Download - E-FILED...1 (hereinafter "Cross-Defendant") hereby answers the Cross-Complaint of CELL-CRETE 2 CORPORATION (hereinafter "CELL-CRETE"). 3 GENERAL DENIALS

1 RICHARD N. SIEVING, ESQ. (SB #133634) LUKE G. PEARS-DICKSON, ESQ. (SB #296581)

2 THE SIEVING LAW FIRM, A.P.C. 100 Howe Avenue, Suite 220N

3 Sacramento, California 95825 Telephone: (916) 444-3366

4 Facsimile: (916) 444-1223

5 Attorneys for DefendantlCross-DefendantlCross-Complainant JELD-WEN, inc., an Oregon Corporation dba SUMMIT WINDOW

6 & PATIO DOOR (erroneously sued herein as separate entities "JELD-WEN, INC." and "SUMMIT WINDOW & PATIO DOOR")

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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF SANTA CLARA

CILKER APARTMENTS, LLC,

Plaintiff,

v.

WESTERN NATIONAL

Case No. 1-13-CV-258281

15 CONSTRUCTION, et al.

JELD-WEN, INC. DBA SUMMIT WINDOW & PATIO DOOR'S ANSWER TO CELL-CRETE CORPORATION'S CROSS· COMPLAINT

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Defendants. ___________________________ 1

CELL-CRETE CORPORATION,

Cross-Complainant,

v.

ALLIANCE BUILDING PRODUCTS, 21 INC., et al.

22 Cross-Defendants. --------------------------_.1

23 AND ALL RELATED CROSS-ACTIONS.

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Judge: Dept.:

Hon. Peter H. Kirwan One (1)

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DefendantlCross-ComplainantlCross-Defendant JELD-WEN, inc., an Oregon

Corporation dba SUMMIT WINDOW & PATIO DOOR (erroneously sued herein as

separate entities "JELD-WEN, INC." and "SUMMIT WINDOW & PATIO DOOR")

HE SIEVING LAW FIRM, A.P.c. 100 Howe Ave., Suite 220N Sacramento, CA 95825

-1-[Olker Answer to Cell-Crete's Cross-Complaint 11.1 O.15.wpd (lpd:ltm

JELD-WEN, INC. DBA SUMMIT WINDOW & PATIO DOOR'S ANSWER TO CELL-CRETE CORPORATION'S CROSS-COMPLAINT

(916) 444-3366

E-FILEDNov 10, 2015 3:45 PM

David H. YamasakiChief Executive Officer/Clerk

Superior Court of CA, County of Santa ClaraCase #1-13-CV-258281 Filing #G-78324

By T. Mai, Deputy

1 (hereinafter "Cross-Defendant") hereby answers the Cross-Complaint of CELL-CRETE

2 CORPORATION (hereinafter "CELL-CRETE").

3 GENERAL DENIALS

4 1. This answering Cross-Defendant denies each and every paragraph of each

5 and every cause of action and further denies each and every, all and singular, separately

6 and severally, conjunctively and disjunctively, the allegations therein contained and further

7 denies that CELL-CRETE was damaged in any sum or sums whatsoever, or at all.

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2. This answering Cross-Defendant denies that by reason of any act or acts,

omission or omissions, fault, carelessness or negligence on the part of any of its agents,

servants or employees, CELL-CRETE suffered injuries of any kind or character or

damages of any kind or character in any sum or amount whatsoever.

FIRST AFFIRMATIVE DEFENSE

As and for a separate, distinct and First Affirmative Defense, this answering Cross

Defendant alleges that CELL-CRETE does not state facts sufficient to constitute a cause

of action against this answering Cross-Defendant.

SECOND AFFIRMATIVE DEFENSE

As and for a separate, distinct and Second Affirmative Defense, this answering

Cross-Defendant alleges that if, as alleged in the Cross-Complaint, CELL-CRETE

sustained injuries and damages in the mannertherein alleged, CELL-CRETE was totally

and one hundred percent (100%) at fault in and about the matter set forth in the Cross

Complaint, and entirely and solely failed to exercise ordinary care and that such

negligence on its part proximately contributed to, and was a proximate cause of, the

happening of the incidents, injuries, loss and damage complained of, if any there were.

THIRD AFFIRMATIVE DEFENSE

As and for a separate, distinct and Third Affirmative Defense, this answering

Cross-Defendant contends that each alleged cause of action within the Cross-Complaint

is absolutely barred by the terms of Cross-Defendant's written limited warranty and the

II/

HE SIEVING LAW FIRM, A.P.C. 100 Howe Ave., Suite 220N Sacramento, CA 95825

-2- [Cilker Answer to Cell-Crete's Cross-Complaint 11.10.1S.wpd {lpd:ltOJ


(916) 444-3366

E-FILED: Nov 10, 2015 3:45 PM, Superior Court of CA, County of Santa Clara, Case #1-13-CV-258281 Filing #G-78324

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-lE SIEVING LAW FIRM, A.P.c. 100 Howe Ave., Suite 220N Sacramento, CA 95825

(916) 444-3366

failure to give this Cross-Defendant reasonable and sufficient notice of the alleged

breaches of warranty.

FOURTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Fourth Affirmative Defense, this answering

Cross-Defendant asserts that all limitations conspicuously expressed in its Limited

Warranty are enforceable, thus barring and/or limiting any recovery for damages by

Plaintiff, Defendants or Cross-Complainants, if any there were.

FIFTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Fifth Affirmative Defense, this answering Cross

Defendant alleges that said injuries and/or damages sustained by CELL-CRETE were

either solely, or in part, negligently or otherwise caused by persons, firms, corporations,

or entities other than this answering Cross-Defendant and said negligence or other

conduct comparatively reduces the percentages of negligence or responsibility, if any, of

this answering Cross-Defendant.

SIXTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Sixth Affirmative Defense, this answering

Cross-Defendant alleges that the injuries or damages claimed by CELL-CRETE are due

solely to the fact that CELL-CRETE failed to act in a manner which would mitigate any

alleged damages and/or injuries.

SEVENTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Seventh Affirmative Defense, this answering

Cross-Defendant alleges that CELL-CRETE voluntarily and knowingly entered into and

engaged in the operations and conduct alleged in said Cross-Complaint and voluntarily

and knowingly assumed all risks incident to said operations, acts and conduct at the time

and place mentioned in said Cross-Complaint.

EIGHTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Eighth Affirmative Defense, this answering

Cross-Defendant alleges that any contractual provision(s) delineating that this answering

-3- rCilker Answer to Cell-Crete's Cross-Complaint 11.1 O.15.wpd (lpd:lt01



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HE SIEVING LAW FIRM, A.P.c. 100 Howe Ave., Suite 220N Sacramento, CA 95825

(916) 444-3366

Cross-Defendant would indemnify any other parties are unconscionable and

unenforceable.

NINTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Ninth Affirmative Defense, this answering

Cross-Defendant alleges that any contractual provision(s) delineating that this answering

Cross-Defendant would defend any other parties are unconscionable and unenforceable.

TENTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Tenth Affirmative Defense, this answering

Cross-Defendant alleges that CELL-CRETE failed to give timely notice to Cross

Defendant of its claim and that accordingly, CELL-CRETE is estopped to pursue its

alleged remedies by its own conduct and by application of the doctrines of waiver,

estoppel, and laches.

ELEVENTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Eleventh Affirmative Defense, this answering

Cross-Defendant alleges that the Cross-Complaint, and each cause of action thereof

alleged against this Cross-Defendant, is barred by the statutes of limitations set forth in

the California Code of Civil Procedure, commencing with Section 335 and continuing

through Section 349.4, more particularly, but not limited to, the following: Sections 337(1),

337.1, 337.15, 338, 339, 340, and 343; and by Sections 2607(3), and 2725(1) and (2) of

the California Commercial Code.

TWELFTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Twelfth Affirmative Defense, this answering

Cross-Defendant asserts that should CELL-CRETE recover damages from this answering

Cross-Defendant, this answering Cross-Defendant is entitled to indemnification, either in

whole or in part, from all persons or entities whose negligence and/or fault proximately

contributed to CELL-CRETE's damages, if any there are.

/1/

/1/

-4- [Cilker Answer to Cell-Crete's Cross-Complaint 11.1 0.15.wpd (lpd:ltOJ



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~E SIEVING LAW FIRM, A.P.C. 100 Howe Ave., Suite 220N Sacramento, CA 95825

(916) 444-3366

THIRTEENTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Thirteenth Affirmative Defense, this answering

Cross-Defendant alleges that the Cross-Complaint, and each cause of action thereof, is

barred by virtue of CELL-CRETE's conduct in causing the damages alleged by CELL

CRETE under the doctrine of unclean hands.

FOURTEENTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Fourteenth Affirmative Defense, this answering

Cross-Defendant alleges that prior to the commencement of this action, this answering

Cross-Defendant duly performed, satisfied, and discharged all duties and obligations it

may have owed to Plaintiff, Defendants, andlor Cross-Complainants arising out of any

and all agreements, representations, or contracts made by it or on behalf of this

answering Cross-Defendant, and this action is therefore barred by the provisions of

California Civil Code §1473.

FIFTEENTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Fifteenth Affirmative Defense, this answering

Cross-Defendant alleges that Plaintiff, Defendants, Cross-Complainants, and others

unrelated to this answering Cross-Defendant, modified, altered, abused, and/or misused

the materials andlor equipment provided by this answering Cross-Defendant, and such

conduct caused and/or contributed to the damages which are alleged in this lawsuit.

SIXTEENTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Sixteenth Affirmative Defense, this answering

Cross-Defendant alleges that any product manufactured, supplied and/or installed by this

answering Cross-Defendant did not cause damage to any property other than to the

product itself and, therefore, recovery may not be granted on any claims sounding in tort

or seeking contribution and/or indemnity.

/II

/1/

/II

-5- [Cilker Answer to Cell-Crete's Cross-Complaint 11.1O.15.wpd (lpd:lt~J



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,E SIEVING LAW FIRM, A.P.C. 00 Howe Ave., Suite 220N Sacramento, CA 95825

(916) 444-3366

SEVENTEENTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Seventeenth Affirmative Defense, this

answering Cross-Defendant alleges that recovery by CELL-CRETE is barred by the

provisions of Civil Code Sections 2782 and 2782.5.

EIGHTEENTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Eighteenth Affirmative Defense, this answering

Cross-Defendant alleges that CELL-CRETE has suffered no damage as contemplated

by the case of Aas v. Superior Court and therefore cannot recover in tort for the alleged

damages.

NINETEENTH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Nineteenth Affirmative Defense, this answering

Cross-Defendant alleges that the work and/or activities of this Cross-Defendant were

done in a professional and satisfactory manner.

TWENTIETH AFFIRMATIVE DEFENSE

As and for a separate, distinct and Twentieth Affirmative Defense, this

answering Cross-Defendant alleges that CELL-CRETE expressly, voluntarily, and

knowingly assumed all risks about which it now complains as stated in the Cross

Complaint, and is therefore barred either totally or partially to the extent of said

assumption of any damages.

TWENTY-FIRST AFFIRMATIVE DEFENSE

As, and for a separate, distinct and Twenty-First Affirmative Defense, this

answering Cross-Defendant alleges that the work it completed met the standard of

care known at the time the work was performed and was recognized as state of the art

at all relevant times herein.

TWENTY-SECOND AFFIRMATIVE DEFENSE

As and for a separate, distinct and Twenty-Second Affirmative Defense, this

answering Cross-Defendant alleges that the persons or entities legally responsible for

the alleged damages, if any, sustained by CELL-CRETE in this action are persons or

-6- [Cilker Answer to Cell-Crete', Cross-Complaint 11.1 0.15.wpd (lpd:ltOJ



1 entities other than this answering Cross-Defendant. Therefore, Cross:-Defendant is

2 not responsible for any damages alleged by CELL-CRETE in its Cross-Complaint.

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~ E SIEVING LAW FIRM, A.P.C. 100 Howe Ave., Suite 220N Sacramento, CA 95825

(916) 444-3366

WHEREFORE, Cross-Defendant prays Judgment as follows:

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CELL-CRETE takes nothing by virtue of this action;

For costs of suit incurred herein;

For reasonable attorney's fees;

For such other and further relief as the court may deem just and proper.

DATED: November 10, 2015 THE SIEVING LAW FIRM, A.P.C.

BY:L~~~-N---Attorney for Defendant!Cross-Defendant! Cross-Complainant JELD-WEN, inc., an Oregon Corporation dba SUMMIT WINDOW & PATIO DOOR (erroneously sued herein as separate entities "JELDWEN, INC." and "SUMMIT WINDOW & PATIO DOOR")

-7-[Ci lker Answer to Cell-Crete's Cross-Complaint 11 .1 0. 15.wpd (lpd:ItOl



ATTORNEY OR PARTY WITHOUT ATTORNEY (Name and Address): TELEPHONE NO.:

Richard N. Sieving, Esq. (SB #133634) (916) 444-3366 Jennifer L. Snod,rass, Esq. (SB #227823) THE SIEVING L W FIRM, A.P.C. Attorneys at Law 100 Howe Avenue, Suite 220N Sacramento, CA 95825 ATTORNEY FOR (Name): (D/X-D/X-C) JELD-WEN, inc. , an Oregon Corporation dba

SUMMIT WINDOW & PATIO DOOR

Insert name of court and name of judicial district, if any:

Santa Clara County Superior Court

SHORT TITLE OF CASE:

Cilker Apartments, LLC v. Western National Construction, et al.

HRG DATE: I TIME:

I, the undersigned, declare:

I DEPT: 1

PROOF OF SERVICE [C.C.P. §§1013A and 2015.5]

FOR COURT USE ONL Y

CASE NUMBER:

1-13-CV-258281

I am a citizen of the United States and am employed in the County of Sacramento, California. I am over the age of eighteen (18) years, not a party to the above-entitled action, and my business address is located in the County of Sacramento at 100 Howe Avenue, Suite 220N, Sacramento, California 95825.

On the date executed below, I served the document(s) described as:

1.) JELD-WEN, INC. DBA SUMMIT WINDOW & PATIO DOOR'S ANSWER TO CELLCRETE CORPORATION'S CROSS-COMPLAINT

on interested parties in this action addressed as follows:

[ X ] BY ELECTRONIC TRANSFER: I caused all of the above-entitled document(s) to be served through the Santa Clara County Superior Court's Electronic Fiiing System to all parties appearing on the Court's electronic service list on the date executed below. The file transmission was reported as complete and a copy of the "SC Superior Court E-Filing Receipt" page will be maintained with the original document(s) in our office.

[ ] BY FIRST CLASS U.S. MAIL: I placed a true copy in a sealed envelope addressed as indicated above. I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. It is deposited with the U.S. Postal Service on that same day in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation or postage meter date is more than one day after date of deposit for mailing in affidavit.

I declare under penalty of perjury that the foregoing is true and correct. Executed on November 10, 2015 at Sacramento, California.

cf~(2~. ARiNA T. FALCONA .


Re: Cilker Apartments, llC v. Western National Construction Santa Clara County Superior Court

(Updated November 10, 2015)

Case Number 1-13-CV-258281

SERVICE LIST

Attorney:{s} Phone & Fax Numbers PartyHesl

Jon B. Zimmerman, Esq. Phone: 408/298-7120 Plaintiff Cilker Apartments, LLC Gregory B. Cohen, Esq. Fax: 408/298-0477 ROBINSON & WOOD, INC. 227 N. 1 st Street [email protected] San Jose, CA 95113 [email protected]

Michael Erlinger, Esq. Phone: 714/918-7000 Defendant Western National Mihaela Minculescu, Esq. Fax: 714/918-6996 Construction Michael J. Pepek, Esq. Sam M. Danskin, Esq. [email protected] GREEN & HALL [email protected] 1851 East First Street, 10th Floor [email protected] Santa Ana, CA 92705 [email protected]

[email protected]

William D. Morrow Phone: 714/979-7999 ADM Construction Geoffrey Kraemer Fax: 714/979-7779 ADM Construction Co., Inc. MORROW & WHITE 535 Anton Blvd., Suite 1150 [email protected] Costa Mesa, CA 92626 [email protected]

[email protected]

David Levy, Esq. Phone: 415/291-8844 ADM Construction Co., Inc. Daniel A. Serot, Esq. ext. 5242 ADM Painting Company Courtney McFate, Esq. Alt. Phone 925/934-6102 AMPAM LDI Mechanical, Inc. Lisa McConnell, Esq. Fax: 925/934-6060 LDI Mechanical, Inc. VAN DE POEL, LEVY, ALLEN & Eastern Landscape Company, Inc. ARNEAL, LLP [email protected] 1600 South Main Plaza, Suite 325 [email protected] Walnut Creek, CA 94596 [email protected]

[email protected]

Brian H. Gunn, Esq. Phone: 925/280-0004 Alliance Building Products, Inc. Rebecca J. Collaco, Esq. Fax: 925/280-0005 WOLFE & WYMAN LLP 2175 N. California Blvd., Suite 645 bhgunn@wolfe~man.com Walnut Creek, CA 94596 [email protected]

Alison Flowers, Esq. Phone: 562/436-9201 AMPAM Parks Mechanical, Inc TAUBMAN, SIMPSON, YOUNG & Fax: 562/590-9695 SULENTOR One World Trade Center, Suite 400 Long Beach, CA 90831 [email protected]

Robyn S. McClain, Esq. Phone: 858/642-1372 AMPAM Parks Mechanical, Inc LETOFSKY - McCLAIN Fax: 858(642-1379 3655 Nobel Drive, Suite 400 San Diego, CA 92122 [email protected]

Chad S. Tapp, Esq. Phone: 916/929-1481 Anderson Truss PORTER SCOTT Fax: Pacific Coast Building Structures 350 University Avenue, #200 dba Anderson Truss Sacramento, CA 95825 [email protected]

Tom Kirvin, Esq. Phone: 415/777-1308 Intervernor Liberty Mutual SANTANA TCHENG VIERRA & Fax: 415/896-9063 Insurance Company on behalf of its SYMONDS insured California Classic Paver 71 Stevenson Street, Suite 700 Designs, Inc. San Francisco, CA 94105 [email protected]

CllKER APTS., llC v. WESTERN NAT'L CONSTRUCTION SERVICE LIST PAGE -1-


Attorne}l{s} Phone & Fax Numbers Partv{ies}

Michael L. Marx, Esq. Phone: 415/705-0400 Casey-Fog Ii Concrete Contractors Denise Sutherland, Esq. Fax: 415/705-0411 Joseph J. Albanese, Inc. GOODMAN NEUMAN HAMIL TON, LLP 417 Montgomery Street, 10th Floor [email protected] San Francisco, CA 94104 [email protected]

Thomas Yen, Esq. Phone: 415/227-2300 Casey-Fog Ii Concrete Contractors LAW OFFICES OF BEVERLY E. Fax: 415/227-2360 Central Coast Stairs NARAYAN 525 Market Street Suite 2850 San Francisco 94105 [email protected]

Joseph Ryan, Esq. Phone: 925/884-2080 Cell-Crete Corporation Jill Lifter, Esq. Fax: 925/884-2090 Gary Berticevich, Esq RYAN & LIFTER [email protected] 2010 Crow Canyon Place, Suite 330 [email protected] San Ramon, CA 94583 [email protected]

Ayhan M. Menekshe, Esq. Phone: 408/358-1200 Cell-Crete Corporaton Steven W. Feria, Esq. Fax: 408/358-1205 MENEKSHE LAW FIRM 950 East Campbell Avenue Campbell, CA 95008 [email protected]

Benjamin J. Angulo, Esq. Phone: 415/541-5363 Courtney Waterproofing, Inc. Michelle Rogers, Esq. Alt. Phone 714/957-5742 Courtney Waterproofing SPRINGEL & FINK LLP Fax: 415/541-5364 151 Market Street, Suite 2200 San Francisco, CA 94105 [email protected]

[email protected]

Michael J. Estep, Esq. Phone: 925/901-2294 Davey Roofing, Inc. LAW OFFICES OF TIMOTHY R. Fax: 866/386-1186 Pyramid Builders, Inc. WAGNER 2633 Camino Ramon, Suite 210 San Ramon, CA 94583 [email protected]

G Geoffrey Wood, Esq. Phone: 510/832-7770 Demetrius Painting II, Inc. Jenn N. Crittondon ext. 116 Dimetrius Painting II, Inc. ERICKSEN ARBUTHNOT Fax: 510/832-0102 One Concord Center 2300 Clayton Road, Suite 350 [email protected] Concord, CA 94520 [email protected]

Laura K. Buttrell Phone: 916/921-9353 Eastern Landscape Company LAW OFFICE OF DAVID A. WALLIS Fax: 916/921-9040 Robecks Welding & Fabrication, 2251 Harvard Street, Suite 100 Inc. Sacramento, CA 95815 buttrl1 @nationwide.com

Lori R. Mayfield, Esq. Phone: 510/457-9924 Eastern Landscape Company, Inc. Eric Butler, Esq. Fax: 510/893-1841 Roebeck's Welding & Fabrication, LAW OFFICE OF LORI R. MAYFIELD Inc. 505 14th Street, Suite 1210 ma~fiel1 @nationwide.com Oakland, CA 94612 butlere 7 @nationwide.com

Brett L. McKague, Esq. Phone: 916/358-9042 Gentry Associates Construction Jeremy J. Schroeder, Esq. Fax: 916/673-9672 Consultants FLESHER McKAGUE, LLP 2202 Plaza Drive Rocklin, CA 95765 [email protected]

CILKER APTS., LLC v. WESTERN NAT'L CONSTRUCTION SERVICE LIST PAGE -2-


Attorne~{s } Phone & Fax Numbers Part~{ies}

Phillip Bazzano, Esq. Phone: 925/938-1430 Madera Con'struction SELLAR HAZARD & LUCIA Cell: 925/256-7508 201 North Civic Drive, Suite 145 Walnut Creek, CA 94596 [email protected]

Alexander Moore, Esq. Phone: 51 0/834-4350 Madera Framing BOORNAZIAN, JENSEN & GARTHE Fax: 510/839-1897 555 12th Street, Suite 1800 Oakland, CA 94607 [email protected]

Elizabeth W. Lawley Phone: 916/702-3200 Madera Framing HAIGHT BROWN & BONESTEEL, LLP Fax: 916/702-3220 2485 Natomas Park Drive, Suite 450 Sacramento, CA 95833 elawle:[email protected]

Dana Richard, Esq. Phone: 510/844-51 00 McLarand, Vasquez & Partners Stephen B. Litchfield, Esq. Fax: 510/844-5101 COLLINS COLLINS MUIR & STEWART, LLP [email protected] 1999 Harrison Street, Suite 1700 [email protected] Oakland, CA 94612 [email protected]

Todd A Fischer, Esq. Phone: 831/372-9200 Pyramid Builders, Inc. Bryan P. Kerney, Esq. Fax: 831/372-9220 FISCHER KERNEY, LLP 888 Munras Avenue [email protected] Monterey, CA 93940 [email protected]

Bruce Trevithick, Esq. Phone: 714/571-0407 Roebeck's Welding & Fabrication, LAW OFFICES OF MELISSA M. Fax: 877/369-5799 Inc. BALLARD Direct: 714/371-2735 P.O. Box 2282 Brea, CA 92822-2282 jen na. fischer -re:[email protected]

[email protected]

Todd A Jones, Esq. Phone: 916/646-2480 Roebeck's Welding & Fabrication, LAW OFFICES OF ARCHER NORRIS Fax: 916/646-5696 Inc. 301 University Avenue, Suite 110 Sacramento, CA 95825 [email protected]

Thomas B. Wait, Esq. Phone: 909/621-5672 Tara Coatings Robert A Hufnagel, Esq. Fax: WAIT & HUFNAGEL

909/399-0645 Tara Coatings, Inc.

250 West First Street, Suite 222 [email protected] Claremont, CA 91711 mmalcz:[email protected]

Frank J. Perretta, Esq. Phone: 408/292-1765 White Residential, Inc. MILLER, MORTON, CAILLAT & Fax: 408/436-8272 NEVIS, LLP 50 West San Fernando Street, Suite 1300 San Jose, CA 95113 [email protected]

Bruce A Edwards, Esq. Phone: 415/774.2667 Special Master JAMS Fax: 415/982-5287 Two Embarcadero Center, Suite 1500 o Serve Only If Checked San Francisco, CA 94111 [email protected]

[email protected]

Served by:

Richard N. Sieving, Esq. Phone: 916/444-3366 JELD-WEN, inc., an Oregon Luke G. Pears-Dickson, Esq. Fax: 916/444-1223 Corporation dba Summit Window & THE SIEVING LAW FIRM, AP.C. Patio Door 100 Howe Avenue, Suite 220N [email protected] Sacramento, CA 95825 [email protected]

CllKER APTS., llC v. WESTERN NAT'l CONSTRUCTION SERVICE LIST PAGE -3-
