On June 17, 2021 a
Criminal Matters
was filed
involving a dispute between
City Of Needles,
and
Countrywide Title Corporation,
Cusson, Lorraine L,
Does 1 Through 10,
Schmidt, William,
for Other Complaint (Not Spec) Unlimited
in the District Court of San Bernardino County.
Preview
V OR‘UINI‘U— v
JOHN O. PINKNEY, Bar N0. 162586 EXEMPT FROM FILING FEES PURSUANT
TO GOVERNMENT CODE SECTION 6103
LENA D. WADE, Bar N0. 258356
SLOVAK BARON EMPEY MURPHY & PINKNEY LLP F —-u-
74785 Highway 111, Suite 105
i L
SUPERIOR COURT 0F CAL;
Indian Wells, CA 92210 COUNTY 0F SAN BERNARFEfiSg'A
SAN BERNARDINO DISTRICT
Telephone: (760) 322—9240
Facsimile: (760) 565-1 1 89 JUN
W
\OWQQUIhMNh-fi
1:7 2021
Email: wade@sbemp.com
OF NEEDLES BY
Attorneys for Plaintiff CITY
JO ANNA LEA %: z“DEPUTY
;
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO — SAN BERNARDINO DIVISION II:i
LLP
CITY OF NEEDLES, a Charter City, Case No.: C‘ SB 21 18 93 8,”,
Assigned for Al Purposes to:
Plaintiff;
A
Pinkney
DECLARATION OF SENIOR CODE
105
& Suite
1,
92210
V. ENFORCEMENT OFFICER ADRIAN
Murphy
11 CA
LORRAINE L. CUSSON, a Joint Tenant;
CHAVEZ IN SUPPORT OF
Wells,
WILLIAM SCHMIDT, a Joint Tenant; APPLICATION FOR WARRANT TO XVj
Empey
Highway
COUNTRYWIDE TITLE CORPORATION, ABATE PUBLIC NUISANCES
Baron
Indian
Beneficiary; and DOES through 10, 1
74-785
NNNNNNNNNHHHHHHHt—tt—tr—t
inclusive, [Filed 0r lodged concurrently with:
Slovak
1. Notice of Ex Parte Application for
Defendants. Warrant to Abate Public Nuisances,
Application and Memorandum 0f
OO\I¢NUI&OJNHO\OOOQO\UIBDJNH©
Points and Authorities in Support
Thereof, and Declaration of 24 Hours
Notice; and
2. (Proposed) Abatement Warrant]
I, ADRIAN CHAVEZ, declare as follows:
1. l am, and at all times material t0 this declaration, have been, employed as the Senior
Code Enforcement Officer by City 0f Needles, California (“City”). If called, I could and would
competently testify t0 the following.
1
DECLARATION OF SENIOR CODE ENFORCEMENT OFFICER ADRIAN CHAVEZ lN SUPPORT OF
APPLICATION FOR WARRANT TO ABATE PUBLIC NUISANCES
Document Filed Date
June 17, 2021
Case Filing Date
June 17, 2021
Category
Other Complaint (Not Spec) Unlimited
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V OR‘UINI‘U— v JOHN O. PINKNEY, Bar N0. 162586 EXEMPT FROM FILING FEES PURSUANT TO GOVERNMENT CODE SECTION 6103 LENA D. WADE, Bar N0. 258356 SLOVAK BARON EMPEY MURPHY & PINKNEY LLP F —-u- 74785 Highway 111, Suite 105 i L SUPERIOR COURT 0F CAL; Indian Wells, CA 92210 COUNTY 0F SAN BERNARFEfiSg'A SAN BERNARDINO DISTRICT Telephone: (760) 322—9240 Facsimile: (760) 565-1 1 89 JUN W \OWQQUIhMNh-fi 1:7 2021 Email: wade@sbemp.com OF NEEDLES BY Attorneys for Plaintiff CITY JO ANNA LEA %: z“DEPUTY ; SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO — SAN BERNARDINO DIVISION II:i LLP CITY OF NEEDLES, a Charter City, Case No.: C‘ SB 21 18 93 8,”, Assigned for Al Purposes to: Plaintiff; A Pinkney DECLARATION OF SENIOR CODE 105 & Suite 1, 92210 V. ENFORCEMENT OFFICER ADRIAN Murphy 11 CA LORRAINE L. CUSSON, a Joint Tenant; CHAVEZ IN SUPPORT OF Wells, WILLIAM SCHMIDT, a Joint Tenant; APPLICATION FOR WARRANT TO XVj Empey Highway COUNTRYWIDE TITLE CORPORATION, ABATE PUBLIC NUISANCES Baron Indian Beneficiary; and DOES through 10, 1 74-785 NNNNNNNNNHHHHHHHt—tt—tr—t inclusive, [Filed 0r lodged concurrently with: Slovak 1. Notice of Ex Parte Application for Defendants. Warrant to Abate Public Nuisances, Application and Memorandum 0f OO\I¢NUI&OJNHO\OOOQO\UIBDJNH© Points and Authorities in Support Thereof, and Declaration of 24 Hours Notice; and 2. (Proposed) Abatement Warrant] I, ADRIAN CHAVEZ, declare as follows: 1. l am, and at all times material t0 this declaration, have been, employed as the Senior Code Enforcement Officer by City 0f Needles, California (“City”). If called, I could and would competently testify t0 the following. 1 DECLARATION OF SENIOR CODE ENFORCEMENT OFFICER ADRIAN CHAVEZ lN SUPPORT OF APPLICATION FOR WARRANT TO ABATE PUBLIC NUISANCES