Citibank South Dakota N.A. vs. David A Gutierrez

Opposition

Cal. Super. - 4th Dist.August 18, 2010

© 0 N N N nh BA 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 HUNT & HENRIQUES Kurtiss Jacobs #218950 Donald Sherrill #266380 Anthony J. DiPiero # 268246 Attorneys at Law 151 Bernal Road Suite 8 San Jose, CA 95119 Telephone (408) 362-2270 Facsimile (408) 362-2299 Attorneys for Plaintiff File No. 542778 ELECTRONICALLY FILED Superior Court of California, County of Orange 0315/2018 at 02:56:00 Pi Clerk of the Superior Court By & Clerk, Deputy Clerk SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE CENTRLA JUSTICE CENTER - UNLIMITED CIVIL CASE CITIBANK (SOUTH DAKOTA) N.A. Plaintiff VS. DAVID GUTIERREZ,, Defendant Outline of opposition Case No. 30-2010-00400279-CU-CU-CJC Opposition to motion to vacate judgment and set aside default Declaration of plaintiff’s counsel in support of opposition Date: April 2,2018 Time: 1:30 p.m. Dept.: C-31 1. Personal service is effective anywhere, so it is irrelevant where defendant lived o R W N Every ground for statutory relief has expired by th e statutes themselves Defendant has not alleged, much less proved, elements required for equitable relief Despite defendant’s protestations, personal service was actually effected Even if defendant could get equitable relief, the case would have to go to trial OPPOSITION TO MOTION TO SET ASIDE DEFAULT AND DEFAULT JUDGMEN T © «© 3 O N Un bs L N N N N N N N N N N e e e s e s e e e e e e e s © J O N Wn BR W O N = O Y N O N N B N = O 1. Personal service is effective anywhere, so it is irrelevant where defendant lived A person need not be served at his residence, but can be personally served anywhere- within the judicial district or without; at home, at work, on the street, at his neighbor’s house, at the market, or even on an airplane during flight (see Grace v. MacArthur (E.D. Ark. 1959) 170 F. Supp. 442, 444 (person in flight on aircraft is amenable to service under Federal Rule of Civil Procedure 4); Code of Civil Procedure § 415.10 (personal service effective on delivery of summons, with no restrictions on location of delivery); Severn v. Adidas Sportschuhfabriken (1973) 33 Cal. App.3d 754 (error to quash California summons served in Florida on resident of France; service was proper)). David Gutierrez submits three declarations and six exhibits supporting his argument that he did not live at 1608 Varna Street on September 13, 2010. But the process server declared that he personally served Gutierrez, so it is irrelevant whether Gutierrez lived at or was merely visiting a former roommate or his parents at Varna Street. Not only is it irrelevant relative to service being effective, but it would be inequitable to deprive plaintiff of its vested property right when it had skiptraced defendant after his one-time roommate af the 38 Dovetail address told the process server three days before service, that she had no forwarding address for Mr. Gutierrez; plaintiff will address this in greater detail in section 3 on equitable relief. Defendant’s evidence, as mentioned above, is irrelevant and has not overcome the presumption that he was served personally. Filing a proof of service that complies with statutory standards creates a rebuttable presumption that service was proper. See, Dill v. Berquist Const. Co., Inc. (1994) 24 Cal. App. 4th 1426, 1441-1442. The proof of service herein appear to comply with statutory standards. Cal. Evid. Code § 606 provides that: “The effect of a presumption attecting the burden of proof is to impose upon the party against whom it operates the burden of proof as to the nonexistence of the presumed fact.” Section 606 describes the manner in which a presumption affecting the burden of proof operates. In the ordinary case, the party against whom it is invoked will have the burden of proving the nonexistence of the presumed fact by a preponderance of the evidence. [...] When sucha OPPOSITION TO MOTION TO SET ASIDE DEFAULT AND DEFAULT JUDGMENT OO 0 NN O N Wn Bs 10 11 12 13 1 15 16 17 18 19 20 21 22 23 24 25 26 27 28 presumption is relied on, the party against whom the presumption operates will have a heavie r burden of proof and will be required to persuade the trier of fact of the nonexistence of the presumed fact by proof “‘sufficiently strong to command the unhesitating assent of every reasonable mind." " Sheehan v. Sullivan (1899) 126 Cal 189. Here, the personal service is presumed to be proper. Plaintiff has relied upon this presumed fact for more than seven years. As such, the burden of proof shifts to defendant to show the nonexistence of the presumed fact (that service of the summons and complaint was proper). Because plaintiff has relied upon this presumption, defendant must prove the nonexistence of the presumed fact, with a heavier burden of proof “sufficiently strong to command the unhesitating assent of every reasonable mind" (/d.) However, the scant evidence defendant puts forward to rebut this presumption is found in defendant’s declaration and accompanying exhibits. Defendant’s broad denial does not really address the issue of proper service. The address documents are irrelevant for purposes of whether he was personally served. Defendant may, in his reply, attempt to introduce evidence, documentary or otherwise, which establishes his location on September 13,2010, at 7:51 p.m.. Any such argument or evidence should be rejected and not considered by the court. “Points raised for the first time in a reply brief will ordinarily not be considered, because such consideration would depiive the respondent of an opportunity to counter the argument.” American Drug Stores, Inc. v. Stroh, (1992) 10 Cal. App. 4th 1446, 1453. Further, The California Supreme Court long ago expressed its hostility to the practice of raising new issues in an appellate reply brief. Where new information is presented for the first time on reply Courts “are not disposed to look with favor upon a point so made, unless good reason appears for the failure to make it in the opening brief” and in fact “the court may properly consider them as waived.” Reichardt v. Hoffman, 52 Cal. App. 4th 754, 764. The scant evidence provided in defendant’s declaration is nowhere near the heavy burden to provide evidence “‘sufficiently strong to command the unhesitating assent of every reasonable mind,” as required under Sheehan, supra. Defendant has not shown the nonexistence of the presumed fact. OPPOSITION TO MOTION TO SET ASIDE DEFAULT AND DEFAULT JUDGMENT © 0 ~ 3 O N nm RR W N = N O N N N N N N N m e e e m e s e e e s e s e e e s 0 ~~ O N Wn RA W N = D O N N N B W N e oO 2. Every ground for statutory relief has expired by the statutes themselves. Defense counsel does deserve credit for recognizing (for the most part) that after two years has passed, a defendant does not qualify for statutory relief from judgment, and must bring a motion in equity. The court has no jurisdiction to grant relief under Code of Civil Procedure §§ 473(b), 473(d), or 473.5. Because defense counsel appears to make an argument-preserving reference to § 473(d), Citibank offers the following to protect the record: Code of Civil Procedure §473(b) states that a court may relieve a party from a judgment taken against him through his mistake, inadvertence, surprise, or excusable neglect and that an application for such relief shall be made within a reasonable time, in no case exceeding six months, after the judgment. Because judgment was entered in 2010, the court lacks jurisdiction to grant relief under this section. Code of Civil Procedure §473.5 states a motion to set aside the default or default judgment shall be served and filed within a reasonable time, but in no event exceeding the earlier of: (i) two years after entry of a default judgment; or (ii) 180 days after service of a written notice that the default or default judgment has been entered. Again, because judgment was entered in 2010, the court lacks jurisdiction to grant relief under this section. Code of Civil Procedure § 473(d) states, “The court may, upon motion of the injured party, or its own motion, correct clerical mistakes in its judgment or orders as entered, so as to conform to the judgment or order directed, and may, on motion of either party after notice to the other party, set aside any void judgment or order.” This subsection does not state a time limit, such as the six-month limit in § 473(b) or the two-year limit in § 473.5. But § 473.5’s (then one-, now two-) year limit applies “by analogy” to a judgment “valid on its face but otherwise void.” See, e.g., Rogers v. Silverman (1989) 216 Cal. App.3d 1114, 1120-1121. Here, the judgment is valid on its face. It was entered by default after defendant’s time to respond expired, with time running from the date of a facially valid proof of service. Defendant asserts that service was not effected, but even if the court were to believe this, it would be looking beyond the face of the judgment roll to make this determination-so the two-year limit would apply, and Gutierrez could not get relief under § 473(d) even if it were true that he were OPPOSITION TO MOTION TO SET ASIDE DEFAULT AND DEFAULT JUDGMENT S H O W D N OO XX N N N Wn 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 not served. Defendant cites Trackman v. Kenney (2010) 187 Cal. App.4th 175, 180 (Motion 6:13-15) as support for the argument that if a judgment is void, it may be set aside “at any time, provided the party acts with diligence upon learning of the relevant facts.” This is true-but except when the judgment is void on its face, relief granted after two years is always granted in equity (Manson, Iver & York v. Black (2009) 176 Cal. App.4™ 36, 42), and thus requires the usual balance-of-harms analysis in addition to three enumerated showings applicable to equitable relie f from judgment. 3. Defendant has not alleged, much less proved, elements required for equitable relief Gibble v. Car-Lene Research, Inc., (1998) 67 Cal. App. 4th 295 stated at pp. 314-315 (citations, brackets, and internal quotes omitted; bold added): A party who seeks to have his default vacated under the court’s equity power must make a stronger showing than is necessary to obtain relief under section 473. During the period when relief under section 473 is available, there is a strong public policy in favor of granting relief and allowing the requesting party his or her day in court. Beyond this period there is a strong public policy in favor of the finality of judgments and only in exceptional circumstances should relief be granted.” Gibble v. Car-Lene Research, Inc., (1998) 67 Cal. App. 4th 295, 314- 315 (Citations, brackets, and internal quotes omitted; bold added). As a general rule once a default has resulted in a judgment there is a high degree of prejudice to the plaintiff in vacating the default because it entails setting aside the judgment and disturbing plaintiff's justifiable reliance on the award. Rappleyea v. Campbell, 8 Cal.4™ 975, 984 (1994). Gibble recognized at p. 315 that intrinsic fraud is “not a valid ground for setting aside a judgment.” Gibble then cited other Court of Appeal and California Supreme Court cases in summarizing the “stronger showing” required for equitable relief: In conjunction with his or her showing of extrinsic fraud, a party seeking equitable relief from a default judgment must satisfy three elements: First, the defaulted party must demonstrate that it has a meritorious case. Secondly, the party seeking to set aside the default must articulate a satisfactory excuse for not presenting a defense to the original action. Lastly, the moving party must demonstrate diligence in seeking to set aside the default once discovered. - Id. at p. 315 (citations, ellipses, and internal quotes omitted). Gutierrez wholly ignores his obligation to demonstrate a meritorious case, and this alone compels that the motion be denied. He also has no excuse tor not presenting a defense to the OPPOSITION TO MOTION TO SET ASIDE DEFAULT AND DEFAULT JUDGMENT BB W N OO 0 NJ O N Wn 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 original action, as his claim of non-service refuted by clear and convincing evidence, infra. 3.A. Defendant has not even attempted to “demonstrate a meritorious case” as required Defendant has failed to put forward any facts showing a meritorious defense to the underlying action. He has proposed a general denial with boilerplate affirmative defenses; without evidence, he has not demonstrated that his denials have merit. Affirmative de fenses 4, 5, 8,9, 11, 14, 15, 16, 17 and 24 appear unrelated to the complaint and refer to parties and even ts not subject to this complaint. The answer appears to be a stock answer from another action that was not modified to be responsive here. Although Gutierrez pleads a general denial, he has not shown that he would be likely to prevail if the case were set for trial. Defendant may argue, as his present motion implies, that the merits don’t matter because he was denied due process due to Plaintiff's fraud. Not only is this factually false (see next section), but it is legally erroneous. A party whose time to request statutory relief has expired may seek equitable relief but then does bear the burden of proving a likelihood of success. This constitutional principle dovetails nicely with the rule for extrinsic fraud, which also requires prejudicial error: A valid judgment will not be set aside merely because it was obtained by extrinsic fraud or mistake, in order to give the barren right to an adversary hearing. The plaintiff must plead and prove that he has a meritorious case, i.e., a good claim or defense that, if asserted in a new trial, would be likely to result in a judgment favorable to him. Estate of McGuigan (2000) 83 Cal. App.4" 639, 652 (citations and internal quotes omitted; italics in original). 3.B. Defendant has not shown a satisfactory excuse for not presenting a defense to the original action. Defendant never directly addresses why he failed to respond to the complaint or to show that he was not personally served. In fact, it is likely defendant did not specifically address this element because there is zero possibility it can be satisfied. Defendant provides numerous documents showing that he listed his address at or near the time or service to be 38 Dovetail, Irvine, CA. While it is questionable whether that was in fact his address, based on the statements of Ingrid Canada, defendant’s actual address and his address for receiving mail is irrelevant. The proof of service on file indicates that defendant as personally served. Defendant has provided zero evidence, OPPOSITION TO MOTION TO SET ASIDE DEFAULT AND DEFAULT JUDGMENT © © ~~ OO wn BA W N N o [\ ®] No N o nN N o NN N o No -_ - p t -_ - - - p d p t B® a A hh RE W N = O WO Re N O N n d W Y N = O documentary or otherwise, to hi that he was not served as indicated. The documents rega rding his address are merely a smoke screen to focus the attention elsewhere. Defendant knew of the lawsuit. The only reason the Answer was not filed was bec ause defendant chose not to respond. There is nothing in that set of facts that would rise to the level of a satisfactory excuse. As such, Defendant does not have a satisfactory excuse for not pre senting a defense to the original action. The motion should be denied. 3.B. Defendant has failed to demonstrate diligence in seeking to set aside the default once discovered. The third element of Gibble requires diligence in seeking to set aside judgment once it is discovered. Defendant never states how he became aware of that judgment was entered against him. In October 2010, Plaintiff sent a letter to defendant advising him that he had been serve d with a Summons and Complaint. Because Plaintiff had not yet updated the address for defendan t in their system of record, the letter dated October 18, 2010, was inadvertently mailed to the Dovetail address. See Exhibit 1 attached to the Declaration of Anthony DiPiero. The October 18,2010, letter wa s not returned to plaintiff’s counsel as undeliverable. As such, it is presumed that the October 18, 2010, letter was received (Evidence Code § 641). As such, defendant should have been aware of a judgment in late 2010 after receipt of the October 18, 2010, letter informing him of service and when he knew he had not respo nded. Therefore, defendant has known for over seven (7) years about the default and default judgmen t and the same amount of time before seeking relief. “Such a motion must not be granted if the moving party is guilty of laches or inexcusable neglect, and the court must weigh the reasonableness of the conduct of the moving party in li ght of the extent of the prejudice to the responding party. The burden is on the moving party, an d the greater the prejudice to the responding party, the greater the burden on the moving party. The g reater the prejudice to the responding party, the more likely it is that the court will determine that equi table defenses such as laches or estoppel apply to the request to vacate a valid judgment” In re Marr iage of Stevenot, 154 Cal. App. 3d 1051, 1071. OPPOSITION TO MOTION TO SET ASIDE DEFAULT AND DEFAULT JUDGMEN T wm BA W N OO 0 J 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 235 26 21 28 4. Despite defendant’s protestations, personal service was actually effected Gutierrez actual argued at 6:20-7:1: Plaintiff could have easily discovered Mr. Gutierrez’s true address via a simple public records search or skiptracing activity, but failed to do so. Moreover, Plaintiff failed within its declaration of due diligence to explain why it believed it could have located [Defendant] at the Varna Street address. Unfortunately, however, Plaintiff did not ever once attempt personal service at the correct address on Dovetail Lane, City of Irvine at all. But he is wrong on all three points. Plaintiff is not required in a declaration of diligence-i.e., a declaration of non-service- to explain why it believes it can locate defendant at an address different from that where se rvice is later effected; this is an errant argument. Court records refute Gutierrez’s assertion that “Plaintiff did not ever once attempt personal service at the correct address on Dovetail Lane, City of Irvine at all.” Gutierrez states in 4 11 of his declaration that the correct address was 38 Dovetail Lane, City of Irvine. The proof of service reflects that Plaintiff attempted personal service at 38 Dovetail Lane, City of Irvine, four times-on 8/21, 8/22, 8/24, and 8/27 of 2010. The first three times, there was no answer; the fourth time, resident Ingrid Canada stated that Gutierrez was an “open roommate” but that there was no forwarding address. See exhibit 2. Instead of leaving the papers with Canada, mailing a second copy, and filing a proof of substituted service-which would no doubt have resulted in a claim today of “I didn’t live at 38 Dovetail Lane’-Plaintiff did discover Mr. Gutierrez’s true address via a simple public records search or skiptracing activity. See declaration of Anthony DiPiero, 3, As seen by exhibit 2, the result was information that Gutierrez could be located at 1608 S Varna Street in Anaheim. The fact that Plaintiff did its best to convey actual notice of the lawsuit is corroborated by Gutier rez’s admission now, more than seven years later, that he did live there until 2005. And whether he has lived there or not since 2005 is irrelevant. Not only is personal service valid anywhere at any time, and it is clear that he maintains close ties to 1608 Varna Street-in fact, it is probably his parents’ home to this day, and the “simple public records search” that Gutierrez recommended shows him living there from 11/97-3/2018 and registering OPPOSITION TO MOTION TO SET ASIDE DEFAULT AND DEFAULT JUDGMENT wm BA W N Oo 0 3 On 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 2:7 28 his vehicle-a 2005 Acura-at that address from 2/16/11-2/27/17. See exhibit 3. Exhibit 3 shows that 1608 Varna Street is owned by Arthur L. Gutierrez and that other current residents of that property include Mary Elizabeth Gutierrez, David A. Gutierrez, and Mark Joseph Gutierrez. This is entirely consistent with the process server’s claim to have served David Gutierrez personally, and with David Gutierrez’s claim that he did not actually live there at the time: It is his parent’s home, and he was visiting. Apparently he has visited plenty over the years-enough to make it the address where he registered the same car six years in a row; enough so that Lexis lists him as living there from 1997 through 2018. And it’s not the wrong David Gutierrez, because he admits living there in 2003. Gutierrez is likely to argue that exhibit 3 is hearsay-but /e is the one who complained that Plaintiff had not searched public records. And he will not declare under penalty of perjury that the records are false: He will not bring a copy of a registration showing that he had registered his Acura at a different address between 2011 and 2017, and he will not declare under penalty of perjury that Arthur L. Gutierrez is not the owner of 1608 Varna Street. Again: whether he lived there or not, personal service was valid because he was present. 5. Even if defendant could get equitable relief, the case would have to go to trial There are two legal reasons that the case cannot be dismissed for failure to serve, in addition to the common-sense logic that one who is complaining that he wants his day in court cannot simultaneously ask the court to deprive a party opponent of its day in court. 5.4. Delay in prosecution statutes are tolled from entry of judgment until judgment is vacated The first reason that the case cannot be dismissed is because Dill and Damjanovic, cited by defendant, do not address the situation here. Defendant cites Damjanovic at 8: 14-20 for the “reason” that the three-year statute for service of summons is strictly construed-that “a plaintiff exercising due diligence is in control of the time of service of summons.” But plaintiff did exercise due diligence, as show above: when Gutierrez could not be found in four tries at Dovetail land his roommate “had no forwarding info,” skiptracing gave the address of Gutierrez’s parents and service was effected. Even if in this particular casc it could be irrefutably proved that Gutierrez had not been served, the law-and Damjanovic’s reason for the law- OPPOSITION TO MOTION TO SET ASIDE DEFAULT AND DEFAULT JUDGMENT OO 00 9 O y Un bh W N em N O N N N N N N N N e e e m e m e e e R e m ed e e ee 0 ~~ O N Wn hls W N = O O N Y B R E W N D = O would have to protect valid service against the tendency of courts to guard against depriving a party of a hearing on the merits by granting relief even in questionable cases. Gutierrez’s citation to Dill is even less helpful. His counsel did not provide a pin cite as he did on every other cite in the brief; he did not quote the case; and he did not even summarize Dill’s facts. As it turns out, the reason that service in Dill was ineffective was not because there was a factual dispute as to whether defendant received the papers and the court sided with the defendant; it was undisputed that “Dill mailed the summons directly to the corporate defendant, rather than to any of the statutorily described persons to be served.” Dill v. Berquist Constr. Co. (1994) 24 Cal. App.4™ 1426, 1434, as modified on denial of reh’g (May 26, 1994). Plaintiff had consciously chosen the method, person, and place of service, and had reason to know that service did not comply with the statute. Dill was an outlier, and the general rule is different. The five-year limit to bring a matter to trial is folled from entry of default judgment until the judgment is vacated. Misic v. Segars (1995) 37 Cal App 4th 1149. See also Howard v. Thrifty Drug & Discount Stores (1995) 10 Cal 4th 424 (same; error to dismiss without tolling the Delay in Prosecution statute). 5.B. Equitable relief requires equitable conditions, including waiver of the delay statutes The second reason is that Gutierrez is seeking equitable relief, and a court can grant equitable relief only on grounds that are equitable. It would not be equitable to deprive a plaintiff of a judgment “just in case” defendant’s tale that he wasn’t served might be true, and then to dismiss the case rather than try it on the merits. The court not only has its own equitable power to enter such an order, but the Legislature has codified this preference for trial: Code of Civil Procedure § 583.130 (which applies to all Delay in Prosecution statutes, including §§ 583.210-250 for failure to serve within three years) states (underscore added): It is the policy of the state that a plaintiff shall proceed with reasonable diligence in the prosecution of an action but that all parties shall cooperate in bringing the action to trial or other disposition. Except as otherwise provided by statute or by rule of court adopted pursuant to statute, the policy favoring the right of parties to make stipulations in their own interests and the policy favoring trial or other disposition of an action on the merits are generally to be preferred over the policy that requires dismissal for failure to proceed with reasonable diligence in the prosecution of an action in construing the provisions of this chapter. OPPOSITION TO MOTION TO SET ASIDE DEFAULT AND DEFAULT JUDGMENT : 10 ~~ S n BR W N 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The court could require Gutierrez to stipulate to waive the time limit as a prerequisite to equitable relief. Section 583.220 expressly recognizes a defendant to enter into a stipulation in writing to waive time for service of process. Summary and conclusion Defendant has lived at 1608 Varna Street-indisputably his parents’ address-on and off from 1997 until 2018. He registers his vehicles there. Having moved away and back again numerous times, he no doubt maintains a solid relationship with his family. He visits them often even when he spends time as an “open roommate” at other addresses. It’s quite clear that David Gutierrez was personally served, so it doesn’t matter whether he lived there or not. Given the totality of the evidence, Plaintiff does not expect that the court will believe that Mr. Gutierrez was not personally served. Plaintiff respectfully requests that the motion to vacate be denied outright. In the event that the court grants equitable relief, then Plaintiff respectfully requests that the court acknowledge Misic and Howard and legally toll the Delay statutes, and that it honor equity by equitably tolling the time to serve, so that both parties can be heard on the merits. Hunt & Henriques MAR 1° Dated: Is 201 Jee Id Ll (Anthony J. DiPiero, Attorneys for Plaintiff Declaration of plaintiff’s counsel I, Anthony J. DiPiero, state: 1. Iam an attorney licensed in California and employed by Plaintiff’s counsel of record Hunt & Henriques. I am a custodian of Hunt & Henriques’s business records. 2. Hunt & Henriques’s business records reflect that on about October 18, 2010, a letter was sent to David A Gutierrez, at 38 Dovetail, Irvine, CA 92603 and that said letter was not returned as undeliverable. A true and correct copy of the October 18, 2010, letter is attached hereto as exhibit 1. 3. Hunt & Henriques’s business records reflect that H&H learned from its process server OPPOSITION TO MOTION TO SET ASIDE DEFAULT AND DEFAULT JUDGMENT : 11 B W OO © 0 ~ 3 O n Wn 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ABC Legal Services on September 3, 2010, that all four attempts to serve Defendant at 38 Dovetail Lane had been unsuccessful, and that on the fourth attempt, a resident named Ingrid Canada stated that defendant was an “open roommate” but had no forwarding information. After skiptracing and finding the defendant affiliated with 1608 S. Varna Street, H&H learned from its process server on September 24, 2010, that Defendant had been personally served. True copies of the declaration of non-service filed with the court on September 9, 2010, and of the proof of personal service filed with the court on September 15, 2010, are attached collectively as exhibit 2. . In response to defendant’s sworn assertions that he did live at 38 Dovetail Lane during the time of attempted service and that he did not live at 1608 S. Varna Street, H&H ran a public records search on advance.lexis.com on March 14 and 15, 2018, searching for Mr. Gutierrez by his full name and Social Security number, obtained the results attached collectively as exhibit 3. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Dated: March 15, 2018 J \ & Anthony J. DiPicro OPPOSITION TO MOTION TO SET ASIDE DEFAULT AND DEFAULT JUDGMENT EXHIBIT 1 HUNT & HENRIQUES MICHAEL S. HUNT ATTORNEYS AT LAW AREA CODE 408 JANALIE HENRIQUES 151 BERNAL ROAD, SUITE 8 TELEPHONE 362-2270 SAN JOSE, CA 95119-1306 FACSIMILE 362-2299 October 18, 2010 Re: CITIBANK (SOUTH DAKOTA) N.A. Account Number: XXXXXXXXXXXX7037 Total: $35207.41 Dear David A Gutierrez, We have been notified by our process server that you have now been served with a Summons and Complaint. We would like to invite you to contact this office regarding the above account to discuss a resolution prior to our office proceeding further, and potentially asking the court to enter a judgment against you. Once a judgment is entered, it is public record and may appear on your credit report. Also, if a judgment is obtained, additional costs and interest may be added to your judgment balance. You should consider if it is in your best interest to resolve this debt now. Please call our office at our toll free number (800) 496-5051. Your prompt attention to this matter is imperative. Very truly yours, Hunt & Henriques Attorneys at Law Letter Serve Jstff: 542778.001 (Please use this number as a reference when calling or mailing our office) This firm is a debt collector. The purpose of this letter is to collect a debt and any information obtained will be used for the purpose of collecting the debt. *California, Colorado, Massachusetts Residents - see reverse side for information on your rights as a consumer per Debt Collect ion Practices. Detach bottom section and return with payment oK HUNT & HENRIQUES ATTORNEYS AT LAW 151 BERNAL ROAD, SUITE 8 SAN JOSE, CA 95119-1306 RETURN SERVICE REQUESTED CITIBANK (SOUTH DAKOTA) N.A, XXXXXXXXXXXXT7037 $35207.41 S-SFHUHE10 L-DD000099 A-542778.001 P19MB200208341 116290 HUNT & HENRIQUES DAVID A GUTIERREZ ATTORNEYS AT LAW 38 DOVETAIL 151 BERNAL ROAD, SUITE 8 SAN JOSE, CA 95119-1306 Holseshboea oI Lesa ea habs ial IRVINE CA 92603-4202 linda l dle sna bale HE nab ba asl 1 Letter Serve Jst#: 542778.001 Amount Paid: $ . CALIFORNIA RESIDENTS: The state Rosenthal Fair Debt Collection Practices Act and the federal Fair Debt Collection Practices Act require that, except under unusual circumstances, collectors may not contact you before 8 a.m. or a fter 9 p.m. They may not harass you by using threats of violence or arrest or by using obscene language. Colle ctors may not use false or misleading statements or call you at work if they know or have reason to know tha t you may not receive personal calls at work. For the most part, collectors may not tell another person, other than your attorney or spouse, about your debt. Collectors may contact another person to confirm your location or en force a judgment. For more information about debt collection activities, you may contact the Federal Trade Commission at 1-877-FTC-HELP or www.ftc.gov. COLORADO RESIDENTS: "FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.AGO.STATE.CO.US/CADC/CADCMAIN.CFM ." “A CONSUMER HAS THE RIGHT TO REQUEST IN WRITING THAT A DEBT COLLECTOR OR COLLECTION AGENCY CEASE FURTHER COMMUNICATION WITH THE CONSUMER. A WRITTEN REQUEST TO CEASE COMMUNICATION WILL NOT PROHIBIT THE DEBT COLLECTOR OR COLLECTION AGENCY FROM TAKING ANY OTHER ACTION AUTHORIZED BY LAW TO COLLECT THE DEBT.” MASSACHUSETTS RESIDENTS: NOTICE OF IMPORTANT RIGHTS YOU HAVE THE RIGHT TO MAKE A WRITTEN OR ORAL REQUEST THAT TELEPHONE CALLS REGARDING YOUR DEBT NOT BE MADE TO YOU AT YOUR PLACE OF EMPLOYMENT. ANY SUCH ORAL REQUEST WILL BE VALID FOR ONLY TEN DAYS UNLESS YOU PROVIDE WRITTEN CONFIRMATION OF THE REQUEST POSTMARKED OR DELIVERED WITHIN SEVEN DAYS OF SUCH REQUEST. YOU MAY TERMINATE THIS REQUEST BY WRITING TO THE COLLECTION AGENCY. EXHIBIT 2 California Declaration [non-servicc| Page 1 of 1 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Bar number, and address): \ FOR COURT USE ONLY Michael S. Hunt, ESQ. #09804; Janalie Henriques, ESQ. #111589 Hunt 8 Henriques : 151 Bernal Road #8 rr i L Sanlose: GARSHD SUPERIOR GOURT OF CALIFORN:» TELEPHONE NO: 408 362-2270 FAX NO. (Optional): COUN o EMAIL ADDRESS {Optiana). CENTRAL JUSTICE CENTER ATTORNEY FOR (Name): CITIBANK (SOUTH DAKOTA] NA. Edel SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE SEP 0 9 2 w STREET ADDRESS 700 Civic Center Drive Wast ALAN CARLSON, Clerk of the Cou, MAILING ADDRESS CITY ANG 2IP CODE" Banta Anas 82701 ) ; VELQZ v BRANCH NAME Central Justice Center BY. EVE DEPUTY PLAINTIFE/PETITIONER: CITIBANK (SOUTH DAKOTA) N.A. CASE NUMBER: ( BARDYA) 30-2010-00400279 DEFENDANT/RESPONDENT: David A Gutierrez Rof. Nu. or Fila No.. DECLARATION OF NON SERVICE 542778-001 | declare that | am and was on the dates herein mentioned, a citizen of the United States, over the age of 18 years, not a party to nor interested in the above entitled action, and competent to be a witness therein. | recelved the following documents for service: Summons; Complaint; Affidavit of Venue; Civil Case Cover Sheet; Alternative Dispute Resolution (adr) Packet | attempted to serve David A Gutierrez at the address of 38 DOVETAIL, Irvine, Orange County, CA 92603-4202 and was unable to effect service for the following reasons: 8/21/2010 4:05 PM: No Answer at the door 8/22/2010 9:20 AM; No Answer at the door, left door tag 8/24/2010 5:45 PM: No Answer at the door, left door tag 8/27/2010 7:01 PM: Per resident, Ingrid Canada confirmed subject was open rcommate but had no forwarding info. Neighbor confirmed Ingrid as resident and had no knowledge of subject. Fee for service: $ 45.00 2 | am a registered California process server; my name, address, phone number, and county of registration and number ar e. z Jesse Gowers 555 N Parkcenter #200, Santa Ana, CA 92705 714-541-4133 Orange, #PSC 2460 | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: 8/28/2010 Jesse Gowers /l 2.444 Pr (PRINTED NAME OF DECLARANT) J ISIGNATURE OF DEELARANT) Fagertols Order No. 8651662 SEA FIL 2a PECLARATION OF oN SERIE IRR AIE http://www abelegal.com/pst/proofs/california-non.asp?ord=8651562&typ=non&ul=Califor... 9/8/20 10 ATTORNEY OR PARTY WITHOUT ATTORNEY (Nama, State far number, and address) FOR COURT USE ONLY Michael S, Hunt, ESQ. #99804; Janalie Henriques, ESQ. #111589 Hunt & Henriques 151 Bernal Road #8 FILED San Jose, CA 95119 SUPERIOR COURT OF CALIFORNtA, TELEPHONE NO: 408 362-2270 FAX NO. {Optional OERAEA Ek x EMAIL ADDRESS (Optional); ATTORNEY FOR (Name) CITIBANK (SOUTH DAKOTA) N.A. SEP 1 5 2010 SUPERIOR GOURT OF CALIFORNIA, COUNTY OF ORANGE STREETADDRESS: 700 Civic Center Drive West At AN CARLSON, Clerk of the Court MAILING ADDRESS: GITY AND ZIP CODE: Santa Ana R701 BY: : oZ BRANCH NAME: Central Justice Center ’ = pl PLAINTIFF/PETITIONER: CITIBANK (SOUTH DAKOTA) N. A. Ee TI P c (sou ) N 30-2010-00400279 DEFENDANT/RESPONDENT. David A Gutierrez Rei. No. orFlaNo.: PROOF OF SERVICE OF SUMMONS 542778-001 1. At the time of service | was at least 18 years of age and not a party to this action. 2. | served copies of the (specify documents): Summons; Complaint; Affidavit of Venue; Civil Case Cover Sheet; Alternative Dispute Resolution (adr) Packet xv id 8 3. a. Party served (specify name of party as shown on documents served): David A Gutierrez b. [ ] Person {other than the party in item 3a) served on behalf of an entity or as an authorized agent (and not a person under item 5b whom substituted service was made) (specify name and relationship to the party named in item 3a }. 4. Address where the party was served: 1608 S VARNA Street, ANAHEIM, CA 92804 5. | served the party {check proper box) a. [ X] by personal service. | personally delivered the documents listed in item 2 to the party or person authorized to receive service of process for the party (1) on (date): 9/13/2010 (2) at (time). 7:51 PM b. [ ] by substituted service. On (date): © (2) at (me): 1 left the documents listed In item 2 with or in the presence of (name and litle ar relationship: to person indicated in item 3): (13 [ ] (business) a person at legst! 18 Years of age apparently In charge at the office or usual place of business of the parson to be served. | infoged him or her of the general nature of the papers. (2) [ ] (home) a competent member of the household (at least 18 years of age) at the dwelling house or usual place of abode of the party. | Informed him or her of the general nature of the papers. (3) [ ] {physical address unknown) a person of at least 18 years of age apparently in charge at the usual mailing addresss of the person to be served, other than a United States Postal Service post office box. {informed him or her of the general nature of the papers. (4) [ ]1thereafter malled (by first-dass, postage prepaid) coples of the documents to the person to be served at the place where the copies were left (Code Civ. Proc, § 415.20). | mailed the documents on (date). from (city): or [ ]adedaration of mailing is attached. (5) [ ] lattach a declaration of diligence stating actions taken first to attempt personal service. Pasi of2 Fam Adoptd for Man ebry Use ) Code of CVI Procedure, § 417. 10 Judieid Courci of Calforria POSOIRIR EY, dovay 1, 200] PROOF OF SERVICE OF SUMMONS er No. 8651562 SEAFIL = 7 I JH ER - el CASE NUMBER: PLAINTIFF/PETITIONER: CITIBANK {SOUTH DAKOTA) N.A. 30-2010-00400279 DEFENDANT/RESPONDENT: David A Gutierrez ¢. [ ] by mail and acknowledgment of receip of service. | mailed the documents listed in item 2 to the party, to the address shown in item 4, by firstclass mail, postage prepaid, (1) on (date): (2) from (city): (3) [ 1] with two copies of the Notice and Acknowledgment of Receipt and a postage-paid return envelope addressed to me. (Attach completed Notice and Acknowledgment of Receipt.) (Code Civ. Proc., § 416.30) (4) [ 1 toan address outside California with return receipt requested. (Code Civ. Proc., § 415.40) d. [ ] by other means (specify means of service and authorizing code section): [ ] Additional page describing service is attached. 6. The "Notice to the Person Served” (on the summons)was completed as follows: a. [X] as an individual defendant. b. [ ] as the person sued under the fictitious name of (specify): ¢ [ 1] as occupant d. [ ] On behalfof (specify): under the following Code of Civil Procedure section: [ ] 416.10 (corporation) . [ ] 416.20 (defunct corporation) [ ] 416.30 (joint stock companylassodiation) [ [ ] 415.95 (business organization, form unknown) ] 416.60 (minor) ] 416.70 (ward or conservatee) ] 416.90 (authorized person) ] 415.46 (occupant) ] 416.40 (assodation or partnership) 1 416.50 (public entity) ] other 7. Person whoserved papers a. Name: Jim Murray b. Address: 555 N Parkcenter #200, Santa Ana, CA 92705 ¢ Telephone number: 714-541-4133 d. The fee for service was: $59.00 e. lam: (1) [ ] netaregistered California process server. (2) [ 1 exempt from registration under Business and Professions Code section 22350(b). (3) [ X] registered California process server: Xv d AS iy [ Jowner [ ]employee [ X 1 independent contractor (ii) [ X 1 Registration No.: PSC# 2063 (ili)[ X ] County: Orange 8.[X] | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Zi 9.[ ] lama California sheriff or marshal and | certify that the foregoing is true and correct. : LE : . . weit, “7 fo 5 Jim Murray J - NAME OF PERSON WHO SERVED PAPER S/SHERIFF OR MARSHAL) & (SIGNATURE) = Date: 9/14/2010 POS-O10[Rav. January 1, 200] Pegz20f2 en PROOF OF SERVICE OF SUMMONS Ti "EXHIBIT 3 Today 195 or ’ Bh h ) LIND H I A T T RAV ® sino1 R Y ny 61 y o d s y # 5 z a n e R H ‘81 TOAST T O QiAva NIH a1 S R E a . i. ee a i . o y C e = pedsy Es o r EE or ATYOUY SYMOHL “ZTRILND C o a R i g g m m m n e m e e e e ! SEAL: ns H T Y N I A N L * Z 3 W H 3 L N O v1 ¥ o d a y 1 ° "HE I B A N Y I 3ISS3( “ 3 0 4 v N G ‘£1 o d y 7 5 ) A Q v H ‘ Z I Y I L N D Tt T o d o 5 . 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