Preview
Shawn M. Olson, Esq. (SBN 245688)
OLSON LAW FIRM
Facsimile: (714) 847-2550
MS SERVICES, LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SANTA CLARA —- DOWNTOWN COURTHOUSE
MS SERVICES, LLC, a Wyoming limited
liability company,
Judge: Hon. James L. Stoelker
PLAINTIFF MS SERVICES, LLC’S
REQUEST FOR JUDICIAL NOTICE IN
SUPPORT OF MOTION FOR
9:00 a.m.
Order; Memorandum of Points and
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that plaintiff/judgment creditor MS SERVICES, LLC, by
California Evidence
Code section 452, of the following documents:
JUDGMENT CREDITOR’S MOTION FOR ASSIGNMENT ORDER-
REQUEST FOR JUDICIAL NOTICE NO.1:
State of California, Department of Real Estate website printout reflecting the license
status of defendant/judgment debtor CONNIE L. MARTIN, a true an
is attached hereto as Exhibit “1”.
REQUEST FOR JUDICIAL NOTICE NO.2:
State of California, Department of Real Estate website printout reflecting the license
status of Water Wheel Enterprises, Inc. dba Exit Realty Keyston
Judicial notice is the “recognition and acceptance by the court
fact or by the court, of the existence ofa matter of law or fa
action without requiring formal proof of the matter.” ( Lockley
v. Law Office of Cantrell,
Judicial notice of this matter is proper because it is not reas
and the fact is capable of immediate and accurate determination
records of the Department of Real Estate, whose records are of
accuracy and are up-to-date.
Based on the foregoing authorities, Judgment Creditor respectfu
OLSON LAW FIRM
Dated: August 14, 2018 By: J772 Cm
ae Ad
Judgment Creditor MS SERVICES, LLC
JUDGMENT CREDITOR’S MOTION FOR ASSIGNMENT ORDER- 2
EXHIBIT
oT 9
8/14/2018 www2.dre.ca.gov/publicasp/pplinfo.asp?License_id=01043538
STATE OF CALIFORNIA
DEPARTMENT OF REAL ESTATE
The license information shown below represents public information taken from the Department of Real Estate(DRE) database at the time of
your inquiry. It will not reflect pending changes which are being reviewed for subsequent database updating. Also, the license information
provided includes formal administrative actions that have been taken against licensees pursuant to the Business and Professions Code and/or
the Administrative Procedure Act. All of the information displayed is public information. Although the business and mailing addresses of real
estate licensees are included, this information is not intended for mass mailing purposes.
License information taken from records of the Department of Real Esa! on) S/14/2018 HLS 505 A
os
License Type: SALESPERSON
Name: Martin, Connie Lynn
Mailing Address: 25 W 1ST STREET
MORGAN HILL, CA 95037
License ID: 01043538
Expiration Date: 10/21/21
License Status: LICENSED
Salesperson License Issued 09/20/89 (Unofficial -- taken from secondary records)
Former Name(s): NO FORMER NAMES
Employing Broker: License ID: 01348955
Water Wheel Enterprises Inc
25 W 1ST ST
MORGAN HILL, CA 95037
Comment: NO DISCIPLINARY ACTION
NO OTHER PUBLIC COMMENTS
>>>> Public information request complete <<<<
http:/Awww2.dre.ca-gov/publicasp/pplinfo.asp?License_id=01043538 41
EXHIBIT
“9 99
8/14/2018 www2.dre.ca.gov/PublicASP/pplinfo.asp?start=1
STATE OF CALIFORNIA
DEPARTMENT OF REAL ESTATE
The license information shown below represents public information taken from the Department of Real Estate(DRE) database at the time of
your inquiry. It will not reflect pending changes which are being reviewed for subsequent database updating. Also, the license information
provided includes formal administrative actions that have been taken against licensees pursuant to the Business and Professions Code and/or
the Administrative Procedure Act. All of the information displayed is public information. Although the business and mailing addresses of real
estate licensees are included, this information is not intended for mass mailing purposes.
License information taken from records of the Department of Real Estate: on B/1A/2018 HO ;G7:49 AM
=
License Type: CORPORATION
Name: Water Wheel Enterprises Inc
Mailing Address: 25 W 1ST ST
MORGAN HILL, CA 95037
License ID: 01348955
Expiration Date: 08/16/18
License Status: LICENSED
Corporation License Issued: 08/17/02
Former Name(s): NO FORMER NAMES.
Main Office: 25 W 1ST ST
MORGAN HILL, CA 95037
Licensed Officer(s) DESIGNATED OFFICER
01183425 - Expiration Date: 08/16/18
Vierra, Margaret Albertina
DBA Exit Realty Keystone
ACTIVE AS OF 08/17/2002
Key Lending Group
ACTIVE FROM 11/17/2004 TO 05/30/2011
Branches: 940 SARATOGA AVE STE 100
SAN JOSE, CA 95129
Broker Associates: 01082119 - Menor, Florentino G
License Expiration Date : 03/06/2020
Salespersons: 01783780 - Adineh, Reza
License Expiration Date : 01/04/2021
00898712 - Boigon, Shanna R.M.
License Expiration Date : 12/17/2021
01784315 - Bustillos, Juan Carlos
License Expiration Date : 10/28/2020
01343055 - Butron, Andrew Robert
hitp:/www2.dre.ca.gov/PublicASP/pplinfo.asp?start=1 1/2
8/14/2018 www2.dre.ca.gov/PublicASP/pplinfo.asp?start=1
License Expiration Date: 04/17/2020
02036185 - Castro, Veronica
License Expiration Date 05/31/2021
01891865 - Cheng, Judy P
License Expiration Date 11/29/2018
00670619 - Dupree, Rolly Cid
License Expiration Date 05/01/2022
1045961 - Johnson, Darryl D
License Expiration Date 12/02/2021
01451295 - Lofano, Annette Chanel
License Expiration Date 09/26/2021
1043538 - Martin, Connie Lynn
License Expiration Date 10/21/2021
01419445 - Meneses, Edgar Javier
License Expiration Date: 03/03/2020
02043901 - Ramirez Rodriguez, Edith Araceli
License Expiration Date: 11/15/2021
01447603 - Rodgers, Celeste
License Expiration Date: 08/13/2020
02016515 - Rojas, Mikaela Noel
License Expiration Date: 10/05/2020
02063320 - Vierra, Kathleen Ann
License Expiration Date: 05/21/2022
Comment: NO DISCIPLINARY ACTION
NO OTHER PUBLIC COMMENTS
>>>> Public information request complete <<<<
http:/Awww2.dre.ca.gov/PublicASP/pplinfo.asp?start=1 2/2
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF ORANGE
Jam an employee in the County of Orange, State of California. I am over the age of 18
and not a party to the within action; my business address is 7372 Prince Drive, Suite 104,
Huntington Beach, CA 92647.
On August 1S. 2018, I served the foregoing document(s) described, PLAINTIFF
MS SERVICES, LLC’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
MOTION FOR ASSIGNMENT ORDER, to the interested parties in this action by electronic
service as follows:
Connie L. Martin
1000 Rucker Avenue
Gilroy, CA 95020
10
XX_ (BY MAIL) The package was delivered with postage thereon fully prepaid. | am
i
“readily” familiar with the firm’s practice of collection and processing correspondence
12 for mailing. The package was deposited with U.S. Postal Service on that same day in
the ordinary course of business. | am aware that on motion of a party served, service is
13 presumed invalid if the postal cancellation date or postage meter date is more than one
day after date of deposit for mailing an affidavit.
14
18 _ VIA Electronic Service. I certify that I will cause a copy of the above document to be
served upon the following counsel via One Legal on August 18, 2015.
16
{OVERNIGHT COURIER) I caused such envelope to be deposited in the mail
17
at Huntington Beach, California, United Postal Service. The envelope was mailed
18 with postage thereon fully prepaid. I am “readily” familiar with the firm’s
practice of collection and processing correspondence for mailing. The package
19 was deposited with United Postal Service on that same day in the ordinary course
of business. [ am aware that on motion of a party served, service is presumed
20
invalid if the postal cancellation date or postage meter date is more than one day
21 after date of deposit for mailing an affidavit.
22 XX_ (STATE) I declare under penalty of perjury under the laws of the State of California that
the above is true and correct.
moet
23
24 August 2018
Date Michael Moore
25
26
27
28
JUDGMENT CREDITOR’S MOTION FOR ASSIGNMENT ORDER- 3
Preview
Shawn M. Olson, Esq. (SBN 245688) OLSON LAW FIRM Facsimile: (714) 847-2550 MS SERVICES, LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA —- DOWNTOWN COURTHOUSE MS SERVICES, LLC, a Wyoming limited liability company, Judge: Hon. James L. Stoelker PLAINTIFF MS SERVICES, LLC’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION FOR 9:00 a.m. Order; Memorandum of Points and TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that plaintiff/judgment creditor MS SERVICES, LLC, by California Evidence Code section 452, of the following documents: JUDGMENT CREDITOR’S MOTION FOR ASSIGNMENT ORDER- REQUEST FOR JUDICIAL NOTICE NO.1: State of California, Department of Real Estate website printout reflecting the license status of defendant/judgment debtor CONNIE L. MARTIN, a true an is attached hereto as Exhibit “1”. REQUEST FOR JUDICIAL NOTICE NO.2: State of California, Department of Real Estate website printout reflecting the license status of Water Wheel Enterprises, Inc. dba Exit Realty Keyston Judicial notice is the “recognition and acceptance by the court fact or by the court, of the existence ofa matter of law or fa action without requiring formal proof of the matter.” ( Lockley v. Law Office of Cantrell, Judicial notice of this matter is proper because it is not reas and the fact is capable of immediate and accurate determination records of the Department of Real Estate, whose records are of accuracy and are up-to-date. Based on the foregoing authorities, Judgment Creditor respectfu OLSON LAW FIRM Dated: August 14, 2018 By: J772 Cm ae Ad Judgment Creditor MS SERVICES, LLC JUDGMENT CREDITOR’S MOTION FOR ASSIGNMENT ORDER- 2 EXHIBIT oT 9 8/14/2018 www2.dre.ca.gov/publicasp/pplinfo.asp?License_id=01043538 STATE OF CALIFORNIA DEPARTMENT OF REAL ESTATE The license information shown below represents public information taken from the Department of Real Estate(DRE) database at the time of your inquiry. It will not reflect pending changes which are being reviewed for subsequent database updating. Also, the license information provided includes formal administrative actions that have been taken against licensees pursuant to the Business and Professions Code and/or the Administrative Procedure Act. All of the information displayed is public information. Although the business and mailing addresses of real estate licensees are included, this information is not intended for mass mailing purposes. License information taken from records of the Department of Real Esa! on) S/14/2018 HLS 505 A os License Type: SALESPERSON Name: Martin, Connie Lynn Mailing Address: 25 W 1ST STREET MORGAN HILL, CA 95037 License ID: 01043538 Expiration Date: 10/21/21 License Status: LICENSED Salesperson License Issued 09/20/89 (Unofficial -- taken from secondary records) Former Name(s): NO FORMER NAMES Employing Broker: License ID: 01348955 Water Wheel Enterprises Inc 25 W 1ST ST MORGAN HILL, CA 95037 Comment: NO DISCIPLINARY ACTION NO OTHER PUBLIC COMMENTS >>>> Public information request complete <<<< http:/Awww2.dre.ca-gov/publicasp/pplinfo.asp?License_id=01043538 41 EXHIBIT “9 99 8/14/2018 www2.dre.ca.gov/PublicASP/pplinfo.asp?start=1 STATE OF CALIFORNIA DEPARTMENT OF REAL ESTATE The license information shown below represents public information taken from the Department of Real Estate(DRE) database at the time of your inquiry. It will not reflect pending changes which are being reviewed for subsequent database updating. Also, the license information provided includes formal administrative actions that have been taken against licensees pursuant to the Business and Professions Code and/or the Administrative Procedure Act. All of the information displayed is public information. Although the business and mailing addresses of real estate licensees are included, this information is not intended for mass mailing purposes. License information taken from records of the Department of Real Estate: on B/1A/2018 HO ;G7:49 AM = License Type: CORPORATION Name: Water Wheel Enterprises Inc Mailing Address: 25 W 1ST ST MORGAN HILL, CA 95037 License ID: 01348955 Expiration Date: 08/16/18 License Status: LICENSED Corporation License Issued: 08/17/02 Former Name(s): NO FORMER NAMES. Main Office: 25 W 1ST ST MORGAN HILL, CA 95037 Licensed Officer(s) DESIGNATED OFFICER 01183425 - Expiration Date: 08/16/18 Vierra, Margaret Albertina DBA Exit Realty Keystone ACTIVE AS OF 08/17/2002 Key Lending Group ACTIVE FROM 11/17/2004 TO 05/30/2011 Branches: 940 SARATOGA AVE STE 100 SAN JOSE, CA 95129 Broker Associates: 01082119 - Menor, Florentino G License Expiration Date : 03/06/2020 Salespersons: 01783780 - Adineh, Reza License Expiration Date : 01/04/2021 00898712 - Boigon, Shanna R.M. License Expiration Date : 12/17/2021 01784315 - Bustillos, Juan Carlos License Expiration Date : 10/28/2020 01343055 - Butron, Andrew Robert hitp:/www2.dre.ca.gov/PublicASP/pplinfo.asp?start=1 1/2 8/14/2018 www2.dre.ca.gov/PublicASP/pplinfo.asp?start=1 License Expiration Date: 04/17/2020 02036185 - Castro, Veronica License Expiration Date 05/31/2021 01891865 - Cheng, Judy P License Expiration Date 11/29/2018 00670619 - Dupree, Rolly Cid License Expiration Date 05/01/2022 1045961 - Johnson, Darryl D License Expiration Date 12/02/2021 01451295 - Lofano, Annette Chanel License Expiration Date 09/26/2021 1043538 - Martin, Connie Lynn License Expiration Date 10/21/2021 01419445 - Meneses, Edgar Javier License Expiration Date: 03/03/2020 02043901 - Ramirez Rodriguez, Edith Araceli License Expiration Date: 11/15/2021 01447603 - Rodgers, Celeste License Expiration Date: 08/13/2020 02016515 - Rojas, Mikaela Noel License Expiration Date: 10/05/2020 02063320 - Vierra, Kathleen Ann License Expiration Date: 05/21/2022 Comment: NO DISCIPLINARY ACTION NO OTHER PUBLIC COMMENTS >>>> Public information request complete <<<< http:/Awww2.dre.ca.gov/PublicASP/pplinfo.asp?start=1 2/2 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF ORANGE Jam an employee in the County of Orange, State of California. I am over the age of 18 and not a party to the within action; my business address is 7372 Prince Drive, Suite 104, Huntington Beach, CA 92647. On August 1S. 2018, I served the foregoing document(s) described, PLAINTIFF MS SERVICES, LLC’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION FOR ASSIGNMENT ORDER, to the interested parties in this action by electronic service as follows: Connie L. Martin 1000 Rucker Avenue Gilroy, CA 95020 10 XX_ (BY MAIL) The package was delivered with postage thereon fully prepaid. | am i “readily” familiar with the firm’s practice of collection and processing correspondence 12 for mailing. The package was deposited with U.S. Postal Service on that same day in the ordinary course of business. | am aware that on motion of a party served, service is 13 presumed invalid if the postal cancellation date or postage meter date is more than one day after date of deposit for mailing an affidavit. 14 18 _ VIA Electronic Service. I certify that I will cause a copy of the above document to be served upon the following counsel via One Legal on August 18, 2015. 16 {OVERNIGHT COURIER) I caused such envelope to be deposited in the mail 17 at Huntington Beach, California, United Postal Service. The envelope was mailed 18 with postage thereon fully prepaid. I am “readily” familiar with the firm’s practice of collection and processing correspondence for mailing. The package 19 was deposited with United Postal Service on that same day in the ordinary course of business. [ am aware that on motion of a party served, service is presumed 20 invalid if the postal cancellation date or postage meter date is more than one day 21 after date of deposit for mailing an affidavit. 22 XX_ (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. moet 23 24 August 2018 Date Michael Moore 25 26 27 28 JUDGMENT CREDITOR’S MOTION FOR ASSIGNMENT ORDER- 3