Motion,Ex Parte: LANGER'S DELICATESSEN INC VS KAREN WONG ET AL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 03/05/2019 04:38 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk




        1     STEVEN M. GARBER (SBN 156153)
              LAWRENCE M. BOESCH (SBN 114658)
        2     STEVEN M. GARBER & ASSOCIATES
              A PROFESSIONAL CORPORATION
        3     24025 PARK SORRENTO, SUITE 240
              CALABASAS, CALIFORNIA 91302
        4     Phone: (323) 777-8000
              Fax: (323) 777-3000
        5
              Attorneys for Plaintiff and Judgment Creditor
        6     LANGER’S DELICATESSEN, INC.
        7
        8                                   SUPERIOR COURT OF THE STATE OF CALIFORNIA
        9                            COUNTY OF LOS ANGELES, CENTRAL JUDICIAL DISTRICT
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      11      LANGER’S DELICATESSEN, INC., a               )                                Case No.: BC543450
              California corporation,                      )
      12                                                   )                                ASSIGNED FOR ALL PURPOSES TO
                     Plaintiff and Judgment Creditor,      )                                THE HONORABLE LIA MARTIN
      13                                                   )                                DEPARTMENT 16
                     vs.                                   )
      14                                                   )                                PLAINTIFF AND JUDGMENT
                                                           )                                CREDITOR LANGER’S DELICATESSEN,
      15      CHIEN PING LUU, aka TOM LUU, an              )                                INC.’S NOTICE OF MOTION AND
              individual; LIXIA ZHAO, aka LIXIA ZHAO )                                      MOTION FOR ORDER DETERMINING
      16      LUU, an individual; NEW SINO, INC., a        )                                THE PREVAILING PARTY ON APPEAL,
              California corporation; SINO ENTERPRISES, )                                   FIXING AMOUNT OF REASONABLE
      17      INC., a Dissolved California corporation; CL )                                ATTORNEY’S FEES ON APPEAL TO BE
              & LZ, LLC, a California limited liability    )                                AWARDED TO PLAINTIFF, AWARDING
      18      company; and DOES 2 to 100, inclusive,       )                                REASONABLE ATTORNEYS' FEES TO
                                                           )                                PLAINTIFF, AND AMENDING THE
      19                                                   )                                JUDGMENT TO INCLUDE PLAINTIFF'S
                     Defendants and Judgment Debtors.      )                                ATTORNEYS' FEES AND COSTS
      20                                                   )                                INCURRED IN THE APPEAL AND
                                                           )                                INTEREST TO-DATE; MEMORANDUM
      21                                                   )                                OF POINTS AND AUTHORITIES;
                                                           )                                DECLARATION OF STEVEN M.
      22                                                   )                                GARBER; DECLARATION OF
                                                           )                                LAWRENCE M. BOESCH
      23                                                   )
                                                           )                                DATE:          August 6, 2019
      24                                                   )                                TIME:          9:00 a.m.
                                                           )                                DEPT.:         16
      25                                                   )                                [Filed concurrently with Memorandum of
                                                           )                                Costs; a proposed Second Amended Judgment
      26                                                   )                                is being lodged concurrently]
                                                           )                                Reservation No. 374571861973
      27
      28      TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:


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                M OTION FOR ORDER DETERM INING PREVAILING PARTY ON APPEAL, FIXING THE AM OUNT
                OF ATTORNEY’S FEES TO BE AW ARDED, AND AM ENDING THE JUDGM ENT TO INCLUDE THE
                          PREVAILING PARTY'S REASONABLE ATTORNEYS' FEES AND COSTS