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  • ROBERT LINDOW  vs.  DARREN WALLACE, et al(16) Unlimited Fraud document preview
  • ROBERT LINDOW  vs.  DARREN WALLACE, et al(16) Unlimited Fraud document preview
  • ROBERT LINDOW  vs.  DARREN WALLACE, et al(16) Unlimited Fraud document preview
  • ROBERT LINDOW  vs.  DARREN WALLACE, et al(16) Unlimited Fraud document preview
  • ROBERT LINDOW  vs.  DARREN WALLACE, et al(16) Unlimited Fraud document preview
  • ROBERT LINDOW  vs.  DARREN WALLACE, et al(16) Unlimited Fraud document preview
						
                                

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WERE: if?” SAN MATEG Gm tan-“tr Robert Lindow Pro Se JUL. 3 fl. 2018 286 Jaunell Road, Aptos, CA 95003 .___ Phone: 831—818—5512 Glam ’; . WW.. '- Emall. L1ndow1@gma11.com By DEPUTYO W; Superior Court of the State of California County of San Mateo ROBERT LINDOW CIV 05803 ‘ Case No.: 17 10 Plaintiff, Response to Motion for Sanctions 11 vs. Date: August 8, 2018 12 Darren Wallace, individually and as Conservator Time 9:00 am. of the Estate of carl E. Lindow, Rebecca Department 21 Law and Motion 13 Wiseman, Does 1 through X. 14 7 __! __ __ __.__——fi Defendants {'/i7—c1V-05803 OPP 15 i i Opposition 16 17 kitiiifiilullllmmH‘Nu“-, 18‘ 19 Now comes Robert Lindow, and in response to the motion for sanctions filed by 20 Darren Wallace shows the Court: 21 1. That the previous motion filed by Robert Lindow and complained of in the present 22 motion was based on changes in circumstances relating to the real and personal 23 ‘ property which were subjects of the complaint. 24 25 2. That the Plaintiff” s motion was based on new fact that the Defendant had breached his 26 previous agreement not to list or attempt to sell the home located at 226 J aunell Road, 27 Aptos, California. 28 Response to Motion for sanctions ‘ i it} : E a: 5141570493190 $1090 JQL’WQQ ; 9/82 4.1110703 i {F WWW/91:) 737' ’% Gfifi i 03; W1; M78 .1? figfl ’ 3. However, the court did not consider or determine that the memorandum supplied by the Plaintiff was sufficient to establish new facts. That Plaintiff is at a loss how to prevent the sale of the personal items which have great sentimental value and can never be replaced. However, it should be noted that the Defendant failed, refused and neglected to bring their motion for sanctions as a response to the Plaintiffs motion. 4. At no time did the Plaintiff intent or desire to violate the court rules, harass or delay this cause of action. On the contrary, Plaintiff believed it would save the court and . party’s time and expense. 10 5. That the motion was originally set for August 8, but recent communication indicate 11 that the motion is now set for August 14. However, this new date does not allow 12 sufficient time in accordance with the Court Rules. 13 6. Further, that at no time did the Defendants properly raise these sanctions in response 14 15 to the original motion. 16 17 18 ‘- Respectfully submitted: 19 July 26, 2018 20 21 22 23 24 25 26 27 28 Response to Motion for sanctions