On November 08, 2019 a
Order to Show Cause
was filed
involving a dispute between
Leu, Evan,
Leu, Miyabi,
and
Does 1 To 50, Inclusive,
Estrada, Juan Jose,
for PERSONAL INJURY/PROPERTY DAMAGE - VEHICLE RELATED
in the District Court of San Francisco County.
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1 INFINITY LAW GROUP LLP
ILYA FILMUS (CSB #251512)
2 3450 Geary Blvd. Suite 210
ELECTRONICALLY
San Francisco, California 94118
3 Tel: (415) 426-3580 F I L E D
Fax: (415) 426-3581 Superior Court of California,
County of San Francisco
4 Email: ifilmus@infinitylawca.com
07/12/2021
5 Clerk of the Court
Attorneys for plaintiff BY: VANESSA WU
MIYABI LEU Deputy Clerk
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8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE CITY AND COUNTY OF SAN FRANCISCO
10 MIYABI LEU, CASE NO. CGC-19-580635
11 PLAINTIFF’S RESPONSE TO ORDER
Plaintiff, TO SHOW CAUSE
12
v.
13 Date: August 3, 2021
3450 Geary Boulevard, Suite 210
INFINITY LAW GROUP LLP
San Francisco, California 94118
JUAN JOSE ESTRADA Time: 10:30 a.m.
14 Dept.: 610
Fax: (415) 426-3581
Tel: (415) 426-3580
Defendant.
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17 Plaintiff MIYABI LEU respectfully submits this Response to the Court’s Order to Show
18 Cause regarding failure to enter judgment. Plaintiff was informed by the California Insurance
19 Guarantee Association (“CIGA”) that Defendant’s auto insurance company no longer exists.
20 (Declaration of Ilya Filmus, hereafter “IF Dec.,” Paragraph 2.) Accordingly, Plaintiff engaged in
21 negotiations with CIGA, but those negotiations were not successful. (IF Dec., Par. 3). CIGA then
22 represented that this matter would be assigned to defense counsel for further handling; however, this
23 did not happen for months. (IF Dec., Par. 4). Defense counsel has been assigned, and the parties,
24 through counsel, have started negotiating a stipulation for setting aside entry of default, but Plaintiff
25 is waiting for a draft stipulation from defense counsel. (IF Dec., Par. 5).
26 In light of the foregoing, Plaintiff respectfully requests that the Court vacate the Order re:
27 CASE MANAGEMENT and ORDER TO SHOW CAUSE, that a Case Management Conference be
28 scheduled for September 2021 in order to provide Plaintiff and Defendant ample opportunity to set
1
PLAINTIFF’S RESPONSE TO ORDER TO SHOW CAUSE
1 aside entry of default, and that Plaintiff not be sanctioned.
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3 DATED: July 12, 2021 INFINITY LAW GROUP LLP
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By________________________
6 Ilya Filmus, Esq.
7 Attorney for Plaintiff MIYABI LEU
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3450 Geary Boulevard, Suite 210
INFINITY LAW GROUP LLP
San Francisco, California 94118
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Fax: (415) 426-3581
Tel: (415) 426-3580
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PLAINTIFF’S RESPONSE TO ORDER TO SHOW CAUSE
Document Filed Date
July 12, 2021
Case Filing Date
November 08, 2019
Category
PERSONAL INJURY/PROPERTY DAMAGE - VEHICLE RELATED
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1 INFINITY LAW GROUP LLP ILYA FILMUS (CSB #251512) 2 3450 Geary Blvd. Suite 210 ELECTRONICALLY San Francisco, California 94118 3 Tel: (415) 426-3580 F I L E D Fax: (415) 426-3581 Superior Court of California, County of San Francisco 4 Email: ifilmus@infinitylawca.com 07/12/2021 5 Clerk of the Court Attorneys for plaintiff BY: VANESSA WU MIYABI LEU Deputy Clerk 6 7 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE CITY AND COUNTY OF SAN FRANCISCO 10 MIYABI LEU, CASE NO. CGC-19-580635 11 PLAINTIFF’S RESPONSE TO ORDER Plaintiff, TO SHOW CAUSE 12 v. 13 Date: August 3, 2021 3450 Geary Boulevard, Suite 210 INFINITY LAW GROUP LLP San Francisco, California 94118 JUAN JOSE ESTRADA Time: 10:30 a.m. 14 Dept.: 610 Fax: (415) 426-3581 Tel: (415) 426-3580 Defendant. 15 16 17 Plaintiff MIYABI LEU respectfully submits this Response to the Court’s Order to Show 18 Cause regarding failure to enter judgment. Plaintiff was informed by the California Insurance 19 Guarantee Association (“CIGA”) that Defendant’s auto insurance company no longer exists. 20 (Declaration of Ilya Filmus, hereafter “IF Dec.,” Paragraph 2.) Accordingly, Plaintiff engaged in 21 negotiations with CIGA, but those negotiations were not successful. (IF Dec., Par. 3). CIGA then 22 represented that this matter would be assigned to defense counsel for further handling; however, this 23 did not happen for months. (IF Dec., Par. 4). Defense counsel has been assigned, and the parties, 24 through counsel, have started negotiating a stipulation for setting aside entry of default, but Plaintiff 25 is waiting for a draft stipulation from defense counsel. (IF Dec., Par. 5). 26 In light of the foregoing, Plaintiff respectfully requests that the Court vacate the Order re: 27 CASE MANAGEMENT and ORDER TO SHOW CAUSE, that a Case Management Conference be 28 scheduled for September 2021 in order to provide Plaintiff and Defendant ample opportunity to set 1 PLAINTIFF’S RESPONSE TO ORDER TO SHOW CAUSE 1 aside entry of default, and that Plaintiff not be sanctioned. 2 3 DATED: July 12, 2021 INFINITY LAW GROUP LLP 4 5 By________________________ 6 Ilya Filmus, Esq. 7 Attorney for Plaintiff MIYABI LEU 8 9 10 11 12 13 3450 Geary Boulevard, Suite 210 INFINITY LAW GROUP LLP San Francisco, California 94118 14 Fax: (415) 426-3581 Tel: (415) 426-3580 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 PLAINTIFF’S RESPONSE TO ORDER TO SHOW CAUSE