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V Gamma; v
VASILIKI AWADALLA, SBN 2655 15
LAW OFFICES OF SCHNEIDER & HOLTZ
4685 MacArthur Court, Suite 200
sup Fl L E D
NeWport Beach, CA 92660 003739589355 SERCAUFOR MA
Telephone: (949) 250-5530 SAN BERNARowo
Facsimile: (855) 880-5646
D%fi'?
File# 19-014410 MAR 1 5 2022
Awadavl @Nationwide.com
BY , x .f
Attorneys for Plaintiff, AMCO INSURANCE '
COMPANY Jhselc JOAMS, Dgp
d3!
SUPERIOR COURT OF THE STATE OF CALIFORNIA V
COUNTY OF SAN BERNARDINO rfl—j
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”-1.
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ll AMCO INSURANCE COMPANY, Case No. CIVSB2125566
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Plaintiff,
l3 DECLARATION OF VASILIKI
vs. AWADALLA IN SUPPORT OF
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DEFAULT JUDGMENT [CCP §585]
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EVERGREEN CONSTRUCTION GROUP,
INC., A CALIFORNIA CORPORATION and
l6 DOES TO 50,l
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Defendants.
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19 I, VASILIKI AWADALLA, declare as follows:
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1. I am an attorney at law duly admitted to practice before all the courts 0f the State of
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California and the attorney 0f record herein for plaintiff, AMCO INSURANCE COMPANY
[hereinafter “AMCO”] in the instant action, and I am aware of the matters stated herein of my
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own personal knowledge and if called upon and sworn I could and would competently testify as
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follows:
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2. This is an insurance subrogation action to recover reimbursement for property and
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related damages paid by plaintiff, AMCO, to or behalf of its insured, Barbara Neira, pursuant t0
26 the terms of the insurance policy.
27 3. On or about September 3, 2021, plaintiff filed a Complaint requesting damages in the
28 amount 0f $200,624.40, plus legal costs and pre-judgment interest at the rate of 7% per annum.
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DECLARATION OF VASILIKI AWADALLA IN SUPPORT OF DJP
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4. This is m_t a personal injury 0r wrongful death action for which a Statement of
Damages is required pursuant to California Code ofCivil Procedure §425.1 1, so one was not
served.
5. Defendant EVERGREEN, was served with plaintiff’s Complaint on October 15, 2021,
to the Agent for Service of Process listed on their California Secretary of State filings, and the
proof of service was sent for filing with this Court 0n or about October 26, 2021. A true and
correct copy ofthe Proof of Service is attached hereto as Exhibit A.
6. Defendant EVERGREEN, did not respond to plaintiff’s complaint, and plaintiff‘s
Request to Enter Default was submitted to the Court for filing on or about December 6, 2021.
A true and correct copy of the conformed Request is attached hereto as Exhibit B.
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7. Plaintiff’ s Request for Entry of Default and Court Judgment and CCP §585 default
judgment prove-up package is also being submitted concurrently herewith.
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8. Pre—judgment interest is requested in the amount of $7,425.85, calculated at the rate
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$38.48 per day beginning September 3, 2021 . A true and correct copy ofthe plaintiff’s pre-
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judgment interest calculation worksheet is attached hereto as Exhibit C.
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9. Costs of suit are requested in the amount 0f $509.25, broken down as follows:
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$435.00 for clerk’s filing fees and $74.25 for service fees for defendant, Evergreen. True and
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correct copies of these charges are attached hereto as Exhibit D.
l7 10. Plaintiff is now submitting its Request for Entry of Default and Court Judgment, and
18 accompanying declarations in support of a court judgment, concurrently herewith. Plaintiff
l9 requests the Court to enter judgment in favor 0f plaintiff, AMCO and against defendant,
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Evergreen, as follows, all of which are Within the jurisdictional limit 0f the Court and do not
exceed the demand amount 0f the Complaint:
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Property Damage: $ 200,624.40
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Pre-judgment interest: $ 7,425.85
23 Legal costs of suit: $ 509.25
TOTAL: $ 208,559.50
24 I declare under penalty of perjury under the laws of the State of California that the foregoing
25 is true and correct and if called as a witness I could and would competently testify thereto of my
26 own personal knowledge.
Executed this 15th day of March at Newport Beach, California.
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VASILIKI AWADALLA
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DECLARATION OF VASILIKI AWADALLA IN SUPPORT OF DJP
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V Gamma; v VASILIKI AWADALLA, SBN 2655 15 LAW OFFICES OF SCHNEIDER & HOLTZ 4685 MacArthur Court, Suite 200 sup Fl L E D NeWport Beach, CA 92660 003739589355 SERCAUFOR MA Telephone: (949) 250-5530 SAN BERNARowo Facsimile: (855) 880-5646 D%fi'? File# 19-014410 MAR 1 5 2022 Awadavl @Nationwide.com BY , x .f Attorneys for Plaintiff, AMCO INSURANCE ' COMPANY Jhselc JOAMS, Dgp d3! SUPERIOR COURT OF THE STATE OF CALIFORNIA V COUNTY OF SAN BERNARDINO rfl—j X ”-1. 10 :3 ll AMCO INSURANCE COMPANY, Case No. CIVSB2125566 12 Plaintiff, l3 DECLARATION OF VASILIKI vs. AWADALLA IN SUPPORT OF l4 DEFAULT JUDGMENT [CCP §585] 15 EVERGREEN CONSTRUCTION GROUP, INC., A CALIFORNIA CORPORATION and l6 DOES TO 50,l 17 Defendants. i8 19 I, VASILIKI AWADALLA, declare as follows: 20 1. I am an attorney at law duly admitted to practice before all the courts 0f the State of 21 California and the attorney 0f record herein for plaintiff, AMCO INSURANCE COMPANY [hereinafter “AMCO”] in the instant action, and I am aware of the matters stated herein of my 22 own personal knowledge and if called upon and sworn I could and would competently testify as 23 follows: 24 2. This is an insurance subrogation action to recover reimbursement for property and 25 related damages paid by plaintiff, AMCO, to or behalf of its insured, Barbara Neira, pursuant t0 26 the terms of the insurance policy. 27 3. On or about September 3, 2021, plaintiff filed a Complaint requesting damages in the 28 amount 0f $200,624.40, plus legal costs and pre-judgment interest at the rate of 7% per annum. 1 DECLARATION OF VASILIKI AWADALLA IN SUPPORT OF DJP \a \r 4. This is m_t a personal injury 0r wrongful death action for which a Statement of Damages is required pursuant to California Code ofCivil Procedure §425.1 1, so one was not served. 5. Defendant EVERGREEN, was served with plaintiff’s Complaint on October 15, 2021, to the Agent for Service of Process listed on their California Secretary of State filings, and the proof of service was sent for filing with this Court 0n or about October 26, 2021. A true and correct copy ofthe Proof of Service is attached hereto as Exhibit A. 6. Defendant EVERGREEN, did not respond to plaintiff’s complaint, and plaintiff‘s Request to Enter Default was submitted to the Court for filing on or about December 6, 2021. A true and correct copy of the conformed Request is attached hereto as Exhibit B. 10 7. Plaintiff’ s Request for Entry of Default and Court Judgment and CCP §585 default judgment prove-up package is also being submitted concurrently herewith. ll 8. Pre—judgment interest is requested in the amount of $7,425.85, calculated at the rate 12 $38.48 per day beginning September 3, 2021 . A true and correct copy ofthe plaintiff’s pre- l3 judgment interest calculation worksheet is attached hereto as Exhibit C. 14 9. Costs of suit are requested in the amount 0f $509.25, broken down as follows: 15 $435.00 for clerk’s filing fees and $74.25 for service fees for defendant, Evergreen. True and l6 correct copies of these charges are attached hereto as Exhibit D. l7 10. Plaintiff is now submitting its Request for Entry of Default and Court Judgment, and 18 accompanying declarations in support of a court judgment, concurrently herewith. Plaintiff l9 requests the Court to enter judgment in favor 0f plaintiff, AMCO and against defendant, 20 Evergreen, as follows, all of which are Within the jurisdictional limit 0f the Court and do not exceed the demand amount 0f the Complaint: 21 Property Damage: $ 200,624.40 22 Pre-judgment interest: $ 7,425.85 23 Legal costs of suit: $ 509.25 TOTAL: $ 208,559.50 24 I declare under penalty of perjury under the laws of the State of California that the foregoing 25 is true and correct and if called as a witness I could and would competently testify thereto of my 26 own personal knowledge. Executed this 15th day of March at Newport Beach, California. 27 28 VASILIKI AWADALLA 2 DECLARATION OF VASILIKI AWADALLA IN SUPPORT OF DJP