Memorandum At Issue

Cal. Super. - 6th Dist.April 29, 2021

I Henry J. Yandell, Esq. SBN: 321114 Kambrie L. Keith, Esq. SBN: 303847 2 Lina M. Michael, Esq. SBN: 237842 MICHAEL dk, ASSOCIATES, PC 3 555 St. Charles Drive, Suite 204 Thousand Oaks, California 91360 4 Telephone: (805) 379-8505 Facsimile: (805) 379-8525 5 Attorneys for Plaintiff, 6 American Express National Bank Our File Number: 20126738 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SANTA CLARA 10 LIMITED CIVIL CASE American Express National Bank., Successor 12 by Merger to American Express Bank, FSB, Plaintiff, 14 15 Christopher Aubuchon, aka Christophe 16 Aubuchon, aka Christopher M Aubuchon, an individual; Does I to 20. 17 Defendants. 19 TO ALL INTERESTED PARTIES: Case Number: 21CV381090 PLAINTIFF'S AT-ISSUE MEMORANDUM 21 PLEASE TAKE NOTICE that Plaintiff filed a Summons and Complaint on April 29, 24 q days but not prior to ninety (90) days. 25 DATE: October ~, 2021 26 MICHAEL k ASSOCIATES, PC 27 Henry J. Yandell, Attorney for Plaintiff 2021. Defendant filed an Answer on or about August 4, 2021. Discovery has been completed by both parties and the case is currently at issue. Plaintiff re uests the court set this matter for a 2-4 hour bench trial within the next 180 PLAINTIFF'S AT-ISSUE MEMORANDUM Electronically Filed by Superior Court of CA, County of Santa Clara, on 10/18/2021 8:21 AM Reviewed By: Y. Chavez Case #21CV381090 Envelope: 7480167 21CV381090 Santa Clara - Civil Y. Chavez PROOF OF SERVICE 2 I, the undersigned, declare: 3 I am a citizen of the United States of Ainerica, am over the age of eighteen (18) years, and not a party to the within action. I am an employee of the law firm of Michael & Associates, PC and my business address is 555 St. Charles Drive, Suite 204, Thousand Oaks, California 91360. 6 On October t 4, 2021, I caused to be served the following documents: PLAINTIFF'S AT-ISSL'K MEMORANDUM 8 on the party involved and address as follows: 9 Christopher M. Aubuchon 835 Mesa Court Palo Alto, CA 94306-3711 Tel: 650-269-6466 Defendant in Pro Per 13 BY PERSONAL DELIVERY: I caused such envelope to be delivered by hand to the offices of each addressee above, 14 X BY MAIL: I caused each envelope, with postage thereon fully prepaid, to be placed in the United States mail at Thousand Oaks, California. I atn "readily familiar" with the business 16 practice for collection and processing of mail in this office; that in the ordinary course ol business said document would be deposited with the U.S. Postal Service in Thousand Oaks on that same day. I understand that service shall be presmned invalid upon motion of a party served 18 if the postal cancellation date or postage meter date on the envelope is more than one day after the date of deposit for mailing contained on this declaration. 19 BY FACSIMILE: By use of facsimile machine telephone number 805-379-8525, I served 20 a copy of the within document on the above interested patties at the facsimile number(s) listed above on this date before 5:00 p.m. 21 BY FEDERAL EXPRFSS OVERNIGHT DELIVERY: I am "readily familiar" with the firm's practice of collection and processing correspondence for Federal Express. Under that 23 practice„ it would be picked up by a representative on that same day, in the ordinary course of business and would be delivered the next business day. 24 25 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 26 EXECUTED: October 1 ~, 2021, at Thousand Oaks, Calif 27 Amanda Jo son PLAINTIFF'S AT-ISSUE MEMORANDUM