Preview
MICHAEL B. BROWN (SB #179222)
michael. broy stoel.com.
NICHOLAS D. KARKAZIS (SB #299075)
nicholas. karkazis@stoel.com
STOEL RIVES tip
500 jitol Mall, Suite 1600
Sacramento, CA 95814.
Telephone: 916.447.0700
Facsimile: 916.447.4781
GREG C. GATTO (SB #226903)
sierral: aw.com,
LAW OFFICE OF GREG GATTO
PO Box 85
Calpine, CA 96124
Telephone: 530.205.6503
Attomeys for Defendant and Cross-Complainant
10 KILA TAHOE, LLC
11 SUPERIOR COURT OF THE STATE OF CALIFORNIA
12 COUNTY OF PLACER
13 SIERRA NORTHWEST PROPERTIES, LLC, CASE NO. SCV0041099
14 Plaintiff, STIPULATION AND [PROPOSED]
ORDER CONTINUING JULY 31, 2020
15 Vv. HEARING DATE
16 KILA TAHOE, LLC; BY FAX
ALL PERSONS UNKNOWN, claiming any
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legal or equitable right, title, estate, lien, or
interest
in or to the real described in
the complaint adverse to plaintiffs’ title, or any
Dae
July 3 3020"
Time: TBD
cloud on plaintiffs’ title thereto; Dept: TBD
19 DOES 1 through 10, inclusive,
Action Filed: May 2, 2018
20 Defendants.
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AND RELATED CROSS-ACTION.
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STOEL Rives LLP 1
ATTORNEYS
AT Law
Sacr STIPULATION
AND [PROPOSED] ORDER CONTINUING JULY 31, 2020 HEARING DATE -- SCV0041099
107437987.1 0053477-00003.
IT IS STIPULATED by and between Pilaintiff/Cross-Defendant Siema Northwest
Properties, LLC (“SNP”) and Defendant/Cross-Complainant Kila Tahoe, LLC (“Kila”) through
their respective counsel as follows:
WHEREAS, on May 15, 2020, SNP filed
a Motion to Strike Memorandum
of Costs and set
the motion to be heard on June 12, 2020;
WHEREAS, by tentative nuling dated June 11, 2020, the Court continued the hearing on
SNP’s motion to June 19, 2020;
WHEREAS, on June 12, 2020, Kila filed a Motion for Attomeys’ Fees and set the motion
to be heard
on July 24, 2020,
10 WHEREAS, by tentative
ruling dated June 18, 2020, the Court continued
the hearing on
11 SNP’s motion to July 24, 2020, to be heard in conjunction with Kila’s motion;
12 WHEREAS, by tentative ruling dated July 23, 2020, the Court continued the hearing on
13 both motions to July 31, 2020;
14 WHEREAS, counsel for Kila is unavailable on July 31, 2020; and
15 WHEREAS, counsel for SNP and Kila are available and agree to continue the hearing on
16 the motions to August 7, 2020.
17 THE PARTIES HEREBY STIPULATE
18 1 The hearings on SNP’s Motion to Strike Memorandum of Costs and Kila’s Motion
19 forAttomeys’ Fees shall be continued
to August 7, 2020, to atime and department
to be determined.
20 by the Court; and
21 2. The parties agree that no additional briefing may be filed in support of the respective
22 motions.
23 Dated: July 23, 2020 STOEL RIVES tip
24.
25 iy, a
Michael B. Brown
26 Nicholas D. Karkazis
Homeys for Pa
Defendant and Cross-Complainant
27 Riot
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STOEL Rives LLP -2-
ATTORNEYS AT La
Sacr STIPULATION
AND [PROPOSED] ORDER CONTINUING JULY 31, 2020 HEARING DATE -- SCV0041099
107437987.1 0053477-00003.
Dated: July 23, 2020 DESMOND, NOLAN, LIVAICH & CUNNINGHAM
By:
Gary Livaich
Kristen Renfro
Attomeys for Plaintiffs Sierra Northwest Properties,
LLC; Sierra Northwest Holdings, LLC; Sam
Rudnick, Jr.; and Antionette Rudnick
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STOEL Rives LLP 3
ATTORNEYS AT Law
SACRAMEN! STIPULATION
AND [PROPOSED] ORDER CONTINUING JULY 31, 2020 HEARING DATE -- SCV0041099
107437987.1 0053477-00003.
[PROPOSED] ORDER
Having reviewed the foregoing stipulation of the parties, and good cause appearing the
Court HEREBY ORDERS:
1 The hearings on on SNP’s Motion to Strike Memorandum of Costs and Kila’s
Motion for Attomeys’ Fees shall be continued to August 7, 2020, at am/pm in
Department :
2. No further briefings are allowed on either motion.
IT ISSO ORDERED.
10 Dated:
Judge of the Superior Court
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STOEL Rives LLP -4-
ATTORNEYS AT Law
SACRAMEN! STIPULATION
AND [PROPOSED] ORDER CONTINUING JULY 31, 2020 HEARING DATE -- SCV0041099
107437987.1 0053477-00003.
DECLARATION OF SERVICE
I declare that I am over the age of eighteen years and not a party to this action. Iam
employed in the City and County of Sacramento and my business address is 500 Capitol Mall,
Suite 1600, Sacramento, California 95814.
On July 23, 2020, at Sacramento, California, I served the attached document(s):
STIPULATION AND [PROPOSED] ORDER CONTINUING
JULY 31, 2020 HEARING DATE
on the following parties:
Gary Livaich Attorneys for Plaintiff and Cross-
Kristen Renfro Defendants
Desmond, Nolan, Livaich & Cunningham Sierra Northwest Properties, LLC
15th & S Building Sierra Northwest Holdings, LLC
10 1830 15th Street Antionette Rudnick
Sacramento, CA 95811 Sam Rudnick, Jr.
11 Phone: 916-443-2051
glivaich@dnlc.net
12 krenfro@dnlc.net
kstokes@dnlc.net
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14 John G. Bilheimer Attorneys for Defendant and
Haley & Bilheimer Cross-Complainant
15 505 Coyote St., Ste. A Tahoe City Public Utility District
Nevada City, CA 95959
16 Phone: 530-265-6357
17 jbilheimer@lawhb.com
18 x BY EMAIL: On the date written above, I emailed a copy of the attached documents to the addressee, as shown
on the service list, per agreement of the parties.
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I declare under penalty of perjury under the laws of the State of California that the
20 foregoing is true and correct and that this document was executed on July 23, 2020, at
Sacramento, California.
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Dawn Dawn
? R.orgeu/
Forgetr, CCLS
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STOEL Rives LLP -l-
ATTORNEYSAT LAW
SACRAMENTO PROOF OF SERVICE — CASE NO. SCV0041099
97057628.1 0053477-00003
Preview
MICHAEL B. BROWN (SB #179222) michael. broy stoel.com. NICHOLAS D. KARKAZIS (SB #299075) nicholas. karkazis@stoel.com STOEL RIVES tip 500 jitol Mall, Suite 1600 Sacramento, CA 95814. Telephone: 916.447.0700 Facsimile: 916.447.4781 GREG C. GATTO (SB #226903) sierral: aw.com, LAW OFFICE OF GREG GATTO PO Box 85 Calpine, CA 96124 Telephone: 530.205.6503 Attomeys for Defendant and Cross-Complainant 10 KILA TAHOE, LLC 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 COUNTY OF PLACER 13 SIERRA NORTHWEST PROPERTIES, LLC, CASE NO. SCV0041099 14 Plaintiff, STIPULATION AND [PROPOSED] ORDER CONTINUING JULY 31, 2020 15 Vv. HEARING DATE 16 KILA TAHOE, LLC; BY FAX ALL PERSONS UNKNOWN, claiming any 17 18 legal or equitable right, title, estate, lien, or interest in or to the real described in the complaint adverse to plaintiffs’ title, or any Dae July 3 3020" Time: TBD cloud on plaintiffs’ title thereto; Dept: TBD 19 DOES 1 through 10, inclusive, Action Filed: May 2, 2018 20 Defendants. 21 AND RELATED CROSS-ACTION. 22 23 24. 25 26 27 28 STOEL Rives LLP 1 ATTORNEYS AT Law Sacr STIPULATION AND [PROPOSED] ORDER CONTINUING JULY 31, 2020 HEARING DATE -- SCV0041099 107437987.1 0053477-00003. IT IS STIPULATED by and between Pilaintiff/Cross-Defendant Siema Northwest Properties, LLC (“SNP”) and Defendant/Cross-Complainant Kila Tahoe, LLC (“Kila”) through their respective counsel as follows: WHEREAS, on May 15, 2020, SNP filed a Motion to Strike Memorandum of Costs and set the motion to be heard on June 12, 2020; WHEREAS, by tentative nuling dated June 11, 2020, the Court continued the hearing on SNP’s motion to June 19, 2020; WHEREAS, on June 12, 2020, Kila filed a Motion for Attomeys’ Fees and set the motion to be heard on July 24, 2020, 10 WHEREAS, by tentative ruling dated June 18, 2020, the Court continued the hearing on 11 SNP’s motion to July 24, 2020, to be heard in conjunction with Kila’s motion; 12 WHEREAS, by tentative ruling dated July 23, 2020, the Court continued the hearing on 13 both motions to July 31, 2020; 14 WHEREAS, counsel for Kila is unavailable on July 31, 2020; and 15 WHEREAS, counsel for SNP and Kila are available and agree to continue the hearing on 16 the motions to August 7, 2020. 17 THE PARTIES HEREBY STIPULATE 18 1 The hearings on SNP’s Motion to Strike Memorandum of Costs and Kila’s Motion 19 forAttomeys’ Fees shall be continued to August 7, 2020, to atime and department to be determined. 20 by the Court; and 21 2. The parties agree that no additional briefing may be filed in support of the respective 22 motions. 23 Dated: July 23, 2020 STOEL RIVES tip 24. 25 iy, a Michael B. Brown 26 Nicholas D. Karkazis Homeys for Pa Defendant and Cross-Complainant 27 Riot 28 STOEL Rives LLP -2- ATTORNEYS AT La Sacr STIPULATION AND [PROPOSED] ORDER CONTINUING JULY 31, 2020 HEARING DATE -- SCV0041099 107437987.1 0053477-00003. Dated: July 23, 2020 DESMOND, NOLAN, LIVAICH & CUNNINGHAM By: Gary Livaich Kristen Renfro Attomeys for Plaintiffs Sierra Northwest Properties, LLC; Sierra Northwest Holdings, LLC; Sam Rudnick, Jr.; and Antionette Rudnick 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24. 25 26 27 28 STOEL Rives LLP 3 ATTORNEYS AT Law SACRAMEN! STIPULATION AND [PROPOSED] ORDER CONTINUING JULY 31, 2020 HEARING DATE -- SCV0041099 107437987.1 0053477-00003. [PROPOSED] ORDER Having reviewed the foregoing stipulation of the parties, and good cause appearing the Court HEREBY ORDERS: 1 The hearings on on SNP’s Motion to Strike Memorandum of Costs and Kila’s Motion for Attomeys’ Fees shall be continued to August 7, 2020, at am/pm in Department : 2. No further briefings are allowed on either motion. IT ISSO ORDERED. 10 Dated: Judge of the Superior Court 11 12 13 14 15 16 17 18 19 20 21 22 23 24. 25 26 27 28 STOEL Rives LLP -4- ATTORNEYS AT Law SACRAMEN! STIPULATION AND [PROPOSED] ORDER CONTINUING JULY 31, 2020 HEARING DATE -- SCV0041099 107437987.1 0053477-00003. DECLARATION OF SERVICE I declare that I am over the age of eighteen years and not a party to this action. Iam employed in the City and County of Sacramento and my business address is 500 Capitol Mall, Suite 1600, Sacramento, California 95814. On July 23, 2020, at Sacramento, California, I served the attached document(s): STIPULATION AND [PROPOSED] ORDER CONTINUING JULY 31, 2020 HEARING DATE on the following parties: Gary Livaich Attorneys for Plaintiff and Cross- Kristen Renfro Defendants Desmond, Nolan, Livaich & Cunningham Sierra Northwest Properties, LLC 15th & S Building Sierra Northwest Holdings, LLC 10 1830 15th Street Antionette Rudnick Sacramento, CA 95811 Sam Rudnick, Jr. 11 Phone: 916-443-2051 glivaich@dnlc.net 12 krenfro@dnlc.net kstokes@dnlc.net 13 14 John G. Bilheimer Attorneys for Defendant and Haley & Bilheimer Cross-Complainant 15 505 Coyote St., Ste. A Tahoe City Public Utility District Nevada City, CA 95959 16 Phone: 530-265-6357 17 jbilheimer@lawhb.com 18 x BY EMAIL: On the date written above, I emailed a copy of the attached documents to the addressee, as shown on the service list, per agreement of the parties. 19 I declare under penalty of perjury under the laws of the State of California that the 20 foregoing is true and correct and that this document was executed on July 23, 2020, at Sacramento, California. 21 22 Dawn Dawn ? R.orgeu/ Forgetr, CCLS 23 24 25 26 27 28 STOEL Rives LLP -l- ATTORNEYSAT LAW SACRAMENTO PROOF OF SERVICE — CASE NO. SCV0041099 97057628.1 0053477-00003