On April 20, 2023 a
Hearing
was filed
involving a dispute between
Mv Cal, Llc,,
and
Does 1 Through 20, Inclusive,
Levi, Nickolay R.,
for CONTRACT/WARRANTY
in the District Court of San Francisco County.
Preview
DEPARTMENT: 505
1 George M. Lee (SBN 172982) Hearing: 11/29/2023 9:00 am
gml@seilerepstein.com
2 SEILER EPSTEIN LLP ELECTRONICALLY
4 Embarcadero Center, 14th Floor
3 San Francisco, California 94111 FILED
Phone: (415) 979-0500 Superior Court of California,
County of San Francisco
4 Fax: (415) 979-0511
08/29/2023
5 Attorneys for Plaintiff Clerk of the Court
MV CAL, LLC BY: STACY GEE
Deputy Clerk
6
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 IN AND FOR THE COUNTY OF SAN FRANCISCO
9 MV CAL, LLC, a California limited liability Case No. CGC 23-606008
10 company,
NOTICE OF HEARING ON PLAINTIFF’S
11 Plaintiff, REQUEST FOR ENTRY OF DEFAULT
JUDGMENT
12
vs.
13 [CCP § 585]
SEILER EPSTEIN LLP
14 NICKOLAY R. LEVI, an individual Date: _________
Attorneys at Law
a/k/a NICK LEVY, DDS, et al., Time: _________
15
Dept.: 505
16 Defendants.
17
18 TO DEFENDANT NICKOLAY R. LEVI, an individual a/k/a NICK LEVY, DDS:
19 PLEASE TAKE NOTICE that on _____________________________, at _____ a.m./p.m.,
20 or as soon thereafter as the matter may be heard in Department 505 of the above-captioned court,
21 Plaintiff MV CAL, LLC (“Plaintiff”) will and hereby does move the court for entry of default
22 judgment against Defendant NICKOLAY R. LEVI, an individual a/k/a NICK LEVY, DDS
23 (“Defendant”), pursuant to Cal. Code Civ. Pro. § 585. By and through this motion, Plaintiff requests
24
that a default judgment be entered against the named Defendant in the principal amount of
25
$94,759.79.
26
Plaintiff also seeks to recover, and hereby moves for pre-judgment interest in the amount of
27
$5,560.97, attorneys’ fees pursuant to contract in the amount of $9,495.00, and costs in the amount
28
of $1,589.69, to be added to the judgment, as set forth in the supporting declaration of counsel.
-1-
NOTICE OF MOTION AND MOTION FOR ENTRY OF DEFAULT JUDGMENT
CASE NO. CGC 23-606008
1 In support of said motion, Plaintiff will rely upon this notice of motion and motion, the
2 Request for Entry of Default Judgment form (Jud. Council Form CIV-100) filed herewith, the
3 supporting memorandum of points and authorities, the supporting declarations of counsel and of
4 Mark Seiler, and all exhibits thereto, the complete records of the court pertaining to this action, all
5 other matters of which the court may take judicial notice, and any other such evidence and
6 argument that the court may consider upon hearing this matter.
7 Dated: August 29, 2023 SEILER EPSTEIN LLP
8
9 ______________________________________
George M. Lee
10
Attorneys for Plaintiff
11 MV CAL, LLC
12
13
SEILER EPSTEIN LLP
14
Attorneys at Law
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-2-
NOTICE OF MOTION AND MOTION FOR ENTRY OF DEFAULT JUDGMENT
CASE NO. CGC 23-606008
Document Filed Date
August 29, 2023
Case Filing Date
April 20, 2023
Category
CONTRACT/WARRANTY
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DEPARTMENT: 505 1 George M. Lee (SBN 172982) Hearing: 11/29/2023 9:00 am gml@seilerepstein.com 2 SEILER EPSTEIN LLP ELECTRONICALLY 4 Embarcadero Center, 14th Floor 3 San Francisco, California 94111 FILED Phone: (415) 979-0500 Superior Court of California, County of San Francisco 4 Fax: (415) 979-0511 08/29/2023 5 Attorneys for Plaintiff Clerk of the Court MV CAL, LLC BY: STACY GEE Deputy Clerk 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 IN AND FOR THE COUNTY OF SAN FRANCISCO 9 MV CAL, LLC, a California limited liability Case No. CGC 23-606008 10 company, NOTICE OF HEARING ON PLAINTIFF’S 11 Plaintiff, REQUEST FOR ENTRY OF DEFAULT JUDGMENT 12 vs. 13 [CCP § 585] SEILER EPSTEIN LLP 14 NICKOLAY R. LEVI, an individual Date: _________ Attorneys at Law a/k/a NICK LEVY, DDS, et al., Time: _________ 15 Dept.: 505 16 Defendants. 17 18 TO DEFENDANT NICKOLAY R. LEVI, an individual a/k/a NICK LEVY, DDS: 19 PLEASE TAKE NOTICE that on _____________________________, at _____ a.m./p.m., 20 or as soon thereafter as the matter may be heard in Department 505 of the above-captioned court, 21 Plaintiff MV CAL, LLC (“Plaintiff”) will and hereby does move the court for entry of default 22 judgment against Defendant NICKOLAY R. LEVI, an individual a/k/a NICK LEVY, DDS 23 (“Defendant”), pursuant to Cal. Code Civ. Pro. § 585. By and through this motion, Plaintiff requests 24 that a default judgment be entered against the named Defendant in the principal amount of 25 $94,759.79. 26 Plaintiff also seeks to recover, and hereby moves for pre-judgment interest in the amount of 27 $5,560.97, attorneys’ fees pursuant to contract in the amount of $9,495.00, and costs in the amount 28 of $1,589.69, to be added to the judgment, as set forth in the supporting declaration of counsel. -1- NOTICE OF MOTION AND MOTION FOR ENTRY OF DEFAULT JUDGMENT CASE NO. CGC 23-606008 1 In support of said motion, Plaintiff will rely upon this notice of motion and motion, the 2 Request for Entry of Default Judgment form (Jud. Council Form CIV-100) filed herewith, the 3 supporting memorandum of points and authorities, the supporting declarations of counsel and of 4 Mark Seiler, and all exhibits thereto, the complete records of the court pertaining to this action, all 5 other matters of which the court may take judicial notice, and any other such evidence and 6 argument that the court may consider upon hearing this matter. 7 Dated: August 29, 2023 SEILER EPSTEIN LLP 8 9 ______________________________________ George M. Lee 10 Attorneys for Plaintiff 11 MV CAL, LLC 12 13 SEILER EPSTEIN LLP 14 Attorneys at Law 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- NOTICE OF MOTION AND MOTION FOR ENTRY OF DEFAULT JUDGMENT CASE NO. CGC 23-606008