On July 25, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Chaney, Steven R,
and
Does 1 Through 50, Inclusive,
Green, Brenda Lee,
for Other non-PI/PD/WD Tort Unlimited
in the District Court of San Bernardino County.
Preview
V V
F | L E
SUPERIOR COURT 0F CALIFORNIA
COUNTY 0F SAN BERNARDINO
Scott J. Sheldon, SBN 290258 NOV 3 0 2022
Law Office 0f Scott J. Sheldon
10788 Civic Center Drive
Rancho Cucamonga, CA 91730
Telephone: (909) 660-3062
Email: sc0ttsheld0n@sheldonlawgroup.com
BY: jW a
'c
""amson- DePUtV
Attorney for Defendant, BRENDA LEE GREEN
\OOOQONKJI-PWNH
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
STEVEN R. CHANEY, an individual Case N0: CIVSB22161 94
Plaintiff, Assigned to: The Hon. Winston Keh
Dept. S33
NOTICE 0F MOTION AND MOTION TO
STRIKE PORTIONS 0F THE COMPLAINT
BRENDA LEE GREEN, an individual; and DOES OF PLAINTIFF STEVEN R. CHANEY;
1 through 50, inclusive, DECLARATION OF SCOTT J. SHELDON
Defendants. [Filed concurrently with Notice ofDemurrer and
Demurrer, and Requestfor Judicial Notice]
NNNNNNNNNHt—HHH—Hp—p—‘p—n
OOQQUI-tht—OOOONONUl-RWNP-‘O
Hearing Date: January 30, 2023
Time: 8:30 a.m.
Department: S33
Complaint Filed: July 25, 2022
Trial Date: Not Set
TO EACH PARTY AND COUNSEL OF RECORD FOR EACH PARTY:
YOU ARE HEREBY NOTIFIED that on the date and time set forth above, 0r as soon thereafter
as counsel may be heard in the above-identified department of the Superior Court of California, County
of San Bemardino, San Bemardino District — Civil Division, located at 247 West Third Street, San
Bernardino, California, 92415, Defendant, BRENDA LEE GREEN, will and hereby does bring a Motion
_ 1 _
NOTICE OF MOTION TO STRIKE OF BRENDA LEE GREEN
to Strike Portions of the Complaint of Plaintiff, STEVEN R. CHANEY. '
accompanying Demurrer and the Memorandum
’of
IQ This Motion is based upon this Notice, the
Defendant’s Request for Judicial
b)
Points and Authorities in support thereof filed concurrently herewith,
Notice filed concurrently herewith, the complete files and pleadings in this action,
and upon other and
further oral and documentary evidence as may be introduced at the time of the hearing on this Demurrer.
The portions of the Complaint that are requested t0 be stricken are:
xooowom-b
1. Paragraph Seven (7), in its entirety.
2. The portion 0f Paragraph 9 on Page 3, Lines 16: 17 stating, “and discovery that the terms of
had been changed by defendant, giving herself all of plaintiff‘s estate.”
plaintiff’s will
3. The portion ofParagraph 12 on Page 4, Lines 5-6 stating, “Additionally, as alleged herein,
without plaintiff s consent or knowledge, defendant made changes to plaintiff s will, that
plaintiff was not aware of until after the POA was revoked,”
4. Paragraph Thirteen (13), in its entirety.
This request is on the basis that the above-identified portions of the Complaint are irrelevant, false, or
improper.
Dated: November zq , 2022
Scott J. Sfigldon, Esq.
Anomey for Attorney for Defendant,
BRENDA LEE GREEN
- 2 -
NOTICE OF MOTION TO STRIKE OF BRENDA LEE GREEN
Document Filed Date
November 30, 2022
Case Filing Date
July 25, 2022
Category
Other non-PI/PD/WD Tort Unlimited
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V V F | L E SUPERIOR COURT 0F CALIFORNIA COUNTY 0F SAN BERNARDINO Scott J. Sheldon, SBN 290258 NOV 3 0 2022 Law Office 0f Scott J. Sheldon 10788 Civic Center Drive Rancho Cucamonga, CA 91730 Telephone: (909) 660-3062 Email: sc0ttsheld0n@sheldonlawgroup.com BY: jW a 'c ""amson- DePUtV Attorney for Defendant, BRENDA LEE GREEN \OOOQONKJI-PWNH SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO STEVEN R. CHANEY, an individual Case N0: CIVSB22161 94 Plaintiff, Assigned to: The Hon. Winston Keh Dept. S33 NOTICE 0F MOTION AND MOTION TO STRIKE PORTIONS 0F THE COMPLAINT BRENDA LEE GREEN, an individual; and DOES OF PLAINTIFF STEVEN R. CHANEY; 1 through 50, inclusive, DECLARATION OF SCOTT J. SHELDON Defendants. [Filed concurrently with Notice ofDemurrer and Demurrer, and Requestfor Judicial Notice] NNNNNNNNNHt—HHH—Hp—p—‘p—n OOQQUI-tht—OOOONONUl-RWNP-‘O Hearing Date: January 30, 2023 Time: 8:30 a.m. Department: S33 Complaint Filed: July 25, 2022 Trial Date: Not Set TO EACH PARTY AND COUNSEL OF RECORD FOR EACH PARTY: YOU ARE HEREBY NOTIFIED that on the date and time set forth above, 0r as soon thereafter as counsel may be heard in the above-identified department of the Superior Court of California, County of San Bemardino, San Bemardino District — Civil Division, located at 247 West Third Street, San Bernardino, California, 92415, Defendant, BRENDA LEE GREEN, will and hereby does bring a Motion _ 1 _ NOTICE OF MOTION TO STRIKE OF BRENDA LEE GREEN to Strike Portions of the Complaint of Plaintiff, STEVEN R. CHANEY. ' accompanying Demurrer and the Memorandum ’of IQ This Motion is based upon this Notice, the Defendant’s Request for Judicial b) Points and Authorities in support thereof filed concurrently herewith, Notice filed concurrently herewith, the complete files and pleadings in this action, and upon other and further oral and documentary evidence as may be introduced at the time of the hearing on this Demurrer. The portions of the Complaint that are requested t0 be stricken are: xooowom-b 1. Paragraph Seven (7), in its entirety. 2. The portion 0f Paragraph 9 on Page 3, Lines 16: 17 stating, “and discovery that the terms of had been changed by defendant, giving herself all of plaintiff‘s estate.” plaintiff’s will 3. The portion ofParagraph 12 on Page 4, Lines 5-6 stating, “Additionally, as alleged herein, without plaintiff s consent or knowledge, defendant made changes to plaintiff s will, that plaintiff was not aware of until after the POA was revoked,” 4. Paragraph Thirteen (13), in its entirety. This request is on the basis that the above-identified portions of the Complaint are irrelevant, false, or improper. Dated: November zq , 2022 Scott J. Sfigldon, Esq. Anomey for Attorney for Defendant, BRENDA LEE GREEN - 2 - NOTICE OF MOTION TO STRIKE OF BRENDA LEE GREEN