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  • COMMONWEALTH LAND TITLE INSURANCE COMPANY VS. FEDEX OFFICE AND PRINT SERVICES, INC et al (PROVIDE ACCESS) FRAUD document preview
  • COMMONWEALTH LAND TITLE INSURANCE COMPANY VS. FEDEX OFFICE AND PRINT SERVICES, INC et al (PROVIDE ACCESS) FRAUD document preview
  • COMMONWEALTH LAND TITLE INSURANCE COMPANY VS. FEDEX OFFICE AND PRINT SERVICES, INC et al (PROVIDE ACCESS) FRAUD document preview
  • COMMONWEALTH LAND TITLE INSURANCE COMPANY VS. FEDEX OFFICE AND PRINT SERVICES, INC et al (PROVIDE ACCESS) FRAUD document preview
						
                                

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Jason W. Estavillo (Bar No. 188093) Caitlin M. Phair (Bar No. 306685) David I. Blumenfeld (Bar No. 124157) ELECTRONICALLY LAW OFFICES OF JASON ESTAVILLO F I L E D 1330 Broadway, Suite 501 Superior Court of California, County of San Francisco Oakland, California 94612 Telephone: (510) 982-3001 09/18/2019 Clerk of the Court Facsimile: (510) 982-3002 BY: BOWMAN LIU Deputy Clerk Attorneys for Proposed Judgment Debtors EZRESOURCE, Inc., Michael Flores, and Investment Property Management LLC SUPERIOR COURT FOR THE STATE OF CALIFORNIA 10 CITY AND COUNTY OF SAN FRANCISCO 12 COMMONWEALTH LAND TITLE ) Lead Case No.: CGC-10-503332 INSURANCE COMPANY, ) (Consolidated for all purposes with 13 CGC-11-512012) Plaintiff, ) 14 V. ) 15 ) ATTORNEY AFFIDAVIT OF JASON W. FEDEX OFFICE AND PRINT SERVICES ) ESTAVILLO IN SUPPORT OF INC.; WINSTON LUM; KAUSHAL ) PEREMPTORY DISQUALIFICATION NIROULA; JAY CHANDRAKANT SHAH; OF JUDGE NEWTON J. LAM ELVIA PALOMINO; MORAD AFRAIMI; ) 17 ) MELVIN LEE EMERICH; MARTINI CHNOOGLE; GRACHELE LANGUBAN; ) 18 MERCHANTS BONDING COMPANY, and ) DOES 1-24, ) 19 ) Defendants. ) 20 ) 21 SHIRLEY S. HWANG, ) Plaintiff, ) Case No. CGC-11-512102 22 V. ) 23 ) FEDEX OFFICE AND PRINT SERVICES ) 24 INC., WINSTON LUM, KAUSHAL NIROULA, JAY CHANDRAKANT SHAH, ) 25 MELVIN LEE EMERICH, ) GRACECHELLED LANGUBAN, AND 26 MARTINI & CHNOOGLE, AND DOES 1-50,) ) Defendants, 28 CAW OFFICSSOF3AS3S CA ESIABBIO, PC 1330 deaden, 5 ce 501 Commonwealth etc., et al. Caalaad, CA 91512 TBFPuae 5510) 9953501 v.Fedex, etc., et al., Attorney Affidavit is Support of Peremptory Fa and related cross action CSN) 992-3002 la. Disqualifrcation of Judge Newton J. Lam AFFIDVAIT IN SUPPORT OF PEREMPTORY CHALLKNGK 3 I, Jason W. Estavillo, being duly sworn, deposes and declares: 1. Third Parties/Proposed Judgment Debtors herein EZRESOURCE, Inc., Michael Flores, and Investment Property Management (the "Third Parties" ), were not parties to the underlying civil actions herein and were not part of any judgment in these matters. Cross- Defendant/Plaintiff Shirley S. Hwang, through her counsel, is attempting to have Third Parties added to the Judgment as judgment debtors after trial. 2. Iam an attorney licensed to practice before all the Courts of the State of California and I am 10 one of the attorneys for the Third Parties. 3. Judge Newton J. Lam, who was the trial judge in the underlying actions, and before whom 12 Cross-Defendant/Plaintiff Shirley S. Hwang's motion to amend judgment to add judgment 13 debtors, and order to show cause directed to the Third Parties, is pending is prejudiced against 14 the Third Parties or the interests of the Third Parties, so that declarant believes that the Third 15 Parties cannot have a fair and impartial ntaI or hearing before this Judge. [CCP II 170.6(a)(6) j 16 17 I declare under penalty of perjury, under the laws of the State of California that the foregoing is true 18 and correct. 19 Dated: September 18, 2019 20 21 Jason W JEstavillo 22 23 24 25 26 27 28 IAW OFFIOW OF )8939 W. 85FAV010, FC 13308mad as,s 1 501 Commonwealth etc., Cdkuad, CA 95832 Fdaaa m (510) 982-3001 et al.v.Pedex, etc., et al., Attorney Affidavit is Support of Peremptory Fats mls. and related cross action 2510) 982-3002 Disgualificatton o/ Judge Newton J. /am