On December 08, 2016 a
Judgment
was filed
involving a dispute between
Valencia, Lourdes,
and
Pleasanton Fitness Llc,
for Wrongful Termination: Unlimited
in the District Court of Stanislaus County.
Preview
ClV-1 10
ATTORNEY OR PARTY WITHOUT AWORNEY (Mama. Safe Barnlmbnf. muddle“):
FOR COURT USE MLV
Lawrence W. Freiman. Esq. SBN 28891 7
100 Wilshire Blvd., Suite 700 Santa Monica, CA 90401
TELEPHONE Mo; 31 0-91 7-1 024
m "a W, 888-835-851 1 Electronically Filed
ADDRESS
E-MA-L lawrence @treimanlawmm
(apnonan:
9/25/2018 4:12 PM
““0““ F0“ (”m"): Lourdes Valencia Superior Court of California
SUPERIOR COURT 0F CALIFORNIA. COUNTV OF StaniSIaus County of Stanislaus
STREErADDREss: 801 10th 3L. 4th Floor Clerk of the Court
MAILING ADDRESS: By: Lindsey Stringfellow, Deputy
Modesto,
crrY AND ap cons; CA 95354
man mus: City Towers Courthouse
PLAINTIFF/PETITIONER: Lourdes Valencia
DEFENDANTIRESPONDENT: Pleasanton Fitness LLC
REQUEST FOR DISMISSAL CASE NUMBER: 9000248
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 as follows:
this action
E
a. (1)
D
With prejudice
Complaint
(2)
D Without prejudice
(3)
(4)
D
b. (1)
D
(2) Petition
Cross-oomplaint filed by (name):
Cross-complaint filed by (name):
on
on
(dale):
D (date):
2.
(5)
(6)
(Complete
The court
the clerk.
Entire action of
Other
D
in all
did
court fees
If
all
(specify):'
and
parties causes of action
all
did not waive court fees and costs for a party
and costs were waived.the declaration
case.
in this may be
(This information
an the back of this form must be completed).
obtained fi'om
m
Dismiss Claim 17 with pmjudice as to Plaintiff and without prejudice as to any potentially aggrieved
cases except family law cases.)
,
Date; September 25,20 l 8 .
E
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Cross—Complainant
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Defendant/Respondent
3.TO THE CLERK: Consent to theabove dismissalishereby given.“
Date:
’
mp2 0R mm NAME 0F
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Cross—Complainant
E Defendant/Respondem
(To be completed by clerk)
4.D Dismissal entered as requested on (date):
5 Ex Dismissal entered on (date): 9/25/2018 4:12 PM as stated above.
as to only (name):
6.D Dismissal not entered as requested forthe following reasons (specify):
7. a.
b.
D
D
x anomsy
Attorney or party without notified on (date):
Attorney or party without attorney not notified.
9/27/2018
a copy to be conformed E means to return
provide
Filing party failed to
conformed copy
Date: 9/25/2018 4:12 PM c'e'k-by .Deputy
Lindsey Stringfellow
Plan 1
of Z
“?WWW‘W mm? REQUEST FOR DISMISSAL gmfiafifimwflflm
cw cu...
Io [Ram Jun.
ClV-‘l 2013]
1.
www.mawv
CIV-1 1 0
PLAINTIFF/PETITIONERI Lourdes Valencia CASE NUMBER:
DEFENDANT/RESPONDENT: Pleasanton Fitness LLC 9000248
COURT'S RECOVERY OF WAIVED COURT FEES AND COSTS
Ifa 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 action for (name):
in this
The person named
2.
a- a
D
in item1 is(check one below):
not recovering anything of value by this action.
D
b.
c. D recovering less than $10,000
more
recovering $1 0.000 or
in
in
value by this action.
ischecked, item 3 must be completed.)
value by this action. (Ifitem 2c
3. Allcourt feesand court coststhatwere waived action
in this have been paid to the court
(check one): E Yes E No
ldeclare under penalty of petjury under the laws of the State of California that the information above
istrueand correct.
Date:
r
(TYPE D
0R PRINT NAME 0F ATTORNEYD oecuwmom
PARTY MAKING (S'GNATURE)
CIV-flo
|Rev. Janualy
2013]
‘l.
REQUEST FOR DISMISSAL Paco 2
of 2
PROOF OF SERVICE
I, Lawrence W. Freiman, declare:
AWN I am a resident of the State 0f California and over the age 0f eighteen years and represent the
Plaintiff in the within action. My business address is 100 Wilshire Blvd., Suite 700, Santa Monica,
CA 90401. On September 25, 2018, I served the within documents, entitled REQUEST FOR
DISMISSAL (PARTIAL) by placing the documents listed above in a sealed envelope with
\OOOVONLJ:
postage thereon fully prepaid, in the United States mail addressed to:
Dan Newman
Newman & Broomand
2360 East Bidwell St., Suite 100
10 Folsom, CA 95630
11 I am readily familiar with the firm’s practice of collection and processing documents for
mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day
12
with postage thereon fully prepaid in the ordinary course of business.
13 declare under penalty of pteury under the laws of the
I State of California that the above is
14 true and correct.
15
16
17 By:
Lawrence W. Freiman
18
19
20
21
22
23
24
25
26
27
28
PROOF OF SERVICE
Document Filed Date
September 25, 2018
Case Filing Date
December 08, 2016
Category
Wrongful Termination: Unlimited
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Preview
ClV-1 10 ATTORNEY OR PARTY WITHOUT AWORNEY (Mama. Safe Barnlmbnf. muddle“): FOR COURT USE MLV Lawrence W. Freiman. Esq. SBN 28891 7 100 Wilshire Blvd., Suite 700 Santa Monica, CA 90401 TELEPHONE Mo; 31 0-91 7-1 024 m "a W, 888-835-851 1 Electronically Filed ADDRESS E-MA-L lawrence @treimanlawmm (apnonan: 9/25/2018 4:12 PM ““0““ F0“ (”m"): Lourdes Valencia Superior Court of California SUPERIOR COURT 0F CALIFORNIA. COUNTV OF StaniSIaus County of Stanislaus STREErADDREss: 801 10th 3L. 4th Floor Clerk of the Court MAILING ADDRESS: By: Lindsey Stringfellow, Deputy Modesto, crrY AND ap cons; CA 95354 man mus: City Towers Courthouse PLAINTIFF/PETITIONER: Lourdes Valencia DEFENDANTIRESPONDENT: Pleasanton Fitness LLC REQUEST FOR DISMISSAL CASE NUMBER: 9000248 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 as follows: this action E a. (1) D With prejudice Complaint (2) D Without prejudice (3) (4) D b. (1) D (2) Petition Cross-oomplaint filed by (name): Cross-complaint filed by (name): on on (dale): D (date): 2. (5) (6) (Complete The court the clerk. Entire action of Other D in all did court fees If all (specify):' and parties causes of action all did not waive court fees and costs for a party and costs were waived.the declaration case. in this may be (This information an the back of this form must be completed). obtained fi'om m Dismiss Claim 17 with pmjudice as to Plaintiff and without prejudice as to any potentially aggrieved cases except family law cases.) , Date; September 25,20 l 8 . E (1'va 0R PRINT NAME or Anomzv D Lamenqefrgiman ............................ PARTY wrmou‘r Anoanm (SIGMTURE) 'lf dismissal r uasted is figfiofl'fiigfifi Mw'YIS-fs'gai‘igfififufigfgn ‘r‘d ”m" "‘993"“ Attorney or party wm‘OUt of specified parties only 01 apeclfied causes cl adion D PIaintiff/Petitioner Cross—Complainant E anomey for: Defendant/Respondent 3.TO THE CLERK: Consent to theabove dismissalishereby given.“ Date: ’ mp2 0R mm NAME 0F “ E Anoausv D PARTV wn‘nour ATTORNEY) (SIGNATURE) —nor Regmnse (Famu seekingd 33mm anomey for: Attorney or party without D It [a fmnlnplaim °' ' 0" _ , an m a Ifaw)‘ P&Lm 3g: missozzsasm H&u‘i’ggybyoéodmwn moon a1 seeds" g9?» D . .. Plaintnff/Pemloner Cross—Complainant E Defendant/Respondem (To be completed by clerk) 4.D Dismissal entered as requested on (date): 5 Ex Dismissal entered on (date): 9/25/2018 4:12 PM as stated above. as to only (name): 6.D Dismissal not entered as requested forthe following reasons (specify): 7. a. b. D D x anomsy Attorney or party without notified on (date): Attorney or party without attorney not notified. 9/27/2018 a copy to be conformed E means to return provide Filing party failed to conformed copy Date: 9/25/2018 4:12 PM c'e'k-by .Deputy Lindsey Stringfellow Plan 1 of Z “?WWW‘W mm? REQUEST FOR DISMISSAL gmfiafifimwflflm cw cu... Io [Ram Jun. ClV-‘l 2013] 1. www.mawv CIV-1 1 0 PLAINTIFF/PETITIONERI Lourdes Valencia CASE NUMBER: DEFENDANT/RESPONDENT: Pleasanton Fitness LLC 9000248 COURT'S RECOVERY OF WAIVED COURT FEES AND COSTS Ifa 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 action for (name): in this The person named 2. a- a D in item1 is(check one below): not recovering anything of value by this action. D b. c. D recovering less than $10,000 more recovering $1 0.000 or in in value by this action. ischecked, item 3 must be completed.) value by this action. (Ifitem 2c 3. Allcourt feesand court coststhatwere waived action in this have been paid to the court (check one): E Yes E No ldeclare under penalty of petjury under the laws of the State of California that the information above istrueand correct. Date: r (TYPE D 0R PRINT NAME 0F ATTORNEYD oecuwmom PARTY MAKING (S'GNATURE) CIV-flo |Rev. Janualy 2013] ‘l. REQUEST FOR DISMISSAL Paco 2 of 2 PROOF OF SERVICE I, Lawrence W. Freiman, declare: AWN I am a resident of the State 0f California and over the age 0f eighteen years and represent the Plaintiff in the within action. My business address is 100 Wilshire Blvd., Suite 700, Santa Monica, CA 90401. On September 25, 2018, I served the within documents, entitled REQUEST FOR DISMISSAL (PARTIAL) by placing the documents listed above in a sealed envelope with \OOOVONLJ: postage thereon fully prepaid, in the United States mail addressed to: Dan Newman Newman & Broomand 2360 East Bidwell St., Suite 100 10 Folsom, CA 95630 11 I am readily familiar with the firm’s practice of collection and processing documents for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day 12 with postage thereon fully prepaid in the ordinary course of business. 13 declare under penalty of pteury under the laws of the I State of California that the above is 14 true and correct. 15 16 17 By: Lawrence W. Freiman 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE