On March 22, 2016 a
Motion-Secondary
was filed
involving a dispute between
San Bernardino County Transportation Commision, A Public Agency,
and
All Persons Unknown Claiming An Interest In The Property,
Anelle, Catherine C,
Anelle, Renald J,
Bank Of America, National Association,
Bank Of New York Trust Company, As Trustee For Mogal Stanley Capital I, Inc.,
Behrens, Anne C.,
Behrens, Edward J.,
City Of Riverside,
Keeney, Candice L,
Keeney, Robert E,
Lasalle Banknational Association,
Morgan Stanley Capital I, Inc.,
Pacific Bell Telephone Company, A California Corporation,
Riverside Highland Water Co., A California Corporation,
Riverside Public Utilities,
Riverside Water Company,
Southern California Edison Company, A California Corporation,
Terrace Village Rv Park, Llc A California Limited Liability Company,
The Bank Of New York Mellon Trust Company National Association,
for Eminent Domain
in the District Court of San Bernardino County.
Preview
ATTORNEY OR PARTY WITHOUT ATTORNEY Name Address Telephone Number FOR COURT USE ONLY
PATRICIA A CIRUCCI STATE BAR NO 210574
LISA DELORME STATE BAR NO 198940
2244 Walnut Grove Avenue Third Floor Rosemead Ca 91770
SUPERIOR COURTOF CALfFORNIA
Tele P hone 626 302 6889 4890 0
S 1NTY OF SAN BERNARDINO
Fax 626 302 6997 R11AR INO DISTRICT
Superior Court
ofCalifornia
CountyofSan Bernardino JA N 6 J Q 7
Civil Division
247 West Third Street
BY
San Bernardino
EANNE M LANDEROS G
TITLE OF CASE
SAN BERNARDINO COUNTY v TERRACE VILLAGE RV PARK LLC etc et al
CASE NUMBER
GENERAL CIVIL CASE AT ISSUE MEMORANDUM COUNTER CIVDS1604312
THE COURT IS REQUESTED TO SET THIS CASE FOR TRIAL
1 I LISA DeLORME declare
a All essential parties have been served with process or have appeared and this action is at issue I
request that all unserved parties named in my pleading except fictitiously named parties be
dismissed without prejudice
b All essential parties have not been served with process or appeared and this action is NOT at issue
c I represent a defendant and Ibelieve this action is at issue and ready to be set for trial
2 A jury trialis demanded
3 Estimated time for trial hours 5 days
4 Case entitledto preference Yes Code and Section
5 Date complaint was filed May 22 2016
6 List allother names addresses and telephone numbers of attorneys for the parties or of parties appearing without
counsel
Alyson C Suh Esq Representing
Woodruff Spradlin Smart APC Plaintiff Defendant
555 Anton Boulevard Suite 1200
Costa Mesa CA 92626 7670 Cross Complainant Cross Defendant
Patrick A Hennessey Esq Representing
Palmieri Tyler Wiener Wilhelm Waldron LLP Plaintiff Defendant
1900 Main Street Suite 700
Irvine Ca 92614 7328 Cross Complainant Cross Defendant
Terry L Higham Esq Representing
Ronald R St John Esq Plaintiff Defendant
Barton Klugman Oetting LLP
350 S Grand Ave Ste 2200 Cross Complainant Cross Defendant
Los An eles Ca 90071
Representing
Lilian M Khanjian Esq Plaintiff Defendant
Locke Lord LLP
300 S Grand Avenue Ste 2600 Cross Complainant Cross Defendant
Los An eles CA 90071
7 See attached for additional parties
Ideclare under penalty of perjury under the laws of the State of Caiifornia that the foregoing is true and correct
Date 201
LISA DeLORME Attorneyfor Plaintiff f c
Type or Print Name T1 Signature
13 12390 360 Civil new 9I2013 GENERAL CIVIL CASE AT ISSUE MEMORANDUM
American LegalNet
nc
vI
onnsWorkPlo
com
CASE TITLE CASE NUMBER
SAN BERNARDINO COUNTY v TERRACE VILLAGE RV PARK CIVDS1604312
LLC etc et al
PROOF OF SERVICE BY MAIL
Must be completed in full or General Civil At Issue Memorandum will not be accepted for filing
Any party not in agreement with this General Civil At Issue Memorandum shall within 10 days after service
thereof serve and file itsown General Civil At Issue Memorandum
At the time of mailing Iwas at least 18 years of age not a party to this cause and a resident of or employed in
the county where the mailing occurred
My residence or business address is specify
2244 Walnut Grove Avenue Rosemead CA 91770
I enclosed a true copy of this Notice of General Civil At Issue Memorandum and referenced documents in a
sealed envelope by first class postage fully prepaid mail and deposited the envelope directly inthe United
States OR
mail
at my place of business for same day collection and mailing with the United States mail
following our ordinary business practices with which I am readily familiar
The envelope was addressed and mailed as follows
1 Addressed as shown inItem 6 and inAttachment 7
2 Date of
mailing January 19 2017
3 Place of mailing City and State Rosemead CA
Ideclare under penalty of perjury under the laws of the State of California that the foregoing is true and
correct
Date January 19 2017
ANA A CALDERON
Type or Print Name of Declarant Signature of Declarant
13 12390 360 Civilnew 9 2013 GENERAL CIVIL CASE AT ISSUE MEMORANDUM
American LegalNet
Inc
wu vFonns WorkFlow
com
Document Filed Date
January 23, 2017
Case Filing Date
March 22, 2016
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ATTORNEY OR PARTY WITHOUT ATTORNEY Name Address Telephone Number FOR COURT USE ONLY PATRICIA A CIRUCCI STATE BAR NO 210574 LISA DELORME STATE BAR NO 198940 2244 Walnut Grove Avenue Third Floor Rosemead Ca 91770 SUPERIOR COURTOF CALfFORNIA Tele P hone 626 302 6889 4890 0 S 1NTY OF SAN BERNARDINO Fax 626 302 6997 R11AR INO DISTRICT Superior Court ofCalifornia CountyofSan Bernardino JA N 6 J Q 7 Civil Division 247 West Third Street BY San Bernardino EANNE M LANDEROS G TITLE OF CASE SAN BERNARDINO COUNTY v TERRACE VILLAGE RV PARK LLC etc et al CASE NUMBER GENERAL CIVIL CASE AT ISSUE MEMORANDUM COUNTER CIVDS1604312 THE COURT IS REQUESTED TO SET THIS CASE FOR TRIAL 1 I LISA DeLORME declare a All essential parties have been served with process or have appeared and this action is at issue I request that all unserved parties named in my pleading except fictitiously named parties be dismissed without prejudice b All essential parties have not been served with process or appeared and this action is NOT at issue c I represent a defendant and Ibelieve this action is at issue and ready to be set for trial 2 A jury trialis demanded 3 Estimated time for trial hours 5 days 4 Case entitledto preference Yes Code and Section 5 Date complaint was filed May 22 2016 6 List allother names addresses and telephone numbers of attorneys for the parties or of parties appearing without counsel Alyson C Suh Esq Representing Woodruff Spradlin Smart APC Plaintiff Defendant 555 Anton Boulevard Suite 1200 Costa Mesa CA 92626 7670 Cross Complainant Cross Defendant Patrick A Hennessey Esq Representing Palmieri Tyler Wiener Wilhelm Waldron LLP Plaintiff Defendant 1900 Main Street Suite 700 Irvine Ca 92614 7328 Cross Complainant Cross Defendant Terry L Higham Esq Representing Ronald R St John Esq Plaintiff Defendant Barton Klugman Oetting LLP 350 S Grand Ave Ste 2200 Cross Complainant Cross Defendant Los An eles Ca 90071 Representing Lilian M Khanjian Esq Plaintiff Defendant Locke Lord LLP 300 S Grand Avenue Ste 2600 Cross Complainant Cross Defendant Los An eles CA 90071 7 See attached for additional parties Ideclare under penalty of perjury under the laws of the State of Caiifornia that the foregoing is true and correct Date 201 LISA DeLORME Attorneyfor Plaintiff f c Type or Print Name T1 Signature 13 12390 360 Civil new 9I2013 GENERAL CIVIL CASE AT ISSUE MEMORANDUM American LegalNet nc vI onnsWorkPlo com CASE TITLE CASE NUMBER SAN BERNARDINO COUNTY v TERRACE VILLAGE RV PARK CIVDS1604312 LLC etc et al PROOF OF SERVICE BY MAIL Must be completed in full or General Civil At Issue Memorandum will not be accepted for filing Any party not in agreement with this General Civil At Issue Memorandum shall within 10 days after service thereof serve and file itsown General Civil At Issue Memorandum At the time of mailing Iwas at least 18 years of age not a party to this cause and a resident of or employed in the county where the mailing occurred My residence or business address is specify 2244 Walnut Grove Avenue Rosemead CA 91770 I enclosed a true copy of this Notice of General Civil At Issue Memorandum and referenced documents in a sealed envelope by first class postage fully prepaid mail and deposited the envelope directly inthe United States OR mail at my place of business for same day collection and mailing with the United States mail following our ordinary business practices with which I am readily familiar The envelope was addressed and mailed as follows 1 Addressed as shown inItem 6 and inAttachment 7 2 Date of mailing January 19 2017 3 Place of mailing City and State Rosemead CA Ideclare under penalty of perjury under the laws of the State of California that the foregoing is true and correct Date January 19 2017 ANA A CALDERON Type or Print Name of Declarant Signature of Declarant 13 12390 360 Civilnew 9 2013 GENERAL CIVIL CASE AT ISSUE MEMORANDUM American LegalNet Inc wu vFonns WorkFlow com