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SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Jul-20-2018 10:46 am
Case Number: CUD-18-661994
Filing Date: Jul-20-2018 10:44
Filed by: VANESSA WU
Image: 06423907
EX PARTE APPLICATION FOR ORDER
PETER GONG VS. MATTHEW NUDELMAN ET AL
001006423907
Instructions:
Please place this sheet on top of the document to be scanned.© 3°
DAVID J. FORAN, ESQ. (161790)
SACRAMENTO AND FORAN LAW OFFICE, INC.
1489 Webster Street, Suite 248
San Francisco, CA 94115
Telephone: (415) 775-0891
Fax:(415) 775-1350 F
Attorney for: Plaintiff PETER GONG s
I. L of E.
|
County af Gar Srannl
JUL 20.2018
CLERK OF THE COURT
By: l MWe
Deputy Clerk:
SUPERIOR COURT OF THE STATE OF CALIFORNIA
SAN FRANCISCO COUNTY - LIMITED CIVIL JURISDICTION
No. CUD-18-661994
EX PARTE
APPLICATION FOR ENTRY OF
JUDGMENT PURSUANT TO
STIPULATION AND SUPPORTING
DECLARATIONS
PETER GONG,
Plaintiff,
vs.
MATTHEW NUDELMAN and DOES I - X,
Date: July 20, 2018
Time: 11:00 a.m.
Dept: 501
Defendant.
Plaintiff, PETER GONG, by and through his attorney, DAVID FORAN, ESQ, of
SACRAMENTO AND FORAN LAW OFFICE, INC. hereby applies before this Court on July 20,
2018, at 11:00 a.m,, in the Law and Motion Department, Room 501, for entry of Judgment
Pursuant to Stipulation. This application is made pursuant to the terms of the Stipulation for
Entry of Judgment entered into in open Court on June 29, 2018, executed by the parties and filed
with the Court thereafter.
By the terms of the parties Stipulation, defendant agreed that he would pay partial back
rent, daily damages and unpaid water and sewage invoices in the total amount of $7,356.32, in
EXPARTE APPLICATION FOR ENTRY OF JUDGMENT PURSUANT TO STIPULATION 1© 0
installments and also agreed that during the period of the payment plan that for the probationary
period of six months, he would pay his monthly rent of $1,789.08, on or before the 5th of each
month.
Defendant paid the first payment of $7,356.32.
By the terms of the parties Stipulation, defendants agreed that in the event that he failed to
timely make agreed payments the parties authorize this Court to take the following action: Upon 72
hours notice to defendant, plaintiff could seek an exparte application, for Judgment Pursuant to
Stipulation, for possession of the premises from defendant and all occupants in possession, forfeiture of
the lease or rental agreement, and recovery of the remaining sums owed.
Pursuant the terms of the Stipulation Plaintiff now seeks entry of judgment for restitution
of the premises.
Dated: 4 &
DA J. FORAN, ESQ.
SACRAMENTO AND FORAN
LAW OFFICE, INC,
Attorney for Plaintiff
PETER GONG
DECLARATION OF PLAINTIFF'S ATTORNEY IN SUPPORT
OF ENTRY OF JUDGMENT PURSUANT TO STIPULATION
I, DAVID J. FORAN, declare as follows:
1. [am an attorney at law, duly licensed to practice before all the Courts of the State of
California, associated with the SACRAMENTO AND FORAN LAW OFFICE, INC. attorneys
for plaintiff in the above entitled action.
EXPARTE APPLICATION FOR ENTRY OF JUDGMENT PURSUANT TO STIPULATION 2© °
2. This is an unlawful detainer action for nonpayment of rent involving residential
premises. The parties entered into a Stipulation for Entry of Judgment on June 29, 2018 and filed
it with the Court thereafter. A true and exact copy of said Stipulation for Entry of Judgment, is
attached, marked “Exhibit A,” and incorporated by reference herein.
3. By the terms of the parties Stipulation, defendant agreed that he would pay back rent,
daily damages in the total amount of $7,356.32, in installments and also agreed that during the
period of the payment plan that for the probationary period of six months, he would pay his
monthly rent of $1,789.08, on or before the 5th of each month.
4. Defendant failed to make his July 15, 2018 payment of $7,356.32.
5. By the terms of the parties Stipulation, defendant agreed that in the event that he failed
to timely make agreed payments the parties authorize this Court to take the following action: Upon 72
hours notice to defendant, plaintiff could seek an exparte application, for Judgment Pursuant to
Stipulation, for possession of the premises from defendant and all occupants in possession, forfeiture of
the lease or rental agreement, and recovery of the remaining sums owed.
6. On June 18, 2018, at approximately 9:15 a.m., I telephoned the defendant and left a
voice mail on his answering ’s service of plaintiff's intent to submit this exparte application on
July 20, 2018, at 400 McAllister Street, San Francisco, in Department 501. I also sent a
confirming letter by regular mail and email. A true and exact copy of said letter/email is attached,
marked “Exhibit B,” and incorporated by reference herein.
10. Under these circumstances, plaintiff requests that this Court enter judgment against
Defendant MATTHEW NUDELMAN, for restitution of possession of the premises located at
1737 - 9th Avenue, San Francisco, California 94122.
EXPARTE APPLICATION FOR ENTRY OF JUDGMENT PURSUANT TO STIPULATION 3© °o
11. Plaintiff also requests that the judgment include an award of monetary damages
against Defendant MATTHEW NUDELMAN in the amount of $7,356.32as set forth in the
agreement at paragraph 4(1)(a).
12. Plaintiff also requests that the judgment include an award of attorneys fees of $800.00
for three hours preparing this application and $60.00 costs filing fees for this application as agreed
in the parties stipulation at paragraph 4(1)(b) and (c).
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 in the City and County of San
Francisco, State of California.
(€
Dated: |
DAVID J. FORAN, ESQ.
SACRAMENTO AND FORAN
LAW OFFICE, INC.
Attorney for Plaintiff
PETER GONG
EXPARTE APPLICATION FOR ENTRY OF JUDGMENT PURSUANT TO STIPULATION 4© °o
DAVID J. FORAN, ESQ. (161790
SACRAMENTO AND FORAN LAW OFFICE, INC.
1489 Webster Street, Suite 248
San Francisco, CA 94115
Telephone: (415) 775-0891
Fax:(415) 775-1350 Gong
Attorney for: Plaintiff PETER FPS
Se0 Preneeg ht
SUPERIOR COURT OF THE STATE OF CALIFORNIA
SAN FRANCISCO COUNTY - LIMITED CIVIL JURISDICTION
PETER GONG, No. CUD-18-661994
Plaintiff,
SETTLEMENT AGREEMENT AND
STIPULATION FOR CONDITIONAL
ENTRY OF JUDGMENT
vs.
MATTHEW NUDELMAN and DOES I - X,
Defendant
Plaintiff, PETER GONG, by and with its attorney, DAVID J. FORAN, ESQ., of the
FORAN LAW OFFICE, INC. and Defendant MATTHEW
NUDELMAN, with his attorney sherry stipulate for entry of
judgment as follows:
1. Plaintiff is awarded judgment for restitution of possession of the premises located
at 1737 -9th Avenue, #E, San Francisco, CA 94122, (hereinafter “subject premises”) as against
Defendant MATTHEW NUDELMAN.
EXHIBIT A
SETTLEMENT AGREEMENT AND STIPULATION FOR CONDITIONAL ENTRY OF JUDGMENT 1© °
2. The Stipulation for Judgment and Judgment shall be stayed in this matter, and will
not be entered, unless defendant fails to pay to plaintiff the total amount of $7,356.32,
representing the back rent and daily damages from April 1, 2018, through July 31, 2018 in the
amount of $7,156.32, and late fees for April and May 2018 in the amount of $200.00 (hereinafter
“back amount”) as follows:
a. On or before July 15, 2018, defendant will pay plaintiff the amount of
$7,356.32.
Defendant, further agrees that he will pay his monthly rent in the amount of $1,789.08, as said
rent becomes due on the first of every month. For a six month probationary period, commencing
August 1, 2018 and ending January 2019, in the event that defendant fails to timely pay his rent on or
before the Sth of the month, plaintiff may seek an Ex Parte application for Judgment as set forth in
paragraph 4, below.
3. If defendant pays all of the above amounts, plaintiff shall dismiss this unlawful
detainer action against defendant, with prejudice. Furthermore, plaintiff shall then allow
defendant to continue to remain in possession of the subject premises and defendant shall pay rent
on the first day of each and every month thereafter.
4. If defendant fails to timely comply with in every material respect with each and every
term contained in paragraph 2 herein, the parties stipulate and agree, request and authorize this Court
to take the following action:
(1) Upon seventy-two (72) hours notice to seek an exparte application for
Judgment Pursuant to Stipulation, for possession of the premises from defendants and all occupants in
possession, forfeiture of the lease or rental agreement, and recovery of the following sums:
SETTLEMENT AGREEMENT AND STIPULATION FOR CONDITIONAL ENTRY OF JUDGMENT 2© 9
(a) Back rent, and daily damages, in the amount of $7,356.32, less
payments made by or on behalf of defendant;
(b) Costs in the amount of $60.00;
(c) _ Attomey’s fees in the amount of $800.00.
(2) Toissue a Writ of Possession directing the Sheriff of San
Francisco County to take all steps necessary to remove defendants and all occupants in possession
from the premises and restore possession to plaintiff.
6. If judgment is entered, there are no stays of execution of judgment for any reason.
7. Defendant stipulates that there are no other adults in possession of the subject
premises who have any legitimate claim of right to possession of said premises through any co-
tenancy, sub-tenancy or assignment of rights. The undersigned parties represent and warrant that
they are authorized to enter into this Stipulation.
8. Except for enforcement of the Stipulation and any judgment that may be entered
herein, there is a mutual release of all other claims, causes of action, and damages, either known
or unknown, that either party may have against the other. Each party specifically waives any and
all rights and or remedies provided under Civil Code Section 1542 which provides as follows:
"A general release does not extend to claims which a
creditor does not know or suspect to exist in his favor at the time of executing the
release which if known by him must have materially affected his settlement with
the debtor."
9. In the event that judgment is entered, plaintiff shall retain any personal property
remaining the subject premises at the time plaintiff recovers possession. Plaintiff shall not be
obligated to store any of defendants’ personal property items.
SETTLEMENT AGREEMENT AND STIPULATION FOR CONDITIONAL ENTRY OF JUDGMENT 3© °
10. In the event that judgment is entered, defendant forfeits any further interest in the
lease and leasehold.
11. This Stipulation shall bind and inure to the benefit of each party’s heirs, assigns
and successors.
12. Asa material covenant of this Stipulation, defendant agrees to notify plaintiff of
any issues concerning the subject premises prior to reporting plaintiff or the subject premises to
any governmental agency, except for emergency circumstances.
13. Time is of the essence with respect to any act, performance, or payment under this
Stipulation.
14. Nothing in this agreement shall prevent plaintiff from increasing defendant’s monthly
rent in compliance with the San Francisco Rent Ordinance, if applicable.
15. Defendant represents and warrants that defendant has been advised by counsel or
to seek counsel regarding the terms and conditions of the Stipulation for Judgment, and enters
into said Stipulation freely and voluntarily.
16. The acceptance of rent by plaintiff shall not constitute a waiver of plaintiff s rights
to enforce the terms of this Stipulation, or to serve any other eviction notice against defendant.
nN G
vue B ICAP A
MATTHEW NUDELMAN
Defendant
ou [28 ]
PETER GONG
Plaintiff
SETTLEMENT AGREEMENT AND STIPULATION FOR CONDITIONAL ENTRY OF JUDGMENT 4© LAW OFFICES OF Q
SACRAMENTO AND FORAN, INC.
1489 WEBSTER ST., SUITE 248
SAN FRANCISCO, CA 94115
BUS: (415)
Of eounsel THOMAS E. FORAN June 18, 2018 FAX: ais Hess)
Matthew Nudelman via email: matthewinudelman@gmail.com
1737 9th Ave, #E (Original mailed)
San Francisco, CA 94122
Re: Gong v Nudelman CUD-18-661994
Dear Mr. Nudelman:
This letter/email will confirm the the voice mail I left on your answering service at
approximately 9:15 a.m., this morning and will confirm that your seventy-two hour notice
that myself, or an associate from our office, will appear Exparte for an Order to proceed
with enforcement of the Judgment Pursuant to Stipulation in the above named case,
because you failed to make your settlement payment on July 15, 2018 of $7,156.32,
pursuant to the Settlement Agreement.
The above matter will be heard at 11:00 a.m., Friday, July 20, 2018 at 400
McAllister Street, San Francisco, CA, in Department 501.
Thank you very much.
Yours truly,
wid J. Foran, Esq.
SACRAMENTO AND FORAN
LAW OFFICE, INC.
EXHIBIT B
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SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Jul-20-2018 10:46 am Case Number: CUD-18-661994 Filing Date: Jul-20-2018 10:44 Filed by: VANESSA WU Image: 06423907 EX PARTE APPLICATION FOR ORDER PETER GONG VS. MATTHEW NUDELMAN ET AL 001006423907 Instructions: Please place this sheet on top of the document to be scanned.© 3° DAVID J. FORAN, ESQ. (161790) SACRAMENTO AND FORAN LAW OFFICE, INC. 1489 Webster Street, Suite 248 San Francisco, CA 94115 Telephone: (415) 775-0891 Fax:(415) 775-1350 F Attorney for: Plaintiff PETER GONG s I. L of E. | County af Gar Srannl JUL 20.2018 CLERK OF THE COURT By: l MWe Deputy Clerk: SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN FRANCISCO COUNTY - LIMITED CIVIL JURISDICTION No. CUD-18-661994 EX PARTE APPLICATION FOR ENTRY OF JUDGMENT PURSUANT TO STIPULATION AND SUPPORTING DECLARATIONS PETER GONG, Plaintiff, vs. MATTHEW NUDELMAN and DOES I - X, Date: July 20, 2018 Time: 11:00 a.m. Dept: 501 Defendant. Plaintiff, PETER GONG, by and through his attorney, DAVID FORAN, ESQ, of SACRAMENTO AND FORAN LAW OFFICE, INC. hereby applies before this Court on July 20, 2018, at 11:00 a.m,, in the Law and Motion Department, Room 501, for entry of Judgment Pursuant to Stipulation. This application is made pursuant to the terms of the Stipulation for Entry of Judgment entered into in open Court on June 29, 2018, executed by the parties and filed with the Court thereafter. By the terms of the parties Stipulation, defendant agreed that he would pay partial back rent, daily damages and unpaid water and sewage invoices in the total amount of $7,356.32, in EXPARTE APPLICATION FOR ENTRY OF JUDGMENT PURSUANT TO STIPULATION 1© 0 installments and also agreed that during the period of the payment plan that for the probationary period of six months, he would pay his monthly rent of $1,789.08, on or before the 5th of each month. Defendant paid the first payment of $7,356.32. By the terms of the parties Stipulation, defendants agreed that in the event that he failed to timely make agreed payments the parties authorize this Court to take the following action: Upon 72 hours notice to defendant, plaintiff could seek an exparte application, for Judgment Pursuant to Stipulation, for possession of the premises from defendant and all occupants in possession, forfeiture of the lease or rental agreement, and recovery of the remaining sums owed. Pursuant the terms of the Stipulation Plaintiff now seeks entry of judgment for restitution of the premises. Dated: 4 & DA J. FORAN, ESQ. SACRAMENTO AND FORAN LAW OFFICE, INC, Attorney for Plaintiff PETER GONG DECLARATION OF PLAINTIFF'S ATTORNEY IN SUPPORT OF ENTRY OF JUDGMENT PURSUANT TO STIPULATION I, DAVID J. FORAN, declare as follows: 1. [am an attorney at law, duly licensed to practice before all the Courts of the State of California, associated with the SACRAMENTO AND FORAN LAW OFFICE, INC. attorneys for plaintiff in the above entitled action. EXPARTE APPLICATION FOR ENTRY OF JUDGMENT PURSUANT TO STIPULATION 2© ° 2. This is an unlawful detainer action for nonpayment of rent involving residential premises. The parties entered into a Stipulation for Entry of Judgment on June 29, 2018 and filed it with the Court thereafter. A true and exact copy of said Stipulation for Entry of Judgment, is attached, marked “Exhibit A,” and incorporated by reference herein. 3. By the terms of the parties Stipulation, defendant agreed that he would pay back rent, daily damages in the total amount of $7,356.32, in installments and also agreed that during the period of the payment plan that for the probationary period of six months, he would pay his monthly rent of $1,789.08, on or before the 5th of each month. 4. Defendant failed to make his July 15, 2018 payment of $7,356.32. 5. By the terms of the parties Stipulation, defendant agreed that in the event that he failed to timely make agreed payments the parties authorize this Court to take the following action: Upon 72 hours notice to defendant, plaintiff could seek an exparte application, for Judgment Pursuant to Stipulation, for possession of the premises from defendant and all occupants in possession, forfeiture of the lease or rental agreement, and recovery of the remaining sums owed. 6. On June 18, 2018, at approximately 9:15 a.m., I telephoned the defendant and left a voice mail on his answering ’s service of plaintiff's intent to submit this exparte application on July 20, 2018, at 400 McAllister Street, San Francisco, in Department 501. I also sent a confirming letter by regular mail and email. A true and exact copy of said letter/email is attached, marked “Exhibit B,” and incorporated by reference herein. 10. Under these circumstances, plaintiff requests that this Court enter judgment against Defendant MATTHEW NUDELMAN, for restitution of possession of the premises located at 1737 - 9th Avenue, San Francisco, California 94122. EXPARTE APPLICATION FOR ENTRY OF JUDGMENT PURSUANT TO STIPULATION 3© °o 11. Plaintiff also requests that the judgment include an award of monetary damages against Defendant MATTHEW NUDELMAN in the amount of $7,356.32as set forth in the agreement at paragraph 4(1)(a). 12. Plaintiff also requests that the judgment include an award of attorneys fees of $800.00 for three hours preparing this application and $60.00 costs filing fees for this application as agreed in the parties stipulation at paragraph 4(1)(b) and (c). 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 in the City and County of San Francisco, State of California. (€ Dated: | DAVID J. FORAN, ESQ. SACRAMENTO AND FORAN LAW OFFICE, INC. Attorney for Plaintiff PETER GONG EXPARTE APPLICATION FOR ENTRY OF JUDGMENT PURSUANT TO STIPULATION 4© °o DAVID J. FORAN, ESQ. (161790 SACRAMENTO AND FORAN LAW OFFICE, INC. 1489 Webster Street, Suite 248 San Francisco, CA 94115 Telephone: (415) 775-0891 Fax:(415) 775-1350 Gong Attorney for: Plaintiff PETER FPS Se0 Preneeg ht SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN FRANCISCO COUNTY - LIMITED CIVIL JURISDICTION PETER GONG, No. CUD-18-661994 Plaintiff, SETTLEMENT AGREEMENT AND STIPULATION FOR CONDITIONAL ENTRY OF JUDGMENT vs. MATTHEW NUDELMAN and DOES I - X, Defendant Plaintiff, PETER GONG, by and with its attorney, DAVID J. FORAN, ESQ., of the FORAN LAW OFFICE, INC. and Defendant MATTHEW NUDELMAN, with his attorney sherry stipulate for entry of judgment as follows: 1. Plaintiff is awarded judgment for restitution of possession of the premises located at 1737 -9th Avenue, #E, San Francisco, CA 94122, (hereinafter “subject premises”) as against Defendant MATTHEW NUDELMAN. EXHIBIT A SETTLEMENT AGREEMENT AND STIPULATION FOR CONDITIONAL ENTRY OF JUDGMENT 1© ° 2. The Stipulation for Judgment and Judgment shall be stayed in this matter, and will not be entered, unless defendant fails to pay to plaintiff the total amount of $7,356.32, representing the back rent and daily damages from April 1, 2018, through July 31, 2018 in the amount of $7,156.32, and late fees for April and May 2018 in the amount of $200.00 (hereinafter “back amount”) as follows: a. On or before July 15, 2018, defendant will pay plaintiff the amount of $7,356.32. Defendant, further agrees that he will pay his monthly rent in the amount of $1,789.08, as said rent becomes due on the first of every month. For a six month probationary period, commencing August 1, 2018 and ending January 2019, in the event that defendant fails to timely pay his rent on or before the Sth of the month, plaintiff may seek an Ex Parte application for Judgment as set forth in paragraph 4, below. 3. If defendant pays all of the above amounts, plaintiff shall dismiss this unlawful detainer action against defendant, with prejudice. Furthermore, plaintiff shall then allow defendant to continue to remain in possession of the subject premises and defendant shall pay rent on the first day of each and every month thereafter. 4. If defendant fails to timely comply with in every material respect with each and every term contained in paragraph 2 herein, the parties stipulate and agree, request and authorize this Court to take the following action: (1) Upon seventy-two (72) hours notice to seek an exparte application for Judgment Pursuant to Stipulation, for possession of the premises from defendants and all occupants in possession, forfeiture of the lease or rental agreement, and recovery of the following sums: SETTLEMENT AGREEMENT AND STIPULATION FOR CONDITIONAL ENTRY OF JUDGMENT 2© 9 (a) Back rent, and daily damages, in the amount of $7,356.32, less payments made by or on behalf of defendant; (b) Costs in the amount of $60.00; (c) _ Attomey’s fees in the amount of $800.00. (2) Toissue a Writ of Possession directing the Sheriff of San Francisco County to take all steps necessary to remove defendants and all occupants in possession from the premises and restore possession to plaintiff. 6. If judgment is entered, there are no stays of execution of judgment for any reason. 7. Defendant stipulates that there are no other adults in possession of the subject premises who have any legitimate claim of right to possession of said premises through any co- tenancy, sub-tenancy or assignment of rights. The undersigned parties represent and warrant that they are authorized to enter into this Stipulation. 8. Except for enforcement of the Stipulation and any judgment that may be entered herein, there is a mutual release of all other claims, causes of action, and damages, either known or unknown, that either party may have against the other. Each party specifically waives any and all rights and or remedies provided under Civil Code Section 1542 which provides as follows: "A general release does not extend to claims which a creditor does not know or suspect to exist in his favor at the time of executing the release which if known by him must have materially affected his settlement with the debtor." 9. In the event that judgment is entered, plaintiff shall retain any personal property remaining the subject premises at the time plaintiff recovers possession. Plaintiff shall not be obligated to store any of defendants’ personal property items. SETTLEMENT AGREEMENT AND STIPULATION FOR CONDITIONAL ENTRY OF JUDGMENT 3© ° 10. In the event that judgment is entered, defendant forfeits any further interest in the lease and leasehold. 11. This Stipulation shall bind and inure to the benefit of each party’s heirs, assigns and successors. 12. Asa material covenant of this Stipulation, defendant agrees to notify plaintiff of any issues concerning the subject premises prior to reporting plaintiff or the subject premises to any governmental agency, except for emergency circumstances. 13. Time is of the essence with respect to any act, performance, or payment under this Stipulation. 14. Nothing in this agreement shall prevent plaintiff from increasing defendant’s monthly rent in compliance with the San Francisco Rent Ordinance, if applicable. 15. Defendant represents and warrants that defendant has been advised by counsel or to seek counsel regarding the terms and conditions of the Stipulation for Judgment, and enters into said Stipulation freely and voluntarily. 16. The acceptance of rent by plaintiff shall not constitute a waiver of plaintiff s rights to enforce the terms of this Stipulation, or to serve any other eviction notice against defendant. nN G vue B ICAP A MATTHEW NUDELMAN Defendant ou [28 ] PETER GONG Plaintiff SETTLEMENT AGREEMENT AND STIPULATION FOR CONDITIONAL ENTRY OF JUDGMENT 4© LAW OFFICES OF Q SACRAMENTO AND FORAN, INC. 1489 WEBSTER ST., SUITE 248 SAN FRANCISCO, CA 94115 BUS: (415) Of eounsel THOMAS E. FORAN June 18, 2018 FAX: ais Hess) Matthew Nudelman via email: matthewinudelman@gmail.com 1737 9th Ave, #E (Original mailed) San Francisco, CA 94122 Re: Gong v Nudelman CUD-18-661994 Dear Mr. Nudelman: This letter/email will confirm the the voice mail I left on your answering service at approximately 9:15 a.m., this morning and will confirm that your seventy-two hour notice that myself, or an associate from our office, will appear Exparte for an Order to proceed with enforcement of the Judgment Pursuant to Stipulation in the above named case, because you failed to make your settlement payment on July 15, 2018 of $7,156.32, pursuant to the Settlement Agreement. The above matter will be heard at 11:00 a.m., Friday, July 20, 2018 at 400 McAllister Street, San Francisco, CA, in Department 501. Thank you very much. Yours truly, wid J. Foran, Esq. SACRAMENTO AND FORAN LAW OFFICE, INC. EXHIBIT B