Motion,Ex Parte: KATHERINE HOVEY VS. KATHLEEN WELSH et al

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                                MINNA

SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

Document Scanning Lead Sheet
Nov-29-2011 3:27 pm

Case Number: CGC-09-494873
Filing Date: Nov-29-2011 3:22
Juke Box: 001 Image: 03401021
EX PARTE APPLICATION FOR ORDER

KATHERINE HOVEY VS. KATHLEEN WELSH et al

001003401021

Instructions:
Please place this sheet on top of the document to be scanned.27

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Ao

Katherine Hovey tT

461 Oak Street “eSany orate
San Francisco, 94102

(415) 829-3972 Nov 29 2011

(in Proper) + CLERK OF THE COURT
ner vols Eset )

SUPERIOR COURT OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO

KATHERINE HOVEY, Case No.: CGC-09-494873

)
)
Plaintiff, )
) NOTICE OF MOTION AND EXPARTE
vs. ) MOTION FOR RELIEF
)
KATHLEEN WELSH, et al., )
)
)
}

Defendant.

Plaintiff gives Defendant Notice that on December 12, 2011,
a Motion For Relief will be heard in Dept. 302 at 11 am in the
San Francisco Superior Court at 400 McAllister Street.

This notice is being made pursuant to CalCodes 473(b) in
which a judge may provide relief for a Judgment with good cause
given, and 473(b)(c) (1) (A) for which Plaintiff also Motions the
court for an order directing Defendant pay $1,000.00 to
Plaintiff, 473(b)(c)(1)(B) for which Plaintiff also Motions the
court for an order directing Defendant pay the Bar $1,000.00,

and 473(b)(c)(1)(C) for which Plaintiff also Motions the court

Notice of Motion/Motion For Relief

1for an order directing Defendant to also pay the Plaintiff's
costs of this Motion and prior Motions (($360.00).

This Motion is made because though there have been numerous
attempts on Plaintiff’s part to have the matter resolved without
prejudice to her, as she was severely disfigured (have first
corrective surgery of multiple surgeries and other medical
treatments to correct what can be corrected of the damage done
to plaintiff - the first is scheduled for December 19, 2011;
therefore, the need for this motion to be ex-parte).

Defense counsel sent Plaintiff an Agreement that is again
one-sided and not fair to the Plaintiff being that her rights
were taken away from her not only by the malpractice of the
physician named in this matter, but also a second time through
when Plaintiff’s own counsel(s) and defense counsels made an
agreement to “sink” her case purposely after it was realized
that Plaintiff’s counsel had messed up the initial complaint so
badly, it would not have held up in court.

I have been put through hell and back by both counsels and
should not be made further victim.

In the interim of the last hearing where Defense motioned
for a judgment of costs against Plaintiff because they were
being held responsible personally for the monies they spent to
litigate a case that should have been dismissed with one motion

at onset due to the problems with the complaint, I have been
Notice of Motion/Motion For Relief

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able to recoup multiple documents that prove my own attorneys
and defense counsel conspired, committed fraud, obstruction, and
colluded with another doctor, Dr. Michael Dans, to produce
falsified testimony and documents (within Defenses Motion For
Summary Judgment); and even though my attorneys new this and

did nothing about it, except Motion the court to be allowed to
be relieved as my counsel when I brought the errors (I knew of
then) to their attention, I have them now.

I will be filing a supplemental declaration along with
copies of all papers (and the civil and criminal codes that each
of them broke) by beginning of next week.

I need to put this on ex-parte because the normal 20 days
would go into right after my initial surgery - for which I need
at least three weeks for the initial healing to bE safe.

Thank you and respectfully submitted in San Francisco, CA

on November 28, 2011.

HY! £3, (2p

nérine (Hevey

4
a

Notice of Motion/Motion For Relief

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PROOF OF SERVICE BY HAND DELIVERY

On 11/29, 2011, I served by hand-delivery the following

documents:

NOTICE OF MOTION AND EXPARTE MOTION FOR RELIEF

On the following:

Dexter Louie, Esq.
Two Embarcadero Center 18 Floor
San Francisco, CA 94111

I am a legal citizen over the age of 18 years old and

reside in the City/County of San Francisco.

true and correct and that this POS was executed on November 29,

2011,

I declare under penalty of perjury that the foregoing is

at

San Francisco, CA.

Notice of Motion/Motion For Relief

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