On August 12, 2022 a
69425HRG01005509
was filed
involving a dispute between
Lawyers Title Company,
and
Does 1 Through 50, Inclusive,
Gorog, Stephen J.,
Mar, David,
Mar, Samantha,
for (42) Unlimited Other Complaint (Not Spec)
in the District Court of San Mateo County.
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1 ADAM R. SALVAS (SBN 191379)
Fidelity National Law Group
2 The Law Division of Fidelity National Title Group, Inc.
1550 Parkside Drive, Suite 300
3 Walnut Creek, CA 94596
Telephone: (925) 817-3719
4 Facsimile: (925) 930-9588
adam.salvas@fnf.com
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Attorneys for Plaintiff,
6 LAWYERS TITLE COMPANY
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE COUNTY OF SAN MATEO
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LAWYERS TITLE COMPANY, Case No.: 22CIV03316
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Plaintiff, NOTICE OF NON-OPPOSITION TO
12 MOTION TO DISCHARGE & DISMISS
vs. STAKEHOLDER
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DAVID MAR and SAMANTHA MAR, as
14 Trustees of the David Mar and Samantha Mar Date: January 25, 2023
Revocable Living Trust dated 06/13/2016; Time: 2:00 p.m.
15 STEPHEN J. GOROG; and DOES 1 through 50, Dept.: 2
inclusive,
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Defendants.
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19 Plaintiff LAWYERS TITLE COMPANY (“LTC”) hereby submits this Notice of Non-
20 Opposition to Motion to Discharge & Dismiss Stakeholder.
21 Defendants David and Samantha Mar, as trustees of the David and Samantha Mar Revocable
22 Living Trust dated June 13, 2016 (the “Mar Defendants”) and Stephen Gorog (“Gorog”) were duly
23 served with LTC’s moving papers on November 22, 2022. Any opposition was due on or before January
24 11, 2023.
25 As of the date of filing the instant pleading, which is the date LTC’s Reply Brief is due, the Mar
26 Defendants and Gorog have not filed or served any opposition to the motion.
27 Consequently, the lack of any opposition is a concession on the merits. Sexton v. Superior Court
28 (1997) 58 Cal.App.4th 1403, 1410. Therefore, LTC respectfully requests that the Court enter an Order
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Notice of Non-Opposition to Motion to Discharge & Dismiss
1 discharging and dismissing LAWYERS TITLE COMPANY.
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Dated: January 18, 2023 FIDELITY NATIONAL LAW GROUP
3 THE LAW DIVISION OF FIDELITY NATIONAL TITLE GROUP, INC.
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5 ________________________________________
ADAM R. SALVAS
6 ATTORNEYS FOR PLAINTIFF
LAWYERS TITLE COMPANY
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Notice of Non-Opposition to Motion to Discharge & Dismiss
1 PROOF OF SERVICE
Lawyers Title Company. v. David Mar, et al.
2 San Mateo County Superior Court Case No.: 22CIV03316
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I am employed in the County of Contra Costa, State of California. I am over the age of 18
4 years and not a party to the within action. My business address is 1550 Parkside Drive, Suite 300,
Walnut Creek, California 94596.
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On January 17, 2023, I served the within:
6 • NOTICE OF NON-OPPOSITION TO MOTION TO DISCHARGE & DISMISS
7 STAKEHOLDER
on the parties in said action by placing a true copy thereof as indicated below, addressed as follows:
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Stephen J. Gorog
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5916 Hazel Avenue
10 Richmond, CA 94805
Telephone: (415) 309-0235
11 Email: stevegorog@gmail.com
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David Mar
13 115 Maywood Drive
San Francisco, CA 94127
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Samantha Mar
15 115 Maywood Drive
16 San Francisco, CA 94127
17 BY MAIL: I caused such envelope(s) with postage thereon fully prepaid to be placed for
collection and mailing at my place of business. Following ordinary business practices, said
18 correspondence will be deposited with the United States Postal Service at Walnut Creek,
19 California, on the referenced date in the ordinary course of business. There is delivery
service by United States mail at the place so addressed in the City of Walnut Creek, County
20 of Contra Costa, State of California.
21 BY OVERNIGHT MAIL: I caused such copies to be placed in envelopes designated by the
express carrier, Golden State Overnight, with delivery fees provided for and deposited those
22 envelopes in a pickup box regularly maintained by Golden State Overnight.
23 BY FACSIMILE: I faxed such document(s) from Walnut Creek, California to the facsimile
number(s) of the parties listed above. The sending facsimile machine number is (925) 930-
24 9588. The transmission was reported as complete and without error and the transmission
report was properly issued by the transmitting facsimile machine.
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BY EMAIL: I caused a PDF document to transmit via electronic mail to the email
26 addresses listed on the proof of service.
BY PERSONAL SERVICE: I caused such envelope to be delivered by hand to the offices
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of the addressee(s).
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Proof of Service
1 I declare under the penalty of perjury under the laws of the State of California, that the
foregoing is true and correct.
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Executed on January 18, 2023, at Walnut Creek, California.
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___________________________________
5 Jordan Gossage
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Proof of Service
Document Filed Date
January 18, 2023
Case Filing Date
August 12, 2022
Category
(42) Unlimited Other Complaint (Not Spec)
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1 ADAM R. SALVAS (SBN 191379) Fidelity National Law Group 2 The Law Division of Fidelity National Title Group, Inc. 1550 Parkside Drive, Suite 300 3 Walnut Creek, CA 94596 Telephone: (925) 817-3719 4 Facsimile: (925) 930-9588 adam.salvas@fnf.com 5 Attorneys for Plaintiff, 6 LAWYERS TITLE COMPANY 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF SAN MATEO 10 LAWYERS TITLE COMPANY, Case No.: 22CIV03316 11 Plaintiff, NOTICE OF NON-OPPOSITION TO 12 MOTION TO DISCHARGE & DISMISS vs. STAKEHOLDER 13 DAVID MAR and SAMANTHA MAR, as 14 Trustees of the David Mar and Samantha Mar Date: January 25, 2023 Revocable Living Trust dated 06/13/2016; Time: 2:00 p.m. 15 STEPHEN J. GOROG; and DOES 1 through 50, Dept.: 2 inclusive, 16 Defendants. 17 18 19 Plaintiff LAWYERS TITLE COMPANY (“LTC”) hereby submits this Notice of Non- 20 Opposition to Motion to Discharge & Dismiss Stakeholder. 21 Defendants David and Samantha Mar, as trustees of the David and Samantha Mar Revocable 22 Living Trust dated June 13, 2016 (the “Mar Defendants”) and Stephen Gorog (“Gorog”) were duly 23 served with LTC’s moving papers on November 22, 2022. Any opposition was due on or before January 24 11, 2023. 25 As of the date of filing the instant pleading, which is the date LTC’s Reply Brief is due, the Mar 26 Defendants and Gorog have not filed or served any opposition to the motion. 27 Consequently, the lack of any opposition is a concession on the merits. Sexton v. Superior Court 28 (1997) 58 Cal.App.4th 1403, 1410. Therefore, LTC respectfully requests that the Court enter an Order 1 Notice of Non-Opposition to Motion to Discharge & Dismiss 1 discharging and dismissing LAWYERS TITLE COMPANY. 2 Dated: January 18, 2023 FIDELITY NATIONAL LAW GROUP 3 THE LAW DIVISION OF FIDELITY NATIONAL TITLE GROUP, INC. 4 5 ________________________________________ ADAM R. SALVAS 6 ATTORNEYS FOR PLAINTIFF LAWYERS TITLE COMPANY 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 Notice of Non-Opposition to Motion to Discharge & Dismiss 1 PROOF OF SERVICE Lawyers Title Company. v. David Mar, et al. 2 San Mateo County Superior Court Case No.: 22CIV03316 3 I am employed in the County of Contra Costa, State of California. I am over the age of 18 4 years and not a party to the within action. My business address is 1550 Parkside Drive, Suite 300, Walnut Creek, California 94596. 5 On January 17, 2023, I served the within: 6 • NOTICE OF NON-OPPOSITION TO MOTION TO DISCHARGE & DISMISS 7 STAKEHOLDER on the parties in said action by placing a true copy thereof as indicated below, addressed as follows: 8 Stephen J. Gorog 9 5916 Hazel Avenue 10 Richmond, CA 94805 Telephone: (415) 309-0235 11 Email: stevegorog@gmail.com 12 David Mar 13 115 Maywood Drive San Francisco, CA 94127 14 Samantha Mar 15 115 Maywood Drive 16 San Francisco, CA 94127 17 BY MAIL: I caused such envelope(s) with postage thereon fully prepaid to be placed for collection and mailing at my place of business. Following ordinary business practices, said 18 correspondence will be deposited with the United States Postal Service at Walnut Creek, 19 California, on the referenced date in the ordinary course of business. There is delivery service by United States mail at the place so addressed in the City of Walnut Creek, County 20 of Contra Costa, State of California. 21 BY OVERNIGHT MAIL: I caused such copies to be placed in envelopes designated by the express carrier, Golden State Overnight, with delivery fees provided for and deposited those 22 envelopes in a pickup box regularly maintained by Golden State Overnight. 23 BY FACSIMILE: I faxed such document(s) from Walnut Creek, California to the facsimile number(s) of the parties listed above. The sending facsimile machine number is (925) 930- 24 9588. The transmission was reported as complete and without error and the transmission report was properly issued by the transmitting facsimile machine. 25 BY EMAIL: I caused a PDF document to transmit via electronic mail to the email 26 addresses listed on the proof of service. BY PERSONAL SERVICE: I caused such envelope to be delivered by hand to the offices 27 of the addressee(s). 28 Proof of Service 1 I declare under the penalty of perjury under the laws of the State of California, that the foregoing is true and correct. 2 Executed on January 18, 2023, at Walnut Creek, California. 3 4 ___________________________________ 5 Jordan Gossage 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Proof of Service