Motion-Secondary: FINANCIAL PACIFIC LEASING, INC., A WASHINGTON CORPORATION VS RAMCO DEMOLITION, INC., A CALIFORNIA CORPORATION, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 01/20/2023 07:06 PM David W. Slayton, Executive Officer/Clerk of Court, by E. Armenta,Deputy Clerk




                                                                NICK I. IEZZA, SBN 128570
                                                            1   SPIWAK & IEZZA, LLP
                                                                555 Marin Street, Suite 140
                                                            2   Thousand Oaks, CA 91360
                                                                Tel: (805) 777-1175
                                                            3   Fax: (805) 777-1168
                                                            4   Refer to File No. 314.1173

                                                            5   Attorneys for Plaintiff
                                                            6
                                                                                             SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                                            7
                                                                                                      FOR THE COUNTY OF LOS ANGELES
                                                            8

                                                            9         FINANCIAL PACIFIC LEASING, INC., a                   CASE NO.: 22NWCV01712
                                                                      Washington corporation,
                                                           10                                                              [Limited Jurisdiction]
                                                                                        Plaintiff
                                                           11                                                              (Prayer Amount - $70,446.83)
                                                                      vs.
    555 Marin Street, Suite 140, Thousand Oaks, CA 91360




                                                           12                                                              MEMORANDUM OF POINTS AND
                                                                                                                           AUTHORITIES IN SUPPORT OF
                                                           13         RAMCO DEMOLITION, INC., a California                 APPLICATIONS FOR WRIT OF
                        (805) 777-1175




                                                                      corporation; GERARDO RAMIREZ, an                     ATTACHMENT AND WRIT OF
                                                           14         individual; and DOES 1-10, inclusive,                POSSESSION
                                                           15                           Defendants.
                                                                                                                           DATE:    July 18, 2023
                                                           16                                                              TIME:    9:30 a.m.
                                                                                                                           DEPT:    C
                                                           17                                                              RES #:  201559734051; 723189666822;
                                                                                                                           194000663334
                                                           18

                                                           19

                                                           20                                                         I.
                                                           21                                                     FACTS
                                                           22               This matter involves a breach of an Equipment Finance Agreement and Guaranty by Defendants,
                                                           23   and each of them. Defendants, and each of them, have failed to make payments due on the Agreement
                                                           24   and are presently indebted to Plaintiff in the sum of $70,446.83. The obligation is commercial in nature
                                                           25   and Plaintiff’s equipment which has an estimated fair market value of $52,000.00 secures the total amount
                                                           26   owed and Plaintiff is without any other collateral to protect itself from the loss it has suffered.
                                                           27   ///
                                                           28
314.1188                                                                                                             -1-
                                                                       MEMO OF POINTS AND AUTHORITIES IN SUPPORT OF APPLICATIONS FOR WRITS OF ATTACHMENT AND POSSESSION