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CANDICE N. HAMANT, ESQ. (SB# 184016)
Chamant@tysonmendes.com
S. MICHAEL LEE (SB# 199007) erior Courtof Calitomia
SupCaninhe =
lee@tysonmendes.com
TYSON & MENDES LLP
371 Bel Marin Keys Blvd., Suite 100
DEC 13 2023
Novato, CA 94949
Telephone: (628) 253-5070 a
Facsimile: (628) 299-7764
Attorneys for Defendant,
STACEY SOLOMAN (erroneously sued as “STACY SOLOMAN”)
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
10
Case No.: CGC-23-605806
11 SHARON ALLEN | to 500 JOHN & JANE DOES|
Ode c
PROPOSED
12 Plaintiffs, GRANTING STACEY SOLOMAN’S
SPECIAL MOTION TO STRIKE
13 Vv PURSUANT TO CODE OF CIVIL
PROCEDURE SECTION 425.16
14 RELATED MANAGEMENT CO., LA SALLE (ANTI-SLAPP MOTION)
APT. BUILDING COMPLEX CO., STACY
15 SOLOMAN and Does 1-500 DEPT: 501
16 Case Filed: April 13, 2023
Defendants. Trial Date: Not Set
17
18 [PROPOSED] JEDEMENT Order
19 The special motion to strike pursuant to Code of Civil Procedure section 425.16 (“Anti-
20 SLAPP Motion”) of defendant STACEY SOLOMAN erroneously sued as “STACY
21 SOLOMAN?”), came on regularly for hearing on August 29, 2023 at 9:30 a.m. in Department 501
22 of the above-entitled court, located at 400 McAllister Street, San Francisco, California. At that
23 hearing, the court granted the motion to strike. Plaintiff filed a motion for reconsideration, and a
24 motion for reconsideration of the dismissal pursuant to the Motion to Strike came on regularly for
25 hearing on October 10, 2023, in Department 501, of the above-entitled court. S. Michael Lee with
26 Tyson & Mendes, LLP appeared on behalf of defendants. Upon due consideration, having read and
27 considered the moving and opposing papers and having heard and considered oral arguments, the
28
1
[PROPOSED] ORDER GRANTING STACEY SOLOMAN’S SPECIAL MOTION TO STRIKE PURSUANT
TO CODE OF CIVIL PROCEDURE SECTION 425.16 (ANTI-SLAPP MOTION)
court denied plaintiff Sharon Allen’s motion for reconsideration. Therefore, the court’s prior
dismissal pursuant to Code of Civil Procedure section 425.16, commonly referred to as the Anti-
SLAPP statute is affirmed.
After full consideration of the moving and opposition papers and counsels’ oral argument,
and after good cause having been shown, the Court adopts its tentative ruling published on
August 29, 2023, which states as follows:
DEFENDANT STACEY SOLOMAN'S SPECIAL MOTION TO STRIKE
PURSUANT TO CODE OF CIVIL PROCEDURE SECTION 425.16 (ANTI-
SLAPP MOTION) is GRANTED. Moving party met its burden under the first
prong. On August 25, 2023, Plaintiff filed documents, which may be construed as
10 an opposition. It is not clear if these documents have been served. This opposition
would be untimely and does not appear to contain argument or evidence that
11 would meet the requirements under the second prong of the Anti-Slapp statute.
12
13 IT IS SO ORDERED
14
15 Dated: / o/ (3/ Po 22.2003
16
17 Ub) Cus
\W - Honorable Judge Charles F. Haines
18
19
20
21
22
23
24
25
26
27
28
2
[PROPOSED] ORDER GRANTING STACEY SOLOMAN’S SPECIAL MOTION TO STRIKE PURSUANT
TO CODE OF CIVIL PROCEDURE SECTION 425.16 (ANTI-SLAPP MOTION)
‘ \ -
"” [MJTYSON & MENDES
S. MICHAEL LEE 371 BEL MARIN KEYS BLVD, SUITE 100
MLEE@TYSONMENDES.COM NOVATO, CA 94949
DIRECT: 628-236-3321 PHONE: (628) 253-5070 FAX: (628) 299-7764
October 30, 2023
Via US Mail
Ms. Sharon Allen
225 Berry Street, #321
San Francisco, CA 94158
Re: Sharon Allen_and I to 500 John & Jane Does v Related Management Co., La
Salle Apt. Building Complex Co., Stacy Soloman and Does One to 500
San Francisco County Superior Court Case No.: CGC-23-605806
Our Client: Stacey Soloman
Dear Ms. Allen,
We represent the interests of Ms. Stacey Solomon. The purpose of this letter is to ask you to review
the proposed judgment we intend to send to the court for the case against Ms. Soloman. The actual
proposed judgment is below.
As you are aware, your case against Ms. Soloman was dismissed by the court on August 29, 2023,
by Judge Anne-Christine Massullo in Department 610.
The motion, filed by Mr. Wright on your behalf, for reconsideration of the August 29, 2023
dismissal was denied on October 10, 2023.
This is an explanation of what occurred. The court often publishes a tentative ruling prior to a
motion’s hearing date. On the hearing date, if the court does not change its ruling, the tentative
ruling becomes the final ruling. On October 10, 2023, the court’s tentative ruling denying the motion
to reconsider became the final ruling. Thus, the motion to reconsider has been denied. The case as to
Ms. Soloman remains dismissed.
The party that prevails in a case writes the judgment, or judge’s order. They then send a copy of the
proposed order to the other side to ask if they approve of the language. If there is no issue, the judge
will sign the judgment.
That is why we have included a copy of our proposed language for the “JUDGMENT OF
DISMISSAL AFTER GRANTING OF SPECIAL MOTION TO STRIKE COMPLAINT
PURSUANT TO C.C.P. §425.16 (“ANTI-SLAPP MOTION”)” below. Please review it.
SEE EXHIBIT “A’ RE
COMPLIANCE WITH CRC 3.1312
2
¥ =e
Ms. Sharon Allen
October 30, 2023
Page 2
Please sign above the line which states “SHARON ALLEN, pro per plaintiff” if you approve the
language in the proposed judgment. Then return the signed document to us by mail.
Tf you do not approve of the language in the proposed judgment, please indicate why you do not
approve and how you would change the language in order to make it acceptable. Then returned the
annotated document to us by mail.
As always, please feel free to call me directly at 628-236-3321 should you have any questions or
concerns.
Sincerely,
eS
S. Michael Lee
Enclosure: [Proposed] Judgment of Dismissal
Self-addressed Stamped Envelope
—
INZ| TYSON & MENDES
S. MICHAEL LEE 371 BEL MARIN KEYS BLVD, SUITE 100
MLEE@TYSONMENDES.COM NOVATO, CA 94949
DIRECT: 628-236-3321 PHONE: (628) 253-5070 FAX: (628) 299-7764
CANDICE N. HAMANT, ESQ. (SB# 184016)
Chamant@tysonmendes.com
S. MICHAEL LEE, ESQ. (SB # 199007)
mlee@tysonmendes.com
TYSON & MENDES LLP
371 Bel Marin Keys Bivd., Suite 100
Novato, CA 94949
Telephone: (628) 253-5070
Facsimile: (628) 299-7764
Attorneys for Defendant,
STACEY SOLOMAN erroneously sued as “STACY SOLOMAN”)
COVER LETTER FOR CLERK OF THE COURT
Case Number: CGC-23-605806
San Francisco County Superior Court
Department 501
Honorable Judge
Enclosed, please find the proposed Order for the Special Motion to Strike Pursuant to Code of Civil
Procedure Section 425.16 (Anti-Slapp Motion). The proposed order was mailed to plaintiff's home
at 225 Berry Street, #321 on October 30, 2023 via regular United States mail. A copy of the letter is
enclosed for the convenience of the court. The letter included a self-addressed stamped envelope to
allow plaintiff to return the signed judgment or any comments conveniently and without incurring
any expenses.
Respectfully submitted,
ee
Candice Hamant
S. Michael Lee
Attorneys for Defendant
Stacey Soloman
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CANDICE N. HAMANT, ESQ. (SB# 184016) Chamant@tysonmendes.com S. MICHAEL LEE (SB# 199007) erior Courtof Calitomia SupCaninhe = lee@tysonmendes.com TYSON & MENDES LLP 371 Bel Marin Keys Blvd., Suite 100 DEC 13 2023 Novato, CA 94949 Telephone: (628) 253-5070 a Facsimile: (628) 299-7764 Attorneys for Defendant, STACEY SOLOMAN (erroneously sued as “STACY SOLOMAN”) SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO 10 Case No.: CGC-23-605806 11 SHARON ALLEN | to 500 JOHN & JANE DOES| Ode c PROPOSED 12 Plaintiffs, GRANTING STACEY SOLOMAN’S SPECIAL MOTION TO STRIKE 13 Vv PURSUANT TO CODE OF CIVIL PROCEDURE SECTION 425.16 14 RELATED MANAGEMENT CO., LA SALLE (ANTI-SLAPP MOTION) APT. BUILDING COMPLEX CO., STACY 15 SOLOMAN and Does 1-500 DEPT: 501 16 Case Filed: April 13, 2023 Defendants. Trial Date: Not Set 17 18 [PROPOSED] JEDEMENT Order 19 The special motion to strike pursuant to Code of Civil Procedure section 425.16 (“Anti- 20 SLAPP Motion”) of defendant STACEY SOLOMAN erroneously sued as “STACY 21 SOLOMAN?”), came on regularly for hearing on August 29, 2023 at 9:30 a.m. in Department 501 22 of the above-entitled court, located at 400 McAllister Street, San Francisco, California. At that 23 hearing, the court granted the motion to strike. Plaintiff filed a motion for reconsideration, and a 24 motion for reconsideration of the dismissal pursuant to the Motion to Strike came on regularly for 25 hearing on October 10, 2023, in Department 501, of the above-entitled court. S. Michael Lee with 26 Tyson & Mendes, LLP appeared on behalf of defendants. Upon due consideration, having read and 27 considered the moving and opposing papers and having heard and considered oral arguments, the 28 1 [PROPOSED] ORDER GRANTING STACEY SOLOMAN’S SPECIAL MOTION TO STRIKE PURSUANT TO CODE OF CIVIL PROCEDURE SECTION 425.16 (ANTI-SLAPP MOTION) court denied plaintiff Sharon Allen’s motion for reconsideration. Therefore, the court’s prior dismissal pursuant to Code of Civil Procedure section 425.16, commonly referred to as the Anti- SLAPP statute is affirmed. After full consideration of the moving and opposition papers and counsels’ oral argument, and after good cause having been shown, the Court adopts its tentative ruling published on August 29, 2023, which states as follows: DEFENDANT STACEY SOLOMAN'S SPECIAL MOTION TO STRIKE PURSUANT TO CODE OF CIVIL PROCEDURE SECTION 425.16 (ANTI- SLAPP MOTION) is GRANTED. Moving party met its burden under the first prong. On August 25, 2023, Plaintiff filed documents, which may be construed as 10 an opposition. It is not clear if these documents have been served. This opposition would be untimely and does not appear to contain argument or evidence that 11 would meet the requirements under the second prong of the Anti-Slapp statute. 12 13 IT IS SO ORDERED 14 15 Dated: / o/ (3/ Po 22.2003 16 17 Ub) Cus \W - Honorable Judge Charles F. Haines 18 19 20 21 22 23 24 25 26 27 28 2 [PROPOSED] ORDER GRANTING STACEY SOLOMAN’S SPECIAL MOTION TO STRIKE PURSUANT TO CODE OF CIVIL PROCEDURE SECTION 425.16 (ANTI-SLAPP MOTION) ‘ \ - "” [MJTYSON & MENDES S. MICHAEL LEE 371 BEL MARIN KEYS BLVD, SUITE 100 MLEE@TYSONMENDES.COM NOVATO, CA 94949 DIRECT: 628-236-3321 PHONE: (628) 253-5070 FAX: (628) 299-7764 October 30, 2023 Via US Mail Ms. Sharon Allen 225 Berry Street, #321 San Francisco, CA 94158 Re: Sharon Allen_and I to 500 John & Jane Does v Related Management Co., La Salle Apt. Building Complex Co., Stacy Soloman and Does One to 500 San Francisco County Superior Court Case No.: CGC-23-605806 Our Client: Stacey Soloman Dear Ms. Allen, We represent the interests of Ms. Stacey Solomon. The purpose of this letter is to ask you to review the proposed judgment we intend to send to the court for the case against Ms. Soloman. The actual proposed judgment is below. As you are aware, your case against Ms. Soloman was dismissed by the court on August 29, 2023, by Judge Anne-Christine Massullo in Department 610. The motion, filed by Mr. Wright on your behalf, for reconsideration of the August 29, 2023 dismissal was denied on October 10, 2023. This is an explanation of what occurred. The court often publishes a tentative ruling prior to a motion’s hearing date. On the hearing date, if the court does not change its ruling, the tentative ruling becomes the final ruling. On October 10, 2023, the court’s tentative ruling denying the motion to reconsider became the final ruling. Thus, the motion to reconsider has been denied. The case as to Ms. Soloman remains dismissed. The party that prevails in a case writes the judgment, or judge’s order. They then send a copy of the proposed order to the other side to ask if they approve of the language. If there is no issue, the judge will sign the judgment. That is why we have included a copy of our proposed language for the “JUDGMENT OF DISMISSAL AFTER GRANTING OF SPECIAL MOTION TO STRIKE COMPLAINT PURSUANT TO C.C.P. §425.16 (“ANTI-SLAPP MOTION”)” below. Please review it. SEE EXHIBIT “A’ RE COMPLIANCE WITH CRC 3.1312 2 ¥ =e Ms. Sharon Allen October 30, 2023 Page 2 Please sign above the line which states “SHARON ALLEN, pro per plaintiff” if you approve the language in the proposed judgment. Then return the signed document to us by mail. Tf you do not approve of the language in the proposed judgment, please indicate why you do not approve and how you would change the language in order to make it acceptable. Then returned the annotated document to us by mail. As always, please feel free to call me directly at 628-236-3321 should you have any questions or concerns. Sincerely, eS S. Michael Lee Enclosure: [Proposed] Judgment of Dismissal Self-addressed Stamped Envelope — INZ| TYSON & MENDES S. MICHAEL LEE 371 BEL MARIN KEYS BLVD, SUITE 100 MLEE@TYSONMENDES.COM NOVATO, CA 94949 DIRECT: 628-236-3321 PHONE: (628) 253-5070 FAX: (628) 299-7764 CANDICE N. HAMANT, ESQ. (SB# 184016) Chamant@tysonmendes.com S. MICHAEL LEE, ESQ. (SB # 199007) mlee@tysonmendes.com TYSON & MENDES LLP 371 Bel Marin Keys Bivd., Suite 100 Novato, CA 94949 Telephone: (628) 253-5070 Facsimile: (628) 299-7764 Attorneys for Defendant, STACEY SOLOMAN erroneously sued as “STACY SOLOMAN”) COVER LETTER FOR CLERK OF THE COURT Case Number: CGC-23-605806 San Francisco County Superior Court Department 501 Honorable Judge Enclosed, please find the proposed Order for the Special Motion to Strike Pursuant to Code of Civil Procedure Section 425.16 (Anti-Slapp Motion). The proposed order was mailed to plaintiff's home at 225 Berry Street, #321 on October 30, 2023 via regular United States mail. A copy of the letter is enclosed for the convenience of the court. The letter included a self-addressed stamped envelope to allow plaintiff to return the signed judgment or any comments conveniently and without incurring any expenses. Respectfully submitted, ee Candice Hamant S. Michael Lee Attorneys for Defendant Stacey Soloman