HomeMy WebLinkAbout[External]Clarke CooperFrom:Clarke Cooper
To:Jason Simpson
Subject:[External]Clarke Cooper
Date:Tuesday, April 16, 2024 8:22:16 PM
Attachments:JUAN ROTELLI (Case Number CVRI2401174).pdf
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Clarke Cooper
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ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO: 313780
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NAME: EDWARD W. O'CONNELL JR.
FOR COURT USE ONLY
FIRM NAME:
(3) = for default previously entered on (date):
STREETADDRESS: P.O. BOX 1243
CITY: LAKE ELSINORE STATE: CA ZIP CODE: 92531
Credits acknowledged
TELEPHONE NO.: 951-464-9619 FAX No.: 951-880-0527
a.
E-MAIL ADDRESS:
$
ATTORNEY FOR (name): JUAN ROTELLINI
b.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF RIVERSIDE
STREET ADDRESS: 4050 MAIN STREET
MAILING ADDRESS:
(1) Special .................... $
CITY AND ZIP CODE: RIVERSIDE, 92501
$
BRANCH NAME: HISTORIC RIVERSIDE COURTHOUSE
(2) General .................... $
Plaintiff/Petitioner: JUAN ROTELLINI
Defendant/Respondent: CLARKE M. COOPER ET AL
c.
REQUEST FOR aj Entry of Default 0 Clerk's Judgment
CASE NUMBER:
(Application) = Court Judgment
CVR12401174
Not for use in actions under the Fair Debt Buying Practices Act (Civ. Code, § 1788.50 et seq.); (see form CIV -105)
1. TO THE CLERK: On the complaint or cross-complaint filed
a. on (date): MARCH 4, 2024
b. by (name): JUAN ROTELLINI
c. Enter default of defendant (names):
CLARKE M. COOPER AND CLARKE M. COOPER LIVING FAMILY TRUST AS DATED 10-4-1989
d. 0 I request a court judgment under Code of Civil Procedure sections 585(b), 585(c), 989, etc., against defendant
(names):
(Testimony required. Apply to the clerk fora hearing date, unless the court will enter a judgment on an affidavit under
Code Civ. Proc., § 585(d).)
e. Enter clerk's judgment
(1) 0 for restitution of the premises only and issue a writ of execution on the judgment. Code of Civil Procedure section
1174(c) does not apply. (Code Civ. Proc., § 1169.)
0 Include in the judgment all tenants, subtenants, named claimants, and other occupants of the premises. The
Prejudgment Claim of Right to Possession was served in compliance with Code of Civil Procedure section
415.46.
(2) = under Code of Civil Procedure section 585(a). (Complete the declaration under Code Civ. Proc., § 585.5 on the
g. Daily damages were demanded in complaint at the rate of: $ per day beginning (date):
(* Personal injury or wrongful death actions; Code Civ. Proc., § 425. 11.)
3. 0 (Check if filed in an unlawful detainer case.) Legal document assistant or unlawful detainer assistant information is on the
reverse (complete item 4).
Date: 4/12/2023 '��
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EDWARD W. O'CONNELL JR.
(TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY FOR P/AINTIFF)
FOR COURT (1) F_x_1 Default entered as requested on (date):
USE ONLY (2) = Default NOT entered as requested (state reason):
Clerk, by Deputy Page 1 or
Form Adopted for Mandatory Use REQUEST FOR ENTRY OF DEFAULT Code of Civil Procedure, §§
Judicial Council of California WWW.Courts.ca.gov
CIV -100 [Rev. January 1. 2023] (Application to Enter Default)
c nr-inn
Plaintiff/Petitioner: JUAN ROTELLINI CASE NUMBER:
Defendant/Respondent: CLARKE M. COOPER ET AL CVR12401174
4. Legal document assistant or unlawful detainer assistant (Bus. & Prof. Code, § 6400 et seq.). A legal document assistant or
unlawful detainer assistant= did = did not for compensation give advice or assistance with this form. If declarant has
received any help or advice for pay from a legal document assistant or unlawful detainer assistant, state:
a. Assistant's name:
b. Street address, city, and zip code:
c. Telephone no.:
d. County of registration:
e. Registration no.:
f. Expires on (date):
5. Ox Declaration under Code Civ. Proc., § 585.5 (for entry of default under Code Civ. Proc., § 585(a)). This action
a. 0 is Ox is not on a contract or installment sale for goods or services subject to Civ. Code, § 1801 et seq. (Unruh Act).
b. 0 is Fx is not on a conditional sales contract subject to Civ. Code, § 2981 et seq. (Rees -Levering Motor Vehicle Sales
and Finance Act).
c. is F_x_1 is not on an obligation for goods, services, loans, or extensions of credit subject to Code Civ. Proc., § 395(b).
6. Declaration of mailing (Code Civ. Proc., § 587). A copy of this Request for Entry of Default was
a• = not mailed to the following defendants, whose addresses are unknown to plaintiff or plaintiffs attorney (names):
b. 0 mailed first-class, postage prepaid, in a sealed envelope addressed to each defendant's attorney of record or, if none,
to each defendant's last known address as follows:
(1) Mailed on (date): 4/12/2024 (2) To (specify names and addresses shown on the envelopes):
Clarke M. Cooper Living Family Trust as dated 10-4-1989 CLARKE M. COOPER
240 HACIENDA DRIVE ARCADIA, CA 91006 240 HACIENDA DRIVE ARCADIA, CA 91006
I declare under penalty of perjury under the laws of the State of California that the foregoing items 4, 5, and 6 are true and correct.
Date: 4/12/2024
EDWARD W. O'CONNELL JR. '
(TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT)
7. Memorandum of costs (required if money judgment requested). Costs and disbursements are as follows (Code Civ. Proc.,
§ 1033.5):
a. Clerk's filing fees .................... $
b. Process server's fees ................. $
c. Other (specify): $
d. $
e. TOTAL ............................. $
f. = Costs and disbursements are waived.
g. I am the attorney, agent, or party who claims these costs. To the best of my knowledge and belief this memorandum of costs is
correct and these costs were necessarily incurred in this case.
I declare under penalty of perjury under the laws of the State of California that the foregoing item 7 is true and correct.
Date:
(TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT)
CIV -100 [Rev. January 1, 2023] REQUEST FOR ENTRY OF DEFAULT
(Application to Enter Default)
t IV-Iut
Plaintiff/Petitioner: JUAN ROTELLINI CASE NUMBER:
Defendant/Respondent. CLARKE M. COOPER ET AL CVR12401174
S. Declaration of nonmilitary status (required for a judgment).
No defendant/respondent named in item 1 c is in the military service of the United States as defined by either the Servicemembers
Civil Relief Act (see 50 U.S.C. § 3911(2)) or California Military and Veterans Code sections 400 and 402(f).
1 know that no defendant/respondent named in item 1 c is in the U.S. military service because (check all that apply):
a. the search results that I received from https://scra.dmdc.osd mil/ say the defendant/respondent is not in the U.S. military
service.
b. I am in regular communication with the defendant/respondent and know that they are not in the U.S. military service.
c. I recently contacted the defendant/respondent, and they told me that they are not in the U.S. military service.
d• 0 I know that the defendant/respondent was discharged from U.S. military service on or about (date):
e. the defendant/respondent is not eligible to serve in the U.S. military because they are:
= incarcerated = a business entity
f. 0 other (specify):
Note
• U.S. military status can be checked online at https://scra.dmdc.osd.mill..
• If the defendant/respondent is in the military service, or their military status is unknown, the defendant/respondent
is entitled to certain rights and protections under federal and state law before a default judgment can be entered.
• For more information, see https,//selfhelp courts ca gov/military-defaults.
I declare under penalty of perjury under the laws of the State of California that the foregoing item 8 is true and correct.
Date:
(TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT)
CIV -100 [Rev. January 1, 2023] REQUEST FOR ENTRY OF DEFAULT
(Application to Enter Default)
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