On April 06, 2018 a
Motion-Secondary
was filed
involving a dispute between
Jacqueline Misho,
and
Cat Cora, Inc,
Cora, Catherine Ann,
for Unlimited Other Collections (09)
in the District Court of Santa Barbara County.
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1
RICHARD l. WIDEMAN, Esq, [SB#41 185]
JONATHAN D, WIDEMAN, Esq. [SE#274526]
2 Frederik's Court # 232
485 Alisal Roarj
a
J Solvang, CA 93463
Phone: (805)245-8916 Fax (805)688-9424
4
riwlaw@gmail.r:om
5 jgnelhanwidem a n @q m a il.
6 Attorneys for Plaintiff
7
8
9 SUPERIOR COURT FOR THE S'IATB OF CA-LIFORN{IA
10
COUNTY OF SANTII, I}ARBARA
ANACAPA DI\TSION
l1
l2 JACQUELINE MISHO dba MISHO
Case No.: 18CV0tr749
LAW GROIJP Pauline Maxwell]
13
fludge
lPlaintiff.
14 REPLY' T'O OPPOSITIONT TO
VS.
15
APPLICATNON FOR RIGHT TO
CATHBRINE ANN (,.CAT") CORA, ATTACI-]I ORDI]R A].{D S.RII] OF.
lo ATTACIil\4EN!|' lDeclariltion
CAT CORA INC., ET AL, - attachecl
t7
lDefendants. fHearing: ]l25l18; 9:30 AM, Dept. (il
18
I9 In her Opposition to the Right to Attach Order, lMsi. Cora (a "celebrity chef'with at least 6
20 contracts with food service providers paying her for thr: use of her nam{3 anicerpt attached hereto and Trial Brief - E,x. E to Mrisho Declaration).
12 Cora's claim (']f 3 of Declaration) that Misho wss flot hired "in connection. with arry
13 business" is obviously false, considering the issues dec,icled by Judge Anderle about the nrature of
t4 businesses and ttre claim by her ex-sprouse that these business assets and contracts and income were
15 and are "comrnunity properly" - which claims were all rejected by Judge Anderle.
1/
lo The Declaration of Misho (attached) explains the situation and is mu.ch more factually
l7 complete and accurate than the conch:sory and obvioui;ly false clairns try Ms. Co,ra.
18 The one single case cited in the Opposition is not applicable and did not present a riituation
19 anything like 1.he situation here. That caselNak(luo132)Lflg4dalleg\2),l2g cal,App 3d 757,,163f
20 dealt 'with a single transaction involving the sale of oner parcel of real pr:ope.rty. 'Tlae court found
2I that ttrat single transaction did not meet the "trade or business" of sellin,g real estate: stan6lrd for
22 granting an attachment. The Court differentiated between IvIs. Kim's business (r,vhich was as a real
ZJ estate broker) and the sale of her long-owned personal real estate as no1. beirrg aytartof that'itrade
24 or business."
25 Here, Cora's businesses and business arrangements were the acttal subject of the liitigation.
)6 Her ooentertainment
business manager" was deposed in the lawsujit, as \ /ere her aocounl.anl. anrJ an
27 attorney who represented her in her Mesa Burger business negotiation, as well as her Mesa Burger
28
REPLY TO OPPOSITION TO APPLICATION F'OI|. RIGHT'IO ATT'ACH ORDIIR
@ues-ct jt g :J9JJAL
I business 'opartner," among others. Experts were employed, deposed anrl testified on the busirress
I issues; the expert for Ms. Cora also vras not paid by Ms. Cora2 - who iloes not explain why she
3 also did not pay her expert.
A
a The claim that somehow the Judgment requiring her to pay child an
Document Filed Date
July 17, 2018
Case Filing Date
April 06, 2018
Category
Unlimited Other Collections (09)
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1 RICHARD l. WIDEMAN, Esq, [SB#41 185] JONATHAN D, WIDEMAN, Esq. [SE#274526] 2 Frederik's Court # 232 485 Alisal Roarj a J Solvang, CA 93463 Phone: (805)245-8916 Fax (805)688-9424 4 riwlaw@gmail.r:om 5 jgnelhanwidem a n @q m a il. 6 Attorneys for Plaintiff 7 8 9 SUPERIOR COURT FOR THE S'IATB OF CA-LIFORN{IA 10 COUNTY OF SANTII, I}ARBARA ANACAPA DI\TSION l1 l2 JACQUELINE MISHO dba MISHO Case No.: 18CV0tr749 LAW GROIJP Pauline Maxwell] 13 fludge lPlaintiff. 14 REPLY' T'O OPPOSITIONT TO VS. 15 APPLICATNON FOR RIGHT TO CATHBRINE ANN (,.CAT") CORA, ATTACI-]I ORDI]R A].{D S.RII] OF. lo ATTACIil\4EN!|' lDeclariltion CAT CORA INC., ET AL, - attachecl t7 lDefendants. fHearing: ]l25l18; 9:30 AM, Dept. (il 18 I9 In her Opposition to the Right to Attach Order, lMsi. Cora (a "celebrity chef'with at least 6 20 contracts with food service providers paying her for thr: use of her nam{3 anicerpt attached hereto and Trial Brief - E,x. E to Mrisho Declaration). 12 Cora's claim (']f 3 of Declaration) that Misho wss flot hired "in connection. with arry 13 business" is obviously false, considering the issues dec,icled by Judge Anderle about the nrature of t4 businesses and ttre claim by her ex-sprouse that these business assets and contracts and income were 15 and are "comrnunity properly" - which claims were all rejected by Judge Anderle. 1/ lo The Declaration of Misho (attached) explains the situation and is mu.ch more factually l7 complete and accurate than the conch:sory and obvioui;ly false clairns try Ms. Co,ra. 18 The one single case cited in the Opposition is not applicable and did not present a riituation 19 anything like 1.he situation here. That caselNak(luo132)Lflg4dalleg\2),l2g cal,App 3d 757,,163f 20 dealt 'with a single transaction involving the sale of oner parcel of real pr:ope.rty. 'Tlae court found 2I that ttrat single transaction did not meet the "trade or business" of sellin,g real estate: stan6lrd for 22 granting an attachment. The Court differentiated between IvIs. Kim's business (r,vhich was as a real ZJ estate broker) and the sale of her long-owned personal real estate as no1. beirrg aytartof that'itrade 24 or business." 25 Here, Cora's businesses and business arrangements were the acttal subject of the liitigation. )6 Her ooentertainment business manager" was deposed in the lawsujit, as \ /ere her aocounl.anl. anrJ an 27 attorney who represented her in her Mesa Burger business negotiation, as well as her Mesa Burger 28 REPLY TO OPPOSITION TO APPLICATION F'OI|. RIGHT'IO ATT'ACH ORDIIR @ues-ct jt g :J9JJAL I business 'opartner," among others. Experts were employed, deposed anrl testified on the busirress I issues; the expert for Ms. Cora also vras not paid by Ms. Cora2 - who iloes not explain why she 3 also did not pay her expert. A a The claim that somehow the Judgment requiring her to pay child an