Motion StrikeCal. Super. - 6th Dist.October 2, 201815 l6 l7 l8 20 21 22 23 24 25 26 27 28 Maria Wong, in propria persona c/o 4874 Scarletwood Terrace San Jose, California [95129] Tel: 408-823-8598 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA 191 N. 15‘ St., San Jose, CA 951 10 Civil Limited Jurisdiction CAPITAL ONE BANK, (USA) NA. ) Case No. 18-CV-336042 . . > Alleged Plaintiff ) DEFENDANT / CROSS-COMPLAINANT ) MARIA WONG, ”3' ) 1. MOTION T0 STRIKE VACATING MARIA WONG, ) JUDGE PATRICIA M. LUCAS ORDER T0 ) NOT RECUSE HERSELF CCP 170.6 Alleged Defendant ) 2. MOTION T0 STRIKE VACATING ) RECUSED JUDGES ORDER GRANTING ) PLAINTIFF MOTION FOR ADMISSIONS MARIA WONG, ) DEEMED ADMITTED g 3. DECLARATION Cross-Complainant ) Date: E I 03,7“ 1391/ 10/ 7 ) Time: 9 AM ) Dept: 9 CEO Janalie Ann Henriques ofHUNT & ) JUdgeI Mary E. Arand HENRIQUES, INC, ANTHONY J. DIPIERO, Esq #268246 ROES 1-5 VS. ) ) COMPLAINT FILED: October 1, 2018 ) CROSS-COMPLAINT FILED: June l7, 2019 ) TRIAL DATE: None Set Cross-Defendant(s) g JURY TRIAL DEMANDED TO: THE COURT, THE CLERK OF THE ABOVE-ENTITLED COURT, THE PLAINTIFF AND COUNSEL FOR PLAINTIFF, CROSS-DEFENDANTS, AND ANY INTERESTED PARTIES: Page1 of 8 Case # 18-CV-336042- Alleged Defendant] Cross-Complainant MARIA WONG, Motion for Order Vacating Judges refusal to recuse and Motion for Order Vacating recused Judges Order Granting Plaintiffs Admissions Deem Admitted 20 21 22 23 24 25 26 27 28 a c 7" .2 2 , 22 ° / 7 On SeptembeHW at 9 AM or at time deemed by the Court, the above captioned court Defendant / Cross-Complainant MARIA WONG will move the court for a 1) Motion to Stn'ke, Vacating Judge Patricia M. Lucas, July 16, 2019 refusal to recuse herself from the hearing date of July 18, 2019, at 9 AM, as a Judge cannot rule on their own recusal and 2) Motion to Strike, Vacating Twice Recused Judge Patricia M. Lucas, Order Granting the Plaintiff / Cross - Defendants Motion to Admissions Deemed Admitted. DEFENDANT MOTION FOR ORDER TO STRIKE, 1) VACATING JUDGES, CCP 170.6 FILING, REFUSING TO RECUSE HERSELF AND 2) VACATING TWICE RECUSED JUDGES ORDER GRANTING PLAINTIFF ADMISSIONS DEEMED ADMITTED Alleged Defendant / Cross-Complainant for MARIA WONG, by her own hand in propria persona, filed a CCP 170.6 filing, recusing Judge Patricia M. Lucas on July l6, 2016, from hearing Plaintiffs Motion for Admissions Deemed Admitted with hearing scheduled for July 18, 2019, 9 AM, "due to being prejudiced against my interests so that I cannot have a fair and impartial hearing/trial before her", hereby 1) moves this court for an Order Vacating Judge Patricia M. Lucas unlawfully signing her own order refusing my CCP 170.6 to recuse herself from a hearing scheduled for July 18, 2019, 9 AM. (EXHIBIT - A -) 2) Moves this court for an Order Vacating Recused Judge Patricia M. Lucas Order Granting Plaintiff, Attorney Anthony DiPiero Admissions Deemed Admitted, filed a fraudulent, scandalous motion to deny Alleged Defendant / Cross-Complainant MARIA WONG acknowledgement of fact, that MARIA WONG did respond, NOTADMITTING PLAINTIFF'S ADMISSIONS on April 29, 2019, to Plaintiff‘s Admissions Deemed Admitted. (EXHIBIT - B -) ARGUMENT IN SUPPORT OF MOTION FOR ORDER VACATING JUDGE PATRICIA M. LUCAS REFUSAL TO RECUSE HERSELF PER CCP 170.6 FILING Maria Wong makes the following arguments in support of her Motion to Strike, Vacating Judge Patricia M. Lucas July 16, 2019 order denying alleged defendant / cross-complainant MARIA WONG, her lawful right, under California Law, to recuse a Judge deemed to be biased and prejudice against her. Page 2 of 8 Case # 18-CV-336042- Alleged Defendant I Cross-Complainant MARIA WONG, Motion for Order Vacating Judges refusal to recuse and Motion for Order Vacating recused Judges Order Granting Plaintiff‘s Admissions Deem Admitted 11 12 l3 20 21 22 23 24 25 26 27 28 While researching online, MARIA WONG found Judge Patricia M. Lucas has accusations against her 0f taking bribes, along with many other accusations of conduct unbecoming of a Judge, then realized HUNT & HENRIQUES INC. possibly specifically picked her court to hear their motion to grant their fraudulent admissions on May 15, 2019. HUNT & HENRIQUES INC. contract attorney, Alan Sherwood, told MARIA WONG at the Ex Parte hearing before Judge Mary E. Arand, on April 30, 2019, 9 AM, that she was 'going to lose this case', that ‘there is no way she could win'. She began to realize HUNT & HENRIQUES INC. may have privileged connections, relationships and inroads to the court, as seen by the voluminous complaints online against HUNT & HENRIQUES INC being able to get judgments granted by Judges in Superior Courts of California before trial dates are even held, or claiming defendants were served when so many say they were never served, by judgments, liens & wage garnishments being levied without defendants not even knowing they were being sued, thus HUNT & HENRIQUES INC. may have a ringer(s), or go to Judges, that will rule in their favor regardless of the facts, shutting down defendants ability to speak before the court, refusing to hear / see evidence proving Plaintiff accusations improper, wrong or outright lies. Judge Patricia M. Lucas rejected my Peremptory Challenge CCP 170.6 recusal request, stating it was 'Untimely', then unlawfully signing the order herself, which is unlawful and contrary to the judicial procedures in Superior Courts of California, for a Judge to sign their own order denying the request to not have herself recused. It is my understanding that the matter must be presented to the Presiding Judge, Deborah A. Ryan, a hearing held within 5 days and another judge sign any order granting or denying the Peremptory Challenge CCP 170.6 or another Judge sit in for the recused Judge. My rights as a tax paying resident / citizen of the State of California were severely violated by Judge Patricia M. Lucas. The basis for a CCP §170.6 challenge affidavit to be filed with the Court is that the party or attorney believes that (1) the challenged judge is prejudiced against such pany or attorney or his or her interest, and (2) that the party or attorney cannot have a fair and impanial trial before that judge. (CCP §170.6 (a)(2)) Any party or attorney appearing in the action has standing to make a CCP § 170.6 challenge. (CCP § 170.6 (a)(2)) But note that if a party has more than one attorney, only one of his or her attorneys may make this challenge. (Pappa v. Sup. Ct. (1960) 54 Cal.2d 350, 355.) Page 3 of 8 Case # 18-CV-336042- Alleged Defendant! Cross-Complainant MARIA WONG, Motion for Otder Vacating Judges refusal to recuse and Motion for Order Vacating recused Judges Order Granting Plaintiff‘s Admissions Deem Admitted 12 l3 l4 15 l7 l8 20 21 22 23 24 25 26 27 28 Once the challenge is made, it is automatically accepted by the Court and the truth of the affidavit cannot be challenged - that is why it is peremptory. A CCP §170.6 challenge must be timely. (Grant v. Sup. Ct. (Jacobs) (2001) 90 Cal.App.4th 5 1 8, 527) The general rule is that “disqualification of the judge is permitted any time prior to the commencement oftrial.” (People v. Sup. Ct. (Lavi) (1993) 4 Cal.4th 1164, 1171) Per CCP §170.6 (a)(2), a peremptory challenge may not be made after the following things occur: 1. The drawing of the name of the first juror; or 2. If a nonjury trial, after plaintiff” s counsel makes his or her opening statement; or 3. If there is no such opening statement, after the swearing in of the first witness or the giving of any evidence; or 4. “after trial of the cause has otherwise commenced.” On July 15, 2019 I prepared my Affidavit: Peremptory Challenge CCP 170.6 for Judge Patricia M. Lucas to recuse herself "due t0 being prejudiced against my interests s0 that I cannot have afair and impartial hearing/trial before her". It was filed in California Superior Court, County of Santa in a 'timely' manner on July 16, 2019, prior to the hearing date ofJuly 18, 2019, 9 AM as stated above, even prior to any tentative ruling in the case on July 17, 201 9 at 2 PM. I called the Clerk of Court for Judge Patn'cia M. Lucus before 4 PM on July 17, 2019 notifying the Court I was contesting Judge Patricia M. Lucus tentative ruling 'Granting' the Plaintiff‘s false claims that I did not respond to their Admissions, when I clearly did, when on April 29th, 201 9 the admissions and production of documents was mailed to HUNT & HENRIQUES INC. via USPS Certified Mail 701 8 1130 0000 7829 9448, (EXHIBIT - C -), with Proof of Service witness, Jeffery Black, which was filed with the court in multiple filings, and available for Judge Patricia M. Lucas in previously filed submission to case, in this Superior Court of Califomia, County of Santa Clara. When I appeared in court on Thursday morning, July 18, 2019 at 9 AM before Judge Patricia M. Lucas, the first thing I read to the court was the following: Page 4 of 8 Case # 18-CV-336042- Alleged Defendant I Cross-Complainant MARIA WONG, Motion fat Order Vacating Judges refusal to recuse and Motion for Order Vacating recused Judges Order Granting Plaintiff's Admissions Deem Admitted 20 2] 22 23 24 25 26 27 28 "Judge Patricia M. Lucas, I recusedyou and I ’m concerned that you are biased against me now andyou will only retaliate against me here and now and I demand a written appealable ruling 0f findings offact and conclusions oflaw. " (EXHIBIT - D -) I asked Judge Patricia M. Lucas, whether she read my entire case, including my objections and cross-complaint, which she said she had, then when I wanted to hand her the physical evidence proving that the Plaintiff attorney lied to the court, committed fraud upon the court, the Judge refused to see any evidence. She asked whether there was anything new in my statement to the court, since I knew the evidence was included in various forms in previous filings with the court, I said 'No'. Judge Patricia M. Lucas said she was ready to make a ruling, 'Granting Plaintiff‘s Motion to Admit Admissions' which per the evidence should of been readily evident to the court for the evidence ofmy Admissions sent to the Plaintiff, that I did not admit to what the Plaintiff lied to the court that I did. I felt I was bullied by the Judge and she ruled, this was concluded in all of 5 minutes or less from opening words in court, as if the Judge had better things to be doing than seeking justice for a 64 year old elderly Asian woman, who is not an attorney or lawyer trying to defend herself for a unlawful, wrongful lawsuit by a vicious predatory law firm called HUNT & HENRIQUES INC, where going into California Superior Court is the equivalent to a slaughterhouse mentality. Judge Patricia M. Lucas showed prejudice and bias from the beginning, which became fully evident by going forward ruling on her own recusal, personally unlawfully denying my request for her recusal, then proceeding with the motion on the case and making an obvious legally wrong ruling that shows extreme prejudice and bias based on the evidence previously submitted into the court record. During the Thursday, July 18, 2019, 9 AM Court hearing on the motion, I had 5 - witnesses (Dr. Corey Crochiere, Rania Cao, Hang (Rose) Tran, Trang Duong, Jeflery Black) in the courtroom as I already sensed Judge Patricia M. Lucas was going to be prejudiced, bias and retaliatory toward me for recusing her, at minimum, (Jeflery Black was my ProofofService witness to my April 29, 201 9 mailing ofmy response t0 the Plaintiff's requestsfor admissions andproduction ofdocuments, which the Judge didn’t want to see 0r hearfrom) I had these witnesses in the courtroom watching Page 5 of 8 Case # 18-CV-336042- Alleged Defendant I Cross-Complainant MARIA WONG, Motion for Order Vacating Judges refusal to recuse and Motion for Order Vacating recused Judges Order Granting Plaintiff's Admissions Deem Admitted l9 20 2] 22 23 24 25 26 27 28 the proceedings because there was 'NO' court reporters, nor any known recordings of the proceedings. The judge is participating and violating the fair debt collection act and financial elder abuse. The judge should be investigated for bribes and just how many cases as she ruled in HUNT & HENRIQUES INC. favor. The evidence shown above lends suppon to the appearance of Judge Patricia M. Lucas to be “fixing” cases for HUNT & HENRIQUES INC and gives support to the appearance, possibility of truth, to online allegations of the Judge taking bribes. HUNT & HENRIQUES, INC. and Attorney ANTHONY J. DIPIERO, Esq #268246 have a history, custom, and practice of violations of the fair debit collection act and have been sued in a class-action law suit in federal court filed 12/1 6/2016 Case No. l6-CV-3048 CAB alleging similar unlawful acts and violation of the fair debit collection act as this instant case. Since a Cross-Complaint was filed on June 17, 2019 in Superior Court of California, County of Santa Clara, then by law in California, this barred Judges hearing any motions by the Plaintiff from being heard by the Court, prior to the Cross-Complaint being heard first before the Court and ruled upon, which a hearing is scheduled for November 12, 2019. By law, all Plaintiff hearings, motions must of stopped being heard by the Court until the cross-complaint was heard first. If that were not enough for the Plaintiff attorneys and Judge showing a blatant disregard of rule of law, the Alleged Defendant / Cross-Complainant filed a Motion to Dismiss, which isn't schedule to be heard by the Coun until October 17, 2019. Therefore, the Alleged Defendant/ Cross-Complainants rights to having a neutral, fair, unbiased court is put in question and jeopardy, resulting in her day in court being denied, due to being circumvented by both the Plaintiff and the Judge, giving the appearance of the possibility they are working in collusion with one another, in an attempt by Plaintiff‘s attorneys to deny MARIA WONG due process and deceiving the Court into Granting an Order that amounts to a summary judgment that Plaintifi is not entitled to, as seen by all the filings the Plaintiff‘s attorneys are filing with the court, claiming summary judgment. This type of reckless and or predatory behavior seems to be the hallmark ofHUNT & HENRIQUES INC. and their attorneys. Courts have "fundamental inherit equity, supervisory, and administrative powers, as well as inherent power to control litigation before them." (Rutherford v. Owens-Illinois, Inc.(1997) 16 Cal. Page 6 of 8 Case # 18-CV-336042- Alleged Defendant I Cross-Complainant MARIA WONG, Motion for Order Vacating Judges refusal to recuse and Motion for Order Vacating recused Judges Order Granting Plaintiffs Admissions Deem Admitted 12 l3 l4 15 l6 l7 18 l9 20 2| 22 23 24 25 26 27 28 4th 953,967.) This court has failed to control the litigation before them by hearing the Plaintiffs Motion to Deemed Matters Admitted. CONCLUSION For the reasons set forth above, the court record, exhibits, and any oral argument in furtherance of the 1) Motion to Strike, Vacating Judge Patricia M. Lucas refusal to recuse herself when CCP 170.6 was filed in a timely manner and 2) Motion to Stn'ke, Vacating recused Judge Patricia M. Lucas Granting Plaintiff‘s Motion to Deem Matters (Admissions) Admitted to. The Plaintiff‘s and Judges actions in this instance and case are Scandalous, Fraudulent, Self-Serving and Frivolous. Plaintiff attorney Anthony J. DiPiero in addition to the proceeding reasons may have violated PC-125/PC- 118, California Business & Professional Code § 6129, and both HUNT & HENRIQUES INC, CEO Janalie Ann Henriques, and Anthony J. DiPiero are named Cross-Defendant in the instant case. PRAYER Alleged Defendant and Cross-Complainant, MARIA WONG prays the Court accepts the 1) Motion to Strike, Vacating Judge Patricia M. Lucas, July 16, 2019 refusal to recuse herself from the hearing date 0f July 18, 2019, at 9 AM, as a Judge cannot rule on their own recusal and 2) Motion to Strike, Vacating a twice Recused Judge Patricia M. Lucas, Order 'Granting' the Plaintiff / Cross - Defendants Motion to Admissions Deemed Admitted Plaintiff‘s Motion. The actions of both Judge Patricia M. Lucas and the Plaintiff‘s attorney, Anthony DiPiero, are Malfeasance, Scandalous, Committing Fraud upon the Court, Self-Serving and Frivolous, award sanctions of $2,500 dollars, costs and fees of the litigation, and terminating sanctions dismissing Plaintiff‘s law suit. Dated: August 2, 2019 By: 771W W0» \ Maria Wtfixg, alleged Defendgat and Cross-Complainant in Propria persona DECLARATION I, Man'a Wong, declare as follows: 1. I am the alleged Defendant and Cross-Complainant in the above-entitled matter. Page 7 of 8 Case # 18-CV-336042- Alleged Defendant I Cross-Complainant MARIA WONG, Motion for Order Vacating Judges refusal to recuse and Motion for Order Vacating recused Judges Order Granting Plaintiff's Admissions Deem Admitted l3 l4 15 l6 17 18 l9 20 2| 22 23 24 25 26 27 28 2. I have read the foregoing l) Motion to Strike, Vacating Judges Refusal to Recuse as well as 2) Motion to Strike, Vacating Twice Recused Judges Order 'Granting' Plaintiff‘s Motion for Admission Deemed Admitted and know the contents thereof. 3. The same is true ofmy own knowledge, except as to those matters which are therein stated on information and belief, and, as to those matters, I believe it to be true. Executed on August 2, 2019, at Santa Clara County, California. I declare (or certify) under pains of perjury that the foregoing is true and correct to the best ofmy knowledge. Dated: August 2, 2019 By:WWM\ / Maria ang, in Propria persofl VERIFICATION I, the undersigned make this declaration under penalty of perjury, that the pleading is true. Each of the signer(s) of this document is a person having firsthand knowledge of the facts stated herein. The undersigned has made a reasonable inquiry into fact and law and affirms to the Court that this claim: 1. is not frivolous or intended solely to harass. 2. is not made in Bad Faith - Nor for any improper purpose, i.e. harass or delay. 3. may advocate changes in the law - arguments justified by existing law or non-frivolous argument to change law. 4. has Foundations for factual allegations - alleged facts have evidentiary support. 5. and has Foundation for denials - denials of factual allegations must be warranted by evidence. Date: August 2, 2019 By 7745M ”m Y Maria Wonk, Alleged Defendant @ross- Complainant, in Propria persona Page 8 of 8 Case # 18-CV-336042- Alleged Defendant I Cross-Complainant MARIA WONG, Motion for Order Vacating Judges refusa| to recuse and Motion for Order Vacating recused Judges Order Granting Plaintiffs Admissions Deem Admitted PROOF OF SERVICE BY [ X ]MAIL OR [ ]PERSONAL SERVICE In the California Republic state, of the Santa Clara county. I, the undersigned, herein declare that I am over the age 0f eighteen years and NOT a party to the within entitled action. My business address is: 405 El Camino Real, Ste 61 l, Menlo Park, California [94025]. I hereby declare under the penalty 0f perjury of the California Republic state and these united States of America, thatI served the foregoing registered document as entitled: on the opposing party(s) by registering with the post office maintained by the United States, Postal Service with postage paid or by evidence 0f file stamp, addressed as follows: CAPITAL ONE BANK (USA), N.A. c/o Hunt & Henriques Inc, Attorneys at Law Attorney Anthony J. DiPiero 151 Bemal Road Suite 8 San Jose, California 951 19 DEFENDANT MOTION FOR ORDER T0 STRIKE, l) VACATING JUDGES, CCP 107.6 FILING, REFUSING TO RECUSE HERSELF AND 2) VACATING TWICE RECUSED JUDGES ORDER GRANTING PLAINTIFF ADMISSIONS DEEMED ADMITTED I declare under the penalty of perjury of the Laws 0f the California Republic state and these united States 0f the America, that the foregoing is correct and complete to the best of my knowledge, information and belief, and that this declaration is executed by the voluntary act ofmy own hand in San Jose Township and is dated below; DatezAugust 2,2019 g 2 éé MJA Jeffery Black r 405 E1 Camino Real, Ste 611 fl / ’ Jeffery Black Menlo Park, California [94025] EXHIBIT -A- June 16, 2019, CCP 107.6 RECUSAL OF JUDGE PATRICIA M. LUCAS WITH COPY OF HER REFUSAL TO RECUSE 23 24 25 26 27 28 Maria Wong, in propria persona g ($113.“i gaps c/o 4874 Scarletwood Terrace «:9' g figérx San Jose, California [95 129] ii: 52$? 44 I J é? - - - - ‘9 A 6’ r ,. ‘ 1’ 0,10}! “I [a ,. SUPERIOR COURT OF CALIFORNIA ‘ “"129?th COUNTY 0F SANTA CLARA 32% 191 N. First Street, SAN JOSE, CA 95113 5907), 6. Q0hr. CAPITAL ONE BANK (USA), N-A- 3 Case No. 18-CV-336042 "“304 Alleged Plélntlff ) Alleged Defendant / Cross-Complainant vs_ ' ) MARIA WONG, Peremptory Challenge of ) Judge Patricia M. Lucas MARIA WONG, ) [FRCP Rule 7(b) and C.C.P. 170.6] ) Alleged Defendant ) Judge Patricia M. Lucas g Case Filed: 10/02/201 8 MARIA WONG’ g Attachment: Points & Authorities Cross-Complainant ) ) Hearing Date: July 18, 2019 V5. ) Time: 9:00 AM ) Dept. 9 HUNT & HENRIQUES, INC., ) CEO. JANALIE ANN HENRIQUES, ) COMPLAINT FILED: October 2, 2018 #1 1 1589 ) CROSS-COMPLAINT FILED: June l7, 2019 ANTHONY J. DIPIERO, Esq #268246 ) TRIAL DATE: None Set ROES 1-5 ) ) JURY TRIAL DEMANDED )Cross-Defendant(s) PLEASE TAKE NOTICE that Alleged Defendant / Cross-Complainant, MARIA WONG, submits a peremptory challenge, to Patricia M. Lucas: STATE OF CALIFORNIA, ) COUNTY OF SANTA CLARA ) DECLARATION OF TRUTH I, Maria Wong, declare: Page1 of 2 Case Number 18~CV-336042, CAPITAL ONE BANK (USA), N.A. vs. MARIA WONG Peremptory challenge of Judge Patricia M. Lucas by Alieged Defendant I Cross-Complainant MARIA WONG 14 15 16 l7 l8 19 20 2] 22 23 24 25 26 27 28 7. 8. I am your Declarant. Your Declarant is known as, and legally known as, Maria Wong. Your Declarant states that the undersigned is a party to the within action, as a Alleged Defendant / Cross-Complainant. Your Declarant makes a timely declaration, per statute, for peremptory challenge against Judge Patricia M. Lucas. Your Declarant is mentally competent, and makes these statements under penalty of perjury, and has personal knowledge of that which is declared, and these statements are true, correct, and not misleading. Your Declarant states that the undersigned believes that Judge Patricia M. Lucas, before whom the heafing/trial in this case is pending, is prejudiced against my interest so that I cannot have a fair and impartial hearing/trial before her. Your Declarant makes this declaration under penalty of pexjury that the foregoing is true and correct. Further Declarant Sayeth Naught. Executed on July 15th, 2019 in San Jose, California ByMm WONG, Allegéd Defendant / Cross- Complainant Page 2 of 2 Case Number 18-CV-336042, CAPITAL ONE BANK (USA), N.A. vs. MARIA WONG Peremptory challenge of Judge Patricia M. Lucas by Alleged Defendant / Cross-Complainant MARIA WONG SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA COURT ADDRESS: 191 North First Street. San José. CA 951 13 Filed MAIUNG ADDRESS; 191 North First Street July 16’ 201 9 CITY AND ZIP CODE: San José, CA 951 13 Clerk 0f the Court BRANCH NAME: Downtown Courthouse Superior Court of CA FOR COURT USE ONLY PLAINTIFF: Capital One Bank County of Santa Clara 18CV336042cpK By: hkeniston DEFENDANT: Maria Wong CASE NUMBER: REQUEST FOR ACTION 18cv336042 Date: 7/16/2019 To Judge; Patricia Lucas g For your review and instruction For your information m Other Defendant filed a peremptory challenge under CCP 170.6 on 7/1 6/2019. There has not been any challengesnfiled by Defendant in this case. There is a motion set on 7/18/2019 in this matter. Is the challenge timely? Legal Process Clerk Superviia’Wanager Approval H. eniston Order of Court D File Stamp D Schedule Hearing D Place in File - No Action Required a Order(s) as Follows: Date: No the Challenge is not timply CCP 170 6 requires that when a iudge not aqsigned for all purposes is known at least 1O days before the hearing, the challenge must be made five days ' ’ -po ‘6 0-“’- 6/17. Th9 challenge iq denied a: untimely Signed: 7/16/2019 10:54 AM P0111Ma’l $64.0 7/1 6/19 Judicial Officer cw-9003 REV 5/23/03 REQUEST FOR ACTION Page 1 on EXHIBIT -B- July 18, 2019, Twice Recused Judge Patricia M. Lucas Order Granting Plaintifl‘s Motion Admissions Deemed Admitted SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA MINUTE ORDER Capital One Bank (USA), N.A. vs Maria Wong Hearing Start Time: 9:00 AM 18CV336042 Hearing Type: Hearing: Discovery Date of Hearing: 07/18/2019 Comments: Heard By: Lucas, Patricia M Location: Department 3 Cou rtroom Reporter: Parties Present: DiPiero, Anthony Wong, Maria Exhibits: - No Court Reporter Attorney Defenda nt/Cross Complaina nt Cou rtroom Clerk: Cou rt Interpreter: Cou rt Investigator: Future Hearingg: Naomi Matautia - Plaintiff cou nsel appeared via court call. Matter contested -- and was heard. Tentative ruling adopted as follows: G ra nted Pn'nted: 7/19/2019 07/18/2019 Hearing: Discovery - 18CV336042 Page EXHIBIT -C- Alleged Defendants / Cross-Complainant MARIA WONG, April 29, 2019 submittal of Completed Plaintiffs Admissions and Productions 0f Documents, with Proof of Service and USPS Certified Mail 7018 1130 0000 7829 9448 Receipt Maria Wong, in propria persona c/o 4874 Scarletwood Terrace San Jose, California [95129] Tel: 408-823-8598 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA 191 N. 18‘ St, San Jose, CA 95110 Civil Limited Jurisdicu'on CAPITAL ONE BANK (USA), NA. ) Case No. 18-CV-336042 ) Plaintiff, ) DEFENDANT RESPONSE ) T0 PLAINTIFF'S REQUEST vs. g FOR ADMISSIONS ) MAMA WONG, ) ) Defendant, ) ) ) ASKING PARTY: PLAINTIFF CAPITAL ONE BANK (USA), NA. RESPONDING PARTY: DEFENDANT MARIA WONG SET NUIWBER‘ ONE To Plaintiff Capital One Bank (USA), N.A. The following response to requwt that Defendant MARIA WONG make admission "EACH OF THE FOLLOWING FACTS IS TRUE: " First to Plaintifi‘ counsel, your request for admissions paper work is incomplete as received consisting of one page paginaled as "page 6" I am not obligated to r&cpond or correct your papers and therefore any response may not be deemed final, RESPONSE ADMISSION NUMBER 1: I do not Admit or Agree and insist on proof at trial. RESPONSE ADMISSION NUMBER 2: I do not Admit or Agree and insist on proof at tn'al. RESPONSE ADMISSION NUMBER 3: I do not Admit or Agree, and insist on proof at trial. RESPONSE ADMISSION NUMBER 4: I do not Admit or Agree and insist on proof at trial. RESPONSE ADMISSION NUMBER 5: I do not Admit or Agree and insist on proof at trial. I Maria Wong respond and make the statements above although I am not obligated to r&spond and not required to guess or correct papers and therefore any response made is not to be deemed final. Dated: April 29, 2019 k By: mW W537 ( Mariaang Man'a Wong, in propria persona c/o 4874 Scarletwood Terrace San Jose, California [95129] SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY 0F SANTA CLARA 191 N. 1“ St, San Jose, CA 95110 Civil Limited Jurisdiction CAPITAL ONE BANK (USA), N‘A- g Case No. 18-CV-336042 Plaintiff, ) DEFENDANT RESPONSE To ) PLAINTIFF'S DEMAND FOR Vs. ) PRODUCTION 0F DOCUMENTS ) To DEFENDANT MARIA WONG, ) SET ONE MARIA WONG, ) ) [CCP § 2030.010 et seq] Defendant, ) ) ) ASKING PARTY: PLAINTIFF CAPITAL ONE BANK (USA), N.A. RESPONDING PARTY: DEFENDANT MARIA WONG SET NUMBER: ONE To Plaintiff Capital One Bank (USA),NA The following response to requwt that alleged Defendant MARIA WONG "production of documents must be verified, dated, and signed." and "Plaintiff Capital One Bank (USA),NA demands that you produce and permit the inspection and copying, pursuant to § 2030.010 et seq, of the Code of Civil Procedure of the following documents" RESPONSE INTERROGATORY NUMBER 1: I do not have any records of submitting a request for a credit account to Capital One Bank (USA), N.A. First lets addms the cost of your demands for the production of documents and your failure to provide the customary request and ofi'er to pay for the time, travel expenses, copy chargw, Etc. Simply put MARIA WONG cannot fully comply to unfunded demands, especially in a frivols Suit that should never been filed due to lack of Standing, Jurisdiction, and Improper Venue (refer to alleged contract). NOTICE§ 0F COSTS SERVICE§ AND EXPEN§E§ 1. MARIA WONG: $300.00 Per Hour bill able in 1/4 Hour increments and Two Hour minimum for trip requests thereafter actual time. 2. Copy chargw $0.50 Per Page. 3. Service of Process $1 00.00 Per Service 4. Travel, actual cost of Taxi, Uber, Lyft (est. $30.00 each way to fi’om your office) Or 5. Mileage $1.20 Per Mile (act. $60.00 round tn'p to your omce) DEFENDANT RESPONSE TO PLAINTIFF'S DEMAND FOR PRODUCTION OF DOCUMENTS T0 DEFENDANT MARIA WONG, SET ONE l. RESPONSE TO PRODUCTION OF DOCUMENTS NUMBER 1: At this time I am not in possession of any records to provide. 2. RESPONSE TO PRODUCTION OF DOCUMENTS NUMBER 2: At this time I am not in possession of any records to provide. 3. RESPONSE TO PRODUCTION OF DOCUMENTS NUMBER 3: At this time I am not in possession of any records to provide. Afier my notice of cost are addressed I can check further. 4. RESPONSE TO PRODUCTION OF DOCUMENTS NUMBER 4: At this time I am not in possession of any records to provide. If Plaintiff answers my Bill of Particulars this may change. 5. RESPONSE T0 PRODUCTION OF DOCUMENTS NUMBER 5: At this time I am not in possession of any records to provide. Again, If and Whm Plaintiffls) comply with my formal requwt for Bill of Particulars this may change. I declare under pains of perjury under the laws of the State of California that the foregoing is true and correct to the bat of my knowledge and belief , and believe them to be true. Dated: April 29, 2019 By; 74W Mam , Maliaan PROOF OF SERVICE BY MAIL In the California Republic state, of the Santa Clara county, I, the undersigned, herein declare thatI am over the age of eighteen years and NOT a pany to the within entitled action. My business address is: 405 E1 Camino Real, Ste 61 l, Menlo Park, California [940251 I hereby declare under the penalty of perjury of the California Republic state and these united States of America, that I served the foregoing registered document as entitled: on the opposing party(s) by registering with the post office maintained by the United States, Postal Service with postage paid or by evidence of file stamp, addressed as follows: CAPITAL ONE BANK, (USA), NA. c/o Hunt & Henriques, Attorneys at Law 151 Berna] Road Suite 8 San Jose, California 951 19 DEFENDANT, MARIA WONG's RESPONSE T0 PLAINTIFF'S REQUEST FOR ADMISSIONS AND DEFENDANT, MARIA WONG's RESPONSE TO PLAINTIFF'S DEMAND FOR PRODUCTION 0F DOCUMENTS I declare under the penalty of perjury of the Laws of the California Republic state and these united States of the America, that the foregoing is correct and complete to the best of my knowledge, information and belief, and that this declaration is executed by the voluntary act ofmy own hand in San Jose Township and is dated below; Date: 4/29/2019 Jeffery Black 405 El Camino Real, Ste 611 V Jeffery Black Menlo Park, California [94025] NON-NEGOTIABLE, NON-ASSIGNABLE (CertifiedMail Nnmber# 7"01'9 Li30 00w ??zfifitfg/g FAXTRANMSSION (408) 362-2299 Maria Wong c/o 4874 Scarletwood Terrace San Jose, California [95129] April 29, 201 9 Mr. Anthony Dipiero c/o HUNT & HENRIQUES Attorneys at Law 151 Bemal Road, Suite 8 San Jose, California 951 19 Subject: l“ Notice of Written Request for Verification of Debt Reference: CAPITAL ONE BANK (USA), N.A. / MARIA WONG 5M8). Case Number: 18CV336042 It is hereby requested in writing that you provide ven'fication of this alleged debt within the time set certain of21 days fi'om this date until May 20, 2019. The verification of debt is to be as follows: 1) 2) 3) 4) 5) 6) 7) 8) 9) Name and address of the holder in due course of the alleged Debt, and any first hand witnwses, A copy of the original signed Contract and all of {ts amendments, addendums, between the parties, ‘ Copy ofthe original signature for web item listed on the account statements, Verification is to be attested, under penalty of pcxjury, by a wet ink signature, Debt Collector Verification Disclosure Statement = Attachment “A”, Affidavit of Individual Surety Form filled out = Attachment “ B”, Proof of Claim Pre Petition for Disclosure per 11 USC Bankruptcy Code = Attachment “C”, Notice to any Valid Claimants of Title 15 Fair Debt Collection §l692 = Attachment “D”, Attachment “E” is your offer to contract (law suit) made by Unrecorded-Foreign-Agents, 10) PROVE that you are not in Violation of California Business and Professions Code § 6129. Failure to provide the verification in thjs format within the time set certain as provided above will constitute a Default on your part. Notice to Agent is Notice to Principal; Notice to Principal is Notice to Agent Presented by: //s//Maria Won Maria Wong This is a non-negotiable Legal Instrument under the Uniform Commercial Code (UCC) II USPS.com® - USPS TrackingQ Results 1 FA haps://tools.mps.comlgon‘rackConfi1mActio USPS TrackinQO FAQ: > Wd/www.ucps.comlfaqsluspstacldng-faqs.htzn) Track Another Package + Remove X Tracking Number: 701 81 130000078299448 Your item was delivered to an individual at the address at 9:39 am on May 3, 2019 in SAN JOSE, CA 95119. ‘. , (9/ Delivered May 3, 2019 at 9:39 am Delivered, Left with Individual SAN JOSE. CA 951 19 Get Updates V SeaMore \ U S Postal Serwce CERTJHED MM? Domestic Mai} Only anus l SAN JBSEr fifi 951 19 . Certsfied Mal! Fae _ _,. L $354.! / Emamcesafiees/mccx adding 4mm; DEM. mmmaaopyy s_i ’ ‘ unou” Rocaim‘wmu) 3gmm- macaw $1.3: 5: :AnunsmmMm s ""‘ :Aduumamnmvum-s m Postage _ . s: .xs \ Tam? Pastnge and Foo: \ 4 wt. ' s L I ‘J‘. Sen! Tomg WMAW/ Azflzgga..................... '5‘er music :1. fleflj44 (80.49.” 49.174?yW aim C4 V 7,3; / ‘ 701.6 1.1.30 DUDE] 7625 Go to our FAQs section to find answers to your tracking questions. FAQs (httpsd/www.usps.comlfaqs/uspswacking-faqshtm) EXHIBIT -D- MARIA WONG'S NOTES TO BE SUBMITTED INTO EVIDENCE TO THE COURT ON JULY 18, 2019 @ 9 AM, DEPT 3 CAPITAL ONE BANK (USA), N.A. v MARIA WONG Page 1 of 8 Good morning your Honor, | would like to submit my notes and comments today into the official record. Note: If not allowed, I would like to read my notes into the record. First it must be stated: The attorneys here with HUNT & HENRIQUES INC. are Cross-defendants therefore flex cannot testify in today's HEARING without their attorney being present. They cannot represent themselves. Next do you have my opposition and rebuttals in front of you? And your Honor, did you read both my opposition and rebuttal in their entirety? J_‘ua/gg I Agat’m c/ yea ano/Z'm fl'dflc'é/"flec/ 454% you d/aei A/é'ggo/ 4 aan/ ”7e Almxz/ flfld 704/ Wz// éfl/y fle/a//a%£ QJQURS?’ @{d Z flécase, 70a Kata. aflO/flalx/an JJ é/vM/ao/ A h/g/zééey aM4/4-é/t flaAO. 0f f/flOV/Jj Kéo/f 4/70/ [Zw/c/j/ou'of /a(,4/ MARIA WONG NOTES FOR JULY 18, 2019 - 9 AM, DEPT 3 CASE #18-CV-336042 Motion to Deem Matters Admitted by Plaintiff Capital One Bank (USA), N.A. (Anthony DiPiero) CAPITAL ONE BANK (USA), N.A. v MARIA WONG Page 2 of 8 THIS CASE IS BASED ON CONTRACT LAW PER HUNT & HENRIQUES INC INITAL FILING. TWO CONTRACTS ARE CRITICAL TO THIS CASE: 1) WET INK AUTOGRAPH CONTRACT BETWEEN MARIA WONG AND CAPITAL ONE BANK (USA), N.A. (NEVER PRODUCED AND NOW HUNT & HENRIQUES DISCOVERY IS CLOSED 10-DAYS AFTER CCP-454 SERVED ON JUNE 25TH, 2019) 2) WET INK AUTOGRAPHED CONTRACT BETWEEN HUNT & HENRIQUES INC AND CAPITAL ONE BANK (USA), N.A. (NEVER PRODUCED AND NOW HUNT & HENRIQUES DISCOVERY IS CLOSED 10-DAYS AFTER CCP-454 SERVED ON JUNE 25TH, 2019) The Plaintiff‘s attorneys are completely without justification in bringing the Motion and seeking an "order that matters in request for admission of truth of facts be admitted" and the attempt is Scandalous, Misleading the Court, Self-Serving and Frivolous. This is an attempt by Plaintiffs attorneys to deny the Defendant due process and deceive the Court into issuing an Order that amounts to a summary judgment that Plaintiff is not entitled t0. This type of reckless and or predatory behavior seems to be the hallmark ofHUNT & HENRIQUES and their attorneys. MARIA WONG NOTES FOR JULY 18, 2019 - 9 AM, DEPT 3 CASE #18-CV-336042 Motion to Deem Matters Admitted by Plaintiff Capital One Bank (USA), N.A. (Anthony DiPiero) CAPITAL ONE BANK (USA), N.A. v MARIA WONG Page 3 of 8 1) On HUNT & HENRQUES’ Letters delivered by the U.S. Postal Service), HUNT & HENRIQUES claim they are a Debt Collector. So HUNT & HENRIQUES INC. stated thev a Debt Collector, and now they are trying to represent before the Court they are Attorneys representing the Plaintiff, CAPITAL ONE BANK (USA), N.A. - they CANNOT be both. NOTE: Give to Judge the 3 Samples... 2) If HUNT & HENRIQUES is a California Corporation and they are a _D_efi Collector as stated, then the debt collector cannot bring a lawsuit in the State of California. In letters received from HUNT & HENRIQUES INC, delivered via the United States Postal Service, they clearly state they are a debt collector. (EXHIBIT G proves HUNT & HENRIQUES is a California Corporation) 3) If HUNT & HENRIQUES is indeed hired legal counsel for Capital One Bank (USA), N.A., then CAPITAL ONE BANK (USA), N.A. cannot bring a lawsuit in the State of California or California Superior court. They can only bring a lawsuit under Virginia Law and Courts or United States Federal Courts according to their own agreement on the internet. (EXHIBIT H) 4) Based on the information above, this case should not, and cannot, be tried in California Superior Court. On April 29th, 2019, Three (3) - separate actions took place by the Defendant in communicating with the Plaintiff: 5) First on April 29th, 2019, Defendant mailed a response Plaintiff Discovery by replying to: 1) Admissions and 2) Production of Documents, with Proof of Service, (my proof of service witness is here in the court today) to Attorney ANTHONY J. DIPIERO and HUNT & HENRIQUES INC. (EXHIBIT D) MARIA WONG NOTES FOR JULY 18, 2019 - 9 AM, DEPT 3 CASE #18-CV-336042 Motion to Deem Matters Admitted by Plaintiff Capital One Bank (USA), N.A. (Anthony DiPiero) CAPITAL ONE BANK (USA), N.A. v MARIA WONG Page 4 of 8 6) Secondly on April 29th, at 9:50 AM Defendant notified Anthony DiPiero of the Ex Parte filing which was heard on April 30th, The Honorable Judge Mary E. Arand issued the Ex Parte Order on May 2nd, and it was filed with the court on May 3rd, Please read Honorable Judge Arand's Court Order in its entirety (EXHIBIT B) 1) Vacating the May 6, 2019 Trial Date, Set a Conference Date of July 9, 2019, 11 AM, which was held 2) Extending the Defendant's time to respond to Plaintiff's Discovery in its entirety to May 29th, which contained the following: 9’ lnterrogatories, b. Admissions, The Plaintiff's Form RequestforAdmissions to be accepted was NEVER signed or returned by Alleged Defendant, c. Production of Documents, d. Proof of Service Please note Plaintiff's sloppy Discovery request - Law firm papers seem to be deliberately confusing and several pages were missm (including Pages 4 & 5). (EXHIBIT C) Lastly the Defendant makes a strong argument that the Ex Parte papers must be liberally construed, and that when Defendant asked for and got extension of time it was for "ALL DISCOVERY" 7) Lastly on April 29, 2019 a separate 21-Page of Request for Defendants Discovery was sent to Plaintiff Attorney ANTHONY J. DIPIERO, subsequently MARIA WONG NOTES FOR JULY 18, 2019 - 9 AM, DEPT 3 CASE #18-CV-336042 Motion to Deem Matters Admitted by Plaintiff Capital One Bank (USA), N.A. (Anthony DiPiero) CAPITAL ONE BANK (USA), N.A. v MARIA WONG Page 6 of 8 c. physical proof that Hunt & Henriques Inc. is the attorney of record for Capital One d. validations & audit of each and every claim, e. providing witnesses with firsthand knowledge to each alleged transaction, f. proof that the Defendant was present during each transaction presented by the Plaintiff, also g. proof of relationship between alleged Plaintiff and Hunt & Henriques. Look at this list of times the Defendant request for documents was ignored: 11) On March 13, 2019 a letter to mailed, with Proof of Delivery and receipt, which was basically ignored by Plaintiff (EXHIBIT A) 12) On April S, 2019 a letter to mailed with Proof of Delivery and receipt, which was ignored by Plaintiff (EXHIBIT A) 13) Attorney ANTHONY J. DIPIERO and HUNT & HENRIQUES INC. are infull default on both requests. 14) On April 29, 2019 a separate 21-Page Request for documents, admissions, production of documents, etc was sent to Plaintiff, 15) May 23, 2019 the 21-Page of Request Package, etc was resent to Plaintiff that along with notice they were in DEFAULT 16) Lastly on May 30, 2019 the Zl-Page of Request Package was resent to Attorney ANTHONY J. DIPIERO Esq #268246, subsequently HUNT & HENRIQUES INC. with full notice of default. (ALL 3 - ARE EXHIBITED IN MY JUNE 24TH, 2019 FILED OPPOSITION TO MOTION FILED ON JUNE 24, 2019) MARIA WONG NOTES FOR JULY 18, 2019 - 9 AM, DEPT 3 CASE #18-CV-336042 Motion to Deem Matters Admitted by Plaintiff Capital One Bank (USA), N.A. (Anthony DiPiero) CAPITAL ONE BANK (USA), N.A. v MARIA WONG Page 8 of 8 Defendant/Cross Complainant while they make a mockery of the Rule of Law, the Court and the Judges 23) Attorney ANTHONY J. DIPIERO Esq #268246, subsequently HUNT & HENRIQUES INC. are showing a history of refusing to fully answer Alleged Defendant / Cross Complainant requests for proof of wet ink contract between Plaintiff and Defendant under Contract Law, proof of relationship with Plaintiff, validation and audit of each individual charge, proof of their lawful right to sue in California Superior Court, witnesses with first-hand knowledge of all allegations. The Defendant pleads with the Court to: 1) Deny Plaintiff's Motion as Scandalous, Misleading the Court, Self-Serving and Frivolous, 2) Grant the Defendant damages are stated and, 3) Dismiss the case based upon the Rule of Law with the evidence presented MARIA WONG NOTES FOR JULY l8, 2019 - 9 AM, DEPT 3 CASE #18-CV-336042 Motion to Deem Matters Admitted by Plaintiff Capital One Bank (USA), N.A. (Anthony DiPiero) "Fir HUNT&HENRIQUES s. I t ~ t - - * 1&3: . I . “Towns ”MW r laljgnouqoe also 2m.0“” ‘15: asanuxaanswnn” ’ '“C‘é‘mffflg-Jn-azfe sanyosrcmnoxmassiu T“’““""~‘5’2°f2 Mun“! jANA] 11.! m i9, 201’9‘ MARIA WONG . 4874.SCARLETWOODIER i:- SAN Jose CA 95129-1939; Ryyh CamemBankwsaxNA/MARIAWONG ..;_;' ' 7 ‘ OurCliem. CapitaIOncBank (USA),NA ' X ' a 3 ;"'Aocount Ending 2709 Your rwént inquiry has been forwarded to ‘me for respome Enclosedfindwefiafloumgaocomdocmncmsf. r . 1. Awoum Stamens from: Februty 6,2017 through February 6 2018. 11 -' A, ' -_ . I ' r ' - ATTORNEYS AT LAW mCHAEL s. HUNT ‘ 151 BERNAL ROAD, SUITE 8 ‘ w JANALIE HgNRIQUES ‘ > SAN Jose, CA 951 191306 ‘ September 6. 2018 v < _ WONG. _ L Eagmn . LETWOOD TER. "SAN Jose CA 95129-1939 Re NOTICE 0F INTENT To FILE sun AND INCUR COURT cosrs ~ CMTAL ONE BANK (USA). NA Account number ending in: 2709 Balance due as of September 6, 2018: 54.175.35 fmar MARlAWONG : ‘ b This firm isa®g very WW Yours : " 53“?) Anthony DIPIeI'O L , . Hunt &'Henan$ ‘ l r t I r ‘ VHUNT a HENRIQUES ATTORNEYS AT LAW ‘ 151,BERNAL ROAD. suns a ' 3m Jose CA ww-saos v 'mum SERVICE REQUESTED ' ~ MH'uP”;-"-J‘l‘sfii'vh-illls‘flmll'i‘l'lmt'lll'l'l ~ ' MARIA WONG ; 4374 semmmooo TER - SAN Jose CA 95129-1939 17"»; ‘. - ,4 HUNWHENRIQUES TELEPHONE 800-680-2426 FACSIMILE 408-362-2299 TTY 800-735v2922 ‘j The purpése-of thisalettef 15k) advisé' you that our firm intends to file suit against you on behalf of our client CAPITAL ft: ONE BANK (USA). NA. Legal action could r&suh in a judgment against you that would include the costs and necessary g disbursemms which shafl be limited to the actual cost of the filing fee and the actual costs of service of process. a MICHAELS. HUNT JANALIE HENRIQUES ‘mFH "y‘""~'.-va-. HUNT & HENRI o 1“ ATTORNEYSATLAW 151 BERNALROADSUITES SANIOSECALIFORNIA95119 *1usrnofiuuaus ‘2 FACSINIL‘E ‘cfi-3‘2-2299 TTY 800-735-7292va particular amount is actually being claimed, not to vouch for the validity of the underlying debt.” Chaudhrv v. Gallezjzzo, 174 F.3d 394, 406 (4m cir. 1999). Notwithstanding {hat Capital One Bank (USA), N.A. is not required to validate under either federal or stale law and that a debtor is not authorized to request any particular documents as ‘ and state law. Anfiony DiPi‘crq r . _ = Hung & Hémiqucsz Anomeys at Law - ' verification or validation oftbe debt, this office did provide validation on March 19, 2019 and on May 6, 201 9. Our validation letter provided you with the name ofthe creditor - Capital One Bank (USA), N.A. -who is your original creditor, as well copies of account statements for the account ‘ fit issue. The aqcount statemcnts enclosed in our May 6, 2019, letter provided you with the full account nutnber.‘A copy hfour May 6, 2019 lefler is enclosed for your convenience. Hunt & Henriques arid Capital One Bank (USA), N.A. are in full compliance with both federal- ‘ 7 1fyim Egve'an’y quesfidhs, you may contact me undersigned ax (877) 732-9498. mg. ,