Document for ARNTSEN FAMILY PARTNERSHIP, LP, et al vs. GREGORY J DAVIS, et al

• 
• 
• 
• 

						
                                
Preview
                                1    Collin J. Vierra (State Bar No. 322720)
      EIMER STAHL LLP
 2    99 S. Almaden Blvd., Ste. 600
      San Jose, CA 95113-1605
 3    Telephone: (408) 889-1668
 4    Email: cvierra@eimerstahl.com

 5    Attorney for Plaintiffs

 6
                       SUPERIOR COURT OF THE STATE OF CALIFORNIA
 7
                                          COUNTY OF SAN MATEO
 8

 9    Robert Arntsen; Mary Lee; Arntsen Family            Case No. 22-CIV-01148
      Partnership, LP; Brian Christopher Dunn
10                                                        Dept. 21
      Custodianship;
11                          Plaintiffs,                   Hon. Robert D. Foiles

12   vs.                                                  NOTICE OF MOTION AND
                                                          MOTION FOR DEFAULT
13   David M. Bragg; Silicon Valley Real Ventures LLC;    JUDGMENT
     SVRV 385 Moore, LLC; SVRV 387 Moore, LLC;
14   Gregory J. Davis; Kevin Wolfe; Jason Justesen;       Hearing Date: May 26, 2023

15   Paramont Woodside, LLC; and Paramont Capital,        Hearing Time: 9:30am
     LLC;
16                          Defendants.
17

18

19

20

21

22

23

24

25

26

27

28
                                                  -1-
     NOTICE MOTION AND MOTION FOR DEFAULT JUDGMENT
 1
            TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
 2
            PLEASE TAKE NOTICE that on May 26, 2023, at 9:30am, or as soon thereafter as the
 3
     matter may be heard by this Court, located at 400 County Center, Redwood City, CA 94063,
 4
     Plaintiffs Robert Arntsen (“Bob”), Mary Lee (“Mary”), the Arntsen Family Partnership, LP (the
 5
     “Partnership”), and the Brian Christopher Dunn Custodianship (the “Custodianship”) will move
 6
     this Court for a default judgment against Defendants David Matthew Bragg (“Bragg”) and Silicon
 7
     Valley Real Ventures, LLC (“SVRV”), pursuant to Code of Civil Procedure section 585(b) and
 8
     Rules of Court sections 3.110 and 3.1800.
 9
            In addition to this notice and motion, this motion is based on the accompanying:
10
     memorandum of points and authorities; declarations of Plaintiffs and Plaintiffs’ counsel and
11
     associated Exhibits; interest and damages computations and memorandum of costs; declaration of
12
     nonmilitary status; proposed form of judgment; application under Code of Civil Procedure section
13
     579; request for dismissal; all pleadings and papers filed in this Court; all pleadings and papers
14
     filed in the related adversary proceeding in the bankruptcy court for the Eastern District of
15
     California, No. 22-02112; and any arguments at the hearing.
16

17

18
                                                       EIMER STAHL LLP
19    Dated:    March 21, 2023

20

21
                                                       Collin Vierra
22
                                                       Attorney for Plaintiffs Robert Arntsen,
23                                                     Mary Lee, the Arntsen Family Partnership, LP,
                                                       and the Brian Christopher Dunn Custodianship
24

25

26

27

28
                                                    -2-
     NOTICE MOTION AND MOTION FOR DEFAULT JUDGMENT