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  • GERALDINE CANNON VS KIRSTEN DARLEY ET AN Other Commercial/Business Tort (not fraud/ breach of contract) (General Jurisdiction) document preview
  • GERALDINE CANNON VS KIRSTEN DARLEY ET AN Other Commercial/Business Tort (not fraud/ breach of contract) (General Jurisdiction) document preview
						
                                

Preview

FILED Superior Court of Califomia ounty of Los Angeles CURD, GALINDO & SMITH, L.L.P. JOSEPH D. CURD, SBN 115764 301 East Ocean Boulevard, Suite 1700 JAN"1 22018 Long Beach, CA 90802 Shi err] (Clerk Telephone: (562) 624-1177 Deputy Facsimile: (562) 624-1178 Gomez Attorneys for Plaintiff SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES - CENTRAL DISTRICT GERALDINE CANNON, an individual; Case No.: BC650743 Reservation No.: 180106279491 10 Plaintiffs NOTICE OF MOTION AND MOTION FOR MW vs. ENFORCEMENT OF SETTLEMENT PURSUANT TO CCP §664.6 12 KIRSTEN DARLEY, individually and as Trustee of the DARLEY FAMILY TRUST, [Declarations of Joseph D. Curd and Geraldine 13 DATED JULY 8, 2004; CASHCALL, INC., a ) Cannon filed concurrently herewith] Boo California corporation; WELLS FARGO ) Ser se s 14 BANK, NATIONAL ASSOCIATION, a ) Date: February 6, 2018 tdey National Association; and DOES 1 through 10,) Time: 8:30 a.m. Osa 15 inclusive, Dept.: 50 en Sag sos BAD aor 16 Defendants. op ead ) [Unlimited Civil Action] 17 18 TO THE INTERESTED PARTIES AND TO THEIR ATTORNEYS OF RECORD: 19 PLEASE NOTICE that on February 6, 2018 at 8:30 a.m. in Department 50 the above 20 entitled court, located at 111 N. Hill St., Los Angeles CA 90012, Plaintiff Geraldine Cannon wil 21 and hereby does move this Court for: 22 qd) An Order that Defendant Kirsten Darley is to sign the $2,548.48 check made 23 payable to Geraldine Cannon and Kirsten Darley over to Plaintiff Geraldine Cannon as 24 Defendant has no interest in the check. Or, in the alternative, an Order that Defendant is to pay 25 Plaintiff the amount of the check, and Plaintiff will sign the check over to Defendant. be 26 (2) An Order that Defendant Kirsten Darley is to stop using the Google Ad account = 27 that is associated with the ACT Bookkeeping name. Further, Plaintiff seeks an order that Kirsten] 28 Darley is to shut down the Google Ad account that is associated with the ACT Bookkeeping 1 Notice of Motion to Enforce Settlement Agreement Pursuant to CCP §664.6 Points and Authorities