Preview
1 THE MORRISON LAW GROUP
A Professional Corporation
2 Edward F. Morrison, Jr. (State Bar No. 149495)
Larry A. Schwartz (State Bar No. 202038)
3 77530 Enfield Lane, Suite H-1
Palm Desert, California 92211
4 Telephone: (760) 978-6200
Facsimile: (760) 904-0987
5 Email: morrison@morrisonlawgroup.com
schwartz@morrisonlawgroup.com
6
Attorneys for Del Terra Real Estate Services, Inc.
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
COUNTY OF SAN MATEO UNLIMITED JURISDICTION
9
ALUM ROCK UNION ELEMENTARY CASE NO. 20-CIV-02466
10 SCHOOL DISTRICT,
Assigned to the Hon. Danny Y. Chou
.,"11 Plaintiff, Dept. K
""~
0
0"'
12 vs. STIPULATION OF PLAINTIFF ALUM
"'
~ ROCK UNION ELEMENT ARY SCHOOL
w
J
~ 13 DEL TERRA REAL ESTATE SERVICES, DISTRICT AND DEFENDANT DEL
iii
u
INC. dba DEL TERRA GROUP, a California TERRA REAL ESTATE SERVICES, INC.
.
~
0
14 corporation; and DOES 1 through 10, RE ORDER TO PERMIT DEL TERRA
0
N
.,'f
REAL ESTATE SERVICES, INC. TO
"0"'
15 Defendants . FILE A CROSS-COMPLAINT AGAINST
"'
~
BRCO CONSTRUCTORS, INC., AND
w
z
16 DEL TERRA REAL ESTATE SERVICES, FAST-TRACK CONSTRUCTION
a
:,:
Q.
INC. dba DEL TERRA GROUP, a California CORPORATION; [PROPOSED] ORDER
~ 17 corporation; and DOES 1 through 10, THEREON
>--
18 Cross-Complainant Action Filed: August 29, 2019
Trial Date: April 10, 2023
19 vs.
20 BRCO CONSTRUCTORS, INC., a California
corporation, FAST-TRACK
21 CONSTRUCTION CORPORATION, a
California corporation, and ROES 1 through
22 100,
23 Cross-Defendants
24
25 TO THE HON. DANNY Y. CHOU, THE PARTIES, AND THEIR COUNSEL OF RECORD:
26 WHEREAS, this lawsuit concerns disputes involving the ALUM ROCK UNION
27 ELEMENTARY SCHOOL DISTRICT ("DISTRICT") and DEL TERRA REAL ESTATE
28
---------------~1~------------------,-
STIPULATION RE STIPULATION AND ORDER TO ALLOW DEL TERRA TO FILE CROSS-COMPLAINT
AGAINST BRCO CONSTRUCTORS AND FAST-TRACK CONSTRUCTION
October 27, 2022
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF RIVERSIDE
3 At the time of service, I was over 18 years of age and not a party to this action. I am
employed in the County of Riverside, State of California. My business address is 77530 Enfield
4 Lane, Suite H-1, Palm Desert, CA 92211.
5 On October 27, 2022, I served true copies of the following document(s) described as
STIPULATION OF ALUM ROCK UNION ELEMENTARY SCHOOL DISTRICT AND
6 DEL TERRA REAL ESTATE SERVICES, INC., IN REGARD TO A STIPULATION AND
ORDER TO PERMIT DEL TERRA REAL ESTATE SERVICES, INC., TO FILE A
7 CROSS-COMPLAINT AGAINST BRCO CONSTRUCTORS, INC., AND FAST-TRACK
CONSTRUCTION CORPORATION on the interested parties in this action as follows:
9 Peter M. Rehon, Esq.
Rogelio M. Ruiz, Esq
10 Steven Wheat, Esq.
Nancy Wong
11 REHON & ROBERTS, APC
830 The Alameda,
12 San Jose, CA 95126
Email: rruiz@rehonroberts.com
13 Email: prehon@rehonroberts.com
Email: swheat@rehonroberts.com
14 Email: nwong@rehonroberts.com
15 Attorneys for Alum Rock Union Elementary
School District
16
BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
17 document(s) to be sent from e-mail address aldwin@morrisonlawgroup.com to the persons at the
e-mail addresses listed in the Service List. I did not receive, within a reasonable time after the
18 transmission, any electronic message or other indication that the transmission was unsuccessful.
19 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
20
Executed on October 27, 2022, at Palm Desert, California.
21
22
ls/Aldwin Hernandez
23 Aldwin Hernandez
24
25
26
27
28
1
PROOF OF SERVICE
Preview
1 THE MORRISON LAW GROUP A Professional Corporation 2 Edward F. Morrison, Jr. (State Bar No. 149495) Larry A. Schwartz (State Bar No. 202038) 3 77530 Enfield Lane, Suite H-1 Palm Desert, California 92211 4 Telephone: (760) 978-6200 Facsimile: (760) 904-0987 5 Email: morrison@morrisonlawgroup.com schwartz@morrisonlawgroup.com 6 Attorneys for Del Terra Real Estate Services, Inc. 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF SAN MATEO UNLIMITED JURISDICTION 9 ALUM ROCK UNION ELEMENTARY CASE NO. 20-CIV-02466 10 SCHOOL DISTRICT, Assigned to the Hon. Danny Y. Chou .,"11 Plaintiff, Dept. K ""~ 0 0"' 12 vs. STIPULATION OF PLAINTIFF ALUM "' ~ ROCK UNION ELEMENT ARY SCHOOL w J ~ 13 DEL TERRA REAL ESTATE SERVICES, DISTRICT AND DEFENDANT DEL iii u INC. dba DEL TERRA GROUP, a California TERRA REAL ESTATE SERVICES, INC. . ~ 0 14 corporation; and DOES 1 through 10, RE ORDER TO PERMIT DEL TERRA 0 N .,'f REAL ESTATE SERVICES, INC. TO "0"' 15 Defendants . FILE A CROSS-COMPLAINT AGAINST "' ~ BRCO CONSTRUCTORS, INC., AND w z 16 DEL TERRA REAL ESTATE SERVICES, FAST-TRACK CONSTRUCTION a :,: Q. INC. dba DEL TERRA GROUP, a California CORPORATION; [PROPOSED] ORDER ~ 17 corporation; and DOES 1 through 10, THEREON >-- 18 Cross-Complainant Action Filed: August 29, 2019 Trial Date: April 10, 2023 19 vs. 20 BRCO CONSTRUCTORS, INC., a California corporation, FAST-TRACK 21 CONSTRUCTION CORPORATION, a California corporation, and ROES 1 through 22 100, 23 Cross-Defendants 24 25 TO THE HON. DANNY Y. CHOU, THE PARTIES, AND THEIR COUNSEL OF RECORD: 26 WHEREAS, this lawsuit concerns disputes involving the ALUM ROCK UNION 27 ELEMENTARY SCHOOL DISTRICT ("DISTRICT") and DEL TERRA REAL ESTATE 28 ---------------~1~------------------,- STIPULATION RE STIPULATION AND ORDER TO ALLOW DEL TERRA TO FILE CROSS-COMPLAINT AGAINST BRCO CONSTRUCTORS AND FAST-TRACK CONSTRUCTION October 27, 2022 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF RIVERSIDE 3 At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of Riverside, State of California. My business address is 77530 Enfield 4 Lane, Suite H-1, Palm Desert, CA 92211. 5 On October 27, 2022, I served true copies of the following document(s) described as STIPULATION OF ALUM ROCK UNION ELEMENTARY SCHOOL DISTRICT AND 6 DEL TERRA REAL ESTATE SERVICES, INC., IN REGARD TO A STIPULATION AND ORDER TO PERMIT DEL TERRA REAL ESTATE SERVICES, INC., TO FILE A 7 CROSS-COMPLAINT AGAINST BRCO CONSTRUCTORS, INC., AND FAST-TRACK CONSTRUCTION CORPORATION on the interested parties in this action as follows: 9 Peter M. Rehon, Esq. Rogelio M. Ruiz, Esq 10 Steven Wheat, Esq. Nancy Wong 11 REHON & ROBERTS, APC 830 The Alameda, 12 San Jose, CA 95126 Email: rruiz@rehonroberts.com 13 Email: prehon@rehonroberts.com Email: swheat@rehonroberts.com 14 Email: nwong@rehonroberts.com 15 Attorneys for Alum Rock Union Elementary School District 16 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the 17 document(s) to be sent from e-mail address aldwin@morrisonlawgroup.com to the persons at the e-mail addresses listed in the Service List. I did not receive, within a reasonable time after the 18 transmission, any electronic message or other indication that the transmission was unsuccessful. 19 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 20 Executed on October 27, 2022, at Palm Desert, California. 21 22 ls/Aldwin Hernandez 23 Aldwin Hernandez 24 25 26 27 28 1 PROOF OF SERVICE