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1 Martin L. Hirsch, Bar No. 255718
Kelsey L. O'Rourke, Bar No. 322676
2 PERRY, JO;INSON, ANDERSON,
MILLER & MOSKOWITZ,LLP
D 438 l.t Street, 4th Floor
Santa Rosa, California 95401
4 Telephone : (7 07) 525-8800
Facsimile: (7 07) 545-8242
5 Email: hirsch@perrlrlaw. net
orourke@perrylaw.net
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Attorneys for Defendant,
7 Farmparc. LLC
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SONOMA
10 Commercial Collections of America, Case No. SCV-268881
LLC,
11 STIPULATION TO SET ASIDE
Plaintiffs, DEFAULT JUDGMENT
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v. Action Filed: Jilv 17.202L
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OF
N 13 Trial Date: None
e= Farmparc,LLC, and DOES 1-10
--i :< t4 inclusive, ASSIGNED FOR ALL PURPOSES
=a TO THE HONORABLE JENNIFER
2= Defendants. V. DOLLARD
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77 Plaintiff Commercial Collections of America, LLC ("Plaintiff') filed this
18 action against Defendant Farmparc, LLC on July 17,2021.
19 On Januar-tr 12, 2A22, Plaintiff requested a Default against Defendant,
20 which was entered.
2T On January 27, 2022, a Default Judgment was requested by Plaintiff and
22 entered by the Court.
23 The parties have agreed to set aside the Default Judgment against
24 Defendant and aliow Defendant to file an Answer to the Complaint.
25 Accordingly, THE PARTIES HEREBY STIPULATE AND AGREE AS
26 FOLLOWS:
27 1. The Default Judgment entered against Defendant on January 27,2022
28 will be set asj.de;
STIPULATION TO SET ASIDE DEFAULT JUDGMENT
1 2. Defendant shall be permitted to file its Answer to the Ptaintiffs
2 Complaint concurrent to the filing of this stipuiation.
D
4 PERRY, JOHNSON, ANDERSON,
MILLER & MOSKOWITZ, LLP
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DATtrD: Bv:
7 Martin L. Hirsch
Kelsey L. O'Rourke
8 Attorneys for Defendant,
Farmparc. LLC
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DATED:61 ;i>- By: *
Frank
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J. Love
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tJ Attorney for Plaintiff
LUN 13
OF Commercial Collections of America,
<- 14
LLC
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9= 15
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STIPIILATION TO SET ASIDE DEFAULT JUDGMENT
1 PROOF OF SERVICE
2 I declare that:
3 I am and was at the time of service of the papers herein, over the age of
eighteen (18) years and am not a party to the action. I am employed in the County
4 of Sonoma, California, and my business address is 438 1st Street, 4th Floor, Santa
Rosa, California 95401.
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On June 7, 2022, I served the following document, described as set forth
6 below on the interested parties in this action by placing true copies thereof
enclosed in sealed envelopes, at Sonoma, addressed as follows:
7
STIPULATION TO SET ASIDE DEFAULT JUDGMENT
8
SEE ATTACHED SERVICE LIST
9
BY FIRST-CLASS MAIL: I caused such envelopes to be deposited in the
10 United States mail, at Santa Rosa, California, with postage thereon fully
prepaid, individually, addressed to the parties as indicated. I am readily
11 familiar with the firm’s practice of collection and processing
correspondence in mailing. It is deposited with the United States postal
12 service each day and that practice was followed in the ordinary course of
PERRY, JOHNSON, ANDERSON,
business for the service herein attested to.
MILLER & MOSKOWITZ LLP
13
BY FACSIMILE TRANSMISSION: By use of facsimile machine number
14 (707)545-8286, I served a copy of the within document(s) on the above
interested parties at the facsimile numbers listed above. The transmission
15 was reported as complete and without error. The transmission report was
properly issued by the transmitting facsimile machine.
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BY ELECTRONIC FILING SERVICE: My electronic business address
17 is guzman@perrylaw.net and I caused such document(s) to be
electronically served for the above-entitled case to those parties on the
18 Service List below. The file transmission was reported complete and a
copy will be maintained with the original document(s) in our office.
19
BY HAND DELIVERY: By personal service I caused each such envelope/
20 package to be delivered by hand to the addresses as stated above.
21 By personally delivering the copies;
22 By leaving the copies at the attorney’s office;
23 With a receptionist, or with a person having charge thereof; or
24 In a conspicuous place in the office between the hours of ______
in the morning and five in the afternoon;
25
By leaving the copies at the individual’s residence, a conspicuous
26 place, between the hours of eight in the morning, and six in the
afternoon.
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I declare under penalty of perjury under the laws of the State of California
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1
Proof of Service
1 that the foregoing is true and correct.
2 Executed on June 7, 2022, at Santa Rosa, California.
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4 _____________________________
Cenaida E. Guzman
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MILLER & MOSKOWITZ LLP
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Proof of Service
1 SERVICE LIST
2 Commercial Collections of America, LLC v. Farmparc, LLC, et al.
3 Sonoma County Superior Court Case No.: SCV-268881
4 Frank J. Love Attorney for Plaintiff
800 South Barranca Ave, Ste 100,
5 Covina, CA 91723
6 Tel: (626) 653-0455
Fax: (626) 653-0465
7 E-mail: office@fjlovelaw.com
clove@lovelawpc.com
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PERRY, JOHNSON, ANDERSON,
MILLER & MOSKOWITZ LLP
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Proof of Service
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1 Martin L. Hirsch, Bar No. 255718 Kelsey L. O'Rourke, Bar No. 322676 2 PERRY, JO;INSON, ANDERSON, MILLER & MOSKOWITZ,LLP D 438 l.t Street, 4th Floor Santa Rosa, California 95401 4 Telephone : (7 07) 525-8800 Facsimile: (7 07) 545-8242 5 Email: hirsch@perrlrlaw. net orourke@perrylaw.net 6 Attorneys for Defendant, 7 Farmparc. LLC 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SONOMA 10 Commercial Collections of America, Case No. SCV-268881 LLC, 11 STIPULATION TO SET ASIDE Plaintiffs, DEFAULT JUDGMENT z. o(L t2 AJ tJ v. Action Filed: Jilv 17.202L I.IJ OF N 13 Trial Date: None e= Farmparc,LLC, and DOES 1-10 --i :< t4 inclusive, ASSIGNED FOR ALL PURPOSES =a TO THE HONORABLE JENNIFER 2= Defendants. V. DOLLARD I"o 15 -E-LU >-J 16 tJ ffi> o_ 77 Plaintiff Commercial Collections of America, LLC ("Plaintiff') filed this 18 action against Defendant Farmparc, LLC on July 17,2021. 19 On Januar-tr 12, 2A22, Plaintiff requested a Default against Defendant, 20 which was entered. 2T On January 27, 2022, a Default Judgment was requested by Plaintiff and 22 entered by the Court. 23 The parties have agreed to set aside the Default Judgment against 24 Defendant and aliow Defendant to file an Answer to the Complaint. 25 Accordingly, THE PARTIES HEREBY STIPULATE AND AGREE AS 26 FOLLOWS: 27 1. The Default Judgment entered against Defendant on January 27,2022 28 will be set asj.de; STIPULATION TO SET ASIDE DEFAULT JUDGMENT 1 2. Defendant shall be permitted to file its Answer to the Ptaintiffs 2 Complaint concurrent to the filing of this stipuiation. D 4 PERRY, JOHNSON, ANDERSON, MILLER & MOSKOWITZ, LLP 5 6 DATtrD: Bv: 7 Martin L. Hirsch Kelsey L. O'Rourke 8 Attorneys for Defendant, Farmparc. LLC I 10 z_ oo- 11 t2 DATED:61 ;i>- By: * Frank ffrt--* J. Love AJ tJ Attorney for Plaintiff LUN 13 OF Commercial Collections of America, <- 14 LLC =a 9= 15 $"o -t>-J -uJ tJ 16 oa= o_ 77 18 19 20 27 22 23 24 25 26 27 28 STIPIILATION TO SET ASIDE DEFAULT JUDGMENT 1 PROOF OF SERVICE 2 I declare that: 3 I am and was at the time of service of the papers herein, over the age of eighteen (18) years and am not a party to the action. I am employed in the County 4 of Sonoma, California, and my business address is 438 1st Street, 4th Floor, Santa Rosa, California 95401. 5 On June 7, 2022, I served the following document, described as set forth 6 below on the interested parties in this action by placing true copies thereof enclosed in sealed envelopes, at Sonoma, addressed as follows: 7 STIPULATION TO SET ASIDE DEFAULT JUDGMENT 8 SEE ATTACHED SERVICE LIST 9 BY FIRST-CLASS MAIL: I caused such envelopes to be deposited in the 10 United States mail, at Santa Rosa, California, with postage thereon fully prepaid, individually, addressed to the parties as indicated. I am readily 11 familiar with the firm’s practice of collection and processing correspondence in mailing. It is deposited with the United States postal 12 service each day and that practice was followed in the ordinary course of PERRY, JOHNSON, ANDERSON, business for the service herein attested to. MILLER & MOSKOWITZ LLP 13 BY FACSIMILE TRANSMISSION: By use of facsimile machine number 14 (707)545-8286, I served a copy of the within document(s) on the above interested parties at the facsimile numbers listed above. The transmission 15 was reported as complete and without error. The transmission report was properly issued by the transmitting facsimile machine. 16 BY ELECTRONIC FILING SERVICE: My electronic business address 17 is guzman@perrylaw.net and I caused such document(s) to be electronically served for the above-entitled case to those parties on the 18 Service List below. The file transmission was reported complete and a copy will be maintained with the original document(s) in our office. 19 BY HAND DELIVERY: By personal service I caused each such envelope/ 20 package to be delivered by hand to the addresses as stated above. 21 By personally delivering the copies; 22 By leaving the copies at the attorney’s office; 23 With a receptionist, or with a person having charge thereof; or 24 In a conspicuous place in the office between the hours of ______ in the morning and five in the afternoon; 25 By leaving the copies at the individual’s residence, a conspicuous 26 place, between the hours of eight in the morning, and six in the afternoon. 27 I declare under penalty of perjury under the laws of the State of California 28 1 Proof of Service 1 that the foregoing is true and correct. 2 Executed on June 7, 2022, at Santa Rosa, California. 3 4 _____________________________ Cenaida E. Guzman 5 6 7 8 9 10 11 12 PERRY, JOHNSON, ANDERSON, MILLER & MOSKOWITZ LLP 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 Proof of Service 1 SERVICE LIST 2 Commercial Collections of America, LLC v. Farmparc, LLC, et al. 3 Sonoma County Superior Court Case No.: SCV-268881 4 Frank J. Love Attorney for Plaintiff 800 South Barranca Ave, Ste 100, 5 Covina, CA 91723 6 Tel: (626) 653-0455 Fax: (626) 653-0465 7 E-mail: office@fjlovelaw.com clove@lovelawpc.com 8 9 10 11 12 PERRY, JOHNSON, ANDERSON, MILLER & MOSKOWITZ LLP 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 Proof of Service