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  • ALLY FINANCIAL INC., A CORPORATION VS ANDREW LLOYD BARKER Other Complaint (non-tort/non-complex) (Limited Jurisdiction) document preview
  • ALLY FINANCIAL INC., A CORPORATION VS ANDREW LLOYD BARKER Other Complaint (non-tort/non-complex) (Limited Jurisdiction) document preview
						
                                

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Electronically FILED by Superior Court of California, County of Los Angeles on 03/02/2020 11:44 AM Sherri R. Carter, Executive Officer/Clerk of Court, by C. Ramos,Deputy Clerk J Michael D. Vanlochem, SBN 110Q68 VANLOCHEM & ASSOCIATES LLP 2 6565 Sun1set Blvd. Suite 412 Hollywood, CA 90028 3 Tel. (323)993-0500 Fax (323)993-0501 4 Attorneys for Plaintiff ALLY FINANCIAL INC., a corporation 5 6 SUPERIOR COURT OF THE STATE OF CALIFORNIA 7 COUNTY OF LOS ANGELES 8 (LOS ANGELES DISTRICT) 9 ALLY FINANCIAL INC., a corporation, CASE NO. 19STLC05187 10 Plaintiff, DECLARATION OF MICHAEL D. VANLOCHEM RE: RELIEF FROM 11 vs. BANKRUPTCY STAY 12 ANDREW LLOYD BARKER, etc., et al ., 13 Defendants. 14 I, M~chael D. Vanlochem, declare and say as follows: 15 1. I am an attorney duly licensed to practice law before all 16 competent courts of the State of California and a partner in the law firm 17 of Vanlochjem & Associates LLP. I have personal knowledge of the facts 18 hereinafter set forth, and if called as a witness, I would and could testify 19 competently thereto. I am the attorney primarily responsible for the 20 litigation of this action. 21 2. On or about November 25, 2019, defendant Andrew Lloyd 22 Barker filed Bankruptcy under chapter 13 of the bankruptcy code. A 23 copy of the docket of the bankruptcy case is attached hereto as Exhibit 24 "A", and inicorporated herein by this reference as though set forth in full. 25 3. · Based on that bankruptcy notice, our client instructed us to 26 file a Notice of Stay of Proceedings, which we did on or about December 27 13, 2019. A conformed copy of that Notice of Stay is attached hereto as 28 -1- DECLARATION OF MICHAEL D. VANLOCHEM RE: RELIEF FROM STAY