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CIV-1 00
ATrORNEY 0R pARTY WITHOUT ATTORNEY: STATE BAR ND: FOR cm,” USE ONLY
NAME:Susan K Hatmaker 172543/ Danielle N‘ Kjar 291481
HRM Hatmaker Law Group, A Professional Corporation
NAME:
STREET ADDRESS: 7522 N. Colonial Avenue, Ste. 105
E-FILED
STATE CA 93711
ZIP cone:
1/15/2019 11:46 AM
CITY:Fresno
TELEPHONE Nu:(559) 374-0077 FAXNO‘:(559) 374-0078 FRESNO COUNTY SUPERIOR COURT
susan@hatmakerlaw.com
E-MAILADnRess: By: M.Sanchez, Deputy
Plaintiff Olam Americas,
ATrORNEY FOR (name): Inc.
SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F FRESNO
STREET ADDRESS:1130 "O" Street
MAILING ADDRESS:
1130 "O" Street
AND ZIP CODE:
CITY Fresno, CA 93721
BRANCH NAME: Civil Department/ Central Division
Olam Americas.
Plaintiff/Petitioner: Inc.
Defendant/Respondent: William Lee Robinson
REQUEST FOR
(Application)
E Entry of Default
CourtJudgment
E Clerk's Judgment
CASE NUMBER:
17CECGO4157
Not for use in actions under the Fair Debt Buying Practices Act (Civ. Code, § 1788.50 et seq.) (see C/V-105)
1. TO THE CLERK: On the complaint or cross-complaint filed
a. on (date):Dec 5, 2017
b. by (name): Olam Americas. Inc,
c. Enter default of defendant (names):
William Lee Robinson
d. irequest a courtjudgment under Code of Procedure sections
Civil 989. eta, against defendant
585(k)), 585(c),
(names):
William Lee Robinson
(Testimony required. Apply to the clerk for a hearing
date,unless the court enter a judgment on
will an under
affidavit
e. EE
(1)
Code CivA Proc.,
§ 585(d).)
Enter clerk’s judgment
premises only and issue a writ of execution on the judgment. Code of Civil Procedure section
for restitution of the
E Proc
1174(c) does not apply. (Code Civ
Include'In the judgment all tenants
Prejudgmem‘ Claim ofRight lo
§ 1169.)
subtenants named claimants
Possession was sewed Incompliance with Code ofCivil
The
and other occupants of the premises
Procedure section
415. 46.
(2)E under Code of
reverse (item
Civil
5).)
Procedure section 585(3). (Complete the declaration under Code § 585.5 on
Clv. Proc., the
.
(3) E: on
for default previously entered (date):
2. Judgment to be entered. Amount Cteditsa kndowledge Balance
a. Demand of complaint ............. $ 0 $ 0 $ D
b. Statement of damages“
(1)Special .................... $ $ 0 $
(2)General .................... $ 0 $ 0 $
c. Interest........................ $ 0 $ 0 $ O
d. Costs (see reverse) .............. $ 16,832.40 $ 0 $ 16,832.40
e. Attorney fees ................... $ 74,181.75 $ 0 $ 74,181.75
f 91 O14 15 $ 0 $ 91'014'15
Injunction- S’e‘e'AftééIirhéfit‘A$
eonEAaL—esnt
g. Dailydamages were demanded Incomplaint at the rate
of: $ O. 00 per day beginning (date):
(” Code
Personal Injury or wrongful death actions, Civ. Proc.§ 425. 1 1 )
3. [j (Checklffi/ed In an unlawful detainer case.) Legal document assistant or unlawful detainar assistant information
ison the
reverse (complete item
4).
Date: Jan 15,2019
Robert W. Branch ’ /s/Robert W. Branch
(TYPE 0R PRINT NAME) 0R ArroRNEY FOR
(SIGNATURE oF PwNTIFF PLAINTIFF)
FOR COURT
USE ONLY
(1)
(2)
E
E Default entered as requested on
DefaultNOT entered
(date):
as requested (state reason):
Clerk, by ,
Deputy Page1 uf2
5*
5:32;“;5521rurftvxmuw REQUESTFORENTRY OFDEFAULT
201E)
GIV71OOIReV- January
1. (Application to Enter Default)
CIV-1 00
CASE NUMBER:
Am 61103
'
v - -~
.
01am
Plalntlff/Petltloner. I n0
_
,
_ 17CECG041 57
I -
DefendanflReSPondenti Wllham Lee Robinson
Legal document assistant or unlawful detainer assistant (Bus. & Prof. Code, § 6400 et seq.). A
legal document assistant or
4.
E
unlawful detainer assistant
received any help
did E did not forcompensation
document assistant
or advice for pay from a legal
give adviceor assistancewith this form. If declarant has
or unlawful detainer assistant, state:
a. name:
Assistant's c. Telephone no.2
b. Street address, and
city, zip code: d. County of registration:
e. Registration no.:
f. Expires on (date):
5, Declaration under Code under Code
Civ. Proc., § 585.5 (for entry of default Civ. Proc.,
§585(a)). This action
a. E is isnot goods or services subject
on a contract or installment sale
for to Civ‘Code. § 1801 et seq. (Unruh
Act).
b. D is isnot on a conditional sales contract subjectto
and Finance Act).
Civ.Code, § 2981 et seq. (Rees-Levering Motor Vehicle Sales
c. E is isnot Code Civ. Proc., § 395(b).
on an obligation for goods. services, loans. or extensions of credit subject to
Request for Entry ofDefau/t was
A copy of this
Declaration of mailing (Code Civ. Proc., § 587).
6.
a.
E not mailed whose addresses
to the following defendants, are unknown to plaintiff or plaintiffs attorney (names):
b. E to each defendant's last known address as follows:
toeach defendant‘s attorney of record
mailed first—class, postage prepaid, in a sealed envelope addressed or, none,
if
(1) Mailed on (date):Jan 15. 2019 (2) To (specifynames and addresses shown on the envelopes):
and by Email on Jan. 15,219 See attached Proof of Service
items 4, and 6 aretrueand correct.
declare under penalty of perjury under the laws ofthe State of California that the foregoing
5,
l
Date: January 15, 2019
Christine Tej eda
Christine Tejeda } /s/
DR PRINT NAME)
(TYPE (SIGNATURE OF DECLARANT)
of costs (required ifmoneyjudgment requested). Costs and disbursements are as follows (Code
Civ. Proc..
7. Memorandum
§ 1033.5):
$ 684.26
'.
a. Clerk's filing fees.................. .
b. Process server‘s fees ................. $ 14,469.08
c_ Other (speciM: See Attachment A $
d. See Dec. D
of Hatmaker, Exhibit -other cost $ 1,697.06
e. TOTAL ............................. $ 16,832.40
f.
g.
D
lam
Costs and disbursements are waived.
my knowledge and
the attorney, agent, or party who claims these costs. To the best of
memorandum
belief this of costsis
and these costs were necessarily incurred in this case.
correct
trueand correct
declare under penalty of perjury under the laws of the State of California that the foregoing
is
I
Date: January 15.2019
Robert W. Branch } /s/Robert W. Branch
OR PRNT NAME)
(TYPE (SIGNATURE 0F DECLARANT)
of the application is in the military
8. Declaration of nonmilitary status (required for a judgment). No defendant named in item 1c
U.S.C. App. § 391 1(2). or California Military and
service as that term is defined by either the Servicemembers Civil Relief Act, 50
Veterans Code section 400(b).
trueand correct.
declare under penalty of perjury under the laws of the State of California that the foregoing
is
I
Date: January 15,2019 V
Robert W. Branch
Robert w, Branch > /s/
(IYPEOR PRINT NAME) (SIGNATURE 0F DECLARANT)
”95“”
C'V'WOIREV' January 1-2013] REQUEST FOR ENTRY 0F DEFAULT
(Application to Enter Default)
ATTACHMENT A
#035.)
ORDERED Plaintiff’s request for Permanent Injunction is granted. Defendant
IT IS that
and persons acting with
WILLIAM LEE ROBINSON (“Defendant”) and his employees, agents,
him, 01‘on his behalf, are pelmanently restrained and enj oined from:
\IO\UI
Disclosing, sharing, divulging, making known, copying, possessing or
(1)
divulging any of The confidential, trade secret, proprietary information of
Plaintiff, and/or its subsidiaries, to any business or individual, including
usernames and passwords;
10 employees’,
Accessing Plaintiff‘s, including its subsidiaries’ and
(2)
computers, networks, servers and computer systems and using, copying,
11
taking, erasing, deleting or overwriting any data or information; and/or
12
Destroying, deleting, erasing, or corrupting any property, data, codes,
(3)
13
software, or technical information taken, obtained, copied, or deleted flom
and/or its subsidiaries.
14
15
16 Dated:
JUDGE DONALD BLACK
17 OF THE SUPERIOR COURT
18
19
20
21
22
23
24
25
26
27
28
Hatmaker Law Group
751: N. CoLoNIALAvmuE
1
SUITE :n;
FRESNO, CA 33711
[PROPOSED] ORDER GRANTING PLAINTIFF’S PRELTMTNARY LNJUNCTION
PROOF OF SERVICE
Colonial Avenue, Suite Fresno, California
My business address is 7522 N. 105,
9371 1. I am employed in Fresno County, California. I am over the age of 18 years and am not
a party t0 this case.
On the date indicated below, I served the foregoing document described as
\OOOQQU‘IAWNH
REQUEST FOR COURT JUDGEMENT
action by placing a true copy thereof enclosed in sealed
0n all interested parties in this
envelopes addressed as follows:
William Lee Robinson By Email on 01/15/19
3 149 29th Street, Apt. D8 By U.S. Mail 0n 01/15/19
Astoria, NY 11106
Ph: (415) 996-7578
Email: wleel'obins0n@gmail.com
- and -
William Lee Robinson
87—11 57th Road
Elmhurst, NY 11373
x (BY FIRST CLASS MAIL)I am readily familiar with the business' practice for
collection and processing of correspondence for mailing, and that correspondence,
postage thereon prepaid, will be deposited with the United States Postal
with fully
Service on the date noted above in the ordinary course 0f business, at Fresno,
California.
X (BY ELECTRONIC
NNNNNNNNNI—Ir—IHHHHp—dp—Ay—Ap—a
TRANSMISSION) I caused the above-referenced document to
be sent to the person(s) at the e-mail address(es) of the addressee(s) 0n the date stated
mflmmbWN—‘OOWQQU‘IAUJNHO
thereon. I did not receive, within a reasonable time after the transmission, any
electronic message or other indication that the transmission was unsuccessful. The
electric notification address of the person making' the service is
christine@hatmakerlaw.com.
EXECUTED ON January 15, 2019, at Fresno, California.
x (STATE) I declare under penalty of perjury under the laws of the State of
California that the foregoing is true and correct.
/s/ Christine Teieda
CHRISTINE TEJEDA
PROOF 0F SERVICE
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CIV-1 00 ATrORNEY 0R pARTY WITHOUT ATTORNEY: STATE BAR ND: FOR cm,” USE ONLY NAME:Susan K Hatmaker 172543/ Danielle N‘ Kjar 291481 HRM Hatmaker Law Group, A Professional Corporation NAME: STREET ADDRESS: 7522 N. Colonial Avenue, Ste. 105 E-FILED STATE CA 93711 ZIP cone: 1/15/2019 11:46 AM CITY:Fresno TELEPHONE Nu:(559) 374-0077 FAXNO‘:(559) 374-0078 FRESNO COUNTY SUPERIOR COURT susan@hatmakerlaw.com E-MAILADnRess: By: M.Sanchez, Deputy Plaintiff Olam Americas, ATrORNEY FOR (name): Inc. SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F FRESNO STREET ADDRESS:1130 "O" Street MAILING ADDRESS: 1130 "O" Street AND ZIP CODE: CITY Fresno, CA 93721 BRANCH NAME: Civil Department/ Central Division Olam Americas. Plaintiff/Petitioner: Inc. Defendant/Respondent: William Lee Robinson REQUEST FOR (Application) E Entry of Default CourtJudgment E Clerk's Judgment CASE NUMBER: 17CECGO4157 Not for use in actions under the Fair Debt Buying Practices Act (Civ. Code, § 1788.50 et seq.) (see C/V-105) 1. TO THE CLERK: On the complaint or cross-complaint filed a. on (date):Dec 5, 2017 b. by (name): Olam Americas. Inc, c. Enter default of defendant (names): William Lee Robinson d. irequest a courtjudgment under Code of Procedure sections Civil 989. eta, against defendant 585(k)), 585(c), (names): William Lee Robinson (Testimony required. Apply to the clerk for a hearing date,unless the court enter a judgment on will an under affidavit e. EE (1) Code CivA Proc., § 585(d).) Enter clerk’s judgment premises only and issue a writ of execution on the judgment. Code of Civil Procedure section for restitution of the E Proc 1174(c) does not apply. (Code Civ Include'In the judgment all tenants Prejudgmem‘ Claim ofRight lo § 1169.) subtenants named claimants Possession was sewed Incompliance with Code ofCivil The and other occupants of the premises Procedure section 415. 46. (2)E under Code of reverse (item Civil 5).) Procedure section 585(3). (Complete the declaration under Code § 585.5 on Clv. Proc., the . (3) E: on for default previously entered (date): 2. Judgment to be entered. Amount Cteditsa kndowledge Balance a. Demand of complaint ............. $ 0 $ 0 $ D b. Statement of damages“ (1)Special .................... $ $ 0 $ (2)General .................... $ 0 $ 0 $ c. Interest........................ $ 0 $ 0 $ O d. Costs (see reverse) .............. $ 16,832.40 $ 0 $ 16,832.40 e. Attorney fees ................... $ 74,181.75 $ 0 $ 74,181.75 f 91 O14 15 $ 0 $ 91'014'15 Injunction- S’e‘e'AftééIirhéfit‘A$ eonEAaL—esnt g. Dailydamages were demanded Incomplaint at the rate of: $ O. 00 per day beginning (date): (” Code Personal Injury or wrongful death actions, Civ. Proc.§ 425. 1 1 ) 3. [j (Checklffi/ed In an unlawful detainer case.) Legal document assistant or unlawful detainar assistant information ison the reverse (complete item 4). Date: Jan 15,2019 Robert W. Branch ’ /s/Robert W. Branch (TYPE 0R PRINT NAME) 0R ArroRNEY FOR (SIGNATURE oF PwNTIFF PLAINTIFF) FOR COURT USE ONLY (1) (2) E E Default entered as requested on DefaultNOT entered (date): as requested (state reason): Clerk, by , Deputy Page1 uf2 5* 5:32;“;5521rurftvxmuw REQUESTFORENTRY OFDEFAULT 201E) GIV71OOIReV- January 1. (Application to Enter Default) CIV-1 00 CASE NUMBER: Am 61103 ' v - -~ . 01am Plalntlff/Petltloner. I n0 _ , _ 17CECG041 57 I - DefendanflReSPondenti Wllham Lee Robinson Legal document assistant or unlawful detainer assistant (Bus. & Prof. Code, § 6400 et seq.). A legal document assistant or 4. E unlawful detainer assistant received any help did E did not forcompensation document assistant or advice for pay from a legal give adviceor assistancewith this form. If declarant has or unlawful detainer assistant, state: a. name: Assistant's c. Telephone no.2 b. Street address, and city, zip code: d. County of registration: e. Registration no.: f. Expires on (date): 5, Declaration under Code under Code Civ. Proc., § 585.5 (for entry of default Civ. Proc., §585(a)). This action a. E is isnot goods or services subject on a contract or installment sale for to Civ‘Code. § 1801 et seq. (Unruh Act). b. D is isnot on a conditional sales contract subjectto and Finance Act). Civ.Code, § 2981 et seq. (Rees-Levering Motor Vehicle Sales c. E is isnot Code Civ. Proc., § 395(b). on an obligation for goods. services, loans. or extensions of credit subject to Request for Entry ofDefau/t was A copy of this Declaration of mailing (Code Civ. Proc., § 587). 6. a. E not mailed whose addresses to the following defendants, are unknown to plaintiff or plaintiffs attorney (names): b. E to each defendant's last known address as follows: toeach defendant‘s attorney of record mailed first—class, postage prepaid, in a sealed envelope addressed or, none, if (1) Mailed on (date):Jan 15. 2019 (2) To (specifynames and addresses shown on the envelopes): and by Email on Jan. 15,219 See attached Proof of Service items 4, and 6 aretrueand correct. declare under penalty of perjury under the laws ofthe State of California that the foregoing 5, l Date: January 15, 2019 Christine Tej eda Christine Tejeda } /s/ DR PRINT NAME) (TYPE (SIGNATURE OF DECLARANT) of costs (required ifmoneyjudgment requested). Costs and disbursements are as follows (Code Civ. Proc.. 7. Memorandum § 1033.5): $ 684.26 '. a. Clerk's filing fees.................. . b. Process server‘s fees ................. $ 14,469.08 c_ Other (speciM: See Attachment A $ d. See Dec. D of Hatmaker, Exhibit -other cost $ 1,697.06 e. TOTAL ............................. $ 16,832.40 f. g. D lam Costs and disbursements are waived. my knowledge and the attorney, agent, or party who claims these costs. To the best of memorandum belief this of costsis and these costs were necessarily incurred in this case. correct trueand correct declare under penalty of perjury under the laws of the State of California that the foregoing is I Date: January 15.2019 Robert W. Branch } /s/Robert W. Branch OR PRNT NAME) (TYPE (SIGNATURE 0F DECLARANT) of the application is in the military 8. Declaration of nonmilitary status (required for a judgment). No defendant named in item 1c U.S.C. App. § 391 1(2). or California Military and service as that term is defined by either the Servicemembers Civil Relief Act, 50 Veterans Code section 400(b). trueand correct. declare under penalty of perjury under the laws of the State of California that the foregoing is I Date: January 15,2019 V Robert W. Branch Robert w, Branch > /s/ (IYPEOR PRINT NAME) (SIGNATURE 0F DECLARANT) ”95“” C'V'WOIREV' January 1-2013] REQUEST FOR ENTRY 0F DEFAULT (Application to Enter Default) ATTACHMENT A #035.) ORDERED Plaintiff’s request for Permanent Injunction is granted. Defendant IT IS that and persons acting with WILLIAM LEE ROBINSON (“Defendant”) and his employees, agents, him, 01‘on his behalf, are pelmanently restrained and enj oined from: \IO\UI Disclosing, sharing, divulging, making known, copying, possessing or (1) divulging any of The confidential, trade secret, proprietary information of Plaintiff, and/or its subsidiaries, to any business or individual, including usernames and passwords; 10 employees’, Accessing Plaintiff‘s, including its subsidiaries’ and (2) computers, networks, servers and computer systems and using, copying, 11 taking, erasing, deleting or overwriting any data or information; and/or 12 Destroying, deleting, erasing, or corrupting any property, data, codes, (3) 13 software, or technical information taken, obtained, copied, or deleted flom and/or its subsidiaries. 14 15 16 Dated: JUDGE DONALD BLACK 17 OF THE SUPERIOR COURT 18 19 20 21 22 23 24 25 26 27 28 Hatmaker Law Group 751: N. CoLoNIALAvmuE 1 SUITE :n; FRESNO, CA 33711 [PROPOSED] ORDER GRANTING PLAINTIFF’S PRELTMTNARY LNJUNCTION PROOF OF SERVICE Colonial Avenue, Suite Fresno, California My business address is 7522 N. 105, 9371 1. I am employed in Fresno County, California. I am over the age of 18 years and am not a party t0 this case. On the date indicated below, I served the foregoing document described as \OOOQQU‘IAWNH REQUEST FOR COURT JUDGEMENT action by placing a true copy thereof enclosed in sealed 0n all interested parties in this envelopes addressed as follows: William Lee Robinson By Email on 01/15/19 3 149 29th Street, Apt. D8 By U.S. Mail 0n 01/15/19 Astoria, NY 11106 Ph: (415) 996-7578 Email: wleel'obins0n@gmail.com - and - William Lee Robinson 87—11 57th Road Elmhurst, NY 11373 x (BY FIRST CLASS MAIL)I am readily familiar with the business' practice for collection and processing of correspondence for mailing, and that correspondence, postage thereon prepaid, will be deposited with the United States Postal with fully Service on the date noted above in the ordinary course 0f business, at Fresno, California. X (BY ELECTRONIC NNNNNNNNNI—Ir—IHHHHp—dp—Ay—Ap—a TRANSMISSION) I caused the above-referenced document to be sent to the person(s) at the e-mail address(es) of the addressee(s) 0n the date stated mflmmbWN—‘OOWQQU‘IAUJNHO thereon. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. The electric notification address of the person making' the service is christine@hatmakerlaw.com. EXECUTED ON January 15, 2019, at Fresno, California. x (STATE) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. /s/ Christine Teieda CHRISTINE TEJEDA PROOF 0F SERVICE