Preview
jan Francisco CA 94105
‘ax (415) 778-0700
www.hedanichoy.com
ing & Salvagione, LLP
om ND HW PF WN
NN N RM se se ese Be Be Be Be Be eB
RBRRFRREBBRFES SeRERARFAREBSEHREeS
RANDALL P. CHOY (SBN 83194)
CHARLIE W. YU (SBN 268233) ELECTRONICALLY
HEDANI, CHOY, SPALDING & SALVAGIONE LLP FILED
595 Market Street, Suite 1100
San Francisco, CA 94105 i coins bean mamceeo ft
Telephone: (415) 778-0800 09/20/2016
Facsimile: (415) 778-0700 /20/
Clerk of the Court
Er BY:VANESSA WU
Attorneys for Plaintiff Deputy Clerk
SEAN MARTIN
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
UNLIMITED CIVIL JURISDICTION
SEAN MARTIN, an individual, CASE NO. CGC-14-538489
Plaintiff, MARTIN’S REPLY IN SUPPORT OF
MOTION FOR ORDER APPOINTING
vs. RECEIVER TO ENFORCE JUDGMENT
SHANON LOFTUS, an individual; [CCP §§ 564, 708.620}
CHRISTOPHER FENSTER, an individual;
and DOES 1 through 50, inclusive, Date: September 26, 2016
Time: 1:30 pm
Defendants. Dept.: 514
Judge: The Honorable Judge Quinn
This is a Motion for Order Appointing Receiver to Enforce Judgment. Plaintiff SEAN
MARTIN and Defendant SHANON LOFTUS entered into a Stipulated Judgment pursuant to a
partition action. The terms of the Stipulated Judgment are that Defendant SHANON LOFTUS
is to refinance the property and pay Plaintiff SEAN MARTIN $300,000.00 and remove his
name from the mortgage. Thereafter, Plaintiff SEAN MARTIN will quitclaim the property at
issue to Defendant SHANON LOFTUS. The terms of the Stipulated Judgment also provide
that Defendant SHANON LOFTUS shall be responsible for the mortgage and all debts incurred
to Christopher Fenster commencing October 8, 2015.
The Motion for Oder Appointing Receiver to Enforce Judgment was originally set for
April 25, 2016. Thereafter, the moving party Plaintiff SEAN MARTIN continued the hearing
1
MARTIN’S REPLY IN SUPPORT OF MOTION FOR ORDER APPOINTING RECEIVER TO
ENFORCE JUDGMENT
CASE NO. CGC-14-538489}) 778-0800 | Fax (415) 778-0700
wow.hedanichoy.com
Cem YD HW FF WBN
= 6
12
date numerous times until the most recent date of September 26, 2016 under the assumption
that Defendant SHANON LOFTUS was close to refinancing the property and paying Plaintiff
SEAN MARTIN the $300,000.00 that became due on February 12, 2016 (with interest accruing
at 10% on the judgment). It is Plaintiff SEAN MARTIN’s understanding that Defendant
SHANON LOFTUS is still close to obtaining financing, with the mortgage broker appraising
the house on September 19, 2016. However, Plaintiff SEAN MARTIN is also concerned that
the parties will always be close but not quite there without the proper motivation.
Therefore, the Plaintiff SEAN MARTIN respectfully requests that this Court appoint a
receiver to sell Plaintiff SEAN MARTIN and Defendant SHANON LOFTUS’ interest in the
subject property. To the extent the refinancing is successful prior to retaining the Receiver,
there is no harm no foul. However, given that the refinancing was to occur before February 12,
2016, Plaintiff SEAN MARTIN is compelled to move ahead.
Moreover, Plaintiff SEAN MARTIN is also aware of an issue between Defendant
SHANON LOFTUS and third party Christopher Fenster in that Christopher Fenster wants his
debts from Defendant SHANON LOFTUS paid through escrow in order to sign off on the
refinancing, however, it is unclear whether Defendant SHANON LOFTUS is willing to provide
for his debt through the refinancing. To the extent Defendant SHANON LOFTUS refuses to
pay for her portion of the Fenster debt, Mr. Fenster will not agree to the refinance.
Plaintiff SEAN MARTIN requests that the Court appoint a receiver. Plaintiff SEAN
MARTIN is fine with any receiver of the Court’s choosing, but recommended Justice Harry
Low. Recently, Plaintiff SEAN MARTIN has also be in contact with Mr. Kevin Singer of
Receivership Specialists who charges $250.00 an hour, and his CV is attached.
DATED: September 20, 2016 HEDANI, CHOY, SPALDING & SALVAGIONE
CHARLIE W. YU
Attorney for Plaintiff
SEAN MARTIN
2
MARTIN’S REPLY IN SUPPORT OF MOTION FOR ORDER APPOINTING RECEIVER TO
ENFORCE JUDGMENT
CASE NO. CGC-14-538489RECEIVERSHIP SPECIALISTS
STATE AND U.S. FEDERAL COURT RECEIVERS/TRUSTEES
Kevin Singer
Court Receiver, Court Referee, Bankruptcy Trustee
Cell: (323) 864-4214
E-mail: Kevin @ReceivershipSpecialists.com
Web: www.ReceivershipSpecialists.com
Kevin Singer is founder and President of Receivership Specialists and with his business
partner John Rachlin, they specialize in state and federal court receiverships, referee assignments,
partition sales, provisional director assignments and Bankruptcy Trustee assignments.
Receivership Specialists has offices in Los Angeles, San Francisco, Sacramento, San Diego,
Phoenix, Reno, Las Vegas and Denver and handles assignments throughout the Southwest. The
alliance of these two professionals brings together their vast knowledge and experience in the areas
of law, real estate, business management, construction, and conflict resolution.
Mr. Singer first started getting appointed as a rents & profits receiver due to his extensive
real estate, property management and construction experience as founder and co-owner of a
diversified real estate and consulting company. He is both a California Real Estate Broker and
Licensed Building Contractor. After selling that company in 2000, Mr. Singer once again joined
forces with his long time counsel, friend and business partner, Mr. Rachlin, to specialize in
receivership assignments. Mr. Rachlin is co-founder and CEO of Receivership Specialists and
has been a licensed attorney for 22 years. Mr. Rachlin has practiced in various areas of real
estate and general business law, as well as serving as in-house counsel for a large real estate
company. Over the past fifteen years, Mr. Singer and Mr. Rachlin have handled over 261 cases for
large and small banks, private lenders, private investors and municipalities. They have also
managed and transitioned over a billion dollars in assets. Mr. Singer has served as a Receiver,
Referee, and Bankruptcy Trustee over all different types of real estate, businesses, gas stations,
hotels, assisted living facilies, restaurants, bars, liquor licenses, family estates/trusts, commodities
and construction projects. Mr. Singer is currently on the Board of Directors for the California
Receivers Forum (CRF), an Associate Publisher for Receivership News, five time participant and
panelist at the CRF in Conjunction with Loyola Law School Receivers Education Program and he
lecturers and writes on various topics in the receivership field.
Corporate Headquarters
Los Angeles
| 11150 W. Olympic Blvd.
Suite 810
Los Angeles, CA 90064
Tel: (310) 552-9064
Fax: (310) 552-9066
Fi
795 Folsom Street
Ist Floor
San Francisco, CA 94107
Tel: (415) 848-2984
Fax: (415) 848-2301
‘San Diego
4370 La Jolla Village Drive
Suite 400
San Diego, CA 92122
Tel: (858) 546-4815
Fax: (858) 646-3097
Sacramento
980 9th Street
16th Floor
Sacramento, CA 95814
Tel: (916) 449-9655
Fax: (916) 446-7104
Las Vegas
7251 W. Lake Mead Blvd,
Suite 300
Las Vegas, Nevada 89128
Tel: (702) 562-4230
Fax: (702) 562-4001
Reno
200 S. Virginia Street
Suite 800
Reno, Nevada 89501
Tel: (775) 398-3103
Fax: (775) 686-2401
Phoenix
40 N. Central Ave.
Suite 1400
Phoenix, Arizona, 85004
Tel: (602) 343-1889
Fax: (602) 343-1801HOURLY BILLING RATES: $250 per hour for principals and associates, $185 per hour for project managers
and $85 an hour for support staff.
Affiliated Organizations - Member & Board of Director for California State and Los Angeles/Orange
County Chapter of California Receivers Forum; Bay Area Receivers Forum; San Diego Receivers
Forum, Clark County Bar Association; Maricopa Bar Association, California Apartment Association;
National Apartment Association, National Association of Realtors, California Association of Realtors;
Beverly Hills/Los Angeles Association of Realtors.
Speaking Engagements & Publications
5/13/2016 Medical Marijuana Receiverships (The Law Firm of Gust Rosenfeld, Phoenix Arizona)
10/28/2015 Sex, Drugs, and Section 8:The Seedy Underbelly of Receiverships (Bay Area Receivers Forum)
6/17/2015 Oil Fields & Gas Station Receiverships (Los Angeles/Orange Country Receivers Forum).
Summer 2014 California Receivership News: A Story Of Risk In A Post-Judgment Receivership
9/11/2014 Successful Sale of Assets through Post Judgment Receiverships (Los Angeles/Orange County
Chapter of CRF)
5/2/2014 State & Federal Court Receiverships (Ron Siegel Radio Show)
4/04/2013 Environmental Receiverships (Los Angeles/Orange County Chapter of CRF)
2/22/2013 Business Receiverships (The Law Firm of Wolf, Rifkin, Shapiro, Schulman & Rabkin, LLP)
1/19/2013 Receiverships With Environmental Issues (California Receivers Forum In Conjunction with Loyola
Law School).
Fall 2012 California Receivership News: Interview with Judge Luis A. Lavin
10/31/2011 Selling Personal Property Through Receiverships (Orange County Receivers Forum).
10/17/2011 Receiverships 2012 & Beyond (San Diego Receivers Forum).
Fall 2011 California Receivership News: Receivership Liquor License Sales.
9/26/2011 Condominium Receiverships (Bank & Financial Institutions Forum).
9/22/2011 Receiverships Selling Property and Clearing Title (Los Angeles Receivers Forum).
5/21/2011 Commercial Receiverships (California Bankruptcy Forum).
1/22/2011 Rents & Profits Receiverships (California Receivers Forum in Conjunction with Loyola Law
School).
8/25/2010 Receiverships over Broken Condominium Projects (California Receivers Forum).
10/27/2009 How to Sell Real Estate Though a Partition or Receivership (California Receivers Forum).
8/20/2009 Ask The Commissioner and Receiver (California Receivers Forum).
8/19/2009 Protecting Tenants at Foreclosure Act 2009 and Receiverships (American Legal Financial
Network).
2/25/2009 Partition Referees, a Tool for Estate Management and Sales (Riverside County Bar
Association).
9/11/2008 Breakfast with the Experts (San Diego Receivers Forum).Hedani, Choy, Spalding & Salvagione, LLP
‘www.hedanichoy.com
Ce YN KH A BB YW YD =
Sus
PROOF OF SERVICE
(C.C.P. SECTION 1013a)
Re: Martin v. Loftus, et al.
San Francisco County Superior Court Case No. CGC-14-538489
Iam a citizen of the United States, over the age of 18 years, and not a party to the
within action. I am employed in the City and County of San Francisco, California, and my
business address is 595 Market Street, Suite 1100, San Francisco, California.
On September 20, 2016, service of the enclosed MARTIN’S REPLY IN SUPPORT OF
MOTION FOR ORDER APPOINTING RECEIVER TO ENFORCE JUDGMENT, was
effected on the interested parties in this action by placing a true copy thereof in a sealed envelope
addressed as follows:
Shanon Loftus
151] Baker Street
San Francisco, CA 94115
(415)250-1938
Sloftus415@gmail.com
[Respondent IN PRO PER]
/XX/ (BY MAIL) I placed each such sealed envelope, with postage thereon fully prepaid, on
the date of execution of this declaration, with our office's outgoing mail following
ordinary business practices. I am readily familiar with my employer's business practice
for collection and processing of correspondence for mailing. Such correspondence is
deposited with the United States Postal Service, the same day in the ordinary course of
business.
// (BYELECTRONIC MAIL) By causing the document(s) listed above to be served
electronically mailing a true and correct copy through Hedani, Choy, Spalding &
Salvagione’s electronic mail system to the e-mail address(es), as stated in the above
list, and the transmission was reported as completed and no error was reported.
i/ (BY FACSIMILE) I caused the said document(s) to be transmitted by Facsimile to the
numbers indicated above.
I certify under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed on September 20, 2016, in the City and County of San Francisco, California.
CO A
MIMI MAO MADAYAG
Preview
jan Francisco CA 94105 ‘ax (415) 778-0700 www.hedanichoy.com ing & Salvagione, LLP om ND HW PF WN NN N RM se se ese Be Be Be Be Be eB RBRRFRREBBRFES SeRERARFAREBSEHREeS RANDALL P. CHOY (SBN 83194) CHARLIE W. YU (SBN 268233) ELECTRONICALLY HEDANI, CHOY, SPALDING & SALVAGIONE LLP FILED 595 Market Street, Suite 1100 San Francisco, CA 94105 i coins bean mamceeo ft Telephone: (415) 778-0800 09/20/2016 Facsimile: (415) 778-0700 /20/ Clerk of the Court Er BY:VANESSA WU Attorneys for Plaintiff Deputy Clerk SEAN MARTIN SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO UNLIMITED CIVIL JURISDICTION SEAN MARTIN, an individual, CASE NO. CGC-14-538489 Plaintiff, MARTIN’S REPLY IN SUPPORT OF MOTION FOR ORDER APPOINTING vs. RECEIVER TO ENFORCE JUDGMENT SHANON LOFTUS, an individual; [CCP §§ 564, 708.620} CHRISTOPHER FENSTER, an individual; and DOES 1 through 50, inclusive, Date: September 26, 2016 Time: 1:30 pm Defendants. Dept.: 514 Judge: The Honorable Judge Quinn This is a Motion for Order Appointing Receiver to Enforce Judgment. Plaintiff SEAN MARTIN and Defendant SHANON LOFTUS entered into a Stipulated Judgment pursuant to a partition action. The terms of the Stipulated Judgment are that Defendant SHANON LOFTUS is to refinance the property and pay Plaintiff SEAN MARTIN $300,000.00 and remove his name from the mortgage. Thereafter, Plaintiff SEAN MARTIN will quitclaim the property at issue to Defendant SHANON LOFTUS. The terms of the Stipulated Judgment also provide that Defendant SHANON LOFTUS shall be responsible for the mortgage and all debts incurred to Christopher Fenster commencing October 8, 2015. The Motion for Oder Appointing Receiver to Enforce Judgment was originally set for April 25, 2016. Thereafter, the moving party Plaintiff SEAN MARTIN continued the hearing 1 MARTIN’S REPLY IN SUPPORT OF MOTION FOR ORDER APPOINTING RECEIVER TO ENFORCE JUDGMENT CASE NO. CGC-14-538489}) 778-0800 | Fax (415) 778-0700 wow.hedanichoy.com Cem YD HW FF WBN = 6 12 date numerous times until the most recent date of September 26, 2016 under the assumption that Defendant SHANON LOFTUS was close to refinancing the property and paying Plaintiff SEAN MARTIN the $300,000.00 that became due on February 12, 2016 (with interest accruing at 10% on the judgment). It is Plaintiff SEAN MARTIN’s understanding that Defendant SHANON LOFTUS is still close to obtaining financing, with the mortgage broker appraising the house on September 19, 2016. However, Plaintiff SEAN MARTIN is also concerned that the parties will always be close but not quite there without the proper motivation. Therefore, the Plaintiff SEAN MARTIN respectfully requests that this Court appoint a receiver to sell Plaintiff SEAN MARTIN and Defendant SHANON LOFTUS’ interest in the subject property. To the extent the refinancing is successful prior to retaining the Receiver, there is no harm no foul. However, given that the refinancing was to occur before February 12, 2016, Plaintiff SEAN MARTIN is compelled to move ahead. Moreover, Plaintiff SEAN MARTIN is also aware of an issue between Defendant SHANON LOFTUS and third party Christopher Fenster in that Christopher Fenster wants his debts from Defendant SHANON LOFTUS paid through escrow in order to sign off on the refinancing, however, it is unclear whether Defendant SHANON LOFTUS is willing to provide for his debt through the refinancing. To the extent Defendant SHANON LOFTUS refuses to pay for her portion of the Fenster debt, Mr. Fenster will not agree to the refinance. Plaintiff SEAN MARTIN requests that the Court appoint a receiver. Plaintiff SEAN MARTIN is fine with any receiver of the Court’s choosing, but recommended Justice Harry Low. Recently, Plaintiff SEAN MARTIN has also be in contact with Mr. Kevin Singer of Receivership Specialists who charges $250.00 an hour, and his CV is attached. DATED: September 20, 2016 HEDANI, CHOY, SPALDING & SALVAGIONE CHARLIE W. YU Attorney for Plaintiff SEAN MARTIN 2 MARTIN’S REPLY IN SUPPORT OF MOTION FOR ORDER APPOINTING RECEIVER TO ENFORCE JUDGMENT CASE NO. CGC-14-538489RECEIVERSHIP SPECIALISTS STATE AND U.S. FEDERAL COURT RECEIVERS/TRUSTEES Kevin Singer Court Receiver, Court Referee, Bankruptcy Trustee Cell: (323) 864-4214 E-mail: Kevin @ReceivershipSpecialists.com Web: www.ReceivershipSpecialists.com Kevin Singer is founder and President of Receivership Specialists and with his business partner John Rachlin, they specialize in state and federal court receiverships, referee assignments, partition sales, provisional director assignments and Bankruptcy Trustee assignments. Receivership Specialists has offices in Los Angeles, San Francisco, Sacramento, San Diego, Phoenix, Reno, Las Vegas and Denver and handles assignments throughout the Southwest. The alliance of these two professionals brings together their vast knowledge and experience in the areas of law, real estate, business management, construction, and conflict resolution. Mr. Singer first started getting appointed as a rents & profits receiver due to his extensive real estate, property management and construction experience as founder and co-owner of a diversified real estate and consulting company. He is both a California Real Estate Broker and Licensed Building Contractor. After selling that company in 2000, Mr. Singer once again joined forces with his long time counsel, friend and business partner, Mr. Rachlin, to specialize in receivership assignments. Mr. Rachlin is co-founder and CEO of Receivership Specialists and has been a licensed attorney for 22 years. Mr. Rachlin has practiced in various areas of real estate and general business law, as well as serving as in-house counsel for a large real estate company. Over the past fifteen years, Mr. Singer and Mr. Rachlin have handled over 261 cases for large and small banks, private lenders, private investors and municipalities. They have also managed and transitioned over a billion dollars in assets. Mr. Singer has served as a Receiver, Referee, and Bankruptcy Trustee over all different types of real estate, businesses, gas stations, hotels, assisted living facilies, restaurants, bars, liquor licenses, family estates/trusts, commodities and construction projects. Mr. Singer is currently on the Board of Directors for the California Receivers Forum (CRF), an Associate Publisher for Receivership News, five time participant and panelist at the CRF in Conjunction with Loyola Law School Receivers Education Program and he lecturers and writes on various topics in the receivership field. Corporate Headquarters Los Angeles | 11150 W. Olympic Blvd. Suite 810 Los Angeles, CA 90064 Tel: (310) 552-9064 Fax: (310) 552-9066 Fi 795 Folsom Street Ist Floor San Francisco, CA 94107 Tel: (415) 848-2984 Fax: (415) 848-2301 ‘San Diego 4370 La Jolla Village Drive Suite 400 San Diego, CA 92122 Tel: (858) 546-4815 Fax: (858) 646-3097 Sacramento 980 9th Street 16th Floor Sacramento, CA 95814 Tel: (916) 449-9655 Fax: (916) 446-7104 Las Vegas 7251 W. Lake Mead Blvd, Suite 300 Las Vegas, Nevada 89128 Tel: (702) 562-4230 Fax: (702) 562-4001 Reno 200 S. Virginia Street Suite 800 Reno, Nevada 89501 Tel: (775) 398-3103 Fax: (775) 686-2401 Phoenix 40 N. Central Ave. Suite 1400 Phoenix, Arizona, 85004 Tel: (602) 343-1889 Fax: (602) 343-1801HOURLY BILLING RATES: $250 per hour for principals and associates, $185 per hour for project managers and $85 an hour for support staff. Affiliated Organizations - Member & Board of Director for California State and Los Angeles/Orange County Chapter of California Receivers Forum; Bay Area Receivers Forum; San Diego Receivers Forum, Clark County Bar Association; Maricopa Bar Association, California Apartment Association; National Apartment Association, National Association of Realtors, California Association of Realtors; Beverly Hills/Los Angeles Association of Realtors. Speaking Engagements & Publications 5/13/2016 Medical Marijuana Receiverships (The Law Firm of Gust Rosenfeld, Phoenix Arizona) 10/28/2015 Sex, Drugs, and Section 8:The Seedy Underbelly of Receiverships (Bay Area Receivers Forum) 6/17/2015 Oil Fields & Gas Station Receiverships (Los Angeles/Orange Country Receivers Forum). Summer 2014 California Receivership News: A Story Of Risk In A Post-Judgment Receivership 9/11/2014 Successful Sale of Assets through Post Judgment Receiverships (Los Angeles/Orange County Chapter of CRF) 5/2/2014 State & Federal Court Receiverships (Ron Siegel Radio Show) 4/04/2013 Environmental Receiverships (Los Angeles/Orange County Chapter of CRF) 2/22/2013 Business Receiverships (The Law Firm of Wolf, Rifkin, Shapiro, Schulman & Rabkin, LLP) 1/19/2013 Receiverships With Environmental Issues (California Receivers Forum In Conjunction with Loyola Law School). Fall 2012 California Receivership News: Interview with Judge Luis A. Lavin 10/31/2011 Selling Personal Property Through Receiverships (Orange County Receivers Forum). 10/17/2011 Receiverships 2012 & Beyond (San Diego Receivers Forum). Fall 2011 California Receivership News: Receivership Liquor License Sales. 9/26/2011 Condominium Receiverships (Bank & Financial Institutions Forum). 9/22/2011 Receiverships Selling Property and Clearing Title (Los Angeles Receivers Forum). 5/21/2011 Commercial Receiverships (California Bankruptcy Forum). 1/22/2011 Rents & Profits Receiverships (California Receivers Forum in Conjunction with Loyola Law School). 8/25/2010 Receiverships over Broken Condominium Projects (California Receivers Forum). 10/27/2009 How to Sell Real Estate Though a Partition or Receivership (California Receivers Forum). 8/20/2009 Ask The Commissioner and Receiver (California Receivers Forum). 8/19/2009 Protecting Tenants at Foreclosure Act 2009 and Receiverships (American Legal Financial Network). 2/25/2009 Partition Referees, a Tool for Estate Management and Sales (Riverside County Bar Association). 9/11/2008 Breakfast with the Experts (San Diego Receivers Forum).Hedani, Choy, Spalding & Salvagione, LLP ‘www.hedanichoy.com Ce YN KH A BB YW YD = Sus PROOF OF SERVICE (C.C.P. SECTION 1013a) Re: Martin v. Loftus, et al. San Francisco County Superior Court Case No. CGC-14-538489 Iam a citizen of the United States, over the age of 18 years, and not a party to the within action. I am employed in the City and County of San Francisco, California, and my business address is 595 Market Street, Suite 1100, San Francisco, California. On September 20, 2016, service of the enclosed MARTIN’S REPLY IN SUPPORT OF MOTION FOR ORDER APPOINTING RECEIVER TO ENFORCE JUDGMENT, was effected on the interested parties in this action by placing a true copy thereof in a sealed envelope addressed as follows: Shanon Loftus 151] Baker Street San Francisco, CA 94115 (415)250-1938 Sloftus415@gmail.com [Respondent IN PRO PER] /XX/ (BY MAIL) I placed each such sealed envelope, with postage thereon fully prepaid, on the date of execution of this declaration, with our office's outgoing mail following ordinary business practices. I am readily familiar with my employer's business practice for collection and processing of correspondence for mailing. Such correspondence is deposited with the United States Postal Service, the same day in the ordinary course of business. // (BYELECTRONIC MAIL) By causing the document(s) listed above to be served electronically mailing a true and correct copy through Hedani, Choy, Spalding & Salvagione’s electronic mail system to the e-mail address(es), as stated in the above list, and the transmission was reported as completed and no error was reported. i/ (BY FACSIMILE) I caused the said document(s) to be transmitted by Facsimile to the numbers indicated above. I certify under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on September 20, 2016, in the City and County of San Francisco, California. CO A MIMI MAO MADAYAG