This case was last updated from Los Angeles County Superior Courts on 06/12/2019 at 13:50:30 (UTC).

JINGXUAN ZHANG VS HUMMINGBIRD NEST ENTERTAINMENT CORP

Case Summary

On 10/25/2017 JINGXUAN ZHANG filed a Labor - Other Labor lawsuit against HUMMINGBIRD NEST ENTERTAINMENT CORP. This case was filed in Los Angeles County Superior Courts, Pomona Courthouse South located in Los Angeles, California. The Judge overseeing this case is GLORIA WHITE-BROWN. The case status is Pending - Other Pending.

Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    ****9738

  • Filing Date:

    10/25/2017

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Labor - Other Labor

  • Court:

    Los Angeles County Superior Courts

  • Courthouse:

    Pomona Courthouse South

  • County, State:

    Los Angeles, California

Judge Details

Presiding Judge

GLORIA WHITE-BROWN

 

Party Details

Plaintiff

ZHANG JINGXUAN

Defendants

HUMMINGBIRD NEST ENTERTAINMENT CORP

YE YIPING

HUMMINGBIRD NEST ENTERTAINMENT CORP.

Attorney/Law Firm Details

Plaintiff Attorneys

KEARNEY THOMAS A.

LITTLEFIELD PRESCOTT WAYNE

Defendant Attorney

HSU RAY

 

Court Documents

Complaint

10/25/2017: Complaint

Unknown

10/25/2017: Unknown

Unknown

12/13/2017: Unknown

Minute Order

3/23/2018: Minute Order

Unknown

5/3/2018: Unknown

Unknown

5/3/2018: Unknown

Amendment to Complaint (Fictitious/Incorrect Name)

8/20/2018: Amendment to Complaint (Fictitious/Incorrect Name)

Declaration

10/31/2018: Declaration

Motion re:

10/31/2018: Motion re:

Order

12/10/2018: Order

Order

12/10/2018: Order

Notice

3/4/2019: Notice

Request for Entry of Default / Judgment

3/27/2019: Request for Entry of Default / Judgment

Unknown

5/8/2019: Unknown

Proof of Service (not Summons and Complaint)

5/8/2019: Proof of Service (not Summons and Complaint)

Order

5/9/2019: Order

Order

5/9/2019: Order

Summons (Joint Debtor)

5/30/2019: Summons (Joint Debtor)

38 More Documents Available

 

Docket Entries

  • 05/30/2019
  • Summons (Joint Debtor); Filed by Jingxuan Zhang (Plaintiff)

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  • 05/16/2019
  • Declaration (DECLARATION OF ANDREW J. KEARNEY RE POSTAL DAMAGE OF NOTICE OF ORDERS AND RE-SERVICE THEREOF); Filed by Jingxuan Zhang (Plaintiff)

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  • 05/10/2019
  • Notice (Notice of Orders); Filed by Jingxuan Zhang (Plaintiff)

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  • 05/09/2019
  • at 09:00 AM in Department J, Gloria White-Brown, Presiding; Hearing on Ex Parte Application (TO SERVE DEFENDANT YIPING YE VIA PUBLICATION AND MEMORANDUM IN SUPPORT) - Held - Motion Granted

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  • 05/09/2019
  • at 09:00 AM in Department J, Gloria White-Brown, Presiding; Hearing on Ex Parte Application (FOR AMENDMENT TO COMPLAINT) - Held - Motion Granted

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  • 05/09/2019
  • at 09:00 AM in Department J, Gloria White-Brown, Presiding; Hearing on Ex Parte Application (TO EXTEND THE TIME PLAINTIFF HAS TO OBTAIN DEFAULT JUDGMENT AGAINST DEFENDANT) - Held - Motion Granted

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  • 05/09/2019
  • Order (Extending Time Plaintiff Has to Obtain Default Judgment Against Defendant Hummingbird Nest Entertainment Corp); Filed by Jingxuan Zhang (Plaintiff)

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  • 05/09/2019
  • Minute Order ( (Hearing on Ex Parte Application TO EXTEND THE TIME PLAINTIFF ...)); Filed by Clerk

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  • 05/09/2019
  • Order (For Publication of Summons); Filed by Jingxuan Zhang (Plaintiff)

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  • 05/09/2019
  • Order (Granting Amendment to Complaint); Filed by Jingxuan Zhang (Plaintiff)

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40 More Docket Entries
  • 02/07/2018
  • at 08:30 AM in Department J; Order to Show Cause Re: Failure to File Proof of Service (OSC-Failure to File Proof of Serv; Matter Placed Off Calendar) -

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  • 01/16/2018
  • Answer; Filed by Hummingbird Nest Entertainment Corp. (Defendant)

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  • 01/11/2018
  • Request for Entry of Default / Judgment; Filed by Jingxuan Zhang (Plaintiff)

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  • 12/13/2017
  • Notice

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  • 12/01/2017
  • OSC-Failure to File Proof of Serv; Filed by Clerk

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  • 10/26/2017
  • Notice of Case Management Conference; Filed by Clerk

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  • 10/25/2017
  • Complaint; Filed by Jingxuan Zhang (Plaintiff)

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  • 10/25/2017
  • Notice of Case Assignment - Unlimited Civil Case; Filed by Clerk

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  • 10/25/2017
  • Civil Case Cover Sheet; Filed by Jingxuan Zhang (Plaintiff)

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  • 10/25/2017
  • Summons (on Complaint)

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Tentative Rulings

Case Number: KC069738    Hearing Date: October 19, 2020    Dept: J

OSC DATE: Monday, October 19, 2020

RE: Zhang v. Hummingbird Nest Entertainment Corp. (KC069738)

______________________________________________________________________________

 

Plaintiff Jingxuan Zhang’s APPLICATION FOR DEFAULT JUDGMENT

Tentative Ruling

Plaintiff Jingxuan Zhang’s Application for Default Judgment is DENIED without prejudice.

Background

Plaintiff Jingxuan Zhang (“Plaintiff”) alleges that Hummingbird Nest Entertainment Corp. (“Hummingbird”) failed to provide him with rest and meal breaks, failed to pay him all wages due, including overtime, and failed to provide him with accurate wage statements. On October 25, 2017, Plaintiff filed a complaint, asserting causes of action against Defendants Hummingbird and Does 1-50 for:

  1. Failure to Provide Rest Periods—Cal. Labor Code § 226.7

  2. Failure to Provide Meal Periods—Cal. Labor Code § 226.7

  3. Failure to Pay Minimum Wage—Cal. Labor Code § 1197

  4. Failure to Pay Overtime—Cal. Labor Code §§ 510 and 1194

  5. Failure to Provide Accurate Wage Statements—Cal. Labor Code § 226

  6. Failure to Reimburse for Reasonable Business Expenses—Cal. Labor Code § 2802

  7. Waiting Time Penalties—Cal. Labor Code §§ 201-203

    On August 20, 2018, Plaintiff filed an Amendment to Complaint, wherein Yiping Ye (“Ye”) was substituted in for Doe 1.

    On March 18, 2019, Hummingbird’s answer was stricken. On March 27, 2019, Hummingbird’s default was entered. On May 9, 2019, the court granted, inter alia, Plaintiff’s ex parte application for amendment to complaint. On August 7, 2019, Ye’s default was entered.

    An Order to Show Cause Re: Failure to Proceed with Default Judgment is set for October 19, 2020.

Discussion

Plaintiff’s Application for Default Judgment is DENIED without prejudice. The following defects are noted:

  1. Again, the Judicial Council Request for Entry of Default Form CIV-100 identifies the following amounts: $43,610 as “[d]emand of complaint,” $35,642.50 in general damages, $4,355.00 in interest, $3,210.69 in costs and $1,698.00 in attorney fees; however, the “TOTALS” amount is listed as $39,997.50 (the above figures, however, total $80,548.69). Again, the proposed default judgment lists damages of $35,642.50, $4,355.00 in interest, $1,698 in attorney fees and $3,210.69, but states the “TOTAL” is $39,997.50 (the above figures, however, total $44,906.19).

  2. Again, Ye is identified as Hummingbird’s Chief Executive. (See Supplemental Statement of the Case, 2:1-3; Plaintiff’s Supplemental Decl., ¶1.) Plaintiff attests that Ye “personally directed [his] job duties on a day to day basis” and that “Ye knew [his] schedule every day and would order [him] to work longer than 8 hours in a single day or 40 hours in a single week” (Plaintiff’s Decl., ¶6); however, it is unclear how the foregoing supports the conclusion that Ye would be personally liable as Plaintiff’s employer. Plaintiff does not provide any documentary evidence supporting his statement that Ye was “the owner of Defendant Hummingbird Nest Entertainment Corp.” (Id., ¶15.) Plaintiff’s complaint does not include alter ego allegations.

  3. Much of Exhibits A-C and Exhibits D and E are comprised of communications made in a foreign language. California Rules of Court (“CRC”) Rule 3.1110(g) provides that “[e]xhibits written in a foreign language must be accompanied by an English translation, certified under oath by a qualified interpreter.”) There is no indication that the translation provided complies with this provision.

ANALYSIS

Yes (3/27/19;

8/7/19) Default Entered. (JC Form CIV-100.)

Yes Dismissal of all parties against whom judgment is not sought or an

application for separate judgment against specified parties under CCP

579, supported by a showing of grounds for each judgment. (CRC 3.1800(a)(7).)

Yes Mandatory Judicial Council Form CIV-100. (CRC 3.1800(a).)

Yes Relief sought is within amount of prayer of complaint or statement of damages. (Due Process; Greenup v. Rodman (1986) 42 Cal.3d 822, 824.)

Yes Summary of the case. (CRC 3.1800 (a)(1).)

Yes Declarations in support of the judgment. (CRC 3.1800 (a)(2).)

Yes Attorney fees if supported by contract, statute or law. (CRC 3.1800 (a)(9); Local R. 3.214; open book – CC 1717.5.)

Yes __ __ Interest computations. (CRC 3.1800 (a)(3); 10% for contracts - Civ. Code 3289.)

Yes Memorandum of costs and disbursements. (CRC 3.1800 (a)(4); JC Form CIV-100 item 7.)

Yes Declaration of nonmilitary status for each defendant. (CRC 3.1800 (a)(5); JC Form CIV-100 item 8.)

Yes Proposed form of judgment. (CRC 3.1800 (a)(6).)

N/A Statement of Damages served (P.I./wrongful death). (JC Form CIV-050; CCP 425.11.)

N/A Punitive Damages are supported. Info re Defendant’s financial status. (CCP 425.115)

Case Number: KC069738    Hearing Date: August 14, 2020    Dept: J

OSC DATE: Friday, August 14, 2020

RE: Zhang v. Hummingbird Nest Entertainment Corp. (KC069738)

______________________________________________________________________________

 

Plaintiff Jingxuan Zhang’s APPLICATION FOR DEFAULT JUDGMENT

Tentative Ruling

Plaintiff Jingxuan Zhang’s Application for Default Judgment is DENIED without prejudice.

Background

Plaintiff Jingxuan Zhang (“Plaintiff”) alleges that Hummingbird Nest Entertainment Corp. (“Hummingbird”) failed to provide him with rest and meal breaks, failed to pay him all wages due, including overtime, and failed to provide him with accurate wage statements. On October 25, 2017, Plaintiff filed a complaint, asserting causes of action against Defendants Hummingbird and Does 1-50 for:

  1. Failure to Provide Rest Periods—Cal. Labor Code § 226.7

  2. Failure to Provide Meal Periods—Cal. Labor Code § 226.7

  3. Failure to Pay Minimum Wage—Cal. Labor Code § 1197

  4. Failure to Pay Overtime—Cal. Labor Code §§ 510 and 1194

  5. Failure to Provide Accurate Wage Statements—Cal. Labor Code § 226

  6. Failure to Reimburse for Reasonable Business Expenses—Cal. Labor Code § 2802

  7. Waiting Time Penalties—Cal. Labor Code §§ 201-203

    On August 20, 2018, Plaintiff filed an Amendment to Complaint, wherein Yiping Ye (“Ye”) was substituted in for Doe 1.

    On March 18, 2019, Hummingbird’s answer was stricken. On March 27, 2019, Hummingbird’s default was entered. On May 9, 2019, the court granted, inter alia, Plaintiff’s ex parte application for amendment to complaint. On August 7, 2019, Ye’s default was entered.

    An Order to Show Cause Re: Failure to Proceed with Default Judgment is set for August 14, 2020.

Discussion

Plaintiff’s Application for Default Judgment is DENIED without prejudice. The following defects are noted:

  1. The Judicial Council Request for Entry of Default Form CIV-100 identifies the following amounts: $43,610 as “[d]emand of complaint,” $35,642.50 in general damages, $4,355.00 in interest, $3,210.69 in costs and $1,698.00 in attorney fees; however, the “TOTALS” amount is listed as $39,997.50 (the above figures, however total $80,548.69). The proposed default judgment lists damages of $35,642.50, $4,355.00 in interest, $1,698 in attorney fees and $3,210.69, but states the “TOTAL” is $39,997.50 (the above figures, however, total $44,906.19).

  2. Again, Ye is identified as Hummingbird’s Chief Executive. (See Supplemental Statement of the Case, 2:1-3; Plaintiff’s Supplemental Decl., ¶1.) It is unclear, then, how Ye would be personally liable as Plaintiff’s employer. Although Plaintiff addresses Ye’s personal liability in 2:5-11 of the Supplemental Statement of the Case, the statements are not corroborated by Plaintiff’s declaration.

  3. Plaintiff attests that, “[f]rom February of 2016 through April 15, 2017 I worked 6 days per week and more than 8 hours in a day or 40 hours in a week. I took the time to look at a calendar and compare each day with my recollection of time worked and records including emails, text messages, and various schedules, attached hereto as Exhibit ‘A,’ to calculate the number of hours that I worked in excess of 8 hours in a day or 40 hours in a week.” (Plaintiff’s Supplemental Decl., ¶6.) Much of Exhibit A, however, is comprised of communications made in a foreign language. No translation has been provided. (See California Rules of Court (“CRC”) Rule 3.1113.)

ANALYSIS

Yes (3/27/19;

8/7/19) Default Entered. (JC Form CIV-100.)

Yes Dismissal of all parties against whom judgment is not sought or an

application for separate judgment against specified parties under CCP

579, supported by a showing of grounds for each judgment. (CRC 3.1800(a)(7).)

Yes Mandatory Judicial Council Form CIV-100. (CRC 3.1800(a).)

Yes Relief sought is within amount of prayer of complaint or statement of damages. (Due Process; Greenup v. Rodman (1986) 42 Cal.3d 822, 824.)

Yes Summary of the case. (CRC 3.1800 (a)(1).)

Yes Declarations in support of the judgment. (CRC 3.1800 (a)(2).)

Yes Attorney fees if supported by contract, statute or law. (CRC 3.1800 (a)(9); Local R. 3.214; open book – CC 1717.5.)

Yes __ __ Interest computations. (CRC 3.1800 (a)(3); 10% for contracts - Civ. Code 3289.)

Yes Memorandum of costs and disbursements. (CRC 3.1800 (a)(4); JC Form CIV-100 item 7.)

Yes Declaration of nonmilitary status for each defendant. (CRC 3.1800 (a)(5); JC Form CIV-100 item 8.)

Yes Proposed form of judgment. (CRC 3.1800 (a)(6).)

N/A Statement of Damages served (P.I./wrongful death). (JC Form CIV-050; CCP 425.11.)

N/A Punitive Damages are supported. Info re Defendant’s financial status. (CCP 425.115)

Case Number: KC069738    Hearing Date: January 13, 2020    Dept: J

HEARING DATE: Monday, December 9, 2019 [No OSC]

RE: Zhang v. Hummingbird Nest Entertainment Corp. (KC069738)

______________________________________________________________________________

 

Plaintiff Jingxuan Zhang’s APPLICATION FOR DEFAULT JUDGMENT

Tentative Ruling

Plaintiff Jingxuan Zhang’s Application for Default Judgment is DENIED without prejudice.

Background

Plaintiff Jingxuan Zhang (“Plaintiff”) alleges that Hummingbird Nest Entertainment Corp. (“Hummingbird”) failed to provide him with rest and meal breaks, failed to pay him all wages due, including overtime, and failed to provide him with accurate wage statements. On October 25, 2017, Plaintiff filed a complaint, asserting causes of action against Defendants Hummingbird and Does 1-50 for:

  1. Failure to Provide Rest Periods—Cal. Labor Code § 226.7

  2. Failure to Provide Meal Periods—Cal. Labor Code § 226.7

  3. Failure to Pay Minimum Wage—Cal. Labor Code § 1197

  4. Failure to Pay Overtime—Cal. Labor Code §§ 510 and 1194

  5. Failure to Provide Accurate Wage Statements—Cal. Labor Code § 226

  6. Failure to Reimburse for Reasonable Business Expenses—Cal. Labor Code § 2802

  7. Waiting Time Penalties—Cal. Labor Code §§ 201-203

    On August 20, 2018, Plaintiff filed an Amendment to Complaint, wherein Yiping Ye (“Ye”) was substituted in for Doe 1.

    On March 18, 2019, Hummingbird’s answer was stricken. On March 27, 2019, Hummingbird’s default was entered. On May 9, 2019, the court granted, inter alia, Plaintiff’s ex parte application for amendment to complaint. On August 7, 2019, Ye’s default was entered.

    Trial is set for December 9, 2019.

Discussion

Plaintiff’s Application for Default Judgment is DENIED without prejudice. The following defects are noted:

  1. Plaintiff identifies Ye as Hummingbird’s Chief Executive. (See Plaintiff’s Decl., ¶1.) It is unclear, then, how Ye would be personally liable as Plaintiff’s employer.

  2. It is unclear what Plaintiff’s salary was during the entirety of his employment. The Statement of the Case (1:6-7), Plaintiff’s declaration (¶3) and ¶6 of the complaint state that Plaintiff was paid $10/hour from November 2015 through January 2016. The Statement of the Case (1:7-9) and Plaintiff’s declaration (¶4) then state that Plaintiff was paid $2,000.00 per month no matter how many hours he worked during the February 2016-April 15, 2017 time period. The Statement of the Case states that Plaintiff’s “regular rate of pay was $20 per hour based on the salary he received” (1:17). Plaintiff, attests that during the February 2016-April 15, 2017 time period, he “worked 6 days per week and more than 8 hours in a day or 40 hours in a week” (¶6.) If the court takes the quoted $2,000.00/month figure and divides it by 160 hours (i.e., 40 hours/week, not taking any purported overtime into account), the court would arrive at an hourly rate of $12.50, not $20.00. The court requires clarification as to Plaintiff’s hourly figure during the February 2016-April 15, 2017 time period.

  3. Plaintiff references records “including emails, text messages, and various schedules” he purportedly reviewed to calculate the number of hours that he worked (Plaintiff’s Decl., ¶6), yet has failed to attach same to his declaration.

4. Plaintiff does not provide the court with any calculation regarding the 27,000 miles he estimates he drove his personal vehicle during his employment.

5. Plaintiff is requested to articulate each of the statutes pursuant to which he seeks attorney’s fees; “among others” is insufficient. (See Statement of the Case, 4:2.)

ANALYSIS

Yes (3/27/19;

8/7/19) Default Entered. (JC Form CIV-100.)

Yes Dismissal of all parties against whom judgment is not sought or an

application for separate judgment against specified parties under CCP

579, supported by a showing of grounds for each judgment. (CRC 3.1800(a)(7).)

Yes Mandatory Judicial Council Form CIV-100. (CRC 3.1800(a).)

Yes Relief sought is within amount of prayer of complaint or statement of damages. (Due Process; Greenup v. Rodman (1986) 42 Cal.3d 822, 824.)

Yes Summary of the case. (CRC 3.1800 (a)(1).)

Yes Declarations in support of the judgment. (CRC 3.1800 (a)(2).)

See above Attorney fees if supported by contract, statute or law. (CRC 3.1800 (a)(9); Local R. 3.214; open book – CC 1717.5.)

Yes __ __ Interest computations. (CRC 3.1800 (a)(3); 10% for contracts - Civ. Code 3289.)

Yes Memorandum of costs and disbursements. (CRC 3.1800 (a)(4); JC Form CIV-100 item 7.)

Yes Declaration of nonmilitary status for each defendant. (CRC 3.1800 (a)(5); JC Form CIV-100 item 8.)

Yes Proposed form of judgment. (CRC 3.1800 (a)(6).)

N/A Statement of Damages served (P.I./wrongful death). (JC Form MC-010; CCP 425.11.)

N/A Punitive Damages are supported. Info re Defendant’s financial status. (CCP 425.115)

Case Number: KC069738    Hearing Date: December 09, 2019    Dept: J

HEARING DATE: Monday, December 9, 2019 [No OSC]

RE: Zhang v. Hummingbird Nest Entertainment Corp. (KC069738)

______________________________________________________________________________

 

Plaintiff Jingxuan Zhang’s APPLICATION FOR DEFAULT JUDGMENT

Tentative Ruling

Plaintiff Jingxuan Zhang’s Application for Default Judgment is DENIED without prejudice.

Background

Plaintiff Jingxuan Zhang (“Plaintiff”) alleges that Hummingbird Nest Entertainment Corp. (“Hummingbird”) failed to provide him with rest and meal breaks, failed to pay him all wages due, including overtime, and failed to provide him with accurate wage statements. On October 25, 2017, Plaintiff filed a complaint, asserting causes of action against Defendants Hummingbird and Does 1-50 for:

  1. Failure to Provide Rest Periods—Cal. Labor Code § 226.7

  2. Failure to Provide Meal Periods—Cal. Labor Code § 226.7

  3. Failure to Pay Minimum Wage—Cal. Labor Code § 1197

  4. Failure to Pay Overtime—Cal. Labor Code §§ 510 and 1194

  5. Failure to Provide Accurate Wage Statements—Cal. Labor Code § 226

  6. Failure to Reimburse for Reasonable Business Expenses—Cal. Labor Code § 2802

  7. Waiting Time Penalties—Cal. Labor Code §§ 201-203

    On August 20, 2018, Plaintiff filed an Amendment to Complaint, wherein Yiping Ye (“Ye”) was substituted in for Doe 1.

    On March 18, 2019, Hummingbird’s answer was stricken. On March 27, 2019, Hummingbird’s default was entered. On May 9, 2019, the court granted, inter alia, Plaintiff’s ex parte application for amendment to complaint. On August 7, 2019, Ye’s default was entered.

    Trial is set for December 9, 2019.

Discussion

Plaintiff’s Application for Default Judgment is DENIED without prejudice. The following defects are noted:

  1. Plaintiff identifies Ye as Hummingbird’s Chief Executive. (See Plaintiff’s Decl., ¶1.) It is unclear, then, how Ye would be personally liable as Plaintiff’s employer.

  2. It is unclear what Plaintiff’s salary was during the entirety of his employment. The Statement of the Case (1:6-7), Plaintiff’s declaration (¶3) and ¶6 of the complaint state that Plaintiff was paid $10/hour from November 2015 through January 2016. The Statement of the Case (1:7-9) and Plaintiff’s declaration (¶4) then state that Plaintiff was paid $2,000.00 per month no matter how many hours he worked during the February 2016-April 15, 2017 time period. The Statement of the Case states that Plaintiff’s “regular rate of pay was $20 per hour based on the salary he received” (1:17). Plaintiff, attests that during the February 2016-April 15, 2017 time period, he “worked 6 days per week and more than 8 hours in a day or 40 hours in a week” (¶6.) If the court takes the quoted $2,000.00/month figure and divides it by 160 hours (i.e., 40 hours/week, not taking any purported overtime into account), the court would arrive at an hourly rate of $12.50, not $20.00. The court requires clarification as to Plaintiff’s hourly figure during the February 2016-April 15, 2017 time period.

  3. Plaintiff references records “including emails, text messages, and various schedules” he purportedly reviewed to calculate the number of hours that he worked (Plaintiff’s Decl., ¶6), yet has failed to attach same to his declaration.

4. Plaintiff does not provide the court with any calculation regarding the 27,000 miles he estimates he drove his personal vehicle during his employment.

5. Plaintiff is requested to articulate each of the statutes pursuant to which he seeks attorney’s fees; “among others” is insufficient. (See Statement of the Case, 4:2.)

ANALYSIS

Yes (3/27/19;

8/7/19) Default Entered. (JC Form CIV-100.)

Yes Dismissal of all parties against whom judgment is not sought or an

application for separate judgment against specified parties under CCP

579, supported by a showing of grounds for each judgment. (CRC 3.1800(a)(7).)

Yes Mandatory Judicial Council Form CIV-100. (CRC 3.1800(a).)

Yes Relief sought is within amount of prayer of complaint or statement of damages. (Due Process; Greenup v. Rodman (1986) 42 Cal.3d 822, 824.)

Yes Summary of the case. (CRC 3.1800 (a)(1).)

Yes Declarations in support of the judgment. (CRC 3.1800 (a)(2).)

See above Attorney fees if supported by contract, statute or law. (CRC 3.1800 (a)(9); Local R. 3.214; open book – CC 1717.5.)

Yes __ __ Interest computations. (CRC 3.1800 (a)(3); 10% for contracts - Civ. Code 3289.)

Yes Memorandum of costs and disbursements. (CRC 3.1800 (a)(4); JC Form CIV-100 item 7.)

Yes Declaration of nonmilitary status for each defendant. (CRC 3.1800 (a)(5); JC Form CIV-100 item 8.)

Yes Proposed form of judgment. (CRC 3.1800 (a)(6).)

N/A Statement of Damages served (P.I./wrongful death). (JC Form MC-010; CCP 425.11.)

N/A Punitive Damages are supported. Info re Defendant’s financial status. (CCP 425.115)