Preview
FIDELITY NATIONAL LAW GROUP ELECTRONICALLY FILED
MARY ANN ROUSSO (SBN 289426) SUPERIOR COURT OF CALIFORNIA
601 So. Figueroa Street, Suite 4025 COUNTY OF SAN BERNARDINO
Los Angeles, California 9001 7 SAN BERNARDINO DISTRICT
Telephone: 21 3-43 8-44 1 6 12/27/2023 5:34 PM
Facsimile: 213-438-4417
Email: mm-ann.rousso@fnf.com By: Abrianna Rodriguez, DEPUTY
Attorney for Plaintiff,
FIDELITY NATIONAL TITLE
\OOOflQLh-hUJN"
INSURANCE COMPANY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO, CENTRAL DISTRICT
FIDELITY NATIONAL TITLE INSURANCE CASE NO.: CIV SB 2130313
COMPANY, a Florida corporation,
TSC: February 22, 2024
Plaintiff, Date Action Filed: October 22, 2021
v.
MARTIN GONZALEZ, aka MARTIN
JESUS GONZALEZ, an individual; CESAR
MONTANO, aka CESAR MONTANO, JR.,
an individual; GOLDEN RULE LENDING,
LLC, a California Limited Liability
Company; DOES 1 through 100, inclusive,
NNNNNNNNr—Ir—tr—Ir—Ir—Ir—Ir—nr—Ir—Ir—I
Defendants.
N$MhWN~O©OOQQMhUJNHO
CASE NO.: CIVSB 2130684
FIDELITY NATIONAL TITLE INSURANCE
COMPANY, a Florida corporation, Date Action Filed: October 28, 2021
Trial Date: February 5, 2024
Plaintiff,
Trial Readiness Conf. February l, 2024
:
V.
REQUEST FOR JUDICIAL NOTICE
MARTIN GONZALEZ, aka MARTIN
JESUS GONZALEZ, an individual; CESAR
MONTANO, aka CESAR MONTANO, JR.,
an individual; MONTANO INVESTMENTS, Date: March 18, 2024
Time: 8:30 a.m.
INC., a California corporation; DOES 1
Dept. SZ3-SBJC
through 100, inclusive,
[Assigned to: Hon. Donald Alvarez]
Defendants.
///
28
l
601 So. Flcuenm Smear.
Sun: 4025
Los ANGELes. CA 90017 REQUEST FOR JUDICIAL NOTICE [1N SUPPORT OF MOTION 1'0 CONSOLIDATE CASES]
1 TO THIS HONORABLE COURT:
2 Pursuant to certain provisions of the Evidence Code, Plaintiff, COMMONWEALTH LAND
3 TITLE INSURANCE COMPANY, a Floria corporation respectfully requests that the Court take
4 judicial notice of the following documents:
5 Pursuant to Evidence Code§ 452(d): Records of (1) any court of this state or (2) any
6 court of record of the United States or of any state of the United States.
7 1. That certain Complaint filed by Fidelity National Title Insurance Company
8 against Martin Gonzalez, aka Martin Jesus Gonzalez, et al., filed in this Court on October 22,
9 2021, under the case number of CIVSB 2130313, a true and correct copy of which is attached
10 as hereto as Exhibit 1 and incorporated herein by this reference.
11 2. That certain Complaint filed by Fidelity National Title Insurance Company
12 against Martin Gonzalez, aka Martin Jesus Gonzalez, et al., filed in this Court on October 28,
13 2021, under the case number of CIVSB 2130684, a true and correct copy of which is attached
14 hereto Exhibit 2 and incorporated herein by this reference.
15 3. The Notices of Related Cases filed in the Case bearing No. CIVSB 2130313 and
16 CIVSB 2130684, respectively, true and correct copies of which are attached hereto,
17 collectively, as Exhibit 3 attached hereto and incorporated herein by this reference.
18 Pursuant to Evidence Code§ 453: The trial court shall take judicial notice of any matter
19 specified in Section 452 if a party requests it and:
20 (a) Gives each adverse party sufficient notice of the request, through the pleadings
21 or otherwise, to enable such adverse party to prepare to meet the request; and
22 (b) Furnishes the court with sufficient information to enable it to take judicial
23 notice of the matter.
24 Plaintiff will provide notice of this Request for Judicial Notice by serving this notice, along
25 with Motion to Consolidate Actions and all supporting documents on said Defendants and any
26 attorney of record for Defendants.
27 This Request for Judicial Notice, is being filed concurrently herewith.
28
601 So. FIGUEROA STREET.
SUITE4025
Los ANGELES, CA 90017 REQUEST FOR JUDICIAL NOTICE [IN SUPPORT OF MOTION TO CONSOLIDATE CASES)
Preview
FIDELITY NATIONAL LAW GROUP ELECTRONICALLY FILED MARY ANN ROUSSO (SBN 289426) SUPERIOR COURT OF CALIFORNIA 601 So. Figueroa Street, Suite 4025 COUNTY OF SAN BERNARDINO Los Angeles, California 9001 7 SAN BERNARDINO DISTRICT Telephone: 21 3-43 8-44 1 6 12/27/2023 5:34 PM Facsimile: 213-438-4417 Email: mm-ann.rousso@fnf.com By: Abrianna Rodriguez, DEPUTY Attorney for Plaintiff, FIDELITY NATIONAL TITLE \OOOflQLh-hUJN" INSURANCE COMPANY SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, CENTRAL DISTRICT FIDELITY NATIONAL TITLE INSURANCE CASE NO.: CIV SB 2130313 COMPANY, a Florida corporation, TSC: February 22, 2024 Plaintiff, Date Action Filed: October 22, 2021 v. MARTIN GONZALEZ, aka MARTIN JESUS GONZALEZ, an individual; CESAR MONTANO, aka CESAR MONTANO, JR., an individual; GOLDEN RULE LENDING, LLC, a California Limited Liability Company; DOES 1 through 100, inclusive, NNNNNNNNr—Ir—tr—Ir—Ir—Ir—Ir—nr—Ir—Ir—I Defendants. N$MhWN~O©OOQQMhUJNHO CASE NO.: CIVSB 2130684 FIDELITY NATIONAL TITLE INSURANCE COMPANY, a Florida corporation, Date Action Filed: October 28, 2021 Trial Date: February 5, 2024 Plaintiff, Trial Readiness Conf. February l, 2024 : V. REQUEST FOR JUDICIAL NOTICE MARTIN GONZALEZ, aka MARTIN JESUS GONZALEZ, an individual; CESAR MONTANO, aka CESAR MONTANO, JR., an individual; MONTANO INVESTMENTS, Date: March 18, 2024 Time: 8:30 a.m. INC., a California corporation; DOES 1 Dept. SZ3-SBJC through 100, inclusive, [Assigned to: Hon. Donald Alvarez] Defendants. /// 28 l 601 So. Flcuenm Smear. Sun: 4025 Los ANGELes. CA 90017 REQUEST FOR JUDICIAL NOTICE [1N SUPPORT OF MOTION 1'0 CONSOLIDATE CASES] 1 TO THIS HONORABLE COURT: 2 Pursuant to certain provisions of the Evidence Code, Plaintiff, COMMONWEALTH LAND 3 TITLE INSURANCE COMPANY, a Floria corporation respectfully requests that the Court take 4 judicial notice of the following documents: 5 Pursuant to Evidence Code§ 452(d): Records of (1) any court of this state or (2) any 6 court of record of the United States or of any state of the United States. 7 1. That certain Complaint filed by Fidelity National Title Insurance Company 8 against Martin Gonzalez, aka Martin Jesus Gonzalez, et al., filed in this Court on October 22, 9 2021, under the case number of CIVSB 2130313, a true and correct copy of which is attached 10 as hereto as Exhibit 1 and incorporated herein by this reference. 11 2. That certain Complaint filed by Fidelity National Title Insurance Company 12 against Martin Gonzalez, aka Martin Jesus Gonzalez, et al., filed in this Court on October 28, 13 2021, under the case number of CIVSB 2130684, a true and correct copy of which is attached 14 hereto Exhibit 2 and incorporated herein by this reference. 15 3. The Notices of Related Cases filed in the Case bearing No. CIVSB 2130313 and 16 CIVSB 2130684, respectively, true and correct copies of which are attached hereto, 17 collectively, as Exhibit 3 attached hereto and incorporated herein by this reference. 18 Pursuant to Evidence Code§ 453: The trial court shall take judicial notice of any matter 19 specified in Section 452 if a party requests it and: 20 (a) Gives each adverse party sufficient notice of the request, through the pleadings 21 or otherwise, to enable such adverse party to prepare to meet the request; and 22 (b) Furnishes the court with sufficient information to enable it to take judicial 23 notice of the matter. 24 Plaintiff will provide notice of this Request for Judicial Notice by serving this notice, along 25 with Motion to Consolidate Actions and all supporting documents on said Defendants and any 26 attorney of record for Defendants. 27 This Request for Judicial Notice, is being filed concurrently herewith. 28 601 So. FIGUEROA STREET. SUITE4025 Los ANGELES, CA 90017 REQUEST FOR JUDICIAL NOTICE [IN SUPPORT OF MOTION TO CONSOLIDATE CASES)