David Bartel Vs. 2046 Filbert, Llc, Et Al

DECLARATION OF MICHAEL T. JOYCE IN RESPONSE TO ORDER TO SHOW CAUSE SET FOR JUNE 14, 2022 (TRANSACTION ID # 67711623) FILED BY DEFENDANT 2046 FILBERT LLC

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED DENYING PLAINTIFF'S MOTION FOR ORDER DETERMINING TRUTH OF MATTERS SPECIFIED IN REQUESTS FOR ADMISSION AND FOR SANCTIONS (TRANSACTION ID # 66263963) FILED BY DEFENDANT 2046 FILBERT LLC

ORDER TO SHOW CAUSE SET FOR JUN-14-2022 IN DEPARTMENT 610 AT 10:30 AM TO CROSS COMPLAINANT'S COUNSEL FOR FAILURE TO BRING FIRST AMENDED CROSS COMPLAINT AT ISSUE. THE APR-27-2022 CASE MANAGEMENT CONFERENCE IS OFF CALENDAR. NOTICE SENT BY COURT.

DECLARATION OF DONALD F. DRUMMOND IN SUPPORT OF MOTION FOR ORDER DETERMINING TRUTH OF MATTERS SPECIFIED IN REQUESTS FOR ADMISSION AND FOR SANCTIONS (TRANSACTION ID # 100117201) FILED BY PLAINTIFF BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006

NOTICE OF CHANGE OF ADDRESS (TRANSACTION ID # 66582685) FILED BY ATTORNEY BUI, NEIL H.

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 100156181) FILED BY PLAINTIFF BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006 ESTIMATED TIME FOR TRIAL: 5.0 DAYS

ORDER DENYING PLAINTIFF'S MOTION FOR ORDER DETERMINING TRUTH OF MATTERS SPECIFIED IN REQUESTS FOR ADMISSION AND FOR SANCTIONS

CASE MANAGEMENT CONFERENCE OF MAR-16-2022 CONTINUED TO APR-27-2022 AT 10:30 AM IN DEPARTMENT 610 FOR CROSS COMPLAINANT TO BRING FIRST AMENDED CROSS COMPLAINT AT ISSUE AS TO CROSS DEFENDANT(S) COMPASS CALIFORNIA II, AND PACIFIC UNION INTERNATIONAL, INC., AND JOHN KIRKPATRICK. NOTICE SENT BY COURT.

DECLARATION OF NEIL H. BUI IN SUPPORT OF OPPOSITION TO MOTION TO DETERMINE TRUTH OF MATTERS SPECIFIED IN REQUESTS FOR ADMISSION (TRANSACTION ID # 66214996) FILED BY DEFENDANT 2046 FILBERT LLC

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 100160829) FILED BY PLAINTIFF BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006 ESTIMATED TIME FOR TRIAL: 5.0 DAYS

NOTICE AND ACKNOWLEDGMENT OF RECEIPT, SIGNED JAN-04-2021, SERVED DEC-15-2020 (TRANSACTION ID # 66267951) FILED BY CROSS COMPLAINANT 2046 FILBERT LLC AS TO CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION

ORDER TO SHOW CAUSE SET FOR JUN-14-2022 CONTINUED TO SEP-13-2022 AT 10:30 AM IN DEPARTMENT 610 TO CROSS COMPLAINANT'S COUNSEL FOR FAILURE TO BRING FIRST AMENDED CROSS COMPLAINT AT ISSUE. NOTICE SENT BY COURT.

NOTICE TO PLAINTIFF

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 67450648) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 10.0 DAYS

REPLY IN SUPPORT OF MOTION RE REQUESTS FOR ADMISSION AND SANCTIONS (TRANSACTION ID # 100120111) FILED BY PLAINTIFF BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006

NOTICE AND ACKNOWLEDGMENT OF RECEIPT, SIGNED JAN-21-2021, SERVED DEC-15-2021 (TRANSACTION ID # 66292284) FILED BY CROSS COMPLAINANT 2046 FILBERT LLC AS TO CROSS DEFENDANT KIRKPATRICK, JOHN AN INDIVIDUAL

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR ORDER DETERMINING TRUTH OF MATTERS SPECIFIED IN REQUESTS FOR ADMISSION AND FOR SANCTIONS (TRANSACTION ID # 100117201) FILED BY PLAINTIFF BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006

ANSWER TO COMPLAINT (TRANSACTION ID # 66016968) FILED BY DEFENDANT 2046 FILBERT LLC

NOTICE AND ACKNOWLEDGMENT OF RECEIPT, SIGNED JAN-04-2021, SERVED DEC-15-2020 (TRANSACTION ID # 66267951) FILED BY CROSS COMPLAINANT 2046 FILBERT LLC AS TO CROSS DEFENDANT COMPASS CALIFORNIA II A CORPORATION FORMED IN DELAWARE

OTHER NON EXEMPT COMPLAINTS, COMPLAINT FILED BY PLAINTIFF BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006 AS TO DEFENDANT 2046 FILBERT, LLC, A CALIFORNIA LIMITED LIABILITY COMPANY DOES 1 THROUGH 10 NO SUMMONS ISSUED, JUDICIAL COUNCIL CIVIL CASE COVER SHEET FILED CASE MANAGEMENT CONFERENCE SCHEDULED FOR DEC-30-2020 PROOF OF SERVICE DUE ON SEP-28-2020 CASE MANAGEMENT STATEMENT DUE ON DEC-07-2020

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 66188801) FILED BY DEFENDANT 2046 FILBERT LLC JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 3.0 DAYS

CASE MANAGEMENT CONFERENCE OF DEC-30-2020 CONTINUED TO FEB-24-2021 AT 10:30 AM IN DEPARTMENT 610 FOR CROSS COMPLAINANT(S) TO BRING CROSS COMPLAINT(S) AT ISSUE. NOTICE SENT BY COURT.

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 100128602) FILED BY PLAINTIFF BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006 ESTIMATED TIME FOR TRIAL: 5.0 DAYS

ANSWER TO CROSS COMPLAINT (TRANSACTION ID # 100115013) FILED BY CROSS DEFENDANT BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006

AMENDED NOTICE OF MOTION AND MOTION FOR ORDER DETERMINING TRUTH OF MATTERS SPECIFIED IN REQUESTS FOR ADMISSION AND FOR SANCTIONS, PROOF OF SERVICE (TRANSACTION ID # 100117946) FILED BY PLAINTIFF BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006 HEARING SET FOR JAN-12-2021 AT 09:00 AM IN DEPT 302

DECLARATION OF SHANNON B. JONES IN SUPPORT OF 30-DAY EXTENSION TO FILE MOTION TO STRIKE FOR PACIFIC UNION INTERNATIONAL, INC. AND JOHN KIRKPATRICK TO CROSS-COMPLAINANT 2046 FILBERT LLC?S CROSS-COMPLAINT (TRANSACTION ID # 66458874) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL

CASE MANAGEMENT CONFERENCE OF APR-28-2021 CONTINUED TO JUN-09-2021 AT 10:30 AM IN DEPARTMENT 610 FOR CROSS COMPLAINANT(S) TO BRING CROSS COMPLAINT(S) AT ISSUE. NOTICE SENT BY COURT.

CASE MANAGEMENT CONFERENCE OF FEB-24-2021 CONTINUED TO APR-28-2021 AT 10:30 AM IN DEPARTMENT 610 FOR CROSS COMPLAINANT(S) TO BRING CROSS COMPLAINT(S) AT ISSUE. NOTICE SENT BY COURT.

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 100117943) FILED BY PLAINTIFF BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006 ESTIMATED TIME FOR TRIAL: 5.0 DAYS

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 67325739) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 10.0 DAYS

SUMMONS ISSUED TO CROSS COMPLAINANT 2046 FILBERT LLC

PROOF OF SERVICE BY ELECTRONIC MAIL (TRANSACTION ID # 66898738) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL

OPPOSITION TO MOTION TO DETERMINE TRUTH OF MATTERS SPECIFIED IN REQUESTS FOR ADMISSION (TRANSACTION ID # 66214996) FILED BY PLAINTIFF BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006

PROOF OF SERVICE BY MAIL OF ANSWER TO COMPLAINT; CROSS-COMPLAINT; SUMMONS ON CROSS-COMPLAINT (TRANSACTION ID # 66016968) FILED BY DEFENDANT 2046 FILBERT LLC

CROSS COMPLAINT (TRANSACTION ID # 66016968) FILED BY CROSS COMPLAINANT 2046 FILBERT LLC AS TO CROSS DEFENDANT BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006 THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006 THE ESTATE OF PEGGY BARTEL, A DECEASED PERSON COMPASS CALIFORNIA II A CORPORATION FORMED IN DELAWARE PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL ROES 1 THROUGH 10,

NOTICE OF MOTION AND MOTION FOR ORDER DETERMINING TRUTH OF MATTERS SPECIFIED IN REQUESTS FOR ADMISSION AND FOR SANCTIONS, PROOF OF SERVICE (TRANSACTION ID # 100117201) FILED BY PLAINTIFF BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006 HEARING SET FOR DEC-29-2020 AT 09:00 AM IN DEPT 302

NOTICE OF ENTRY OF DISMISSAL AND PROOF OF SERVICE (TRANSACTION ID # 67270949) FILED BY CROSS COMPLAINANT 2046 FILBERT LLC

SUMMONS ISSUED TO PLAINTIFF BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006

CASE MANAGEMENT CONFERENCE OF OCT-27-2021 CONTINUED TO DEC-15-2021 AT 10:30 AM IN DEPARTMENT 610. NOTICE SENT BY COURT.

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 66834664) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION ALSO FILED BY CROSS DEFENDANT KIRKPATRICK, JOHN AN INDIVIDUAL JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 10.0 DAYS

DISMISSAL WITHOUT PREJUDICE OF 1ST AMENDED CROSS COMPLAINT FILED BY 2046 FILBERT LLC (TRANSACTION ID # 67222603) AS TO CROSS DEFENDANT BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006 THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006 THE ESTATE OF PEGGY BARTEL, A DECEASED PERSON

OPPOSITION TO MOTION FOR JUDGMENT ON THE PLEADINGS (TRANSACTION ID # 67037029) FILED BY DEFENDANT 2046 FILBERT LLC

MOTION FOR JUDGMENT ON THE PLEADINGS (TRANSACTION ID # 66956422) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL HEARING SET FOR OCT-28-2021 AT 09:30 AM IN DEPT 501

1ST AMENDED CROSS COMPLAINT (TRANSACTION ID # 66711331) (TRANSACTION ID # 66711331) FILED BY CROSS COMPLAINANT 2046 FILBERT LLC AS TO CROSS DEFENDANT BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006 THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006 THE ESTATE OF PEGGY BARTEL, A DECEASED PERSON COMPASS CALIFORNIA II A CORPORATION FORMED IN DELAWARE PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL ROES 1 THROUGH 10,

REPLY TO 2046 FILBERT, LLC?S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO MOTION TO STRIKE PORTIONS OF 2046 FILBERT, LLC?S FIRST AMENDED CROSS-COMPLAINT (TRANSACTION ID # 66984175) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL

PROOF OF SERVICE BY ELECTRONIC MAIL AND BY MAIL (TRANSACTION ID # 66956422) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 67131289) FILED BY DEFENDANT 2046 FILBERT LLC JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 3.0 DAYS

DECLARATION OF ALAN PALMER JACOBUS IN SUPPORT OF 30-DAY EXTENSION FOR PACIFIC UNION INTERNATIONAL, INC. AND JOHN KIRKPATRICK TO FILE DEMURRER AND MOTION TO STRIKE RELATIVE TO FIRST AMENDED CROSS-COMPLAINT (TRANSACTION ID # 66802616) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL

ANSWER TO 1ST AMENDED CROSS COMPLAINT (TRANSACTION ID # 100140099) FILED BY CROSS DEFENDANT BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 66983758) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 10.0 DAYS

MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO MOTION TO STRIKE PORTIONS OF FIRST AMENDED CROSS COMPLAINT (TRANSACTION ID # 66971416) FILED BY DEFENDANT 2046 FILBERT LLC

CASE MANAGEMENT CONFERENCE OF JUN-09-2021 CONTINUED TO AUG-25-2021 AT 10:30 AM IN DEPARTMENT 610. NOTICE SENT BY COURT.

REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF CROSS-DEFENDANTS PACIFIC UNION INTERNATIONAL, INC. AND JOHN KIRKPATRICK'S MOTION FOR JUDGMENT ON THE PLEADINGS ON THE SECOND CAUSE OF ACTION OF 2046 FILBERT, LLC'S FIRST AMENDED CROSS-COMPLAINT (TRANSACTION ID # 67043003) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL

CASE MANAGEMENT CONFERENCE OF AUG-25-2021 CONTINUED TO OCT-27-2021 AT 10:30 AM IN DEPARTMENT 610 FOR CROSS COMPLAINANT(S) TO BRING CROSS COMPLAINT(S) AT ISSUE. NOTICE SENT BY COURT.

CASE MANAGEMENT CONFERENCE OF DEC-15-2021 CONTINUED TO MAR-16-2022 AT 10:30 AM IN DEPARTMENT 610 FOR CROSS COMPLAINANT TO BRING FIRST AMENDED CROSS COMPLAINT AT ISSUE. NOTICE SENT BY COURT.

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 66611864) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 10.0 DAYS

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 100137738) FILED BY PLAINTIFF BARTEL, DAVID , TRUSTEE OF THE PEGGY BARTEL LIVING TRUST DATED APRIL 17, 2006 ESTIMATED TIME FOR TRIAL: 5.0 DAYS

DECLARATION OF SHANNON B. JONES IN SUPPORT OF MOTION FOR JUDGMENT ON THE PLEADINGS ON THE SECOND CAUSE OF ACTION OF 2046 FILBERT, LLCS FIRST AMENDED CROSS-COMPLAINT (TRANSACTION ID # 66956422) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL

MOTION TO STRIKE CROSS COMPLAINT (TRANSACTION ID # 66626212) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL HEARING SET FOR JUL-07-2021 AT 09:30 AM IN DEPT 501

PROOF OF SERVICE BY ELECTRONIC MAIL AND BY MAIL (TRANSACTION ID # 66626212) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL

MOTION TO STRIKE 1ST AMENDED CROSS COMPLAINT (TRANSACTION ID # 66898738) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL HEARING SET FOR OCT-12-2021 AT 09:30 AM IN DEPT 501

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 67112699) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 10.0 DAYS

DECLARATION OF ALAN PALMER JACOBUS IN SUPPORT OF MOTION TO STRIKE CROSS COMPLAINT (TRANSACTION ID # 66626212) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO STRIKE CROSS COMPLAINT (TRANSACTION ID # 66626212) FILED BY CROSS DEFENDANT PACIFIC UNION INTERNATIONAL, INC. A CALIFORNIA CORPORATION KIRKPATRICK, JOHN AN INDIVIDUAL