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  • JASON EVERETT THOMPSON et al VS. DEAN GREGORY ASIMOS CONTRACT/WARRANTY document preview
  • JASON EVERETT THOMPSON et al VS. DEAN GREGORY ASIMOS CONTRACT/WARRANTY document preview
  • JASON EVERETT THOMPSON et al VS. DEAN GREGORY ASIMOS CONTRACT/WARRANTY document preview
  • JASON EVERETT THOMPSON et al VS. DEAN GREGORY ASIMOS CONTRACT/WARRANTY document preview
  • JASON EVERETT THOMPSON et al VS. DEAN GREGORY ASIMOS CONTRACT/WARRANTY document preview
  • JASON EVERETT THOMPSON et al VS. DEAN GREGORY ASIMOS CONTRACT/WARRANTY document preview
						
                                

Preview

Kyle Law Corporation STEPHAN E. KYLE (SBN 158075) ANDREW H. WINETROUB (SBN 291847) KYLE LAW CORPORATION 230 California Street, Suite 600 San Francisco, CA 94111 TILED i Telephone: (415) 839-8100 Facsimile: _ (415) 839-8189 [ Golnty draus renciecs Email: skyle@kylelawcorp.com 11/04/2015 Attorneys for Plaintiffs evant eee JASON EVERETT THOMPSON and Deputy Clerk WIRED REAL ESTATE GROUP, INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO JASON EVERETT THOMPSON and WIRED REAL ESTATE GROUP, INC., CASE NO. CGC-11-514980 Plaintiffs, NOTICE OF DEFENDANT’S FAILURE v. TO COMPLY WITH COURT ORDER DEAN GREGORY ASIMOS, dba DRAKE REALTY, Defendant. AND RELATED CROSS-ACTION. TO THE HON. TERI L. JACKSON, JUDGE OF THE SUPERIOR COURT, DEFENDANT DEAN GREGORY ASIMOS AND HIS ATTORNEY OF RECORD: Pursuant to the oral order of this Court, as further described in the Declaration of Stephan E. Kyle In Support Thereof attached hereto, Defendant DEAN GREGORY ASIMOS, dba DRAKE REALTY was ordered to execute the document authorizing the disbursement of funds held by the law firm of Carr McClellan, P.C. and to deliver the executed document to counsel for Plaintiffs by’ no later than the end of day on Monday, November 2, 2015. As of the filing of this Notice of| Failure to Comply With Court Order, counsel for Plaintiffs have not received an executed -l- NOTICE OF DEFENDANT’S FAILURE TO COMPLY WITH COURT ORDER CGC-11-514980fe _ om IN DA HW PB WwW DN 10 authorization document from Defendant as ordered by the Court. As such, Defendant failed to comply with the clear order and instruction from this Court, and still has not complied with the| terms of the permanent injunction entered on August 23, 2013, which requires Defendant “to| cooperate immediately with the distribution of the entirety of the funds held in trust” and “to sign| immediately any documents reasonably necessary to effectuate the distribution” to Plaintiffs. Respectfully submitted, DATED: November 4, 2015 KYLE LAW CORPORATION ov. PEK STEPHANE, KYLE ANDREW H. WINETROUB Attorneys for Plaintiffs JASON EVERETT THOMPSON and WIRED REAL ESTATE GROUP, INC. 2. NOTICE OF DEFENDANT'S FAILURE TO COMPLY WITH COURT ORDER CGC-11-514980Kyle Lat Ww Corporation oC em ND HW PF Ww NY Poe Ss Be Be Be Be Be eB ee BBe 8S Se BDaanaranperes 24 Thompson v. Asimos San Francisco Superior Court Case No. CGC-11-514980 PROOF OF SERVICE J, the undersigned, state: I am a citizen of the United States. My business address is 230 California Street, Suite 600, San Francisco, California 94111. I am employed in the City and County of San Francisco. I am over the age of eighteen years and not a party to this action. On the date set forth below, I served the foregoing documents described as follows: NOTICE OF DEFENDANT’S FAILURE TO COMPLY WITH COURT ORDER on the following person(s) in this action by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Jessica R. Barsotti, Esq. LAW OFFICE OF JESSICA R. BARSOTTI 5032 Woodminster Lane Oakland, CA 94602 [x] BY FIRST CLASS MAIL - I am readily familiar with my firm’s practice for collection and processing of correspondence for mailing with the United States Postal Service, to wit, that correspondence will be deposited with the United States Postal Service this same day in the ordinary course of business. I sealed said envelope and placed it for collection and mailing this date, following ordinary business practices. [] BY PERSONAL SERVICE — Following ordinary business practices, I caused to be served, by hand delivery, such envelope(s) by hand this date to the offices of the addressee(s). [] | BY OVERNIGHT MAIL —I caused such envelope to be delivered by a commercial carrier service for overnight delivery to the office(s) of the addressee(s). {] BY FACSIMILE — I caused said document to be transmitted by Facsimile machine to the number indicated after the address(es) noted above. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed this date in San Francisco, California. Dated: November 4, 2015 etd H. WINETROUB 3+ NOTICE OF DEFENDANT’S FAILURE TO COMPLY WITH COURT ORDER CGC-11-514980