Motion,Ex Parte: ROSA AQUINO VS YARDEN DANO, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 11/28/2022 12:10 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk




                1   Hesam Dean Yazdanpanah (SBN 275664)
                    LAW OFFICES OF D. HESS PANAH
                2   & ASSOCIATES
                    9454 Wilshire Blvd., 6th Floor
                3   Beverly Hills, CA 90212
                    T: (310) 860-9464
                4   F: (310) 860- 8929
                    Email: vania@cainjurynetwork.com
                5   Attorney for Plaintiff
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                8                                       SUPERIOR COURT FOR THE STATE OF CALIFORNIA
                9                                                               LOS ANGELES COUNTY
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                                                                                                   )
                                                                                                   )       CASE NO. 21STCV07505
              11    ROSA AQUINO, an individual;                                                    )
                                                                                                   )
              12                           Plaintiffs,                                             )       NOTICE OF MOTION AND MOTION TO
                                                                                                   )       SET ASIDE DISMISSAL BASED ON
              13                vs.                                                                )       ATTORNEY'S EXCUSABLE NEGLECT
                                                                                                   )       (C.C.P. §473); MEMORANDUM OF
              14
                                                                                                   )       POINTS & AUTHORITIES IN SUPPORT
                    YARDEN DANO, an individual; KEREN                                              )       THEREOF, AND DECLARATION OF D.
              15    SHEMESH, an individual; FORD GREEN                                             )       HESS PANAH, ESQ.
                    WING LLC; CANVAS; DOES 1-50,                                                   )
              16    inclusive,                                                                     )       Date: March 7, 2023
                                                                                                   )       Time: 1:30 p.m.
              17                           Defendants,                                             )       Dept 28
                                                                                                   )       Reservation ID:818914495804
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                                TO DEFENDANT, YARDEN DANO ET AL; AND DOES 1-50 INCLUSIVE, AND THEIR
              22    ATTORNEYS OF RECORD HEREIN:
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              24                PLEASE TAKE NOTICE that on March 7, 2023, at 1:30PM, or as soon thereafter as the
                    matter may be heard, in Department 28 of the above-entitled court, located at 312 N. Spring
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                    Street, Los Angeles, California, 90012, Plaintiff will move the Court for an order seeking relief
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                    from an Order of Dismissal based on the excusable neglect of his attorney.
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                      NOTICE OF MOTION AND MOTION TO SET ASIDE
                      DISMISSAL                                                                1