On March 15, 2022 a
(Paramont) App Pro Hac Vice tf (2)
was filed
involving a dispute between
Arntsen Family Partnership, Lp,
Arntsen, Robert,
Brian Christopher Dunn Custodianship,
Ho, John,
Huang, Quanyu,
Lee, Mary,
and
Black Horse Holdings, Llc,
Bragg, David M,
Caproc Iii, Llc,
Davis, Gregory J,
Huang, Quanyu,
Huish, Dale,
Justesen, Jason,
Kludt, Kurtis Stuart,
Mclan Trust,
Monks Family Trust,
Oneil, Scott,
Paramont Capital, Llc,
Paramont Woodside, Llc,
Silicon Valley Real Ventures, Llc,
Stoker, Diane,
Stoker, Phil,
Svrv 385 Moore, Llc,
Svrv 387 Moore, Llc,
Teh Capital, Llc,
Wild Rose Irrevocable Trust,
Wolfe, Kevin,
Wz Partners Llc,
for (16) Unlimited Fraud
in the District Court of San Mateo County.
Preview
1 Ernesto F. Aldover (SBN 157625)
RETZ & ALDOVER, LLP
2 2550 Via Tejon, Suite 3A
Palos Verdes Estates, California 90274
3 (310) 540-9800 telephone
4
Attorneys for Defendants
5 Gregory J. Davis; Paramont Woodside, LLC;
and Paramont Capital, LLC, SVRV 385 Moore LLC,
6 SVRV 387 Moore LLC
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
9 COUNTY OF SAN MATEO
10
Palos Verdes Estates, CA 90274
RETZ & ALDOVER, LLP
2550 Via Tejon, Suite 3A
11 Robert Arntsen; Mary Lee; Arntsen Family Case No. 22-CIV-01148
Partnership, LP; and Brian Christopher Dunn
12 Custodianship; APPLICATION TO ADMIT BRIAN W.
ZIMMERMAN PRO HAC VICE;
13 Plaintiffs, DECLARATIONS OF BRIAN W.
ZIMMERMAN
14 -vs-
15 David M. Bragg; Kurtis Stuart Kludt; Silicon [DECLARATION OF ERNESTO F.
Valley Real Ventures, LLC; SVRV 385 Moore, ALDOVER; [PROPOSED] ORDER]
16 LLC; SVRV 387 Moore, LLC; Gregory J.
Davis; Paramont Woodside, LLC; and
17 Paramont Capital, LLC; [Hon. Robert D. Foiles]
18 Defendants.
Date: August 19, 2022
19 Time: 9:00 AM
Dept.: 21
20
21
22 Pursuant to California Rules of Court, Rule 9.40, Defendants Gregory J. Davis; Paramont
23 Woodside, LLC; and Paramont Capital, LLC, (collectively, “Defendants”), hereby move for pro
24 hac vice admission of Brian W. Zimmerman in the San Mateo County Superior Court of the State
25 of California. As demonstrated in the memorandum of points and authorities and his Declaration,
26 Mr. Zimmerman is qualified to be admitted pro hac vice for this matter.
27
28
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APPLICATION TO ADMIT BRIAN W. ZIMMERMAN PRO HAC VICE
1 MEMORANDUM OF POINTS AND AUTHORITIES
2 The attached Declaration of Brian W. Zimmerman (“Zimmerman Declaration”) sets forth
3 the facts required to be presented to this Court under Rule 9.40(d).
4 As enumerated in the rule:
5 1. Mr. Zimmerman’s residence is at 5215 Dumfries, Houston, Texas 77096. His
6 office is at Spencer Fane LLP. Mr. Zimmerman’s office telephone number is (713) 212-2651.
7 Zimmerman Declaration, ¶1.
8 2. Mr. Zimmerman was admitted to practice before the bar of the State of Texas in
9 1993, the United States District Courts for the Southern District of Texas in 1995, the United
10 States District Courts for the North District of Texas in 1996, the United States District Court for
Palos Verdes Estates, CA 90274
RETZ & ALDOVER, LLP
2550 Via Tejon, Suite 3A
11 the Eastern District of Texas in 1996, the United States District Courts for the Western District of
12 Texas in 2011, and the Supreme Court of Texas in 1993. Zimmerman Declaration, ¶2.
13 3. Mr. Zimmerman is a member in good standing of the courts in which he has been
14 admitted. Zimmerman Declaration, ¶2.
15 4. Mr. Zimmerman is not currently suspended or disbarred from practice in any
16 court. Zimmerman Declaration, ¶2.
17 5. Mr. Zimmerman has not applied to appear ex parte before any Court in the state of
18 California in the past 2 years.
19 Mr. Zimmerman is not regularly employed in the State of California, and Mr. Zimmerman
20 does not regularly engage in substantial business, professional, or other activities in the state of
21 California. Zimmerman Declaration, ¶3.
22 6. Ernesto F. Aldover, Esq., who is an active member of the State Bar of California,
23 is the attorney of record for Defendants in the above-entitled action. Mr. Aldover’s office address
24 is 2550 Via Tejon, Suite 3A, Palos Verdes Estates, CA 90274, and his office telephone number is
25 (310) 540-9800. Zimmerman Declaration, ¶4.
26 In addition, this motion has been served on the State Bar of California together with a
27 check for the $50, concurrently with the filing of this application. Zimmerman Declaration, ¶5.
28 Based on the foregoing legal authority and facts, appellants respectfully request that this Court
-2-
APPLICATION TO ADMIT BRIAN W. ZIMMERMAN PRO HAC VICE
1 grant this motion.
2
3
4 Dated: June 13, 2022 RETZ & ALDOVER, LLP
5
6
7 By: _________________________________
Ernesto F. Aldover, Esq.
8 Attorneys for Defendants
Gregory J. Davis; Paramont Woodside,
9 LLC; and Paramont Capital, LLC, SVRV
385 Moore LLC, SVRV 387 Moore LLC
10
Palos Verdes Estates, CA 90274
RETZ & ALDOVER, LLP
2550 Via Tejon, Suite 3A
11
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APPLICATION TO ADMIT BRIAN W. ZIMMERMAN PRO HAC VICE
1 DECLARATION OF BRIAN W. ZIMMERMAN
2 I, Brian W. Zimmerman do hereby declare:
3 1. I am not a resident of California. My residence is 5215 Dumfries, Houston, Texas
4 77096. My office is at Spencer Fane LLP, 3040 Post Oak Blvd., Suite 1300, Houston, Texas 77056.
5 My office telephone number is (713) 212-2651.
6 2. I was admitted to practice before the bar of the State of Texas in 1993, the United
7 States District Courts for the Southern District of Texas in 1995, the United States District Courts
8 for the North District of Texas in 1996, the United States District Court for the Eastern District of
9 Texas in 1996, the United States District Courts for the Western District of Texas in 2011, and the
Palos Verdes Estates, CA 90274
10 Supreme Court of Texas in 1993. I am a member in good standing of the courts in which I have
RETZ & ALDOVER, LLP
2550 Via Tejon, Suite 3A
11 been admitted, and I am not currently suspended or disbarred from practice in any court.
12 3. I have not made an application to appear as counsel pro hac vice before any court in
13 the State of California within the past 2 years. I am not regularly employed in the State of California,
14 and do not regularly engage in substantial business, professional, or other activities in the state of
15 California.
16 4. My colleague, Ernesto F. Aldover, Esq., who is an active member of the State Bar of
17 California, is the attorney of record for Defendants in the above-entitled action. Mr. Aldover’s
18 office address is 2550 Via Tejon, Suite 3A, Palos Verdes Estates, CA 90274, and his office
19 telephone number is (310) 540-9800.
20 5. Concurrently with the filing of this motion, Ernesto F. Aldover, Esq., is serving this
21 motion on the State Bar of California together with a check for the $50 fee.
22 I declare under penalty of perjury under the laws of the State of California that the foregoing
23 is true and correct.
24
25 Executed this 3rd day of June, 2022 at Houston, Texas.
26
________________________________
27 Brian W. Zimmerman
28
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APPLICATION TO ADMIT BRIAN W. ZIMMERMAN PRO HAC VICE
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
3
I am employed in the county of Los Angeles, State of California. I am over the age of 18
4 and not a party to the action; my business address is 2550 Via Tejon, Suite 3A, Palos Verdes
Estates, CA 90274.
5
On June 14, 2022 I served the foregoing document(s) described as APPLICATION TO
6 ADMIT BRIAN W. ZIMMERMAN PRO HAC VICE on the interested parties in this action as
7 follows:
8
Collin J. Vierra (State Bar No. Attn:
9 322720) EIMER STAHL LLP Pro Hac Vice Program
99 Almaden Blvd., Suite 641 The State Bar of California
10
Palos Verdes Estates, CA 90274
San Jose, CA 95113-1605 180 Howard Street
RETZ & ALDOVER, LLP
2550 Via Tejon, Suite 3A
11 Telephone: (408) 889-1668 San Francisco, CA 94105
Email: cvierra@eimerstahl.com Email: ProHac@calbar.ca.gov
12 Admissions Applicant Portal:
Attorney for Plaintiffs https://admissions.calbar.ca.gov/s/login/?startURL
13 =%2Fs%2F&ec=302
14
15 _X_ (BY US MAIL) As follows: I am “readily familiar” with the firm’s practice of collection
and processing correspondence for mailing. Under that practice it would be deposited with the
16 U.S. Postal Service on that same day with postage thereon fully prepaid at Palos Verdes Estate,
CA in the ordinary cause of business. I am aware that on motion of the party served, service is
17 presumed invalid of postal cancellation date or postage meter is more than one day after date of
18 deposit for mailing an affidavit.
19 ___ (BY ELECTRONIC SERVICE) I electronically served the foregoing document(s) on
opposing counsel via electronic mail.
20
___ (BY OVERNIGHT MAIL) By depositing copies of the above documents in a box or other
21
facility regularly maintained by General Logistics Systems US with delivery fees paid or
22 provided for, addressed to the individual listed above, at the address listed above. [C.C.P. §§
1013(c), 2015.5]
23
X (STATE) I declare under penalty of perjury under the laws of the State of California that
24 the foregoing is true and correct.
25
Executed on June 14, 2022 at Palos Verdes Estates, California.
26
27
__________________________________
28 Alex Landavazo
-5-
APPLICATION TO ADMIT BRIAN W. ZIMMERMAN PRO HAC VICE
Preview
1 Ernesto F. Aldover (SBN 157625) RETZ & ALDOVER, LLP 2 2550 Via Tejon, Suite 3A Palos Verdes Estates, California 90274 3 (310) 540-9800 telephone 4 Attorneys for Defendants 5 Gregory J. Davis; Paramont Woodside, LLC; and Paramont Capital, LLC, SVRV 385 Moore LLC, 6 SVRV 387 Moore LLC 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 9 COUNTY OF SAN MATEO 10 Palos Verdes Estates, CA 90274 RETZ & ALDOVER, LLP 2550 Via Tejon, Suite 3A 11 Robert Arntsen; Mary Lee; Arntsen Family Case No. 22-CIV-01148 Partnership, LP; and Brian Christopher Dunn 12 Custodianship; APPLICATION TO ADMIT BRIAN W. ZIMMERMAN PRO HAC VICE; 13 Plaintiffs, DECLARATIONS OF BRIAN W. ZIMMERMAN 14 -vs- 15 David M. Bragg; Kurtis Stuart Kludt; Silicon [DECLARATION OF ERNESTO F. Valley Real Ventures, LLC; SVRV 385 Moore, ALDOVER; [PROPOSED] ORDER] 16 LLC; SVRV 387 Moore, LLC; Gregory J. Davis; Paramont Woodside, LLC; and 17 Paramont Capital, LLC; [Hon. Robert D. Foiles] 18 Defendants. Date: August 19, 2022 19 Time: 9:00 AM Dept.: 21 20 21 22 Pursuant to California Rules of Court, Rule 9.40, Defendants Gregory J. Davis; Paramont 23 Woodside, LLC; and Paramont Capital, LLC, (collectively, “Defendants”), hereby move for pro 24 hac vice admission of Brian W. Zimmerman in the San Mateo County Superior Court of the State 25 of California. As demonstrated in the memorandum of points and authorities and his Declaration, 26 Mr. Zimmerman is qualified to be admitted pro hac vice for this matter. 27 28 -1- APPLICATION TO ADMIT BRIAN W. ZIMMERMAN PRO HAC VICE 1 MEMORANDUM OF POINTS AND AUTHORITIES 2 The attached Declaration of Brian W. Zimmerman (“Zimmerman Declaration”) sets forth 3 the facts required to be presented to this Court under Rule 9.40(d). 4 As enumerated in the rule: 5 1. Mr. Zimmerman’s residence is at 5215 Dumfries, Houston, Texas 77096. His 6 office is at Spencer Fane LLP. Mr. Zimmerman’s office telephone number is (713) 212-2651. 7 Zimmerman Declaration, ¶1. 8 2. Mr. Zimmerman was admitted to practice before the bar of the State of Texas in 9 1993, the United States District Courts for the Southern District of Texas in 1995, the United 10 States District Courts for the North District of Texas in 1996, the United States District Court for Palos Verdes Estates, CA 90274 RETZ & ALDOVER, LLP 2550 Via Tejon, Suite 3A 11 the Eastern District of Texas in 1996, the United States District Courts for the Western District of 12 Texas in 2011, and the Supreme Court of Texas in 1993. Zimmerman Declaration, ¶2. 13 3. Mr. Zimmerman is a member in good standing of the courts in which he has been 14 admitted. Zimmerman Declaration, ¶2. 15 4. Mr. Zimmerman is not currently suspended or disbarred from practice in any 16 court. Zimmerman Declaration, ¶2. 17 5. Mr. Zimmerman has not applied to appear ex parte before any Court in the state of 18 California in the past 2 years. 19 Mr. Zimmerman is not regularly employed in the State of California, and Mr. Zimmerman 20 does not regularly engage in substantial business, professional, or other activities in the state of 21 California. Zimmerman Declaration, ¶3. 22 6. Ernesto F. Aldover, Esq., who is an active member of the State Bar of California, 23 is the attorney of record for Defendants in the above-entitled action. Mr. Aldover’s office address 24 is 2550 Via Tejon, Suite 3A, Palos Verdes Estates, CA 90274, and his office telephone number is 25 (310) 540-9800. Zimmerman Declaration, ¶4. 26 In addition, this motion has been served on the State Bar of California together with a 27 check for the $50, concurrently with the filing of this application. Zimmerman Declaration, ¶5. 28 Based on the foregoing legal authority and facts, appellants respectfully request that this Court -2- APPLICATION TO ADMIT BRIAN W. ZIMMERMAN PRO HAC VICE 1 grant this motion. 2 3 4 Dated: June 13, 2022 RETZ & ALDOVER, LLP 5 6 7 By: _________________________________ Ernesto F. Aldover, Esq. 8 Attorneys for Defendants Gregory J. Davis; Paramont Woodside, 9 LLC; and Paramont Capital, LLC, SVRV 385 Moore LLC, SVRV 387 Moore LLC 10 Palos Verdes Estates, CA 90274 RETZ & ALDOVER, LLP 2550 Via Tejon, Suite 3A 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -3- APPLICATION TO ADMIT BRIAN W. ZIMMERMAN PRO HAC VICE 1 DECLARATION OF BRIAN W. ZIMMERMAN 2 I, Brian W. Zimmerman do hereby declare: 3 1. I am not a resident of California. My residence is 5215 Dumfries, Houston, Texas 4 77096. My office is at Spencer Fane LLP, 3040 Post Oak Blvd., Suite 1300, Houston, Texas 77056. 5 My office telephone number is (713) 212-2651. 6 2. I was admitted to practice before the bar of the State of Texas in 1993, the United 7 States District Courts for the Southern District of Texas in 1995, the United States District Courts 8 for the North District of Texas in 1996, the United States District Court for the Eastern District of 9 Texas in 1996, the United States District Courts for the Western District of Texas in 2011, and the Palos Verdes Estates, CA 90274 10 Supreme Court of Texas in 1993. I am a member in good standing of the courts in which I have RETZ & ALDOVER, LLP 2550 Via Tejon, Suite 3A 11 been admitted, and I am not currently suspended or disbarred from practice in any court. 12 3. I have not made an application to appear as counsel pro hac vice before any court in 13 the State of California within the past 2 years. I am not regularly employed in the State of California, 14 and do not regularly engage in substantial business, professional, or other activities in the state of 15 California. 16 4. My colleague, Ernesto F. Aldover, Esq., who is an active member of the State Bar of 17 California, is the attorney of record for Defendants in the above-entitled action. Mr. Aldover’s 18 office address is 2550 Via Tejon, Suite 3A, Palos Verdes Estates, CA 90274, and his office 19 telephone number is (310) 540-9800. 20 5. Concurrently with the filing of this motion, Ernesto F. Aldover, Esq., is serving this 21 motion on the State Bar of California together with a check for the $50 fee. 22 I declare under penalty of perjury under the laws of the State of California that the foregoing 23 is true and correct. 24 25 Executed this 3rd day of June, 2022 at Houston, Texas. 26 ________________________________ 27 Brian W. Zimmerman 28 -4- APPLICATION TO ADMIT BRIAN W. ZIMMERMAN PRO HAC VICE 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 3 I am employed in the county of Los Angeles, State of California. I am over the age of 18 4 and not a party to the action; my business address is 2550 Via Tejon, Suite 3A, Palos Verdes Estates, CA 90274. 5 On June 14, 2022 I served the foregoing document(s) described as APPLICATION TO 6 ADMIT BRIAN W. ZIMMERMAN PRO HAC VICE on the interested parties in this action as 7 follows: 8 Collin J. Vierra (State Bar No. Attn: 9 322720) EIMER STAHL LLP Pro Hac Vice Program 99 Almaden Blvd., Suite 641 The State Bar of California 10 Palos Verdes Estates, CA 90274 San Jose, CA 95113-1605 180 Howard Street RETZ & ALDOVER, LLP 2550 Via Tejon, Suite 3A 11 Telephone: (408) 889-1668 San Francisco, CA 94105 Email: cvierra@eimerstahl.com Email: ProHac@calbar.ca.gov 12 Admissions Applicant Portal: Attorney for Plaintiffs https://admissions.calbar.ca.gov/s/login/?startURL 13 =%2Fs%2F&ec=302 14 15 _X_ (BY US MAIL) As follows: I am “readily familiar” with the firm’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the 16 U.S. Postal Service on that same day with postage thereon fully prepaid at Palos Verdes Estate, CA in the ordinary cause of business. I am aware that on motion of the party served, service is 17 presumed invalid of postal cancellation date or postage meter is more than one day after date of 18 deposit for mailing an affidavit. 19 ___ (BY ELECTRONIC SERVICE) I electronically served the foregoing document(s) on opposing counsel via electronic mail. 20 ___ (BY OVERNIGHT MAIL) By depositing copies of the above documents in a box or other 21 facility regularly maintained by General Logistics Systems US with delivery fees paid or 22 provided for, addressed to the individual listed above, at the address listed above. [C.C.P. §§ 1013(c), 2015.5] 23 X (STATE) I declare under penalty of perjury under the laws of the State of California that 24 the foregoing is true and correct. 25 Executed on June 14, 2022 at Palos Verdes Estates, California. 26 27 __________________________________ 28 Alex Landavazo -5- APPLICATION TO ADMIT BRIAN W. ZIMMERMAN PRO HAC VICE