Page 1 Electronically Filed
by Superior Court of CA,
County of Santa Clara,
on 5/27/2020 11:12 AM
Reviewed By: S. Alvarez
Case #19CVEnvelope:
GARDENER, RIEcH~ k CHow
Ron Chow S.B. 438 E. Katella Ave, Ste Orange, CA P: 714 972-8989 F: 714 972-E: ron@grclawfirm.corn
Attorneys for Plaintiff
CURRENT POWER ELECTRIC, INC.
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CLARA, DOWNTOWN SUPERIOR COURT (DTS)
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CURRENT POWER ELECTRIC, INC.,
Plaintiff,
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Case No.: 19CV
DECLARATION OF RON CHOW IN
SUPPORT OF JUDGMENT
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SOLARCITY ENGINEERING INC; AND
DOES 1 TO 10, INCLUSIVE,
Defendants.
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DECLARATION OF RON CHOW
I, RON CHOW, declare as follows:
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1.
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I am a partner with the law firm
of Gardener, Riechmann k Chow, attorneys for plaintiff herein.
2. This declaration is made in response to the rejection
3.
of the application for default judgment.
Plaintiff submitted request for default judgment against Defendant on 12/24/19. Default was entered
on 9/29/19,
4. This court rejected the judgment because
"l. Venue appear improper; 585 Dec attaches invoice w/
San Mateo address, complaint says "Defendant's address"
5.
This case was filed on July 3, 2019.
DECLARATION OF RON CHOW IN SUPPORT OF JUDGMENT Page 2 6. The invoice that is the subject
of this case was issued on 12/17/2016 against Defendant
SOLARCITY ENGNEERING INC at 3005 Clearview Way, San Mateo, CA 94402, which is San
Mateo County.
7, At that time according to the California Secretary
of State, Defendant was located at 3005 Clearview
Way„San Mateo„CA 94402. See Defendant's Statement of Information filed May 31, 2018, a true
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and correct copy of which is attached to this declaration as Exhibit "A".
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8.
Subsequently, Defendant moved from 3005 Clearview Way, San Mateo, CA 94402 to 3500 Deer
Jl
Creek Road, Palo Alto, CA 94304 in about April of 2019. See Defendant's Statement of
"'"
Information filed April 5, 2019, a true and correct copy of which is attached to this declaration as
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I
Exhibit "B".
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9.
Defendant's current address of 3500 Deer Creek Road, Palo Alto, CA 94304 is within the county of
this court. Venue is appropriate as the Defendant is currently located within this county.
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Plaintiff requests entry of default judgment against the Defendant.
I declare, under penalty
of perjury, under the laws of the State of California, that the foregoing is
true and correct, that I possess personal knowledge thereof, and that if called to testify regarding same, I
could and would so testify.
'
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Executed this May 17, 2020, at Orange, California.
RON CHOW, Declarant
DECLARATION OF RON CHOW IN SUPPORT OF JUDGMENT Page 3 et
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DECLARATION OF RON CHOW IN SUPPORT OF JUDGMENT Page 4 Exhibit A
ExhibitPage 5 State of California
S
Secretary of State
Statement of Information
FX1
(Domestic Stock and Agricultural Cooperative Corporations)
FEES (Filing and Disclosure): $ 25.00.
If this is an amendment, see instructions.
FILED
IMPORTANT — READ INSTRUCTIONS BEFORE COMPLETING THIS FORM
1.
CORPORATE NAME
In
the office of the Secretary of State
of the State of California
SOLARCITY ENGINEERING, INC.
MAY-31
2. CALIFORNIA CORPORATE NUMBER
This Space for Filing Use Only
C31
No Change Statement (Not applicable if agent address of record is a P.O. Box address. See instructions.)
If there have been any changes to the information contained in the last Statement of Information filed with the California Secretary
of State, or no statement of information has been previously filed, this form must be completed in its entirety.
If there has been no change in any of the information contained in the last Statement of Information filed with the California Secretary
of State, check the box and proceed to Item 17.
Complete Addresses for the Following
(Do not abbreviate the name of the city. Items 4 and 5 cannot be P.O. Boxes.)
STREET ADDRESS OF PRINCIPAL EXECUTIVE OFFICE
4.
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
3055 CLEARVIEW WAY, SAN MATEO, CA 5.
STREET ADDRESS OF PRINCIPAL BUSINESS OFFICE
6.
MAILING ADDRESS OF CORPORATION, IF DIFFERENT THAN ITEM
IN CALIFORNIA, IF ANY
Names and Complete Addresses of the Following Officers (The corporation must list these three officers. A comparable title for the specific
officer may be added; however, the preprinted titles on this form must not be altered.)
ADDRESS
CHIEF EXECUTIVE OFFICER/
7.
TODD MARON
6.
9.
ADDRESS
SECRETARY
TODD MARON
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
3055 CLEARVIEW WAY, SAN MATEO, CA 3055 CLEARVIEW WAY, SAN MATEO, CA ADDRESS
CHIEF FINANCIAL OFFICER/
3055 CLEARVIEW WAY, SAN MATEO, CA Names and Complete Addresses of All Directors, Including Directors Who are Also Officers (The corporation must have at least one
VACANCY VACANCY
director. Attach additional pages,
10. NAME
DEEPAK AHUJA
if
necessary.)
ADDRESS
ADDRESS
11. NAME
TODD MARON
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
3055 CLEARVIEW WAY, SAN MATEO, CA 3055 CLEARVIEW WAY, SAN MATEO, CA ADDRESS
12. NAME
13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY:
If the agent is an individual, the agent must reside in California and Item 15 must be completed with a California street
address, a P.O. Box address is not acceptable. If the agent is another corporation, the agent must have on file with the California Secretary of State a
certificate pursuant to California Corporations Code section 1505 and Item 15 must be left blank.
Agent for Service of Process
14. NAME OF AGENT FOR SERVICE OF PROCESS
C T CORPORATION SYSTEM
16. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA, IF AN INDIVIDUAL CITY
STATE
ZIP CODE
Type of Business
16. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION
SOLAR SYSTEM INSTALLATION, SEL
17. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATION
CONTAINED HEREIN, INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT.
05/31/DATE
SI-200 (REV 01/2013)
POA
KELLY LETTMANN
TYPE/PRINT NAME OF PERSON COMPLETING FORM
Page 1 of
TITLE
SIGNATURE
APPROVED BY SECRETARY OF STATEPage 6 Exhibit B
ExhibitPage 7 State of California
S
Secretary of State
Statement of Information
G
(Domestic Stock and Agricultural Cooperative Corporations)
FEES (Filing and Disclosure): $ 25.00.
If this is an amendment, see instructions.
FILED
IMPORTANT — READ INSTRUCTIONS BEFORE COMPLETING THIS FORM
1.
CORPORATE NAME
In
the office of the Secretary of State
of the State of California
SOLARCITY ENGINEERING, INC.
APR-06 2. CALIFORNIA CORPORATE NUMBER
This Space for Filing Use Only
C31
No Change Statement (Not applicable if agent address of record is a P.O. Box address. See instructions.)
If there have been any changes to the information contained in the last Statement of Information filed with the California Secretary
of State, or no statement of information has been previously filed, this form must be completed in its entirety.
If there has been no change in any of the information contained in the last Statement of Information filed with the California Secretary
of State, check the box and proceed to Item 17.
Complete Addresses for the Following
4.
(Do not abbreviate the name of the city. Items 4 and 5 cannot be P.O. Boxes.)
STREET ADDRESS OF PRINCIPAL EXECUTIVE OFFICE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
3500 DEER CREEK ROAD, PALO ALTO, CA 5.
STREET ADDRESS OF PRINCIPAL BUSINESS OFFICE
6.
MAILING ADDRESS OF CORPORATION, IF DIFFERENT THAN ITEM
IN CALIFORNIA, IF ANY
Names and Complete Addresses of the Following Officers (The corporation must list these three officers. A comparable title for the specific
officer may be added; however, the preprinted titles on this form must not be altered.)
7.
CHIEF EXECUTIVE OFFICER/
SANJAY SHAH
8.
ADDRESS
ADDRESS
SECRETARY
CHIEF FINANCIAL OFFICER/
YARON KLEIN
STATE
ZIP CODE
CITY
STATE
ZIP CODE
STATE
ZIP CODE
3500 DEER CREEK ROAD, PALO ALTO, CA
EMMANUELLE STEWART
9.
CITY
3500 DEER CREEK ROAD, PALO ALTO, CA
ADDRESS
CITY
3500 DEER CREEK ROAD, PALO ALTO, CA
Names and Complete Addresses of All Directors, Including Directors Who are Also Officers (The corporation must have at least one
director. Attach additional pages,
if
necessary.)
ADDRESS
10. NAME
ZACHARY KIRKHORN
ADDRESS
11. NAME
JONATHAN CHANG
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
3500 DEER CREEK ROAD, PALO ALTO, CA 3500 DEER CREEK ROAD, PALO ALTO, CA ADDRESS
12. NAME
13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY:
Agent for Service of Process
If the agent is an individual, the agent must reside in California and Item 15 must be completed with a California street
address, a P.O. Box address is not acceptable. If the agent is another corporation, the agent must have on file with the California Secretary of State a
certificate pursuant to California Corporations Code section 1505 and Item 15 must be left blank.
14. NAME OF AGENT FOR SERVICE OF PROCESS
C T CORPORATION SYSTEM
15. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA, IF AN INDIVIDUAL CITY
STATE
ZIP CODE
Type of Business
16. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION
SOLAR SYSTEM INSTALLATION, SEL
17. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATION
CONTAINED HEREIN, INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT.
04/05/DATE
SI-200 (REV 01/2013)
POA
KELLY LETTMANN
TYPE/PRINT NAME OF PERSON COMPLETING FORM
Page1of
TITLE
SIGNATURE
APPROVED BY SECRETARY OF STATE
PDF Page 1
PlainSite Cover Page
PDF Page 2
Electronically Filed
by Superior Court of CA,
County of Santa Clara,
on 5/27/2020 11:12 AM
Reviewed By: S. Alvarez
Case #19CV350566
Envelope: 4381751
GARDENER, RIEcH~ k CHow
Ron Chow S.B. 241946
438 E. Katella Ave, Ste 202
Orange, CA 92867
P: 714 972-8989 F: 714 972-3928
E: ron@grclawfirm.corn
Attorneys for Plaintiff
CURRENT POWER ELECTRIC, INC.
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CLARA, DOWNTOWN SUPERIOR COURT (DTS)
Jl
9
10
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11
CURRENT POWER ELECTRIC, INC.,
Plaintiff,
12
&
Case No.: 19CV350566
DECLARATION OF RON CHOW IN
SUPPORT OF JUDGMENT
~x
;:
13
&J
::
—,-,
,—,.
',-'5
14
('1
'-.
SOLARCITY ENGINEERING INC; AND
DOES 1 TO 10, INCLUSIVE,
Defendants.
16
d5
-
17
I" I
DECLARATION OF RON CHOW
18
19
I, RON CHOW, declare as follows:
eP
20
M:
1.
C
I am a partner with the law firm
of Gardener, Riechmann k Chow, attorneys for plaintiff herein.
21
2. This declaration is made in response to the rejection
23
3.
of the application for default judgment.
Plaintiff submitted request for default judgment against Defendant on 12/24/19. Default was entered
on 9/29/19,
24
4. This court rejected the judgment because
"l. Venue appear improper; 585 Dec attaches invoice w/
San Mateo address, complaint says "Defendant's address"
5.
This case was filed on July 3, 2019.
DECLARATION OF RON CHOW IN SUPPORT OF JUDGMENT
1
PDF Page 3
6. The invoice that is the subject
of this case was issued on 12/17/2016 against Defendant
SOLARCITY ENGNEERING INC at 3005 Clearview Way, San Mateo, CA 94402, which is San
Mateo County.
5
7, At that time according to the California Secretary
of State, Defendant was located at 3005 Clearview
Way„San Mateo„CA 94402. See Defendant's Statement of Information filed May 31, 2018, a true
g
and correct copy of which is attached to this declaration as Exhibit "A".
7
(
8.
Subsequently, Defendant moved from 3005 Clearview Way, San Mateo, CA 94402 to 3500 Deer
Jl
9
Creek Road, Palo Alto, CA 94304 in about April of 2019. See Defendant's Statement of
10
"'"
Information filed April 5, 2019, a true and correct copy of which is attached to this declaration as
" ll
I
Exhibit "B".
12
s
~&;- 13
9.
14
Defendant's current address of 3500 Deer Creek Road, Palo Alto, CA 94304 is within the county of
this court. Venue is appropriate as the Defendant is currently located within this county.
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10.
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= 17
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Plaintiff requests entry of default judgment against the Defendant.
16
I declare, under penalty
of perjury, under the laws of the State of California, that the foregoing is
18
true and correct, that I possess personal knowledge thereof, and that if called to testify regarding same, I
19
could and would so testify.
'0
FJ
Executed this May 17, 2020, at Orange, California.
21
RON CHOW, Declarant
25
27
DECLARATION OF RON CHOW IN SUPPORT OF JUDGMENT
2
PDF Page 4
10
et 11
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Kamila
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21
22
23
24
25
26
27
28
DECLARATION OF RON CHOW IN SUPPORT OF JUDGMENT
3
PDF Page 5
Exhibit A
Exhibit
PDF Page 6
State of California
S
Secretary of State
Statement of Information
FX1 6990
(Domestic Stock and Agricultural Cooperative Corporations)
FEES (Filing and Disclosure): $ 25.00.
If this is an amendment, see instructions.
FILED
IMPORTANT — READ INSTRUCTIONS BEFORE COMPLETING THIS FORM
1.
CORPORATE NAME
In
the office of the Secretary of State
of the State of California
SOLARCITY ENGINEERING, INC.
MAY-31 2018
2. CALIFORNIA CORPORATE NUMBER
This Space for Filing Use Only
C31 03057
No Change Statement (Not applicable if agent address of record is a P.O. Box address. See instructions.)
If there have been any changes to the information contained in the last Statement of Information filed with the California Secretary
of State, or no statement of information has been previously filed, this form must be completed in its entirety.
If there has been no change in any of the information contained in the last Statement of Information filed with the California Secretary
of State, check the box and proceed to Item 17.
3
Complete Addresses for the Following
(Do not abbreviate the name of the city. Items 4 and 5 cannot be P.O. Boxes.)
STREET ADDRESS OF PRINCIPAL EXECUTIVE OFFICE
4.
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
3055 CLEARVIEW WAY, SAN MATEO, CA 94402
5.
STREET ADDRESS OF PRINCIPAL BUSINESS OFFICE
6.
MAILING ADDRESS OF CORPORATION, IF DIFFERENT THAN ITEM 4
IN CALIFORNIA, IF ANY
Names and Complete Addresses of the Following Officers (The corporation must list these three officers. A comparable title for the specific
officer may be added; however, the preprinted titles on this form must not be altered.)
ADDRESS
CHIEF EXECUTIVE OFFICER/
7.
TODD MARON
6.
9.
ADDRESS
SECRETARY
TODD MARON
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
3055 CLEARVIEW WAY, SAN MATEO, CA 94402
3055 CLEARVIEW WAY, SAN MATEO, CA 94402
ADDRESS
CHIEF FINANCIAL OFFICER/
3055 CLEARVIEW WAY, SAN MATEO, CA 94402
Names and Complete Addresses of All Directors, Including Directors Who are Also Officers (The corporation must have at least one
VACANCY VACANCY
director. Attach additional pages,
10. NAME
DEEPAK AHUJA
if
necessary.)
ADDRESS
ADDRESS
11. NAME
TODD MARON
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
3055 CLEARVIEW WAY, SAN MATEO, CA 94402
3055 CLEARVIEW WAY, SAN MATEO, CA 94402
ADDRESS
12. NAME
13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY:
If the agent is an individual, the agent must reside in California and Item 15 must be completed with a California street
address, a P.O. Box address is not acceptable. If the agent is another corporation, the agent must have on file with the California Secretary of State a
certificate pursuant to California Corporations Code section 1505 and Item 15 must be left blank.
Agent for Service of Process
14. NAME OF AGENT FOR SERVICE OF PROCESS
C T CORPORATION SYSTEM
16. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA, IF AN INDIVIDUAL CITY
STATE
ZIP CODE
Type of Business
16. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION
SOLAR SYSTEM INSTALLATION, SEL
17. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATION
CONTAINED HEREIN, INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT.
05/31/2018
DATE
SI-200 (REV 01/2013)
POA
KELLY LETTMANN
TYPE/PRINT NAME OF PERSON COMPLETING FORM
Page 1 of 1
TITLE
SIGNATURE
APPROVED BY SECRETARY OF STATE
PDF Page 7
Exhibit B
Exhibit
PDF Page 8
State of California
S
Secretary of State
Statement of Information
G 666234
(Domestic Stock and Agricultural Cooperative Corporations)
FEES (Filing and Disclosure): $ 25.00.
If this is an amendment, see instructions.
FILED
IMPORTANT — READ INSTRUCTIONS BEFORE COMPLETING THIS FORM
1.
CORPORATE NAME
In
the office of the Secretary of State
of the State of California
SOLARCITY ENGINEERING, INC.
APR-06 2019
2. CALIFORNIA CORPORATE NUMBER
This Space for Filing Use Only
C31 03057
No Change Statement (Not applicable if agent address of record is a P.O. Box address. See instructions.)
If there have been any changes to the information contained in the last Statement of Information filed with the California Secretary
of State, or no statement of information has been previously filed, this form must be completed in its entirety.
If there has been no change in any of the information contained in the last Statement of Information filed with the California Secretary
of State, check the box and proceed to Item 17.
Complete Addresses for the Following
4.
(Do not abbreviate the name of the city. Items 4 and 5 cannot be P.O. Boxes.)
STREET ADDRESS OF PRINCIPAL EXECUTIVE OFFICE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
3500 DEER CREEK ROAD, PALO ALTO, CA 94304
5.
STREET ADDRESS OF PRINCIPAL BUSINESS OFFICE
6.
MAILING ADDRESS OF CORPORATION, IF DIFFERENT THAN ITEM 4
IN CALIFORNIA, IF ANY
Names and Complete Addresses of the Following Officers (The corporation must list these three officers. A comparable title for the specific
officer may be added; however, the preprinted titles on this form must not be altered.)
7.
CHIEF EXECUTIVE OFFICER/
SANJAY SHAH
8.
ADDRESS
ADDRESS
SECRETARY
CHIEF FINANCIAL OFFICER/
YARON KLEIN
STATE
ZIP CODE
CITY
STATE
ZIP CODE
STATE
ZIP CODE
3500 DEER CREEK ROAD, PALO ALTO, CA 94304
EMMANUELLE STEWART
9.
CITY
3500 DEER CREEK ROAD, PALO ALTO, CA 94304
ADDRESS
CITY
3500 DEER CREEK ROAD, PALO ALTO, CA 94304
Names and Complete Addresses of All Directors, Including Directors Who are Also Officers (The corporation must have at least one
director. Attach additional pages,
if
necessary.)
ADDRESS
10. NAME
ZACHARY KIRKHORN
ADDRESS
11. NAME
JONATHAN CHANG
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
CITY
STATE
ZIP CODE
3500 DEER CREEK ROAD, PALO ALTO, CA 94304
3500 DEER CREEK ROAD, PALO ALTO, CA 94304
ADDRESS
12. NAME
13. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY:
Agent for Service of Process
If the agent is an individual, the agent must reside in California and Item 15 must be completed with a California street
address, a P.O. Box address is not acceptable. If the agent is another corporation, the agent must have on file with the California Secretary of State a
certificate pursuant to California Corporations Code section 1505 and Item 15 must be left blank.
14. NAME OF AGENT FOR SERVICE OF PROCESS
C T CORPORATION SYSTEM
15. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA, IF AN INDIVIDUAL CITY
STATE
ZIP CODE
Type of Business
16. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION
SOLAR SYSTEM INSTALLATION, SEL
17. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATION
CONTAINED HEREIN, INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT.
04/05/2019
DATE
SI-200 (REV 01/2013)
POA
KELLY LETTMANN
TYPE/PRINT NAME OF PERSON COMPLETING FORM
Page1of1
TITLE
SIGNATURE
APPROVED BY SECRETARY OF STATE
Back to 
