Plaintiff's Legal Billing Summary

Plaintiff is informed and believes and thereon alleges that each of the Defendants was the agent and employee of each of the remaining Defendants and was at all times acting within the purpose and scope of such agency and employment.

If you contend that the Plaintiff has made an admission, or declaration against interest, please state the substance of the alleged admission or declaration together with the time and place of the alleged admission or declaration and the names and addresses and telephone numbers of the persons, if any, who were present.

Defendant will agree that Plaintiff filed an Affidavit of Compliance. However, Plaintiff failed to file the return receipt or any document which actually shows more than attempted service on Defendant, Norman Henson,

Plaintiffs/Counter-Defendants Robert Higgins and Teresa Higgins (the “Higginses”) and Plaintiffs/Counter-Defendants Richard Hargrove and Kathleen Hargrove (the “Hargroves”), by their respective undersigned counsel, hereby submit this Memorandum of Law in Support of their Motion for Summary Judgment.

To sue in small claims court is required to find out whether your claim are meeting the

Plaintiff filed this motion for summary judgment on November 17, 2014. The Court heard oral argument on December 15, 2014, and took the matter under submission. For the reasons discussed below, the Court grants the motion.

Defendants, Starboard Financial Services (“Starboard” or “Defendant”), by and through counsel, respectfully submit their brief in support of Defendant’s Motion to Dismiss Plaintiff’s Complaint.

DEFENDANTS’ REPLY IN SUPPORT OF THEIR MOTION TO DISMISS PLAINTIFFS’ SECOND AMENDED COMPLAINT PURSUANT TO SECTION 2-603 OF THE CODE OF CIVIL PROCEDURE, OR IN THE ALTERNATIVE, DISMISS COUNTS I, II, VI AND VII PURSUANT TO SECTION 2-619.1 OF THE CODE OF CIVIL PROCEDURE

The following responses and objections are based upon information presently available to Plaintiff, which this Plaintiff believes to be correct. These admissions are made without prejudice to the Plaintiff’s right to utilize subsequently discovered facts and documents.

This Settlement Agreement and Mutual Release of All Claims (“Agreement”) is made and entered into between APRIL STAR DAVIS (“DAVIS”) and THE LAW OFFICES OF ROBERT BURNS (“BURNS”), with reference to the following facts:

Attempts were made to serve the Defendant JUAN ESPARZA via personal service. Affidavits of due Diligence attached hereto as exhibit “A”.

In order to avoid repetition, the defendant refer to facts of case mentioned in statement of claim ,however it is necessary before defense and response hereinafter upholding lack of prima facie evidence mentioned and cited by the claimant especially for the contract which is being claimed made by parts contrary to facts as will be mentioned hereinafter.

1. Are the financial statements in Exhibit 3.7 consistent with V. Dourtan assumptions in Exhibit 3.1?

WHEREAS, the Parties have concluded that this Agreement is a fair, reasonable and adequate resolution of all Claims that have been made, or could have been made in the Suit; and