Pre Trial Motion in Patsy Moler vs Chris Hulme| Trellis.Law

On July 01, 2013 a Trial Materials was filed involving a dispute between Clearview Industries Inc, Moler, Patsy, and Clearview Industries Inc, Hulme, Chris, Hulme, Jennifer, for Unlimited Fraud (16) in the District Court of Santa Barbara County.

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LawOﬂiceOf
MICHAEL P. RING 3” FILED
gssmﬂmﬂ gﬁhgmu
AND ASSOCIATES
Michael P. Ring, State Bar #95922
Iris L. M. Ring, State Bar #298179 JUL 1 8 2016
1234 Santa Barbara Street Darrel E. Parker,
Executive0 icer
Santa Barbara, CA 9310] BY
(805) 564-2333 0” ay 11- era , e e

ATTORNEYS FOR PATSY MOLER

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF SANTA BARBARA

10
ANACAPA DIVISION

11 PATSY MOLER, ) Case No. 1417847
)
12 Plaintiff, ) PATSY MOLER’S TRIAL BRIEF
)
13 v. ) DATE: 7/18/16
) TIME: 9:30 A.M.
14 Chris Hulme, individually and dba DEPT: SB]
)
Clearview Industries, Inc., Jennifer Hulme, )
15
individually and dba Clearview Industries, )
Inc., and DOES 1 through 10, inclusive ) (Assigned to Hon. James E. Herman)
16
Defendants. )
1
17
And Related Cross-Actions )
18 Patsy Moler submits the following Trial Brief.

19 1.
INTRODUCTION
20
In the present case, Plaintiff hired Defendants to do improvements to her Santa Barbara
21
residential property. However, Defendants were not properly licensed and misrepresented their
22
licensing status. Defendants also represented they would only bill for services and materials
23
provided, yet thereafter grossly inﬂated their billing to Plaintiff’s detriment.
24
Additionally, Mr. & Mrs. Hulme personally participated in the fraud, and corporate
25
formalities were utterly disregarded. Under the law they are personally liable to Ms. Moler herein.
26
Frances T. v. Village Green Owners Association (1986) 42 Cal.3d 490.
27
Astoundingly, Defendants have filed a Cross-Complaint, alleging that they were, inter alia,
28
defrauded by Ms. Moler in that she never intended to pay them for the work they did after a certain

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PATSY MOLER’S TRIAL BRIEF
date. Not only is this ridiculous and not supported by any evidence, Defendants are conclusively

barred from seeking any recovery from Ms. Moler as a matter of law. See, generally, Bus. & Prof.

Code § 7031, Hydrotech Systems, Ltd. v. Oasis Waterpark (1991) 52 Cal.3d 988.

II.
PERTINEN T FACTUAL BACKGROUND
The initialscope of the project was the proposal of a painting job. The scope of the project
expanded over time. Mr. Hulme informed Plaintiff that he and Clearview were properly licensed.
Plaintiff did not learn of the lack of appropriate licensing until near the end of Defendants’ work.
Mr. Hulme did not know how many days or man hours it was all going to take, so he told Ms. Moler
they could do a time and materials arrangement, and Ms. Moler agreed. She gave Mr. Hulme three
10
post-dated checks for $10,000 each, one available for each week of work at the end of the week.
11
Defendants represented and agreed that they would only bill for the actual time and expenses
12 incurred.
13 Ms. Moler did not sign a written agreement. Even though there was never a written agreement

14 signed by Plaintiff, Clearview Industries, Inc. started work anyway.

15
Chris Hulme was generally in charge of all of the aspects of the construction at Plaintiff’s
property from August/September 2011 through May 2013. Clearview hired and paid people on
16
Plaintiff‘s project to work in trades other than landscaping or painting. They were coordinated by
17
Chris Hulme. The electrician was hired by Chris Hulme. Chris Hulme personally arranged to bring
18
in all the tradesmen and materials, scheduled all the tradesmen, coordinated the project, and
19
negotiated with all the tradesmen. Plaintiff did not hire subcontractors to work on the project,
20
Clearview hired subcontractors to work on the project. Many different sub-contractors worked for
21 Plaintiff’s
Clearview on project. The sub-contractors billed through Clearview. However,
22 Clearview does not have a general contractor’s license.
23 Clearview obtained a painting contractor’s license in 2007, and a landscape contractor’s

24 license in late 2012, #906290. Chris Hulme is the only Registered Managing Ofﬁcer (“RMO”).

25
When he got the quote request for the Plaintiff’ 5 project, Mr. Hulme did not have a landscape license.

26
As of October 31, 2011, Clearview Industries, Inc. was working on the landscaping project.
However, Clearview Industries, Inc. did not have a landscaping license until September 13,
27
2012.
28
The Defendants did not obtain any permits for the work they did for Plaintiff.

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PATSY MOLER’S TRIAL BRIEF
At one point, Mr. Hulme brought in a man named Paul Speed purportedly for the landscaping

aspects of the project. Mr. Speed did not have employees. Clearview people were going to actually
do the work, with Mr. Speed’s help. The “Landscape Labor Quote” submitted by Defendants is on

Clearview Industries Inc. letterhead, and is not from Paul Speed. The signature block includes
“Chris Hulme, President.” It is not signed by anyone, including Mr. Speed.

When Mr. Hulme introduced Mr. Speed to Patsy Moler and he told her that Mr. Speed was

a landscape contractor licensed to do landscape work that he had a lot of experience and he

recommended Mr. Speed. That was false. Mr. Speed has never been a licensed contractor in the state

of California.
Chris Hulme and Clearview represented to Plaintiff that Paul Speed held contractor license
10
#717907. The Contractors State License Board license detail for License #717907 shows it expired
11 on January 31, 1998, that the license “is expired and not able to contract at this time” and that the
12 license was in the name of “McChesney Construction” in California City, CA, and is not in the name
13 of Paul Speed. There is no Paul Speed licensed under the California Contractor’s State License

14 Board under any capacity. Chris Hulme did not look at Mr. Speed’s actual license, and Mr. Hulme
never looked into whether the license number provided by Mr. Speed was valid. Chris Hulme never
15
saw Paul Speed’s landscaping contractor’s license, and never contacted the Contractors State
16
Licensing Board to ﬁnd out if Paul Speed had a valid license. Mr. Speed never provided a copy of
17
his contractor’s license, or his bonding, or any insurance to Clearview and Clearview never requested
18
any of these things. No effort was made by Defendants to check on whether or not Mr. Speed in
19
fact held a valid landscaping contractor’s license. Clearview Industries Inc. received multiple
20
invoices from Mr. Speed. Clearview Industries Inc. would pay Mr. Speed, and then invoice Ms.
21 Moler.
22 Eventually Mr. Speed got another consulting project that was paying him more money, and

23 he lost interest in what they were doing and just went on to something else. Ms. Moler had

24 complained about the billing. Mr. Speed became less and less actively involved and Mr. Hulme

25
became more actively involved in the landscape. Mr. Hulme was then doing the daily oversight of
what was going on landscaping wise but had not yet gotten his landscape license.
26
CFO Jennifer Hulme personally reviewed the time slips of the employees of Clearview
27
Industries, Inc., but she was not going to job sites to corroborate the employees’ information, and
28
Chris Hulme did not typically review the time slips. CFO Jennifer l-lulme did not ever take any

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PATSY MOLER’S TRIAL BRIEF
efforts to conﬁrm the time that was being invoiced to Clearview Industries, Inc. that pertained to the
Plaintiff’s project. CFO Jennifer Hulme never spoke with any of the workers to ascertain whether
or not the time records that were being submitted to her were in fact accurate.
Prior to the landscape project, Clearview only charged Plaintiff for the cost of materials.
Once the landscaping project started, Clearview added a 100% mark-up for materials to the

Plaintiff s billings. There are no documents showing that Plaintiff was notified or agreed to this
change. There is nothing on the invoices that would have informed Plaintiff that Clearview
Industries, Inc. was charging a mark-up on materials. Clearview paid the subcontractor’s invoices
directly. This would be put into the invoice Clearview sent to Plaintiff, but not itemized individually.
Clearview would bill Plaintiff for not only for Mr. Speed’s time and materials, but also for his travel
10
expenses, but this was not broken down on the invoices, and there would just be a gross total shown.
11 Looking at the labor allocation on the invoices, there is no way for Plaintiff to know how many
12 people worked on the job, how many hours any given day and whether or not the $95 service charge

13 was incurred.

14 Clearview Industries, Inc. is a sham corporation. The articles for Clearview Industries, Inc.

15
were filed January 2, 2007. The directors and ofﬁcers are the same: Chris Hulme and Jennifer
Hulme. The business was portrayed by Chris Hulme and Jennifer Hulme to Plaintiff as being more
16
of a “mom and pop” business rather than a structured corporation. Clearview Industries, Inc. does
17
not have the corporate minute book at its location. Attorney Brigham Ricks has had possession of
18
the minute book since 2007. Mr. Ricks also has the corporate seal. The stock certificates are in the
19
minute book. Jennifer Hulme has not seen the corporate seal since the beginning of January, 2007.
20
The last time Chris Hulme and Jennifer Hulme saw the corporate minute book was probably back in
21 January 2007.
22 CFO Jennifer Hulme did not create the corporate minutes until 2015, after a January 7, 2015,

23 Court order, and she then fraudulently backdated the documents. Ms. Hulme knew that the minutes

24 submitted to Plaintiff and the Court bore dates that were not the dates the documents were created.

25
No written notice was provided for the directors or shareholder meetings held in Nuevo
Vallarta in May of 2008. At the May 2008 meeting, the directors gave Chris l-Iulme a raise effective
26
eight months in the future. At the May 2008 meeting there were discussions about corporate policy
27
to regularly raise the compensation of Mr. Hulme, but this was not documented in the minutes.
28
Jennifer Hulme cannot explain why not. At the May 2008 meeting, more than eight months before

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PATSY MOLER’S TRIAL BRIEF
ﬁscal year 2009, the board approved payment of dividends to stockholders of $80,000 for ﬁscal year
2009 out of cash ﬂow, not out of proﬁts, without even knowing if there would be proﬁts from which
to legally pay dividends. At the June 2009 meeting, more than six months before ﬁscal year 2010,

the board approved payment of dividends to stockholders of $100,000 for ﬁscal year 2010, out of
cash ﬂow, not out of proﬁts, without even knowing if there would be proﬁts from which to legally

pay dividends. At the May 2010 meeting, more than seven months before ﬁscal year 201 1, the board
approved payment of dividends to stockholders of $100,000 for ﬁscal year 201 1, out of cash ﬂow,
not out of proﬁts, without even knowing if there would be proﬁts from which to legally pay
dividends. At the September 2011 meeting, more than three months before ﬁscal year 2012, the

board approved payment of dividends to stockholders of $150,000 for ﬁscal year 2012, out of cash
10
ﬂow, not out of proﬁts, without even knowing if there would be proﬁts from which to legally pay
11 dividends.
12 The intention of the board that compensation to Chris Hulme and Jennifer Hulme was to be

13 made 1/3 from salary and 2/3 from dividends is not stated anywhere in the minutes. When the

14 minutes say that “The minutes of the May 19th, 2008 meeting were presented and approved,” that

15
is not accurate because the minutes were not in existence. There was no formal notice of intent to
have the 2009 Board of Directors meeting. The Board of Directors’ minutes in September of 2011
16
state that the minutes from the 2010 meeting were presented and approved, but this did not happen.
17
There were no notices for any of the director’s meetings from 2007 to the present. There
18
was no unanimous written consent of waiver of notice for any of the board of director meetings from
19
2007 to the present. There were no written notices of shareholder meetings from 2007 to the present.
20
There was no written unanimous waiver of notice for the shareholder meetings from 2007 to the
21 present. All of the shareholder minutes mention that the prior minutes were “distributed” and “were
22 adopted and approved.” This language is not correct since no prior minutes were distributed.

23 Chris Hulme as shareholder contributed a Ford F -1 50 truck to the corporation on January 2,

24 2007, but received a note payable, so the net change to the value of the corporation was zero. As to

25
the note to Chris Hulme as shareholder for the Ford F-150 truck contributed to the corporation,

26
Jennifer Hulme can’t remember if there were exact formal documents. Chris Hulme contributed a

Ford 13-350 truck to the corporation in exchange for the assumption of an auto loan to Chase Auto
27
Finance of $1 8,008.24, but no documents were signed committing the corporate entity to paying the
28
ﬁnancing. CFO Jennifer Hulme does not know one way or the other whether the Ford E-350

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PATSY MOLER’S TRIAL BRIEF
contributed to the corporation by Chris Hulme had any equity, or was underwater. If you look at it
over time, the net asset value of what the corporation was receiving in contributions from Chris

Hulme in January of 2007 was zero.

In 2009 the corporation borrowed $5,000 from Chris Hulme, but CFO Jennifer Hulme does

not recall if there was a promissory note. She has not been able to locate any written documentation

of this transaction. She does not know the terms or conditions of the loan, but believes it was an

interest free loan. The minutes from the November 11, 2013 meeting mention a short term note for

$20,000 between the corporation and Chris Hulme. There is no documentation of this promissory
note. This was interest free even though CFO Jennifer I-Iulme believed this obligation was above

the threshold that required interest. In February of 2014, the Board of Directors set the 2015
1O
compensation for Chris Hulme and Jennifer Hulme, even though this was almost 11 months away.
11 As early as November of 2013 they were considering winding down and closing the

12 corporation as an option because of this lawsuit. Chris Hulme started a sole proprietorship business

13 in 2014 called Clearview Property Services because Clearview Industries, Inc. is being sued. Since

14 Chris Hulme obtained his license as an individual sole proprietorship for Clearview Property
Services, Clearview Industries, Inc. has not continued to do business offering services to customers
15
since August 2014.
16
Chris Hulme dba Clearview Property Services is currently using all the assets of Clearview
17
Industries, Inc. under a purported lease agreement. When he entered into the lease with Clearview
18
Industries, Inc., it was Chris Hulme’s intention to lease the corporate assets to use in Clearview
19
Property Services. He is renting the corporate assets for $750.00 per month. He is basically leasing
20
everything that had to do with Clearview Industries, Inc. This includes all hard assets of the
21 corporation, all intellectual property of the corporation and the customer lists. Clearview Industries
22 Inc. has leased its website SBHolidaylights.com to Clearview Property Services. This for a

23 business that has generated up to $200,000.00 per year in revenue!

24 Clearview Industries, Inc. has ceased doing business.

25 Additionally, not only was Mrs. Moler the victim of a major fraud both in the inception of
26 her business relationship with Hulme/Clearview and in the performance of the home improvement
27 construction work that Hulme/Clearview accomplished upon the Moler property, but it is clear

28 from the Defendants’ own documentation and cited evidence that the work “performed” by

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PATSY MOLER’S TRIAL BRIEF
Hulme/Clearview was thoroughly deﬁcient, fraudulently billed and wholly outside the scope of the

state sanctioned constructing licensing.

Over the course of this project, the Defendants billed Ms. Moler over $925,000.00. Ms.

Moler actually paid over $750,000.00 to the defendants. The Defendants are not entitled to any of

the money paid to them.

III.
THE STRONG PUBLIC POLICY OF THE STATE OF CALIFORNIA
PROHIBITS DEFENDANTS FROM KEEPING ANY MONEY PAID TO
THEM, OR PURSUING ANY CLAIMS AGAINST MS. MOLER
Bus. & Prof. Code Section 7031 represents a legislative determination that the importance
10 of deterring unlicensed persons from engaging in the contracting business outweighs any harshness
11
between the parties. MW Erectors, Inc. v. Niederhauser Ornamental & Metal Works Co., Inc.
12
(2005) 36 Cal. 4th 412. The statutory contained in Bus. & Prof. Code Section 7031 disallowing
13
claims for payment by unlicensed subcontractors reﬂects a longstanding public policy of the State
14
of California. Pacific Caisson & Shoring, Inc. v. Bernards Bros. Inc., (2015) 236 Cal.App.4th
15
1246.
16
By statute, a contractor seeking damages must allege and prove it held a valid license before
17
it can prosecute any claim for damages. Bus. & Prof. Code Section 7031; Jeff Tracy, Inc v. City
18
OfPico Rivera (2015) 240 Cal.App.4th 510. This the defendants cannot do as they did not have a
19
license to conduct the work they did for most of the time involved in the within matter. When
20
licensure or proper licensure is controverted, the burden of proof to establish licensure or proper
21

22
licensure shall be on the licensee. Bus. & Prof. Code Section 7031; Jeff Tracy, Inc v. City OfPico

23
Rivera (2015) 240 Cal.App.4th 510.

24 When a contractor does not have the specific license speciﬁed in the contract under which

25 the work is performed, the contractor is “unlicensed” for purposes of section 7031, subdivision (b).
26 Bus. & Prof. Code Section 7031; Jeff Tracy. Inc v. City OfPico Rivera (2015) 240 Cal.App.4th

27 510. The authorization of recovery of ‘all compensation paid to the unlicensed contractor for
28

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PATSY MOLER’S TRIAL BRIEF
performance of any act or contract’ under Bus. & Prof. Code § 7031, means that unlicensed

contractors are required to return all compensation received without reductions or offsets. Id.

The purpose of the licensing law is to protect the public from incompetence and dishonesty
in those who provide building and construction services. The licensing requirements provide

minimal assurance that all persons offering such services in California have the requisite skill and

character, understand applicable local laws and codes, and know the rudiments of administering a
contracting business. Judicial Council Of California v. Jacobs Facilities, Inc., (2015) 239

Cal.App.4th 882. The two provisions of the Contractor’s State Licensing Law of concern here are

designed to enforce compliance with the Contractor’s State Licensing Law’s licensing
10
requirements. Section 7031, subdivision (a) provides that no person “engaged in the business or
11

acting in the capacity of a contractor” can bring an action for compensation for work requiring a
12

13
contractor’s license if the person was not properly licensed at all times during the performance of

14
the work. Section 7031, subdivision (b) goes further, permitting a person “who utilizes the services

15 of an unlicensed contractor” to bring an action for disgorgement of “all compensation paid to the

16 unlicensed contractor.” Although the language of the two provisions is somewhat different, they

17 are interpreted “in a consistent manner, resulting in the same remedy regardless of whether the

18 unlicensed contractor is the plaintiff or the defendant. Id. Section 7031 denies all compensation

19 for a contractor’s work, regardless of the quality of the work or the reasons for the failure of
20 licensure. Id. If a contractor is unlicensed for any period of time while delivering construction
21
services, the contractor forfeits all compensation for the work, not merely compensation for the
22
period when the contractor was unlicensed. Id.
23
Further, an unlicensed contractor is subject to forfeiture even if the other contracting party
24
was aware of the contractor’s lack of a license, and the other party’s bad faith or unjust enrichment
25
cannot be asserted by the contractor as a defense to forfeiture. Judicial Council Of California v.
26
Jacobs Facilities, Inc., (2015) 239 Cal.App.4th 882.
27

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PATSY MOLER’S TRIAL BRIEF
IV.
THE DEFENDANTS ARE LIABLE TO PLAINTIFF FOR
DAMAGES ASSOCIATED WITH THE REMDIATION
EFFORTS THAT MS. MOLER INCURRED
The evidence will show that in addition to the payments That Ms. Moler made to Defendants
she incurred around $104,000.00 in her efforts to repair and replace the defective work done by

Defendants. She is entitled to recover that sum from Defendants herein.

V.
DEFENDANTS DEF RAUDED PLAINTIFF
Defendants committed fraud, both in the inducement and by the billings which were not

accurate. Mr. Hulme informed Plaintiff that he and Clearview were properly licensed. As noted
10
above, Defendants were not properly licensed. Plaintiff did not learn of the lack of appropriate
11
licensing until near the end of Defendants’ work.
12
Defendants represented and agreed that they would only bill for the actual time and expenses
13
incurred. CFO Jennifer Hulme personally reviewed the time slips of the employees of Clearview
14
Industries, Inc., but she was not going to job sites to corroborate the employees” information, and
15
Chris Hulme did not typically review the time slips. CFO Jennifer Hulme did not ever take any
16
efforts to conﬁrm the time that was being invoiced to Clearview Industries, Inc. that pertained to the
17
Plaintiff’ s project. CFO Jennifer Hulme never spoke with any of the workers to ascertain whether
18
or not the time records that were being submitted to her were in fact accurate.
19
Prior to the landscape project, Clearview only charged Plaintiff for the cost of materials.
20
Once the landscaping project started, Clearview added a 100% mark-up for materials to the
21
Plaintiffs billings. There are no documents showing that Plaintiff was notiﬁed or agreed to this
22
change. There is nothing on the invoices that would have informed Plaintiff that Clearview
23
Industries, Inc. was charging a 100% mark-up on materials.
24
Clearview paid the subcontractor’s invoices directly. This would be put into the invoice
25
Clearview sent to Plaintiff, but not itemized individually. Clearview would bill Plaintiff for not only
26
for Mr. Speed’s time and materials, but also for his travel expenses, but this was not broken down
27
on the invoices, and there would just be a gross total shown. Looking at the labor allocation on the
28

-9.

PATSY MOLER’S TRIAL BRIEF
invoices, there is no way for Plaintiff to know how many people worked on the job, how many hours

any given day and whether or not the $95 service charge was incurred.

Quite simply, Defendants represented they had proper licensing to do the work, and they did

not. They represented that would only bill for actual time and expenses, and they did not.

Defendants defrauded Plaintiff in virtually every aspect of their relationship.

VI.
THE DEFENDANTS ARE LIABLE TO
PLAINTIFF FOR PUNITIVE DAMAGES

California Civil Code §3294 provides, “[i]n an action for the breach of an obligation not
1O
arising from contract, where it is proven by clear and convincing evidence that the defendant has
11
been guilty of oppression, mg, or malice, the plaintiff, in addition to the actual damages, may
12
recover damages for the sake of example and by way of punishing the defendant.”
13
As the uncontradicted evidence at trial will establish that Defendants’ conduct was
14
fraudulent, oppressive and malicious, Plaintiff is entitled to an award of exemplary damages. Civ.
15
Code §3295(c); Cobb v.Superior Court (1979) 99 Cal.App.3d 543.
16
“Malice” refers to “conduct which is intended by the defendant to cause injury to the plaintiff
17
or despicable conduct which is carried on by the defendant with a willful and conscious disregard of
18
the rights or safety of others.” Civ. Code §3294(c). Defendants’ conduct constituted malice when
19
they intentionally deprived Plaintiff of her money by wrongfully converting it to their own use.
20
As such, upon a ﬁnding that Plaintiff is entitled to an award of punitive damages, this Court
21

should reconvene the trial for the sole purpose of establishing the amount of said award. Civ. Code
22
§3295(d).
23
VII.
24
DEFENDANTS UTTERLY DISREGARDED
25
CORPORATE FORMALITIES

26
Furthermore, the alter ego doctrine is clearly applicable.

27
Factors supporting application of the alter ego doctrine include, but are not limited to,

28
inadequate capitalization, disregard of corporate formalities, and lack of segregation of corporate
records, and identical directors and officers. See, e.g., Tomasellz' v. Transamerica Ins. Co. (1994)

-10-

PAVFSY’h4()LEH{’S'TI{LAI,EHRIEIT
25 Cal.App.4th 1269, 1285; Associated Vendors, Inc. v. Oakland Meat C0. (1962) 210 Cal.App.2d

825, 838-839. This is exactly what has occurred in this case. No one characteristic governs. The

Court must look at all the circumstances to determine whether the doctrine should be applied. Talbot

v. Fresno-Paciﬁc Corp. (1960) 181 Cal.App.2d 425, 432.

In this case, the evidence at trial will make clear that the corporate formalities were, and

continue to be, utterly disregarded.

VIII.
DEFENDANTS CROSS-COMPLAINT SHOULD BE DISMISSED

As noted hereinabove, California law precludes anyone from seeking compensation for any

work done that requires a valid contractor’s license. See, generally, Bus. & Prof. Code § 7031,
10

Hydrotech Systems, Ltd. v. Oasis Walerpark (1991) 52 Cal.3d 988. The Cross-Complaint seeks
11

damages for work done in violation of that law, and should be disallowed, and should not even be
12

13
submitted to the jury as it is the Trial Court who acts as the gate keeper of what issues the jury will
be called upon to determine.
14

CONCLUSION
15

16 The evidence at trial will show that Defendants were contracting without the proper

17 licensing, made numerous fraudulent misrepresentations, submitted billing that was fraudulent,

18 ignored and continue to ignore corporate formalities.

19 Plaintiff is be entitled to judgment against each of the defendants herein.
20 Respectfully submitted,

21 LAW OFFICE OF MICHAEL P. RING & ASSOC.

~
23

26
Dated: July 18, 2016 By:
MICI-IAEITPT
ATTORN
~ ING~
SFOR PLA
~ IFF

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PATSY MOLER’S TRIAL BRIEF
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA

w
I am employed in the County of Santa Barbara, State of California. I am over the age of 18
and not a party to the within action; my business address is 1234 Santa Barbara Street, Santa Barbara,
California, 93101.

kit
On July 18, 2016 I served the foregoing document described as PLAINTIF F ’S TRIAL
BRIEF on the interested parties in this action

XX by placing __ the original XX a true copy thereof addressed as follows:
JEFFREY M. BENNION BRIAN K. FINDLEY
2869 INDIA ST
\OOO\IO\

MULLIGAN, BANHAM & FINDLEY
SAN ”"3300, CA 92103 2442 Fourth Avenue, Suite 100
San Diego, CA 92101
10
(BY FEDERAL EXPRESS OVERNIGHT DELIVERY) I caused such documents to be
ll picked up by Federal Express at 1234 Santa Barbara St., Santa Barbara, California, 93101, in a box
designated by Federal Express for overnight delivery, with delivery fees provided for, addressed to
l2 the person on whom it is to be served.
l3 XX (BY PERSONAL SERVICE) I caused such envelope to be delivered by hand to the
addressee at l 100 ANACAPA STREET, SANTA BARBARA CA
14

15 (BY ELECTRONIC SERVICE) the electronic address where 1 served this is
jeff@jbennionlaw.com.
16
(BY PLACING FOR COLLECTION AND MAILING) I placed the above-mentioned '

17 document(s) in sealed envelope(s) addressed as set forth above, and placed the envelope(s) for
collection and mailing following ordinary business practices. I am readily familiar with the firm’s
18
practice for collection and processing of correspondence for mailing with the United States Postal
19 Service. Under that practice itwould be deposited with the US. Postal Service on that same day
with postage thereon fully prepaid at 1234 Santa Barbara Street, Santa Barbara, CA 93101 in the
1

20 ordinary course of business.

21 XX (STATE) I declare und

Case Info

Judge

Maxwell, Pauline Track Judge’s New Case

Case No.

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Document Filed Date

July 18, 2016

Case Filing Date

July 01, 2013

County

Parties

Bennion, Jeffrey M Attorney for the Defendant
Clearview Industries Inc Cross Complainant
Clearview Industries Inc Defendant
Hulme, Chris Defendant
Hulme, Jennifer Defendant
Moler, Patsy Cross Defendant
Moler, Patsy Plaintiff
Ring, Michael P Attorney for the Plaintiff
William Clinkenbeard Attorney
Iris Ring Attorney
James Francis Attorneys for Plaintiffs
Cathy Anderson Attorney
Michael Pappas Attorney

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Trial Materials: Patsy Moler vs Chris Hulme

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