On August 08, 2008 a
Order to Show Cause
was filed
involving a dispute between
Beacon Residential Community Association,
Catellus Commericial Development Corp.,
Catellus Development Corporation,
Catellus Operating Limited Partnership,
Catellus Residential Construction, Inc.,
Catellus Third And King Investors Llc,
Catellus Third And King Llc,
Catellus Urban Development Corporation,
Catellus Urban Development Group, Llc, A Delaware,
Centurion Real Estate Investors Iv,Llc,
Centurion Real Estate Partners, Llc,
Mission Place Llc,
Mission Place Mezzanine Llc,
Mission Place Mezz Holdings Llc,
Mission Place Partners Llc,
Prologis,
Shooter & Butts, Inc.,
Third And King Investors Llc,
Third And King Investors, Llc, A Delaware Limited,
Thyssenkrupp Elevator Corporation (Erroneously,
Webcor Builders,Inc,
Webcor Construction Inc.,
Webcor Construction, Inc Dba Webcor Builders,
Window Solutions, Inc.,
and
All Defendants See Scanned Documents,
Allied Fire Protection,
Anning-Johnson Company,
Architectural Glass & Aluminum Co., Inc,
Blue'S Roofing Company,
Carefree Toland Pools, Inc.,
Catellus Commerical Development Corporation,
Catellus Commericial Development Corp.,
Catellus Development Corporation,
Catellus Operating Limited Partnership,
Catellus Residential Construction, Inc.,
Catellus Third And King Investors Llc,
Catellus Third And King Llc,
Catellus Urban Development Corporation,
Catellus Urban Development Group, Llc, A Delaware,
Catellus Urban Development, Llc,
Centurion Partners, Llc,
Centurion Real Estate Investors Iv,Llc,
Centurion Real Estate Partners, Llc,
Creative Masonry, Inc,
Critchfield Mechanical, Inc.,
Cupertino Electric,Inc.,
Does 1 Through 200,
Does 52-200, Inclusive,
F. Rodgers Corporation,
F. Rodgers Corporation (Fka F. Rodgers Insulation,
F. Rodgers Insulation Residential, Inc.,
Hks Architects, Inc,
Hks, Inc,
Hks, Inc Individually And Dba Hks Architects, Inc,
J.W. Mcclenahan Co.,
Mission Place Llc,
Mission Place Mezzanine Llc,
Mission Place Mezz Holdings Llc,
Mission Place Partners Llc,
N.V. Heathorn, Inc.,
Poma Corporation,
Prologis,
Roofing Constructors, Inc. Dba Western,
Shooter & Butts, Inc.,
Skidmore Owings & Merrill Llp,
Skimore Owings & Merrill Llp,
Third And King Investors Llc,
Thyssen Krupp Elevator Corporation,
Thyssenkrupp Elevator Corporation (Erroneously,
Thyssenkrupp Elevators Corporation,
Tractel Inc.,
Van-Mulder Sheet Metal, Inc.,
Webcor Builders,Inc,
Webcor Construction Inc.,
Webcor Construction, Inc,
Webcor Construction, Inc Dba Webcor Builders,
Webcor Construction Inc.,Individually And Doing,
Webcor Construction Lp Individually And Dba Webcor,
Webcor Construction Partners Llc,
West Coast Protective Coatings, Inc.,
Western Roofing Service,
Window Solutions, Dba Window Solutions, Inc.,
Window Solutions, Inc.,
for CONSTRUCTION
in the District Court of San Francisco County.
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Christian P. Lucia (SBN 203567)
Brent F, Basilico (SBN 197159)
SELLAR HAZARD & LUCIA
A Professional Law Corporation
1800 Sutter Street, Suite 460
Concord, CA 94520
Telephone: (925) 938-1430
Facsimile: (925) 256-7508
Email: clucia@sellarlaw.com; bbasilico@sellarlaw.com
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
DEC 11 2014
Clerk of the Court
BY: MAURA RAMIREZ
Deputy Clerk
Attorneys for Defendants/Cross-Defendants/Cross-Complainants Cupertino Electric, Inc.; Creative
Masonry, Inc.; Carefree Toland Pools, Inc.; J.W. McClenahan, Inc.; Van-Mulder Sheet Metal, Inc.;
N.V. Heathorn, Inc.; Critchfield Mechanical, Inc.; Blue's Roofing Company; West Coast Protective
Coatings; Allied Fire Protection; F. Rodgers Corporation; Western Roofing Service
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
BEACON RESIDENTIAL COMMUNITY
ASSOCIATION
Plaintiff,
v.
CATELLUS THIRD AND KING, LLC, et al.
Defendants.
AND ALL RELATED CROSS-ACTIONS.
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Case No.: CGC08-478453
REQUEST FOR JUDICIAL NOTICE IN
SUPPORT OF JOINT ORDER TO SHOW
CAUSE HEARING STATEMENT
SUBMITTED BY CERTAIN DEFENDANTS,
CROSS-DEFENDANTS, CROSS-
COMPLAINANTS REGARDING
APPLICATION OF THE OCTOBER 1, 2014,
ORDER TO OTHER PARTIES
FOLLOWING HEARING ON SKIDMORE,
OWINGS, AND MERRILL, LLP’S,
MOTION TO STRIKE PORTIONS OF
PLAINTIFF’S THIRD AMENDED
COMPLAINT
Documents Served and Filed Herewith
1. Declaration of Brent F. Basilico
2. Joint Order to Show Cause Hearing
Statement
Hearing Date: December 18, 2014
Hearing Time: 4:00 p.m.
Department: 304
Judge: Honorable Curtis Karnow
REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT
115330
Case No, CGC08-478453oO YN DH BRB Ww BH
how NM RRM ee ~ es o4
A & oO 8 &£§ SF Fe TDAaARESBR ES
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28
L INTRODUCTION AND STATEMENT OF PERTINENT FACTS
Pursuant to California Evidence Code §§ 351, 451, 452, and 453, Defendants, Cross-
Defendants, and Cross-Complainants Webcor Construction, Inc., Webcor Builders, Inc., Webcor
Construction, Inc., dba Webcor Builders on its own behalf and erroneously sued as Webcor
Construction, LP, dba Webcor Builders (collectively “Webcor”); Catellus Third and King LLC,
Catellus Development Corporation, Catellus Commercial Development Corp., Catellus Operating
Limited Partnership, Catellus Urban Development Corporation, Third and King Investors LLC, and
Prologis (collectively “Catellus”); Cupertino Electric, Inc., Creative Masonry, Inc., Carefree Toland
Pools, Inc., J.W. Mcclenahan, Inc., Van-Mulder Sheet Metal, Inc., Critchfield Mechanical, Inc., Blue’s
Roofing Company, Allied Fire Protection, Western Roofing Service, N.V. Heathorn, Inc., West Coast
Protective Coatings, F. Rodgers Corporation, Anning-Johnson Co., Shooter & Butts, Inc., and
Architectural Glass and Aluminum, Inc. (collectively “Subcontractor Defendants”); submit their
request for judicial notice in support of their joint order to show cause statement, and respectfully
request that the above captioned Court’s order of October 1, 2014, which granted the motion to strike
portions of Plaintiff Beacon Residential Community Association's (“Plaintiff” or “Beacon”) third
amended complaint (“TAC”) brought by Skidmore, Owings, and Merrill, LLP (“SOM”), and joined by
HKS, Inc. (“HKS”), will also apply to Webcor, Catellus, and the Subcontractor Defendants as if said
parties had been moving parties with SOM.
Webcor, Catellus, and the Subcontractor Defendants request that the Court take judicial notice
of the documents described below.
A. Plaintiff's TAC which is attached to the declaration of Brent F, Basilico as Exhibit “A” for
identification purposes only. Webcor, Catellus, and the Subcontractor Defendants request
that the Court only take judicial notice of the existence of Plaintiff's TAC.
B. SOM’s amended notice of renewed motion to strike portions of Plaintiff's TAC which is
attached to the declaration of Brent F. Basilico as Exhibit “B”.
C. The Court’s order of October 1, 2014 which is attached to the declaration of Brent F.
Basilico as Exhibit “C”.
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REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT
115330 Case No, CGC08-478453co PI HAH BW Ny Le
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ei’ acr re SSRS SETI RRESR oe
D. The Court’s order of November 10, 2014 which is attached to the declaration of Brent F.
Basilico as Exhibit “D”.
E. The Court's order of March 22, 2013, which is attached to the declaration of Brent F.
Basilico as Exhibit “E”,
5
ARGUMENT AND LEGAL AUTHORITY
The Court may take judicial notice of the matters described below.
© Official acts of the legislative, executive, and judicial departments of the United States
and of any state of the United States.
¢ Records of the following: (1) any court of the State of California; or (2) any court of
record of the United States or of any state of the United States.
© Facts and propositions that are not reasonably subject to dispute and are capable of
immediate and accurate determination by resort to sources of reasonably indisputable
oouracy.
California Evidence Code §§ 452(c), (d), (h).
Plaintiff's TAC, SOM’s amended notice of renewed motion to strike portions of Plaintiff's
TAC, and the Court’s orders of October 1, 2014, November 10, 2014, and March 22, 2013, are
contained in the Court’s file in the above captioned matter. The orders of October 1, 2014, November
10, 2014, and March 22, 2013 were all issued by the Superior Court in the above captioned matter.
Accordingly, the foregoing documents are properly subject to judiciat notice.
Dated: MF?
By:
ROPERS, MAJESKI, KOHN &
BENTLEY LLP
nT
John A. Koeppel
Kathleen Strickland
Attorneys for Defendants, Cross-Defendants,
Cross-Complainants Catellus Development
Corporation; Catellus Commercial Development
Corporation; Catellus Urban Development
Corporation; Catellus Operating Limited
Partnership; Catellus Urban Development Group,
LLC, Catellus Third and King LLC; and Third and
King Investors, LLC; ProLogis
-36
,
REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO.SHOW CAUSE HEARING STATEMENT
115330
Case No. CGC08-478453come Na Dw em wD BD
Bb NY NM YH NHN Bw BD —
So FE SE Se eT RR EER Ss
pars, 12/11
Dated:
Dated:
“
ut
Mt
By:
WOOD, SMITH, HENNING &
BERMAN LLP
-
David S. Webster
Mark J, D’Argenio
Attomeys for Defendants, Cross-Defendants,
Cross-Complainants Catellus Development
Corporation; Catellus Commercial Development
Corporation; Catellus Urban Development
Corporation; Catellus Operating Limited
Partnership; Catellus Urban Development Group,
LLC, Catellus Third and King LLC; and Third and
King Investors, LLC; ProLogis
GORDON & REES, LLP
By:
Sandy Kaplan.
Gregory Hanson
Attorneys for Defendants, Cross-Defendants,
Cross-Complainants Webcor Construction, Inc.,
dba Webcor Builders; Webcor Builders, Inc.;
Webcor Construction, LP
COLLINS COLLINS MUIR + STEWART
LLP
By:
Samuel Muir
Erin Dunkerly
Attomeys for Defendants, Cross-Defendants,
Cross-Complainants Webcor Construction, Inc.,
dba Webcor Builders; Webcor Builders, Inc.;
Webcor Construction, LP
~4-
REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT
115330
Case No, CGC08-478453Cc em TNA eR eH we
PR &® MP RNY DB oe
SUT VMF FH FPS FSeRFAURTEESH AS
Dated:
Dated:_ (> //
By:
WOOD, SMITH, HENNING &
BERMAN LLP
David S. Webster
Mark J. D’Argenio
Attorneys for Defendants, Cross-Defendants,
Cross-Complainants Catellus Development
Corporation; Catellus Commercial Development
Corporation; Caiellus Urban Development
Corporation; Catellus Operating Limited
Partnership; Catellus Urban Development Group,
LLC, Catellus Third and King LLC; and Third and
King Investors, LLC; ProLogis
By:
Gross-Complainants Webcor Construction, Inc.,
dba Webcor Builders; Webcor Builders, Inc.;
Webcor Construction, LP
COLLINS COLLINS MUIR + STEWART
LLP
wee FZ. ale
Samuel Muir
Erin Dunkerly
Attomeys for Defendants, Cross-Defendants,
Cross-Complainants Webcor Construction, Inc.,
dba Webcor Builders; Webcor Builders, Inc.;
Webcor Construction, LP
~4-
REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT
115330
Case No. CGC08-4784531 || Dated: KDEY/// DoF
Dated:
Dated:
Dated: ese / i /ZESY
By:
By:
By:
By:
SELLAR HAZARD & LUCIA
ee
Christian P. Lucia
Brent F. Basilico
Attorneys for Defendants, Cross-Defendants,
Cross-Complainants Cupertino Electric, Inc.;
Creative Masonry, Inc.; Carefree Toland Pools,
Inc.; J.W. McClenahan, Inc.; N.V. Heathorn, Inc.;
Critchfield Mechanical, Inc.; West Coast
Protective Coating, Inc.; Blue’s Roofing
Company; Van-Mulder Sheet Metal, Inc., F.
Rogers Corporation; Roofing Constructors, Inc.,
dba Western Roofing Service
ARCHER NORRIS
William H. Staples
Attorneys for Defendants, Cross-Defendants,
Cross-Complainants Anning Johnson Company
LYNCH, GILARDI & GRUMMER
Randel Campbell
Attorneys for Defendants, Cross-Defendants,
Cross-Complainants Architectural Glass and
Aluminum Co., Inc.
BLEDSOE, CATHCART, DIESTEL,
PEDERSON & TREPPA, LLP
oF 2
Steven McDonald
Attorneys for Defendants, Cross-Defendants,
Cross-Complainants Shooter & Butts, Inc.
(2
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REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT
115330
Case No. CGC08-478453Dated:
Dated:
Dated:
Dated:
By:
By:
By:
By:
SELLAR HAZARD & LUCIA
Christian P. Lucia
Brent F. Basilico
Attorneys for Defendants, Cross-Defendants,
Cross-Complainants Cupertino Electric, Inc.;
Creative Masonry, Inc.; Carefree Toland Pools,
Inc.; J.W. McClenahan, Inc.; N.V. Heathorn, Inc.;
Critchfield Mechanical, Inc.; West Coast
Protective Coating, Inc.; Blue’s Roofing
Company; Van-Mulder Sheet Metal, Inc., F.
Rogers Corporation; Roofing Constructors, Inc.,
dba Western Roofing Service
ARCHER NORRIS
S
Attorneys for Defendants, Cross-Defendants,
Cross-Complainants Anning Johnson Company
LYNCH, GILARDI & GRUMMER
Randel Campbell
Attorneys for Defendants, Cross-Defendants,
Cross-Complainants Architectural Glass and
Aluminum Co., Inc.
BLEDSOE, CATHCART, DIESTEL,
PEDERSON & TREPPA, LLP
Steven McDonald
Attorneys for Defendants, Cross-Defendants,
Cross-Complainants Shooter & Butts, Inc.
-7-
REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT
115330
Case No. CGC08-478453Dated:
Dated:
Dated:
115330
By:
By:
By:
By;
SELLAR HAZARD & LUCIA.
Christian P, Lucia
Brent F. Basilico
Attomeys for Defendants, Cross-Defendants,
Cross-Complainants Cupertino Electric, Inc.;
Creative Masonry, Inc.; Carefree Toland Poots,
Inc,; J.W. McClenahan, Inc.; N.V. Heathorn, Inc.;
Critchfield Mechanical, Inc.; West Coast
Protective Coating, Inc.; Blue’s Roofing
Company; Van-Mulder Sheet Metal, Inc., F.
Rogers Corporation; Roofing Constructors, Inc.,
dba Western Roofing Service
ARCHER NORRIS
William H. Staples
Attomeys for Defendants, Cross-Defendants,
Cross-Complainants Anning Johnson Company
LYNCH, GILARDI & GRUMMER
Attorneys fot Defendants, Cross-Defendants,
Cross-Complainants Architectural Glass and
Aluminum Co., Inc.
BLEDSOE, CATHCART, DIESTEL,
PEDERSON & TREPPA, LLP
Steven McDonald
Attomeys for Defendants, Cross-Defendants,
Cross-Complainants Shooter & Butts, Inc,
-5e
REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT
Case No, CGC08-478453
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wn Co Oe ND 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Christian P. Lucia (SBN 203567) Brent F, Basilico (SBN 197159) SELLAR HAZARD & LUCIA A Professional Law Corporation 1800 Sutter Street, Suite 460 Concord, CA 94520 Telephone: (925) 938-1430 Facsimile: (925) 256-7508 Email: clucia@sellarlaw.com; bbasilico@sellarlaw.com ELECTRONICALLY FILED Superior Court of California, County of San Francisco DEC 11 2014 Clerk of the Court BY: MAURA RAMIREZ Deputy Clerk Attorneys for Defendants/Cross-Defendants/Cross-Complainants Cupertino Electric, Inc.; Creative Masonry, Inc.; Carefree Toland Pools, Inc.; J.W. McClenahan, Inc.; Van-Mulder Sheet Metal, Inc.; N.V. Heathorn, Inc.; Critchfield Mechanical, Inc.; Blue's Roofing Company; West Coast Protective Coatings; Allied Fire Protection; F. Rodgers Corporation; Western Roofing Service SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO BEACON RESIDENTIAL COMMUNITY ASSOCIATION Plaintiff, v. CATELLUS THIRD AND KING, LLC, et al. Defendants. AND ALL RELATED CROSS-ACTIONS. -1- Case No.: CGC08-478453 REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT SUBMITTED BY CERTAIN DEFENDANTS, CROSS-DEFENDANTS, CROSS- COMPLAINANTS REGARDING APPLICATION OF THE OCTOBER 1, 2014, ORDER TO OTHER PARTIES FOLLOWING HEARING ON SKIDMORE, OWINGS, AND MERRILL, LLP’S, MOTION TO STRIKE PORTIONS OF PLAINTIFF’S THIRD AMENDED COMPLAINT Documents Served and Filed Herewith 1. Declaration of Brent F. Basilico 2. Joint Order to Show Cause Hearing Statement Hearing Date: December 18, 2014 Hearing Time: 4:00 p.m. Department: 304 Judge: Honorable Curtis Karnow REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT 115330 Case No, CGC08-478453oO YN DH BRB Ww BH how NM RRM ee ~ es o4 A & oO 8 &£§ SF Fe TDAaARESBR ES 26 27 28 L INTRODUCTION AND STATEMENT OF PERTINENT FACTS Pursuant to California Evidence Code §§ 351, 451, 452, and 453, Defendants, Cross- Defendants, and Cross-Complainants Webcor Construction, Inc., Webcor Builders, Inc., Webcor Construction, Inc., dba Webcor Builders on its own behalf and erroneously sued as Webcor Construction, LP, dba Webcor Builders (collectively “Webcor”); Catellus Third and King LLC, Catellus Development Corporation, Catellus Commercial Development Corp., Catellus Operating Limited Partnership, Catellus Urban Development Corporation, Third and King Investors LLC, and Prologis (collectively “Catellus”); Cupertino Electric, Inc., Creative Masonry, Inc., Carefree Toland Pools, Inc., J.W. Mcclenahan, Inc., Van-Mulder Sheet Metal, Inc., Critchfield Mechanical, Inc., Blue’s Roofing Company, Allied Fire Protection, Western Roofing Service, N.V. Heathorn, Inc., West Coast Protective Coatings, F. Rodgers Corporation, Anning-Johnson Co., Shooter & Butts, Inc., and Architectural Glass and Aluminum, Inc. (collectively “Subcontractor Defendants”); submit their request for judicial notice in support of their joint order to show cause statement, and respectfully request that the above captioned Court’s order of October 1, 2014, which granted the motion to strike portions of Plaintiff Beacon Residential Community Association's (“Plaintiff” or “Beacon”) third amended complaint (“TAC”) brought by Skidmore, Owings, and Merrill, LLP (“SOM”), and joined by HKS, Inc. (“HKS”), will also apply to Webcor, Catellus, and the Subcontractor Defendants as if said parties had been moving parties with SOM. Webcor, Catellus, and the Subcontractor Defendants request that the Court take judicial notice of the documents described below. A. Plaintiff's TAC which is attached to the declaration of Brent F, Basilico as Exhibit “A” for identification purposes only. Webcor, Catellus, and the Subcontractor Defendants request that the Court only take judicial notice of the existence of Plaintiff's TAC. B. SOM’s amended notice of renewed motion to strike portions of Plaintiff's TAC which is attached to the declaration of Brent F. Basilico as Exhibit “B”. C. The Court’s order of October 1, 2014 which is attached to the declaration of Brent F. Basilico as Exhibit “C”. -2- REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT 115330 Case No, CGC08-478453co PI HAH BW Ny Le ven yw LV = ei’ acr re SSRS SETI RRESR oe D. The Court’s order of November 10, 2014 which is attached to the declaration of Brent F. Basilico as Exhibit “D”. E. The Court's order of March 22, 2013, which is attached to the declaration of Brent F. Basilico as Exhibit “E”, 5 ARGUMENT AND LEGAL AUTHORITY The Court may take judicial notice of the matters described below. © Official acts of the legislative, executive, and judicial departments of the United States and of any state of the United States. ¢ Records of the following: (1) any court of the State of California; or (2) any court of record of the United States or of any state of the United States. © Facts and propositions that are not reasonably subject to dispute and are capable of immediate and accurate determination by resort to sources of reasonably indisputable oouracy. California Evidence Code §§ 452(c), (d), (h). Plaintiff's TAC, SOM’s amended notice of renewed motion to strike portions of Plaintiff's TAC, and the Court’s orders of October 1, 2014, November 10, 2014, and March 22, 2013, are contained in the Court’s file in the above captioned matter. The orders of October 1, 2014, November 10, 2014, and March 22, 2013 were all issued by the Superior Court in the above captioned matter. Accordingly, the foregoing documents are properly subject to judiciat notice. Dated: MF? By: ROPERS, MAJESKI, KOHN & BENTLEY LLP nT John A. Koeppel Kathleen Strickland Attorneys for Defendants, Cross-Defendants, Cross-Complainants Catellus Development Corporation; Catellus Commercial Development Corporation; Catellus Urban Development Corporation; Catellus Operating Limited Partnership; Catellus Urban Development Group, LLC, Catellus Third and King LLC; and Third and King Investors, LLC; ProLogis -36 , REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO.SHOW CAUSE HEARING STATEMENT 115330 Case No. CGC08-478453come Na Dw em wD BD Bb NY NM YH NHN Bw BD — So FE SE Se eT RR EER Ss pars, 12/11 Dated: Dated: “ ut Mt By: WOOD, SMITH, HENNING & BERMAN LLP - David S. Webster Mark J, D’Argenio Attomeys for Defendants, Cross-Defendants, Cross-Complainants Catellus Development Corporation; Catellus Commercial Development Corporation; Catellus Urban Development Corporation; Catellus Operating Limited Partnership; Catellus Urban Development Group, LLC, Catellus Third and King LLC; and Third and King Investors, LLC; ProLogis GORDON & REES, LLP By: Sandy Kaplan. Gregory Hanson Attorneys for Defendants, Cross-Defendants, Cross-Complainants Webcor Construction, Inc., dba Webcor Builders; Webcor Builders, Inc.; Webcor Construction, LP COLLINS COLLINS MUIR + STEWART LLP By: Samuel Muir Erin Dunkerly Attomeys for Defendants, Cross-Defendants, Cross-Complainants Webcor Construction, Inc., dba Webcor Builders; Webcor Builders, Inc.; Webcor Construction, LP ~4- REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT 115330 Case No, CGC08-478453Cc em TNA eR eH we PR &® MP RNY DB oe SUT VMF FH FPS FSeRFAURTEESH AS Dated: Dated:_ (> // By: WOOD, SMITH, HENNING & BERMAN LLP David S. Webster Mark J. D’Argenio Attorneys for Defendants, Cross-Defendants, Cross-Complainants Catellus Development Corporation; Catellus Commercial Development Corporation; Caiellus Urban Development Corporation; Catellus Operating Limited Partnership; Catellus Urban Development Group, LLC, Catellus Third and King LLC; and Third and King Investors, LLC; ProLogis By: Gross-Complainants Webcor Construction, Inc., dba Webcor Builders; Webcor Builders, Inc.; Webcor Construction, LP COLLINS COLLINS MUIR + STEWART LLP wee FZ. ale Samuel Muir Erin Dunkerly Attomeys for Defendants, Cross-Defendants, Cross-Complainants Webcor Construction, Inc., dba Webcor Builders; Webcor Builders, Inc.; Webcor Construction, LP ~4- REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT 115330 Case No. CGC08-4784531 || Dated: KDEY/// DoF Dated: Dated: Dated: ese / i /ZESY By: By: By: By: SELLAR HAZARD & LUCIA ee Christian P. Lucia Brent F. Basilico Attorneys for Defendants, Cross-Defendants, Cross-Complainants Cupertino Electric, Inc.; Creative Masonry, Inc.; Carefree Toland Pools, Inc.; J.W. McClenahan, Inc.; N.V. Heathorn, Inc.; Critchfield Mechanical, Inc.; West Coast Protective Coating, Inc.; Blue’s Roofing Company; Van-Mulder Sheet Metal, Inc., F. Rogers Corporation; Roofing Constructors, Inc., dba Western Roofing Service ARCHER NORRIS William H. Staples Attorneys for Defendants, Cross-Defendants, Cross-Complainants Anning Johnson Company LYNCH, GILARDI & GRUMMER Randel Campbell Attorneys for Defendants, Cross-Defendants, Cross-Complainants Architectural Glass and Aluminum Co., Inc. BLEDSOE, CATHCART, DIESTEL, PEDERSON & TREPPA, LLP oF 2 Steven McDonald Attorneys for Defendants, Cross-Defendants, Cross-Complainants Shooter & Butts, Inc. (2 -5- REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT 115330 Case No. CGC08-478453Dated: Dated: Dated: Dated: By: By: By: By: SELLAR HAZARD & LUCIA Christian P. Lucia Brent F. Basilico Attorneys for Defendants, Cross-Defendants, Cross-Complainants Cupertino Electric, Inc.; Creative Masonry, Inc.; Carefree Toland Pools, Inc.; J.W. McClenahan, Inc.; N.V. Heathorn, Inc.; Critchfield Mechanical, Inc.; West Coast Protective Coating, Inc.; Blue’s Roofing Company; Van-Mulder Sheet Metal, Inc., F. Rogers Corporation; Roofing Constructors, Inc., dba Western Roofing Service ARCHER NORRIS S Attorneys for Defendants, Cross-Defendants, Cross-Complainants Anning Johnson Company LYNCH, GILARDI & GRUMMER Randel Campbell Attorneys for Defendants, Cross-Defendants, Cross-Complainants Architectural Glass and Aluminum Co., Inc. BLEDSOE, CATHCART, DIESTEL, PEDERSON & TREPPA, LLP Steven McDonald Attorneys for Defendants, Cross-Defendants, Cross-Complainants Shooter & Butts, Inc. -7- REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT 115330 Case No. CGC08-478453Dated: Dated: Dated: 115330 By: By: By: By; SELLAR HAZARD & LUCIA. Christian P, Lucia Brent F. Basilico Attomeys for Defendants, Cross-Defendants, Cross-Complainants Cupertino Electric, Inc.; Creative Masonry, Inc.; Carefree Toland Poots, Inc,; J.W. McClenahan, Inc.; N.V. Heathorn, Inc.; Critchfield Mechanical, Inc.; West Coast Protective Coating, Inc.; Blue’s Roofing Company; Van-Mulder Sheet Metal, Inc., F. Rogers Corporation; Roofing Constructors, Inc., dba Western Roofing Service ARCHER NORRIS William H. Staples Attomeys for Defendants, Cross-Defendants, Cross-Complainants Anning Johnson Company LYNCH, GILARDI & GRUMMER Attorneys fot Defendants, Cross-Defendants, Cross-Complainants Architectural Glass and Aluminum Co., Inc. BLEDSOE, CATHCART, DIESTEL, PEDERSON & TREPPA, LLP Steven McDonald Attomeys for Defendants, Cross-Defendants, Cross-Complainants Shooter & Butts, Inc, -5e REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF JOINT ORDER TO SHOW CAUSE HEARING STATEMENT Case No, CGC08-478453 Scanned by CamScanner