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1 REICKER, PFAU, PYLE & McROY LLP
1421 State Street, Suite B ELECTRONICALLY FILED
2 Santa Barbara, CA 93101 Superior Court of California
Tel (805) 966-2440 County of Santa Barbara
3 Fax (805) 966-3320 Darrel E. Parker, Executive Officer
Kevin R. Nimmons (State Bar No. 261577)
4 knimmons@rppmh.com 5/27/2021 8:57 PM
Meghan K. Woodsome (State Bar No. 272459) By: Elizabeth Spann, Deputy
5 mwoodsome@rppmh.com
Cory T. Baker (State Bar No. 315763)
6 cbaker@rppmh.com
7 Attorneys for Defendants
Andrew Waters and FCP Private, LLC
8
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SANTA BARBARA—ANACAPA DIVISION
11 MARK SCHAUB, an individual; TLG LTD., Case No.: 20CV02113
a Hong Kong limited Liability company Assigned to: Hon. Donna D. Geck
12
Plaintiffs,
13 NOTICE OF PLAINTIFFS' NON-
v. OPPOSITION TO DEFENDANTS'
14 MOTION TO STRIKE FIRST
ANDREW WYLES WATERS, an individual;
15 FCP CORPORATION LTD., a Hong Kong AMENDED COMPLAINT
limited liability company; FCP PRIVATE,
16 LLC, a California limited liability corporation;
and DOES 1 through 10, inclusive, Date: June 4, 2021
17 Time: 10:00 a.m.
Defendants. Dept.: 4
18
19
20 NOTICE IS HEREBY GIVEN that Plaintiffs MARK SCHAUB and TLG LTD ("Plaintiffs")
21 have not filed an opposition to Defendants ANDREW WATERS and FCP PRIVATE, LLC's
22 ("Defendants") Motion to Strike portions of the First Amended Complaint ("Motion to Strike").
23 Said opposition was due on May 21, 2021. Accordingly, Defendants request that the Court grant
24 the relief requested in the Motion to Strike.
25 Dated: May 27, 2021 REICKER, PFAU, PYLE AND McROY LLP
26
By ___________________________________
27
Kevin R. Nimmons
28 Attorneys for Defendants
Andrew Waters and FCP Private, LLC
NOTICE OF NON-OPPOSITION TO MOTION TO STRIKE FIRST AMENDED COMPLAINT: Page 1
1 PROOF OF SERVICE
2 I, the undersigned, say that I am a citizen of the United States, over 18 years of age, and not
a party to the within action. I am employed by the law firm of Reicker, Pfau, Pyle & McRoy LLP,
3 1421 State Street, Ste. B, Santa Barbara, California 93101.
4 On May 27, 2021, I served the within: NOTICE OF PLAINTIFFS' NON-OPPOSITION
5 TO DEFENDANTS' MOTION TO STRIKE FIRST AMENDED COMPLAINT on the
interested parties listed below, as follows:
6
Matthew Donald Umhofer
7 Diane H. Bang
SPERTUS, LANDES & UMHOFER, LLP
8 1990 South Bundy Dr., Suite 705
Los Angeles, California 90025
9 Telephone: (310) 826-4700
Facsimile: (310) 826-4 711
10 Email: matthew@spertuslaw.com
Email: diane@spertuslaw.com
11
(X) (By Mail) I caused such document to be mailed in a sealed envelope, by first-class mail,
12 postage fully prepaid. I am “readily familiar” with this firm’s practice of collection and
processing correspondence for mailing. It is deposited with the U.S. postal service on that
13 same day in the ordinary course of business. I am aware that on motion of party served,
service is presumed invalid if the postal cancellation date or postage meter date is more
14 than one (1) day after the date of deposit for mailing as stated in this declaration.
15 ( ) (By Personal Service) I caused such document to be delivered by hand.
16 ( ) (By FAX) I caused such document to be sent via facsimile transmission to the above-listed
addressee(s) and FAX number(s). This transmission was reported as complete and without
17 error.
18 (X) ((By E-MAIL [CCP § 1010.6(a)(2)) On the date indicated on this Proof of Service, at the
time indicated on in the header of my electronic mail, I transmitted the foregoing
19 document(s) by electronic mail to one or more of the recipients at each firm indicated on
this Proof of Service. I caused the my computer to print or maintain a record of the
20 electronic mail to the recipients named in this Proof of Service, a true and correct copy of
which has been retained by Reicker, Pfau, Pyle & McRoy LLP in either hard copy or
21 electronic format in the ordinary course of business and is available for inspection if
necessary.
22
(X) (State) I declare under penalty of perjury pursuant to the laws of the State of California
23 that the foregoing is true and correct.
24 Executed on May 27, 2021, at Santa Barbara, California.
25
_______________________________
26 Catrine Casper
Legal Assistant
27
28
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1 REICKER, PFAU, PYLE & McROY LLP 1421 State Street, Suite B ELECTRONICALLY FILED 2 Santa Barbara, CA 93101 Superior Court of California Tel (805) 966-2440 County of Santa Barbara 3 Fax (805) 966-3320 Darrel E. Parker, Executive Officer Kevin R. Nimmons (State Bar No. 261577) 4 knimmons@rppmh.com 5/27/2021 8:57 PM Meghan K. Woodsome (State Bar No. 272459) By: Elizabeth Spann, Deputy 5 mwoodsome@rppmh.com Cory T. Baker (State Bar No. 315763) 6 cbaker@rppmh.com 7 Attorneys for Defendants Andrew Waters and FCP Private, LLC 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SANTA BARBARA—ANACAPA DIVISION 11 MARK SCHAUB, an individual; TLG LTD., Case No.: 20CV02113 a Hong Kong limited Liability company Assigned to: Hon. Donna D. Geck 12 Plaintiffs, 13 NOTICE OF PLAINTIFFS' NON- v. OPPOSITION TO DEFENDANTS' 14 MOTION TO STRIKE FIRST ANDREW WYLES WATERS, an individual; 15 FCP CORPORATION LTD., a Hong Kong AMENDED COMPLAINT limited liability company; FCP PRIVATE, 16 LLC, a California limited liability corporation; and DOES 1 through 10, inclusive, Date: June 4, 2021 17 Time: 10:00 a.m. Defendants. Dept.: 4 18 19 20 NOTICE IS HEREBY GIVEN that Plaintiffs MARK SCHAUB and TLG LTD ("Plaintiffs") 21 have not filed an opposition to Defendants ANDREW WATERS and FCP PRIVATE, LLC's 22 ("Defendants") Motion to Strike portions of the First Amended Complaint ("Motion to Strike"). 23 Said opposition was due on May 21, 2021. Accordingly, Defendants request that the Court grant 24 the relief requested in the Motion to Strike. 25 Dated: May 27, 2021 REICKER, PFAU, PYLE AND McROY LLP 26 By ___________________________________ 27 Kevin R. Nimmons 28 Attorneys for Defendants Andrew Waters and FCP Private, LLC NOTICE OF NON-OPPOSITION TO MOTION TO STRIKE FIRST AMENDED COMPLAINT: Page 1 1 PROOF OF SERVICE 2 I, the undersigned, say that I am a citizen of the United States, over 18 years of age, and not a party to the within action. I am employed by the law firm of Reicker, Pfau, Pyle & McRoy LLP, 3 1421 State Street, Ste. B, Santa Barbara, California 93101. 4 On May 27, 2021, I served the within: NOTICE OF PLAINTIFFS' NON-OPPOSITION 5 TO DEFENDANTS' MOTION TO STRIKE FIRST AMENDED COMPLAINT on the interested parties listed below, as follows: 6 Matthew Donald Umhofer 7 Diane H. Bang SPERTUS, LANDES & UMHOFER, LLP 8 1990 South Bundy Dr., Suite 705 Los Angeles, California 90025 9 Telephone: (310) 826-4700 Facsimile: (310) 826-4 711 10 Email: matthew@spertuslaw.com Email: diane@spertuslaw.com 11 (X) (By Mail) I caused such document to be mailed in a sealed envelope, by first-class mail, 12 postage fully prepaid. I am “readily familiar” with this firm’s practice of collection and processing correspondence for mailing. It is deposited with the U.S. postal service on that 13 same day in the ordinary course of business. I am aware that on motion of party served, service is presumed invalid if the postal cancellation date or postage meter date is more 14 than one (1) day after the date of deposit for mailing as stated in this declaration. 15 ( ) (By Personal Service) I caused such document to be delivered by hand. 16 ( ) (By FAX) I caused such document to be sent via facsimile transmission to the above-listed addressee(s) and FAX number(s). This transmission was reported as complete and without 17 error. 18 (X) ((By E-MAIL [CCP § 1010.6(a)(2)) On the date indicated on this Proof of Service, at the time indicated on in the header of my electronic mail, I transmitted the foregoing 19 document(s) by electronic mail to one or more of the recipients at each firm indicated on this Proof of Service. I caused the my computer to print or maintain a record of the 20 electronic mail to the recipients named in this Proof of Service, a true and correct copy of which has been retained by Reicker, Pfau, Pyle & McRoy LLP in either hard copy or 21 electronic format in the ordinary course of business and is available for inspection if necessary. 22 (X) (State) I declare under penalty of perjury pursuant to the laws of the State of California 23 that the foregoing is true and correct. 24 Executed on May 27, 2021, at Santa Barbara, California. 25 _______________________________ 26 Catrine Casper Legal Assistant 27 28