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1 RENE I. GAMBOA, Bar No. 136166
rgamboa@grsm.com
2 GORDON REES SCULLY MANSUKHANI, LLP
275 Battery Street, Suite 2000
3 San Francisco, California 94111
Telephone: (415) 986-5900
4 Facsimile: (415) 986-8054
5 Attorneys for Defendants
QADISIYYAH RANCH LLC; WAQAAS AL-
6 SIDDIQ; and RUFIA AL-SIDDIQ
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SONOMA
GORDON REES SCULLY MANSUKHANI, LLP
10
275 BATTERY STREET, SUITE 2000
SAN FRANCISCO, CA 94111
11 DIANE PINNEY, Case No. 23CV01909
12 Plaintiff, UNLIMITED JURISDICTION
13 v. NOTICE OF MOTION TO DEMURRER
OF DEFENDANTS QADISIYYAH
14 QADISIYYAH RANCH LLC; WAQAAS AL- RANCH LLC; WAQAAS AL-SIDDIQ;
SIDDIQ; RUFIA AL-SIDDIQ; and DOES 1 and RUFIA AL-SIDDIQ TO THE
15 TO 10, COMPLAINT OF DIANE PINNEY
16 Defendants. [Concurrently filed and served with
Memorandum of Points and Authorities;
17 Declaration of Rene I. Gamboa; and
[Proposed] Order]
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Trial Date:
20 Date Action Filed: December 11, 2023
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22 TO ALL PARTIES AND TO THEIR COUNSEL OF RECORD:
23 PLEASE TAKE NOTICE that on ___________, 2024 at ____ a.m., or as soon thereafter
24 as the matter may be heard in Courtroom 16 of the above-entitled court, located at 3055 Cleveland
25 Avenue, Santa Rosa, CA 95403, defendants QADISIYYAH RANCH LLC; WAQAAS AL-
26 SIDDIQ; and RUFIA AL-SIDDIQ (“Defendants”) will, and hereby do, demur to the Fourth Cause
27 of Action for Fraud and the Sixth Cause of Action for Defamation contained in the Complaint of
28 plaintiff DIANE PINNEY (“Plaintiff”).
NOTICE OF MOTION TO DEMURRER OF DEFENDANTS QADISITYYAH RANCH LLC; WAQAAS AL-
SIDDIQ; AND RUFIA AL-SIDDIQ TO THE COMPLAINT OF DIANE PINNEY
1 This Demurrer is based on the ground that the Complaint fails to state facts sufficient to
2 constitute causes of action for fraud and defamation because the Complaint fails to plead these
3 causes of action with the requisite specificity required under California law.
4 This Demurrer is based on this Notice of Demurrer, the accompanying Memorandum of
5 Points and Authorities, the Request for Judicial Notice, the Declaration of René I. Gamboa, all
6 papers that may be filed in Reply in support of this Demurrer, all other records and pleadings on
7 file with the Court in this matter, all matters of which the Court may take judicial notice, and such
8 further evidence and argument as may be presented at or before the hearing on this Demurrer.
9 Dated: March 1, 2024 GORDON REES SCULLY MANSUKHANI,
GORDON REES SCULLY MANSUKHANI, LLP
LLP
10
275 BATTERY STREET, SUITE 2000
SAN FRANCISCO, CA 94111
11
By:
12 Rene I. Gamboa
13 Attorneys for Defendants QADISIYYAH
RANCH, LLC; WAQAAS AL-SIDDIQ; and
14 RUFIA AL-SIDDIQ
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NOTICE OF MOTION TO DEMURRER OF DEFENDANTS QADISITYYAH RANCH LLC; WAQAAS AL-
SIDDIQ; AND RUFIA AL-SIDDIQ TO THE COMPLAINT OF DIANE PINNEY
1 PROOF OF SERVICE
2 I am a resident of the State of California, over the age of eighteen years, and not a party
to the within action. My business address is: Gordon Rees Scully Mansukhani, LLP 1111
3 Broadway, Suite 1700, Oakland, CA 94607. On the date shown below, I served the within
documents:
4
NOTICE OF MOTION TO DEMURRER OF DEFENDANTS QADISITYYAH
5 RANCH LLC; WAQAAS AL-SIDDIQ; AND RUFIA AL-SIDDIQ TO THE COMPLAINT
OF DIANE PINNEY
6
7 BY EMAIL OR ELECTRONIC TRANSMISSION: Pursuant to CCP § 1010.6, I
caused the document(s) to be sent to the person(s) at the E-Mail address(es) listed
below. I did not receive, within a reasonable time after the transmission, any
8 electronic message or other indication that the transmission was unsuccessful.
9
David Hiller, Esq.
10 Law Office of David W. Hiller
4040 Civic Center Drive, Suite 200
11 San Rafael, CA 967-1984
Tel: (415) 967-1984
Fax: (415) 480-8531
Gordon Rees Scully Mansukhani, LLP
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Email: david@dwhesq.com
1111 Broadway, Suite 1700
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Attorneys for Plaintiff
Oakland, CA 94607
14 Diane Pinney
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16 I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.
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Executed on March 1, 2024, at Oakland, California.
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Nadine E. Williams
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PROOF OF SERVICE
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1 RENE I. GAMBOA, Bar No. 136166 rgamboa@grsm.com 2 GORDON REES SCULLY MANSUKHANI, LLP 275 Battery Street, Suite 2000 3 San Francisco, California 94111 Telephone: (415) 986-5900 4 Facsimile: (415) 986-8054 5 Attorneys for Defendants QADISIYYAH RANCH LLC; WAQAAS AL- 6 SIDDIQ; and RUFIA AL-SIDDIQ 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SONOMA GORDON REES SCULLY MANSUKHANI, LLP 10 275 BATTERY STREET, SUITE 2000 SAN FRANCISCO, CA 94111 11 DIANE PINNEY, Case No. 23CV01909 12 Plaintiff, UNLIMITED JURISDICTION 13 v. NOTICE OF MOTION TO DEMURRER OF DEFENDANTS QADISIYYAH 14 QADISIYYAH RANCH LLC; WAQAAS AL- RANCH LLC; WAQAAS AL-SIDDIQ; SIDDIQ; RUFIA AL-SIDDIQ; and DOES 1 and RUFIA AL-SIDDIQ TO THE 15 TO 10, COMPLAINT OF DIANE PINNEY 16 Defendants. [Concurrently filed and served with Memorandum of Points and Authorities; 17 Declaration of Rene I. Gamboa; and [Proposed] Order] 18 19 Trial Date: 20 Date Action Filed: December 11, 2023 21 22 TO ALL PARTIES AND TO THEIR COUNSEL OF RECORD: 23 PLEASE TAKE NOTICE that on ___________, 2024 at ____ a.m., or as soon thereafter 24 as the matter may be heard in Courtroom 16 of the above-entitled court, located at 3055 Cleveland 25 Avenue, Santa Rosa, CA 95403, defendants QADISIYYAH RANCH LLC; WAQAAS AL- 26 SIDDIQ; and RUFIA AL-SIDDIQ (“Defendants”) will, and hereby do, demur to the Fourth Cause 27 of Action for Fraud and the Sixth Cause of Action for Defamation contained in the Complaint of 28 plaintiff DIANE PINNEY (“Plaintiff”). NOTICE OF MOTION TO DEMURRER OF DEFENDANTS QADISITYYAH RANCH LLC; WAQAAS AL- SIDDIQ; AND RUFIA AL-SIDDIQ TO THE COMPLAINT OF DIANE PINNEY 1 This Demurrer is based on the ground that the Complaint fails to state facts sufficient to 2 constitute causes of action for fraud and defamation because the Complaint fails to plead these 3 causes of action with the requisite specificity required under California law. 4 This Demurrer is based on this Notice of Demurrer, the accompanying Memorandum of 5 Points and Authorities, the Request for Judicial Notice, the Declaration of René I. Gamboa, all 6 papers that may be filed in Reply in support of this Demurrer, all other records and pleadings on 7 file with the Court in this matter, all matters of which the Court may take judicial notice, and such 8 further evidence and argument as may be presented at or before the hearing on this Demurrer. 9 Dated: March 1, 2024 GORDON REES SCULLY MANSUKHANI, GORDON REES SCULLY MANSUKHANI, LLP LLP 10 275 BATTERY STREET, SUITE 2000 SAN FRANCISCO, CA 94111 11 By: 12 Rene I. Gamboa 13 Attorneys for Defendants QADISIYYAH RANCH, LLC; WAQAAS AL-SIDDIQ; and 14 RUFIA AL-SIDDIQ 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- NOTICE OF MOTION TO DEMURRER OF DEFENDANTS QADISITYYAH RANCH LLC; WAQAAS AL- SIDDIQ; AND RUFIA AL-SIDDIQ TO THE COMPLAINT OF DIANE PINNEY 1 PROOF OF SERVICE 2 I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is: Gordon Rees Scully Mansukhani, LLP 1111 3 Broadway, Suite 1700, Oakland, CA 94607. On the date shown below, I served the within documents: 4 NOTICE OF MOTION TO DEMURRER OF DEFENDANTS QADISITYYAH 5 RANCH LLC; WAQAAS AL-SIDDIQ; AND RUFIA AL-SIDDIQ TO THE COMPLAINT OF DIANE PINNEY 6 7 BY EMAIL OR ELECTRONIC TRANSMISSION: Pursuant to CCP § 1010.6, I caused the document(s) to be sent to the person(s) at the E-Mail address(es) listed below. I did not receive, within a reasonable time after the transmission, any 8 electronic message or other indication that the transmission was unsuccessful. 9 David Hiller, Esq. 10 Law Office of David W. Hiller 4040 Civic Center Drive, Suite 200 11 San Rafael, CA 967-1984 Tel: (415) 967-1984 Fax: (415) 480-8531 Gordon Rees Scully Mansukhani, LLP 12 Email: david@dwhesq.com 1111 Broadway, Suite 1700 13 Attorneys for Plaintiff Oakland, CA 94607 14 Diane Pinney 15 16 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 17 Executed on March 1, 2024, at Oakland, California. 18 19 Nadine E. Williams 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE