On April 17, 2018 a
Motion-Secondary
was filed
involving a dispute between
Trujillo, Bryan,
Trujillo, Cindy,
and
Does 1-20,
Does 1-50,
Magee, Stephen,
Sac Aero Flying Club, Inc.,
for (23) Unlimited Other PI/PD/WD
in the District Court of San Mateo County.
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GARRY L. MONTANAREL, State Bar No. 89790 Electronically *
WESLEY S. WENIG, State Bar No. 162351
JOHN H. MOON, State Bar No. 253811
RECEIVED
MICHAELIS, MONTANARI & JOHNSON, P.C. 12/20/2019
4333 Park Terrace Dr, #110
Westlake Village, CA 91361 CLERK OF THE SUPERIOR COURT
‘SAN MATEO COUNTY
Telephone No.: (818) 865-0444
Attorneys for defendants, STEPHEN MAGEE and
SAC AERO FLYING CLUB, INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
10
11
BRYAN TRUJILLO and CINDY Case No.: 18CTV01901
TRUJILLO, Honorable Robert D. Foiles; Dept. 21
12 [PROPOSED] ORDER RE
Plaintiffs, DEFENDANTS STEPHEN MAGEE
13 AND SAC AERO FLYING CLUB,
VS. INC.’S NOTICE OF MOTION AND
14 MOTION FOR LEAVE TO AMEND
ITS ANSWER
15
STEPHEN MAGEE, SAC AERO FLYING
CLUB, INC. and DOES 1 - 50, Date: February 26, 2020
16 Time: 9:00 a.m.
Defendants. Dept.: Law and Motion
17
Complaint filed: April 17, 2018
18 Trial Date: February 10, 2020
19
[PROPOSED] ORDER
20
Having reviewed the defendants STEPHEN MAGEE’s and SAC AERO FLYING CLUB,
2
INC.’s (collectively “Defendants”) Notice of Motion and Motion for Leave to Amend its Answer
2
(“Motion for Leave”), and good cause appearing:
23
IT IS ORDERED THAT Defendants’ Motion for Leave is granted.
24
IT IS SO ORDERED.
25
26
DATE:
27 Judge of the Superior Court
28 N:\L7517\pld\p-mtn.amend.answer.ord.wpd
-1-
PROPOSED] ORDER RE DEFENDANTS STEPHEN MAGEE AND SAC AERO FLYING CLUB, INC.’S NOTICE
DF MOTION AND MOTION FOR LEAVE TO AMEND ITS ANSWER
PROOF OF SERVICE
STATE OF CALIFORNIA )
SS.
COUNTY OF LOS ANGELES )
Tam employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action; my business address is 4333 Park Terrace Dr. #110, Westlake
Village, California 91361.
On December 20, 2019, I served the foregoing document described as [PROPOSED]
ORDER RE DEFENDANTS STEPHEN MAGEE AND SAC AERO FLYING CLUB, INC.’S
NOTICE OF MOTION AND MOTION FOR LEAVE TO AMEND ITS ANSWER on the
interested parties in this action by placing a true copy thereof in a sealed envelope with postage
thereon fully prepaid in the United States mail at Westlake Village, California, addressed as follows:
Michael S. Danko, Esq. Attorneys for Plaintiffs
Danko Meredith
10 333 Twin Dolphin Dr. #145
Redwood Shores, CA 94065
11 tel: (650) 453-3600; fax: (650) 394-8672
Email: mdanko@dankolaw.com
12
[x] (MAIL) I deposited such envelope addressed in the mail at Westlake Village, California.
LZ The envelope was mailed with postage thereon fully prepaid. I am “readily familiar” with firm's
practice of collection and processing correspondence for mailing. It is deposited with U.S. postal
14 service on that same day in the ordinary course of business. I am aware that on motion of party
served, service is presumed invalid if postal cancellation date or postage meter date is more than 1
1s day after date of deposit for mailing in affidavit.
16 Ul (ELECTRONIC TRANSFER) | caused all of the pages of the above-entitled document to
be sent to the recipient noted below via electronic transfer (email) at the respective email address
7 indicated below.
18 U (BY ELECTRONIC TRANSFER) | caused all of the pages of the above-entitled document
to be sent to the recipients noted below via electronic transfer (FAX) at the respective telephone
9 numbers indicated below.
20 U (FEDERAL EXPRESS) I deposited such envelope addressed at the Federal Express office
located at Westlake Village, California. The envelope was mailed fully prepaid. I am “readily
57 familiar” with firm’s practice of collection and processing correspondence for mailing with Federal
21
Express. It is deposited with the Westlake Village Federal Express service on that same day in the
22 ordinary course of business. I am aware that on motion of party served, service is presumed invalid
if cancellation date is more than 1 day after date of deposit for overnight mailing in affidavit.
23
24 I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct.
25
26 Executed on December 20, 2019 at Westlake Village, California.
27 # I
& liZe—
Barba i 5 itectann CCLS
28
Document Filed Date
December 20, 2019
Case Filing Date
April 17, 2018
Category
(23) Unlimited Other PI/PD/WD
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GARRY L. MONTANAREL, State Bar No. 89790 Electronically * WESLEY S. WENIG, State Bar No. 162351 JOHN H. MOON, State Bar No. 253811 RECEIVED MICHAELIS, MONTANARI & JOHNSON, P.C. 12/20/2019 4333 Park Terrace Dr, #110 Westlake Village, CA 91361 CLERK OF THE SUPERIOR COURT ‘SAN MATEO COUNTY Telephone No.: (818) 865-0444 Attorneys for defendants, STEPHEN MAGEE and SAC AERO FLYING CLUB, INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO 10 11 BRYAN TRUJILLO and CINDY Case No.: 18CTV01901 TRUJILLO, Honorable Robert D. Foiles; Dept. 21 12 [PROPOSED] ORDER RE Plaintiffs, DEFENDANTS STEPHEN MAGEE 13 AND SAC AERO FLYING CLUB, VS. INC.’S NOTICE OF MOTION AND 14 MOTION FOR LEAVE TO AMEND ITS ANSWER 15 STEPHEN MAGEE, SAC AERO FLYING CLUB, INC. and DOES 1 - 50, Date: February 26, 2020 16 Time: 9:00 a.m. Defendants. Dept.: Law and Motion 17 Complaint filed: April 17, 2018 18 Trial Date: February 10, 2020 19 [PROPOSED] ORDER 20 Having reviewed the defendants STEPHEN MAGEE’s and SAC AERO FLYING CLUB, 2 INC.’s (collectively “Defendants”) Notice of Motion and Motion for Leave to Amend its Answer 2 (“Motion for Leave”), and good cause appearing: 23 IT IS ORDERED THAT Defendants’ Motion for Leave is granted. 24 IT IS SO ORDERED. 25 26 DATE: 27 Judge of the Superior Court 28 N:\L7517\pld\p-mtn.amend.answer.ord.wpd -1- PROPOSED] ORDER RE DEFENDANTS STEPHEN MAGEE AND SAC AERO FLYING CLUB, INC.’S NOTICE DF MOTION AND MOTION FOR LEAVE TO AMEND ITS ANSWER PROOF OF SERVICE STATE OF CALIFORNIA ) SS. COUNTY OF LOS ANGELES ) Tam employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is 4333 Park Terrace Dr. #110, Westlake Village, California 91361. On December 20, 2019, I served the foregoing document described as [PROPOSED] ORDER RE DEFENDANTS STEPHEN MAGEE AND SAC AERO FLYING CLUB, INC.’S NOTICE OF MOTION AND MOTION FOR LEAVE TO AMEND ITS ANSWER on the interested parties in this action by placing a true copy thereof in a sealed envelope with postage thereon fully prepaid in the United States mail at Westlake Village, California, addressed as follows: Michael S. Danko, Esq. Attorneys for Plaintiffs Danko Meredith 10 333 Twin Dolphin Dr. #145 Redwood Shores, CA 94065 11 tel: (650) 453-3600; fax: (650) 394-8672 Email: mdanko@dankolaw.com 12 [x] (MAIL) I deposited such envelope addressed in the mail at Westlake Village, California. LZ The envelope was mailed with postage thereon fully prepaid. I am “readily familiar” with firm's practice of collection and processing correspondence for mailing. It is deposited with U.S. postal 14 service on that same day in the ordinary course of business. I am aware that on motion of party served, service is presumed invalid if postal cancellation date or postage meter date is more than 1 1s day after date of deposit for mailing in affidavit. 16 Ul (ELECTRONIC TRANSFER) | caused all of the pages of the above-entitled document to be sent to the recipient noted below via electronic transfer (email) at the respective email address 7 indicated below. 18 U (BY ELECTRONIC TRANSFER) | caused all of the pages of the above-entitled document to be sent to the recipients noted below via electronic transfer (FAX) at the respective telephone 9 numbers indicated below. 20 U (FEDERAL EXPRESS) I deposited such envelope addressed at the Federal Express office located at Westlake Village, California. The envelope was mailed fully prepaid. I am “readily 57 familiar” with firm’s practice of collection and processing correspondence for mailing with Federal 21 Express. It is deposited with the Westlake Village Federal Express service on that same day in the 22 ordinary course of business. I am aware that on motion of party served, service is presumed invalid if cancellation date is more than 1 day after date of deposit for overnight mailing in affidavit. 23 24 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 25 26 Executed on December 20, 2019 at Westlake Village, California. 27 # I & liZe— Barba i 5 itectann CCLS 28