Motion,Ex Parte: San Francisco Pizza, Inc et al vs Vietnam Town Condominium Owners Association, Inc et al

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                                GUY W. STILSON, SBN 142194
     LOW, BALL & LYNCH
     505 Montgomery Street, 7th Floor
     San Francisco, California 94111
     Telephone:    (415) 981-6630
     Facsimile:    (415) 982-1634
     gstilson@lowball.com


     Attorney for Defendant
     MATRIX REAL ESTATE SERVICES, INC.,
     sued herein as MATRIX ASSOCIATION MANAGEMENT

                             IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                       IN AND FOR THE COUNTY OF SANTA CLARA
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11   SAN FRANCISCO PIZZA, INC., TAN                                     No. 17CV318151
     NGUYEN, NGHIA NGUYEN and KIM
12   THUY HO,                                                            (Unlimited Jurisdiction)
13                                 Plaintiffs,
                                                                        NOTICE OF HEARING ON MATRIX’
14            vs.                                                       DEMURRERS TO PLAINTIFFS’
                                                                        VERIFIED COMPLAINT
15   VIETNAM TOWN CONDOMINIUM
     OWNERS ASSOCIATION, INC.; MATRIX
16   ASSOCIATION MANAGEMENT; JOSEPH
     NGUYEN, an individual, LAP T. TANG, an                              Date:          May 31, 2018
17   individual; MICHAEL JOHNSON, an                                     Time:          9:00 a.m.
     individual; DAVID ALVARADO, an                                      Dept.:         19
18   individual; AQUATEK PLUMBING, INC., a                               Judge:         Hon. Peter Kirwan
     California corporation; and DOES 1 through
19   50 inclusive,                                                       Complaint Filed:       October 25, 2017
                                                                         Trial Date:            Not Yet Set
20                                 Defendants.

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22   TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS:

23             YOU ARE HEREBY NOTIFIED that at the time and place set forth above, or as soon thereafter

24   as the court may provide, Defendant MATRIX REAL ESTATE SERVICES, INC., sued herein as

25   MATRIX ASSOCIATION MANAGEMENT (“Matrix”), will request the above-entitled honorable

26   court rule on Matrix’ demurrers to Plaintiffs’ “Verified Complaint For Trespass, Conversion,

27   Intentional Interference With Prospective Economic Advantage, Breach Of Contract, Declaratory

28   Relief, Fraud, Negligent Misrepresentation And Civil Extortion” (the “Complaint”).

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                 NOTICE OF HEARING ON MATRIX’ DEMURRERS TO PLAINTIFFS’ VERIFIED COMPLAINT
     J:M1089\SF0043\Pleadings\Demurrer Strike 001\NOM Demurrers.docx.
YOU ARE FURTHER NOTIFIED that Matrix is also moving to strike portions of plaintiffs’

     Complaint and is requesting the hearing on its motion to strike be held concurrently with the hearing on

     its demurrers. Please see Matrix’ Notice of Motion and Motion to Strike which is being filed and served
     simultaneously herewith. Please note that in order to save time and space, Matrix is submitting a single

     brief which addresses the issues relating to both its demurrers and motion to strike.

               The motion will be based upon this notice of motion, Matrix’ statement of demurrers, the

     supporting memorandum of points and authorities, the supporting request for judicial notice, and upon

     such argument and evidence as may be submitted in connection with the hearing on this matter.


10             Dated: February 23, 2018

11                                                                     LOW, BALL & LYNCH
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13                                                               By.
                                                                       GUY W.   STILSO!
14                                                                     Attorney for Attorne   efendant
                                                                       MATRIX REAL ESTATE SERVICES, INC.,
15                                                                     sued herein as MATRIX ASSOCIATION
                                                                       MANAGEMENT
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                 NOTICE OF HEARING ON MATRIX’ DEMURRERS TO PLAINTIFFS’ VERIFIED COMPLAINT
     J:\1089\SF0043\Pleadings\Demurrer Strike 001\NOM Demurrers.docx