Application Ex Parte No FeesCal. Super. - 6th Dist.April 27, 202110 11 12 13 14 15 16 l7 18 19 20 21 22 23 24 25 26 27 28 \_..-_ v. .-_.~-, ROBERT T. TANG, Esq., SBN 296544 1 The Law Office of Robert T. Tang JUN 1' 7 2021 255 N. Market Street, Suite 244 Clerk of the ComSan Jose, CA 95 1 10 aupanor Gem: e! 9A figumv st Sam Clara (408) 816-8098 5y ’ r fi ‘j- s Attorney for Defendant, LIEM BUT, dba BEST CLEANERS SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA UNLIMITED CIVIL CASE Case No.2 21CV38 1279 l 1402 CAMDEN LLC, a California Limited Liability | EX PARTE APPLICATION Company, I RE MOTION TO SET ASIDE | DEFAULT/VACATE DEFAULT | JUDGMENT; and | POINTS AND AUTHORITIES Plaintiff, I v. I I LIEM BUI, dba BEST CLEANERS l Date: June 17, 2021 I Time: 9:00 am. I Dept; Defendant. | Judge: | l l I Complaint Filed: 04/27/2021 Defendant, LIEM BUT, dba BEST CLEANERS (hereinafter “Defendant”), respectfufly hereby moves the Court under Code of Civil Procedure (CCP) Section 473 for an ex parte order setting aside the default entered in this action on May 25, 2021 and vacating a default judgment entered in this action on May 26, 2021. Defendant further moves for an order permitting Defendant to file an Answer, a true and correct copy is attached to this motion and incorporated by reference and appear at trial on the merits. EX PARTE APPLICATION RE MOTION TO SET ASIDE DEFAULT/VACATE DEFAULT JUDGMENT; AND POINTS AND AUTHORITIES 10 11 12 l3 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 This motion to set aside the default and vacate the default judgment taken against the Defendant on the grounds that: 1. Defendant’s surprise. Defendant was prevented from responding due to Plaintiff’s failure to properly serve the Defendant and provide him actual notice of the action against him. 2. The court lacks personal jurisdiction over Defendant because he was not properly served by the Plaintifl. This Motion is based upon the supporting Declaration 0f Liem Bui; Declaration of Robert T. Tang; Declaration of Thuy Do; the attached Points and Authorities; upon all the papers and records on file herein; and on such evidence as may be presented at the hearing of the motion. f7 Robert T Tang / Dated: June 15, 2021 EX PARTE APPLICATION RE MOTION TO SET ASIDE DEFAULT/VACATE DEFAULT JUDGMENT; 2 AND POINTS AND AUTHORITIES 10 11 12 13 14 15 16 l7 18 19 20 21 22 23 24 25 26 27 28 NIEMORANDUM OF POINTS AND AUTHORITIES I.W On May 3 1, 2017, Defendant, Liem Bui, dba Best Cleaners entered into a commercial lease (hereinafter “Lease”) with Plaintiff, 1402 Camden LLC (hereinafier “Plaintiff’) for the premises located at 2854 Alum Rock Avenue, San Jose, CA 95 127 (hereinafter “Subject Premises”). Unfortunately, due to the Pandemic, in or about April 2020, Defendant began to be unable to make his monthly rent payment. On June 23, 2020, Plaintiff offered to modify the rent payment for the refiainder of the 2020 year. In or about October 2020, Plaintiff received a check in the amount of $15,000.00 for rental assistance from America SBDC on behalf of the Defendant who had applied for it. As of January 1, 2021, Defendant was not only current on rent but had a credit of $12,000.00 towards rent for the subsequent months. However, on or about April 15, 2021, Plaintiff allegedly served a Five-Day Notice to Pay Rent or Quit (hereinafter “5-Day Notice”) attached to the Unlawful Detainer (UD) Complaint, indicated that the period ofunpaid rent was $39,000.00 when the total amount should have been $13,000.00. [Declaration ofLiem Bui in Support ofEx Parke Application Re Motion to Set Aside Default/Vacate Default Judgment; and Motion for Stay ofExecution (“Dec1. Liem Bui”), 1[ fl 9, 10] Although pursuant to C.C.P. sections 1161.1, the amount of rent can be estimated, it still should be reasonable. The amount alleged due is 3 timés the amount actually owed. This clearly is not reasonable. In addition to providing a defective notice that was allegedly served on Defendant, Plaintiff also failed t0 properly serve the Defendant with the Unlawful Detainer Summons/Complaint (“UD”), when it served a “Vit Do” on May 5, 2021. Although a “Vit Do” does not exist to the knowledge ofthe Defendant, the only individual who worked on that day would be Thuy Do, who is under the age of 18. (Decl. Liem Bui, fl 11 3, 5, Exhibit 1) Assuming the UD was actually EX PARTE APPLICATION RE MOTION TO SET ASIDE DEFAULTNACATE DEFAULT JUDGMENT; 3 AND POINTS AND AUTHORITIES 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 served, Thuy Do, would have been the only individual to have received it. Defendant was unaware of the entry of the UD judgment until a Sheriff s notice was posted on the business door on June 11, 2021. (Decl. Liem Bui, 1] 6) Defendant is now seeking an ex parte order from the court to set aside the default entered in this action on May 25, 2021 and vacating a default judgment entered in this action on May 26, 2021. (Decl. Liem Bui), 'fl 2] On Tuesday, June 15, 2021, at 10:05 a.m., I emailed Plaintiffs counsel, Kirkman Hoffinan, Esq. (info@kirkhoffinan.com) to inform him that I will be appearing to file an ex-parte application in regard to a motion for a stay of execution of the judgment as well as a motion t0 set aside default and vacate the judgment. (Declaration of Robert T. Tang in Support ofEx Pane Application Re Motion to Set Aside Default/Vacate Default Judgment; and Motion for Stay of Execution, 1] 2) II. LEGALAIITHQ2RITYZARGUMEETS California Rules of Civil Procedure 473: (b) The court may, upon any terms as may be just, relieve a party or his or her legal representative from a judgment, dismissal, order, or other proceeding taken against him or her through his or her mistake, inadvertence, surprise, or excusable neglect. Application for this relief shall be accompanied by a copy of the answer or other pleading proposed to be filed therein, otherwise the application shall not be granted, and shall be made within a reasonable time, in no case exceeding six months, after the judgment, dismissal, order, or proceeding was taken. However, in the case of a judgment, dismissal, order, or other proceeding determining the ownership or right to possession of real or personal property, without extending the six-month period, when a notice in writing is personally served within the State of California both upon the party against whom the judgment, dismissal, order, or other proceeding has been taken, and upon his or her attorney of record, if any, notifying that party and his or her attorney of record, if any, that the order, judgment, dismissal, or other proceeding was taken against him or her and that any rights the party has to apply for relief under the provisions of Section 473 of the Code of Civil Procedure shall expire 90 days after service of the .notice, then the application shall be made within 90 days after service of the notice upon the defaulting party or his or her attorney of record, if any, whichever service shall be EX PARTE APPLICATION RE MOTION TO SET ASIDE DEFAULT/VACATE DEFAULT JUDGMENT; AND POINTS AND AUTHORITIES 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 later. No affidavit or declaration of merits shall be required of the moving party. Notwithstanding any other requirements of.this section, the court shall, whenever an application for relief is made no more than six months after entry ofjudgment, is in proper form, and is’ accompanied by an attorney’s sworn affidavit attesting to his or her mistake, inadvertence, surprise, or neglect, vacate any (1) resulting default entered by the clerk against his or her client, and which will result in entry of a defaultjudgment, or (2) resulting default judgment or dismissal entered against his or her client, unless the court finds that the default or dismissal was not in fact caused by the attorney’s mistake, inadvertence, surprise, or neglect. The court shall, whenever relief is granted based on an attorney’s affidavit of fault, direct the attorney to pay reasonable compensatory legal fees and costs to opposing counsel or parties. However, this section shall not lengthen the time within which an action shall be brought to trial pursuant to Section 583.310. In this case, as discussed below, Defendant’s surprise prevented him from timely filing a response because he was not properly served, he did not have actual notice to file the response. As such, this Court pursuant to CCP 473(b) should relieve the Defendant from a default judgment entered against him, as this would be just because Defendant is entitled to his due process rights under the Constitution. In addition, this Motion was brought Within a reasonable time as it was brought within 2 $6 weeks of the date the default judgment was entered. Finally, a copy of the Answer is attached hereto as Exhibit A. A. THE COURT DID NOT HAVE PERSONAL JURISDICTION OVER DEFENDANT BECAUSE HE WAS NOT PROPERLY SERVED California Rules of Civil Procedure 415.20: (a) In lieu ofpersonal delivery of a copy of the summons and complaint to the person to be served as specified in Section 416.10, 416.20, 416.30, 416.40, or 416.50, a summons may be served by leaving a copy of the summons and complaint during usual office hours in his or her office or, ifno physical address is known, at his or her usual mailing address, other than a United States Postal Service post office box, with the person who is apparently in charge thereof, and by thereafter mailing a copy of the summons and complaint by first-class mail, postage prepaid to the person to be served at the place where a copy of the summons and complaint were lefi. When service is effected by leaving a copy of the summons and complaint at a mailing address, it shall be left with a person at least 18 years of age, who shall be informed ofthe contents thereof. Service of a summons in this manner is deemed complete on the 10th day EX PARTE APPLICATION RE MOTION TO SET ASIDE DEFAULTNACATE DEFAULT JUDGMENT; 5 AND POINTS AND AUTHORITIES 10 11 12_ 13 14 15 16 17 18 l9 20 21 22 23 24 25 26 27 28 after the mailing. (b) If a copy of the summons and complaint cannot With reasonable diligence be personally delivered to the person to be served, as specified in Section 416.60, 416.70, 416.80, 0r 416.90, a summons may be served by leaving a copy ofthe summons and complaint at the person’s dwelling house, usual place of abode, usual place of business, or usual mailing address other than a United States Postal Service post office box, in the presence 0f a competent member of the household or a person apparently in charge of his or her office, place of business, or usual mailing address other than a United States Postal Service post office box, at least 18 years of age, who shall be informed of the contents thereof, and by thereafter mailing a copy 0f the summons and ofthe complaint by first-class mail, postage prepaid to the person to be served at the place where a copy of the summons and complaint were left. Service of a summons in this manner is deemed complete on the 10th day afier the mailing. Here, according the proof of service executed by “K. Atkinson” dated May 5, 2021, it indicates that “Vit Do” was served on May 5, 2021 at 11:45 a.m., however, there are only three individuals who have ever worked at the business. They are the Defendant (Liem Bui), Quyen Do, and Thuy Do. Ms. Thuy Do usually works on Wednesdays and Fridays. Ms. Quyen Do does not work on Wednesdays and Fridays when her sister Ms. Thuy Do is working. (Decl. Liem Bui, 11 3, Exhibit 1) In addition, Ms. Thuy Do has confirmed that she was working on May 5, 2021 during the time that the Summons and Complaint was allegedly served, however, she does not remember being served any papers. Assuming it was Ms. Thuy Do that was served since she was the only person with the surname Do there 0n May 5, 2021 during that time, she is nevertheless under the age of 18. (Decl. Liem Bui, fl 5) It should also be noted that the proof of service indicates that the first and second attempts were made at 5:00 pm. and 8:35 am. outside of the business normal hours of operation of 10:00 am. t0 5:00 p.m. (Decl. Liem Bui, 11 4) Therefore, given that service was not proper because the individual served was under EX PARTE APPLICATION RE MOTION TO SET ASIDE DEFAULT/VACATE DEFAULT JUDGMENT; AND POINTS AND AUTHORITIES 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 the age 0f 18 and the first two attempts were outside ofnormal business hours, which clearly shows the lack of reasonable diligence before substituted service was performed, the Court did not have personal jurisdiction over the Defendant when it entered its default judgment. B. DEFENDANT’S SURPRISE PREVENTED HIM FROM FILING A TIMELY RESPONSE As discussed immediately above, Defendant was no properly sewed. Given that service was improper, Defendant did not have actual notice of the UD, therefore, he was prevented from filing a timely response. IILQMCLHSIQN For the forgoing reasons, Defendant respectfufly requests that this Court issue an ex parte order setting aside the default entered in this action 0n May 25, 2021 and vacating a default judgment entered in this action on May 26, 2021. Dated: June 15, 2021 %///’MI Robert T(Tang , Attorney for Defendant, , dba BEST CLEANERS. EX PARTE APPLICATION RE MOTION TO SET ASIDE DEFAULT/VACATE DEFAULT JUDGMENT; 7 AND POINTS AND AUTHORITES Exhibit A UD-1 05 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 296544 FOR COURTUSEOMY NAME Robert T. Tang, Esq. FIRM NAME: STREET ADDRESS: 255 N. Market St.. Suite 244 CITY: San Jose STATE CA ZIP cona- 951 1o TELEPHONE N0.: (408) 81 6-3093 FAX N0.; E-MAIL ADDRESS: roberttlaw1 @gmail.com; robert@roberttlaw.org ATTORNEY FOR(name): Liem Bui. dba Best Cleaners SUPERIOR COURT OF CALIFORNIA. COUNTY OF SANTA CLARA sTREEr ADDRESS: 1 91 N. First Street MAILING ADDRESS: 1 91 N. First Street CITYAND ZIP CODESan Jose 951 13 BRANCH NAME: PLAINTIFF: 1402 Camden LLC DEFENDANTILiem Bui CASE NUMBER ANSWER-UNLAWFUL DETAINER 21 CV381 279 1. Defendant (all defendants for whom this answer is filed must be named and must sign this answer unless their attorney signs): Liem Bui, dba Best Cleaners answers the complaint as follows: DENIALS (Check ONLY ONE of the next two boxes.) a. E General Denial (Do not check this box if the complaint demands more than $1,000.) Defendant generally denies each statement of the complaint and of the Mandatory Cover Sheet and Supplemental AIIegations-Unlawful Detainer (form UD-1 01 ). b. Specific Denials (Check this box and complete (1) and (2) below if complaint demands more than $1,000.) Defendant admits that all of the statements of the complaint and of the Mandatmy Cover Sheet and Supplemental AIIegations-Unlawful Detainer (form UD-101) are true EXCEPT: (1) Denial of Allegations in Complaint (Form UD-100 or Other Complain! for Unlawful Detainer) (a) Defendant claims the following statements of the complaint are false (state paragraph numbers from the complaint or explain below or, ifmore room needed, on form MC-025):E Explanation is on form MC-025, titled as Attachment 2b(1)(a). garagragh S(d) is false: Omitted modified agreement made on June 23, 2020 after Defendant stopped pay rent due to the pandemic on April 2020 that allowed Defendant to pay $3,000.00 per month forthe remainder of the 2020 year, ifthey paid an immediate lump sum of $9,000.00 to cover past rent due' (b) Defendant has no information or belief that the following statements of the complaint are true, so defendant denies them (state paragraph numbers from the complaint or explain below or, ifmore room needed, on form MC-025):E Explanation is on form MC-025, titled as Attachment 2b(1)(b). (2) Denial of Allegations in Mandatory Cover Sheet and Supplemental Allegations-Unlawful Detainer (form UD-1 01) (a) E Defendant did not receive plaintiff's Mandatory Cover Sheet and Supplemental Allegations (form UD-101). (If not checked, complete (b) and (0).) (b) Defendant claims the following statements on the MandatOIy Cover Sheet and Supplemental AIIegations-Unlawful Detainer (form UD-‘l O1) are false (state paragraph numbels from form UD-101 or explain below or, ifmore room needed, on form MC-025): E Explanation is on forrn MC-025, titled as Attachment 2b(2)(b). (C) Defendant has no information or belief that the following statements on the Mandatory Cover Sheet and Supplemental AIIegations-Unlawfu/ Detainer (form UD-101) are true, so defendant denies them (state paragraph numbers from form UD-101 or explain below or, ifmore room needed, on form MC-025):E Explanation is on form MC-025, titled as Attachment 2b(2)(c). Page 1 of 5 Form Approved for Optional Use Civfl Coda. § 1940 at seq.; Judicial Councn of California ANSWER-UNLAWFUL DETAINER c°d° °f cw“ Pmmdm' §§ 425'12' UD-105 (Rev. May 24, 2021] 1161 at seq. 1119.01 et seq. www.courrs.ca.gov UD-1 05 CASE NUMBER 21CV381279 3. DEFENSES AND OBJECTIONS (NOTE: For each box checked, you must state bn'ef facts to support it in item 3v (on page 3) or, if more room is needed, on form MC-025. You can learn more about defenses and objections at www.courts.ca:goviselfhe/Q-evictioa.firm _) a. E (Nonpayment ofrent only) Plaintiff has breached the warranty to provide habitable premises. b. E (Nonpayment ofrent only) Defendant made needed repairs and properly deducted the cost from the rent, and plaintiffdid not give proper credit. C. E (Nonpayment ofrent only) On (date): before the notice to pay or quit expired, defendant offered the rent due but plaintiff would not accept it. d. E Plaintiff waived, changed, or canceled the notice to quit. e. E Plaintiff sewed defendant with the notice to quit or filed the complaint to retaliate against defendant. f_ E By sewing defendant with the notice to quit or filing the complaint, plaintiff is arbitrarily discriminating against the defendant in violation of the Constitution or the laws of the United States or California. 9- E P'a'm'ffs demand f°r messw" @4332; 39%;%°g'6a¢;gevéaelsagmgau89'3291isgfi'cneanggfig9sm wefysactfis? .292,ordinam’e' and date gfpassage): Ms-9,293 and Ms-9.299, as of September 1, 2020. (Also, bn'efly state in Item 3v the facts showing Violation of the ordinance.) Plaintiffs demand for possession is subject to the Tenant Protection Act of 2019, Civil Code section 1 946.2 or 1947.12, and is not in compliance with the act. (Check all that apply and briefly state in item 3v the facts that support each.) D (1) E Plaintiff failed to state ajust cause for termination of tenancy in the written notice to terminate. (2) E Plaintiff failed to provide an opportunity to cure any alleged violations of terms and conditions of the lease (other than payment of rent) as required under Civ. Code, § 1946.2(c). (3) E Plaintiff failed to comply with the relocation assistance requirements of Civ. Code, § 1946.2(d). (4) E Plaintiff has raised the rent more than the amount allowed under Civ. Code, § 1947.12, and the only unpaid rent is the unauthorized amount. (5) E Plaintiff violated the Tenant Protection Act in another manner that defeats the complaint. i. E Plaintiff accepted rent from defendant to cover a period of time after the date the notice to quit expired. j. E Plaintiff seeks to evict defendant based on an act against defendant or a member of defendant's household that constitutes domestic violence, sexual assault, stalking, human trafficking, or abuse of an elder or a dependent adult. (This defense requires one of the following: (1) a temporary restraining order, protective order, or police report that is not more than 180 days old; OR (2) a signed statement from a qualified thirdparty (e.g., a doctor, domestic violence or sexual assault counselor, human trafficking caseworker, or psychologist) concerning the injun'es or abuse resulting fi'om these acts).) k. E Plaintiff seeks to evict defendant based on defendant or another person calling the police or emergency assistance (e.g., ambulance) by or on behalf of a victim of abuse, a victim of crime, or an individual in an emergency when defendant or the other person believed that assistance was necessary. /. E Plaintiff's demand for possession of a residential property is in retaliation for nonpayment of rent or other financial obligations due between March 1, 2020, and June 30, 2021, even though alleged to be based on other reasons. (Civ. Code, § 1942.5(d) or Gov. Code, § 12955.) m.E Plaintiff's demand for possession of a residential property is based on nonpayment of rent or other financial obligations due between March 1, 2020, and June 30, 2021, and (check all that apply): (1) E Plaintiff did not serve the general notice of rights under the COVlD-19 Tenants Relief Act as required by Code of Civil Procedure section 1179.04. .(2) E Plaintiff did not serve the required 15-day notice. (Code Civ. Proc., § 11 79.03(b) or (0).) (3) E Plaintiff did not provide an unsigned declaration of COVID-19-related financial distress with the 15-day notice. (Code . Civ. Proc., § 1179.03(d).) (4) E Plaintiff did not provide an unsigned declaration of COVlD-1 9-related financial distress in the language in which the landlord was required to provide a translation of the rental agreement. (Code Civ. Proc., § 1179.03(d).) (5) E Plaintiff identified defendant as a “high-income tenant” in the 15-day notice, but plaintiff did not possess proof at the time the notice was served establishing that defendant met the definition of high-income tenant. (Code Civ. Proc., § 1179.02.5(b).) UM°5IRW Mavmozu ANSWER-UNLAWFUL DETAINER WW5 UD-1 05 CASE NUMBER‘ 21 CV381 279 m- (6) E Defendant delivered to plaintiff one or more declarations of COVlD-1 9-related financial distress and, if required as a "high-income tenant," documentation in support. (Code Civ. Proc., §§ 1179.03(f) and 1179.025.) (Describe when and how delivered and check all otheritems below that apply): (a) E Plaint'rffs demand for payment includes late fees on rent or other financial obligations due between March 1. 2020, and June 30, 2021. (b) E Plaintiff's demand for payment includes fees for services that were increased or not previously charged. (c) E (For cases filed aflerJune 30, 2021) Defendant, on or before June 30, 2021 , paid or offered plaintiff payment of at least 25% of the total rental payments that were due between September 1, 2020, and June 30, 2021 , and that were demanded in the termination notices for which defendant delivered the declarations described in (a). (Code Civ. Proc., § 1179.03(g)(2).) (7) E Defendant is currently filing or has already filed a declaration of COVlD-1 9-related financial distress with the court. (Code Civ. Proc., § 1179.03(h).) (8) Rental Assistance (Health & Saf. Code, §§ 50897.1(d)(2)(B) and 50897.3(e)) (check all that apply): (a) m Plaintiff received or has appliedfor rental assistance from the State Rental Assistance Program or financial compensation from some other source relating to the amount claimed in the notice to pay rent or quit. (b) E Plaintiff received or has applied for rental assistance from the State Rental Assistance Program for rent accruing since the notice to pay rent or quit. n. E (For cases filed before July 1, 2021) Plaintiff's demand for possession of a residential tenancy is based on a reason other than nonpayment of rent or other financial obligations, and plaintiff lacks just cause for termination of the tenancy, as defined in Civil Code section 1946.2(b) or Code of Civil Procedure section 1179.03.5(a)(3)(A). o. E Plaintiff violated the COVID-19 Tenant Relief Act (Code Civ. Proc., § 11 79.01 et seq.) or a local COVlD-1 9-related ordinance regarding evictions in some other way (bn'efly state facts describing this in item 3v). p. E Defendant provided plaintiff with a declaration under penalty of perjury for the Centers for Disease Control and Prevention‘s temporary halt in evictions to prevent further spread of COVlD-19 (85 Federal Register 55292 at 55297), and plaintiff's reason for termination of the tenancy is one that the temporary halt in evicfions applies to. (Describe when and how provided): q. E Plaintiff violated the federal CARES Act, because the property is covered by that act and (check all that apply): (1) D The federally backed mortgage on the property was in forbearance when plaintiff brought the action. (15 U.S.C. § 9057.) (2) D The plaintiff did not give the required 30 days' notice. (15 U.S.C. § 9058(c).) r. E Plaintiff improperly applied payments made by defendant in a tenancy that was in existence between March 1, 2020, and June 30, 2021 (Code Civ. Proc., § 1179.045), as follows (check all that apply): (1) E Plaintiff applied a security deposit to rent, or other financial obligations due, without tenant's wn'tten agreement. (2) D Plaintiff applied a monthly rental payment to rent or other financial obligationsthat were due between March 1, 2020, and June 30, 2021, other than to the prospective month’s rent, without tenant’s written agreement. UD-105 [Rev. May 24. 2021] ANSWER-UNLAWFUL DETAINER Page 3 of5 UD-1 05 CASE NUMBER: 21 CV381 279 U) . E Plaintifi refused to accept payment from a third party for rent due. (Civ. Code, § 1947.3; Gov. Code, § 12955.)E Defendant has a disability and plaintiff refused to provide a reasonable accommodation that was requested. (Cal. Code Regs. tit. 2, § 121 76 (c).) . E Other defenses and objections are stated in item 3v. . (Provide facts for each item checked above, either below or, ifmore room needed, on form MC-025):E Description of facts or defenses are on form MC-025, titled as Attachment 3v. r. (TYPEOR PRINT NAME) f (SGNATURE 0F DEFENDANr) “”105 [Rev- May 24' 2°21] ANSWER-UNLAWFUL DETAINER Page 5 °f 5 For your protection and privacy, please press the Cl_ear This Fonn button afler you have printed the form. r- lipfififtfifiifgfifiil l: ave- ls. orm