Motion-Secondary: GLENN FELDMAN VS KEYSHIA COLE

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 01/03/2020 12:29 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Parententeau,Deputy Clerk

                          1 MAURICE WAINER (SBN 121678)
                            SNIPPER WAINER & MARKOFF
                          2 232 North Canon Drive
                            Beverly Hills, California 90210-5302
                          3 Telephone: (310) 550-5770
                            e-mail: mrwainer@swmfirm.com
                          4
                            Attorneys for Plaintiff
                          5 GLENN FELDMAN, an individual
                          6
                          7                               SUPERIOR COURT OF THE STATE OF CALIFORNIA
                          8                                             FOR THE COUNTY OF LOS ANGELES
                          9                                 WEST DISTRICT – SANTA MONICA COURTHOUSE
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                        11 GLENN FELDMAN, an individual,                )                                         Case No. 19SMCV01785
                                                                        )
                        12                        Plaintiff,            )                                         Hon. Marc D. Gross, Judge, Dept. R
                                                                        )
                        13              vs.                             )                                         MEMORANDUM OF POINTS AND
                                                                        )                                         AUTHORITIES IN SUPPORT OF
                        14     KEYSHIA COLE, an individual; and DOES 1- )                                         PLAINTIFF’S APPLICATION FOR
                               10, inclusive,                           )                                         COURT DEFAULT JUDGMENT
                        15                                              )                                         AGAINST DEFENDANT KEYSHIA
                                                  Defendants.           )                                         COLE
                        16                                              )
                                                                        )                                         [No Hearing Required]
                        17                                              )
                               ______________________________________ )                                           Action filed: 10/08/2019
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                        19      1.          Summary of the Case
                        20                  On or about March 1, 2017, Plaintiff GLENN FELDMAN (“Plaintiff” or “Feldman”)
                        21      and Defendant KEYSHIA COLE (“Defendant” or “Cole”) entered into a written Residential
                        22      Lease, with written Lease Renewals (collectively, the “Lease”), by which the Defendant initially
                        23      leased from Plaintiff his residential property located at 944 Harbor Crossing Lane, Marina Del
                        24      Rey, California 90292 (the “Property”) commencing March 15, 2017 and continuing through
                        25      February 14, 2018, which Lease term was extended through February 14, 2019, and thereupon
                        26      the Lease continued on a month-to-month basis through May 1, 2019. True and correct copies of
                        27      the written Residential Lease with Renewals, are collectively attached herein as Exhibit “A”.
                        28      (See Declaration of Glenn Feldman [“Feldman Decl.”], ¶¶ 3-4, Exh. A.)
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                                     MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PLAINTIFF’S APPLICATION
                                          FOR COURT DEFAULT JUDGMENT AGAINST DEFENDANT KEYSHIA COLE