Velasco vs Velasco

Motion for Attorney Fees

Cal. Super. - 4th Dist.May 14, 2018

po d H. TROY ROMERO (CBN 224867) ELECTRONICALLY FILED CHRISTOPHER M. POWELL (CBN 285748) Superior Court of California, ROMERO PARK P.S. County of San Diego 16935 West Bernardo Drive, Suite 260 14/08/2018 at 02:31:00 PI San Diego, CA 92127 oo TEL: (838) 592-0065 FAX: (425) 450-0728 Hi Jes Hct, Heute Hier tromero@romeropark.com OO © 9 OA wn B A W N DN DN ND N N N O N N N m e e m e m e d e a e d e m e m e e 0 N N B R A W N = O O N N O Y B R A W N = O cpowell@romeropark.com Attorneys for Defendant Javier Velasco SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN DIEGO DENNISE VELASCO, an individual, Case No. 37-2018-00023733-CU-FR-CTL Plaintiff, DEFENDANT JAVIER VELASCO’S Vs. NOTICE OF MOTION AND MOTION FOR ATTORNEY FEES JAVIER VELASCO, an individual; : 2 SP : . Eddie C. Stu ARTURO VELASCO, an individual; and pee HL, BRAT DOES 1 through 100, inclusive, Hearing Date: 12/07/2018 Defendants. Time: 9:00 a.m. TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on Friday, December 7, 2018, at the hour of 9:00 a.m. or as soon thereafter as counsel may be heard in Department C-67 of the above-entitled court, located at 330 W. Broadway, San Diego, CA 92101, Defendant Javier Velasco (“Dr. Velasco”) will move the Court for an order awarding him his reasonable attorneys’ fees incurred in connection with his successful special motion to strike (the “Motion”). The Motion will be made pursuant to Code of Civil Procedure section 425.16(c) upon grounds that Dr. Velasco is entitled to a mandatory award of such fees following the Court’s grant of his special motion to strike. The Motion will be based upon this Notice of Motion and Motion, the attached Memorandum of Points and Authorities, the Declarations of Javier Velasco and Christopher M. NOTICE OF MOTION & MOTION FOR ATTORNEYS FEES - 1 © ©0 0 9 O N wn ~~ W N 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Powell, the exhibits attached to these moving papers, upon the entire Court file in this matter, and upon such further evidence as may be presented at or before the hearing on this matter. DATED this 8" day of November, 2018. ROMERO PARK P.S. 7 Fy H. Troy Romero Christopher M. Powell NOTICE OF MOTION & MOTION FOR ATTORNEYS FEES - 2 © 0 3 O& O Un HbA W N = D O N N N N N N N N = e e m e e e m e m p m e d e d 0 9 L A W N = O 0 X N Y R W N = Oo PROOF OF SERVICE I, Kathy Koback, certify and declare as follows: I am a citizen of the United States and a resident of the State of Washington. I am over the age of 18 years and not a party to the within-entitled cause. I am an employee with the law firm of Romero Park P.S., whose addresses are 16935 West Bernardo Drive, Suite 260, San Diego, California 92127 and 155 — 108™ Avenue NE, Suite 202, Bellevue, Washington 98004, which is located in the county where the mailing described below took place. On November 8, 2018, at my place of business in Bellevue, Washington, a copy of the attached document described as: DEFENDANT JAVIER VELASCO’S NOTICE OF MOTION AND MOTION FOR ATTORNEY FEES was sent via electronic mail, pursuant to California Rules of Court 2.251(b)(1)(B), and addressed to: Plaintiff Dennise Velasco: Dennise Velasco 5820 Miramar Road, Suite 201 San Diego, California 92121 Email: dennise.velasco@yahoo.com Dennise Velasco 153 South Sierra Avenue, #323 Solana Beach, California 92075 I certify and declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. DATED this 8" day of November, 2018. 20 Kathy Koback, Legal Assistant