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Electronically FILED by Superior Court of California, County of Los Angeles on 12/30/2021 10:47 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Young,Deputy Clerk
CD-100
ATTORNEY OR PARTY IMTHOUT ATTORNEY (Name, State sar number and FOR COURT USE ONLY
address('atthew
R. Harrison (SBN 267477)
Bloom Charter Law Assoc.
275 Battery Street, 16th Floor
San Francisco, CA 94111
TELEPHONE NO (4 I 5) 890-3422 FAX No. (Opt onali
E-MAR.AooREss(oprrona» mrhpb)OOmeharterlaW.COm
ATTDRNEYFDR (niamei Plaintiff InternatiOnal PaW AngelS
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
sTREETADDREss 312 North Spring Street
MAILING ADDRESS
DITY AND zip coDE Los Angeles, CA 900 I 2
ERANcH NAME Spring Street Courthouse, Civil Limited
PLAINTIFF: International Paw Angels
ocFLNDAm Bobi Leonard and Paul Beirold, Does I to 20
APPLICATION FOR WRIT OF POSSESSION H3 AFTER HEARING
EX PARTE C] AND FOR TEMPORARY RESTRAINING ORDER 21STLC01582
1. Plaintiff" has filed a complaint and makes dalm for delivery of property in the possession of the defendant named in b.
a. Plaintiff (name): International Paw Angels (IPA)
b. Defendant (name): Bobi Leonard and Paul Beirold
2. Plaintiff appfies for (check a/i that app/y):
a. ~v
b.
c.
~
~
Writ of possession after hearing (Code Civ Proc, (C.C.P.), 8 512.010).
Ex parte writ of possession (C.C.P., 8 512.020). (File Declaration for Ex Parte Writ of Possession, form CD-180)
Temporary restraining order (C.C.Pu 8 513.010). (File Application for Temporary Restraining Order, form CD-190)
3. The basis of the plaintiffs claim and right to possession of the claimed property is specified in ~V a wntten document,
a copy of which is attached. C]
the verified complaint. Z3
the attached declaration. CZ the following facts (specify):
Plaintiff has facts and documents to support its claim and right to possession of the property (which is a
rescue dog, "Vanilla" ) as shown in the attached declaration of Declaration of Joanna Ging, Individually and
on Behalf of International Paw Angels, in Support of Plaintiffs Application for Writ of Possession
(Attachment I, hereto). See also, Memorandum of Points and Authorities in Support of Plaintiffs
Application for Writ of Possession, filed concurrently herewith.
4. Claimed property (Describe, state value, and further identify any property thatis a farm product (Code Civ Proc., 5 511.040)
orinventory held for sale or lease (Code Civ. Proc., 5 511.050)):
The claimed property is Plaintiffs dog, Vanilla, a female standard poodle breed dog, white in coloring,
approximately 3.5 years old, weighing approximately 50 pounds. The reasonable value of the claimed
property is at least approximately $ 7,500, which includes Plaintiff's out-of-pocket costs for obtaining,
taking ownership of, and caring for Vanilla; this includes, but is not limited to, paying for the dog's health
care expenses, such as her spaying, vaccinations, veterinary expenses, lodging and meals, health check,
export papers, microchip, travel and transportation costs, as well as other related expenses.
Continued on Attachment 4.
* **Plaintiff"
includes cross-complainant, "defendant" includes cross-defendant, snd "complaint*'ndudes cross-complaint. Page I of 2
Form Adopted for Mandatory Use CodeCrv. Proc. »512010
Jud oal Counol of Cal fomra
CD-100 IRev. January I, 2000( APPLICATION FOR WRIT OF POSSESSION www owmnro ce gov
(claim and Delivery)
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Electronically FILED by Superior Court of California, County of Los Angeles on 12/30/2021 10:47 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Young,Deputy Clerk CD-100 ATTORNEY OR PARTY IMTHOUT ATTORNEY (Name, State sar number and FOR COURT USE ONLY address('atthew R. Harrison (SBN 267477) Bloom Charter Law Assoc. 275 Battery Street, 16th Floor San Francisco, CA 94111 TELEPHONE NO (4 I 5) 890-3422 FAX No. (Opt onali E-MAR.AooREss(oprrona» mrhpb)OOmeharterlaW.COm ATTDRNEYFDR (niamei Plaintiff InternatiOnal PaW AngelS SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES sTREETADDREss 312 North Spring Street MAILING ADDRESS DITY AND zip coDE Los Angeles, CA 900 I 2 ERANcH NAME Spring Street Courthouse, Civil Limited PLAINTIFF: International Paw Angels ocFLNDAm Bobi Leonard and Paul Beirold, Does I to 20 APPLICATION FOR WRIT OF POSSESSION H3 AFTER HEARING EX PARTE C] AND FOR TEMPORARY RESTRAINING ORDER 21STLC01582 1. Plaintiff" has filed a complaint and makes dalm for delivery of property in the possession of the defendant named in b. a. Plaintiff (name): International Paw Angels (IPA) b. Defendant (name): Bobi Leonard and Paul Beirold 2. Plaintiff appfies for (check a/i that app/y): a. ~v b. c. ~ ~ Writ of possession after hearing (Code Civ Proc, (C.C.P.), 8 512.010). Ex parte writ of possession (C.C.P., 8 512.020). (File Declaration for Ex Parte Writ of Possession, form CD-180) Temporary restraining order (C.C.Pu 8 513.010). (File Application for Temporary Restraining Order, form CD-190) 3. The basis of the plaintiffs claim and right to possession of the claimed property is specified in ~V a wntten document, a copy of which is attached. C] the verified complaint. Z3 the attached declaration. CZ the following facts (specify): Plaintiff has facts and documents to support its claim and right to possession of the property (which is a rescue dog, "Vanilla" ) as shown in the attached declaration of Declaration of Joanna Ging, Individually and on Behalf of International Paw Angels, in Support of Plaintiffs Application for Writ of Possession (Attachment I, hereto). See also, Memorandum of Points and Authorities in Support of Plaintiffs Application for Writ of Possession, filed concurrently herewith. 4. Claimed property (Describe, state value, and further identify any property thatis a farm product (Code Civ Proc., 5 511.040) orinventory held for sale or lease (Code Civ. Proc., 5 511.050)): The claimed property is Plaintiffs dog, Vanilla, a female standard poodle breed dog, white in coloring, approximately 3.5 years old, weighing approximately 50 pounds. The reasonable value of the claimed property is at least approximately $ 7,500, which includes Plaintiff's out-of-pocket costs for obtaining, taking ownership of, and caring for Vanilla; this includes, but is not limited to, paying for the dog's health care expenses, such as her spaying, vaccinations, veterinary expenses, lodging and meals, health check, export papers, microchip, travel and transportation costs, as well as other related expenses. Continued on Attachment 4. * **Plaintiff" includes cross-complainant, "defendant" includes cross-defendant, snd "complaint*'ndudes cross-complaint. Page I of 2 Form Adopted for Mandatory Use CodeCrv. Proc. »512010 Jud oal Counol of Cal fomra CD-100 IRev. January I, 2000( APPLICATION FOR WRIT OF POSSESSION www owmnro ce gov (claim and Delivery)