On June 15, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Barajas, Hugo,
and
for Petition for Letters of Administration
in the District Court of San Bernardino County.
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MATTHEW E. SHEASBY (SBN 197217) StggERIOR CQUIFFT Er
”N” 0F aLumRMA
SHEASBY AND ASSOCIATES SAN Bmwmwo
9227 Haven Avenue. Suite 280
Rancho Cucamon a, CA 91730 JUL 3 1 2023
Telephone: (909) 22-2543
Facsnmile: (909) 922-2544 \ '
/~
/ I
j
BY‘
Attorneys for Petitioner,
'
am” ”"0; Deputy
Hugo Barajas
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY 0F SAN BERNARDINO
In re the Petition of: Case No. PROSBZ300759
YOLANDA BARAJAS. NOTICE OF EX PARTE MOTION
FOR TEMPORARY
RESTRAINING ORDER AND
MOTION FOR PRELIMINARY
Hugo Barajas, Administrator of the Estate INJUNCTION AND FOR
of Yolanda Barajas AFFIRMATIVE RELIEF AGAINST
DEFENDANTS; AND
l6 v. MEMORANDUM OF POINTS AND
AUTHORITIES
l7
Martha Alicia Angulo Martinez, an
l8
Individual; Karina Ramirez. An Individual; (PROBATE CODE §850)
DOES l to 10.
2m
7
l9 DateAUG 0
Time: 9:00 am
20 Dept:
2|
3w
22 TO THE HONORABLE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF
23
RECORD:
24
Plaintiff, Hugo Barajas (hereinaficr referred to as “Plaintiff"), respectfully moves for
25
preliminary injunction against defendants, Martha Alicia Angulo Martinez, an Individual, and
26
27 Karina Ramirez, an Individual, (hereinafier collectively referred to as “Dcfcndants”):
28 l
NOTICE OF EX PARTE MOTION
1. For an Order that the monies held in Wells Fargo Account number XXXX5049 in
the name 0f Martha Alicia Angulo Martinez, Karina Ramirez, individually or jointly
with each other or with any third party. be frozen by Wells Fargo and that no funds
shall be distributed therefrom without prior court order.
2. That any and all funds held by Martha Alicia Angulo Martinez and Karina
Ramirez deriving from the proceeds of the sale of the residence at 13731 Newcastle
Court Fontana. California be delivered to Matthew Sheasby to be held in trust
pending further order of the court.
l0
3. For an order that Martha Alicia Angulo Martinez and Karina Ramirez not dispose
ll
12 of any funds held by them from the sale of the residence at I373] Newcastle Court
Fontana. California.
4. That Martha Alicia Angulo Martinez and Karina Ramirez be cited by the court to
appear at the next hearing
This Motion is made on the grounds that it appears by the motion and verified complaint
that Plaintiff is entitled to the relief requested, and the relief. or any part thereof, consists in
l9 restraining the commission or continuance of the act complained of pursuant to Code ofCivil
20
Procedure (C.C.P.) § 526, et seq., and that irreparable injury would result to the Estate if
2]
Defendants are not enjoined from further action.
22
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24 Dated: July 24, 2023 SHEASBY AND ASSOCIATES
25
26
27
atthew Sheasby
28
2
NOTICE OF EX PARTE MOTION
Document Filed Date
July 31, 2023
Case Filing Date
June 15, 2023
Category
Petition for Letters of Administration
Status
Under Court Supervision
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\r F l MATTHEW E. SHEASBY (SBN 197217) StggERIOR CQUIFFT Er ”N” 0F aLumRMA SHEASBY AND ASSOCIATES SAN Bmwmwo 9227 Haven Avenue. Suite 280 Rancho Cucamon a, CA 91730 JUL 3 1 2023 Telephone: (909) 22-2543 Facsnmile: (909) 922-2544 \ ' /~ / I j BY‘ Attorneys for Petitioner, ' am” ”"0; Deputy Hugo Barajas IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY 0F SAN BERNARDINO In re the Petition of: Case No. PROSBZ300759 YOLANDA BARAJAS. NOTICE OF EX PARTE MOTION FOR TEMPORARY RESTRAINING ORDER AND MOTION FOR PRELIMINARY Hugo Barajas, Administrator of the Estate INJUNCTION AND FOR of Yolanda Barajas AFFIRMATIVE RELIEF AGAINST DEFENDANTS; AND l6 v. MEMORANDUM OF POINTS AND AUTHORITIES l7 Martha Alicia Angulo Martinez, an l8 Individual; Karina Ramirez. An Individual; (PROBATE CODE §850) DOES l to 10. 2m 7 l9 DateAUG 0 Time: 9:00 am 20 Dept: 2| 3w 22 TO THE HONORABLE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF 23 RECORD: 24 Plaintiff, Hugo Barajas (hereinaficr referred to as “Plaintiff"), respectfully moves for 25 preliminary injunction against defendants, Martha Alicia Angulo Martinez, an Individual, and 26 27 Karina Ramirez, an Individual, (hereinafier collectively referred to as “Dcfcndants”): 28 l NOTICE OF EX PARTE MOTION 1. For an Order that the monies held in Wells Fargo Account number XXXX5049 in the name 0f Martha Alicia Angulo Martinez, Karina Ramirez, individually or jointly with each other or with any third party. be frozen by Wells Fargo and that no funds shall be distributed therefrom without prior court order. 2. That any and all funds held by Martha Alicia Angulo Martinez and Karina Ramirez deriving from the proceeds of the sale of the residence at 13731 Newcastle Court Fontana. California be delivered to Matthew Sheasby to be held in trust pending further order of the court. l0 3. For an order that Martha Alicia Angulo Martinez and Karina Ramirez not dispose ll 12 of any funds held by them from the sale of the residence at I373] Newcastle Court Fontana. California. 4. That Martha Alicia Angulo Martinez and Karina Ramirez be cited by the court to appear at the next hearing This Motion is made on the grounds that it appears by the motion and verified complaint that Plaintiff is entitled to the relief requested, and the relief. or any part thereof, consists in l9 restraining the commission or continuance of the act complained of pursuant to Code ofCivil 20 Procedure (C.C.P.) § 526, et seq., and that irreparable injury would result to the Estate if 2] Defendants are not enjoined from further action. 22 23 24 Dated: July 24, 2023 SHEASBY AND ASSOCIATES 25 26 27 atthew Sheasby 28 2 NOTICE OF EX PARTE MOTION