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LAW OFFICES OF JOHN L. FALLAT
JOHN L. FALLAT (State Bar No. 114842)
TIMOTHY J. TOMLIN (State Bar No. 142294)
68 Mitchell Boulevard, Suite 135
San Rafael, CA 94903-2046
Telephone: (415) 457-3773
Facsimile: (415) 457-2667
Attorney for Defendant/Cross-Complainant
HUDSON INSURANCE COMPANY RECEIVED
2/10/2021 3:19 PM
FRESNO COUNTY SUPERIOR COURT
By: E. Alvarado, Deputy
SUPERIOR COURT OF CALIFORNIA
COUNTY OF FRESNO
10
ALEJANDRINA GOMEZ CHAIDEZ, an CASE NO. 20CECG02170
11 individual;
12 STIPULATION FOR
Plaintiffs, DISBURSEMENT OF ALL
13 INTERPLEADED FUNDS AND
vs. FOR DISMISSAL OF CASE
14
RSIDHU AUTO GROUP, INC. D/B/A
15 AUTO EMPIRE D/B/A AUTO EMPIRE OF
FRESNO; T AUTO FINANCE, LLC;
16
HUDSON INSURANCE COMPANY, and
17 DOES Ithrough 100, inclusive,
18 Defendants.
19
)
20 HUDSON INSURANCE COMPANY, a )
Delaware corporation, )
21 )
Cross-Complainant, )
vs. )
23 )
ALE JANDRINA GOMEZ CHAIDEZ, an )
24 individual; JUDY NAVARRO, an individual; )
ROSARIO REYES, an individual; )
25 CALIFORNIA DEPARTMENT OF MOTOR )
26 VEHICLES, a State Agency, RAJ SIDHU, an )
individual, and ROES I through 50, inclusive, )
27 )
Cross-Defendants. )
28
STIPULATION FOR DISBURSEMENT OF ALL INTERPLEADED FUNDS AND FOR DISMISSAL OF CASE;
ORDER THEREON
1
The parties, through their counsel of record, stipulate as follows:
1. The claimants on the motor vehicle dealer's bond (No. 10076266) of Rsidhu Auto Group, Inc.
dba Auto Empire interpleaded herein have appeared in this case except for Rosario Reyes who has noi
pursued the claim and has been dismissed;
2. The interpleaded bond funds on deposit with the Court amount to $ 10,000.00, which isthe
portion of the $ 50,000.00 bond available after settlement of previous lawsuits and claims;
3. The appearing parties have agreed to a disbursement of the interpleaded funds, which includes
a reimbursement to cross-complainant Hudson Insurance Company of costs and minimal attorney fees, a:
9 follows:
Party ("Payee" in quotes) Reason Disbursement of Bond
10 Proceeds
11
Surety: For attorney fees and $ 1,750.00
12 costs recoverable &om
"HUDSON INSURANCE the interpleaded funds
13 COMPANY" pursuant to CCP 5386.6
c/o Timothy Tomlin, Esq. (a compromise figure)
14
Law Offices of John L. Fallat
15 68 Mitchell Blvd, Suite 135
San Rafael, CA 94903
17
Bond Claimant: Agreed upon payment:
18 11.02% of $ 8,250.00 of $ 909 15
ALEJANDRINA GOMEZ available funds
19 CHAIDEZ
20
Payee: "Law Offices of Robert
21
Mobasseri, Client Trust Account"
22 c/o Robert Mobasseri, Esq.
Law Offices of Robert B.
23 Mobasseri, A.P.C
1055 W. 7th Street, Suite 2140
24 Los Angeles, California 90017
25
26
28
STIPULATION FOR DISBURSEMENT OF ALL ~LEADED FUNDS AND FOR DISMISSAL OF CASE;
ORDER THEREON
2
Bond Claimant:
Agreed upon payment:
77.66% of $ 8,250.00 of $6 4p6 95
JUDY NAVARRO
available funds
Payable to "Law Offices of Kevin
F sulk — Trust Account"
c/o Kevin Faulk, Esq.
530 Lawrence Expressway ¹361
Sunnyvale, CA 94085
Bond Claimant:
Agreed upon payment:
11.32% of $ 8,250.00 of $ 933 9p
av&able fimds
and MARTHA HERNANDEZ
10 Payee: "Consumer Action Law
11 Group Attorney Trust Account"
12 c/o Pauliana Lars, Esq.
Consumer Action Law Group, PC
13 3700 Eagle Rock Boulevard,
14
Los Angeles, CA 90065
15
4. Any interest earned on the bond now deposited with the Court shall be disbursed among the
16
Bond Claimant parties hereto according to their respective percentage distribution shares — 11.02% to
17
Alejandrina Gomez Chaidez, 77.66 to Judy Navarro aud 11.32% to Martin Tapia and Martha Hernandez.
18
5. The parties agree that each party shall bear their own attorney's fees and costs in the litigation
19
except as set forth above.
20
6. This agreement is entered into by the parties for the purpose of settling the bond claims
21
described in the Crossp-Complaint. It does not constitute, nor shall it be construed as, an admission by
22
any party of the truth or validity of any allegations asserted except where expressly noted within this
23
Stipulation.
24
7. Each party and each party's respective successors, assigns, agents, directors, officers,
25
employees, representatives, and attorneys hereby fully and expressly release and discharge one another
26
and each's respective successors, assigns, agents, directors, officers, employees, representatives, snd
27
attorneys fiom all liability for all present and future rights, claims, demands and actions, known or
28
STIPULATION FOR DISBURSEMENT OF ALL INTERPLEADED FUNDS AND FOR DISMISSAL OF CASE;
ORDER THEREON
3
I unknown, either of them now have, or may hereafter have, against one another arising out of the
2 complaint. Further, the parties expressly aclutowledge and agree that none of them would enter into this
3 Stipulation but for the representation and warranty of the other that they are releasing any and all claims
4 of any nature whatsoever, whether statutory or at common law, which any of them may believe any of
5 them now has or could assert directly or indirectly against the other arising out of the circumstances
6 alleged in the Complaint in interpleader.
7 8. Upon the execution of the Order on this Stipulation, the parties agree that the interpleader
8 cause of action of the Complaint shall be dismissed with prejudice.
9 9. This stipulation shall not affect any claims or causes of action the parties hereto may have
10 against Rsidhu Auto Group, Inc. or its personal indemnitors.
11 10. The parties request that the Court issue the Order as proposed.
12 IT IS SO STIPULATED.
13
14
DATED: ~ C.—
TiivIOTHY J. TOMLIN,
15 Attorney for Cross-Complainant
HUDSON INSURANCE COMPANY
16
DATED:
18 KEVIN FAULK
Attontey for Cross-Defendant
19 JUDY NAVARRO
20
DATED:
ROBERT MOBASSERI
22 Attorney for Cross-Defendant
ALE JANDRINA GOMEZ CHAIDEZ
DATED; % 1 iI'LLiL~
25 PAU IAkACLARA
Atto ey for Cross-Defendants
26 MA TIN TAPIA and MARTHA HERNANDEZ
27
STIPULATION FOI& DISBURSEMENT OF ALL INTERPLEADED FUNDS AND FOR DISMISSAL OF CASE;
DIDDER THEREON
4
unknown, either of them now have, or may hereafter have, against one another arising out of the
complaint. Further, the parties expressly acknowledge and agree that none of them would enter into this
Stipulation but for the representation and warranty of the other that they are releasing any and all claims
of any nature whatsoever, whether statutory or at common law, which any of them may believe any of
them now has or could assert directly or indirectly against the other arising out of the circumstances
alleged in the Complaint in interpleader.
8. Upon the execution of the Order on this Stipulation, the parties agree that the interpleader
cause of action of the Complaint shall be dismissed with prejudice.
9. This stipulation shall not affect any claims or causes of action the parties hereto may have
10 against Rsidhu Auto Group, Inc. or its personal indemnitors.
10. The parties request that the Court issue the Order as proposed.
12 IT IS SO STIPULATED.
13
DATED:
14
TIMOTHY J. TOMLIN,
15 Attorney for Cross-Complainant
HUDSON INSURANCE COMPANY
16
17 DATED:
18 KEVIN FAULK
Attorney for Cross-Defendant
19 JUDY NAVARRO
20
21 DATED:
ROBERT MOBASSERI
22 Attorney for Cross-Defendant
ALEJANDRINA GOMEZ CHAIDEZ
23
24
DATED:
25 PAULIANA LARA
Attorney for Cross-Defendants.
MARTIN TAPIA and MARTHA HERNANDEZ
27
28
STIPULATION FOR DISBURSEMENT OF ALL INTERPLEADED FUNDS AND FOR DISMSSAL OF CASE;
ORDER THEREON
4
unknown, either of them now have, or may hereafter have, against one another arising out of the
complaint. Further, the parties expressly'acknowledge and agree that none of them would enter into this
Stipulation but for the representation and warranty of the other that they are releasing any and all claims
of any nature whatsoever, whether statutory or at common law, which any of them may believe any of
them now has or could assert directly or indirectly against the other arising out of the circumstances
alleged in the Complaint in interpleader.
8. Upon the execution of the Order on this Stipulation, the parnes agree that the interpleader
cause of action of the Complaint shall be dismissed with prejudice.
9. This stipulation shall not affect any claims or causes of action the parties hereto may have
10 against Rsidhu Auto Group, Inc. or its personal indemnitors.
10. The parties request that the Court issue the Order as proposed.
12 IT IS SO STIPULATED.
13
DATED:
14
TIMOTHY J. TOMLIN,
15 Attorney for Cross-Complainant
HUDSON INSURANCE COMPANY
16
17 DATED:
18 KEVIN FAULK
Attorney for Cross-Defendant
JUDY NAVARRO
20
DATED 2/4/2021
21
ROBERT MOBAS SERI
22 Attorney for Cross-Defendant
ALEJANDRINA GOMEZ CHAIDEZ
23
24
DATED:
25 PAULIANA LARA
Attorney for Cross-Defendants
MARTIN TAP IA and MARTHA HERNANDEZ
27
28
STIPULATION FOR DISBURSEMENT OF ALL INTERPLEADED FUNDS AND FOR DISMISSAL OF CASE;
ORDER THEREON
4
I ORDER ON STIPULATION
Having reviewed the stipulafion of the parties, and good cause appearing therefor,
1. The interpleader funds on the deposit with the Court &om the Bond of Hudson Insurance
Company Bond No. 10076266 issued to Rsidhu Auto Group, Inc. dba Auto Empire shall be disbursed by
the Clerk of the Court as follows:
A. $ 1,750.00 payable to "HUDSON INSURANCE COMPANY" and mailed to
Timothy Tomlin, Law Offices of John L. Fallat, 68 Mitchell Blvd, Suite 135, San Rafael, CA 94903.
B. $ 909.15 re: ALEJANDRINA GOMEZ CHAIDEZ, payable to "Law Offices of
Robert Mobasseri, Client Trust Account" and mailed to Robert Mobasseri, Esq. Law Offices of Robert B.
10 Mobasseri, A.P.C., 1055 W. 7th Street, Suite 2140, Los Angeles, California 90017.
C. $ 6,406.95 re: Judy Navarm payable to "Law Offices of Kevin Faulk — Trust
12 Account" and mailed to Kevin Faulk, Esq. 530 Lawrence Expressway ¹361, Sunnyvale, CA 94085.
13 D. $ 933.90 re: MARTIN TAPIA and MARTHA HERNANDEZ, payable to
14 "MARTIN TAPIA and MARTHA HERNANDEZ" and mailed to Pauliana Lara, Esq. Consumer Action
15 Law Group, PC, 3700 Eagle Rock Boulevard, Los Angeles, CA 90065.
16 E. Interest on the deposited funds shall be paid to the specified parties as follows:
17 11.02% to Alejandrina Gomez Chaidez, 77.66% to Judy Navarm and 11.32% to Martin Tapis and Martha
18 Hernandez jointly.
19 2. The Cross-Complaint shall be dismissed with prejudice as to the stipulating cross-
20 defendants upon the payment of the interpleaded funds.
21 3. The stipulation of the parties and this Order thereon shall not affect any claims or rights of
22 action the parties hereto may have against RSIDHU AUTO GROUP, INC. D/B/A AUTO EMPIRE D/B/A
23 AUTO EMPIRE OF FRESNO or its personal indemnitor Raj Sidhu.
24
25 IT IS SO ORDERED.
26
DATED:
27
JUDGE OF THE SUPERIOR COURT
STIPULATION FOR DISBURSEMENT OF ALL INTERPLEADED FUNDS AND FOR DISMISSAL OF CASE;
ORDER THEREON
5
1 PROOF OF SERVICE BY MAIL
[CCP tt1013(a)]
I, ROXANNE CULLEN, declare that I am not a party to this action, am over the age of 18 years,
maintain a business address at 68 Mitchell Boulevard, Suite 135, San Rafael, CA 94903-2046, County of
Marin, and that on the date shown below, I caused to be served the documents listed below on the persons
listed herein by placing the envelopes for collection and mailing following our ordinary business practices.
I am readily familiar with this business'ractice for collecting and processing correspondence for mailing.
On the same day that correspondence is placed for collection and mailing, it isdeposited in the ordinary
9
course of business with the United States Postal Service in a sealed envelope with postage fully prepaid.
The envelope(s) were addressed and mailed as follows:
10
11 DOCUMENTS SERVED: "STIPULA TION FOR DISBURSEMENT OF ALL INTERPLEADED
12 FUNDS AND FOR DISMISSAL OF CASE"
13 SERVED UPON:
14 Barbara A. Rohr, Esq.
15 Law Offices of Robert B. Mobasseri, PC
1055 West 7@ Street, Suite 2140
16 Los Angeles, CA 90017
Tel: (213) 282-2000
17 Fax: (213) 282-3000
18 Counsel for PlaintiWICross-Defendant Aleiandrina Gomez Chaidez
19 Kevin Faulk, Esq.
Law Offices of Kevin Faulk
20 530 Lawrence Expressway, ¹361
Sunnyvale, CA 94085
21
Tel: (408) 599-3277
22 Fax: (408) 800-4046
Counsel for Plaintiff/Cross-Defendant Judv Navarro
23
Pauliana N. Lara, Esq.
24
Consumer Action Law Group, PC
25 3700 Eagle Rock Boulevard
Los Angeles, CA 90065
26 Tel: (818) 254-8413
Fax: (866) 400-0475
27 Counsel for Martin Taoia and Martha Hernandez
28
Jamie D. Wells, Esq.
McGuire Woods LLP
Two Embarcadero Center, Suite 1300
3 San Francisco, CA 94111
Tel: (415) 844-9944
Email: aleQmcauirewoods.corn
Counsel for Defendant TD Auto Finance LLC
6 I declare under penalty of perjury that the foregoing is true and correct and that this proof of service
7 was executed on the date stated below, at San Rafael, California
DATED: February 10, 2021
ROXAhfNE CULLEN
10
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15
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Preview
LAW OFFICES OF JOHN L. FALLAT JOHN L. FALLAT (State Bar No. 114842) TIMOTHY J. TOMLIN (State Bar No. 142294) 68 Mitchell Boulevard, Suite 135 San Rafael, CA 94903-2046 Telephone: (415) 457-3773 Facsimile: (415) 457-2667 Attorney for Defendant/Cross-Complainant HUDSON INSURANCE COMPANY RECEIVED 2/10/2021 3:19 PM FRESNO COUNTY SUPERIOR COURT By: E. Alvarado, Deputy SUPERIOR COURT OF CALIFORNIA COUNTY OF FRESNO 10 ALEJANDRINA GOMEZ CHAIDEZ, an CASE NO. 20CECG02170 11 individual; 12 STIPULATION FOR Plaintiffs, DISBURSEMENT OF ALL 13 INTERPLEADED FUNDS AND vs. FOR DISMISSAL OF CASE 14 RSIDHU AUTO GROUP, INC. D/B/A 15 AUTO EMPIRE D/B/A AUTO EMPIRE OF FRESNO; T AUTO FINANCE, LLC; 16 HUDSON INSURANCE COMPANY, and 17 DOES Ithrough 100, inclusive, 18 Defendants. 19 ) 20 HUDSON INSURANCE COMPANY, a ) Delaware corporation, ) 21 ) Cross-Complainant, ) vs. ) 23 ) ALE JANDRINA GOMEZ CHAIDEZ, an ) 24 individual; JUDY NAVARRO, an individual; ) ROSARIO REYES, an individual; ) 25 CALIFORNIA DEPARTMENT OF MOTOR ) 26 VEHICLES, a State Agency, RAJ SIDHU, an ) individual, and ROES I through 50, inclusive, ) 27 ) Cross-Defendants. ) 28 STIPULATION FOR DISBURSEMENT OF ALL INTERPLEADED FUNDS AND FOR DISMISSAL OF CASE; ORDER THEREON 1 The parties, through their counsel of record, stipulate as follows: 1. The claimants on the motor vehicle dealer's bond (No. 10076266) of Rsidhu Auto Group, Inc. dba Auto Empire interpleaded herein have appeared in this case except for Rosario Reyes who has noi pursued the claim and has been dismissed; 2. The interpleaded bond funds on deposit with the Court amount to $ 10,000.00, which isthe portion of the $ 50,000.00 bond available after settlement of previous lawsuits and claims; 3. The appearing parties have agreed to a disbursement of the interpleaded funds, which includes a reimbursement to cross-complainant Hudson Insurance Company of costs and minimal attorney fees, a: 9 follows: Party ("Payee" in quotes) Reason Disbursement of Bond 10 Proceeds 11 Surety: For attorney fees and $ 1,750.00 12 costs recoverable &om "HUDSON INSURANCE the interpleaded funds 13 COMPANY" pursuant to CCP 5386.6 c/o Timothy Tomlin, Esq. (a compromise figure) 14 Law Offices of John L. Fallat 15 68 Mitchell Blvd, Suite 135 San Rafael, CA 94903 17 Bond Claimant: Agreed upon payment: 18 11.02% of $ 8,250.00 of $ 909 15 ALEJANDRINA GOMEZ available funds 19 CHAIDEZ 20 Payee: "Law Offices of Robert 21 Mobasseri, Client Trust Account" 22 c/o Robert Mobasseri, Esq. Law Offices of Robert B. 23 Mobasseri, A.P.C 1055 W. 7th Street, Suite 2140 24 Los Angeles, California 90017 25 26 28 STIPULATION FOR DISBURSEMENT OF ALL ~LEADED FUNDS AND FOR DISMISSAL OF CASE; ORDER THEREON 2 Bond Claimant: Agreed upon payment: 77.66% of $ 8,250.00 of $6 4p6 95 JUDY NAVARRO available funds Payable to "Law Offices of Kevin F sulk — Trust Account" c/o Kevin Faulk, Esq. 530 Lawrence Expressway ¹361 Sunnyvale, CA 94085 Bond Claimant: Agreed upon payment: 11.32% of $ 8,250.00 of $ 933 9p av&able fimds and MARTHA HERNANDEZ 10 Payee: "Consumer Action Law 11 Group Attorney Trust Account" 12 c/o Pauliana Lars, Esq. Consumer Action Law Group, PC 13 3700 Eagle Rock Boulevard, 14 Los Angeles, CA 90065 15 4. Any interest earned on the bond now deposited with the Court shall be disbursed among the 16 Bond Claimant parties hereto according to their respective percentage distribution shares — 11.02% to 17 Alejandrina Gomez Chaidez, 77.66 to Judy Navarro aud 11.32% to Martin Tapia and Martha Hernandez. 18 5. The parties agree that each party shall bear their own attorney's fees and costs in the litigation 19 except as set forth above. 20 6. This agreement is entered into by the parties for the purpose of settling the bond claims 21 described in the Crossp-Complaint. It does not constitute, nor shall it be construed as, an admission by 22 any party of the truth or validity of any allegations asserted except where expressly noted within this 23 Stipulation. 24 7. Each party and each party's respective successors, assigns, agents, directors, officers, 25 employees, representatives, and attorneys hereby fully and expressly release and discharge one another 26 and each's respective successors, assigns, agents, directors, officers, employees, representatives, snd 27 attorneys fiom all liability for all present and future rights, claims, demands and actions, known or 28 STIPULATION FOR DISBURSEMENT OF ALL INTERPLEADED FUNDS AND FOR DISMISSAL OF CASE; ORDER THEREON 3 I unknown, either of them now have, or may hereafter have, against one another arising out of the 2 complaint. Further, the parties expressly aclutowledge and agree that none of them would enter into this 3 Stipulation but for the representation and warranty of the other that they are releasing any and all claims 4 of any nature whatsoever, whether statutory or at common law, which any of them may believe any of 5 them now has or could assert directly or indirectly against the other arising out of the circumstances 6 alleged in the Complaint in interpleader. 7 8. Upon the execution of the Order on this Stipulation, the parties agree that the interpleader 8 cause of action of the Complaint shall be dismissed with prejudice. 9 9. This stipulation shall not affect any claims or causes of action the parties hereto may have 10 against Rsidhu Auto Group, Inc. or its personal indemnitors. 11 10. The parties request that the Court issue the Order as proposed. 12 IT IS SO STIPULATED. 13 14 DATED: ~ C.— TiivIOTHY J. TOMLIN, 15 Attorney for Cross-Complainant HUDSON INSURANCE COMPANY 16 DATED: 18 KEVIN FAULK Attontey for Cross-Defendant 19 JUDY NAVARRO 20 DATED: ROBERT MOBASSERI 22 Attorney for Cross-Defendant ALE JANDRINA GOMEZ CHAIDEZ DATED; % 1 iI'LLiL~ 25 PAU IAkACLARA Atto ey for Cross-Defendants 26 MA TIN TAPIA and MARTHA HERNANDEZ 27 STIPULATION FOI& DISBURSEMENT OF ALL INTERPLEADED FUNDS AND FOR DISMISSAL OF CASE; DIDDER THEREON 4 unknown, either of them now have, or may hereafter have, against one another arising out of the complaint. Further, the parties expressly acknowledge and agree that none of them would enter into this Stipulation but for the representation and warranty of the other that they are releasing any and all claims of any nature whatsoever, whether statutory or at common law, which any of them may believe any of them now has or could assert directly or indirectly against the other arising out of the circumstances alleged in the Complaint in interpleader. 8. Upon the execution of the Order on this Stipulation, the parties agree that the interpleader cause of action of the Complaint shall be dismissed with prejudice. 9. This stipulation shall not affect any claims or causes of action the parties hereto may have 10 against Rsidhu Auto Group, Inc. or its personal indemnitors. 10. The parties request that the Court issue the Order as proposed. 12 IT IS SO STIPULATED. 13 DATED: 14 TIMOTHY J. TOMLIN, 15 Attorney for Cross-Complainant HUDSON INSURANCE COMPANY 16 17 DATED: 18 KEVIN FAULK Attorney for Cross-Defendant 19 JUDY NAVARRO 20 21 DATED: ROBERT MOBASSERI 22 Attorney for Cross-Defendant ALEJANDRINA GOMEZ CHAIDEZ 23 24 DATED: 25 PAULIANA LARA Attorney for Cross-Defendants. MARTIN TAPIA and MARTHA HERNANDEZ 27 28 STIPULATION FOR DISBURSEMENT OF ALL INTERPLEADED FUNDS AND FOR DISMSSAL OF CASE; ORDER THEREON 4 unknown, either of them now have, or may hereafter have, against one another arising out of the complaint. Further, the parties expressly'acknowledge and agree that none of them would enter into this Stipulation but for the representation and warranty of the other that they are releasing any and all claims of any nature whatsoever, whether statutory or at common law, which any of them may believe any of them now has or could assert directly or indirectly against the other arising out of the circumstances alleged in the Complaint in interpleader. 8. Upon the execution of the Order on this Stipulation, the parnes agree that the interpleader cause of action of the Complaint shall be dismissed with prejudice. 9. This stipulation shall not affect any claims or causes of action the parties hereto may have 10 against Rsidhu Auto Group, Inc. or its personal indemnitors. 10. The parties request that the Court issue the Order as proposed. 12 IT IS SO STIPULATED. 13 DATED: 14 TIMOTHY J. TOMLIN, 15 Attorney for Cross-Complainant HUDSON INSURANCE COMPANY 16 17 DATED: 18 KEVIN FAULK Attorney for Cross-Defendant JUDY NAVARRO 20 DATED 2/4/2021 21 ROBERT MOBAS SERI 22 Attorney for Cross-Defendant ALEJANDRINA GOMEZ CHAIDEZ 23 24 DATED: 25 PAULIANA LARA Attorney for Cross-Defendants MARTIN TAP IA and MARTHA HERNANDEZ 27 28 STIPULATION FOR DISBURSEMENT OF ALL INTERPLEADED FUNDS AND FOR DISMISSAL OF CASE; ORDER THEREON 4 I ORDER ON STIPULATION Having reviewed the stipulafion of the parties, and good cause appearing therefor, 1. The interpleader funds on the deposit with the Court &om the Bond of Hudson Insurance Company Bond No. 10076266 issued to Rsidhu Auto Group, Inc. dba Auto Empire shall be disbursed by the Clerk of the Court as follows: A. $ 1,750.00 payable to "HUDSON INSURANCE COMPANY" and mailed to Timothy Tomlin, Law Offices of John L. Fallat, 68 Mitchell Blvd, Suite 135, San Rafael, CA 94903. B. $ 909.15 re: ALEJANDRINA GOMEZ CHAIDEZ, payable to "Law Offices of Robert Mobasseri, Client Trust Account" and mailed to Robert Mobasseri, Esq. Law Offices of Robert B. 10 Mobasseri, A.P.C., 1055 W. 7th Street, Suite 2140, Los Angeles, California 90017. C. $ 6,406.95 re: Judy Navarm payable to "Law Offices of Kevin Faulk — Trust 12 Account" and mailed to Kevin Faulk, Esq. 530 Lawrence Expressway ¹361, Sunnyvale, CA 94085. 13 D. $ 933.90 re: MARTIN TAPIA and MARTHA HERNANDEZ, payable to 14 "MARTIN TAPIA and MARTHA HERNANDEZ" and mailed to Pauliana Lara, Esq. Consumer Action 15 Law Group, PC, 3700 Eagle Rock Boulevard, Los Angeles, CA 90065. 16 E. Interest on the deposited funds shall be paid to the specified parties as follows: 17 11.02% to Alejandrina Gomez Chaidez, 77.66% to Judy Navarm and 11.32% to Martin Tapis and Martha 18 Hernandez jointly. 19 2. The Cross-Complaint shall be dismissed with prejudice as to the stipulating cross- 20 defendants upon the payment of the interpleaded funds. 21 3. The stipulation of the parties and this Order thereon shall not affect any claims or rights of 22 action the parties hereto may have against RSIDHU AUTO GROUP, INC. D/B/A AUTO EMPIRE D/B/A 23 AUTO EMPIRE OF FRESNO or its personal indemnitor Raj Sidhu. 24 25 IT IS SO ORDERED. 26 DATED: 27 JUDGE OF THE SUPERIOR COURT STIPULATION FOR DISBURSEMENT OF ALL INTERPLEADED FUNDS AND FOR DISMISSAL OF CASE; ORDER THEREON 5 1 PROOF OF SERVICE BY MAIL [CCP tt1013(a)] I, ROXANNE CULLEN, declare that I am not a party to this action, am over the age of 18 years, maintain a business address at 68 Mitchell Boulevard, Suite 135, San Rafael, CA 94903-2046, County of Marin, and that on the date shown below, I caused to be served the documents listed below on the persons listed herein by placing the envelopes for collection and mailing following our ordinary business practices. I am readily familiar with this business'ractice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it isdeposited in the ordinary 9 course of business with the United States Postal Service in a sealed envelope with postage fully prepaid. The envelope(s) were addressed and mailed as follows: 10 11 DOCUMENTS SERVED: "STIPULA TION FOR DISBURSEMENT OF ALL INTERPLEADED 12 FUNDS AND FOR DISMISSAL OF CASE" 13 SERVED UPON: 14 Barbara A. Rohr, Esq. 15 Law Offices of Robert B. Mobasseri, PC 1055 West 7@ Street, Suite 2140 16 Los Angeles, CA 90017 Tel: (213) 282-2000 17 Fax: (213) 282-3000 18 Counsel for PlaintiWICross-Defendant Aleiandrina Gomez Chaidez 19 Kevin Faulk, Esq. Law Offices of Kevin Faulk 20 530 Lawrence Expressway, ¹361 Sunnyvale, CA 94085 21 Tel: (408) 599-3277 22 Fax: (408) 800-4046 Counsel for Plaintiff/Cross-Defendant Judv Navarro 23 Pauliana N. Lara, Esq. 24 Consumer Action Law Group, PC 25 3700 Eagle Rock Boulevard Los Angeles, CA 90065 26 Tel: (818) 254-8413 Fax: (866) 400-0475 27 Counsel for Martin Taoia and Martha Hernandez 28 Jamie D. Wells, Esq. McGuire Woods LLP Two Embarcadero Center, Suite 1300 3 San Francisco, CA 94111 Tel: (415) 844-9944 Email: aleQmcauirewoods.corn Counsel for Defendant TD Auto Finance LLC 6 I declare under penalty of perjury that the foregoing is true and correct and that this proof of service 7 was executed on the date stated below, at San Rafael, California DATED: February 10, 2021 ROXAhfNE CULLEN 10 12 13 14 15 16 17 18 20 21 22 23 25 27 28