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06+Ex+Parte+App+to+Stay+Judgment

06+Ex+Parte+App+to+Stay+Judgment

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Published by: Gregory Russell on Mar 02, 2014
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1
MOTION FOR STAY OF JUDGMENT/EXECUTION PENDING APPEAL
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Frances M. Campbell (SBN 211563) Anthony Carr, Of Counsel (SBN 123011)Law Office of Frances M. Campbell, a Professional Corporation8050 Melrose Avenue, 2nd FloorLos Angeles, CA 90046Tel: (323) 863-5290Fax: (323) 944-0952 Attorney for Defendant Eurasian Auto Body, Inc.SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, WEST DISTRICTBEVERLY HILLS COURTHOUSEPETE’S AUTO, INC., SIMON SIMONYAN, Plaintiffs, v. EURASIAN AUTO BODY INC., et al., Defendants.)))))))))))))))))))))CASE NO.: 10U00096[A 
SSIGNED
 
TO
 
THE
 H
ON
. L
ESLIE
 E. B
ROWN
, D
EPT
. 6]
EX PARTE MOTION FOR STAY OF EXECUTION OF JUDGMENT FOR POSSESSION PENDING APPEAL[C. CIV. PROC. §§ 1176(
 A 
) / 918]; MEMORANDUM OF POINTS AND  AUTHORITIES[[P
ROPOSED
] O
RDER
 
LODGED
 
CONCURRENTLY 
 
HEREWITH
]
Date: May 5, 2010Time: 1:30 p.m.Dept.: 6Trial date March 5, 2010Judgment entered April 2, 2010 TO THE COURT, AND TO THE PLAINTIFFS AND THEIR ATTORNEY OF RECORD:
 
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MOTION FOR STAY OF JUDGMENT/EXECUTION PENDING APPEAL
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PLEASE TAKE NOTICE that Defendant Eurasian Auto Body, Inc. hereby respectfully applies for an Order directed to Plaintiffs and to the Sheriff’s Department of the County of Los Angeles, and to any other person acting on behalf of, or in concert with Plaintiff, staying execution of the judgment for possession entered on April 2, 2010 in this matter and the writ of possession issued on April 22, 2010.The application is made pursuant to Code of Civil Procedure sections 1176(a) and 918 on the grounds that (1) Judgment was entered against Defendant on April 2, 2010;(2) the writ of possession was issued on April 22, 2010;(3) Notice of Appeal was filed on May 4, 2010. Therefore, the April 2, 2010  judgment may be reversed, or the matter may be remanded to the Court with instructions to take some other action affecting the rights of Defendant. (4) Defendant will suffer considerable hardship if the judgment is not stayed pending appeal, in that it will incur over $200,000.00 if it is forced to move, only to potentially have the judgment against it vacated; and(5) Plaintiff will suffer no hardship at all so long as the Order staying execution of the Judgment is conditioned on Defendant’s payment of rent during the period of the stay, in accordance with
 Medford v. Superior Court,
140 Cal. App. 3d 236 (1983).The application is based on the Memorandum of Points and Authorities attached hereto, the declarations of Frances M. Campbell and Joe Merdkhanian, upon the Notice of of Appeal filed on May 4, 2010, and upon such other evidence and argument as the Court may consider at the hearing.Dated: March 2, 2014Respectfully submitted,LAW OFFICE OF FRANCES M. CAMPBELL a Professional Corporation By:__________________________________________Frances M. Campbell
 
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MOTION FOR STAY OF JUDGMENT/EXECUTION PENDING APPEAL
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 Attorney for Defendant Eurasian Auto Body, Inc.

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