Preview
on 5/9/2023 9:50 AM
Envelope: 11920458
Reviewed By: A. Harding
CiV-100
ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO. FOR COURT USE ONLY
NAME: KENNETH J. FREED, ESQ. (SBN 125349] /ERIC J JUN, ESQ. (SBN 263502]
rirmname: Law Offices of Kenneth J. Freed
streetappress: 4340 Fulton Avenue, Third Floor
cry: Sherman Oaks state: CA apcove: 91423
TevepHone no: (818) 990-0888 raxno: (818) 990-1047
ema aopress: kfreed@kjfesq.com / ejun@kjfesq.com
ATTORNEY FOR (name): CREDITORS ADJUSTMENT BUREAU, INC.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA
streetaporess: 191 N. First Street
MaIING ADDREss: Same aS Above
cityanp zipcope: San Jose, CA 95113
BrancHName: Downtown Superior Court
Plaintiff/Petitioner: CREDITORS ADJUSTMENT BUREAU, INC
Defendant/Respondent: GENESIS DEMOLITION & HAULING SERVICES LLC
REQUEST FOR [XJ Entry of Default () Clerk's Judgment CASE NUMBER:
(Application) C) Court Judgment 22CV405075
Not for use in actions under the Fair Debt Buying Practices Act (Civ. Code, § 1788.50 et seq.) (see form CIV-105)
1 TO THE CLERK: On the complaint or cross-complaint filed
a. on (date): 10/05/2022; AMENDED 11/04/2022
b. by (name): CREDITORS ADJUSTMENT BUREAU, INC.
c. K] Enter default of defendant (names): GENESIS DEMOLITION & HAULING SERVICES LLC AKA GENESIS SITE SERVICES LLC AKA GENESIS
SITE SERVICES DBA GENESIS DEMOLITION ADBA GENESIS ATTACHMENTS
d. (2) | request a court judgment under Code of Civil Procedure sections 585(b), 585(c), 989, etc., against defendant
(names):
(Testimony required. Apply to the clerk for a hearing date, unless the court will enter a judgment on an affidavit under
Code Civ. Proc., § 585(d).)
e. () Enter clerk's judgment
(1) (2) for restitution of the premises only and issue a writ of execution on the judgment. Code of Civil Procedure section
1174(c) does not apply. (Code Civ. Proc., § 1169.)
(C} Include in the judgment all tenants, subtenants, named claimants, and other occupants of the premises. The
Prejudgment Claim of Right to Possession was served in compliance with Code of Civil Procedure section
415.46.
(2) (2) under Code of Civil Procedure section 585(a). (Complete the declaration under Code Civ. Proc., § 585.5 on the
reverse (item 5).)
(3) (CQ) for default previously entered on (date):
Judgment to be entered. Amount Credits acknowledged Balance
a Demand of complaint... $ DEFAULT ONLY 0 00 00
b. Statement of damages*
(1) Special 00 00 00
(2) General . 00 00 00
Interest 00 00 00
Costs (see reverse) 00 00 00
Attorney fees 00 00 00
TOTALS 00 00 00
Daily damages were demanded in complaint at the rate of: $ per day beginning (date):
(* Personal injury or wrongful death actions; Code Civ. Proc., § 425.11.)
3. (2) (Check if filed in an unlawful detainer case.) Legal document assistant or unlawful detainer assistant information is on the
reverse (complete item 4).
Date: 5/9/2023 Ei
ERIC J JUN ESQ Ericson (ay a3 POT]
(TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY FOR PLAINTIFF)
FOR COURT (1) (C) Default entered as requested on (date):
USE ONLY (2) ) Default NOT entered as requested (state reason):
Clerk, by , Deputy Page 1 of 3
Form Adopted for Mandatory Use Code of Civil Procedure, §§ 585-587, 1169
Judicial Council of California
Civ-100 [Rev. January 1, 2023] CEB | Essential REQUEST FOR ENTRY OF DEFAULT /Ww.COUItS.ca.gov
ceb.com | §2)Forms (Application to Enter Default) 6084387/6087499
CIV-100
Plaintiff/Petitioner: CREDITORS ADJUSTMENT BUREAU, INC. CASE NUMBER:
Defendant/Respondent: GENESIS DEMOLITION & HAULING SERVICES LLC} 22CV405075
4, Legal document assistant or unlawful detainer assistant (Bus. & Prof. Code, § 6400 et seq.). A legal document assistant or
unlawful detainer assistant (CQ did (QQ didnot for compensation give advice or assistance with this form. If declarant has
received any help or advice for pay from a legal document assistant or unlawful detainer assistant, state:
a. Assistant's name: c. Telephone no.:
b. Street address, city, and zip code: d. County of registration:
e. Registration no.:
f. Expires on (date):
5. CQ) Declaration under Code Civ. Proc., § 585.5 (for entry of default under Code Civ. Proc., § 585(a)). This action
a. CQ is EQ isnot on a contract or installment sale for goods or services subject to Civ. Code, § 1801 et seq. (Unruh Act).
b. CQ is EQ isnot on a conditional sales contract subject to Civ. Code, § 2981 et seq. (Rees-Levering Motor Vehicle Sales
and Finance Act).
ce. CQ) is EQ is not on an obligation for goods, services, loans, or extensions of credit subject to Code Civ. Proc., § 395(b).
Declaration of mailing (Code Civ. Proc., § 587). A copy of this Request for Entry of Default was
a. (.] not mailed to the following defendants, whose addresses are unknown to plaintiff or plaintiff's attorney (names):
b. EX] mailed first-class, postage prepaid, in a sealed envelope addressed to each defendant's attorney of record or, if none,
to each defendant's last known address as follows:
(1) Mailed on (date): 5/9/2023 (2) To (specify names and addresses shown on the envelopes):
Ss TE SERVICES
GENESIS DEMOL ION & HAULING SERVICES LLC AKA GENESIS su’
LLC AKA GEI SITE SERVICES DBA GENES DEMOLITION ADBA GENESIS
ATTACHME
c/o TREVAR SHYSHKA, REGISTERED AGENT FOR SERVICE OF PROCESS
810 PALM ST.,
SAN JOSE, CA 95110
| declare under penalty of perjury under the laws of the State of California that the foregoing items 4, 5, and 6 are true and correct.
Date: 5/9/2023
KATRINA TURNER » Aghia Tanner
(TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT)
7. Memorandum of costs (required if money judgment requested). Costs and disbursements are as follows (Code Civ. Proc.,
§ 1033.5):
Clerk's filing fees DEFAULT ONLY
Process server's fees... 0.00
Other (specify): 0.00
0.00
TOTAL
(CJ Costs and disbursements are waived.
lam the attorney, agent, or party who claims these costs. To the best of my knowledge and belief this memorandum of costs is
correct and these costs were necessarily incurred in this case.
| declare under penalty of perjury under the laws of the State of California that the foregoing item 7 is true and correct.
Date: 5/9/2023 eri
ERL J JUN, ESQ Eniun (May 9, 2075 0543 POT)
(TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT)
CIV-100 [Rev. January 1, 2023] Page 2 of 3
REQUEST FOR ENTRY OF DEFAULT
GICEB Essential (Application to Enter Default) 6084387/6087499
ceb.com §=)Forms
CIV-100
Plaintiff/Petitioner: CREDITORS ADJUSTMENT BUREAU, INC. CASE NUMBER:
Defendant/Respondent: GENESIS DEMOLITION & HAULING SERVICES LLC} 22CV405075
8. Declaration of nonmilitary status (required for a judgment).
No defendant/respondent named in item ‘1c is in the military service of the United States as defined by either the Servicemembers
Civil Relief Act (see 50 U.S.C. § 3911(2)) or California Military and Veterans Code sections 400 and 402(f).
| know that no defendant/respondent named in item 1c is in the U.S. military service because (check all that apply):
a. (.) the search results that | received from https://scra.dmdc.osd.mil/ say the defendant/respondent is not in the U.S. military
service.
b. C2) Lam in regular communication with the defendant/respondent and know that they are not in the U.S. military service.
c. [L} I recently contacted the defendant/respondent, and they told me that they are not in the U.S. military service.
d. (L) | know that the defendant/respondent was discharged from U.S. military service on or about (date):
e. LX] the defendant/respondent is not eligible to serve in the U.S. military because they are:
C) incarcerated (&) a business entity
f. [LJ other (specify):
Notice
U.S. military status can be checked online at https://scra.dmdc.osd.mil/.
. If the defendant/respondent is in the military service, or their military status is unknown, the defendant/respondent
is entitled to certain rights and protections under federal and state law before a default judgment can be entered.
For more information, see https.//selfhelp.courts.ca.gov/military-defaults.
| declare under penalty of perjury under the laws of the State of California that the foregoing item 8 is true and correct.
Date: 5/9/2023
Erie
ERIC J JUN, ESQ Eric Jun (May 9, 2073 09:43 PDT)
(TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT)
CIV-100 (Rev. January 1, 2023] Page 3 of 3
REQUEST FOR ENTRY OF DEFAULT
GICEB Essential 6084387/6087499
ceb.com [=]Forms: (Application to Enter Default)
6084387 - Reg for Default
Final Audit Report 2023-05-09
Created: 2023-05-09
By: Katrina Turner (kturner@kjfesq.com)
Status: Signed
Transaction ID: CBJCHBCAABAAS9Xx77HQ_jSAFn7_vpxil1eucrUSXFVIt
"6084387 - Req for Default" History
©) Document created by Katrina Turner (kturner@kjfesq.com)
2023-05-09 - 4:40:31 PM GMT- IP address: 209.36.37.58
©4 Document emailed to Eric Jun (ejun@kjfesq.com) for signature
2023-05-09 - 4:41:01 PM GMT
© Email viewed by Eric Jun (ejun@kifesq.com)
2023-05-09 - 4:43:21 PM GMT- IP address: 209.36.37.58
© Document e-signed by Eric Jun (ejun@kjfesq.com)
Signature Date: 2023-05-09 - 4:43:33 PM GMT - Time Source: server- IP address: 209.36.37.58
© Agreement completed.
2023-05-09 - 4:43:33 PM GMT
8 Adobe Acrobat Sign
Preview
on 5/9/2023 9:50 AM Envelope: 11920458 Reviewed By: A. Harding CiV-100 ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO. FOR COURT USE ONLY NAME: KENNETH J. FREED, ESQ. (SBN 125349] /ERIC J JUN, ESQ. (SBN 263502] rirmname: Law Offices of Kenneth J. Freed streetappress: 4340 Fulton Avenue, Third Floor cry: Sherman Oaks state: CA apcove: 91423 TevepHone no: (818) 990-0888 raxno: (818) 990-1047 ema aopress: kfreed@kjfesq.com / ejun@kjfesq.com ATTORNEY FOR (name): CREDITORS ADJUSTMENT BUREAU, INC. SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA streetaporess: 191 N. First Street MaIING ADDREss: Same aS Above cityanp zipcope: San Jose, CA 95113 BrancHName: Downtown Superior Court Plaintiff/Petitioner: CREDITORS ADJUSTMENT BUREAU, INC Defendant/Respondent: GENESIS DEMOLITION & HAULING SERVICES LLC REQUEST FOR [XJ Entry of Default () Clerk's Judgment CASE NUMBER: (Application) C) Court Judgment 22CV405075 Not for use in actions under the Fair Debt Buying Practices Act (Civ. Code, § 1788.50 et seq.) (see form CIV-105) 1 TO THE CLERK: On the complaint or cross-complaint filed a. on (date): 10/05/2022; AMENDED 11/04/2022 b. by (name): CREDITORS ADJUSTMENT BUREAU, INC. c. K] Enter default of defendant (names): GENESIS DEMOLITION & HAULING SERVICES LLC AKA GENESIS SITE SERVICES LLC AKA GENESIS SITE SERVICES DBA GENESIS DEMOLITION ADBA GENESIS ATTACHMENTS d. (2) | request a court judgment under Code of Civil Procedure sections 585(b), 585(c), 989, etc., against defendant (names): (Testimony required. Apply to the clerk for a hearing date, unless the court will enter a judgment on an affidavit under Code Civ. Proc., § 585(d).) e. () Enter clerk's judgment (1) (2) for restitution of the premises only and issue a writ of execution on the judgment. Code of Civil Procedure section 1174(c) does not apply. (Code Civ. Proc., § 1169.) (C} Include in the judgment all tenants, subtenants, named claimants, and other occupants of the premises. The Prejudgment Claim of Right to Possession was served in compliance with Code of Civil Procedure section 415.46. (2) (2) under Code of Civil Procedure section 585(a). (Complete the declaration under Code Civ. Proc., § 585.5 on the reverse (item 5).) (3) (CQ) for default previously entered on (date): Judgment to be entered. Amount Credits acknowledged Balance a Demand of complaint... $ DEFAULT ONLY 0 00 00 b. Statement of damages* (1) Special 00 00 00 (2) General . 00 00 00 Interest 00 00 00 Costs (see reverse) 00 00 00 Attorney fees 00 00 00 TOTALS 00 00 00 Daily damages were demanded in complaint at the rate of: $ per day beginning (date): (* Personal injury or wrongful death actions; Code Civ. Proc., § 425.11.) 3. (2) (Check if filed in an unlawful detainer case.) Legal document assistant or unlawful detainer assistant information is on the reverse (complete item 4). Date: 5/9/2023 Ei ERIC J JUN ESQ Ericson (ay a3 POT] (TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY FOR PLAINTIFF) FOR COURT (1) (C) Default entered as requested on (date): USE ONLY (2) ) Default NOT entered as requested (state reason): Clerk, by , Deputy Page 1 of 3 Form Adopted for Mandatory Use Code of Civil Procedure, §§ 585-587, 1169 Judicial Council of California Civ-100 [Rev. January 1, 2023] CEB | Essential REQUEST FOR ENTRY OF DEFAULT /Ww.COUItS.ca.gov ceb.com | §2)Forms (Application to Enter Default) 6084387/6087499 CIV-100 Plaintiff/Petitioner: CREDITORS ADJUSTMENT BUREAU, INC. CASE NUMBER: Defendant/Respondent: GENESIS DEMOLITION & HAULING SERVICES LLC} 22CV405075 4, Legal document assistant or unlawful detainer assistant (Bus. & Prof. Code, § 6400 et seq.). A legal document assistant or unlawful detainer assistant (CQ did (QQ didnot for compensation give advice or assistance with this form. If declarant has received any help or advice for pay from a legal document assistant or unlawful detainer assistant, state: a. Assistant's name: c. Telephone no.: b. Street address, city, and zip code: d. County of registration: e. Registration no.: f. Expires on (date): 5. CQ) Declaration under Code Civ. Proc., § 585.5 (for entry of default under Code Civ. Proc., § 585(a)). This action a. CQ is EQ isnot on a contract or installment sale for goods or services subject to Civ. Code, § 1801 et seq. (Unruh Act). b. CQ is EQ isnot on a conditional sales contract subject to Civ. Code, § 2981 et seq. (Rees-Levering Motor Vehicle Sales and Finance Act). ce. CQ) is EQ is not on an obligation for goods, services, loans, or extensions of credit subject to Code Civ. Proc., § 395(b). Declaration of mailing (Code Civ. Proc., § 587). A copy of this Request for Entry of Default was a. (.] not mailed to the following defendants, whose addresses are unknown to plaintiff or plaintiff's attorney (names): b. EX] mailed first-class, postage prepaid, in a sealed envelope addressed to each defendant's attorney of record or, if none, to each defendant's last known address as follows: (1) Mailed on (date): 5/9/2023 (2) To (specify names and addresses shown on the envelopes): Ss TE SERVICES GENESIS DEMOL ION & HAULING SERVICES LLC AKA GENESIS su’ LLC AKA GEI SITE SERVICES DBA GENES DEMOLITION ADBA GENESIS ATTACHME c/o TREVAR SHYSHKA, REGISTERED AGENT FOR SERVICE OF PROCESS 810 PALM ST., SAN JOSE, CA 95110 | declare under penalty of perjury under the laws of the State of California that the foregoing items 4, 5, and 6 are true and correct. Date: 5/9/2023 KATRINA TURNER » Aghia Tanner (TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT) 7. Memorandum of costs (required if money judgment requested). Costs and disbursements are as follows (Code Civ. Proc., § 1033.5): Clerk's filing fees DEFAULT ONLY Process server's fees... 0.00 Other (specify): 0.00 0.00 TOTAL (CJ Costs and disbursements are waived. lam the attorney, agent, or party who claims these costs. To the best of my knowledge and belief this memorandum of costs is correct and these costs were necessarily incurred in this case. | declare under penalty of perjury under the laws of the State of California that the foregoing item 7 is true and correct. Date: 5/9/2023 eri ERL J JUN, ESQ Eniun (May 9, 2075 0543 POT) (TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT) CIV-100 [Rev. January 1, 2023] Page 2 of 3 REQUEST FOR ENTRY OF DEFAULT GICEB Essential (Application to Enter Default) 6084387/6087499 ceb.com §=)Forms CIV-100 Plaintiff/Petitioner: CREDITORS ADJUSTMENT BUREAU, INC. CASE NUMBER: Defendant/Respondent: GENESIS DEMOLITION & HAULING SERVICES LLC} 22CV405075 8. Declaration of nonmilitary status (required for a judgment). No defendant/respondent named in item ‘1c is in the military service of the United States as defined by either the Servicemembers Civil Relief Act (see 50 U.S.C. § 3911(2)) or California Military and Veterans Code sections 400 and 402(f). | know that no defendant/respondent named in item 1c is in the U.S. military service because (check all that apply): a. (.) the search results that | received from https://scra.dmdc.osd.mil/ say the defendant/respondent is not in the U.S. military service. b. C2) Lam in regular communication with the defendant/respondent and know that they are not in the U.S. military service. c. [L} I recently contacted the defendant/respondent, and they told me that they are not in the U.S. military service. d. (L) | know that the defendant/respondent was discharged from U.S. military service on or about (date): e. LX] the defendant/respondent is not eligible to serve in the U.S. military because they are: C) incarcerated (&) a business entity f. [LJ other (specify): Notice U.S. military status can be checked online at https://scra.dmdc.osd.mil/. . If the defendant/respondent is in the military service, or their military status is unknown, the defendant/respondent is entitled to certain rights and protections under federal and state law before a default judgment can be entered. For more information, see https.//selfhelp.courts.ca.gov/military-defaults. | declare under penalty of perjury under the laws of the State of California that the foregoing item 8 is true and correct. Date: 5/9/2023 Erie ERIC J JUN, ESQ Eric Jun (May 9, 2073 09:43 PDT) (TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT) CIV-100 (Rev. January 1, 2023] Page 3 of 3 REQUEST FOR ENTRY OF DEFAULT GICEB Essential 6084387/6087499 ceb.com [=]Forms: (Application to Enter Default) 6084387 - Reg for Default Final Audit Report 2023-05-09 Created: 2023-05-09 By: Katrina Turner (kturner@kjfesq.com) Status: Signed Transaction ID: CBJCHBCAABAAS9Xx77HQ_jSAFn7_vpxil1eucrUSXFVIt "6084387 - Req for Default" History ©) Document created by Katrina Turner (kturner@kjfesq.com) 2023-05-09 - 4:40:31 PM GMT- IP address: 209.36.37.58 ©4 Document emailed to Eric Jun (ejun@kjfesq.com) for signature 2023-05-09 - 4:41:01 PM GMT © Email viewed by Eric Jun (ejun@kifesq.com) 2023-05-09 - 4:43:21 PM GMT- IP address: 209.36.37.58 © Document e-signed by Eric Jun (ejun@kjfesq.com) Signature Date: 2023-05-09 - 4:43:33 PM GMT - Time Source: server- IP address: 209.36.37.58 © Agreement completed. 2023-05-09 - 4:43:33 PM GMT 8 Adobe Acrobat Sign