Motion,Ex Parte: Schmid vs Two Rock Fire Dept

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                                1 William L. Adams, Esq. (SBN 166027)
   WILLIAM L. ADAMS, P.C.
 2 P.O. Box 1050
   Windsor, California 95492-1050
 3 Telephone: (707) 236-2176
   E-mail:    bill@wladamspc.com
 4

 5 Counsel for Defendant
   TWO ROCK VOLUNTEER FIRE DEPARTMENT
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 8                      SUPERIOR COURT OF THE STATE OF CALIFORNIA

 9                             IN AND FOR THE COUNTY OF SONOMA
10 FREAR STEPHEN SCHMID AND                             Case No. SCV-266225 and consolidated
   ASTRID SCHMID,                                            actions SCV-266731 and SCV-270339
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             Plaintiffs,                                Assigned for All Purposes
12                                                      Hon. Oscar A. Pardo
                     vs.
13                                                      DEFENDANT TWO ROCK
                                                        VOLUNTEER FIRE DEPARTMENT’S
14 TWO ROCK VOLUNTEER FIRE                              JOINDER TO DEFENDANT COUNTY
   DEPARTMENT,                                          OF SONOMA’S MOTION TO ENFORCE
15                                                      JUDICIAL SETTLEMENT
             Defendant.                                 [CCP § 664.6]
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17                                                      Hearing Date: April 5, 2023
                                                        Time:         3:00 p.m.
18                                                      Dept:         19

19                                                      Trial Date:    July 13, 2023

20 AND CONSOLIDATED ACTIONS.

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22 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

23          Defendant TWO ROCK VOLUNTEER FIRE DEPARTMENT (“TRVFD”), by and

24 through its Counsel, hereby joins in and adopts the Defendant COUNTY OF SONOMA’s Motion

25 to Enforce Judicial Settlement (“County’s Motion”), including the arguments and statements of

26 issues and/or facts; together with exhibits and supporting evidence incorporated therein.

27          TRVFD requests the Court take judicial notice of its own files and records pursuant to

28 Evidence Code section 451 et seq., including all cases at issue in the County’s Motion; and
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     DEFENDANT TWO ROCK VOLUNTEER FIRE DEPARTMENT’S JOINDER TO DEFENDANT
          COUNTY OF SONOMA’S MOTION TO ENFORCE JUDICIAL SETTLEMENT
 1 TRVFD reserves all its respective rights and remedies to present additional pleadings,

 2 declarations, evidence, and arguments in support of the Court’s consideration and determination of

 3 the issues raised in connection with the County’ Motion and this TRVFD joinder.

 4         Pursuant to Code of Civil Procedure section 664.6 (a), TRVFD requests the Court issue an

 5 Order entering judgment on the terms of the parties’ settlement announced on the record in open

 6 Court before Hon. Barbara Zuniga on November 10, 2022, including the engineered plan drawing

 7 showing project revisions recited in the Settlement Agreement attached as Exhibit E to the

 8 accompanying supporting declaration of TRVFD counsel William L. Adams.

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10 DATED: February 27, 2023                      WILLIAM L. ADAMS, PC
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12                                         By:
                                                 William L. Adams, Counsel for Defendant
13                                               TWO ROCK VOLUNTEER FIRE DEPARTMENT

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     DEFENDANT TWO ROCK VOLUNTEER FIRE DEPARTMENT’S JOINDER TO DEFENDANT
          COUNTY OF SONOMA’S MOTION TO ENFORCE JUDICIAL SETTLEMENT