Preview
ELECTRONICALLY FILED
Superior Court of California
County of Santa Barbara
1 REICKER, PFAU, PYLE & McROY LLP Darrel E. Parker, Executive Officer
1421 State Street, Suite B 11/18/2021 11:29 AM
2 Santa Barbara, CA 93101 By: Narzralli Baksh, Deputy
Tel (805) 966-2440
3 Fax (805) 966-3320
Kevin R. Nimmons (State Bar No. 261577)
4 knimmons@rppmh.com
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Attorneys for Defendants
6 Andrew Waters, FCP Corporate LTD, and FCP Private, LLC
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SANTA BARBARA—ANACAPA DIVISION
10
11 MARK SCHAUB, an individual; TLG LTD., CASE NO.: 20CV02113
a Hong Kong limited liability company, [Assigned to Donna D. Geck, Dept. 4]
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Plaintiffs, DECLARATION OF KEVIN R.
13 NIMMONS RE ADDITIONAL SERVICE
v. OF:
14
ANDREW WYLES WATERS, an individual; 1) NOTICE OF MOTION AND MOTION
15 FCP CORPORATE LTD., a Hong Kong TO BE RELIEVED AS COUNSEL-CIVIL;
limited liability company; FCP PRIVATE,
16 LLC, a California limited liability corporation; 2) DECLARATION IN SUPPORT OF
and DOES 1 through 10, inclusive, ATTORNEY'S MOTION TO BE
17 RELIEVED AS COUNSEL-CIVIL;
Defendants.
18 3) ORDER GRANTING ATTORNEY'S
MOTION TO BE RELIEVED AS
19 COUNSEL-CIVIL
20 HEARING
21 DATE: January 7, 2022
TIME: 10:00 a.m.
22 DEPT: 4
23 Complaint filed: June 14, 2021
24
25 DECLARATION OF KEVIN R. NIMMONS
26 I, Kevin R. Nimmons, declare that:
27 1. I am an attorney at law duly licensed to practice before all Courts of the State of
28 California. I am a partner with the law firm of Reicker, Pfau, Pyle & McRoy LLP, attorneys of
1
DECLARATION OF KEVIN R. NIMMONS RE ADDITIONAL SERVICE OF: 1) NOTICE OF MOTION AND MOTION TO BE RELIEVED AS
COUNSEL-CIVIL; 2) DECLARATION IN SUPPORT OF ATTORNEY'S MOTION TO BE RELIEVED AS COUNSEL-CIVIL; 3) ORDER
GRANTING ATTORNEY'S MOTION TO BE RELIEVED AS COUNSEL-CIVIL
1 record for defendants Andrew Waters, FCP Private, LLC and FCP Corporate, Ltd. I have
2 personal knowledge of the matters stated herein, and if called to testify, I could and would
3 competently testify thereto.
4 2. My office previously served the defendants with the following: Notice of Motion
5 and Motion to be Relieved as Counsel-Civil; Declaration in Support of Attorney's Motion to be
6 Relieved as Counsel-Civil; and Order Granting Attorney's Motion to be Relieved as Counsel-
7 Civil (collectively, the "Motion to be Relieved as Counsel") and filed a proof of service with
8 the Motion to be Relieved as Counsel. I offer this declaration as an additional proof of service.
9 My legal assistant, Susie Hernandez, is also filing a further additional proof of service for service
10 of the Motion to be Relieved as Counsel on defendant FCP Private, LLC.
11 3. On October 20, 2021, I met in my office with my client, defendant Andrew
12 Waters. He stated that he was authorized to accept service of documents on behalf of himself,
13 FCP Private, LLC and FCP Corporate, Ltd., as an officer and/or manager of each entity. I
14 personally handed him three copies of the October 12, 2021 file stamped Motion to be Relieved
15 as Counsel.
16 I declare under penalty of perjury under the laws of the State of California that the
17 foregoing is true and correct. Executed on November 18, 2021, at Santa Barbara, California.
18
__________________________________
19 Kevin R. Nimmons
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25
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DECLARATION OF KEVIN R. NIMMONS RE ADDITIONAL SERVICE OF: 1) NOTICE OF MOTION AND MOTION TO BE RELIEVED AS
COUNSEL-CIVIL; 2) DECLARATION IN SUPPORT OF ATTORNEY'S MOTION TO BE RELIEVED AS COUNSEL-CIVIL; 3) ORDER
GRANTING ATTORNEY'S MOTION TO BE RELIEVED AS COUNSEL-CIVIL
Preview
ELECTRONICALLY FILED Superior Court of California County of Santa Barbara 1 REICKER, PFAU, PYLE & McROY LLP Darrel E. Parker, Executive Officer 1421 State Street, Suite B 11/18/2021 11:29 AM 2 Santa Barbara, CA 93101 By: Narzralli Baksh, Deputy Tel (805) 966-2440 3 Fax (805) 966-3320 Kevin R. Nimmons (State Bar No. 261577) 4 knimmons@rppmh.com 5 Attorneys for Defendants 6 Andrew Waters, FCP Corporate LTD, and FCP Private, LLC 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SANTA BARBARA—ANACAPA DIVISION 10 11 MARK SCHAUB, an individual; TLG LTD., CASE NO.: 20CV02113 a Hong Kong limited liability company, [Assigned to Donna D. Geck, Dept. 4] 12 Plaintiffs, DECLARATION OF KEVIN R. 13 NIMMONS RE ADDITIONAL SERVICE v. OF: 14 ANDREW WYLES WATERS, an individual; 1) NOTICE OF MOTION AND MOTION 15 FCP CORPORATE LTD., a Hong Kong TO BE RELIEVED AS COUNSEL-CIVIL; limited liability company; FCP PRIVATE, 16 LLC, a California limited liability corporation; 2) DECLARATION IN SUPPORT OF and DOES 1 through 10, inclusive, ATTORNEY'S MOTION TO BE 17 RELIEVED AS COUNSEL-CIVIL; Defendants. 18 3) ORDER GRANTING ATTORNEY'S MOTION TO BE RELIEVED AS 19 COUNSEL-CIVIL 20 HEARING 21 DATE: January 7, 2022 TIME: 10:00 a.m. 22 DEPT: 4 23 Complaint filed: June 14, 2021 24 25 DECLARATION OF KEVIN R. NIMMONS 26 I, Kevin R. Nimmons, declare that: 27 1. I am an attorney at law duly licensed to practice before all Courts of the State of 28 California. I am a partner with the law firm of Reicker, Pfau, Pyle & McRoy LLP, attorneys of 1 DECLARATION OF KEVIN R. NIMMONS RE ADDITIONAL SERVICE OF: 1) NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL-CIVIL; 2) DECLARATION IN SUPPORT OF ATTORNEY'S MOTION TO BE RELIEVED AS COUNSEL-CIVIL; 3) ORDER GRANTING ATTORNEY'S MOTION TO BE RELIEVED AS COUNSEL-CIVIL 1 record for defendants Andrew Waters, FCP Private, LLC and FCP Corporate, Ltd. I have 2 personal knowledge of the matters stated herein, and if called to testify, I could and would 3 competently testify thereto. 4 2. My office previously served the defendants with the following: Notice of Motion 5 and Motion to be Relieved as Counsel-Civil; Declaration in Support of Attorney's Motion to be 6 Relieved as Counsel-Civil; and Order Granting Attorney's Motion to be Relieved as Counsel- 7 Civil (collectively, the "Motion to be Relieved as Counsel") and filed a proof of service with 8 the Motion to be Relieved as Counsel. I offer this declaration as an additional proof of service. 9 My legal assistant, Susie Hernandez, is also filing a further additional proof of service for service 10 of the Motion to be Relieved as Counsel on defendant FCP Private, LLC. 11 3. On October 20, 2021, I met in my office with my client, defendant Andrew 12 Waters. He stated that he was authorized to accept service of documents on behalf of himself, 13 FCP Private, LLC and FCP Corporate, Ltd., as an officer and/or manager of each entity. I 14 personally handed him three copies of the October 12, 2021 file stamped Motion to be Relieved 15 as Counsel. 16 I declare under penalty of perjury under the laws of the State of California that the 17 foregoing is true and correct. Executed on November 18, 2021, at Santa Barbara, California. 18 __________________________________ 19 Kevin R. Nimmons 20 21 22 23 24 25 26 27 28 2 DECLARATION OF KEVIN R. NIMMONS RE ADDITIONAL SERVICE OF: 1) NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL-CIVIL; 2) DECLARATION IN SUPPORT OF ATTORNEY'S MOTION TO BE RELIEVED AS COUNSEL-CIVIL; 3) ORDER GRANTING ATTORNEY'S MOTION TO BE RELIEVED AS COUNSEL-CIVIL