On December 20, 2017 a
Motion-Secondary
was filed
involving a dispute between
Lindow, Robert,
and
Does 1 Through X,
Wallace, Darren,
Weisman, Rebecca,
Wiseman, Rebecca,
for (16) Unlimited Fraud
in the District Court of San Mateo County.
Preview
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SAN MATEG Gm tan-“tr
Robert Lindow
Pro Se JUL. 3 fl. 2018
286 Jaunell Road, Aptos, CA 95003 .___
Phone: 831—818—5512 Glam ’;
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Emall. L1ndow1@gma11.com By
DEPUTYO W;
Superior Court of the State of California
County of San Mateo
ROBERT LINDOW CIV 05803
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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
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Defendants {'/i7—c1V-05803
OPP
15 i
i Opposition
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17
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18‘
19 Now comes Robert Lindow, and in response to the motion for sanctions filed by
20
Darren Wallace shows the Court:
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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,
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Aptos, California.
28
Response to Motion for sanctions
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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
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15 to the original motion.
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17
18 ‘-
Respectfully submitted:
19
July 26, 2018
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Response to Motion for sanctions
Document Filed Date
July 31, 2018
Case Filing Date
December 20, 2017
Category
(16) Unlimited Fraud
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