Preview
HEU
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Oct-26-2015 12:10 pm
Case Number: CGC-15-544243
Filing Date: Oct-26-2015 12:01
Filed by: CAROL BALISTRERI
Juke Box: 001 Image: 05129920
MOTION (CIVIL GENERIC)
HDM FURNITURE INDUSTRIES INC VS. VICTORIA L CARD ET AL
001005129920
Instructions:
Please place this sheet on top of the document to be scanned.F
Name: Victoria L. Card hd ED
Address: P.O. Box 502
Petaluma CA 94953 OCT 2
T: 415-710 9296 CLERK 52015
In Pro Per &y. “OF THE Courr
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
a - 7 or
LAINTIFF, | Case No.: CGC-15-5444 ZFS
IDM FURNITURE INDUTRIES INC. | NOTICE OF MOTION AND MOTION
FOR ORDER SETTING ASIDE AND
‘VACATING ORDERS COMPELLING
‘RESPONSES TO INTERROGATORIES
vs. ‘AND SANCTIONS THEREON.
EFENDANT, Dete :fo. 20,206
| / PY Zoj%s
ICTORIA L. CARD He ~G.PF AM
To: PLAINTIFF AND ATTORNEY OF RECORD
Notice is here given that as soon as thereafter as the matter may be heard in SUPERIOR
COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN
FRANCISCO located at 400 McAllister Street room 103, San Francisco, CA 95102
SAN FRANCISCO Judicial District defendant will and hereby does move for an order
setting aside and vacating the orders compelling responses to interrogatories and for
sanctions thereon against defendant and granting defendant leave to defend the action.
The motion will be made on the ground that the service of plaintiff’s notices failed proper
service to result in actual notice to defendant. Motion proposed to be filed and served
herewith, on the records and file herein, and on such evidence as may be presented at the
hearing of the motion.
1, I Victoria L. Card defendant, declare that the Plaintiff has failed to service the
notification of any kind to this date.2. The only time I came to notice what was actually going on was when I discovered on
the Court’s website around October 8, 20125 as to what was filed. I immediately
prepared a motion to postpone the hearing since I was out of time to prepare and submit
an answer and to attend the hearing. So, I mailed my response on October 13, 2015 and
today October 26, 2015, I find out that the USPS has failed to deliver the certified mail
and been held at the San Francisco mail center. I am enclosing my response of October
13, 2015, proof of service and the USPS receipt, which is self-explanatory.
[Continue]
I declare under penalty of perjury under the laws of the state of California that the
foregoing is true and correct.
I pray the court reverses the orders and denies the sanctions and schedule a new hearing.
Date: 10/26/2015 Vide Cart... [signature]
Victoria L. Card
Plate for wphiber A and 2PROOF OF SERVICE
The undersigned declares as follows:
Iam a citizen of the United States, over 18 years of age, reside in the County of
Marin State of California, and am not a party to the within cause of action. My address is
1977B Union Street Francisco, CA 94123 On 10/26/2015 I served a copy of the
document (s) described as: MOTION RESPONSE
On all interested parties in this action as addressed below in the indicated manner:
‘LAW OFFICE OF STEVEN A. BOOSKO | Case number: CGC 15-544243
“HDM FUNITURE
PO BOX 2169
“OAKLAND CA 94621
_X (BY MAIL & FAX) I placed said document(s) in a sealed envelope, with postage
thereon fully prepaid for first class mail, and placed such envelope in the United States
mail at San Francisco, California.
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 this Monday day
of 10/26/2015 San Francisco, CA California.
Michael Mott: Signature:4g
or PETALUMA MPO
A 420 4TH ST
PETALUNA, CA 94952-9998
10/43/2015
SRS SEE SRSS
a Sales Receipt _
Product Sale Unit Final
Description Qty Price Price
SAN FRANCISCO,
CA 94102-4512 $1.42
Zone-1
First-Class Mail® Large Envelope
ws USPS Certified Mail™:
9507 1000 1333 5286 0001 64
O Ib. 2.20 oz.
* Expected Delivery Day Thursday,
October 15.
Certified Mail™ $3.45
Issue Postage: $4.87
PETALUMA, CA 94953 $1.20
Zone-0
i rst-Class Mail® Large Envelope
O ib. 1.30 oz.
‘* Expected Delivery Day Thursday,
October 15.
Issue Postage: $1.20
Total:
$6.0"
Paid by:
VISA $6.07
Account #: OOOOKKKXXXO9-43
Approval #: 922253
Transaction #: ‘017
23-902470368 -99
BSK Transaction #: 26
USPS@ # 055958 -9550
€
6% To check onthe delivery status of
this article, visit our Track &
Confirm website at USPS.com, use this
self-service kiosk (or any
self-service kiosk at other Postal
Jocations) or call 1-800-222-1811.
t
Thanks.
{it's a pleasure to serve you.
ALL SALES FINAL ON STAMPS AND POSTAGE.
REFUNDS FOR GUARANTEED SERVICES ONLY.
Today's Postal Service is hiring!
immediateopanings available for
' City Carrier Assistants (CCA) in many
jocations nationwide! Apply today at
www. usps .com/emptoyment .Name: Victoria L. Card Lah ho
Address: P.O. Box 502
Petaluma, CA 94953
In Pro Per
Tel: 415-710-9296
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
PLAINTIFF, /
i Case No.: CGC - 15 — 544243
_ HDM FURNITURE INDUSTRIES INC, j
HERITAGE HOME GROUP LLC. : RESPONSE TO:
_ NOTICE OF DEFENDANT’S MOTION FOR i
ORDER COMPELLING RESPONSE TO i
vs INTERROGATORIES AND FOR SANCT! TONS |
i THEREON.
| DEFENDANT, Date: October 7, 2015
\ ‘Time: 9.30 am
VICTORIA CARD Dept: 302
TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
FACTS
1. Plaintiffs Counsel assertions submitted are false. The Plaintiff in question filed
bankruptcy back in September 2011/12 therefore, the company dissolved. The Counsel’s
attempt is baseless and unfounded and I don’t owe plaintiff a Cent. Furthermore the
Counsel operates a collection agency and is not representing the actually a plaintiff.
2. Plaintiff's counsel continuously is diverting the truth, resorting to misleading legal
ways to extort monetary relief. In fact, the entire lawsuit is bogus and plaintiff has to date
failed to provide a shred of evidence to show proof to justify the lawsuit.
3. Plaintiff has failed to prove ownership of this debt. Therefore, applying CCP2033.280 and pressing for documents or admission and asking the court for sanctions is
baseless and has no standing in court.
CONCLUSION
I pray the court dismiss plaintiff's entire complaint.
I pray for cost of suit incurred herein; and
For such other further relief as the court may find just and proper.
I am 60 year old single women self-employed in the Bay Area for over 35 years. I
have to represent myself without a lawyer because I can't afford and justify the
expense. I fully rely on the honorable judge in court to apply the correct law and
reach the right conclusions.
tre ae: Cava
YetPROOF OF SERVICE
The undersigned declares as follows:
Iam a citizen of the United States, over 18 years of age, reside in the County of
Marin State of California, and am not a party to the within cause of action. My address is
1977B Union Street Francisco, CA 94123 On 10/13/2015 I served a copy of the
document (s) described as: MOTION RESPONSE
On all interested parties in this action as addressed below in the indicated manner:
‘LAW OFFICE OF STEVEN A. BOOSKO | Case number: CGC 15-544243
]
'
_HDM FUNITURE
PO BOX 2169 :
j
“OAKLAND CA 94621
_X (BY MAIL & FAX) I placed said document(s) in a sealed envelope, with postage
thereon fully prepaid for first class mail, and placed such envelope in the United States
mail at San Francisco, California..
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 this Monday day
of 10/13/2015 San Francisco, CA California.
Michael Mott:
Preview
HEU SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Oct-26-2015 12:10 pm Case Number: CGC-15-544243 Filing Date: Oct-26-2015 12:01 Filed by: CAROL BALISTRERI Juke Box: 001 Image: 05129920 MOTION (CIVIL GENERIC) HDM FURNITURE INDUSTRIES INC VS. VICTORIA L CARD ET AL 001005129920 Instructions: Please place this sheet on top of the document to be scanned.F Name: Victoria L. Card hd ED Address: P.O. Box 502 Petaluma CA 94953 OCT 2 T: 415-710 9296 CLERK 52015 In Pro Per &y. “OF THE Courr SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO a - 7 or LAINTIFF, | Case No.: CGC-15-5444 ZFS IDM FURNITURE INDUTRIES INC. | NOTICE OF MOTION AND MOTION FOR ORDER SETTING ASIDE AND ‘VACATING ORDERS COMPELLING ‘RESPONSES TO INTERROGATORIES vs. ‘AND SANCTIONS THEREON. EFENDANT, Dete :fo. 20,206 | / PY Zoj%s ICTORIA L. CARD He ~G.PF AM To: PLAINTIFF AND ATTORNEY OF RECORD Notice is here given that as soon as thereafter as the matter may be heard in SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO located at 400 McAllister Street room 103, San Francisco, CA 95102 SAN FRANCISCO Judicial District defendant will and hereby does move for an order setting aside and vacating the orders compelling responses to interrogatories and for sanctions thereon against defendant and granting defendant leave to defend the action. The motion will be made on the ground that the service of plaintiff’s notices failed proper service to result in actual notice to defendant. Motion proposed to be filed and served herewith, on the records and file herein, and on such evidence as may be presented at the hearing of the motion. 1, I Victoria L. Card defendant, declare that the Plaintiff has failed to service the notification of any kind to this date.2. The only time I came to notice what was actually going on was when I discovered on the Court’s website around October 8, 20125 as to what was filed. I immediately prepared a motion to postpone the hearing since I was out of time to prepare and submit an answer and to attend the hearing. So, I mailed my response on October 13, 2015 and today October 26, 2015, I find out that the USPS has failed to deliver the certified mail and been held at the San Francisco mail center. I am enclosing my response of October 13, 2015, proof of service and the USPS receipt, which is self-explanatory. [Continue] I declare under penalty of perjury under the laws of the state of California that the foregoing is true and correct. I pray the court reverses the orders and denies the sanctions and schedule a new hearing. Date: 10/26/2015 Vide Cart... [signature] Victoria L. Card Plate for wphiber A and 2PROOF OF SERVICE The undersigned declares as follows: Iam a citizen of the United States, over 18 years of age, reside in the County of Marin State of California, and am not a party to the within cause of action. My address is 1977B Union Street Francisco, CA 94123 On 10/26/2015 I served a copy of the document (s) described as: MOTION RESPONSE On all interested parties in this action as addressed below in the indicated manner: ‘LAW OFFICE OF STEVEN A. BOOSKO | Case number: CGC 15-544243 “HDM FUNITURE PO BOX 2169 “OAKLAND CA 94621 _X (BY MAIL & FAX) I placed said document(s) in a sealed envelope, with postage thereon fully prepaid for first class mail, and placed such envelope in the United States mail at San Francisco, California. 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 this Monday day of 10/26/2015 San Francisco, CA California. Michael Mott: Signature:4g or PETALUMA MPO A 420 4TH ST PETALUNA, CA 94952-9998 10/43/2015 SRS SEE SRSS a Sales Receipt _ Product Sale Unit Final Description Qty Price Price SAN FRANCISCO, CA 94102-4512 $1.42 Zone-1 First-Class Mail® Large Envelope ws USPS Certified Mail™: 9507 1000 1333 5286 0001 64 O Ib. 2.20 oz. * Expected Delivery Day Thursday, October 15. Certified Mail™ $3.45 Issue Postage: $4.87 PETALUMA, CA 94953 $1.20 Zone-0 i rst-Class Mail® Large Envelope O ib. 1.30 oz. ‘* Expected Delivery Day Thursday, October 15. Issue Postage: $1.20 Total: $6.0" Paid by: VISA $6.07 Account #: OOOOKKKXXXO9-43 Approval #: 922253 Transaction #: ‘017 23-902470368 -99 BSK Transaction #: 26 USPS@ # 055958 -9550 € 6% To check onthe delivery status of this article, visit our Track & Confirm website at USPS.com, use this self-service kiosk (or any self-service kiosk at other Postal Jocations) or call 1-800-222-1811. t Thanks. {it's a pleasure to serve you. ALL SALES FINAL ON STAMPS AND POSTAGE. REFUNDS FOR GUARANTEED SERVICES ONLY. Today's Postal Service is hiring! immediateopanings available for ' City Carrier Assistants (CCA) in many jocations nationwide! Apply today at www. usps .com/emptoyment .Name: Victoria L. Card Lah ho Address: P.O. Box 502 Petaluma, CA 94953 In Pro Per Tel: 415-710-9296 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO PLAINTIFF, / i Case No.: CGC - 15 — 544243 _ HDM FURNITURE INDUSTRIES INC, j HERITAGE HOME GROUP LLC. : RESPONSE TO: _ NOTICE OF DEFENDANT’S MOTION FOR i ORDER COMPELLING RESPONSE TO i vs INTERROGATORIES AND FOR SANCT! TONS | i THEREON. | DEFENDANT, Date: October 7, 2015 \ ‘Time: 9.30 am VICTORIA CARD Dept: 302 TO ALL PARTIES AND THEIR COUNSEL OF RECORD: FACTS 1. Plaintiffs Counsel assertions submitted are false. The Plaintiff in question filed bankruptcy back in September 2011/12 therefore, the company dissolved. The Counsel’s attempt is baseless and unfounded and I don’t owe plaintiff a Cent. Furthermore the Counsel operates a collection agency and is not representing the actually a plaintiff. 2. Plaintiff's counsel continuously is diverting the truth, resorting to misleading legal ways to extort monetary relief. In fact, the entire lawsuit is bogus and plaintiff has to date failed to provide a shred of evidence to show proof to justify the lawsuit. 3. Plaintiff has failed to prove ownership of this debt. Therefore, applying CCP2033.280 and pressing for documents or admission and asking the court for sanctions is baseless and has no standing in court. CONCLUSION I pray the court dismiss plaintiff's entire complaint. I pray for cost of suit incurred herein; and For such other further relief as the court may find just and proper. I am 60 year old single women self-employed in the Bay Area for over 35 years. I have to represent myself without a lawyer because I can't afford and justify the expense. I fully rely on the honorable judge in court to apply the correct law and reach the right conclusions. tre ae: Cava YetPROOF OF SERVICE The undersigned declares as follows: Iam a citizen of the United States, over 18 years of age, reside in the County of Marin State of California, and am not a party to the within cause of action. My address is 1977B Union Street Francisco, CA 94123 On 10/13/2015 I served a copy of the document (s) described as: MOTION RESPONSE On all interested parties in this action as addressed below in the indicated manner: ‘LAW OFFICE OF STEVEN A. BOOSKO | Case number: CGC 15-544243 ] ' _HDM FUNITURE PO BOX 2169 : j “OAKLAND CA 94621 _X (BY MAIL & FAX) I placed said document(s) in a sealed envelope, with postage thereon fully prepaid for first class mail, and placed such envelope in the United States mail at San Francisco, California.. 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 this Monday day of 10/13/2015 San Francisco, CA California. Michael Mott: