On July 15, 2003 a
Motion,Ex Parte
was filed
involving a dispute between
Gwen R. Sykes,
and
Douglas Sykes,
for Unlimited Civil
in the District Court of Alameda County.
Preview
sraeante ae HO ed)
a. Fe
@ @ *3929069*
STEVEN B. PISER, SBN 62414
LAW OFFICES OF STEVEN B. PISER FILED
|
A Professional Corporation A
499 Fourteenth Street, Suite 210 ALAMEDA COUNTY
WN
akland, Califormia 94612
Telephone 510-835-5582 JUL 2 6 2004
BRB
CLERK OF THE SUPERIOR COURT
Attomey for Defendant °
Douglas G. Sykes
WwW
: By OAtert yh
te
BOER Geary
A
1
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
oo
IN AND FOR THE COUNTY OF ALAMEDA
10
GWEN R. SYKES, Case No. RG03106646
eet! Nee” Sear! “emma” Nee! Neat” Nena” Smee” Srmeseh” Nonaset Seman”
1]
Plaintiff, NOTICE OF MOTION AND MOTION
12 - FOR ORDER GRANTING PRIOR
Vv. SEPARATE TRIAL ON ISSUE OF
VALIDITY OF PRENUPTIASL
DOUGLAS SYKES, an individual, DOES 1 AGREEMENT
14 through 20, inclusive,
1S Defendants Date: Angust 26, 2004
Time: 9:00 a.m.
16 Dept: 136
Nee?
17 Trial Date: October 1,2004 gy FAX
18 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
19 NOTICE IS HEREBY GIVEN that on August 26, 2004 at 9:00 a.m., or as soon
20 thereafter as the matter may be heard in Department 136 of this court, located at600 Washington
Street, Oakland, California, defendant Douglas Sykes will, and hereby does, move for an order
22 that the issue of the validity and enforceability of the prenuptial agreement entered into by
23 defendant and plaintiff Gwendolyn Sykes in October 2000.
24 The motion will be brought pursuant to Cade of Civil Procedure section 598 and
25 will be made on the grounds that the convenience of the parties and witnesses, the ends of justice,
26 and the economy and efficiency of handling the litigation will be promoted thereby.
Legal
By
27 The motion is based on this notice of motion, the declaration of Steven B. Piser,
Filed
One
28 and the memorandum of points and authorities served and filed herewith, on the records and files
1
LawOffires
af
STEVEN
B. PISER
NOTICE OF MOTION & MOTION FOR ORDER GRANTING PRIOR SEPARATE TRIAL ON ISSUE OF VALIDITY OF
PRENUPTIAL AGREEMENT
PAGE .@2
JUL 26 2664 11:56
= 11:85 FROK- T-150 = P.003 FeAl
O7-26-2004
1 herein, and on such further and additional evidence as may be presented at the hearing of the
2 motion. .
3 Dated: July 23, 2004 LAW OFFICES OF STEVEN B. PISER
4 A Professional Corporation
A
By: fL L
Roc ® Piser
DA
ttorney for Defendant
Douglas Sykes
ST
CO
Oo
10
14
12
13
14
15
16
17
18
19
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25
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2
LowOffieas of
STEVEN.
PISER NOTICE OF MOTION & MOTION FOR ORDER GRANTING PRIOR SEPARATE TRIAL ON ISSUE OF VALIDITY OF
PRENUPTIAL AGREEMENT
PAGE.@3
JUL 26 2664 11:56
T-150 = P.004/012 = F4}5
07-26-2004 = 11:55 PROM-
Sykes v. Sykes.
Alameda County Superior Court Action No. RG03 106840 & RGO3 106646
WW
PROOF OF SERVICE BY MAIL
WY
L, Carole Aubuchon, declare as follows:
FH
Tam employed in Alameda County, California, am over eighteen years of age, and
A
am not a party to the within action or proceeding. My business address is 499 Fourteenth
BO
Street, Suite 210, Oakland, California 94612.
I served a copy of the following document:
won
NOTICE OF MOTION AND MOTION FOR ORDER GRANTING PRIOR
SEPARATE TRIAL ON ISSUE OF VALIDITY OF PRENUPTIAL AGREEMENT
mo
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION
FOR ORDER GRANTING PRIOR SEPARATE TRIAL ON ISSUE OF VALIDITY
el OF PRENUPTIAL AGREEMENT
12 DECLARATION
ORDER GRANTING
OF STEVEN
PRIOR
B. PISER
SEPARATE
IN SUPPORT
TRIAL OF
OF
ISSUE
MOTION
OF
FOR
VALIDITY OF
13 PRENUPTIAL AGREEMENT
14 [PROPOSED] ORDER GRANTING MOTION FOR PRIOR SEPARATE TRIAL
_ON ISSUE OF VALIDITY OF PRENUPTIAL AGREEMENT
15 by placing said copy sealed in an envelope(s) addressed as follows:
16
Hab Siam
17 2921 South Winchester Blvd.
Campbell, California 95008
18
with postage thereon fully prepaid, and thereafter was deposited in the United States Mail
19 at Oakland, California. That there is a delivery service by the United States Mail at the
20 place addressed. That the date of deposit in the mail was July 26, 2004.
21 Ideclare under penalty of perjury that the foregoing is true and correct. Executed
July 26, 2004, at Oakland, California.
22
23
24
Carole Aubuchon
25
26
27
28
PAGE.@4
JUL 26 2@@4 11:57
Document Filed Date
July 26, 2004
Case Filing Date
July 15, 2003
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sraeante ae HO ed) a. Fe @ @ *3929069* STEVEN B. PISER, SBN 62414 LAW OFFICES OF STEVEN B. PISER FILED | A Professional Corporation A 499 Fourteenth Street, Suite 210 ALAMEDA COUNTY WN akland, Califormia 94612 Telephone 510-835-5582 JUL 2 6 2004 BRB CLERK OF THE SUPERIOR COURT Attomey for Defendant ° Douglas G. Sykes WwW : By OAtert yh te BOER Geary A 1 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA oo IN AND FOR THE COUNTY OF ALAMEDA 10 GWEN R. SYKES, Case No. RG03106646 eet! Nee” Sear! “emma” Nee! Neat” Nena” Smee” Srmeseh” Nonaset Seman” 1] Plaintiff, NOTICE OF MOTION AND MOTION 12 - FOR ORDER GRANTING PRIOR Vv. SEPARATE TRIAL ON ISSUE OF VALIDITY OF PRENUPTIASL DOUGLAS SYKES, an individual, DOES 1 AGREEMENT 14 through 20, inclusive, 1S Defendants Date: Angust 26, 2004 Time: 9:00 a.m. 16 Dept: 136 Nee? 17 Trial Date: October 1,2004 gy FAX 18 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 19 NOTICE IS HEREBY GIVEN that on August 26, 2004 at 9:00 a.m., or as soon 20 thereafter as the matter may be heard in Department 136 of this court, located at600 Washington Street, Oakland, California, defendant Douglas Sykes will, and hereby does, move for an order 22 that the issue of the validity and enforceability of the prenuptial agreement entered into by 23 defendant and plaintiff Gwendolyn Sykes in October 2000. 24 The motion will be brought pursuant to Cade of Civil Procedure section 598 and 25 will be made on the grounds that the convenience of the parties and witnesses, the ends of justice, 26 and the economy and efficiency of handling the litigation will be promoted thereby. Legal By 27 The motion is based on this notice of motion, the declaration of Steven B. Piser, Filed One 28 and the memorandum of points and authorities served and filed herewith, on the records and files 1 LawOffires af STEVEN B. PISER NOTICE OF MOTION & MOTION FOR ORDER GRANTING PRIOR SEPARATE TRIAL ON ISSUE OF VALIDITY OF PRENUPTIAL AGREEMENT PAGE .@2 JUL 26 2664 11:56 = 11:85 FROK- T-150 = P.003 FeAl O7-26-2004 1 herein, and on such further and additional evidence as may be presented at the hearing of the 2 motion. . 3 Dated: July 23, 2004 LAW OFFICES OF STEVEN B. PISER 4 A Professional Corporation A By: fL L Roc ® Piser DA ttorney for Defendant Douglas Sykes ST CO Oo 10 14 12 13 14 15 16 17 18 19 20 21 22 23 25 26 27 28 2 LowOffieas of STEVEN. PISER NOTICE OF MOTION & MOTION FOR ORDER GRANTING PRIOR SEPARATE TRIAL ON ISSUE OF VALIDITY OF PRENUPTIAL AGREEMENT PAGE.@3 JUL 26 2664 11:56 T-150 = P.004/012 = F4}5 07-26-2004 = 11:55 PROM- Sykes v. Sykes. Alameda County Superior Court Action No. RG03 106840 & RGO3 106646 WW PROOF OF SERVICE BY MAIL WY L, Carole Aubuchon, declare as follows: FH Tam employed in Alameda County, California, am over eighteen years of age, and A am not a party to the within action or proceeding. My business address is 499 Fourteenth BO Street, Suite 210, Oakland, California 94612. I served a copy of the following document: won NOTICE OF MOTION AND MOTION FOR ORDER GRANTING PRIOR SEPARATE TRIAL ON ISSUE OF VALIDITY OF PRENUPTIAL AGREEMENT mo MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR ORDER GRANTING PRIOR SEPARATE TRIAL ON ISSUE OF VALIDITY el OF PRENUPTIAL AGREEMENT 12 DECLARATION ORDER GRANTING OF STEVEN PRIOR B. PISER SEPARATE IN SUPPORT TRIAL OF OF ISSUE MOTION OF FOR VALIDITY OF 13 PRENUPTIAL AGREEMENT 14 [PROPOSED] ORDER GRANTING MOTION FOR PRIOR SEPARATE TRIAL _ON ISSUE OF VALIDITY OF PRENUPTIAL AGREEMENT 15 by placing said copy sealed in an envelope(s) addressed as follows: 16 Hab Siam 17 2921 South Winchester Blvd. Campbell, California 95008 18 with postage thereon fully prepaid, and thereafter was deposited in the United States Mail 19 at Oakland, California. That there is a delivery service by the United States Mail at the 20 place addressed. That the date of deposit in the mail was July 26, 2004. 21 Ideclare under penalty of perjury that the foregoing is true and correct. Executed July 26, 2004, at Oakland, California. 22 23 24 Carole Aubuchon 25 26 27 28 PAGE.@4 JUL 26 2@@4 11:57