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CIV-110
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY
NAME: Valerie D. Escalante Troesh, SBN 281386; Angela J. Dailey, SBN 278572
FIRM NAME: Lauren E. Brown, SBN 345528; CIVICA LAW GROUP, APC
STREET ADDRESS: 4000 Barranca Parkway, Suite 250, PMB# 782
CITY: Irvine STATE: CA ZIP CODE: 92604
TELEPHONE NO.: (949) 592-0165 FAX NO.: (949) 335-1701
E-MAIL ADDRESS: VEscalantetroesh@CivicaLaw.com; ADailey@CivicaLaw.com
ATTORNEY FOR (name): Defendant and Cross-Complainant, City of Salinas
SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY
STREET ADDRESS: 1200 Aguajito Road
MAILING ADDRESS: 1200 Aguajito Road
CITY AND ZIP CODE: Monterey, California 93940
BRANCH NAME: Monterey Courthouse
PLAINTIFF/PETITIONER: Maria Trinidad Lopez De Zepeda, et al.
DEFENDANT/RESPONDENT: Alejandro Lara Hernandez, et al.
CASE NUMBER:
REQUEST FOR DISMISSAL 22CV002931
A conformed copy will not be returned by the clerk unless a method of return is provided with the document.
This form may not be used for dismissal of a derivative action or a class action or of any party or cause of action in a
class action. (Cal. Rules of Court, rules 3.760 and 3.770.)
1. TO THE CLERK: Please dismiss this action as follows:
a. (1) With prejudice (2) Without prejudice
b. (1) Complaint (2) Petition
(3) x Cross-complaint filed by (name): City of Salinas on (date): December 8, 2023
(4) Cross-complaint filed by (name): on (date):
(5) Entire action of all parties and all causes of action
(6) Other (specify):*
2. (Complete in all cases except family law cases.)
The court did did not waive court fees and costs for a party in this case. (This information may be obtained from
the clerk. If court fees and costs were waived, the declaration on the back of this form must be completed).
Date: March 26, 2024
Angela J. Dailey
(TYPE OR PRINT NAME OF ATTORNEY PARTY WITHOUT ATTORNEY) (SIGNATURE)
*If dismissal requested is of specified parties only of specified causes of action only, or Attorney or party without attorney for:
of specified cross-complaints only, so state and identify the parties, causes of action, Plaintiff/Petitioner x Defendant/Respondent
or cross-complaints to be dismissed
Cross-Complainant
3. TO THE CLERK: Consent to the above dismissal is hereby given.**
Date:
(TYPE OR PRINT NAME OF ATTORNEY PARTY WITHOUT ATTORNEY) (SIGNATURE)
** If a cross-complaint - or Response (Family Law) seeking affirmative relief - is on Attorney or party without attorney for:
file, the attorney for cross-complainant (respondent) must sign this consent if required Plaintiff/Petitioner Defendant/Respondent
by Code of Civil Procedure section 581 (i) or (j).
Cross-Complainant
4. Dismissal entered as requested on (date):
5. Dismissal entered on (date): as to only (name):
6. Dismissal not entered as requested for the following reasons (specify):
7. a. Attorney or party without attorney notified on (date):
b. Attorney or party without attorney not notified. Filing party failed to provide
a copy to be conformed means to return conformed copy
Date: Clerk, by , Deputy
Page 1 of 2
Form Adopted for Mandatory Use REQUEST FOR DISMISSAL Code of Civil Procedure, § 581 et seq.;
Judicial Council of California Gov. Code, § 68637(c); Cal. Rules of Court, rule 3.1390
CIV-110 [Rev. January 1, 2013] www.courts.ca.gov
CIV-110
PLAINTIFF/PETITIONER: Maria Trinidad Lopez De Zepeda, et al. CASE NUMBER:
22CV002931
DEFENDANT/RESPONDENT: Alejandro Lara Hernandez, et al.
COURT'S RECOVERY OF WAIVED COURT FEES AND COSTS
If a party whose court fees and costs were initially waived has recovered or will recover $10,000 or
more in value by way of settlement, compromise, arbitration award, mediation settlement, or other
means, the court has a statutory lien on that recovery. The court may refuse to dismiss the case until
the lien is satisfied. (Gov. Code, § 68637.)
Declaration Concerning Waived Court Fees
1. The court waived court fees and costs in this action for (name):
2. The person named in item 1 is (check one below):
a. not recovering anything of value by this action.
b. recovering less than $10,000 in value by this action.
c. recovering $10,000 or more in value by this action. (If item 2c is checked, item 3 must be completed.)
3. All court fees and court costs that were waived in this action have been paid to the court (check one): Yes No
I declare under penalty of perjury under the laws of the State of California that the information above is true and correct.
Date:
(TYPE OR PRINT NAME OF ATTORNEY PARTY MAKING DECLARATION) (SIGNATURE)
CIV-110 [Rev. January 1, 2013] Page 2 of 2
REQUEST FOR DISMISSAL
1 PROOF OF SERVICE
2 At the time of this service I was over 18 years of age and I was not a party to this action. My
3 business address is 4000 Barranca Parkway, Suite 250 PMB 782, Irvine, California 92604. On the date
4 specified below, I served the following documents (“Documents”):
5 1. REQUEST FOR DISMISSAL.
6 The Documents were served on the following persons (“Persons”):
7 Omid Razi, Esq. Paul Auchard, Esq.
RJ Molligan, Esq. LAW OFFICE OF PAUL AUCHARD
8 RAZI LAW GROUP, APLC 5713 No. West Avenue, Suite 103
Fresno, California 93711
9 8666 Wilshire Blvd paul@paulauchardlaw.com
Beverly Hills, California 90211 janice@paulauchardlaw.com
10 omid@razilaw.com linda@paulauchardlaw.com
rj@razilaw.com Attorneys for Defendants,
11 sujey@razilaw.com Alejandro Lara Hernandez and
RLG1@razilaw.com Maria Elena Lara Hernandez
12 Attorneys for Plaintiff, Maria Trinidad
13 Lopez de Zepeda Heir to Florentino Zepeda Virgen
14 The Document was delivered by:
15 ☐ United States Mail. I served the Document by enclosing a true copy in a sealed envelope
16 addressed to the Persons at the addresses identified above and depositing the envelope in the United
17 States mail with the postage fully prepaid in the county where I reside or am employed.
18 ☒ Email. Pursuant to CCP 1010.6(e)(1), the Document was served via email to the email
19 addresses listed above and no indication was received that the email was not successfully received.
20
21 I declare under penalty of perjury under the laws of the State of California that the foregoing is
22 true and correct.
23
Kathleen Lane
24 Dated: March 27, 2024 ______________________________
KATHLEEN LANE
25
26
27
28
–1–
PROOF OF SERVICE
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CIV-110 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY NAME: Valerie D. Escalante Troesh, SBN 281386; Angela J. Dailey, SBN 278572 FIRM NAME: Lauren E. Brown, SBN 345528; CIVICA LAW GROUP, APC STREET ADDRESS: 4000 Barranca Parkway, Suite 250, PMB# 782 CITY: Irvine STATE: CA ZIP CODE: 92604 TELEPHONE NO.: (949) 592-0165 FAX NO.: (949) 335-1701 E-MAIL ADDRESS: VEscalantetroesh@CivicaLaw.com; ADailey@CivicaLaw.com ATTORNEY FOR (name): Defendant and Cross-Complainant, City of Salinas SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY STREET ADDRESS: 1200 Aguajito Road MAILING ADDRESS: 1200 Aguajito Road CITY AND ZIP CODE: Monterey, California 93940 BRANCH NAME: Monterey Courthouse PLAINTIFF/PETITIONER: Maria Trinidad Lopez De Zepeda, et al. DEFENDANT/RESPONDENT: Alejandro Lara Hernandez, et al. CASE NUMBER: REQUEST FOR DISMISSAL 22CV002931 A conformed copy will not be returned by the clerk unless a method of return is provided with the document. This form may not be used for dismissal of a derivative action or a class action or of any party or cause of action in a class action. (Cal. Rules of Court, rules 3.760 and 3.770.) 1. TO THE CLERK: Please dismiss this action as follows: a. (1) With prejudice (2) Without prejudice b. (1) Complaint (2) Petition (3) x Cross-complaint filed by (name): City of Salinas on (date): December 8, 2023 (4) Cross-complaint filed by (name): on (date): (5) Entire action of all parties and all causes of action (6) Other (specify):* 2. (Complete in all cases except family law cases.) The court did did not waive court fees and costs for a party in this case. (This information may be obtained from the clerk. If court fees and costs were waived, the declaration on the back of this form must be completed). Date: March 26, 2024 Angela J. Dailey (TYPE OR PRINT NAME OF ATTORNEY PARTY WITHOUT ATTORNEY) (SIGNATURE) *If dismissal requested is of specified parties only of specified causes of action only, or Attorney or party without attorney for: of specified cross-complaints only, so state and identify the parties, causes of action, Plaintiff/Petitioner x Defendant/Respondent or cross-complaints to be dismissed Cross-Complainant 3. TO THE CLERK: Consent to the above dismissal is hereby given.** Date: (TYPE OR PRINT NAME OF ATTORNEY PARTY WITHOUT ATTORNEY) (SIGNATURE) ** If a cross-complaint - or Response (Family Law) seeking affirmative relief - is on Attorney or party without attorney for: file, the attorney for cross-complainant (respondent) must sign this consent if required Plaintiff/Petitioner Defendant/Respondent by Code of Civil Procedure section 581 (i) or (j). Cross-Complainant 4. Dismissal entered as requested on (date): 5. Dismissal entered on (date): as to only (name): 6. Dismissal not entered as requested for the following reasons (specify): 7. a. Attorney or party without attorney notified on (date): b. Attorney or party without attorney not notified. Filing party failed to provide a copy to be conformed means to return conformed copy Date: Clerk, by , Deputy Page 1 of 2 Form Adopted for Mandatory Use REQUEST FOR DISMISSAL Code of Civil Procedure, § 581 et seq.; Judicial Council of California Gov. Code, § 68637(c); Cal. Rules of Court, rule 3.1390 CIV-110 [Rev. January 1, 2013] www.courts.ca.gov CIV-110 PLAINTIFF/PETITIONER: Maria Trinidad Lopez De Zepeda, et al. CASE NUMBER: 22CV002931 DEFENDANT/RESPONDENT: Alejandro Lara Hernandez, et al. COURT'S RECOVERY OF WAIVED COURT FEES AND COSTS If a party whose court fees and costs were initially waived has recovered or will recover $10,000 or more in value by way of settlement, compromise, arbitration award, mediation settlement, or other means, the court has a statutory lien on that recovery. The court may refuse to dismiss the case until the lien is satisfied. (Gov. Code, § 68637.) Declaration Concerning Waived Court Fees 1. The court waived court fees and costs in this action for (name): 2. The person named in item 1 is (check one below): a. not recovering anything of value by this action. b. recovering less than $10,000 in value by this action. c. recovering $10,000 or more in value by this action. (If item 2c is checked, item 3 must be completed.) 3. All court fees and court costs that were waived in this action have been paid to the court (check one): Yes No I declare under penalty of perjury under the laws of the State of California that the information above is true and correct. Date: (TYPE OR PRINT NAME OF ATTORNEY PARTY MAKING DECLARATION) (SIGNATURE) CIV-110 [Rev. January 1, 2013] Page 2 of 2 REQUEST FOR DISMISSAL 1 PROOF OF SERVICE 2 At the time of this service I was over 18 years of age and I was not a party to this action. My 3 business address is 4000 Barranca Parkway, Suite 250 PMB 782, Irvine, California 92604. On the date 4 specified below, I served the following documents (“Documents”): 5 1. REQUEST FOR DISMISSAL. 6 The Documents were served on the following persons (“Persons”): 7 Omid Razi, Esq. Paul Auchard, Esq. RJ Molligan, Esq. LAW OFFICE OF PAUL AUCHARD 8 RAZI LAW GROUP, APLC 5713 No. West Avenue, Suite 103 Fresno, California 93711 9 8666 Wilshire Blvd paul@paulauchardlaw.com Beverly Hills, California 90211 janice@paulauchardlaw.com 10 omid@razilaw.com linda@paulauchardlaw.com rj@razilaw.com Attorneys for Defendants, 11 sujey@razilaw.com Alejandro Lara Hernandez and RLG1@razilaw.com Maria Elena Lara Hernandez 12 Attorneys for Plaintiff, Maria Trinidad 13 Lopez de Zepeda Heir to Florentino Zepeda Virgen 14 The Document was delivered by: 15 ☐ United States Mail. I served the Document by enclosing a true copy in a sealed envelope 16 addressed to the Persons at the addresses identified above and depositing the envelope in the United 17 States mail with the postage fully prepaid in the county where I reside or am employed. 18 ☒ Email. Pursuant to CCP 1010.6(e)(1), the Document was served via email to the email 19 addresses listed above and no indication was received that the email was not successfully received. 20 21 I declare under penalty of perjury under the laws of the State of California that the foregoing is 22 true and correct. 23 Kathleen Lane 24 Dated: March 27, 2024 ______________________________ KATHLEEN LANE 25 26 27 28 –1– PROOF OF SERVICE