Document for Environmental Stewardship Foundation vs. Chris N Vrame

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                                EHLERS LAW CORPORATION
     WESLEY CJ. EHLERS (SBN 181537)
     2600 Capitol Avenue, Suite 300
     Sacramento, CA 95816-5930
                                                                     PILED/ENDORSED
     Telephone: (916)442-0300
     Facsimile: (916)650-1039                                               AUG 0 2 2019
     e-mail: wes@ehlerslawcorp.com
                                                                    By:.       R- GpfUBH!
     JEAN M. HOBLER, ESQ., A PROF. CORPORATION                                ueputy Claric
     JEAN M. HOBLER (SBN 214106)
     400 Capitol Mall, Suite 2560
     Sacramento, CA 95814
     Telephone: (916)531-7979
     e-mail: jmh@hobleresq.com

     Attomeys for: Plaintiff
     ENVIRONMENTAL STEWARDSHIP FOUNDATION

10
11                             SUPERIOR COURT OF CALIFORNIA

12                      IN AND FOR THE COUNTY OF SACRAMENTO

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14   ENVIRONMENTAL STEWARDSHIP                           Case No. 34-2016-00201850
     FOUNDATION, a Califomia nonprofit public
15   benefit corporation,                                ENVIRONMENTAL STEWARDSHIP
                                                         FOUNDATION'S NOTICE OF
16                      Plaintiff,                       MOTION AND MOTION TO
             v.                                          COMPEL PRODUCTION OF
17                                                       DOCUMENTS FROM CHRIS
     CHRIS N. VRAME, an individual and dba CV            VRAME / CV INVESTMENTS
18   INVESTMENTS; SIERRA HOLDINGS, LLC,
     a Califomia limited liability company; SIERRA       [REFILED MOTION ORIGINALLY
19   HOLDINGS TWO, LLC, a Califomia limited              SET FOR JUNE 3, 2019]
     liability company; SIERRA PHOENICIAN,
20   LLC, a Califomia limited liability company;
     CONSERVANCY TO PROTECT THE LAND,                    Complaint: October 17, 2016
21   a Califomia nonprofit public benefit corporation;   Trial Date: January 27, 2019
     CONSERVATION RESOURCES, LLC, a
22   Califomia limited liability company; CIRRUS,
     LLC, a Califomia limited liability company;         Date: August 26, 2019
23   MOANA MANAGEMENT, LLC, a Delaware                   Time: 9:00 a.m.
     limited liability company; POOLS, LLC, a            Dept.: 54
24   Delaware limited liability company; KIEFER
     SIERRA 80, LLC, a Califomia limited liability
25   company; EXMOOR, INC., a Califomia
     corporation; GILL RANCH, LLC, a Delaware
26   limited liability company; CELIA
     MCCORMACK GLASS, an individual,
27   individually and as Tmstee of the CELIA
     MCCORMACK GLASS FAMILY TRUST;
28   ANTON VRAME, an individual; WAYNE E.

     {00009186.2}                                                       34-2016-00201805
         ESF'S NOTICE OF MOTION AND MOTION TO COMPEL PROD. OF DOCS BY CHRIS VRAME
     SCHELL, an individual; SUSANNE M.
 1   SCHELL, an individual; and DOES 1 through
     100, inclusive,
 2                      Defendants.
 3

4

 5
 6          TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
 7          NOTICE IS HEREBY GIVEN that on August 26, 2019, or as soon thereafter as the
 8   matter may be heard in Department 54, located at 813 6'"^ Street, Sacramento, CA 95814,
 9   Plaintiff Environmental Stewardship Foundation ("Plaintiff or "ESF") will, and hereby
10 does, move the Court for an order compelling Defendant Chris Vrame and the affiliates
11 under his confrol to produce documents in response to Request No. 9 of the April 12, 2019
12 Amended Notice of Taking Deposition of Chris Vrame and Request for Production of
13 Documents, as specifically identified in the supporting separate statement, and rendering
14 such other relief as the Court deems appropriate.
15          This motion was taken off calendar pursuant to a stipulation by the parties regarding
16 mediation and settlement negotiations. The parties were unable to come to a resolution of
17 this matter. This notice will serve as a re-setting of the motion originally filed on May 9,
18 2019, and is based on these previously-filed documents, and the authorities cited therein:
19
            Docket No. 143:        Plaintiff s Memorandum of Points and Authorities in Support
20
                                   of Motion to Compel Production of Documents from Chris
21
                                   Vrame/CV Investments
22          Docket No. 144:
                                   Separate Statement in Support of Motion to Compel
23
                                   Production of Documents from Chris Vrame/CV Investments
24          Docket No. 145:
                                   Request for Judicial Notice in Support of Motion to Compel
25
                                   Production of Documents from Chris Vrame/CV Investments
26          Docket No. 146:
                                   Declaration of Steven Delaney in Support of Environmental
27
                                   Stewardship Foundation's Motion to Compel Production of
28
                                   Documents from Chris Vrame/CV Investments, and exhibits
     {00009186.2}                                                       34-2016-00201805
                                            -2-
         ESF'S NOTICE OF MOTION AND MOTION TO COMPEL PROD. OF DOCS BY CHRIS VRAME
 1                                thereto
 2          Docket No. 147:       Declaration of Jean M. Hobler in Support of Environmental
 3                                Stewardship Foundation's Motion to Compel Production of
4                                 Documents from Chris Vrame/CV Investments, and exhibits
 5                                thereto
 6          Docket No. 148:       Declaration of Wesley Ehlers in Support of Environmental
 7                                Stewardship Foundation's Motion to Compel Production of
 8                                Documents from Chris Vrame/CV Investments, and exhibits
9                                 thereto
10          This motion is also based on all pleadings and papers on file in this action, and any
11 other matters the Court may deem appropriate.
12          All supporting documents identified in this notice, and the original notice, have been
13 previously filed and served (Docket No. 149), and re-served on August 1, 2019, in light of
14 substitutions and withdrawal of counsel. The original notice of motion and motion was
15 originally filed at Docket No. 142.
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     {00009186.2}                           -3                          34-2016-00201805
         ESF'S NOTICE OF MOTION AND MOTION TO COMPEL PROD. OF DOCS BY CHRIS VRAME
 1          Pursuant to Local Rule 1.06 (A), the court will make a tentative ruling on the

2    merits of this matter by 2:00 p.m., the court day before the hearing. The complete text

 3 of the tentative rulings for the department may be downloaded off the court's Web site.

4    If the party does not have online access, they may call the dedicated phone number for

 5   the department as referenced in the local telephone directory between the hours of

6    2:00 p.m. and 4:00 p.m. on the court day before the hearing and receive the tentative

7    ruling. If you do not call the court and the opposing party by 4:00 p.m. the court day

 8   before the hearing, no hearing will be held.

9

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11 Dated: August 2, 2019                EHLERS LAW CORPORATION
                                        WESLEY CJ. EHLERS
12                                      2600 Capitol Avenue, Suite 320
                                        Sacramento, CA 95816-5930
13
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15                                      By.
                                                Wesley CJ. Ehlers
^6                                               Attomey for Plaintiff ENVIRONMENTAL
                                                STEWARDSHIP FOUNDATION
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     {00009186.2}                           -4-                         34-2016-00201805
         ESF'S NOTICE OF MOTION AND MOTION TO COMPEL PROD. OF DOCS BY CHRIS VRAME