Re: Sheriff Plumbing, Incorporated v. Kenneth Gray (KC067580)

MOTION TO COMPEL THE JUDGMENT CREDITOR TO PROVIDE THE JUDGMENT DEBTOR AN ACKNOWLEDGMENT OF SATISFACTION OF JUDGMENT AND FOR AN AWARD OF ATTORNEY FEES AND COSTS PURSUANT TO CCP § 724.050

Moving Party: Judgment Debtor Kenneth Gray

Respondent: Plaintiff Sheriff Plumbing, Inc.

POS: Moving OK; Opposing served by regular mail contrary to CCP § 1005(c)

In this breach of contract action, plaintiff alleged that Defendant Kenneth Gray (“Gray”) breached a written agreement consisting whereby plaintiff agreed to furnish labor, services, equipment and material for plumbing repairs and replacement to a sewer line damaged by a tree on the subject property, for which Defendant Gray agreed to pay the sum of $14,300.00. Thereafter, then parties agreed to modify the scope of the work to be performed, bringing the contract price to $57,086.75. Plaintiff sought to recover an unpaid balance of $55,656.75. The complaint, filed 4/15/15, assert