Motion StrikeCal. Super. - 6th Dist.November 25, 2019l6 17 18 19 20 21 22 23 24 25 26 27 28 LINO V. MARTIRE (SBN 169639) E'ectronlcally Flled LAW OFFICES 0F LINO V. MARTIRE by Super“ 30"” 0f CA: 1 ALMADEN BLVD, SUITE 505 County of Santa Clara, SAN JOSE, CALIFORNIA 951 13 on 11/9/2020 2:03 PM Lino.martire@martirelaw.com Reviewed By; R_ Tien TELEPHONE: (408) 280-6898 Case #19cv359203FACSIMLE: (408) 280~6899 Envelope: 5264453 Attorney for Defendant IDC TECHNOLOGIES, INC. IN THE SUPERIOR COURT OF CALIFORNIA COUNTY 0F SANTA CLARA Case No.2 19CV359203 INNOVA CONSULTING SERVICES, LLC, DEFENDANT IDC TECHNOLOGIES,dba CELERUS CONSULTING, a Delaware [Na,s NOTICE OF. MOTION T0 Limited Liability Company» STRIKE PLAINTIFF’S COMPLAINT AND ITS ANSWER T0 DEFENDANT’S Plaintiff, CROSS- COMPLAINT Date of Hearing: $Bér 1 /26/21 Time 0f Hearing: 9:00 am. Dept: fl 1 9 VS. IDC TECHNOLOGIES, INC. a California Corporation and DOES 1 through 50, inclusive, Defendants. TO PLAINTIFF/CROSS-DEFENDANT INNOVA CONSULTING SERVICES, LLC, DOING BUSINESS AS CELERUS CONSULTING AND ITS ATTORNEY OF RECORD: YOU ARE HEREBY NOTIFIED that the motion of defendant/cross-complainant IDC TECHNOLOGIES, INC to strike the Complaint and Answer t0 Cross~Comp1aint filed by Innova Consulting Services, LLC on November 25, 2019 and the Answer to Cross-Complaint filed by Innova Consulting Services, LLC on February 18, 2020, will be heard in Department 21 ofthe Santa Clara County Superior Court, located at 161 North First St, San Jose, California, 951 13, at 9:00 am. on a date to be determined by the Court, or as soon thereafter as the motion may be Innova Consulting Services, LLC v. IDC Technologies, Inc. DEFENDANT IDC TECHNOLOGIES, INC.’S NOTICE OF MOTION TO STRIKE PLAINTIFF’S COMPLAINT AND ITS ANSWER TO DEFENDANT’S CROSS- COMPLAINT I 14 15 16 l7 l8 19 20 21 22 23 24 25 26 27 28 heard. This motion is made 0n the grounds that plaintiff/cross-defendant Innova Consulting Services, LLC is n0 longer represented by counsel and cannot represent itself without an attorney of record. The relief requested is an order striking the Complaint filed by plaintiff/cross- defendant Innova Consulting Services, LLC on November 25, 2019 and the Answer to Cross- Complaint filed by plaintiff/cross-defendant on February 18, 2020. This motion is authorized by C.C.P. Section 436 and is based on all of the pleadings, papers and records in this action, plaintiffs’ memorandum of points and authorities, the declaration of Mafiire and any evidence presented at the hearing. Dated: November jg, 2020 Respectfully submitted, By: Wpa/k LINO V. MARTIRE Attorney for Defendant IDC Technologies, Inc. Innova Consulting Services, LLC v. IDC Technologies, Inc. DEFENDANT IDC TECHNOLOGIES, INC.’S NOTICE OF MOTION TO STRIKE PLAINTIFF’S COMPLAINT AND ITS ANSWER TO DEFENDANT’S CROSS- COMPLAINT ’1
