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James Alan Bush 2967 Sherbrooke Way San Jose, California 95127 (408) 569-1634 Defendant in pro per

SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA SAN JOSE DIVISION

Yvonne Ly, et al., Plaintiffs, v. James Alan Bush, Defendant.

Case No. 1-13-CV-252652 NOTICE OF INTENTION TO MOVE FOR NEW TRIAL DEPT: JUDGE: DATE: 4 Hon. Derek Woodhouse May 1st, 2013 at 9:15 am

TO THE PLAINTIFFS AND THEIR ATTORNEY OF RECORD: PLEASE TAKE NOTICE that in Department 4, at the time that shall be set by the Court pursuant to Code of Civil Procedure 661, Defendant, James Alan Bush, will move the Court to vacate the judgment entered on April 4th, 2013, in plaintiffs favor, and to grant the defendant a new trial on the issue of the courts jurisdiction in this matter, which is more fully explained in Defendants Motion for Reconsideration of Motion to Quash Service of Summons already on le in this action. // // NOTICE PAGE 1 OF 2 1-13-CV-252652

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 // // // // NOTICE 7.

GROUNDS FOR MOTION This motion is made on the following grounds, each of which materially affected the substantial rights of the defendant from having a fair trial: 1. Irregularity in the proceedings of the Court; 2. Irregularity on the part of Plaintiff, Yvonne Ly; 3. Improper orders of the Court; 4. Abuse of discretion by the Court; 5. Accident or surprise, or other acts that ordinary prudence could not have guarded against; 6. Newly discovered evidence, material to the moving party, that could not have been discovered with reasonable diligence and produced at trial; Insufciency of the evidence to justify the _ _ [verdict/decision] _ _ ;

8. The verdict is against law; 9. Error in law occurring at the trial and excepted to by the moving party; SUPPORTING PAPERS The motion is also based on this notice; all pleadings, papers, and records in this action; the evidence presented at trial; and the attached supporting memorandum. Dated: April 4th, 2013

Respectfully submitted,

James Alan Bush Defendant in pro per

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