Demurrer in Dhesi, Harry Mohan Singh vs. Garcia, Mary Elizabeth| Trellis.Law

On November 19, 2019 a Motion,Ex Parte was filed involving a dispute between Harry Dhesi, and Elystina Garcia, Ilidio Garcia, James Taylor, Mary Garcia, for Civil-Roseville in the District Court of Placer County.

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ELECTRONICALLY FILED
superior Court of California,
County of Placer
09/18/2020
W.H. WHITAKER, SBN 145560 By: LaurelSanders, Deputy Clerk
hwhitaker@Isnc.net
CATHLEEN LEAVENWORTH, SBN 314534
cleavenworth@Isnc.net
NATALIA DASILVA, SBN 329468
ndasilva@Isnc.net

LEGAL SERVICES OF NORTHERN CALIFORNIA
190 Reamer Street
Auburn, CA 95603
(530) 823-7560 Telephone
(530)823-7601 Facsimile

Attorneys for Defendants Elystina Garcia, Ilidio Garcia, James Taylor

10
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
ll
IN AND FOR THE COUNTY OF PLACER
12

13
Case No.: SCV0043998
14 Harry Mohan Singh Dhesi,
ee ee”

NOTICE OF DEMURRER AND
15 Plaintiff, DEMURRER TO FIRST AMENDED
COMPLAINT; MEMORANDUM OF
16 Vs. POINTS AND AUTHORITIES IN SUPPORT
OF DEMURRER; DECLARATION OF
17 Mary Elizabeth Garcia, Elystina Garcia, Ilidio CATHLEEN LEAVENWORTH; PROPOSED
ee

ORDER
ee

18 Garcia, James Cody Taylor, and DOES 1-40,
ee
ee

19 inclusive, DATE: October 22, 2020
ee

TIME: 8:30 A.M.
20 Defendants. DEPT: 42
ee

22 TO PLAINTIFF: Harry Mohan Singh Dhesi

24 PLEASE TAKE NOTICE that Defendants ELYSTINA GARCIA, ILIDIO GARCIA, appearing
25 through his guardian ad litem Mary Elizabeth Garcia, and JAMES CODY TAYLOR hereby
26 demur to the FIRST AMENDED COMPLAINT and that the hearing on the demurrer will take
27

1
Notice of Demurrer and Demurrer toFirst Amended Complaint for Defendants Elystina Garcia, Ilidio
Garcia, James Taylor
place at 8:30 A.M., on October 22, 2020, in the Law and Motion Department of the above-
entitled Court, Department 42, located at 10820 Justice Center Drive, Roseville, CA 95678.
This demurrer isbased on this notice, the accompanying memorandum, and all papers and
records on file in this action, and such evidence, both oral and documentary, as may be presented
at the hearing of this demurrer.

OBJECTIONS TO THE COMPLAINT
Defendants ELYSTINA GARCIA, ILIDIO GARCIA, and JAMES CODY TAYLOR, demur
on each of the following grounds:

11 Objections to the Fourth Cause of Action — Waste

12 The Fourth Cause of Action does not state facts sufficient to constitute a cause of action

13 against Elystina Garcia, Ilidio Garcia, and James Cody Taylor. (Code Civ. Pro. § 430.10(e).)

15 Objections to the Fifth Cause of Action — Conversion

16
The Fifth Cause of Action does not state facts sufficient to constitute a cause of action against

17
Elystina Garcia, Ilidio Garcia, and James Cody Taylor. (Code Civ. Pro. § 430.10(e).)

19
Based upon the foregoing, Defendants, ELYSTINA GARCIA, ILIDIO GARCIA and JAMES
CODY TAYLOR, submit that Plaintiff has failed to state facts sufficient to constitute valid
20

21
causes of action in its complaint, and therefore respectfully requests that their demurrers to each
cause of action in the complaint be sustained without leave to amend.
22

24
The undersigned certifies that this demurrer is filed in good faith and not for the purposes of

25
delay.

26
HII

27
MII

28
Mil

2
Notice of Demurrer and Demurrer to FirstAmended Complaint for Defendants Elystina Garcia, Ilidio
Garcia, James Taylor
Dated:

Respectfully submitted,

Date: a /\ $/Jo QO By: Ns Ves CARAS AK

Legal Services of Northern California
Cathleen Leavenworth
Attorney for Defendants Elystina Garcia, Ilidio
Garcia, and James Cody Taylor

3
Notice of Demurrer and Demurrer to First Amended Complaint for Defendants Elystina Garcia, Ilidio
Garcia, James Taylor
W.H. WHITAKER, SBN 145560
hwhitaker@Isnc.net
CATHLEEN LEAVENWORTH, SBN 314534
cleavenworth@Isnc.net
NATALIA DASILVA, SBN 329468
ndasilva@Isnc.net
LEGAL SERVICES OF NORTHERN CALIFORNIA
190 Reamer Street
Auburn, CA 95603
(530) 823-7560 Telephone
(530)823-7601 Facsimile

Attorneys for Defendants Elystina Garcia, Ilidio Garcia, James Taylor

10
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
11
IN AND FOR THE COUNTY OF PLACER
12

13
Case No.: SCV0043998
14 Harry Mohan Singh Dhesi,
Oe

MEMORANDUM OF ELYSTINA GARCIA,
15 Plaintiff, ILLIDIO GARCIA, AND JAMES CODY
TAYLOR IN SUPPORT OF DEMURRER TO
16 vs. PLAINTIFF’S FIRST AMENDED
eee

COMPLAINT;
17 Mary Elizabeth Garcia, Elystina Garcia, Ilidio
ae

Garcia, James Cody Taylor, and DOES 1-40, DATE: October 22, 2020
eee

18
TIME: 8:30 AM
ee

19 inclusive, DEPT: 42
ee

20 Defendants.
ee

22
I. INTRODUCTION
23
This Memorandum is submitted on behalf of Defendants Elystina Garcia, Ilidio Garcia,
24
and James Cody Taylor only in support of their motion for demurrer of the Fourth and Fifth
25
Causes of Action to the First Amended Complaint filed by Plaintiff Harry Dhesi on August 20,
26
2020. Co-defendant Mary Garcia will file a separate responsive pleading.
27

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Elystina Garcia, Ilidio Garcia, James Cody Taylor Memorandum In Support of Demurrer to
Plaintiff's First Amended Complaint
The party against whom a complaint or cross-complaint has been filed may object to the

pleading by demurrer or answer as provided in CCP § 430.30. A complaint or cross-complaint is

subject to demurrer for the reasons stated in CCP § 430.10 including but not limited to: 1) The

pleading does not state facts sufficient to constitute a cause of action and; 2) The pleading is

uncertain. As used in this subdivision, ‘uncertain’ includes ambiguous and unintelligible.

The function of a demurrer is to test the legal sufficiency of a pleading. (Hegyes v. Unjian

(delete underline, except for case name) Enterprises, Inc., (2d Dist. 1991) 234 Cal. App. 3d

1103, 1111, 286 Cal. Rptr. 85.) In reviewing the sufficiency of a complaint against a general

demurrer, the court treats the demurrer as admitting allmaterial facts properly pleaded, as well as

10 matters which may be judicially noticed. Contentions, deductions or conclusions of fact or law

Ll are insufficient to constitute a cause of action. (Adelman vy.Associated Intern. Ins. Co., (2d Dist.

12 2001) 90 Cal. App. 4th 352, 359, 108 Cal. Rptr. 2d 788.) Additionally, the court treats as true the

13 contents of any exhibits attached to the complaint. (Bld. Permit Consultants, Inc. v. Mazur,
14 (2004) 122 Cal. App. 4" 1400, 1409, 19 Cal. Rptr. 3d 562, 568.) And where the exhibits

15 contradict the pleadings, the facts as stated in the exhibits supersede inconsistent and contrary
16 allegations in the pleadings. (/d.)

17 A demurrer will succeed when a complaint fails to state a claim which constitutes a cause

18 of action where the allegations in the complaint are too vague or uncertain to state a cause of

19 action. Green v. Uccelli (1989) 207 Cal. App. 3d 1112, 1119, 255 Cal. Rptr. 315.

20 Elystina and Ilidio are siblings and the children of co-defendant Mary Garcia. Plaintiff

21 alleges that Elystina, Illidio, and Mr. Taylor resided at 506 I Street, Lincoln, CA (the Residence)

22 between November 2016 and August 2018. Elystina was born on May 14, 2001. For the entire

23 time she was alleged to live at the Residence, she was a minor. Illidio was born on April 17,

24 2004. For the entire time he was alleged to live at the Residence, he was a minor. (See Request

25 for Judicial Notice electronically filed July 7, 2020). The status of Elystina and Ilidio as minors

26 is acknowledged by Plaintiff in his First Amended Complaint. (First Amended Complaint

27 Paragraph 3; Fourth Cause of Action; Fifth Cause of Action.)

2
Elystina Garcia, Ilidio Garcia, James Cody Taylor Memorandum In Support of Demurrer to
Plaintiff's First Amended Complaint
In November 2019, Plaintiff filed a complaint against Mary Garcia, Elystina Garcia,
Ilidio Garcia, and co-defendant James Taylor. The firstthree causes of action are against Mary
Garcia only. The Fourth and Fifth causes of action are against Mary Garcia, Elystina Garcia,
Ilidio Garcia, and James Cody Taylor.

Elystina Garcia, Ilidio Garcia, and James Taylor filed a Demurrer to the Fourth and Fifth
causes of action of the Complaint on July 10, 2020. In response to the defendants Demurrer,
Plaintiff filed a First Amended Complaint on August 20, 2020.

Plaintiff's First Amended Complaint repeats nearly verbatim the causes of action inthe
original complaint. As with the original complaint, Plaintiff's First Amended Complaint is
10 ambiguous, and relies on contentions, deductions, and conclusions of law and fact. Further,
11 Plaintiff s reliance on the same allegations for each cause of action routinely fails to state a cause
12 of action. Additionally, Plaintiffs First Amended Complaint includes facts which contradict
13 allegations and which state a clear defense barring recovery.

14 As with the initialcomplaint, Plaintiff's First Amended Complaint has five causes of
15 action. The first three causes of action are against Mary Garcia only. The fourth (Waste) and fifth
16 (Conversion) causes of action are against Mary Garcia on her behalf and on behalf of her minor
17 children Elystina Garcia, [lidio Garcia, and Defendant James Cody Taylor..

18 Elystina and Ilidio Garcia, and James Cody Taylor demurrer to both the fourth and the
19 fifth causes of action because Plaintiff failsto state a cause of action against them.

21 II. GROUNDS FOR DEMURRER

22 Grounds for Demurrer of Fourth Cause of Action: Waste

23 “To constitute waste, there must be an injury to the inheritance (Civ. Code § 818),

24 substantially depreciating the market value of the property.” (Civ. Code § 385) (What

25 Constitutes Waste, 12 Witkin, Summary 11th Real Prop § 385 (2019).) California Civil Code

26 section 826 provides that a person having an estate in remainder or reversion may maintain an

27 action for any injury done to the inheritance. Injury to the inheritance is defined as permanently

3
Elystina Garcia, Ilidio Garcia, James Cody Taylor Memorandum In Support of Demurrer to
Plaintiff’s First Amended Complaint
or substantially depreciating the value of the property. (Eastman v.Peterson (1968) 268
Cal.App.2d 169, 175, 73 Cal-Rptr. 803; Sallee v. Daneri (1942) 49 Cal. App.2d 324, 327, 121
P.2d 781; Smith v. Cap Concrete, Inc. (1982) 133 Cal.App.3d 769, 776-777, 184 Cal.Rptr. 308.)
Plaintiff states no cause of action against Elystina Garcia, Ilidio Garcia, or James Taylor.
The Fourth Cause of Action — Waste, is against Mary Garcia on her behalf and on behalf of her
minor children Elystina Garcia, Ilidio Garcia, and Defendant James Cody Taylor.
Additionally, Paragraph 52 alleges that “Defendants Mary Elizabeth Garcia was under a
duty to preserve and protect the property from third parties such as Defendant James Cody
Taylor and her minor children Elystina Garcia and Ilidio Garcia,...” Plaintiff does not allege in
10 the First Amended Complaint that Elystina Garcia, Ilidio Garcia, and James Cody Taylor had a
11 duty to preserve and protect the property.
12 Plaintiff alleges in paragraph 53 that James Taylor was “allowed to live” at the property
13 by Defendant Mary Garcia. Plaintiff makes no allegation that Taylor had any possessory
14 interest. Plaintiff’s allegations failas to allthree defendants.
15 To establish a claim for waste, the damage alleged must substantially or permanently
16 diminish the value of the property. Plaintiff utterly fails to allege facts which if proven as true,
17 would show substantial damage to the value of the property due to failure to pay utility bills,
18 failure to irrigate the property, or maintaining the swimming pool as alleged in Paragraph 54.
19 These allegations, if true, would constitute only a temporary condition, but would not cause
20 depreciation to the value of the property sufficient to constitute a claim for waste. (Rowe v. Wells
21 Fargo Realty Servs., Inc., (Ct. App. 1985) 166 Cal. App. 3d 310, 320, 212 Cal. Rptr. 374, 379.)
22 While California CC section 1714.1 imputes liability on a parent for the acts of the
23 minors under their care and control, there is no such law that imputes liability on a minor for the
24 acts of their parents or other adults in their household.

25 Paragraph 54 alleges that all Defendants failed to pay utility charges, however, Paragraph
26 7 of the First Amended Complaint specifically states that both Mary Garcia and her roommate
27 Jeffrey Clelio Bellotti agreed to pay these bills in exchange for a tenancy at the Residence. As
28

4
Elystina Garcia, Ilidio Garcia, James Cody Taylor Memorandum In Support of Demurrer to
Plaintiff's First Amended Complaint
modified in June 21, 2018, the oral contract provided that only Mary Garcia agreed to pay for the
utility bills (First Amended Complaint Paragraph 9).Further, as stated above, minors are
prohibited from contracting for an interest in real property, so Elystina and Ilidio could not have
agreed to pay utility bills in exchange for tenancy and Elystina and Ilidio cannot be held liable
for their mother’s alleged failure to pay bills that she agreed to pay in exchange for tenancy at the
Residence. Mr. Taylor never agreed to pay utility charges, and so cannot be held liable for
damages caused by alleged non-payment. All bills were in Mary Garcia’s name. (First Amended
Complaint Paragraphs 7, 19.) Plaintiff fails to state how Defendants’ failure to pay bills in Mary
Garcia’s name caused damage or waste to his real property.
10 In paragraphs 12, 13, 15, 22, 26, 27, 36, and 53, Plaintiff alleges that Defendant James
il Cody Taylor caused damage to the upstairs bathroom, the sprinkler system, and the pool, and
12 Elystina and Ilidio’s mother allowed this to happen. Elystina and Ilidio are not liable for the
13 alleged actions of their mother or of James Taylor, another adult living at the Residence.
14 In support of his claim for punitive damages, Plaintiff alleges that Elystina and Ilidio
15 Garcia, and Mr. Taylor acted intentionally, oppressively, and with an evil motive to vex, injure,
16 harass, and/or annoy Plaintiff and to cause severe emotional distress.” (First Amended Complaint
17 Paragraph 59.) These are purely conclusory statements with no facts to support Plaintiff's
18 contentions.

19 Plaintiff claims Elystina and Ilidio Garcia and Mr. Taylor are subject to treble damages
20 pursuant to California Code of Civil Procedure §732. (First Amended Complaint Paragraph 60)
21 California Code of Civil Procedure section 732 provides for ajudgment for treble damages
22 where a “guardian, conservator, tenant for life or years, jointtenant, or tenant in common of real
23 property, commit waste thereon...” A transfer of real property interest for life years, as joint
24 tenant or tenant in common must be in writing. (Civ. Code § 1624(a)(3).) As alleged in
25 paragraphs 7 and 51 of the First Amended Complaint, no one but Mary Garcia was given an
26 interest inthe property. Thus, Elystina and Ilidio Garcia and Mr. Taylor did not have a
27 possessory interest, and so did not have a tenancy for years, or a life estate; they do not have any
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5
Elystina Garcia, Iidio Garcia, James Cody Taylor Memorandum In Support of Demurrer to
Plaintiff's First Amended Complaint
tenancy at all as they were minors who could not enter into contracts for any interest of real
property. (Civ. Code § 6701.) Therefore, they are not subject to treble damages under California
Civil Code section 732.

Without apossessory interest, Elystina and Iidio Garcia and Mr. Taylor had no duty to
preserve the property. Additionally, Elystina and Ilidio Garcia cannot be held liable for the
actions of their parent. Therefore, Elystina and Ilidio Garcia and Mr. Taylor are not liable for any
of the alleged waste. The Court should sustain this demurrer because Plaintiff is not entitled to
damages from Elystina and Ilidio Garcia and Mr. ‘l'aylor.

Grounds for Demurrer of Fifth Cause of Action (Conversion)
Grounds for Demurrer of Fifth Cause of Action (Conversion)
10
To plead a cause of action for conversion, the plaintiff must establish (1) plaintiffs’
11
ownership or right to possession of the property at the time of the conversion; (2) defendants’
12
conversion by a wrongful act or disposition of plaintiffs' property rights; and (3) damages.
13
(Baldwin v. Marina City Properties, Inc., (Ct. App. 1978) 79 Cal. App. 3d 393, 410, 145 Cal.
14
Rptr. 406, 416.). (Demurrer granted for failure to properly allege conversion damages.)
15
Plaintiff's claim of conversion is subject to a demurrer because Plaintiff fails to allege
16
sufficient facts to state a cause of action for conversion and conspiracy to commit conversion,
17
and the First Amended Complaint isvague and ambiguous.
18
Plaintiff states no cause of action against Elystina Garcia, Ilidio Garcia, or James Taylor.
19
The Fifth Cause of Action — Conversion, is against Mary Garcia on her behalf and on behalf of
20
her minor children Elystina Garcia, Ilidio Garcia, and Defendant James Cody Taylor.
21
Plaintiff failsto allege facts to support the third element of conspiracy: i.e.damages. CC
22
§ 3336, states damages as the value at the time and place of conversion plus interest or
23
alternatively, faircompensation for time and money expended in pursuit of property. A measure
24
of replacement value is not a proper measure of damages, although replacement value may be a
25
factor in determining actual value. (See Baldwin, Id. at 393; Franklin v. Municipal Court, (Ct.
26
App. 1972) 26 Cal.App.3d 884, 902, 103, Cal.Rptr. 354; Cal. Civ. Prac. Torts § 15:10; and
27
Chatterton v. Boone, (1947) 81 Cal. App. 2d 943, 947, 185 P.2d 610, 612.)
28

6
Elystina Garcia, Ilidio Garcia, James Cody Taylor Memorandum In Support of Demurrer to
Plaintiff's First Amended Complaint
Exhibit 13 of the First Amended Complaint listsa value of each item allegedly sold by
Elystina, Ilidio, Mr. Taylor, Mary Garcia and/or and Does 1-40, but Plaintiff fails to establish
that the amount listed in Exhibit 13 is the value at the time and place of conversion and not the
replacement value of each item. Additionally, Plaintiff alleges real property darnage as a result of
the conversion. (First Amended Complaint Paragraph 67.) This too is in violation of CC §3336.
A plaintiff cannot recover real property damages for conversion of personal property.
Paragraph 69, seeks recovery for punitive damages. Punitive damages are only available
where plaintiff shows by clear and convincing evidence that defendant was guilty of oppression,
fraud or malice. (Civ. Code § 3294(a); Krieger v. Pacific Gas & Elec. Co. (1981) 119 CA3d 137,
10 148, 173 CR 751, 757-758) Plaintiff has failed to allege facts showing by clear and convincing
11 evidence that defendants are guilty of oppression, fraud or malice, but rather states in a
12 conclusory manner that defendants Elystina, Illidio, and Mr. Taylor acted “intentionally,
13 oppressively, and with an evil motive to vex, injure, harass, and/ or annoy Plaintiff.” Thus,
14 Plaintiff has failed to state a claim for punitive damages.
15 A claim of civil conspiracy isnot a separate tort cause of action, but rather a way to join
16 all co-defendants in liability for the tort stated in the cause of action. (Applied Equip. Corp. v.
17 Litton Saudi Arabia Ltd., (1994) 7 Cal. 4ths 503, 511, 869 P.2d 454, 457.)
18 For Plaintiff to establish a claim of conspiracy, he must allege Defendant had knowledge
19 of and agreed to both the objective and the course of action that resulted in the injury, that there
20 was a wrongful act committed pursuant to that agreement, and that there was resulting damage.
21 (Spencer v. Mowat, 46 Cal. App. 5th 1024, 1036, 260 Cal. Rptr. 3d 372, 383 (Ct. App. 2020).
22 Civil conspiracy claims are subject to a heightened pleading standard, demanding that a plaintiff
23 allege specific facts “containing evidence of unlawful intent, or face dismissal of the claim.”
24 (Buckey v.Cnty. ofLos Angeles, (9th Cir. 1992) 968 F.2d 791, 794; (Ponomarenko v. Shapiro,
25 (N.D. Cal. 2018). 287 F. Supp. 3d 816, 831.)
26 The First Amended Complaint fails to allege facts to show that each defendant named
27 had individual knowledge of an agreement to convert the personal property described from Mr.
28

7
Elystina Garcia, Ilidio Garcia, James Cody Taylor Memorandum In Support of Demurrer to
Plaintiff's First Amended Complaint
Dhesi’s possession. In addition, the language of the claim, as pled, is unclear and ambiguous. In

particular, the language used in Paragraph 62 states, “at a time that Defendants, and each of

them, at the time of Defendants, and each of their, actions Defendants, and each of them, had

control over the items listed in ‘Exhibit 13’...” isso ambiguous and confusing that defendants

Elystina, Ilidio, and Mr. Taylor cannot reasonably formulate an answer to this allegation.

By failing to state facts with the required specificity to show conspiracy, Plaintiff fails to

allege any facts at all that supports a claim that either Elystina, [lidio, or Mr. Taylor committed

conversion. Instead, Plaintiff depends on his theory of conspiracy listing each defendant

including “Does 1-40” as an “and/or” combination (First Amended Complaint Paragraphs 62-69)
10 without ever specifying which defendant actually did the act. Elystina, Ilidio and Mr. Taylor
11 cannot be held liable for damages suffered by Plaintiff due to conversion that may or may not
12 have resulted from the acts of “Does 1-40.”

13 Because Plaintiff fails to allege facts sufficient to state a cause of action for conversion
14 and conspiracy to commit conversion, the court should sustain the demurrer.

iD Il. CONCLUSION
16 Based upon the foregoing, defendants, Elystina and Illido Garcia and Mr. Taylor, submit
17 that Plaintiff has failed to state facts sufficient to constitute valid causes of action in itsFirst

18 Amended Complaint, and therefore respectfully request that their demurrer to each cause of

19 action in the First Amended Complaint be sustained without leave to amend.

20 Dated:

21 Respectfully submitted,

24 Date: X/ LX ZA FO Legal Services of Northern California

25 By: C. [ee ae

26 Cathleen Leavenworth

8
Elystina Garcia, Ilidio Garcia, James Cody Taylor Memorandum In Support of Demurrer to
Plaintiff's First Amended Complaint
DECLARATION OF CATHLEEN LEAVENWORTH

I,Cathleen Leavenworth, declare:

1. I make this declaration of my personal knowledge and could testify thereto if called as a

witness.

2. Iam an attorney duly licensed to practice law in the State of California and am counsel for

Defendants Mary Elizabeth Garcia, Elystina Garcia, Ilidio Garcia, and James Cody Taylor.

3. On September 17, 2020 I spoke to Mr. Dhesi on the telephone. Inotified Mr. Dhesi that I

planned on filing a demurrer for all causes of action as to Mary Garcia and a separate demurrer for

10 her children, Elystina and Ilidio Garcia for the Fourth and Fifth Causes of Action. I also advised Mr.

11 Dhesi that the hearing date for the demurrers has been scheduled for October 22, 2020 at 8:30 AM.
12 Mr. Dhesi expressed no objection to that date
13
4. At the conclusion of our meet and confer, Mr. Dhesi was unwilling to stipulate to amending
14
his pleadings.
15

16
Dated September 18, 2020 in Auburn, Ca. C 2.
17 ‘ AMADAR UB OES

Cathleen Leavenworth
18
Attorney for Defendants
19

28
1
Declaration of Cathleen Leavenworth
W.H. WHITAKER, SBN 145560
hwhitaker@lsnc.net
CATHLEEN LEAVENWORTH, SBN 314534
cleavenworth@Isnc.net
NATALIA DASILVA, SBN 329468
ndasilva@I|snc.net

LEGAL SERVICES OF NORTHERN CALIFORNIA
190 Reamer Street
Auburn, CA 95603
(530) 823-7560 Telephone
(530)823-7601 Facsimile

Attorneys for Defendants Elystina Garcia, Ilidio Garcia, James Taylor

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
IN AND FOR THE COUNTY OF PLACER
11

Case No.: SCV0043998
13 Harry Mohan Singh Dhesi,
Se

Plaintiff,
[PROPOSED] ORDER ON DEMURRER
14
OF ELYSTINA GARCIA; ILIDIO GARCIA:
JAMES CODY TAYLOR
eee

Vs.
ee

16 Mary Elizabeth Garcia, Elystina Garcia, Ilidio ) DATE: October 22, 2020
TIME: 8:30 AM
17 Garcia, James Cody Taylor, and DOES 1-40, DEPT: 42
18 inclusive,

19 Defendant

20
IT IS HEREBY ORDERED:
21

22
The Demurrer of Elystina Garcia, Ilidio Garcia, and James Cody Taylor is sustained.
23

25
Dated:
26

JUDGE OF THE SUPERIOR COURT
27

1
[Proposed] Order On Demurrer of Elystina Garcia; Ilidio Garcia; James Cody Taylor

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September 18, 2020

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November 19, 2019

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Motion,Ex Parte: Dhesi, Harry Mohan Singh vs. Garcia, Mary Elizabeth

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