Declaration

Cal. Super. - 6th Dist.April 27, 2021

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 21 CV381279 Santa Clara - Civil Electronicall Filed ROBERT T. TANG, Esq., SBN 296544 y The Law Office of Robert T. Tang gifxtpeorrgaclfizréloaiaCA’ 255 N. Market Street, Suite 244 y ’ San JOSC,CA 95110 0n 6/17/2021 4.10 PM (408) 816_8098 REVlewed By: M. Scrum Case #21 CV381 279 Attorney for Defendant, Envelope: 66741 03 LIEM BUI, dba BEST CLEANERS SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA UNLIMITED CIVIL CASE Case No.2 21CV381279 | | DECLARATION OF ROBERT T. | TANG | IN SUPPORT OF 1402 CAMDEN LLC, a California Limited Liability | MOTION TO SET ASIDE Company, | DEFAULT/VACATE DEFAULT | JUDGMENT AND MOTION | FOR ORDER SHORTENING | TIME Plaintiff, | V. | || LIEM BUI, dba BEST CLEANERS | Date: T.B .D. | Time: 9:00 am. | Dept: 4 Defendant. | Commissioner: Erik S. Johnson | Complaint Filed: 04/27/2021 DECLARATION OF ROBERT T. TANG IN SUPPORT OF MOTION TO SET ASIDE DEFAULT/VACATE DEFAULT JUDGMENT; AND MOTION FOR ORDER SHORTENING TIME M. Sorum IQ 17 18 l9 I, Robert T. Tang, declare: 1. I am an attorney at law admitted to practice before all courts ofthe state of California. I have personal knowledge of each matter and the facts stated herein as the attorney for Defendant, LIEM BUI (“Moving Party”), and if called upon and sworn as a witness,I could and would testify competently thereto. 2. On Tuesday, June 15, 2021, at 10:05 a.m., I emailed Plaintiffs counsel, Kirkman Hoffman, Esq. (info@kirkhoffman.com) to inform him that I will be appearing to file an ex-parte application in regard t0 a motion for a stay 0f execution 0fthe judgment as well as a motion to set aside default and vacate the judgment given the inaccurate amount 0f alleged rent due and improper service. (Attached hereto as Exhibit 1) I declare under penalty of pteury under the laws of California that the foregoing is true and conect, and that this Declaration was executed on June 15, 2021, at San Jose, California./ I l/ 5,. -’/ I / //7(//c// 7/ /fl/7 Robert T. Tang, DeclaI DECLARATION OF ROBERT T. TANG IN SUPPORT OFMOTION TO SET ASIDE DEFAULT/VACATE DEFAULT JUDGMENT; AND MOTION FOR ORDER SHORTENING TIME Exhibit 1 Wednesday, June 16, 2021 at 11:08:28 AM Pacific Daylight Time Subject: Re: 1402 Camden v. Bui, Case No. 21CV381279 Date: Tuesday, June 15, 2021 at 10:05:38 AM Pacific Daylight Time From: Robert Tang To: Kirkman Hoffman Mr. Hoffman, My clients will appear to request the stay of execution on THURSDAY, June 17, 2021. They will request an extension of 40-days and submit a motion to set aside the default and vacate the judgement as well given that they were not properly served and a closer look at the documents revealed an inaccurate amount claimed to be due. Again, it will be Thursday and not tomorrow. Robert The Law Office of Robert 1: Tang 255 N. Market Street, Suite 244 San Jose, CA 95110 Office: (4W) 816-8Q8 Fax: (669) 231-4049 This email (inclusive of any attachment) was sent from the Law Office of Robert 12 Tang andmay contain information that is privileged/confidential. Ifyou are not the intended recipient, please delete this email and destroy any hard copies that may have been made. Please also immediately notify us of this error. Thank You. From: Kirkman Hoffman Date: Tuesday, June 15, 2021 at 9:53 AM To: Robert Tang Subject: Re: 1402 Camden v. Bui, Case No. 21CV381279 Mr. Tang: Please contact me today concerning your intent to appear ex parte for a stay tomorrow. I am currently unavailable to appear in person tomorrow, but can appear by telephone or Zoom. My client objects to any stay beyond the 40-day limit and, even then, would require advance payment in accordance with law and equity. I look forward to hearing from you. Kirk On Mon, Jun 14, 2021 at 4:54 PM Kirkman Hoffman wrote: Dear Mr. Tang: I can check with my client, but before | do, please confirm that your client is willing and able to pay forthe requested stay. 40-days would cap out at 7/5/21. Page 1 of 2 Kirkman J. Hoffman, Esq. KIRKMAN J. HOFFMAN, ESQ. THE HOFFMAN LAW GROUP, APC. 2021 The Alameda, Suite 275 San Jose, California 95126 Tel (408) 241-9620 Fax (408) 241-9624 Email: kirk@kirkhoffman.com Website: kirkhoffman.com Kirkman J. Hoffman, Esq. KIRKMAN J. HOFFMAN, ESQ. THE HOFFMAN LAW GROUP, APC. 2021 The Alameda, Suite 275 San Jose, California 95126 Tel (408) 241-9620 Fax (408) 241-9624 Email: kirk@kirkhoffman.com Website: kirkhoffman.com Celebrafing 20 year‘s of Excellence! Page 2 of 2