Eun Jung Lim
17192 Murphy Avenue #17723
Irvine, California [92623]
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF ORANGE
EUN JUNG LIM,
Plaintiff,
v.
HOAG MEMORIAL HOSPITAL
PRESBYTERIAN; and HERBERT
CONRAD,
Defendants.
Case No.: 30-2022-01242187
DECLARATION IN SUPPORT OF
DEFAULT JUDGMENT PURSUANT TO
CCP § 585(d)
To The Honorable Court:
Plaintiff Eun Jung Lim, being duly sworn, depose and state as follows:
1. I am the Plaintiff in this case, and am therefore competent to make this declaration.
2. The incidence giving rise to this action began when my mother had been admitted at the
Defendant hospital’s facility. On January 25, 2020, I went to visit my mother. As I was
checking in at the ER at the hospital’s facility, Defendant Herbert stole my phone from
the ER lobby and pushed me until I fell.
3. Consequently, the police officers arrived and took a police report of the incidence.
4. Herbert gave false information that I was the one who punched his face. Accordingly, I
was charged and a case was filed against me.
5. During the pendency of the said case, the Irvine Police Department refused to give me a
copy of the Police Report. It was only when the case was dismissed when the Irvine
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DECLARATION IN SUPPORT OF DEFAULT JUDGMENT PURSUANT TO CCP § 585(d)
Police Department gave me the Report.
6. The said case was dismissed on May 2021. Unfortunately, my mother died during the
pendency of the case against me.
7. I filed an action against the Defendants on or about January 25, 2022. In the Complaint, I
alleged that Defendants were blameworthy for negligence, malicious prosecution, and
intentional infliction of emotional distress.
8. I made several attempts to serve Herbert Conrad, who appeared to have intentionally
hidden his identity to avoid Defending the case. Accordingly, despite a diligent attempt to
locate the Defendant for service, I was unable to do so.
9. I made several efforts to learn the Defendant’s whereabouts. For instance, on Wednesday,
February 2, 2022, my process server emailed me and notified me that nobody knew who
Herbert Conrad was and that there was no Herbert working at Hoag Memorial Hospital
Presbyterian.
10. On February 4, 2022, the process server informed me that the process server would go
back to Hoag Memorial Hospital Presbyterian in Irvine to look for Herbert Conrad. On
February 14, 2022, the process server again went back to the Hoag Memorial Hospital
Presbyterian. A security guard informed the process server was Herbert Conrad did not
work at the hospital any more, and that he had not been working there for the last six
months.
11. The process server further sought to confirm whether Herbert Conrad worked at the Hoag
Memorial Hospital Presbyterian. The process server was informed that the hospital could
not disclose any information about who worked there as security.
12. Further, online Private investigators found information from certain individuals bearing
Herbert Conrad’s name. I called the phone numbers revealed in the search and paid for
the online directory such as BeenVerified, However, the internet results showed names
and ages that did not correlate.
13. I had also researched professional licenses for bureau of security and investigative
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DECLARATION IN SUPPORT OF DEFAULT JUDGMENT PURSUANT TO CCP § 585(d)
services, to no avail.
14. I finally served Defendant Herbert by substituted service.
15. Defendant Herbert should have filed a response to the Complaint on or before September
14, 2022. However, Defendant Herbert has failed to plead or otherwise defend this
action.
16. I understand that Service of a summons by substituted service is deemed complete on the
10th day after the mailing. (California Code of Civil Procedure (CCP) § 412.20(a)).
17. I further understand that upon being served by substituted service, a Defendant has 40
calendar days from follow-up mailing, to file a response to the Complaint. (CCP §
412.20(a) (3)).
18. I am entitled to judgment by default against Defendant Herbert Conrad.
I declare under penalty of perjury that everything that stated herein is true and correct to the extent of
my knowledge, information, and belief.
____________________ ___________________
Eun Jung Lim Date
Sworn To Before Me This
_____ day of ___________, _____
___________________
Notary Public
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