Party Statement: Lucero, Jennifer et al vs. Dudley, Matthew Thomas et al

On June 15, 2020 a Party Statement was filed involving a dispute between Alice Kwan, Matthew Dudley, James Olson, Jennifer Lucero, and Alice Kwan, Jpmorgan Chase Bank, N.A., Matthew Dudley, Mortgage Electronic Registration Systems, Inc., Opes Advisors, Inc., for Civil-Roseville in the District Court of Placer County.

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1 KENNETH S. KATZOFF (SBN 103490)
NICOLE C. CAMPBELL (SBN 325516) 08/24/2020
2 Katzoff & Riggs LLP
1500 Park Avenue, Suite 300
3 Emeryville, CA 94608
Tel. (510) 597-1990
4 Fax. (510) 597-0295
kkatzoff@katzoffriggs.com
5 ncampbell@katzoffriggs.com

6 Attorneys for Plaintiffs JENNIFER LUCERO
and JAMES D. OLSON
7
SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER
8
UNLIMITED CIVIL JURISDICTION
9
JENNIFER LUCERO, an individual, and ) Case No. S-CV-0045037
10 JAMES D. OLSON, an individual, )
KATZOFF & RIGGS LLP
1500 PARK AVE., SUITE 300

) DECLARATION OF NICOLE C.
EMERYVILLE, CA 94608

11 Plaintiffs, ) CAMPBELL IN RESPONSE TO
(510) 597-1990

) MOTION OF DEFENDANTS AND
12 v. ) CROSS-COMPLAINANTS
) MOTION TO APPOINT REFEREE
13 ) AND FOR ENTRY OF
) INTERLOCUTORY JUDGMENT
14 MATTHEW THOMAS DUDLEY, et al. )
) Date: September 4, 2020
15 Defendants. ) Time: 8:30 a.m.
__________________________________ ) Dept. 3
16 )
AND RELATED CROSS-ACTION ) Hon. Michael Jones
17 )
__________________________________ )
18

19 NICOLE C. CAMPBELL declares:

20 1. I am an attorney of record for Plaintiffs and Cross-Defendants JENNIFER

21 LUCERO and JAMES D. OLSON (“Plaintiffs”) in this action. I have personal knowledge

22 of the matters set forth in this declaration, and can competently testify thereto. I am a

________________________________________________________________
1
DECLARATION OF NICOLE C. CAMPBELL IN RESPONSE TO MOTION TO APPOINT REFEREE AND ENTRY
OF INTERLOCUTORY JUDGMENT
1 custodian of records with respect to documents produced in and relating to this litigation

2 and have received and reviewed such documents.

3 2. Plaintiffs and Defendants have reached an agreement to stipulate to entry of

4 an interlocutory judgment and to appoint a referee on the following terms:

5 a. Kevin Singer shall be appointed referee pursuant to Cal. Code of Civil

6 Procedure § 873.010, et seq.

7 b. The Referee shall employ Cliff Busby of Dickson Realty Truckee Inc. as the

8 listing agent to sell the property that is the subject of this partition Action.

9 3. A copy of the resume of Kevin Singer is attached as Exhibit A.

10 4. Plaintiffs anticipate the parties and Mr. Singer will agree upon the form of a
KATZOFF & RIGGS LLP
1500 PARK AVE., SUITE 300
EMERYVILLE, CA 94608

11 stipulation for entry of interlocutory judgment and appointment of a referee prior the
(510) 597-1990

12 hearing on Defendants’ motion for entry of interlocutory judgment (the “Motion”)

13 scheduled for September 4, 2020.

14 5. On July 29, 2020, Ethan Birnberg sent my office an e-mail requesting

15 appointment of a referee.

16 6. On August 6, 2020, my office agreed to appointment of a referee and

17 provided a draft stipulation for entry of interlocutory judgment. I requested a conference

18 call with Mr. Birnberg to discuss the stipulation and proposed judgment. Mr. Birnberg’s

19 response failed to address my request for a conference call, however, Mr. Birnberg agreed

20 to review the stipulation and provide a written response. Moreover, the parties exchanged

21 information regarding their respective proposed referee candidates. A true copy of a series

22 of e-mail exchanges between Mr. Birnberg and our office between August 6, 2020 and

________________________________________________________________
2
DECLARATION OF NICOLE C. CAMPBELL IN RESPONSE TO MOTION TO APPOINT REFEREE AND ENTRY
OF INTERLOCUTORY JUDGMENT
,..

1 August 10, 2020, as well as the proposed stipulation and judgment, are attached as Exhibit B

2 7. On August 11, 2020, Defendants rejected the draft stipulation without

3 providing any suggested revisions and served the Motion.

4 8. On August 12, I e-mailed Mr. Birnberg to inform him the Motion had been

5 prematurely filed before completing good faith meet and confer efforts. A true copy of a

6 series of e-mail exchanges between Mr. Birnberg and our office between August 11, 2020

7 and August 13, 2020 is attached as Exhibit C.

8 9. Subsequent to my e-mail of August 12, the parties engaged in further meet

9 and confer efforts and reached the agreement set forth above. A true copy of an e-mail

from Mr. Birnberg dated August 20, 2020 in which he confirms the agreement to appoint

Kevin Singer as referee is attached as Exhibit D.

10. Plaintiffs respectfully request the Court enter an interlocutory judgment

consistent with the agreement of the parties and approved as to form by the parties and Mr.

14 Singer.

15 I declare under penalty of perjury under the laws of the State of California that the

16 foregoing is true and correct. Executed on August 24, 2020 in Hayward, California.

19 NICOLEC. CA

DECLARATION OF NICOLE C. CAMPBELL IN RESPONSE TO MOTION TO APPOINT REFEREE AND ENTRY
OF INTERLOCUTORY JUDGMENT
1 PROOF OF SERVICE

2 I, the undersigned, declare that I am, and was at the time of service of the papers herein
referred to, over the age of eighteen (18) years and not a party to the within action or
3
proceeding. I am employed in the County of Alameda, State of California. My business
4 address is 1500 Park A venue, Suite 300, Emeryville, CA 94608. I am familiar with the

5 regular mail collection and processing practices of Katzoff & Riggs LLP for
correspondence deposited for mailing with the United States Postal Service. My electronic
6
service address is ncampbell@katzoffriggs.com. On the date set forth below, I caused to
7 be served the following document(s):

8
DECLARATION OF NICOLE C. CAMPBELL IN RESPONSE TO MOTION OF
9 DEFENDANTS AND CROSS-COMPLAINANTS MOTION TO APPOINT
REFEREE AND FOR ENTRY OF INTERLOCUTORY JUDGMENT

addressed to each such addressee respectively as follows:

Ethan Birnberg
Porter Simon
Professional Corporation
40200 Truckee Airport Road, Suite 1
Truckee, CA 96161
14 birnberg@portersimon. com

15 I then served the above documents on the above addressee(s) in the following manner:

16 [X] VIA E-MAIL by causing a true copy thereof to be electronically transmitted to the
e-mail address(es) listed above.
17
I declare under penalty of perjury, under the laws of the State of California and the
18

19
United States of America that the foregoing is true and correct.

2020, at Hayward, California. -W Executed on August 24,

t:J/ /
20 NICOLEC.C~

DECLARATION OF NICOLE C. CAMPBELL IN RESPONSE TO MOTION TO APPOINT REFEREE AND ENTRY
OF INTERLOCUTORY JlJDGMENT
EXHIBIT A
Receivership Specialists
State and U.S. Federal Court Receivers / Referees / Trustees

Kevin Singer
Court Receiver, Court Referee, Trustee, Special Master & Bankruptcy Trustee
Expert Witness

Cell: (323) 864-4214
E-mail: Kevin@ReceivershipSpecialists.com Corporate Headquarters
Los Angeles
Web:www.ReceivershipSpecialists.com 11500 W. Olympic Blvd
Suite 530
Los Angeles, California
Kevin Singer is founder and President of Receivership Specialists and with his 90064
Tel: (310) 552-9064
Fax: (310) 552-9066
business partner John Rachlin, they specialize in state and Federal Court Receiverships,
San Francisco
795 Folsom Street, 1st Floor
Referee Assignments, Partition Sales, Provisional Director Assignments, Professional San Francisco, California
94107
Trustee Assignments and Bankruptcy Trustee Assignments. Receivership Specialists has Tel: (415) 848-2984
Fax: (415) 848-2301
offices in Los Angeles, San Francisco, Sacramento, San Diego, Ventura, Phoenix, Reno, San Diego
4370 La Jolla Village Drive,
and Las Vegas and handles assignments throughout the Southwest. The alliance of these Suite 400
San Diego, California 92122
Tel: (858) 546-4815
two professionals brings together their vast knowledge and experience in the areas of Fax: (858) 646-3097

law, real estate, business management, construction, and conflict resolution. Sacramento
980 9th Street, 16th Floor
Sacramento, CA 95814
Mr. Singer first started getting appointed as a rents & profits receiver due to his Tel: (916) 449-9655
Fax: (916) 446-7104
extensive real estate, property management and construction experience as founder and
Ventura / Santa Barbara
1500 Palma Drive
co-owner of a diversified real estate and consulting company. He is a Real Estate Broker, 2nd Floor
Ventura, CA 93003
Licensed Building Contractor and Professional Fiduciary. After selling that company in Tel: (805) 267-1283
Fax: (805) 654-0080
2000, Mr. Singer once again joined forces with his longtime counsel, friend and business Las Vegas
7251 W. Lake Mead Blvd.
partner, Mr. Rachlin, to specialize in receivership assignments. Mr. Rachlin is co- Suite 300
Las Vegas, NV 89128
Phone: (702) 562-4230
founder and a principal with Receivership Specialists and has been a licensed attorney Fax: (702) 562-4001

for 26 years. Although Mr. Rachlin now serves as a full-time Receiver and Referee, he Reno
200 South Virginia Street,
Suite 800
previously practiced in various areas of real estate and general business law, as well as Reno, NV 89501
Phone: (775) 398-3103
served as in-house counsel for a large real estate company. Over the past seventeen Fax: (775) 686-2401

Phoenix
years, Mr. Singer and Mr. Rachlin have handled over 400 cases for large and small 40 North Central Avenue
Suite 1400
banks, private lenders, private investors and municipalities. They have also managed and Phoenix, AZ 85004
Phone: (602) 343-1889
Fax: (602) 343-1801
transitioned over a billion dollars in assets. Mr. Singer has served as a Receiver, Referee,
Trustee, and Bankruptcy Trustee over all different types of real estate, businesses, gas

Receivership Specialists
State and U.S. Federal Court Receiver / Trustees
Page 1 of 78
Receivership Specialists
State and U.S. Federal Court Receivers / Referees / Trustees

stations, hotels, assisted living facilities, restaurants, bars, liquor licenses, family estates/trusts,
commodities and construction projects. Mr. Singer is currently President and on the Board of
Directors of the California Receivers Forum (CRF), an Associate Publisher for Receivership
News, seven time participant and panelist at the CRF in conjunction with Loyola Law School
Receivers Education Program, and he lectures and writes on various topics in the receivership
field.

Hourly Billing Rates:
• $275 per hour for principals
• $250 per hour for senior project managers
• $185 per hour for project managers
• $150 per hour for accountants
• $85 per hour for support staff

Affiliated Organizations:
• Member & Board of Director for California State and Los Angeles/Orange County Chapter of
California Receivers Forum
• Bay Area Receivers Forum
• San Diego Receivers Forum
• Clark County Bar Association
• Maricopa Bar Association

Speaking Engagements & Publications
6/24/2020 How To Navigate Business Defaults In The Cannabis Industry (Provisors)
4/15/2020 Current Climate of Receiverships (California Receivers Forum)
2/6/2020 Partition Actions (WRS&R)
5/22/2019 Navigating Liquor License and Cannabis Receiverships (Los Angeles County Bar
Association)
5/18/2019 ABC, Bankruptcy or Receivership - Choosing Your Trajectory (California Bankruptcy
Forum)
5/8/2019 Receivership News: Receiver’s Rights Trump Secured Creditors Rights To Collect Rent
1/24/2019 Health & Safety Receiverships & The California Housing Crisis (California Receivers
Forum in Conjunction with Loyola Law School (“CRFICW Loyola Law School”).
1/24/2019 All Things Cannabis (“CRFICW Loyola Law School”).
11/2/2018 Morning in the Weeds, A Blunt Discussion of Marijuana Businesses (State Bar of
Arizona)
5/10/2018 Receivership Appointments (Graceli Conference)

Receivership Specialists
State and U.S. Federal Court Receiver / Trustees
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Receivership Specialists
State and U.S. Federal Court Receivers / Referees / Trustees

4/4/2018 Partition Actions & Sale Of Real Property (WRS&R)
3/23/2017 Receiverships’ Joint Role in Cannabis: Where There’s Smoke, How to Fire? (San
Francisco Receivers Forum)
9/14/2017 Cannabis-ness (Turnaround Management Association)
9/1/2017 How To Sell Real Estate Through A Receivership (WRS&R)
8/17/2017 Receivership Reality (California Receivers Forum)
6/7/2017 Receivership 101 (Pima County Bar Association)
3/4/2017 Marijuana Receiverships (California Receivers Forum)
3/3/2017 Procedures To Control Vexatious Litigation In Receivership Cases (California
Receivers Forum)
2/27/2017 Budding Issues: The Intersection of Legal Marijuana and Federal Bankruptcy
Proceedings (Los Angeles Bankruptcy Forum
11/10/2016 Ask The Judges Luncheon (California Receivers Forum)
8/18/2016 Receivership News: The Do’s and Don’ts of Medical Marijuana Receiverships
7/16/2016 Running a Pot Business (Turnaround Management Association, San Diego California)
6/9/2016 Gas Stations & Convenience Stores: Preparing for a Successful Sale (OC Receivers
Forum)
5/13/2016 Medical Marijuana Receiverships (The Law Firm of Gust Rosenfeld, Phoenix
Arizona)
10/28/2015 Sex, Drugs, and Section 8: The Seedy Underbelly of Receiverships (Bay Area
Receivers Forum)
6/17/2015 Oil Fields & Gas Station Receiverships (Los Angeles/Orange County Receivers
Forum)
Summer 2014 California Receivership News: A Story of Risk in a Post-Judgment Receivership
9/11/2014 Successful Sale of Assets through Post Judgment Receiverships (Los Angeles/Orange
County Chapter of CRF)
5/2/2014 State & Federal Court Receiverships (Ron Siegel Radio Show)
4/04/2013 Environmental Receiverships (Los Angeles/Orange County Chapter of CRF)
2/22/2013 Business Receiverships (The Law Firm of Wolf, Rifkin, Shapiro, Schulman & Rabkin,
LLP)
1/19/2013 Receiverships with Environmental Issues (California Receivers Forum in Conjunction
with Loyola Law School)
Fall 2012 Receivership News: Interview with Judge Luis A. Lavin
10/31/2011 Selling Personal Property through Receiverships (Orange County Receivers Forum)
10/17/2011 Receiverships 2012 & Beyond (San Diego Receivers Forum)
Fall 2011 Receivership News: Receivership Liquor License Sales
9/26/2011 Condominium Receiverships (Bank & Financial Institutions Forum)
9/22/2011 Receiverships Selling Property and Clearing Title (Los Angeles Receivers Forum)
5/21/2011 Commercial Receiverships (California Bankruptcy Forum)

Receivership Specialists
State and U.S. Federal Court Receiver / Trustees
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Receivership Specialists
State and U.S. Federal Court Receivers / Referees / Trustees

1/22/2011 Rents & Profits Receiverships (California Receivers Forum in Conjunction with
Loyola Law School)
8/25/2010 Receiverships over Broken Condominium Projects (California Receivers Forum)
10/27/2009 How to Sell Real Estate Though a Partition or Receivership (California Receivers
Forum)
8/20/2009 Ask The Commissioner and Receiver (California Receivers Forum)
8/19/2009 Protecting Tenants at Foreclosure Act 2009 and Receiverships (American Legal
Financial Network)
2/25/2009 Partition Referees, a Tool for Estate Management and Sales (Riverside County Bar
Association)
9/11/2008 Breakfast with the Experts (San Diego Receivers Forum)

Receivership Specialists
State and U.S. Federal Court Receiver / Trustees
Page 4 of 78
Receivership Specialists
State and U.S. Federal Court Receivers / Referees / Trustees

Case Assignments:
Ama Urrutia vs. Hasna Bashara - Judge Arnold Levin Dept. 66
(Los Angeles County, Los Angeles Superior Court, Case Number: BC229134)
642 Plymouth Avenue, Los Angeles, CA 90038
May 2000 to February 2001
Receiver (appointed to protect, manage and correct Health & Safety Violations for an apartment
building).

Margaret Martin vs. Maria Wooden - Judge Richard Fruin Jr. Dept. 15
(Los Angeles County, Los Angeles Superior Court, Case Number: BC271829)
833 W. 58th Street, Los Angeles, CA 90037
November 2002 to March 2003
Receiver/Referee/Partitioner (appointed to protect, manage, correct Health & Safety
Violations, sell single family home, and facilitate the division of proceeds amongst the parties).

Hartel Dillion vs. Jaspal Dillion - Judge Richard Fruin Jr. Dept. 15
(Los Angeles County, Los Angeles Superior Court, Case Number: TC011162)
8227 Alhambra Avenue, Paramount, CA 90723
September 2003 to January 2004
Receiver/Partitioner (appointed to protect, manage and partition an apartment building).

CMR Mortgage vs. M & S Properties LLC - Commissioner Victor Greenberg Dept. 66
(Los Angeles County, Los Angeles Superior Court, Case Number: BC314632)
729 S. Union Avenue, Los Angeles, CA 90058
1021 S. Park View Street, Los Angeles, CA 90006
May 2004 to November 2004
Receiver (appointed to protect, manage and correct Health & Safety violations for two single
room occupancy (SRO) apartment buildings with 166 units).

Julia Torres vs. Ruben Torres - Judge Joanne O’Donnell
(Los Angeles County, Los Angeles Superior Court, Case Number: )
1929 Hancock Street, Los Angeles, CA 90031
October 2004 to March 2005
Receiver/Referee/Partitioner (appointed over an apartment building to protect, manage, sell
and facilitate the division of the proceeds amongst the parties).

Juan Rodarte vs. Mario Frias - Judge Richard Fruin Jr. Dept. 15
(Los Angeles County, Los Angeles Superior Court, Case Number: BC310006)
6131 Clybourn Street, North Hollywood, CA 91605
November 2004 to April 2005

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State and U.S. Federal Court Receiver / Trustees
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Receivership Specialists
State and U.S. Federal Court Receivers / Referees / Trustees

Receiver/Referee/Partitioner (appointed over an apartment building to protect, manage, sell
and facilitate the division of proceeds amongst the parties).

CMR Mortgage vs. M & S Properties LLC - Judge Barry Russell
(United States Bankruptcy Court, Case Number: LA0432491BR)
729 S. Union Avenue, Los Angeles, CA 90058
1021 S. Park View Street, Los Angeles, CA 90006
November 2004 to May 2005
United State Bankruptcy Custodian (appointed to protect and manage two single room
occupancy (SRO) apartment buildings with 166 units).

City of Los Angeles vs. Patrick Larkin - Commissioner Bruce Mitchell Dept. 59
(Los Angeles County, Los Angeles Superior Court, Case Number: BC328299)
2117 to 2129 Vallejo Street, Los Angeles, CA 90031
May 2005 to August 2005
Court Consultant (appointed to write an Property Evaluation, Project Feasibility, Comparative
Market Analysis, and Rent Evaluation Reports).

CMR Mortgage vs. P. Bidda Holdings Inc. - Judge Steve Brick
(County of Alameda, Oakland Superior Court, Case Number: HG05220034)
4160 - 4170 Business Center Drive, Fremont, CA 94538
June 2005 to February 2006
Receiver (appointed to protect and manage a 38,000 square foot office/manufacturing complex).

CMR Mortgage vs. P. Bidda Holdings Inc. - Judge Leslie Tchaikovsky
(United States Bankruptcy Court, Case Number: 05-49187)
4160 Business Center Drive, Fremont, CA 94538
November 2005 to February 2006
United States Bankruptcy Custodian (appointed to protect and manage a 38,000 square foot
office/manufacturing complex).

Tom Block vs. Glen D. Boon - Commissioner Bruce Mitchell Dept. 59
(Los Angeles County, Los Angeles Superior Court, Case Number: BC 355173)
4017 Country Club Drive, Los Angeles, CA 90019
July 2006 to November 2006
Receiver (appointed to protect and manage an apartment building).

Torres vs. Torres - Judge Richard Fruin Jr. Dept. 15
(Los Angeles County, Los Angeles Superior Court, Case Number: B 295780)
5616 Via Corona Street, Los Angeles, CA 90022

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State and U.S. Federal Court Receiver / Trustees
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State and U.S. Federal Court Receivers / Referees / Trustees

July 2006 to February 2007
Receiver/Referee/Partitioner (appointed over an apartment building to protect, manage sell and
facilitate the division of proceeds amongst the parties).

California Mortgage And Realty, Inc. vs. Twenty-Seven Fresno, LLC.-Judge Peter J. Busch
Dept. 301
(San Francisco County, San Francisco Superior Court, Case Number: CGC-06-456531)
4715 to 4741 McKinley Avenue, Fresno, CA 93703
575 California Avenue, Sand City, CA 93955
655 Redwood Avenue, Sand City, CA 93955
October 2006 to June 2008
Receiver (appointed to protect and manage a 200 unit public storage building and a 33 unit
apartment building).

Akira Bob Nakamur vs. Mora Bee Siewert - Judge William G. Willett Dept. 11,
(Los Angeles County, South Bay Superior Court, Case Number: YC054106)
10208 to 10212 Felton Avenue, Inglewood, CA 90304.
December 2006 to May 2007
Receiver (appointed to protect and manage a 32 unit apartment building).

Juan Meza vs. Valentina Jimenez - Judge Rolf M. Treu Dept. 58
(Los Angeles County, Los Angeles Superior Court, Case Number: BC 362146)
4660 Dozier Avenue, Los Angeles, CA 90022
January 2007 to September 2008
Receiver/Referee/Partitioner (appointed over a single family home to protect, manage, sell and
facilitate the division of proceeds amongst the parties).

Scarlett vs. Eddings - Judge Richard Fruin Jr. Dept. 15
(Los Angeles County, Los Angeles Superior Court, Case Number: BC 353354)
4524-4528 Edgwood Place, Los Angeles, CA 90019
Lancaster Land
June 2007 to October 2008
Referee/Partitioner (appointed over an apartment building and 80 acres of land to protect,
manage, sell and facilitate the division of proceeds amongst the parties).

De Witt vs. Peterson - Judge Paul Gutman Dept. 34
(Los Angeles County, Los Angeles Superior Court, Case Number: BC 336162)
1434 Stanford Street, Santa Monica, CA 90404
July 2007 to November 2007

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State and U.S. Federal Court Receiver / Trustees
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Receiver (appointed over an apartment building to protect, manage and sell and facilitate the
division of proceeds amongst the parties).

Lone Oak Fund vs. Nasser Albo Abdo, LLC - Judge Sheila Fell/ Clay Smith Dept. C-22
(Orange County, Santa Ana Superior Court, Case Number: 07CC08271)
114 Berry Street, Brea, CA 92821
July 2007 to November 2008
Receiver (appointed to protect and manage a 100,000 sq. ft. Industrial Warehouse collecting over
$912,000 of rents per year).

California Mortgage And Realty, Inc. vs. Twenty-Seven Fresno, LLC.-Judge Peter J. Busch
Dept. 301
(San Francisco County, San Francisco Superior Court, Case Number: CGC-07-467287)
575 California Avenue, Sand City, CA 93955
655 Redwood Avenue, Sand City, CA 93955
950, 707, 709, 713, 717, 719, 938 Linden Avenue, South San Francisco, CA 94080.
712, 714 Linden Avenue, South San Francisco, CA 94080
311 Aspen Avenue, South San Francisco, CA 94080
6010 Mariposa Road, Hesperia, CA 92344
4819 Clayton Road, Concord, CA 94521
31252 Veasy Street, Union City, CA 94587
4700-4862 Homer Street, Union City, CA 94587
September 2007 to March 2009
Receiver (appointed to protect and manage a 200 unit public storage building, 110,000 square
feet of office and industrial space, gas station, 40 unit parking lot, and 20 unit apartment
building).

Howard Higginson v. Gwendolyn Patin - Judge Mary Thorton House Dept. 17
(Los Angeles County, Los Angeles Superior Court, Case Number: BC356318)
616 East 84th Place, Los Angeles, CA 90001
September 2007 to March 2008
Referee/Partitioner (appointed over a single family home to protect, manage, sell and facilitate
the division of proceeds amongst the parties).

Marrufo vs. Portillo - Judge Ralph W. Dau Dept. 57
(Los Angeles County, Los Angeles Superior Court, Case Number: BC 353107)
4796 Academy Street, Los Angeles, CA 90032
October 2007 to May 2008
Referee/Partitioner (appointed over an apartment building to protect , manage, sell and
facilitate the division of proceeds amongst the parties).

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State and U.S. Federal Court Receiver / Trustees
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Garnik Gholikandi Badalyans vs. Caltron Construction, Inc - Judge Richard Fruin Dept.
15
(Los Angeles County, Los Angeles Superior Court, Case Number: BC-341906)
Apn: Riverside County - 407-100-107, 407-100-108, 407-070-023, 407-070-024 & 407-060-001
October 2007 to February 2009
Referee/Partitioner (appointed over 320 acres of land to protect, manage, sell and facilitate the
division of proceeds amongst the parties).

California Mortgage & Realty vs. Edward Suleiman - Judge Charles R. Hayes
(San Diego County, San Diego Superior Court, Case Number: 37-2007-00078050-CU-OR-CTL)
2640-2644 Market Street, San Diego, CA 92102
3626 Maint Street, San Diego, CA 92113
November 2007 to October 2008
Receiver (appointed to protect and manage a 11,000 square feet commercial building).

Terry vs. Puentes - Judge Richard Fruin Dept. 15
(Los Angeles County, Los Angeles Superior Court, Case Number: BC-372787)
4257 E. Eugene Street, Los Angeles, CA 90063
December 2007 to August 2008
Referee/Partitioner (appointed over a single family home to protect, manage, sell and facilitate
the division of proceeds amongst the parties).

Janet Mimms vs. Joyce Scott - Judge Barbara Zaniga Dept. 2
(Contra Costa County, Martinez Superior Court, Case Number: MSC07-02491)
January 2008 to November 2008
Receiver (appointed to protect and manage a janitorial company).

Coastline Commercial Capital vs. Rosario Del Carmen Canjura - Commissioner Victor
Greenberg Dept. 66
(Los Angeles County, Los Angeles Superior Court, Case Number: BC385018)
1659-1681 South Catalina Avenue, Los Angeles, CA 90006
February 2008 to March 2008
Receiver (appointed to protect and manage an apartment building).

Norm Pomeranz vs. Michelle Diaz - Commissioner Bruce Mitchell Dept. 59
(Los Angeles County, Los Angeles Superior Court, Case Number: BC385287)
16815 W. Sunset Blvd., Pacific Palisades, CA 90272
February 2008 to June 2009
Receiver (appointed to protect and manage a single family estate in the Palisades).

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State and U.S. Federal Court Receiver / Trustees
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Undisclosed Individual vs. Undisclosed Individual - Judge Michelle R. Rosenblatt Dept. A
(Los Angeles County, Burbank Superior Court, Case Number: EC 043484)
Global Domination Industries, LLC
March 2008 to November 2009
Partition Referee/Receiver (appointed over an Adult Entertainment Business to protect,
manage, sell and facilitate the distribution of proceeds amongst the partners).

John Schweizer & Forrest Canutt vs. Rediation Services, Inc.-Judge Peter J. Busch Dept.
301
(San Francisco County, San Francisco Superior Court, Case Number: CGC-08-472561)
Remediation Services, Inc.
April 2008 to December 2008
Court Receiver (appointed to protect and manage an environmental engineering company with
multi-million dollar environmental clean-up and abatement contracts).

Alliance Bank vs. Silver Oaks Estates - Judge Kenneth Freeman, Dept. 64
(Los Angeles County, Los Angeles Superior Court, Case Number: BC3887047)
Silver Oak Estates, Lancaster, CA
April 2008 to February 2009
Receiver (appointed to protect, manage, obtain entitlement, complete construction and sell a 21
unit housing development project).

Alliance Bank vs. Davy J. Shuffler - Judge Kirk H. Hakamura, Dept. C56
(Orange County, Santa Ana Superior Court, Case Number: 30-2008-00105514)
2753 Solana Way, Laguna Beach, CA 92651
May 2008 to March 2009
Receiver (appointed to protect, manage, develop budgets to complete the construction for a
luxury beach home).

Lone Oak Fund, LLC. vs. Phu Hin Cheng-Judge Peter J. Busch Dept. 301
(San Francisco County, San Francisco Superior Court, Case Number: GHG-08-475703)
2201 Irvining Street and 1311-1315 23rd Ave., San Francisco, CA 94122
May 2008 to January 2009
Receiver (appointed to protect and manage an 11,000 square foot office and grocery retail store
building).

Lone Oak Fund, LLC. vs. Jose L. Lara, Commissioner Victor Greenberg Dept. 66
(Los Angeles County, Los Angeles Superior Court, Case Number: BC 393531)
1545 Gordon Street, 5923 Carlton Way, 5947 Carlton Way, Los Angeles, CA 90028

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State and U.S. Federal Court Receiver / Trustees
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July 2008 to November 2008
Receiver (appointed to protect and manage a 41 unit apartment building).

Budget Finance Company vs. Charles Green, Commissioner Victor Greenberg Dept. 66
(Los Angeles County, Los Angeles Superior Court, Case Number: BC 393582)
1144 Commonwealth, Los Angeles, CA 90029
July 2008 to July 2008
Receiver (appointed to protect, administer and manage an apartment building)

Alliance Bank vs. 138 ¼ Portfolio, Judge Joseph E. Di Loreto Dept. H
(Los Angeles County, Long Beach Superior Court, Case Number: NC 051283)
1148 Stanley Avenue, Long Beach, CA
833-839 Gaviota, Long Beach, CA
755 Gaviota Avenue, Long Beach, CA
1126 Raymond Avenue, Long Beach, CA
2914 16th Street, Long Beach, CA
1124 Molino Avenue, Long Beach, CA
784 Rose Avenue, Long Beach, CA
2330 E. 6th Street, Long Beach, CA
1119 Dawson Avenue, Long Beach, CA
777-784 Gaviota, Long Beach, CA
1045 Myrtle Avenue, Long Beach, CA
1621 E. 7th Street, Long Beach, CA
329 W. 14th Street, Long Beach, CA
July 2008 to November 2008
Receiver (appointed to a protect, manage and develop 138 condominium units in 14 separate
properties - value of portfolio was $27 million).

Zions First National Bank vs. Eva Correa, Commissioner Victor Greenberg Dept. 66
(Los Angeles County, Los Angeles Superior Court, Case Number: BC 393374)
9900 Lakewood Blvd., Downey, CA 90240
July 2008 to January 2009
Receiver (appointed to protect and manage an office building).

Jaun Garcia vs. Manuel Avila, Judge Michael Mink Dept. B
(Los Angeles County, Burbank Superior Court, Case Number: EC 045029)
12003 Neenach Street, Sun Valley, CA 91352-3017
August 2008 to May 2009
Referee/Partitioner (appointed over a single family residence to protect, manage, sell and
facilitate the division of proceeds amongst the parties).

Receivership Specialists
State and U.S. Federal Court Receiver / Trustees
Page 11 of 78
Receivership Specialists
State and U.S. Federal Court Receivers / Referees / Trustees

Budget Financial vs. Angel Tamiko, Judge Brett C. Klein Dept. 66

Case Info

Case No.

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Document Filed Date

August 24, 2020

Case Filing Date

June 15, 2020

County

Parties

Alice Kwan Cross Complainant
Alice Kwan Defendant
Campbell, Nicole C. Attorneys for Plaintiffs
Campbell, Nicole C. Katzoff & Riggs LLP Attorneys for Plaintiffs
James Olson Cross Defendant
James Olson Plaintiff
Jennifer Lucero Cross Defendant
Jennifer Lucero Plaintiff
JPMorgan Chase Bank, N.A. Defendant
Matthew Dudley Cross Complainant
Matthew Dudley Defendant
Mortgage Electronic Registration Systems, Inc. Defendant
Opes Advisors, Inc. Defendant
Pomeroy, Timothy Robert Aldridge Pite, LLP Attorney for the Defendant
Simon, James Ernest Porter-Simon, P.C. Attorneys for Defendants
Simon, James Ernest Porter-Simon, P.C. Attorney for the Defendant
Kenneth Katzoff Attorneys for Plaintiffs
Ravn Whitington Attorneys for Defendants
Ethan Birnberg Attorneys for Defendants
Christian Brown Attorneys for Plaintiffs
Robert French Attorney

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Party Statement: Lucero, Jennifer et al vs. Dudley, Matthew Thomas et al

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