Motion,Ex Parte: GREEN FARMS, INC. VS IVAN A. TORRES, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 04/13/2022 02:18 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Riveros,Deputy Clerk




                              Thomas R. Mulally, SBN 116880
                              SPENCER 4 MULALLY
                              14156 Magnolia Boulevard, Suite 200
                              Sherman Oaks, CA 91423
                              Telephone: (818) 784-8700
                              Facsimile: (818) 784-5406
                              File No.: 2665-072
                              Attorney for Plaintiff



                                                            SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                                FOR THE COUNTY OF LOS ANGELES, NORTH VALLEY DISTRICT
                      10                                                                 Limited Jurisdiction

                      11      GREEN FARMS, INC. dba WORLDWIDE) Case No.: 20CHLC31041
                              PRODUCE,
                      12
                                                                                                         Action Filed:                      December 15, 2020
                      13                                                                                 Judge Assigned:                    Hon. Graciela Freixes
                                                      Plaintiff,                                         Dept:                              F43
                      14                  vs.
                                                                                                         NOTICE OF MOTION AND MOTION TO
                      15                                                                                 ENFORCE SETTLEMENT AGREEMENT
                               THE MALIBU HOUSE, LLC dba CLIFF                                           AT TIME OF TRIAL AND FOR ENTRY OF
                       16      DIVER; IVAN A. TORRES; and DOES 1                                         JUDGMENT THEREON; MEMORANDUM
                                                                                                         OF POINTS AND AUTHORITIES; AND
                       17
                               through 100, inclusive,                                                   DECLARATION OF THOMAS R.
                                                                                                         MULALLY IN SUPPORT THEREOF
                       18                 De fendants.
                                                                                                          Reservation No.                    466950628619
                       19                                                                                 Date:                              December 28, 2022
                                                                                                          Time:                              8:31 a.m.
                      20                                                                                  Dept.:                             F43

                      21

                      22       TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
                      23                  PLEASE TAKE NOTICE that on December 28, 2022 at 8:31 a.m. in Department F43,
                      24       or as soon thereafter as counsel can be heard, Plaintiff, GREEN FARMS, INC. dba
                      25       WORLDWIDE PRODUCE, will, through its attorneys of record herein, move this Court to
                      26       enforce the settlement reached prior to Trial on February 17, 2022 and for Entry of Judgment in
                               this action in favor of said Plaintiff, including an award of costs and reasonable attorneys fees.
                      28

                                                                                                         I
                               NOTICE OF MOTION AND MOTION TO KNFORCK SKTTLKMKNT AGREEMENT AT
                               TIME OF TRIAL AND FOR ENTRY OF JUDGMENT THEREON; MEMORANDUM OF
                               POINTS AND AUTHORITIES; AND DECLARATION OF THOMAS R. MULALLY IN
                               SUPPORT THEREOF