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ESTEBAN L. VALENZUELA, ESQ. (State Bar N0. 73001)
ESTEBAN L. VALENZUELA & ASSOCIATES
204 North Vine Street
P.0. Box I718
Santa Maria, CA 93454-1718
E-FILED
Telephone; (805) 922-6674
3/17/2023 12:23 PM
cslcbunriIAvalenzuelalaw.e0m
Superior Court of California
County of Fresno
RICHARD C. BENNETT, ESQ. (State Bar No. 60.561)
BENNETT & JOHNSON, LLP By: I. Herrera, Deputy
\DWQO‘UI&W
21 Orinda Way, N0. C366
Orinda, CA 94563
Telephone: (5 10) 207-2404
I‘iclmrdfiflbcnncttiohnsunlaw.cum
CYNTHIA A. TOOMEY, ESQ. (State Bar No. 210348)
Anomey at Law
1011 "G” Street, Suite 4
10 Recdley, CA 93654
Telephone: (559) 638-8002
ll czmrruxufivbvurimn.net
12 Attorneys for Petitioner TERESA RAMOS SANCHEZ and Associated counsel for Plaintiff
JAYI.A SOFIA PEREZ, a minor, by and through her Guardian ad Litem, MIGUEL PEREZ
13
l4 SUPERIOR COURT OF THE STATE OF CALIFORNIA
15 IN AND FOR THE COUNTY OF FRESNO
l6
l7 DALEYZA VARGAS, a minor by and through No. 22CECG01 831
JOSE MIGUEL
her Guardian ad Litem,
18 VARGAS; XAVIER JOSE PEREZ, and JAYLA EX PARTE PETITION TO REMOVE
SOFIA PEREZ, minors, by and through their MIGUELPEREZ AS GUARDIAN AD
l9 Guardian ad Litcm, MIGUEL PEREZ, LITEM FOR THE MINOR CHILD JAYLA
SOFIA PEREZ AND TO APPOINT
20 Plaintiffs, PETITIONER TERESA RAMOS
SANCHEZ AS GUARDIAN AD LITEM
21 vs. FOR MINOR PLAINTIFF JAYLA SOFIA
PEREZ
22
JAMES LEONARD COMAZZI, BONNIE
23 COMAZZI and DOES through 20, inclusive,
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24 Defendants.
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COMES NOW Petitioner TERESA RAMOS SANCHEZ and hereby petitions for the
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removal of MIGUEL PEREZ as Guardian ad Litem for the Minor PlaintiffJAYLA SOFIA
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PETITION T0 REMOVE GUARDIAN AD LITBM
PEREZ, due to the recent death of MIGUEL PEREZ.
Based upon good cause as set forth in the attached Declaration of Esteban L. Valenzuela,
Petitioner TERESA RAMOS SANCHEZ requests the Court appbint her as Guardian ad Litem
for the Minor PlaintiffJAYLA SOFIA PEREZ.
Dated '?V25
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ESTEBAN ALRNV U ZLA & ASSOCIATES
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By: .
11 CYNT IA A. TOOME
Attorneys for Petitioner
12 TERESA RAMOS SANCHEZ
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PETITION T0 REMOVE GUARDIAN AD LITEM
PROOF OF SERVICE
I am employed in the County of Alameda, State of California.
I am over the age of eighteen (18) years and not a party to the within action.
On March 16, 2023, I served the within:
PETITION TO REMOVE GUARDIAN AD LITEM;
DECLARATION OF ESTEBAN L. VALENZUELA;
PROPOSED ORDER
on the parties to this action as follows:
SEE ATTACHED
(BY MAIL) I placed each such sealed envelope with postage thereon fully prepared for
first-class mail, for collection and mailing at Oakland, California, following ordinary business
practices. I am readily familiar with the practice of BENNETT & JOHNSON LLP for processing of
correspondence, said practice being that in the course of ordinary business, correspondence is
deposited in the United States Postal Service the same day it is posted for processing.
(BY OVERNIGHT DELIVERY) I enclosed the documents in an envelope or package
provided by an overnight delivery carrier and addressed to the person(s) at the address(es) listed
above. I placed the envelope or package for collection and overnight delivery at an office or a
regularly utilized drop box of the overnight delivery carrier.
(BY MESSENGER) I served the documents by placing them in an envelope or package
and providing them to a messenger for service to be delivered by hand to the address(es) listed.
(BY FACSIMILE) Based on the agreement of the parties to accept service by fax
transmission, I caused said document to be transmitted by Facsimile machine to the number
indicated after the address(es) noted above. No error was reported by the fax machine that I
used. Time of service: __________
(BY EMAIL OR ELECTRONIC TRANSMISSION) Based on an agreement between the
parties and/or as a courtesy, I sent the documents to the person(s) at the email address(es) listed
above. I did not receive, within a reasonable time after the transmission, any electronic message
or other indication that the transmission was unsuccessful. Time of service:______________
I declare under penalty of perjury under the laws of the State of California, that the
foregoing is true and correct. Executed at Alameda, California, on March 16, 2023.
__________________________________
CINDY HERMANSON
SERVICE LIST
ESTEBAN L. VALENZUELA, ESQ. (State Bar No. 73001)
ESTEBAN L. VALENZUELA & ASSOCIATES
204 North Vine Street
P.O. Box 1718
Santa Maria, CA 93454-1718
Telephone: (805) 922-6674
esteban@valenzuelalaw.com
RICHARD C. BENNETT, ESQ. (State Bar No. 60561)
BENNETT & JOHNSON, LLP
21 Orinda Way, No. C366
Orinda, CA 94563
Telephone: (510) 207-2404
richard@bennettjohnsonlaw.com
CYNTHIA A. TOOMEY, ESQ. (State Bar No. 210348)
Attorney at Law
1011 “G” Street, Suite 4
Reedley, CA 93654
Telephone: (559) 638-8002
caarroyo@verizon.net
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ESTEBAN L. VALENZUELA, ESQ. (State Bar N0. 73001) ESTEBAN L. VALENZUELA & ASSOCIATES 204 North Vine Street P.0. Box I718 Santa Maria, CA 93454-1718 E-FILED Telephone; (805) 922-6674 3/17/2023 12:23 PM cslcbunriIAvalenzuelalaw.e0m Superior Court of California County of Fresno RICHARD C. BENNETT, ESQ. (State Bar No. 60.561) BENNETT & JOHNSON, LLP By: I. Herrera, Deputy \DWQO‘UI&W 21 Orinda Way, N0. C366 Orinda, CA 94563 Telephone: (5 10) 207-2404 I‘iclmrdfiflbcnncttiohnsunlaw.cum CYNTHIA A. TOOMEY, ESQ. (State Bar No. 210348) Anomey at Law 1011 "G” Street, Suite 4 10 Recdley, CA 93654 Telephone: (559) 638-8002 ll czmrruxufivbvurimn.net 12 Attorneys for Petitioner TERESA RAMOS SANCHEZ and Associated counsel for Plaintiff JAYI.A SOFIA PEREZ, a minor, by and through her Guardian ad Litem, MIGUEL PEREZ 13 l4 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 IN AND FOR THE COUNTY OF FRESNO l6 l7 DALEYZA VARGAS, a minor by and through No. 22CECG01 831 JOSE MIGUEL her Guardian ad Litem, 18 VARGAS; XAVIER JOSE PEREZ, and JAYLA EX PARTE PETITION TO REMOVE SOFIA PEREZ, minors, by and through their MIGUELPEREZ AS GUARDIAN AD l9 Guardian ad Litcm, MIGUEL PEREZ, LITEM FOR THE MINOR CHILD JAYLA SOFIA PEREZ AND TO APPOINT 20 Plaintiffs, PETITIONER TERESA RAMOS SANCHEZ AS GUARDIAN AD LITEM 21 vs. FOR MINOR PLAINTIFF JAYLA SOFIA PEREZ 22 JAMES LEONARD COMAZZI, BONNIE 23 COMAZZI and DOES through 20, inclusive, 1 24 Defendants. 25 COMES NOW Petitioner TERESA RAMOS SANCHEZ and hereby petitions for the 26 removal of MIGUEL PEREZ as Guardian ad Litem for the Minor PlaintiffJAYLA SOFIA 27 28 PETITION T0 REMOVE GUARDIAN AD LITBM PEREZ, due to the recent death of MIGUEL PEREZ. Based upon good cause as set forth in the attached Declaration of Esteban L. Valenzuela, Petitioner TERESA RAMOS SANCHEZ requests the Court appbint her as Guardian ad Litem for the Minor PlaintiffJAYLA SOFIA PEREZ. Dated '?V25 _3_ />_.___w ... ESTEBAN ALRNV U ZLA & ASSOCIATES fl 10 By: . 11 CYNT IA A. TOOME Attorneys for Petitioner 12 TERESA RAMOS SANCHEZ 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 23 2 PETITION T0 REMOVE GUARDIAN AD LITEM PROOF OF SERVICE I am employed in the County of Alameda, State of California. I am over the age of eighteen (18) years and not a party to the within action. On March 16, 2023, I served the within: PETITION TO REMOVE GUARDIAN AD LITEM; DECLARATION OF ESTEBAN L. VALENZUELA; PROPOSED ORDER on the parties to this action as follows: SEE ATTACHED (BY MAIL) I placed each such sealed envelope with postage thereon fully prepared for first-class mail, for collection and mailing at Oakland, California, following ordinary business practices. I am readily familiar with the practice of BENNETT & JOHNSON LLP for processing of correspondence, said practice being that in the course of ordinary business, correspondence is deposited in the United States Postal Service the same day it is posted for processing. (BY OVERNIGHT DELIVERY) I enclosed the documents in an envelope or package provided by an overnight delivery carrier and addressed to the person(s) at the address(es) listed above. I placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier. (BY MESSENGER) I served the documents by placing them in an envelope or package and providing them to a messenger for service to be delivered by hand to the address(es) listed. (BY FACSIMILE) Based on the agreement of the parties to accept service by fax transmission, I caused said document to be transmitted by Facsimile machine to the number indicated after the address(es) noted above. No error was reported by the fax machine that I used. Time of service: __________ (BY EMAIL OR ELECTRONIC TRANSMISSION) Based on an agreement between the parties and/or as a courtesy, I sent the documents to the person(s) at the email address(es) listed above. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. Time of service:______________ I declare under penalty of perjury under the laws of the State of California, that the foregoing is true and correct. Executed at Alameda, California, on March 16, 2023. __________________________________ CINDY HERMANSON SERVICE LIST ESTEBAN L. VALENZUELA, ESQ. (State Bar No. 73001) ESTEBAN L. VALENZUELA & ASSOCIATES 204 North Vine Street P.O. Box 1718 Santa Maria, CA 93454-1718 Telephone: (805) 922-6674 esteban@valenzuelalaw.com RICHARD C. BENNETT, ESQ. (State Bar No. 60561) BENNETT & JOHNSON, LLP 21 Orinda Way, No. C366 Orinda, CA 94563 Telephone: (510) 207-2404 richard@bennettjohnsonlaw.com CYNTHIA A. TOOMEY, ESQ. (State Bar No. 210348) Attorney at Law 1011 “G” Street, Suite 4 Reedley, CA 93654 Telephone: (559) 638-8002 caarroyo@verizon.net