CASE NAME: Jill Hays v. Kalnel Gardens LLC

CASE NO.: 19SMCV00880

MOTION: Defendant’s Second Motion for Order Directing Payment of Taxes and Insurance Pursuant to California Civil Code § 2938(g)

HEARING DATE: 08/05/2021

Defendant/Cross-Complainant Kalnel Gardens LLC seeks an order directing Plaintiff/ Cross-Defendants Jill Hays, Wolfe Family Trust dated October 21, 1998 and Michael Ryan Wolfe (Collectively “Hays”) to pay for real property taxes and insurances from rents collected by them on 8655 Washington Boulevard, Culver City, California 90232 since Winter 2020 pursuant to California Civil Code §2938(g). Kalnel filed this motion on June 14, 2021. This is Kalnel’s second motion for such an order. The Court previously granted Kalnel’s initial motion on October 6, 2020 for taxes and insurance costs related to a prior tax year.

Kalnel seeks payment of $41,427.35, consisting of $38,566.35 in real property taxes and $2,861.00 in insurance premiums that were paid by Kalnel when the Cro