On March 11, 2021 a
Motion-Secondary
was filed
involving a dispute between
Domino Realty Management Company A California Corporation,
and
Dain Julianna,
Julianna Dain Trustee Of The Jeff & Julie Friedman Family Trust Dated 8 9 79,
for Other Real Property (not eminent domain, landlord/tenant, foreclosure) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 04/22/2021 01:02 PM Sherri R. Carter, Executive Officer/Clerk of Court, by B. McClendon,Deputy Clerk
1 RAINES FELDMAN LLP
Ronald E. Altman (State Bar No. 116628)
2 raltman@raineslaw.com
Rachael H. Berman (State Bar No. 174718)
3 rberman@raineslaw.com
Jeremy T. Borden (State Bar No. 252141)
4 jborden@raineslaw.com
1800 Avenue of the Stars, 12th Floor
5 Los Angeles, California 90067
Telephone: (310) 440-4100
6 Facsimile: (310) 691-1943
7 Attorneys for Defendants
JULIANNA DAIN an individual, as Trustee of
8 the JEFF & JULIE FRIEDMAN FAMILY
TRUST DATED 8/9/79
9
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 FOR THE COUNTY OF LOS ANGELES - WEST DISTRICT
12
13 DOMINO REALTY MANAGEMENT Case No.: 21SMCV00479
COMPANY, a California
14 corporation, Assigned to: Hon. Elaine Mandel, Dept. P
15 Plaintiff(s), DECLARATION OF RACHAEL
BERMAN IN SUPPORT OF MOTION
16 v. TO EXPUNGE LIS PENDENS AND
REQUEST FOR ATTORNEYS’ FEES
17 JULIANNA DAIN, an individual, as AND COSTS IN THE SUM OF
$16,721.96 PURSUANT TO CODE OF
Trustee of the JEFF & JULIE FRIEDMAN CIVIL PROCEDURE SECTION 405.38
18
FAMILY TRUST DATED 8/9/79; and all
19 persons unknown, claiming any legal or [Filed concurrently with Motion to Expunge
equitable title, estate, lien or interest in the Lis Pendens; Declarations of Julianna Dain
20 property described in the complaint adverse in support of the Motion]
to Plaintiff's title, or any cloud on Plaintiff's
21 title thereto; and DOES 1 through 20,
inclusive, Date: June 4, 2021
22 Time: 8:30 a.m.
Defendant(s) Dept: P
23
RESERVATION ID: 248828007752
24
Complaint Filed: March 11, 2021
25 Trial Date: None
26
27
28
2846845.1 -1-
DECLARATION OF RACHAEL BERMAN IN SUPPORT OF MOTION TO EXPUNGE LIS PENDENS
Document Filed Date
April 22, 2021
Case Filing Date
March 11, 2021
Category
Other Real Property (not eminent domain, landlord/tenant, foreclosure) (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 06/03/2021
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 04/22/2021 01:02 PM Sherri R. Carter, Executive Officer/Clerk of Court, by B. McClendon,Deputy Clerk 1 RAINES FELDMAN LLP Ronald E. Altman (State Bar No. 116628) 2 raltman@raineslaw.com Rachael H. Berman (State Bar No. 174718) 3 rberman@raineslaw.com Jeremy T. Borden (State Bar No. 252141) 4 jborden@raineslaw.com 1800 Avenue of the Stars, 12th Floor 5 Los Angeles, California 90067 Telephone: (310) 440-4100 6 Facsimile: (310) 691-1943 7 Attorneys for Defendants JULIANNA DAIN an individual, as Trustee of 8 the JEFF & JULIE FRIEDMAN FAMILY TRUST DATED 8/9/79 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 FOR THE COUNTY OF LOS ANGELES - WEST DISTRICT 12 13 DOMINO REALTY MANAGEMENT Case No.: 21SMCV00479 COMPANY, a California 14 corporation, Assigned to: Hon. Elaine Mandel, Dept. P 15 Plaintiff(s), DECLARATION OF RACHAEL BERMAN IN SUPPORT OF MOTION 16 v. TO EXPUNGE LIS PENDENS AND REQUEST FOR ATTORNEYS’ FEES 17 JULIANNA DAIN, an individual, as AND COSTS IN THE SUM OF $16,721.96 PURSUANT TO CODE OF Trustee of the JEFF & JULIE FRIEDMAN CIVIL PROCEDURE SECTION 405.38 18 FAMILY TRUST DATED 8/9/79; and all 19 persons unknown, claiming any legal or [Filed concurrently with Motion to Expunge equitable title, estate, lien or interest in the Lis Pendens; Declarations of Julianna Dain 20 property described in the complaint adverse in support of the Motion] to Plaintiff's title, or any cloud on Plaintiff's 21 title thereto; and DOES 1 through 20, inclusive, Date: June 4, 2021 22 Time: 8:30 a.m. Defendant(s) Dept: P 23 RESERVATION ID: 248828007752 24 Complaint Filed: March 11, 2021 25 Trial Date: None 26 27 28 2846845.1 -1- DECLARATION OF RACHAEL BERMAN IN SUPPORT OF MOTION TO EXPUNGE LIS PENDENS