Declaration

Cal. Super. - 6th Dist.October 25, 2018

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 180V337007 Santa Clara - Civil Mark W. Good (Bar N0. 218809) EleCtronically Filed LAW OFFICE OF MARK W. GOOD by Superior Court of CA, 7415 Eigleberry Street, Suite 102 County of Santa Clara, Gilroy, CA 95020 on 1/8/2020 7:32 PM Telephone (408) 300-5309 Reviewed By: D Harris Facsumle (408) 513-6299 case #1 3cv337007 Attorney for Opportunity Fund Community Development EnveloPe: 3862259 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA OPPORTUNITY FUND COMMUNITY Case N0. 18CV337007 DEVELOPMENT, DECLARATION OF MARK W. GOOD IN Plaintiff, SUPPORT OF REQUEST FOR ENTRY OF DEFAULT JUDGMENT VS. CALEB ’ S EXPRESS TRANSPORTATION LLC, SAYDA AYALA PINTO, and DOES 1 t0 10, inclusive, Date Action Filed: October 25, 2018 Defendants. Trial Date: None I, Mark W. Good, declare: 1. I am the attorney for plaintiff Opportunity Fund Community Development (“Opportunity Fund”), movant herein. Ihave personal knowledge 0f the facts set forth in this declaration, and if called as a witness, I could and would competently testify to the matters contained herein. 2. Opportunity Fund sued defendants CALEB’S EXPRESS TRANSPORTATION LLC and SAYDA AYALA PINTO (“defendants”) for breach 0f contract and common counts based on defendants” failure t0 pay back a loan as agreed t0 by the parties in a written contract. 3. Defendant was properly served with a summons and complaint and failed to respond in any manner. Default was entered against defendant effective 0n 03/25/2019. 1 DHa DECLARATION OF MARK W. GOOD IN SUPPORT OF REQUEST FOR ENTRY OF DEFAULT JUDGMENT rris 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4. Although the contract between the parties contained an attorney fee clause, attorney fees were calculated using the Court’s schedule 0f reasonable attorney fees. The principal amount sued on was $52,276.69. Under the Court’s schedule, the amount of reasonable attorney fees for principal amounts between $10,001 and $50,000 are $2,600.00 plus 2% over the amount of $50,000. The attorney fees due in this case under the schedule are therefore $2,645.53 ($2,600 + $45.53 [2% X $2,276.69]). I declare under penalty 0f perjury under the laws 0f the State of California that the foregoing is true and correct. Executed this 3rd day of January, 2020 at Gilroy, California /s/ Mark W. Good Mark W. Good 2 DECLARATION OF MARK W. GOOD IN SUPPORT OF REQUEST FOR ENTRY OF DEFAULT JUDGMENT