On October 11, 2023 a
Order
was filed
involving a dispute between
San Bernardino County Transportation Authority,
and
All Persons Unknown Claiming An Interest In The Property,
City Of Riverside,
Does 1 Through 100, Inclusive,
Jeffries, James W,
Jeffries, Sharen K,
Journey West Motors, Inc,
Riverside Water Company,
The Heirs And Devisees Of James L. Johnson,
Trinh, Lan To,
Wfg National Title Company Of California,
for Eminent Domain/Inv Cond Unlimited
in the District Court of San Bernardino County.
Preview
Fee Exempt Per Gov. Code § 6103
WOODRUFF & SMART, APC
CRAIG G. FARRINGTON - State Bar N0. 125274
ELECTRONICALLY FILED
cfarrington@woodruff.law SUPERIOR COURT OF CALIFORNIA
ALYSON C. SUH - State Bar No. 225083 COUNTY OF SAN BERNARDINO
asuh@woodruff.law SAN BERNARDINO DISTRICT
MICHAEL C. VALDEZ - State Bar N0. 295948
mvaldez@w00druff.law 11/13/2023 1307 PM
555 Anton Boulevard, Suite 1200
By: Gloria Portillo, DEPUTY
Costa Mesa, CA 92626-7670
KDOOQONU‘I-PUJNt—k
Telephone: (714) 558-7000
Facmmile: (714) 835-7787
Attorneys for Plaintiff SAN BERNARDINO COUNTY TRANSPORTATION
AUTHORITY, a public agency
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT
SAN BERNARDINO COUNTY CASE NO.: CIVSB2325463
TRANSPORTATION AUTHORITY, a
public agency, ASSIGNED FOR ALL PURPOSES TO
SMART
LAW
THE HONORABLE MICHAEL A. SACHS
&
AT MESA
Plaintiff, DEPARTMENT: 828
EYS
WOODRUFF
RN COSTA
V. PLAINTIFF'S NOTICE OF MOTION
ATTO
AND MOTION FOR PREJUDGMENT
LAN TO TRINH, a single woman; The ORDER OF POSSESSION
Heirs and Devisees 0f JAMES L. MEMORANDUM OF POINTS AND
NNNNNNNNNt—th—tt—th—tr—th—tr—tt—tr—tt—t
JOHNSON, deceased, and all persons AUTHORITIES; DECLARATIONS OF
claiming by, through, or under said JUAN LIZARDE, PE., CHRISTINE s.
decedent; RIVERSIDE WATER SANTOLUCITO AND MICHAEL C.
COMPANY; JAMES W. JEFFRIES, VALDEZ IN SUPPORT THEREOF
trustee 0f the Jeffries Trust dated November
OONQMJ>WNHOKOOONQLA$UJNHO
19, 2001; SHAREN K. JEFFRIES, trustees [Notice ofDeposit ofProbable Compensation
0f the Jeffries Trust dated November 19, and [Proposed] Orderfor Prejudgment
WFG
2001; NATIONAL TITLE Possession submitted concurrently herewith]
COMPANY OF CALIFORNIA, a
California Corporation; JOURNEY WEST [Assessor Parcel Nos. 0164-172-30, 0164-
MOTORS, INC., a California corporation; 172-31, 0164-172-32 and 0164-172-33]
DOES 1 through 100, inclusive; and ALL
PERSONS UNKNOWN CLAIMING AN HEARING DATES PENDING:
INTEREST IN THE PROPERTY, Motion Prejudgment Possession
for
Date: February 29, 2024
Defendants. Time: 8:30 a.m.
Dept: $28
Initial Trial Setting Conference
Date: April 18, 2024
Time: 8:30 a.m.
Dept. 828
DATE ACTION FILED: October 11, 2023
TRIAL DATE: None
1
PLAINTIFF'S NOTICE OF MOTION AND MOTION FOR PREJUDGMENT ORDER OF POSSESSION
17971 17.1
TO ALL DEFENDANTS, OCCUPANTS AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that on February 29, 2024 at 8:30 a.m., or as soon thereafter
as the matter may be heard in Department $28 ofthe above-entitled Court, located at 247 West
Third Street, San Bemardino, California 92415, Plaintiff San Bernardino County
("SBCTA") move
KDOOQONU‘I-PUJNt—k
Transportation Authority will the Court for an order 0f prejudgment
possession 0f the property interests, which SBCTA is seeking to acquire by way 0f the
complaint in this action and Which are identified With specificity therein. Namely, SBCTA is
seeking an order authorizing it to take possession of the property interests being acquired
herein thirty (30) days after service of the order 0f possession.
The motion is brought pursuant to Code of Civil Procedure section 1255.410, Which
permits SBCTA t0 move the Court for an order 0f possession prior to entry ofjudgment upon
meeting certain requirements. The motion is made 0n the grounds that SBCTA has met all the
statutory requirements for a prejudgment order of possession under Code of California Civil
SMART
LAW
AT MESA
& Procedure section 1255 .410.
EYS
RN COSTA
WOODRUFF
ATTO PLEASE TAKE NOTICE that you have the right to oppose this motion for an order 0f
possession 0f your property. If you oppose this motion, you must serve SBCTA and file with
NNNNNNNNNt—th—tt—th—tr—th—tr—tt—tr—tt—t
the court a written opposition t0 the motion Within thirty (30) days from the date you were
served with this motion. SBCTA reserves the right t0 seek issuance 0f an order for possession
OONQMJ>WNHOKOOONQLA$UJNHO
0n an ex part9 basis if n0 opposition is served and filed within thirty (30) days from service of
this motion.
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2
PLAINTIFF'S NOTICE OF MOTION AND MOTION FOR PREJUDGMENT ORDER OF POSSESSION
17971 17.1
Document Filed Date
November 13, 2023
Case Filing Date
October 11, 2023
Category
Eminent Domain/Inv Cond Unlimited
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Fee Exempt Per Gov. Code § 6103 WOODRUFF & SMART, APC CRAIG G. FARRINGTON - State Bar N0. 125274 ELECTRONICALLY FILED cfarrington@woodruff.law SUPERIOR COURT OF CALIFORNIA ALYSON C. SUH - State Bar No. 225083 COUNTY OF SAN BERNARDINO asuh@woodruff.law SAN BERNARDINO DISTRICT MICHAEL C. VALDEZ - State Bar N0. 295948 mvaldez@w00druff.law 11/13/2023 1307 PM 555 Anton Boulevard, Suite 1200 By: Gloria Portillo, DEPUTY Costa Mesa, CA 92626-7670 KDOOQONU‘I-PUJNt—k Telephone: (714) 558-7000 Facmmile: (714) 835-7787 Attorneys for Plaintiff SAN BERNARDINO COUNTY TRANSPORTATION AUTHORITY, a public agency SUPERIOR COURT FOR THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT SAN BERNARDINO COUNTY CASE NO.: CIVSB2325463 TRANSPORTATION AUTHORITY, a public agency, ASSIGNED FOR ALL PURPOSES TO SMART LAW THE HONORABLE MICHAEL A. SACHS & AT MESA Plaintiff, DEPARTMENT: 828 EYS WOODRUFF RN COSTA V. PLAINTIFF'S NOTICE OF MOTION ATTO AND MOTION FOR PREJUDGMENT LAN TO TRINH, a single woman; The ORDER OF POSSESSION Heirs and Devisees 0f JAMES L. MEMORANDUM OF POINTS AND NNNNNNNNNt—th—tt—th—tr—th—tr—tt—tr—tt—t JOHNSON, deceased, and all persons AUTHORITIES; DECLARATIONS OF claiming by, through, or under said JUAN LIZARDE, PE., CHRISTINE s. decedent; RIVERSIDE WATER SANTOLUCITO AND MICHAEL C. COMPANY; JAMES W. JEFFRIES, VALDEZ IN SUPPORT THEREOF trustee 0f the Jeffries Trust dated November OONQMJ>WNHOKOOONQLA$UJNHO 19, 2001; SHAREN K. JEFFRIES, trustees [Notice ofDeposit ofProbable Compensation 0f the Jeffries Trust dated November 19, and [Proposed] Orderfor Prejudgment WFG 2001; NATIONAL TITLE Possession submitted concurrently herewith] COMPANY OF CALIFORNIA, a California Corporation; JOURNEY WEST [Assessor Parcel Nos. 0164-172-30, 0164- MOTORS, INC., a California corporation; 172-31, 0164-172-32 and 0164-172-33] DOES 1 through 100, inclusive; and ALL PERSONS UNKNOWN CLAIMING AN HEARING DATES PENDING: INTEREST IN THE PROPERTY, Motion Prejudgment Possession for Date: February 29, 2024 Defendants. Time: 8:30 a.m. Dept: $28 Initial Trial Setting Conference Date: April 18, 2024 Time: 8:30 a.m. Dept. 828 DATE ACTION FILED: October 11, 2023 TRIAL DATE: None 1 PLAINTIFF'S NOTICE OF MOTION AND MOTION FOR PREJUDGMENT ORDER OF POSSESSION 17971 17.1 TO ALL DEFENDANTS, OCCUPANTS AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on February 29, 2024 at 8:30 a.m., or as soon thereafter as the matter may be heard in Department $28 ofthe above-entitled Court, located at 247 West Third Street, San Bemardino, California 92415, Plaintiff San Bernardino County ("SBCTA") move KDOOQONU‘I-PUJNt—k Transportation Authority will the Court for an order 0f prejudgment possession 0f the property interests, which SBCTA is seeking to acquire by way 0f the complaint in this action and Which are identified With specificity therein. Namely, SBCTA is seeking an order authorizing it to take possession of the property interests being acquired herein thirty (30) days after service of the order 0f possession. The motion is brought pursuant to Code of Civil Procedure section 1255.410, Which permits SBCTA t0 move the Court for an order 0f possession prior to entry ofjudgment upon meeting certain requirements. The motion is made 0n the grounds that SBCTA has met all the statutory requirements for a prejudgment order of possession under Code of California Civil SMART LAW AT MESA & Procedure section 1255 .410. EYS RN COSTA WOODRUFF ATTO PLEASE TAKE NOTICE that you have the right to oppose this motion for an order 0f possession 0f your property. If you oppose this motion, you must serve SBCTA and file with NNNNNNNNNt—th—tt—th—tr—th—tr—tt—tr—tt—t the court a written opposition t0 the motion Within thirty (30) days from the date you were served with this motion. SBCTA reserves the right t0 seek issuance 0f an order for possession OONQMJ>WNHOKOOONQLA$UJNHO 0n an ex part9 basis if n0 opposition is served and filed within thirty (30) days from service of this motion. /// /// /// /// /// /// /// /// 2 PLAINTIFF'S NOTICE OF MOTION AND MOTION FOR PREJUDGMENT ORDER OF POSSESSION 17971 17.1