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L ORIGINAL V
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J. Pat Ferraris, Esq. [SBN: 267223]
JulietK Mushet, Esq. [SBN: 247968] H.Cr' “
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HOMAN STONi3&ROSSI > AWE“?
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1461 Ford Street, Suite 201
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Redlands, CA 92373 '
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Telephone: (909) 307-9380 9 4022
Facsimile: (909) 793-0210
jpfenafisGIDhOInan-stone.com
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in1ushet@homan-stone.com
Attorneys for Defendants, JEREMY DANIEL LIZAMA and ROSA LIZAMA
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
FOR THE COUNTY OF SAN BERNARDTNO
11
12
ELENO NAVARRETE, an individual, Case No.: CIVD82020372
13 Unlimited Civil Jurisdiction
14
15
VS.
Plaintiff,
STIPULATION AND [W]
ORDER
TO SET ASIDE/VACATE DEFAULT AND
COURT JUDGMENT
JEREMY DANIEL LIZAMA, an individual, ROSA
l6
LIZAMA, an individual and DOES through 25,
1 [Assigned to Honorable John M. Pacheco; Dept.
inclusive, $3 1]
l7
GZI‘IH
18' Defendants.
19
20
A8
Plaintiff ELENO NAVARRETE (“Plaintiff”), by and through her attorneys of record, Ethan
21
XV:I
22
Ysias, Esq. of The Lawyer’s Group, Inc., and Defendants JEREMY DANIEL LIZAMA and ROSA
LIZAMA (collectively, “Defendants”), by and through their attomeys ofrecord, J. Pat Fenan's, Esq. of
23
Homan, Stone & Rossi, (Plaintiff and Defendants, collectively, the “Pal“cies”) HEREBY JOINTLY
24
STIPULATE AS FOLLOWS:
25
WHEREAS, Plaintiff filed a Request for Ently of Default on March 10, 2021 as to Defendant
26
JEREMY DANIEL LIZAMA;
27
WHEREAS, Plaintiff filed a Request for Entry of Default on March IO, 2021 as to Defendant
28
-1-
STIPULATION AND [WSW] ORDER TO SET ASIDE/VACATE DEFAULT AND COURT JUDGMENT
ROSA LIZAMA;
WHEREAS, Plaintiff filed a Request for Court Judgment against Defendants 0n June 21, 2021.
WHEREAS, the Parties executed and filed a Stipulation and Proposed Order t0 Set Aside
Default 0n October 2 I ,
2021.
WHEREAS, the Parties appeared at the Case Management Conference 0n October 22, 2021
before the Honorable John M. Pacheco and informed the Court that a stipulation and order to set aside
the default judgment had been submitted, and an answer Will be filed once default is set aside. The
Court set a Trial Setting Conference for March 2 l 2022. ,
WHEREAS, the Court entered a Court Judgment against Defendants in this matter 0n November
2, 202].
WHEREAS, the Parties wish to cooperate in setting aside/vacating the Court Judgment and t0
proceed with this action,
IT IS HEREBY STIPULATED that:
1. The Parties hereby respectfully request that the Court set aside or vacate the Court Judgment
entered by the Clerk in this matter; and
2. Defendants shall be pelmitted t0 file a. responsive pleading in response t0 the Complaint in
this action within twenty (20) calendar days from the date that this Order is entered by the
Court.
IT IS SO STIPULATED.
DATED: Janualy 5, 2022
J. F(ayléerraris, Esq.
for Defendants, JEREMY DANIEL
Attomeys
LIZAMA and ROSA LIZAMA
STIPULATION AND [W] -2-
ORDER TO SET ASIDE/VACATE DEFAULT AND COURT JUDGMENT
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L ORIGINAL V ,1, p—a J. Pat Ferraris, Esq. [SBN: 267223] JulietK Mushet, Esq. [SBN: 247968] H.Cr' “ fggflf’ HOMAN STONi3&ROSSI > AWE“? 21;}; , .iE , ”(,me 1461 Ford Street, Suite 201 L " I'm ,v Jffif’O LN Redlands, CA 92373 ' m" JUN 3 Telephone: (909) 307-9380 9 4022 Facsimile: (909) 793-0210 jpfenafisGIDhOInan-stone.com w in1ushet@homan-stone.com Attorneys for Defendants, JEREMY DANIEL LIZAMA and ROSA LIZAMA SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN BERNARDTNO 11 12 ELENO NAVARRETE, an individual, Case No.: CIVD82020372 13 Unlimited Civil Jurisdiction 14 15 VS. Plaintiff, STIPULATION AND [W] ORDER TO SET ASIDE/VACATE DEFAULT AND COURT JUDGMENT JEREMY DANIEL LIZAMA, an individual, ROSA l6 LIZAMA, an individual and DOES through 25, 1 [Assigned to Honorable John M. Pacheco; Dept. inclusive, $3 1] l7 GZI‘IH 18' Defendants. 19 20 A8 Plaintiff ELENO NAVARRETE (“Plaintiff”), by and through her attorneys of record, Ethan 21 XV:I 22 Ysias, Esq. of The Lawyer’s Group, Inc., and Defendants JEREMY DANIEL LIZAMA and ROSA LIZAMA (collectively, “Defendants”), by and through their attomeys ofrecord, J. Pat Fenan's, Esq. of 23 Homan, Stone & Rossi, (Plaintiff and Defendants, collectively, the “Pal“cies”) HEREBY JOINTLY 24 STIPULATE AS FOLLOWS: 25 WHEREAS, Plaintiff filed a Request for Ently of Default on March 10, 2021 as to Defendant 26 JEREMY DANIEL LIZAMA; 27 WHEREAS, Plaintiff filed a Request for Entry of Default on March IO, 2021 as to Defendant 28 -1- STIPULATION AND [WSW] ORDER TO SET ASIDE/VACATE DEFAULT AND COURT JUDGMENT ROSA LIZAMA; WHEREAS, Plaintiff filed a Request for Court Judgment against Defendants 0n June 21, 2021. WHEREAS, the Parties executed and filed a Stipulation and Proposed Order t0 Set Aside Default 0n October 2 I , 2021. WHEREAS, the Parties appeared at the Case Management Conference 0n October 22, 2021 before the Honorable John M. Pacheco and informed the Court that a stipulation and order to set aside the default judgment had been submitted, and an answer Will be filed once default is set aside. The Court set a Trial Setting Conference for March 2 l 2022. , WHEREAS, the Court entered a Court Judgment against Defendants in this matter 0n November 2, 202]. WHEREAS, the Parties wish to cooperate in setting aside/vacating the Court Judgment and t0 proceed with this action, IT IS HEREBY STIPULATED that: 1. The Parties hereby respectfully request that the Court set aside or vacate the Court Judgment entered by the Clerk in this matter; and 2. Defendants shall be pelmitted t0 file a. responsive pleading in response t0 the Complaint in this action within twenty (20) calendar days from the date that this Order is entered by the Court. IT IS SO STIPULATED. DATED: Janualy 5, 2022 J. F(ayléerraris, Esq. for Defendants, JEREMY DANIEL Attomeys LIZAMA and ROSA LIZAMA STIPULATION AND [W] -2- ORDER TO SET ASIDE/VACATE DEFAULT AND COURT JUDGMENT