On April 10, 2014 a
Party Notice
was filed
involving a dispute between
Garcia, Phillip,
and
Carrie Wilson, In Her Capacitcy As Trustee Of The,
Does 1 To 20,
Markham, Erika,
Markham, Shaun,
Markham, Shawn,
Wilson, Angelo,
Wilson, Carrie,
for civil
in the District Court of San Francisco County.
Preview
LAW OFFICES OF BENNY MARTIN
Filed at the Insistence of the Litigant
Benjamin Martin (SBN 257452)
3245 Geary Street ELECTRONICALLY
PO Box 591477
San Francisco, CA 94118
FILED
Superior Court of California,
Phone: (510) 227-4406 County of San Francisco
Email: knowyourightsinsf@ gmail.com 01/21/2016
Attorneys for Plaintiff Phillip Garcia Clerk of the Court
BY:VANESSA WU.
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION
PHILLIP GARCIA, an individual, ) Case No. CGC-14-538560
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Plaintiff, PLAINTIFF PHILLIP GARCIA‘S
)
ll NOTICE OF LODGMENT OF
vs. ) EVIDENCE IN SUPPORT OF HIS
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) MOTION FOR SUMMARY
13 CARRIE WILSON, in her capacity as trustee of ADJUDICATION ON HIS SIXTH
THE WILSON FAMILY TRUST, SHAUN
)
) CAUSE OF ACTION
14 MARKHAM, an individual, ERIKA
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MARKHAM, an individual, and ANGELO ) Date: April 11, 2016
WILSON, an individual, and DOES 1-20. ) Time: 9:30 am.
) Dept: 501
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)
7 )
Defendants. )
)
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20 Plaintiff Phillip Garcia hereby gives notice that he lodged the following evidence in support
21 of his Motion for Summary Adjudication on His Sixth Cause of Action.
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. In Case No. CUD-13-645240 in San Francisco Superior Court, Angelo Wilson’s unlawful
23 detainer Complaint, filed May 3, 2013. A true and correct copy is attached as Exhibit A to
Request for Judicial Notice in Support of Plaintiff Phillip Garcia’s Motion to Summarily
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Adjudication his Sixth Cause of Action.
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In Case No. CUD-13-645240 in San Francisco Superior Court, Judgment, filed November 21,
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2013, pursuant to Evidence Code § 452(d) as it constitutes a record of the court of this state.
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PLAINTIFF PHILLIP GARCIA‘S NOTICE OF LODGMENT OF EVIDENCE IN SUPPORT OF HIS MOTION
FOR SUMMARY ADJUDICATION HIS SIXTH CAUSE OF ACTION
cI =
A true and correct copy is attached as Exhibit B to Request for Judicial Notice in Support of
Plaintiff Phillip Garcia’s Motion to Summarily Adjudication his Sixth Cause of Action.
In Case No. CUD-13-645240 in San Francisco Superior Court, Phillip Garcia’s Memorandum
of Costs, filed November 25, 2013. A true and correct copy is attached as Exhibit C to
Request for Judicial Notice in Support of Plaintiff Phillip Garcia’s Motion to Summarily
Adjudication his Sixth Cause of Action.
In Case No. CUD-13-645240 in San Francisco Superior Court, the Court’s February 14, 2014,
Order. A true and correct copy is attached as Exhibit D to Request for Judicial Notice in
Support of Plaintiff Phillip Garcia’s Motion to Summarily Adjudication his Sixth Cause of
Action.
10 In Case No. CGC-14-538560 in San Francisco Superior Court, Phillip Garcia’s 2nd Amended
ll Complaint (“SAC”) in this action was filed, filed July 31, 2014. A true and correct copy is
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attached as Exhibit E to Request for Judicial Notice in Support of Plaintiff Phillip Garcia’s
Motion to Summarily Adjudication his Sixth Cause of Action.
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In Case No. CUD-13-645240 in San Francisco Superior Court, Phillip Garcia’s Memorandum
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of Costs After Judgment, and Declaration of Accrued Interest, filed January 30, 2015. A true
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and correct copy is attached as Exhibit F to Request for Judicial Notice in Support of Plaintiff]
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Phillip Garcia’s Motion to Summarily Adjudication his Sixth Cause of Action.
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In Case No. CUD-13-645240 in San Francisco Superior Court, the Court’s March 27, 2015
18 Order. A true and correct copy is attached as Exhibit G to Request for Judicial Notice in
19 Support of Plaintiff Phillip Garcia’s Motion to Summarily Adjudication his Sixth Cause of
20 Action.
21 Phillip Garcia’s July 18, 2013, deposition transcript. A true and correct copy of the deposition
transcript is attached as Exhibit A to the Declaration of Plaintiffs Counsel Benny Martin in
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Support of Plaintiffs Motion to Summarily Adjudication His Sixth Cause of Action.
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The San Francisco Sheriff's Office’s Memorandum of Garnishee, dated August 20, 2014. A
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true and correct copy of the deposition transcript is attached as Exhibit B to the Declaration
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of Plaintiff's Counsel Benny Martin in Support of Plaintiff's Motion to Summarily
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Adjudication His Sixth Cause of Action.
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PLAINTIFF PHILLIP GARCIA‘S NOTICE OF LODGMENT OF EVIDENCE IN SUPPORT OF HIS MOTION
FOR SUMMARY ADJUDICATION ON HIS SIXTH CAUSE OF ACTION
cI 2 =
Writ of execution from San Francisco Superior Court, dated May 12, 2014. A true and correct
copy of the deposition transcript is attached as Exhibit C to the Declaration of Plaintiff's
Counsel Benny Martin in Support of Plaintiff's Motion to Summarily Adjudication His Sixth
Cause of Action.
Angelo Wilson’s verified his responses to Form Interrogatory No. 2.11, dated July 19, 2013.
A true and correct copy of the deposition transcript is attached as Exhibit D to the
Declaration of Plaintiff's Counsel Benny Martin in Support ofPlaintiffs Motion to
Summarily Adjudication His Sixth Cause of Action.
Angelo Wilson’s August 7, 2014 deposition transcript. A true and correct copy of the
deposition transcript is attached as Exhibit E to the Declaration of Plaintiffs Counsel Benny
10 Martin in Support of Plaintiff's Motion to Summarily Adjudication His Sixth Cause of
ll Action.
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A copy the generated search results for the name “Angelo Wilson” in the Public License
Information search field from the government California Department of Consumer Affairs,
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Bureau of Real Estate, dated September 30, 2015. A true and correct copy of the deposition
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transcript is attached as Exhibit F to the Declaration of Plaintiff's Counsel Benny Martin in
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Support of Plaintiff's Motion to Summarily Adjudication His Sixth Cause of Action.
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7 Dated: January 20, 2016 LAW OFFICES OF BENNY MARTIN
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By:
21 Benny Martin
Attorney for Plaintiff Garcia
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PLAINTIFF PHILLIP GARCIA‘S NOTICE OF LODGMENT OF EVIDENCE IN SUPPORT OF HIS MOTION
FOR SUMMARY ADJUDICATION ON HIS SIXTH CAUSE OF ACTION
Cao