Motion Summary JudgmentCal. Super. - 6th Dist.April 30, 2021Otomflmm-th-‘t MNNMNNMNNAAAAAAAAAA mem¥®NAO©mN®m#WN-‘ 21 CV381 264 Santa Clara - Civil Claudia Gavrilescu, Esq. (CA Bar No. 333030) REESE LAW GROUP 3 168 Lionshead Avenue Carlsbad, CA, 92010 Tel. No.: 760/842-5850 Attorney for Plaintiff: WELLS FARGO BANK, N.A. SUPERIOR COURT OF CALIFORNIA, COUNTY 0F SANTA CLARA SANTA CLARA JUDICIAL DISTRICT, SAN JOSE SUPERIOR COURT WELLS FARGO BANK, N.A., V. TITA F ARAFILES, Plaintiff, Defendant. Please take notice that on the date, time and department set forth above located at 191 North First Street, San Jose, CA 951 13, Plaintiff WELLS FARGO BANK, N.A. will move this court for summary judgment against Defendant TITA F ARAFILES (hereinafter “Defendant”) or in the alternative, for an order granting summary adjudication against Defendant and in favor 0f Plaintiff’s causes of action in the Complaint, 0n the grounds that Plaintiff has established the elements 0f its causes of action for Breach of Contract and Common Counts, and on the grounds that there is no defense t0 this action and that there is no triable issue of fact. V. Castaneda Electronically Filed by Superior Court of CA, County of Santa Clara, on 1I20l2022 5:43 AM Reviewed By: V. Castaneda Case #21 CV381 264 Envelope: 8094959 Case No. 21CV381264 NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION Date: 6-7-22 Time: 9:00 am Dept: 2 Assigned Judge: Complaint Filed: April 30, 2021 Trial Date: May 23, 2022 NOTICE OF MOTION AND MOTION FOR SUMNIARY JUDGMENT Case N0. 21CV38 1264 OR IN THE ALTERNATIVE SUMMARY ADJUDICATION 1 A OLDWNODU‘l-POON This motion is based 0n this Notice, all supporting Memoranda 0f Points and Authorities, all Supporting Declarations, the Separate Statement of Undisputed Material Facts, Request for Judicial Notice, as well as all pleadings and papers filed herein, and all evidence and argument Which may be presented at the hearing 0n the motion. f) n I ‘ ‘\ Dated: January 18, 2022 W Claudia Gavrilescu, Esq., Attorney for Plaintiff NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT Case No. 21CV38 1264 OR IN THE ALTERNATIVE SUMMARY ADJUDICATION 2
