAINT