On August 23, 2018 a
Motion-Secondary
was filed
involving a dispute between
Henry, Billy C,
Sunrise Ford Inc A California Corporation,
and
Bruncati, Daniel,
Bruncati, James,
Bruncati, Robert,
Does 2 Through 50,
Ford Motor Company,
Ford Motor Credit Company,
Sunrise Ford, Inc.,
for Business Tort
in the District Court of San Bernardino County.
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ATTORNEY 0R PARTY WITHOUT ATrORNEY: ClV-1 41
STATE BAR No: 320504 FOR COURT USE ONLY
NAMEzJiwon Michael Shin, Esq.
Callahan Thompson Sherman
FIRM NAME: & Caudil], LLP
STREEr ADDREss:2601 Main Street, Ste. 800 3..
CITY: Irvine
TELEpHoNE No; 949-261-2872
STATECA zn= CODE:92614 SUPER’ORpEO'UR E
:Ax No; 949-261-6060 CQUNTY or. s AT, gEFFgAUFORMA
E-MAIL M AN
ADDRESS:mshin@ctsclaw.com BERNAFDINO DIS/firfilbégo
ATTORNEY FOR (Name): Sunrise Ford, Inc.
SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F SAN BERNARDINO APR
‘
'
1 l 2022
STREEr ADDRESS 247 West Third
Street
MAILING ADDRESS: 247 West Third Street 1”!"
CITY AND ZIP CODE: San Bemardino, 92415-02 1 0
:
3y
f
BRANCH NAME San Bemardino District - Civil Division 33 ‘ L K D'AM’CO'
PLAINTIFF/PETITIONER: Billy C. Henry
DEPUTY
DEFENDANT/RESPONDENT: Sunrise Ford, Inc., et al.
DECLARATION 0F DEMURRING 0R MOVING PARTY ”SENUMBER
IN SUPPORT 0F AUTOMATIC EXTENSION CIVDs1822222
1. (Name ofparty): Sunrise Ford, Inc. was sewed with
E a complaint D an amended complaint
D a cross-complaint
Ein
an answer
the above-titled action.
Other (SPeC/fl’)-'Amendment to Complaint re DOE 1
2. For a demurrer or motion to strike, a responsive pleading due on
is (date).'April 12, 2022
DECLARATION
intend to file a demurrer, motion to strike, or motion forjudgment on the pleadings
l
in this action. Before can do so, am required to I |
meet and confer with the party who filed the pleading that am responding to at least five |
days before the date when the responsive
pleading is due (ifl am filing a demurrer or motion to strike) and at least five
days before the last day a motion for judgment on the
pleadings may be filed (ifl am filing a motion forjudgment on the pleadings). We
have not been able to meet and confer. have not l
previously requested an automatic extension of fime. Therefore, on timely filing and serving
a declaration that meets the requirements
of Code of Civil Procedure sections 430.41, 435.5, or 439, am entitled to an automatic 30-day extension of time within which to file a
|
responsive pleading or motion forjudgment on the pleadings.
| made a good
faith attempt to meet and confer with the party who filed the pleading
at least five days before the date the responsive
pleading was due (ifl am filing a demurrer or motion to strike) and at least five days before the last day a motion for
judgment on the
pleadings may be filed (ifl am filing a motion for judgment on the pleadings). Iwas unable to
meet with that party because
(the reasons why the pan‘ies could not meet and confer are stated):
m below E on form MC-031, Attached Declaration
We have not been able to meet and confer with Plaintiff because we have hot yet completed our analysis of
the Amendment to Complaint.
Datei 4/1 1/2022
Jiwon Michael Shin, Esq. >
(NAME or: PARTV 0R ATTORNEY FOR PARTY) (sweNATUREK:
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Document Filed Date
April 11, 2022
Case Filing Date
August 23, 2018
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ATTORNEY 0R PARTY WITHOUT ATrORNEY: ClV-1 41 STATE BAR No: 320504 FOR COURT USE ONLY NAMEzJiwon Michael Shin, Esq. Callahan Thompson Sherman FIRM NAME: & Caudil], LLP STREEr ADDREss:2601 Main Street, Ste. 800 3.. CITY: Irvine TELEpHoNE No; 949-261-2872 STATECA zn= CODE:92614 SUPER’ORpEO'UR E :Ax No; 949-261-6060 CQUNTY or. s AT, gEFFgAUFORMA E-MAIL M AN ADDRESS:mshin@ctsclaw.com BERNAFDINO DIS/firfilbégo ATTORNEY FOR (Name): Sunrise Ford, Inc. SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F SAN BERNARDINO APR ‘ ' 1 l 2022 STREEr ADDRESS 247 West Third Street MAILING ADDRESS: 247 West Third Street 1”!" CITY AND ZIP CODE: San Bemardino, 92415-02 1 0 : 3y f BRANCH NAME San Bemardino District - Civil Division 33 ‘ L K D'AM’CO' PLAINTIFF/PETITIONER: Billy C. Henry DEPUTY DEFENDANT/RESPONDENT: Sunrise Ford, Inc., et al. DECLARATION 0F DEMURRING 0R MOVING PARTY ”SENUMBER IN SUPPORT 0F AUTOMATIC EXTENSION CIVDs1822222 1. (Name ofparty): Sunrise Ford, Inc. was sewed with E a complaint D an amended complaint D a cross-complaint Ein an answer the above-titled action. Other (SPeC/fl’)-'Amendment to Complaint re DOE 1 2. For a demurrer or motion to strike, a responsive pleading due on is (date).'April 12, 2022 DECLARATION intend to file a demurrer, motion to strike, or motion forjudgment on the pleadings l in this action. Before can do so, am required to I | meet and confer with the party who filed the pleading that am responding to at least five | days before the date when the responsive pleading is due (ifl am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the pleadings may be filed (ifl am filing a motion forjudgment on the pleadings). We have not been able to meet and confer. have not l previously requested an automatic extension of fime. Therefore, on timely filing and serving a declaration that meets the requirements of Code of Civil Procedure sections 430.41, 435.5, or 439, am entitled to an automatic 30-day extension of time within which to file a | responsive pleading or motion forjudgment on the pleadings. | made a good faith attempt to meet and confer with the party who filed the pleading at least five days before the date the responsive pleading was due (ifl am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the pleadings may be filed (ifl am filing a motion for judgment on the pleadings). Iwas unable to meet with that party because (the reasons why the pan‘ies could not meet and confer are stated): m below E on form MC-031, Attached Declaration We have not been able to meet and confer with Plaintiff because we have hot yet completed our analysis of the Amendment to Complaint. Datei 4/1 1/2022 Jiwon Michael Shin, Esq. > (NAME or: PARTV 0R ATTORNEY FOR PARTY) (sweNATUREK: w PA¥Y 0R ATTORNEY POW Page1 of1 jgggiglpgfuvneglgrgafigggfiyse DECLARATION 0F DEMURRING 0R MOVING PARTY Cogggmjgoscgéggeé C'V-W IR" Jaw 1r 2°19] IN SUPPORT 0F AUTOMAnc EXTENSION Wanawvggcwfgggggmr 6 gs; aw G 1.4 6am © gfi» V W T7 fl Tn o V y ?;‘g *’ m q- ‘ 9.2%?” 3% 2% 9% A ‘9‘” @ fl“ x, p