On March 30, 2015 a
Motion-Secondary
was filed
involving a dispute between
Guinn, Justin,
and
All Persons Unknown, Claiming Any Legal Or Equitable Right, Title, Estate, Etc,
Ford, Carol,
Ford, Kenneth W.,
Mullis, Kathleen,
Mullis, Richard,
Mullis, Stephen,
Scott Andersn General Engineering Contractors Inc.,
The Testate And Intestate Successors Of Jack Mullis,
The Testate And Intestate Successors Of James Mullis,
The Testate And Intestate Successors Of Wilma Mullis,
Water Heaters Only, Inc.,
for (26) Unlimited Other Real Property
in the District Court of San Mateo County.
Preview
ROBERT
LAW OFFICE
B JACOBS
OF ROBERT
HOPYARD ROAD, SUITE 280
S B No. 131160
B. JACOBS e~aK9
4900 SAN MATEG CQUNTY
PLEASANTON, CA 94588
TELEPHONE (925) 847-8680 QA8 5 ~ 20>5
the Suoenor @~i rt
Attorney for Plaintiff c erkot
JUSTIN GUINN
ly
IN THE SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN MATEO
JUSTIN GUINN AS TRUSTEE OF THE CASE NO (;[!P $ ) ) j g >r:
JUSTIN GUINN SEPARATE PROPERTY
TRUST, DATED NOVEMBER 30, 2012,
Plaintiff
10
KENNETH W FORD, also known as DECLARATIONOF JUSTIN GUINN
KENNETI-I WALTER FORD, an Individual, PURSUANTTO C CP $762 030 IN
12 known CAROL Y SUPPORT OF COMPLAINT FOR
CAROL FORD, also as
FORD, an Individual, STEPHEN MULLIS, CANCELLATIONOF INSTRUMENTS,
13 DECLARATORY RELIEF AND TO QUIET
also known as STEVE MULLIS or STEVEN
MULLIS, m his capacity as an Individual and TITLE
14 of
also as Admimstrator CTA of the Estate
WILMAMULLIS, KATHLEEN MULLIS,
15
an Individual, RICHARD MULLIS, also
known as RICHARD J MULLIS, an
16
Individual, SCOTT ANDERSON
GENERAL ENGINEERING
17
CONTRACTORS, INC, a Cahfornia
corporation, WATER HEATERS ONLY,
INC, a California corporation, THE
TESTATE AND INTESTA fE
19 JACK MULLIS,
SUCCESSORS OF
DECEASED, and all persons claiming by,
20 or under such decedent, THE
through,
TESTATE AND INTESTATE
21 WILMAMULLIS, also
SUCCESSORS OF
22
known as WILMAKATHLEENMULLIS,
DECEASED, and all persons claimmg by,
through, or under such decedent, THE
23
TESTATE AND INTESTATE
SUCCESSORS OF JAMES MULLIS, also
24 JAMES VICTOR MULLIS,
known as
DECEASED, and all persons claiming by,
25 decedent, all persons
through, or under such
unknown, claiming any legal or equitable
26 hen or interest m the
right, title, estate,
Property described in this Complamt which
27 to Plaintiffs title or creates any
is adverse
cloud on Plaintiffs title thereto, and DOES
28
1-50,
Defendants
I, Justin Guinn, Declare.
1 I am the Plamtiff m the within Action I am over 18 years of age and have personal
knowledge of the followmg
2 JACK MULLIS is a person required to be nained as a Defendant m this action to quiet
title, but as shown by his death certificate issued by the County San Joaqum, he is deceased
JACK MULLIS is one of four named Beneficiaries on a Deed of Trust which is the subject of the
withm action and as to which Deed of Trust I am seeking m this Action to quiet title
3. I am mformed and beheve and thereon allege that the estate of JACK MULLIS was
never probated or otherwise administered and that there is no personal representative of the estate
10 of JACK MULLIS
4 WILMAMULLIS, also known as WILMAKATHLEENMULLIS, is a person
required to be named as a Defendant m this action to quiet title, but as shown by her death
12
certificate issued by the County San Joaquin, she is deceased WILMAMULLIS is one of four
13
14 named Beneficiaries on a Deed of Trust which is the subJect of the within action and as to winch
15 Deed of Trust I am seeking in this Action to quiet title
5 I am informed and believe and thereon alleged that the Administrator CTA of her
16
estate was STEPHEN MULLIS, he is named as a Defendant in this Action However, m order to
17
make absolutely certam that allof her successors are included within the scope of this quiet title
18
action, her testate and intestate successors are also named as defendants
19
6 JAMES MULLIS, also known as JAMES VICTOR MULLIS, is a person required to
20
be named as a Defendant in this action to quiet title, but as shown by his death certificate issued
21
22 by the County San Joaquin, he is deceased. JAMES MULLIS is one of four named Beneficiaries
on a Deed of Trust which is the subJect of the within action and as to which Deed of Trust I am
23
24 seeking m this Action to quiet title
25
26
27 //
28 //
DECLARATIONOF JUSTIN GUINN IN SUPPORT OF COMPLAINTTO QUIET TITLE
2
7. I am informed and believe and thereon allege that the estate of JAMES MULLIS, also
known as JAMES VICTOR MULLIS, was never probated or otherwise admimstered and that
there is no personal representative of the estate of JAMES MULLIS
5
I Declare under Penalty of PerJury under the Laws of the State of Cahfornia that the
foregomg is true and correct.
Executed at Cupertino, Cahfornia on March 30, 2015
10
us
Guin'2
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
DECLARATIONOF JUSTIN GUINN IN SUPPORT OF COMPLAINT TO QUIET TITLE
3
Preview
ROBERT LAW OFFICE B JACOBS OF ROBERT HOPYARD ROAD, SUITE 280 S B No. 131160 B. JACOBS e~aK9 4900 SAN MATEG CQUNTY PLEASANTON, CA 94588 TELEPHONE (925) 847-8680 QA8 5 ~ 20>5 the Suoenor @~i rt Attorney for Plaintiff c erkot JUSTIN GUINN ly IN THE SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN MATEO JUSTIN GUINN AS TRUSTEE OF THE CASE NO (;[!P $ ) ) j g >r: JUSTIN GUINN SEPARATE PROPERTY TRUST, DATED NOVEMBER 30, 2012, Plaintiff 10 KENNETH W FORD, also known as DECLARATIONOF JUSTIN GUINN KENNETI-I WALTER FORD, an Individual, PURSUANTTO C CP $762 030 IN 12 known CAROL Y SUPPORT OF COMPLAINT FOR CAROL FORD, also as FORD, an Individual, STEPHEN MULLIS, CANCELLATIONOF INSTRUMENTS, 13 DECLARATORY RELIEF AND TO QUIET also known as STEVE MULLIS or STEVEN MULLIS, m his capacity as an Individual and TITLE 14 of also as Admimstrator CTA of the Estate WILMAMULLIS, KATHLEEN MULLIS, 15 an Individual, RICHARD MULLIS, also known as RICHARD J MULLIS, an 16 Individual, SCOTT ANDERSON GENERAL ENGINEERING 17 CONTRACTORS, INC, a Cahfornia corporation, WATER HEATERS ONLY, INC, a California corporation, THE TESTATE AND INTESTA fE 19 JACK MULLIS, SUCCESSORS OF DECEASED, and all persons claiming by, 20 or under such decedent, THE through, TESTATE AND INTESTATE 21 WILMAMULLIS, also SUCCESSORS OF 22 known as WILMAKATHLEENMULLIS, DECEASED, and all persons claimmg by, through, or under such decedent, THE 23 TESTATE AND INTESTATE SUCCESSORS OF JAMES MULLIS, also 24 JAMES VICTOR MULLIS, known as DECEASED, and all persons claiming by, 25 decedent, all persons through, or under such unknown, claiming any legal or equitable 26 hen or interest m the right, title, estate, Property described in this Complamt which 27 to Plaintiffs title or creates any is adverse cloud on Plaintiffs title thereto, and DOES 28 1-50, Defendants I, Justin Guinn, Declare. 1 I am the Plamtiff m the within Action I am over 18 years of age and have personal knowledge of the followmg 2 JACK MULLIS is a person required to be nained as a Defendant m this action to quiet title, but as shown by his death certificate issued by the County San Joaqum, he is deceased JACK MULLIS is one of four named Beneficiaries on a Deed of Trust which is the subject of the withm action and as to which Deed of Trust I am seeking m this Action to quiet title 3. I am mformed and beheve and thereon allege that the estate of JACK MULLIS was never probated or otherwise administered and that there is no personal representative of the estate 10 of JACK MULLIS 4 WILMAMULLIS, also known as WILMAKATHLEENMULLIS, is a person required to be named as a Defendant m this action to quiet title, but as shown by her death 12 certificate issued by the County San Joaquin, she is deceased WILMAMULLIS is one of four 13 14 named Beneficiaries on a Deed of Trust which is the subJect of the within action and as to winch 15 Deed of Trust I am seeking in this Action to quiet title 5 I am informed and believe and thereon alleged that the Administrator CTA of her 16 estate was STEPHEN MULLIS, he is named as a Defendant in this Action However, m order to 17 make absolutely certam that allof her successors are included within the scope of this quiet title 18 action, her testate and intestate successors are also named as defendants 19 6 JAMES MULLIS, also known as JAMES VICTOR MULLIS, is a person required to 20 be named as a Defendant in this action to quiet title, but as shown by his death certificate issued 21 22 by the County San Joaquin, he is deceased. JAMES MULLIS is one of four named Beneficiaries on a Deed of Trust which is the subJect of the within action and as to which Deed of Trust I am 23 24 seeking m this Action to quiet title 25 26 27 // 28 // DECLARATIONOF JUSTIN GUINN IN SUPPORT OF COMPLAINTTO QUIET TITLE 2 7. I am informed and believe and thereon allege that the estate of JAMES MULLIS, also known as JAMES VICTOR MULLIS, was never probated or otherwise admimstered and that there is no personal representative of the estate of JAMES MULLIS 5 I Declare under Penalty of PerJury under the Laws of the State of Cahfornia that the foregomg is true and correct. Executed at Cupertino, Cahfornia on March 30, 2015 10 us Guin'2 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATIONOF JUSTIN GUINN IN SUPPORT OF COMPLAINT TO QUIET TITLE 3