Re: Nobia Joyce v. Shawn M. Millner, etc., et al. (KC067782)

MOTION FOR SUMMARY JUDGMENT

Moving Party: Plaintiff Nobia Joyce

Respondents: Defendants Shawn M. Millner and Laurence Todd

POS: Moving OK; Opposing filed timely, but the manner of service cannot be determined from the proof of service

This is an action filed by Plaintiff Nobia Joyce against her daughter Shawn M. Millner, individually and as trustee for the Shawn Marie Millner Revocable Trust, and her daughter’s boyfriend, Laurence Todd. Plaintiff alleges that she purchased the subject property with her daughter in March 21, 1996 and that she owns 50% of the subject property, but that defendants have been attempting to remove her from the subject property. The complaint, filed on July 17, 2015, asserts causes of action for:

1. Partition (CCP §§ 872.210, 872.230, 872.820)
2. Accounting
3. Conversion
4. Elder Abuse
5. Intentional Infliction of Emotional Distress
6. Negligent Infliction of Emotional Distress

On December 2