Motion to Waive Court Fees in Jonas Svensson vs iO73 Investments Inc et al| Trellis.Law

On December 18, 2020 a Appellate Materials was filed involving a dispute between Svensson, Jonas, and Io73 Investments Inc, Strauss, Tristan, for Unlimited Writ of Mandate (02) in the District Court of Santa Barbara County.

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ELECTRONICALLY FILED
Superior Court of California
County of Santa Barbara
1 STEPHEN L. RAM, State Bar No. 240769 Darrel E. Parker, Executive Officer
sram@stradlinglaw.com 12/5/2022 5:16 PM
2 NICOLE L. CARBONEL, State Bar No. 329262 By: Narzralli Baksh , Deputy
ncarbonel@stradlinglaw.com
3 STRADLING YOCCA CARLSON & RAUTH
A PROFESSIONAL CORPORATION
4 660 Newport Center Drive, Suite 1600
Newport Beach, CA 92660-6422
5 Telephone: 949 725 4000
Facsimile: 949 725 4100
6
Attorneys for Petitioner
7 JONAS SVENSSON
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF SANTA BARBARA
10 ANACAPA DIVISION
11 JONAS SVENSSON, CASE NO. 20CV04285
12 Petitioner, Hon. Colleen K. Sterne
13 vs.
NOTICE OF MOTION AND MOTION
14 iO73 INVESTMENTS, INC., and TRISTAN FOR ATTORNEYS’ FEES AND
STRAUSS, COSTS BY PETITIONER JONAS
15 SVENSSON IN THE AMOUNT OF
Respondents $87,591.50 IN FEES AND $148.50 IN
16 COSTS; MEMORANDUM OF
POINTS AND AUTHORITIES
17

19 Date: February 6, 2023
Time: 10:00 a.m.
20 Dept: 5
21 Amended Complaint Filed:
March 30, 2020
22

28
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MOTION FOR FEES AND COSTS AFTER APPEAL
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1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

2 PLEASE TAKE NOTICE THAT on February 6, 2023, at 10:00 a.m., or as soon

3 thereafter as this matter may be heard in Department 5 of the Santa Barbara Superior Court,

4 located at 1100 Anacapa Street, Santa Barbara, CA 93101, Petitioner Jonas Svensson

5 (“Svensson”) will and hereby does move the Court for an order awarding attorneys’ fees and

6 costs for defending an appeal, and in bringing this motion in the total amount of $87,591.50 in

7 fees and $148.50 in costs.

8 Svensson brings this motion pursuant to California Rules of Court, rules 8.278 and

9 California Corporations Code § 1604, and the Court of Appeal’s opinion dated August 16,

10 2022, which provides, in part, that: “The matter is remanded to the trial court with directions

11 to award respondent [Svensson] his reasonable appellate attorney fees, which shall be payable

12 by iO73 pursuant to section 1604. Respondent shall recover his costs on appeal from both

13 appellants. (Cal. Rules of Court, rule 8.278.)”

14 This motion is based on this upon this Notice, the Memorandum of Points and

15 Authorities in support thereof, the Declaration of Stephen L. Ram, the pleadings, record and

16 files in this action, and other matters of which the Court may take judicial notice and such

17 matters as may be presented to the Court at the time of the hearing.

19
DATED: December 5, 2022 STRADLING YOCCA CARLSON & RAUTH
20 A Professional Corporation
21

22 By:
Stephen L. Ram
23 Nicole L. Carbonel
Attorneys for Petitioner JONAS SVENSSON
24

28
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NOTICE OF MOTION AND MOTION
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1 I. INTRODUCTION

2 This dispute began as a straightforward request by a member of iO73 Investments,

3 Inc.’s (“iO73”) board of directors and substantial shareholder to inspect corporate records in

4 its possession. This Court granted Petitioner Jonas Svensson’s (“Svensson”) Petition for Writ

5 of Mandamus (the “Petition”) and ordered Respondents iO73 and Tristan Strauss (collectively,

6 the “Headwaters Parties”) to permit Svensson’s inspection under Sections 1601 and 1602 of

7 the Corporations Code, finding that the requested documents were within his rights as a

8 shareholder and director to inspect. The Headwaters Parties appealed the Court’s decision,

9 erroneously claiming, among other things, that the Court applied the wrong standard when

10 granting Svensson’s Petition. The Court of Appeal rejected their contentions and affirmed this

11 Court’s judgment, finding that iO73’s failure to comply with Svensson’s demand to inspect

12 corporate records was without justification. The Court of Appeal further issued the following

13 order: “The matter is remanded to the trial court with directions to award respondent

14 [Svensson] his reasonable appellate attorney fees, which shall be payable by iO73 pursuant to

15 section 1604. Respondent shall recover his costs on appeal from both appellants. (Cal. Rules

16 of Court, rule 8.278.)” Pursuant to the Court of Appeal’s remand order, Svensson now seeks

17 an award of $87,591.50 in attorneys’ fees.

18 Accordingly, Svensson respectfully requests that the Court grant this motion.

19 II. STATEMENT OF FACTS

20 A. Svensson Serves Documents Requests Seeking Corporate Records From

21 The Headwaters Group.

22 iO73 is the parent company of several subsidiaries and affiliated companies that do

23 business as the Headwaters Group in cultivating and distributing cannabis. (See (See

24 Declaration of Stephen L. Ram (“Ram Decl.”), ¶ 6, Ex. 4 (August 16, 2022 Opinion at 3-4).)

25 Svensson is a member of iO73’s board of directors and the second largest shareholder of iO73.

26 (Petition for Writ of Mandamus (“Petition”) ¶¶ 5, 7.) Following the termination of Svensson’s

27 employment as the Executive Chairman of iO73 and the Headwaters Parties’ subsequent

28 scheme to freeze out and involuntarily compel Svensson’s sale of his shares at an artificially
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1 delated price, Svensson filed a lawsuit against the Headwaters Parties and others (Svensson v.

2 iO73 Investments, Inc., et al., Santa Barbara Superior Court Case No. 20CV01556), alleging

3 causes of action for breach of an employment agreement and California Labor Code, among

4 others (the “Related Case”). 1

5 In the course of that lawsuit, Svensson served document requests on iO73 seeking,

6 among other things, certain documents and information relating to iO73 and the valuation of its

7 corporate enterprise as the Headwaters Group, including investor presentations, financial

8 information, contracts, debt instruments, and capitalization information. (See Petition ¶¶ 13,

9 18.) Despite acknowledging that Svensson is entitled to the requested records as a shareholder

10 and board member and despite not contending that such materials were not within its

11 possession, custody, or control, the Headwaters Parties refused to provide Svensson with the

12 requested information. (See id. ¶¶ 11-16.)

13 After the Headwaters Parties refused to produce the requested documents, on December

14 18, 2020, Svensson moved to compel. The Headwaters Parties objected to the motion to

15 compel, in part, contending that as a director and shareholder, Svensson needed to enforce his

16 inspection rights through a writ of mandamus, rather than pursue those same records under the

17 Civil Discovery Act. (Opp’n to Motion to Compel at 11.) On March 22, 2021, this Court

18 granted Svensson’s Motion to Compel as to 31 of the 34 requests, and imposed monetary

19 sanctions. (See Order Granting Motion To Compel.)

20 B. Svensson Files A Petition For Writ Of Mandamus, Asserting His Rights

21 Under Sections 1601 and 1602 of the Corporations Code Which The Court

22 Grants.

23 On the same day as the motion to compel in the Related Case, on December 18, 2020,

24 Svensson filed this action seeking to compel the inspection of iO73’s records under Sections

25 1601 and 1602 of the Corporations Code. (See generally Petition.) The Petition set forth

26 Svensson’s rights as a shareholder and the purposes reasonably related to his shareholder

27
1
Svensson respectfully requests that the Court take judicial notice of the proceedings in the
28 Related Case, as it previously has. Evid. Code §§ 452(d), 453.
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1 interests for the inspection demands, and as a director and lack of any applicable exception or

2 limitation to those rights. (See id. at 8-10.)

3 Despite the Headwaters Parties repeatedly claiming in the Related Case that that the

4 mandamus proceeding would fully protect Svensson’s rights, the Headwaters Parties filed a

5 demurrer claiming that: “The Petition does nothing to explain why Petitioner’s rights to the

6 records identified in the Petition could not be fully and fairly adjudicated in the Related Case.”

7 (Dem. at 2:21-22.) The Court overruled the demurrer on April 26, 2021.

8 The Headwaters Parties repeated that same contradictory position in opposing the

9 Petition. They again argued that Svensson’s interests were adequately protected in the Related

10 Case. (Opp’n to Petition at 2, 4, 5, 9.) The Headwaters Parties also added a new theory to

11 resist providing corporate records in their possession; they contended that Svensson is only a

12 shareholder of the so-called “non-touching” companies that do not hold cannabis licenses, and

13 that he was not entitled to records of the “touching companies” – those with the cannabis

14 licenses – within the Headwaters Group. (See id. at 7.) The “non-touching” and “touching”

15 distinction was just a form of diversion; it was contrary to the intertwined nature and control

16 exerted by iO73 over all of the Headwaters Group. Notably, the Headwaters Parties did not

17 contend that iO73 was not in possession of touching company documents. (See id. at 4-9.) In

18 fact, they admitted that in their Answer. (Compare Petition ¶ 4 with Answer ¶ 4.)

19 On September 3, 2021, the Court granted the Petition. (See Ram Decl., ¶ 3, Ex. 1

20 (Sept. 3, 2021 Ruling on Request for Writ of Mandate ¶ 8).) The Court discussed the interplay

21 of the Headwaters Parties’ contradictory contentions in the Related Case and those advanced in

22 this action, stating “[a]t the time the motion to compel was litigated in the Related Case, it was

23 argued by Respondents that the discovery being sought should be addressed by a Writ of

24 Mandate. And in this Writ proceeding, it has been argued that adequate relief exists in the

25 Related Cased such that the Writ proceeding should not have been pursued.” (Id., Ex. 1 at ¶¶

26 2, 4.)

27 In granting the Petition, the Court found that the requested documents were reasonably

28 related to Svensson’s interests as a shareholder and quoted from the Ballantine and Sterling
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1 California Corporations Laws treatise. (Id., Ex. 1 ¶ 5.) The Court further concluded that

2 Svensson had a right to the requested documents as a director, finding that the Headwaters

3 Parties urged exceptions were inapplicable. (Id., Ex. 1 ¶¶ 6-7.) Lastly, the Court rejected the

4 claimed distinction between the touching and non-touching companies and determined that:

5 “The corporate subsidiary relationship are sufficiently intertwined to permit discovery relating

6 to the entire Headwaters group. The court previously reached this conclusion in the Related

7 Case, and the court refers the parties to that ruling.” (Id., Ex. 1 ¶ 7.) The Headwaters Parties

8 filed a notice of appeal on October 14, 2021. (Id., ¶ 5, Ex. 3 (Notice of Appeal).)

9 On October 26, 2021, Svensson filed a motion seeking attorneys’ fees in connection

10 with his Petition in the total amount of $49,722, which the Court granted on August 8, 2022.

11 (See id., ¶ 4, Ex. 2 (August 8, 2022 Minute Order).) In granting Svensson’s fee request, the

12 Court found that “respondents repeatedly refused Svensson’s request as a shareholder to be

13 able to view and copy this information, forcing him to file his petition for writ of mandate,”

14 and that “[t]here was no legal justification for respondents’ refusal to make the information

15 available.” (Id.)

16 C. The Court of Appeal Affirms The Court’s Judgment And Orders iO73 To

17 Pay The Reasonable Appellate Attorney Fees Incurred By Svensson.

18 In challenging the Court’s order of September 3, 2021, the Headwaters Parties

19 contended that the Court erred in ruling that Svensson is entitled to inspect the records of the

20 “touching” companies because he is neither a director nor a shareholder of those entities. (See

21 generally Appellants’ Opening Brief.) To that end, the Headwaters Parties argued that the

22 Court applied the wrong legal standard and erred in reasoning that because the corporate

23 subsidiary relationships are “sufficiently intertwined,” that entitles Svensson to inspect the

24 corporate documents under Sections 1601 and 1602 of the Corporations Code. (Appellant’s

25 Opening Brief at 15.)

26 In opposition, Svensson prepared and filed his brief addressing the contentions of the

27 Headwaters Parties, including the applicable appellate standard of review, the legal standard in

28 Section 1601 and 1063, and raising additional, alternative bases upon which to affirm this
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1 Court’s judgment. Svensson also filed a request for judicial notice to expand the record to

2 include materials from the Related Case upon which this Court had in reaching its decision on

3 September 3, 2021. The Headwaters Parties filed a reply brief.

4 The Court of Appeal held oral argument on August 10, 2022. The next week, the Court

5 of Appeal issued its opinion on August 16, 2022, siding with Svensson on all issues. (See Ram

6 Decl., ¶ 6, Ex. 4.) The Court of Appeal found that substantial evidence supports the Court’s

7 finding that the companies are sufficiently intertwined such that Svensson’s status as a director

8 and shareholder of iO73 permits him to inspect and copy the books and records of the related

9 entities. (Id., Ex. 4 at 9-11.) Indeed, the Court of Appeal found that the “touching companies

10 and iO73 share a unity of management, control, and ownership,” that “the touching companies

11 were operating as if they were subsidiaries of iO73,” and thus “[a]lthough iO73 and the

12 touching companies are separate entities in form, it is reasonable to infer that in substance they

13 are operating as a single enterprise.” (Id., Ex. 4 at 10-11.) Therefore, the Court of Appeal held

14 that:

15 [T]he trial court was warranted in concluding . . . that [the touching companies
16 were] but an instrumentality or conduit of [iO73] in the prosecution of a single
venture namely, the [commercial cultivation and distribution of cannabis]. . . .
17 There was such unity of interest and ownership that the separateness of the
[touching companies and iO73] had in effect ceased and an adherence to the
18 fiction of [their] separate existence . . . would, under the circumstances here
present, promote injustice and make it inequitable . . . to deny respondent
19
permission to inspect the records of the touching companies under sections 1601
20 and 1602.
(Id., Ex. 4 at 11-12 (internal citations omitted).)
21
Upon Svensson’s request for an award of attorneys’ fees under Section 1604, the Court
22
of Appeal found that “iO73’s failure to comply with [Svensson’s] demand to inspect records of
23
the touching companies was without justification. (Id., Ex. 4 at 13.) The Court of Appeal
24
ordered: “The matter is remanded to the trial court with directions to award respondent
25
[Svensson] his reasonable appellate attorney fees, which shall be payable by iO73 pursuant to
26
section 1604. Respondent shall recover his costs on appeal from both appellants. (Cal. Rules
27
of Court, rule 8.278.)” (Id.)
28
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1 III. ARGUMENT

2 A. Based Upon The Court of Appeal’s Order, Svensson Is Entitled To Recover

3 His Appellate Attorneys’ Fees Under California Corporations Code § 1604.

4 “In any action or proceeding under Section 1600 or Section 1601, if the court finds the

5 failure of the corporation to comply with a proper demand thereunder was without justification,

6 the court may award an amount sufficient to reimburse the shareholder . . . for the reasonable

7 expenses incurred by such holder, including attorneys’ fees, in connection with such action or

8 proceeding.” Cal. Corp. Code § 1604. A corporation liable for attorney fees under section

9 1604 “is . . . liable for the fees the [shareholder] incurred at trial and on appeal.” Valtz v. Penta

10 Inv. Corp., 139 Cal. App. 3d 803, 811 (1983). 2

11 While the court of appeal has jurisdiction to award attorney fees relating to appeals, the

12 trial court is generally considered better suited to decide the factual issues inherent in fixing fee

13 amounts. Milman v. Shukhat, 22 Cal. App. 4th 538, 546 (1994) (holding appellants “shall also

14 be allowed to make a motion in [the trial] court for attorney fees on appeal.”). Upon remittitur,

15 a trial court has the authority award attorney’s fees on appeal to the prevailing party as

16 authorized by statute, contract, or law. Code of Civil Procedure § 1033.5; Harbour Landing-

17 Dolfann v. Anderson, 48 Cal. App. 4th 260, 264-65 (1996) (when right to an award of

18 attorney’s fees is statutory, “the trial court is authorized to award attorney’s fees as part of

19 costs on appeal notwithstanding a lack of direction in the remittitur.”).
20 Here, the Court of Appeal already determined that the Headwaters Parties’ appeal was

21 “without substantial justification.” (Ram Decl., Ex. 4 at 13.) As part of the remand, the Court

22 of Appeal ordered: “The matter is remanded to the trial court with directions to award

23 respondent [Svensson] his reasonable appellate attorney fees, which shall be payable by iO73

25 2
A party also may seek fees reasonably incurred in bringing a motion for attorneys’ fees. See
26 Doppes v. Bentley Motors, Inc., 174 Cal. App. 4th 967, 1002 (2009) (when attorney fees are
recoverable by statute, the reasonable attorney fees incurred in preparing the motion are also
27 recoverable); Serrano v. Unruh, 32 Cal. 3d 621, 639 (1982) (recoverable fees include hours spent
establishing and defending fee claim).
28
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1 pursuant to section 1604. Respondent shall recover his costs on appeal from both appellants.

2 (Cal. Rules of Court, rule 8.278.)” (Id.)

3 B. The Requested Attorneys’ Fees Are Reasonable.

4 “[A] party who qualifies for a fee should recover for all hours reasonably spent unless

5 special circumstances would render an award unjust.” Vo v. Las Virgenes Mun. Water Dist.,

6 79 Cal. App. 4th 440, 446 (2000). In determining the amount of recoverable fees, California

7 courts apply the lodestar method, which entails multiplying the number of hours reasonably

8 spent working on the litigation by the reasonable hourly rate. See PLCM Grp., Inc. v. Drexler,

9 22 Cal. 4th 1084, 1095 (2000). “The reasonable hourly rate is that prevailing in the community

10 for similar work.” Id. In making the determination, the Court may consider “the nature of the

11 litigation, its difficulty, the amount involved, the skill required in its handling, the skill

12 employed, the attention given, the success or failure, and the other circumstances in the case.”

13 Id.

14 The party seeking an award of attorneys’ fees is required to “present ... evidence,

15 documentary or oral, of the services actually performed[,] [including] the number of hours

16 worked, billing rates, types of issues dealt with and appearances made on the client’s behalf . . .

17 .” Martino v. Denevi, 182 Cal. App. 3d 553, 558-59 (1986). Declarations documenting the

18 number of hours worked are sufficient to prove the reasonableness of the time spent litigating

19 the case. Syers Properties Ill, Inc. v. Rankin, 226 Cal. App. 4th 691, 698-99 (2014) (“The trial
20 court did not abuse its discretion in accepting ... counsel’s computation of attorney hours as

21 hours reasonably spent working on the case” as supported by “declarations under penalty of

22 perjury in support of the hours sought . . . .”).

23 Here, Svensson seeks to recover his reasonable appellate attorneys’ fees in the amount

24 of $87,591.50. (See Ram Decl., ¶¶ 14-16, Exs. 8-14.) While detailed time records are not

25 required, Svensson has included with this motion not only the appropriate declaration, but also

26 detailed invoices containing time entries corresponding to the fees he seeks. (See id. ¶ 14, Exs.

27 8-13.) The attached declarations and invoices are prima facie evidence that the fees were

28 necessarily incurred. See Hadley v. Krepel, 167 Cal. App. 3d 677, 682 1985) (observing that
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1 “items on a verified cost bill are prima facie evidence the costs, expenses and services listed

2 were necessarily incurred”.).

3 As evidenced by the supporting declaration and invoices, the rates charged by

4 Svensson’s counsel are reasonable and within the market rate for attorneys with comparable

5 experience practicing securities and complex business litigation in Southern California,

6 particularly for shareholder disputes. (Ram Decl. ¶¶ 11, 14, Exs.8-13.) Svensson’s counsel

7 has particular experience in litigating shareholder and director inspection right disputes in

8 California and other jurisdictions. (Id. ¶ 9.) Svensson’s counsel did not charge Svensson their

9 full, normal rates that other clients pay, instead Svensson received certain discounts, and thus

10 the effective hourly rates for the primary timekeepers were: $742.50 for shareholder Stephen

11 L. Ram and $436.50 for third-year associate Nicole Carbonel. (Id. ¶ 12.) Federal courts

12 located in Southern California have found that similar rates are reasonable under California

13 law. See, e.g., Murtaugh v. Star Sci. Ltd., No. SA CV 15-0113-DOC (RNBx), 2018 U.S. Dist.

14 LEXIS 227450, at *8 (C.D. Cal. July 2, 2018) (finding hourly rates of $650 and $495 per hour

15 reasonable over four years ago in awarding fees under California Civil Code Section 1717);

16 Schonbrun v. SNAP, Inc., No. CV 21-7189 PSG (MRWx), 2022 U.S. Dist. LEXIS 104486, at

17 *8-*10 (C.D. Cal. May 17, 2022) (finding partner rate of $695 and $575 for fifth and sixth year

18 associates reasonable in comparison to the 2021 Real Rate Report, The Industry's Leading

19 Analysis of Law Firm Rates, Trends, and Practices identifying for commercial litigation a

20 median hourly rate of $901 for partners and $753 for associates); Ishiyama v. Glines, No. CV

21 16-07725-AB (ASx), 2018 U.S. Dist. LEXIS 223844, at *10 (C.D. Cal. Nov. 28, 2018)

22 (finding partner rates reasonable of $625 in 2017 and $650 in 2018). The discounted rates

23 underscore the reasonableness of the rates here.

24 Moreover, the time and resources spent on the services performed and fees incurred by

25 Svensson’s counsel were not only reasonable, but also necessary and justified given the nature

26 of the appeal and the continuing relationships of the parties. The appellate contentions of the

27 Headwaters Parties required the interpretation of Sections 1601 and 1602 and the decisional

28 authority, and counsel’s experience with similar inspection statutes from other jurisdictions and
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1 the rationales underlying those statutes. (Ram Decl. ¶ 14.) While the Headwaters Parties only

2 appealed this Court’s September 3, 2021 order, the interconnectedness between this action and

3 the Related Case required an expansive examination of the record in both cases, that ultimately

4 led Svensson to file a request for judicial notice to properly provide the Court of Appeal with

5 the necessary background, including the briefing on the motion to compel in the Related Case.

6 (Id.) The Court of Appeal granted that request. (Id., Ex. 4 at 3.) Critically, the appeal has

7 added importance to Svensson because Svensson remains a substantial shareholder and director

8 of iO73. Svensson’s success on appeal prevents, or at least deters, the Headwaters Parties from

9 continuing to frustrate Svensson’s rights and access to the documents and information of the

10 “touching companies” in the future – a point that Svensson even highlighted on the appeal.

11 The Headwaters Parties decided to prolong this litigation by pursuing the appeal,

12 despite the fact that they possessed the requested records and this Court’s factual

13 determinations. Svensson and his counsel necessarily defended this Court’s order, and as such,

14 the attorneys’ fees and costs Svensson incurred during the appeal were a direct result of iO73’s

15 continued resistance to Svensson’s statutory rights as a director and shareholder.

16 IV. CONCLUSION

17 For the foregoing reasons, Svensson respectfully requests that the Court award of

18 $87,591.50 in fees and $148.50 in costs.

19
DATED: December 5, 2022 STRADLING YOCCA CARLSON & RAUTH
20 A Professional Corporation
21

22 By:
Stephen L. Ram
23 Nicole L. Carbonel
Attorneys for Petitioner JONAS SVENSSON
24

28
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PROOF OF SERVICE
1
STATE OF CALIFORNIA )
2 ) ss
COUNTY OF ORANGE )
3
I am employed by Stradling Yocca Carlson & Rauth A Professional Corporation in the
4 County of Orange, State of California. I am over the age of 18 and not a party to the within
action. My business address is: 660 Newport Center Drive, Suite 1600, Newport Beach, CA
5 92660-6422. On December 5, 2022, I served the within documents:
6 NOTICE OF MOTION AND MOTION FOR ATTORNEYS’ FEES AND COSTS
BY PETITIONER JONAS SVENSSON IN THE AMOUNT OF $87,591.50 IN
7 FEES AND $148.50 IN COSTS; MEMORANDUM OF POINTS AND
AUTHORITIES XXX
8
By electronic service. Based on a court order or an agreement of the parties to accept
9 service by electronic transmission, I caused the above-referenced document(s) to be
10 sent to the person(s) at the electronic address(es) listed below.

11
Steven M. Selna Attorneys for Respondents iO73
12 steven@selnapartners.com INVESTMENTS, INC., and TRISTAN
Robert W. Selna STRAUSS
13 robert@selnapartners.com
14 SELNA PARTNERS LLP
70 Washington Street
15 Suite 303
Oakland, California 94607
16
(510) 387-8508
17
Naomi R. Dewey CO COUNSEL Attorneys for Respondents
18 naomi@trusted.legal iO73 INVESTMENTS, INC., and TRISTAN
Nicole Hornick STRAUSS
19 nicole@trusted.legal
TRUSTED LEGAL, PLC
20 21 E. Carillo Street
Suite 130
21
Santa Barbara, CA 93101
22
Tel: (805) 979-5160
23
I declare that I am employed in the office of a member of the bar of this court whose
24 direction the service was made. I declare under penalty of perjury under the laws of the State of
California that the above is true and correct.
25
Executed on December 5, 2022, at Newport Beach, California
26

27
_______________________________
28 Kim Kirkpatrick
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Case Info

Judge

Sterne, Colleen K Track Judge’s New Case

Case No.

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Document Filed Date

December 05, 2022

Case Filing Date

December 18, 2020

County

Parties

Condren, Alan D Attorney
Condren, Alan D Attorney
Dewey, Naomi R Attorney
iO73 Investments Inc Respondent
iO73 Investments Inc Respondent
Ram, Stephen L Attorney
Selna, Steven M Attorneys for Defendants
Selna, Steven M Attorney
Strauss, Tristan Respondent
Strauss, Tristan Respondent
Svensson, Jonas Petitioner
Svensson, Jonas Petitioner
Nicole Hornick Attorneys for Defendants
Colleen Sterne Attorney
Nicole Carbonel Attorneys for Plaintiffs
Thomas Anderle Attorney
Colleen Keeley Attorney
Robert Selna Attorneys for Defendants
David Allard Attorney

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Appellate Materials: Jonas Svensson vs iO73 Investments Inc et al

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Case Info

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