On March 24, 2022 a
Miscellaneous
was filed
involving a dispute between
Barrinuevo, Licia,
Corley-Emerueh, Denise,
Elder & Spencer, Llp,
Greenwood, Dorcey,
and
Does 1 Through 50,
Group Xiv Properties, Lp,
Hightower Management, Inc.,
Pama Management, Inc.,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
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r
”Nanyi/“Vo 3‘“
AEORNEY 0R PARTY vsATHOUT ATTORNEY (Name, s~rnumben
D
and address):
LAAxn. nil.
\r
LN»
-~-
F” “WW“ °”"
it; CM-o1o
CHANDRA GEHRI SPENCER (SBN 184010); ELDER a SPENCER LLP
12625 TOWNSGATE ROAD, SUITE 330, WESTLAKE VILLAGE CA 91361 u a
w
EETEO'PALIFORNIA
~-‘ ~ "
TELEpHoNe No; (21 3) 631 -8331 FAx No. (optional): (888) 422-8027 5%%j§y’$ 59%;».N arefimARDINp
vasr-u'aipmcf) UIQTRKET
E.MAIL AooRess;
s '..»
L352
ATTORNEY FOR (Name): PLAINTIFFS DENISE CORLEY-EMERUEH ET AL
MAR 24 2022
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
STREET ADDRESS: 247 THIRD AVENUE W ‘
MAiLING ADDRESS: 247 THIRD AVENUE W 3v Ark” 7&3!
CITY ANDZIP CODE: SAN BERNARDINO CA 92415 macr—eAEL‘.nIE!_3:-: :2, 0531:?!
BRANCH NAME: SAN BERNARDlNO - CIVIL DISTRICT
CASE NAME:
DENISE CORLEY-EMERUEH ET AL V GROUP XIV PROPERTlES LP ET AL
-
CASE
CASE COVER SHEET Comp.“ Case Designation Nve A
E CIVIL
D E E C| gB 2 2 n B 8 2 l1
Ulllimned
(Amount
exceeds $25,000)
LimitEd
(Amount
$25,000 or Iess)
(9W) Counter
'
Items 1—6 below must be completed (see
'
Joinder
-
infstructions
m
DEPT.:
on page 2).
case type that best describes this case:
1. Check one box below for the
Provlslonally Complex Clvi| thigation
Auto Tort
E
E Auto (22) E
Contract
E Breach of comracuwarramy (06)
(Cal. Rules of Court, rules 3400-3403)
D regu'afim (03)
Uninsured motorist(46)
E Rule 3,740 collections (09)
E
E
AntitrUSt/Trade
Construction defect (10)
Other PI/PDIwo (Personal InjuryIProperty
Damage’wrongful 09am) Ton
E E
E
Other collections (09)
Insurance coverage (18)
D
Mass 1°" (40)
Securities litigation (28)
E
E
Asbestos (04)
Pmduc‘ “abimy
Medical malpractice (45)
(24)
Other contract (37)
Real Property S
E EnvironmentalfToxic ton (30)
Insuran'ce coveralg'e claims arising from the
E Other PI/PD/wo (23)
E
Eminent domain/lnverse
condemnation (1 4) gilesegfiged
prowsuonany complex case
E
E
Non-PIIPDIWD(Other)Tort
Business tort/unfair business practice (07) D Wrongfuleviction(33)
Other real Property (25)
unlaw‘u' Detalner
Enforcement of Judgment
E Enforcement of judgment (20)
E CiV" rights (08)
Defamation (13) E C°mme’°‘a' (31)
Mlscellaneous
E Rico
Civil Complaint
E
E Frau“ (15) [j Res'dem'al (32)
E (27)
Other complaint (notspecified above) (42)
'”‘°"e°‘“a'
Professional ne
pr°Pe”Y(19>
ence 25 E
Eu
Fifi“)
c"°V 9w
E
Misceuaneous Civil Petition
‘
E Partnership and corporate governance (21)
Ii
Other non-plngNQVD tort((3;)
E Asset forfenure (05)
award E Other Petition (”0t SPECified abOVe) (43)
EEmployment
E E E Wrongfunerminatiomae)
Other employment (1 5)
E
E
Petition re: arbitration
Writofmandatewz)
Other judicial review (39)
(1 1)
3.400 of the California Rules of Court. the case is complex, mark the
N This case is is not complex under rule If
E
E
a.
b.
factors requiring exceptional judicial
Large number of separately represented parties
management:
Extensive motion practice raising difficult or novel
d.
e.
E
E Large number of witnesses
Coordination with related actions pending in one or more
courts other counties, states, or countries, or in a federal
issues that will be time—consuming to resolve in
D
EE
Court
c. Substantial amount of documentary evidence
3. Remedies sought (check a/l that apply): a.
Number of causes of action (specify): FOUR
E monetary b.
f. Substantial postjudgmentjudicial supervision
nonmonetary; declaratory or injunctive relief c4 E punitive
4.
5. E E
This case is is not a class action suit.
6‘ If there are any
Date: MARCH 24.
CHANDRA GEHRI SPENCER
known
2022
related cases, fi|e and serve a notice of related case.
) (I
(You may use
‘
form CM—015.)
Afl\
(TYPE OR PRINT NAME) (SIGNATURE OF PMY OR ATTORNEY FOR PARTY)
NOTICE
or cases filed
must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases
Plaintiff
Failure to file may result
under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.)
in sanctions.
File this cover sheet any cover sheet required by local court rule.
in addition to
sheet on all
If this case is 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover
complex under rule
other parties to the action or proceeding.
statistical purposes only.
Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for Page 1 of 2
Calv Rules ol Court. mlas 2.30, 3220, 3400—3403, 3.740:
Form Adopted for Mandatory Use
Judicial Council of California
CIVIL CASE COVER SHEET Cal. Standards 01 Judicial Adminislralion, std. 3,10
www courts cagov
CM—O10 [RevSeplember 1. 2021]
\r
INSTRUCTBNS 0N How To COMPLETE THE COVER SHEET CM-010
To Plaintiffs and Others Filing First Papers. paper (for example. a complaint) in a civil case, you must
If you are filing a first
complete and file. along with your first paper. the Civil Case Cover Sheet contained on page 1‘ This information will be used to compile
statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1. you must check
one box for the case type that best describes the case. If the case fits both a general and a more specific type of case listed in item 1.
check the more specific one. If the case has multiple causes of action. check the box that best indicates the primary cause of action.
To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 are provided below. A cover
sheet must be filed only with your initial paper. Failure to file a cover sheet with the first paper filed in a civil case may subject a party,
its counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court. .
To Parties in Rule 3.740 Collections Cases. A "conections case" under rule 3.740 is defined as an action for recovery of money owed
in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in which
property. services. or money was acquired on credit. A collections case does not include an action seeking the following: (1) tort
damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of
attachment. The identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general
time-for-service requirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections
case will be subject to the requirements for service and obtaining a judgment in rule 3.740.
To Parties in Complex Cases. In complex cases only. parties must also use the Civil Case Cover Sheet to designate whether the
case is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by
completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex. the cover sheet must be served with the
complaint on all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in the
plaintiff's designation, a counter-designation that the case is not complex, or. if the plaintiff has made no designation, a designation that
the case is complex. CASE TYPES AND EXAMPLES
Contract
Auto Tort Provisionally Complex Clvll Litigation (Cal.
Auto (22)-Personal Injury/Property Breach of Contract/Warranty (06)
Rules of Court Rules 3.400-3.403)
DamageNVrongful Death Breach of Rental/Lease Antitrust/Trade Regulation (03)
Uninsured Motorist (46) (if the Contract (not unlawful detainer
Construction Defect (10)
or wrongful eviction)
case involves an uninsured Claims Involving Mass Ton (40)
motorist claim subject to Contract/Warranty Breach—Seller Securities Litigation (28)
Plaintiff (not fraud or negligence)
arbitration, check this item Environmental/Toxic Tort (30)
Negligent Breach of Contract/
instead ofAuto) Insurance Coverage Claims
Other PI/PDNVD (Personal Injuryl Warranty (arising from provisionally complex
Property DamageIWrongful Death) Other Breach of Contract/Warranty
case type listed above) (41)
Tort Collections (e.g., money owed, open Enforcement of Judgment
Asbestos (04) book accounts) (09) Enforcement of Judgment (20)
Asbestos Property Damage Collection Case—Seller Plaintiff
Abstract of Judgment (Out of
Asbestos Personal Injuryl Other Promissory Note/Collections
County)
Wrongful Death Case Confession of Judgment (non-
Product Liability (not asbestos or Insurance Coverage (not provisionally
domestic relations)
toxic/envimnmental) (24) complex) (1 8)
Sister State Judgment
Medical Malpractice (45) Auto Subrogation
Administrative Agency Award
Medical Malpractice— Other Coverage
(no! unpaid taxes)
Physicians & Surgeons Other Contract (37)
Petition/Certification of Entty of
Other Professional Health Care Contractual Fraud
Judgment on Unpaid Taxes
Malpractice Other Contract Dispute
Other Enforcement of Judgment
Other PI/PDNVD (23) Real Propeny
Case
Premises Liability (e.g.. slip
Eminent Domain/Inverse
Miscellaneous Civil Complaint
and Condemnation (14)
fall) RICO (27)
Intentional Bodily Injury/PDNVD Wrongful Eviction (33)
Other Complaint (not specified
(e.g., assault, vandalism) Other Real Property (e.g., quiet title) (26)
above) (42)
Intentional Infliction of Writ of Possession of Real Property
Declaratory Relief Only
Emotional Distress Mongage Foreclosure Injunctive Relief Only (non-
Negligent Infliction of Quiet Title
harassment)
Emotional Distress Other Real Property (not eminent
Mechanics Lien
Other PI/PD/WD domain, Iandlord/tenant, or
Other Commercial Complaint
Non-PIIPDNVD (Other) Tort foreclosure)
Case (non-tort/non-comp/ex)
Business Tort/Unfair Business Unlawful Detalner
Other Civil Complaint
Practice (07) Commercial (31)
(non-tort/non-complex)
Civil Rights (e.g.. discrimination.
Residential (32)
Miscellaneous Civil Petition
false arrest) (not civil Drugs (38) (if the case involves illegal
Partnership and Corporate
harassment) (08) drugs, check this item; othem/ise,
Governance (21)
Defamation (e.g., slander, report as Commercial or Residenfial)
libel) Other Petition (not specified
(13)
Judicial Review
above) (43)
Fraud (16) Asset Forfeiture (05)
Civil Harassment
Property (19)
Intellectual Petition Re: Arbitration Award (1 1)
Workplace Violence
Professional Negligence (25) Writ of Mandate (02)
Elder/Dependent Adult
Legal Malpractice Writ—Administrative Mandamus Abuse
Other Professional Malpractice Writ-Mandamus on Limited Court
Election Contest
(not medical or legal) Case Matter Name Change
Petition for
Other Non-Pl/PDNVD Ton (35) Writ—Other Limited Court Case
Petition for Relief From Late
Employment Review
Claim
Wrongful Termination (36) Other Judicial Review (39)
Other Civil Petition
Other Employment (15) Review of Health Officer Order
Notice of Appeal—Labor
Commissmner Appeals
CM-010 [Rev. September 1 2021] Page 2 of 2
‘
CIVIL CASE COVER SHEET
Preview
- - v r ”Nanyi/“Vo 3‘“ AEORNEY 0R PARTY vsATHOUT ATTORNEY (Name, s~rnumben D and address): LAAxn. nil. \r LN» -~- F” “WW“ °”" it; CM-o1o CHANDRA GEHRI SPENCER (SBN 184010); ELDER a SPENCER LLP 12625 TOWNSGATE ROAD, SUITE 330, WESTLAKE VILLAGE CA 91361 u a w EETEO'PALIFORNIA ~-‘ ~ " TELEpHoNe No; (21 3) 631 -8331 FAx No. (optional): (888) 422-8027 5%%j§y’$ 59%;».N arefimARDINp vasr-u'aipmcf) UIQTRKET E.MAIL AooRess; s '..» L352 ATTORNEY FOR (Name): PLAINTIFFS DENISE CORLEY-EMERUEH ET AL MAR 24 2022 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO STREET ADDRESS: 247 THIRD AVENUE W ‘ MAiLING ADDRESS: 247 THIRD AVENUE W 3v Ark” 7&3! CITY ANDZIP CODE: SAN BERNARDINO CA 92415 macr—eAEL‘.nIE!_3:-: :2, 0531:?! BRANCH NAME: SAN BERNARDlNO - CIVIL DISTRICT CASE NAME: DENISE CORLEY-EMERUEH ET AL V GROUP XIV PROPERTlES LP ET AL - CASE CASE COVER SHEET Comp.“ Case Designation Nve A E CIVIL D E E C| gB 2 2 n B 8 2 l1 Ulllimned (Amount exceeds $25,000) LimitEd (Amount $25,000 or Iess) (9W) Counter ' Items 1—6 below must be completed (see ' Joinder - infstructions m DEPT.: on page 2). case type that best describes this case: 1. Check one box below for the Provlslonally Complex Clvi| thigation Auto Tort E E Auto (22) E Contract E Breach of comracuwarramy (06) (Cal. Rules of Court, rules 3400-3403) D regu'afim (03) Uninsured motorist(46) E Rule 3,740 collections (09) E E AntitrUSt/Trade Construction defect (10) Other PI/PDIwo (Personal InjuryIProperty Damage’wrongful 09am) Ton E E E Other collections (09) Insurance coverage (18) D Mass 1°" (40) Securities litigation (28) E E Asbestos (04) Pmduc‘ “abimy Medical malpractice (45) (24) Other contract (37) Real Property S E EnvironmentalfToxic ton (30) Insuran'ce coveralg'e claims arising from the E Other PI/PD/wo (23) E Eminent domain/lnverse condemnation (1 4) gilesegfiged prowsuonany complex case E E Non-PIIPDIWD(Other)Tort Business tort/unfair business practice (07) D Wrongfuleviction(33) Other real Property (25) unlaw‘u' Detalner Enforcement of Judgment E Enforcement of judgment (20) E CiV" rights (08) Defamation (13) E C°mme’°‘a' (31) Mlscellaneous E Rico Civil Complaint E E Frau“ (15) [j Res'dem'al (32) E (27) Other complaint (notspecified above) (42) '”‘°"e°‘“a' Professional ne pr°Pe”Y(19> ence 25 E Eu Fifi“) c"°V 9w E Misceuaneous Civil Petition ‘ E Partnership and corporate governance (21) Ii Other non-plngNQVD tort((3;) E Asset forfenure (05) award E Other Petition (”0t SPECified abOVe) (43) EEmployment E E E Wrongfunerminatiomae) Other employment (1 5) E E Petition re: arbitration Writofmandatewz) Other judicial review (39) (1 1) 3.400 of the California Rules of Court. the case is complex, mark the N This case is is not complex under rule If E E a. b. factors requiring exceptional judicial Large number of separately represented parties management: Extensive motion practice raising difficult or novel d. e. E E Large number of witnesses Coordination with related actions pending in one or more courts other counties, states, or countries, or in a federal issues that will be time—consuming to resolve in D EE Court c. Substantial amount of documentary evidence 3. Remedies sought (check a/l that apply): a. Number of causes of action (specify): FOUR E monetary b. f. Substantial postjudgmentjudicial supervision nonmonetary; declaratory or injunctive relief c4 E punitive 4. 5. E E This case is is not a class action suit. 6‘ If there are any Date: MARCH 24. CHANDRA GEHRI SPENCER known 2022 related cases, fi|e and serve a notice of related case. ) (I (You may use ‘ form CM—015.) Afl\ (TYPE OR PRINT NAME) (SIGNATURE OF PMY OR ATTORNEY FOR PARTY) NOTICE or cases filed must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases Plaintiff Failure to file may result under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) in sanctions. File this cover sheet any cover sheet required by local court rule. in addition to sheet on all If this case is 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover complex under rule other parties to the action or proceeding. statistical purposes only. Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for Page 1 of 2 Calv Rules ol Court. mlas 2.30, 3220, 3400—3403, 3.740: Form Adopted for Mandatory Use Judicial Council of California CIVIL CASE COVER SHEET Cal. Standards 01 Judicial Adminislralion, std. 3,10 www courts cagov CM—O10 [RevSeplember 1. 2021] \r INSTRUCTBNS 0N How To COMPLETE THE COVER SHEET CM-010 To Plaintiffs and Others Filing First Papers. paper (for example. a complaint) in a civil case, you must If you are filing a first complete and file. along with your first paper. the Civil Case Cover Sheet contained on page 1‘ This information will be used to compile statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1. you must check one box for the case type that best describes the case. If the case fits both a general and a more specific type of case listed in item 1. check the more specific one. If the case has multiple causes of action. check the box that best indicates the primary cause of action. To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 are provided below. A cover sheet must be filed only with your initial paper. Failure to file a cover sheet with the first paper filed in a civil case may subject a party, its counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court. . To Parties in Rule 3.740 Collections Cases. A "conections case" under rule 3.740 is defined as an action for recovery of money owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in which property. services. or money was acquired on credit. A collections case does not include an action seeking the following: (1) tort damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of attachment. The identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general time-for-service requirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections case will be subject to the requirements for service and obtaining a judgment in rule 3.740. To Parties in Complex Cases. In complex cases only. parties must also use the Civil Case Cover Sheet to designate whether the case is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex. the cover sheet must be served with the complaint on all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in the plaintiff's designation, a counter-designation that the case is not complex, or. if the plaintiff has made no designation, a designation that the case is complex. CASE TYPES AND EXAMPLES Contract Auto Tort Provisionally Complex Clvll Litigation (Cal. Auto (22)-Personal Injury/Property Breach of Contract/Warranty (06) Rules of Court Rules 3.400-3.403) DamageNVrongful Death Breach of Rental/Lease Antitrust/Trade Regulation (03) Uninsured Motorist (46) (if the Contract (not unlawful detainer Construction Defect (10) or wrongful eviction) case involves an uninsured Claims Involving Mass Ton (40) motorist claim subject to Contract/Warranty Breach—Seller Securities Litigation (28) Plaintiff (not fraud or negligence) arbitration, check this item Environmental/Toxic Tort (30) Negligent Breach of Contract/ instead ofAuto) Insurance Coverage Claims Other PI/PDNVD (Personal Injuryl Warranty (arising from provisionally complex Property DamageIWrongful Death) Other Breach of Contract/Warranty case type listed above) (41) Tort Collections (e.g., money owed, open Enforcement of Judgment Asbestos (04) book accounts) (09) Enforcement of Judgment (20) Asbestos Property Damage Collection Case—Seller Plaintiff Abstract of Judgment (Out of Asbestos Personal Injuryl Other Promissory Note/Collections County) Wrongful Death Case Confession of Judgment (non- Product Liability (not asbestos or Insurance Coverage (not provisionally domestic relations) toxic/envimnmental) (24) complex) (1 8) Sister State Judgment Medical Malpractice (45) Auto Subrogation Administrative Agency Award Medical Malpractice— Other Coverage (no! unpaid taxes) Physicians & Surgeons Other Contract (37) Petition/Certification of Entty of Other Professional Health Care Contractual Fraud Judgment on Unpaid Taxes Malpractice Other Contract Dispute Other Enforcement of Judgment Other PI/PDNVD (23) Real Propeny Case Premises Liability (e.g.. slip Eminent Domain/Inverse Miscellaneous Civil Complaint and Condemnation (14) fall) RICO (27) Intentional Bodily Injury/PDNVD Wrongful Eviction (33) Other Complaint (not specified (e.g., assault, vandalism) Other Real Property (e.g., quiet title) (26) above) (42) Intentional Infliction of Writ of Possession of Real Property Declaratory Relief Only Emotional Distress Mongage Foreclosure Injunctive Relief Only (non- Negligent Infliction of Quiet Title harassment) Emotional Distress Other Real Property (not eminent Mechanics Lien Other PI/PD/WD domain, Iandlord/tenant, or Other Commercial Complaint Non-PIIPDNVD (Other) Tort foreclosure) Case (non-tort/non-comp/ex) Business Tort/Unfair Business Unlawful Detalner Other Civil Complaint Practice (07) Commercial (31) (non-tort/non-complex) Civil Rights (e.g.. discrimination. Residential (32) Miscellaneous Civil Petition false arrest) (not civil Drugs (38) (if the case involves illegal Partnership and Corporate harassment) (08) drugs, check this item; othem/ise, Governance (21) Defamation (e.g., slander, report as Commercial or Residenfial) libel) Other Petition (not specified (13) Judicial Review above) (43) Fraud (16) Asset Forfeiture (05) Civil Harassment Property (19) Intellectual Petition Re: Arbitration Award (1 1) Workplace Violence Professional Negligence (25) Writ of Mandate (02) Elder/Dependent Adult Legal Malpractice Writ—Administrative Mandamus Abuse Other Professional Malpractice Writ-Mandamus on Limited Court Election Contest (not medical or legal) Case Matter Name Change Petition for Other Non-Pl/PDNVD Ton (35) Writ—Other Limited Court Case Petition for Relief From Late Employment Review Claim Wrongful Termination (36) Other Judicial Review (39) Other Civil Petition Other Employment (15) Review of Health Officer Order Notice of Appeal—Labor Commissmner Appeals CM-010 [Rev. September 1 2021] Page 2 of 2 ‘ CIVIL CASE COVER SHEET