Response

Cal. Super. - 1st Dist.March 13, 2019

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ROBERT G. MACK, ESQ. (SBN 293196) ROBERT G. BURTON, ESQ. (SBN 88016) KURLANDER & BURTON 100 Bush Street, Suite 2150 San Francisco, CA 94104 ELECTRONICALLY Telephone: (415) 392-8920 FILED Facsimile: (415) 392-8921 Superior Court of California, County of San Francisco Attorneys for Plaintiff NOUREDDINE MANSER CHE aaneD. rt BY: DAVID YUEN Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION NOUREDDINE MANSER, ) Case No.: CGC-19-574487 Plaintiff, ) PLAINTIFF'S RESPONSE TO v. ) ORDER TO SHOW CAUSE ) DENYS SHAMETO and DOES 11050, ~~) inclusive, DATE: MARCH 27, 2020 J TIME: 10:30 A.M. Defendants. ) DEPT: 610 ) Plaintiff, NOUREDDINE MANSER, hereby responds to the Order to Show Cause as follows: While Plaintiff’s counsel was in the process of obtaining and preparing documentation to obtain a default judgment against Defendant Denys Shameto, the Defendant contacted Plaintiffs counsel’s office in response to receiving Plaintiff’s Case Management Statement served upon him on January 2, 2020. Unfortunately, Defendant and counsel have not yet communicated. WHEREFORE, Plaintiff respectfully requests this matter be continued for 60 days to allow time for Plaintiff’s counsel and Defendant Denys Shameto to confer about this case. rr rrr DECLARATION OF ROBERT G. MACK IN SUPPORT OF APPLICATION FOR DEFAULT JUDGMENT 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Should Defendant not follow through with filing an answer to the complaint after conferring with counsel, Plaintiff will proceed in obtaining a default judgment against Defendant. Dated; 3/16/2020 KURLANDER & BURTON (zh ROBERT G. MACK, ESQ. Attorney for Plaintiff NOUREDDINE MANSER DECLARATION OF ROBERT G. MACK IN SUPPORT OF APPLICATION FOR DEFAULT JUDGMENT 10 11 12 I3 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE [C.C.P. §§ 1013a, 2015.5, 2008] Re: Manser v. Shameto, et al. San Francisco County Superior Court Case No.: CGC-19-574487 I, the undersigned, declare: [am a resident of the United States and employed in San Francisco County, California. I am over the age of eighteen years and not a party to the within action. My business address is 100 Bush Street, Suite 2150, San Francisco, California 94104. On the date set forth below, I served the following documents: Plaintiff’s Response to Order To Show Cause [>< BY UNITED STATES MAIL. I enclosed the documents noted above in a sealed envelope or package addressed to the person(s) indicated below and depositing the sealed envelope with the United States Postal Service at San Francisco, California, with the postage fully prepaid. BY OVERNIGHT DELIVERY. I enclosed the documents noted above in an envelope or package provided by an overnight delivery carrier and addressed to the person(s) listed below. I placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier. BY ELECTRONIC MAIL (Email) as follows: based on a court order or an agreement of the parties to accept electronic service, I caused the documents noted above to be sent to the persons at the electronic service addresses listed below. BY ELECTRONIC SERVICE VIA FILE & SERVE XPRESS I electronically served the document(s) noted above via File & ServeXpress on the recipients designated on the Transaction Receipt located on their website: htips:secure.fileandservexpress.com. BY FAX TRANSMISSION. Based on an agreement of the parties to accept service by fax transmission, I faxed the documents noted above to the addressee(s) at their fax numbers indicated below. The fax machine I used complied with Rule 2003(3) and no error was reported by the machine. Pursuant to Rule 2005(i), I caused the machine to print a transmission record of the transmission. BY CERTIFIED MAIL. I enclosed the documents noted above in a Certified/Return Receipt Requested envelope with postage thereon fully prepaid to be placed in the U.S. Mail at San Francisco, California to the addressee as indicated above. BY PERSONAL SERVICE as follows: I enclosed the documents noted above in an envelope or package and caused each such envelope or package to be delivered by hand to the addressee(s) identified below. Denys Shameto 3427 Evergreen Cir Apt 21 West Sacramento, CA 95691-2936 916-600-4974 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this Declaration was executed on Ma 020 at San Francisco, California. RARI MONIQUE OLTS