On August 30, 2018 a
Request,Application
was filed
involving a dispute between
Bernard Te Velde And Rebecca Dee Te Velde, Trustees Of The 2000 Te Velde Family Trust *,,
Holt Repair & Manufacturing, Inc.,
Mona Tovar, Individually And As Special Administrator Of The Estate Of Carlos Alexander Tovar, Deceased,
and
Bernard Dee Te Velde And Rebecca Dee Te Velde, Trustees Of The 2000 Te Velde Family Trust,
Holt Repairs & Manufacturing, Inc.,
for civil
in the District Court of San Joaquin County.
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Malcolm D. Schick, Esq. ~ State Bar No. 118978
Erica C. Gonzalez, Esq. - State Bar No. 289557
G&P|ScHICK, A Professional Corporation ROSA Sunes
99 Almaden Boulevard, Suite 740: . ® SUNQUEIRG
San Jose, California 95113-1605 .
a
Tel: (408) 995-5050; Fax: (408) 995-5150 SEP pa
Attorneys for Defendant, Cross-~ . ce | te
Defendant, and Cross-Complainant,
HOLT REPAIR & MANUFACTURING, INC.
SUPERIOR COURT OF THE.STATE OF CALIFORNIA
“FOR THE COUNTY OF SAN JOAQUIN
MONA TOVAR, Individually and
as Special Administrator of
the Estate. of Carlos Alexander
Tovar, Deceased, and IZAIAH
TOVAR and OLIVIA TOVAR,
Minors, by and through their
Guardian ad Litem, MONA TOVAR
Case No. STK-CV-UPI-2018-10826
Judge: Roger Ross
Dept.: 11B .
Complaint. filed:8/30/18
Trial: Not set yet
REQUEST FOR JUDICIAL NOTICE: IN
SUPPORT OF HOLT REPAIR &
MANUFACTURING, INC.’S MOTION
Plaintiffs,
v. FOR DETERMINATION OF GOOD FAITH
: SETTLEMENT .
BERNARD TE VELDE and REBECCA
DEE TE VELDE, Trustees of the ‘Date: May 30, 2019
2000 Te Veide Family Trust, Time: 9:00 a.m.
HOLT REPAIR & MANUFACTURING, Dept.: 11B
INC., and DOES .1 to 100,
inclusive ~ .
Defendants.
TO: ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
Defendant, HOLT REPAIR & MANUFACTURING, INC., hereby requests
that this Court take. judicial notice of the following pursuant to
the provisions of California Evidence Code Sections 451, 452, and
453: :
1. Grant Deed, Assessors Parcel No. 131-070-07, San Joaquin
County, for the real property commonly referred to as 3650 S. Holt
-1- .
DEC. GREG BI IN SUPFOR: = CTURING, INC.
FOR DETERMINATION OF GOOD FAITH SETTLEMENT
FILED BY FAXRoad, Stockton, CA 95206, attached as Exhibit A to the accompanying
Notice of Lodgment.
DATED: __May 21, 2019 G&P| SCHICK
By
akcolW/b. \Sféhipk, Esq.
Efica Ck Ggn fez, Esq:
A ys for Defendant, Cross-
Defendant, and Cross-Complainant,
HOLT REPAIR & MANUFACTURING, INC.
-2-+
“BECLARATION OF GREG BURGIN IN SUPPORT OF HOLT REPAIR & MANUFACTORING, INC.'S MOTION
FOR DETERMINATION OF GOOD FAITH SETTLEMENT
Document Filed Date
May 22, 2019
Case Filing Date
August 30, 2018
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am Ww 27 28 Malcolm D. Schick, Esq. ~ State Bar No. 118978 Erica C. Gonzalez, Esq. - State Bar No. 289557 G&P|ScHICK, A Professional Corporation ROSA Sunes 99 Almaden Boulevard, Suite 740: . ® SUNQUEIRG San Jose, California 95113-1605 . a Tel: (408) 995-5050; Fax: (408) 995-5150 SEP pa Attorneys for Defendant, Cross-~ . ce | te Defendant, and Cross-Complainant, HOLT REPAIR & MANUFACTURING, INC. SUPERIOR COURT OF THE.STATE OF CALIFORNIA “FOR THE COUNTY OF SAN JOAQUIN MONA TOVAR, Individually and as Special Administrator of the Estate. of Carlos Alexander Tovar, Deceased, and IZAIAH TOVAR and OLIVIA TOVAR, Minors, by and through their Guardian ad Litem, MONA TOVAR Case No. STK-CV-UPI-2018-10826 Judge: Roger Ross Dept.: 11B . Complaint. filed:8/30/18 Trial: Not set yet REQUEST FOR JUDICIAL NOTICE: IN SUPPORT OF HOLT REPAIR & MANUFACTURING, INC.’S MOTION Plaintiffs, v. FOR DETERMINATION OF GOOD FAITH : SETTLEMENT . BERNARD TE VELDE and REBECCA DEE TE VELDE, Trustees of the ‘Date: May 30, 2019 2000 Te Veide Family Trust, Time: 9:00 a.m. HOLT REPAIR & MANUFACTURING, Dept.: 11B INC., and DOES .1 to 100, inclusive ~ . Defendants. TO: ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: Defendant, HOLT REPAIR & MANUFACTURING, INC., hereby requests that this Court take. judicial notice of the following pursuant to the provisions of California Evidence Code Sections 451, 452, and 453: : 1. Grant Deed, Assessors Parcel No. 131-070-07, San Joaquin County, for the real property commonly referred to as 3650 S. Holt -1- . DEC. GREG BI IN SUPFOR: = CTURING, INC. FOR DETERMINATION OF GOOD FAITH SETTLEMENT FILED BY FAXRoad, Stockton, CA 95206, attached as Exhibit A to the accompanying Notice of Lodgment. DATED: __May 21, 2019 G&P| SCHICK By akcolW/b. \Sféhipk, Esq. Efica Ck Ggn fez, Esq: A ys for Defendant, Cross- Defendant, and Cross-Complainant, HOLT REPAIR & MANUFACTURING, INC. -2-+ “BECLARATION OF GREG BURGIN IN SUPPORT OF HOLT REPAIR & MANUFACTORING, INC.'S MOTION FOR DETERMINATION OF GOOD FAITH SETTLEMENT