On May 22, 2019 a
Party Discovery
was filed
involving a dispute between
Cruz, Nicole,
Mitchell, David,
The Lucas Corporation,
and
All Persons Claiming,
California Td Specialists,
Milligan, Jerilyn,
Milligan, Tim,
Nolan, Margaret Katherine,
Profit Sharing Plan,
Red Leaf Servicing,
Red Leaf Servicing, Inc.,
Red Leaf Servicing, Llc,
Rothchild, Jeffery,
Source Capital Funding, Inc.,
Tjm Real Estate Investments,
Tjm Real Estate Investments Inc.,
for Unlimited Civil Complaint - Real Property
in the District Court of San Bernardino County.
Preview
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\OOOQCNU‘IAL»
RandalP.Hannah,Es
LAW OFFICE OF RA DAL P. HANNAH
489 N. Central Avenue
Upland CA 91786
rhannai1@rphannahlaw.com
Telephone:
FaCSImile:
Attorne
‘
909%
.,
608-1220
SBN: 138778
909 608—1222)608-1222
for Plaintiffs,
NICOL CRUZ, ADMINISTRATOR 0F
THE ESTATE OF DAVID JOHN MITCHELL
and THE LUCAS CORPORATION
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
By
W ,
DANIEL
F I
_‘
L E
SUPERIOR COURT 0F CALIFORNIA
COUNTY 0F SAN BERNARDINO
SAN BERNARDINO DISTRICT
JUN 1
D
3 2023
.
IERLEIN.
.
DEPUTY
10 DAVID MITCHELL, an individual, and CASE NO. CIVD81915345
THE LUCAS CORPORATION, a vv
11 California corporation SUMMARY OF RESPONSES
12 Plaintiffs, [California Rules 0f Court 3.1312]
13 VS.
14 MARGARET KATHERINE NOLAN, an DATE: June ’7, 2023
individual; TJM REAL ESTATE vvvvvvvvvvvvvvv
TIME: 8:30 am.
15 INVESTMENTS PROFIT SHARE PLAN; DEPT: 829
TIM REAL ESTATE INVESTMENTS,
16 Ina, a California corporation; RED LEAF
SERVICING, 1110., a corporation; RED
17 LEAF SERVICING, LLC,a limited liability
compan ;REDILEAF SERVICING, a
18 palmers. ip; RED
LEAF SERVICING, a
30%firletorship; SOURCE CAPITAL
.19 F1. G, INC, a co oration, dba Red
Leaf Servicing; JEFF Y ROTHCHILD, an
20 individual; and all fiersons claiming by,
through, 0r undert em, any legal or
21 equitable, or right, title, estate, lien 0r
interest in the rogertsy described in this
22 complaint; an D E 1 through 50, vvvvvvvvvvvvvvv
inclusive,
23
Defendants.
24
25 MARGARET KATHERINE NOLAN, and
TIM MILLIGAN as CO—TRUSTEE 0f the
26 TJM REAL ESTATE INVESTMENTS,
INC. PROFIT SHARING PLAN AND VV
27 JERILYN MILLIGAN as CO-TRUSTEE 0f
the TJM REAL ES'I'ATE INVESTMENTS,
28 INC. PROFIT SHARING PLAN, vvvv
SUMMARY OF RESPONSES
1
Cross-Complainants, )
)
vs.
3
DAVID J. MITCHELL, and individual, and )
THE LUCAS CORPORATION, a )
Califomia co oration; GENERAL )
PROPERTIE INCORPORATED, a )
Koooflmmgwmr—A
Nevada corporation, and ROES 1 through )
20, inclusive, )
)
Cross—Defendants. )
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
Pursuant to Califomia Rules of Court, Rule 3.13 12, a summary 0f Defendants responses
t0 the Proposed Order submitted to this Court by Plaintiff, NICOLE CRUZ, ADMINISTRATOR
OF THE ESTATE OF DAVID JOHN MITCHELL and THE LUCAS CORPORATION,
herewith, is as follows:
1. Defendants served Objections to the Proposed Order proposing a specific dollar
amount be included in the Order. This is inconsistent with the final ruling 0f the Court. A true
and correct copy of the Defendants’ obj actions to the Proposed Order are attached hereto as
Exhibit “A”.
2. Plaintiffs respectfully request that the Court enter the Order With such
modifications as the Court deems appropriate for the written order to correspond with the
NNNNNNNNNHHr—tt—dr—IHHHHH
OO‘QQMLUJNHOWOQ‘QQM-DWNP‘C
Court’s ruling 0n June 7, 2023.
Dated: June 13,2023
LAW OFFICE OF RANDAL P. HANNAH
726%
R.ANDAI., P.
W
HANNAH Aftomey/for Plaintiffs,
NICOLE CRUZ, ADMINISTRATOR OF THE
ESTATE OF DAVID JOHN MITCHELL and
THE LUCAS CORPORATION
SUMMARY OF RESPONSES
2
Preview
k) \OOOQCNU‘IAL» RandalP.Hannah,Es LAW OFFICE OF RA DAL P. HANNAH 489 N. Central Avenue Upland CA 91786 rhannai1@rphannahlaw.com Telephone: FaCSImile: Attorne ‘ 909% ., 608-1220 SBN: 138778 909 608—1222)608-1222 for Plaintiffs, NICOL CRUZ, ADMINISTRATOR 0F THE ESTATE OF DAVID JOHN MITCHELL and THE LUCAS CORPORATION SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO By W , DANIEL F I _‘ L E SUPERIOR COURT 0F CALIFORNIA COUNTY 0F SAN BERNARDINO SAN BERNARDINO DISTRICT JUN 1 D 3 2023 . IERLEIN. . DEPUTY 10 DAVID MITCHELL, an individual, and CASE NO. CIVD81915345 THE LUCAS CORPORATION, a vv 11 California corporation SUMMARY OF RESPONSES 12 Plaintiffs, [California Rules 0f Court 3.1312] 13 VS. 14 MARGARET KATHERINE NOLAN, an DATE: June ’7, 2023 individual; TJM REAL ESTATE vvvvvvvvvvvvvvv TIME: 8:30 am. 15 INVESTMENTS PROFIT SHARE PLAN; DEPT: 829 TIM REAL ESTATE INVESTMENTS, 16 Ina, a California corporation; RED LEAF SERVICING, 1110., a corporation; RED 17 LEAF SERVICING, LLC,a limited liability compan ;REDILEAF SERVICING, a 18 palmers. ip; RED LEAF SERVICING, a 30%firletorship; SOURCE CAPITAL .19 F1. G, INC, a co oration, dba Red Leaf Servicing; JEFF Y ROTHCHILD, an 20 individual; and all fiersons claiming by, through, 0r undert em, any legal or 21 equitable, or right, title, estate, lien 0r interest in the rogertsy described in this 22 complaint; an D E 1 through 50, vvvvvvvvvvvvvvv inclusive, 23 Defendants. 24 25 MARGARET KATHERINE NOLAN, and TIM MILLIGAN as CO—TRUSTEE 0f the 26 TJM REAL ESTATE INVESTMENTS, INC. PROFIT SHARING PLAN AND VV 27 JERILYN MILLIGAN as CO-TRUSTEE 0f the TJM REAL ES'I'ATE INVESTMENTS, 28 INC. PROFIT SHARING PLAN, vvvv SUMMARY OF RESPONSES 1 Cross-Complainants, ) ) vs. 3 DAVID J. MITCHELL, and individual, and ) THE LUCAS CORPORATION, a ) Califomia co oration; GENERAL ) PROPERTIE INCORPORATED, a ) Koooflmmgwmr—A Nevada corporation, and ROES 1 through ) 20, inclusive, ) ) Cross—Defendants. ) TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: Pursuant to Califomia Rules of Court, Rule 3.13 12, a summary 0f Defendants responses t0 the Proposed Order submitted to this Court by Plaintiff, NICOLE CRUZ, ADMINISTRATOR OF THE ESTATE OF DAVID JOHN MITCHELL and THE LUCAS CORPORATION, herewith, is as follows: 1. Defendants served Objections to the Proposed Order proposing a specific dollar amount be included in the Order. This is inconsistent with the final ruling 0f the Court. A true and correct copy of the Defendants’ obj actions to the Proposed Order are attached hereto as Exhibit “A”. 2. Plaintiffs respectfully request that the Court enter the Order With such modifications as the Court deems appropriate for the written order to correspond with the NNNNNNNNNHHr—tt—dr—IHHHHH OO‘QQMLUJNHOWOQ‘QQM-DWNP‘C Court’s ruling 0n June 7, 2023. Dated: June 13,2023 LAW OFFICE OF RANDAL P. HANNAH 726% R.ANDAI., P. W HANNAH Aftomey/for Plaintiffs, NICOLE CRUZ, ADMINISTRATOR OF THE ESTATE OF DAVID JOHN MITCHELL and THE LUCAS CORPORATION SUMMARY OF RESPONSES 2