Motion-Secondary: City of Needles -v- Cusson et al Print

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                                ~          ORIGINAL

     JOHN O. PINKNEY, Bar No. 162586                                    EXEMPT FROM FILING FEES PURSUANT
     LENA D. WADE, Bar No. 258356                                       TO GOVERNMENT CODE SECTION 6103
     SLOVAK BARON EMPEY MURPHY & PINKNEY LLP
     74785 Highway 111, Suite 105
     Indian Wells, CA 92210                                              SUPERIOR COURT OF CALIFORNIA
     Telephone: (760) 322-9240                                            COUNTY OF SAN BERNARDINO
                                                                            SAN BERNARDINO DISTRICT
     Facsimile: (760) 565-1189
     Email: wade@sbemp.com
                                                                               JUN 17 2021
     Attorneys for Plaintiff CITY OF NEEDLES


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                        SUPERIOR COURT OF THE STATE OF CALIFORNIA                                          -

                   COUNTY OF SAN BERNARDINO - SAN BERNARDINO DIVISION                                      m

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12    CITY OF NEEDLES, a Charter City,                      case No CIV SB 2 1 16            93      8
                                                            Assigned for All Purposes to:
13                   Plaintiff;
                                                            NOTICE OF EX PARTE APPLICATION
14            v                                             FOR WARRANT TO ABATE PUBLIC
15                                                          NUISANCES, APPLICATION AND
      LORRAINE L. CUSSON, a Joint Tenant;
                                                            MEMORANDUM OF POINTS AND
      WILLIAM SCHMIDT, a Joint Tenant;
16    COUNTRYWIDE TITLE CORPORATION,                        AUTHORITIES IN SUPPORT
      Beneficiary; and DOES       | through 10,             THEREOF
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      inclusive,                                               Date:    -—=p=2030- Ov ne    Q2 2021
18                                                            Time: 9:00-em. 8B BOAM
                     Defendants.                              Dept.:_   G26
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                                                            [Filed or lodged concurrently with:
20                                                               1 Declaration of Adrian Chavez; And
21                                                              2. [Proposed] Abatement Warrant.]

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                                                              Fting Fee in the amownt of §. 40- 00
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                                                                                     C3.5; 62630-88640)

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       NOTICE OF EX PARTE APPLICATION FOR WARRANT TO ABATE PUBLIC NUISANCES, APPLICATION
                    AND MEMORANDUM         OF POINTS AND AUTHORITIES       IN SUPPORT THEREOF
APPLICATION

            PLEASE TAKE NOTICE THAT on June22, 2021 at 30 a.m., or as soon thereafter as
     the matter can be heard, in Department $28 of the above entitled Court located at 247 West 3%

     Street, San Bernardino, California, Plaintiff City of Needles (“City”) will and hereby does move
     for an Abatement Warrant pursuant to California Code of Civil Procedure sections 1822.50 et seq.
     by ex parte application. City is seeking the issuance of an Abatement Warrant to abate a public
     nuisance on real property having APN #0486-144-23-0000, located at 511 Bazoobuth Street,
     Needles, California, owned by Defendants Lorraine L. Cusson and William Schmidt.           City also
     seeks an award of its attorney’s fees, costs and staff time charges incurred in connection herewith.
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il          This application is made pursuant to Code of Civil Procedure sections 1822.50 et seg.      This
12   application is based on the accompanying Memorandum of Points and Authorities, Declaration of
13   Chavez, and upon any oral and documentary evidence that may be presented to the Court.
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     Dated: June 15, 2021              SBEMP LLP
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17                                     LENA D. WADE
18                                     Attorneys for Plaintiff
                                       THE CITY OF NEEDLES
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      NOTICE OF EX PARTE APPLICATION FOR WARRANT TO ABATE PUBLIC NUISANCES, APPLICATION
                  AND MEMORANDUM        OF POINTS AND AUTHORITIES      IN SUPPORT THEREOF