Motion,Ex Parte: Jason Neel vs United States Real Estate Corporation, et al

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                                1   Cody Molica
     1029 North Road, #175
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     Westfield, MA 01085
 3   (619) 693-7896
     cmolica11@gmail.com
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     Cross-Defendant in Pro Per
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 7                                SUPERIOR COURT OF CALIFORNIA
 8                                   COUNTY OF SANTA CRUZ
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     JASON NEEL                                   Case No.: 22CV01758
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                   Plaintiff,
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     vs.                                          DEFENDANT CODY MOLICA’S NOTICE
12                                                OF MOTION AND MOTION TO QUASH
     SUPERIOR LOAN SERVICING; ASSET               SERVICE OF SUMMONS, DECLARATION
13                                                MEMORANDUM OF POINTS AND
     DEFAULT MANAGEMENT, INC., UNITED
14                                                AUTHORITIES IN SUPPORT (CCP § 418.10
     STATES REAL ESTATE CORPORATION;              (A)
15   CNA EQUITIES GROUP, LLC; AND
     RUSHMYFILE, BUSINESS ENTITY FORM             DEPT. 5
16   UNKNOWN, and VIGIL REAL ESTATE,              ACTION FILED 08/16/2022
17   BUSINESS ENTITY FORM UNKNOWN and             HON. TIMOTHY VOLKMANN
     DOES 1-50, inclusive, Defendants.
18                                                HEARING: 5/25/23
                                                  TIME: 9AM
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     UNITED STATES REAL ESTATE                    UNLIMITED CIVIL ACTION
20   CORPORATION,     Cross-Complainant,
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            v.
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23   JASON NEEL, CNA EQUITY GROUP, INC, a
     professional corporation, RUSHMYFILE, INC,
24   a California corporation, CODY MOLICA, and
25   ROES 1-50, inclusive,

26                        Cross-Defendants.
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     NOTICE OF MOTION TO QUASH SUMMONS AGAINST CROSS DEFENDANT CODY MOLICA
 1          To: UNITED STATES REAL ESTATE CORPORATION, Cross-Complainant, and to
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     Jeffrey Lowenthal, their respective attorney of record: NOTICE IS HEREBY GIVEN that Cross-
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     Defendant CODY MOLICA appears specially to make this motion only and, so specially
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     appearing, hereby does and will, on Thursday, May 25, 2023, at 9:00 AM, or as soon thereafter
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 6   as the matter may be heard, in dept. 5 of this court, located at 701 Ocean Street, Room 110, Santa

 7   Cruz, CA 95060, move for an order quashing the service of summons on this cross-defendant. The
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     motion will be made on the grounds that the court lacks jurisdiction over the person of this cross-
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     defendant. The motion will be based on this notice of motion, on the declaration of CODY
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     MOLICA and the supporting memorandum served and filed herewith, on the records and file
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12   herein, and on such evidence as may be presented at the hearing of the motion.

13          Date: February 23, 2023
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                                           ___/S/ Cody Molica_________________
16                                         Cody Molica,
                                           Cross-defendant in Pro Per
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     NOTICE OF MOTION TO QUASH SUMMONS AGAINST CROSS DEFENDANT CODY MOLICA