On January 03, 2022 a
No Value
was filed
involving a dispute between
Havarti Brie,
Jung James,
and
Carter Samson,
Cater Samson,
Cater Tiffany,
Gant Roshima,
Hankins Willie D,
Manchego Blue,
for Unlawful Detainer/Residential (not drugs or wrongful eviction) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 01/31/2022 12:00 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Vargas,Deputy Clerk
1 JOSEPH L. CRUZ, ESQ.
JOSEPH L. CRUZ, APC
2 527 W. 7TH STREET, SUITE 903
3 LOS ANGELES, CA 90014
TEL: (323) 692-0199
4 EMAIL: JOE@CRUZAPC.COM
STATE BAR # 290139
5
Attorney for Plaintiff
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
COUNTY OF LOS ANGELES, CHATSWORTH, LIMITED
10
11
JAMES JUNG, CASE NUMBER: 22CHCV00003
12
PLAINTIFF, EX PARTE APPLICATION SHORTENING TIME AND
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TO ADVANCE THE HEARING OF THE DEMURRER;
14 vs. DECLARATION OF JOSEPH L. CRUZ;
MEMORANDUM OF POINTS AND AUTHORITIES;
15 WILLIE D. HANKINS; ET AL.; DOES 1-10 INCLUSIVE, DECLARATION RE: EX PARTE NOTICE
16
DEFENDANT. DATE: 2/1/2022
17 TIME: 8:30 A.M.
DEPT: F49
18
19 TO DEFENDANT(S) AND THEIR ATTORNEY OF RECORD:
PLEASE TAKE NOTICE that JAMES JUNG (“PLAINTIFF”) hereby moves this Court for an Ex Parte
20
Application Shortening Time and to Advance the Hearings of the Demurrers filed by Defendants WILLIE
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D. HANKINS, ROSHIMA GANT, TIFFANY CATER, and SAMSON CARTER AKA SAMSON CATER
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(“DEFENDANT” or “DEFENDANTS”) and/or, in the alternative, to have the Court hear DEFENDANTS’
23
Demurrers at the hearing of this Ex Parte Application.
24 DEFENDANTS’ Demurrers are frivolous and totally and completely without merit and were filed
25 in bad faith. The Demurrers lack legal grounds, lack any evidentiary showing, and have resulted in an
26 unconscionable delay resulting in prejudice to PLAINTIFF. It is obvious that DEFENDANTS filed the
Demurrers solely intending to cause this unnecessary delay and the Demurrers are clearly a stalling
27
tactic and an effort to thwart the eviction process.
28
EX PARTE APPLICATION SHORTENING TIME AND TO ADVANCE THE HEARING OF THE DEMURRER; DECLARATION OF JOSEPH L.
CRUZ; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION RE: EX PARTE NOTICE - 1
Document Filed Date
January 31, 2022
Case Filing Date
January 03, 2022
Category
Unlawful Detainer/Residential (not drugs or wrongful eviction) (General Jurisdiction)
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 01/31/2022 12:00 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Vargas,Deputy Clerk 1 JOSEPH L. CRUZ, ESQ. JOSEPH L. CRUZ, APC 2 527 W. 7TH STREET, SUITE 903 3 LOS ANGELES, CA 90014 TEL: (323) 692-0199 4 EMAIL: JOE@CRUZAPC.COM STATE BAR # 290139 5 Attorney for Plaintiff 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES, CHATSWORTH, LIMITED 10 11 JAMES JUNG, CASE NUMBER: 22CHCV00003 12 PLAINTIFF, EX PARTE APPLICATION SHORTENING TIME AND 13 TO ADVANCE THE HEARING OF THE DEMURRER; 14 vs. DECLARATION OF JOSEPH L. CRUZ; MEMORANDUM OF POINTS AND AUTHORITIES; 15 WILLIE D. HANKINS; ET AL.; DOES 1-10 INCLUSIVE, DECLARATION RE: EX PARTE NOTICE 16 DEFENDANT. DATE: 2/1/2022 17 TIME: 8:30 A.M. DEPT: F49 18 19 TO DEFENDANT(S) AND THEIR ATTORNEY OF RECORD: PLEASE TAKE NOTICE that JAMES JUNG (“PLAINTIFF”) hereby moves this Court for an Ex Parte 20 Application Shortening Time and to Advance the Hearings of the Demurrers filed by Defendants WILLIE 21 D. HANKINS, ROSHIMA GANT, TIFFANY CATER, and SAMSON CARTER AKA SAMSON CATER 22 (“DEFENDANT” or “DEFENDANTS”) and/or, in the alternative, to have the Court hear DEFENDANTS’ 23 Demurrers at the hearing of this Ex Parte Application. 24 DEFENDANTS’ Demurrers are frivolous and totally and completely without merit and were filed 25 in bad faith. The Demurrers lack legal grounds, lack any evidentiary showing, and have resulted in an 26 unconscionable delay resulting in prejudice to PLAINTIFF. It is obvious that DEFENDANTS filed the Demurrers solely intending to cause this unnecessary delay and the Demurrers are clearly a stalling 27 tactic and an effort to thwart the eviction process. 28 EX PARTE APPLICATION SHORTENING TIME AND TO ADVANCE THE HEARING OF THE DEMURRER; DECLARATION OF JOSEPH L. CRUZ; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION RE: EX PARTE NOTICE - 1