Motion,Ex Parte: ODEH -V- FERNANDEZ Print

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    6/3/2022 15:18:51                   To: 190970.                       Page: 02/39            Fr'neral    Business Services         Faxz7752766927




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                    Peter Gibbons             (CBN 1 96169)
                    Law Offices of Gibbons and Associates
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                    1805  North Carson Street,     Suite E
                    Carson City, Nevada      89701 -I 216
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                    Telephone:    775-546-1450
                    Email:  LawDr] @npn.net
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                    Attorney for   Defendant Janet Summerfield
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                                                                                                                                           By
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                                         SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                                FOR THE COUNTY OF SAN BERNARDINO
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                                                                           v  case N0”     CWSBZIOSS”
                     CITY 0F SAN        BERNARDINO,          a municipal
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                    corporation,                                              Notice 0f Motion      and Motion to File
                                                                              Demurrer Nunc Pro Tunc,
                                         Plaintiff,                           per Rule 2.304(d)

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                                                                              By Fax
                    Janet Summerfield, an individual;          and,            Remote Appearance Requested
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                     Does  1 to 7
                                55,  Incluswc ‘


                                                                               Date:    July  38’ 2022

                                         Defendants.
                                                                               Time:    8:30  AM
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                                                                               Dept:    823   -SBJC
                                                                           V   Judge:   Hon.   Donald Alvarez




                                                                   NOTICE      0F MOTION
                             To  all parties  and   their attorneys of record, please take notice that on July           i8, 2022  at


                    8:30  AM,    0r at such   other time   as the court  may   hear this  matter,  before  the  Honorable    Donald

                    Alvarez    in Department     SZB-SBJC     of the   above-entitled   court,  located   at the   San  Bernardino

                    Justice    Center,   247    West    Third    Street,   San   Bemardino,      California,    Defendant,     Janet

                    Summerfieid,     will move    this court  to enter  an  order t0  the clerk  of the  court to file  Defendant’s

                    demurrer    to the complaint nunc pro tune, effective      May   23, 2022.


                             This motion    is opposed by    Plaintiff’s counsel.


                             This Motion    is based on California Rules of Court, Rule         2.304(d) and California Code       of

                    Civil  Procedure    (C..C.P.)   § 473(b),   the  attached    Memorandum       of  Points   &  Authorities,   the



                     Defendant’s Notice 0f Motion                                                                CIVSB2 1085      I 2

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                i    Declaration Ofcounsel, the pleadings and records 0n           file in this action,  allother matters ofwhich

                2    the  court  may    take  judicial  notice,   and  on   such  further  argument     and  evidence    as may   be

                3    presented.

                4             Dated:   June 3, 2022

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                7                                                        Peter Gibbons
                                                                         Attorney for Defendant, Janet Summerfield
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                     Defendant’s Notice ()fMotion                                                                CIVSBZ 1085 12
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