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| Default Judgment |
A request for default judgment must be technically perfect
We have a bullet proof default judgment package that even lawyers come to us to prepare for them. We are one of the few paralegal services that has actually good default judgments granted where the defendant was served by publication. Default judgments are considered a summary procedure by the court and so the technical details are crucial. There are certain documents you must perfectly complete, including a declaration of exactly what the case is all about. Check this out:
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
JOE BLACK, Plaintiff, v. DICK DICKSON, Defendant.
Case No.: 09 B 00000
DECLARATION OF PLAINTIFF JOE BLACK IN SUPPORT OF DEFAULT JUDGMENT
I, JOE BLACK, hereby declare as follows:
1.That I am an adult living in the County of Los Angeles, have personal knowledge of the facts in this declaration, am the plaintiff in the above-entitled action and can and will competently testify to the following facts.
That I am an adult living in the County of Los Angeles, have personal knowledge of the facts in this declaration, am the plaintiff in the above-entitled action and can and will competently testify to the following facts.2.That on July 7, 2007 Defendant DICK DICKSON, California driver license E7 999999, driving a 2001 Dodge Grand Caravan license number BADDRIVER, was traveling northbound on Wilshire Blvd. in the City of Los Angeles, County of Los Angeles, and failed to stop at the posted stop sign at Bush Street. Defendant DICKSON’s negligence caused her vehicle to collide with my work vehicle and impact my passenger side door. My work vehicle was declared a total loss by Defendant’s insurer, Allstate Insurance Company, who paid me for the partial replacement cost of my vehicle only.
That on July 7, 2007 Defendant DICK DICKSON, California driver license E7 999999, driving a 2001 Dodge Grand Caravan license number BADDRIVER, was traveling northbound on Wilshire Blvd. in the City of Los Angeles, County of Los Angeles, and failed to stop at the posted stop sign at Bush Street. Defendant DICKSON’s negligence caused her vehicle to collide with my work vehicle and impact my passenger side door. My work vehicle was declared a total loss by Defendant’s insurer, Allstate Insurance Company, who paid me for the partial replacement cost of my vehicle only. 3.That I incurred $23,500 in additional unpaid general and special damages for personal injury to myself, loss of earnings, storage for tools of the trade while Defendant’s insurance company wrote the check to replace my totaled vehicle, and additional vehicle replacement costs for my vehicle not paid by defendant’s insurance company.
That I incurred $23,500 in additional unpaid general and special damages for personal injury to myself, loss of earnings, storage for tools of the trade while Defendant’s insurance company wrote the check to replace my totaled vehicle, and additional vehicle replacement costs for my vehicle not paid by defendant’s insurance company.4.That Defendant’s insurance company offered me $600 for my additional unpaid general and special damages which I declined.
That Defendant’s insurance company offered me $600 for my additional unpaid general and special damages which I declined.5.That liability for the accident lies with Defendant DICKSON, as established by her admission to my insurance company and an eye witness who was stopped at the stop sign at the scene of the accident.
That liability for the accident lies with Defendant DICKSON, as established by her admission to my insurance company and an eye witness who was stopped at the stop sign at the scene of the accident. 6.That at the scene of the accident defendant DICK DICKSON represented that her true and correct current and address was 103 N. Kingsley Dr., Los Angeles, CA 90004.
That at the scene of the accident defendant DICK DICKSON represented that her true and correct current and address was 103 N. Kingsley Dr., Los Angeles, CA 90004.7.That 103 N. Kingsley Dr., Los Angeles, CA 90004 was in fact not defendant’s true and correct current address.
That 103 N. Kingsley Dr., Los Angeles, CA 90004 was in fact not defendant’s true and correct current address.8.That I used three different process servers to attempt personal service of process upon defendant DICK DICKSON for total costs of $341.30.
That I used three different process servers to attempt personal service of process upon defendant DICK DICKSON for total costs of $341.30. 9.That I exercised due diligence by hiring a private investigator to locate defendant for service of process at a cost of $593.61.
That I exercised due diligence by hiring a private investigator to locate defendant for service of process at a cost of $593.61. 10.That I had to serve defendant DICK DICKSON by publication at a cost of $250.00.
That I had to serve defendant DICK DICKSON by publication at a cost of $250.00. 11.That I paid $345.00 in clerk’s filing fees for my complaint.
That I paid $345.00 in clerk’s filing fees for my complaint.12.That I incurred $4,500.00 in special damages in the form of unpaid medical bills, and storage for my tools of the trade.
That I incurred $4,500.00 in special damages in the form of unpaid medical bills, and storage for my tools of the trade.13.That the original proof of service by publication was filed with the court on December 10, 2009.
That the original proof of service by publication was filed with the court on December 10, 2009. 14.That my total damages, fees and costs in this matter are $25,000.
That my total damages, fees and costs in this matter are $25,000.I declare under penalty of perjury of the laws of the State of California that the foregoing is true and correct.
Dated: January 8, 2010______________________
______________________JOE BLACK, Declarant