Motion-Secondary: xxxxxxxxxx VS xxxxxx xxxxxxx ET AL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 05/20/2021 05:00 PM Sherri R. Carter, Executive Officer/Clerk of Court, by R. Perez,Deputy Clerk




                         1     Paul B. Hundley (SBN 173189)
                               The Hundley Law Firm
                         2     6080 Center Drive, Suite 600
                               Los Angeles, California 90045
                         3     Telephone: (310) 242-5541
                               Facsimile: (424) 309-5642
                         4
                               Attorney Specially Appearing
                         5     for Defendants xxxxxx xxxxxxx
                               and xxxxxx xxxxxxxxxx
                         6

                         7

                         8                    SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES,

                         9                                                   STANLEY MOSK COURTHOUSE
                       10

                       11
                                xxxxxxxxxx,                                                                ) Case No . BC699586
                       12                                                                                  )
                                                             Plaintiff                                     ) EX PARTE APPLICATION FOR
                       13                                                                                  ) ORDER TO CONTINUE DEBTOR
                       14
                                    vs.
                                                                                                           j EXAMINATIONS;SUPPORTING
                                SHARONJOHNSON, xxxxxx                                                      ) DECLARATIONS [PROPOSED
                       15       xxxxxxxxxx, et al. ,                                                       ) ORDER FILED CONCURRENTLY]
                                                                                                           )
                       16                                      Defendants.                                 ) Date: May 24, 2021
                                                                                                           ) Time: 8:30 a.m.
                       17                                                                                  ) Dept. 19
                       18

                       19                 TO PLAINTIFF AND HER ATTORNEYS OF RECORD:

                       20                 PLEASE TAKE NOTICE that on May 24, 2021at8 :30 a.m. or as soon thereafter as the

                       21      matter may be heard, in Department 19 of the above-entitled court, located at 111 N Hill St, Los

                       22      Angeles, CA 90012 - Stanley Mosk Courthouse, Defendants xxxxxx xxxxxxx and xxxxxx

                       23      xxxxxxxxxx will move the court via ex parte application for an order continuing their debtor

                       24      examinations that are currently scheduled for May 24, 2021 and June 6, 2021 , repectively. Good
                       25      cause exists for this ex parte application as Defendant xxxxxx xxxxxxx is out of the State on May

                       26      24, 2021 on a prepaid vacation. Further, Defendants are willing and are actively working to enter

                       27      an agreement with Plaintiff for the payment of the judgment by making substantial monthly

                       28      payments until the judgement is paid so that the debtor examinations should not be required.


                                                                                                        1.
                                                         EX PARTE APPLICATION TO CONTINUE DEBTOR EXAMINATIONS