On October 08, 2019 a
Complaint,Petition
was filed
involving a dispute between
Acosta, Sandy,
Jetcruzer International, Llc.,
and
Acosta, Sandy,
Does 3 Through 50,
Guzman, Marvin J.,
Zepeda, Ulises A.,
for Fraud
in the District Court of San Bernardino County.
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CASE ATTACHMENT COVER PAGE (ENDORSED)
ELECTRONICALLY
SUPERIOR COURT 0F CALIFORNIA, COUNTY OF SAN BERNARDINO FILED
STREET ADDREss;247 West Third Street
MAILING ADDRESS: w _
-
BY SUPERIOR COURT
CITY AND ZIP cope; San Bernardino, CA 92415
‘
OF CALIFORNIA, COUNTY OF
BRANCH NAME:San Bernardino Justice Center San Bernardino
WEBSITEhttp //www. sb—court. org
:
on Sep 9, 2021
CLERK OF THE SUPERIOR COURT
ATTACHMENTNAME: Declaration: of Demurring or Moving Party in Support of
DepuoICIerk: Angeline Garcia
Automatic Extension
CASE NAME: Jetcruzer
International LLC vs. Sandy Acosta et al CASE NUMBER:
CIVDSl 930132
Please log on to www.TurboCourt.com regularly for updates
Please staple this to your original attachment
unoooqmufidyq
/uloo
CIV-141
ATTORNEV 0R pARTY WITHOUT ATTORNEY: STATE BAR No: 248214 FOR counr use ONLY
NAME: R. Christopher Harshman
HRM NAME: David M. Shaby and Associates, II APC
STREET ADDRESS: 11949 Jefferson Blvd. Ste 104
elm Culver city
STATE: CA ZIP cons: 90230
TELEPHONE No.: (310) 827-7171
FAX N0; (310) 822-8529
E-MAILADDRESS: charshman@shabyandassociates.com
ATTORNEY FOR (Name):Acosta, Zepeda, and Guzman
SUPERIOR COURT OF CALIFORNIA, COUNTY OFSan Bernardino
STREET ADDRESS: 247 W. Third St.
MAILING ADDRESS:
CITY AND ZIP CODE: San Bernardino 92415
BRANCH NAME: San Bernardino
PLAINTIFF/PETITIONER: Jetcruzer International LLC
DEFENDANT/RESPONDENT: Acosta et al
CASE NUMBER:
DECLARATION OF DEMURRING OR MOVING(PAIRT¥ '
CND81930132
IN SUPPORT OF AUTOMATIC EXTENSION”
'
Guzman. and Ulises A. Zépeda
' '
was served with
1, (Name ofparty): Sandy Acosta, Marvin J.
E acomplaint E an amended complaint E across-complaint
Ein
an answer
the above-titled action.
E other (specify):
a responsive pleading is due on (date): September 8. 2021
2. For a demurrer or motion to strike,
DECLARATION
judgment on the pleadings in this action. Before can do so. am required
to l |
intend to file a demurrer, motion to strike. or motion for
I
to at least five days before the date when the responsive
meet and confer with the party who filed the pleading that am responding |
judgment on the
at least five days before the last day a motion for
pleading is due (if am filing a demurrer or motion to strike) and
l
forjudgment on the pleadings). We have not been able to meet and confer. have not |
pleadings may be filed (ifl am filing a motion
the requirements
Therefore. on timely filing and serving a declaration that meets
previously requested an automatic extension of time.
am entitled to an automatic 30-day extension of time within which to file a
of Code of Civil Procedure sections 430.41, 435.5,
or 439, I
responsive pleading or motion for judgment on the pleadings.
at least five days before the date the responsive
l made attempt to meet and confer with the party who filed the pleading
a good faith
and at least five days before the last day a motion for judgment on the
pleading was due (if am filing a demurrer
|
or motion to strike)
was unable to meet with that party because
pleadings may be filed (if am filing a motion forjudgment on the
|
pleadings). l
reasons why the parties could not meet and
(the
confer are stated):
E
I
below
sent the attached
E
letter
on form MC-031, Attached Declaration
(Exhibit A) at approximately 3 p.m. on .Augusi 30, 2021
_
was September 3rd, the (the deadline to confer
LLC ("Opposing Counsel") until
co’uhé‘elytor Jelcruzer International,
|
deadline to respond September 8th), and heard nothing from
email‘corresponc'snce (Exhibits B, C, D, E) ensued. As set forth
followed up before 9 a.m. on September 2nd. The attached
was unable or unwilling to confer by telephone before the deadline: "We are unable to conduct any
therein, Opposing Counsel
from Grant Reader, Ex. C, p. 1.) have not previously
meaningful meet and confer today." (September 3. 2021 1:35 p.m. email
|
requested an automatic extension of time in connection with the plaintiffs amended complaint, dated August 6. 2021, and
defendant Acosta has never requested an automatic extension of time
at all.
California that the information above is true and correct.
| declare under penalty of perjury under the laws of the State of
Date: 9/8/2021
R. Christopher Harshman >
W'WW’“
(NAME OF PARTY OR ATTORNEY FOR PARTY)
XfiGNATURE OF PARTY OR ATTORNEY FOR PARTY)
Page 1 of1
v
Code of Clvll Procedure,
Form Approved for Optional Use DECLA R A TION OF DEMU RRING OR MOVING PARTY §§ 430.41. 435.5. 439
Judicial Council of California wwwus-ma
CW4“ [Rwanuaw “0191 iN SUPPORT 0F AUTOMATIC EXTENSION
Document Filed Date
September 10, 2021
Case Filing Date
October 08, 2019
For full print and download access, please subscribe at https://www.trellis.law/.
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CASE ATTACHMENT COVER PAGE (ENDORSED) ELECTRONICALLY SUPERIOR COURT 0F CALIFORNIA, COUNTY OF SAN BERNARDINO FILED STREET ADDREss;247 West Third Street MAILING ADDRESS: w _ - BY SUPERIOR COURT CITY AND ZIP cope; San Bernardino, CA 92415 ‘ OF CALIFORNIA, COUNTY OF BRANCH NAME:San Bernardino Justice Center San Bernardino WEBSITEhttp //www. sb—court. org : on Sep 9, 2021 CLERK OF THE SUPERIOR COURT ATTACHMENTNAME: Declaration: of Demurring or Moving Party in Support of DepuoICIerk: Angeline Garcia Automatic Extension CASE NAME: Jetcruzer International LLC vs. Sandy Acosta et al CASE NUMBER: CIVDSl 930132 Please log on to www.TurboCourt.com regularly for updates Please staple this to your original attachment unoooqmufidyq /uloo CIV-141 ATTORNEV 0R pARTY WITHOUT ATTORNEY: STATE BAR No: 248214 FOR counr use ONLY NAME: R. Christopher Harshman HRM NAME: David M. Shaby and Associates, II APC STREET ADDRESS: 11949 Jefferson Blvd. Ste 104 elm Culver city STATE: CA ZIP cons: 90230 TELEPHONE No.: (310) 827-7171 FAX N0; (310) 822-8529 E-MAILADDRESS: charshman@shabyandassociates.com ATTORNEY FOR (Name):Acosta, Zepeda, and Guzman SUPERIOR COURT OF CALIFORNIA, COUNTY OFSan Bernardino STREET ADDRESS: 247 W. Third St. MAILING ADDRESS: CITY AND ZIP CODE: San Bernardino 92415 BRANCH NAME: San Bernardino PLAINTIFF/PETITIONER: Jetcruzer International LLC DEFENDANT/RESPONDENT: Acosta et al CASE NUMBER: DECLARATION OF DEMURRING OR MOVING(PAIRT¥ ' CND81930132 IN SUPPORT OF AUTOMATIC EXTENSION” ' Guzman. and Ulises A. Zépeda ' ' was served with 1, (Name ofparty): Sandy Acosta, Marvin J. E acomplaint E an amended complaint E across-complaint Ein an answer the above-titled action. E other (specify): a responsive pleading is due on (date): September 8. 2021 2. For a demurrer or motion to strike, DECLARATION judgment on the pleadings in this action. Before can do so. am required to l | intend to file a demurrer, motion to strike. or motion for I to at least five days before the date when the responsive meet and confer with the party who filed the pleading that am responding | judgment on the at least five days before the last day a motion for pleading is due (if am filing a demurrer or motion to strike) and l forjudgment on the pleadings). We have not been able to meet and confer. have not | pleadings may be filed (ifl am filing a motion the requirements Therefore. on timely filing and serving a declaration that meets previously requested an automatic extension of time. am entitled to an automatic 30-day extension of time within which to file a of Code of Civil Procedure sections 430.41, 435.5, or 439, I responsive pleading or motion for judgment on the pleadings. at least five days before the date the responsive l made attempt to meet and confer with the party who filed the pleading a good faith and at least five days before the last day a motion for judgment on the pleading was due (if am filing a demurrer | or motion to strike) was unable to meet with that party because pleadings may be filed (if am filing a motion forjudgment on the | pleadings). l reasons why the parties could not meet and (the confer are stated): E I below sent the attached E letter on form MC-031, Attached Declaration (Exhibit A) at approximately 3 p.m. on .Augusi 30, 2021 _ was September 3rd, the (the deadline to confer LLC ("Opposing Counsel") until co’uhé‘elytor Jelcruzer International, | deadline to respond September 8th), and heard nothing from email‘corresponc'snce (Exhibits B, C, D, E) ensued. As set forth followed up before 9 a.m. on September 2nd. The attached was unable or unwilling to confer by telephone before the deadline: "We are unable to conduct any therein, Opposing Counsel from Grant Reader, Ex. C, p. 1.) have not previously meaningful meet and confer today." (September 3. 2021 1:35 p.m. email | requested an automatic extension of time in connection with the plaintiffs amended complaint, dated August 6. 2021, and defendant Acosta has never requested an automatic extension of time at all. California that the information above is true and correct. | declare under penalty of perjury under the laws of the State of Date: 9/8/2021 R. Christopher Harshman > W'WW’“ (NAME OF PARTY OR ATTORNEY FOR PARTY) XfiGNATURE OF PARTY OR ATTORNEY FOR PARTY) Page 1 of1 v Code of Clvll Procedure, Form Approved for Optional Use DECLA R A TION OF DEMU RRING OR MOVING PARTY §§ 430.41. 435.5. 439 Judicial Council of California wwwus-ma CW4“ [Rwanuaw “0191 iN SUPPORT 0F AUTOMATIC EXTENSION