On March 19, 2021 a
Party Statement
was filed
involving a dispute between
Bimemiller, Kim,
Bimemiller, Laila,
Equity Law Group,
and
Bimemiller, Kim R.,
for Unlimited Civil Other Contract
in the District Court of San Joaquin County.
Preview
Eyad Yaser Abdeljawad, Esq. SBN: 308427
Electronically Filed
BRIDGEPOINT LAW GROUP, APC
Superior Court of California
5670 Schaefer Ave Unit P
Chino CA 91710
County of San Joaquin
2021-09-16 20:24:59
(951) 407-0211 (951) 602-7747
eddie@bridgepointlawgroup.com
Clerk: Taylor Hiedeman
Equity Law Group, S. David Kozich
SAN JOAQUIN
180 E. Weber Avenue
180 E. Weber Avenue
Stockton, 95202
Stockton Courthouse
Equity Law Group
Bimemiller, et al
X
STK-CV-UOCT-2021-0002453
Sept 30, 2021 10: 00 am 10C
X Eyad Yaser Abdeljawad
X Equity Law Group, S. David Kozich
March 19, 2021
X June 14, 2021
X
X
X X Breach of
Contract; Fraud; Breach of Implied Covenant of Good Faith & Fair Dealing; Breach of Fiduciary Duty; Interference
with Prospective Economic Advantage
Equity Law Group
STK-CV-UOCT-2021-0002453
Bimemiller, et al
X
X
2-5-22 thru 2-22-22 - Bench Trial in LA County; 5-13-22 - Administrative Trial
X 1-2
X
X
Equity Law Group
STK-CV-UOCT-2021-0002453
Bimemiller, et al
X
X
X
X
Equity Law Group
Bimemiller, et al STK-CV-UOCT-2021-0002453
X
Petition of ZBS LAW, LLP, Kim R Bimemiller, Kim R Bimemiller c/o Equity Law Group, Laila
Bimemiller,
SAN JOAQIN LailaBimemiller
COUNTY c/o Equity
SUPERIOR Law Group,
COURT Equity Law
- STOCKTON Group
COURTHOUSE
STK-CV-UCP-2021-0000011
ACTIVE
X
MOTION TO STRIKE PORTIONS OF CROSS COMPLAINT; DEMURRER TO CROSS COMPLAINT; MOTION
FOR SUMMARY JUDGMENT
X
Plaintiff/Cross-Defendant Written Discovery December 2021
Plaintiff/Cross-Defendant Deposition January 2021
Equity Law Group
STK-CV-UOCT-2021-0002453
Bimemiller, et al
X
Potential Consolidation of the Interpleader Petition filed by ZBS LLP and this case.
X
Opposing counsel has refused to return my emails and telephone calls
1
September 16, 2021
Eyad Yaser Abdeljawad, Esq.
1 ATTACHMENT TO 4(B)
2
Defendant Kim Bimemiller entered into a 30% contingency fee agreement with Equity
3
Law Group. The scope of the services included exploring the irregularity of a Non-Judicial
4
Foreclosure Sale that was conducted against Defendant’s property, as well as recover any excess
5
6 proceeds that remained after the lienholders were paid off. The written agreement that
7 Bimemiller entered into granted Plaintiff a charging lien that attached to recovery obtained.
8
Plaintiff and its staff performed a substantial amount of work on the Defendant’s file.
9
Defendant, however, had no intention of performing his promises per the agreed upon terms. As
10
shown by the chain of events that transpired, Bimemiller waited until after Equity Law Group
11
12 performed its legal services for Bimemiller to make a claim on his own.
13 Defendant disingenuously asserted that he did not authorize Plaintiff to collect surplus.
14
Defendant in bad faith, filed a Complaint against Plaintiff with the State Bar of California, that
15
was reasonably designed to hinder, intimidate, and dissuade Equity Law Group from pursuing its
16
remedies for Defendants’ malicious and odious conduct.
17
18 Plaintiff bases its request for general damages on the written terms of the fee agreement.
19 Plaintiff is also seeking punitive damages as the conduct of Defendant was fraudulent, malicious,
20
and oppressive. Plaintiff further requests additional fees and costs.
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28 ATTACHMENT 4(B)
-1
1 PROOF OF SERVICE
2
I, EYAD YASER ABDELJAWAD, declare as follows:
3
4 I am over the age of 18 years and not a party to within this action. I am a resident of
5 employed in the county where the mailing occurred. My business address is: 5670 Schaefer Ave
6 Sept. 16, 2021I served the following documents:
Unit P Chino CA 91710. On ___________,
7
8 PLAINTIFF’S CASE MANAGEMENT STATEMENT
9
on the following person(s):
10 • SEE ATTACHED LIST
11 (XX) VIA FIRST CLASS MAIL. I caused such envelop with postage thereon fully
12 prepaid to be placed in the US mail, at Rancho Cucamonga CA. I am familiar with the
firm’s practice of correspondence for mailing with the United States Postal Service and
13 that Correspondence shall be deposited with the United States Postal Service the same
day in the ordinary course of business pursuant to CCP Sec. 1013 (a)
14
15 (XX) VIA EMAIL SUBMISSION PURSUANT TO CCP §1010.6. I emailed a copy of
said documents from eddie@bridgepointlawgroup.com
16
( ) VIA FACSIMILIE TRANSMISSION. By sending true copies thereof via facsimilie
17
transmission to the parties and/or counsel of record.
18
I declare under the penalty of perjury under the laws of the State of California that the
19
20
forgoing is true and correct, that I am readily familiar with the business practice for collection
21 and processing of documents for transmitting via facsimile and US mail, and that this declaration
22 Sept. 16, 2021
was executed on ________________ at Chino, California.
23
24
25
26
27 _____________________
Eyad Yaser Abdeljawad, Esq.
28
PROOF OF SERVICE
-1
1 SERVICE LIST
2
Frank E. Mayo
3 Attorney at Law
4962 El Camino Real Ste 104
4 Los Altos CA 94022
5
fmayolaw@aol.com
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PROOF OF SERVICE
-2
Document Filed Date
September 16, 2021
Case Filing Date
March 19, 2021
Category
Unlimited Civil Other Contract
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Eyad Yaser Abdeljawad, Esq. SBN: 308427 Electronically Filed BRIDGEPOINT LAW GROUP, APC Superior Court of California 5670 Schaefer Ave Unit P Chino CA 91710 County of San Joaquin 2021-09-16 20:24:59 (951) 407-0211 (951) 602-7747 eddie@bridgepointlawgroup.com Clerk: Taylor Hiedeman Equity Law Group, S. David Kozich SAN JOAQUIN 180 E. Weber Avenue 180 E. Weber Avenue Stockton, 95202 Stockton Courthouse Equity Law Group Bimemiller, et al X STK-CV-UOCT-2021-0002453 Sept 30, 2021 10: 00 am 10C X Eyad Yaser Abdeljawad X Equity Law Group, S. David Kozich March 19, 2021 X June 14, 2021 X X X X Breach of Contract; Fraud; Breach of Implied Covenant of Good Faith & Fair Dealing; Breach of Fiduciary Duty; Interference with Prospective Economic Advantage Equity Law Group STK-CV-UOCT-2021-0002453 Bimemiller, et al X X 2-5-22 thru 2-22-22 - Bench Trial in LA County; 5-13-22 - Administrative Trial X 1-2 X X Equity Law Group STK-CV-UOCT-2021-0002453 Bimemiller, et al X X X X Equity Law Group Bimemiller, et al STK-CV-UOCT-2021-0002453 X Petition of ZBS LAW, LLP, Kim R Bimemiller, Kim R Bimemiller c/o Equity Law Group, Laila Bimemiller, SAN JOAQIN LailaBimemiller COUNTY c/o Equity SUPERIOR Law Group, COURT Equity Law - STOCKTON Group COURTHOUSE STK-CV-UCP-2021-0000011 ACTIVE X MOTION TO STRIKE PORTIONS OF CROSS COMPLAINT; DEMURRER TO CROSS COMPLAINT; MOTION FOR SUMMARY JUDGMENT X Plaintiff/Cross-Defendant Written Discovery December 2021 Plaintiff/Cross-Defendant Deposition January 2021 Equity Law Group STK-CV-UOCT-2021-0002453 Bimemiller, et al X Potential Consolidation of the Interpleader Petition filed by ZBS LLP and this case. X Opposing counsel has refused to return my emails and telephone calls 1 September 16, 2021 Eyad Yaser Abdeljawad, Esq. 1 ATTACHMENT TO 4(B) 2 Defendant Kim Bimemiller entered into a 30% contingency fee agreement with Equity 3 Law Group. The scope of the services included exploring the irregularity of a Non-Judicial 4 Foreclosure Sale that was conducted against Defendant’s property, as well as recover any excess 5 6 proceeds that remained after the lienholders were paid off. The written agreement that 7 Bimemiller entered into granted Plaintiff a charging lien that attached to recovery obtained. 8 Plaintiff and its staff performed a substantial amount of work on the Defendant’s file. 9 Defendant, however, had no intention of performing his promises per the agreed upon terms. As 10 shown by the chain of events that transpired, Bimemiller waited until after Equity Law Group 11 12 performed its legal services for Bimemiller to make a claim on his own. 13 Defendant disingenuously asserted that he did not authorize Plaintiff to collect surplus. 14 Defendant in bad faith, filed a Complaint against Plaintiff with the State Bar of California, that 15 was reasonably designed to hinder, intimidate, and dissuade Equity Law Group from pursuing its 16 remedies for Defendants’ malicious and odious conduct. 17 18 Plaintiff bases its request for general damages on the written terms of the fee agreement. 19 Plaintiff is also seeking punitive damages as the conduct of Defendant was fraudulent, malicious, 20 and oppressive. Plaintiff further requests additional fees and costs. 21 22 23 24 25 26 27 28 ATTACHMENT 4(B) -1 1 PROOF OF SERVICE 2 I, EYAD YASER ABDELJAWAD, declare as follows: 3 4 I am over the age of 18 years and not a party to within this action. I am a resident of 5 employed in the county where the mailing occurred. My business address is: 5670 Schaefer Ave 6 Sept. 16, 2021I served the following documents: Unit P Chino CA 91710. On ___________, 7 8 PLAINTIFF’S CASE MANAGEMENT STATEMENT 9 on the following person(s): 10 • SEE ATTACHED LIST 11 (XX) VIA FIRST CLASS MAIL. I caused such envelop with postage thereon fully 12 prepaid to be placed in the US mail, at Rancho Cucamonga CA. I am familiar with the firm’s practice of correspondence for mailing with the United States Postal Service and 13 that Correspondence shall be deposited with the United States Postal Service the same day in the ordinary course of business pursuant to CCP Sec. 1013 (a) 14 15 (XX) VIA EMAIL SUBMISSION PURSUANT TO CCP §1010.6. I emailed a copy of said documents from eddie@bridgepointlawgroup.com 16 ( ) VIA FACSIMILIE TRANSMISSION. By sending true copies thereof via facsimilie 17 transmission to the parties and/or counsel of record. 18 I declare under the penalty of perjury under the laws of the State of California that the 19 20 forgoing is true and correct, that I am readily familiar with the business practice for collection 21 and processing of documents for transmitting via facsimile and US mail, and that this declaration 22 Sept. 16, 2021 was executed on ________________ at Chino, California. 23 24 25 26 27 _____________________ Eyad Yaser Abdeljawad, Esq. 28 PROOF OF SERVICE -1 1 SERVICE LIST 2 Frank E. Mayo 3 Attorney at Law 4962 El Camino Real Ste 104 4 Los Altos CA 94022 5 fmayolaw@aol.com 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE -2