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  • JOEL ANDREWS, ET AL. VS JOHN GAULE, ET AL. Legal Malpractice (General Jurisdiction) document preview
  • JOEL ANDREWS, ET AL. VS JOHN GAULE, ET AL. Legal Malpractice (General Jurisdiction) document preview
						
                                

Preview

Electronically FILED by Superior Court of California, County of Los Angeles on 01/28/2020 01:39 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Wong,Deputy Clerk F. Thomas Hovore (SBN 196851) 1 HOVORE LAW 3500 W. Olive Ave, Suite 300 2 Burbank, CA 91505 3 Phone: (800) 418-1337 Fax: (818) 369-6880 4 Email: Tom@Hovore.com Attorney for Plaintiffs 5 6 SUPERIOR COURT OF THE STATE OF CALIFORNIA 7 IN AND FOR THE COUNTY OF LOS ANGELES 8 9 JOEL and TELMA ANDREWS, husband and Case No.: 19BBCV00813 wife, [Assigned for All Purposes to Hon. Ralph C. 10 Plaintiffs, Hofer, Dept. D] vs. 11 JOHN V. GAULE, individually; LAW OFFICE PLAINTIFFS’ NOTICE OF MOTION AND 12 OF JOHN V. GAULE, APC a California MOTION FOR LEAVE TO FILE FIRST professional corporation; ODDENINO AND AMENDED COMPLAINT 13 GAULE, APC a California professional corporation; MICHAEL L. ODDENINO, [CONCURRENTLY FILED WITH 14 individually; and DOES 1 through 50, inclusive, DECLARATION OF F. THOMAS HOVORE IN SUPPORT THEREOF; 15 Defendants {PROPOSED} ORDER] 16 Hearing Date: February 21, 2020 Hearing Time: 8:30 p.m. 17 Department: D 18 Reservation No. 044499822352 19 20 Complaint Filed: September 9, 2019 21 22 PLEASE TAKE NOTICE that on February 21, 2020, at 8:30 a.m. or as soon thereafter as the 23 matter may be heard, in Department D of the Glendale Courthouse, located at 600 East Broadway, 24 Glendale, CA, 91206, Plaintiffs Joel and Telma Andrews (collectively, “Plaintiffs”) will and hereby do 25 move this Court for an order granting Plaintiffs leave to file their First Amended Complaint and that the 26 proposed First Amended Complaint submitted with this Motion be deemed filed. 27 This Motion is made pursuant to California Code of Civil Procedure section 473(a)(1) and is based 28 on this Notice of Motion, the Memorandum of Points and Authorities, the proposed First Amended -1- _____________________________________________________________________________________________________________________________ _________________________________________________________________________________________ PLAINTIFFS’ NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT