Motion-Secondary: PETE G. CORRALES & CARMEN C. CORRALES TRUST Print

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                                ELECTRONICALLY FILED
                                                           SUPERIOR COURT OF CALIFORNIA
                                                           COUNTY OF SAN BERNARDINO
                                                           FONTANA DISTRICT

                                                           1/11/2024 4:10 PM
 1 LOUIE A. RUIZ (SBN: 309657)
   GEORGE V. KARR (SBN: 339298)                            By: Nycole Patterson, DEPUTY
 2 VISTAS LAW GROUP, LLP
   430 N. Vineyard Ave., Suite 303
 3 Ontario, California 91764
   Telephone:     (909) 415-0540
 4 Facsimile:     (213) 745-8748
   Email:         lruiz@vistaslawgroup.com
 5                gkarr@vistaslawgroup.com
 6
   Attorneys for Respondent,
 7 Lorraine Corrales

 8
                         SUPERIOR COURT OF THE STATE OF CALIFORNIA
 9
                                   COUNTY OF SAN BERNARDINO
10

11                                                  Case No.: PROPS1100680
     IN THE MATTER OF:                              Honorable, Michelle Gilleece, Judge
12
   PETE G. CORRALES AND CARMEN C.                   DECLARATION OF LOUIE A. RUIZ
13 CORRALES REVOCABLE TRUST Dated                   IN SUPPORT OF THE EX PARTE
   November 25, 1994                                APPLICATION TO TRANSFER,
14 ________________________________________         COORDINATE, AND CONSOLIDATE
                                                    MATTERS; OR IN THE
15                                                  ALTERNATIVE; TO HEAR A
     Gilbert Corrales,                              MOTION TO TRANSFER,
16                                                  COORDINATE, AND CONSOLIDATE
                    Petitioner,                     MATTERS ON SHORTENED TIME
17
          vs.
18                                                  [Filed and Served Concurrently with
     Lorraine Corrales,                             Memorandum of Points and Authorities;
19                                                  Declaration of Lorraine Corrales; and
                    Respondent.                     [Proposed] Order]
20
                                                    [Cal. Civ. Proc. Code §§ 403, 404, 404.1,
21                                                  1005, 1048; Cal. Rules of Ct., Rules
                                                    3.1200 and 3.1300(b)]
22
                                                    Hearing Date:    January 17, 2024
23                                                  Time:         9:00 a.m.
                                                    Location:        F3
24                                                  Complaint Filed: September 26, 2011
25

26
                                  DECLARATION OF LOUIE A. RUIZ
27

28                                              1
           DECLARATION OF LOUIE A. RUIZ IN SUPPORT OF THE EX PARTE APPLICATION TO
         TRANSFER, COORDINATE, AND CONSOLIDATE MATTERS; OR IN THE ALTERNATIVE; TO
            HEAR A MOTION TO TRANSFER, COORDINATE, AND CONSOLIDATE MATTERS ON
                                      SHORTENED TIME
 1          I, LOUIE A. RUIZ, declare,
 2          1.      I am a licensed California attorney with VISTAS LAW GROUP, LLP, counsel of
 3
     record for Respondent Lorraine Corrales (the “Respondent”), in the above-captioned matter. If
 4
     called to testify in Court regarding this Declaration and its contents, I could and would do so
 5
     competently.
 6

 7          2.      This Declaration is in Support of Respondent’s EX PARTE APPLICATION

 8 TO TRANSFER, COORDINATE, AND CONSOLIDATE MATTERS; OR IN THE

 9 ALTERNATIVE; TO HEAR A MOTION TO TRANSFER, COORDINATE, AND
10
     CONSOLIDATE MATTERS ON SHORTENED TIME. Attached hereto is a true and
11
     correct copy of the operative June 18, 2019 Petition filed by Petitioner Gilbert Corrales
12
     (“Petitioner”) in this above-captioned matter, Case No. PROPS1100680 and is incorporated
13

14 herein by reference as Exhibit 1. Attached hereto is a true and correct copy of the operative

15 December 28, 2023 Petition filed by Respondent (“Petitioner”) in the Superior Court of

16 California, County of Orange, Case No. 30-2023-01369443-PR-TR-CMC and is incorporated

17
     herein by reference as Exhibit 2.
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            2.      Lead Case No. PROPS1100680 and Case No. 30-2023-01369443-PR-TR-CMC
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     involve common questions of law and fact, and the transfer and consolidation will reduce
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     unnecessary costs, preserve judicial resources, reduce inconveniences of the Parties and
21

22 witnesses, and avoid inconsistent judgments on identical issues of fact and law.

23          3.      Case No. PROPS1100680 began with Respondent filing on September 26,
24 2011 an “Ex Parte Petition for Instructions to Confirm that an Enforceable Declaration of Trust

25
     was Established and that Certain Assets are Held by the Successor Trustee of the Pete G.
26
27

28                                                      2
           DECLARATION OF LOUIE A. RUIZ IN SUPPORT OF THE EX PARTE APPLICATION TO
         TRANSFER, COORDINATE, AND CONSOLIDATE MATTERS; OR IN THE ALTERNATIVE; TO
            HEAR A MOTION TO TRANSFER, COORDINATE, AND CONSOLIDATE MATTERS ON
                                      SHORTENED TIME