Preview
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PETERSON & PETERSON
AN ASSOCIATION OF ATTORNEYS,
769 MONTEREY BOULEVARD ELECTRONICALLY
SAN FRANCISCO, CALIFORNIA 94127-2299 FILED
‘TELEPHONE (415) 586-7460 Superior Court of Califomia,
County of San Francisco
By Robert H. Peterson, III, Bar #111963 09/24/2015
Clerk of the Court
ATTORNEYS FOR Defendant, BY:ROMY RISK
JENNIFER NGAI eee
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
ASHLEY HERSHBERGER, No. CGC-15-547392
Plaintiff DEFENDANT JENNIFER NGAI’S
REQUEST FOR COURT TO TAKE
vs. JUDICIAL NOTICE
[Evid. Code Sections 451 to 453]
JENNIFER NGAI, WOON KEUNG NGAI, and
DOES 1 through 20, Date of Hearing: February 24, 2016
Place: Dept. 302
Defendants Time: 9:30 a.m.
Reference Number: 09230224-05
TO Plaintiff ASHLEY HERSHBERGER and to her attorney of record:
PLEASE TAKE NOTICE that Defendant JENNIFER NGAI, in support of her motion to
strike complaint and in support of her motion for demurrer, respectfully requests the court to
take judicial notice, pursuant to section 452 and 453 of the Evidence Code, of the following:
1. Grant Deed recorded December 8, 2011. A true and correct certified copy of the
Grant Deed for Subject Premises (1602 24" Avenue) is attached as Exhibit A.
Dated: September 23, 2015 Respectfully submitted,
PETERSON & PETERSON
By
ROBERT H. PETERSON, III
Attorney for Defendant
Jennifer Ngai
DEFENDANT JENNIFER NGAI’S REQUEST FOR COURT TO TAKE JUDICIAL NOTICE, Page 1oO 0 ow N ® wo PF WN BS
mn NN NY NY SB BB Ba Bw Ba Baw aw Bw
® NB RR 8 RR 8 6b eas ae BD S
PROOF OF SERVICE
|, ROBERT H. PETERSON, II, am employed in the City and County of San Francisco,
State of California. | am over the age of 18 years and not a party to the within action. My
business address is 769 Monterey Blvd., San Francisco, California 94127.
On September 23, 2015, | served the foregoing JENNIFER NGAI’S REQUEST FOR
COURT TO TAKE JUDICIAL NOTICE on each person named below by placing a true copy
thereof, enclosed in a sealed envelope, addressed as follows:
Mark Hooshmand
Jasna Veledar
Hooshmand Law Group
22 Battery St., Ste 610
San Francisco, CA 94111
| am readily familiar with the business’ practice for the collection and processing of
correspondence for mailing with the United States Postal Service and the fact that the
correspondence would be deposited with the United States Postal Service that same day in
the ordinary course of business. On this date, the above-referenced correspondence was
place for deposit at San Francisco, California, and placed for collection and mailing following
ordinary business practices.
| declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Dated: September 23, 2015 L——
ROBERT H. PETERSON, III
DEFENDANT JENNIFER NGAI’S REQUEST FOR COURT TO TAKE JUDICIAL NOTICE, Page 2EXHIBIT ACERTIFIED COPY
sl MA
RECORDING REQUESTED BY - Feanclege Assessor-Recorder
First American Title Company Ting Assesser-Recorder
Pa Bo. 2011-J312954-00
AND WHEN RECORDED MAIL DOCUMENT TO: | fect 3-FIRST AMERICAN Titie Company
Woon Keing Ngai Thursday, DEC 08, 2011 08:20:20
125 San Rafael Way Tel Pd 00 Rept # 0004292904
San Francisco, CA 94127 REEL K538 IMAGE 0026
afe/FT/1-2 f
/
Space Above This Line for Recorder's Use Only AW
AP.N.: LOT: 050, BLOCK: 1920 File No.: 3802-3831379 (nic)
Property Address: 1600-1602 24th Avenue, San Francisco, CA 94122
Lot Number:
Block Number:
GRANT DEED
‘The Undersigned Grantor(s) Dedare(s): DOCUMENTARY TRANSFER TAX $; CITY TRANSFER TAX $;
‘SURVEY MONUMENT FEE $
[ ] computed on the consideration or full value of property conveyed, OR
] ‘computed on the consideration or full value less value of Hlens and/or encumbrances remaining at time of sale,
|] unincorporated area; [X } City of San Francisco, and
]
x Exempt from wansfer tax; Reason: Remove from Individual back to Trust
{
[
FOR A VALUABLE CONSIDERATION, receipt of which Is hereby acknowledged,
Woon Keung Ngal and Mo Yee Ngal, Husband and Wife
hereby GRANT(s) to Woon Keung Ngal and Mo Yee Ngal, As Trustees of the Woon Keung Ngal and Mo
Yee Ngal Revocable Trust 2002
the following described property in the City of San Francisco, County of San Francisco, State of California:
BEGINNING AT THE POINT OF INTERSECTION OF THE SOUTHERLY LINE OF LAWTON STREET
WITH THE EASTERLY LINE OF 24TH AVENUE; RUNNING THENCE SOUTHERLY ALONG SAID
LINE OF 24TH AVENUE 25 FEET; THENCE AT A RIGHT ANGLE EASTERLY 95 FEET; THENCE AT
ARIGHT ANGLE NORTHERLY 25 FEET TO THE SOUTHERLY LINE OF LAWTON STREET;
THENCE AT A RIGHT ANGLE WESTERLY ALONG SAID LINE OF LAWTON STREET 95 FEET TO
THE POINT OF BEGINNING.
BEING A PORTION OF OUTSIDE LAND BLOCK NO. 842.
Mall Tax Statements To: SAME AS ABOVECERTIFIED COPY
Grant Deed - continued
Date: 11/29/2011
A.P.N.: LOT: 050, BLOCK: 1920 yer
File No.: 3802-3831379 (nic)
Dated: __13/29/2011 fet
therrborie née We nae
Woon Keung Ngal bee Mo Yee Ngai
STATEOR «= _ Cahsfo— d ss
COUNTY OF =
On fal before me, Mb ft Cle Notary
Public, personally dppefred oe ws 2 7
who to me on the basis of ry evidence to
be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that
he/she/they executed the same In his/her/their authorized capacity(les), and that by his/her/their signature(s) on
the Instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument.
I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph Is
true and correct.
WITNESS my hand and official seal. eee
ANCY LOK CHAN
oN i wasn
Signa BH SS reancisco COUNTY ©
Anak 5>/COMM. EXPIKES JUNE 23, 2035
7 t
My Commission Expires; This area for official notarial seal
Notary Name: Notary Phone:
Notary Registration Numbers County of Principal Place of Business:,
Page 2of 2CERTIFIED COpy
This is a true certifieg Copy of the record
if it bears the Seal, imprinted in purple ink,
of the Assessor-Recorder
CARMEN CI) {SEP 22 on
Darrelyn Butler
Preview
oO © © NN ® om BF WwW NN = Db NM Be a ae a a ew an nw ew SBN & BR B8R SS 8S 6 atisaszr oye PETERSON & PETERSON AN ASSOCIATION OF ATTORNEYS, 769 MONTEREY BOULEVARD ELECTRONICALLY SAN FRANCISCO, CALIFORNIA 94127-2299 FILED ‘TELEPHONE (415) 586-7460 Superior Court of Califomia, County of San Francisco By Robert H. Peterson, III, Bar #111963 09/24/2015 Clerk of the Court ATTORNEYS FOR Defendant, BY:ROMY RISK JENNIFER NGAI eee SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO ASHLEY HERSHBERGER, No. CGC-15-547392 Plaintiff DEFENDANT JENNIFER NGAI’S REQUEST FOR COURT TO TAKE vs. JUDICIAL NOTICE [Evid. Code Sections 451 to 453] JENNIFER NGAI, WOON KEUNG NGAI, and DOES 1 through 20, Date of Hearing: February 24, 2016 Place: Dept. 302 Defendants Time: 9:30 a.m. Reference Number: 09230224-05 TO Plaintiff ASHLEY HERSHBERGER and to her attorney of record: PLEASE TAKE NOTICE that Defendant JENNIFER NGAI, in support of her motion to strike complaint and in support of her motion for demurrer, respectfully requests the court to take judicial notice, pursuant to section 452 and 453 of the Evidence Code, of the following: 1. Grant Deed recorded December 8, 2011. A true and correct certified copy of the Grant Deed for Subject Premises (1602 24" Avenue) is attached as Exhibit A. Dated: September 23, 2015 Respectfully submitted, PETERSON & PETERSON By ROBERT H. PETERSON, III Attorney for Defendant Jennifer Ngai DEFENDANT JENNIFER NGAI’S REQUEST FOR COURT TO TAKE JUDICIAL NOTICE, Page 1oO 0 ow N ® wo PF WN BS mn NN NY NY SB BB Ba Bw Ba Baw aw Bw ® NB RR 8 RR 8 6b eas ae BD S PROOF OF SERVICE |, ROBERT H. PETERSON, II, am employed in the City and County of San Francisco, State of California. | am over the age of 18 years and not a party to the within action. My business address is 769 Monterey Blvd., San Francisco, California 94127. On September 23, 2015, | served the foregoing JENNIFER NGAI’S REQUEST FOR COURT TO TAKE JUDICIAL NOTICE on each person named below by placing a true copy thereof, enclosed in a sealed envelope, addressed as follows: Mark Hooshmand Jasna Veledar Hooshmand Law Group 22 Battery St., Ste 610 San Francisco, CA 94111 | am readily familiar with the business’ practice for the collection and processing of correspondence for mailing with the United States Postal Service and the fact that the correspondence would be deposited with the United States Postal Service that same day in the ordinary course of business. On this date, the above-referenced correspondence was place for deposit at San Francisco, California, and placed for collection and mailing following ordinary business practices. | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Dated: September 23, 2015 L—— ROBERT H. PETERSON, III DEFENDANT JENNIFER NGAI’S REQUEST FOR COURT TO TAKE JUDICIAL NOTICE, Page 2EXHIBIT ACERTIFIED COPY sl MA RECORDING REQUESTED BY - Feanclege Assessor-Recorder First American Title Company Ting Assesser-Recorder Pa Bo. 2011-J312954-00 AND WHEN RECORDED MAIL DOCUMENT TO: | fect 3-FIRST AMERICAN Titie Company Woon Keing Ngai Thursday, DEC 08, 2011 08:20:20 125 San Rafael Way Tel Pd 00 Rept # 0004292904 San Francisco, CA 94127 REEL K538 IMAGE 0026 afe/FT/1-2 f / Space Above This Line for Recorder's Use Only AW AP.N.: LOT: 050, BLOCK: 1920 File No.: 3802-3831379 (nic) Property Address: 1600-1602 24th Avenue, San Francisco, CA 94122 Lot Number: Block Number: GRANT DEED ‘The Undersigned Grantor(s) Dedare(s): DOCUMENTARY TRANSFER TAX $; CITY TRANSFER TAX $; ‘SURVEY MONUMENT FEE $ [ ] computed on the consideration or full value of property conveyed, OR ] ‘computed on the consideration or full value less value of Hlens and/or encumbrances remaining at time of sale, |] unincorporated area; [X } City of San Francisco, and ] x Exempt from wansfer tax; Reason: Remove from Individual back to Trust { [ FOR A VALUABLE CONSIDERATION, receipt of which Is hereby acknowledged, Woon Keung Ngal and Mo Yee Ngal, Husband and Wife hereby GRANT(s) to Woon Keung Ngal and Mo Yee Ngal, As Trustees of the Woon Keung Ngal and Mo Yee Ngal Revocable Trust 2002 the following described property in the City of San Francisco, County of San Francisco, State of California: BEGINNING AT THE POINT OF INTERSECTION OF THE SOUTHERLY LINE OF LAWTON STREET WITH THE EASTERLY LINE OF 24TH AVENUE; RUNNING THENCE SOUTHERLY ALONG SAID LINE OF 24TH AVENUE 25 FEET; THENCE AT A RIGHT ANGLE EASTERLY 95 FEET; THENCE AT ARIGHT ANGLE NORTHERLY 25 FEET TO THE SOUTHERLY LINE OF LAWTON STREET; THENCE AT A RIGHT ANGLE WESTERLY ALONG SAID LINE OF LAWTON STREET 95 FEET TO THE POINT OF BEGINNING. BEING A PORTION OF OUTSIDE LAND BLOCK NO. 842. Mall Tax Statements To: SAME AS ABOVECERTIFIED COPY Grant Deed - continued Date: 11/29/2011 A.P.N.: LOT: 050, BLOCK: 1920 yer File No.: 3802-3831379 (nic) Dated: __13/29/2011 fet therrborie née We nae Woon Keung Ngal bee Mo Yee Ngai STATEOR «= _ Cahsfo— d ss COUNTY OF = On fal before me, Mb ft Cle Notary Public, personally dppefred oe ws 2 7 who to me on the basis of ry evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same In his/her/their authorized capacity(les), and that by his/her/their signature(s) on the Instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph Is true and correct. WITNESS my hand and official seal. eee ANCY LOK CHAN oN i wasn Signa BH SS reancisco COUNTY © Anak 5>/COMM. EXPIKES JUNE 23, 2035 7 t My Commission Expires; This area for official notarial seal Notary Name: Notary Phone: Notary Registration Numbers County of Principal Place of Business:, Page 2of 2CERTIFIED COpy This is a true certifieg Copy of the record if it bears the Seal, imprinted in purple ink, of the Assessor-Recorder CARMEN CI) {SEP 22 on Darrelyn Butler