Satisfaction of Judgment: JOHNA PECOT et al VS. SAN FRANCISCO DEPUTY SHERIFF'S ASSOCIATION, A et al

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                                LAW OFFICES OF PAUL L. KRANZ,
PAUL L. KRANZ, ESQ., SBN 114999
499 14" Street, Suite 300

Oakland, CA 94612
kranzlaw@sbcglobal.net

(510) 839-1200
(510) 444-6698

Telephone:
Facsimile:

Attorneys for Plaintiffs Johna Pecot, ef ai.

ELECTRONICALLY

FILED

Superior Court of California,
County of San Francisco

05/26/2015
Clerk of the Court
BY:ROMY RISK

Deputy Clerk

SUPERIOR COURT FOR THE STATE OF CALIFORNIA

COUNTY OF SAN FRANCISCO
JOHNA PECOT, et al. ) CASE NO. CGC-10-501168
)
Plaintiffs, ) NOTICE OF MOTION FOR ORDER
) COMPELLING ACKNOWLEDGMENT
v. ) OF SATISFACTION OF JUDGMENT
)  SATISFEED IN FACT OR ENTERING
SAN FRANCISCO DEPUTY SHERIFF’S )} SATISFACTION WITHOUT
ASSOCIATION, a California Nonprofit ) ACKNOWLEDGMENT; FOR ORDER
Corporation, ef al. ) AWARDING FORFEITURE OF
) PENALTY, AND ATTORNEY'S FEES
Defendants. ) FOR UNJUST REFUSAL TO EXECUTE
) ACKNOWLEDGMENT OF
) SATISFACTION OF JUDGMENT

[Code Civ. Proc. § 724.010 et seq.), 724.080]

Date: June 17, 2015
Time: 9:30 am.
Dept.; 302

To Defendant Wong and his attorney of record, Lawrence D. Murray:

NOTICE IS HEREBY GIVEN that on June 17, 2015, at 9:30 a.m., or as soon thereafter

as the matter may be heard, in Department 302 of this court, located at 400 McAllister Street,

San Francisco, California, plaintiffs will and hereby do move, for either an order compelling

David Wong, Defendant, and/or his attorney of record; Lawrence D. Murray, to comply with

plaintiffs’ demand to acknowledge satisfaction of judgment herein or for an order that the clerk

enter satisfaction of judgment.

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~~ NOTICE OF MOTION FOR ORDER FOR SATISFACTION OF JUDGMENTBw

Cm In A

The motion will be made on the grounds that a judgment based on an October 9, 2013
order for attorneys’ fees has been satisfied in full by plaintiffs paying the full amount due under
the judgment and that Defendant David Wong and/or his attorney Lawrence D. Murray has failed
without just cause to comply with the demand for acknowledgment of satisfaction.

Plaintiffs will also move this Court under Code Civ. Proc. $§ 724.050(e) and 724.080,
and other relevant statutes for a mandatory award of their attorneys’ fees, as provided because of
defendant’s and his attorney’s unjust refusal to execute an acknowledgment of satisfaction of
judgment.

The motion will be based on this notice of motion, on the declaration of Paul L. Kranz,
and the memorandum served and filed herewith, on papers and records on file herein, and on
such oral and documentary evidence as may be presented at the hearing of the motion.

Dated: May 22, 2015

Respectfully submitted,

By: Yaw = ko

Paul L. Kranz

194

NOTICE OF MOTION FOR ORDER FOR SATISFACTION OF JUDGMENT