Krause v. Moreno
Helen L. Krause sued Steven Moreno in his individual capacity and as trustee of The Steven Moreno Trust for allegedly delaying the settlement of Krause's claims in a probate matter. Moreno was properly served with the summons and complaint. Six months later Krause amended the complaint to add Cal-Jems Irrevocable Trust (Cal-Jems) and Moreno, as trustee of Cal-Jems, as Doe defendants. Krause served the amendments on Moreno by mail but failed to attach a copy of the summons and complaint. The trial court granted Moreno's motion to quash service on Cal-Jems and himself as trustee. We reverse.[1]



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