Motion-Secondary: PETE G. CORRALES & CARMEN C. CORRALES TRUST Print

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                                LOUIE A. RUIZ (SBN:          309657)
     GEORGE V. KARR (SBN: 339298)                              ELECTRONICALLY FILED
     VISTAS LAW GROUP, LLP                                     SUPERIOR COURT OF CALIFORNIA
                                                               COUNTY OF SAN BERNARDINO
     430 N. Vineyard Ava, Suite 303                            SAN BERNARDINO DISTRICT
     Ontario, California 9 1 764
     Telephone:         (909) 4 1 5 -0540                      7/31/2023 12:23    PM
     Facsimile:              745 —8748
                        (2 1 3)
     Email:             1ruiz@ Vistaslawgroup.com              By: Elizabeth Aguilar,   DEPUTY
                        gkarr@vistaslawgroup.com




     Attorneys for Respondent,
     Lorraine Corrales



                              SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                            COUNTY OF SAN BERNARDINO
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                                                         Case No.: PROPSl 100680
12   IN   THE MATTER OF:                                 Honorable, Michelle Gilleece, Judge

13   PETEG. CORRALES AND CARMEN C.                       DECLARATION OF LOUIE A. RUIZ
     CORRALES REVOCABLE TRUST Dated                      IN SUPPORT OF THE MOTION TO
14   November 25, 1994                                   EXPUNGE NOTICE OF PENDENCY
                                                         ACTION AND FOR ATTORNEY’S
15                                                       FEES AND COSTS
16                                                        [C.C.P. § 405.30 et seq.]
     Gilbert Corrales,
17                                                        [Filed   and Served Concurrently with
                        Petitioner,                      Memorandum       ofPoints and Authorities;
18                                                       and [Proposed] Order]
           vs.
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     Lorraine Corrales,                                  Hearing Date:
20                                                       Time:
                         Respondent.                     Location:             S36
21                                                       Complaint    Filed:   June 18, 2019

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24                                      DECLARATION OF LOUIE A. RUIZ
25            I,   Louie A. Ruiz, declare:

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          DECLARATION OF LOUIE A. RUIZ IN SUPPORT OF THE MOTION TO EXPUNGE NOTICE OF
                    PENDENCY ACTION AND FOR ATTORNEY’S FEES AND COSTS
                1.          I   am a licensed California attorney with Vistas Law Group, LLP                                and the counsel 0f

     record for Respondent Lorraine Corrales (“Respondent”) herein. If called t0 testify in Court


     regarding this Declaration and                     its   contents,      I   could and would d0 so competently based 0n                my

     personal knowledge 0f the facts herein.


               2.           This Declaration             is   submitted in support 0f the          MOTION TO EXPUNGE NOTICE
     OF PENDENCY ACTION AND FOR ATTORNEY’S FEES AND COSTS against Petitioner

     Gilbert Corrales (the “Petitioner”).


               3.           On June         18,   2019, Petitioner filed his Petition (the “Petition”)per                     this   Court’s docket.


10   Attached hereto            is   a true and correct copy 0f the Petition and                  is    incorporated herein     by reference           as


11   Exhibit     1.   On July         12, 2019, Petitioner’s counsel,                 Harvey M. Payne,       III   recorded the July 12, 2019

12                                                 and cloud                 0n the Huntington Drive Property located
     Pendency Action             t0 slander                          title                                                          at   112 N.

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     Huntington Drive, Alhambra, California 91801 (the “Huntington Drive Property”). Attached hereto
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     is   a true and correct copy 0f the July 12, 2019 Pendency Action and                                  is   incorporated herein by
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     reference as Exhibit              2.
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               4.           On October 25,              2022,    I   emailed Petitioner’s counsel, Mr. Payne a meet and confer


18   letter   providing the legal and factual basis for the request t0 withdraw the July 12, 2019 Pendency


19   Action. Attached hereto                is    a true and correct copy 0f the October 25,                 2022-November           30,   2022 Meet

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     and Confer Emails between Mr. Ruiz and Mr. Payne and                                   is   incorporated herein by reference as

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     Exhibit     3.   Attached hereto             is   a true and correct copy 0f the October 25, 2022                     Meet and Confer
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     Letter and       is   incorporated herein by reference as Exhibit                      4.   On November         11,   2022, Mr. Payne
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     responded with an email providing that Petitioner disagrees with withdrawing the July 12, 2019
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25   Pendency Action and proposed an “undertaking” despite the                                    lis   pendens    statutes not requiring         an


26   undertaking.          On November 23,               2022, Iresponded by email providing that Respondent wanted t0

27   proceed with the motion t0 expunge.                          On November 29,          2023, Mr. Payne responded by email

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            DECLARATION OF LOUIE A. RUIZ IN SUPPORT OF THE MOTION TO EXPUNGE NOTICE OF
                      PENDENCY ACTION AND FOR ATTORNEY’S FEES AND COSTS
                                                                                     2