Motion-Secondary: Bank of America, N.A vs Jacqueline Lefton

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2888
:

Hunt & Henriques, Attorneys at Law
Michael S. Hunt, Esq. #99804
Janalie Henriques, Esq. #111589

151 Bernal Road Suite 8

San José CA 95119-1306
Telephone: (408) 362-2270
Facsimile: (408) 362-2299
Attorneys for Plaintiff

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA

SANTA CLARA SUPERIOR COURT DISTRICT ~ UNLIMITED CIVIL

BANK OF AMERICA, N.A.,
Plaintiff,
vs.
JACQUELINE SISO LEFTON, et al.,

Defendant(s).

I, Jaime Ritton, declare:

1. I am an attorney licensed to practice law in t

Case No. 17CV313899

AT ISSUE MEMORANDUM FOR TRIAL
SETTING

e state of California. I am employed by the firm

of Hunt & Henriques, attorneys for plaintiff herein.

2. Irepresent to the court that this case is at issue. An answer or other legal response was filed

on August 21, 2017.

3. Defendant failed to respond to discovery. Plaintiff brought a Motion for Order that Matters in

Request for Admission of Truth of Facts be Admitted on January 23, 2018. The Court issued

a tentative ruling granting Plaintiff's Motion, which the Court adopted on January 23, 2018.

4. A jury trial is not requested. Plaintiff’s time estimate for trial is two hours.

5. This case is not entitled to preference.

6. Plaintiff respectfully requests that the trial be set in 90-120 days in the future due to a heavy

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At Issue Memorandum For Trial Setting

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HUNT & HENRIQUES
151 BERNAL ROAD SUITE 8
SAN JOSE CALIFORNIA 95119
TELEPHONE: (408) 362-2270
FACSIMILE: (408) 362-2299
I A A BR BN

triallcalendar. I declare under penalty of perjury under the laws of the State of California that

the foregoing is true and correct.

Dated: _ JAN 29 2018

Hyfit & Henriques
ttorneys for Plaintiff

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At Issue Memorandum For Trial Setting
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PROOF OF SERVICE

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA
SANTA CLARA SUPERIOR COURT DISTRICT
RE: BANK OF AMERICA, N.A. vs. JACQUELINE SISO LEFTON, et al.
CASE NO: 17CV313899

I declare that:

I am a resident of, or employed in, Santa Clara County, California.

I am over the age of eighteen years and not a party to the within entitled cause;
My business address is: 151 Bernal Road Suite 8, San José, CA 95119-1306

On January 29, 2018, I served the attached:
AT ISSUE MEMORANDUM FOR TRIAL SETTING

on the interested parties in said cause, by placing [ ] the original; [X] true copy thereof enclosed
in a sealed envelope addressed as follows:

Jacqueline Siso Lefton
8501 Bear Creek Rd
Los Gatos, CA 95033

[X] BY MAIL: placing the envelope for collection and mailing following our ordinary business
ractices. I am readily familiar with this businesses practice for collecting and processing
correspondence for mailing. On the same day that correspondence is placed for collection and
mailing, it is deposited in the ordinary course of business with the United States Postal Service in
a sealed envelope with postage fully prepaid.

|] BY PERSONAL SERVICE: I caused such envelope to be delivered by hand to this office(s)
of the addressee(s).

] BY UNITED PARCEL SERVICE: I caused such envelope to be delivered by United Parcel
Service for overnight courier service to the office(s) of the addressee(s).

] BY FACSIMILE: I caused a copy of such document to be sent via FACSIMILE to:
CO

I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct that this declaration was executed on January 29, 2018, in San José, CA.

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