On September 08, 2010 a
Request,Application
was filed
involving a dispute between
Commonwealth Land Title Insurance Company,
Hwang, Shirley S.,
Fedex Office And Print Services, Inc,
Lum, Winston,
Merchants Bonding Company,
and
Aeschbacher, Bruno,
Afraimi, Morad,
Does 1-25,
Does 1-50,
Emerich, Melvin Lee,
Fedex Office And Print Services, Inc,
Fellmann, Stephen,
Languban, Grachelle,
Lum, Winston,
Lum,, Winston,
Martini & Chnoogle,
Martini & Chnoogle, Inc.,
Megan & Kasi Properties Llc,
Merchants Bonding Company,
M & K Properties, Llc,
Niroula, Kaushal,
Palomino, Elvia,
Replogle, David P.O. Box,
Shah, Jay Chandrakant Ap3101 California Medical Faci Vacaville, Ca 95696,
Hwang, Shirley S.,
for civil
in the District Court of San Francisco County.
Preview
GLYNN & FINLEY, LLP
CLEMENT L. GLYNN, Bar No. 57117
MORGAN K. LOPEZ, Bar No. 215513
One Walnut Creek Center
100 Pringle Avenue, Suite 500 FEES TRONICALEY
Walnut Creek, CA 94596 FILED
Telephone: (925) 210-2800 Superior Court of California,
Facsimile: (925) 945-1975 Ceuiay ofan anetece
11/29/2018
Attorneys for Cross-Defendant/Plaintiff CE oun
Shirley Hwang Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
Lead Case No. CGC-10-503332
(Consolidated for all purposes with
CGC-11-512102)
COMMONWEALTH LAND TITLE
INSURANCE COMPANY,
Plaintiff,
PLAINTIFF SHIRLEY S. HWANG’S
REQUEST FOR ENTRY OF
JUDGMENT
vs.
FEDEX OFFICE AND PRINT SERVICES
INC.; WINSTON LUM; KAUSHAL
NIROULA; JAY CHANDRAKANT
SHAH; ELVIA PALOMINO; MORAD
AFRAIMI; MELVIN LEE EMERICH;
MARTINI CHNOOGLE; GRACHELLE
LANGUBAN; MERCHANTS BONDING
COMPANY, and DOES 1-24,
Original Trial Date: August 7, 2017
Defendants.
CASE NO. CGC-11-512102
SHIRLEY S. HWANG,
Plaintiff,
vs.
FEDEX OFFICE AND PRINT SERVICES
INC., WINSTON LUM, KAUSHAL
NIROULA, JAY CHANDRAKANT SHAH,
MELVIN LEE EMERICH, GRACHELLE
LANGUBAN, and MARTINI &
CHNOOGLE, and DOES 1-50,
Cross-Defendants.
Eee
PLTFF S. HWANG’S REQUEST FOR ENTRY OF JUDGMENTThe Court served all counsel with its Tentative Statement of Decision on April 17, 2018,
its Proposed Statement of Decision on July 6, 2018, and its Statement of Decision on September
18, 2018. A written judgment is required to be entered within 50 days of service of the tentative
decision pursuant to Rule of Court 3.1590(1). Additionally, Code of Civil Procedure section 664
requires that “[i]f the trial has been had by the court, judgment must be entered by the clerk, in
conformity to the decision of the court, immediately upon the filing of such decision.”
In its Statement of Decision, the Court ordered that the parties “submit briefing regarding
the setoff required for the calculation of the final judgment within 10 court days of notice and
receipt of this statement.” Final briefing on this issue was filed October 11, 2018. As ordered by
the Court, Plaintiff also submitted a Proposed Judgment on October 9, 2018. Because all
outstanding issues have been addressed and the applicable procedural deadlines satisfied,
Plaintiff respectfully requests that the Court enter a final judgment in this matter forthwith.
Dated: November 29, 2018 GLYNN & FINLEY, LLP
CLEMENT L. GLYNN
MORGAN K. LOPEZ
One Walnut Creek Center
100 Pringle Avenue, Suite 500
Walnut Creek, CA 94596
By Poe OS
Al or Plaintiff
Shirley S™Hwang
-1-
PLTFF S. HWANG’S REQUEST FOR ENTRY OF JUDGMENTLead Case No. CGC-10-503332
(consolidated for all purposes with CGC-11-512102)
PROOF OF SERVICE BY U.S. MAIL
I, Gina M. Bentley, the undersigned, hereby certify and declare under penalty of
perjury that the following statements are true and correct:
1. Tam over the age of 18 years and am not a party to the within cause.
2. My business address is One Walnut Creek Center, 100 Pringle Avenue,
Suite 500, Walnut Creek, CA 94596.
3. I am familiar with my employer’s mail collection and processing practices;
know that said mail is collected and deposited with the United States Postal Service on the same
day it is deposited in interoffice mail; and know that postage thereon is fully prepaid.
4. Following said practice, on November 29, 2018 I served a true and correct
copy of the attached document entitled exactly:
PLAINTIFF SHIRLEY S. HWANG’S REQUEST FOR ENTRY OF JUDGMENT
by placing it in an addressed, sealed envelope and depositing it in regularly maintained
interoffice mail to the following:
Craig Jay Bassett Yauheni V, Halavanau
Attorney at Law Law Offices of Gene Halavanau
25 W. First Street 55 Francisco Street, Suite 403
Morgan Hill, CA 95037 San Francisco, CA 94133-2115
T: 408-779-0007; F: 408-778-6005 T: 415-692-5301; F: 415-692-8412
Email: cbassett@garlic.com Email: gene@halavanau.com
Attorney for Defendants Elvia Palomino and Association of Counsel for Defendant
Jay Chandrakant Shah Jay Chandrakant Shah
Executed this 29th day of November4018 at Walnut Creek, California.
”Gina M. Bentley ]
-1-
PROOF OF SERVICE
Preview
GLYNN & FINLEY, LLP CLEMENT L. GLYNN, Bar No. 57117 MORGAN K. LOPEZ, Bar No. 215513 One Walnut Creek Center 100 Pringle Avenue, Suite 500 FEES TRONICALEY Walnut Creek, CA 94596 FILED Telephone: (925) 210-2800 Superior Court of California, Facsimile: (925) 945-1975 Ceuiay ofan anetece 11/29/2018 Attorneys for Cross-Defendant/Plaintiff CE oun Shirley Hwang Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO Lead Case No. CGC-10-503332 (Consolidated for all purposes with CGC-11-512102) COMMONWEALTH LAND TITLE INSURANCE COMPANY, Plaintiff, PLAINTIFF SHIRLEY S. HWANG’S REQUEST FOR ENTRY OF JUDGMENT vs. FEDEX OFFICE AND PRINT SERVICES INC.; WINSTON LUM; KAUSHAL NIROULA; JAY CHANDRAKANT SHAH; ELVIA PALOMINO; MORAD AFRAIMI; MELVIN LEE EMERICH; MARTINI CHNOOGLE; GRACHELLE LANGUBAN; MERCHANTS BONDING COMPANY, and DOES 1-24, Original Trial Date: August 7, 2017 Defendants. CASE NO. CGC-11-512102 SHIRLEY S. HWANG, Plaintiff, vs. FEDEX OFFICE AND PRINT SERVICES INC., WINSTON LUM, KAUSHAL NIROULA, JAY CHANDRAKANT SHAH, MELVIN LEE EMERICH, GRACHELLE LANGUBAN, and MARTINI & CHNOOGLE, and DOES 1-50, Cross-Defendants. Eee PLTFF S. HWANG’S REQUEST FOR ENTRY OF JUDGMENTThe Court served all counsel with its Tentative Statement of Decision on April 17, 2018, its Proposed Statement of Decision on July 6, 2018, and its Statement of Decision on September 18, 2018. A written judgment is required to be entered within 50 days of service of the tentative decision pursuant to Rule of Court 3.1590(1). Additionally, Code of Civil Procedure section 664 requires that “[i]f the trial has been had by the court, judgment must be entered by the clerk, in conformity to the decision of the court, immediately upon the filing of such decision.” In its Statement of Decision, the Court ordered that the parties “submit briefing regarding the setoff required for the calculation of the final judgment within 10 court days of notice and receipt of this statement.” Final briefing on this issue was filed October 11, 2018. As ordered by the Court, Plaintiff also submitted a Proposed Judgment on October 9, 2018. Because all outstanding issues have been addressed and the applicable procedural deadlines satisfied, Plaintiff respectfully requests that the Court enter a final judgment in this matter forthwith. Dated: November 29, 2018 GLYNN & FINLEY, LLP CLEMENT L. GLYNN MORGAN K. LOPEZ One Walnut Creek Center 100 Pringle Avenue, Suite 500 Walnut Creek, CA 94596 By Poe OS Al or Plaintiff Shirley S™Hwang -1- PLTFF S. HWANG’S REQUEST FOR ENTRY OF JUDGMENTLead Case No. CGC-10-503332 (consolidated for all purposes with CGC-11-512102) PROOF OF SERVICE BY U.S. MAIL I, Gina M. Bentley, the undersigned, hereby certify and declare under penalty of perjury that the following statements are true and correct: 1. Tam over the age of 18 years and am not a party to the within cause. 2. My business address is One Walnut Creek Center, 100 Pringle Avenue, Suite 500, Walnut Creek, CA 94596. 3. I am familiar with my employer’s mail collection and processing practices; know that said mail is collected and deposited with the United States Postal Service on the same day it is deposited in interoffice mail; and know that postage thereon is fully prepaid. 4. Following said practice, on November 29, 2018 I served a true and correct copy of the attached document entitled exactly: PLAINTIFF SHIRLEY S. HWANG’S REQUEST FOR ENTRY OF JUDGMENT by placing it in an addressed, sealed envelope and depositing it in regularly maintained interoffice mail to the following: Craig Jay Bassett Yauheni V, Halavanau Attorney at Law Law Offices of Gene Halavanau 25 W. First Street 55 Francisco Street, Suite 403 Morgan Hill, CA 95037 San Francisco, CA 94133-2115 T: 408-779-0007; F: 408-778-6005 T: 415-692-5301; F: 415-692-8412 Email: cbassett@garlic.com Email: gene@halavanau.com Attorney for Defendants Elvia Palomino and Association of Counsel for Defendant Jay Chandrakant Shah Jay Chandrakant Shah Executed this 29th day of November4018 at Walnut Creek, California. ”Gina M. Bentley ] -1- PROOF OF SERVICE