Motion for Relief from Default Pursuant to C.C.P. 473 w/Attorney Affidavit [Memorandum of Points & Authorities] with supporting authorities for the arguments including, inter alia the matter appropriate for relief; petitioner was prevented from a full and fair hearing; good cause for relief; satisfies the statutory statutory grounds for relief, including mistake, inadvertence, surprise, excusable neglect with supporting affidavit; the mistake was the cause of the default, petitioner has a meritorious claim/defense; no prejudice to opposing party; relief not barred by petitioner’s neglect, not caused by the client; the request is timely; the court has authority to grant relief consistent with the showing – relief is mandatory; court’s findings are controlling and presumed correct, would not effect an injustice. 37 pages."