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1 DOMINIC V. SIGNOROTTI, SBN 267712
dominic@mckennabrink.com 7/26/2022
2 TANNER D. BRINK, SBN 244791
tanner@mckennabrink.com
3 MCKENNA | BRINK | SIGNOROTTI LLP
1350 Treat Blvd, Suite 105
4 Walnut Creek, CA 94597
Telephone: 925 433-5448
5 Facsimile: 844 230-2856
6 Attorneys for Defendant TIM ONDERKO
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SAN MATEO
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M C K ENNA |B RINK |S IGNOROTTI LLP
11 GOLDEN GLOBAL ENTERPRISES Case No. 22-CIV-02099
INC., a California Corporation; GOLDEN
12 GLOBAL INVESTMENT TRUST – 2017, NOTICE OF PETITION AND PETITION
W A L NUT C RE E K , CA
A T T ORNE YS A T L A W
by and through its Trustee, Donald A. TO COMPEL ARBITRATION
13 Wilson; and 8880 ELDER CREEK
HOLDINGS, a California limited liability Date: September 14, 2022
14 corporation, Time: 2:00 p.m.
Dept.: 2
15 Plaintiffs,
Action Filed: April 25, 2022
16 vs. Trial Date: None
17 TIM ONDERKO, an individual, and as
owner of a 49% interest in 8880 Elder
18 Creek Holdings, LLC, a California limited
liability corporation; and DOES 1-10,
19 inclusive,
20 Defendants.
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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
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NOTICE IS HEREBY GIVEN that the Petition to Compel Arbitration filed by Defendant
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Tim Onderko (“Defendants”) against Plaintiffs Golden Global Enterprises, Inc., Golden Global
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Investment Trust – 2017 and 8880 Elder Creek Holdings, LLC will be heard on September 14,
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2022 at 2:00 p.m., or as soon thereafter as the matter can be heard, in Department No. 2 of this
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Court.
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This Motion is based on this Notice, the records and papers on file herein, the accompanying
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NOTICE OF PETITION TO COMPEL ARBITRATION
1 Memorandum of Points and Authorities, the Declaration of Dominic Signorotti, the Declaration of
2 Tim Onderko and on such other evidence as may be presented at the hearing of this motion.
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Dated: July 25, 2022 MCKENNA | BRINK | SIGNOROTTI LLP
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By:
6 Dominic V. Signorotti
Tanner D. Brink
7 Attorneys for Defendant TIM ONDERKO
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M C K ENNA |B RINK |S IGNOROTTI LLP
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W A L NUT C RE E K , CA
A T T ORNE YS A T L A W
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NOTICE OF PETITION TO COMPEL ARBITRATION
1 PROOF OF SERVICE
Golden Global Enterprises Inc vs. Onderko
2 San Mateo Superior Court - Case No. 22-CIV-02099
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I, Aurora DeVilbiss, declare as follows:
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I am over the age of 18 and not a party to this action.
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I am a resident of or employed in the county where the mailing occurred; my business
6 address is: 1350 Treat Blvd, Suite 105, Walnut Creek, CA 94597.
7 On July 25, 2022, I served the parties indicated on the attached Service List the foregoing
document(s) described as:
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NOTICE OF PETITION AND PETITION TO COMPEL ARBITRATION
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☐ (by mail) I deposited such envelope in the mail at Walnut Creek, California with
10 postage thereon fully prepaid. I am aware that on motion of the party served,
service is presumed invalid if postal cancellation date or postage meter date is
M C K ENNA |B RINK |S IGNOROTTI LLP
11 more than one day after date of deposit for mailing in affidavit.
12 ☐ (by overnight delivery) by placing the document(s) listed above in a sealed
W A L NUT C RE E K , CA
A T T ORNE YS A T L A W
envelope and affixing a pre-paid air bill, and causing the envelope to be delivered
13 to a FedEx collection box at Walnut Creek, California, and addressed as set forth
below.
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☐ (by personal service) I caused such envelope to be delivered by hand via
15 messenger service to the address above;
16 ☐ (by facsimile) I served a true and correct copy by facsimile during regular
business hours to the number(s) listed above. Said transmission was reported
17 complete and without error.
18 ☒ (by email) on all parties by transmitting said document(s) from our offices by
email (aurora@mckennabrink.com) to email addresses shown below.
19 ** pursuant to CCP 1010.6, as amended on September 18, 2020**
20 I am readily familiar with the firm's practice of collection and processing correspondence
for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same
21 day with postage thereon fully prepaid in the ordinary course of business. I am aware that on
motion of the party served, service is presumed invalid if postal cancellation date or postage
22 meter date is more than one day after date of deposit for mailing in affidavit.
23 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
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25 DATED: July 25, 2022 __________________________________________
Aurora DeVilbiss
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NOTICE OF PETITION TO COMPEL ARBITRATION
1 SERVICE LIST
Golden Global Enterprises Inc vs. Onderko
2 San Mateo Superior Court - Case No. 22-CIV-02099
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Donald A. Wilson Tel : 650.366.8241
4 Wilson & Wilson wildon43@gmail.com
1695 Broadway St
5 Redwood City, CA 94063 Attorney for GOLDEN GLOBAL ENTERPRISES
6 and GLOBAL INVESTMENT TRUST-2017Y
7 John J. Hartford Tel : 650-366-7000
Attorney at Law hartfordjlaw@gmail.com
8 PO Box 685
Belmont, CA 94002 Attorney for GOLDEN GLOBAL ENTERPRISES
9 and GLOBAL INVESTMENT TRUST-2017Y
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4869-7262-6731, v. 1
M C K ENNA |B RINK |S IGNOROTTI LLP
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W A L NUT C RE E K , CA
A T T ORNE YS A T L A W
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NOTICE OF PETITION TO COMPEL ARBITRATION
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1 DOMINIC V. SIGNOROTTI, SBN 267712 dominic@mckennabrink.com 7/26/2022 2 TANNER D. BRINK, SBN 244791 tanner@mckennabrink.com 3 MCKENNA | BRINK | SIGNOROTTI LLP 1350 Treat Blvd, Suite 105 4 Walnut Creek, CA 94597 Telephone: 925 433-5448 5 Facsimile: 844 230-2856 6 Attorneys for Defendant TIM ONDERKO 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SAN MATEO 10 M C K ENNA |B RINK |S IGNOROTTI LLP 11 GOLDEN GLOBAL ENTERPRISES Case No. 22-CIV-02099 INC., a California Corporation; GOLDEN 12 GLOBAL INVESTMENT TRUST – 2017, NOTICE OF PETITION AND PETITION W A L NUT C RE E K , CA A T T ORNE YS A T L A W by and through its Trustee, Donald A. TO COMPEL ARBITRATION 13 Wilson; and 8880 ELDER CREEK HOLDINGS, a California limited liability Date: September 14, 2022 14 corporation, Time: 2:00 p.m. Dept.: 2 15 Plaintiffs, Action Filed: April 25, 2022 16 vs. Trial Date: None 17 TIM ONDERKO, an individual, and as owner of a 49% interest in 8880 Elder 18 Creek Holdings, LLC, a California limited liability corporation; and DOES 1-10, 19 inclusive, 20 Defendants. 21 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 22 NOTICE IS HEREBY GIVEN that the Petition to Compel Arbitration filed by Defendant 23 Tim Onderko (“Defendants”) against Plaintiffs Golden Global Enterprises, Inc., Golden Global 24 Investment Trust – 2017 and 8880 Elder Creek Holdings, LLC will be heard on September 14, 25 2022 at 2:00 p.m., or as soon thereafter as the matter can be heard, in Department No. 2 of this 26 Court. 27 This Motion is based on this Notice, the records and papers on file herein, the accompanying 28 1 NOTICE OF PETITION TO COMPEL ARBITRATION 1 Memorandum of Points and Authorities, the Declaration of Dominic Signorotti, the Declaration of 2 Tim Onderko and on such other evidence as may be presented at the hearing of this motion. 3 Dated: July 25, 2022 MCKENNA | BRINK | SIGNOROTTI LLP 4 5 By: 6 Dominic V. Signorotti Tanner D. Brink 7 Attorneys for Defendant TIM ONDERKO 8 9 10 M C K ENNA |B RINK |S IGNOROTTI LLP 11 12 W A L NUT C RE E K , CA A T T ORNE YS A T L A W 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- NOTICE OF PETITION TO COMPEL ARBITRATION 1 PROOF OF SERVICE Golden Global Enterprises Inc vs. Onderko 2 San Mateo Superior Court - Case No. 22-CIV-02099 3 I, Aurora DeVilbiss, declare as follows: 4 I am over the age of 18 and not a party to this action. 5 I am a resident of or employed in the county where the mailing occurred; my business 6 address is: 1350 Treat Blvd, Suite 105, Walnut Creek, CA 94597. 7 On July 25, 2022, I served the parties indicated on the attached Service List the foregoing document(s) described as: 8 NOTICE OF PETITION AND PETITION TO COMPEL ARBITRATION 9 ☐ (by mail) I deposited such envelope in the mail at Walnut Creek, California with 10 postage thereon fully prepaid. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is M C K ENNA |B RINK |S IGNOROTTI LLP 11 more than one day after date of deposit for mailing in affidavit. 12 ☐ (by overnight delivery) by placing the document(s) listed above in a sealed W A L NUT C RE E K , CA A T T ORNE YS A T L A W envelope and affixing a pre-paid air bill, and causing the envelope to be delivered 13 to a FedEx collection box at Walnut Creek, California, and addressed as set forth below. 14 ☐ (by personal service) I caused such envelope to be delivered by hand via 15 messenger service to the address above; 16 ☐ (by facsimile) I served a true and correct copy by facsimile during regular business hours to the number(s) listed above. Said transmission was reported 17 complete and without error. 18 ☒ (by email) on all parties by transmitting said document(s) from our offices by email (aurora@mckennabrink.com) to email addresses shown below. 19 ** pursuant to CCP 1010.6, as amended on September 18, 2020** 20 I am readily familiar with the firm's practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same 21 day with postage thereon fully prepaid in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage 22 meter date is more than one day after date of deposit for mailing in affidavit. 23 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 24 25 DATED: July 25, 2022 __________________________________________ Aurora DeVilbiss 26 27 28 -3- NOTICE OF PETITION TO COMPEL ARBITRATION 1 SERVICE LIST Golden Global Enterprises Inc vs. Onderko 2 San Mateo Superior Court - Case No. 22-CIV-02099 3 Donald A. Wilson Tel : 650.366.8241 4 Wilson & Wilson wildon43@gmail.com 1695 Broadway St 5 Redwood City, CA 94063 Attorney for GOLDEN GLOBAL ENTERPRISES 6 and GLOBAL INVESTMENT TRUST-2017Y 7 John J. Hartford Tel : 650-366-7000 Attorney at Law hartfordjlaw@gmail.com 8 PO Box 685 Belmont, CA 94002 Attorney for GOLDEN GLOBAL ENTERPRISES 9 and GLOBAL INVESTMENT TRUST-2017Y 10 4869-7262-6731, v. 1 M C K ENNA |B RINK |S IGNOROTTI LLP 11 12 W A L NUT C RE E K , CA A T T ORNE YS A T L A W 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -4- NOTICE OF PETITION TO COMPEL ARBITRATION