On May 25, 2023 a
Declaration Filed - of Jonathan W Cayton ISO OSC re Enforcement of Settlement Agreement and Transcript of MSC
was filed
involving a dispute between
Carriage Hills Planned Development Association,
Ju, Michael,
and
Carriage Hills Home Owner Association,
Does 1 Through 50, Inclusive,
Ju, Michael,
Wang, Hailing,
Wang, Sarah,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
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JONATHAN (‘AYTON (SBN 303877)
Cayton Legal. PC
[J 200 E Chapman Ava. Suite 203
Orange. CA 92866
'4)
Telephone: (949) 287-8735
_/'cu_\‘l(m¢i cqvtonlcgul. cum
Attorneys for Defendant MICHAEL JU and HAILING WANG
'Jl
THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
CARRIAGE HILLS PLANNED Case N0.: CIVSB2315763 [consolidated with
DEVELOPMENT ASSOCIATION. a California Case N0.: SCVAZBOI 825]
Nonprofit Mutual Benefit Corporation.
[CONFIDENTIAL AND TO BE FILED
Plaintiff. UNDER SEAL!
-——“
DECLARATION 0F JONATHAN W.
MOVED
VS. CAYTON IN SUPPORT OF OSC RE
ENFORCEMENT ()F SETTLEMENT
AGREEMENT AND TRANSCRIPT OF
MICHAEL JU. an individual; HAILING WANG. MANDATORY SETTLEMENT
an individual; and DOES through 50. inclusive.
1 CONFERENCE HELD ON SEPTEMBER 29,
2023
Defendants.
The Honorable Charlie Hill
Dept. S30
Complaint Filed: July 12. 2023
Trial Date: None Set
AND RELATED CROSS ACTIONS.
DECLARATION OF JONATHAN W. CAYTON
I. Jonathan W. Cayton. declare as follows:
l. I have been a California licensed attorney since June 0f201 5 and am the principal 0f
Cayton Legal. PC. counsel ofrecord for Defendants and Cross-Complainant‘s Michael .lu and Hailing
Wang (“Defendants"). As such. l have personal knowledge 0f the facts stated herein below.
2. On May 25. 2023 Defendants filed a Small-Claims Complaint alleging that Plaintiff
Carriage Hills Planned Development Association (the “HOA") improperly forced Defendants t0
maintain a slope outside the boundaries 0f Defendants‘ lot by threatening 10 penalize and/or fine
1
DELCARATION OF JWC SUPPORT OF ORDER TO SHOW CAUSE RE DISMISSAL'STATUS 0F TRANSCRIPT
IN
0F SETTLEMENT AGREEMENT REACHED ON SEPTEMBER 29. 2023
10/616/0041/0W/V698M
”Q&fitfiifiéflafiég
éaozwé'dfi'
094/3036r
Document Filed Date
April 25, 2024
Case Filing Date
May 25, 2023
Category
Breach of Contract/Warranty Unlimited
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JONATHAN (‘AYTON (SBN 303877) Cayton Legal. PC [J 200 E Chapman Ava. Suite 203 Orange. CA 92866 '4) Telephone: (949) 287-8735 _/'cu_\‘l(m¢i cqvtonlcgul. cum Attorneys for Defendant MICHAEL JU and HAILING WANG 'Jl THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO CARRIAGE HILLS PLANNED Case N0.: CIVSB2315763 [consolidated with DEVELOPMENT ASSOCIATION. a California Case N0.: SCVAZBOI 825] Nonprofit Mutual Benefit Corporation. [CONFIDENTIAL AND TO BE FILED Plaintiff. UNDER SEAL! -——“ DECLARATION 0F JONATHAN W. MOVED VS. CAYTON IN SUPPORT OF OSC RE ENFORCEMENT ()F SETTLEMENT AGREEMENT AND TRANSCRIPT OF MICHAEL JU. an individual; HAILING WANG. MANDATORY SETTLEMENT an individual; and DOES through 50. inclusive. 1 CONFERENCE HELD ON SEPTEMBER 29, 2023 Defendants. The Honorable Charlie Hill Dept. S30 Complaint Filed: July 12. 2023 Trial Date: None Set AND RELATED CROSS ACTIONS. DECLARATION OF JONATHAN W. CAYTON I. Jonathan W. Cayton. declare as follows: l. I have been a California licensed attorney since June 0f201 5 and am the principal 0f Cayton Legal. PC. counsel ofrecord for Defendants and Cross-Complainant‘s Michael .lu and Hailing Wang (“Defendants"). As such. l have personal knowledge 0f the facts stated herein below. 2. On May 25. 2023 Defendants filed a Small-Claims Complaint alleging that Plaintiff Carriage Hills Planned Development Association (the “HOA") improperly forced Defendants t0 maintain a slope outside the boundaries 0f Defendants‘ lot by threatening 10 penalize and/or fine 1 DELCARATION OF JWC SUPPORT OF ORDER TO SHOW CAUSE RE DISMISSAL'STATUS 0F TRANSCRIPT IN 0F SETTLEMENT AGREEMENT REACHED ON SEPTEMBER 29. 2023 10/616/0041/0W/V698M ”Q&fitfiifiéflafiég éaozwé'dfi' 094/3036r