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24-1411114·orange·Civil·Civil
Hearing todayDENIED

Jergensen v. NAHS Holding, Inc.

Motion for an Order Authorizing Alternative Service

Hearing date
Aug 20, 2026
Department
C20
Prevailing
Opposing Party

Motion type

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Parties

DefendantNAHS Holding, Inc.
DefendantNAHS SouthEast, Inc.
DefendantMark Walton
DefendantMichael Moore

Ruling

25-1506621

Mr. Keefe has complied with the requirements set forth in California Rules of Court, Rule 9.40. Accordingly, the application is GRANTED.

Mr. Keefe is ordered to give notice of this ruling.

3. Kolaar v. FCA US LLC 25-1493558 The motion for terminating sanctions filed by defendants FCA US LLC and Huntington Beach Chrysler Dodge Jeep Ram (collectively, Defendants) against plaintiff Aaron Van Korlaar (Plaintiff) is DENIED WITHOUT PREJUDICE.

The proof of service for this motion lists an incorrect email address for Plaintiff’s counsel. The email address for Plaintiff’s counsel listed in the proof of service contains a misspelling and omits the number 4 from the email address. (See ROA 10, 41.) There is no opposition filed. It is thus unclear if Plaintiff received proper notice of this motion.

Based on the foregoing, the motion is DENIED WITHOUT PREJUDICE.

Counsel for Defendant shall give notice.

4. Jergensen v. NAHS Holding, Inc. 24-1411114 The Motion for an Order Authorizing Alternative Service by Defendants, NAHS Holding, Inc., NAHS SouthEast, Inc., Mark Walton and Michael Moore, is DENIED.

The only method authorized for service of a subpoena on a non-party deponent is personal service. [CCP §1981(a); CCP 2020.220(b); Target National Bank v. Rocha (2013) 216 CA4th Supp. 1, 7-8; In re Abrams (1980)108 Cal.App.3rd 685, 690] No “alternate service” is authorized.

5. Li v. Li 25-1517999

Self-represented plaintiff Jun Li brought this action against defendant Xian Li on October 13, 2025. The complaint (ROA 1) asks for declaratory relief in the form of a judicial statement that defendant’s unauthorized modification of the official filing of StarRide Auto Services, LLC, is invalid.

On December 31, 2025, plaintiff filed proof of service on defendant Xian Li by personal service on November 18, 2025.

When electronic filing and service are mandatory, some important exemptions apply, including one relating to self-represented litigants. Code Civ. Proc. § 1010.6(g)(4); CRC 2.253(b)(2).

If a case involves both represented and unrepresented parties, the electronic filing and service requirements apply only to the represented parties. Unrepresented parties are permitted to file, serve, and be served by nonelectronic means unless they affirmatively consent to electronic service. CRC 2.254(b)(3).

Nothing in the Court’s file indicates that plaintiff has affirmatively consented to electronic service. Therefore, plaintiff was entitled to service of the motion through a means other than electronic service.

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