On April 02, 2010 a
Motion,Ex Parte
was filed
involving a dispute between
Capital One Bank,
and
Bako, Agnes E,
in the District Court of Contra Costa County.
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GEORGE APOSHIAN, ESQ., Bar #303238
LAURA M. D’ANNA, ESQ., Bar #266113 J
PATENAUDE & FELIX, A.P.C.
6800 Owensmouth Avenue, Suite 290
Canoga Park, CA 91303-4216
(818) 784-3366
Attorneys for Plaintiff
IN THE SUPERIOR COURT OF CALIFORNIA
COUNTY OF CONTRA COSTA, MARTINEZ JUDICIAL DISTRICT
CAPITAL ONE BANK (USA), N.A. , CASE NO. L10-03712
. Plaintiff, ~- + NOTICE OF MOTION AND MOTION TO
SET ASIDE AND VACATE DEFAULT
AND DEFAULT JUDGMENT;
MEMORANDUM OF POINTS AND
AUTHORITIES; DECLARATION;
PROPOSED ORDER
vs.
AGNES E BAKO ,
DATE:
TIME:
Defendants. DEPT:
SUBMITTED WITHOUT APPEARANCE
PURSUANT TO CRC 3.1304 (c)
TO: DEFENDANT, AGNES E BAKO, IN PRO PER:
NOTICE IS HEREBY GIVEN that on , at , or as soon thereafter as
the matter may be heard in Department/Division , of the above-entitled
court located at 725 Court St., Rm. 103, Martinez, CA, 94553,
Plaintiff, will move the Court to vacate and. set aside the Judgment
1
NOTICE OF MOTION AND MOTION TO SET ASIDE AND VACATE
DEFAULT AND DEFAULT JUDGMENT
MVF/16-13896 -0/0102-99entered by the Court on 6/14/11 and renewed on 1/04/21. The motion
will be made on the grounds that the Judgment entered against the
Defendant was the result of the reasonable mistake, inadvertence,
surprise and neglect of plaintiff attorneys, PATENAUDE & FELIX,
A.P.C..
This motion will be based on this notice of motion, the
accompanying Declaration of Laura M. D’Anna, the Complaint already on
file herein, the Memorandum of Points and Authorities served and filed
herewith, on the records and files herein, and on such evidence as may
be presented at the hearing of the motion.
DATED: April 5 1 2022 PATENAUDE & FHLIX, A.P.C.
By:
LAURA M. D‘ANNA
Attorneys for Plaintiff
2
NOTICE OF MOTION AND MOTION TO SET ASIDE AND VACATE
DEFAULT AND DEFAULT JUDGMENT
MVF/16- 13896 -0/0102-99
Document Filed Date
April 11, 2022
Case Filing Date
April 02, 2010
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27 28 GEORGE APOSHIAN, ESQ., Bar #303238 LAURA M. D’ANNA, ESQ., Bar #266113 J PATENAUDE & FELIX, A.P.C. 6800 Owensmouth Avenue, Suite 290 Canoga Park, CA 91303-4216 (818) 784-3366 Attorneys for Plaintiff IN THE SUPERIOR COURT OF CALIFORNIA COUNTY OF CONTRA COSTA, MARTINEZ JUDICIAL DISTRICT CAPITAL ONE BANK (USA), N.A. , CASE NO. L10-03712 . Plaintiff, ~- + NOTICE OF MOTION AND MOTION TO SET ASIDE AND VACATE DEFAULT AND DEFAULT JUDGMENT; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION; PROPOSED ORDER vs. AGNES E BAKO , DATE: TIME: Defendants. DEPT: SUBMITTED WITHOUT APPEARANCE PURSUANT TO CRC 3.1304 (c) TO: DEFENDANT, AGNES E BAKO, IN PRO PER: NOTICE IS HEREBY GIVEN that on , at , or as soon thereafter as the matter may be heard in Department/Division , of the above-entitled court located at 725 Court St., Rm. 103, Martinez, CA, 94553, Plaintiff, will move the Court to vacate and. set aside the Judgment 1 NOTICE OF MOTION AND MOTION TO SET ASIDE AND VACATE DEFAULT AND DEFAULT JUDGMENT MVF/16-13896 -0/0102-99entered by the Court on 6/14/11 and renewed on 1/04/21. The motion will be made on the grounds that the Judgment entered against the Defendant was the result of the reasonable mistake, inadvertence, surprise and neglect of plaintiff attorneys, PATENAUDE & FELIX, A.P.C.. This motion will be based on this notice of motion, the accompanying Declaration of Laura M. D’Anna, the Complaint already on file herein, the Memorandum of Points and Authorities served and filed herewith, on the records and files herein, and on such evidence as may be presented at the hearing of the motion. DATED: April 5 1 2022 PATENAUDE & FHLIX, A.P.C. By: LAURA M. D‘ANNA Attorneys for Plaintiff 2 NOTICE OF MOTION AND MOTION TO SET ASIDE AND VACATE DEFAULT AND DEFAULT JUDGMENT MVF/16- 13896 -0/0102-99