EXHIBITS To Compl Kamala Harris VOL I Exh1 To Exh11 Mailed 4-10-15.compressed

EXHIBIT LIST
Appendix Codes and Court Rules [1-2] CRC 10.603Authorities & Duties of Presiding Judge [3-5] Volume II
First 2-year Round of Relentless Harassment Enabled by Judges Who are Afraid to Rule Against Stubblefield
1. ARNOLD STUBBLIELD [R] - billionaire developer who has been bribing officials & judges for 40 years
Stubblefield billboard supporting criminal NEIL DERRY (takes bribes and launders $$$ through PACs)
Attorney General Indictment Affidavit on Neil Derryfor laundering Stubblefields bribes through PACs
Stubblefields son DALE convicted of criminal corrupt influence (like father, like son)
San Bernardino DA felony indictment of Bill Postmus (corrupt county tax assessor who laundered bribes)
2. Stubblefield contributed $2,500 to Bob Dutton campaign (tax assessor who replaced felon Bill Postmus)
Duffys 2/4/13 Letter to San Bernardino Board of Supervisors Demand to Audit Stubblefield Properties
(Stubblefield has bribed tax assessors for 40 years to assess his properties so he owes little or no taxes)
3. Tax Assessor Report shows Stubblefield owns about 2/3 of the homes in Mountain Shadows Community
4. The MSMHC Directory shows only 175 mobile homes are owned by private individuals (less than half)
5. Stubblefields use of the court to harass Duffy resulted in 85 hearings, 30 volumes, and 610 docket entries.
(shows 95% of the time judges rule in Stubblefields favor against Stare Decisis, codes and court rules)
6. Docket Entries shows he prosecuted two SHAM evictions against Bonnie Shipley and Nancy Duffy.
7. 85 Minute Orders Judges serve as Weapons of Mass Harassment to whip anyone who challenges him.
8. 10/13/12 Duffy implored Presiding Judge Marsha Slough to do her job; i.e. investigate judicial corruption
9. Shipley filed a writ to reverse denial of MSJ. Two honest judges (Brisco & Ochoa) granted her petition.
Shipley prevailed in Stubblefield v. Shipley UDDS1204130 thinking two years of living hell was over.
10. Over Duffys vehement objections Judge Sachs let loser Stubblefield compose Shipleys final judgment.
Sachs let Stubblefield paraphrase the Appellate Panels findings to carve a new remedy to evict Shipley
and every other park resident without cause. Sachs engaged in 9 serial violations of the law, codes, court
rules, and ethics by inserting or resident into Stubblefields quote of Civil 798.56[d]s in the judgment.
11. Shipley filed an OSC in re: contempt complaint in the Appellate Division, asking the Panel to order Sachs
to Show Cause why he should not be held in contempt for disobeying the Panels writ of mandate order.
The Panel had held Stubblefield could not proceed directly against Shipley because there was no privity of
contract as Stubblefield was not her landlord. The court mysteriously removed Ochoa & Brisco from Panel,
leaving only Judge Hosking on the new Panel--who dissented in the first Panels reversal of the trial court.
The newly appointed Appellate Panel from Rancho Cucamonga would rubber stamp Judge Sachs rulings.
The new Panel denied a stay a day after receiving our writ petition and denied a hearing on OSC petition.
12. Prevailing party Shipley was forced to appeal her victory to get or resident stricken from her judgment
13. Duffy filed a claim against City San Bernardino-not for $ damages but to fire a corrupt arson investigator
and his supervisor (Battalion Chief) for conspiring with Stubblefield to file a false arson report on our fire.
14. Stubblefield filed a second sham eviction against Duffy & Shipley which Judge Brodie assigned to Judge
Schneider---after he had voluntarily recused himself. We disqualified him and Brodie took over as Judge.
15. Brodie ruled against Stare Decisis, codes, court rules on every motion in favor of Stubblefield. Brodie
refused to reclassify the case to unlimited jurisdiction, despite damages sought exceeded $25,000.00.
16. Court accepted Stubblefields ex parte motions (24-hr notice) regularly without proofs of service attached
and heard motions without any notice to Duffy other than by an obscure email she may or may not receive.
17. Sachs back-dated a purported internal order the same day Stubblefield appeared ex parte to a week before.
Order shows Sachs signed it February 27, 2015 (date stamp appears distorted from turning date backwards)
Envelope shows postmark 3/4/15 (a week later) the same day as Stubblefield appeared without me there.
Sachs ignored CCP 916s auto-stay pending appealto expunge Shipleys lis pendens (ruling without
jurisdiction and against the law). He refused to hear Duffys attorney fee motion due to stay on appeal
He denied Shipleys request for order to compel Stubblefield to restore utilities to the home after a
mysterious fire burned out all the electric and gas lines feeding into the mobile home from the pedestal.
Sachs held he was without jurisdiction due to a stay on appeal --- yet, he suddenly had jurisdiction to
expunge Shipleys recorded lis pendens. Sachs had no jurisdiction for us but plenty of it for Stubblefield.
18. Shipleys valid motion for award of attorney fees under MRL to prevailing party was continued 8 times.
Sachs continues to thwart every attempt Shipley makes to get her motion on calendar and actually heard.
Shipley prevailed on 5/16/13; yet has been unable to get Judge Sachs to award her statutory attorney fees.
Shipleys motions to compel documents, interrogatory responses, motion for terminating sanctions for
failure to comply with ONE court order to answer ONE interrogatory (only motion we won in 6 months)
Stubblefield failed to obey the order because he knew in advance there would be no negative consequences.
Kyle Brodie transferred our case from Kyle Brodies Fontana UD court to Judge Sachs at Justice Center.
Kyle Brodie first continued our 3 motions, then took them under submission at the continued hearing,
then vacated all 3 motions when he transferred our case to Judge Sachs in S28. Judge Brodie did not
vacate 3 motions Stubblefield had set---Sachs added his 3 motions to his calendar on date set in Fontana.
Shipleys attorney fee motion and 3 MTCs were vacated not reset like Stubblefields 3 pending MTC.
This disparate treatment shows clear bias in favor of Stubblefield and against Shipley in all procedures.
The court intentionally burdens Shipley by vacating her motions and ordering her to refile and reserve
the vacated motions, increasing her labor and costs to reproduce lengthy motions a second and third time.
Our 3 voluminous discovery motions now have to be re-printed, re-served and re-filed at significant costs.
This significant burden was intentionally imposed upon Duffy to harass her and bury her with busy work.
The minute order transferring our case did not state that our case was reclassified to unlimited jurisdiction.
Stubblefield continues to serve multiple, simultaneous, burdensome motions (150 pages) on 5-day notice.
Judge Sachs continues to accept them and set hearings on 5-day notice. Pending are 4 sanction motions
(Duffy McCarron, Steve Allen, Chris Allen, Bonnie Shipley) seeking over $27,000 in total sanctions.
Despite a death in my immediate family and a daughter in the hospital, Sachs refused to extend extra time to
oppose the motions---imposing a cruel burden at a time when Sachs should let Duffy grieve a family death.
Sachs enabled Stubblefield to continue to pummel Duffy with thousands of sheets of paper on 5-day notice.
Sachs denied our valid motion to disqualify him under CCP 170.6 (2) where bias is presumed after a party
obtains a reversal of any part of a judgment on appeal. The current Panel ordered or resident stricken.
19. Letter to County Risk Management Officer amending prior claim against corrupt, bribed arson investigator,
to add Judge Sachs as facilitator in Stubblefields racketeering enterprise. We intend to file racketeering
charges against Stubblefield and participants in his racketeering enterprise in federal court in a few weeks.
Stubblefields racketeering enterprise continues to steal mobile homes from elderly residents to add to his
portfolio of rentals for profit, while avoiding paying any county taxes on that income by artificially low
assessments by officials he bribes within the assessors office. Tenants pay $1,000-$1,500 month in rent.
Stubblefield launders money via PACs to Tax Assessors and Judges to facilitate his racketeering enterprise.
20. Petition for Review to Sup Court [4th Dist. Ct of Appeals refusal to reclassify to unlimited jurisdiction.]
21. Writ Petition to 4th. Dist. & Appellate Division to reverse Judge Sachs denial of a CCP 170.6 (2) motion.
22. Shipleys Motion for Summary Judgment set for April 13, 2015 which should be granted to end this second
round of using county Judges as Weapons of Mass Harassment (imposing a high cost burden on taxpayers).
We expect Sachs to deny our motion as he will never rule against a big potential supporter in his reelection.
Judge Sachs refused to disqualify himself, when under a clear duty to do so, because he wants revenge now.
Shipley will be forced to file her 8th writ petition to reverse anticipated denial of summary judgment motion.
EXHIBIT 1
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KAMAI,AD.H A R R ~ S
Anvmey Gcnezal uf California
DANEQ~L-I.ETTE
Chief Assistant Attorney Creneral
GARYW.S~IONS
Senior Assistan1 Attorney C'rencral
JAMES D. DUTTQX
Supervising Deputy Attorney General
EMILYR. J ~ A N K S
Deputy Altcrmey General
Slate Bar Nu. 230442
1 10 West A Streor, Suite 1 100
Sar, Diego, GA 92i 0 1
P.O. Uox 85266
S m Diego, CA 92 f 86-5266
'Felcphonc: (619) 645-3 1 96
Fax: (619) 645-2191
E-mail : Emily .Nanks@doj,ca.gov
A i r or~ley~jitr
the 1'eopLr
SUPERlOR COlJRT OF"'fHE STATE QF ClALIFOKtdlA

COUNTY OF SAN REKNARDINO
I4
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PEOPLE OF THE ST-4TE OF CALIFORNIA,
Case Na
Ylaint;f*f, DECLARATIOIL' IN S-EPPORT OF
COMPLAINT
I8
NETLAND KENNETH DERRV,
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Defendant.
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TilE UNDBRSlGNED HERWY IIECLARFS. UPON RJFORhlATlON AND BEI.lEF:
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't
Rure;lu of lnvcstigsttion and tntelligence. Office of the Attorney Generalal,I have been employed
I
t
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That I, Shmnon Wl!iiams, am a Special Agent with the Gafilbmia Dcpaament of Justice,
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as a fcace OfficerlAgent within thic Srnte of California within thc mcaning of l'cnal Code section
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870.1(3)(b)16] ia excess of fifteen yyerus, currently assigncd to the Aai'rncy General's Special
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Emlestigotions Tcarn. Prior ". my appointment as a Special Agent. f was employed as a Peace
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Officer wit11 tile Sen Diegtl Sheriffs Drpartmcut for apprt~ximatelyseven years, where I
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a .
"
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I>l;clutnrrn~i$11Eirtppert
nl C omphlnk
I
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1
1
participated in numerous crlrn~nalinvestrgations I hold
kin
advanced ccmficate issued by the
Commission on Peace Oliicer's Standards and Truining as well as a Bachcior oSAns degree in
/
i
Sociology lrom Sari Uiego Stale University. Additionally, I have attended clrrsses rekiting to!
criminal investigations tat~ghlby cxpericnced investiptions and proseculing attorneys. Which r

include, but. arc not limited lo:
Advanced officer training in oncer-involvcd shootings,
inlervicw and inccrrogation, and finanziol crimes investiga~ions. I am familiar with California
wdos related tu financial crimes, conspirncy. and the rules oSevidcn:nce,
That a 3-count felony complaint charging Neiland nerry with Perjury, in violation ~i
Section It 8 of he Penal Code, a felony; Filling a False Document, in violation o r Scctivn 115 o i
the Penal Code, a felony; and Failure lo Report Contribution. in violation of Section 84302 of the
Government Codc, a misdemeanor, has been issued and is filcd here within San Bcmdrdino
County with the Clerk oi'tlle Court.
During !he course of my duties, 1 have read the official files wd repons of the
Sm
Bemardino District Anorney's Office, Bureau of Investigation, concerning the condoc1 described
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below, w h ~ c hcontenls J believe to be true, and documenw seized during the course of the
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invstiga~ion.
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UETAILS OF THE INVESTIGATIUN
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Neiland I>crry is the elected 3rd District Supervisor for tht: County of Snn Uernardino.
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Arnold "A.ll," Siubblclield is a Sar~Bernardino properly owner and dcveloper. Stubblcfield hw
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told investigators that on May 31. 2007. he wrorc a check on a business acwunl of Highland
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Town 5%ops Tor $5,000 payablc lo the Inland Eniyirc Political Action Commiltcc ("I'AC"), a
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PAC controllcd by then C o m ~ yilssessor and Sormcr chalnnan of lhe Bolrrd of Supervlson,
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William Postmus. Stubblcficld intendcd to make a eontribu~ion10 the supcrvisor~alcampaign
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fund of Dcrr) and understood that is whcrc the funds from Lhc $5,000 check would go.
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Stuhblefield docs not rcrnemkr who told him to make thc check payablc lo thc Inland Ernpire
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PAC and he had no knowledge of the lnland h p r e PAC
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remembers eithrr rna~l~np

or handing the check lo i)rrry
;
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clr
who controllcd it. Stubblcfi~ld
l l c ~ s ytold invesligalors tho1 he con~wtedStubbIclield during thc campaign seeking a
contribution. !Jerry related that Suibbicfield told him that Sol. '.political rensc>ns7'he did nol Wdnl
.1
to
donate
tbc Inl'wd Empirc PAC was "probably'" goillf to suppori his car;lpirign, Dcrry did not mmember I
how he rcccivccl tho Stubblclteld chcck. Hnwc.\fcr,1)errq udmlltcd hc garc iht: check l o Pustrnub,
who he knew cnntlpllccl the lnland bmpirv PAC
conlributiorrs [iom tbr inland Empire PAC. Den) irdmilt~dthat it wt~e"undarstood" that lthe
she* up on campaign rcporra as supponing Uerry! anii askod if thcrc wus o PAC he could
lo
(which was supprtiiig l>crry). Derry said ha old S~nbblcfieldit was his culderstmdinp
Drrry admined his canlpargn llacr received
In June. 2007, 1)erry wss a1 a lunch meeling ut a San Hernardinn Coco'e restnumnl, wilh
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Stuhblcfield I'unds were l o suppofl his campaign
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Jim Erwin, Mikc Richman, Uill f'astmus, and Postmus' associalcs Oina D e h d o ilnd Adam
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.Alcman. Richman. Alcmitn and Posmus have mld investigators thut a)that occasion 1)crry gave
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Ponrnus a numbcr of checks made oul t ihc Inland Ernpil.r PAC, including the Srubblcficld-
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llighland Town Shop check for $5.000. I'ostrnus indicuied he brlievcd l>erry provided checks
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totaling $10.000. Postmus did no1 recell the n m e s of the donors for h e additional $5.000.
i
i
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Postmus told invcstlg:~lurs fhili at the bchcsr of Jim Erwin, who was working on Derry's
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carnpaip, he aprecd with Erwin and Derry to '.launder" $5.000-$10,000 of conlributiont: intended
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Sor llerry's campaign lhrough thc Inland Empire PAC. Posln~usunderstood lhal Deny did 11o1
19
want to receive (and hc required to r ~ p o nthcuc

)
conlrihutions dircctiy
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Poslmus agrccd with Derry lo accrpl the crrntrlbuuons imo the lnldnd Lmpirc PAC und then
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pay nu1 that amount
LO
his campaign, and so
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Deny's campaign.
Polilical Ilcfor~nha ('.I'R,4")
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rcpurts and bank records of thc Inland Empire PA(' reflect
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inat on Junc 25, 2007: Ihc I'AC deposilcd [nlo its account the May 2 1: 2007, 55.000 Sfubblelirld-
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llighla~ldl'own Shops chcck. E-mails reflect ha^ Poslmus dircolcd lhc Jnland Empire PAC
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treasurer lo draft a chuck ir! thc a~nounitrS$10,000 lo Dcrry's campaign on June 28,2007. Hank
Ih
records arid llrc Inl;und Empire PAC' PR.4 reporLs rcllccl ihak thc PAC issurd a chcck (PI01 I) in j
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thal amount tu 1)crry.s carnpiign on June 29. 2007 Bank records re!lcct that the c h ~ k(*I01 I j
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n a s dep(1sitec1il~tcrthe Dcrr) campaign accnunl on July 11; 20U7.
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I ) v r ~ a r 1 1 1)!I~ ~S1u~p ~ ~ i ro?
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On July 25, 2007, Deny signed o Recipient Committee Campaign Statemenl (Gov. Code, i
i
45 84200-84216.5)
pcrjury.
Voters. The repon roflccted thal the campaign received $10,000 from the Inland Empire PAC on
June 30, 2007. Thc repod foiled lo reflect that Lhe campaign received any amounl from
Stubblefield-HighlandTown Shops.
Oti
Fair Polllical Practices Commission ("FPPC") F o m 460 under pcnaltp o f "
July 31, 2007, the mpon was filed with the San Bcrnard'i Counly Registrar of
1 declare under penalty of perjury tha? the ttoregoing is me and oorrect to the h s l of my
knowledge. Exccuted in the.County of San Uiego, California, on this 25th day of April, 201 I .
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SmOI 1800338
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4-a
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l>rclmlton in Suppun ol COlIIp
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N Nu: JUdB.d w k a D m y P m b a l i ~dm-
[ 0ms)(ing N w a ( PE.uun- Pres....
SAN BERNARDINO
COUNTY: Judge denies
Deny probation changes
BY IMRAN GHORl
STAFF WRITER
Published: 13 August 2012 06:22
PM
San Bernardino
CountySupeMsor
A ,d*mB
..-.
NeU Dertysoughtb modify his plobation

conditions from hb guilty plea last year In a
campaignflnance violation case, but a judge
rejected the request according to cow
records.
Attorney Rajan Maline appemd on behalf of

Deny before Superlor Court Judge Rlchard
Peel to seek the changes on Aug. 3.
Court records state W i and StepMnle
Chow, a state deputy attorney general,
wnfsned wi!h the judge off the record.
When they went backon the record, Pee[
nded that Derrywuld continue probationon
the same t e n s and cond'nions.
Deny, when reached by phone Monday, Aug.
13, declined tn comment on hi6 request
except to say it wer 'penonal."
A spokesperson for the attorney generak
office sald h y were looldng into the case
but dM not have details as of Monday
evenlng.
State prosecutors accused Derry of
atlernpting to launder a campaign mnbibution
a~..~12aeI~-banardba0Wdgbd0der-daYPmbaIOn~aW~.~~
WNWNURWNO COUUN: J*
denbs Denypmbeson Fhengea I Bnrsldng News IPE.corn- Pm...
and charged hlm with twP felonies and a

misdemeanor in Apdl2011.
Dewy agreed to a plea deal in July 2011,
where he admitled to a slrgle misdemeanor
&age of faitimg to reporl a campaign
conhibution.
t!.e as s e n t e n d to three years pmbation.

under which he is requlredto obey ail laws or
face a 3Dday )all sentaw that was
suspended.
Derry also was fhred about $10,000.
The charges stemmed from e $5,000

campaign contribution in May 2007 fmm San
Bernardinodeeloper Amold Stubblefield.
Prosecutors say Stubblefield approached
Deny about conklbutlng to his campaign but
dld not want to do so directly. Deny referred
Mm to a political&doncomrnmee that then
made a contributlonto Deny, according to
the indictment
The comiction has become an issue in
Derry's re-alection cempelgn. In campafgn
malers, challenger James Rarnos, former
chainman of the San Manuel tibe, has
accused Deny of bdng part of a dhne of
conuption at Re county.
Deny has said the charges against hlm were
politlcalty motivated and said he took the plea
deal to m i d a dmbmout ttial.
In June. Ramos took 47 percent end Deny
got 33 percent of the vote. A third candidate
won 20 percent A majority is requlred to win,
pmrnpting the need for the November runoff
election.
-....
V-ur.
~
LocalNem
Riwrside Counly
vvvom
.
reease for Mansprger, Stubblefeld IBreaking News I PE.com PressEnterprise
Wnor'rauia
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n:?..a~i.r
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Jacinta > Hemet-San Lac~ntoHeadlines
SAN JACINTO: Work

release for Mansperger,
Stubblefield
UevMorc Jobs
Hemet-San Jacinto
Headlines
bJ
SRN JACINTO. Cwncil to consider

smoke shop rna~ato"un
SAN JACINTO: Palr anested ater
high speed chase
MOUNTAIN CENTER Paddling iw
cancer camp donatimr
REDLANDS: ldyilwrld lesli@I chdr
permm~slhii weekend
Today's
Poll
.Watk thj:?
o enough bowg Jnne La p m n l

7eop e from be np hat oy Ira ns in
Featured Business
I Mardon Jewelers
(I
mD
In
trt tho MiRsl0~
InIan2 Southsm Cal#hma7
BY RiCnNiD K. De AnEY
rderUa~e.com
~~ulhed~~8~~mb~r2011011:23AM
maneykmde*g roles
in the San Jacimo
carmptim case.
John R M a m w w
and Jmmie Ode
mbMefield ~ rwere
.
No. Regardless d cost. wz need

to make c d a i n that pedestrians
and motorists cannot e e r into
the patho dtrains.
Yes. Mlinons d d d l a n haw

h e w , spent to bdsterdiw8l tradlc
and warn motmsts and
pedestrians.
0 Pemaps. sure, we can spend
STWF WRITER
dais d ~ k
wak nloDso k their
mare and boy more salety.

H-r,
the only s u d r e
solution is l o stay away horn the
track..
~ ~ l ~ r &
Photos
WBrUNKJohn henspergerand Jimmie
Dale SlubbWela Jr.PIead GuiW

W B U N K B p n JenyEIHron and Scan
Sheull Read W i l y
W E B u ~ ~ s pSsdon:
~ d ~ l Sen Jadnlo
senlenced along MW
Cormpdan Pmbe
businessmen Bymn
Jew EIIISM Sr. and
swu Shaul, ~ d n only
g ND ol We nine de(pnlanls stlll (Bcino
AGUANGA: T W
days offighting the
B ~ c kFnre
Mardon J e w e l e r s
951-682-2325
ihrerrae " e m Rgm
.-
*AN
JAL;INTO: WO* release fw Mansperger, Shlbblef~ldI Breaking News I PE.com P - ~ n t e r p " ~ ~
chargep in the ease.
MENIFEE: S ~ d d e n
downdraff snappsd
power lines
Former ccuncil m*
Amss Potls and demoper Paben
O s b w faceid4 Ja. 17. They rejected pleahrgdn offks.
We-
in the San JBcinto m m o t i w
Your Photos
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me,e
Meanuhle, jail a d vxlR m o d s Friday shrur James Ayrss, m e

ofthe 6rst defenaantr sentenced in the case.war released Nov.
He ha4 receibd a oneyea sentence Aug. 12. A y w urar ordered

to mpmllo county pmbab'onoRcm by Wednesday to sign up for
house arrest m me remaindr Dl his senletwe.
me case ~ I o h kind Ncwnbw2WB uhen e 155enunt

indlctmsnt us.iled. Fcurdthose chmged mve San JadnloCity
Council members at Uw the.
npm
The indictment a l l 4 a ysan-lma

-&heme between
d R e l o m and elected dcials In the cily m d Included charges
cdbrfbery and campaign mmsy laundering that enended fm
city council erections andwtes toa2W6 state Assembly race.
De$ndanb, pmsecutom said, bypassed C a l i l a campaign

erection I-. On the Assembly m e , they somdbuted past their
maxlmum dl~wsbledonations by bmneling money to a web of
polllid allies, Mathes and business associates, vho -Id
lhen
contribute In &her thelr name a the name ofa business.
h local elections, Mere lhera mem no donetion IlmBs.
d d b u l o m usedthid partis to hide the !me some dthe Unds
and m i d the appearance dunaue inluence.
Elibery took place when Sheuli bougld Ayme' hcuse fw tens of

Uausanh dddlan .stem mkfl d u e , and others PsM for
; t M C A
............
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uI r r l ~
SAN JACINTO: YHork rdeare far Manspeger, Slubbbfield 1 BrealdngNew. j PEcom P-Erderprise
~mpcmamerctson A y R s l M n h a s .
b s t i g e b sald d & a p Stephen Holgate &as Ihe source d

-h
dthousendP ddoAers in inlclt money I t m Rrund b way
hlo pdlclars'hands. Wgab hst pleaded guilty to hi6 d e and
b raMrhg a Bmcmthjail sdeme.
MempergermmeledthausenQ dddlero in illegal campeipn
ConMbutlm 10 -S
drelothsk Thy felsety chimed the
moneyceanehnthmon6liedtoegrand)ury ~ t h e l r m l e i n
me m m y leundering schema
S k dtnoss WIO f e c mthe mamy wrm Cheged in e m
e
a
e
,
end &I h ~ l sins
pleadedgdky lu misdemeanorsand
hew been sentmeed

Amthose sl* dekndem rsMmnqmqgds wi& Shende
Lynn; Mweprvger'r ddnr and tmhusbmd; 8nd Menepergar's
ncphrm.
Deputy Dkttict Atwnsy Ahb'i Marsh sald Fdday t b t Job
M a n ~ r g e r ~ m y e d h o t j u a t but
h ahlr
~ ownsmrlyand
empluyem he w
g
M Into this tangled wreh"
Menspcger, who nsle e f e m i I y U n a a 6 tow s&e and

myding yard In San JecInto, oeld ihrngh Ms ettomy hs Wwld
nmerageln seek W c oaka
h i d e Cumly Superlw b u d Judge Michele M e a d
ware'not just mLFgulded lvlt cdmlnel."
Mmp~qefs
The Judgeeald she b e E d Msnsperger hed taken UI
respomibirQ.
Manspergetend 6tuWdWd &a were A t m i $2,000each and

placed an thm yews' probatlm. lheY M
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FAB
MICHAEL A. RAMOS
District Attorney
R. LEWIS COPE
Deputy District Attorney
State Bar No. 97495
JOHN GORITZ
Deputy District Attorney
State Bar No. 207223
303 West Third Street
San Bernardino, CA 92415
Telephone: (909) 382-7609
Fax: (909) 382-7677
E-mail: rcope@sbcda.orq
EDMUND G. BROWN JR.
Attorney General of California
DANE R. GILLEUE
Chief Assistant Attorney General
GARY W. SCHONS
Senior Assistant Attorney General
JAMES D. DUlTON
Supervising Deputy Attorney General
MELISSA MANDEL
Deputy Attorney General
State Bar No. 159141
110 West A Street, Suite 1100
San Diego, CA 92101
Telephone: (619) 645-2211
Fax: (619) 645-2191
E-mail: melissa.mandelAdoi.ca.aov
Attorneys for Plaintiff
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO

SAN BERNARDINO DISTRICT
THE PEOPLE OF THE STATE OF CAI-IFORNIA, ) COURT CASE NO

)
Plaintiff
VS.
)
) FELONY COMPLAINT
William John Postmus, and

James Howard Erwin.
1
Defendants
The undersigned is informed and believes that:

1
COUNT 1 (Penal Code 5182(a)(ll

CONSPIRACY TO COMMIT A CRIME
I. INTRODUCTION
At all times relevant to this complaint:
Defendant WILLIAM JOHN POSTMUS (Postmus) was a member of the Board of
Supervisors of San Bernardino County, having first been sworn into office in 2000.
Postmus was made Chairman of the Board of Supervisors on January 5,2005, and
served until taking office as Assessor of San Bernardino County in January of 2007
after his election in November of 2006. He resigned from his position as Assessor on
February 6,2009.
Defendant JAMES HOWARD ERWIN (Erwin) was the President of the Sheriffs
Employees Benefit Association (SEBA) from 1997 until February of 2005 and became
Chief of Administration of SEBA beginning in April, 2005. In 2006 Erwin was an agent
In January of 2007, Erwin was appointed Assistant Assessor of San
for John Doe #I.
Bernardino County, resigning in November of 2007. In 2008, Erwin joined the
supervisorial campaign of Neil Derry. In September of 2008, Supervisor-Elect Derry
named Erwin as his Chief of Staff. He was formally made Chief of Staff in December of
2008.
was a General Partner of Colonies Partners, L.P.
John Doe #I
John Doe #2 was a General Partner of Colonies Partners, L.P.
John Doe #3 was a media consultant for John Doe #1 and John Doe #2.
John Doe #4 was Chief of Staff for a member of the Board of Supervisors of San
Bernardino County.
John Doe #5 was a member of the Board of Supervisors of San Bernardino
County.
Gary Ovitt (Ovitt) was a member of the Board of Supervisors of the County of
San Bernardino, having been sworn in to Office on December 7, 2004.
Matt Brown (Brown) was Chief of Staff for a member of the Board of Supervisors
of San Bernardino County.
Adam Aleman (Aleman) was a Special Assistant to Postmus from 2004 to 2006.
From 2005 to 2006 he was also the Executive Director of the San Bernardino County
Republican Party. In early 2007 Postmus appointed Aleman to the position of Assistant
Assessor. Aleman resigned as Assistant Assessor on July 8, 2008.
Mike Richman (Richman) was a political consultant and San Bernardino County
Republican Party official.
Dino DeFazio (DeFazio) was a real estate developer and officer of Tri-Land, Inc.,
a real estate investment company, which he co-owned with Postmus.
Colonies Partners, L.P. (Colonies), was a limited partnership organized under the
laws of the State of California.
San Bernardino County (County) was a local government jurisdiction formed
under the laws of the State of California.
II. CHARGES
Between on or about January I , 2005, and September 15,2008, WILLIAM JOHN
POSTMUS; JAMES HOWARD ERWIN; John Doe # I , not charged herein; John Doe #2,
not charged herein; John Doe #3, not charged herein; John Doe #4, not charged herein;
and John Doe #5, not charged herein; did unlawfully conspire together and with another
person, and persons whose identity is known and unknown, to commit the crimes of
Corrupt Influencing (Penal Code Section 85), Accepting a Bribe (Penal Code Section
86), Offering a Bribe to a Supervisor (Penal Code Section 165), Supervisor Accepting a
Bribe (Penal Code Section 165), Misappropriation of Public Funds (Penal Code 424),
Extortion (Penal Code Section 518), Conflict of Interest (Government Code Section
1090), Obtaining Money to Improperly Influence a Legislator (Government Code 9054),
and Willfully Omitting to Perform a Duty (Government Code Section 1222) in violation of
Penal Code Section 182 (a)(l ), a felony.
Ill. OBJECTS OF THE CONSPIRACY
The object of the conspiracy was to illegally obtain $102,000,000 from the
County, for personal gain, and for certain public officials to share in those gains by
forsaking their solemn duties and responsibilities to the County and the citizens they
served, in violation of their oaths of office and the laws of the State of California.
IV. MEANS BY WHICH THE 0B.IECTS OF THE CONSPIRACY WERE TO BE
ACCOMPLISHED
In 1997 Colonies bought a 434-acre parcel of land in Upland for $16 million from
the San Antonio Water Company's liquidation trust for the purpose of residential and
commercial development. The parcel contained a 67-acre flood control basin over
which the County asserted it had easement rights. As the development project
proceeded, Colonies asserted they spent $23.5 million on flood control improvements to
maximize the amount of land they could develop for commercial and residential sales.
Colonies requested that the County cover the costs it spent for flood control. The
County declined to pay the entire amount that Colonies spent on flood control, claiming
that the 67-acre basin itself was sufficient for flood control without improvements.
In March 2002 Colonies sued the County, challenging the County's easements to
the basin and claiming that it had been deprived of the ability to develop the 67-acre
flood control basin. The litigation proceeded with various rulings as to the validity and
size of the easements. The California Court of Appeal ruled in favor of the County in
July of 2005 determining that a 1933 easement to 30 of the acres was clear. They also
acknowledged a 1939 easement, in favor of the County, but found there were factual
issues still to be determined as to applicability and extent.
At an unknown time after the lawsuit was filed, John Doe # I and John Doe #2
concocted a scheme to obtain a monetary settlement from the County through corrupt
means. On or between January I , 2005, and November 29,2006, John Doe # I and
John Doe #2 attempted to corruptly influence members of the Board of Supervisors
through a combination of threats, extortion, inducements, and bribery in order to secure
their vote in favor of a settlement.
Defendant ERWIN and John Doe #3 joined the conspiracy and both conveyed
various threats andlor inducements from John Doe # I and John Doe #2 to Defendant
POSTMUS, John Doe #4 and John Doe #5. John Doe #4 agreed to accept a bribe to
deliver the vote of Ovitt. Defendant POSTMUS and John Doe #5 joined the conspiracy
by agreeing to accept a bribe to vote to approve the Colonies settlement.
On November 28,2006,Defendant POSTMUS and John Doe #5, along with
Ovitt, voted, as members of the Board of Supervisors, to approve a $102 million
settlement with Colonies to be paid by the County. No member of the County Counsel's
staff, nor any private attorney retained by the County, endorsed the settlement amount.
Defendant POSTMUS and John Doe #5 voted knowing that they had a financial interest
in the outcome.
After Colonies received substantial sums of money from the settlement with the
County, John Doe #I and John Doe #2 distributed from Colonies the agreed upon
bribes and payments to Defendant POSTMUS, Defendant ERWIN, John Doe #4, and
John Doe #5.
Defendant POSTMUS engaged the assistance of Aleman, Richman, and
DeFazio to create two Political Action Committees (PACs) that he secretly controlled for
the express purpose of concealing the receipt of the bribe of $100,000from Colonies.
Defendant ERWIN created a PAC to accept $100,000from Colonies for his part
in committing Extortion and Bribery.
John Doe #4 created a PAC into which he accepted a bribe of $100,000from
Colonies for delivering the vote of Ovitt.
John Doe #5 already had a PAC that he secretly controlled into which he
accepted a $1 00,000bribe from Colonies.
Defendant POSTMUS, Defendant ERWIN, John Doe #4, and John Doe #5,
through different means, distributed varying amounts of the monies, received from
Colonies into the PACs each controlled, directly to themselves.
V. OVERT ACTS
In the County of San Bernardino, State of California, pursuant to the above
conspiracy and in furtherance of the objects thereof, the following overt acts were
committed:
OVERT ACT 1
On or between September 8,2005, and September 20,2005, John Doe # I

attended a Discovery Tour and Trade Mission to China with Defendant POSTMUS and
provided meals, entertainment, and the services of a prostitute to Defendant POSTMUS
and promised to take care of Defendant POSTMUS for the rest of his political career if
he would support a settlement of the Colonies lawsuit.
OVERT ACT 2
On or about September 20, 2005, upon return from the Mission, Defendant
POSTMUS immediately went to County Administrative Officer Mark Uffer and stated,
"We've got to settle this Colonies thing."
OVERT ACT 3
On or between January I , 2005, and November 28,2006, John Doe #I
offered
to give John Doe #4 $100,000 if John Doe #4 would obtain Ovitt's vote for a settlement
amount dictated by John Doe # I in the Colonies lawsuit against the County.
OVERT ACT 4
On or between January I , 2005, and November 28,2006, John Doe # I offered
to give $100,000 to Defendant ERWIN if Defendant ERWIN would assist him in
obtaining a settlement amount dictated by John Doe # I in the Colonies lawsuit against
the County.
OVERT ACT 5
In 2006 County voters were presented with Measure P whose passage would
raise the salaries of Board of Supervisors members from $99,000 to $152,000. John
Doe #I and John Doe #2 conducted a campaign against Measure P as a means to
obtain influence over John Doe #5 in order to obtain a settlement in the Colonies lawsuit
against the County.
OVERT ACT 6
On or between January I , 2006, and November 28,2006, John Doe # I hired
private investigators to go through Defendant POSTMUS' trash to find incriminating
information that could be used to pressure Defendant POSTMUS to vote in favor of a
settlement in the Colonies lawsuit against the County.
6
OVERT ACT 7
On or between January I,
2006, and November 7,2006, at the request of John
Doe #1, Defendant ERWIN created political mailers for the Assessor's race depicting
Defendant POSTMUS' addiction to drugs and his homosexuality to be used to influence
Defendant POSTMUS to vote in favor of a settlement in the Colonies lawsuit against the
County.
OVERT ACT 8
On or between January I,2006, and November 7,2006, Defendant ERWIN
advised Aleman that if there were a settlement of the lawsuit that John Doe #1 found
favorable, the mailers depicting Defendant POSTMUS' addiction to drugs and his
homosexuality would not go out.
OVERT ACT 9
On or between January 1, 2006, and November 7, 2006, Defendant ERWIN
created political mailers in opposition to Measure P that asserted that John Doe #5 had
excessive indebtedness and was unable to pay his bills. The mailers were to be used
to influence John Doe #5 to vote in favor of a settlement in the Colonies lawsuit against
County.
OVERT ACT 10
On or between January 1,2006, and November 28,2006, John Doe #1
communicated to John Doe #5 that John Doe #5 would receive $100,000 if John
Doe #5 voted for a settlement in the Colonies lawsuit against the County.
OVERT ACT 11
On or between January 1,2006, and November I , 2006, John Doe # I advised
Defendant POSTMUS that if there were a favorable settlement of the Colonies lawsuit,
as dictated by John Doe # 1, that John Doe # I would give Defendant POSTMUS
$100,000.
OVERT ACT 12
On or between October I , 2006, and November 28,2006, Defendant POSTMUS
and John Doe #I
engaged in negotiations concerning the settlement amount for the
Colonies lawsuit at the Doubletree Hotel in Ontario with Defendant ERWIN and John
Doe #3 acting as intermediaries.
OVERT ACT 13
On or between October I , 2006, and Novernber 28, 2006, during the negotiations
concerning the settlement amount for the Colonies lawsuit at the Doubletree Hotel,
Defendant ERWIN conveyed to Defendant POSTMUS various threats from John
Doe # I to Defendant POSTMUS' that would be carried out if the terms dictated by John
Doe # I for the settlement of the Colonies lawsuit were not accepted.
OVERT ACT 14
On or between October I,2006, and November 28,2006, Defendant POSTMUS
agreed to vote to approve a $102 million settlement of the Colonies lawsuit as dictated
by John Doe #I
in exchange for $100,000 to be given to Defendant POSTMUS.
OVERT ACT 15
On or between December 7,2004, and November 28,2006, John Doe #4 agreed
to obtain Ovitt's vote for a settlement of the Colonies lawsuit as dictated by John Doe # I
in exchange for $100,000 to be given to John Doe #4.
OVERT ACT 16
On or between October I , 2006, and November 28,2006, John Doe #5 agreed
to vote to approve the $102 million settlement of the Colonies lawsuit as dictated by
John Doe # I in exchange for $100,000 to be given to John Doe #5.
OVERT ACT 17
On or between October 1,2006, and November 28,2006, John Doe #4
successfully urged Ovitt to vote to approve the $102 million settlement of the Colonies
lawsuit without the concurrence and against the recommendations of County staff,
County Counsel, and private attorneys retained by the County.
OVERT ACT 18
On or about November 28, 2006, John Doe #5 voted to approve a $102 million
settlement of the Colonies lawsuit without the concurrence and against the
recommendations of County staff, County Counsel, and private attorneys retained by
the County.
OVERT ACT 19
On or about November 28, 2006, Defendant POSTMUS voted to approve a $102
million settlement of the Colonies lawsuit without the concurrence and against the
recommendations of County staff, County Counsel, and private attorneys retained by
the County.
OVERT ACT 20
On or about November 28, 2006, pursuant to the settlement agreement,
Defendant POSTIVIUS directed that the Auditor-Controller-Recorder, Larry Walker,
transfer $22 million by November 29, 2006, from the San Bernardino County Flood
Control District to Colonies as the initial payment toward the settlement.
OVERT ACT 21
On or between January 29, 2007, and January 31, 2007, John Doe # I hosted
Defendant ERWIN and John Doe #3 on a private jet trip to New York and Washington,
D.C., where he provided meals, refreshments, lodging, watches, entertainment,
spending money, and prostitutes as gifts for their assistance in obtaining the Colonies
settlement from the County.
OVERT ACT 22
On or between October I , 2006, and February 14, 2007, Defendant POSTMUS
told Aleman that he was going to receive $100,000 from John Doe # I for voting to
approve the Colonies settlement. Defendant POSTMUS requested AlemanJs
assistance in creating a PAC that Defendant POSTMUS would secretly control to
conceal the $100,000 he received from John Doe # I .
OVERT ACT 23
On or between October I , 2006, and February 14,2007, Defendant POSTMUS
advised Richman that he was going to be receiving a sum of money and asked
Richman's assistance in creating a PAC using the names of his friends but that
Defendant POSTMUS would secretly control.
OVERT ACT 24
On or about February 14, 2007, Defendant POSTMUS, Aleman, and Richman
agreed to the creation of the Inland Empire PAC secretly controlled by Defendant
POSTMUS but publicly listing Dino DeFazio as Chairman, Mike Gallagher-Vice-Chair,
Jeff Bentow-Community Outreach Director, and Mike Richman as Executive Director.
OVERT ACT 25
On or about February 20, 2007, Defendant POSTMUS directed that Aleman
create an e-mail account using DeFazio's name and asked Aleman to use the e-mail
account to direct the creation of the Inland Empire PAC with DeFazio as the named
Chairman and to further direct expenditures through the e-mail account as if Aleman
were DeFazio.
OVERT ACT 26
On or between June I , 2007, to July 12, 2007, Defendant POSTMUS, Aleman,
and Richman agreed to the creation of the "Conservatives for a Republican Majority"
PAC secretly controlled by Defendant POSTMUS but naming "Mike Richman" as the
sole member of the Board of Directors and Executive Director.
OVERT ACT 27
On or about June 29,2007, John Doe # I signed check #4615 for $50,000 from
Colonies to the Inland Empire PAC secretly controlled by Defendant POSTMUS.
OVERT ACT 28
On or about June 29,2007, John Doe # I signed check # 4616 for $50,000 from
Colonies to the "Republicans for a Conservative Majority" PAC.
OVERT ACT 29
On or about July 5,2007, Defendant POSTMUS arranged that check #4615 for
$50,000 be deposited into the lnland Empire PAC secretly controlled by Defendant
POSTMUS.
OVERT ACT 30
On or about July 12,2007, Defendant POSTMUS arranged the deposit of check
#4616 for $50,000 from Colonies to "Republicans for a Conservative Majority" into the
"Conserva~tivesfor a Republican Majority" PAC secretly controlled by Defendant
POSTMUS.
OVERT ACT 31
On or between July 5, 2007, and October 30, 2008, Defendant POSTMUS
directed Aleman and Richman to disperse approximately $50,000 from the Inland
Empire PAC to Defendant POSTMUS' campaign account without any consultation with
the Board of Directors of the PAC.
OVERT ACT 32
On or between March I , 2007, and October 30, 2008, Defendant POSTMUS
used funds in his campaign account for personal meals and personal entertainment.
OVERT ACT 33
On or about March 18, 2007, John Doe #4 contacted a campaign accountant
about establishing a PAC named the Alliance for Ethical Government.
OVERT ACT 34
On or about May 16,2007, John Doe # I wrote check #4533 for $100,000 from
Colonies to the Alliance for Ethical Government PAC.
OVERT ACT 35
On or about May 25, 2007, John Doe #4 directed his campaign accountant to
complete the establishment of the Alliance for Ethical Government PAC that he secretly
controlled.
OVERT ACT 36
On or about May 29,2007,John Doe M arranged that check M533 for $100,000
be deposited into the Alliance for Ethical Government PAC that he secretly controlled.
OVERT ACT 37
On or about October 31,2007,John Doe M submitted a campaign consulting
contract valued at $10,000to the Alliance for Ethical Government PAC that he secretly
controlled; payment was made to John Doe M on November 7,2007
OVERT ACT 38
On or about April 16,2008,John Doe M submitted a campaign consulting
contract valued at $10,000to the Alliance for Ethical Government PAC that he secretly
controlled; payment was made to John Doe #4 on April 23,2008.
OVERT ACT 39
On or between April 30,2008,and May 16,2008,the Alliance for Ethical
Government PAC made non-monetary contributions in the amount of $6,336.19
to John
Doe M's campaign for election to the Republican Central Committee.
OVERT ACT 40
On or about June 15,2007,John Doe #I and John Doe #2 signed check #4579
for $100,000from Colonies to the San Bernardino County Young Republicans PAC
secretly controlled by John Doe #5.
OVERT ACT 41
On or between June 15,2007,and September 15,2008,
John Doe #5 directed
that the San Bernardino County Young Republicans PAC pay campaign expenses for
John Doe #5 and fund ,the campaign account of John Doe #5.
OVERT ACT 42
On or about March 20,2007,
John Doe #I wrote check M417 for $100,000from
Colonies to the Committee for Effective Government PAC-, to be controlled by
Defendant ERWIN, to compensate Defendant ERWlN for his role in obtaining the votes
needed to approve the settlement of the Colonies lawsuit.
OVERT ACT 43
On or about March 23, 2007, the Committee for Effective Government PAC was
created by Defendant ERWlN with Defendant ERWlN as Chairman, Clyde Boyd-ViceChairman, Elizabeth Sanchez-Secretary, Betty Presley-Treasurer, Gloria Affatati-BoydDirector. and Steven Hauer-Director.
OVERT ACT 44
On or about March 28, 2007, Defendad ERWlN arranged the deposit of check
#4417 for $100,000 into the Committee for Effective Government PAC controlled by
Defendant ERWIN.
OVERT ACT 45
On or about September 15, 2008, Defendant ERWlN forged the signature of
Director Steven Hauer on a payment authorization from the Comrr~itteefor Effective
Government PAC that directed the payment of $5,000 to Defendant ERWIN; payment
was made to Defendant ERWlN on the same date.
COUNT 2 (Penal Code 585)

BRIBING A LEGISLATIVE BODY MEMBER
On or about January 01,2005, through July 12,2007, in the above named
judicial district, the crime of BRIBING A LEGISLATIVE BODY MEMBER, to wit: William
John Postmus, in violation of PENAL CODE SECTION 85, a felony, was committed by
JAMES HOWARD ERWIN, who on and between January 01, 2005, and July 12,2007,
did unlawfully, give and offer to give a bribe to a Member of the Legislature, to a
member of a legislative body of a city, county, city and county, school district and other
special district and to another person for the member, and attempted by menace,
deceit, suppression of truth, and corrupt means, to influence a member in giving and
withholding his and her vote, and in not attending the house and a committee of which
he and she was a member.

BRIBING A LEGISLATIVE BODY MEMBER
On or about January 01,2005, through June 15,2007, in the above named
judicial district, the crime of BRIBING A LEGISLATIVE BODY MEMBER, to wit: John
Doe #5, in violation of PENAL CODE SECI-ION 85, a felony, was committed by JAMES
HOWARD ERWIN, who on and between January 01,2005, and June 15,2007, did
unlawfully, give and offer to give a bribe to a Member of the Legislature, to a member of
a legislative body of a city, county, city and county, school district and other special
district and to another person for the member, and attempted by menace, deceit,
suppression of truth, and corrupt means, to influence a member in giving and
withholding his and her vote, and in not attending the house and a committee of which
he and she was a member.
BRIBERY
On or about January 01,2005, through July 12,2007, in the above named
judicial district, the crime of BRIBERY, in violation of PENAL CODE SECTION 165, a
felony, was committed by JAMES HOWARD ERWIN, who on or between January 01,
2005, and July 12, 2007, did unlawfully give and offer to give a bribe to a member of the
San Bernardino County Board of Supervisors, to wit: William John Postmus, upon an
understanding that his official vote, opinion, judgment, and action would be influenced
thereby and given in a particular manner, and upon a particular side of a question and
matter upon which helshe might be required to act in hislher official capacity.
BRIBERY
On or about January 01, 2005, through June 15,2007, in the above named
felony, was committed by JAMES HOWARD ERWIN, who on and between January 01,
2005, and June 15, 2007, did unlawfully give and offer to give a bribe to a member of
the San Bernardino County Board of Supervisors, to wit: John Doe #5, upon an
understanding that his official vote, opinion, judgment, and action would be influenced
thereby and given in a particular manner, and upon a particular side of a question and
matter upon which helshe might be required to act in hislher official capacity.
14
COUNT 6 (Penal Code 65181

EXTORTION
On or about January 01,2005, through November 28,2006, in the above named
judicial district, the crime of EXTORTION, in violation of PENAL CODE SECTION 518,
a felony, was committed by JAMES HOWARD ERWIN, who on and between
January 01,2005, and November 28,2006, extorted money and other property and
obtained an official act of a public officer, to wit: William John Postmus, by means of
force and threat such as is mentioned in Section 519.
EXTORTION
On or about January 01, 2005, through November 28, 2006, in the above named
judicial district, the crime of EXTORTION, in violation of PENAL CODE SECTION 518,
a felony, was committed by JAMES HOWARD ERWIN, who on and between
January 01, 2005, and November 28, 2006, extorted money and other property and
obtained an official act of a public officer, to wit: John Doe #5, by means of force and
threat such as is mentioned in Section 519.
ASKING FORIRECEIVING A BRIBE
On or about January 01,2005, through July 12, 2007, in the above named
judicial district, the crime of ASKING FORIRECEIVING A BRIBE, in violation of PENAL
CODE SECTION 86, a felony, was committed by WILLIAM JOHN POSTMUS, who on
and between January 01, 2005, and July 12, 2007, being a Member of a house of the
legislature and a member of the legislative body of a city, county, city and county, a
school district, and other special district did ask, receive, and agree to receive a bribe
upon an understanding that his and her official vote, opinion, judgment, and action
should be influenced thereby, and gave in a particular matter and upon a particular side
of a question and matter upon which he and she was required to act in his and her
official capacity, and gave and offered and promised to give an official vote in
consideration that another Member of the Legislature and another member of the
legislative body of a city, county, city and county, school district, and other special
district should give this vote on the same and another question.
15

BRIBERY
On or about January 01, 2005, through July 12,2007, in the above named
felony, was committed by WILLIAM JOHN POSTMUS, who on and between
January 01, 2005, and July 12, 2007, did unlawfully, being a member of the San
Bernardino County Board of Supervisors, receive, offer, and agree to receive a bribe
upon an understanding that hislher official vote, opinion, judgment, and action would be
influenced thereby and given in a particular manner, and upon a particular side of a
question and matter upon which helshe might be required to act in hislher official
capacity.
COUNT 10 (Government Code 61090)
CONFLICT OF INTEREST
On or about January 01,2005, through November 28,2006, in the above named
judicial district, the crime of CONFLICT OF INTEREST, in violation of GOVERNMENT
CODE SECTIONS 1090 and 1097, a felony, was committed by WlLLlAlW JOHN
POSTMUS, who on and between January 01, 2005, and November 28, 2006, did, while
a member of the San Bernardino County Board of Supervisors, knowingly and willingly
become financially interested in a contract made by him in his official capacity, and by a
body and board of which the defendant was a member.
PUBLIC OFFICER CRIME
On or about November 28, 2006, in the above named judicial district, the crime of
PUBLIC OFFICER CRIME, in violation of PENAL CODE SECTION 424, a felony, was
committed by WILLIAM JOHN POSTMUS and JAMES HOWARD ERWIN, who being a
person described in Penal Code section 424 charged with the receipt, safekeeping,
transfer, and distribution of public moneys, did in a mariner not incidental and minimal
without authority of law, appropriate the same, and a portion thereof, to personal use
and the use of another and did in a manner not incidental and minimal without authority
of law, appropriate the same and a portion thereof, to personal use and the use of
another and loaned the same or any portion thereof and made a profit out of and used
the same for any purpose not authorized by law and fraudulently altered, falsified,
concealed, destroyed, and obliterated any account.
COUNT 12 (Penal Code 5470(a) and (d))
FORGERY
On or about September 15, 2008, in the above named judicial district, the crime
of FORGERY, in violation of PENAL CODE SECTIONS 470(a) and (d), a felony, was
committed by JAMES HOWARD ERWIN, did, with the intent to defraud, and knowingly
without authority to do so, sign the name of another person and of a fictitious person, to
wit: Steve Hauer, and falsely make, alter, forge and counterfeit, utter, publish, pass and
attempt to offer to pass, as true and genuine, Authorization for Payment of Invoice,
knowing the same to be false, altered, forged and counterfeited.
NOTICE TO DEFENDANT AND DEFENDANT'S ATTORNEY

Pursuant to Penal Code Sections 1054.5.(b), the People are hereby informally
requesting that defense counsel provide discovery to the People as required by Penal
Code Section 1054.3.
NOTICE TO ATTORNEY
The materials accompanying this notice may include information about witnesses. If so,
these materials are disclosed to you pursuant to Penal Code section 1054.2 which
provides: "No attorney may disclose or permit to be disclosed to a defendant the
address or telephone number of a victim or witness whose name is disclosed to the
attorney pursuant to subdivision (a) of Section 1054.1 unless specifically permitted to do
so by the court after a hearing and a showing of good cause."
I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND

CORRECT AND THAT THIS COMPLAINT CONSISTS OF 12 COUNT(S).
Executed at San Bernardino, California, on February 9, 2010.
H. Randles
DECLARANT AND COMPLAINANT
Aaency: District Attorney B of I-Central

Defendant
William John Postmus
James Howard Erwin
Birth Date
05/03/197 1
09/08/1962
Prelim Est. 00:OO

Booking No.
CII No.
NClC
EXHIBIT 2
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Welcome from Bob Dutton,
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Archives
Assessor
On January 26, 2010 The Board of Supervisors approved

the consolidation and reorganization of the offices of the
Birth Certificates
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Assessor, Treasurer-Tax Collector, and AuditorControllerIRecorder to enhance public service, while

generating cost savings and operational efficiencies
Process Server
Effective January 3, 201 1, the offices of the Assessor

and Recorder-County Clerk have been consolidated. Bob
Dutton, the Assessor-Recorder-County Clerk is
committed to serve the citizens of San Bemardino
County with efficiency and integrity. Please dick one of
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Online Services
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the division links below that best describes the services

we may assist you with or e-mail the Taxpayer Liaison
for assistance, or call the Assessor toll free at 877-8857654 or the Recorder-Clerk toll free at 855-732-2575.
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Bob Dutton
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San Bemardino County
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Nancy Duffy McCarron, CBN 164780

Law Office of Nancy Du@McCarron
950 Roble Lane
Santa Barbara. CA 93103
February 4,2013
TO: SAN BERNARDINO COUNTY BOARD OF SUPERVISORS (ALL 5 DISTRICTS)
Robert Lovingood (la)),Janice Rutherford (2d), Jamea Ramos (3rd), Gary Ovitt (49, Josie Gonzales (5*)
faxed to 909-387-3018and sent by em.ailto all Supervisors

RE: DEMAND TO AUDIT ASSESSOR'S OFFICE- STUBBLEFIELD COUNTY TAX EVASION
Please consider this a demand to appoint an independent auditor to investigate the
San Bernardino County Tax Assessor's Office [Larry Walker] for more Stubblefield corruotion.
As you krhw, the former Tax Assessor pled guilty to crimes involving Stubblehld bribes.
We downloaded all tax parcel records &om the Assessor's website associated with address:
4040 Piedmont Drive, Highland, California 92346, property owned by Arnold Stubblefield.
This property is known as Mountain Shadows Mobile Home Community (MSMHC) 402 spaces.
When the above address is entered into the "property tax informatrionusearch tool at the
Assessor's website, a "Situs Address Seamh-PameIList' pops up showing a vertical row of blue
links [parcel numbers] associated with the address. i33xh.A.l Although there are 402 mobile
home spaces listed numerically 11-4021the blue link pareels are not listed in numerical order.
The last three digits of each blue link parcel number is the space number for that mobilehome.
The first bluehkparcel number 1199291026359 is a combination of the orieinal lot arce el no.
assigned by county staff to a lot -[
- to which 359 wa9 a ~ ~ e n d to

e dreflect space 359.
The first bluelinkevokes records for a mobilehome [space 3591 owned by Craigs.lExh.B11
showing no tax paid since 2003 [Bz-s] an artificially low assessment of $7,542md, which should
have been assessed at the purchase price when installed in 1989 (after 1980) per tax rules[Bsd.
The MSMHC 2012 Directory shows tenant Valerie Vetrone (UL phone #) rents space 359[B,-sl
This home may actually be owned by Stubblefield. Since $1000-$1,300 in rent is being collected
on this parcel---andoccupants use police, fire, and other county services---taxesshould be paid.
One of the main reasons the City is bankrupt and County nearly bankrupt is employees are at
best incompetent or a t worst complacent with Stubblefield corruption ongoing for 50 years.
Tax Assessor rolls are deliberately listed out of order to confuse anyone trying to make
sense of them and to prevent the average citizen from discovering complacency and corruption.
We downloaded records for 444 parcels associated with 4040 Piedmont Drive in Highland, CA
and inserted the downloaded data into two large word documents [one for properties owned by
Stubblefield, and one for properties owned by homeowners renting spaces in the MSMHC.
We then copied related data entries and inserted them into a n excel spreadsheet we designed
to sort data numerically by parcel number, and to show complacency & corruption in columns.
The excel spreadsheets prove staff (one or more) in the tax assessor's office have conspired with
Stubblefield to tweak tax records to insure that Stubblefield pays either minimal or no taxes.
STUBBLEFIELD TAX FRAUD HAS OCCURRED SINCE 1974 AND CONTINUES TO DATE
The park has operated since as early as 1974 (tax assessor records show owners in 1974)
but Department of Community Housing [Riverside], having jurisdiction over mobilehomes,
shows a start date of Nov 28, 1998 [CI] and amazingly has "no records" of current residents[C~].
There are two excel spreadsheets [one for l/z of the homes listed a t the assessor's office as being
owned by Stubblefield [D1-sl and one for l/z of the homes listed as being owned by others. [El-171.
We are submitting downloaded data from assessor's website in two word documents bv email
because these documents are too manv panes to send bv fax. This is back-up for spreadsheets.
[homes owned by Stubblefield Properties or MSMHC & homes owned by his tenant residents].
The downloaded, sorted data shows a distinct pattern and history of Stubblefield tax evasion.
Vertical columns show that Stubblefield pays little or nothing in use taxes for homes he rents.
Stubblefield has evaded paying hundreds of thousands of dollars in taxes due the last 40 years.
Many of the parcels associated with 4040 Piedmont are for his lots not used for mobile homes.
The parcels are vacant lots Stubblefield acquired over the years for which he evaded paying
annual property taxes by concealing the owned lots under the pretext of mobilehome park use.
Stubblefield rents out most of the nearly 200 homes he owns for $1,000-$1,50O/month,
without paving anv taxes on assessed values of the rented mobilehomes, whose assessed values
were either never entered on tax rolls. or were assessed a t 0. or were deleted from the tax rolls.
Comparing the Stubblefield-owned homes spreadsheet to the private homeowners' spreadsheet
shows onlv private owners regularlv pav, or have paid annual taxes based on assessed value.
HOW THE STUBBLEFIELD RACKETEERING ENTERPRISE OPERATES IN MSMHC

Stubblefield has filched % of the homes in a racketeering enterprise designed to defraud.
When an owner dies, in most cases Tom Parrish refuses to allow the heirs to live in the home,
and refuses to approve the heir's prospective buyer renderihg it impossible for the heir to sell it.
Parrish precludes the heir from renting the home by refusing to approve the heir's sub-lessee.
There is no rent control so Stubblefield raises rents $50 per year. Current rents exceed $1,000.
The heir is forced to continue to pay Stubblefield $1,000-$1,300 per month for a vacant home.
The heir cannot afford to pay the exorbitant rent, is not allowed to live in the home and rent
out his own home t o make up the loss, and cannot afford to pay a n attorney to save the home.
Elderly residents and heirs are abandoning homes because they cannot afford to pay rent and
Stubblefield will not allow any owner to take in a co-resident to help pay the exhorbitant rent.
Stubblefield offers a "peace ofmind home'' program. If the elderly resident conveys the home to
Stubblefield her rent is reduced $200/mo; Stubblefield acquires title when she dies or moves.
Stubblefield's income is $400,000-$500,000 per month 1400 homes x $1,000-$1,300 per month].
Stubblefield could easilv afford to pav his fair share of taxes while raking in millions in rent!
Instead he bribes staff a t the tax assessor's office to make sure he pays little or no taxes at all.
The most important columns are in the middle: Roll Yr, Leg Descr, Roll Val Info, as of.
We used the same column titles as the tax assessor uses in online tax roll records. [Exh. Dl
The excel spreadsheets paint a clear picture of a long history of complacency and corruption.
Most of the 200 homes Stubblefield owns [out of 402 total spaces] shows Roll Val Info as either
unavailable, &or artificially low roll values. The as of column shows the last year the home's
value was assessed or the last year a tax bill was generated. In most cases the entries show
that no tax was ever paid, or the last time a tax bill was generated was 1998, 1994, 1985, etc.
P
column shows how Stubblefield and his conspirator(s) in the tax assessor's office
The L ~ Descr
list many parcels as tractNoLot while tenants are renting mobilehomes installed on those lots.
The Roll Yr column shows years 1997,1994,1993,1985 as the last year a tax bill was generated.
If Stubblefield is renting the homes for $1,000-$1,300per month he should pay tax on values.
Stubblefield's tenants use services such as policemen & firemen, and he should pay for services.
IT IS PATENTLY UNFAIR FOR SELECTED PRIVATE RESIDENTS TO PAY TAXES WHILE
STUBBLEFIELD, WHO RAKES IN $400,00O/MO INCOME PAYS LITTLE OR NO TAXES.
WE DEMAND AN AUDITOR BE ASSIGNED TO GET THESE HOMES ON TAX ROLLS.
HOW THE STUBBLEFIELD RACKETEERING ENTERPRISE DEFLATED HOME VALUES

Homes in MSMHC were selling for over $100,000 just a few years ago. Stubblefield rakes
in $1,000-$1,30O/mofrom a cash cow of rental homes advertised in monthly flyers. [Exh FI-31
Because Stubblefield precludes most residents (except for a few of his friends) from selling by
refusing to "approve" the new buyer for residency, precludes owners from sub-leasing by also
refusing to "approve" the owner's sub-lessee, and precludes owners from taking in a co-resident
to share the exorbitant rents for use of the lot, homes values were deflated to nearly zero value.
In 2010 Stubblefield imposed new "Community Rules" (written by GOLIATH HKC law firm)
upon residents which are so onerous that few prospective buyers or tenants want to move in.
The former "Community Rules" imposed in 2000 were only 14 pages long and mostly benign.
The new 2010 "Community Rules" are about 50 pages long with attached addendums requiring
residents to acquire private liability insurance to protect Stubblefield's land and legal interests.
The new rules are being enforced by a Gestapo like atmosphere, run by NAZI-like manager,
Marvin Freeman, whose job is to drive through the park daily looking for "rule violators" and
issuing "citations" to residents. Three "citations" will result in eviction from the park and
confiscation of the mobilehome by Stubblefield to add to his cash cow of monthly rental units.
For example, Mary Dunbar (space 331) was issued a "citation" because her daughter came
to visit Mary Dunbar "too many times." Mary faces eviction for "too many daughter visits."
The elderly Mary has a $74,000 assessment for which she pays $767 in annual taxes [Exh. GI
This is while Stubblefield collects $1,00O/month from Mary and pays no tax on his rental units.
Manager Marvin Freeman put the fear of God into the elderly Mary Dunbar who is in her 80's.
Freeman told Mary she will be evicted if she "dares to talk to Nancy Duffy McCarron" or if her
daughter and/or son-in-law [Cynthia Cole and Jim Tate] "dare to testify against Stubblefield"
in his sham forcible detainer eviction case being prosecuted in San Bernardino Superior Court
[S-321 against Bonnie Shipley [McCarron's co-resident] which should have been dismissed at
the first demurrer in September 2012 by Judge Schneider who eventually recused himself.
The case is now in S-32 with Judge Donald Alvarez who should have dismissed it but did not.
[See today's letter to Presiding Judge Marsha Slough on Stubblefield's "influence" over Judges].
THIS SHAM COMPLAINT IS NOW 8 VOLUMES WITH NEARLY 200 DOCKET ENTRIES.
JUDGES HAVE ALLOWED THIS SHAM CASE TO CONTINUE FOR SEVEN MONTHS!!!
THE COUNTY MUST STOP THESE MISCARRIAGES O F JUSTICE AND CORRUPTION.

Newly elected Supervisor James Ramos ran his campaign against Supervisor Neil Derry,
who pled guilty to criminal charges for failure to disclose campaign contributions (bribes) from
Arnold Stubblefield laundered through Bill Postmus (former Tax Assessor who resigned when
the corruption story went public and he pled guilty to criminal charges for corruption).
James Ramos won by a vote of 2 to 1over Stubblefield's "chore boy7'Neil Derry. This shows
that voters overwhelmingly want the County Board of Supervisors to take against to stop the
blatant complacency and corruption between Stubblefield and elected officials and employees.
IT IS TIME FOR JAMES RAMOS TO MAKE GOOD ON HIS CAMPAIGN PROMISES.
IT IS TIME FOR THE BOARD OF SUPERVISORS TO STOP BLATANT CORRUPTION.
We demand that a n auditor visit every mobilehome space in Stubblefield's park [MSMHC]
to assess the current value of each home regardless of whether it is rented or owned privately.
Every home has tenants who use the services of county employees [sheriff, police, firemen, etc.1
Each home needs to be included in the county's property tax rolls with updated assessed values
and bills must be generated for back taxes owed on these homes and current bills for this year.
These taxes owed should be recorded as liens against 4040 Piedmont Dr, owned by Stubblefield
so that if and when he decides to sell any of the related parcels assigned to that address, he is
forced to pay all back taxes, and current taxes, owed to the citizens of San Bernardino County.
THIS IS THE LEAST YOU CAN DO AS ELECTED OFFICIALS CHARGED WITH THE
DUTY TO ENSURE THAT EVERY CITIZEN IS PAYING HIS FAIR SHARE O F TAXES.
THIS COUNTY DESPERATELY NEEDS THE FUNDS WHICH WILL BE COLLECTED BY
UPDATING ASSESSMENTS ON 402 SPACES AND FORCING STUBBLEFIELD TO PAY.
We demand a meeting with all Supervisors and county counsel to explain in more detail how
to use the excel spreadsheets and how to collect back taxes Stubblefield has evaded for years.
I look forward to hearing from your staff a s soon as possible with dates for a closed session.
Sunday, Feb 03,2013 04:07 PM
Sunday, Feb 03,2013 04:08 PM
Sunday, Feb 03,2013 04:09 P M
FREQUENTLY ASKED QUESTIONS

California Mobilehome Park Residency Law (MRL)
PAGE
RENTS, FEES & TAXES
#I
Rent Increases
#2
Pass-Through Fees
#3
Short Notice of Rent Increase
#4
Back-Rent Billing
#5
Clubhouse Fee
#6
Security Deposit
#7
Deducting Rent Due to Lack of Functioning Park Utilities
#8
Withholding Rent When Park Loses Operating Permit
# I2
Low-Income Rent Vouchers: Section 8
UTILITIES
# I 3 Park Utility Costs
# I 4 Itemized Charges
# I 5 Park Cable Nor Common Antenna System Fees
# I 6 Water Charges
LEASES & RENTAL AGREEMENTS
# I 7 Long Term Leases Exempt from Rent Control
# I 8 Leases in Lavguage Other than English
# I 9 Length of lease: long-term, annual, or month-to-month
TERMINATION OF TENANCY
#20 Eviction for Late Payment of Rent
#21 Eviction for Rule Violations
#22 End of Rental Agreement Term
#23 Tenant Rights in Park-Owned Mobilehomes
#24 Park Closure or Conversion
PARK RULES & REGULATIONS
#25 Park Rules v. Mobilehome Residency Law (MRL)
#26 MRL protections
#27 Rule Changes
#28 Selective Enforcement of Park Rules
#29 Senior Park Changed to All-Age Park
#30 All-Age Park Back to Senior-Only Park
#31 Rights of Disabled Homeowners
#32 Occupancy Standards
bear a reasonable relationship to the actual damages that could be

anticipated or sustained by the landlord for late payment, such as
administrative costs relating to accounting for and collecting ,the late
payments. For example, a 3% charge for late payment of rent ($15 on a
$500 rent bill) is probably going to be construed as reasonable. Whether
$50 is reasonable depends on the outstanding amount of the late rent and
utilities owed.
Recap:
If the signed lease or rental agreement stipulates a late fee, then the
resident must pay.
# I 0 Why do residents have to pay taxes on their mobilehomes in

addition to paying the park owner a fee for property taxes?
Mobilehome owners, who are park residents, pay for the park's property
taxes either through their rent or sometimes through separate passthrough fees for property taxes, or property tax increases, on the park
property. Yet mobilehome owners may also be liable for an individual
property tax to the county on their home and accessory structures. Prior
to July 1, 1980 most mobilehomes were taxed like vehicles by the state
with a vehicle license fee (VLF) in lieu of local property taxes. However,
the law was changed in 1979 to subject new mobilehomes and
manufactured homes sold on or after July 1, 1980 to local property taxes
instead of the VLF. Pre-July 1980 homes remain on the VLF unless the
owner voluntarily switches the home to the local property tax system. Tax
law does not allow the county assessor to base assessment of taxes on
mob~lehomesin parks on the value of the park land or space. Hence, the
mobilehome owner's property tax is separate from the property tax on the
park owner's land.
Recap:
Resident pays the park's property tax pass-through fee. Resident may
also have to pay county's tax assessment on their home and accessory
structures.
Before July 1, 1980, mobilehomes pay Vehicle License Fee.
. taxes, separate from
After July ,' 1980,_new
. . mobilehomes pay property
the tax assessment on park property.
_I-_*-7
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-.%
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m
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#I
1 How can a resident get their taxes reduced?
Local property taxes are based on 1O h of the assessed value (AV) of the
property or home, plus any local bonded debt, such as school bonds.
Under the California Constitution (Article VIIIA), the county assessor may
increase the AV by 2% a year; however, when a home is sold and
ownership is transferred, the assessor may re-assess the property
(usually to the higher selling price or value). Therefore, homes that have
been resold in a "good" real estate market have been reassessed at
higher values, sometimes significantly higher, than those that have
remained under the same ownership for years with the application of the
2-,
_;"
4040 E Piedmont Drive. Highland. California 92346
................................................
...........................................
.........................
........................................................
......................................................
...........................................
...............
Manager's Office
(909) 862-2400
(909) 862-0260
Main Gate Telephone
Mountain Shadows Sales & Leasing
(909) 864-8621
Club House
(909) 425-2223
Hobby House
(909) 271-9728
(909) 864-1522
Administrative Office
After Hours Voice Mail maintenance Emergence Only).(909) 862-2400
911
Fire, Police & Medical Assistance & Fire. Police (S.B.).
SP# LAST NAME

331
332
333
335
335
336
337
338
339
340
342
343
345
345
346
347
350
351
352
353
353
355
356
357
Dunbar
Harman
Duffy
Hardesty
Greve
Lesnick
Andersen
Duff
Alonso
Anchales
Kelley
Chavez
Hazelbaker
Linville
Hurst
Harbeson
Satchel1
Canedy
Villarreal
Lug0
Sanchez
Rabenstock
Keller
Baker
Vetrone
361 Rice
FIRST NAME
Mary
LeLynn & Lois
Nancy
Annina
Frances
Ardelle
Beverly
Jim
Max & Diane
Pat
Michael & Cheryl
Diana
Ina
Rick & Judy
Eric & Susan
Nancy
Lester
Oren & Lois
Daniel & Karen
Louis
Ruby
Sunny
Toni
Peggy
Valerie
Barbara
PHONE NUMBER
862-1560
863-0486
UL .
864-6029
864-6029
864-0613
864-6177
863-1394
(951) 538-6657
UL
864-8864
379-9222
864-2873
864-2873
214-7760
864-9801
425-8810
425-1058
864-3834
862-2436
862-2436
863-9082
425-1736
863-0992
9
.
,
UL
864-6333 p*?
- .
>,-
r Vacant Lot [No Un...
r Vacant Lat (Na Utl...
Stubblefield Properties, a California General Partnership dba Mountain Shadows Mobile Home Community TAX Rolls to 2013
118
1199-291-02-6118
MSMHC
Corporat~on
2010040700007
04/07/2010
04/07/2010
2010
$13,000
1/1/12
GROW, LYDIA A
Owner
0%
UNKNOWN
0000000000000
1199-291-02-6177
1199-291-02-6178
AN IUNULLI JUHN
rast
Owner
0%
SOLE OWNER
8400000000000
1985'02
273
i199 291-02-6273 Stubblef'eld Co
Corporatlon
2002013100016
01/31/2002
01/31/2002
2002
$4,586
1/1,02
BAIN ,ADAM P
Owner
0%
SOLE OWNER
0000000000000
1989/03/01
273
Stubblefield Properties, a California General Partnership dba Mountain Shadows Mobile Home Community TAX Rolls t o 2013
TractNoLot unavailable
1199-291-02-6432
1-0001 1199-291-01-000
---
40001 1199-291-04-0000
--
.
-
00000000000
t
!
~
BOO5 ,1199-291-62-~005 No Present Owner Information Was Found For This Parcel
6-0000
TractNoLot $2,139
1/1/96 DAN LEMAY
Past Owner
960048847*3
11/1/96
12/28/1993 BOO5
PRIVATE OWNERS MSMHC
TAX Rolls to 2013
LACKWELDER, DEAN L
-.
.
-
Owner
>IUt)u~tk~t~u
vast
0%
PRIVATE OWNERS
I'
--
OWNER NAME
Relationship
Document No
Record Date
TAX Rolls to 2013
MSMHC
Acquire Date Roll Yr RO1'vallnfojZ
past Owner Name

31uumtl-ItLu
(status
% ownr
Relationship
Document No
I*.
Date
2001072300020
2001/07/23
Acquire Date
cast
PROPERTIES
PASCUZZI ,MARIO
I tNANLY
BRAMPTON , MARY
Owner
50%
IN
COMMON
2001/07/23
1199-291-02-6089
-
1199-291-02-6097
TAX Rolls to 2013
0%
SOLE OWNER
OOOOOOOOOOOOO
TAX Rolls to 2013
TAX Rolls to 2013
199-291-02-6163
LASBY ,JAMES A
50%
HUSBAND
AND WIFE
03/19/1998
9800000000000
03/19/1998
1
1998 1
TAX Rolls to 2013

OWNER NAME
Relationship
JUIN I
Document No
Record Date
Y~/I~OII Val info/
Acquire Date (Roll
-1
as of j ~ a sOwner
t
Name
Istatus
% ownr
Relationship
Document No
Rec. Date
/ Acquire Date
PRIVATE OWNERS MSMHC TAX Rolls to 2013
1199-291-02-6219
199-291-02-6220
199-291-02-6221
0 ,1199-291-02-6230
1199-291-02-6231
_t
--
9-291-02-6236
1199-291-02-6237
SMITH, ROBERT
M)00000000000
0000000000000
HNES ,CARLA G
1989/03/01
TAX Rolls to 2013
--
99-291-02-6251
9400000000000
1994/09/16
1994/09/16
1199-291-02-6259
1199-291-02-6267
HAYES, KIMBERLY
TAX Rolls to 2013
TAX Rolls to 2013
9-291-02-6280
99-291-02-6283
1C
TAX Rolls to 2013
11
TAX Rolls to 2013
9-291-02-6309
1199-291-02-6310
9-291-02-6314
199-291-02-6317
199-291-02-632
PARRISH ,MARVLOU
Owner
0%
COMMON
9600000000000
1996/06/02
1996/06/02
PRIVATE OWNERS MSMHC TAX Rolls to 2013
326 ,1199-291-02-6326
1199-291-02-6327
199-291-02-6328
---
CHAPPARO ,PELIN M
199-291-02-6332
200501140000
-~
I-1ARLAM , HAROLD G
SIUtStSLtkltLU
Owner
0%
-~
TAX Rolls to 2013
PRIVATE OWNERS M S M H C
TAX Rolls to 2013
1199-291-02-6
199-291-02-6359
GOlN LOIS M
1199-291-02-63
THAM , LEONARD M
ANDEZ VIRGINIA
99-291-02-6369
TAX Rolls to 2013
OWNER NAME
9-291-02-6375
ADAK ,KENNElH
S
008061900Wl
ERNIER ,LAURENCE
RETON, J E PAUL
INNER , LORETTA J
.
ITTAKER, FONDA
DAVIS ELIZABETHR
[TAKER MARGARET
000000000000
1199-291-02-63
LIVAN EDWARD J
HEELER ROSALIE
CLARK TERRY G
TAX Rolls t o 2013
9-291-02-6401
per tax assessor roll
eowner spaces listed on tax assr ro s
~-
This beautiful home at the "TOP"of the park has a magnificent view!
2 bedroom/2 bath with French doors leading onto the balcony from the master bedroom!
Fireplace large laundry room and a 2 car garage!
View from balcony
Living room leading onto balcony.
Beautiful Kitchen
Balcony as seen from below
S~ace
79
- $1.025 on a 2 vear lease.
This beautiful home has a beautiful view! Hardwood floors

extra parking spaces and rnwch more!
View from your patio at space 79.
;
b
Front entrance to
--
#bnv of tbshuffl~boardcourt 8 dog park

from space 79.
2 bedrood2bath bright and beautiful!

Come view this home today leasing at $1150 month on a 2 year lease
The Clubhouse with pool, Jacuzzi, spa,

exercise room and much more.
The Hobby ~ o u s e
- Meeting Friends,
Playing Games or Relaxing With a Game.
Front entrance to welco

8"
;-/
I
C'
a www ceb.com...
,
@ santa b h a ...
Yahoo1 Mail, T...
Free Legal For... @ a a gslist. acco... 0 ANDROID 0 AVIATION
C2 BIOS
"
>Otherbookmaks
h
Home
County of San Bernardino
Office o f t h e District Attorney

MICHAEL A. RAMOS, District Attorney
February 28,201 3
Ms. Nancy McCarron

950 Roble Lane .
Santa Barbara, CA 93103
RE: PI 726
-.---
McCarron:
~.~
- .
~ - -
-.
- -
This is to acknowledge that this office has received your electronic complaint of
February 4, 2013, addressed to the San Bernardino County Board of Supervisors and
forwarded to the Public lntegrity Unit of the District Attorney's Office.
Thank you for taking the time to write to us. The information you have provided is under
review.
Sincerely,
MICHAEL A. RAMOS
District Attorney
Public Integrity Unit
303 W. Third Street, 5thFloor, San Bernardino, CA 92415-051 1 (909) 382-7609 Fax (909) 382-7677
E-mail: da@-sbcda.orq
Web site: www.district-attomey.org
.~
EXHIBIT 3
Dir
~000000002
Street Name
1199291026359
1199291026272
1199291026295
1199291026001
~~
000000003
1000000013
1
5
1
r.
5
5
LO40 E OECMONT 1 RSP9 d G n A h D LA92146

to40 E >IENtAOhTDR SF ' O n G r 4 h L CA J i ~ 4 6
4040 E -EDMONTIIR r I G.lAh3. LA92346

4040 E PEDr/OhT DRH G n r N C 29234b
SAUER WOLFGANG
WHENHAM R J
MT SHADOWS MOBILE HOME COMMUNITY
DUNBAR MARY L
MT SHADOWS MOBILE HOME CUMMUNIW
VACANT I PARWNGL o n
S P 8~6 COMBINED
JOY. CAROL
MT Sn,;rJOnS r 4 O i LE rCrAE COtAMbr. T Y
ST <Hfi-EF C-3 PROPERnES
STbBf-TTIEZ PROPERT ES
11991(102Cfl~q
11992r102~010
~-
OOlOOOOlZ
000000013
4040 PETER RABBITTR 29PALMS. CA92277

4040 E PIEDMONT DRSP 359 HIGHLAND CA 92346
4040 E PIEDMONTDR SP 272 HIGHLAND. CA92346
4040 E PlEDMONTDRSP295HIGHLAND.CA92346
4040 E PIEDMONT DRSP1 HIGHLAND. CA92546
A
A
11993'1050030
11993' 1130000
SAN BERNARDlNO COUN
DENNIS DWEGER
A S S E S ~ O R ~ E ~ O R ~ % - C O CLERK
UNW
. ~.~~
. .
--..
~ e r c e l 1 1 1 9291
~ 01 1 992
~~
Land Type Size
3RAIIY~
Use
P Parcel Data
mJ+ij;*$9gine"
~,
,
Dir
000000015
000000016
000000017
OOOOOOOl8
000000019
000000020
000000021
000000022
000000023
000000024
000000025
000000026
Cwcel
.
,~,?
~. .-
Sheet Name
1199311160000
1199311170000
1199311180000
1199291026296
1199291026297
11 93291026298
1199291026299
1199291026300
1199291026301
1199291026302
1199291026303
1199291026304
A
A
A
A
A
A
A
A
A
A
A
A
1
1
1
5
1
1
1
1
1
5
1
1
4040t PIEDMONTDR HIGHLAND. CA92346

4040 E PIEDMONT DR HIGHLAND. CA 92345
4040 EPIEDMONTDRHIGHLAND.CAY2346
4040 E PIEDMONT DRSP 296 HIGHLAND. CA 92346
4040 E PIEDMONT UR SP 298 HIGHLAND. CA92346
4040E PIEDMONTDR SP300 HIGHLAND. CA 92346
4040E PIEDMONT DRSP 301 HIGHLAND. CA92346
4040E PIEDMONT DR SP302 HIGHLAND. CA92346
4040 EPlEDMONTDRSP303 HIGHLAND. CA32346
4040 EPlEDMDNTDRSP304 HIGHLAND.CA92346
Get NEXT 13
STUBRLEFIELD PROPERTIES
STUBBLEFIELD PROPERTES
STUBBLEFIELD PROPERTIES
CLINE. JAMES A
CIINE. JAMES A
MOUNTAIN SHADOWS MOBILEHOME COMMU...
WISE. PATRICIA F
BWMBLETT EDWARD W
PROVOST. PAULETE B
HAUG FAMILY TRUSTDATED 021592
Stat Tau Stat
Properly Address
AUKVcIues
F Omership - History
F Parcel Data
Dir
000000032
000000033
000000034
000000035
000000036
000000037
000000038
000000039
...~
. ~ .. .
~~
~-~ ~~~
~~~
Street Name
1199291026310
1193291026311
1199291026312
1199291026313
1199291026314
1199291026316
1199291026316
1199241026317
A
A
A
A
A
A
A
A
1
1
5
5
1
1
1
1
4040 E PIEDMONT DRSP 31 0 HIGHLAND. CA 92346

4040 E PlEOMONTDRSP311 HIGHLANO. CA91346
4040 E PIEDMONTDR SP312 HIGHLAND. C492346
4040 E PIEDMONTDR SP 313 HIGHLAND. C492346
4040 E PIEDMONTDR SP 314 HIGHLAND CA 92346
4040 E PlEDMONTDRSP315 HIGHLAND. CA92346
4040 E PlEOMONTDRSP316 HIGHLAND. CA92346
4040E PIEDMONTDR SP317 HIGHLAND. C492346
MOBILHOME COMMUNIlY
PARSONS. EDWARD A
DARE. JEANNIE
MT SHADOWS MOBILE HOME CDMMUNIV
MOUNTAIN SHADOWS MOBILEHOME COMMU
COWNTH J GUFORTH INTER VlVDS TRUST
HOFMANN. IDA F
COHEN. M E N L
MOCZAWY. WALTER J
-Matches were lound. more data exists
-.
~. .
~~
~.
-~~
Dir
000000041
000000042
000000043
000000044
0000nn045
000000046
000000047
000000048
000000043
000000050
000000051
Street Name
1199231026313
1199291026320
1199231026321
1193231026322
1199291026323
119929102632<
1199291026325
1199291026326
1139231026327
1199291026328
1199291026323
A
A
1
1
A
A
A
1
1
1
1
1
1
1
1
5
A
A
A
A
A
A
4040 E WEDMONTDR SP313 HIGHIAND. CA 92346-4840

4040 F PlFDMONTDRSP321 HIGHLAND. (2492346
4040 E PlEDMONTDRSP322HIGHLAND. CA32346
4040 EPlEDMDNTURSP324HlGHLAND. CA92346
4040 EPlEDMONTDRSP326HIGHLAND,CA923<6
4040 E PlEDMONTDRSP328HIGHIAND. CA 32346
4040E PlEDMONTDRSP329 HIGHLAND. CA92346
4040 E PIEDMONT DRSP 13 HIGHIAND. CA 32346
ACFWDO. W O N
MTSHADOWS MOBILE HOME COMMUNIlY
ROBERT REVOCABLE TRUST 072005
ACKEK JACK E
WALDEN FAMICf TRUST01 2237
WILLIAMS. JAMFS 8
COURTNEY FQUSEB BERNICE CBUSE FAM ...
DOWN. KAREN A
COURTNN t LL BERNICE C BUSE LlVlROgOlO
NEUMAN, KEIW M
COURTNEYFe BERNICE BLlSE UTR030100
SPlZ 8 13 WMBINED
Land Type Size
Use
r-C--BPS Aud Casls

BPS !Apt Costs
Ownership - History
Porcel Data
Parcel Info
P r o t ~ l n mDned
>,F,* ,,? i
,
Tools
Map ] 'IractMipl g"bdGlnd&

WIT^^;;; ASSG.~~~!
MG I
arcel
Dir
000000057
000000058
000000059
000000060
000000061
000000062
000000063
000000064
000000065
( P ~ ~ L 1 ~m
~ ~( ~I pDp g a ~1 sicd N
Street Name
1199291026333
119929i026334
1199291026335
1199291026336
11Y9291026357
1199291026338
1199291026339
1199291026340
1199291026341
A
A
A
A
A
A
1
5
1
5
1
1
A
A
5
5
4040 E PIEDMONT DR SP 333 HIGHLAND. CA32346

4040 E PIEDMONT DR SP 334 HIGHLAND. CA 92346
4040 E PIEDMONTDR SP336 HIGHLAND CA 92346
4040 E PIEDMONTDR SP 330 HIGHLAND, C4 92346
4040E PlEDMONTDRSP340 HIGHLAND.CA92346
Matdles were found, more dala exists
Caccel
Jiltached I i G p m y N o
matches
DUFW, NANCY B
MOUNTAIN SHADOWS MOBILE HOME COMMU..
HARDESW, ANNINAT
MTSMDOWS MOBILHOME COMMUNITY
ANDERSON. ROY E
DUFF. JAMES R
MT SHADOWS MOBILHOME COMMUNITY
MT SHADOWS MOBILE HOME COMMUNIN
VACANT
il
-.
...
Slut Tax Slut
Properly Address
Ownership - Cunent
I
.. .
Dir
000000067
000000068
000000069
000000070
000000071
000000072
000000073
000000074
000000075
000000076
000000077
00000078
Street Name
1199291026343
1199291026341
1199291026345
1199291026346
1199291026347
1199291026348
1199291026349
1199231026350
1199291026351
1199291026352
1199291026353
1199291026354
A
A
A
A
A
A
A
A
A
A
A
A
1
5
1
1
5
5
1
1
5
5
1
5

4040 F FiEnMONTDR SP 344 HIGHW4D. CA 92346
4040 E PIEDMONTDRSP 346 HIGHLAND. CA92346
4040 E PIEDMONTDR SP 347 HIGHLAND. W92346
4040 E PIEDMONTDR SF 348 HIGHLAND. CA92346
4040 E PIEDMONTDRSP 351 HIGHLAND CA92346
4040 E PlEDMONTDRSF352 HIGHLAND. CA92346
GetNM13
HAZEMAKER INA
HURST ERlCE
HAREESON. IIIAIKY E
MTSHADOWSMOBILHOME COMMUNITY
SATCHEL LESTER G
CANEDY OREN E
VllLARPEAL KAREN
LUGO. LOUIS
MT SHAOOWS td0811E HOME COMMUNITY
m $ * ~ & l & ~ n ~ i n e - - _ ~-.
-----
,,
--
---
Took
.~.
&[[S?tusi~~~arce!~apj
Dir
000000080
0OO000OBl
000000082
000000083
000000084
000000085
000000086
000000087
000000088
000000089
000000090
Cancel
&pi&
. .~~~
6.G ( Appeals I ~
Street Name
1199291026356
1199291026016
1193291026017
119'3291026357
1199291026358
1199291026360
1199291026361
1199291026362
11992'31026363
1199291026364
1199291 026365
A
A
A
A
A
A
A
A
A
A
A
5
5
1
5
1
5
5
1
1
1
1
4040 E PIEDMONT DR SP356 HIGHLAND. CA 92346

4040 E PlEDMONT3RSP16 H I G H M D . CA92346
4040 E PIEDMONTOR SP17 HIGHLAND, CA 92346
4040 E PlEDMONTDRSP358 HIGHLAND. CAY2346
4040 E PIEDMONTDR SF 362 HIGHLAND. CA92346
4040 E PIEDMONTDR SP364 HIGHLAND. C492346
4040 E PIEDMONTDR SP365 HIGHLAND. CA92346
...
~~
c c l (~ o
KELLER TONI L
MT SHADOWS MH COMMUNITY
MT SHADOWS MOBlL HOME COMMUNITY
MOUN1AIN SHADOW MOBILEHOME CUMMU..
MT SHADOWS MOBlL HOME COLItdUNITY
PICE. GLEN A JR
MTSHADOWS MOBILE HOME COMMUNITY
OTTO RAND DONNA J LU1L FAMILY TRUST
GILLETTE LIWNGTRUST
LATHAM. LEONARD M
CROSS. ALEC
-. .
.
.
-.
Parcel 11199 291 o1 I 992
LandType Sire
Use
I
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~~
3R i ~ i Y I
rr
~
Ownership Current
Omership History
,F Parcel Data
BPS Aud Costs F Parcel Info
m~ptc0.t~
F..-~hl~:n
r ; ~ ~ r i
PS e-File
F Reviews
siness Char F Roll V d - Extracted
Aux i 1 = l u ~ s
:.+
TO015
.. -. .
w j l S?tusssRG&Map- 1
~~
Dir
000000093
000000094
000000035
OOOOO0096
000000097
000000098
000000099
000000100
000000101
000000102
000000103
CwCel
laa~.&~I
suici"
l n d e d enached
I-TGI ~ ~ p eI qG
a l ~NU/
~
Prope&hlld
~
~
~
Sheet Name
1199291026368
1199291026369
1199291026370
1199291026371
1199291026372
1193251026373
1199291026374
1199291026375
1199291026376
1139291026377
1199291026378
1199291026379
A
A
A
A
A
A
A
A
A
A
A
A
1
1
5
1
5
1
1
5
1
5
5
5
4040 E PIEDMONT DR SP368 HIGHLAND. CA92346

4040 E PIEDMONT DRSP 369 HIGHLAND. CA92346
4040 EPIEDMONT DRSP371 HIGHLAND. CA32346
4040 E PIEDMONT DRSP377 HIGHMD. C.492346
4040 E PIEDMONTDRSP 379 HIGHMD. CA92346
1
Get NEXT 13
matches
MOUSER-PETRO. JOYCE W E
WITATE ALBERT
BEAUREGARO. WILLIAM P
STUEELEFIFLDPROPERTIES
HIGGINEOTHAM MARKMOMAS
MTSHADOWS MOBILE HOME COMMUI\IITY
CAIN. WREN A
WALKEP, GARY
VACANT
MOUNTAIN SHADOWS MOBILE HOME COMMU ..
;&Assignment p Omership - Cunenl

k r ~ u Vxc . , e a
F Ownership - History
FozI Chit
Parcel Data
:TBPS Aud Costs [7 Pmcel Into
1.:
r Pcohlern n e e d
BPS Rpt Casts
l;r BPS e-file
I
Address Last Changed
F Revtews
$:rBusiness Chmr
p Roll Val - Exlraded

i7a-".t
~ ~ . . . ~ ~ . . . ~ . .
M ( ( S ? t u s ASSRParA! hlap
Dir
000000106
000000107
000000106
OOOOOOl09
0000@0110
0000001 11
0000001 12
0000001 1 3
000000114
000000115
00000116
0000011 7
Street Name
1199291026381
1199291026382
1199291026333
1193291026384
1199291026019
11 99291 026020
1199291026385
1199291 026386
1199291026387
1199291026388
1199291026389
11 99291026390
A
A
A
A
A
A
A
A
A
A
A
A
5
5
5
1
5
5
5
5
5
1
1
4040 t PIEDMONT DRSP381 HIGI ILAND. W 9 2 3 1 6

4040 E PIEDMONTDRSP 383HIGHLAND. CA92346
4040 E PlEDMONTDRSP19 HIGHlAND. CA92346
4040 E PIEDMONTDRSP 385 HIGHLAND. CA 92346
4040 E PIEDMONTDR SP 386 HIGHLAND. CA 92346
4040 E PlEDMONTDRSP71-AHIGHLAND. CA92346
4040 E PlEDMONTDRSP100-AHIGHMND. CA92346
4040 E PIEDMONT DR SP 1 0 0 8 HIGHLAND. CA 92346
STUBELFFIELD PROPERTIES
MT SHADOWS MOBILE HOME COMMUNIV
MTSHADOWS MOBILE HOME COMMUNrlY
BREI~ON.J E PAUL
MOUNTAIN SHADOWS MOBILE HOME COMMU..
TAYLOR RICHARD L
VACANT
VACANT
DRMLER KENNETH L
SHERBUWE. PETERC
DAVIS. EUZABFTH R
11
Stat Tax Stat
Parcel
r r
(1199-291-01-1992
and Type Size
Properly Address
Use
r- rr--
1
r
Mailing Address
BPS Aud Costs
.,
F Parcel Info
Tools
I Parcel Map I
--Dir
00000120
000000121
000000122
OOOOOOl23
000000124
OOOOOO125
000000126
000000127
OOOO00120
OOOOOOl29
000000130
Cacel
? i d tdiP
~ " b d i vlndex I ~ t t a c h e d&I m i &
ly / &. I ~ p p i i l Is~ c NdU / _ _ ~
No / ~ r o p e &
Street Name
1199291 026393
1199291026394
1199291026395
1199291026396
1199291026397
1199291026398
1199291026399
1199291026400
1199291026401
1199291026402
1199291026403
A
A
A
A
A
A
A
A
A
A
5
1
1
1
5
5
5
5
1
5
5
4040 E PIEDMONT DR SF 134-AHIGHLAND.CA 92346

4040 E PIEDMONTDRSPI 58-AHGHMD. 0492346
4040 EPlEDMONTDRSP15RBHIGHLAND. CA52346
4040 E PIEDMONT DRSP158-CHIGHMD. 0492346
4040 E PlEDMONTDRSP248-AHIGHLAND.CA92346
4040 E PIEDMONT DRSP255-AHIGHLAND. CA 92346
4040 E PlEDMONTDRSP255-6HIGHLAND. CA 92346
4040 E PlEDMONTDRSP362-AHIGHLAND. CA92346
4040 E PIEDMONT DR. SF 368AHIGHLAND. CA 92346
4040 EPIEDMONTDRHIGHLAND. CA92346
4040 E PIEDMONTDRHIGHLAND. C.492346
matches
DIAMOND. RENEE M
VOSS. RICHARD
THE GARRElTTRUST 021395
BILLRAND JUANITABAKER REV LVG TR
MT SHADOWS MOBILE HOME COMMUNIW
BUSE FAMILY TRUST
VACANT-SF NOT BUILT
VACANTSP NOTBUILT
...
Assignment
I? Ownership - Current
Au~'t't~iuo:>
BPS Aud Casts

BPS ~ pcosts
t
BPS e-File
Business Char
P Parcel Info
Parcel D e l e
d
FA&R
Dir
000000132
000000133
COO000134
000000135
000000136
000000137
000000130
000000139
000000140
000000141
000000142
000000143
~aic.!
& I &cel
M&
i r a d Map
_j
~ u b d i v l n d i x &ached
j
( !%paG~il
P r o p e r t y - ~TW
~
Street N m e
1199291026405
1199291026406
1199291016407
1199291026408
1199291026403
1199291026410
11992910P6111
1199291076023
1199291026024
1199291026412
1199291016413
1199291026414
A
A
A
A
A
A
A
A
A
A
A
A
6
5
5
5
5
5
6
1
5
5
5
4040 E PIEDMONTDRHIGHLAND. CA92346

4040 E PIEDMONT OR HIGHLAND. CA92346
4040 E PIEDC40NTDRHIGHLAND. CA92346
4040 E PlEVMONTDRHGHW.ID. CA92346
40LOE PIEDC40NTDRHIGHLAND.CA92346
4040 E PIEDMONTDRHIGHLAND, CA92346
4040 E PIEDL40NTDRSP24HIGHLAND. CA32346
4040 E PIEDMONTDRHIGIILAND. CA92316
4040 E PlEDM0NTDRHIGHW.ID. CA92346
VACANT-SP NOTBUILT
VACANT-SP NOT BUILT
VACANT - SP NOT WILT
VACANTSPNOTBUILT
VACANT- SP NOT B111LT
VACANT-SP NOT BUILT
VACANT - SP NOT BUILT
CHRIST. SAM G
DERLETH. PATRIClA L
VACANT- SP NOT BUILT
VACANT- SPNOT BUILT
VACANT-SPNOTBUILT
1~
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F Reviews
I? Roll Val - Exbeded
& ~d l qs
'
Land Type Size
Use
I
r
l
I
Dir
00000146
OOOOOOl47
000000148
000000149
OOOOOO150
000000151
000000152
000000153
OOOOOOl54
000000155
000000156
SBeet Name
1199291026417
1199291026410
1199291026419
1199291026420
1199291026421
1199291026422
1199291026423
1199291025424
1199291026425
1199291026426
1199291026421
A
A
A
A
A
A
A
A
A
A
A
5
5
5
5
5
5
5
5
5
5
4040 E PIE3MONTDRHIGHLAND. CA92346

40411 E PIEDMONTORHIGHLAND.CAY2346
4040 E PICDMONTDRHIGHLAND.CA92346
4040 E PIEDMONTDR HIGHLAND. CA92346
4040 E PIEDMONTDRHIGHLAND. CA92X46
4040 E PIEDMONTDRHIGHLAND.CA92346
4040 E PIEDMONT DRHIGHLAND. CA92X46
4040 E PIEDMONTDR HIGHLAND. CA 92346
LO40 E PIEDMONT DR HIGHLAND. CA 92346
VACANT-SP NOT BUILT

VACANTSP NOTBUILT
VACANT-SPNOTBUILT
VACANT-SP NOT BUILT
VACANT-SPNOTBUILT
VACANT-SP NOT BUILT
VACANT-SP NOTBUILT
VACANT-SP NOT BUILT
L m d Type Size
r- r
Use
F Parcel Data
AuxVolues
BPS Aud Cask
ar
/-..
..
.,
Twls
Dir
000000159
000OOOlCO
OOOtiOO161
000000162
000000163
000000164
OOOOOOlfi5
000000166
000000167
000000168
000000169
Street Name
1199291026430
1139231026431
1133291026432
1193291026433
1199231026434
1133231026435
1133231026436
1139231026437
1193291026438
1199231026025
1199231026027
A
A
A
A
5
5
5
5
5
5
5
5
5
5
A
A
A
A
A
4040 E PlEDMONTDRHIGHWND.CA92346
4040 E PIEDMONTDRHIGHLAND. CA 92346
4040 E PlEDMONTDRHIGHLAND.CA92346
411411 E PlEDMONTDRHIGHLAND.CA92346
4040 E PlEDMONTDRHIGHLAND. CA92346
4040 E PlEDMONTDRHIGHLAND.UAY2346
4040 E PIEDMONTDRHIGHLAND. a 9 2 3 4 6
4040 E PlEUMONTDRSP25 HIGHLAND. a 9 2 3 4 6
4040 k PltDMONTORSP27 HIGHLANO.C.492346
Gel NEXT 1 3
V A U N T - SP NOT BUILT
VAOWT - SP NOT BUILT
VACANT-SPNOTBUILT
V A U N T - SF NOT BUILT
V A W T - S P A C E NOT BUILT
VACANT-SP NOT BUlLT
VACANT- SPNOT BIJlLT
VACANT
MT SHADOWS MOBILE HOME COMMUNIlY
BATES. VOOhTRUE
Parcel Info
P Roll V d - Ertmcted
~ . . ~
~~~
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I ~ u b d i vl n d d Anached I &mpeny
N;/
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1 TEV' ~1 A
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000000170
000000171
000000172
000000173
000000174
000000175
000000176
000000177
000000178
OOOOOO173
000000180
000000181
000000182
Street N a m e
1199291026439
1199291026440
1199291026441
1I99291026442
1199791030000
119929104P001
119929104P003
1199291 040000
1199291041000
1193291028005
1199291 028006
1199291028007
1199291028008
A
A
A
A
A
5
5
1
5
1
1
1
1
1
1
4040 E PIEDMONTDRHIGHIAND. C492346

4040 E FiEDMONTDRHIGHLAND.CA92346
4040 E PlEDMONTDRHlGHMD.CA92346
4040 E PIEDMONT DR HIGHLAND. 04 92346
4040EPlEDMONTDRHIGHMND.CA92346
4040 E PIEDMONT D R H I G H W D . CA 92346
4040E FlEDMONTDRHIGHLANn, CA92346
4040 E PIEDMONT DR HIGHLAND. CA92?46
4040E PIEDf4ONTERHIGHLAND. 0492346
4040E PIEUMUNT DRHlGHLAND.Cn.92346

VACANT-SP NOT BUILT
STUBBLEFIELD PROPFRTIES
STUBBEFIELD CONSTR CO ETAL
STUBBEFIELD CONSTRUCTION CO INC
STUBBLEFIELD CONSTRUCTION CO INC
LEMAY. DAN
BUCHANAN. ROBERT WALLACE ORWENDY J~
PERDUE. ROaERT
M I T O N FAMILVTRUST
1 - - .~--l
~
.~~~
F A S S R~ i r c i M.&
!
/
Dir
Sheet Name
--
~~~
000000184
000000185
000000186
000000187
000000188
000000189
000000190
000000191
0000192
0000193
0000194
0000195
1199291020000
1199291026004
1199291026005
1199291026007
1199291026008
1199291026014
1199291026018
1199291026022
1199291026030
I199291026033
1199291026034
1199291026035
A
A
A
A
A
A
A
A
A
A
A
A
1
1
1
5
1
5
1
5
5
5
5
5
I
2
4040 E PIEDMONT DR HIGHLAND. CA92346

4040 E PIEOMONTDRSP 4 HIGHLAND. a 9 2 3 4 6
4040E PIEDMONTDRSPS HIGHLAND. CA92346
4040 E PlEDMONTDRSP7 HIGHWD.C.492346
4040 E PIEDMONTDRSPB HIGHLAND.CA92346
4040 E PlEDMONTDRSP14 HIGtiLAND. CA92346
4040 E PlEDMONTDRSP18 HIGHLAND, 0.92346
4040 E PlEDMONTDRSP22 tiIGHLAND. CA92346
4040 E PlEOMONTDRSP33 HIGHMND. CA92346
GetNDCT13
MTSHADOWS MOBILHOMECOMMUNITY
BLACKWELDER DEAN L
MT SHADOWS MOBILE HOME W M M U N T (
FURST W R Y
MOUNTAIN SHADOWS MOBILE HOME COMMU
MOUNTAIN SHADOWS MOBILEHOME COMMU...
STUBBLEFIELO PROPERTlES
MT SHADOWS MORILE HOME COMMUNIW
~~.
r r
jl199-291-01.1992
L a n d T y p e Sire
Use
Am
valuer,
BPS Aud Costs

BPS Rpt Costs
P Ownership - History
P Parcel D a t a
F Parcel Info
r Flotllern need
a.
~..~~ ~..
....
(S?tus ASSRP a r e ! M a p I
Dir
-1
OOOOOUl90
000000199
000000200
000000201
000000202
000000203
000000204
000000205
000000206
000000207
000000208
~~
No
.~~
.~~~~
1 Property I01 TBA

~
&pcals
1 Acd
Street N a m e
F--
1199291026032
1199291026037
1199291026038
1199291026039
1199291026040
1199291026041
1199291026042
1199291026044
1199291026045
1199291026052
1199291026053
A
A
A
A
A
A
A
A
A
A
A
6
1
5
5
5
5
1
5
5
5
5
--
4040 E PIEDMONT DRSP 32 HIGHLAND. CAg2346

4040 E PIEDMONT DRSP 37 HIGHLAND. CA 92345.
4040EPlEDMONTDRSP38 HIGHLAND.CA92346
4040E PIFDMONT DRSP39 HIGHLAND. CA92343
4040 E PIEDMONTDRSP40 HIGHLAND,CA92346
4040 E PlEDMONTDRSP42 HIGHLAND. CA 92346
4040E PlEDMONTDRSP45 HIGHLAND, CA92346
4040 E PIEDMONT DR S P Y HIGHLAND. CA 923<6
SANDIFER LUCINDAANN
MTSHADOWS MHC
MTSHADOWS MOBILHOME COMMUNIW
STUBBEFIELD PROFFRTES
MOUNTAIN SHADOWS MOBILE HOME COMM'J...
WAGNER LUMLE MARIE
MTSHADOWS MOBILE HOME COMMUNIW
MACEWICZ. FLOPENCEG
MILLS. RONALD 0
~~
~ ~ ~ . . ~...
.
~~~~
Stat Tax Stat
Land Type Size
r7
Use
/I
Propew A
I
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M ~ S l f l l S i i k R . b B i & !p~aG
r ~il a
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-
00000211
00000212
00000213
00000214
00000215
00000216
00000217
00000218
00000219
00000220
00000221
Cancel
1199291026056
1199291026057
1199291026058
119929102605'3
1199291026060
1199291026061
1133291026062
1199291026063
1199291026064
1199291026065
1199291026066
A
A
A
A
A
A
A
A
A
A
A
1
1
5
5
5
1
5
5
1
5
1
F Ownership -History
BPS Aud Casts
F P a r d Info
-.
. ~ ~ . .
I Anached 1 -~
company...
~ m p e r t ID
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piei is/ i c d . i i I
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4040 E PEDMONTDRSPEO HIGHLAND. CA92346
4040 E PIEDMONT DRSPGI HIGHLAND. CA92346
4040 E PiEDMONTDRSP62 HIGHLAND. CA92346
4040 E PIEDMONT DRSP64HIGHLAND. CA92346
4040 E PlEDMONTDRSP65 HIGHLAND. a 9 2 3 4 6
4040 E PlEDMONl UHSP66 HIGHLAND. CA 92346
Get N E m 13
COLLINS. STEPHEN
MT SHADOWS MOBILE HOME CaMMUNIW
MT S W O W S MOBILE-IOME OJt4k$UNlV
MT SHADOWS MOBILEHOME COMMUNITY
MT SHADOWS MOBILE HOME COMMUNW
PALTDRIGE. WILLIAM
MT SHADOWS MOBILE HOMC COMMUNIW
FOGLID. FFIANKA
MTSHADOWG MOBIE HOME COMMUNITY
..~
~~
Parcel Data
Roll Val - Extraded
00 S
,,.I,,
4Jj
--
Map] e
S?tusAS~R~~&cei
.
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a p~ u h d i v l n d e x 4 i i = h i d ; p a n y
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I ~ ~ i/lD~ I T&p &/ ~
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i i ~i ~ so
.-
Dir
000000223
000000224
000000225
000000226
000000227
000000728
000000229
000000230
000000231
00000232
00000233
00000234
Street Name
1199291026068
1199291026069
1199291026070
1199291026043
1199291026046
1199291026071
1199291026072
1199291026073
1199291026074
1199291026075
1199291026076
1199291026077
A
A
A
A
A
A
A
A
A
A
A
A
5
5
1
1
5
1
5
5
5
5
5
1
4040 E PIEDMONTDRSP 67 HIGH

4040 E PlEDMONTDRSP60 tiIGHL4ND. CA92346
4040 E PIEDMONTDRSP JOHIGHLAND. CA92346
4040 E PIEDMONTDHSP 46 HIGHLAND. CA97346
4040 E PlEDMONTDRSP74 tiIGHLAND. CA92346
4040 E PlEDtrlONTDR SP75 HIGHLAND. CA92346
4040 E PIEDMONTOR SP 77 HIGHLAND. CP.92346
dchee *rere found. more data exists
Cancel
BtNEXT13
TALLMAN. LAEL W E
SlLVA WILMA
MOUNTAIN SHADOWS MOBILEHOME CUMMU ,.
SIMMONS. VIRGINIA
HAROLD MC GHATH TRUST
MT SHADOWS MOBILE HOME COMMUNiTf
MTSHADOWS MOBILE HOME COMMIINIW
CRAWFORD. JOHN
MOUNTAIN SHADOWS MOBILEHOME COMMU~
FAFACE. EOWARD I
1~
Land Type Sire
Use
I" Parcel Data
Dir
Sheet Name
A
A
A
A
A
A
A
1
5
5
1
1
1
5
5
5

4040 E PIEDMONT DRSP79 HIGHLAND. CA 92346-4831
4040E PlEDMONTDRSP8OHIGHLAND. C492346
4040 E PIEIIMONT DR SP 84 HIGHLAND. CA 92346
4040 EPlEDMONTDRSP90 HIGHLA
000000236
000000237
000000238
000000239
000000240
000000241
000000242
000000243
000000244
1199291026079
1199291026080
1199291026081
1199291026082
1199291026083
1189291026084
1199291026085
1199291026086
1199291026087
OOOOO02L7
1199291026090
MTSHADOWS MOB1
PN4LICK TI IOMAS J
KUZIEL JOHN P
MT SHADOWS MOBlL HOME COMMUNITY
STUBBLEFIELD PROPERnES
COVINGTON. DOLORES M
mBLE TRUST
Matches were found. more data exists
.....
. . ..
P a e l 11199 291 01 1 992

-.
~-
Stat Tax Stat
Land Type Size
P1NI-S - Search Englne
d
(
(
AS&
Dir
i"
Omership - Current
Use
Mailing Address
Farce! M&(
Aus Vaiocr
I? Ownership - History
BPS Aud Costs

BPS Rpt Casts
I? Parcel Info
Business Char
I? Roll Val - Extracted
-1
G r c e l t i a p I ~ r a c t ~ - i~iu b d i vi d e x Attached
~~
Property
ID/T
~ j Appgals
.
Street Name
I----r--r
.
..-A
9
0
1
2
0000253
000000254
000000255
1199291026092
1199291026093
1199291026094
1199291026095
1199291026096
1199291026097
1199291026047
A
A
A
A
A
A
A
5
5
5
000000259
000000260
1199291026100
1199291026101
5
5
1
r i:iok!l(irr:
,--pri
Start Search
~ I I Y ~
Property Address
Address k s t Changed
-A r~~

4040 E PIEDMONT DRSP93 HIGHLAND. a92346
4040 E PlEDMONTDRSP94 HIGHLAND. a92346
4040 E WEDMONT DRSP 97 HIGHLAND.CA 92346
4040 E PIEDMONT DRSPlOO HIGHLAND. a92346

4040 E PlEDMONTDRSP101 HIGHLAND. a92346
OME COMMUNITY
STUBBLEFIE
POOLE. THOMAS E
FAULISE. WTHRINE M
ROBERTA E MONHEY UVllilG TRUST
STIEFKEN. CHARLES R
JARRELL SR ROBERT W
No
Land Type Size
Ownership - Current
Use
BPS Aud Costs P Parael Infa

BPS R P costs
~
nc+,+d
B P S e-File
F Reviews
Business Char P R o l l V a l - E l r a d e d
--
~~
Dir
000000262
000000263
000000264
000000265
000000266
000000267
000000268
000000269
000000270
000000271
00272
00273
Sweet Name
1139291026103
1133291026104
1133291026105
1193231026106
1139231026107
1139231026100
1133291026109
1193231026110
1199291026111
1199291026112
1133291026113
119929102fi114
A
A
A
A
A
A
A
A
A
A
A
A
5
5
5
1
1
1
5
1
1
5
1

4040 E PIEDMONT DRSP105HlGHlAND. CA32346
4040 E PlEDMONTDRSPlOE HIGHLAND. CA9234fi
4040 E PIEDMONT D R S P I I O HIGHLAND. C432346
4040 E PIEDMONT D R S P 111 HIGHLAND. CA 32346
4040 E PIEDMONT DRSP113 H!GHlAND. CA92346
4040 E PIEDMONT D R S P 114 HIGHLAND. CA 32346

LOPEZ. LEILA P
ROSENBUSCH. FRANK E
BULLER LEWIS D
FlTZGERaLU, PAY B E N N E T
MOUNTAIN SHADOWS MOBILEHOME COMMU.
DORSEY. CAMILLE M
MT SHADOWS MOBILE HOME U3MMUNlTY
MTSHADOWS MOBILHOME COMMUNITY
CADY. WILLIAM
VACANT
~139-2g1-01-1gg2-
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Ownership - Current
is
BPS Aud Costs
Business Char
~~~
~~
~. .~~
~~~
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. . ~ ~...~
.
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v
Anached
..
~.
Gompany
Property ID ] TBA
-
000000275
000000276
000000277
000000278
000000279
000000280
000000281
000000282
000000283
000000284
000000285
000000286
Street Name
1199291026115
1199291026116
1193291026117
1199291026118
1199291026119
1199291 026120
1199291026121
1199291026122
1199291026123
1199291026124
1199291026049
1199291026050
1199291026125
A
A
A
A
A
A
A
A
A
A
A
A
A
5
1
1
1
1
1
5
5
5
5
5
1
4040 E PlEDMONTDRSP116 HIGHLAND. C492346

4040 E PlEDMONTDRSPll8 HIGHLAND. CA92346
4040 E PlEDMONTORSP119 HIGHLAND. C492346
4040 E PIEDMONT DRSP 120 HIGHLAND. C4 32346
4040 E PIEDMONT DRSP 121 HIGHLAND. CAW46
4040E PIEDMONT DRSP123 HIGHLAND. C492346
4040 E PIEDMONT DR SP 124 HIGHLAND. C492346
4040 E PlEDMONTORSP49 HIGHLAND. CA92346
4040E PIEDMONT DRSP50 HIGHUND, a92346
4040 E PIEOMONTDRSP 125 HIGHMND. a92346
Roll V d - Extraded
I ,ipp&k1 bcdiiI
Dir
Parcel Data
F Parcel Info
CHAPLINSKI. DORiS C
JOHNSON. ROBERTL
ARTECHE. JANICE I
JACINTO. MARTIN C
SAINTECLAIRE. KAREN L
MOUNTAIN SHADOWS MH PK
SHARP, LOUISEA
PFTERSON. WlLlARD P
r r
11199-291-01-1992
Land Type Size
Use
F Parael Data
i-------~. ,.
~~~
--. ...- .
000000288
000000289
000000290
000000291
000000292
000000293
000000294
000000295
000000296
000000297
1199291026127
1199291026128
1199291026129
1199291026130
1199291026131
1199291026132
1199291026133
1193291026134
1199291026135
1199291026136
ll99291026137
1199291026138
A
A
A
A
A
A
A
A
A
A
A
A
5
5
5
5
1
5
5
1
5
5
1
5
4040 EPIEDMONT DRSP127 HIGHLAND. CA92346

4040 E PlEDMONTDRSP128HIGHWND. CA92346
4040 E PlEDMONTDRSP129 HIGHLAND, CA92346
4040 C PlEDMONTDRSPl32 HIGHLAND. CA 92346
4040 E PlEDMONTDRSP136 HIGHWND. CA92346
4040 E PlEDMONTDRSP137 H!GHLAND. CA92346
CONWAY. SAM H
LlTEL JAMES G
BOUMA RlCKY L
DALY CANDACE K
TRICAS. LORRIE BOUTER
FOWLES. MARIANNA
MTSHADOWS MOBlL HOME COMMUNITY
DUANE HALEY1SHIRLEY ANN MELLINGERLV...
YORK GUY
Get NEXT 13
-4
..
--
Tools
.
~~. .
~
d
FAsSRPLG!M&I
Dir
000000300
000000301
000000302
000000303
000000304
000000305
000000306
000000307
000C00308
000000309
000000310
000000311
000000312
Parcel ~
1~
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, ~ i101
~TG
~
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ai v ~I 4ttached 1 ~ ~ ,Nb(
Street Name
11992910
1199291026140
1199291026141
1199291026142
1199291026143
1199291026144
1199291026145
11892910261 46
1199291026147
11992910261 48
1199291026149
1199291026150
1199291376151
A
A
A
A
A
A
A
A
5
5
5
1
5
1
5
5
1
A
A
5
5

4040 E FlEDMONTDRSP141 HIGHLAND. a92346
4040 E PIEDMONTDRSP 142 HIGHLAND. C432346
4040 E PIEDMONTDRSP 144 HIGHLAND, C492346
4040 EPlEDMONTDRSP147 HIGHLAND. C492346
4040 E PIEDMONT DRSP 148 HIGHLAND. C4 92346
4040 EPIEDMONTDRSP 149 HIGHLAND. CA92346
4040 EPlEDMONTDRSP151 HIGHLAND 0,97346
Matches were found, more d d a exisls
Cancel
I ~ p p e dIi~
G e t NEXT 13
BERRY. JUPNITA
SANDWICK D
MT SI IADOWS MH COMMUNITY
AL'ANCE. C4RL ROBERT
FREEMAN. MARVIN D
PETERSON. TOM
MT SHADOWS MOBILE HOME COMMUNllY
DICKERSOI\?CAROLR
SOUADYWDMMRLIVING TRUST
HENRY, BRlDGFT
DARBY. ROBERTL
BASHAM. PEGGY
~od
"I
~ o n Type
d
Sire
Use
I
r Disbid
1
Mailing Address
Assignment
A~,xVni:iec
17 Ownership -Current
BPS Aud Costs

BPS Rpt Costs
P Parcel Info
Business Char
F R o l l Val - Exhacted
r !?:nl!n?rim i~,,:,,,:
I
II
-~
Parcel Map
Dir
00000314
00000315
00000316
00000317
00000318
00000319
00000320
00000321
00000322
00000323
00000324
00000325
. .., ...~-
r a d Map
Subdiv
lndk/ &&hed
I ~ o & a & No 1 P;ope&lDJ~&+ '1
Reviews
pi gals I&NO
1
Street Name
1199291026051
1199291026152
1199291026153
1199291026154
1199291026155
1199291026156
1199291026157
1199291026158
1199291026159
1199291026160
1199291026161
1199291026162
1199291026163
A
A
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4040 E PIEDMONT DR SP 154 HIGHLAND, CA 92346
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4040 E MEDMONTDR SP161 HIGHLAND. CA92346
4040 E PlEDMONTDRSPI62HIGHLAND. C.492346
4040 E PlEDMONTDRSP163 HIGHLAND. C.492346

REED. ROBERTC
SMITH. CHARLES 0
A M S T A JOE N
SAGERMAN. B m L T R
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SEITZ. DEIDREA
LASBY. JAMES A
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DRIVER B E M R L Y A
BUSHONG. GER4LD E
JONES. BEATRICE
SANSOM. HAROLD D
STUBBLEFIELD. JOHN L
SIMS. ALVAL
KRAUSE. BARBAPA L
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STUCKY, GEWLD G
WHALE* MARY T
HANSEN DON C
MClrAGUE. GARY
COOK PAULE
TERWCE. CAROLINA
ROMER CHARLES A
MT SHADOWS MOBlLE HOME COMMUNITY
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4040 EPIEDMONTDRHIGHLAND, CA22346
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Mobile Home Community

1 4040 E. Piedmont Drive, Highland, California 92346
(909'1 862-2400
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89 Rodriguez
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98 Stiefken
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100B Davis
101 Kunz
Del Ray
1 101A Whittaker
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101B Ramirez
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105 Rosenbusch
Frank & Barbara
106 Buller .
Lewis & Mirial
107 Fitiperald
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128 Gray
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760-245-8915
129 Bouma
Rick
838-4640
130 Daly (Kimball) Candace
(626) 602-4083
131 Tricas
Lorrie
583-5828
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127 ,,J*,
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138 York
139
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141 Harps
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113 Avance
144 Stauffer
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149 Grasso
150 Darby
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_ Robert & Marge
RSteve 8 Linda
Thomas & Dawna
Ken W.8Souad
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153 Johnson
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155 &hez
156 Smith
157 Acosta
158 Conner
158A Diamond
158A Broadhead
158B Voss
158C d%r?;
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&Richard Jr. & Susan

Chuck & Barbara
Joe & Marie
Patricia.
Renee
Peggy
Mary Ann
Joe
Ruth
Deidre
James & Bonnie
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171 Grissom
171 SaIazar
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174 Forbes
175 Gregory
176 Whitney
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185 Gallo
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201 Richie
202 Sackett
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Stella
Bob & Sue
Robert
Elaine Plll/rnh
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Joe & Lupe
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863-1210
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203 Glasson
3 S*C&C
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207 Blair
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216
217
218
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Gerald & Shirley
Lee & Sheila
862-9644
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Richard
Peggy
Marjorie & Sherri
Elizabeth "Liz"
Beverly
Virginia
Hal & Hilda
Jean
518-4597Awc
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425-88 74
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633-3443
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242
243
243
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245
Arthur
RKim
Stucky
Gene
Henry
Steve
Whaley
Mary
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246 Cook
247 Terrace
248 R o y r
f-h m l # C
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254 Morris
255 Gordon 1
255A Smarte
256 Fontaine
I 257 Moore
258 Cervantes
259 lverson
FIRST NAME
PHONE NUMBER
Elaine
p 4
George
Charles & Meleanie
Greg & Carol
Arlind & Marleen
Bob
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Bob & Diann
Audrey
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264 Groszewski & ~ a n i e l & Sandy d
Dennis & Angela265 Sutherl'and
Rosemary B.
266 Krause
Rueben & Mary
267 Jones
Susan
268 Schwingel
Sam
269 Newcomer
Richard
270 Hynes
271 rnSrr2M CMike & Jeanette
272 Scott
Jim
273 Chenoski
Betsy
273 Voss
Robert & Maxine
274 McCaslin
Mike & Carol
275 Karas
Al & Carolyn
276 Bowie
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838-8655
864-6408
838-0910 m l r H C
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863-9039 f i s f l q
863-7584
425-2423
725-1821
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262-0635 f l f l k c
862-3118
425-5152
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864-0431
936-7572
S P # LAST NAME
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277
278
279
280
Sutherland
Bruno
Hammond
Mott-Smith
FIRST NAME
PHONE NUMBER
Dennis & Donna

Robert
Pam
Barbara
Thomas & Chris
Terry & Sue
Erlinda
Barbara
Diane
864-2672
425-1373
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Steve & Patricia (Pat)
Ray & Vicki*
Stella
Cynthia
4~ bf( ROY& Lori L e r CLI'ue
Jim & Gloria
Laura
Pat
Ed & Rene
I
Paulette
I'
Dick & Kay
1
Ralph & Dixie
Rosemary
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EXHIBIT-5
Minute
Order
pre
judge
1
2
3
4
5
6
7
DATE
JUDGE
8/27/2012
to be
assigned
Complaint -Civ 798.75[c] n/a as Bonnie Shipley is

not purchaser or transferee; no privity of contract
Wilfred
Schneider
Wilfred
Schneider
Wilfred
Schneider
Demurrer, Motion to Quash, MT-Strike as invalid

eviction based on code not applicable to Shipley
Motion to Reclassify to Unlmiited Jurisdiction as
value of property to be seized exceeds $25,000
P's Motion Compel Inspection of Inside of Duffy's
Mobilehome [goon squad to invade mobilehome]
Wilfred
Schneider
Wilfred
Schneider
Motion to Compel defense counsel to submit to

deposition against interest of her client Shipley
Motion to compel Shipley to deposition in Orange
County Hart|King office 1 hour driving distance
re-set to
Wilfred
Schneider
Motion to compel non-party Steve Allen to depo @

Hart|King - defective subpoena mail service
re-set to
11/16/2012
Wilfred
Schneider
Deny Inspection; award illegal $9,000 atty fees

against Shipley, Allen & McCarron pay by 1/1/13
Oct 2012 March 2013
Marsha
Slough
9/27/2012
10/4/2012
11/7/2012
11/7/2012
11/7/2012
11/7/2012
11/25/2012
8
9
10
11
12
13
14
15
of Hearing
Marsha
Slough,
Pre.Jug
assign to S31
Schneider
denied
Shipley
denied
Shipley
P knows it is a SHAM complaint because D's atty

notified P's atty of the SHAM by letter dated 8-3-12
notice of sham
D's complaint
PreJudge
ShamCmplt
1-7
1-13
Schneider overruled Demurrer, denies Motion to Quash

& Strike attorney fees
authethenticated evidence shows home value to be
seized exceeds $25,000 limited jurisdiction max
Duffy objected to motion brought on 5-days' notice-not
enough time to write opposition
Minute Order
Minute Order
Minute Order

Minute Order
Minute Order

Minute Order
$9,000
sanctions
shocking sanctons were illegal under the law and

unjustified; Duffy was forced to file Appeal
Minute Order
for Stubbleifeld
we demanded Slough answer if Kim Schneider is related to

Judge Schneider; Slough ignored 2 ltrs
1b Ltr 1 to Slough
1c Ltr 2 to Slough
extra
exhibits
Ltr1 69
Ltr2 20
was Plaintiff Tom Parrish's son's wife [Kim

Schneider] related to Judge Schneider?
Death Certificate
Tom Parrish son
extra
exhibits
only reasonable inference is they are related since

Slough refused to answer 2 letters
Minute Order
11/15
11/15
granted
Shipley complains to County Board Supervisors &

Slough re: Stubblfield use of courts to harass
Tom Parrish's son dies; surviving widow is Kim

Wilfred
Schneider Schneider [related to Judge Wilfred Schneider?
revoked
granted
9K sanction
vacated
Stubblfield
re-set
12/17/12
re-set
1/10/13
denied
Shipley
Shipley
12/13/2012
Donald
Alvarez
P's EX PARTE Motion OSC to Compel McCarron

to answer questions
MTC Videos by Shipley denied; P tells court that no
independent 3rd party reports presently exist
1/10/2013
Donald
Alvarez
Donald
Alvarez
Shipley's Motion for Judgment on the Pleadings

denied; not enough notice; past code deadline
Stubblefield's MSJ nestled inside "opposition" to D's
MJOP was improper to avoid MSJ filing fee
denied
1/10/2013
Donald
Alvarez
Trial Setting Conference continued due to MTC ;

reset to 2/27/13
re-set
2/27/13
1/10/2013
Donald
Alvarez
Donald
Alvarez
P's MTC is treated as timely (even though late); no

M&C or separate statement filed as required
P has until 1/14/13 to serve supplemental
pleading w/M&C and separate statement
re-set
2/27/13
re-set
2/27/13
4/6/2015
Pages
re-set to
Donald
Alvarez
1/10/2013
Exhibit
11/15
12/13/2012
17
Exhibit Name
11/15
Donna Garza Wilfred Schneider vacated $9,000 atty fee order

entered 11/16/12 atty fee issue is reserved
12/4/2012
Wilfred
recused himself-sua sponte-transferred case to
Schneider Donna Garza PJ, Civil Department
12/4/2012
D Garza Donna Garza reassigned to Donald Alvarez S32
12/5/2012
Donald
P's EX PARTE motion re-set trial on death of
Alvarez
Tom Parrish's step-son Joe Gallal
12/10/2012
Donald
MTC Videos is re-set to 12/17/12 10 am S32A;
Alvarez
estimated length of trial 3 days jury demanded
1/10/2013
19
RESULT
re-set to
12/3/2012
16
18
UDDS1204130 Stubblefield v. Shipley
denied
COMMENTS
is Tom Parrish's son's death related ?

Shipley's Motion to Compel Production of Secret Videos
taken of Shipley, Duffy, Allen, McCarron
Minute Order
Minute Order
10
11
1
1
trial readiness trailing date is set to 12/17/12
Minute Order
12
12/17/12 trial trailing date vacated; MTC Def. set for

1/10/13; trial setting conf set 1/10/13
trial setting conference date reset to 1/10/13
Minute Order
13
Minute Order
14
ruling was against the law; MJOP should have been

granted as a matter of law
D's "opposition" to P's improper MSJ nestled inside
its opposition to D's MJOP improper
Minute Order
15
Minute Order
16
Minute Order
17
Minute Order
18
Minute Order
19
P's motion will be limited only to issues raised in

the December 11, 2012 email sent
MTC should have been denied; passed cut-off,
without M&C & sep stmt; no sanctions
Case-History-Excel-3-19-15.xlsx
20
Minute
Order
21
22
23
24
25
1/14/2013
Donald
Alvarez
Court set OSC why it should hear P's MSJ before

P's 2/27/13 MTC; file directly in dept
re-set
1/22/13
aberation from judicial duties; court tried to shield

Stubblefield lawyer from malpractice
Minute Order
20
DATE
JUDGE
RESULT
of Hearing
COMMENTS
Exhibit Name
Exhibit
Pages
1/22/2013
Donald
Alvarez
1/31/2013
Donald
Alvarez
Donald
Alvarez
Court trained Williamson like a novice atty

couseled by experienced "clientadvocate"
Shipley's MSJ heard; matter ordered continued to
2/14/13 together with P's MSJ at same time
Plaintiff's MSJ heard; matter ordered continued to
2/14/13 together with D's MSJ at same time
BIAS
improper judical conduct; Alvarez stepped out of his

role as arbiter into role of advocate
Minute Order
21
Minute Order
22
Minute Order
23
Donald
Alvarez
Donald
Alvarez
P's and D's Joint MSJ heard together; denied all;

issue: does Duffy regularly occupy mobilehome
Alvarez should have granted summary judgment
under clear language of Civil 798.75[c]
Minute Order
24
Minute Order
25
2/21/2013
Donald
Alvarez
P's EX PARTE Motion re: TRO communicating with

employees re: request for preliminary injunction
Minute Order
26
2/27/2013
Donald
Alvarez
Donald
Alvarez
Donald
Alvarez
Donald
Alvarez
Donald
Alvarez
Donald
Alvarez
Donald
Alvarez
Donald
Alvarez
P's MTC Shipley, Allen, McCarron granted in part;

denied certain questions & documents
McCarron objection to question 1 overruled; grants
MTC response
CMC; Trial Setting Conference; P's MTC re-set
granted in
part
Minute Order
27
granted in
part
Minute Order
28
re-set
3/7/13
re-set
4/23/13
re-set
4/23/13
re-set
4/23/13
re-set
7/22/13
re-set
7/22/13
Minute Order
29
Minute Order
30
Minute Order
31
Minute Order
32
Minute Order
33
Minute Order
34
4/23/2013
Donald
Alvarez
P's Motion for Preliminary Injunction continued due

to stay awaiting ruling by Appellate Division
re-set
7/22/13
Minute Order
35
7/2/2013
Donald
Alvarez
Shipley's Motion for Atty Fees Stayed/appeal

pending
re-set
7/22/13
NO FEES
Minute Order
36
7/22/2013
Donald
Alvarez
Minute Order
37
Donald
Alvarez
re-set
10/21/13
re-set
10/21/13
NO FEES
7/22/2013
Shipley's Motion for Atty Fees Stayed/appeal

pending awaiting remittitur
Motion reconsider denial of MTC videos re-set; writ
still pending; case is stayed
Minute Order
38
7/22/2013
Donald
Alvarez
Minute Order
39
7/22/2013
Donald
Alvarez
Trial Setting Conference held;re-set due to stay; 4th.

re-set
District Ct-Appeal Denied P's writ prohibition
10/21/13
P's Motion for Preliminary Injunction continued due
re-set
to stay awaiting remittitur by Appellate Div
10/21/13
Minute Order
40
8/6/2013
Donald
Alvarez
P's EX PARTE Motion re: Stay of Enforcement ;

opposition to be filed by 8/12/13; reply 8/14/13
re-set
8/22/13
Minute Order
41
1/31/2013
2/14/2013
2/14/2013
26
27
28
29
30
31
32
33
34
35
2/27/2013
2/27/2013
3/7/2013
3/7/2013
3/7/2013
4/23/2013
4/23/2013
36
37
38
39
40
41
4/6/2015
re-set
2/14/13
re-set
2/14/13
court finds Civil Code 798.75[c] not limited to
purchaser/transferee; jury to decide facts
D's Motion to reconsider denial of MTC videos reset

due to stay issued by Appellate Division
Trial Setting Conference continued due to stay
issued by Appellate Division
P's Motion for Preliminary Injunction Heard; D's
counsel notifies court writ was granted & stay
Motion reconsider denial of MTC videos re-set; writ
still pending; case is stayed
Trial Setting Conference Held; re-set due to stay
re-set
3/7/13
no emergency; set for hearing; def. file opposition

by 2/25/13; P file reply by 2/27/13
Minute
Order
DATE
JUDGE
Exhibit Name
Exhibit
Pages
8/22/2013
Donald
Alvarez
P's EX PARTE Motion re: Stay of enforcement is rere-set

10/21/13
set as case presently still stayed
Minute Order
42
10/21/2013
Donald
Alvarez
Donald
Alvarez
Donald
Alvarez
P's motion is without merit due to CA Sup. Court

denying P's Petition and request for stay
D's Atty Fees to be heard after submitting prop
judgment to P's counsel via email/fax
Motion reconsider denial of MTC videos deemed
moot in light of writ mandate from Appellate Div
Minute Order
43
Minute Order
44
Minute Order
45
Donald
Alvarez
Donald
Alvarez
Donald
Alvarez
CMC/OSC Shipley's MSJ is granted in entirety;

defendant to prepare judgment
complaint dispositioned by judgment
Minute Order
46
Minute Order
47
P's Motion for Prel. Injunction deemed moot in light

of writ of mandate ruling
Minute Order
48
Donald
Alvarez
Donald
Alvarez
Atty Fee Motion 170.6 recusal request; Alvarez

recuses; transfer Michael Sachs
Notice given to Judiciial Asst. to give notice of case
transferrred to Michael Sachs S33
re-set
2/10/14
re-set
2/10/14
Minute Order
49
Minute Order
50
2/10/2014
Michael
Sachs
Court received proposed judgments from atty

McCarron; instructs P's counsel to submit jdgmt
re-set
2/19/14
Minute Order
51
2/19/2014
Michael
Sachs
Michael
Sachs
Michael
Sachs
Michael
Sachs
Michael
Sachs
Michael
Sachs
Michael
Sachs
Court review hybrid jgmt; p to send jgmt to def

re-set
counsel by 3/5/14; opposition filed by 3/12/14
3/17/14
Ct rec'd def. objections & P's response; court revised denied
jgmt; copy of notes given to counsel
Minute Order
52
Minute Order
53
Action complete; minute order end
Minute Order
54
Minute Order
55
Minute Order
56
Minute Order
57
Minute Order
58
Michael
Sachs
Michael
Sachs
Michael
Sachs
Michael
Sachs
Judgment UD Complaint <$10,000 filed 8/27/12 for

defendant Shipley against Stubblfeield
Atty McCarron states petition filed w/Appellate Court
4/8/14; continue to 6/16/14
Mot expunge lis pendens/award fees filed by P court
rec's call from McCarron - not present
Motion expunge lis pendens granted for
Stubblefield despite no jurisdiction as case on
appeal
mail
delivery confirmation shows ex parte papers
delivered 10:58 am; not put on calendar
refused to hear D's ex parte as P's lawyer not there;
ordered McCarron to return next day
D's ex parte Motion to replace electric pedestal and
gas meter promptly denied
P's EX PARTE Motion to continue hearing on D's
attorney fee motion to depose expert Joel Marks
P's EX PARTE Mot to re-set D's Atty Fee Mot set
3/18/15 after court approved "renotice" 11:19am
would not
hear
Minute Order
59
Minute Order
60
Minute Order
61
Michael
Sachs
P's EX PARTE re-set D's Atty Fee Mot set 3/18/15

after court approved "renotice" 11:19am
Minute Order
62
42
43
44
45
46
47
48
49
10/21/2013
10/21/2013
10/21/2013
10/21/2013
10/21/2013
1/7/2014
1/7/2014
50
51
52
53
54
55
56
57
58
3/17/2014
3/17/2014
3/20/2014
4/9/2014
6/16/2014
6/23/2014
9/8/2014
59
60
61
62
9/9/2014
9/17/2014
3/3/2015
3/4/2015
4/6/2015
RESULT
of Hearing
COMMENTS
NO FEES
NO FEES
Denied Shipley's Motion for Atty Fees w/out

prejuduce; more detail needed on fees
re-set
6/16/14
re-set
6/23/14
BIAS
finds jurisdiction for Stubblfield despite case stayed

on appeal, overrule Shipley objection
double standard
denied
BIAS
stayed
appeal
BIAS
finds no jurisdiction for Shipley as "case is stayed

on appeal" & fire unrelated to eviction proceedings
finds no jurisdiction for Shipley "on appeal" yet
expunged lis pendens for Stubblefield
granted
vacated
Minute
Order
1
2
3
DATE
10/14/2014
11/10/2014
JUDGE
RESULT
UDFS1406978 Stubblefield v. Duffy
Kyle Brodie CCP 170.6 filed as to Wilfred Schneider Kyle

Brodie reassigned case to HIMSELF
Kyle Brodie Demurrer, MTQ,MTS overruled, Duffy and Shipley
ordered to answer in five days
Exhibit Name
Exhibit
Pages
Minute Order
Minute Order
receipt $22
Minute Order
Minute Order
Minute Order
Minute Order
receipt $22
under
submissio
n
Minute Order
denied
Minute Order
10
under
submissio
n
Minute Order
11
Minute Order
12
Minute Order
13
receipt $22
14
Minute Order
15
Minute Order
16
receipt $22
17
receipt $60
18
Minute Order
19
receipt $120
20
Minute Order
21
Minute Order
22
receipt $60
23
answer 5
days
12/19/2014
granted
Stubblefield
denied
Shipley
should have denied; Shipley & McCarron already

deposed 3 days in UDDS1204130
should have been granted
Shipley
should have been granted
12/31/2014
12/31/2014
Victor Stull D's Motion Transfer Jurisdiction to Unlimited
denied
Victor Stull D's Motion to Compel Further Responses with

Separate Statement filed against Stubblfield
Victor Stull
Nancy Duffy paid $22 for audio CD 12/31/14
granted
only 1
12/31/2014
1/5/2015
1/29/2015
Kyle Brodie
MTC Timothy McCarron to Appear, Testify

1/29/2015
Kyle Brodie
10
telephonic appearance denied basis: no setup

1/29/2015
Kyle Brodie
MTC Inspection; request sanctions
11
1/29/2015
Kyle Brodie Nancy Duffy's request for stay pending writ
denied
1/29/2015
Kyle Brodie Mot to Dismiss Lack Subject Matter Jurisdiction
denied
14
1/29/2015
Kyle Brodie Nancy Duffy paid $22 for audio CD for 1/19/15
15
1/30/2015
Kyle Brodie Hearings set for 2/3/15 continued to 2/10/15
2/10/2015
Kyle Brodie P's MTC Documents and Responsed to

Interrogatories + Terminating sanctions
2/13/2015
Kyle Brodie Nancy Duffy paid $22 for audio CD of 2/10/15
2/18/2015
Lily Sienfeld
2/19/2015
Lily Sienfeld Ex parte motion TRO is denied w/out prejudice
20
3/2/2015
Kyle Brodie Stubblfield paid $120 for two motions
21
3/2/2015
Kyle Brodie MTC Tomothy McCarron is denied
3/6/2015
Kyle Brodie Motions Under submission 2/10/15 vacated; motions

set for 3/18/15 moved to Sachs S28
Kyle Brodie Stubblefield paid filing fee for 2 motions
12
13
16
17
18
under
submissio
n
23
3/12/2015
4/6/2015
should have issued stay pending appeal

should have transferred to unlimited jurisdiction
damages sought exceed $25,000
should have granted - never ruled on any of D's 3

motions, vacated all 3; transferred case
Stubblfield pays filing fee for TRO re: prel. Injunc

denied
19
22
demurrer should have been sustained and case

ordered transferred to justice cener
Kyle Brodie Nancy Duffy paid $22 for audio CD 11/10/14
COMMENTS
11/14/2014
Kyle Brodie P'as MTC McCarron & Shipley to Appear for

Deposition in Orange County for second time
Victor Stull D's Motion Set Aside Default Improperly taken
of Hearing
TRO was never served on McCarron; no phone

notice; hearing w/out her knowledge
denied
1st
1
Writ
UDDS1204130-Stubblefield v. Shipley
WRITS AND APPEALS 10/9/2012 to 3/19/2015
CIVDS1210511 - BONNIE SHIPLEY -V- SUPERIOR COURT
UDDS1204130
10/26/2012 FILE RCVD IN SB & FILED BACK
10/22/2012 CASE DISPOSITIONED-JUDGEMENT WITH DECISION
10/22/2012 STAGE AT DISPOSITION: ALL OTHER JUDGMENTS BEFORE TRIAL.
10/22/2012 ORDER DENYING PETITION FOR WRIT OF MANDATE FILED
10/9/2012 PETITIONERS APPENDIX - VOL 2 FILED
10/9/2012 PETITIONERS APPENDIX - VOL 1 FILED
10/9/2012 DECL PETNRS COUNSEL RE: ORDERING TRANSCRIPT OF HEARINGS, ORDER ORVERRULING
NotDEMURRER
Applicable & DENY TRNSFR
10/9/2012 UNDERLYING CASE UDDS1204130 - SAN BERNARDINO
10
10/9/2012 NOTICE OF RELATED CASES FILED
11
10/9/2012 PETITION FILED (CIVIL)
2nd CIVDS1302013-BONNIE SHIPLEY-v-SUPERIOR COURT (Writ Alvarez-denied MSJ)

1
Writ Petition
DENIED
Writ Petition
Granted
(Writ Petition Wilfred Schneider - Overrule Demurrer, Deny MTQ, MTS Complaint)
10/21/2013 NOTICE OF POS BY PERSONAL DELIVERY TO JUDGE ALVAREZ AND RETURN OF WRIT OF MANDATE FILED.
8/20/2013 RECEIVED SUPREME COURT ORDER DENYING PETITION FOR REVIEW AND APPLICATION FOR STAY PLACED IN FILE
8/13/2013 WRIT OF MANDATE FILED.
8/13/2013 NOTICE ON DECISION OF REMITTITUR PRINTED
8/13/2013 REMITTITUR ISSUED AND FILED. DECISION: ORDER DISMISSING APPEAL FILED ON 05/06/13.
8/9/2013 ORDER FOR RECALL OF REMITTITUR ISSUES 7/22/13 FILED
8/5/2013 ANSWER TO PETITION FOR REVIEW PLACED IN FILE
10
7/25/2013 SERVICE COPY OF PETITION FOR REVIEW PLACED IN FILE
11
12
7/22/2013 REMITTITUR ISSUED AND FILED. DECISION: OPINION FILED ON 05/06/13.
13
7/22/2013 REQUEST FOR IMMEDIATE RECUSAL OF JUDGE ALVAREZ BEFORE RULING ON ANY PENDING
NotMOTIONS
ApplicablePLACED IN FILE
14
7/22/2013 NOTICE OF ENTRY OF ORDER FROM FOURTH DISTRICT COURT OF APPEAL-DIVISION 2 PLACED IN FILE
15
7/19/2013 OPINION RECEIVED FROM THE COURT OF APPEALS AND ROUTED TO S32.
16
7/19/2013 DCA ORDER RE: PETITION FOR WRIT OF MANDATE/ PROHIBITION/CERTIORARI DENIED; STAY IS LIFTED PLACED IN FILE
17
7/8/2013 SERVICE COPY OF OBJECTIONS TO REPLY PLACED IN FILE
18
7/5/2013 PETITIONERS MEMO 0F P&AS IN REPLY TO REAL PARTY IN INTERESTS OPPOSITION TO PETITION PLACED IN FILE
19
6/26/2013 DCA ORDER RE: FILING FEE WAIVED PLACED IN FILE
20
6/24/2013 OPPOSITION TO PETITION FOR WRIT OF MANDATE, PROHBITION AND/OR CERTIORARI PLACED IN FILE
21
6/11/2013 SERVICE COPY OF AMENDED PROOF OF SERVICE PLACED IN FILE
22
4/6/2015
6/6/2013 COPY OF ORDER STAYING ALL PROCEEDINGS INCLUDING ISSUANCE OF A REMITTITUR PLACED IN FILE
23
6/4/2013 ORDER RECEIVED FROM DCA STAYING ALL PROCEEDINGS INCLUDING ISSUANCE OF A REMITTITUR PLACED IN FILE
24
6/3/2013 PETITIONERS EXHIBITS TO PETITION FOR WRIT OF MANDATE - VOLUME 4 PLACED IN FILE
25
26
27
28
6/3/2013 PETITION FOR WRIT OF MANDATE, PROHIBITION AND/OR CERTIORARI OR OTHER APPROPRIATE
Not Applicable
RELIEF PLACED IN FILE
29
5/14/2013 PETITIONERS OPPOSITION TO REAL PARTYS MOTION TO STRIKE BRIEFS FILED AFTER APRIL 9, 2013 FILED.
30
5/7/2013 REAL PARTY IN INTERESTS MOTION TO STRIKE BRIEFS FILED AFTER APRIL 9, 2013 FILED.
31
5/6/2013 OPINION- PETITION GRANTED FILED.
32
4/29/2013 AMENDED POS TO OBJECTION TO PET REPLY TO RPIS OPPOSITION TO WRIT OF MANDATE FILED. (IMAGED)
33
4/25/2013 AMENDED PROOF OF SERVICE TO OBJECTION TO PETITIONERS REPLY TO RPI OPP TO WRIT
NotOF
Applicable
MANDATE FILED. (IMAGED)
34
4/25/2013 PETITIONERS SUPP REPLY TO REAL PARTYS OBJ TO PETITIONERS REPLY TO OPP TO WRIT OF MANDATE FILED.
35
4/22/2013 OBJECTION TO PETITIONERS REPLY TO REAL PARTY IN INTERESTS OPPOSITION TO WRIT OF MANDATE FILED.
36
4/15/2013 REPLY TO REAL PARTYS OPPOSITION TO WRIT OF MANDATE FILED.
37
4/9/2013 OPPOSITION TO WRIT OF MANDATE; MEMORANDUM OF POINTS AND AUTHORITIES; EXHIBITS FILED.
38
3/28/2013 REAL PARTY IN INTERESTS NOTICE OF INTENT TO FILE OPPOSITION TO THE ORDER OF 3/26/13 FILED.
39
3/27/2013 ORDER DENYING APPLICATION FOR CLARIFICATION AND FOR IMMEDIATE STAY FILED
40
3/26/2013 ORDER GRNTG TRIAL COURT OPPORTUNITY TO VACATE ORDER OF 2/14/13 AND ISSUE A NEW
Not Applicable
ORDER GRANTING MSJ FILED
41
3/14/2013 OPPOSITION SENT TO RANCHO LEGAL RESEARCH FOR REVIEW
42
3/14/2013 OPPOSITION TO REAL PARTYS APPLICATION FOR CLARIFICATION AND IMMEDIATE RELIEF FROM STAY FILED.
43
3/12/2013 APPLICATION FOR CLARIFICATION AND DECL IN SUPPORT OF APPLICATION SENT TO RANCHO LR
44
3/12/2013 DEC OF ROBERT G. WILLIAMSON, JR. WITH EXHIBITS IN SUPPORT OF APPLICATION FILED. (IMAGED)
45
3/12/2013 APPLICATION FOR CLARIFICATION OF AND IMMEDIATE RELIEF FROM STAY FILED.
46
3/5/2013 ORDER GRANTING STAY PENDING FURTHER CONSIDERATION OF THE PETITION FOR WRIT OF MANDATE FILED
47
2/27/2013 PETITIONERS APPENDIX VOLUME III FILED.
48
2/27/2013 UNDERLYING CASE # UDDS 1204130 - SAN BERNARDINO
49
2/27/2013 PETITION FILED (CIVIL)
3rd
CIVDS1403933-Bonnie Shipley v Superior Court UDDS1204130 OSC in re Contempt Michael Sachs (inserted or resident into Civil 798.75[d] recited in final judgment)
7/2/2014 PETITIONERS APPLICATION TO CERTIFY APPELLATE DIVISION APPEAL TO 4TH APPELLATE

Not Applicable
DISTRICT PLACED
IN FILE
UDDS1204130-Stubblefield
v. Shipley
6/23/2014 ORDER FROM SUPREME COURT DENYING PETITION FOR REVIEW AND APPLICATION Not
FORApplicable
STAY PLACED IN FILE
6/20/2014 PETITION FOR REVIEW PLACED IN FILE
6/17/2014 PETITION FOR REVIEW PLACED IN FILE
6/16/2014 APPELLATE ORDER RE TRANSFER OF APPEAL IS DENIED FILED AND FORWARDED TO COURTHOUSE
DENIED
6/9/2014 ORDER DENYING PETITIONERS APPLICATION FOR CERTIFICATION AND TRANSFER FILED
7
8
Writ Petition
6/4/2014 ORDER DENYING PETITION FOR WRIT OF REVIEW REQUEST FOR IMMEDIATE STAY PLACED IN FILE
5/29/2014 PROOF OF SERVICE
Not Applicable
OF MOTION TO TRANSFER APPEAL TO 4TH DISTR, DIV 2 BY MAIL ON 05/19/14 AS TO RESPONDENT AND TRIAL COURT, FILED.
4/6/2015
5/28/2014 STAY REQUESTED WRIT OF REVIEW PLACED IN FILE
10
5/22/2014 LETTER RE: POS ON APPLICATION FOR TRANSFER PLACED IN FILE
11
5/21/2014 PETITIONERS APP TO CERTIFY APPELLATE DIVISION APPEAL TO 4TH APPELLATE DIST - DIV 2 FILED.
12
5/21/2014 DCA ORDER- PAYMENT OF THE STATUTORY FILING FEE- WAIVED UNDER RULE 8.100(B)-Not
PLACED
Applicable
IN FILE
13
14
15
5/6/2014 ORDER DENYING PETITION FOR WRIT OF MANDATE FILED
16
4/21/2014 PROOF OF SERVICE OF WRIT PETITION AND SUPPORTING DOCUMENTS BY MAIL ON 04/17/14 AS TO SAN BERNARDINO TRIAL COURT & COUNSEL FOR RPI, FILED
17
4/14/2014 ATTY FROM HART KING & COLDREN (RPI) CALLED - NEVER RECEIVED A COPY OF WRIT PET
Not Applicable
FROM PETITIONER
18
4/9/2014 WAIVER FILED ON THIS DATE FOR COURT OF APPEAL OR SUPREME COURT
REQUEST
FOR WAIVER OF COURT FEES AND COSTS FILED BY BONNIE SHIPLEY IS GRANTED
19
4/9/2014
20
4/9/2014 ORDER ON COURT FEE WAIVER GRANTED FILED.
21
4/8/2014 ORDER DENYING REQUEST FOR IMMEDIATE STAY FILED
22
4/7/2014 CIVIL CASE COVER SHEET FILED.
23
4/7/2014 REQUEST FOR WAIVER OF COURT FEES & COSTS FILED BY BONNIE SHIPLEY.
24
4/7/2014 WRIT PETITION AND SUPPORTING DOCUMENTS SENT TO RANCHO LEGAL RESEARCH FOR REVIEW
25
4/7/2014 REQUST FOR JUDICIAL NOTICE FILED.
26
4/7/2014 EXHIBITS 1-19 SUPPORTING PETITIONERS VERIFIED COMPLAINT AND PETITION FOR OSC FILED.
27
4/7/2014 SUPERIOR COURT CASE #UDDS 1204130-SAN BERNARDINO
28
4/7/2014 COMPLAINT FILED
4th
ACIAS1400026-Stubblefield v Shipley UDDS1204130 Michael Sachs (inserted words or resident into Civil 798.56[d] in final judgment
2/3/2015 CASE STATUS SET TO CLOSED
Writ Petition
DENIED
2/3/2015 REMITTITUR ISSUED AND FILED. DECISION: PER CURIUM OPINION FILED ON 12/22/14.
12/22/2014 APPEAL JUDGMENT IS AFFIRMED AS MODIFIED
12/22/2014 JUDGMENT WITH OPINION
HEARING
ONS37P
APPEAL - Minutes
12/19/2014 1:30
PM DEPT.
11/21/2014 1:30
HEARING
PM DEPT.
ONS37P
VACATED
APPEAL
11/18/2014 NOTICE OF HEARING ON APPEAL PLACED IN FILE
10
10/24/2014 CASE PREPARED FOR DECEMBER CALENDAR.
11
10/24/2014 VACATE AHOA HEARING SCHEDULED FOR 11/21/14 AT 01:30 IN DEPARTMENT S37P.
12
10/24/2014 ORDER VACATING APPELLATE HEARING CURRENTLY SET FOR 11/21/14 FILED
13
10/17/2014 NOTICE OF HEARING ON APPEAL PLACED IN FILE
14
10/14/2014 APPELLANT'SNot
REPLY
Applicable
BRIEF FILED.
15
REVERSED)
10/3/2014 CASE PREPARED FOR NOVEMBER CALENDAR.
4/6/2015
16
10/3/2014 APPELLANT'S REPLY BRIEF DUE 10/23/14
10/3/2014 RESPONDENT'S BRIEF FILED.
9/26/2014 ORDER DENYING APPELLANTS MOTION TO AUGMENT RECORD ON APPEAL FILED
9/8/2014 RESPONDENT'S BRIEF DUE 10/08/14
9/8/2014 MOTION TO AUGMENT THE RECORD FILED.
9/8/2014 APPELLANT'S OPENING BRIEF FILED.
8/12/2014 APPELLANT'S OPENING BRIEF DUE 09/11/14
8/12/2014 NOTICE OF BRIEFING SCHEDULE FILED.
7/31/2014 RECORD ON APPEAL FILED - CT 1 VOL / RT 1 VOL
4/15/2014 SUPERIOR COURT CASE #UDDS 1204130-SAN BERNARDINO
10
4/15/2014 NOTICE OF FILING OF NOTICE OF APPEAL
5th
CIVDS1417078-Shipley v Superior Court UDFS1406978 KYLE BRODIE (WritDemurrer, MTQ, MTS)
1
2
3
4
1/28/2015
12/30/2014
12/19/2014
12/12/2014
12/10/2014 ORDER DENYING PETITION FOR WRIT OF MANDATE AND STAY OF THE ACTION FILED
Writ Petition
DENIED
12/4/2014 TRANSCRIPT OF 11/10/14 ELECTRONIC RECORDING FILED.
11/14/2014 MOTION FOR APPELLATE PANEL TO TAKE JUDICIAL NOTICE FILED.
10
11/14/2014 EXHIBITS TO WRIT PETITION FILED.
11
11/14/2014 FILING FEE WAIVED ON BONNIE SHIPLEY FOR WRIT PETITION IN THE AMOUNT OF $225.00.
12
11/14/2014 REQUEST FOR WAIVER OF COURT FEES AND COSTS FILED BY BONNIE SHIPLEY IS GRA
13
11/14/2014 ORDER ON COURT FEE WAIVER GRANTED FILED.
14
11/14/2014 REQUEST FOR WAIVER OF COURT FEES & COSTS FILED BY BONNIE SHIPLEY.
15
16
11/14/2014 SUPERIOR COURT CASE #UDFS1406978-FONTANA

11/14/2014 COMPLAINT FILED
6th
AFTER SUMMARY DENIAL OF WRIT PETITION TO COURT OF APPEAL PLACED IN FILE

COURT OF APPEAL ORDER-PETITION FOR WRIT OF MANDATE REQUEST FOR IMMEDIATE STAY DENIED- PLACED IN FILE
COURT OF APPEAL ORDER- FILING FEE WAIVED- PER CRC 8.100(B)- PLACED IN FILE
APPELLATE ORDER PETITION FOR WRIT OF MANDATE IS DENINED FILED AND FORWARDED TO COURTHOUSE
CIVDS1502107-Shipley v Superior Court UDFS1406978 KYLE BRODIE (Writ-Denied Motion to Transfer Jurisdiction)
1
2
3
4
3/9/2015
3/9/2015
3/9/2015
3/9/2015
CASE DISPOSITIONED-JUDGEMENT WITH DECISION

STAGE AT DISPOSITION: ALL OTHER JUDGMENTS BEFORE TRIAL.
APPELLATE ORDER ON PETITION FOR WRIT OF MANDATE - DENIED FILED AND FORWARDED TO COURTHOUSE
ORDER DENYING PETITION FOR WRIT OF MANDATE FILED
2/17/2015 EXHIBITS - PETITION FOR WRIT OF MANDATE AND OR PROHIBITION OR REVIEW - VOLUME 1 0F 1 (1-7) FILED.
6
7
8
9
2/17/2015
2/17/2015
2/17/2015
2/17/2015
4/6/2015

Writ Petition
DENIED
FILING FEE WAIVED ON BONNIE SHIPLEY FOR FILING FEE ON WRIT OF MANDATE IN THE AMOUNT OF $225.00.
REQUEST FOR WAIVER OF COURT FEES AND COSTS FILED BY BONNIE SHIPLEY IS GRANTED
REQUEST FOR WAIVER OF COURT FEES & COSTS FILED BY BONNIE SHIPLEY.
COMPLAINT FILED
EXHIBIT 6,
Page 1 of 5
most recent 100 documents
1-100
DOCKET ACTIONS
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Page 5 of 5 last 28 of 428 docket entries
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Page 1 of 2 133 docket entries 10/3/14-3/26/15
UDFS1406978 Stubblefield v. Nancy Duffy & Bonnie Shipley
Page 2 of 2 133 docket entries 10/3/14-3/26/15
UDFS1406978 Stubblefield v. Nancy Duffy & Bonnie Shipley
EXHIBIT 7
3/14/2015
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UDDS1204130MinuteOrdersSanBernardinoMain
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CaseUDDS1204130STUBBLEFIELDVSHIPLEY
Action: (Choose)
MOTIONRE:DEMURRER*FILEDBYDEFENDANTBONNIESHIPLEY
09/27/20127:30AMDEPT.S31
WILFREDJ.SCHNEIDER,JUDGE
CLERK:KATHLEENSAENZ
COURTREPORTERCRAIGANDERSON11800
COURTATTENDANTKRISTINCORNETT
09:01
APPEARANCES:
ATTORNEYROBERTGWILLIAMSONJRPRESENTFORPLAINTIFF/PETITIONER.
ATTORNEYNANCYDUFFYMCCARRONPRESENTFORDEFENDANT/RESPONDENT.
DEFENDANTBONNIESHIPLEYPRESENT
PROCEEDINGS:
PREDISPOSITIONHEARINGHELD
MOTION
BONNIESHIPLEY'SMOTIONTODEMURRERTOPLAINTIFFSCOMPLAINTISHEARD.
THECOURTHASREADANDCONSIDEREDTHEDEMURRERANDALLOPPOSITIONANDREPLIES.
AFTERTESTIMONYANDDUECONSIDERATIONBYTHECOURT:
MATTERTAKENUNDERSUBMISSION.
SUBSEQUENTLY,NOTREPORTED:
COURTRULESASFOLLOWSONSUBMITTEDMATTER:
DEFENDANTSMOTIONTOQUASHISDENIEDDEFENDANTSMOTIONTOSTRIKEISDENIED.
DEMURRERISOVERRULED
THECOURTORDERSTOANSWERTHECOMPLAINTWITHIN5DAYSOFRECEIVINGNOTICEOFTHE
COURTSORDER.
NOTICETOBEGIVENBYPLAINTIFF.
CLERK'SOFFICETOGIVENOTICETOALLPARTIESOFTHECOURTSRULING.
ACTIONCOMPLETE
===MINUTEORDEREND===
http://openaccess.sbcourt.org/OpenAccess/civil/civilminutes.asp?courtcode=X&casenumber=DS1204130&casetype=UD&dsn=&actionseq=2&actiondate=201
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MOTIONRE:TRANSFERJURISDICTION*FILEDBYDEFENDANTBONNIESHIPLEY
10/04/20128:30AMDEPT.S31A
WILFREDJSCHNEIDERJR.,JUDGE
CLERK:TRENESHABEAMON
08:20
APPEARANCES:
ATTORNEYROBERTWILLIAMSONJR.APPEARSBYCOURTCALLFORSTUBBLEFIELDPROPERTIESA
CAGENERALPARTNER.
PROCEEDINGS:
WITNESSBONNIESHIPLEY,DEFENDANTISSWORNANDEXAMINED.
MOTION
BONNIESHIPLEY'SMOTIONRE:TRANSFERJURISDICTIONISHEARD.
THECOURTHASREADANDCONSIDEREDTHEMOVINGPAPERSANDOPPOSITIONPRESENTED.
ARGUEDBYCOUNSELANDSUBMITTED.
COURTFINDS:
SUBSEQUENTLYNOTREPORTED
BONNIESHIPLEY'SMOTIONRE:TRANSFERJURISDICTIONISDENIED.
CLERK'SOFFICETOGIVENOTICEOFTHECOURTSRULING.
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MOTIONRE:MOTIONFORANORDERTOCOMPELINSPECTIONREQUESTFOR
MONETARYSANCTIONSFILEDBYPLAINTIFFSTUBBLEFIELDPROPERTIESACA
GENERALPARTNER
11/07/20127:30AMDEPT.S31
CLERK:KATHLEENSAENZ
08:39
APPEARANCES:
PROCEEDINGS:
MOTION
STUBBLEFIELDPROPERTIESACAGENERALPARTNER'SMOTIONTOCOMPELINSPECTIONAND
REQUESTFORSANCTIONSISHEARD.
COURTFINDS:
THECOURTORDERSTHEFOLLOWINGBRIEFINGSCHEDULE:ANYFURTHEROPPOSITIONBY
DEFENDANTISDUEONOR
BEFORE11/9/12ANYREPLYTOFURTHEROPPOSITIONISDUEONORBEFORE11/14/12.THIS
MATTERSHALL
BEDEEMEDSUBMITTEDON11/15/12.
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MOTIONRE:COMPELNANCYDUFFYMCCARRONTOAPPEAR*FILEDBYPLAINTIFF
STUBBLEFIELDPROPERTIESACAGENERALPARTNER
11/07/20127:30AMDEPT.S31
CLERK:KATHLEENSAENZ
08:39
APPEARANCES:
PROCEEDINGS:
MOTION
STUBBLEFIELDPROPERTIESACAGENERALPARTNER'SMOTIONTOCOMPELNANCYDUFFY
MCCARRONSDEPOSITIONISHEARD.
COURTFINDS:
DEFENDANTISDUEONOR
MATTERSHALL
INTHEEVENTTHATTHECOURTORDERSDEPOSITION(S),THECOURTDESIGNATED11/26/12ASTHE
DATE,WITH
THEDEPOSITION(S)TOBESEQUENTIALBEGINNINGWITHTHEDEPOSITIONOFBONNIESHIPLEY.
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MOTIONRE:COMPELBONNIESHIPLEYTOAPPEAR*FILEDBYPLAINTIFF
11/07/20127:30AMDEPT.S31
CLERK:KATHLEENSAENZ
08:39
APPEARANCES:
PROCEEDINGS:
MOTION
STUBBLEFIELDPROPERTIESACAGENERALPARTNER'SMOTIONTOCOMPELBONNIESHIPLEYS
DEPOSITIONISHEARD.
COURTFINDS:
DEFENDANTISDUEONOR
MATTERSHALL
DATE,WITH
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MOTIONRE:COMPELNONPARTYSTEPHENC.ALLENFILEDBYDEFENDANT
11/07/20127:30AMDEPT.S31
CLERK:KATHLEENSAENZ
08:39
APPEARANCES:
PROCEEDINGS:
MOTION
STUBBLEFIELDPROPERTIESACAGENERALPARTNER'SMOTIONTOCOMPELSTEPHENCALLENS
DEPOSITIONISHEARD.
COURTFINDS:
DEFENDANTISDUEONOR
MATTERSHALL
DATE,WITH
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RULINGONSUBMITTEDMATTER
11/16/20127:30AMDEPT.S31
WILFREDJSCHNEIDERJR.,JUDGE
CLERK:TRENESHABEAMON
NOTREPORTED
ASTOPLAINTIFFSDISCOVERYMOTION:
PLAINTIFFSMOTIONSTOCOMPELTHEDEPOSITIONSOFBONNIESHIPLEY,STEVENC.ALLENAND
NANCYDUFFY
MCCARRONAREGRANTED.
THEDEPOSITIONSSHALLCOMMENCEONNOVEMBER26,2012AT9:30AMATTHELAWOFFICESOF
PLAINTIFF
WITHBONNIESHIPLEYSDEPOSITIONTOPROCEEDFIRSTANDTHEOTHERTWODEPONENTS
DEPOSITIONS
TOCOMMENCEIMMEDIATELYATTHECONCLUSIONOFMS.SHIPLEYSDEPOSTION,ONEAFTERTHE
OTHER.
PLAINTIFFISAWARDEDATTORNEYSFEESINTHEAMOUNTOF$9,000.00TOBEPAIDONORBEFORE
JANUARY1,
2013.
PLAINTIFFSMOTIONTOCOMPELINSPECTIONISDENIED.DEFENDANTSHIPLEYISAWARDED
ATTORNEYS
FEESINTHEAMOUNTOF$2,500.00TOBEPAIDONORBEFOREJANUARY1,2013.
NOTICEGIVENBYJUDICIALASSISTANT
CORRESPONDENCECOVERSHEETGENERATEDTOMAILCOPYOFMINUTEORDERDATED11/16/12
TOCOUNSELOFRECORD.
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EXPARTEHEARINGRE:ORDERREGARDING11/16/12ORDERRE:ATTYFEES
12/03/20127:30AMDEPT.S31
CLERK:KATHLEENSAENZ
NOTREPORTED
ONTHECOURTSOWNMOTION,THECOURTVACATESITSPREVIOUSORDERFORATTORNEYSFEES
INFAVOROF
THEPLAINTIFFANDINFAVOROFTHEDEFENDANT,CONTAINEDINITSRULINGON11/16/12.
THEISSUEOFATTORNEYSFEESISRESERVED.
CORRESPONDENCECOVERSHEETGENERATEDTOMAILCOPYOFMINUTEORDERTOCOUNSELOF
RECORD.
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EXPARTEHEARINGRE:RECUSAL
12/04/20127:30AMDEPT.S31
CLERK:KATHLEENSAENZ
NOTREPORTED
PROCEEDINGS:
JUDGEWILFREDJSCHNEIDERRECUSESSELFFROMCASE.THEABOVECASEISHEREBY
FORWARDEDTOSUPERVISING
CIVILJUDGEDONNAGGARZAFORREASSIGNMENT.
CORRESPONDENCECOVERSHEETGENERATEDTOMAILCOPYOFMINUTEORDERTOCOUNSELOF
RECORD.
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HEARINGRE:REASSIGNMENTOFCASEDUETORECUSAL
12/04/20128:30AMDEPT.S31
DONNAGUNNELLGARZA,JUDGE
CLERK:KIMALLAIN
NOTREPORTED
COURTATTENDANTBRANDONAUTEN
APPEARANCES:
NOAPPEARANCE.
PROCEEDINGS:
JUDGEWILFREDJ.SCHNEIDERRECUSESSELFFROMTHEABOVEENTITLEDCASETHISDATE.
CASEIS
REASSIGNEDPERCASESPLITTOJUDGEDONALDALVAREZSITTINGINDEPARTMENTS32FORALL
PURPOSES.
ALLHEARINGSINTHISCASEWILLREMAINASSETANDNOWBEHEARDINDEPARTMENTS32.
CORRESPONDENCECOVERSHEETGENERATEDTOMAILCOPYOFMINUTEORDERREASSIGNING
CASETOCOUNSELOFRECORD.
ACTIONCOMPLETE
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MOTIONRE:TOCOMPELPRODUCTIONDOCUMENTSANDVIDEOSFILEDBY
DEFENDANTBONNIESHIPLEY
12/05/20128:30AMDEPT.S32A
DONALDALVAREZ,JUDGE
CLERK:STEPHANIECHANDLER
COURTREPORTERDEBORAHTHOMPSON7079
COURTATTENDANTERICASHE
APPEARANCES:
ATTORNEYROBERTWILLIAMSONPRESENTFORPLAINTIFF/PETITIONER.
ATTORNEYNANCYDUFFYMCCANNONPRESENTFORDEFENDANT/RESPONDENT.
MOTION
BONNIESHIPLEY'SMOTIONTOCOMPELPRODUCTIONOFDOCUMENTSANDVIDEOSISHEARD.
ITISNOTEDTHATTHECOURTJUSTRECEIVEDTHISFILELATEYESTERDAYANDORDERSTHIS
MATTERAS
WELLASPLAINTIFFSEXPARTETOCONTINUETRIALCONTINUEDTO12/10/12AT8:30AMIN
DEPARTMENT
S32.
HEARINGS:
CURRENTHEARINGCONTINUEDTO12/10/12AT08:30INDEPARTMENTS32.
VACATEXPMHEARINGSCHEDULEDFOR12/06/12AT08:30INDEPARTMENTS32.
HEARINGRE:EXPARTEMOTIONTOCONTINUETRIALBYPLAINTIFFSETFOR12/10/12AT08:30IN
DEPARTMENTS32.
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COURTTRIALSETNOTICESENTTOPARTIES.ESTIMATEDTRIALLENGTH08:00
HRS.
12/10/20128:30AMDEPT.S32
DONALDALVAREZ,JUDGE
COURTREPORTERDEBORAHTHOMPSON7079
APPEARANCES:
PROCEEDINGS:
COURTTRIALPROCEEDS.
MATTERORDEREDCONTINUED
REASON:COURTTORULEONMOTIONTOCOMPEL
HEARINGS:
CURRENTHEARINGCONTINUEDTO12/17/12AT10:00INDEPARTMENTS32A.
ESTIMATEDLENGTHOFTRIAL3DAY(S).
JURYDEMANDEDBYDEFENDANT.
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EXPARTEMOTIONREAPPLICATIONFORORDERTOCOMPLE
DEFENDANTS/COUNSE
12/13/20128:30AMDEPT.S32A
DONALDALVAREZ,JUDGE
COURTREPORTERSTACEYDETTMERS13303
APPEARANCES:
PROCEEDINGS:
EXPARTEHEARINGISHELD.
EXPARTEAPPLICATIONARGUED.
THECOURTSETSTHEFOLLOWINGBRIEFINGSCHEDULE:THEMOTIONSHALLBESERVEDAND
FILEDTODAYBY
CLOSEOFBUSINESS.
THEPROOFOFSERVICEOFTHEMOTIONSHALLBEFILEDBY12/14/12.
THEOPPOSITIONANDREPLYSHALLBESERVEDANDFILEDACCORDINGTOCODE.
SUBSEQUENTLYLATER:
PERSONALSERVICEOFOSCDOCUMENTSEXECUTEDONTHISDATEINOPENCOURT.PERSONAL
SERVICEOFPARTY:BONNIESHIPLEY.DATE:12/13/12.
TRIALDATESAREORDEREDVACATED
HEARINGS:
LAW&MOTIONRE:ORDERTOCOMPLELDEFENDANTSETFOR01/10/13AT08:30INDEPT.S32.
VACATECTSHEARINGSCHEDULEDFOR12/17/12AT10:00INDEPARTMENTS32A.
TRIALSETTINGCONFERENCESETFOR01/10/13AT08:30INDEPT.S32
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MOTIONRE:TOCOMPELPRODUCTIONDOCUMENTSANDVIDEOSFILEDBY
12/13/20128:30AMDEPT.S32A
DONALDALVAREZ,JUDGE
COURTREPORTERSTACEYDETTMERS13303
APPEARANCES:
MOTION
BONNIESHIPLEY'SMOTIONTOCOMPELPRODUCTIONOFDOCUMENTS&VIDEOSISHEARD.
COURTFINDS:
BONNIESHIPLEY'SMOTIONTOCOMPELPRODUCTIONOFDOCUMENTSANDVIDEOSISDENIED.
PLAINTIFFINFORMSTHECOURTTHATNOINDEPENDENT3RDPARTYREPORTSPRESENTLYEXIST
ANDTHECOURT
ADVISESTHATTHEYMAYBEEXCLUDEDATTIMEOFTRIAL.(FINDINGSONTHERECORD)
THECOURTNOTESTHATTHEREISANEXPARTEFORANORDERTOCOMPELSETTODAYFILEDBY
PLAINTIFFS
COUNSEL.
TRIALDATESAREORDEREDRESET.
HEARINGS:
HEARINGDATEOF01/10/13CONFIRMED.
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MOTIONRE:JUDGMENTONTHEPLEADINGS(FILEDASANINLIMINE)
01/10/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
COURTREPORTERVICTORIAVILLEGAS9843
APPEARANCES:
MOTION
BONNIESHIPLEY'SMOTIONFORJUDGMENTONTHEPLEADINGSISHEARD.
COURTFINDS:
BONNIESHIPLEY'SMOTIONFORJUDGMENTONTHEPLEADINGSISDENIED.
WITHOUTPREJUDICE
THECOURTFINDSTHATPROCEDURALISSUESEXISTASTHEMOTIONWASNOTPROPERLY
NOTICEDANDTHE
MOTIONWASBROUGHTPASSEDTHESTATUTORYDEADLINEFORBRININGASTATUTORY
JUDGMENTONPLEADINGS
UNDERCCP438ANDTHEMOTIONWASBARREDBYDEFENDANTSPRIORDEMURRERBROUGHT
ANDOVERRULED
ONTHESAMEGROUNDS.
(FINDINGSONTHERECORD)
REPLAINTIFFSMOTIONFORSUMMARYJUDGMENT
STUBBLEFIELDPROPERTIESACAGENERALPARTNER'SMOTIONFORSUMMARYJUDGMENTIS
DENIED.
WITHOUTPREJUDICE
THECOURTFINDSTHATPROCEDURALISSUESEXISTASPLAINTIFFDIDNOTFILEASEPARATE
NOTICEDMOTION
PURSUANTTOCCP437(C),BUTINSTEADFILEDITASPARTOFPLAINTIFFSOPPOSITIONTO
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DEFENDANTS
JUDGMENTONTHEPLEADINGSANDDIDNOTPAYTHEREQUIREDFILINGFEES.(FINDINGSONTHE
RECORD)
REDEFENDANTSMOTIONFORSUMMARYJUDGMENT
BONNIESHIPLEY'SMOTIONFORSUMMARYJUDGMENTISDENIED.
WITHOUTPREJUDICE
THECOURTFINDSTHATPROCEDURALISSUESEXISTASTHEDEFENDANTALSODIDNOTFILEA
SEPARATE
NOTICEDMOTIONBUTINSTEADFILEDITASPARTOFHEROPPOSITIONTOPLAINTIFFSMOTIONFOR
SUMMARY
JUDGMENTANDWITHININCLUDEDACOUNTERSUMMARYJUDGMENTMOTION
HEARINGS:
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TRIALSETTINGCONFERENCE
01/10/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
PROCEEDINGS:
HEARINGON:TRIALSETTINGCONFERENCEHELD
REASON:TOBEHEARDWITHMOTIONTOCOMPEL
CONTINUEDTO2/27/13.
HEARINGS:
HEARINGRE:CASEMGMTCONF/TRIALSETTINGCONFSETFOR02/27/13AT08:30INDEPARTMENT
S32.
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MOTIONRE:PLAMOTIONTOCOMPEL000100FILEDBY0001
01/10/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
MOTION
STUBBLEFIELDPROPERTIESACAGENERALPARTNER'SMOTIONTOCOMPELANSWERSTODEPO
QUESTIONS&PRODUCEDOCSISHEARD.
COURTFINDS:
MOTIONISTREATEDASTIMELYFILED,BUTTHECOURTFINDSTHATPROCEDUREISSUESEXIST.
THECOURTFINDSTHATTHEMEETANDCONFERREQUIREMENTSWERENOTMETANDTHE
SEPARATE
STATEMENTISDEFICIENTANDDOESNOTCOMPLYWITHCALIFORNIARULESOFCOURT.
THECOURTFURTHERRULESTHATPLAINTIFFSMOTIONSHOULDBELIMITEDTOONLYTHOSE
ISSUESRAISEDIN
THEDECEMBER11,2012EMAIL.
MATTERORDEREDCONTINUEDTOALLOWPLAINTIFFTOCOMPLYWITHTHEMEETANDCONFER
ANDSEPARATE
STATEMENTREQUIREMENTS.
THECOURTSETSADEADLINEOFJANUARY24,2013FORTHEPLAINTIFFTOFILEANDSERVEA
SUPPLEMENTAL
FILINGSETTINGFORTHTHEMEETANDCONFERANDANAMENDEDSEPARATESTATEMENTFOR
QUESTIONS/DOCUMENTSSTILLATISSUE.
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DEFENDANTSHALLRESPONDACCORDINGTOCODE.
DEFENDANTSREQUESTFORSANCTIONSISDENIED.
HEARINGS:
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NOTICEOFOSCWHYCOURTSHOULDHEARMSJBEFOREMTNCOMPELSENT.
01/14/20133:01PM
COUNSELISADVISEDTHATANORDERTOSHOWCAUSEWHYTHECOURTSHOULDHEAR
PLAINTIFFSMOTIONFOR
SUMMARYJUDGMENTBEFOREPLAINTIFFSMOTIONTOCOMPELPRESENTLYSETFOR2/27/13HAS
BEENRULED
ONISORDEREDSETON1/22/13AT8:30AMINDEPARTMENTS32.COUNSELIS
ORDEREDTOSERVEANDFILEWRITTENRESPONSESNOLATERTHAN1/17/13BY10:00AM.ALL
DOCUMENTS
SHALLBEFILEDDIRECTLYINTHEDEPARTMENT.
NOTICESPRINTED
NOTICESPRINTED
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HEARINGRE:OSCREWHYCOURTSHOULDHEARMSJBEFOREMTNCOMPEL
01/22/20138:30AMDEPT.S32A
DONALDALVAREZ,JUDGE
APPEARANCES:
PROCEEDINGS:
HEARINGON:OSCREWHYCOURTSHOULDHEARMSJBEFOREMTNCOMPEL
COURTFINDS:
BOTHSUMMARYJUDGMENTMOTIONSSHALLBEHEARDON1/31/13ANDBOTHPARTIESSHALLFILE
ANDSERVE
THEMOTIONSPERCODE.
HEARINGS:
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MOTIONRE:MOTIONFORSUMMARYJUDGMENTFILEDBYDEFENDANTBONNIE
SHIPLEY
01/31/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
MOTION
BONNIESHIPLEY'SMOTIONFORSUMMARYJUDGMENTISHEARD.
COURTFINDS:
ONTHECOURTSOWNMOTION,THECOURTORDERSTHISMATTERCONTINUEDTO2/14/13AT8:30
AMIN
DEPARTMENTS32.
OBJECTIONSAREMADEBYTHEDEFENDANTONTHERECORDANDTHECOURTREPORTERIS
ORDEREDTO
PREPAREATRANSCRIPTOFTHESEPROCEEDINGS.
BOTHCOUNSELISADVISEDTHATNOADDITIONALDOCUMENTSSHALLBEFILEDREGARDINGTHESE
MOTIONS.
HEARINGS:
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MOTIONRE:SUMMARYJUDGMENTPLAFILEDBYPLAINTIFF
01/31/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
MOTION
HEARD.
COURTFINDS:
ONTHECOURTS0WNMOTION,THECOURTORDERSTHISMATTERCONTINUEDTO2/14/13AT8:30
AMIN
DEPARTMENTS32.
OBJECTIONSMADEBYTHEDEFENDANTONTHERECORD.THECOURTREPORTERISORDEREDTO
PREPAREA
TRANSCRIPTOFTHESEPROCEEDINGS.
BOTHCOUNSELISADVISEDTHATNOADDITIONALDOCUMENTSSHALLBEFILEDREGARDINGTHESE
MOTIONS.
HEARINGS:
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MOTIONRE:MOTIONFORSUMMARYJUDGMENTFILEDBYDEFENDANTBONNIE
SHIPLEY
02/14/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
ATTORNEYROBERTWILLIAMSONJRPRESENTFORPLAINTIFF/PETITIONER.
MOTION
BONNIESHIPLEY'SMOTIONFORSUMMARYJUDGMENTISHEARD.
COURTFINDS:
BONNIESHIPLEY'SMOTIONFORSUMMARYJUDGMENTISDENIED.
(BASEDONUNDISPUTEDFACTS14ANDTHESUPPORTINGEVIDENCETHERETOANDTHECOURT
FINDSTHATA
TRIABLEISSUEOFMATERIALFACTEXISTS.)
DEFENDANTSREQUESTFORJUDICIALNOTICEIS
DEFENDANTSOBJECTIONSAREOVERRULED.
HEARINGS:
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MOTIONRE:SUMMARYJUDGMENTPLAFILEDBYPLAINTIFF
02/14/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
MOTION
HEARD.
COURTFINDS:
DENIED.
(BASEDONUNDISPUTEDFACTS115ANDTHESUPPORTING
EVIDENCETHERETOANDTHECOURTFINDSTHATA
TRIABLEISSUEOFMATERIALFACTEXISTS.)
PLAINTIFFSREQUESTFORJUDICIALNOTICEISGRANTEDTOTHEEXTENTTHATTHEDOCUMENTS
CONTAIN
JUDICIALADMISSIONSBUTNOTASTOTHETRUTHOFTHEALLEGATIONSASSERTEDTHEREINAS
TO
EXHIBIT(S)A,B,D&EANDDENIEDASTOEXHIBIT(S)C,FL.(FINDINGSONTHERECORD)
DEFENDANTTOPREPAREORDER.
HEARINGS:
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EXPARTEMOTIONRE:TRORECOMMUNICATINGDIRECTLY&OSCREPRLMNRYINJ
02/21/20138:30AMDEPT.S32A
DONALDALVAREZ,JUDGE
APPEARANCES:
PROCEEDINGS:
NOEMERGENCYSETFORHEARINGONLY
EXPARTEPAPERSAREDEEMEDTHEMOVINGPAPERS.
DEFENDANTSHALLSERVEANDFILEASUPPLEMENTALOPPOSITIONON/ORBEFORE2/25/13AND
THE
PLAINTIFFSHALLSERVEANDFILEAREPLYNOLATERTHAN2/27/13.
COUNSELISADVISEDTHATALLDOCUMENTSSHALLBEFILEDDIRECTLYINTHEDEPARTMENT.
HEARINGS:
LAW&MOTIONRE:PRELIMINARYINJUNCTIONSETFOR03/07/13AT08:30INDEPT.S32.
COUNSELFORPLAINTIFFTOGIVENOTICE.
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MOTIONRE:ORDERCOMPELLINGDEFENDANT/NONPARTYTOAPPEARAND
PRODUCEDOCUMENTSFILEDBYPLAINTIFFSTUBBLEFIELDPROPERTIESACA
GENERALPARTNER
02/27/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
MOTION
STUBBLEFIELDPROPERTIESACAGENERALPARTNER'SMOTIONREORDERCOMPELLINGDEF/NON
PARTYTOAPPEAR/PRODDISHEARD.
COURTFINDS:
MOTIONASTODEFTBONNIESHIPLEY:
OBJECTIONSTOQUESTIONS#1,2,3&4AREOVERRULEDANTHEMOTIONTOCOMPELISGRANTED.
STUBBLEFIELDPROPERTIESACAGENERALPARTNER'SMOTIONTOCOMPELASTOQUESTIONS
#1,2,3&4ISGRANTED.
OBJECTIONSTOQUESTIONS#5,6,7,8,9,10,11&12THEMOTIONISDENIED.
THECOURTDENIESTHEMOTIONTOCOMPELASTOTHERESIDENTIALLEASEAGREEMENTTO
SHAREOCCUPANCY.
MOTIONASTOSCOTTSTEVEALLEN:
QUESTIONS1AND3AREDENIEDANDQUESTIONS#2,
4,5,6&7AREALSODENIED.
MOTIONTOCOMPELASTODEFTNANCYMCCARRON:
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THECOURTFINDSTHATATTORNEYMCCARRONRECEIVEDSUFFICIENTSERVICEOFTHEMOTION
INLIGHTOFHER
CAPACITYASCOUNSELINTHISMATTER.
OBJECTIONTOQUESTION#1ISOVERRULEANDTHECOURTGRANTSTHEMOTIONTOCOMPEL.
THEMOTIONTOCOMPELISPRODUCTIONOFDOCUMENTSISDENIED.
STUBBLEFIELDPROPERTIESACAGENERALPARTNER,BONNIESHIPLEY'SMOTIONFORSANCTIONS
ISDENIED.
COUNSELISORDEREDTOMEETANDCONFER
HEARINGS:
NOTICEWAIVED.
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HEARINGRE:CASEMGMTCONF/TRIALSETTINGCONF
02/27/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
PROCEEDINGS:
HEARINGON:CASEMGMTCONF/TRIALSETTINGCONFHELD
COURTRULESONPLAINTIFFSMOTIONTO
COMPELTHISDATE.MATTERORDEREDCONTINUED.
REASON:TOBEHEARDWITHMOTIONFOR
PRELIMINARYINJUNCTIONPRESENTLYSET3/7/13.
HEARINGS:
TRIALSETTINGCONFERENCESETFOR03/07/13AT08:30INDEPT.S32
JURYDEMANDEDBYDEFENDANT.
NOTICEWAIVED.
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MOTIONRE:FORRECONSIDERATIONREDENIALMTNTOCOMPEL
03/07/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
MOTION
BONNIESHIPLEY'SMOTIONRERECONSIDERATIONOFDENIALOFMOTIONTOCOMPELISHEARD.
REASON:TEMPORARYSTAYISSUEDONWRIT.CASESTAYED.
HEARINGS:
ACTIONCOMPLETE
====MINUTEORDERCORRECTEDON03/12/13====
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03/07/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
PROCEEDINGS:
REASON:TEMPORARYSTAYONWRITFILEDBYDEFENDANT
WASGRANTED.CASESTAYED.
HEARINGS:
ACTIONCOMPLETE
====MINUTEORDERCORRECTEDON03/07/13====
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MOTIONRE:PRELIMINARYINJUNCTION
03/07/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
MOTION
STUBBLEFIELDPROPERTIESACAGENERALPARTNER'SMOTIONFORPRELIMINARYINJUNCTIONIS
HEARD.
DEFENDANTSCOUNSELINFORMSTHECOURTTHATTHEWRITWASGRANTEDANDASTAYWAS
ISSUEDINTHIS
CASE.
MATTERORDEREDCONTINUEDASFOLLOWS:
HEARINGS:
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04/23/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
MOTION
BONNIESHIPLEY'SMOTIONFORRECONSIDERATIONREDENIALOFMTNTOCOMPELISHEARD.
REASON:WRITSTILLPENDING.CASESTAYED.
HEARINGS:
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04/23/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
PROCEEDINGS:
REASON:WRITSTILLPENDING
HEARINGS:
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04/23/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
MOTION
HEARD.
REASON:CASESTAYED.STILLAWAITINGRULING
FROMCOURTOFAPPEAL.
HEARINGS:
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MOTIONRE:ATTORNEYFEESFILEDBYDEFENDANTBONNIESHIPLEY
07/02/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
COURTREPORTERFRANCESMACIAS10918
APPEARANCES:
ROBERTWILLIAMSONJRAPPEARSBYCOURTCALLFORSTUBBLEFIELDPROPERTIESACAGENERAL
PARTNER.
ATTORNEYNANCYDUFFYMCCARRON(BYPHONEPRIORTOCALENDAR)PRESENTFOR
DEFENDANT/RESPONDENT.
MOTION
BONNIESHIPLEY'SMOTIONFORATTORNEYFEESISHEARD.
REASON:CASESTAYED/APPEALPENDING
HEARINGS:
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07/22/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
NOTREPORTED
APPEARANCES:
PARTNER.
MOTION
REASON:STILLAWAITINGREMITTITUR
MOTIONORDEREDTOTRIALOSCRESTATUS
HEARINGS:
NOTICEWAIVED.
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07/22/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
NOTREPORTED
APPEARANCES:
PARTNER.
MOTION
BONNIESHIPLEY'SMOTIONFORRECONSIDERATIONREDENIALMTNTOCOMPELISHEARD.
MOTIONORDEREDTOTRIALOSCRESTATU
HEARINGS:
NOTICEWAIVED.
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07/22/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
NOTREPORTED
APPEARANCES:
PARTNER.
PROCEEDINGS:
THECOURTISINFORMEDTHATTHEFOURTHDISTRICTCOURTOFAPPEALISSUEDANORDER
DENYING
PLAINTIFFSWRITOFPHOHIBITIONON7/19/13.
NOTE:ALLOTHERMATTERSSETONTODAYS
CALENDARISORDEREDTOTRAILTHEOSCSET10/21/13
HEARINGS:
HEARINGRE:CASEMGMTCONF/OSCRESTATUSOFAPPEALSETFOR10/21/13AT08:30IN
DEPARTMENTS32.
NOTICEWAIVED.
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07/22/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
NOTREPORTED
APPEARANCES:
PARTNER.
MOTION
BONNIESHIPLEY'SMOTIONFORPRELIMINARYINJUNCTIONISHEARD.
MOTIONORDEREDTOTRAILOSCRESTATUS
HEARINGS:
NOTICEWAIVED.
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EXPARTEMOTIONRE:FORSTAYOFENFRCMNTOFAPPELLTDIVSWOM
08/06/20138:30AMDEPT.S32X
DONALDALVAREZ,JUDGE
APPEARANCES:
ATTORNEYROBERTDICKSONPRESENTFORPLAINTIFF/PETITIONER.
ATTORNEYNANCYDUFFYMCCARRON(BYPHONEON8/5/13)PRESENTFOR
DEFENDANT/RESPONDENT.
PROCEEDINGS:
COURTNOTESTHATCOUNSELFORTHEDEFENDANT
FILEDANOPPOSITIONTOTHEEXPARTE.
EXPARTEORDERSREORDERSHORTENINGTIMEISGRANTED
MATTERSETFORMOTIONFORSTAYOFENFORCEMENT
ON8/22/13AT8:30AMINDEPARTMENTS32.
EXPARTEPAPERSAREDEEMEDTHEMOVINGPAPERS.
OPPOSITIONTOBESERVEDANDFILEDBY8/12/13.
REPLYTOBESERVEDANDFILEDON/BEFORE8/14/13.
NOTE:IFASUPPLEMENTALOPPOSITIONHASNOTBEENFILEDTHEOPPOSITIONFILEDTOTHEEX
PARTESHALL
BEDEEMEDASARESPONSE.
HEARINGS:
LAW&MOTIONRE:STAYOFENFORCMNTOFAPPELLTDIVISIONWRITMANDATESETFOR08/22/13AT
08:30INDEPT.S32.
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MOTIONRE:STAYOFENFORCMNTOFAPPELLTDIVISIONWRITMANDATE
08/22/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
COURTREPORTERJILLLANGLEY7663
APPEARANCES:
NOAPPEARANCE.
MOTION
STUBBLEFIELDPROPERTIESACAGENERALPARTNER'SMOTIONTOSTAYENFORCMNTOFAPPELLT
DIVWRITOFMANDATEISHEARD.
REASON:CASEPRESENTLYSTAYED.
HEARINGS:
CORRESPONDENCECOVERSHEETGENERATEDTOMAILMINUTEORDERDATED8/22/13TO
COUNSELOFRECORD.
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MOTIONRE:STAYOFENFORCMNTOFAPPELLTDIVISIONWRITMANDATE
10/21/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
MOTION
STUBBLEFIELDPROPERTIESACAGENERALPARTNER'SMOTIONFORSTAYOFENFORCMNTOF
APPELLNTDIVWRITMANDATEISHEARD.
SUBMITTEDONPOINTSANDAUTHORITIES
COURTFINDS:
PLAINTIFFSMOTIONFORSTAYOFENFORCEMENTOFAPPELLATEDIVISIONWRITOFMANDATEIS
WITHOUT
MERITINLIGHTOFTHECALIFORNIASUPREMECOURTDENYINGITSPLAINTIFFSPETITIONAND
REQUESTFOR
ASTAY.
HEARINGS:
(REDEFENDANTSMOTIONFORATTORNEYFEES)
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10/21/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
MOTION
STUBBLEFIELDPROPERTIESACAGENERALPARTNER'SMOTIONFORATTORNEYFEESISHEARD.
MATTERORDEREDCONTINUEDTOBEHEARDAFTERDEFENDANTHASPREPAREDANDSUBMITTED
APROPOSED
JUDGMENTANDORDER.
DEFENDANTTOLISTATTORNEYFEESTOBEDETERMINEDINTHEPROPOSEDJUDGMENT.
PURSUANTTOSTIPULATIONOFCOUNSEL:
DEFENDANTSHALLBEALLOWEDTOSERVEACOPYOFTHEPROPOSEDORDERANDJUDGMENTTO
PLAINTIFFS
COUNSELVIALEMAILORBYFAX.
HEARINGS:
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10/21/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
MOTION
BONNIESHIPLEY'SMOTIONFORRECONSIDERATIONREDENIALMTNTOCOMPELISHEARD.
OFFCALENDAR.REASON:DEEMEDMOOTINLIGHTOF
THEWRITOFMANDAMUSRULING
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HEARINGRE:CASEMGMTCONF/OSCRESTATUSOFAPPEAL
10/21/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
NOTREPORTED
APPEARANCES:
PROCEEDINGS:
HEARINGON:CASEMGMTCONF/OSCRESTATUSOFAPPEALHELD
BASEDONTHERULINGISSUEDBYTHEAPPELLATEDIVISIONONTHEWRITOFMANDAMUSANDTHE
CALIFORNIASUPREMECOURTHAVINGDENIEDPLAINTIFFSPETITIONFORREVIEWAND
APPLICATION
FORSTAY,THECOURTHEREBYRULESASFOLLOWS:
COURTFINDS:
THECOURTSRULINGONDEFENDANTSMOTIONFORSUMMARYJUDGMENTHEARDONFEBRUARY
14,2013IS
HEREBYREVERSEDANDRULESASFOLLOWS:
BONNIESHIPLEY'SMOTIONFORSUMMARYJUDGMENTISGRANTEDASTOITSENTIRETY.
DEFENDANT/MOVINGPARTYTOPREPAREJUDGMENT.
HEARINGS:
(REDEFENDANTSMOTIONFORATTORNEYFEES)
COUNSELOFRECORD.
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ACTIONDISPO:JUDGMENT
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10/21/20138:30AMDEPT.S32
DONALDALVAREZ,JUDGE
APPEARANCES:
MOTION
HEARD.
OFFCALENDAR.REASON:DEEMEDMOOTINLIGHT
OFTHEWRITOFMANDAMUSRULING
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01/07/20148:30AMDEPT.S32
DONALDALVAREZ,JUDGE
COURTREPORTERREGINAVEGA12612
APPEARANCES:
ATTORNEYROBERTGWILLIAMSONPRESENTFORPLAINTIFF/PETITIONER.
MOTION
COURTFINDS:
THECOURTISINFORMEDTHATTHEDEFENDANTFILEDAREQUESTFORRECUSAL(170.6)ON
7/22/13.
NOTE:THECOURTNOTESTHATTHE170.6WASPREMATURELYFILEDBYDEFENDANTON7/22/13,
ASTHECOURTWASSTILLAWAITINGTHEREMITTITUR
(THATTHECOURTHADNOTYETRECEIVED)
HOWEVERDEFENDANTHAVINGMADEANORALREQUESTFORRECUSALINOPENCOURT,THE
COURTRULESAS
FOLLOWS:
JUDGEDONALDALVAREZRECUSESSELFFROMTHECASE.CASEASSIGNEDTOJUDGEMICHAELA
SACHSFORALLPURPOSES.
CASEASSIGNEDTODEPARTMENTS33,BEFORETHEHONORABLEJUDGESACHSFORALL
PURPOSES.
HEARINGS:
CORRESPONDENCECOVERSHEETGENERATEDTOMAILMINUTEORDERDATED1/7/14TOCOUNSEL
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OFRECORD.
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02/10/20148:30AMDEPT.S33
MICHAELASACHS,JUDGE
CLERK:WIMALABLANCHARD
COURTREPORTERKATHYSELLERS4420
COURTATTENDANTMARYKILGORE
APPEARANCES:
PROCEEDINGS:
MOTION
ACTIONCAMEONFORMOTIONRE:ATTORNEYFEESFILEDBYBONNIESHIPLEY.
COURTHASREVIEWEDTHEMOTION,OPPOSITION,REPLY,EXPERTDECLARATIONS,ANDOTHER
ADDITIONAL
DECLARATIONSWHICHHAVEBEENFILED.
COURTDOESNOTGOFORWARDWITHMOTIONFORATTORNEYFEESANDSETSMATTERFOR
HEARING
REGARDINGJUDGMENT.COURTHASRECEIVEDPROPOSEDJUDGMENTSFROMATTORNEY
MCCARRONANDINSTRUCTS
COUNSELFORPLAINTIFFTOSUBMITTPROPOSEDJUDGMENTTOTHECOURT.HEARING
REGARDING
JUDGMENTWILLBEHELDON2/19/14ANDTHEREAFTERAHEARINGFORTHEMOTIONFOR
ATTORNEYFEESWILL
BESET.
HEARINGS:
HEARINGRE:PROPOSEDJUDGMENTSETFOR02/19/14AT08:30INDEPARTMENTS33A.
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HEARINGRE:PROPOSEDJUDGMENT
02/19/20148:30AMDEPT.S33A
MICHAELASACHS,JUDGE
COURTREPORTERJULIEQUINTANILLA11309
APPEARANCES:
ATTORNEYNANCYDUFFYPRESENTFORDEFENDANT/RESPONDENT.
PROCEEDINGS:
COURTHASREVIEWEDTHEPROPOSEDJUDGMENTSSUBMITTEDBYCOUNSEL.HYBRIDPROPOSAL
WORKED
OUTBYTHECOURT.LANGUAGEISSTATEDONTHERECORD.
COUNSELFORPLAINTIFFTOPREPAREJUDGMENTASPROPOSEDBYCOURT.APPELLATEDOCS
FROMDEFENSE
MAYBEATTACHED.PROPOSEDJUDGMENTDUETODEFENSECOUNSELNOLATERTHAN3/05/14.
OBJECTIONSHALLBEDUENOLATERTHAN3/12/14.IFNOOBJECTIONISFILEDCOURTWILLENTER
JUDGMENT.HEARINGREGARDINGMOTIONFORATTORNEYFEESISSETASFOLLOWS:
HEARINGS:
LAW&MOTIONRE:ATTORNEYFEESSETFOR03/17/14AT08:30INDEPT.S33.
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MOTIONRE:ATTORNEYFEES
03/17/20148:30AMDEPT.S33
MICHAELASACHS,JUDGE
CLERK:ANCHALEEMPRICE
APPEARANCES:
ATTORNEYNANCYDUFFYMCCARRONPRESENTFORPLAINTIFF/PETITIONER.
ATTORNEYROBERTWILLIAMSONJRPRESENTFORDEFENDANT/RESPONDENT.
MOTION
POSTDISPOSITIONHEARINGHELD
THECOURTISINRECEIPTOFDEFENDANTSOBJECTIONSANDPLAINTIFFSRESPONSETOTHE
OBJECTIONS.THE
COURTHASREVISEDTHEPROPOSEDJUDGMENTANDACOPYOFTHEPROPOSEDJUDGMENT
WITHTHECOURTS
NOTESAREPROVIDEDTOCOUNSEL.
PLAINTIFFSCOUNSELTOPREPAREJUDGMENTASDISCUSSEDONTHERECORD.
PURSUANTTOSTIPULATIONOFCOUNSEL:
BONNIESHIPLEY'SMOTIONRE:ATTORNEYFEESISHEARD.
THECOURTRECITESITSTENTATIVERULINGONTHEREOCRD.
COURTFINDS:
BONNIESHIPLEY'SMOTIONRE:ATTORNEYFEESISDENIED.
WITHOUTPREJUDICE
THECOURTFINDSTHATDEFENSECOUNSELISENTITLEDTOHERATTORNEYFEESPURSUANTTO
CCP798,
HOWEVERDEFENSECOUNSELWASNOTSPECIFICASTOHERBILLING.DEFENSECOUNSELMAY
SUBMITANOTHER
MOTIONDETAILINGHERFEESFORTHECOURTSREVIEW.
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JUDGMENTONUDCOMPLAINT<$10,000FILED08/27/2012OF
STUBBLEFIELDPROPERTIESACAGENERALPARTNERFILED
03/20/201412:03PM
JUDGMENTFORDEFENDANTBONNIESHIPLEY
ANDAGAINSTSTUBBLEFIELDPROPERTIESACAGENERALPARTNER
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MOTIONRE:EXPUNGELISPENDENS/AWARDATTYFEES*FILEDBYPLAINTIFF
04/09/20148:30AMDEPT.S33
MICHAELASACHS,JUDGE
CLERK:TAMMYMACIAS
ATTORNEYINFORMATION
ATTORNEYROBERTWILLIAMSONJRPRESENTFORPLAINTIFF.
ATTORNEYNANCYDUFFYMCCARRONPRESENTFORDEFENDANT.
PROCEEDINGS:
POSTDISPOSITIONHEARINGHELD
ATTORNEYNANCYMCCARRONREPRESENTSAPETITIONWASFILEDWITHTHEAPPELLATECOURT
4/8/14.
MATTERCONTINUEDATREQUESTOFCOUNSEL
HEARINGS:
CURRENTHEARINGCONTINUEDTO06/16/14AT08:30INDEPARTMENTS28J.
NOTICEWAIVED.
CASEISREASSIGNEDFORALLPURPOSESTODEPARTMENTS28J
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06/16/20148:30AMDEPT.S28J
MICHAELASACHS,JUDGE
COURTREPORTERBETTYKELLEY3981
APPEARANCES:
LAWOFFICEOFNANCYDUFFYMCCARRONFORBONNIESHIPLEYNOTPRESENT
PROCEEDINGS:
COURTRECEIVESCALLTHISMORNINGRELATINGTOATTORNEYMCCARRON.ATTORNEY
MCCARRONWILLNOT
BEPRESENTTHISMORNINGFORREASONSSTATEDONTHERECORD.COURTCONTINUESMATTER
TO6/23/14
ANDWILLGOFOWARDWITHRULINGTHISDATE.
HEARINGS:
CURRENTHEARINGCONTINUEDTO06/23/14AT08:30INDEPARTMENTS28A.
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06/23/20148:30AMDEPT.S28A
MICHAELASACHS,JUDGE
APPEARANCES:
PROCEEDINGS:
ATTORNEYMCCARRONSTATESAPPEALISONGOING.
MOTION
STUBBLEFIELDPROPERTIESACAGENERALPARTNER'SMOTIONRE:EXPUNGELIS
PENDENS/AWARDATTYFEESISHEARD.
COURTGIVESTENTATIVERULING.
COURTFINDS:
COURTHASREVIEWEDAUTHORITIESSTATEDBYEACHPARTYASITRELATESTOLISPENDENS.
MOTIONTOEXPUNGELISPENDENSISGRANTED..
MOTIONTOEXPUNGELISPENDENSUNTIMELY.
COURTSFINDINGSARESTATEDONTHERECORD.
OTHERORDERS:MOTIONREQUESTINGATTORNEYFEESAREDENIED.
ORDERSIGNEDTHISDATE.
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EXPARTEMOTIONRE:DEFEXPARTEAPPFORORDERTOREPAIRORREPLACEELE
09/09/20149:30AMDEPT.S28X
MICHAELASACHS,JUDGE
COURTREPORTERLINDABALDWIN12453
APPEARANCES:
ATTORNEYROBERTWILLIAMSONPRESENTFORSTUBBLEFIELDPROPERTIES.
ATTORNEYNANCYDUFFYMCCARRONPRESENTFORBONNIESHIPLEY.
PROCEEDINGS:
NOFILE.
COURTHASREADANDCONSIDEREDTHEMOVINGPAPERSANDOPPOSITIONFILED9/8/14.
COURTFINDS:
EXPARTEORDERSDENIED.
FINDINGSARESTATEDONTHERECORD.
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EXPARTEMOTIONRE:FORORDERCONTINUINGHEARING
09/17/20148:31AMDEPT.S28X
MICHAELASACHS,JUDGE
COURTATTENDANTROBERTKRETZMEIER
APPEARANCES:
ATTORNEYNANCYDUFFYMCCARRONPRESENTFORDEFTBONNIESHIPLEY.
PROCEEDINGS:
NOFILE.
COURTADVISESATTORNEYMCCARRONTHATSHEMAYAPPEARBYCOURTCALLONFUTURE
EXPARTEHEARINGS.
COURTDOESNOTHAVEJURISDICTIONTOMOVEFORWARDWITHTODAYSHEARING.CASE
REMAINSSTAYED
PENDINGAPPELLATERULING.COURTVACATESTHEMOTIONREGARDINGATTORNEYFEES
CURRENTLYSET
10/02/14.
HEARINGS:
VACATEL&MHEARINGSCHEDULEDFOR10/02/14AT08:30INDEPARTMENTS28.
NOTICETOBEGIVENBYATTORNEYWILLIAMSON.
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FILINGFEEPAIDBYSTUBBLEFIELDPROPERTIESACAGENERALPARTNERFOREX
PARTEFEE
03/03/201511:19AM
Receipt:1503031653$60.00
1503031653CKReferenceNumber92638
Code
Text
Operator
*FEE
1503031653CKMMF/60.00CRU/30.00Paymt JCONT
*REFNM 1503031653CKReferenceNumber92638
JCONT
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EXPARTEMOTIONRE:PLAEXPARTEAPPFORORDERCONTTHEHEARINGONDEF
03/04/20158:31AMDEPT.S28X
MICHAELASACHS,JUDGE
APPEARANCES:
PROCEEDINGS:
NOFILE.
ACTIONCAMEONFORPLAEXPARTEAPPFORORDERTOCONTDEFTHEARING.
COURTADVISESCOUNSELOFORDERPREVIOUSLYSIGNEDON2/27/15REQUIRINGNEWMOTION
WITHNEW
SUPPORTINGDOCUMENTSTOBEFILED.EXPARTEAPPLICATIONDENIEDASMOOT.
COURTVACATESHEARINGCURRENTLYSET3/18/15.MOVINGPARTYTOCONTACTCLERKSOFFICE
AND
OBTAINFIRSTAVAILABLEDATEFORHEARING.
COURTORDERSCSRREGINAVEGATOPREPAREATRANSCRIPTOFTHEPROCEEDINGSDATED
03/04/15.
HEARINGS:
VACATEHRGHEARINGSCHEDULEDFOR03/18/15AT08:30INDEPARTMENTS28.
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UDFS1406978MinuteOrdersSanBernardinoMain
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CaseUDFS1406978STUBBLEFIELDVSDUFFY
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HEARINGRE:170.6
10/14/20144:00PMDEPT.F2
KYLESBRODIE,JUDGE
CLERK:SHOSHONENEAL
APPEARANCES:
PARTIESNOTPRESENT:STUBBLEFIELDPROPERTIES,ACALIFORNIA,NANCYBDUFFY,BONNIE
SHIPLEY
PROCEEDINGS:
CCP170.6FILEDASTOJUDGEWILFREDJSCHNEIDERJR.,CASEREASSIGNEDTOJUDGEKYLES
BRODIEFORALLPURPOSES.
HEARINGS:
LAW&MOTIONRE:DEMURRER/MOTIONTOSTRIKECOMPLAINT/QUASHSUMMONSSETFOR11/10/14
AT08:00INDEPT.F2.
CASEASSIGNEDFORALLPURPOSESTODEPARTMENTF2
CLERK'SOFFICETONOTIFYALLPARTIES
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MOTIONRE:DEMURRER/MOTIONTOSTRIKECOMPLAINT/QUASHSUMMONS
11/10/20148:00AMDEPT.F7
KYLESBRODIE,JUDGE
CLERK:SHOSHONENEAL
APPEARANCES:
DEFENDANTNANCYBDUFFYPRESENT
PROCEEDINGS:
MATTERELECTRONICALLYRECORDED
09:09
NANCYBDUFFY'SMOTIONDEMURRER/MOTIONTOSTRIKEISHEARD.
ORALARGUMENTPRESENTEDBYDEFENDANT.
ORALARGUMENTPRESENTEDBYCOUNSELFORPLAINTIFF.
MATTERPUTON2NDCALLFORCOURTTOREVIEWDEFENDANTSJUDICIALNOTICEREQUEST.
09:11
10:54
ORALARGUMENTPRESENTEDBYDEFENDANT.
AFTERTESTIMONYANDDUECONSIDERATIONBYTHECOURT:
DEMURRERISOVERRULEDASTONANCYBDUFFY
NANCYBDUFFY,BONNIESHIPLEY'SMOTIONTOSTRIKECOMPLAINT/QUASHSUMMONSISDENIED.
5DAYSTOANSWER.
11:28
CERTIFICATEOFELECTRONICRECORDINGMONITORPRINTED.
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FILINGFEEPAIDBYNANCYBDUFFYFORAUDIOCD
11/14/20143:18PM
Receipt:1411143518$22.00
Code
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*FEE
1411143518CKFAR/22.00Paymt MCARB
MCARB
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MOTIONRE:FORANORDERTOCOMPELNANCYDUFFYMCCARRONANDBONNIE
SHIPLEYTOAPPEAR,TESTIFYFILEDBYPLAINTIFFSTUBBLEFIELDPROPERTIES,A
CALIFORNIA
12/19/20148:00AMDEPT.F7
KYLESBRODIE,JUDGE
CLERK:SHOSHONENEAL
APPEARANCES:
ATTORNEYNANCYSHIPLEYPRESENTFORDEFENDANT/RESPONDENT.
PROCEEDINGS:
10:36
THECOURTHASREVIEWEDTHEMOTIONTOCOMPELANDOPPOSITIONTOMOTIONTOCOMPEL.
PLAINTIFFREQUESTINGANORDERFORDEFENDANTSTOAPPEARFORADEPOSITION.
ORALARGUMENTPRESENTEDBYCOUNSELFORDEFENDANT.
STUBBLEFIELDPROPERTIES,ACALIFORNIA'SMOTIONTOCOMPELISGRANTED.
ASTOBOTHDEFENDANTS.
THISCOURTWILLNOTGRANTANYSANCTIONS.
DEPOSITIONDATESAREASFOLLOWS:
BONNIESHIPLEYSETFOR01/05/15AT9:30AMINORANGECOUNTY.
NANCYDUFFYSETFOR01/06/15AT9:30AMINSANTABARBARACOUNTY.
11:15
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MOTIONRE:SETASIDEDEFAULTIMPROPERLYTAKENBYWITHOUTCOMPLYING
FILEDBYDEFENDANTNANCYBDUFFY,BONNIESHIPLEY
12/31/20148:00AMDEPT.F7A
VICTORROYSTULL,JUDGE
CLERK:SHOSHONENEAL
APPEARANCES:
PROCEEDINGS:
09:07
THECOURTHASREADTHEMOTIONTOSETASIDEDEFAULTANDOPPOSITIONTOMOTIONTOSET
ASIDE
DEFAULT.
NANCYBDUFFY,BONNIESHIPLEY'SMOTIONTOSETASIDEDEFAULTISDENIED.
09:29
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MOTIONRE:TOTRANSFERJURISDICTIONFILEDBYDEFENDANTNANCYBDUFFY,
BONNIESHIPLEY
12/31/20148:00AMDEPT.F7A
MATTERHEARDANDRECORDEDINDEPTF3
CLERK:SHOSHONENEAL
APPEARANCES:
PROCEEDINGS:
09:07
THISCOURTHASREADMOTIONSTOTRANSFERJURISDICTIONANDOPPOSITIONTOMOTION.
NANCYBDUFFY,BONNIESHIPLEY'SMOTIONTOTRANSFERJURISDICTIONISDENIED.
09:29
09:34
COURTRECALLSMATTERTOINQUIRYABOUTMOTIONTOTRANSFERJURISDICTION.
THECOURTSTATESFORTHERECORDTHATTHISMOTIONHASALREADYBEENHEARD,RULED
UPONANDDENIED.
THATISONEOFTHEREASONSFORTODAYSRULINGBYTHECOURT.
09:38
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MOTIONRE:TOCOMPELFURTHERRESPONSEWITHSEPARATESTATEMENTFILED
BYDEFENDANTNANCYBDUFFY,BONNIESHIPLEY
12/31/20148:30AMDEPT.F7A
CLERK:SHOSHONENEAL
APPEARANCES:
PROCEEDINGS:
09:07
THECOURTHASREADTHEMOTIONTOCOMPELANDOPPOSITIONTOMOTIONTOCOMPEL.
COURTTENTATIVEISTOGRANT70.12
NANCYBDUFFY,BONNIESHIPLEY'SMOTIONTOCOMPELASTO70.12ISGRANTED.
PLAINTIFFTORESPONDWITHIN5DAYS
NANCYBDUFFY,BONNIESHIPLEY'SMOTIONTOCOMPELASTO12.2,12.3,12.4,12.6ISDENIED.
ARGUMENTASTO71.5&71.5:
NANCYBDUFFY,BONNIESHIPLEY'SMOTIONTOCOMPELASTO71.4&71.5ISDENIED.
09:29
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01/05/20152:00PM
Receipt:1501052614$22.00
Code
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*FEE 1501052614CSFAR/22.00Paymt CDOUG
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MOTIONRE:FORANORDERTOCOMPELTIMOTHYMCCARRONTOAPPEAR,TESTIFY
ATDEPOFILEDBYPLAINTIFFSTUBBLEFIELDPROPERTIES,ACALIFORNIA
01/29/20158:00AMDEPT.F7
KYLESBRODIE,JUDGE
CLERK:SHOSHONENEAL
BAILIFF:A.VELA
APPEARANCES:
PROCEEDINGS:
11:16
THECOURTHASREADTHENOTICEOFMOTIONANDMOTIONFORANORDERTOCOMPELTIMOTHY
MCCARRON
TOAPPEAR,TESTIFYATDEPOSITIONANDOPPOSITIONTOMOTIONTOCOMPEL.
COUNSELFORDEFENDANTINFORMSCOURTTHATTHEREARE3MOTIONSSETFOR02/03/15.
COURTINFORMS
PARTIESTHATHEWILLREVIEWTHEMOTIONSASAP.THECOURTMAYNEEDTORESCHEDULETHE
MOTIONSTO
ANOTHERDAY.
PARTIESWILLBEINFORMEDIFTHEDATEFORTHEMOTIONWILLBERESCHEDULED.
COUNSELFORDEFENDANTREQUESTINGTELEPHONICAPPEARANCE.
DISCUSSIONHELDONTHERECORDREGARDINGTELEPHONICAPPEARANCE.
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NANCYBDUFFY,BONNIESHIPLEY'SMOTIONFORTELEPHONICAPPEARANCEISDENIED.
DENIALBASEDONTHISCOURTROOMNOTBEINGPROPERLYSETUPFORTELEPHONIC
APPEARANCESANDABILITYTO
HAVEAGOODRECORD.
11:43
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MOTIONRE:FORANORDERTOCOMPELINSPECTIONREQUESTFORMONETARY
SANCTIONSFILEDBYPLAINTIFFSTUBBLEFIELDPROPERTIES,ACALIFORNIA
01/29/20158:00AMDEPT.F7
KYLESBRODIE,JUDGE
CLERK:SHOSHONENEAL
BAILIFF:A.VELA
APPEARANCES:
PROCEEDINGS:
10:37
THECOURTHASREADTHENOTICEOFMOTIONANDMOTIONFORANORDERTOCOMPEL
INSPECTIONAND
REQUESTFORMONETARYSANCTIONSANDOPPOSITIONTOPLAINTIFFSMOTION.
STUBBLEFIELDPROPERTIES,ACALIFORNIA'SMOTIONFORINSPECTIONSISGRANTED.
THISCOURTWILLALLOWINSPECTIONOFINSIDEOFMOBILEHOME.THECOURTWILLNOTALLOW
ANY
OPENINGOFANYCLOSEDCONTAINERS(DOORS,CABINETS,DRAWERS,ETC..)INSPECTIONLIMITED
TO
FURNISHINGSANDLAYOUT,INSPECTIONISLIMITEDTONOMORETHAN15MINUTES.
BALANCEOFREQUESTISDENIEDWITHOUTPREJUDICE.
STUBBLEFIELDPROPERTIES,ACALIFORNIA'SMOTIONFORSANCTIONSISDENIED.
PARTIESTOPREPAREORDERANDSUBMITTOCOURTFORSIGNATURE.
NANCYBDUFFY,BONNIESHIPLEY'SMOTIONFORSTAYTOFILEWRITISDENIED.
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MOTIONRE:TODISMISSFORLACKOFSUBJECTMATTERJURISDICTIONFILEDBY
01/29/20158:00AMDEPT.F7
KYLESBRODIE,JUDGE
CLERK:SHOSHONENEAL
BAILIFF:A.VELA
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10:21
THECOURTHASREADTHEREPLYMOTIONTODISMISSACTIONFORLACKOFJURISDICTIONOR
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AUDIOCDANDAUDIOUPLOADOFTHEELECTRONICALLYRECORDED
PROCEEDINGSHELDON01/29/15,PURCHASEDBYDEF
01/29/201511:49AM
Receipt:1501291208$22.00
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*FEE 1501291208CSFAR/22.00Paymt RPAP
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HEARINGRE:MOTIONSSETFOR02/03/15
01/30/20159:30AMDEPT.F7
KYLESBRODIE,JUDGE
CLERK:SHOSHONENEAL
APPEARANCES:
PARTIESNOTPRESENT:STUBBLEFIELDPROPERTIES,ACALIFORNIA,NANCYBDUFFY,BONNIE
SHIPLEY
PROCEEDINGS:
ONITSOWNMOTION,THEHEARINGONDEFENDANTSMOTIONFORTERMINATINGSANCTIONSAND
TOCOMPEL
RESPONSESARERESETFOR02/10/15AT8:30AMINDEPT.F7.
THECLERKISORDEREDTONOTIFYTHEPARTIESBYTELEPHONE.
BYTELEPHONE&MAILINGOFMINUTEORDER
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MOTIONRE:TOCOMPLERESPONSESTOBONNIESHIPLEYSDOCUMENTINSPECTION
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10:17
THECOURTHASREVIEWEDDEFENDANTSMOTIONFORDOCUMENTPRODUCTION,TERMINATING
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DOCUMENT(S)SUBMITTEDFORREVIEW.
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02/13/20151:12PM
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*FEE 1502132158CKFAR/22.00Paymt CDOUG
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EXPARTERE:ORDERTOENJOINANDRESTRAINDEFNANCYDUFFYMCCARFILED
BYSTUBBLEFIELDPROPERTIES,ACALIFORNIA
02/18/20151:14PM
Receipt:1502182081$60.00
1502182081MCReferenceNumber270163313708
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*REFNM 1502182081MCReferenceNumber270163313708
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EXPARTEMOTIONREORDERTOENJOINANDRESTRAINDEFNANCYDUFFY
MCCAR
02/19/20158:00AMDEPT.F8A
08:57
LILYLSINFIELD,JUDGE
CLERK:SUSANKING
BAILIFF:ALFREDBENNETT
APPEARANCES:
ATTORNEYROBERTWILLIAMSONJR.PRESENTFORPLAINTIFF/PETITIONER.
PARTIESNOTPRESENT:NANCYBDUFFY,BONNIESHIPLEY
PROCEEDINGS:
MOTION
STUBBLEFIELDPROPERTIES,ACALIFORNIA'SMOTIONORDERTOENJOINANDRESTRAINISHEARD.
STUBBLEFIELDPROPERTIES,ACALIFORNIA'SMOTIONORDERTOENJOINANDRESTRAINIS
DENIED.
DENIEDWITHOUTPREJUDICE
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FILINGFEEPAIDBYSTUBBLEFIELDPROPERTIES,ACALIFORNIAFORTWOMOTIONS
SETFOR03/18/15
03/02/20157:27AM
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GMART
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RULINGONSUBMITTEDMATTER
03/02/20154:00PMDEPT.F7
KYLESBRODIE,JUDGE
CLERK:SHOSHONENEAL
STUBBLEFIELDPROPERTIES,ACALIFORNIA'SMOTIONFORORDERTOCOMPELTIMOTHY
MCCARRONTOAPPEARISDENIED.
STUBBLEFIELDPROPERTIES,ACALIFORNIA'SMOTIONFORMONETARYSANCTIONSISDENIED.
CORRESPONDENCECOVERSHEETGENERATEDTOMAILRULINGONSUBMITTEDMATTERTO
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HEARINGRE:MOTIONSUNDERSUBMISSION/NEXTHEARINGDATE
03/06/20154:30PMDEPT.F7
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CLERK:SHOSHONENEAL
PROCEEDINGS:
MOTIONSTAKENUNDERSUBMISSIONON02/10/15ISORDEREDVACATED.MOTIONSTOBEHEARD
ATADATE
TOBEDETERMINEDBYJUDGESACHS(DEPT.S28).
COURTORDERSTHISCASETOSANBERNARDINOJUSTICECENTERTOBEHEARDWITH
UDDS1204130.
COURTORDERSMOTIONSTHATARESETTOBEHEARDON03/18/15INDEPT.F7TOBERE
CALENDAREDFOR
03/18/15INDEPT.S28(SANBERNARDINO)TOEITHERBEHEARDORCONTINUEDTOADATETOBE
DETERMINED
BYTHATDEPARTMENT.
THECOURTNOWORDERSTHISCASEASSIGNEDTODEPARTMENT(S28)FORALLPURPOSES.
CLERK'SOFFICETONOTIFYPARTIES
CLERK'SOFFICETOSENDFILETOSANBERNARDINOFORNEXTHEARING
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FILINGFEEPAIDBYSTUBBLEFIELDPROPERTIES,ACALIFORNIAFORMOTION
03/12/20158:29AM
Receipt:1503120190$60.00
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MOTIONRE:ORDERTOCOMPELSTEPHENC.ALLENTOAPPEAR&TESTIFY/MISC
FILEDBYPLAINTIFFSTUBBLEFIELDPROPERTIES,ACALIFORNIA
03/18/20158:30AMDEPT.S28
MICHAELASACHS,JUDGE
APPEARANCES:
PROCEEDINGS:
COURTTREATSNOTICEOFUNAVAILABILITYOFCOUNSELSUBMITTEDBYATTORNEYMCCARRON
ASAREQUESTFOR
CONTINUANCE.
MATTERISCONTINUEDDUETOATTORNEYMCCARRONSEMERGENCYSITUATION.
COURTNOTESNOOPPOSITIONTOMOTIONFILED.
COURTDOESNOTCONTINUEDUEDATESFORFILINGOFOPPOSITION.
COURTFURTHERSTATESCHRONOLOGYOFCASEONRECORD.
COURTADDRESSESFILINGOFCCP170.6FILEDBYDEFENDANT.PEREMPTORYCHALLENGEAGAINST
JUDGE
SACHSISDENIED.FORADDITIONALCOURTFINDINGSANDRULINGSEEATTACHEDREPORTERS
TRANSCRIPT.
COURTORDERSCSRREGINAVEGATOPREPAREATRANSCRIPTOFTHEPROCEEDINGSDATED
03/18/15.
ADDITIONALLY,COURTCONTINUESTODAYSMOTIONSTO4/10/15.MOTIONTOCOMPELSET3/19/15
AND
STATUSCONFERENCESET3/26/15AREBOTHCONTINUEDTO4/10/15.
ALLHEARINGSSET4/10/15WILLBEHELDAT1:30PM.
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VACATESCUDHEARINGSCHEDULEDFOR03/26/15AT08:00INDEPARTMENTS28.
VACATEL&MHEARINGSCHEDULEDFOR03/19/15AT08:30INDEPARTMENTS28.
LAW&MOTIONRE:ORDERCOMPELLINGB.SHIPLEYFILEDBYPLAINTIFFSETFOR04/10/15AT01:30IN
DEPT.S28.
HEARINGRE:STATUSCONFERENCESETFOR04/10/15AT01:30INDEPARTMENTS28.
CORRESPONDENCECOVERSHEETGENERATEDTOMAILCOPYOFMINUTEORDER3/18/15TO
COUNSELOFRECORD.
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MOTIONRE:ORDERTOCOMPELSTEPHENC.ALLENTOAPPEAR&TESTIFY/MISC
FILEDBYPLAINTIFFSTUBBLEFIELDPROPERTIES,ACALIFORNIA
03/18/20158:30AMDEPT.S28
MICHAELASACHS,JUDGE
APPEARANCES:
PROCEEDINGS:
SEEPREVIOUSMINUTEORDERDATED3/18/15.
HEARINGS:
ACTIONCOMPLETE
VACATELM37HEARINGSCHEDULEDFOR04/10/15AT01:30INDEPARTMENTS28.
LAW&MOTIONRE:ORDERCOMPELMARGARETALLENTOAPPR/TESTIFYSETFOR04/10/15AT01:30
INDEPT.S28.
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EXHIBIT 8

Law Office of Nancy
950 Roble Lane
October 13, 2012
Honorable Marsha G. Slough
Presiding Judge
San Bernardino Superior Court
303 W. Third Street, Fourth Floor
San Bernardino, CA 92415-0302
Dear Ms. Slough:
sent via email to: mslough@sb-court.org

re: Dept. S-31 Limited Jurisdiction Court
Wilfred J. Schneider, Jr. Judge S-31
CONFIDENTIAL
I am writing to you about Department S-31 --- a Limited Jurisdiction Court. (<$25,000).
I have concerns about the way Judge Schneider is conducting mobile home evictions in S-31.
As you know Dept. S-31 adjudicates all Unlawful Detainer and Civil Harassment cases.
I took Bench Conduct, Demeanor & Decorum on 8-18-07 as part of my training to serve as
pro tem judge in San Bernardino. I have served 5 years since 8-18-07 and continue to serve.
I last served on 9-6-12 presiding over a DA Child Support calendar. I served several years
in Riverside Superior Court. I have adjudicated hundreds of cases in all areas including:
criminal arraignment, criminal sentencing, traffic court, juvenile dependency, juvenile
delinquency, family law, unlawful detainer, small claims, etc. I have never had a complaint
about my conduct as a judge and no appeals, except 1 or 2 traffic cases not about my ruling,
but based on allegations that police officers lied under oath. I am very familiar with UD law.
Judicial Bench Guides serve as a primary reference in ruling on Unlawful Detainer cases.
Landlord/Tenant Bench Guide 2012 (BG) recites that UD rules must be strictly applied as
UD home seizures not only result in loss of a place to live but often a litigants life savings.
The first section of the BG contains a judges checklist. No (3) Determine whether the
case is a regular unlawful detainer case explains that mobile home evictions are not
regular UD cases, and must be governed by CC 798-799.79. This scheme was enacted to
protect mobile home residents from arbitrary evictions under summary UD proceedings.
In enacting Mobilehome Residency Law (CC 798 et seq.), the Legislature
intended to provide a procedure for eviction of mobile home tenants which is less
summary than the unlawful detainer procedure established by CCP 1161-1179
Adamson Cos.v Zipp (1984, App Dept Sup Ct) 163 CA.3d Supp 1
Our Legislature enacted CCP 798.55 entitled, LEGISLATIVE INTENT; TERMINATION FOR CAUSE;
60-DAY NOTICE in which it declared that due to the high cost of moving mobile homes residents must
have unique protection, and can only be evicted on 60-days notice and only for just cause; i.e. for 7
statutorily defined reasons enumerated at CC 798.56. The first section of BG cautions a judge to prevent
the accidental confiscation of a mobile home in violation of 798.55 and 798.56 protections, by a park
owner who files for eviction of a resident in a summary proceeding to circumvent MRLs protections.
I believe Judge Schneider is disregarding the Benchguide and facilitating wrongful evictions through
summary proceedings in Dept. S-31, and authorizing mobile home park owners (rich republican developers)
to circumvent MRL protections and confiscate mobile homes in summary proceedings pushed through S-31.
Judge Schneider represented developers before his appointment and we think there is a connection with SP.
Arnold H. Stubblefield, a very wealthy developer, owns Mountain Shadows Mobile Home Community.
Attached as Exhibit A is a print-out of court cases registered under the name Stubblefield Properties (SP).
It shows six Unlawful Detainer cases and three abandonment cases SP prosecuted in summary proceedings.
I am defending a wrongful eviction on a mobile home I have owned since 1-05-2005 in Mountain Shadows.
SP has been trying to evict me since April of 2010 after I protested unconstitutional new rules at a meeting.
Because SP has never had just cause to evict me, SP is now trying to evict me through a back door tactic of
prosecuting a purported eviction of my co-resident in S-31 to take possession of, and steal my mobile home.
I researched Stubblefields -- rich republican developers-- before filing a demurrer to their sham eviction.
Stubblefields sued San Bernardino City when city officials did not authorize their city development plans.
Stubblefield Construction Co. v. City of San Bernardino (1995) 32 Cal.App.4th 687. SP lost the case and
all appeals. When that did not work SP tried to obtain city development approvals by bribing former city
councilman, Neil Derry, after his election as a County Superviser. Stubblefields laundered the $15,000 bribe
through a PAC administered by republican Tax Assessor, Bill Postmus. Derry pled guilty to misdemeanors
involving the bribe. Bill Postmus pled guilty to 14 corruption felonies. see Exhibit B. Dale Stubblefield
(from Hemet) was convicted of corruption crimes. see Exhibit C. Stubblefields corruption and attempts
to bribe city officials is well-documented in this area. We hope it has not infected our local court system.
We first encountered Judge Schneider when my co-resident, Bonnie Shipley, and I filed for protection
against civil and sexual harassment by Marvin Freeman, SPs acting park manager since April of 2010.
Both cases were assigned to Judge Schneider in S-31. John Pentecost appeared for Marvin Freeman, who
was not present at either TRO hearing. Eva Stubblefield Hazard and Tom Parrish (an SP general partner)
appeared at Freemans hearing, even though Freeman failed to appear. They made their presence well
known to Judge Schneider by standing next to Freemans lawyer and smiling at Judge Schneider. Everyone
noticed that they wanted Judge Schneider to realize they were connected to Marvin Freemans pending case.
Judge Schneider announced his denial of the TRO requests as soon as he called the case without testimony.
The judge set a consolidated hearing on the application for 8-29-12.
During the 8-29-12 hearing we were surprised that Marvin Freemans lawyer did not cross-examine us,
made few objections, and did not call any defense witnesses---not even Marvin Freeman, the respondent.
We will supplement this complaint with a transcript of the 8-29-12 hearing next week when it is finished.
Judge Schneider advocated so vigorously for Marvin Freeman that his lawyer found it unnecessary to speak.
Judge Schneider asked Freeman if he made the alleged sugar daddy remark to Shipley, fully expecting
Freeman to deny it as the Judge had read his verified response categorically denying all allegations.
All of us, especially the Judge and SPs lawyer, were shocked when Marvin Freeman actually told the truth.
Freeman admitted trespassing on my lot, after verifying that I was not there, in violation of Civil 798.26,
ordering Shipley to move out the next day, ripping a parking sticker off her car, making her cry, then saying
if she wanted to live in the park she had to get a sugar daddy over 55 to move in with and take care of her.
Freeman also admitted park owners had blacklisted me and anyone associated with me. My petition alleged
Freemans pattern of harassment against me and every co-resident since 2010 to drive me out of the park.
Judge Schneider denied protection. We did not appeal and never asked for attorney fees in our petitions.
We sought the order to prevent any further harassment by Marvin Freeman so that we could live in peace.
Although we perceived bias we thought the Judge just disliked harassment cases and rarely granted orders.
When we tried to review Judge Schneiders Form 700 disclosures county staff told us he had none on file.
Before the 8-29-12 hearing began we asked the Judge why his forms were not filed, and if he were affiliated
in some way with Stubblefield Properties general partners. The judge denied any affiliation with them.
2
Within a few days SP posted a 5-day Notice to Vacate against my co-residnet, Bonnie Shipley, citing
CC 798.75 --- an MRL code applying only to a purchaser of a mobile home who occupies the home
without first executing a rental agreement with park managers. SP attorneys knew CC798.75 did not apply
to Shipley as she had not purchased my mobile home. She had no duty to execute an SP rental agreement.
I had registered Shipley as my co-resident on 8-9-12. I cited Clause 10 of my 1-05-2005 lease, executed by
an SP agent, which authorized me to share my home with a co-resident without park approval and directed
me to CC 798.34(b) concerning space occupancy. I recited the relevant sections as follows:
No persons other than those listed on the signature page of the lease, and
one guest (where Resident would otherwise be living alone), may reside at
the space without Parks prior written consent
and
Please refer to Rules and Regulations of the Park and to the Mobile Home
Residency Law 798-799.6 of the California Civil Code for further
clarification of use and occupancy of the mobile home and Space. Lease-Clause 10
Civil Code 798.34(b), which was incorporated by reference in Lease-Clause 10, recites:
(b) A homeowner who is living alone and who wishes to share his or her mobile home
with one person may do so, and a fee shall not be imposed by management for that
person. The person shall be considered a guest of the homeowner and any agreement
between the homeowner and the person shall not change the terms and conditions of
the rental agreement between management and the homeowner. The guest shall
comply with the provisions of the rules and regulations of the mobile home park.
Rule 2, of the former and current Rules & Regulations recites that only the homeowner
need be 55 years old; any other resident need only be over 40. Shipley qualifies at age 51.
On 8-27-12 SP served an Unlawful Detainer summons on Bonnie Shipley at space 333,
with an attached imaginary forcible detainer complaint alleging a hypothetical fact pattern
of a purchaser who had moved in without first executing a rental agreement with the park,
including imaginary damages of $30.01 per day for fair market rental value. Damages were
alleged despite that SP had collected market rent ($958) from me for August & September.
Even a layperson knows a landlord cannot evict a tenant paying rent by evicting a roommate.
Even a layperson knows a landlord cannot collect double rent from 2 people for the same unit.
Within 5 days of service we filed Demurrer, Motion to Strike Attorney Fees & Damages,
Motion to Quash, and Request for Judicial Notice of admitted, undisputed facts, setting a
hearing for 9-27-12. Judge Schneider knew the true facts on three related cases because he
conducted the 8-29-12 hearing, in which he cross-examined Shipley and I about space #333.
Schneider asked Shipley about what type of lease she had signed for sharing space #333.
Shipley testified that she moved in on 8-1-12 to share the home as my co-resident. Schneider
asked Shipley how many times I slept at the home during August. Shipley responded nine.
I testified about Clause 10 of my lease, which was attached as an exhibit to my trial brief.
Opposing counsel did not object. SP admitted my 1-05-2005 lease in its own trial brief.
SPs brief admitted that I was a homeowner and my lease with SP was governed by MRL.
Judge Schneider knew the true facts in the UD case because he cross-examined all parties
in the harassment case just a few weeks earlier. He knew I owned the mobile home, and that
Shipley was my co-resident. He knew Shipley had not purchased the mobile home from me.
He knew that I was SPs tenant in actual possession of the home and that I had paid the rent.
He could see by Complaint Exhibit A that SP had not served me---the tenant in possession.
Any reasonable Judge, or even a layperson, reading the demurrer, MTS, and MTQ with
Judicially noticed documents, could only arrive at one conclusion; i.e. SP had filed a SHAM
complaint! The required pre-complaint Notice to Vacate (Exh. A to the complaint) did not
match either the UD summons or the imaginary forcible detainer sham complaint.
BG, 31.3 cautions the judge to compare allegations in the notice to make sure they
match allegations in the complaint. If Judge Schneider had followed 31.3 he was required
to sustain the demurrer without leave to amend because he knew it was a SHAM complaint.
He knew SPs Notice did not match its allegations in the complaint or the UD summons.
He knew SP could not amend a complaint to state a forcible detainer claim against Shipley.
Despite knowledge of undisputed facts and the law he denied all three motions, and ordered
Shipley to answer a sham complaint which was a highly prejudicial abuse of discretion.
BG 31.6 explains that a judge must transfer a case, upon motion, or sua sponte, where
it appears that limited jurisdiction is improper because the home plaintiff seeks to seize in
the summary proceeding, is worth more than $25,000, or where issues of title, possession,
and occupancy are disputed, or where the case involves eviction of a mobile home resident.
Judge Schneider ignored 31.6 and refused to transfer the case to unlimited jurisdiction.
This is because he fully intended to facilitate SPs wrongful eviction of Shipley, and intends
to order seizure of my mobile home with an order directed at Shipley, thereby authorizing
SP to confiscate my mobile home in a proceeding infected with Stubblefield corruption.
At both hearings (8-27-12 and 10-4-12) Judge Schneider failed to post a tentative ruling.
While announcing a decision in every other case, in our case he took it under submission.
This was to suppress my ability to challenge the reasons for his rulings or object on record.
At the second hearing, he would not let me make objections on the record or ask for a stay.
I was shocked that after 5 years of serving as a pro tem judge without pay, that one of my
colleagues would treat me with such disrespect; would rule against the law and undisputed
facts, and would facilitate the wrongful confiscation of my home through outright fraud!
On October 9, 2012 we filed a writ petition and ex parte application to prohibit any
further proceedings in S-31 pending outcome of the writ of mandate. I respectfully ask you
to investigate how Judge Schneider is running S-31, and the Stubblefield Properties cases
filed in S-31. We think Judge Schneider is cooperating in SPs overall plan to filch mobile
homes from elderly residents to convert its park into an interim cash cow of rental units,
while waiting to reach the thresh hold number of non-owner occupied homes to apply to
the City and/or County of San Bernardino for a change of use permit to either sell the land
to Indians for casino development or convert it to a more profitable enterprise for partners.
Despite Neil Derrys conviction for corruption, through Bill Postmus, Stubblefield is
bankrolling Neil Derry republican campaign for county supervisor. see Exh. D, which is a
picture of a Neil Derrys signed mounted on SPs property in front of the mobile home park.
4
GLOBAL POLICY CONSIDERATIONS
I have written to you not only because of the grave injustices being perpetrated by
Judge Schneider in S-31 in Stubblefield v. Shiplev UDDS1204130 and the disrespectful
treatment I have received in his courtroom, but also on behalf of all residents in SP's park.
Stubblefields have already confiscated nearly 112 of the mobile homes inside the park.
There are 402 homes in the park with average rents of $1,000-$1,300 per month, per space.
Stubblefields bank $400,000 monthly income, and have banked this high income for years.
In April of 2010 Stubblefield hired Hart, King & Coldren, a large Santa Ana firm
specializing in eliminating rent control and busting park residents, to design an overall plan
to obtain a "change of use" permit to sell SP's land to Indians for casino development, or
convert SP's land to a more profitable enterprise for SP partners to develop themselves.
The firm replaced a simple, pre-existing 14-page "Rules & Regulations" in effect when
I bought a home, with a 2010 version of onerous, restrictive, and unconstitutional rules.
New rules were designed by the law firm to facilitate resident evictions for rule violations.
SP installed two video cameras a t the park entry gate to film every vehicle's license number
and every person entering or exiting the park. Each guest is forced to state a first name,
last name and the resident's namelspace # helshe is visiting before the gate is lifted to enter.
SP installed video cameras at the poolside to film every person swimming in the pool.
SP installed video cameras inside the clubhouse to film every person who is using facilities.
Life in the park is like a prison where surveillance cameras are mounted a t every juncture
to capture 'evidence" of any purported "violation" of any new 2010 rule for a new eviction.
The rules are so onerous, and the ongoing intentional harassment so severe, that many
residents have abandoned mobile homes just to escape living like prisoners inside a regime.
It is nearly impossible for a resident to sell a home because any potential buyer who
sees surveillance cameras and reviews "Rules & Regulations" drives away without an offer.
A resident can not sublet without park approval which is denied under pretext of reasons.
The new rules prohibit roommates. Many residents can not afford the exorbitant space
rents SP charges ($1000-$1300) on a fixed social security income. There is no rent control so
Stubblefields continue to gouge elderly residents until they are forced to abandon the home.
SP then moves the new acquisition into its portfolio of "non-owner occupied rental units.
SP advertises the rental units in monthly newsletters and on billboards around the park.
see Exh. D - a rental ad mounted on SP's endorsement of Nick Derry for county supervisor.
see Exh. E - a picture of one of SP's "non-owner rental units" advertised for $1,30O/month.
By converting homes to "non-owner occupied rentals SP avoids MRL eviction protections
because only homeowners are protected. SP is free to evict occupants on 30 day notice.
We respectfully ask you to investigate how Judge Schneider handles mobile home
seizures and evictions filed by Stubblefield Properties under limited jurisdiction in S -31.
Civil Names
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WEBSITE: www.
This beautiful home at the "TOP"of the park has a magnificent view!
2 bedroom12 bath with French doors leading onto the balcony from the master bedroom!
Fireplace large laundry room and a 2 car garage!
View from balcony
Living room leading onto balcony.
Beautiful Kitchen
Balcony as seen from below7
Superior CLourt of CLaIifornia

CLountp of %an Gernarbino
Marsha G. Slough
Presiding Judge
303 West Third Street, Fourth Floor

(909) 708-8769
Fax: (909) 708-8782
October 16, 2012

--
--
--
~ a n c yDuffy ~ c ~ % r o n Law Office of Nancy

950 Roble Lane
Santa Barbara. CA 93103
Dear Ms. Duffy:
I have received your email dated October 13, 2012, wherein you registered a complaint
about the handling of your case by'Judge W~lfredJ. Schneider. This followed our meeting
wherein you advised me of your issues and wanted to leave portions of the file with me.
As we discussed, I am an Administrative Presiding Judge, not a court of appeal. I
cannot re-decide or reverse decisions made by the judge. You must file an appeal or writ to
accomplish that, and indeed you informed me that you have filed a writ.
As presiding judge, I do oversee the judicial officers in the court. However, that oversight
function does not give me the power or authority to chaqge, vacate or set aside any decision of
another judicial officer. In other words, the law does not permit me to sit as a court of review, or
the pass on the factual findings'or legal rulings of judges. Rather, my role is limited to reviewing
complaints alleging in appropriate demeanor, bias, prejudice, or other conduct that fails to
comply with the Code of Judicial Ethics.
It is my understanding that you are concerned about a potential biaslprejudice as well as
Judge Schneider's demeanor during the hearing. I am forwarding your email to Judge Garza,
who is the supervising judge of Judge Schneider for her to complete an evaluation of your
concerns. She will have a response to you on or before November 16, 2012.
>\-MARSHA G. S
Presiding Judge
MGS:kc1
--
--

Law Office of Nancy
950 Roble Lane
October 26,2012
Presiding Judge

CONFIDENTIAL - PART 2
Dear Ms. Slough:

Thank you for your prompt response to our request to investigate potential biastprejudice
and the manner in which evictions of mobile home residents are wrongfully prosecuted in
SUMMARY PROCEEDINGS in Dept. S-31instead of Superior Court, which has exclusive
jurisdiction per Civil Code 9798.55 & 5798.56, as reaffirmed by stare decisis
"In enacting Mobilehome Residency Law (CC 798 et seq.), the Legislature
intended to provide a procedure for eviction of mobile home tenants which

is less summary than the unlawful detainer procedure established by CCP
1161-1179Adamson Cos.vZipp (1984, App Dept Sup ~ t 163
) CA.3d Supp 1
Your response recited that you asked Judge Schneider's supervisor, Judge Garza to evaluate
and provide a response by 11/16/12. We have an urgent issue concerning clerks in S-31 and a t
the court's filing windows. Jessica, who answered Judge Garza's telephone line, directed me to
contact your office as Judge Garza is on vacation. Jessica also gave me a contact number for Kzm
Greve a t 909-708-8680, My concern is that our cases seem to be red-flagged by clerks in S-31
and a t the filing windows. We encounter roadblocks each time we try to file court pleadings.
The following is a history of roadblocks thwarting our ability to timely file court pleadings:
1. OCTOBER 3, 2012 window clerks tried to prevent Ms. Shipley from filing her answer.
At the 9-27-12hearing on Demurrer, Motion to Strike Attorney Fees, and

Summons, Judge Schneider announced his ruling in every other case but
Judge Schneider then announced he would "take it under submission." I
take to rule. Judge Schneider responded that he would "rule today
Judge Schneider gratuitously commented about my being a witness in Bonnie
which revealed his true intent to overrule our Demurrer, MTQ, & MTS and set
Why else would he make the gratuitous comments? Why didn't he just
ruling a t the hearing? Why doesn't he post tentative rulings
Is he trying to suppress objections or is it because he has no
(see attached transcript of hearings on 9-27-12 and 10-4-12
trial,
My husband returned to S-31 at 3145 pm to obtain a copy of the minute order from the clerk.
There was no explanation for the denial. "Demurrer overruled and both motions "denied."
The clerk gave my husband the minute order which required Bonnie Shipley to file an answer
to Stubblefield's imaginary forcible deatiner complaint within 5 days ofreceiving notice of the
court's ruling. It did not use traditional language; i-e. within 5 days of mailing of the ruling.
We were worried a s opposing counsel had already served us with a "request to enter default"
against "all unknown occupants" the next morning after a 5-day window to answer had expired.
Accordingly, we decided to file Shipley's answer on 10/3/12 (the Hth day after receiving notice).
This turned out to be a prudent decision because the "clerk's mailing" of the ruling, although
SIGNED ON THURSDAY 9-27-12 (the same day as the hearing and entry of the minute order)
the POSTMARK on the envelope was the following Monday (10-1-12) - FOUR DAYS LATER
Since the envelope was not deposited into regular US mail until FOUR DAYS LATER (10-1-12)
it could not possibly reach Santa Barbara before the 5 day window had already expired. (Exh A)
If I had not sent my husband back to court at 3:45 p.m. on 9-27-12to get the minute order
a default would have been entered against Bonnie Shipley a t 8:00 am on 10-4-12(day 6).
Since our motion to transfer jurisdiction was on calendar at 7:30 a.m. on 10-4-12(before the
filing window opened) they were planning to request default to be entered a t 8:00 a.m, while I
was waiting inside Dept S-31 for our case to be called on for a 7:30 am motion to transfer.
Realizing this was the plan I emailed Bonnie Shipley her answer to verify early on 10-3-12
with my electronic signature and proof of service. I told Bonnie to print 2 copies and bring a
conformed copy home. I told her not to leave the court until the clerk had accepted her answer.
As anticipated the clerk tried to prevent Bonnie from filing her answer which was due that day.
First she told Bonnie they could not accept it with an electronic signature. This is not true.
I have filed pleadings with electronic signatures for years. Bonnie called to ask me what to do.
I authorized her to insert my initials in wet ink next to my electronic signature and try again.
The clerk then said she could not accept the answer because there was "a motion on calendar."
Bonnie asked what any motion had to do with filing her answer? The clerk told Bonnie she had
to submit a "PROPOSED ANSWER with a motion." As you know, submitting a PROPOSED
ANSWER with a motion is only required after a default has been entered and a defendant has to
file a motion to set aside default. It could not have been entered until the next day Oct 4, 2012.
Why did a clerk tell Bonnie she had to file "Proposed Answer?" Bonnie persisted and told the
clerk she could not leave without filing her answer. The clerk finally said she would "check to see
if the computer would not block her answer." The computer only blocks filing an answer if a
default has been entered against a defendant. When the computer did not reject it the clerk
finally accepted it. Bonnie had to push and insist on the filing until the clerk finally accepted it.
Who told the clerks to try to thwart Shipley from filing her answer on October 3,2012?
Why was the clerk talking about filing a "PROPOSED ANSWER with a motion" instead of just
filing Bonnie's answer?
2. OCTOBER 9,2012
I filed a writ petition and tried to deliver a copy of the writ to Judge Schneider, a s required.
The courtroom was dark but a deputy sat at the counter in front of 5-31. I asked him to deliver a
copy of the writ to Judge Schneider. He said it had to be delivered at the regular filing window
across the hall and told me t h a t he could not accept the writ copy or deliver it to the Judge.
When I tried to deliver the Judge's copy a t the filing window the clerk said she had to check
with a supervisor and would return in a few minutes. I walked back to S-31 to ask the deputy if
the court reporter was expected to return so I could order a transcript. He said court staff would
return a t 1130 p.m. The filing window clerk called me on my cell phone just a s I was walking
back to her filing window. She said I had to deliver the Judge's writ copy to his clerk in S-31.
I had to wait until 1:30 before the court staff were scheduled to return, according to the deputy.
I decided to find your office to report what was going on with mobile home evictions in S-31.
When we briefly spoke you asked me to submit my concerns in writing. I did not get a chance to
tell you what had happened when Bonnie tried to file her answer on 1013112. I returned to S-31
to find the court staff was showing a video on small claims procedures for litigants on calendar.
I approached the clerk and tried to deliver the Judge's writ copy. The clerk refused to take it and
insisted that I had to deliver it across the hall at the filing window, just a s a deputy said earlier.
I returned to the filing window for the SECOND TIME to try to deliver the judge's writ copy.
The clerk said, a second time, I had to deliver the writ copy to S-31. I finally realized the clerks
in S-31and a t the filing window were just bouncing me back and forth aimlessly. I told the
clerk I would no longer waste my time returning to S-31 for a THIRD TIME only to be rejected.
I asked her to call a supervisor. She left her station while the papers were sitting on her desk.
I departed as I realized the clerks were going to continue to bounce me back and forth again.
Later, I received a voicemail from Marsha Moore, who identified herself a s a supervisor,
directing me to "return to the court to pick up the writ copies I had left at the filing window."
By then I was i n Santa Barbara. I returned Ms. Moore's call to suggest that she establish some
type of clear procedure for delivery of a Judge's copy of a writ. Ms. Moore became very hostile.
Ms. Moore said "she recognized my name when she saw the writ copy" and accused me of
regularly "dumping pleadings at the window." This was not true. Ms. Moore criticized my
pleadings remarking t h a t they were "less than the standards she was accustomed to seeing."
I asked her what she meant by that. She said my proof of service had a date crossed out on it.
I explained that it was printed with 1018112 but the court was closed and we had to return the
next day, which was October 9, 2012 so I simply crossed out the 8, and wrote a 9. No big deal!
Ms Moore then admitted t h a t Judge Schneider was not even in the courthouse that day as he
was on vacation. Ms. Moore assured me that when Judge Schneider returned the writ petition
copy which had been left at the window would be sitting on his desk.
Bottom line: Everyone knew (except me) that Judge Schneider was not there on 10-9-12.
All they had to do was take the copy of my writ petition and put it on his desk.
Instead, they bounced me back and forth for hours t h a t day. I respectfully ask
for a n explanation.
3. October 23,2012
(TUESDAY)
On October 23, 2012 I emailed Bonnie Shipley our Opposition to Stubblefield's motion for
$39,916 in Attorney Fees as opposition was due 9 days before the 1016112 hearing. (CCP 1005)
Bonnie and I had both applied for a restraining order against Marvin Freeman, park manager.
Both applications were heard in a consolidated short hearing on 8-27-12in S-31. (see transcript)
Bonnie and a friend went to the court before 1pm to file the Opposition I had emailed.
They encountered the same roadblocks I had encountered on October 9, 2012; i.e. the clerk a t
the filing window told them they had to file the opposition with the clerk in Department $31.
When they went to S-31they were told to return a t 1130 p.m. When they returned the clerks
were showing the same video to small claims litigants as they were showing when I was there.
Bonnie's friend was told they had to wait for the video to conclude.
He had to sit through the entire video until after 2100 p.m. Finally, they waited while
Kristen Cornett brought the opposition to the clerk next to the Judge's seat. The clerk gave the
opposition back to Kristen who returned it to Bonnie, telling her the clerk would not take it,
and that she had to file it across the hall a t the filing window. They returned to the filing
window and told the clerk they were tired of the run-around and were not going back to S-31.
The clerk then gave Bonnie a "rejection paper" stating they would not accept the opposition
because it had the TWO NAMES and the TWO CASE NUMBERS on the cover and POS.
THIS IS DESPITE THAT THE CLERKS HAD ACCEPTED THE IDENTICAL TYPE OF
COVER PAGE AND POS FROM STUBBLEFIELD---THE OPPOSING PARTY!!! (Exh. B)
Bonnie called me as she didn't know what to do and it was after 3 pm. There was not
enough time to drive home, retrieve new cover sheets and proofs of service from me by email,
and drive back to the court before it closed a t 4100 p.m. I told Bonnie to ask for white out a t the
help desk to remove the second name and second case number on each of the oppositions,
and to remove the second case number listed on both of the respective proofs of service.
The clerk said she did not have any white out. I told Bonnie to take a black pen and put a line
through the second name and second case number on each respective opposition to comply.
Bonnie returned to the filing window a t 3:45 p.m. Even though the papers now showed only
ONE CASE NAME AND ONE CASE NUMBER the clerk refused to file the two oppositions.
The clerk said they would not accept a pleading with a black line through a caption name.
Bonnie explained that the oppositions were due that day and the court was closing at 4100 pm.
The clerk did not care and refused to take the oppositions. Bonnie had to leave without filing
the oppositions after wasting THREE HOURS a t the courthouse trying to file the oppositions.
I redid the cover pages and proofs of service to look exactly the way the clerk demanded and
emailed it to Bonnie that night. Bonnie returned with the papers exactly as they had ordered.
The clerks gave them the same run-around again claiming they could not accept oppositions
and that Bonnie had to file them in S-31. Bonnie went to S-31. I had told Bonnie not to leave
the filings without getting a purale-stam~edconformed copv to Drove we had filed o~positions.
The clerk stamped both identical oppositions and the two "cover pages" for proof of filing.
The clerk returned the two conformed cover pages and mv original opposition to Bonnie.
Returning my opposition to Bonnie meant that the opposition would not be contained in my file
when the judge reviewed the file for the motion. A Judge can grant a motion if no opposition is
on file when he reviews the file to rule on the motion. To return my opposition to Bonnie,
rather than file it in my case file made no sense.
I told Bonnie to bring my opposition back to S-31 and insist that the clerk put the
opposition into my case file. Due to various roadblocks our oppositions did not get filed until
the next day, which was a day late under the rules, although they were timely delivered on the
day they were due in exactly the same format as opposing counsel used. (see Exh. B)
Please explain why the clerks accepted the double case number, double name format from
Stubblefield's attorneys when they filed a trial brief, but rejected the same format from us?
BOTTOM LINE:
I have faithfully served this court without compensation for 5 years helping other judges.
I do not deserve this condescending and biased treatment. Who is ordering clerks in S-31
and the filing window across the hall to play these games? Why are our cases red-flagged?
We are being treated like the perpetrator when we are the victims. Park manager, Marvin
Freeman admitted allegations in our harassment petitions during the hearing. (see transcript).
Billionaire developer Stubblefield is trying to steal my mobilehome by prosecuting a sham
complaint in S-31 for "forcible detainer" against my lawful co-resident, Bonnie Shipley, while
collecting full market rent for space #333 (nearly $1,000 per month) from me, their long-time
tenant who has never missed a rent payment since purchasing the home in January 2005.
During a TRO hearing Stubblefield's attorney asked Judge Schneider to order me to serve
all legal papers on the firm-rather than directly to Marvin Freeman, who was initially served.
Mr. Freeman was not represented when we served him with TRO papers as was required.
Judge Schneider ordered me to serve any other papers on the law firm. I fully complied.
After the TRO hearing, the park's attorney continued to engage process servers to bang on
Bonnie Shipley's door, even as late as 10 p.m. to serve her directly despite that the firm knew
I was representing Bonnie and had sent written notice directing them to serve me with papers.
The firm ignored my notice and continued to engage process servers to serve Bonnie directly.
During the 8/29/12 hearing I asked Judge Schneider to make the same order he made for them.
Judge Schneider skirted the issue and refused to order it. (see transcript, p.27, line 21 et seq.)
Could you please explain the required procedure for filing motion and opposition papers?
It certainly is not clear to us because every time we try to file a pleading we get bounced back
and forth between the clerks in S-31 and the clerks in the filing room. We await a response
at your earliest convenience. Thank you for your cooperation.
+
SUPERIOR COURT OF CALI -;-'?llA
County of San & r ~ l d i n 0
San Bernardino District, Civil ulvision
303 West l'llird Street, First Floor
San Bernardino, CA 9 2 4 1 5 - ~ 0 ' ~ 0 ' f ~
www.sb-coc~rt.orq
c'
Robert S. Coldren, Esq., Bar No. 81710

John H. Pentecost, Esq., Bar ~u'o.99527
Robert G. Williamson, Esq. Bar No.
Richard P. Gerber, Esq., Bar No. 59395
HART, KING & COLDREN
A PROFESSIONAL LAW CORRORATION
200 Sandpointe, Fourth Floor
Santa Ana, California 92707
Telephone: (714) 432-8700
Facsimile: (714) 546-7457
Attorneys for Respondent MARVIN FREEMAN
SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF SAN BERNARDINO
12 NANCY DLTFFY McCARRON,
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, 1 BONNIE SHIPLEY,
Judge: VJilfred 3. Schneider, Jr.

Dept: S-31
Trial Date: August 29: 2012

Time: 9:30 a.m.
Dept.: S-31
Petitioner,
20
21
Assigned for all purposes to:
1
) TRIAL BRIEF
1
Respondent.
17
Case Nos. CIVDS 1208205 (Duffy)

CIVDS 1208367 (Shipley)
(1
v.
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MARVIN FREEMAN,
--
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Respondent Marvin Freeman, person from whom protection is sought in the ahox-e
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Respondent.
captioned consolidated matters, hereby submiis his Trial Brief in connection
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West jr?treet,
San Bernardino, California 9241 5 .
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I hearings on August 29, 2012 at 9:30 a.m. in Department S-31 of this Court located ar 311
16 11
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TRIAL BRIEF

Law OEce of Nancy
950 Roble Lane
November 13,2012
Presiding Judge
sent via email to: msloue;h@sb-court.org

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PS - 3 L
CO%D"ENT"","-~.P"&?
Dear Ms. Slough:

On October 9, 2012 I attempted to deliver a courtesy copy of a writ petition to Judge
~chneiderin S-31, the original of which was filed in the Appellate Division that same day.
I was delayed for hours by court staff in S-31and at S-31 filing window across the hallway,
while each set of clerks refused to accept delivery and kept bouncing me back and forth.
These roadblocks were explained in detail in my second letter to you dated October 26,2012.
During the delay I visited you briefly, on your way out to a meeting, because I had serious
concerns about the manner in which evictions of mobile home residents are being wrongfully
prosecuted in SUMMARY PROCEEDINGS in Dept. S-31instead of Superior Court, which
has exclusive jurisdiction per Civil Code 5798.55 & 5798.56, as reaffirmed by stare decisis :
"In enacting Mobilehome Residency Law (CC $798 et seq.), the Legislature
intended to provide a procedure for eviction of mobile home tenants which
is less summary than the unlawful detainer procedure established by CCP

1161-1179
Adamson Cos.vZpp (1984, App Dept Sup Ct) 163 CA.3d Supp 1
You asked me to put it in writing. On October 13,2012 I sent a letter. (see attachment)
You responded in a letter dated October 16,2012 reciting that you had forwarded my letter to
Judge Garza (Judge Schneider's supervisor) to evaluate and provide a response by 11/16/12.
In the meantime, on October 26,2012 I had to write to you again concerning immediate
concerns about S-31 clerks thwarting our ability to timely file papers. (see attachment)
I wrote to you because Judge Garza was on vacation and there was a n urgency to the matter
because my clients were thwarted from timely filing an opposition to attorney fee motion.
I explained in detail the roadblocks we encountered every time we tried to timely file papers.
I explained how the clerks tried to prevent Bonnie Shipley from filing an answer to complaint.
(see page I), how I was given the run around on 10/9/12 trying to deliver a writ (see page 2).
I explained how on 10123112 Bonnie Shipley was prevented from timely hling her opposition to
Stubblefield's motion for $40.000 attorney fees for a I-hour hearing on a harassment petition,
which Judge Schneider denied, despite Stubblefield's park manager's admission that he
trespassed on Lot #333, tried to orally evict Shipley, made her cry, ripped a parking sticker off
her car, and told her if she wanted to stay in the park she had to " h d a 55-yr old sugar daddy."
I included the transcript of the hearing where the perpetrator admitted this sex harassment.
It is interesting to note that Stubblefield's daughter Eva had no problem getting a civil
harassment restraining order issued in the same S-31court recently. (see attachment).
Bonnie's order was denied. Stubblefield now seeks $40,000 in "defense fees " for 1 hr hearing!
In the second letter I sent you dated October 26,2012 (see attachment) I documented all the
trouble the clerks gave Bonnie Shipley when she tried to file our opposition to the motion for
exorbitant attorney fees ($40,000 for a 1-hour hearing with no cross-exam by Stubblefield).
I explained how clerks told Bonnie Shipley that the two harassment cases [Bonnie Shipley v.
Marvin Freeman - CIVDS 12083671 & [Nancy McCarron v. Marvin Freeman -CIVDS 12082051
were NOT CONSOLIDATED and therefore she could not file a joint response with both case
numbers and both captions on the first page of the Opposition a s was being presented to file.
The clerks refused to file the opposition despite the fact that Stubblefield had filed papers with
THE SAME JOINT CAPTION WITH BOTH CASE NAMES ON A FIRST PLEADING PAGE.
I even attached Stubblefield's first page entitled "Trial Brief' as Exh. B to my 10/26/12 letter.
Bonnie had called me as they refused to take the papers. Since Bonnie had TWO COPIES of
the pleading with her, I told her to cross out the respective case name and number on each of
the two first pages so a s to conform to what the clerks demanded. The clerks refused to file it.
Bonnie had to return the next day with two copies of the same opposition with a new first page
on each one citing only the one case name and one caption. This caused opposition to be late.
Amazingly, after S-31 clerks refused to accept Bonnie's opposition on Oct 23, 2012--making
her return the next dav with new first pages, on October 31,2012 the same clerks accepted
STUBBLEFIELD's REPLY TO OPPOSITION in the exact format (double names & captions)
that clerks rejected when Bonnie tried to file in that format a week before. (see attachment)
Was this done to rub our nose in dirt? Or does Stubblefield own the court? We ask for a
response in writing as to why we are treated differently from preferred party Stubblefield?
As you know, my first letter discussed Stubblefield's bribes to Neil Derry while he was
County Supervisor and the resulting criminal convictions of Neil Derry and Bill Postmus.
My email included a picture of one of Stubblefield's signs supporting Neil Derry for election.
Fortunately, Mr. Ramos defeated Neil Derry (60%/40%of the votes) for County Supervisor.
Apparently, Stubblefield will not have a Supervisor to bribe anymore to get what he wants.
1.understand Ramos' election campaign was based on cleaning up corruption in the county.
Since Ramos won 211 we believe citizens are tired of Stubblefield corruption in the county.
TO THIS END WE RESPECTFULLY ASK FOR AN EXPLANATION AS TO WHY
STUBBLEFIELD IS GETTING OBVIOUS PREFERENTIAL TREATMENT IN S-31???
We want to know why S-31 is allowing Stubblefield to prosecute a n eviction against my coresident Bonnie Shipley, in a summary proceeding based on a n imaginary "forcible detainer"
complaint, based on an improper "5-day Notice to Vacate" which applies only to a purchaser.
(see attached writ petition explaining the facts and how the law is not being applied in S-31).
Please forward this PART 3 to Judge Garza. We await a response to our 3 letters.
Thank you for your cooperation.
A
Attorney for Bonnie Shipley

Robert G. Williamson, Jr. Bar No. 73176
A PROFESSIONAL LAW CORPORATION
Telephone: (714) 432-8700
Facsimile: (714) 546-7457
Attorneys for Respondent MARVIN FREEMAN
NANCY DUFFY McCARRON,
)
)
Case Nos. ClVDS 1208205 (McCarron)

CIVDS 1208367;(Shipley)
1 Assigned for all purposes to:

)
Petitioner,
v.
)
)
)
)
)
)
MARVIN FREEMAN,
Respondent.
i
)
BONNIE SHIPLEY,
Petitioner,
Judge: Wilfred J. Schneider, Jr.

Dept: $31
RESPONDENT'S COMBINED REPLY TO
(MCCARONISHIPLEY'S) OPPOSITION
TO RESPONDENT'S ATTORNEY'S FEES
MOTION
Date: November 6,2012

Time: 9:30 a.m.
Dept.: S31
v.
MARVIN FREEMAN,
1.
Respondent.
Given that an identical opposition was apparently filed by McCanon and Shipley to
Respondent's attorney's fee motion, Respondent combines his reply brief which is intended
t o apply So Petitioners, Nancy Duffy McCarron's and ~ o n n i eShipley's (collectively
27 "McCarron") Opposition to Respondent's attorney fees motion.
28 1
I
36568,02214836-1 882-9841v.l
R E S P O N D E N T ' S R E P L Y TO (MCCARROW A N D S H I P L E Y ) P E T I T I O N E R ' S O P P O S I T I O N T O ATTORNEY'S
F E E S MOTION.
Superior a o u r t of QLalifornia
aountp of S a n aernarbino
Donna Gunnel1 Garza
Judge of the Superior Court
November 15,2012
Nancy Duffy McCarron

Law Ofice of Na04
950 Roble Lane
.-
--
__ _ _ - - -
-----
Dear Ms. Duffy,

I am in receipt of the complaints that you have filed with Presiding Judge Slough, and now they have
been forwarded to me for review and investigation. I had currently completed my investigationof the
first two complaints, and today received your third. I would like however, to be able to give these
matters ample time necessary to be thorough and concise with all three of your complaints. With
that said, the completion of my investigation will be completed by November 28, 2012.
You should be hearing from me, on all three issues at that time. Thank you so much for your
continued patience.
f San Bernardino

Law Office of Nancy Duffy
950 Roble Lane
November 14, 2012
Presiding Judge

Dear Ms. Slough:

This is PART 4 in a series of complaints about the unprecedented prosecution in S-31 of an
imaginary forcible detainer complaint moving forward under an imaginary unlawful detainer
summons, deriving from a totally inapplicable 5-day Notice to Vacate [Civ 798.75] to evict a
purchaser of a mobile home who moves in without first executing a new lease with park owner.
Notice Served 8/11/12

The S-31 court should have sustained demurrer & threw this case out at a hearing on 9-27-12.
The court knew (from the courts own cross-examination of Bonnie Shipley and Nancy Duffy
McCarron on 8-29-12 in a hearing on petitions for protection against park manager Freeman)
that Bonnie Shipley did not purchase McCarrons mobile home and she was living in 333 as an
authorized co-resident pursuant to McCarrons statutory & contractual right to share a home.
Transcript 45:23 8-29-12

Bonnie Shipley testified that McCarron regularly sleeps at 333 and they share the home.
Judge Schneider even noted (see line14 above) that he was listening to what you are saying
also with regard to your case as well and the allegations that are being made. (the UD case)
THIS TRANSCRIPT SHOWS WITHOUT A DOUBT THE COURT KNEW SHIPLEY DID NOT
PURCHASE THE HOME FROM MCCARRON BUT LIVED THERE AS HER CO-RESIDENT.
This transcript proves the court knew the 5-day Notice to Vacate [Civ 798.75] to evict only
a purchaser did not apply to Shipley and was therefore legally invalid. The court knew that if
a notice to vacate is legally invalid there can be no valid unlawful detainer summons, and
no valid forcible detainer eviction which is used only against a trespasser or illegal squatter.
This is basic fruit of the poisonous tree doctrine where legality cannot derive from illegality.
This is basic hornbook law every judge should know as even lay persons know this doctrine.
Judge Schneider should have known, after his own 1-2 hr cross-examination of Shipley and
Duffy McCarron, the complaint Stubblefield filed was legally invalid based on an illegal notice.
The court should have sustained the demurrer without leave to amend and dismissed the case.
Instead the court ordered Shipley to answer the bogus, imaginary complaint and suffer even
more abuse from Stubblefield as his nasty, greedy attorneys kick her through the dirt daily.
The transcript excerpt directly above shows that park Manager Freeman admitted blatant
sex harassment, admitted making Shipley cry, admitted ripping a parking sticker off her car,
and admitted that the park harasses any person who has any affiliation with Nancy Duffy.
Despite these admissions the court refused to issue a protective order to keep Freeman away.
Then, Stubblefields attorneys had the flaming audacity to seek a court order to award them
$40,000 in attorney fees to defend Freeman at the 8-27-12 hearing lasting less than 2 hours.
This was because Stubblefield is so confident that he has the Judge and clerks in his pocket,
he believes the sky is the limit. Why not rape Shipley and Duffy with a $40,000 fee award?
Stubblefield has 4 new motions for exorbitant attorney fees against Shipley and Duffy.
These new motions are the most abusive pleadings I have seen in 20 years of practicing law.
Stubblefield seeks to rape Shipley and Duffy with a new request for Judge Schneider to award
$16,468.09 in attorney fees for 3 motions to compel depositions and an abusive motion to
compel unfettered inspection of the INSIDE OF MCCARRONs MOBILE HOME
1.) Motion to Compel Inspection of McCarrons private residence at #333+$1,730.00 sanctions
[see Proposed Order submitted to S-31 and McCarrons Opposition & Supplemental Briefing]
Proposed Order Filed in S-31

Stubblefield submitted this obnoxious order fully expecting Judge Schneider to sign
it and award $1,730.00 in sanctions for McCarrons refusal to submit to the humiliation.
Stubblefield fully expects Judge Schneider to sign whatever he submits despite the law.
His theory is that McCarron should be punished with a $1,730 sanction for daring to
object to having any random number of unidentified plaintiffs agents barge into her
private residence, including her private bedrooms and bathrooms to conduct nondestructive testing, measuring, videotaping and related activities. I have never seen
such audacity in 20 years of practicing as an attorney and 5 years as a pro tem judge.
A party only has the right to inspect the property of another party. CCP 2031.010(a)
There is no right to inspect a non-partys home. Any motion to compel must be personally
served on a non-party unless she agrees in writing to be served by mail. CRC 3.1346
Although McCarron is attorney for Shipley she is a non-party. McCarrons non-party
rights to limits upon discovery and service upon her under the proper rules of court can
not be denied or waived by a judge. The court lacks jurisdiction to ignore rules of court.
Attached is McCarrons Supplemental Briefing and Objections to Inspection of her home.
IT WOULD BE AN OUTRAGEOUS MISCARRIAGE OF JUSTICE FOR ANY JUDGE
TO ORDER SUCH AN INTRUSIVE VIOLATION OF THE RIGHT TO PRIVACY FOR
UNIDENTIFIED AGENTS TO VIDEOTAPE A PERSONS BEDROOMS & BATHROOMS
THERE IS NO JUSTIFICATION FOR THIS ORDER OR $1,730 SANCTION AWARD
2.) Motion to Compel the deposition of non-party Nancy McCarron + $4,615.32 sanctions
Stubblefields second abusive motion seeks to compel the deposition of defendants attorney,
despite that California public policy prohibits taking the deposition of opposing counsel absent
a strong factual showing of a compelling need and no other way to obtain the information..
The leading case is Spectra-Physics, Inc. v. Superior Court (1988) 198 CA.3d 1487 holding:
" 'Taking the deposition of opposing counsel not only disrupts the adversarial
system and lowers the standard of the profession, but it also adds to the already
burdensome time and costs of litigation. It is not hard to imagine additional
pretrial delays to resolve work-product and attorney- client objections, as well
as delays to resolve collateral issues raised by the attorney's testimony.
Finally, the practice of deposing opposing counsel detracts from the quality of
client representation. Counsel should be free to devote his or her time and
efforts to preparing the client's case without fear of being interrogated by his or
her opponent. Moreover, the "chilling effect" that such practice will have on the
truthful communications from the client to the attorney is obvious
"The circumstances under which opposing counsel may be deposed are limited to
those where (1) no other means exist to obtain the information than to depose
opposing counsel; (2) the information sought is relevant and not privileged; (3)
the information is crucial to the preparation of the case." 198 Cal.App.3d at p. 1496.
Spectra was reaffirmed in Carehouse Conv. Hosp. v. Supr Court (2006) 143 CA.4th.1558:
The adversarial system of justice presumes that the attorneys for each side oppose
one another, not depose one another. We issue a peremptory writ because plaintiffs
have failed to make the requisite showing of "extremely" good cause to overcome the
presumption against taking the deposition of defense counsel. Carehouse @ 1160
Depositions of opposing counsel are presumptively improper, severely restricted, and
require "extremely" good cause -- a high standard {Spectra}There are strong policy
considerations against deposing an opposing counsel. The practice runs counter to the adversarial
process and to the state's public policy to "[p]revent attorneys from taking undue advantage of
their adversary's industry and efforts..
Carehouse @ 1162
Our own Fourth Appellate District Court [in Riverside] recently reaffirmed Carehouse and
Spectra in Riverside Sheriffs Assn v. County of Riverside (2007) 152 C.A.4th 414:
[10] A presumption exists against deposing opposing counsel that can be rebutted
only by meeting a high standard of extremely good cause, as described in Carehouse
Convalescent Hosp. v. Superior Court (2006) 143 Cal.App.4th 1558, 1562-1564,
citing Spectra-Physics, Inc. v. Superior Court (1988)198 C.A.3d 1487, 1493-1496
Despite the strong public policy against deposing a partys attorney Stubblefield boldly
submitted a Proposed Order to Judge Schneider in S-31 to compel McCarron to appear for a
deposition the law forbids him to take, at a location 4 hours away (in Santa Ana) and finally to
compel her to PAY STUBBLEFIELD $4,615.32 as punishment for daring to object to the abuse.
THIS ONE IS BEYOND THE PALE!!!
4
3.) Motion to Compel Depo of non-party building inspector Steve Allen + $4,512.77 sanctions
Stubblefields third abusive motion seeks to compel the deposition of non-party building
inspector Steve Allen, who dared to file a complaint against Stubblefield with the building
department for failure to have any handicapped ramps for senior citizens in his senior only
park at the clubhouse, front office, or hobby house. Stubblefield professes to be so adamant
about enforcing the over 55 resident rule and uses this to evict anyone who dares to have a
roommate under 55 (as an excuse to steal their mobile home), yet he provides NOTHING for
elderly residents safety. In fact, Stubblefield has filched more than one third of the mobile
homes of elderly residents who can not afford to fight the billionaire and his ruthless attorneys.
Stubblefield has turned the mobile homes he filched into a cash cow of rentals to residents
under 55. He admits in pleadings to owning 402 spaces in the park rented to residents.
Average rent ($1,000 to $1,300) provides a cash cow income of $400,000-$500,000 per month.
THERE IS NO RENT CONTROL AND STUBBLEFIELD GOUGES MORE EVERY YEAR.
Yet, this is not enough for the greedy billionaire developer who tries to bribe every official in
San Bernardino County to get what he wants in a never-ending quest FOR MORE MONEY.
STUBBLEFIELD WILL TRY TO BRIBE COUNTY OFFICIALS TO GET WHAT HE WANTS!
This case is not about Bonnie Shipley. It is about STEALING MCCARRONs MOBILE HOME.
If Stubblefield can get a judge, at any cost, to order possession of #333 he can steal all of them.
NO ONE WOULD EVER DARE TO CHALLENGE HIS RUTHLESS, AMORAL ATTORNEYS.
Steve Allen, who is a friend of Bonnie Shipley and Nancy and Tim McCarron, came to the
park on September 28, 2012 to bring a present for McCarrons birthday and first anniversary.
Instead of celebrating McCarron had to work on papers due in court that day and had to drive
to Santa Ana to deliver objections to McCarrons deposition due 3 days before her noticed
appearance, which opposing counsel served her with at the 9-27-12 demurrer (5 days notice).
When Allen arrived at the gate, and opened his window to ask a gate guard to lift up the gate,
she threw a subpoena into his steering wheel and face. What a way to greet a park guest???
The irony is Stubblefield charges residents for the salary and benefits of those gate guards.
Stubblefield makes residents pay for gate guards to throw subpoenas at visiting guests!
Stubblefield is a true feudal lord hoarding his power over every facet of every residents life!
The subpoena thrown into Steve Allens lap by a gate guard on Friday afternoon, 9-28-12
commanded him to appear for a deposition on Wednesday 10/4/12 at 9 am (only 5 days notice)
in Santa Ana. As the following 2 days were the weekend Allen had only Monday & Tuesday to
try to find counsel willing to drive to Santa Ana the next day---a task impossible to accomplish.
This was clearly abusive. Secondly, counsel maliciously set the deposition on 10/4/12 in Santa
Ana, knowing that McCarron had already set a Motion to Transfer hearing in S-31 on 10/4/12.
Counsel did this to force McCarron into a Sophies Choice of either appearing in Santa Ana to
represent Allen (he was unable to find counsel on Monday to drive to Santa Ana on Wednesday)
or appearing for Shipleys motion in S-31. McCarron could not be in two places simultaneously.
McCarron asked counsel to continue the depo because Allen would not appear without counsel.
Instead Stubblefields counsel appeared by telephone at the Motion hearing in S-31 on 10-4-12,
and then had his self-serving deposition officer (whom the firm employs) produce a failure to
appear at deposition document to be used against Steve Allen in Stubblefields abusive motion
to compel his deposition and for an award of $4,512.77 in sanctions. This was beyond the pale!
4.) Motion to Compel Deposition of Bonnie Shipley + $5,610.00 sanctions

Stubblefields fourth abusive motion seeks to compel the deposition of Bonnie Shipley.
This was despite McCarrons email notice sent to opposing counsel on 10/9/12 reciting that
Shipley would fully cooperate and appear for a deposition in Santa Ana as soon as the appellate
court issued an order either granting or denying her writ petition, which is issued in 10 days.
The email attached to Shipleys Supplemental Brief and Opposition asked counsel to explain
what the rush was to take her deposition where there was no prejudice to plaintiff since they
already collected rent for the space from McCarron. Counsels email requested only a 10-day
delay to await the appellate courts ruling on the writ petition. This was a reasonable request.
McCarron fully expected counsel to respond to her email to acknowledge her cooperation and
confirm the arrangements. Instead, and without any forewarning, counsel served a 2 high
stack of 3 motions to compel depositions and a motion to compel inspection of McCarrons
mobile home. Each motion asked for exorbitant and unwarranted attorney fees as sanctions.
Billionaire developer Stubblefield seeks a total of $16,468.09 in attorney fee sanctions
against Bonnie Shipley, a person with no assets and minimal income. The motions also seek
$16,468.09 jointly against attorney McCarron to punish her for having objected to depositions
which were not noticed in compliance with mandatory discovery statutes, which were not
authorized under California law, and which were abusively set in Santa Ana---a 4 hour drive.
McCarron is a 63-year old retired attorney collecting $763 monthly social security, married to
Timothy McCarron, a 62-year old retiree who collects about $900 monthly social security.
There is only ONE issue in this case. Does Duffy McCarron have the right to a co-resident?
YES. She has a statutory right [Civil 798.34(b)] and a contract right [Clause 10 of her lease]
to have a co-resident, Bonnie Shipley, even if McCarron spends more time in Santa Barbara.
A homeowner who is living alone and who wishes to share his or her mobile home
with one person may do so, and a fee shall not be imposed by management for that
person. Civil 798.34(b) [from Mobile Home Residency Law at Civil 798 et seq]
No persons other than those listed on the signature page of this Lease, and one
guest (where resident would otherwise be living alone) may reside at the Space
without Parks prior written consent. [Clause 10 of park lease signed in 2005]
The governing MRL case [Otanez v. Blue Skies Mobile Home Park (1991 2ndD) 1 C.A4th.1521] held:
We hold that the tenant need not live in the

premises full-time in order to be a resident
The preceding 3 paragraphs unequivocally resolved the ONLY ISSUE IN THIS CASE.
The law was recited on page 3 of Shipleys demurrer which the court should have granted.
The judge knew the true facts as he cross-examined Shipley for an hour on 8-29-12 in S-31.
The judge knew plaintiff had admitted to all of the true facts in verified pleadings in his court.
The court should have dismissed this case on 9-27-12 as he knew it was a SHAM COMPLAINT.
Instead he overruled the demurrer facilitating and encouraging Stubblefields continued abuse.
WE WANT TO KNOW WHY?

950 Roble Lane
November 19, 2012
Presiding Judge
URGENT !!!

RE: CLERKS ARE STILL THWARTING OUR DUE PROCESS RIGHT TO FILE
Dear Ms. Slough:
purchaser of a mobile home who moves in without first executing a new residential lease with
park owner. It did not apply to Bonnie Shipley because she is not a purchaser but a roommate.
Judge Schneider ruled for Billionaire Stubblefield against us on 7 consecutive motions:
1
2
3
4
5
6
7
Shipleys application for a restraining order to stop ongoing harassment since 8/2/2012;
My application for a restraining order to stop harassment ongoing since May of 2010;
Overruled Demurrer to imaginary forcible detainer complaint on an invalid Notice to Vacate
Denied Motion to Strike Attorney Fees where no statutory or contractual basis exists
Denied Motion to Strike $30/day in Market Rent Damages while collecting full rent from me
Denied Motion to Transfer Jurisdiction to unlimited where assessed value of home is $27,800
Denied Motion to Quash Service as the imaginary complaint failed to state a cause of action
On October 26, 2012 I wrote to you (Part 2) about clerks throwing up roadblocks to thwart
our ability to timely file pleadings in S-31. Although you referred my October 13, 2012 letter
(Part 1) to Judge Garza, on October 26, 2012 I emailed you as Judge Garza was on vacation and
we had an immediate issue with clerks refusing to accept papers for format, although they had
previously accepted papers in the identical format from Stubblefield. I told you, that even after
rejecting our papers for format clerks accepted Stubblefields papers in the forbidden format.
I assumed you would have taken some action at that time to address this issue with the clerks.
Evidently you did not take any action, or if you did, it was ineffective as it is continuing.
Because Stubblefield prevailed on 7 out of 7 motions, resulting in his belief that Judge
Schneider was/is in his pocket Stubblefield decided the sky is the limit. Why not gouge?
Stubblefield moved the court for $40,000 in attorney fees for defending Marvin Freemans
ADMITTED SEX HARASSMENT (I sent you the transcript of the 8-27-12 hearing on it).
This was for a 5 minute TRO hearing plus a 1-2 hour hearing on our application for protection.
(no cross-exam, no witnesses called by the defense---not even respondent Marvin Freeman).
Perhaps Judge Schneider has finally seen the light because he denied their motion for fees.
Stubblefield is now seeking $16,648.09 in attorney fee sanctionsagainst me jointly:

1.) Motion to Compel Inspection of McCarrons private residence at 333+$1,730.00 sanctions
This motion is to compel unidentified plaintiff agents to barge into our mobile home, under a
demand for inspection with video cameras, audio equipment, testing equipment and cameras
to videotape, record, test, take pictures and samples in every room INSIDE OUR MOBILE
HOME, and all appurtenant structures, which has ABSOLUTLY NOTHING TO DO WITH
WHETHER I HAVE A RIGHT TO HAVE A CO-RESIDENT WITHOUT PARK APPROVAL.
2.) Motion to Compel the deposition of non-party Nancy McCarron + $4,615.32 sanctions
3.) Motion to Compel Depo of non-party building inspector Steve Allen + $4,512.77 sanctions 4.)
4) Motion to Compel Deposition of Bonnie Shipley + $5,610.00 sanctions
Stubblefield believes Judge Schneider is in his pocket and will grant them like candy.
These were filed to harass and intimidate Bonnie Shipley into moving out of the home!
This is because Billionaire Stubblefield is greedy for money any which way he can steal it!
Their motions were finished on Wednesday, October 23, 2012 (attorney signed it that day),
but were withheld from mailing until Friday Oct 26, 2012 and dropped in the mail after 5 pm.
This assured the postman did not pick them up until Saturday, and there is no mail on Sunday.
This assured McCarron would not even see the papers until the following Wednesday when
they finally reached Santa Barbara. This clever maneuver enabled Stubblefields counsel to
truncate McCarrons window of time to work on opposition down to the minimum amount.
Opposition was due Friday, only two days after actual receipt of the 2 inch high stack of paper.
to comply with court rules for a hearing the following Tuesday, November 6, 2012, counsel was
McCarron asked for a continuance at the hearing on Nov. 6, 2012. The court allowed McCarron
to submit supplemental briefing due two days later on Friday, Nov. 9, and authorized a REPLY
from Stubblefield due Nov. 12, 2012 purportedly 3 days after our Supplemental Brief was filed.
This gave Stubblefield another bite at the apple. Since 11/12/12 was a court holiday this gave
Stubblefield an extra day, and he took another extra day----not filing a REPLY until 11/14/12.
Net result was: McCarron got only 2 days while Stubblefield had 5 days to file a REPLY.
This is a significant issue when there are 4 motions and each one is hundreds of pages long.
Counsels REPLY contained numerous blatant misrepresentations of FACTS (all hearsay
as Stubblefields attorney is not a witness yet he peppers arguments with purported facts).
The REPLY contained numerous misrepresentations of law. Shipley needed to object to them.
Counsel did not receive Stubblefields REPLY until Thursday afternoon November 15, 2012.
Counsel stayed up the entire night Thursday to prepare OBJECTIONS to the REPLY and
emailed them to Shipley to file early Friday morning so Judge Schneider could read them.
CLERKS REFUSED TO FILE OBJECTIONS STATING THAT PLEADINGS WERE CLOSED.
THIS NOT ONLY VIOLATED DUE PROCESS BUT WAS BLATANT DISCRIMINATION.
CLERKS ACCEPTED STUBBLEFIELDS REPLY 2 DAYS LATE. Closing date was 11/12/12
and Stubblefield did not file until 11/14/12. Notwithstanding THIS violation of due process,
the clerks were wrong. Clerks are not attorneys and have no right to refuse to file objections.
Objections can be filed any time, even after a hearing. Unless filed they are waived on appeal.
2
I AM SENDING SHIPLEY BACK THIS MORNING TO FILE OUR OBJECTIONS AND

EXPECT THEY WILL BE IMMEDIATELY GIVEN TO JUDGE SCHNEIDER TO READ.
I instructed Bonnie Shipley to go back to court today to bring our Objections directly to S-31
and ask Judge Schneider to review them before ruling on the motions. $16,648.09 is at stake!
I told Bonnie Shipley that if the clerks refuse to take our Objections to submit to the judge
she should take an elevator to the fourth floor to your office so that your staff can intervene.
Apparently, either you did not address the thwarting of filing our papers issue when it was
presented in Part 3, or you thought Judge Garza would instruct the clerks not to discriminate
against us and she took no action, or the clerks ignored any directives coming from you or her.
We have not received a response from Judge Garza, although your letter indicated that she
would respond to our complaint by November 16, 2012. It is November 19, 2012 and we still
have not received a response from the court. We are concerned about not receiving a response.
If this pattern continues, and our concerns are ignored, we will be forced to file a new
complaint with the San Bernardino County Board of Supervisors who has jurisdiction over the
San Bernardino Courts and their staff because this discrimination in treatment must stop.
Stubblefields chore boy (Neil Derry) did not get reelected. Voters overwhelming voted for
Mr. Ramos, who stated in campaign data that San Bernardino has the worst image in the state
for corruption of public officials. Neil Derry and Bill Postmus pled guilty to corruption crimes
involving Stubblefields bribes! It is time to show Stubblefield that he cannot buy every public
official in San Bernardino County, despite having BILLIONS IN MONEY STOLEN FROM
ELDERLY RESIDENTS OF MOUNTAIN SHADOWS MOBILE HOME COMMUNITY.
When Bonnie Shipley ran into her x-husband by chance at a store he asked her how she
was doing and where she was living. When she responded, Mountain Shadows Mobile Home
Community he balked! HE SAID YOU MEAN THAT PLACE WHERE STUBBLEFIELD IS
STEALING ALL THE MOBILE HOMES FROM ALL THE OLD PEOPLE WHO OWN THEM?
Bonnie said how did you know that? He said it was common knowledge around the community.
Stubblefield believes that, with Judge Schneiders help by ruling against the law, he can steal
my mobile home and gouge me for hundreds of thousands in attorney fees per a lease clause.
If Stubblefield can steal my home he can steal any residents home. Residents are following
this case to see if Judge Schneider will apply the law or is in the Stubblefields pocket.
IF JUDGE SCNEIDER HELPS HIM STEAL MINE, NO ONE WILL DARE TO CHALLENGE.
And if Stubblefield gets THOUSANDS OF DOLLARS in attorney fees he hits the court jackpot!
That will be the final nail in residents coffin. No resident will have the courage to fight him.
Attached are my three OBJECTIONS to REPLY which we demand the clerks accept today.
If clerks do not accept objections we will file a complaint with the County Board of Supervisors
and ask them to investigate just how much influence Stubblefield may have in our local courts.

950 Roble Lane
November 20, 2012
Presiding Judge

Dear Ms. Slough:

purchaser of a mobile home who moves in without first executing a new residential lease with
park owner. It does not apply to my roommate as she did not BUY the mobilehome.
PART 5 was sent yesterday notifying you that on Friday 11-16-12 clerks in S-31 prevented
Bonnie Shipley from filing OBJECTIONS to misrepresentations made in Stubblefields REPLY.
The court ordered our briefing to be filed by Friday, Nov 9, 2012, and Stubblefields REPLY
to be filed by Monday, Nov 12, 2012. Stubblefield did not comply with the courts order,
but rather took two extra days---not filing the REPLY until Wednesday November 14, 2012.
I received it the next day. The REPLY contained blatant misrepresentations of the facts
(interposed by Stubblefields counsel on which he had no personal knowledge and were false).
The REPLY misrepresented the law. It was designed to confuse on applicable statutes.
I stayed up the entire night to write OBJECTIONS which Bonnie Shipley had the right to file
as Objections can be filed at any time. If not filed, those objections are waived on appeal.
On Friday, Bonnie tried to file the objections in S-31 and the clerks refused to take them.
The clerks told Bonnie the motion papers closed on November 14, 2012 refusing to file them.
Bonnie had to go back on Monday. I emailed you Monday at 9:00 a.m letting you know what
happened on Friday. I just discovered that Judge Schneider issued his order on Friday,
without reading our OBJECTIONS (because the clerks refused to give it to him) based on the
misrepresentations made in the REPLY-- which was the last pleading he read before ruling.
It is interesting to note that on our REPLY to the former motions (all denied) the clerks let
Stubblefield file a Sur-REPLY after our REPLY which I have never heard of in 20 years.
The clerks did not tell Stubblefield the pleadings were closed after REPLY was filed.
This disparate, biased treatment should not be allowed in any of the courtrooms.
I just discovered, by calling the UD phone number, that Judge Schneider issued $9,000
sanctions against us which were completely unwarranted and unfair as I explained in our
Oppositions, Supplemental Briefing, and Objections. I was within my rights, as attorney for
defendant, to refuse to appear at a deposition as California law prohibits deposing opposing
council absent a court order, after a showing of compelling need, and no other way to obtain the
information.
Nearly every court has reversed a trial judge who ordered a deposition of opposing counsel.
Our 4th. Appellate District just reversed an order for opposing counsel to appear at a deposition
in 2007 [Riverside Sheriffs Assn v. County of Riverside (2007) 152 CA.4th 414.], affirming
what has been the law since the USSC set it forth in Hickman v. Taylor (1947) 329 U.S. 495
Judge Schneider not only ordered my deposition, but ordered me to drive 4 hours to appear for
a deposition at the convenience of Stubblefields attorney at his office in Orange County, all the
way in Santa Ana at 9:30 in the morning. ---- AND ORDERED $9,000 IN SANCTIONS.
This is an outrageous miscarriage of justice. This is rubbing my nose in dirt.
I HAVE DONE NOTHING WRONG!!!
In 20 years of practicing I have never had sanctions ordered against me and have never
been ordered to a deposition myself, as opposing counsel, and never heard of any deponent ever
being ordered to appear at a deposition four hours away. This ruling is patently unfair.
I am going to file an appeal, but because it is a court order I will appear at this deposition in
Santa Ana as I do not want to be prosecuted for contempt of a court order.
The sanctions against Steve Allen (a non-party) were patently unfair as were the
sanctions against Bonnie Shipley. Both times Stubblefields counsel set his deposition on the
same morning Bonnie and I were already scheduled to appear in S-31 for motion hearings.
I notified counsel that Allen could not appear unrepresented by counsel and to cancel them.
We could not be in San Bernardino and Santa Ana simultaneously. Any party and the partys
attorney have a right to be at any deposition taken of any party. Please see Oppositions,
Supplemental Briefing, and Objections.
IT WAS UNFAIR FOR YOUR CLERKS TO REFUSE TO LET US FILE OBJECTIONS
TO BRING STUBBLEFIELDS MISREPRESENTATIONS TO THE COURTS ATTENTION.
AS A RESULT $9,000 IN SANCTIONS WERE ISSUED AGAINST US WHICH WERE
COMPLETELY UNWARRANTED AND PATENTLY UNFAIR.
PLEASE RESPOND AS TO WHAT THE COURT WILL DO TO CORRECT THIS
OUTRAGEOUS MISCARRIAGE OF JUSTICE.
Superior Court of aarifornia

Qountp of S a n Bernarbino
Marsha G. Slough
Presiding Judge
303 West Third Street, Fourth Floor

Nancy Dirffy McCar~on

Law Office of Nancy
950 Roble Lane
RE:
..
(909) 708-8769
Fax: (909) 708-8782
Correspondence(s)
Dear Ms. Duffy:

I have received the second, third, fourth, fifth and sixth parts of your complaint regarding
the handling of your case by the clerk's office and Judge Schneider in the San ~ernardinocivil
District.
I have referred your concerns to Judge Donna Garza, Supervising Judge of the San
Bernardino Civil Courthouse. Please understand that our review will not evaluate nor change
any ruling or decisions made in your case. As such, it is not necessary for you to attach the
briefs that you file as there will be no substantive legal review by Judge Garza or me.
If you seek to have the decision in your case set aside or changed, you will need to
pursue that by way of appropriate legal remedy, such as by way of an appropriate motion, an
appeal, or other remedy as may be available to you. I cannot give you legal advice in this
regarc!. Also, please be aware that strict tirne requirements usually apply to any such action.
Consequently, you should act immediately to avoid loss of any rights you may have.
As soon as Judge Garza's investigation into your concerns is complete, she will respond
to you in writing.
ARSHA G.
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950 Roble Lane
November 22, 2012
THANKSGIVING DAY
Presiding Judge

Dear Ms. Slough:

You are enjoying your thanksgiving turkey dinner with your family and/or friends.
Judge Schneider is enjoying his thanksgiving turkey dinner with his family and/or friends,
having gleefully issued his order of $9,000 against us with absolutely no justification at all.
Stubblefield is enjoying his thanksgiving dinner with his family and/or friends celebrating
that in addition to $500,000 per month rental income from the park, he received a $9,000
gift from Judge Schneider in an order of attorney fees against 3 innocent people being dragged
through a sewer of Stubblefield/S-31 corruption, who have no way to pay $9,000 by Jan 1, 2013.
Does Judge Schneider think we can just pull $9,000 off our trees in the backyard? He is out of
touch with reality. He treats us like a corporate defendant who just writes a $9,000 check!
While you all enjoy your thanksgiving dinners I had to cancel my plans to spend it with
my daughter, and granddaugter in the bay area because I have to work on preparing for my
compelled deposition on Monday, as well as the depositions of Bonnie Shipley, and Steve Allen.
I will represent Bonnie Shipley and Steve Allen in their depositions. I am also researching how
to appeal the $9,000 sanction order gratuitously granted to Stubblefield.
Judge Schneider ruled for Billionaire Stubblefield against us on 8 consecutive motions:
1 Shipleys application for a restraining order to stop ongoing harassment since 8/2/2012;
2 My application for a restraining order to stop harassment ongoing since May of 2010;
3 Overruled Demurrer to imaginary forcible detainer complaint on an invalid Notice to Vacate
4 Denied Motion to Strike Attorney Fees where no statutory or contractual basis exists for them
5 Denied Motion to Strike $30/day in Market Rent Damages while collecting full rent from me
6 Denied Motion to Transfer Jurisdiction to unlimited where assessed value of home is $27,800
7 Denied Motion to Quash Service as the imaginary complaint failed to state a cause of action
8 Granted motions to compel depositions of Allen, Shipley & McCarron + $9,000 in sanctions.
(see attached order) with absolutely NO FINDINGS of what we did to deserve punishment.
Steve Allen
Steve Allen is an inspector who filed complaints with the building department about
Stubblefields failure to comply with state, local, and federal building codes, and his failure to
provide handicapped access to any public buildings in the park (office, clubhouse, hobby house).
Stubblefield has ZERO handicapped access despite insisting the park is a 55 + age park!
The sanctions were sought to punish Steve Allen for insuring public safety for park residents.
Judge Schneider was glad to oblige. It was abuse of discretion to sanction Steve Allen.
(see Part 6 which included our Opposition & Objections to Sanctions against Steve Allen)
Judge Schneider ignored the law, the facts, and all reason in issuing sanctions against Allen.
Judge ignored discovery rule which required Meet & Confer before issuing sanctions.
THERE WAS NO MEET & CONFER WITH NON-PARY STEVE ALLEN BEFORE FILING.
Judge ignored CRC 3.1346 which requires a motion to compel to be served on a non-party by
personal delivery. The proof of service filed in court shows the firm mailed it to an address
which is not Steve Allens mailing address. Stubblefields attorney Williamson unilaterally set
the Allen deposition in Santa Ana the same morning Shipley and I had to be in Dept. S-31 for
a hearing on our Motion to Transfer (which was denied like every other motion we have filed).
Stubblefields counsel Williamson conveniently appeared by TELEPHONE (the only time he
ever appeared by telephone in this case--- from Santa Ana). This was so he could remain there
with his court reporter to create a Failure to Appear for Deposition to use against Steve Allen.
How can plaintiffs counsel unilaterally schedule a witness deposition on a day that opposing
party (defendant) and her counsel can not attend because they have a motion hearing in S-31?
Then, Williamson gets a $9,000 reward for this abuse. THIS PROVES EXTREME BIAS.
Judge Schneider ruled against the law when he ordered an opposing counsel to be deposed.
(see Part 6 which included our Opposition & Objections to Sanctions against Nancy McCarron)
All case law precludes taking deposition of opposing counsel absent a factual showing of a
compelling need for the information sought---and no other means to obtain such information.
Their showing of a compelling need is that they want to discover Bonnies trial defense.
When I refuse to answer invoking work product and attorney client privileges they will move
for more sanctions for failing to reveal my trial strategy to them in a recorded deposition.
The Judge orders nearly whatever they ask for because he is advocating for Stubblefields side.
To rub my nose in dirt, he ordered me to appear in Santa Ana---a FOUR HOUR DRIVE from
Santa Barbara at 9:30 a.m. when discovery rules require a deposition within 75 miles of the
deponents residence. We have to leave Santa Barbara at 4:00 a.m to get there by 9:30 a.m.
This was evidently ordered by relying on Stubblefields lawyers argument that my residence
is the mobile home in Highland which is within 75 miles of Santa Ana. This is the complete
opposite of their argument to justify evicting Bonnie Shipley; i.e. that she is not really my coresident because I live in Santa Barbara. Judge Schneider lets Stubblefield argue these two
mutually exclusive, opposite positions at their whim and rules for them however they argue it.
I argue judicial estoppel precludes a party from inconsistent positions in the same litigation.
Judge Schneider ignored it just like he ignores the facts and law to rule for Stubblefield.
It does not take a rocket scientist to figure what Schneider and Stubblefield are planning.
They know Stubblefield can not win at a jury trial as he cannot buy the jury panel who will see
how ridiculous it is to file a forcible detainer eviction against a co-resident while collecting full
rent from the homeowner. Judge Schneider is planning to grant a summary judgment, which
is why he ordered my deposition! Despite having triable issues of fact he will grant it anyway.
2
THE THREE MAJOR ISSUES OF FACT AND LAW JUDGE SCHNEIDER IGNORED:
1) Clause 10 of Duffy McCarron/Stubblefield lease executed on 1-5-05 [App: 8.66] recites:
No persons other than those listed on the signature page of the lease, and
one guest (where Resident would otherwise be living alone), may reside at
the space without Parks prior written consent.
Clause 10 Duffy lease 1-5-2005
* THIS IS MY CONTRACTUAL RIGHT TO HAVE A CO-RESIDENT WITHOUT PARK APPROVAL
2) Civil Code 798.34(b) MY STATUTORY RIGHT TO A CO-RESIDENT without approval

A homeowner who is living alone and who wishes to share his or her
mobilehome with one person may do so, and a fee shall not be imposed
by management for that person.
Civil Code 798.34 (b)
3) Shipley at 51 is not underage. Park Rule 2 recites 2nd resident must be 40+
Rule 2 MSMHC Rules & Regs

THE THREE CASES GOVERNING THESE FACTS THAT JUDGE SCHNEIDER IGNORED
The controlling cases in this Second Appellate District which must be applied to these facts are:
1 Otanez v. Blue Skies Mobile Home Park (1991 2nd.District) 1 C.A4th.1521 holding:

premises full-time in order to be a resident
2 City of Santa Barbara v. Adamson (1980) 27 Cal.3d 123, holding: people have an inalienable
right to life.. liberty...happinessprivacy. (any 2 or more unrelated people can be a family)
3 Rancho Santa Paula Mobile Homes v. Evans (1994) 26 CA4th. 1129 (no ex post facto)
holding that a new park rule cant be applied to deprive a resident of a right expressly
included in her original lease unless the resident executed a modification to lease.
The court must apply
A homeowner who is living alone and who wishes to share his or her
mobilehome with one person may do so, and a fee shall not be imposed
by management for that person.
Civil Code 798.34 (b)
The court must apply Clause 10 in the 1-05-2005 Duffy lease which was never modified.
No persons other than those listed on the signature page of this Lease,
and one guest (where resident would otherwise be living alone) may reside
at the Space without
Parks prior written consent.

3
SUMMARY OF THE DEVIOUS PLAN ORCHESTRATED BY JUDGE SCHNEIDER

Judge Schneider ordered my deposition, ruling completely against the law and the facts,
for ONE REASON ALONE--------to buttress Stubblefields summary judgment motion.
They are taking Bonnie Shipleys deposition Monday, mine to follow into Tuesday, and
Steve Allens to follow into Wednesday if necessary. Once they get the deposition testimony
they plan to file a summary judgment motion (which is probably already prepared) on FIVE
DAYS NOTICE (yes, this is authorized in UNLIMITED JURISDICTION court). The motion
will be a foot high; they will serve it by mail on a Friday (but not drop it into the box until
after 5 p.m. on Friday --- to insure the postman does not pick it up until Saturday). Then, by
the time it gets to Santa Barbara my time to formulate an opposition will be truncated down
to 1 or 2 days to prepare and file an opposition to summary judgment. Then, the clerks will try
to prevent Bonnie Shipley from filing opposition so the Judge can grant the motion by default.
If that trick does not work, and we actually get to file a timely opposition with declarations
proving there are triable issues of fact, Judge Schneider will not hold a hearing anyway.
Instead he will take it under submission (his modus operandi) and then issue a one-page
minute order with the word granted without any findings of fact, conclusions or rationale.
THIS WILL BE COMPLETELY AGAINST THE LAW BUT HE WILL GRANT IT ANYWAY.
JUDGE SCHNEIDER AND STUBBLEFIELD BOTH KNOW THE ONLY WAY THEY CAN
WIN IS SUMMARY JUDGMENT. THEY WILL NEVER WIN IF WE GET TO A JURY WHO
WILL BE FAIR AND UNBIASED. THERE IS NO WAY 9 OUT OF 12 JURORS WILL
BELIEVE WHAT STUBBLEFIELD IS DOING TO BONNIE SHIPLEY AND I IS JUSTIFIED.
THEY CAN NEVER LET THIS GO TO A JURY TRIAL AS THEY KNOW THEY WILL LOSE!
When Stubblefield files a summary judgment motion I will email it to you immediately.
Then I will send our opposition with declarations under oath proving there are triable issues of
fact which must be presented to a jury. Judge Schneider will then grant their motion, without
oral argument, in a one-page minute order without any explanation (his modus operandi).
Judge Schneider will then sign a writ of possession of the mobile home which Stubblefield
will take to the marshal for immediate service upon all residents in the mobile home forthwith.
The marshal will post the usual 5 day notice to vacate and return in 5 days to remove us all.
Stubblefield will have gained possession of my mobile home by outright fraud orchestrated with
Judge Schneiders blessing as his court installed advocate. WE DEMAND INTERVENTION.
I already asked Judge Schneider to disqualify himself and he denied my request.
THIS IS A KANGAROO COURT WHERE STARE DECISIS, RULES OF COURT, RULES
OF CIVIL PROCEDURE, AND THE TRUE FACTS ARE INTENTIONALY DISREGARDED.

950 Roble Lane
November 26, 2012
MONDAY
Presiding Judge

Dear Ms. Slough:

As explained in PART 7 there is no doubt in my mind that Judge Schneider is talking
with the Stubblefields or their lawyer to conspire how they will keep us from getting to a
JURY TRIAL . Judge Schneider and Stubblefields know they cannot buy a jury. They also
know Stubblefields will not win in a jury trial. The jury will see right through this SHAM.
TODAY CONFIRMED ALL DOUBTS IN MY MIND THAT JUDGE SCHNEIDER IS
HAVING EX PARTE COMMUNICATION WITH STUBBLEFIELDS OR THEIR ATTORNEY.
I told Mr. Williamson I had received the courts order setting this case for trial on 12/10/12.
Mr. Williamson said, YOU WILL NOT BE DOING A TRIAL! I said how do you know that?
I just got an order setting trial. He repeated, YOU WILL NOT BE DOING A TRIAL.
I said how do you know that? Are you clairvoyant? He smirked and said again, YOU WILL
NOT BE DOING A TRIAL? I said a second time. How do you know this? Did the judge say it?
HE SMIRKED AGAIN IN A CONDESCENDING WAY and said Trust me, you will not be
doing a trial. Then, he smirked again. HE DID NOT DENY TALKING TO THE JUDGE!!!
WE DEMAND TO KNOW. IF HE IS TALKING TO THE JUDGE, THIS JUDGE
NEEDS TO BE REMOVED FROM THE BENCH!!! How else would he know that we are not
going to trial unless he is plotting it out in a conspiracy with Judge Schneider---their advocate!
THE ABUSE THRUST UPON US IS OUTRAGEOUS. Judge Schneider ordered me to
a deposition 4 hours from my home at Mr. Williamsons convenience. We arrived 15 minutes
early at 9:15. We had to wait around until nearly 10:00 before they actually started.
We were told that NO ONE could attend except the party and counsel. Yet, Williamson had
TWO WITNESSES in addition to Tom Parish who is a partner, representing the partnership.
Marvin Freeman is an employee---not a party or partner. Eva Stubblefield is the daughter of a
partner, Arnold Stubblefield. Neither had a right to attend. I objected. He refused to exclude
them. We could not walk out because we were under court order to attend. Williamson took
full advantage of having the Judge in his pocket. At 11:45 he said it is almost noon and I
have another meeting set up here. You will have to return in 1 and hours at 1:30. That was
outrageous as he knew we drove 4 hours to get there! THIS WAS CLEARLY ABUSIVE, BUT
WHEN YOU HAVE THE JUDGE IN YOUR POCKET YOU CAN ABUSE ALL YOU WANT!!
We had to wait around 1 and hours to resume with nothing to do. Then at 1:30 we started
again and 1 hour later he said we would quit and resume in the morning, clearly abusive.
HE IS ABUSING THE FACT THAT JUDGE SCHNEIDER ORDERED US TO BE THERE !!!
He suspended Bonnie Shipleys deposition after I told her not to answer questions that were
clearly abusive, violated her privacy rights, and had NOTHING TO DO WITH THIS CASE.
For example, he asked Bonnie what names she used in the past. When she answered honestly
he started on a former husband she divorced in 1999. How long were you married? When did
you get a divorce? Did you get child support? Did you get alimony? on, and on, and on.
Finally, I told her to stop answering all these questions about her personal life from 13 years
ago which NOTHING TO DO WITH THIS CASE. He asked her to name every one of her 5
children and then where they lived, and all about their lives. Clearly this was harassment!
THEN HE HAD THE AUDACITY TO ASK HER IF STEVE ALLEN, MY HANDYMAN,
SLEEPS WITH HER? After several questions which were clearly out of line got on the
record he suspended her deposition and said he would bring it before the Judge again.
SO, WILL JUDGE SCHNEIDER BE ORDERING BONNIE SHIPLEY TO ANSWER
QUESTIONS WHO SHE SLEEPS WITH, AND SANCTION ANOTHER $9,000?
Then, he did the same with Steve Allen, asking him if he owed anyone money? If anyone ever
got a judgment against him? He even had the audacity to ask Steve Allen, a single man, who
he slept with last night? Does he ever sleep at my home? How many times has he been to
my home? What is his relationship with Bonnie Shipley What is his relationship with me.
When did we enter into an attorney client relationship? (I represented him today at the depo)
How did we enter into an attorney client relationship? Is he paying me? What is he paying?
After so many badgering, inappropriate questions I started telling him not to answer and
invoking his right to privacy. Williamson then suspended Steve Allens deposition and said
he would go back to Judge Schneider for more sanctions. WILL JUDGE SCHNEIDER
ORDER STEVE ALLEN TO ANSWER WHO HE SLEEPS WITH, WHERE DOES HE SLEEP?
(Oh, and order $9,000 more in sanctions because Steve didnt answer where he sleeps, who he
sleeps with, and how often he sleeps with her?)
One of the first things he asked me was how long I had been married to my husband Tim?
Then he asked me what day we got married? Then he asked me if I had ever worked on a
racketeering case? When I answered yes, he asked how many? When I answered 5 he then
asked for all the details? Who were the defendants? Who were my clients? What results?
What does my representation of clients have to do with this lawsuit? Because I have been
answering everything so far he has not suspended my deposition. The plan was to suspend
Bonnies so he can now ask Judge Schneider for issue sanctions i.e. he will ask to have
Bonnies answer stricken and judgment for plaintiff because she refused to answer who she
sleeps with and all other inappropriate questions which are nobody elses business!!!
REMEMBER THAT I PREDICTED IT! THE ONLY WAY STUBBLEFIELD CAN WIN
THIS CASE IS BY GRATUITOUS GIFT FROM JUDGE SCHNEIDER!!! I believe this is
why Williamson can be so bloody arrogant, so obnoxious, so abusive, and so condescending.
ONE CAN ONLY GET AWAY WITH THIS IF HE HAS THE JUDGE IN HIS POCKET!
Superior Eourt of QLaIifornia

QLountpof S a n wernarbino
Donna Gunnel1 Garza
Judge of the Superior Court
December 3,2012
- - -
Nancy Duffy McCarron

Law Office of Nancy
950 Roble Lane
sania73ZiFEara;CA 93103
----
__
__
_ _ C _ _ _ _ _
_
I
.
Dear Ms. Duffy,

It has been brought to my attention that you have lodged on-going concerns regarding the ruling and
demeanor of Judge, Wilfred J. Schneider, Jr.
As Civil Supervising Judge of the Superior Court, it is my duty to investigate and act upon any and
all allegations concerning the demeanor andlor impropriety of an active sitting Judge in the Civil
Division. It is my understanding that the present, County of San Bernardino, Presiding Judge,
Marsha Slough, has corresponded to you regarding this matter. As you are aware, neither Judge
Slough or myself, has the authority by law to review or overrule a decision or ruling by an active
sitting Judge. As you are also aware, your avenue of relief must through the appropriate process as
to substantive rulings.
With respect to your concerns regarding inappropriate Judicial temperament, bias or demeanor, it is
my responsibility to investigate complaints of this nature. I am aware of that you have provided
instances of perceived conduct by Judge Schneider. Upon my thorough investigationand review of
all relevant documents involving your case before Judge Schneider, I do not find that there have
been any Judicial violations of conduct. My review of the relevant I see no evidence to support any
bias, or favoritism as you indicated by Judge Schneider.
Please know we take these matters extremely seriously, and conscientiously seek to insure that all
individuals receive the benefits of a fair administration of Justice. Thank you for raising these
concerns, I have fully investigated and taken appropriate steps where necessary.

Robert G. Williamson, Jr., Esq., Bar No. 73176
Justus J. Britt, Esq., Bar No. 267352
HART, KING L COLDREN
A PROFESSIONAL LAW CORPORATION
Telephone: (714) 432-8700
Facsimile: (714) 546-7457
6 Attorneys for Plaintiff Stubblefield Pro erties, a California general partnership
dba Mountain Shadows Mobile Home ommunity
7
8
SUPERIOR COURT OF T I E STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO - CIVIL DTVISTON
STUBBLEFIELD PROPERTIES, a
California general partnership dba
MOUNTAIN SHADOWS MOBILE
HOME COMMUNITY,
1
1
1
1
1
Plaintiff
v.
BONNIE SHIPLEY; and DOES 1 through

10. i~lclusive,
Case No. UDDS1204130

Judge: Hon. Donald R. Alvarez
Dept. S32
PLAINIFFF'S NOTICE O F
UNAVAILABILITFOF
TRIAL
WITNESSES THOMAS PARRISH AND
MARVIN FREEMAN;^.I)ECLARATION
O F ROBERT G. WILLIAMSON, JR.
DATE: December 13,2012
TIME: 8:30 a.m.
DEPT: S32
Defendants.
22
23
TRIAL: December 17,2012
TO ALL PARTIES AND 1'0 THEIR A T T O N Y S OF RECORD:
PLEASE TAKE NOTICE that Plaintiff's,
Stubblefield Properties dba Mountain
1I
24 Shadows Mobile Home Community, trial witnesses set forth below are unavailable to attend
P
I
25 and testify at trial until after January 1, 2013 due to separate compelling circumstances as
26 set forth in the declaration of Plaintiffs counsel.

1. Thomas Parrish, Senior Executive Vice President, Stubblefield Properlies.
28
36568.05314814-7826-5618v.l
1
2. Marvin Freeman. Manager, Mountain Shadows Mobile Home Community.

The reasons for each of these witnesses unavailability are set forth below in the Declaration
of Robert G. Williamson. Jr.
DECLARATION OF ROBERT G . WILLIAMSON, JR.
I. ROBERT G. WILLIAMSON, JR., declare:

1.
1 am an attorney duly licensed to practice law before all courts of the State of
California, and am a partner with the law finn of Hart, King & Coldren, attorney of record
for Plaintiff STUl3BLEFIELD PROPERTIES, a general partnership dba MOUNTAIN
SHADOWS MOBILENOME COMMUNITY ("Plaintiff'). The facts set forth herein are true
of my own personal knowledge, except those facts stated on infonnation and believe and as
to those matters 1 believe them to be tnie and could and would completely testify thereto.
2.
Mr. Thomas Parrish is Senior Executive Vice President of Plaintiff,
Stubblefield Properties. His duties, among others, include supervising management and
operations of Mountain Shadows Mobile Home Community. As Plaintiffs representative he
*
expected to attend trial every day.
3.
Mr. Pamsh is also a percipient witness and expected to $stify at trial about
Defendant's presence in the community, the Community Guidelines and residency age
restriction and his co~nmunicationswith Defendant's counsel Nancy Duffj McCarron.
4.
On December 10, 2012. the initial trial date, the Court with counsel and
Defendant present in court reset the trial dqte for December 17, 2012 and Defendant
requested a jury trial. Although I expected Mr. Parrish to be in court that morning, he was
not.
5.
I learned that morning after leaving court that Mr. Parrish's son's funeral will
be on December 17, 2012. It is my understanding that the passing of Mr. Parrish's son was
tragically premature and naturally his family is deeply grieving their loss. Under the
circu~nstances1 do not expect Mr. Parrish to be prepared to be in court for trial and to testify
until after January I , 20 13.
6.
At approximately 1:00 p.m. that afternoon having learned of Mr. Parrish's
unavailability, I e-mailed Defendant's counsel advising her of Mr. Parrish's unavailability

for trial and the reason. I suggested that in light of her witness's, Mr. Tate, apparent health
issue with che~notherapy as represented to the Court that morning, a stipulation to continue
trial would be appropriate. I also offered to extend discovery cut off if she felt it necessary to
take Mr. Tate's deposition. A true and correct copy of my e-mail to Defendant's counsel of
December 10, 20 12 is attached hereto marlced as Exhibit "1 .?'
7.
That evening at approximately 9:24 p.m. I received a terse and stunningly
insensitive e-mail From Defendant's counsel. She indicated, among other things, that her
understanding was that it was not Mr. Parrish's son who passed away, but his wife's son
from a fpr~nermarriage and that the hneral would "only" be one day and Mr. Parrish could
be reached by telephone. She also mentioned her witncss, Mr. Tate, loolted "very healthy"
when she sewed him with a subpoena. She did not acltnowledge my request for a stipulation.
A true and correct copy of Defendant's counsel's e-mail to me of December 10, 2012 at 9 2 4
-.
p.m. is attached hereto marked as Exhibit "2."

8.
Mr. Mawin Freeman is the community manager of Mountain Shadows Mobile
Home Co~nmunityand a material witness in the above-referenced case. He is the only

person from Plaintiffs management with whom Defendant had any communication. I-le was
prepared lo be available and testify in this case.
9.
On December 12, 2012, Mr. Thomas Parrish also confinned to me that Mr.
Freeman would be unavailable for trial due to Mr. Freeman's Wife's terminal illness and
necessary Family Leave until after January 1, 2013.:
10.
It is
my understanding that Mrs. Freeman had been seriously ill and was
hospitalized at Redlands Community Hospital for several weeks and then transferred to
Braswell Convalescent I-lome. Recently, however, it is my understanding that Mrs. Freeman
was diagnosed as terminally ill and transferred from Braswell back to Redlands Co~nmunity
Hospital and then to her home with hospice care. Mr. Freeman is attending to her at home
ull time with hospice.
11.
Under these unfortunate circumstances, Mr. Freeman also is unavailable for
rial and it is my understanding that his Family Leave is until January 1,2013.
I declare under penalty of perjury under the laws of the State of California that the
'oregoing is true and correct.
Executed this l zLhday of December, 20 12 at Santa Ana, California.

Law Office of Nancy Duffy McCarron
950 Roble Lane
805-965-3492 (ph/fax) 805-450-0450 (cell)
February 6, 2013
TO: SAN BERNARDINO COUNTY BOARD OF SUPERVISORS (ALL 5 DISTRICTS)
Robert Lovingood (1st), Janice Rutherford (2nd), James Ramos (3rd), Gary Ovitt (4th), Josie Gonzales (5th)
faxed to 909-387-9090 and sent by email to all Supervisors

Marsha Slough, Presiding Judge of San Bernardino Superior Court via email
RE:
STUBBLEFIELDS USE OF SAN BERNARDINO SUPERIOR COURTS AS A DEVICE

TO STEAL MOBILEHOMES & HARASS ANYONE WHO REFUSES TO CAPITULATE
JUDGES ENABLE ABUSE & HARASSMENT BY REFUSING TO DISMISS SHAM CASES

The California Bar Journal published an article in its February 2013 issue about how
Californias court system barely escaped additional operation cuts due to a budget crisis with
hypertext links to editorials published in the Los Angeles Times and Sacramento Bee. [Exh A]
The chief justice initiated a top-to-bottom review of court bureaucracy that resulted in 145
Judicial Council directives. The chief justice needs to show how those directives translate into
tangible savings and improvements in court operations with the last sentence reciting:
Equally important, judges need to get on the same page. The tension
between different factions within the courts does not help the judicial
branch make its case in the Legislature or with the governor.
Judges must consider not only a budget crisis within the state court system, but also that
the City of San Bernardino is in bankruptcy and county budgets have been severely reduced.
Accordingly, the County must put an end to Stubblefields use of the San Bernardino Superior
Court as a device not only to steal mobilehomes from helpless elderly residents in summary
proceedings, but also as a whipping tool to harass any homeowner who refuses to capitulate.
We suspect Judges may be afraid to rule against the mighty Stubblefield because they fear he
will bankroll an opponent to run against the Judge in reelection he/she faces every six years.
Judges enable abuse by allowing Stubblefield to prosecute sham complaints to harass anyone
who refuses to capitulate to whims or turn over their mobilehomes to Stubblefield Properties.
1
UDDS1204130 Stubblefield v. Shipley [forcible detainer sham complaint filed in S-31 8-27-12]
San Bernardino Superior Court has allowed Stubblefield to prosecute a sham complaint
filed on 8-27-12 as a forcible detainer action under Unlawful Detainer Summary Proceedings
in S-31 used by Judge Wilfred Schneider to summarily evict tenants who failed to pay rent or
cure a lease term violation after a 3-day Notice to pay, cure or quit was served & has expired.
A prerequisite to filing a UD complaint is the existence of a landlord/tenant relationship; i.e.
the plaintiff must be a landlord seeking to evict a tenant who violated terms of their contract.
Stubblefield moved to evict the roommate of a tenant. Plaintiff has no contract with Shipley.
The sham complaint is based on an invalid 5-day Notice to Vacate citing Civil Code 798.75
which is a statute authorizing eviction only against a purchaser or transferee who moves into
an acquired mobilehome without first obtaining a residency agreement with the park owner.
Civil 798.75. Attachment of rental agreement or statement
(a) An escrow, sale, or transfer agreement involving a mobilehome located in a park
at the time of the sale, where the mobilehome is to remain in the park, shall contain a
copy of either a fully executed rental agreement or a statement signed by the park's
management and the prospective homeowner that the parties have agreed to the terms
and conditions of a rental agreement.
(b) In the event the purchaser fails to execute the rental agreement, the
purchaser shall not have any rights of tenancy.
Defendant Shipley is not a purchaser or transferee, but a roommate whose authorization

to share the home derives from the owners statutory right to share under Civil $798.34(b) and
the owners contractual right to share under General Provision 10 of the owners park lease:
(b) A homeowner who is living alone and who wishes to share his or her mobilehome
with one person may do so, and a fee shall not be imposed by management for that person.
The person shall be considered a guest of the homeowner and any agreement between
the homeowner and the person shall not change the terms and conditions of the rental
agreement between management and the homeowner. The guest shall comply with the
provisions of the rules and regulations of the mobilehome park.
Civil 798.34(b)
No persons other than those listed on the signature page of this Lease, and
one guest (where resident would otherwise be living alone) may reside at the
Space without Park's prior written consent.
Gen. Prov 10
Civil 798.75 does not apply to Shipley because she is not a purchaser or transferee. Finally, only the
owner of the mobilehome (its occupant) has standing to evict under forcible detainer as expressly recited:
The occupant of real property, within the meaning of this subdivision, is one who,
within five days preceding such unlawful entry, was in the peaceable and undisturbed
possession of such lands. CCP 1160 (2) [forcible detainer statute]
2
The case is so simple a third grader could figure it out! We have cited the law 100 times!
Yet the court refuses to dismiss this sham complaint, despite a demurrer filed five days after
the sham complaint was served, a motion to strike attorney fees & damages, a motion to quash
service, a motion for judgment on the pleadings, and a pending motion for summary judgment.
After 7 months, 7 volumes, a 13-page Docket with 258 entries [Exh.C] & 22 Hearings [Exh D]
THIS CASE IS THE LONGEST SUMMARY PROCEEDING IN LOCAL COURT HISTORY!
JUDGES HAVE ENABLED THIS ABUSE AND HARASSMENT FOR SEVEN MONTHS !
HOW MUCH HAS THIS SHAM COMPLAINT COST THE COURT AND COUNTY?
As editorials on the court budget cuts note, parents must wait three months for custody
hearings because there are not enough courtrooms and judges to preside over trials. [Exh A].
Taxpayers in this county would be outraged if they knew how many thousands of dollars
(salaries & benefits for judges, deputies, court reporters, and clerks) have been wasted because
judges continue to coddle Stubblefield & let him use the court as his own private whipping tool.
258 docket entries!

22 court hearings!
7 volumes!
7 months!
Who will end this abuse?
When will it ever end?
3
THE RACKETEERING ENTERPRISE

Stubblefield owns & operates a lucrative mobilehome park at 4040 Piedmont, Highland,
CA entitled Mountain Shadows Mobile Home Community [MSMHC]. It has 402 spaces.
Stubblefield started the mobilehome park in 1974 rapidly filling most of the spaces. Exh. B
There is no rent control. He continues to gouge elderly by raising rents annually since 1974.
The lowest monthly rent homeowners pay currently exceeds $1,000 with $20 guard charges.
While Stubblefield rakes in $400,000-$500,000/month in rent/profits he pays little or no taxes
to San Bernardino County because he arranged to have staff at the County Tax Assessors
Office set values to zero or unavailable or noTract noLot with contrived roll corrections.
(see 2/4/13 letter to BOS concerning the tax evasion facet of the racketeering enterprise)
Stubblefield has filched of the homes (200) in an ongoing racketeering enterprise.
When an owner dies, Stubblefields VP Tom Parrish refuses to allow heirs to live in the home,
and refuses to approve the heirs prospective buyer rendering it impossible for the heir to sell.
Parrish precludes the heir from renting the home by refusing to approve the heirs sub-lessee.
The heir must continue to pay Stubblefield $1,000-$1,300 per month for use of a vacant home.
The heir cannot afford legal fees to try to save the home or prove a buyer/sub-lessee qualifies.
Elderly residents and heirs are abandoning homes because they cannot afford the rent and
Stubblefield will not allow any owner to bring in a co-resident to help pay the exorbitant rent.
Stubblefield offers a secret peace of mind home program. If a resident conveys his/her home
to Stubblefield rent is reduced $200/mo; Stubblefield acquires title when he/she dies or moves.
Potential monthly income is $400,000-$500,000 [400 homes x $1,000-$1,300 per month].
As part of a racketeering enterprise Stubblefield uses the court to filch mobile homes
from elderly residents and/or heirs and to harass anyone who opposes his enterprise. [Exh. G]
Another facet of the racketeering enterprise is witness intimidation, a crime under PC 136.
Marvin Freeman, the parks manager, told Mary Dunbar, a feeble resident in her 80s who lives
2 doors from McCarron, that she will be evicted if she, daughter or son-in-law dares to testify
in favor of Shipley or McCarron in this litigation should it proceed to trial. Marvin Freemans
brothers mobilehome, which was insured to the maximum, mysteriously burned down in a fire
starting in an attic while he, his wife, his dog and valuables were conveniently not present.
4
Stubblefield just bought the mobilehome a few doors from McCarrons mobilehome for
$15,000 telling the seller the park wanted to buy it so they could put Marvin Freemans brother
in the home to spy on Shipley and McCarron. Freemans brother is relocating to the home.
The seller wanted to move because Freeman was pressuring her to spy on Shipley & McCarron.
As explained below this sham case was filed to harass Shipley & McCarron to drive them away.
HISTORY LEADING UP TO THE LAWSUIT :
On 1/5/05 McCarron bought a mobilehome (space 333) in the park. Tenure was uneventful
from 2005 to 2010. In spring 2010 the park summoned all homeowners to a clubhouse meeting
to distribute new Community Rules composed by the parks law firm [Hart, King & Coldren].
The parks 2000 Community Rules were only 14 pages in length and for the most part benign.
Many of the 2010 rules were unconstitutional, overly restrictive and violated privacy rights.
The new rules were intentionally designed to be so oppressive that any prospective buyer or
sub-lessee would opt out as soon as they read the rules. Residents have few rights under the
new rules and live like serfs in a feudal lord system with Tom Parrish as the lord and master.
During the clubhouse meeting McCarron protested the new rules before several hundred
residents as unconstitutional and unenforceable. McCarron was told to sit down and be quiet.
McCarron was not allowed to speak again and VP Tom Parrish decided that night to engage in
a witch hunt to drive McCarron out of the park. Within a week Parrish filed a false complaint
with the City Building & Safety Department alleging McCarron had a human living in a shed,
and the same week served a 60-day Notice to Vacate based on alleged building code violations.
As soon as the building inspector discharged the complaint as unfounded, the park withdrew
its eviction notice. McCarron shared her home with a co-resident Wendy Durr at the time.
McCarron had a long history of sharing the 2 bedroom home which she had done since 2005.
After 2.5 years of sharing McCarrons home Wendy Durr bought the home next door for
$7,000 when she discovered the owners were relocating, intending to abandon the mobilehome.
On 8/1/12 Shipley replaced Wendy Durr as McCarrons new co-resident. On 8/2/12 manager
Marvin Freeman visited Shipley while McCarron was away and ordered her to leave the park.
About 2 weeks later the parks lawyer served Shipley with a 5-day Notice to Vacate citing
Civil Code 798.75 which did not apply to Shipley. Because she did not move on 8-27-12 she
was served with an Unlawful Detainer summons & a complaint entitled Forcible Detainer.
5
JUDGES CODDLING STUBBLEFIELD & REFUSING TO DISMISS A SHAM CASE

8/27/12 Stubblefield filed Unlawful Detainer summons & Forcible Detainer Complaint
C-13
8/31/12 Demurrer, Motion to Strike Atty Fees/Damages & Quash Service hearing set
C-12
9/27/12 Demurrer, MTS, MTQ hearing; Judge Schneider takes it under submission
D-1
9/28/12 Judge Schneider denied Demurrer, MTS, MTQ; no explanation; just denied
D-1
9/28/12 Motion to Transfer jurisdiction served; P seeks possession; home value >$25,000 C-12
Ps attorney served Steve Allen w/notice to appear for depo in Santa Ana 10/4/12
McCarron demands Ps attorney postpone Allens depo set for 10/4/12 in Santa Ana
as she must appear with Shipley to argue her Motion to Transfer in S-31 on 10/4/12
Ps attorney refuses to postpone Allens depo set in Santa Ana on 10/4/12 at 9 am
10/4/12 Motion to Transfer jurisdiction taken under submission; denied 2 hours later
D-2
Ps attorney appeared by telephone from Santa Ana office with a Court Reporter
present; McCarron appeared live in S-31 for oral argument; could not be at depo
10/9/12 Writ petition filed re: denial of demurrer, MTS, MTQ, Motion to transfer
C-11
10/22/12 Writ Petition denied 14 days later with no opposition being filed by plaintiff
C-11
10/25/12 P filed Motion to Compel depos of Non-parties Steve Allen, McCarron & Shipley C-10
10/30/12 Court sets 12/10/12 trial date upon receipt of Ps request to set it filed 10/30/12
C-10
11/16/12 Court grants MTC depos & $9,000 sanctions against Shipley, Allen, & McCarron D-7
for failure to appear in Santa Ana 10/04/12 -same day as Transfer Motion in S-31
Schneiders illegal sanction order was so outrageous it shocked the conscience
McCarron complained to Presiding Judge as Schneiders orders were off the wall!
Rulings for Stubblefield were against law, codes of civil procedure & rules of court
12/3/12
Judge Schneider, sua sponte, revoked his own abusive $9,000 sanction order
D-8
12/4/12
Judge Schneider recused himself from the Stubblefield/Shipley case
D-9
NOTE: a few weeks later Judge Schneider was transferred to Fontana Court
Previously Schneider presided over family court; there were so many
appeals he was transferred to S-31 to rule only on limited jurisdiction cases
12/4/12 Judge Donna Garza reassigned Shipleys case to Donald Alvarez in S-32
D-10
12/5/12 Alvarez continued Shipleys MTC production of Ps secret videos & reports
D-11
12/10/12 Alvarez grants Stubblefields ex parte motion to continue trial set for 12/17/12
D-13
12/13/12 Alvarez denies Shipleys MTC production of videos/reports clearly discoverable
D-15
12/16/12 Alvarez grants Stubblefield leave to file MTC answers after the discovery cutoff
D-16
The above shows an early pattern of a newly assigned judge ruling for Stubblefield every time!
6
McCarron discovered the connection between Judge Schneider & Stubblefield enterprises.
Attorney Williamson filed an ex parte motion on 12/10/12 to be heard on 12/13/12 reciting that
Stubblefields Vice Pres. Tom Parrishs son just died and he needed to grieve his sons death.
We discovered Williamsons affidavit misrepresented the true facts. It was not Tom Parrishs
son who had died---but his wifes son from a former marriage. We discovered he had not just
died but had died 3 weeks earlier on November 25, 2012. Parrishs wife is Mary Lou Gallal.
Her son Joseph Gallal died on 11/25/12 of brain cancer diagnosed a year before his death.
Tom Parrish showed up in Santa Ana on 11/26/12 the next morning after his wifes son died
to attend depos of Shipley, Allen & McCarron. He glared across the table all day for 3 days!
THAT IS HOW GRIEF STRICKEN PARRISH WAS! PARRISH DID NOT MISS A MINUTE!!
We obtained a certified copy of Joe Gallals death certificate from Orange County to prove
he died on 11/25/12 and to prove that Williamson misrepresented facts just to postpone a trial.
GALLALS DEATH CERTIFICATE LISTED A SURVIVING WIFE AS KIM SCHNEIDER.
(Exh. E) WE BELIEVE THIS IS JUDGE SCHNEIDERS NIECE, COUSIN OR RELATIVE.
WE ASK THE COUNTY TO INVESTIGATE AS JUDGE SCHNEIDER HAD A DUTY TO
DISCLOSE THIS FAMILY CONNECTION WITH TOM PARRISH (STUBBLEFIELDS VP)
THIS WAS A CONFLICT OF INTEREST MANDATING DISCLOSURE AND RECUSAL
We wanted to give Judge Alvarez the benefit of the doubt to see if he would apply the law.
We believe he is also afraid to rule against Stubblefield because he believes Stubblefield will
bankroll an opponent to run against him the next time he is faced with reelection (every 6 yrs).
Our belief is based on rulings in this case & other cases he presided over involving Stubblefield.
We reviewed Stubblefield v. Graziano CIVDS1001036.
On 2/25/10 Judge Alvarez granted a
petition for an anti-harassment injunction to Stubblefield Properties, a partnership against a

mobilehome owner Joseph Graziano. [Exh. F1-2] Alvarez knew an anti-harassment injunction
could only be issued to protect human persons not artificial persons [partnerships.]. [Exh. F3-4]
California Benchguide, Injunctions Prohibiting Civil Harassment, 20.9 expressly recites that
an anti-harassment injunction may only be used to protect a human person -not a partnership.
The California Benchguide cites Diamond View Ltd. v. Herz (1986) 180 C.A.3d 612. [Exh.F5-6]
Not only was the injunction against the law, but Alvarez ordered owner Joseph Graziano to
stay away at least 25 yards from any community resident No park residents petitioned the
court for protection from Graziano---their friend for years. THE ORDER WAS ILLEGAL!
The true facts are that Joseph Graziano owned or was heir to the mobilehome at space 35
owned by parents [Joseph & Gloria Graziano Trust]. This was the typical racketeering scam
described on page 4 above, where Stubblefield is able to steal the mobilehome by refusing to
approve the heir to reside in the home after the owner dies, refuses to approve a buyer,
refuses to approve a sub-lessee. If the heir is qualified (age 55) the park refuses to approve
any co-resident to share the burden of paying the exorbitant space rent Stubblefield charges.
We were unable to reach Graziano but figured out what happened by reviewing the records.
An excerpt from county tax assessors site shows Graziano trust owned the home 2007-2010:
Joseph Graziano was probably arguing with VP Tom Parrish, who has the compassion of
a great white shark. Graziano was trying to stop the racketeers from stealing his mobilehome.
To the racketeers this was just another free home to add to its cash cow of rental units after
arranging a roll correction (see above record) with the tax assessor to make sure no tax bills
were generated on the home so Stubblefield could avoid paying tax & rent it for $1,000 a month
Judge Alvarez, by granting the contrived injunction based on a perjured affidavit, became an
enabler of the racketeering enterprise. Graziano was enjoined from the entire park and had to
stay 25 feet away from any park resident. JUDGE ALVAREZ MADE AN ILLEGAL ORDER!
8
Judge Alvarez entered the anti-harassment order against Graziano on 2/25/10. [Exh F]
One week later---on 3/2/10--- tax assessor staff entered MSMHC as 100% owner of space 35:
Note how the tax assessor entered a roll correction under relationship and an artificially
low roll value of $4,745 as of Jan. 1, 2005. No tax bills had been generated after Jan 1, 2005.
Mountain Shadows Mobile Home Community is listed as a CORPORATION which is false.

Stubblefield Properties is a CA partnerhip dba Mountain Shadows Mobile Home Community.
The racketeering enterprise was/is orchestrated by Tom Parrish who became Vice President
of Stubblefield Properties 30 years ago. Before that he was a struggling real estate broker
driving around Lake Arrowhead in a beat-up station wagon begging for real estate commissions
Parrish convinced Stubblefield he knew all the tricks to evade taxes and steal mobilehomes.
The racketeering enterprise flourished under his reign; he now lives in a $1.7 million mansion.
One year Stubblefield got so mad at Parrish they did not even speak for over a year but he
never fired Parrish as VP. We believe Parrish had so much to blackmail Stubblefield with that
he could never fire Parrish--no matter how angry he became. Parrish has job security for life.
One of the racketeering schemes was to insert the names of existing or former residents
into the tax assessors space parcel records as former owners on surrounding lots owned by
Stubblefield to create a pretext that residents had actually occupied the now vacant lots.
This was to insure that Stubblefield paid minimal or no county taxes. Below is an excerpt:
9
bogus names
Exh. B shows Stubblefield Construction Company registered the park in 1974 with
Housing and Community Development in Riverside and reported that it had 402 spaces.
Tom Parrish testified in an affidavit filed a few weeks ago that the park has 402 spaces.
Stubblefield pulled names randomly from his list of current or former owners and plugged the
names into the tax assessors records as past owners. None of the names listed above as past
owners ever held any ownership interest in spaces 403 -420. The spaces were never occupied.
Parrish plugged in the name Edward Graziano as a past owner for space 418 which was bogus.
Graziano was probably upset that his familys name was used in Stubblefields scam to evade
taxes by creating a false pretext the above lots had been used by residents but are now vacant.
Graziano had many reasons to be angry at Tom Parrish and manager Marvin Freeman
who were stealing his home, all of the contents inside his home, and using his family name in
a scheme to defraud county citizens by evading taxes when residents use all county services.
JUDGE ALVAREZ FACILITATED A RACKETEERING ENTERPRISE WITH HIS ORDER.
ALVAREZ CONTINUES SCHNEIDERS PATTERN OF RULING AGAINST THE LAW!!!
10
D-10
12/5/12 Alvarez continued Shipleys MTC production of secret videos & reports
D-11
D-13
D-15
D-16
Above shows an early pattern of a re-assigned judge ruling for Stubblefield against the law.
Although Alvarez is more subtle than Schneider his fear of ruling against Stubblefield is clear.
Schneider should have dismissed Stubblefields sham complaint on a demurrer filed on 8/31/12.
Alvarez continues a pattern of refusing to dismiss a sham complaint enabling the harassment.
Alvarez denied Shipleys motion for Judgment on the Pleadings continued & heard on 1/10/13.
Alvarez continued the trial setting conference to 2/27/13 to enable more deposition harassment.
Stubblefield filed an ex parte motion (on 24 hour notice) for an order to compel second
oral depositions in Santa Ann of Shipley, her attorney Nancy McCarron & friend Steve Allen.
This was a repeat of the same motion Schneider granted with $9,000 sanctions against victims.
Williamson ignored deposition statutes, discovery deadlines and a duty to Meet & Confer with
opposing counsel before filing a motion to compel. COUNSELS DUTY WAS MANDATORY.
CCP 2023.010. Misuses of discovery process
Misuses of the discovery process include, but are not limited to, the following:
(i) Failing to confer in person, by telephone, or by letter with an opposing party or
attorney in a reasonable and good faith attempt to resolve informally any dispute concerning
discovery, if the section governing a particular discovery motion requires the filing of a
declaration stating facts showing that an attempt at informal resolution has been made.
Alvarez made a finding in the minute order that the meet & confer requirements were not met.
19a
Alvarez made a finding the separate statement failed to comply with California Rules of Court
19b
After making those findings Alvarez was required to award attorney fees for the discovery abuse:
CCP 2023.020. Monetary sanction for failure to confer
Notwithstanding the outcome of the particular discovery motion, the court shall
impose a monetary sanction ordering that any party or attorney who fails to confer
as required pay the reasonable expenses, including attorney's fees, incurred by anyone as
a result of that conduct.
Despite having a statutory duty to award attorney sanctions for Williamsons misuse of discovery processes
Alvarez denied Shipleys request for sanctions. When McCarron objected to his refusal to impose sanctions
Alvarez said you did not address it in opposition. This was not true as we addressed it twice in opposition.
11
The following are excerpts from opposition to ex parte motion (24 hour notice) to order second depositions.
Despite a mandatory duty to issue sanctions Alvarez refused to issue it against Stubblefield.
Yet, Schneider issued $9,000 in sanctions against us for failure to appear at depositions set in
another county (Santa Ana) on the same morning he knew we had to appear is his S-31 court.
Stubblefield has been trained like Pavlovs dogs that no matter how many Rules of Court he
ignores, no matter how abusive his violations are, this court will never sanction his conduct.
Judge Alvarez has become an enabler to harassment and blessed blatant attorney misconduct.
There is no incentive to be ethical because Williamson knows there will never be any negative
consequences for his ethical and CRC violations. Plus he bills at $350/hour for the abuse.
12
Judge Alvarez had an opportunity to dismiss Stubblefields sham case by granting

Shipleys motion for Judgment on the Pleadings on 1/10/2013. Yet, he denied Shipleys motion
which should have been granted just like Schneider. Shipley was entitled to judgment and to
dismissal of a sham complaint which should have been dismissed on demurrer in August 2012.
Judge Alvarez was just given a second opportunity to dismiss this sham complaint.
Stubblefield moved for summary judgment and set a SJM hearing for January 31, 2013.
Shipley filed her own summary judgment motion and set the hearing for the same day.
Stubblefields attorney Williamson, in open court on 1/31/13 confirmed that the material facts
were not in dispute. McCarron also confirmed the material facts are not in dispute and that the
Judge had a duty to decide summary judgment as a matter of law in favor of Bonnie Shipley.
Summary Judgment Pleadings are included in the email transmission of this correspondence.
The following shows there is no basis for this sham complaint and it should be dismissed.
13
Stubblefield failed to provide any admissible affidavits to support or oppose summary judgment
Only the affidavit of a partner where plaintiff is a partnership is admissible on a MSJ hearing.
14
Shipley even provided a smoking gun by submitting the affidavit of Maury Priest, the only
person with personal knowledge of what legislators intended when they amended 798.75.
15
Despite that Shipley provided undisputed evidence of what legislators intended when
they amended Civil 798.75, and he testified that forcible detainer could not be used to evict a
mobile home resident, and that Stubblefields attorney admitted the facts were not in dispute,
and even though Shipley proved in her MSJ that she had a complete defense to a forcible
detainer claim because McCarron had been in exclusive possession of space 333 for 8 years,
JUDGE ALVAREZ DID NOT GRANT SUMMARY JUDGMENT ON JANUARY 31, 2013!
INSTEAD HE CONTINUED THE SUMMARY JUDMENT MOTION TO FEBRUARY 14, 2013.
JUDGE ALVAREZ SHOULD HAVE GRANTED SUMMARY JUDGMENT AND DISMISSED

THIS SHAM COMPLAINT JUST AS SCHNEDIER SHOULD HAVE DISMISSED IT 9/27/12!
JUDGE ALVAREZ LACKS THE COURAGE TO RULE AGAINST MIGHTY STUBBLEFIELD.
WHAT IS HE LOOKING FOR? A NEEDLE IN A HAYSTACK TO DENY SHIPLEYS MSJ?
WOULD JUDGE ALVAREZ RATHER SUBMIT THE CASE TO A JURY TO AVOID RULING?
WHY CANT HE DO THE RIGHT THING----APPLY THE LAW AND DISMISS THIS CASE?
WE ASK THE COUNTY TO INVESTIGATE, MEET WITH THE PRESIDING JUDGE,
MARSHA SLOUGH, AND ASK HER TO RULE ON THE CASE HERSELF, OR APPOINT A
JUDGE WHO HAS THE COURAGE TO APPLY THE LAW EVEN IF IT MEANS RULING
AGAINST THE MIGHTY BILLIONAIRE STUBBLEFIELD WHEN THE LAW REQUIRES IT!
WE HAVE ENDURED A LIVING HELL FOR SEVEN MONTHS!!! ENOUGH IS ENOUGH!!!
WE DEMAND JUSTICE FROM THE COURT NOT POLITICS OR CORRUPTION!!!
We await an immediate response from the BOS on this urgent matter!
16
A BAR JOURNAL
01"TK:lA"sC:&I_iCAIiU);yP 17F Tt.x'E
$A@ Or GRLIFR&%$&
FEBRUARY 2013
Courts operate in 'crisis mode' under

governor's budget
By Laura Ernde
Staff Writer
California's court system escaped additional
operational cuts in Gov. Jerry Brown's proposed
2013-14 budget, but that bit of good news was
tempered by the reality of continued courtroom
closures and reduced services across the state.
In a conference call with reporters last month, Chief
Justice Tani Cantil-Sakauye said the budget news
State Bar President Patrick kelly
was on one level a relief. Brown did not eliminate
trial court reserves earlier than expected, a proposal that court leaders said would
have drained $200 n~illionfrom operations.
Instead the governor proposed cutting $200 million from court construction
projects. Also, because the court operations budget remained flat, the trial courts
will be forced to move forward with planned courtroom closures and other
reductions in service. The branch's annual budget is $475 million smaller than it
was before a series of cuts began four years ago.
In the same conference call, Administrative Director of the Courts Steven Jahr
said families facing breakups now have to wait three months for a permanent
custody and visitation order in Shasta County Superior Court, where he used to
be a judge.
"It has real human consequences," he said. "What's happened over the last three
or four years is not being remedied."
Two of the state's most influential newspapers have written editorials about the
impact to trial courts. See the Los Angeles Times and Sacramento Bee.
The Open Courts Coalition - which includes State Bar leaders and members of
the plaintiffs' bar and defense bar - will continue to lobby for the restoration of
court funds, State Bar President Patrick Kelly said.
"Courts are in a crisis mode and members of the judiciary are our heroes in trying
to maintain access to justice for clients in California," he said.
The coalition plans to hold meetings this month to discuss a thorny issue that's
confounded the judiciary for 15 years - a formula to ensure equal access to the
courts throughout the state.
State Bar Executive Director Joseph Dunn said state lawmakers first called for
those metrics 15 years ago, when it transferred funding of the judicial branch
from the counties to the state. But despite years of trying, no one has been able to
devise metrics on which everyone can agree.
Last fall, the governor created a Trial Court Funding Workgro~~p,
with members
appointed by the chief justice and the governor, to evaluate the state's progress
on equal funding envisioned by the Lockyer-Isenberg Trial Court Funding Act of
1997. The group has held a series of meetings and is due to report to the governor
by April.
Dunn said unless the bench and bar can come up with a way to measure whether
state funding is ensuring equal access to litigants, it will be difficult to convince
the legislature to restore court funding.
OPINION
EDITORIAL
Paying for California's courts

Gov. Jerry Brown's budget will force the court system to dose courthouses, cut services,
increase more fees and continue to delay courthouse construction.
January 16,2013
Not long before the economy collapsed in 2008 ,California's courts raised many fees and fines
to pay for a far-reaching program of courthouse construction. The plan was not for new
judicial palaces or unnecessary luxury, but for replacing buildings that were designed with a
1950s population in mind and constructed with equally outdated techniques that now
jeopardize the safety of jurors, litigants and everyone else who uses them. The state's budget
distress put most of the program on hold as money from those higher fines and fees, which
were imposed on a public also feeling the financial hard times, was diverted to pay for basic
operations after court funding was slashed.
The diversion was necessary. All state operations had to be deeply cut during the crisis,
including the courts. But now that voter-approved temporary tax increases and a gradually
improving economy and housing market have slowed the cuts, the courts must be given at
least a little room to breathe.
Gov. Jerry Brown's proposed budget provides some good news: The governor backed off plans
to confiscatethe minimal reserve funds that trial courts had saved to ensure that they
remained solvent even amid continuing fiscal emergencies. Still, his budget does take an
additional $200 million from the court system, which will force it to close courthouses, cut
services, increase more fees and continue to delay courthouse construction. In Los Angeles
County, that would mean further retrenchment from a modern court system that serves its
people and a return to an outdated system with impossibly long freeway treks to, for example,
obtain domestic violence restraining orders or even to appear before a judge in a small claims
or landlord-tenant dispute. It would mean that instead of safe, user-oriented facilities located
near today's population centers, the public - already paying higher fines and fees for updated
buildings - must continue to struggle with postwar-era courthouses offering reduced service
hours and diminished assistance.
Of course, every program that was cut over the last five years is getting in line to have its
funding restored. Or rather, they're jockeying for position at the front of the line. But
Proposition 30, the tax hikes that voters approved in November, doesn't provide funding for
restoring previous cuts. California's new supposed good budget times simply mean that for
most programs there won't be additional cuts. But for courts, the slashing continues.
Courts are not just another program. They are a coequal branch of government, quite
obviously essential to the delivery of justice, but essential as well to a developing economy and
a civil society that can resolve disputes fairly and efficiently. The Legislature should keep that
in mind as it makes adjustments to Brown's proposed budget. Copyright 20x3, ~ oAngeles
s
Times
Monday, February 4,201 3
Editorial: Local court loses amid raids, bad

decisions
By the Editorial Board
Published: Wednesday, Jan. 16,2013 - 12:OO am 1 Page 12A

Last Modified: Saturday, Jan. 26,2013 - 5:19 pm
In recent years, as they struggled with declining revenue, lawmakers and

governors regularly robbed Peter, government programs deemed of lesser
importance, to pay Paul, programs with higher priority.
The state judiciary has been a victim of the state's shell game. For the past three
years, the Legislature has funded its priorities by redirecting $1.1 billion that was
supposed to pay for the replacement and repair of courthouses, including
Sacramento's proposed downtown court.
The consequences are coming due.
In 2010 the Legislature and then-Gov. Arnold Schwarzenegger signed off on a
public-private partnership to build and finance a new courthouse in Long
Beach. The financing arrangement required no upfront payments from the state.
The $490 million courthouse will be ready to occupy in September, and that's
when state payments come due, $35 million initially, growing to an average of
$61 million a year for the next 35 years.
The deal called for the state to appropriate the payments from its general fund.
Gov. Jerry Brown's proposed budget does not include the funding.
The California Judicial Council on Thursday is expected to authorize payments
from one of its courthouse construction funds, although little money is left in that
fund after repeated legislative raids.
The result is that four other courthouse construction projects will be delayed
indefinitely, including Sacramento's. The one bright spot is that an advisory panel
has recommended that the Judicial Council allocate $10 million to purchase the
site in Sacramento's downtown railyard where the new courthouse would be
built.
Dissident judges, critical of what they consider to be bloated spending by
California's court bureaucracy, complain that the Long Beach court should not be
allowed to push to the front of the line. Their argument is buttressed by
the Legislative Analvst's Office, which reported that the unusual public-private
partnership financing arrangement inflated the cost of the Long Beach facility by
as niuch as $160 million.
Nonetheless, this was a deal approved by the Legislature. The state is obligated to
Pay
The dispute is emblematic of wider problems within the justice system, the
judiciary's lack of clout within the Legislature, and the rift between dissident
judges and the court bureaucracy headed by Chief Justice Tani Cantil-Sakauye.
In 2011, the chief justice initiated a top-to-bottom review of the court
bureaucracy that resulted in 145Judicial Council directives. She now needs to
show how those directives translate into tangible savings and improvements in
court operations.
Equally important, judges need to get on the same page. The tension
between different factions within the courts does not help the judicial
branch make its case in the Legislature or with the governor.
Read more here: http:llwww.sacbee.com/2013/01/16/5117550/local-court-loses-amid-raidsbad.html#storylink=cpy#storylink=cpy
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41
Case Type:
Case Number:
Case ClVDSl001036 STUBBLEFIELD PROP -V- GRAZIANO

Action:
MOTION RE: PERMANENT INJUNCTION

02/25/2010 8:35 AM DEPT. S36
DONALD ALVAREZ PRESIDING.

CLERK: STEPHANIE CHANDLER
COURT REPORTER DEBORAH THOMPSON 7079
COLIRT ATTE hlDANT ERIC AS HE
APPEARANCES:
AlTORNEY ROBERT G WlLLlAMSOlV JR PRESENT FOR PLAINTIFF/PETITIONER.
PARTIES NOT PRESENT: JOSEPH D. GRAZIANO
MO1-ION
STUBBLEFIELD PROPERIIES'S MOTION TO RE PERMANENT INJUIVCTION IS HEARD.
SUBMIllED ON POINTS & AUTHORITIES
COURT FINDS:
STUBBLEFIELD PROPERTIES'S MOTlOhl RE PERMANENT INJLINCTION IS GRANTED.
RESTRAINING ORDERS
JOSEPH D GRAZIANO
IS RESTRAIIVED AND ENJOINED FROM ENTERING INTO OR BEING ANYWHERE ON M E PREMISES OF
MOUNTAIN
SHADOWS MOBILEHOME COMMUNITY LOCATED AT 4040 PIEDMONT DRIVE, HIGHLAND, CALIFORNIA
92346,
WITHOUTA VALID COURT ORDER ALLOWING SUCH ACCESS.
RESPONDENT IS RESTRAINED AND ENJOINED FROM HARASSING, ANNOYING, THREATENING, TOUCHING
OR
STALKING ANY COMMUNITY RESIDENT OR MEMBERS OF COMMUNITY MANAGEMENT.
JOSEPH D. GRAZIANO IS ORDERED TO STAY AWAY AT LEAST 25 YARDS FROM ANY COMMUNITY
RESIDENT
" F:'
AND REFRAIN FROM USING VULGAR LANGUAGE, SWEAR WORD

AND ANY OTHER PROFANE OR BELLIGERENT LANGUAGE
TOWARD ANY COlVlMUNlTY RESIDENT.
RESPONDENT SHALL NOT POSSESS AND/OR BRANISH
ANY TYPE OF FIREARM.
THlS ORDER SHALL AUTOMATICALLY EXPIRE AT 11:59 PM ON FEBRUARY 24, 2013, UNLESS 3 MONTHS
BEFORE THE
EXPIRA-rlOIV DATE, PETITIONER PETITIONS FOR A NEW INJUNCTION WHERE THERE HAVE BEEN
RECURRING OF
CONTINUOUS VIOLATIONS OF THIS INJUNCTION OR THERE IS A THREAT OF FUTURE VIOLATIONS LIPON
TERMINATION OF M I S INJUNC11ON.
ORDER SIGNED THlS DATE.
STAGE AT DISPOSlllON: PETlllON GRANTED

DISPOSITION: PETITION GRANTED
ACTION - COMPLETE
=== MINUTE ORDER END ===
CAI-IFORNIA JUDGES BENCHGUIDES
INJUNCTIONS PROHIBITING CIVIL

HARASSMENT AND
WORKPLACEIPOSTSECONDARY
SCHOOL VIOLENCE
[REVISED 20121
ADMINXSTRATIVE OFFICE
OF THE COURTS
EDIl(:ATION I)JVLSION/CENTER FOR
JUDXCIAI, EDIICATIC)N A N D RESEARC2I-I
520.9
California Judges Benchguide
20-1 2
$527.6 is not intended to provide for summary determination of

potentially complex issues, e.g., it cannot be used to resolve dispute over
v b.(o~"~juc:z
?;: (1 987) 1 92 CA3d 1 5 I 3, 1 5 1 7
easement use); i1/Iorqu~::~-luytle
15 ! (Id, 238 Cf.l 1 72 (because CCP 5527.6 protects people, not property,
court does not have authority to evict respondent who has threatened to
damage property but not to harm petitioner).
A person seeking an injunction under these statutes need not make
the showing that is generally required for the granting of injunctive relief.
For example, neither statute requires that before the court may grant an
injunction there must be a showing that a legal remedy (e.g., money
damages) is an inadequate remedy. Nevertheless, in determining whether
to issue such an injunction, the court should consider the general
principles that
Injunctive relief is designed to deter and not to punish (R~$.sL~cEl
1:
Plowa.trr? (2003) 1. t 2 6:)Ailtl.i 3YQ, 401 .-,402,
5 CR3d 137; ,Tca-k/~ps
//t?'t.nltlr.v Af~ai~i
( 1 999) 72 Q7A.!&eh
324, 332: $5 (.'R2d 86);
An injunction is an equitable remedy (l'cc~pte1) ,S~ingd~ic~or,,o
( 4 082)
139 CA3d 364,367, 18 1 C:K 90);
A prior restraint is a disfavored remedy (Hrgrvic v Jfocjffilz (2000)
84 C'A4th 1232. 12.11 1242, 10 1 I'R2d 558); and
A court should issue a mandatory injunction only on a clear
showing that injury will result if the injunction is not issued
(fizurigbloou' -t. FYiIkxfx (1989) 207 CA3d 1368: I373 n l , 255 CR
537).
B. Temporary Restraining Order and Injunction Prohibiting

Harassment (CCP 5527.6)
1. [$20.9] Who May Seek Relief
A person who has suffered harassment (see 920.10) may seek a TRO
and an injunction prohibiting harassment. CCP $527.6(a)(l). The term
"person" is limited to natural persons and does not include artificial
entities such as corporations, partnerships, or associations. i!u~/trrigdo~
Lgi) ,C;esieflces,I w . 1: icjlc>p lIl'linliijgd{~n
Anu?!crl Q jually tj.'iL1, Iirc. (2005f
129 CA4tl1 1228. 1258, 29 C:R3iB 522 (animal testing laboratory cannot
maintain cause of action against organization and individuals protesting
laboratory's activities); P)iiimt,ntl 17iet.tt L ~ t l1; f l i ~ ,(-l986) 180 CB3d 612,
6 18-61 19,225 C:K 65 1 (limited partnership not entitled to injunctive relief).
The petitioner may appear in the proceeding by counsel or in pro per.
CCP 527.6(k).
Diamond View Ltd. v. Herz (1986) 180 Cal.App.3d. 612

[4a] In construing a statute we are enjoined by that same code to ascertain the Legislature's intent. "In the
(5 1859.) fil.
construction of a statute the intention of the legislature is to be pursued, if possible;
5 Consistent with this injunction, the Supreme Court has repeatedly held that the "'fundamental rule of statutory construction is
that the court should ascertain the intent of the Legislature so as to effectuate the purposes of the law.' In determining such
intent, the court must first look to the words of the statute." (T. M. Cobb Co. v. Superior Court (1984) 36 Ca1.:-jddd2~,
277
[204 Cal.Rptr. 143,682 P.ad 3381, citations omitted.) The words of a statute must be read in context, bearing in mind
the nature and obvious purpose of the statute. (Moyer v. Workmen's Comp. Appeals Bd. (1973) lo CaI.2d 222,230 [iio
Cal.Rptr. [180 Cal.App.3d 6181 144,514 P.ad 12241.) [3b, 4b] Implicit in this overriding requirement that the words of a
statute are to be read in context is that the preliminary definition contained in section 17 is superseded when it obviously conflicts
with the Legislature's subsequent use of the term in a different statute. .hl..
...
..."
[3c] We turn then to the language of section 527.6 to determine whether the term "person" was used in the
sense of a "natural person" or whether it was also meant to include "artificial persons" such as partnerships,
corporations and associations. First of all, section 1of the chapter enacting section 527.6 expressly declares that "[tlhe
Legislature intends by this act to protect the individual's right to pursue safety, happiness and privacy as guaranteed by the
California Constitution." (Stats. 1978, ch. 1307,s 1, p. 4294, italics added.) This declaration explicitly states that it was the
rights of individuals, and not artificial entities, that were sought to be protected by this legislation. That
purpose is also reflected in the language of the statute itself. The statute requires that the harassment be
directed against "a specific person." (8 527.6, subd. (b).) This language also strongly suggests that the Legislature
intended that the victim of the harassment be an individual human being rather than an artificial legal entity.
Furthermore, "harassment" is defined in terms of its effect on the victim; that effect is described as one "which
seriously alarms, annoys, or harasses" the tormented person. (5 527.6, subd. (b).) In addition, the harassing course of
conduct "must be such as would cause a reasonable person to suffer substantial emotional distress, and must actually cause
substantial emotional distress to the plaintiff." (lbid) These are emotional states exhibited by natural persons, not by
legal fictions. Consequently, in the context of its usage in this statute, it appears that the term "person" was
l
fn.7 1180 Cal.App.3d 6191
meant to refer only to natural persons, and not to l e ~ aentities.
Our conclusion that the purpose of section 527.6 is to provide a remedy onlv to natural Dersons also finds
support in the legislative history of the statute. In Smith v. Silvey (1983) 149 Cal.App.nd 4oo[ig7 Cal.Rptr. 151, the court
recounted a portion of that history: "Ananalysis prepared for the Senate Committee on Judiciary (1977-1978 Reg. Sess.--Assem.
Bill No. 3093) saw the purpose as follows: 'Under existing law, a victim of harassment may bring a tort action based either on
invasion of privacy or on intentional infliction of emotional distress. Where great or irreparable injury is threatened, such victim
may obtain an injunction under procedures detailed in C.C.P. Sec. 527(a). [TI] This bill would establish an expedited procedure for
enjoining acts of 'harassment,' as defined, including the use of temporary restraining orders. The bill would make it a
misdemeanor to violate the injunction and would provide for the transmittal of information on the TRO or injunction to law
enforcement agencies. [ill The purpose of the bill is to provide quick relief to harrassed persons."' (Id, at p. 405.)
The legislative history further reveals that the source of the bill was a "coalition of McGeorge Law Students"
and that the "impetus for this bill was an intimidating experience recently suffered by a Sacramento law
student. Newsweek in the July 4,1977 issue, described it in the following passage: [ll] 'He followed her day after day, she
remembers. He pressed his face against the windows of her class rooms and peered at her around bookstacks in the library. He
swathed her car in red and white camellia blossoms. He called her 40 times a weekend and sent her gifts such as his sterlingsilver baby cup ...When she fled to her parents' home 150 miles away, he would park nearby for hours ... [He] bombarded her,
she says, with clippings on parapsychology, letters he had written to President Ford and gifts, including a rock shaped like a
phallus."' (Assem. Corn. on Judiciary, Digest of Assem. Bill No. 3093 (1977-1978 Reg. Sess.) as amended April 24,1978.)
Diamond View Ltd. v. Herz (1986) 180 Cal.App.3d. 612

Given this legislative history and the context in which the word "person"is used in the statute, we conclude that
a limited partnership is not a person in whose favor an injunction can be granted pursuant to Code of Civil
Procedure section 527.6. The trial court consequently erred in issuing an injunction in favor of Diamond View.
fn. 8 [180 Cal.App.gd 6201
DISPOSITION
That portion of the judgment (order) prohibiting defendant from harassing plaintiff Diamond View Ltd. and
awarding attorney's fees and costs to Bill Kerns as partner of Diamond View Ltd. is reversed. The matter is
remanded to the trial court with directions to conduct further proceedings on the issue of the award of attorney's fees to plaintiff
Kit Doering. In all other respects, the judgment (order) is affirmed. Each party shall bear its own costs on appeal.
Blease, Acting P. J., and Sims, J., concurred.
APPENDIX A
Section 527.6 of the Code of Civil Procedure provides as follows: "527.6. (a) A person who has suffered harassment as defined in
subdivision (b) may seek a temporary restraining order, and an injunction prohibiting harassment as provided in this section. [I]
(b) For the purposes of this section, 'harassment' is a knowing and willful course of conduct directed at a specific person which
seriously alarms, annoys, or harasses the person, and which serves no legitimate purpose. The course of conduct must be such as
would cause a reasonable person to suffer substantial emotional distress, and must actually cause substantial emotional distress,
to the plaintiff. 'Course of conduct' is a pattern of conduct composed of a series of acts over a period of time, however short,
evidencing a continuity of purpose. Constitutionally protected activity is not included within the meaning of 'course of conduct.'
[%I(c) Upon filing a petition for an injunction under this section, the plaintiff may obtain a temporary restraining order in
accordance with subdivision (a) of Section 527. A temporary restraining order may be granted with or without notice upon an
affidavit which, to the satisfaction of the court, shows reasonable proof of harassment of the plaintiff by the defendant, and that
great or irreparable harm would result to the plaintiff. A temporary [i80 Cal.App.3d 6211 restraining order granted under this
section shall remain in effect, at the court's discretion, for a period not to exceed 15 days, unless otherwise modified or terminated
by the court. [f(d) Within 15days of the filing of a petition, a hearing shall be held on the petition for the injunction. The
defendant may file a response which explains, excuses, justifies, or denies the alleged harassment or may file a cross-complaint
under this section. At the hearing, the judge shall receive such testimony as is relevant, and may make an independent inquiry. If
the judge finds by clear and convincing evidence that unlawful harassment exists, an injunction shall issue prohibiting the
harassment. An injunction issued pursuant to this section shall have a duration of not more than three years. At any time within
the three months before the expiration of the injunction, the plaintiff may apply for a renewal of the injunction by filing a new
petition for an injunction under this section. [TI (e) Nothing in this section shall preclude either party from representation by
private counsel or from appearing on his or her own behalf. [l]](0 Upon filing of a petition for an injunction under this section,
the defendant shall be personally served with a copy of the petition, temporary restraining order, if any, and notice of hearing of
the petition. [%I(g) The court shall order the plaintiff or the attorney of the plaintiff to deliver, or the clerk to mail, a copy of each
temporary restraining order or injunction, or modification or termination thereof, granted under this section, by the close of the
business day on which the order was granted, to the law enforcement agencies within the court's discretion as are requested by
the plaintiff. Each appropriate law enforcement agency shall make available information as to the existence and current status of
these orders to law enforcement officers responding to the scene of reported harassment. [?I]
Home
Name Search Results

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jl~nlawlulDetainer
11
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PROPERTIES. A
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PETITIONER
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Mobilehorne(Ltd) j
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TIME : @2/@6/2613 12:17

k..IAb.IE
: ~~~~AI.IC'U'-ISIJFF''~~
FAX
: 8059653592
TEL
: 8053653492
SEE.# : 00ElG55323985
DATE , TII4E
FAX b10 /NAME
DURATI ?P4
P&E ( 5 :
EESI-ILT'
Pt1OT)E

Law Office of Nancy Duffy McCarron
950 Roble Lane
805-965-3492 (ph/fax) 805-450-0450 (cell)
MARCH 1, 2013
TO: Marsha Slough, Presiding Judge
re: FOLLOW UP to 2-6-13 letter by email
FAXED to: 909-708-8754 and sent by email
cc: SAN BERNARDINO COUNTY BOARD OF SUPERVISORS (ALL 5 DISTRICTS)
Robert Lovingood (1st), Janice Rutherford (2nd), James Ramos (3rd), Gary Ovitt (4th), Josie Gonzales (5th)
faxed to 909-387-9090 and sent by email to all Supervisors

RE:
STUBBLEFIELDS USE OF SAN BERNARDINO SUPERIOR COURTS AS A DEVICE

TO STEAL MOBILEHOMES & HARASS ANYONE WHO REFUSES TO CAPITULATE
JUDGES ENABLE ABUSE & HARASSMENT BY REFUSING TO DISMISS SHAM CASES
PART II
(follow up to 2-6-13 letter sent by email)
ISSUE I: Wilfred Schneider

On February 6, 2013 we asked you in writing to confront Judge Wilfred Schneider
to ask him if he is related to Kim Schneider, surviving wife of Joe Gallal, who died on
11-25-12 and was the son of Tom Parrishs second wife, Mary Lou Gallal Parrish.
Parrish has been VP of Stubblefield Properties, a CA General Partnership, for 30 years.
Stubblefield is plaintiff trying to evict my co-resident Bonnie Shipley in UDDS 1204130.
(attached is a 2nd copy of Gallals death certificate-as attached to 2-6-13 letter) [Exh A]
You failed to respond to our request. On 2-14-13 we went to your office to speak to your
assistant, Kay Lewis (909-708-8769) to ask why you did not answer our written inquiry.
Kay would not accept the call we made at the front reception desk on the 4th. floor.
The receptionist said Kay Lewis would not take our call but to let us know we would
receive a written response within a week. Two weeks have passed and we did not
receive any written response to our inquiry. WHY DID YOU FAIL TO RESPOND?
YOU ARE PRESIDING JUDGE. IT IS NOT ONLY YOUR RESPONSIBILITY BUT
YOUR DUTY TO RESPOND TO THIS WRITTEN INQUIRY. I AM A TAXPAYER
IN SAN BERNARDINO COUNTY AND A LITIGANT IN THE SUBJECT CASE.
I have a duty to discover this answer as an advocate for my client and a right to know.
WE NEED TO KNOW IF JUDGE SCHNEIDER IS RELATED TO KIM SCHNEIDER?
1
ISSUE II. Judge Alvarez

After Judge Schneider recused himself and Donna Garza transferred our case to S-32
we waited to see if Judge Donald Alvarez would actually apply the law to the facts in our case.
The pattern of ruling for Stubblefield and refusing to dismiss the sham case continues to date.
Below is an excerpt from our Feb 6, 2013 letter summarizing more rulings against the law.
JUDGES CODDLING STUBBLEFIELD & REFUSING TO DISMISS A SHAM CASE
12/3/12
Judge Schneider, sua sponte, revoked his own abusive $9,000 sanction order
D-8
12/4/12
Judge Schneider recused himself from the Stubblefield/Shipley case
D-9
NOTE: a few weeks later Judge Schneider was transferred to Fontana Court
Previously Schneider presided over family court; there were so many
appeals he was transferred to S-31 to rule only on limited jurisdiction cases
D-10
12/5/12 Alvarez continued Shipleys MTC production of Ps secret videos & reports
D-11
D-13
D-15
D-16
The above shows an early pattern of a newly assigned judge ruling for Stubblefield every time!
We filed a motion for Judgment on the Pleadings because plaintiff did not allege, and could
not allege statutory elements of forcible detainer recited in Civil Code 1160 and CCP 1172
Plaintiff must show it occupied the premises within 5 days before the alleged forcible entry.
Alvarez knew plaintiff could not prove an element; P admitted I have occupied 333 since 2005.
Alvarez should have granted the Motion for Judgment on the Pleadings; instead he denied it.
Alvarez completely ignored stare decisis, the governing statutes, and rules of procedure, ruling
for Stubblefield once again because he is afraid Stubblefield will BANKROLL an opponent to
try to unseat him. [See Exh. A-2 showing Judge Alvarez is now up for reelection in 2014]
We reviewed Stubblefield v. Graziano CIVDS1001036. On 2/25/10 Alvarez granted
Stubblefields Partnerships petition for an anti-harassment injunction against mobilehome
owner Joseph Graziano. Alvarez knew an anti-harassment injunction could only be issued
to protect human persons and could not protect artificial persons (partnership) [Exh.B]
CA Benchguide, Injunctions Prohibiting Civil Harassment, 20.9 expressly recites that an antiharassment injunction may only be used to protect a human person -not a partnership.
2
The California Benchguide cites Diamond View Ltd. v. Herz (1986) 180 C.A.3d 612.
Not only was the injunction against the law, but Alvarez ordered owner Joseph Graziano to
stay away at least 25 yards from any community resident No park residents petitioned the
court for protection from Graziano---their friend for years. THE ORDER WAS ILLEGAL!
Judge Alvarez, by granting the contrived injunction based on a perjured affidavit, became an
enabler Stubblefields racketeering enterprise. Graziano was enjoined from the park and had
to stay 25 feet away from any park resident. ALVAREZ MADE AN ILLEGAL ORDER!
Judge Alvarez entered the anti-harassment order against Graziano on 2/25/10. [Exh B]
One week later---on 3/2/10--- tax assessor staff entered MSMHC as 100% owner of space 35:
Note how the tax assessor entered a roll correction under relationship and an artificially
low roll value of $4,745 as of Jan. 1, 2005. No tax bills had been generated after Jan 1, 2005.
Mountain Shadows Mobile Home Community is listed as a CORPORATION which is false.

Stubblefield Properties is a CA partnerhip dba Mountain Shadows Mobile Home Community.
Judge Alvarez enabled Stubblefield to steal Joe Grazianos mobile home within a week after he
granted the ILLEGAL INJUCTION AGAINST Joe Graziano. Since there was an injunction
against entering the park he was unable to enter the park to move his familys furniture or
personal property from the mobilehome. Stubblefield stole the home and all of its contents.
Our 2-6-2012 letter outlined the basic arguments set forth for summary judgment which
was on calendar for 1-31-2013. We expected Judge Alvarez to apply the law. Plaintiff failed to
file a statement of disputed facts in opposition to defendants statement of undisputed facts.
Plaintiff failed to file any affidavits opposing three supporting affidavits defendant submitted.
Plaintiff failed to file any affidavit countering the affidavit of defendant submitted from Maury
Priest, a legislative lobbyist, who had personal knowledge about legislative intent because he
attended every legislative session when Civil Code 798.75 was amended to add subsection [c].
Priest testified legislators intended Civil Code 798.75 [c] to be used only against purchasers
and transferees which was why the statute was included in Article 7-Transfers of Ownership
and that legislators never intended it to be used against a homeowner sharing a mobilehome:
Despite that Shipley provided undisputed evidence, from a witness with personal
knowledge of what legislators intended when they added subsection [c] to Civil Code 798.75,
Judge Alvarez disregarded his affidavit and adopted plaintiffs counsels unadulterated, sheer
speculation & conjecture about what he thought legislators intended in adding subsection c.
We predicted on 2-6-13 that Judge Alvarez would not grant summary judgment because he
is afraid Stubblefield will fund a judicial candidate to run against Alvarez in a 2014 election.
JUDGE ALVAREZ SHOULD HAVE GRANTED SUMMARY JUDGMENT AND DISMISSED
THIS SHAM COMPLAINT JUST AS SCHNEDIER SHOULD HAVE DISMISSED IT 9/27/12!
Judge Alvarez ruled against the clear language of Civil Code $798.75, which only applies
to purchasers and transferees who acquire title and occupy with first executing a park lease,
finding that subsection [c] applies to any occupant, abrogating all protections our legislators
granted to mobile home owners in Civil 798.55-798.57 against park owners arbitrary eviction.
[See copy of WRIT PETITION send by separate email].
5
JUDGE ALVAREZ
POTENTIAL CONFLICT OF INTEREST
We discovered that in SCVSS132132 Donald Alvarez recused himself on 3/2/2006 [Exh.C-1]

because he was a partner in a partnership who owns 1839 Commercenter W, San Bernardino.
and a partys attorney [Leland P. McElhaney] rents the building for his firms law practice.
We discovered an array of persons & entities associated with 1839 Commercenter W [Exh. C-2]
We looked up 1839 Commercenter W, San Bernardino in an online tax assessor list, which
shows 2 parcels associated with it. [0141-451-07-000] & [0141-451-07-L001] [Exh. C-3, C-4]
Partners pay $188.45 for L001 & havent paid any tax since 2010 on 07-000. [Exh. C-5, C6]
The 07-000 parcel shows document 19900494381; a grant recorded 12/17/90. [Exh. C-7]
We searched for Commercenter Law Building Partnership and found no records [Exh. C8-9]
We need to know the names of every partner in the partnership to research potential conflicts.
We need to know why this partnership is not registered with SOS as required by law?
We understand that Judge Alvarez disclosed his interest in the building and partnership in the
Form 700 he submitted to the Fair Political Action Committee which you have at the court.
We demand that no further proceedings are conducted in S-32 until we are able to obtain
the names of all partners in the Commercenter Law Building Partnership and the names of
any law firms who have represented any of these partners or the partnership to discover if
there are any conflicts of interest which would require disqualification.
We await an immediate response from your office in WRITING on or before Wednesday,
March 6, 2013 as there is a hearing set on March 7, 2013---plaintiffs motion for an injunction
prohibiting us from talking to employees or so-called agents of Stubblefield---whomever might
be included in that nebulous, undefined group. We demand a stay on proceedings until this
issue of the failure to disclose the names of the other partners in the Commercenter Law
Building Partnership and also failure to disclose the names of any other partnerships in
which Judge Alvarez has a financial interest.
John M. Tomberlin
Updated: 01-02-13:kcl
A-2
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036 ......
STUBBLEFIELD
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MOTION RE: PERMANENT INJUNC'TION

0212512010 8:35 AM DEPT. S36

COURT REPORTER DEBORAH THOMPSON 7079
COURT ATTENDANT ERIC ASHE
APPEARANCES:
ATTORNEY ROBERT G WILI-IAMSON JR PRESENT FOR PLAINTIFFIPETITIONER.
PARTIES NOT PRESENT: JOSEPH D. GRAZIANO
MOTION
SnlBBLEFlELD PROPERIIES'S M O I O N TO RE PERMANENT INJUNCTION IS HEARD.
SUBMITIED ON POINTS & AUTHORITIES
COURT FINDS:
STUBBLEFIELD PROPERTIES~S MOTION RE PERMANENT INJUNCTION IS GRANTED.
RESTRAlhllNG ORDERS
JOSEPH D GRAZIANO
IS RESTRAINED AND ENJOINED FROM ENTERING INTO OR BEING ANYWHERE ON THE PREMISES OF
MOUNTAIN
SHADOWS MOBILEHOME COMMUNITY LOCATED AT 4040 PIEDMONT DRIVE, HIGHLAND, CALIFORNIA
92346,
WITHOUT A VALID COURT ORDER ALLOWING SUCH ACCESS.
RESPOhlDENT IS RESTRAINED AND ENJOINED FROM HARASSING, ANNOYING, THREATENING, TOUCHING

OR
STALKING ANY COMMUNllY RESIDENT OR MEMBERS OF COMMUNITY MANAGEMENT.
JOSEPH D. GRAZIANO IS ORDERED TO STAY AWAY AT LEAST 25 YARDS FROM ANY COMMUNITY
RESIDENT
....
...-. ----*
AND REFRAIN FROM USING VULGAR LANGUAGE, SWEAR WORD

AND ANY OTHER PROFANE OR BELLIGERENT LANGUAGE
TOWARD ANY COMMUNITY RESIDENT.
RESPONDENT SHALL NOT POSSESS AND/OR BRANISH
ANY N P E OF FIREARM.
THlS ORDER SHALL AUTOMATICALLY EXPIRE AT 11:59 PM ON FEBRUARY 24, 2013, UNLESS 3 MONTHS
BEFORE THE
EXPIRATION DATE, PETll-IONER PETlllONS FOR A NEW INJUNCTION WHERE THERE HAVE BEEN
RECURRING OF
CONTINUOUS VIOLATIONS OF THIS INJUNCTION OR THERE IS A THREAT OF FUTURE VIOLATIONS UPON
TERMINATION OF THlS INJLINC11ON.
ORDER SIGNED THIS DATE.
STAGE AT OISPOSI11ON: PETITION GRANTED
DISPOSITION: PETITION GRANTED
ACTION - COMPLETE
520.9
California Judges Benchguide
20-1 2
5527.6 is not intended to provide for summary determination of

potentially complex issues, e.g., it cannot be used to resolve dispute over
easement use); dhmpez-tuque v .24a~quez( I 987) 1 92 CA3d I 5 13, 1 5 t715 13, 238 Cfl 172 (because CCP $527.6 protects people, not property,
C O U does
~
not have authority to evict respondent who has threatened to
damage property but not to harm petitioner).
A person seeking an injunction under these statutes need not make
the showing that is generally required for the granting of injunctive relief.
For example, neither statute requires that before the court may grant an
injunction there must be a showing that a legal remedy (e.g., money
damages) is an inadequate remedy. Nevertheless, in determining whether
to issue such an injunction, the court should consider the general
principles that
Injunctive relief is designed to deter and not to punish (R~usell
Doul.crr7 (2003) 1. 12 C:hiil:h 3CF):40 1 .-..4.02,XCli3d 137; Scrij~ps
/It)~l'tlzv itfu/*i~i
( I 999) 72 C>ALFL~
321.1. 332: 85 C:li2d 86);
An injunction is an equitable remedy (I)copl(: ,';cngJiac*on/o(1 983j
129 CA3d 364, 367. 18 I CR 90);
* A prior restraint is a disfavored remedy (Nnwif: v .I-locjflr'n(2000)
83 CA4tb 1232. 124,1.....I242.10 1 CR2d 558); and
A court should issue a mandatory injunction only on a clear
showing that injury will result if the injunction is not issued
(lburigbkood v Wilcox (1989) 20'3 CA3d 1368, 1372 n l , 255 CR
537).
B. Temporary Restraining Order and Injunction Prohibiting

Harassment (CCP 8527.6)
1. [820.9] Who May Seek Relief
A person who has suffered harassment (see $20.10) may seek a TRO
and an injunction prohibiting harassment. CCP $527.6(a)(1). The term
"person" is limited to natural persons and does not include artificial
entities such as corporations, partnerships, or associations. Hunlirlgdori
L~ .I'~,ie~rces,
in^.. v Siop ZIJniiirgdon rft~l/ri(/l (iwelty IiXt1, Ilrc. (2005)
129 CA4tl1 1228. 1258, 29 CK3d 521 (animal testing laboratory cannot
maintain cause of action against organization and individuals protesting
laboratory's activities); Diornond I'ieu Litf. I; I l i ~ (z1 986) 1XO CA3d 6 12.
6 18-6 19. 225 CK ti5 i (limited partnership not entitled to injunctive relief).
The petitioner may appear in the proceeding by counsel or in pro per.
CCP $527.6(k).
3/1/13
Home
CosnplaintdPadies
Case Type:
Case Number:
".-
SCVSS132132 Minute Orders - San Bernardino Main
Actions
Minutes
Pending
Hearings
-.-
Gas
Report
I*
Case SCVSSl32132 DEMERS -V- ALLEN ET AL

Action:
MOTION RE: DEMURRER FILED BY DEFENDANT ELISE KAREN DEMERS

0310212006 8:30 AM DEPT. S5

CLERK: KIM ALLAIN
REPORTER: LEISHA HENDRIX
COURT ATENDANT ERIC ASHE
APPEARANCES:
AlTORNEY THOMAS DOMIhllCK PRESENT FOR PLAIN-rlFF/PETITlONER.
AlTORNEY LELAND MCELHANEY PRESENT FOR DEFENDANTIRESPONDENT.
MOTION
J U D G ~DONALD ALVAREZ DISQUALIFIES SELF. CASE ASSIGNED TO JUDGE FRANK GAFKOWSKI,
s 5 FOR ALL PURPOSES.
TO DEPARTMENT S5.
HEARI~GS:
CURRENT HEARING CONTINLIED TO 03/22/06 AT 08:30 IN DEPARTMENT S5.
NO11CE TO BE GIVEN BY ATP/ MCELHANEY.

ACTION - COMPLETE
===
ORDER END ===
MINUTE
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EXHIBIT 9
CIVDS1210511
SAN BERNARDINO COUNTY SUPERIOR COURT

APPELLATE DIVISION
BONNIE SHIPLEY,
Petitioner,
v.

Respondent;
_____________________________________________________
STUBBLEFIELD PROPERTIES,
a CA General Partnership,
dba Mountain Shadows Mobile Home Community
Real Party in Interest.
Following Denial of Motion for Summary Judgment
SBSC No. UDDS1204130 [limited jurisdiction]
The Honorable Donald Alvarez, Judge [S-32]
(909)708-8690
PETITION FOR PEREMPTORY WRIT OF MANDATE IN THE FIRST INSTANCE,
ALTERNATIVE WRIT OR OTHER APPROPRIATE RELIEF; MEMORANDUM OF
POINTS & AUTHORITIES; EXHIBITS & TRANSCRIPTS [IN SEPARATE COVER]
IMMEDIATE STAY OF TRIAL DATE REQUESTED

[trial setting conference is 2-27-2013]
Nancy D McCarron, CBN 164780
950 Roble Lane
nancyduffysb@yahoo.com
805-450-0450 fax 805-965-3492
Attorney for Petitioner
TABLE OF CONTENTS AND AUTHORITIES

Certificate of Interested Entities or Persons . filed 10-9-13
WRIT ISSUE PRESENTED..
Is the summary eviction remedy provided under Civil 798.75[c]

limited only to purchasers and transferees who occupy a mobile
home without first executing a park lease? YES. The court said no.
STATEWIDE URGENCY
The courts ruling abrogated all statutory protections against

arbitrary evictions of mobilehome owners without just cause,
and authorized park owners to evict a resident on 5-days notice
by arbitrarily labeling the resident an unlawful occupant.
PETITION . 3
Authenticity of Exhibits .. 3
Beneficial Interest of Petitioner; .. 3
Capacities of Respondent and Real Party In Interest....................................
Urgency to Petitioner....
Chronology of Pertinent Events ...
No Adequate Remedy At Law......
Prayer ....
Verifications ...
10
POINTS & AUTHORITIES ... 11

Standard of Review [De Novo- Summary Judgment]...
11
Argument I Civil 798.75[c] applies only to purchasers & transferees...
12
Argument II Court erred in finding a triable issue of fact on a park rule
15
CONCLUSION .. . 19
Certificate of Word Count... 20
Proof of Service . 21
i
TABLE OF AUTHORITIES
CASES
Addy v. Bliss & Glennon (1996)
44 CA 4th 205, 214 ....
11
AARTS Productions, Inc. v. Crocker Natl Bank (1986)

179 Cal.App.3d 1061, 1065. ..
14
Burton v. Sec Pac Natl Bank (1988)

197 CA.3d 972, 978 ..
14
Camp v. Jeffer, Mangels, Butler & Marmaro (1995)

35 CA.4th 620, 629 quoting Stratton v. First Natl Life Ins Co.......................
11
Clutterham v. Coachmen Industries, Inc. (1985)

169 CA.3d 1223, 1227; ..
14
Cuccia v. Superior Court (2007)

153 Cal. App. 4th 347, 353-354 .
16
Henriksen v. City of Rialto (1993)

20 CA. 4th 1612, 1617 n 2. [4th. Dist. Div 2]. 11, 14
Lehto v. City of Oxnard (1985)
171 CA.3d 285, 293 [review den. Dec. 5, 1985]
12
Lompoc Unified School Dist. v. Superior Court (1993)

20 Cal. App. 4th 1688, 1692 ...
11
Morales v. Fansler (1989)

209 CA.3d 1581, 1584 17 ..
15
Otanez v. Blue Skies Mobile Home Park (1991)

1 CA.4th.1521..
16
Rancho Santa Paula Mobile Homes v. Evans (1994)

26 CA4th.1129 .
18
Rubenstein v. Rubenstein (2000)

81 Cal. App. 4th 1131, 1151 n.10
15
Sanchez v. Swinerton & Walberg Co. (1996)

47 CA 4th 1461, 1465-1466
14
Smiley v. Citibank (1995)

11 Cal. 4th 138, 145 . 15
Suidan v. County of San Diego (1999)
72 CA. 4th 916, 921 . 15
ii
Sutherland v. Barclays American/Mortgage Corp. (1997)

53 CA. 4th 299, 317 . 15
Travelers Casualty & Surety v. Superior Court (1998)
63 Cal. App. 4th 1440, 1450 . 11
Weaver v. Chavez (2005)
133 CA. 4th 1350, 1356
18
West Shield Investigations & Security Consultants v. Superior Court (2000)

82 CA 4th 935, 946 ..
11
Ziman v. Firemans Fund Ins. Co. (1999)

73 CA. 4th 1382, 1387..
15
STATUTES
Code of Civil Procedure 437c
. 11
Code of Civil Procedure 904.1
Code of Civil Procedure 1160
Civil Code 789.3 .. 16

Civil Code 789.19 . 17
Civil Code 798-798.88 [Moblehome Residency Law (MRL)] . 12
Civil Code 798.11. 12
Civil Code 798.25. 18
Civil Code 798.34(b) . 17
Civil Code 798.55 . 1,2,3
Civil Code 798.55-798.57 1,19
Civil Code 798.75[c] .......... 1,2,5,7,11,12,13,17,19
Civil Code 798.77 . 1
Civil Code 798.88
iii
2,13
WRIT ISSUE PRESENTED

Is the summary eviction remedy provided under Civil 798.75[c] limited only to
purchasers and transferees who occupy a mobile home without first executing a lease?
YES. The court answered no, holding all occupants were subject to summary eviction.
The court denied summary judgment on this issue of law and will set trial on 2-27-13.
STATEWIDE URGENCY
Civil Code 798.55-798.57 provides unique protection to owners of mobilehomes
located in a mobilehome park. A park owner can only terminate a tenancy for seven
enumerated reasons, and only after 60-days written notice reciting the authorized reason.
Only a purchaser or transferee, who acquires a mobilehome in a park and unlawfully
occupies it without first signing a lease, can be summarily evicted under Civil 798.75(c)
Article 7 of the Mobilehome Residency Law [MRL] governing transfers of ownership,
provides this limited remedy to protect park owners from surprise, unlawful occupants
and to prevent a new owner from occupying a mobilehome space without paying rent.
The court erroneously expanded the limited scope of 798.75(c) by saying it applied
universally to any occupant a park owner unilaterally labels as an unlawful occupant.
This was despite testimony from Maury Priest who attended every legislative session in
1987 when subsection c was added. He said legislators added a limited remedy only to
evict purchasers and transferees who moved in without first executing a new park lease.
The holding abrogates all protections our legislators granted in Civil 798.55-798.57.
The court impliedly held that any provision in a park lease or rule is enforceable,
regardless of reasonableness. This disregards Civil 798.77 which renders any provision
void & unenforceable if it deprives an owner of a statutory right guaranteed under MRL.
The court held there was a triable jury issue as to whether a park rule was violated.
This ruling authorizes summary eviction of any resident contrary to legislative intent.
Even if summary eviction were authorized under Civil 798.75(c) [it clearly is not] the
ruling bypassed 2 prerequisite issues; i.e. is the park rule constitutional and reasonable?
Both issues must be decided before deciding if a rule was violated justifying eviction.
This action presents a compelling case for immediate writ review to resolve an issue
of urgent statewide importance to all mobilehome residents. The courts ruling enables
a park owner to summarily evict any occupant for an alleged violation of any park rule
unilaterally imposed, contrary to legislative intent recited under Civil Code 798.55:
(a) The Legislature finds and declares that, because of the high cost of
moving mobilehomes, the potential for damage resulting therefrom, the
requirements relating to the installation of mobilehomes, and the cost of
landscaping or lot preparation, it is necessary that the owners of
mobilehomes occupied within mobilehome parks be provided with the
unique protection from actual or constructive eviction afforded by the
provisions of this chapter.
(b) (1) The management may not terminate or refuse to renew a tenancy,
except for a reason specified in this article and upon the giving of written
notice to the homeowner, in the manner prescribed by Section 1162 of the
Code of Civil Procedure, to sell or remove, at the homeowner's election,
the mobilehome from the park within a period of not less than 60 days,
which period shall be specified in the notice.
It is contrary to an expressed legislative goal to encourage owners to use injunctive
relief under Civil 798.88 rather than evict a resident for an alleged park rule violation:
(Legislative intent: This three-year sunset will arguably provide the
Legislature with the opportunity to re-evaluate this bill to ensure that
the stated goal of encouraging a park owner to pursue a lesser remedy
against a resident of a mobilehome park instead of eviction is actually
reached without negative unintended consequences.) (Amended by
Stats. 2012, Chap. 99 (AB 2272, Wagner), eff. 1/1/2013)
2
PETITION
AUTHENTICITY OF EXHIBITS
1.
All exhibits accompanying this petition are true and correct copies of original
documents on file with the respondent court, except Three Transcripts [certified copies
of Reporter's Transcripts of 3 related hearings on 1/22/2013, 1/31/2013 and 2/14/2013.
BENEFICIAL INTEREST OF PETITIONER;
CAPACITIES OF RESPONDENT AND REAL PARTY IN INTEREST
2.
Petitioner is defendant in an action pending trial in Respondent Court entitled,

Stubblefield Properties, a California General Partnership v. Bonnie Shipley
UDDS1204130, a summary eviction proceeding. Plaintiff is Real Party in Interest.
URGENCY TO PETITIONER
3.
Absent intervention by this court petitioner will be compelled to defend herself

in a trial in a summary eviction proceeding which was not authorized under MRL
and is expressly prohibited by clear legislative intent in Civil 798.55. On 2-14-13
the court entered an order denying summary judgment. [App V-III 13.295]
CHRONOLOGY OF PERTINENT EVENTS
4.
On 8/1/12 petitioner (51) moved in as co-resident of a mobile home owner at

Space 333 in plaintiffs park. The owner had a series of co-residents sharing the
home since she bought it on 1/05/05. The owner registered petitioner at the office.
The manager drove up to 333 on 8/2/12 and tried to orally evict petitioner stating if
she wanted to live there she had to move in with a sugar daddy over 55 in the park.
The manager confiscated a parking sticker the owner attached to petitioners car.
The manager told petitioner the owner had gotten away with having a co-resident
in the past but would no longer get away with it under the new 2010 park rules.
3
5.
On August 11, 2012 plaintiff nailed a 5-day Notice to Surrender Possession:
from: App.Vol.I, p.2.8

6.
Petitioner was unable to surrender possession because she did not own the home.
The notice did not apply to petitioner because she did not purchase the mobilehome.
7.
On August 27, 2012 plaintiff served petitioner with a hybrid Unlawful Detainer
summons combined with a Forcible Detainer complaint. Neither made any sense.
from: App.Vol.I, p.1.1
from App. Vol.I, p. 2.3

4
8.
An unlawful detainer was invalid as there was no landlord/tenant relationship.

A forcible detainer complaint was not viable as no forced entry was alleged and
plaintiff was not the occupant in possession as statutorily required. CCP 1160
9.
The sham complaint was bizarre. Plaintiff alleged it was owner of the premises,
while admitting the homeowner owned the premises at 333 and was the occupant in
exclusive possession of the premises since the park owner leased it to her in 2005.
from App V-I. p 2.4

10.
The complaint recited allegations as if petitioner were a purchaser or transferee

unlawfully occupying as described in Article 7 of the MRL at Civil 798.75(a)-(d):
from App V-I. page 2.5

5
11.
The prayer was equally bizarre. Plaintiff prayed for possession of the premises,
without even joining the owner as a defendant, whose home plaintiff prays to seize;
plaintiff prays for damages at $30.01 per day [reasonable rental value of space 333]
while collecting full space rent from the homeowner it never joined as a defendant;
plaintiff prays for attorney fees without being in privity of contract with petitioner
and where there is no contract or statutory basis for entitlement to attorney fees:
App V-I. page 2.6
12.
On 8/31/12 petitioner filed a demurrer to the sham complaint, a motion to quash

service, a motion to strike attorney fees, and a motion to strike rent value damages.
On 9/27/12 Judge Schneider [S-31] overruled demurrer & denied all three motions.
On 10/4/12 petitioner filed a motion to transfer the case from limited jurisdiction to
higher jurisdiction as assessed value of the home (up for seizure) exceeded $10,000.
The motion was denied without explanation. Later, Judge Schneider revoked his
invalid sanction order and recused himself. The case was transferred to Dept S-32.
13.
On December 26, 2012 petitioner filed a Motion for Judgment on the Pleadings
because plaintiff did not allege, and could not allege, the statutory elements of a
forcible detainer complaint, nor could plaintiff prove it was occupant in possession.
Judge Alvarez [S-32] denied that motion and motions to compel production of
alleged secret videos and written reports of alleged violations. The items requested
were clearly discoverable but the court nevertheless denied the timely motions.
14.
At summary judgment, the so-called summary proceeding had mushroomed to:

8 volumes in 7 months, a 13 page docket with 258 docket entries & 30 hearings.
Petitioner believes it is the longest and thickest summary proceeding in history.
The court must realize this case is not about evicting a roommate in a mobilehome.
This case is about a park owner who already filched 200 of 400 homes in the park
and converted them into a cash cow of rentals to non-owner tenants with no rights.
The owner intends to filch the other 200 homes and petitioner is fighting to the end.
15.
Petitioner moved for summary judgment, setting a hearing on 1-31-13, which

was the same day plaintiff had set a hearing on its motion for summary judgment.
The court set an Order To Show for January 22, 2013 for plaintiff to show cause
why it moved for summary judgment before the court ruled on Motion To Compel
responses to deposition questions set for Feb. 27, 2013. The court stepped out of
its role as Judicial Officer & into a role of plaintiffs advocate, even questioning the
wisdom of plaintiffs counsel in setting MSJ prematurely? [see transcript 1/22/13]
16.
Petitioner filed a separate statement of four undisputed facts. [App.V-III, p. 2.15]

Real partys attorney admitted facts were undisputed. [transcript 1/22/13; p.2 line 5]
The undisputed facts are: 1) owner has a valid lease; 2) Community Rules [2000]
were incorporated in her lease; 3) the MRL governs; 4) owner was in continuous
possession of the premises and real party has collected the monthly rent for 8 years.
7
17.
Real party failed to file a statement of disputed facts in opposition to MSJ.
18.
Petitioner submitted the declaration of legislative lobbyist Maury Priest, in

support of her summary judgment motion. Mr. Priest testified that he attended
every session when legislators amended Civil 798.75 to add subsection(c) in 1987.
19.
Maury Priest testified legislators intended the summary eviction remedy in Civil
798.75[c] to be used only against new purchasers and transferees who acquire title
to a mobile home and then occupy it without first executing a park lease to pay rent.
20.
Mr. Priest testified legislators did not intend summary eviction remedies to be
used against co-residents or guests of a homeowner. [App V-III, p. 3.17b, Par. 10]
Real party failed to file any declaration opposing Maury Priests testimony.
21.
Petitioner filed her own declaration and a declaration of the mobile home owner,
which recited that the owner regularly occupied the home and that petitioner signed
a lease to share occupancy of the home with the owner, who regularly used it.
Real party failed to file any witness declarations opposing summary judgment.
22.
Despite that real party failed to file a statement of disputed facts in opposition;
its attorney admitted that facts were undisputed; and real party failed to file any
declarations in opposition or a declaration rebutting the testimony of Maury Priest,
the court denied a motion for summary judgment which should have been granted.
23.
The court did not post a tentative ruling before the summary judgment hearing
on 1/31/2013, or before the continued hearing on 2/14/2013.
Instead the court
announced its ruling in a lengthy transcript. Three Transcripts are filed with this
Writ Petition and Appendix under separate cover. The transcripts show clear errors.
NO ADEQUATE REMEDY AT LAW

24.
The Respondent Court's denial of Plaintiffs motion for summary judgment is not
appealable. CCP 904.1. Delay of review until after final judgment would be an
inadequate remedy as plaintiff will be compelled to defend an unmeritorious claim.
Writ relief is essential to avoid the waste of significant resources of the parties and
the court in this case, as well as courts throughout California that will be compelled
to conduct jury trials in unmeritorious actions. Petitioner faces summary eviction.
Plaintiff never joined the mobile home owner as a defendant; yet it prays for a writ
of possession to seize her premises. If the writ is granted the owner will lose her
mobilehome without due process of law. Petitioner has no adequate remedy at law
for the relief sought in this Petition other than a writ to reverse clear errors of law.
PRAYER FOR RELIEF

WHEREFORE, Petitioner prays that this Court:
1. Issue an immediate stay of trial pending final resolution of this writ proceeding.
2. Either (a) issue its peremptory writ of mandate directing Respondent Court to set
aside and vacate its February 14, 2013 order denying petitioners summary judgment
and directing respondent court to enter a new order granting summary judgment
(b) issue an alternative writ directing Respondent Court to show cause why it should
not so be directed, and upon return to the alternative writ, issue the peremptory writ
set forth in subparagraph (a) next above; or (c) other appropriate relief.
3. Award Petitioners costs incurred in this proceeding and attorney fees under MRL
Respectfully submitted,
_____________________________________________
Nancy D McCarron, Attorney for Petitioner

9
VERIFICATION OF PETITIONER
I, BONNIE SHIPLEY, declare:
I am the Petitioner in this writ proceeding. I have read the foregoing Petition for
Writ of Mandate, and know the contents thereof; the same is true of my own personal
knowledge, except as to those matters which are stated upon my information or belief,
and as to those matters I believe them to be true. I declare under penalty of perjury,
under the laws of the State of California that the foregoing is true and correct and this
Verification was executed on February 27, 2013 at Highland, California.
_____________________________________________
BONNIE J. SHIPLEY, Petitioner
VERIFICATION OF PETITIONERs ATTORNEY

I, NANCY D MCCARRON, declare:
I am the Petitioners attorney in this proceeding. I have read the foregoing Petition
for Writ of Mandate, and know the contents; the same is true of my own personal
knowledge, except as to those matters which are stated upon my information or belief,
and as to those matters I believe them to be true. I declare under penalty of perjury,
under the laws of the State of California that the foregoing is true and correct and this
Verification was executed on February 27, 2013 at Highland, California.
___________________________________________________
NANCY D MCCARRON, Attorney for Petitioner

10
MEMORANDUM OF POINTS AND AUTHORITIES

STANDARD OF REVIEW
The Standard of Review for Orders Denying Summary Adjudication is De Novo
Denial of summary judgment may be reviewed by mandamus. CCP 437c (l)
Where a court's erroneous denial will result in trial on a non actionable claim, a writ
of mandate will issue. Travelers 1 The standard of review is de novo. 2 Id
First, the motion is reviewed to determine whether defendant met its initial
burden to establish that one or more causes of action in the complaint has no merit,
by showing that one or more elements of the cause of action cannot be established,
or that there is a complete defense thereto. CCP 437c, subdivisions (f)(1), (o)(2)
Second, if defendant meets her burden we examine if plaintiff has shown, by setting
forth specific facts, that a triable issue of fact exists as to that claim. 437c (o)(2).3
In reviewing the appellate court need not defer to the trial court's decision.
'We are not bound by the trial court's stated reasons, if any, supporting its ruling;
we review the ruling, not its rationale.' Marmaro
When the sole issue raised by a writ is whether the trial courts ruling on an issue
of law was erroneous, the appellate court need not address whether any triable issues
of material fact exist. Henricksen 5 The sole issue here is interpreting Civil 798.75
If subsection [c] applies only to purchasers/transferees petitioners eviction is illegal.
Travelers Casualty & Surety v. Superior Court (1998) 63 Cal.App.4th 1440,1450;

Lompoc Unified School District v. Superior Court (1993) 20 Cal. App.4th 1688, 1692
2
Travelers, Id. @ 1450
3
West Shield Investigations & Sec Cons v. Superior Court (2000) 82 CA 4th 935, 946;
Addy v. Bliss & Glennon (1996) 44 CA 4th 205,214
4
Camp v. Jeffer, Mangels, Butler & Marmaro (1995) 35 CA.4th 620, 629
quoting Stratton v. First National Life Insurance Company
5
Henriksen v. City of Rialto (1993) 20 CA. 4th 1612, 1617 n 2. [4th. Dist. Div 2]
1
11
I. ARGUMENT ONE
CIVIL CODE 798.75[c] APPLIES ONLY TO PURCHASERS & TRANSEREES
It is well established that statutes must be given a reasonable construction that
conforms to the apparent purpose and intention of the lawmakers, and the various parts
of the statutory enactment must be harmonized by considering the particular clause in
the context of the whole statute. " Lehto 6
Mobilehome Residency Law or MRL
[Civil 798 - 798.88] is divided into 8 Articles separated by subject area:

Mobilehome Residency Law
Article 1
Article 2
Article 3
Article 3.5
Article 4
Article 4.5
Article 5
Article 5.5
Article 6
Article 7
Article 8
General
Rental Agreement
Rules and Regulations
Fees and Charges
Utilities
Rent Control
Homeowner Communications and Meetings
Homeowners Meetings with Management
Termination of Tenancy
Transfer of Mobilehome or Mobilehome Park
Actions, Proceedings, and Penalties
Article 1 General contains provisions such as MRL application and definitions; i.e.
Resident is a homeowner or other person who lawfully occupies a mobile home.
Civil Code 798.11 Plaintiff could have sought declaratory relief to ask a court to
interpret the words lawfully occupies. Instead of seeking declaratory relief plaintiff
prosecuted a sham complaint to summarily evict the roommate of a resident/tenant.
Lehto v. City of Oxnard (1985) 171 CA.3d 285, 293 [review den. Dec. 5, 1985]
12
Article 8 governs Actions, Proceedings, and Penalties. Civil 798.88 (Article 8)

authorizes injunction for rule violations. Article 7 governs Transfers of Mobile homes.
All codes under Article 7 relate to transfers of ownership. Civil 798.75 authorizes a
park owner to summarily evict a purchaser or transferee who takes title and occupies a
home without first executing an occupancy lease to pay rent. The remedy is limited to
purchasers & transferees. It cannot be used against a paying tenant with a valid lease.
Civil Code 798.75. Attachment of rental agreement or statement
(a) An escrow, sale, or transfer agreement involving a mobilehome
located in a park at the time of the sale, where the mobilehome is to
remain in the park, shall contain a copy of either a fully executed rental
agreement or a statement signed by the park's management and the
prospective homeowner that the parties have agreed to the terms and
conditions of a rental agreement.
(b) In the event the purchaser fails to execute the rental agreement,
the purchaser shall not have any rights of tenancy.
(c) In the event that an occupant of a mobilehome has no rights of
tenancy and is not otherwise entitled to occupy the mobilehome
pursuant to this chapter, the occupant is considered an unlawful
occupant if, after a demand is made for the surrender of the mobilehome
park site, for a period of five days, the occupant refuses to surrender the
site to the mobilehome park management. In the event the unlawful
occupant fails to comply with the demand, the unlawful occupant shall
be subject to the proceedings set forth in Chapter 4 (commencing with
Section 1159) of Title 3 of Part 3 of the Code of Civil Procedure.
(d) The occupant of the mobilehome shall not be considered an
unlawful occupant and shall not be subject to the provisions of
subdivision (c) if all of the following conditions are present:
(1) The occupant is the registered owner of the mobilehome.
(2) The management has determined that the occupant has the
financial ability to pay the rent and charges of the park; will comply
with the rules and regulations of the park, based on the occupant's prior
tenancies; and will comply with this article.
(3) The management failed or refused to offer the occupant a
rental agreement.
13
Under Lehto the particular clause (subsection c here) must be considered in the
context of the entire statute. The court erred in reciting only subsection c in its ruling.
Petitioner cited Supreme Court authorities directing courts to consider placement of a
statute in an Article to mean its scope is limited to the subject area within the Article. 7
In support of her motion for summary judgment petitioner submitted an affidavit
of Maury Priest, a lobbyist for homeowners, who attended every legislative session
when Civil 798.75 was amended in 1987 to add subsection [c] and [d] as a remedy.
Priest testified at length about what happened 25 years ago during those sessions. 8
Priest testified that legislators authorized summary evictions only against purchasers
and transferees who acquired title to a mobile home in a park and occupied it without
first executing a park lease to pay rent. 9 Priest testified that legislators never intended
to authorize summary evictions against a guest or co-resident who shared a home with
a park tenant who had a valid park lease and was paying monthly space rent. 10
The court erred by disregarding Priests testimony where no rebuttal was offered.
A court generally cannot resolve questions about a declarant's credibility in a summary
judgment proceeding. Henricksen 11 Adopting plaintiffs counsels conjecture and
speculation on what he thought legislators intended in 1987---instead of Maury Priests
testimony based on personal knowledge---showed prejudicial bias. An assertion based
solely on conjecture or speculation is insufficient to avoid summary judgment. 12
7
App. Vol-III, page 12.289

App. Vol-III, page 3.17-a
9
App. Vol-III, page 3.17-b
10
App. Vol-III, page 3.17-b
11
AARTS Productions, Inc. v. Crocker Natl Bank (1986) 179 Cal.App.3d 1061,1065
Henriksen v. City of Rialto (1993) 20 CA. 4th 1612, 1625 . [4th. Dist. Div 2]
12
Burton v. Sec Pac Natl Bank (1988) 197 CA.3d 972, 978;
Clutterham v. Coachmen Industries, Inc. (1985) 169 CA.3d 1223, 1227;
Sanchez v. Swinerton & Walberg Co. (1996) 47 CA 4th 1461, 1465-1466
14
8
II. ARGUMENT TWO

COURT ERRED IN RULING THAT A TRIABLE ISSUE OF FACT EXISTS
The court erred in not accepting the evidence petitioner submitted; i.e. declarations
from petitioner and the homeowner. Plaintiff failed to file any affidavits opposing
summary judgment which could create any disputed factual issue to invoke a trial.
The validity of summary judgment is to be determined solely by the sufficiency of
affidavits before the court when the motion was heard, and the appellate court will
consider only facts before trial court at time it ruled on motion. Rubenstein
13
If plaintiffs opposing papers fail to address the dispositive issue framed by pleadings
plaintiff may not create an issue outside the pleadings or argue nonissues. Barclays 14
Plaintiffs counsel admitted facts were undisputed. Transcript
15
Plaintiff failed to
file any statement of disputed facts in opposition to petitioners undisputed facts.

Where facts are undisputed, issue is one of law and appellate court is free to draw its
own conclusions of law from undisputed facts. Ziman16 The court reviews a ruling,
not its rationale. 17 In ruling on a motion, the trial court determines what has been
called a pure question of law, but what is in fact a mixed question of law and fact that
is predominantly legal: does plaintiffs complaint state facts sufficient to constitute a
cause of action against the defendant? Smiley 18 When the only issue to be decided
is a pure question of law summary judgment should be granted. Morales 19
13
14
15
16
17
18
19
Rubenstein v. Rubenstein (2000) 81 Cal. App. 4th 1131, 1151 n.10

Sutherland v. Barclays American/Mortgage Corp. (1997) 53 CA. 4th 299, 317
Transcript, 1-31-2013, page 2, line 5
Ziman v. Firemans Fund Ins. Co. (1999) 73 CA. 4th 1382, 1387
Suidan v. County of San Diego (1999) 72 CA. 4th 916, 921
Smiley v. Citibank (1995) 11 Cal. 4th 138, 145
Morales v. Fansler (1989) 209 CA.3d 1581, 1584
15
The court erred in finding a triable issue of fact; i.e. whether or not Ms. McCarron
regularly occupied the mobile home as required under the rules. Transcript
20
This was clear error for 2 reasons. First, a court already decided this issue. Otanez 21
premises full-time in order to be a resident.
Under stare decisis the court was required to apply Otanez to this case. The court
exceeded its jurisdiction by refusing to follow Otanez as explained in Cuccia:
22
Pursuant to Auto Equity Sales, Inc. v. Superior Court (1962) 57 Cal.2d

450, 455... the decisions of every division of the District Court of Appeal
are binding on all superior courts of this state. Courts exercising inferior
jurisdiction must accept the law declared by courts of superior
jurisdiction. It is not their function to attempt to overrule decisions of
the higher court.'' (Ibid.) Here the trial court exceeded its jurisdiction
by refusing to follow Marchman. What should a trial court do when
confronted with a published Court of Appeal opinion which compels it to
rule one way when it believes that the opinion is erroneous? First, it has
no choice but to follow the declared law in the appellate opinion..
This court held Otanez was not controlling because it involved a park owner
who shut off utilities in a mobile home and the governing code [Civil 789.3] is
not part of the MRL. Transcript 23 Civil 789.3 applies to all tenants, including
those who rent mobile homes. The park owner argued because the home owner
did not regularly occupy the home (she lived there periodically) she had no
resident rights. Otanez held a tenant need not occupy full-time to be a resident.
20
21
22
23
Transcript 2/14/2013, page 12, line 17

Otanez v. Blue Skies Mobile Home Park (1991) 1 CA.4th.1521
Cuccia v. Superior Court (2007) 153 Cal. App. 4th 347, 353-354
Transcript 2-14-2013 page 11, line 1
16
By leaping to the conclusion that a jury must decide whether or not Ms. McCarron
regularly occupied the mobile home as required under the rules impliedly found that
the rules are enforceable, regardless of their reasonableness or their constitutionality.
This disregards Civil 798.77 which renders any provision in a lease or park rule void
and unenforceable if it deprives an owner of a statutory right guaranteed under MRL.
The court assumed the rules as created in 2010 were constitutional and reasonable.
A mobile home owner has a statutory right to have a co-resident under Civil 798.34(b):
(a) A homeowner shall not be charged a fee for a guest who does not stay
with him or her for more than a total of 20 consecutive days or a total of
30 days in a calendar year. A person who is a guest, as described in this
subdivision, shall not be required to register with the management.
(b) A homeowner who is living alone and who wishes to share his or her
mobilehome with one person may do so, and a fee shall not be imposed by
management for that person. The person shall be considered a guest of the
homeowner and any agreement between the homeowner and the person
shall not change the terms and conditions of the rental agreement between
management and the homeowner. The guest shall comply with the
provisions of the rules and regulations of the mobilehome park.
Even if summary eviction were authorized under Civil 798.75(c) [it clearly is not]
the ruling bypassed 2 prerequisite issues; i.e. is the rule constitutional and reasonable?
Both issues must be decided before deciding if a rule was violated justifying eviction.
The park may not impose a new rule which waives an owners rights under the MRL.
Civil 789.19. Any such waiver shall be deemed contrary to public policy and void.
The court failed to discuss Civil 789.19 and 798.34(b) in its ruling on 2/14/2013.
There is no language expressed in 798.34(b) which requires an owner to regularly
occupy the home in order to exercise her right to share her home. The regularly
occupy language is contained in a new rule the park has applied ex post facto.
17
A park is barred from applying a new rule retroactively to an owner who did not
agree to such rule in her lease (ex post facto application is unconstitutional) Rancho
24
Respondent contends that the restriction did not operate retroactively

because it was incorporated by law into the original lease. He argues
that since Civil Code, section 798.25 permits the making of new rules
without the homeowner's consent, the homeowner in commencing
the tenancy agrees to subsequently enacted rules. However, the
argument begs the question. To be valid and enforceable, the rule
must be reasonable. A homeowner could not be expected to foresee
a rule change effecting such a radical change in such an important
condition of his tenancy. Insofar as it attempts to operate
retroactively, such a rule is not reasonable. Rancho @1148
By finding the jury must decide if McCarron regularly occupies the home as
required by the rules assumes the rules are constitutional and enforceable.
Whether a newly imposed rule which was not part of the owners original lease is
constitutional and/or reasonable are two issues of fact a jury must decide before they
are faced with deciding whether the rule was violated warranting eviction of a guest.
The court exceeded jurisdiction when it invented an issue of fact where plaintiffs
counsel admitted in court that the facts were undisputed, where plaintiff failed to file a
statement of disputed facts in opposition to defendants undisputed facts, and where
plaintiff failed to submit any evidentiary affidavits opposing summary judgment.
Error is prejudicial if it is reasonably probable a miscarriage of justice exists or when it
is reasonably probable a result more favorable would have been reached. Weaver
24 Rancho Santa Paula Mobile Homes v. Evans (1994) 26 CA4th.1129

25 Weaver v. Chavez (2005) 133 CA. 4th 1350, 1356
18
25
CONCLUSION
In 1978 our legislators enacted Civil Code 798.55 -798.57 to provide unique
protection to mobile home owners from arbitrary evictions without just cause:
(a) The Legislature finds and declares that, because of the high cost of
moving mobilehomes, the potential for damage resulting therefrom, the
requirements relating to the installation of mobilehomes, and the cost of
landscaping or lot preparation, it is necessary that the owners of
mobilehomes occupied within mobilehome parks be provided with the
unique protection from actual or constructive eviction afforded by the
provisions of this chapter.
(b) (1) The management may not terminate or refuse to renew a
tenancy, except for a reason specified in this article and upon the giving
of written notice to the homeowner, in the manner prescribed by
Section 1162 of the Code of Civil Procedure, to sell or remove, at the
homeowner's election, the mobilehome from the park within a period of
not less than 60 days, which period shall be specified in the notice.
In 1987 our legislators added subsections (c) and (d) to Civil Code 798.75
to provide unique protection to park owners from purchasers or transferees who
acquire title to a mobile home and occupy it without first executing a park lease.
This summary eviction remedy was an exception to 60-day notice just cause rule.
This exception gave park owners a speedy remedy to evict a non-paying occupant.
The courts expansion of this speedy remedy [798.75(c)] to apply to any occupant
completely abrogates paying tenants protections granted in Civil 798.55-798.57
The absurd result is that park owners no longer need just cause to evict a resident
and need not give 60-days notice. They can just label a resident an unlawful occupant
for any purported rule violation and summarily evict the resident, who will be forced to
litigate to a trial whereby a jury will decide if the rule was violated to justify eviction.
Because most residents can not afford to litigate against the parks GOLIATH law firm
they will be forced to vacate their home and lose in most cases their entire life savings.
19
This absurd result abrogates legislation enacted to provide statewide protections to

a class of underprivileged, low-income citizens from the wrath of greedy park owners.
It violates the separation of powers clause of the United States Constitution (Art. III).
Our Legislative branches make the laws and our Judicial branches enforce the laws.
This court decided to unilaterally change the law- grossly exceeding delegated powers.
It is contrary to an expressed legislative goal to encourage owners to use injunctive
relief under Civil 798.88 rather than evict a resident for an alleged park rule violation:
(Legislative intent: This three-year sunset will arguably provide the
Legislature with the opportunity to re-evaluate this bill to ensure that
the stated goal of encouraging a park owner to pursue a lesser remedy
against a resident of a mobilehome park instead of eviction is actually
reached without negative unintended consequences.) (Amended by
Stats. 2012, Chap. 99 (AB 2272, Wagner), eff. 1/1/2013)
Petitioner respectfully requests this court to issue an immediate stay on setting trial
and a peremptory writ of mandate directing Respondent Court to set aside and vacate
its February 14, 2013 order denying petitioners summary judgment and directing
respondent court to enter a new order granting summary judgment, or alternatively
issue an order to show cause why the court should not vacate its judgment and enter a
new order granting summary judgment, and to award costs and attorney fees as prayed.
CERTIFICATE OF WORDCOUNT
The petition contains 5,894 words (excluding tables) in roman typeface 14 font.
I relied on a word count generated by MS Word 2007 showing in the status bar.
2-27-2013
20
PROOF OF SERVICE
STATE OF CALIFORNIA,
Stubblefield Properties v. Bonnie Shipley UDDS1204130
The undersigned is counsel for petitioner/defendant at: 950 Roble Lane, Santa Barbara, CA 93103
805-450-0450 fax 805-965-3492
On the date recited below the undersigned served the below document in the manner indicated:
WRIT PETITION to Appellate Division re: Denial of Defendants Summary Judgment Motion [S-32]
[x] (By Personal Delivery) to the parties below as follows: on 2-27-2013
To: RESPONDENT COURT: [S-32] Hon.Donald Alvarez in S-32 at hearing on MTC responses
To: Real Party in Interest, c/o Attorney Robert Williamson, in S-32 at hearing on MTC responses
[ ] (By Fax) Fax machine used complied with Rule 2003(3) and no error was reported by the machine.
Pursuant to Rule CRC, 2008 [c](4). I caused the machine to maintain a record of same.
[x] (By Electronic) to address below (by agreement) & with copy to nancyduffysb@yahoo.com
to: rwilliamson@hkclaw.com by mutual agreement of parties
2-27-2013
[ ] (By Mail) 1013a, 2015.5 CCP. I deposited the documents in a pre-paid stamped envelope to:
Robert Williamson, Hart, King & Coldren
200 Sandpointe, 4th. Floor
Santa Ana, CA 92707 714-432-8700 fax 714-546-7457

I am familiar with mail collection in San Bernardino. I deposited the envelope in the mail at San
Bernardino, CA. I am aware on a motion of the party served, service is presumed invalid if postal
cancellation date is more than one day after deposit date on affidavit.
[x ] (STATE) I declare under penalty of perjury and laws of California that the above is true.
Executed in San Bernardino CA on February 27, 2013
21

APPELLATE DIVISION
BONNIE SHIPLEY,
Petitioner,
SUPERIOR COURT OF THE STATE OF

CALIFORNIA, COUNTY OF SAN
BERNARDINO,
Respondent,
Case No: CIVDSI 302013

(Trial Court: UDDS 12641 30)
-O- -P- -I -N- I O N
STUBBLEFIELD PROPERTIES, A
CALIFORNIA GENERAL PARTNERSHIP
DBA MOUNTAIN SHADOWS
MOBILEHOME COMMUNITY,
Petition for Writ of Mandate, directed to the San Bernardino County

Superior Court, San Bernardino District, Donald R. Alvarez, Judge.
Petition granted.
Nancy D. McCarron, Esq., for petitioner and defendant.
No appearance for respondent.
Hart, King & Coldren, A Professional Law Corporation, Robert S.
Coldren, Esq., Robert G. Williamson, Jr., Esq., for real party in interest.
THE COURT:
FACTUAL AND PROCEDURAL BACKGROllND

On August 11, 2012, real party in interest Stubblefield Properties, a
California General Partnership, dba Mountain Shadows Mobilehome Community
(hereinafter "Stubblefield") served Petitioner with a 5-Day Notice to Surrender
Possession. The notice is based upon Civil Code section 798.75, subdivision (c),
"for failure to move into the mobilehome wiZhout being approved as a sublessee
-
or any other capacity." The notice also states that "this is a violation of the Rules
and Regulations of the mobilehome park."
On August 27, 2012, Stubblefield filed a cornplaint for forcible detainer
(Code Civ. Proc., 1160) naming Petitioner as the sole defendant.
The
complaint alleges that St~~bblefield

is the owner of the premises commonly known
as 4040 E. Piedmont Drive, Space 333, Highland, CA 92346. The complaint also
alleges that prior to service of the Notice to Surrender, Petitioner had, without
Stubblefield's consent or approval, without signing a rental agreement, and
without becoming the registered owner of the mobilehome situated at the
premises, entered into possession of the premises.
The complaint further
alleges that Petitioner has continued to hold and keep possession of the
premises by force and in violation of Civil Code section 798.75 by failing to
surrender the premises to Stubblefield. The complaint prays for possession of
the premises, for damages at $30.01 per day (reasonable rental value of space
333), and for attorney's fees.
On January 23, 2013, Petitioner filed a motion for sunimary judgment. On

February 14, 2013, the trial court denied Petitioner's motion for summary
judgment. The court also denied Stubblefield's motion for summary judgment,
which was heard on the same day.
On February 27, 2013, Petitioner filed her petition for writ of mandate
requesting that the Appellate Division issue an order directing the trial court to set
aside its order denying Petitioner's motion for summary judgment and to enter a
new order granting the motion.
DISCUSSION
Petitioner contends that the trial court erred in interpreting Civil Code
section 798.75, subdivision (c) as being applicable to any occupant a park owner
unilaterally considers an "unlawful occupant," regardless of whether the occupant
is an owner of the mobilehome or a subtenant of the mobilehome owner.
Petitioner contends that the summary eviction remedy provided under Civil Code
section 798.75, subdivision (c) is liniited only to purchasers and transferees who
occupy a mobilehome without first executing a lease with the mobilehome park.
We agree.
Petitioner's motion for summary judgment establishes that on July 27,

2012, Petitioner executed a written lease with homeowner Nancy Duffy
McCarron (hereinafter "McCarron") to share McCarron's mobilehome at space
333, 4040 E. Piedmont Drive, Highland, CA 92346. In support of the motion,
Petitioner presents the declaration of McCarron, who declares that on January 5,
2005, she purchased the mobilehome at space 333 in Stubblefield's mobilehome
park and executed the park's lease. McCarron states that on July 27, 2012,
Petitioner signed a six-month lease to share her home as a co-resident after her
former co-resident moved next door.
McCarron states that Stubblefield has
continl-led to accept monthly rent from her. She also states that all of the utilities
are in her name and she pays for them. Thus, Petitioner's evidence establishes
that she is, in effect, a sublessee or subtenant of McCarron and that McCarron is
the owner of the nob bile home located at space 333 of Stubblefield's mobilehome
park pursuant to a lease agreement between McCarron and Stubblefield.
In its opposition to the motion for summary judgment, Stubblefield argued
that it was not required to establish the elements of a forcible detainer action
pursuant to Code of Civil Procedure section 1160, because in mobilehome park
unlawful occupant situations, section 798.75, subdivisions (c) and (d), control
over the general provisions of the Code of Civil Procedure. Stubblefield argued
that it was apparent from the legislative history that "the Legislature's purpose
and intent in enacting subdivisions (c) and (d) of section 798.75 was to authorize
summary eviction procedures against an unlawful occupant as defined therein,
not as defined in general sections 1160 and 1172 of the Code of Civil Procedure
that would deem an occupant 'guilty of forcible detainer.'" Stubblefield argued
that "purchaser" in subdivision (b) and "occupant" in subdivision (c) are by
ordinary definition distinctly different terms that describe different categories of
persons, although both refer to the same subject of "no rights or tenancy" by
failure to sign a rental agreement. Stubblefield further argued that subdivision (c)
applies to any "unlawful occupant," whether or not he or she is a purchaser or

other transferee.
At the hearing on Petitioner's motion for summary judgment, the co~rrt
found, among other things, that Civil Code section 798.75 does not apply only to
circumstances where ownership is transferred.
Rather, the co~.~rtfound that
Section 798.75, subdivision (c) "is not limited in its application, only in the
escrow, sale or transfer of a mobile home. It applies when an occupant of a
mobile home has no right of tenancy and is not otherwise entitled to occupy the
mobile home pursuant to this chapter. That's Civil Code 798.75(c). This chapter
refers to chapter 2.5 which is the Mobilehome Residence Law and includes such
provision as Civil Code 798.34 as applying to guests at mobile homes." In our
view, the trial court denied Petitioner's motion for summary judgment based on
an erroneous interpretation of Civil Code section 798.75.
The facts are not in dispute. Stubblefield's complaint is based upon a 5-
Day Notice to Surrender pursuant to Civil Code section 798.75, subdivision (c).
Civil Code section 798.75 states as follows:
(a) An escrow, sale, or transfer agreement involving a
mobilehome located in a park at the time of the sale, where the
mobilehome is to remain in tlie park, shall contain a copy of either a
fully executed rental agreement or a statement signed by the park's
management and the prospective homeowner that the parties have
agreed to the terms and conditions of a rental agreement.
(b) In the event the purchaser fails to execute the rental
agreement, the purchaser shall not have any rights of tenancy.
(c) In the event that an occupant of a mobilehome has no rights
of tenancy and is not otherwise entitled to occupy the mobilehome
pursuant to this chapter, the occupant is considered an unlawful
occupant if, after a demand is made for the surrender of the
mobilehome park site, for a period of five days, the occupant
refuses to surrender the site to the mobilehome park management.
In the event the unlawful occupant fails to comply with the demand,
the unlawful occupant shall be subject to the proceedings set forth
in Chapter 4 (commencing with Section 1159) of Title 3 of Part 3 of
the Code of Civil Procedure.
(d) The occupant of the mobilehome shall not be considered an
unlawful occupant and shall not be subject to the provisions of
subdivision (c) if all of the following conditions are present:
(1) The occupant is the registered owner of the mobile home.
(2) The management has determined that the occupant has the
financial ability to pay the rent and charges of the park; will comply
with the rules and regulations of the park, based on the occupant's
prior tenancies; and will comply with this article.
(3) The management failed or refused to offer the occupant a

rental agreement.
Thus, where the mobilehome is to remain in the park, subdivision (a)

provides that, as a condition to the purchaser's or other transferee's rights of
tenancy in the park, at the time of sale or transfer, the escrow, sale or transfer
agreement must contain a copy of either (a) a fully executed rental agreement or
(b) a statement signed by park management and the prospective homeowner
that the parties have agreed to the terms and conditions of a rental agreement.
Subdivision (b) refers to a "purchaser" and requires a written agreement to
be in place between the park and the purchaser. Subdivision (b) provides that if
the purchaser fails to execute a rental agreement, he or she has no rights of

"tenancy."' Where a purchaser fails to execute a lease agreement as provided in
subdivisions (a) and (b), he or she becomes an "unlawful occupant." It follows
that subdivision (c)'s reference to "unlawful occupant" is to a purchaser (or other
transferee) who has not executed a lease agreement and who has no rights of
1
"Tenancy" is defined as "the right of a homeowner to the use of a site within a mobilehome park
on which to locate, maintain, and occupy a mobilehome, site improvements, and accessory
structures for human habitation, including the use of the services and facilities of the park." (Civ.
798.12.)
Code, $j
tenancy.
Thus, this "unlawful occupant" (i.e., purchaser without a lease
agreement) is an occupant that "is not otherwise entitled to occupy the

mobilehome pursuant to this chapter." As a sublessee of a mobilehome owner,
Petitioner does not fall within the definition of an "unlawful occupant."
We find significance in the fact that section 798.75 is contained within
Article 7 (of the Mobilehome Residency Law), which is entitled "Transfer of
Mobilehome or Mobilehome Park."
The statute's language signifies that it
applies only to a purchaser or transferee of a mobilehome in the park. The

language, and thus the overall tone of the statute, indicates that the Legislature
intended that it apply only in the context of a purchase or transfer of a
mobilehome.
(Patarak v. Williams (2001) 91 Cal.App.4th 826, 829 [goal in
interpreting provision of Mobilehome Residency Law is to ascertain and

effectuate the intent of the Legislature]; see Torrey Hills Community Coalition v.
City of San Diego (2010) 186 Cal.App.4th 429, 440 [if there is no ambiguity in the
language of the statute, then the Legislature is presumed to have meant that
what it said, and the plain meaning of the language governs.].) Although in
several places the statute contains the term "unlawful occupant," it is used in the
context of a purchaser without a lease agreement who "is not otherwise entitled
to occupy the mobilehome pursuant to this chapter."
Support for this interpretation is found in subdivision (c) where it states
occupant if, after a demand is made
that "the occupant is considered an ~~nlawful
for the surrender of the mobilehome park site for a period of five days, the
occupant refuses to surrender the site to the mobilehome park management."
(Civ. Code,
5 798.75, subd. (c), emphasis added.)
This language refers to the
occupant of a park "site," not to the occupant of a mobilehome unit. An individual

who is simply an occupant, and not an owner, of a mobilehome has no legal
authority to remove a mobilehome unit from a mobilehome park "site."
We also find support for this interpretation in the well-known practice guide
The Rutter Group Landlord-Tenant, which provides this discussion of Section
798.75:
"A purchaser who refuses to execute a rental agreement with

-
management 'shall not have any rights of tenancy.'
[CC 798.75(b)]
Management may serve a purchaser resident with a demand fo surrender the

mobilehome park site; failure to surrender within five days after the demand
makes the purchaser an 'unlawful occupant.' [CC 798.75(c)]
[fl Once placed
in the status of an 'unlawful occupant,' the purchaser may be evicted under the
statutory summary repossession procedures (CCP 51159 et seq.;
[I)."
(Friedman, Garcia & Hagarty, Cal. Prac. Guide: Landlord-Tenant (The Rutter
Group 2012),
11:257-11:258. Italics in original.)
In addition to the above, Stubblefield cannot directly evict Petitioner

because there is no privity between Stubblefield and Petitioner-i.e.,
Stubblefield
is not the legal owner of the mobilehome unit in which Petitioner is an occupant.
Although Civil Code section 798.75 does not authorize Stubblefield to
evict Petitioner, Stubblefield is not without a remedy under the Mobilehome
Residency Law. Stubblefield alleges that Petitioner has violated park rules by,
among other things, failing to obtain park consent or approval before assuming
occupancy.2
A sublessee must comply with all park rules and regulations.
Failure to do so may result in termination of the homeowner's tenancy in

accordance with Civil Code section 798.56. However, the honleowner's tenancy
may not be terminated if the homeowner completes an unlawful detainer action
or executes a judgment for possession within 60 days of receiving notice of
termination of tenancy.
(Civ. Code,
798.23.5, subd. (b)(3).)
Thus,
Stubblefield's remedy under the Mobilehome Residency Law is to proceed

-
against the homeowner in accordance with Civil Code section 798.56,

subdivision (d) for "failure of the homeowner or resident to cornply with a
reasonable rule or regulation of the park that is part of the rental agreement or
any amendment thereto."
The trial court misinterpreted Civil Code section 798.75.
This statute
applies only to a purchaser or transferee of a mobilehome unit that occupies the

park's space without first executing a written lease agreement with the park.
Petitioner is not a purchaser or transferee of the subject mobilehome. Therefore,
the 5-Day Notice to Surrender is invalid because it is based upon an inapplicable
statute. As such, the eviction of Petitioner by Stubblefield under Civil Code
section 798.75 is not authorized.
DISPOSITION
The petition is granted. Let a writ of mandamus issue directing the
Superior Court to vacate its order denying Petitioner's motion for summary
* We express no opinion regarding the reasonableness of Stubblefield's rules or regulations, as

such a determination is not relevant or necessary to our discussion.

APPELLATE DIVISION
ONNIE SHIPLEY,
Petitioner,
Case No. CIVDS1302013

(Trial Court: UDDS1204130)
v.

ERNARDINO,
Respondent
STUBBLEFIELD PROPERTIES, A
ALIFORNIA GENERAL PARTNERSHIP,
BA MOUNTAIN SHADOWS MOBILE
OME COMMUNITY,
L -_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _\
WRIT OF MANDATE
Directed to the San Bernardino County
Superior Court, San Bernardino District,
Donald R. Alvarez, Judge
Petition Granted.
Petition for Writ of Mandate, directed to the San Bernardino County Superior Court
San Bernardino District, Donald R. Alvarez, Judge.
Nancy D. McCarron, Esq. for petitioner and defendant.
No appearance for Respondent.
Hart, King & Coldren, A Professional Law COtporation, Robert S. Coldren Esq.
Robert G. Williamson, 1rs., Esq. for real party in interest.
THE COURT:
The petition is granted. The Superior Court is directed to vacate its order
4.enying Petitioner's motion for summary judgment and enter a new order granting
Petitioner's motion,"and to enter judgment in favor of Petitioner. Petitioner shall
recover her costs. The previously ordered stay is LIFTED.
GILBERT . OCHOA Presiding

Judge of the Appellate Division
.Judge of the Aprellate Division
The Hon. James 1. Hosking dissents
JUL
11 20\3
THE DOCUMENT TO WHICH THIS CERTIFICATION IS
ATTACHED IS AFUU, TRUE AND CORRECl' COPt Of

THE ORIGINAL ON filE AND OF RECORD IN MY OFFICE.
ATIEST
STEPHEN H. NASH
Cieri( of the SUperiOf Court of the Sate of

CaHfomia, in and for the County of
San Bernardino.
--
COURT OF APPEAL STATE OF

FOURTH DISTRICT
DMSION TWO
IPI
, , i i
n on,,
E058852
Petitioner,
v.
THE APPELLATE DMSION OF THE

S U P m O R COURT OF SAN .
BERNARDINO COUNTY,
Respondent;
BONME SHPLEY,
(Super.Ct.Nos.CNDS 1302013
& UDDS1204130)
County of San Bernardino
THE COURT
The petition for writ of mandate/prohibition/certiorari is DENIED. The
previously issued stay is hereby LIFTED.
Presiding Justice
cc:
Se6,attached list
IIIli
Court of AppeaI, Fourth Appellate District, Division Two No. E058852

S212288
IN THE SUPREME COURT OF CALIFORNIA

En Banc
.
STUl3BLEFIELD PROPERTIES, Petitioner,
SUPERIOR COURT OF SAN BERNARDINO COUNTY, Respondent;
BONNIE SHIPLEY, Real Party in Interest.

The petition for review and-applicationfor stay are denied.
SUPREME COURT
FILED
Baxter, J., was recused and did not participate.
Frank A. McGuire Clerk
Deputy
Chief Justice
Superior Court btate of California

Countp of B a n Pernarbino
APPELLATE DIVISION
401 North Arrowhead Avenue
San Bernardino. Ca 92415-0063
FILED
SUPERIOR COURT
COUNTY OF SAN BERMARBIN0
APPEAL 5 ~ I V I S ~ O N
AUG I 3 28f3
BONNIE SHIPLEY
Petitioner,
VS.
CALIFORNIA. COUNTY OFSANBERNARDlNO

Respondent,
Case Y: c+v~3tJ020131ttOD5
JO
Courthouse: San Bernardino
IT IS HEREBY ORDERED AND ADJUDGED THAT THE ORIGINAL PER CLlRlAM OPINION
ENTERED IN THE ABOVE ENTITLED CAUSE ON MAY 6.2013 HAS BECOME FINAL.
DATED:. August 13,2013
.2 2 ;.
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.::.!..,Assistant Presiding Judge

of the Appellate Div.
WITNESS MY HAND AND SEAL OF THlS COURT ON THlS 13TH DAY OF AUGUST, 2013.
Stephen H. Nash, Court Executive Officer
*.
NANCY D. MCCARRON, ESQ.

950 ROBLE LANE
SANTA BARBARA, CA 93103
WART, KING & COLDREN

200 SANDPOINTE, 4TH FLOOR
SANTA ANA, CA 92707
San' Bernardino Courthouse
I certifv that copies of the above Order were mailed to counsel of record as indicated on
AUG 1 6 2013
CAROLYN SOLBERG
C-
EXHIBIT 10
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Report
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Case Number:
Case UDDSI.--.-...-p.--"---.204130 STUBBLEFIELD-V-SHIPLEY

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HEARING RE: CASE MGMT CONFl OSC RE STATUS OF APPEAL

1012112013 8:30 AM DEPT. S32
DONALD ALVAREZ, JUDGE

NOT REPORTED
APPEARANCES:
AlTORNEY ROBERT WILLIAMSON JR PRESENT FOR PIAINTIFFIPETITIONER.
AlTORNEY NANCY DUFFY MCCARRON PRESENT FOR DEFENDANTIRESPONDENT.
PROCEEDINGS:
HEARING ON: CASE MGMT CONF 1 OSC RE STATUS OF APPEAL HELD
PREDISPOSITION HEARING HELD
BASED ON THE RULING ISSUED BY THE APPELLATE DIVISION ON THE WRIT OF MANDAMUS AND THE
CALIFORNIA SUPREME COURT HAVING DENIED PIAINTIFFS PETITION FOR REVIEW AND
APPLICATION
FOR STAY, THE COURT HEREBY RLILES AS FOLLOWS:
COURT FINDS:
THE COURTS RULING ON DEFENDANTS MOTION FOR SUMfJJIARY JUDGMENT HEARD ON FEBRUARY
14,2013 IS
HEREBY REVERSED AND RULES AS FOLLOWS:
BONNIE SHIPLEY'S MOTION FOR SUMMARY JUDGMENT IS C3RANTFD AS TO ITS ENTIRETY.
DEFENDANTIMOVING PARTY TO PREPARE JUDGMENT.
HEARINGS:
HEARING DATE OF 01/07/14 CONFIRMED.
(RE DEFENDANTS MOTION FOR ATTORNEY FEES)
NOTICE GIVEN BY JUDICIAL ASSISTANT
CORRESPONDENCE COVERSHEET GENERATED TO MAIL MINUTE ORDER DATED 10121113 TO
COUNSEL OF RECORD.
ACTION COMPLETE

0
Case No. UDDS1204130
b
R
I
California General Partnership,

ba Mountain Shadows Mobile
ome Community
'laintiff,
v.
filed: 8-27-12
PROPOSED JUDGMENT IN FAVOR OF
lafier entry of Order Granting Motion for Summy

Judgment in compliance with a Writ of Mandate
ONNIE SHIPLEY,
Defendant Issued by the Appellate Division on July 22,201 3
l ~ e ~S-32
t.
Honorable Donald R. Alvarez
JUDGMENT IN FAVOR O F DEFENDANT BONNIE SHIPLEY AND AGAINST PLAINTIN

Pursuant to a Writ of Mandate issued by the Appellate Division of the San Bernardino Superior Cou
on July 22,2013, directing this court to grant summary judgment to defendant Bonnie Shipley and entc
judgment in her favor with costs as the prevailing party; and for the reasons set forth in the Appellate
Division's 10-page Opinion entered on May 6,2013 THIS COURT ORDERS AS FOLLOWS:
1.) Judgment is entered in favor of defendant Bonnie Shipley and against Plaintiff Stubblefield
Properties, a California General Partnership, dba Mountain Shadows Mobile Home Community.
2.) Defendant, as prevailing party, is awarded all of her costs. Plaintiff is to take nothing.
3.) Total costs to be awarded to defendant as prevailing party is not yet filly determined as defendant
pending motion for attorney fees is set for January 7,20 14. Judgment is effective,upon entry.
DATED:
Donald R. Alvarez, Judge of the San Bernardino Superior Court
PROPOSED JUDGMENT I N FAVOR OF DEFENDANT AND AGAINST PLAINTIFF

after entry of Order Granting Motion for Summary Judgment in compliance with a Writ of Mandate Issued by the Appellate Division on July 22,2013
PROOF OF SERVICE
I1
Stubblefield Properties v. Bonnie Shipley
UDDS1204130
950 Roble Lane, Santa Barbara, CA 93 103

805-450-0450 fax 805-965-3492
The undersigned is counsel for defendant at:
PROPOSED JUDGMENT IN FAVOR OF DEFENDANT AND AGAINST PLAINTIFF

after entry of Order Granting Motion for Summary Judgment in compliance with a Writ of
Mandate Issued by the Appellate Division on July 22,2013
8
9
[ ] (By Personal Delivery) to the parties below as follows:
10
[XI(By Fax) Fax machine used complied with Rule 2003(3) and no error was reported by the machine
Pursuant to Rule CRC, 2008 [c](4. I caused the machine to maintain a record of same.
TO:714-546-7457
12
11
13
14
15
[XI(By Electronic) to address below Jbv agreement) & with copy to nancydufflsb@yahoo.com
to: rwilliamson@hkclaw.com
[ ] (By Mail) 1013a, $2015.5 CCP. I deposited documents in a pre-paid stamped envelope to:
Robert Williamson, Esq.

Hart, King & Coldren
4 Hutton Centre Drive, Ste. 900
Santa Ana, CA 92707
19
20
21
22
I am familiar with mail collection in Santa Barbara. I deposited the envelope in the mail at Santa
Barbara, CA. I am aware on a motion of the party served, service is presumed invalid if postal
[X ] (STATE) I declare under penalty of perjury and laws of California that the above is true.
Executed in Santa Barbara CA on October 28,2013
23
28
PROPOSED JUDGMENT I N FAVOR OF DEFENDANT AND AGAINST PLAINTIFF

after entry of Order Granting Motion for Summary Judgment in compliance with a Writ of Mandate Issued by the Appellate Division on July 22,201 3
Actions
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Case Type:
Case
Report
Pending
Hearings
Case Number:
Case LIDDS1204130
_.
STLIBBLEFIELD-V-SHIPLEY
_ __.__.._,.__.
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Action: [Ichoose)
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MOTION RE: ATTORNEY FEES FILED BY DEFENDANT BONNIE SHIPLEY

01/07/2014 8:30 AM DEPT. S32
DONALD ALVAREZ, JLIDGE

COURT REPORTER REGINA VEGA 12612
APPEARANCES:
ATTORNEY ROBERT G WILLIAMSON PRESENT FOR PLAlNTIFFIPETIl-IONER.
ATTORNEY NANCY DUFFY MCCARRON PRESENT FOR DEFENDANTIRESPONDENT.
MOTION
BONNIE SHIPLEY'S MOTION FOR ATTORNEY FEES IS HEARD.
ARGUED BY COUNSEL AND SUBMITTED.
COURT FIIVDS:
THE COURT IS INFORMED THAT THE DEFENDANT FILED A REQUEST FOR RECUSAL (170.6) ON
7/22/13.
NOTE: THE COURT NOTES THAT THE 170.6 WAS PREMATURELY FILED BY DEFENDANT ON 7/22/13,
AS THE COURT WAS STILL AWAITING THE REMllTlTUR
(THAT THE COURT HAD NOT YET RECEIVED)
HOWEVER DEFENDANT HAVING MADE AN ORAL REQUEST FOR R E C ~ S A LIN OPEN COURT, THE
COURT RULES AS
FOLLOWS:
JUDGE DONALD ALVAREZ RECUSES SELF FROM THE CASE. CASE ASSIGNED TO JUDGE MICHAEL A
SACHS FOR ALL PURPOSES.
CASE ASSIGNED TO DEPARTMENT S33, BEFORE THE HONORABLE JUDGE SACHS FOR ALL
PURPOSES.
HEARINGS:
CURRENT HEARING CONTINUED TO 02/10/14 AT 08.30 IN DEPARTMENT S33.
NOTICE GIVEN BY JUDICIAL ASSISTANT
CORRESPONDENCE COVERSHEET GENERATED TO MAIL MINUTE ORDER DATED 117114 TO COUNSEL
CALIFORNIA
SUPERIOR COURT OF THE STATE

COUNTY OF SAN
0
Case No. U D ~ 1204
S 130
PROPERTIES,
California General Partnership,
Mountain Shadows Mobile
ome Community
'laintiff,
PROPOSED JU GMENT IN FAVOR OF
Defendant
after entry of Or er Granting Motion for Summary

Judgment in co
ONNIE SHIPLEY,
11
16 1 (
filed: 8-27-12
with a Writ of Mandate

on July 22,2013
Issued by the
Dept.
SHFY
I
Pursuant to a Writ of Mandate issued by the Appellate ~ i v i s i b nof the San Bernardino Superior Court
I
17 11 on July 22,201 3, directing this court to grant summary judgme+t to defendant Bonnie Shipley and enter I
15
JUDGMENT IN FAVOR OF DEFENDANT BONNIE
AND AGAINST PLAINTIFF
reasons set forth in the Appellate

18 judgment in her favor with costs as the prevailing party; and
Division's 10-page Opinion entered on May 6,20 13 THE
ORDERS AS FOLLOWS:
19
1.) Judgment is entered in favor of defendant Bonnie Shipley kclagainst Plaintiff Stubblefield
20 '
I
Properties, a California General Partnership, dba Mountain
Mobile Home Community.
11
2.) Defendant is awarded all of her costs. Plaintiff is to take
is effective upon entry.
3.). Any award resulting from defendant's motion f o ~
Code 5798.85 [MRL],
CCP $1021.5 and CRC 3.1702(a) filed 5/29/13, set
3, then to 10121113,
then to 1/7/14, then to 2110114 --- amended twice to add fees for defending two subsequent appeals --will be entered by way of a separate judgment under USSC E(uthorityof Ray Hulich Gravel i o , el a1
v. Central Pension Fund of lnt 'I Union of Operating Engine rs: #12-992, entered January 14,2014.
DATED:
Judge of the San Bernardino Superior Court

PROPOSED JUDGMENTIN FAVOR OF DEFENDANT ~ N AGAINST
D
PLAINTIFF
after ent~yof Order Granting Motion for Summary Judgment in compliance with a Writ of handate Issued by the Appellate Division on July 22,2013

Case No. UDDS 1204130
a California General Partnership,
ba Mountain Shadows ~ o b i l e ome Community
'laintiff,
v.
filed: 8-27-12
DEFENDANT AND AGAINST PLAINTIFF

after entry of Order Granting Motion for Summary
ONNIE SHIPLEY,
Defendant Issued by the Appellate Division on July 22,2013
Dept.
JUDGMENT IN FAVOR OF DEFENDANT BONNIE SHIPLEY AND AGAINST PLAINTIFF

Pursuant to a Writ of Mandate issued by the Appellate Division of the San Bernardino Superior Coul
on July 22,201 3, directing this court to grant summary judgment to defendant B o ~ i Shipley
e
and ente
Division's 10-page Opinion entered on May 6,2013 THE COURT ORDERS AS FOLLOWS:
2.) Defendant is awarded all of her costs. Plaintiff is to take nothing. Judgment is effective upon entry


COUNTY OF SAN BERZVARDINO
a California General Partnership,
dba Mountain Shadows Mobile
Home Community
v.
filed: 8-27-12
DEFENDANT AND AGAINST PLAINTIFF

afier entry of Order Granting Motion for Summary
ONNIE SHIPLEY,
Defendant Issued by the Appellate Division on July 22,2013
JUDGMENT IN FAVOR OF DEFENDANT BONNIE SHIPLEY AND AGAINST PLAINTIFF

Pursuant to a Writ of Mandate issued by the Appellate Division of the San Bemardino Superior Cour
on July 22,2013, directing this court to grant summary judgment to defendant Bonnie Shipley and entei
Division's 10-page Opinion entered on May 6,2013 THE COURT ORDERS AS FOLLOWS:
2.) Defendant is awarded all of her costs. Plaintiff is to take nothing. Judgment is effective upon entry
3.) Attorney Fees are to be determined by separate motion.
DATED:
Judge of the San Bernardino Superior Court
II

PROOF OF SERVICE
I1
Stubblefield Properties v. Bonnie Shipley

4
950 Roble Lane, Santa Barbara, CA 93 103

805-450-0450 fax 805-965-3492
The undersigned is counsel for defendant at:
II
UDDS1204130
PROPOSED JUDGMENTS IN FAVOR OF DEFENDANT AND AGAINST PLAINTIFF

after entry of Order Granting Motion for Summary Judgment in compliance with a Writ of
Mandate Issued by the Appellate Division on July 22,2013
( one with USSC case, one without extra language, one with blank lines for judge) 3 total
8
9
11 x ] (By Personal Delivery) to the parties below as follows: 2110114 at hearing on motion
[
11
[ ] (By Fax) Fax machine used complied with Rule 2003(3) and no error was reported by the machine.
Pursuant to Rule CRC, 2008 [c](4. I caused the machine to maintain a record of same.
To: 714-546-7457
12
13
14
16
[ ] (By Electronic) to address below (by ameement) & with copy to nancyduffysb@yahoo.com
17
18
to: rwilliamson@hkclaw.com
[ ] (By Mail) $1013a, 52015.5 CCP. I deposited documents in a pre-paid stamped envelope to:
Robert Williamson, Esq.

Hart, King & Coldren
4 Hutton Centre Drive, Ste. 900
Santa Ana, CA 92707
19
I am familiar with mail collection in Santa Barbara. I deposited the envelope in the mail at Santa
Barbara, CA. I am aware on a motion of the party served, service is presumed invalid if postal
20
21
22
[X ] (STATE) I declare under penalty of perjury and laws of California that the above is true.
Executed in San Bernardino CA on February 10,2014
23
II

after entry of Order Granting Motion for Summary Judgment in compliance with a Writ ofMandate Issued by the Appellate Division on July 22,2013
UDDS1204130Minute Orders San Bernardino Main
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STUBBLEFIELD-V-SHIPLEY
_._.__~~~.._.-...-...-I.---..-----.-Action: r(~hoose)
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MOTION RE: ATTORNEY FEES FILED BY DEFENDANT BONNIE SHIPLEY

0211012014 8:30 AM DEPT. S33
MICHAEL A SACHS, JUDGE

CLERK: WIMALA BLANCHARD
COURT REPORTER KATHY SELLERS 4420
COURT AlTENDANT MARY KILGORE
APPEARANCES:
ATTORNEY ROBERT WILLIAMSON JR PRESENT FOR PIAINTIFF/FETITIONER.
ATTORNEY NANCY DUFFY MCCARRON PRESENT FOR DEFENDANTIRESPONDENT.
PROCEEDINGS:
MOTION
ACTION CAME ON FOR MOTION RE: AlTORNEY FEES FILED BY BONNIE SHIPLEY.
COURT HAS REVIEWED THE MOTION, OPPOSITION, REPLY, EXPERT DECLARATIONS, AND OTHER
ADDITIONAL
DECLARATIONS WHICH HAVE BEEN FILED.
COLIRT DOES NOT GO FORWARD WITH MOTION FOR ATTORNEY FEES AND SETS MAlTER FOR
HEARING
REGARDING JUDGMENT. COURT HAS RECEIVED PROPOSED JUDGMENTS FROM AlTORNEY
MCCARRON AND INSTRUCTS
COUNSEL FOR PLAINTIFF TO SUBMllT PROPOSED JUDGMENT TO THE COURT. HEARING
REGARDING
JUDGMENT WlLL BE HELD ON 2119114 AhlD THEREAFTER A HEAR1NG FOR'THE MOTION FOR
AUORNEY FEES WlLL
BE SET.
HEARINGS:
HEARING RE: PROPOSED JUDGMENT SET FOR 02119114 AT 08:30 IN DEPARTMENT S33A.
ACTION COMPLETE
St3PEKIC)'K COURT OF ?WE STATE <>I: CA1,IFCdRNIA
COUNTY OF SAN BERN

CdiFomnia gcf~cra!pafinemhip dha
MOWrAfN SHADOWS
FUIOBILEHCIME COMMUNf'fY.
Plainlift:
V.
RONNIE SHIPLEY; and WES 1 thmugh
20
Casa: No. lJDDS 1204131)
Assigned far ail purposes to:
Judge: Hon. Dsndd R,Alvarez

Dept: S-32
1
)
)
#PROPOSED]JUDGMENT IN FAVOR
OF DEFENDANT
OII Febmarqr 14,2023, this Court, after having eonsidered the evidence and poirtts and
laudrorilics sub~ltitteclby all pmies, and oral argutncnt of counsel denied Defendant Banitie
Shipley's moriut~fur summay judgment on the grour~dsthat California Civil Cad@section
798,?S,subdivisim (c) is not limited in its apptiwtion only in ths: escrow, sale, or tramsfftr of
24
25
26
27
28
a mobilehome. trvt that it applied when art occupant of a mobilehonle
no right o f tenancy under the Mabilehnmc Residency Law (Cjv. C
aud is not ofhewise entitled to occupy the r n a b i l ~ l ~ ounder

~ ~ ~ ethe Mobitehomc Residency
1,atv.
UDDS1204130Minute Orders San Bernardino Main
Home
ComplaintslPalties
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Report
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-""
.3
HEARING RE: PROPOSED JUDGMENT

0211912014 8:30 AM DEPT. S33A

CLERK: WIMALA BLANCHARD
COURT REPORTER JULIE QUINTANILIA 11309
COURT ATTENDANT MARY KILGORE
APPEARANCES:
ATTORNEY ROBERT WILLIAMSON PRESENT FOR PLAlNTIFF/PETlTlONER.
ATTORNEY NANCY DUFFY PRESENT FOR DEFENDANTIRESPONDENT.
PROCEEDINGS:
COURT HAS REVIEWED THE PROPOSED JUDGMENTS SUBMITTED BY COUNSEL. HYBRID PROPOSAL
WORKED
OUT BY THE COURT. LANGUAGE IS STATED ON THE RECORD.
COUNSEL FOR PLAINTIFF TO PREPARE JUDGMENT AS PROPOSED BY COURT. APPELLATE DOCS
FROM DEFENSE
MAY BE ATTACHED. PROPOSED JUDGMENT DUE TO DEFENSE COUNSEL NO LATER THAN 3/05/14.
OBJECTION SHALL BE DUE NO LATER THAN 3/12/14. IF NO OBJECTION IS FILED COURT WILL ENTER
JUDGMENT. HEARING REGARDING MOTION FOR ATTORNEY FEES IS SET AS FOLLOWS:
HEARINGS:
LAW & MOTION RE: ATTORNEY FEES SET FOR 03/17/14 AT 08:30 IN DEPT. S33.
ACTION COMPLETE
SUPERIOR COURT OF THE STATEaF CALIFORNIA

C O W OF SAN BERNADIN0 - C M L DIVISION
10 STUBBLEFIELD PROPERTIES, a
Case No. UDDS 1204 130
California general partnership dba

MOUNTAINSHADOWS
12 MOBILEHOME COIsadumw.)
Assigned for all purposes to:
l1
l3
Judge: H Q ~Michael
,
A. Sachs
Dept.: S-33
Plaintiff,
I"I1'
ROPOSED OlRDER VACATING

E m OF SUMMARY JUDGMENT
FAND
JLTDGMENT IN FAVOR OF
DEFErnANT
BONNIE SHIPLEY; and DOES 1 through

16 10, inclusive,
20
Defendants.
On Ftbruaq 14, 2013,the Court, after having considered the evidence and points and
I
I
authorities submitted by all parties, aad oral argument of counsel denied Defendant Bonnie
Shipley's motion for summary judgment on the grounds that California Civil Code section
23
24
25
1
I
26
(798.75, subdivision (c) is w t limited in its application only in tbe escrow, sale, or ttaaslr of
a mnobilehorne, but that it applied when an occupant of a mobilehome

no right of tenancy under the Mobilehome Residency Law (Civ. Cade section 798 et seq.)
1and is not otherwise entitled

I
to occupy the mobilehome under the Mobilehme Residency
27 taw.
[PRDPOSEDJ ORDER AND JWDGhtEMT
la
g-2-
On February 27, 2013, Defendant med a Petition for Writ of Mandate with the
Appellate Division of the San Bcmardino Superior Corn (uAppellate Division") requesting
3 an order that denial of her summaryjudgment motion be vacated and that summaryjudgment
4 be granted in her favor.

On May 6, 2013, the Appellate Division, having considered Defendant Bonnie
5
6 Shipley7sPetition for Writ of Mandate, issued its'unpublished Opinion granting the Writ
7 finding that Civil Code section 798.75 applied only to a purchaser or transferee of a
mobileborne unit that occupies the park's space without frrst executing a written lease
g agreement with the park, that Defendant

10
was not a purchaser but a sublessee of the
mobilehome she occupied which is owned by her attorney Nancy D u e McCarron and
11 situated on space 333 that McCarron leased born Plaintiff in Plaintiff's mobiIehome pa&,
12 and that under the Mobi1ehome Residency
-.
13 proceedinn directly a~ainst
division (d)
e rental
of the Opinion filed May 6,2013is attached

hJuly 22, 2013, the kppellate Division issued a Writ of Mandate directing that the
enying Defendant's summary judgment

motion and to enter a new order ganting sununary judgment in fhvor of Defendaat and to
enter a judgment in favor of Defendant. A copy of the Writ of Mandate issued July 22,
201 3, is attached hereto marked Exhibit "2" and incorporated herein by this reference.
Therefore,
lT IS HEREBY ORDERED THAT:

1. The Court's order entered February 14, 20 13, denying Defendant's motion for
summary judgment is vacated;
2, Summary judgment is granted in favor of Defendant on the grounds that Civil
Code section 798.75 does not apply to Defendant because Defendant was not a
28 1
purchaser of a tnobilehome in PlaintiWs mobilehome park, rendering thc 5-Day

[PRDPOSEO] ORDER AND JUDGMENT
/0*3
Notice to Surrender pursuant to subdivision (c) of 798.75 inapplicable;

3. Summary judgment is granted in favor of Defendant.
4. Judgment is entered in favor of Defendant Bonnie Shipley and against Plaintiff
Stubblefield Properties, a California general partnership dba Mountah Shadows
Mobile Home Community. Plaintiff to take notling by way of its complaint.

5 . Defendant is awarded costs.
6. Any award of attorney's fees is to be determined by way of separate motion.
IT IS SO ORDERED.
Dated:
36268,0531481 1-9686-1 576v.l
, 2014
Hon. Michael A. Sachs, Judge, Superior

Court
3
[PROPo S K D f ORDER AND J V D G M E l t
/o,4
Nanc Duffy McCamn. CBX 164780

Law [lice of Nancy Duffy McCmon
950 Roble h c
Santa Barbar~,CA 93 103
803-450-0450 iks 805-965-3492
nmcy dut~b@pahoo.con~
6
a
Attorney for Dcfcndanc Bonnic Shipley
SUPERIOR COURT OF THE STATE OF CALIFORh'lA

COUh'TY OF SAN 13EIlVARC!3:3
STIJBBLE121ELD PKOPER'I'IES. n
Case No. IJDDS !204 130
California General Parmership dba hlountein DEFWDANI-S O D I E C ~ ~TO
S PLAI~~-,FF?S
Shadows Mobile Home Communily
1 (PROPOSED]ORDER VACA'I'ING DENIAL
Plainliff.
1
OF SIIMMARY JUDGMENT AND
V.
JUDGMENT ]:OK DEFENDAST
BONN& SMIPLEY.
Honorable Mictcel Sachs kpartmcnt S-33

1 303
W. 3d.
Bmnrdino CRC 3.1312
kfcndant
St. S3a
action filed: 8-27-12
Defendant objects tn p1ciinii~T.r~~ttrnplrrirsi~~g

of the hja1 and ap.w!f;(.c court's ordcrs to crcatc a pretex
;' 11the courts made findings against praailinp, my-sintcrcsi which a&iy wcrc not rccitcd in cithrr orderI
I-:
19
1
11
JFplaintiRcan obtain a ~ judicial

y
oflleer.~sikma~urcon atti?1indinBagainst a n~obikhonc resident such
I(order\\ill bc ihro\~nin ihc face of an^. cldaly msiident wlm dahs to chnllcngc park ot\mcis authority.
11 Excerpts below show ho\v plnin1iR tried to gct this
can( lo .utntr)".c11tru n a y lindings a g a i Shipley.

~
In the first paragraph ofits proposed ordcr s h o ~ mbelow plainfi,cfin$cried "such as dcfcndanr" in
I(
middle of thc court's findings. The wuds swtr as&~fendan~

sh'm~c3ndnedanyvhm in *c court's
order ortr~nirrssripl.Plaintiff lriea ta mkc ir appcar Judge Ajwra;5m~dShipley had no right of
KO such M n g wan made. Judge Alvann! set the cane for jury &24kdicating hr. would In e
______________I__--______----------da------_*
retmda>r* ~b3cr.t1 x% c: l?rrps..pdj
Orde:
i*a=rtt;:,rf
- : t "-----------------------------------------
hr.-ai
CL
*:*. 4.
s m c z y f : . ~ i r t r . t*a:! J u i b ~ . * ~fcr
t Xierdasr
. .
Judge Alvarcz mever uttmcd Ihc words "such as I)cfcndmt"in his 2/14/13 ruling h-anscribd below
1lmevmr. it dear rdt a w a r re tho
7 3 8 . 7 5 rlrp;ma
r3:acmen:
IC
1T
C l v : : CDde
only i n thr r w n s nf e n surer rala or trawccr
IF;YO;V:ICJ
(L
mbi le barn l o e a e d in r prrk.
mw
ich clmrl~
w e n not contained in the order.
The appllate division found the L~nlaw..nlucrwpunl" under 15798,751~1did nut apply to ShipIep.
rwam
Yhn. ma ' u n M u o a g t n l 110. R K ~ O Uwmmt

~
II
CM
Plaintiff hied to Mmlr the r)ppdlatedivirion's findings a Shiplcy's least with McCpm~n.a.f'ollourl
11"Defendant
w:ar n1tt.a nurrhawr hut a
she occupicvl which o\mcd by
-
16
~ Q W ~ :bat
C
is
hcr attorney Nancy Dutlj1McCarron and situated on spacc 33 that McCatron Icascsl from Main~itf':
17
Qn hlry 6. 1013. tha A W l r t e Divlsiorl, having coaddcnd P e M Bopnie
Shiplc).'~Peirlon f
a
of Mb7ht. n d k nnplbli~htdQ'ininn grrntlng t

k wdt
lIndin8 !hat civil Corla =tian

mdbiltbomc unjl
198.75
l
M hWa$iCS tbs
ngtrc1nc71u i ~ hIhe prk.
rpplfcd only
pass
to
r p u d u r a m t m k r e a af r
@aa wrhoul ILn maw-
bwiaen lcvr
rhbr Dtlm~&m wsls mt a p u . ~ b c but

r a sublcuea of Ihc
mobilehomc yht arnpkd which is owed by l ~ t r~nomr)Nancy ZhfQ M w n Md
siwarcd on spec 333 lhrr MLCsrtm !& fron P1nmc1fl in Plrin:iFs mclbitdrmc @.
rad UII uri-
Iht %lobitchmeR a i b y law. PlstaUB my t\in
r Sub!-
by
pacmding J W y a~alwiIfk LIUCOUMI

uh3n Ci\4 Codt sectiont98.Mplbdivkh c
4
m
t r *ru~!urc tu cumply wiUf r
a$mmmt ar m y amI
l IPJCcur rq~ulrtianof UIs park rhac hput of& n d
&cs@la.- h capy of Iht Optn~cnhlcd m

y 6.2Q13is arttchcd
hctcm mrrkcd E.'ribir "1" and incarp-
brreia by this mracnw
4 Proposed order. p2
Pltlintiwa misleading paraphrasing did not remotely rcscmblc thc nppflldc division finding below:
PcOlands
motjon for
summay judgrtmt crablish?s lhM on July 27.
2012, PeliUonrr executed a d e n karo with homarvlrnor N o w Dully
333. WOE Piedmont Drhre. Hghland. CA 92348. In s

u
m afIhQ mQtiM,
PeWmef piesuHs the declaraUon of McCmm. who ddares that an Januuy 3.
park and executed Ihe parkblease
July 27, 2032.
k&mm SWbw Uwf
PetWwf Jgned a urr-monlh has to share her h m as a wr&9ent

f#mer
co-askbril movcd
8Wr her
d m . MeCarron slates that StubbUild hlls
a d n u e d to aaceM manthly tern hun her. She alsa Uates that a11d the Witties
are In her n m and sha payr for t
M .
thus. PlptitmYs evident@mhtbliihts
that she b. In Mut, o rribltsssc or wblisnant d McCerron end lhrlMcCsrmn is
t h e a r m e r d ~ ~ ~ e d a l s p e t e 3 3 3 o f S h r l b l k r mobilehoma
ral
pant prrauant lo 8 leabe agreement belwen W n o n end SNbMfecd.
4 \bit
Wcr 5!6;13
The appcllstc division nctrerfound Shipley was a snblessec o f e mobileheme--but nrher found that
defendan1 Shipley \*asa snblasrc nfnttarnm Mecarran who shared the moblehome with Shi~lev.
*=.
P invites this coun to qurgirate i l s manufn~tarcdtinding ihnr Shiplcy is the sublescc of a

Plaintiffcould thcn argue Shiplcy is subleasing a mbilelromc without p r s espmscd written approval..
Shipley is not sublrnsinrr a mohiluhome! Shiplq: i s thc co-rcsidcnt. sublcsscc ofa mobilehamc ~ n n s r .
The apprl.lmcDivision found.that as a sublcsscc o l a mobilcl~omcowner. P'ctitioncr does not fall
within the delinition of an **tntfutc$tf ucc~pnnt."
tenenq.
Thus. lhb 'unlantrr; mmpam' (le. cwcwer hithout
qmemmt)
kb
an oaxpenl mst 'u nd ovwrwies tntlk!d la
bWk
b c a p y Vls
moblbhomo putauanl to this du~plet.' Ib a subbaee d a mObOehome mtW.

PeLlliaw does nMfall within me Mrr(aOnot an 'WwhJ occup8nL'
+Shipley is no! unlawfu1 o c c u p ~ '
Finally, plaintill'misrepfesents what the appllatc division found on Snrbblcficld's a h u a t e remedy.
- 3 _4_________________-d-------a------------------_--"----*------------.--------------------
E-)?rndmPps ::.h:nc'I~:rrr% :c[+:cp.=.bcfl)
O S ~ C I'iarat:xq
DOT.:^^ t,' 8 ~ T A f yJ127Cr.nt on3 Julgreat
roc Zefsr.dzr.z
13 rarl h r u ~ t d atb= Mcibjkbomc bldmcy law, IWaUff may wtn a sublexr

13
14
15
Fmcacxlinfi diratlp againit the homesnmer undu Q+LIW e actian m%

rnbCi%Wn(d)
for "hilamra rumply with v rcaymjbk nik or rqubioa af lhc p k hlu pM dtk rtn!bl
a m r a t or any rrnmdmrm Uxmo." A copy of the Ogininn filed May 6.2013ir amckcd
4 pSp
p Ofdr?r
~
Phintill~sparapbrnscd \ w d s arc inttrrtiomlly misleading and misstate what the appellnw division fou
The appellate division did no1 say Stubbbfieldmay e\*ic~mc. It n~crclynmcd that Stubkleficld had w
adcqmrc rcmcdy b)' invoking Civil Code 798.56.

Raldtnty Lew. Slubbbliekl lrlkgcr that P e M i bar vblaled ~ e r km
m by.
amarg OUWr things, QYing P obm;nparh amant ofamfad before ouuming

a11 park ntles and rapuWom.
occupancy.? A wblcsree must cm@fy

.--
luck.-
o p n ~ r r g r r b r g ~
*MWmIw(ICCCll+rYhlMm.
4Fwtmmemlr ma) b~ unr~lmnablt
Reading bctwccn the lines. \-idp[uituus rnornocc. it suggcsts tha~if Stubblcficld tde to evicl the subIcsscc by cvic~ingrhc homccrwmcr. t h y cnuld drlhnd lhc action b~ arguing ~ h rules
c
arc unwasonnble.
For thu obovc reasons Shipley objects lo the proposed order. If thc courl ~ ~ mlat includc
s
finding in its
It~hrM
judgment l h m is only jurisdiclion to includc findings actually made. vcrb;rtim by the trial court
and
appella~ocoun. There is no jurisdiction adopt newly lnonulbctuhd tindings plaintiff Lbricned
1 and
submi[rcrl in n p m p s ~ ' dordcr. This clcwr mancurer is as m s p a r e n ~ns r piccc of clam @ms.
tB
10
Dcl'mdanl submils hcr altcrnatc proposcd order which includes f n d i w ncnrally msdc-nor fabricated.
AFFIDAVIT OF EAhilL SERVICE BY COUNSEI,
YlnintiR scncd his proposal onier via ernail only. Likcwisc dcfcndant s m e s her order by mail.
A c o of~Objeclions to P l a i l ~ ~ i fProposed
fs
OKDER and dtfen&ntWsalterrmtc P M p o d Odcr twrc
served via email to: r~ilIiamson@hartkingla~v.cx~m:m
w
n-se
an 3/4/14 8:00 am.
1 dcclm rhc ahovc b be truc under pcnnli~ofpcjury. Exccutcd in Iliehland. CA on 3t4115.
SUPERIOR COURT OF THE STATE OF CGLIFORNIA

COUNTY OF SAN BERWARDINO
ZUBBLEFIELD PROPERTIES,a
) Case No. UDDS1204130
Zalifornia General Partnership, dba Mountain )
Shadows Mobile Home Community
[PROPOSED] ORDER VACATING DENIAL
Plaintiff,
OF SUMMARY JUDGMENT AND
v.
JUDGMENT FOR DEFENDANT
3ONNIE SHIPLEY,
Defendant
Honorable Michael Sachs Department S-33
lction filed: 8-27-12
303 W. 3". St. Sen Bernardino CRC 3.1 3 12
!t
On February 14,20 13, the Court, after having considered the evidence and points and authorities
ubmitted by a l l parties, and oral argument of counsel denied Defendant Bonnie ShipIey's motion for
urnmary judgment on the grounds that California Civil Code section 79835, subdivision [c] is not
imited in its application only tn the escrow, sale or transfer of a mobilehome, but that it applied when
Civil Code Section 798 et seq.) and is not otherwise entitled to occupy the mobilehome under the
dobilehome Residency Law.
On February 27,201 3, Defendant filed a Writ of Mandate with the Appellate Division of the
!anBernardino Superior Court ("'Appellate Division") requesting an order that denial of her summary
udgment motion be vacated and that summary judgment be granted in her favor.
On May 6,2013, the Appellate Division, having considered Defendant Bonnie Shipley's Petition
or Writ of Mandate, issued its Opinion granting the Writ Petiti~nfinding that Civil Code section 798.72
.pplied only to a purchaser or transferee of a mobilihome unit that occupies the park's space without
irst executing a written lease agreement with the park; that Defendant wis not a purchaser or transferee
but a sublessee of Nancy DL@ McCarron, who is the owner of the mobgehome pursuant
. I to a lease
greement between McCarron and Stubblefield; and that McCarron shmis the mobilehome with
Iefendant as her co-resident after her fortner co-resident moved next door.
*-
- 1 _-L----_--------------.--.-__--_-__--_____--_----------------------------------4---------
[Proposed] Order Vacating D e n i a l of S m a r

ti.
PJudgment
and Judgment for Defendant
/012/
The Appellate Division found "As sublessee of a mobilehome owner, Petitioner does not fall
within the category of "unlawfil occupant." The Appellate Division found that although Stubblefielc
could not evict defendant under Civil Code section 798.75[c] he was not without a remedy under the
Mobile Home Residency Law, in that he could "
Civil Code section 798.56, subdivision (d) for 'failure of the homeowner or resident to comply with a
reasonable rule or regulation of the park that is part of the rental agreement or any amendment thereto
The Appellate Division noted, in footnote 2, "We express no opinion regarding the reasonableness of
Stubblefield's rules or regulations as such determination is not relevant or necessary to our decision."
A copy of the opinion filed May 6,2013 is attached hereto as Exhibit A.

On July 27,201 3 the Appellate Division issued a Writ of Mandate directing the trial court to
vacate its order denying Defendant's summary judgment and enter a new order granting summary in
favor of Defendant and to enter judgment in favor of Defendant. A copy is attached hereto as Exhibit
Therefore,
IT IS HEREBY ORDERED THAT:
1. The court's order entered February 14,2013 denying Defendant's motion for summary judgmei
is vacated;
2. Summary Judgment is granted in favor of Defendant on the grounds that Civil Code $798.75 dc
not apply to Defendant because Defendant is not a purchaser or transferee of a mobilehome in
Plaintiffs mobilehome park rendering the 5-day Notice to Surrender pursuant to subdivision [c
of 798.75 inapplicable;
3. Summary judgment is granted in favor of Defendant
4. Judgment is entered in favor of Defendant Bonnie Sbipley and against Plaintiff Stubblefield
Properties. a California General Partnership, dba Mountain Shadows Mobilehome Community
Plaintiff to take nothing by way of its complaint.
5. Defendant to be awarded casts.
6. Any award of attorney fees is to be determined by way of separate motion.
IT IS SO ORDERED:
Dated:
20 14
Hon. Michael A. Sachs, Judge of the Superior Court
- 2 -
----------------------------------------------------------------------------------------[Proposed] Order Vacating Denial of Sununary Judgment and Judgment for Defendant
11
k3,
uhat the attorney did in that circumstance. So that: would be
Ruffin, R-u-f-f-i-n, versua Statewide Towing. YOU will see an
attorneyfs fees motion in that matter filed by Mr. ~pitz,he
is the Plaintiff's attorney in the case, and you w i l l see what

he sdmitted in conjunctian with mt: order.
MS. MCc?GZRCN:
Okay.
Did you find that that was okay?
THE COURT: What he submitted was okay. There was

sane issue as to the amaunt, but: what he submitted appeared to
be okay.
M S . McCARRON:
guidance so it is clear.
We submit.
MR. WIUIAMSDN:
Okay, because then I can have sane
I understand your position then.

'Ihank you, your -or
Excuse me, your Honor.

At this time when I do resubrmit and now that we are
MS. M c w :
going to have a judgment I am assuming we can get a copy of

that judgment today?
THE COUZPT :
Somebody has to prepare it.
I just
worked off of what was prepared so I am going to ask counsel
to prepare it and get it filed by the end of the week.

MR. WILLIAMSON: Yes
THE COURT:
the court's decision -MS. McCARRON: Page nine of the courtla decieian.
THE COURT:
--
it say8 the statute applies anly t o a
purchaser or transferee of a mbile ham

MS. McCARIZDN:
ClrOURT:
1 a m sorry, what l i n e
ia that?
I can1t t e l l you what line it
ie ; it is
on page nine, the paragraph right on top, right dbove the

heading that says disposition.
b S . McCARRON: Okay.
TIB CX)URT:
It says the t r i a l court. misinterpreted
The statute applies only t o a
C i v i l Code Section 7 9 8 . 7 5 .
purchaser or transferee of a mabile h m unit.
MS. McCARRON: That occupies the park's space without

first m u t i n g a written lease agreement with the park.
If we are going t o quote, l e t ' s quote the whole
sentence.
THE COURT:
We
danlt need t o quote because the whole
decisian is incorporated by reference so w e don't need to

MS. McCARRON:
TEIE COURT:
Well
--
MS. M
c
C
A
R
R
m
into
THE ~ U R T : Excuse me,
ma am, q are not talking
the mther died and they couldnlt move in because they had an
eight-year-old daughter and they sublet it and he got approval

from the park to sublease and he is in a subleaae with the
pask, he pays the mney directly to the park, and he is what

is known as the sublessee of the mobile home itself; that.is
not the case with Bannie Shipley. Bonnie Shipley is not a

subleseee of the mbile home. Bonnie may be a ~ublesseeof
N a n c y McCazron
--
THE COURT: who has that phone? Ycru need t o leave

the courtmm or that phone is going to go off.
MS. McC?UWX:
is a sublessee of
Bannie -ley
McCanron, the owner, who is in a Valid lease with the park,

but she is not a Bublessee.
--
I really take offense to put that
that miscanstrues what the clxlrt has
--
THE COURT: Haw about you let me finish, ma'am?

MS. McCARRON:
THE,
mURT:
Okay.
What we w i l l do
is we will cross out
mobile home and put McCanmn down there, I think that is

accurate what you just told me.
MS.
m:
MR. WILtIAMSON:
YOU, C O T ~ ~ C ~ .
Well
--
Ms. Mc-:
THE COURT: Excuse me, ma'am.

MS. McCARRCN: Okay
SUPERIOR COURT OF THE STATE OF Ci4UFORNIA
COWTI' OF S A N BEFNARDTNO - CMI. DMSION

10 sTIII~BLEFELDPROPERTIES, a
California general partnersliip dba
MOU'NTAIN SHADOWS
MO%ILEHOME CObfMUMTY,
] CL+SSNO.UDDS
1204130
~siignedfor all purposes to:
Judger Han. MichaeI A. Sachs
Dent.: S-33
PIaintiff,
13
54
ROPOSED ORDER
EN= OF
AND JUDC;MENT INFAVOR OF
v.
DEF'EMIANT
Is
BONNIE SHIPLEY; md DOES I through

16 10, inclusive,
20
21
22
23
24
Defendants.
On F~bruary14,20j3,the Court, affn having mosidaed tbc evidence and

.pu@oritiej;submitted by all parties, and oral a~gumcutof comsel denied
Shipley's motion for summary judgment on the grounds &at Califomi'a
798.75,subdivision (c) is nor lbnited in b appljcation cnly in the

) a mrrbilcl~omc,but that it applied when an occupant af s mobilehome, such ah
and is not othmise entitled to occupy the mobi1ehme under the Mobilehome
On February 27, 2013, Defendimt a d a Petitim fm Wril of Mmdatc with tba
2 l ~ ~ ~ e 1 1Division
a t e of the San Bemardin0 Superior Court (*AppaUste Division") requestlug
I1
1a.order that denial ofher summaryjudgmentmotim bc vacated and that smnmejudgment 1
be granted in her favor.

On Mey 6, 201 3, the Appellate Division, having considered Defendant Bonnjc
af Mandate, issued its uopublished Opinion granting tbe Writ

7 finding &at Civil Code section 798,75 applied only to a purchaser or vansferec of a
6 . Shipky's Petition for Writ
15.
la tion of .the park tbat js part of #the
agreement or any amendment thereb." A copy of the Opinion fad May
2013js attached
16 hereto marked W i b i t "1" and incazporatcd herein by this reference.

17
On July 22, 2013, the Appellate Division issued a Writ of Mandate directing fiat t h
trial court vacate its February 14, 2013 order denying Defendant's sumnary judgment
motion and to enter a new order granting sununary judgment
in favor ofDefeadant and to
enter a judgment in 'favor & f ~ & d a n t .A c&y of the Writ of ~andake'is&edJuly 22,
2013, is attached hereto rnarlsed Exhibit "2" a ~ d
incorporated herein by this reference.
Therefore,
IT IS HEREBY ORDERED THAT:

1 . The Court's order entered February 14, 2013, denying Defendant's motion for
26

2. Summary judgment is granted in favor of Defendant on the grounds ths; Civil
Code section 798.75 does not apply to Defendant because Ddendant was not a
pumhaser d a mobilchome in Plaintiffs mobilehome park, rendering b e 5-Day
Notice to Smender pursuant to subdivision(c) of 798.75 inapplicable;

3. S u ~ a t judgmmt
y
is granted in favor of Bfmdant.
4. Judgment is enmd in favor of Defendant Bormie Shiplty and a
mst PZaintiff
Stuhblcfield Pm$ertks, a Califamia g a m . l pWersbip dba Mmtdn &Ghadows
Mobile Home Commu~ty.Piahtiff to take natlzing by way of its complaint.
Any award af attorney's fees is to be determined b;rway ofsep-
motion.
IT TS SO ORDERED,
Dated;
II
5. Defendant is awarded cos$.
6.
II
2014
Hon. Mchaet A. Sachs, Judge, Supmar

Court
UDDS1204130 Minute Orders - San BernardinoMain
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204130 STUBBLEFIELD-V-SHIPLEY
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"
T .J1
MOTION RE: ATTORNEY FEES

0311712014 8:30 AM DEPT. S33

CLERK: ANCHALEE M PRICE
COURT REPORTER KATHY SELLERS 4420
COURT AlTENDANT MARY KILGORE
APPEARANCES:
AlTORNEY NANCY DUFFY MCCARRON PRESENT FOR PLAINTIFFIPETITIONER.
AlTORNEY ROBERT WILLIAMSON .IR PRESENT FOR DEFENDANTIRESPONDENT.
MOTION
POST-DISPOSITION HEARING HELD
THE COLIRT IS IN RECEIPT OF DEFENDANTS OBJECTIONS AND PLAINTIFFS RESPONSE TO THE
OBJECTIONS . THE
COURT HAS REVISED THE PROPOSED JUDGMENT AND A COPY OF THE PROPOSED JLIDGMENT
WITH THE COURTS
NOTES ARE PROVIDED TO COUNSEL.
PLAINTIFFS COUNSEL TO PREPARE JUDGMENT AS DISCUSSED ON THE RECORD.
PURSUANT TO STIPULATION OF COUNSEL:

BONNIE SHIPLEY'S MOTION RE:AlTORNEY FEES IS HEARD.
THE COURT RECITES ITS TENTATIVE RULING ON THE REOCRD.
ARGUED BY COUNSEL AND SUBMITTED.
COURT FINDS:
BONNIE SHIPLEY'S MOTION RE:AlTORNEY FEES IS DENIED.
WITHOUT PREJUDICE
THE COURT FINDS THAT DEFENSE COUNSEL IS ENTITLED TO HER AlTORNEY FEES PURSUANT TO
CCP 798,
HOWEVER DEFENSE COUNSEL WAS NOT SPECIFIC AS TO HER BtLLING.DEFENSE COUNSEL MAY
SUBMIT ANOTHER
MO-I-ION DETAILING HER FEES FOR THE COURTS REVIEW.
UDDS1204130 Minute Orders San Bernardino Main
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Case UDDSl204130 STUBBLEFIELD-V-SHIPLEY
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IDEPT 533 /
Disposition
I!
MOTION RE: EXPUNGE LIS PENDENSIAWAR

BY PLAINTIFF STUBBLEFIELDPROPERTIES
PARTNER - Minutes
1-1
FEES FILED
I:
:
l^jl)03117120141
r?
FILES RETAINED IN DEPARTMENT.

_
1
r'
DENIED
II
I:
;1
SHIPLEY - Minutes
Complete
13, 1
i l.
'
F l
H A R T 1 K I N G
A T T O R N E Y S A T L A W
Robert G. Williamson, Jr.

rwilliarnson@hartkinglaw.com
March 19. 2014
Our File Number: 36588.053/482&0139-4457~.1
VIA HAND DELIVERY

~onorabteMichael A. Sachs
superior Court of California, County of San Bernardlno
Civil Division, Department S33
303 W. Third Street
San Bernardino. CA 92415-0210
Re: ~ f u b b l e h b dPropetties v. Bonnie Shiplev, Case No. UDDS1204130
Dear Judge ~ b c h s :
Pursuant to t
referenced
Judgment an
- 13 consiste
e Collrt's request at the hearing on March 17, 2014, with respect to the aboveatter, enclosed is a revised [Proposed] Oder Vacating Denial of Summary
Judgment in Favor of Defendant. The revisions are contained on page 2, lines 9
t with the Court's direction.
Very truly you s,
Robert G. Wil iamson, Jr.

i
Cc:
Nancy Duffy McCarron (via U.S. Mail and ernail)
A Professional Corporation
4 Hutton Centre Drive. Suite 900, Santa Ana, California 92707
Ph 714.432.8700 1 www.hartkingtaw.com ( Fx 714.546.7457
t!rt /
1I
COUNTY OF SAN BERNARDINO - ClVlL DIVISION

PROPERTIES,a
California gcaeral partnersliip dba
MOUNTAIN SHADOWS
12 MOBlLEHOME COMMUNITY,
1 0.1 STUBBLEFELD
''
'
Plaintiff,
13
14
BDM.IIE SI-IIPLEY; and DOES 1 through

1 6 10, inclusive,
'17
20
Judge: Hon. Michael A. Sachs

Dept.: S-33
1 ORDER VACATING
V.
Is
Assigned for all pwposes to:
E
rn
E EmDGprENy
? Y ? s u M MIN
my
FAVOR
nmGMENT
OF
DBFETVDANT
Defendants.
On Feb~uary14,2013, the Caul?, afler having co~lsideredthe evidence and points and
authorities sublnitted by all parties, and oral argument of counsel denied Defendant Bonnie
Shipley's motion for smnmary judgment on tbe grounds that California Civil Code section
23
798.75,subdivisian (c) is not limited in its application only in the escrow, sale, or transfer of
24 a mobild~arne,but that it applied when
an occupant of n mohilehorne, such as Defendant, has
25 ino right of tenancy under i l e Mobilelmne Residegcy Law (Civ. Code section 798 el ser].)
and is not otl~erwiseentitled to occupy the mobilehome under the Mobilehome Residency
27
F i r d Legal Support (951)779-0100 00/0012013
On February 27, 2D13, Defendant filed a Petition for Writ of Mandate wilh the
Appellate Division of the San Eernardino 'Superior Court ("Appellate Division") requesting
an order that denial of 1.1er su.mrnGzryjudg~llent1110tionbe vacated and that sur~maryjudgmen~

be granted in ber favor.
5
On May 6, 2013, the Appellate Division, ]laving considered Defendant Bonnie
6 Sliipley's Petition for Writ of Mandate, issued its unpublislled Opinion granting the \Vrit
7 finding that Civil Code section 798.75 applied only to
a purchaser or trar~sferceof a
~nobilehorneunit that occupies the pnrlc's space without first executing a written lease
agreement with tbe park, that Defendant was not a purchaser or transferee of tbe subjeci
mobilehome. Plaintiff may proceed directly agaiilst t11e homeowner or resident under Cj~fil
Code section 798.56, subdivision (d) for "failure to con~plywith s reasonable rule or
regulation of the pmlc that is part of the rental agreement or any amendment thereto." A copy
of t l ~ eOpinion Alcd May 6, 2013 is attached hereto marl<ecl Esllibit "I" and incorporated
herein by this reference.
011July
22, 2013, the Appellate Division issued a Writ of Maildate directing that tile
trial court vacate its February 14, 2013 order denying Defendant's sumluary judgment
motion and to enter
o aetv
order granting sumnlaq judgment in favor o f Defendant and to
enter d judgment in favor of DeFendani. A copy of the Writ of Mandate issued July 22,
2013, is attached hereto marked Exhibit "2" and i~~corporated
Therefore,
IT IS HEREBY ORDEIED THAT:

1. The Court's order entered February 14, 201 3, denying Defendant's nlotion For
2. Su~mnaryjudgalerlt is granted in favor of Defendant on the grounds that Civil

Code section 798.75 does not apply to Defendant because Defendant was not o
purchaser of a mobilehome in Plaintiffs mobilel~olneyarlc, rendering the 5-Day
Notice to Surrender pursuant to subdjvjsion (c) of 798.75 inapplicable;
3. Summary judgment is gr~mtedin favor of Defendant.
r rl5-
3GSSB.DS3NB I t - l 8 8 - ' 7 5 7 S ~ . l
-61
ORDER
.rNn J U D G l l E N T
First Legal Support (951)779-0100 00100l2013
4, Judgment
is entered in favor of Defendant Bonnje Sl~ipleyand against Plaintiff
Slubblefield Properties, a '~alifo'mjageneral pfirtnership dba Mountain Shadows
lvlobile I-lorne Conununity. PlaintiEto take nothing by way o f its colnplaint.
5. Defendant is awwded costs.
6 Any award of attorney's fees is to be delern~inedby way of separate motion.
IT IS SO ORDEED.
Dated:
D ~ / & D ,$14
MICHAELA. SACHS
--
Court
i
i
27
28
-3
I K.I ,
Nanc Duffy McCarron, CBN 164780

Law ffrce of Nancy Duffy McCarron
950 Roble Lane

Santa Barbara, CA 93 103
805-450-0450 fax 805-965-3492
nancydufYysb@yahoo.com
4
Attorney for Defendant Bonnie Shipley

5

CaseNo. UDDS1204130
S'TUBBLEILFLD PROPERTIES,a
California Get~erdPartnership,.dba Mountain
Shadows Mobile Home Community
Plaintiff,
v.
BONNE SHIPLEY,
Defendant
action filed: 8-27-12
()mCTmNS
SECOM) f p m p ~ORDER
~ ~ ~ l
JU3WRITINGA PRIOR JUDGE'S ORDER WITHOUT
AND REWRITING AN APPELLATE
ORDER TN CONTEMPT OF THAT COURT'S ORDER
NOTICE OF INTENT TO APPEAL LLEGAL ORDER
AND H O W MICHAEL SACHS IN CONTEMPT OF
AN APPELLATE DMSTON'S WRIT OF MANDATE
OBJECTIONS TO SACHS ACTING AS ADVOCATE
FOR PLAINTIFF & REQUEST FOR M W S A L
Judge Michael Sachs Department S-33
Acting as Advocate in Violation of Judicial Ethics

Defendant objects to this court's acting as an advocate for plaintiff and demands that Michael
Sacha vohntrrlly recase himagff for violations of Code of~udicialEthics as set forth below:
CODE OF JUDICIAL ETHICS PREAMBLE
Our legal system is based on the principle that an indepc~~dent,

fair, and competent judiciary will
interpret and apply the laws that govern us. The role of the judiciary is central to American concepts of
justice and the rule of law. Intrinsic to this code are the precepts that judges, individually and
must respect and honor the judicial office as a public trust and strive to enhance and maintain confiden
)I in our
legal system. The judge is an arbiter of facts and law for the resolution of disputes and a highly
visiblenmember of government under the rule of law.

A. Promoting Public Confidence
A judge shall respect and comply wit11 thc law* and sha!i act at all times in a manner that pro~notes
.
public confidence in the integrity and impartiality of the jcdiiiary.

- 1 .........................................................................................
Objections to Second[Proposed] Order Vacating
I
r
.. . .
Judgmenz and Judgment far Defendant
The test for the appearance of impropriety is whether a person aware of the facts might reasonabiy
mtertain a doubt that the judge would be able to act with integrity, impartiality, and competence.
Canon 2. A judge shall avoid impropriety and the appearance of impropriety in all of the judge's
rctivities. "Impropriety" includes conduct that violates the law. court rules, or vrovisions of this code,
ind conduct that undermines a judge's independence, intewitv. or impartiality.
ADVISORY COMMITTEE COMMENTARY

Public confidence in the judiciary is eroded by irresponsible or improper conduct by judges.
SPECIFIC ACTS IN VIOLATION OF THE LAW, COURT RULES, AND IMPROPER CONDUCT:
l.)On 5/6/13 the Appellate Division entered its order directing Judge Alvarez in S-32 to vacate his denii
of defendant's summary judgment motion, and enter a new order granting it and enter a final judgme
on the merits for Shipley with costs. On 10/21/13 Judge Alvarez entered the order vacating his denia
of summary judgment and entered a new order granting it to Shipley, but never entered a judgment o.
the merits for Shipley with costs as proposed by Shipley. Judge Alvarez wanted to enter the orders
separately but never entered the judgment although submitted to him.
!.)Shipley fiIed her motion for statutory attorney fees on 5/29/13 set for 7/2/13, which he continued to
7/22/13, then to 10/21/13, then to 1/7/14, then to 2/10/14; because the case was transferred to Michae
Sachs in S-33 after Judge Alvarez recused himself upon Shipley's request.
I.)At the I b t hearing on 2/10/14 for defendant's motion for statutory attorney fees, counsel for Shipley
McCarron bought the judgment to be entered for Shipley exactly as written by the appellate division,
verbatim, the last two sentences of their order. McCarron asked Judge Sachs to enter the judgment om
the merits so her attorney fee motion could be concluded. Judge Sachs had both McCarmn's order an
Stubblefield's order which McCarron objected to because it paraphrased both the trial court and the
appellate court's findings and completely changed the import of the order to benefit Stubblefield.
I.)Judge Sachs then invited Stubbelfleld's counsel to propose a new order. McCarron objected as
the usual practice is for the prevailing party to compose the order---not the losing party--for exactly '
reason she stated-the
loser will rewrite the order to benefit himself.
i.) Judge Sachs also announced sua sponte that he would re-write Judge Alvarez' 10-21-13 order,
There was absolutely no jurisdiction to rewrite another court's order entered 4 months ago.
There was not even a motion to vacate that order pending or ever tiled or served by plaintiff.
Objections to Second[Proposedl Order Vacating Denial of Summary Judgment and Judgment for Defendant
1h.z
i.) McCarron objected to such unoithodox procedures; i.e. letting the loser make up an order re-writing
another Judge's prior order which changed the entire findings and import of the order, as well as
parphrasing the appellate court's order. See Objections attached here as Exhibit B.
'. Despite McCarron's objections Michael Sachs scheduled another hearing letting plaintiff propose ne
'hybrid" order as he called it. See his minute orders attached as Exh. A3-A6 Michael Sachs then
;ontinued it for another hearing on 3/17/13.
,
On 3117/14 Judge Sachs authorized all the paraphrasing to completely change the import of both the
rial court's order and the appellate divisions order. Judge Sachs then dismissed the hearing stating he
vould give counsel a copy of his notes for the "final order."
1.
McCamn was shocked that he actuaIly acted as an advocate for Stubblefield by interjecting the worc
'or resident" after homeowner on page 2---basically authorizing Stubblefield to "proceed against the
~esident,Shipley under Civil code section 798.56(d) which is an action which can only be taken again:
lomeowner---not a resident! This is not what the appellate division wrote in its order.
0. This language was never discussed at the hearing or McCarron would have vehemently objected.
nstead it was gratuitously given as a gift by sneaking the words into his ''notes" given to us.
If course, Stubblefield jumped right on it and inserted them into what will be the ORDER.
rhis grabitous gift was beyond the pale. Judge Sachs has stepped into the role of advocate for
Stubblefield and must disqualify himself as his bias is clearly demonstrated.
tespectfully submitted: 312 1I14
AFFIDAVIT OF SERVICE BY COUNSEL

Objections to Plaintiffs Proposed ORDER and defendant's alternate Proposed Order were served via
nail to attorney Robert Williamson at: Hart King, 4 Hutton Cerzter Dr., Suite 900, Santa Ana, CA 9270'
declare the above to be true under penalty of perjury. Executed in Santa Barbara, CA on 3/21/14.
4 courtesy copy will also be delivered to the appellate division.
Objections to Second[Propossd] Order Vacating Denial of Summazy Judgment and Judgment far Defendant
/ 4.3
BY SUCH CONTRIVANCE SACHS STEPPED OUT OF A ROLE AS INDEPENDENT

JUDGE AND INTO THE ROLE OF ADVOCATE FOR PLAINTIFF STUBBLEFIELD.
By such contrivance, Sachs judicially authorized Stubblefield to proceed directly
against any resident under Civil $798.56[d] - a statute only-applyingto homeowners.
9798.56. Reasons for termination of tenancy; written notice; cure of default
A tenancy shall be terminated by the management only for one or more
of the following reasons:
...
(d) Failure of the homeowner or resident to comply with a reasonable rule or

regulation of the park that is part of the rental agreement or any amendment thereto.
5798.12. Tenancy
Tenancy is the right of a homeowner to the use of a site within a mobilehome park on
which to locate, maintain, and occupy a mobilehome, site improvements, and accessory
structures for human habitation, including the use of the services and facilities of the park.
Civil $798.55 and $798.56 apply only to homeowner tenancies and expressly refers to
termination of tenancy --- not occupancy. Stubblefield cannot directly evict a resident
who is not a homeowner because there is no privity of contract where she is not his tenant.
Such eviction is an illegal nullity as explained by the Division in its Writ of Mandate:
In a d d i n b the s h e , Stubblefieietd csrwfdt dkctPj evict Petitioner
betcause them is no p s i between Stukbkfield and Pefltiamr--i.s.,StuMlclield
is n d ula legal crmer d the mobahme unit in which Petitioner k an axupant
28.
4~
~1, 1.8
h .
Sachs' carving out a new summary eviction remedy for Stubblefield violated not only
his Judicial Oath to be impartial, but also Article 3, $3 of our Constitution---Separation of
Powers Clause. Sachs had no power to revise $798.56 by a naked proclamation, or convert
Stubblefield's loss to a win by authorizing a way to evict Sliipley directly. To guarantee his
gift was entered on the docket before Shipley could object Sachs orchestrated the following:
On 3/17/14 Sachs made a bizarre journal entry "j?les retained in department"
Exh. 17.1
Sachs could exercise exclusive control over what documents were accepted for filing.
Williamson hired "First Legal Support" to deliver the order exparte. Exhibits 15.4 & 18.4
He could then shift the blame for violating CRC 3.113,3.13C 1 & Local Rule 591.3 to FLS.
F'LS delivered a judgment exparte on 3/20/14. Sachs s h e d it immediatelv. Exh. 18.4
29.
Williamson knew if he tried to file a proposed final judgment at the filing window it
may be rejected because it failed to comply with CRC 3.1 13,3.1201 and Local Rule 591.3.
McCarron did not receive Williamson's proposed Judgment until Friday morning 312 1114.
McCarron immediately composed objections and emailed them to Shipley to print out and
deliver to the court. Shipley was unable to file objections at the filing window because of
Sachs' bizarre 3/17/14 journal entry; i.e. all files would be kept in S-33---not downstairs.
Shipley took her objections up to S-33. A clerk told her she had to wait outside the court
while she checked with Judge Sachs; the clerk returned to tell Shipley she could not accept
her objections for filing as Judne Sachs sinned/entered the order the day before on 3120114.
Because the S-33 clerk refused to accept objections for filing Shipley delivered objections
to Appellate Division by dropping them in a drop box as the Division had closed at 3:OO.
Sachs' refusal to accept Shipley's objections for filing, only one day after he accepted
Williamson's proposed Judgment exparte in his chambers, violated CRC 3.130 (d):
(d) Filing of late papers No paper may be rejected for filing on the ground
that it was untimely submitted for filing. If the court, in its discretion, refuses
to consider a late filed paper, the minutes or order must so indicate
If objections were late Sachs was still required to accept them for filing. Objections were
not late because under Local Rule 591.3 Sachs was required to wait at least 10 days before
entering a fmal judgment. Exhibit 19.3 Sachs runs Star Court proceedings.
30.
On Friday 3/21/14 McCarron printed Shipley's online case docket. Exhibit 17.1
There was no journal entry reciting that on 3120114 a judgment had been entered.
On Monday, 3/24/14 there was still no journal entry reciting a 3120114 entry of a judgment.
McCarron called Marsha Lenihan, Legal Processing Supervisor, right before 4:00 p.m. to
ask why there was no journal entry by 3/24/14 on a judgment purportedly entered 3/20/14.
The next day (Tuesday) Marsha Lenihan notified McCarron a journal entry would appear
on the docket showing entry of Judgment on 3/20/14 and would be available that evening.
As of 4/2/14 there was still no camera image icon to click on to download the document.
Finally, on Friday McCarron received plaintiffs "Notice of Ruling" by mail. Exhibit 18
3 1.
On 4/2/14 Shipley drove over to court to obtain a copy of the judgment signed on 3/20/14.
The clerk at the filing window said she could not provide a copy of any document in her file
because Sachs' ordered her files to be maintained upstairs in Department S-33. Shipley went
upstairs to S-33. The clerk in S-33 told Shipley she had to go downstairs to get documents.
Shipley told the S-33 clerk she had already been downstairs and they had sent her upstairs.
The S-33 clerk said to come back the next day. When Shipley came back to S-33 the next
day the S-33 clerk told Shipley she could download the judgment at the court's website.
Shipley told her there was no camera image icon to click on as the judgment had not been
scanned into the case docket. The clerk told Shipley she had to return the next day again.
On Friday April 5,20 14 Shipley returned to S-33. The S-33 clerk told her she did not have
the document. After having made 3 ROUND TRIPS to court, Shipley was unable to get a
copy of a final judgment where she is prevailing party. Sachs runs Star Court proceedings.
32.
On 4/1/14 plaintiffs counsel served McCarron with Notice of Ruling by mail. Exhibit 17
Williamson caught on to Sachs' cue to carve out a new remedy for his client Stubblefield to
evict Shipley directly. Williamson had not yet conjured up such a sneaky trick but Judge
Sachs didn't miss his opportunity to curry favor with the billionaire developer by artfully
inserting the words "or resided' into his judge notes given to both attorneys Exh. 13.2
33.
After 7 years as judge and 13 years as Chief Deputy of County Counsel's litigation team
Sachs knew the limits of his power and that he could not revise a statute by proclamation,
and he could not advocate for a party by inserting words into a statute to carve a remedy.
Sachs knew his power to vacate Judge Alvarez's order expired 60 days after it was entered
and that it violated a judicial oath he signed to uphold the law, court rules & civil procedures.
Sachs runs Star Court proceedings. Plaintiff added the ivords Sachs inserted, "Plaintiff
may proceed directly against the homeowner or resident under Civil Code section 798.56.. ."
mobilehorn. Ptnintiff mey pmced directly epinst thc bomcnwner or resident vndcr Civil
Code section 798.56, subdivbiion [d) Ftw 'fnikue to con~plywith
reasonnbtc rule nr
replation &?he pa& that i&

part of& rtnlal apmncnt or any mmar8ment U~sreta."A copy
of the Opinion filed Mey 6, 2011 is unachcd herdo n~arketlExbibit "1" $174insorporated
lae~einby this m f c n m .
4 Exhibit 18.5
EXHIBIT 11
ECEUVE
APR
I:
3044
SAN BERNARDINO COllNN

SUPERIOR COURT-APPEALS DIVISION
CIVDS
SAN BERNARDINO COUNTY SLTPERIOR COURT

APPELLATE DIVISION
BONNIE SHIPLEY,
Petitioner,
v.
HONORABLE MICHAEL A. SACHS,
SAN BERNARDINO COUNTY
SUPERIOR COURT
Respondent;
dba Mountain Shadows Mobile Home
Community, Real Party in Interest.
1204130 ~ - 3 3 :Michael A. ~ a c h s
Case No.
.
(Trial Court No. UDDS 1204130)
ORDER TO SHOW CAUSE
RE CONTEMPT
40 1 North Arrowhead Avenue
San Bernardino, California 924 15
TO: RESPONDENT HONORABLE MICHAEL A. SACHS

JUDGE, SAN BERNARDINO SUPERIOR COURT
YOU ARE HEREBY ORDERED to appear on
or as soon thereafter as the matter may be heard in courtroom
,2014 at
of the Appellate
Division of San Bernardino Superior Court, located at 401 North Arrowhead Avenue,
San Bernardino, California, 92415; then and there to show cause, if any you have, why you
should not be adjudged in contempt of court for willfully disobeying a Writ of Mandate
issued by this Appellate Division on July 22, 2013 to which you admitted in bvo transcripts
[Exhibits 8 and 12, from Exhibits 1-19 filed concurrently with the verified petition]
that you reviewed, and which you had the present ability to comply with as directed.
The Writ of Mandate entered on July 22,2013, and your disobedience thereto, are
more particularly described in the verified petition (complaint) which is attached hereto
and made a part hereof., together with Exhibits 1- 19 and Request for Judicial Notice of
an Ohio Supreme Court Case, State Ex Re1 Cincinnati Enquirer v. Tracie M. Hunter,
Judge, Hamilton County Court of Common Pleas, Supreme Court Case 13-1171,
affirming an entry of contempt entered by the Court of Appeals against Judge Hunter.
Entry of Contempt was entered because although the Judge technically complied with
the Writ of Mandate, she rendered the relief petitioner sought illusory and meaningless.
It appears fiom the record supporting this petition [Exhibits 1- 19 concurrently filed]
--
that although you technically complied with the Writ of Mandate [Exhibit 2 from 1- 191
by entering Judgment on the merits for petitioner (defendant below) you rendered the
relief petitioner sought [protection from eviction based on a statute which did not apply]
illusory and meaningless, because in that same judgment you authorized real party to
proceed directly against petitioner to evict her on another statute which does not apply.
Of those specific allegations the most important are shown in the attached excerpts
from Exhibits 1-19; i.e Exhibits 13, 18 and 19 attached hereto. Exhibit 13.2 is your
working copy of a proposed order submitted by real party, in which you inserted the
words "or resident" after the word "homeowner" into the judgment. Real party added
those words to a proposed order submitted exparte to your chambers on March 20,2014.
[Exhibit 15.1 from Exhibits 1- 191. You then signed the proposed order the same day,
in violation not only of Rules of Court 3.13 12, but more importantly in violation of San
Bemardino Local Rule 59 1.3 [Exhibit 19 herein] by which you were required to wait ten
[lo days] to afford petitioner a due process opportunity to object to entry of a judgment.
More importantly we held that real party could not proceed to evict petitioner
directly because there was no privity of contract between real party and petitioner.
In direct contravention to the terms of the Writ of Mandate, you expressly authorized
real party to proceed directly against petitioner to evict her. This is not a remedy which
was even proposed by real party, as shown in its proposed order [Exhibit 13.2 herein].
You gratuitously granted real party a new eviction remedy, where there was no
pending motion to do so, and which was in direct violation of your oath to be fair and
impartial to all litigants in all proceedings you preside over as a judicial officer.
You affirmatively acted as an advocate for real party by gratuitously granting a remedy
sua sponte, which was in direct contravention to findings in our decision entered on
May 6,2013, in which we expressly held that real party could not proceed directly
against petitioner for eviction as real party was not in privity of contract with petitioner.
In the judgment you entered you rendered the relief petitioner sought meaningless
because you expressly authorized real party to proceed directly against petitioner to evict
her, under Civil Code 798,56[d] which does not apply because she is not a tenant in
privity of contract with real party. Your gratuitous gift violated the Separation of Powers
Clause of our California Constitution, Article 3, Section 3 because a judge cannot insert
words into a statute not contained therein, as only our Legislators may amend a statute.
Your ultra vires act exceeded the scope of constitutional limitations on judicial powers,
as set forth in California Constitution, Article 3, Section 3.
Secondly, with no service of a pending motion, as required under Rules of Court,
Rules No. 3.1 110 -3.1 113, or any cited jurisdiction to seek relief, you vacated the order
entered in compliance with our Writ of Mandate on October 2 1,2013 which granted
petitioner's summary judgment motion, sua sponte while you had no power to do so.
Your power to vacate that order expired 60 days after it was entered, as set forth in
Code of Civil Procedure, Section 663(b). You had no power to waive this legislatively
imposed statute of limitation, theieby violating Article 6, Section 13 and Article 3,
Section 3 of the California Constitution, which expressly limits your powers.
This order shall be served on you by delivering a copy thereof, together with a
copy of the verified petition (complaint), with Exhibits and Request for Judicial Notice,
at least
day(s) prior to the date of the hearing in this matter.
IT IS ORDERED on this
day of April, 20 14 that Honorable Michael A.
Sachs appear and show cause on the
day of
,2014 at
o'clock in the
noon, or as soon thereafter as counsel can be heard, why a contempt judgment

should not be entered against you as prayed for in the verified petition (complaint).
Any party in interest who wishes to be heard with respect to any of the relief requested
in the petition served with this order to show cause shall file with the Appellate Division,
and serve on petitioner's counsel, an answering affidavit or motion returnable on the
date this matter is to be heard, or other response to this order to show cause and to the
,2014.
relief requested in the petition no later than
Such responding party in interest shall also file with the Appellate Division by the
foregoing date a proof of service on petitioner's attorney at the address on the petition.
Any party in interest who fails to timely file and serve a response in the manner provided
in this order to show cause shall be deemed in default, and the matter may proceed to
judgment without any M e r notice to, or participation by, such defaulting party in interest,
and any judgment entered shall be binding upon such defaulting party in interest.
If no party in interest timely files and serves a response to this order to show cause
as provided for above, the application may be decided by the Court on or afier the date
this matter is scheduled to be heard, and may be decided on the papers without a hearing,
provided that petitioner has filed a proof of service and a proposed form of judgment
as required. If a party in interest timely files a response as provided for above, the court
may entertain argument and may or may not take testimony on the date this matter is heard.
Petitioner must file and serve any written reply to the response of a party in interest by
20 14. The reply papers together with a proof of service must be

filed in the Appellate Division, and a copy of the reply papers must be served by m ai 1
to any party who has appeared no later than
days before the date
this matter is scheduled to be heard. IT IS SO ORDERED.

DATE:
Judge of the Appellate Division
EXHIBIT 13
SUPERZQR COURT OF THE STATE OF C U O R M A

COUNTy OF SAN BEWARDIN0
STUEBLEFELD PROPERTIES, a
California general partnersliip dba
MOUNTAIN SHADOWS
MOBILEHOME CO?MbWMTY,
Plaintiff,
13
14
- C M L DIVISION
Case No.UDDS 1204130
~ssignedfor all purposes to:
Judge: Han. MichaeI A. Sachs

Dept.: S-33
v.
AND JUDCmNT IN FAVOR OP
BONNIE SHIPLEY; and WES I through
20
21
22
23
On Februaq- 14,2013,the Court, after havbg considexed the evidence aod points and
4uthorities submitted by all parties, and oral argument of cowsel
denied Defendant
Bonnie
Ship!eyls motion for sumnary judgment on the grounds that California Civil Code section
798.75, subdivision (c) is not lunited in its application ~ n l yin !he escrow, sale, or bansfer of
a mobilchorne, but that it applied when an occupaat of a mobilehome, such as Defendant, has
no right of tenancy under the Mobilehome Residency Law (Civ. Code section 798 et seg.)
26
t7
2s.
and is not otherwise entitled to ooccllpy the mobilehorne under the Mobilehome Residency
Law.
--
e
r
r
tlogal support (951)~EI-OIPO W,OO&
On February 27, 2013, Defendant f l e d
a Petition for Wrjr
of Mandate with the
-7 IAppellate Division of the San Bema~dinoSuperior Court PAppeUate Division") requesting
3 an ordcr that denial of her summary judgment motion be vacated and that s m & y judgment
be ~ m t e in
d her favor.
On May 6, 2013, tlte Appellate Division, having considered Defendant Bonnie

1 ~ h i ~ l e Petition
~ ' a for Writ of Mandate, issued its unpublished Opinion granting th: Writ
, i f d i n g that Civil Code section 798.75 applied only
to a
purchaser or transferee of a
II
1
mabilehome unit that occupies the park's space without first

that Defendant was not n purcisaser
14
1for "failure to comply w i l a reasonable rule or regulation ofthe park tbat is part of the rental 1
4 agreement or my amendment thereto." A copy ofthe Opini~nfiled May 4 2013ir mached 1
1 6 hereta ~narlcedExhibit "1" and incorparatcd herein by this reference.

17
1trial
On luly 22, 201 3, the Appellate Division isued a Writ of Mandate directing U~atthe
court vacate its Feblvary 24, 201 3 order denying Defendant's sumnary judgment
19 motion a d to enter a new order grauting summary judgment in favor of Defendant and to
. ..
20 enter a judgment in'favor o'f~endant.A cbTy of the Writ of ~ a n d a t eissued July 22,
21 2013, is attached hereto marked Exhibit "2" and incorporated herein by
.-79
Therefare,
23
1T IS HEREBY ORDERED THAT:
this reference.
I. The Court's order entered February 14, 20j3, denying Defendant's motion for
sumaryjudgment is vacated;
261
27
38
2. S u m y judgment is granted in favor of Defendant on the grounds ~lii

Civil
i
!I
Code se~tion798.75 does n n apply to Defendant because Defendant was
not a
purchaser of a mobilehome in PIaintiffs mobiiehornc park, rendering the 5-Day
J656tllS31JBI I-4600-7576~.
I
I
I
I
I
I
I
@rat
tesa support
A3
~ ~ I ) T T ~M
- O W)OO
I
Notice to Smender pursuant i~ subdivjsjon fc) of 798.75 inapplicabie;

3. Summary judgment is granted in favor of Defendant.
4. 3udgment is cntcred In favor of Defendant Bonnie Shipley and against Plaintiff
Stubblefield Pro$&es, a California general partrrersbip dba Mountain Shadows

I
Mobile Home Community. Piahtiffto takenothing by way of its cornplsinr.

5. Dehndant is awarded costs.
6.
Any award of attorney's fees is to be determined by wny of separate motion.
IT IS SO ORDERED.
___,
2014
Court
EXHIBIT 18
F lrsl Legal Suppar\ (95 1)779-0 100 001001201 3
F.[
I-
c-0,,
1I
COUNTY OF SAN BERNARDINO - CIVIL DIVISION
-9
STUBBLEFIELD PROPERTIES, a
Cali fornja gcoeral parlnership dba

MOUNTAIN ST-TADOWS
Assigned for all pul-poses to.
MOBlLEHOME COMMUNITY,
Judge: Hon. Michael A. Sachs

Dept.: S-33
Plaintiff,
7 ORDER VACATING
E%f25?suMMAnY
JUDGMENT
AND JUDCMEN'J' IN FAVOR OF
DEFENDANT
BONNIE SI-I iP:LEI'; and DOES 1 through

10, inclusive,
''1
21-1(
''1
23
24
25
26
27
On February 14, 2013, the Couit, aftel-]laving considered the evidence and points and
authorities submitted by all parties, and oral argument of counsel dellled Defendant Bonnie
Shipley 'r motion for summary judgment on t h grounds h a t California Civil Code section
798.75, subdivision (c) is not limited in its apptication only in the escrow, sale, or transfer of
a mobilehome, but that it applied wl-ren an occupant of a n~ohilehorne,such as Defendant, has
no right of tenancy under the Mobilellolne Residency Law (Civ. Code section 798 et seq.)
and is not otl~enviseentitled to occupy the mobilehome under the Mobilehome Residency
Law.
First Legal Support (951)779-0100 D010012013
On February 27, 2013, Defendant filcd a Petition for Writ of Mandale will] the
Appellate Division of the San Bernardino 'Superior Court (''Appellate Division'') requesting
an order that denial of her swurnLayjudgn~enln~otionbe vacaled and dlat sunmary judgn~enl
be granted in her favor.
On May 6, 2013, the Appellate Division, having considered Defendant Bonnie

Shiplcy's Petition Tor Writ of M a ~ d a t e ,issued its unpublished Opinion granting the W n t
fmding tl~atCivil Code section 798.75 applied only to a purchaser or transferee of a
mabilehorne unit tl-rai occupies the parli's space without first executing a written lease
agreement wit)] the park, that Defendant was not a purchaser or bansfel-ee of hc subject
n~obilehome.Plajntiff may proceed directly against t l ~ eIiolneowner or resident under Civil
Codc scclion 798.56, subdivision (d) For
"ffiil~~l.eto
comply with a reasor~nble rule or
regulation of the park that is part of the rental agreement or any amendment thereto." A copy
f f l ~ eOpinion filecl May 6, 2013 is attached hereto n~arlteclExhibit "7"
ancl incorporated
erein by this rererence.
On July 22, 2013, the Appellate Division issued a W r i t of Mandate directing that tile
ial court vacate its Feb~vary 14, 2013 order denying Defeadanl's sun~nlaryjudgment
otion and to enler a new order granting sulnmaly judgment in favor of Defendant and to
ter a judgment in favor of Defendanr. A copy of the Writ of klandate issued July 22,
13,is attached hereto marked Exhibit "2" and i~~corporated

Therefore,
IT IS HEREBY ORDERED TEXT:

1. The Court's order ellitred February 14, 201 3, denying Defendant's motion for
summary judgmen t is vacated;
2 . S u ~ m ~ ~judgnleot
ary
is granted in favor of Defendant on the grounds
&at
Civil
Code section 79fi.75does not apply to Defendant because Defendant was not a
purchaser of a mobilehome i11 Plaintiffs mobilehome parli, re~lderingthe 5-Day
Notice to Suri-ender pursuant to subdjvjsion (c) of 798.75 inapplicable;
3. Summaryjudgmen t js granted in favor of Defendant.
Firs1 Legal S u p p ~ f l (951)779-0100 OoIOOR013
Bonnie S h i p b ' and against plaintiff

Stubblefield Properties, a 'Calif6;nin gelleral par~neishipdba Mountain Shadouts
4. JuCg~;~enl
is entered in favor of Drfendrrl
-I
Mobile 1-lome Conununity. Plaintiff to take notking by way of its c ~ ~ ~ ~ p l a i n t .

5 . Defendant is awarded costs.
6. Any award nfattorney's fees is to br d e ~ m ~ i n by

e d way of separate notion.
MICHAELA SACHS
Hon. Michael A. Sacbs. Judge, Superior
court
.--
EXHIBIT 19
Superior Court oi California, County of
an Remardino
RULE 560 MOTIONS REMOVED FROM CALENDAR

A law and motion matter that has gone off calendar may be restored thereto only upon
notice, except in an extrnordinaty situation to be determined by the Court in its discretion.
(Former ~ u l 570,
e eff. May 27, 1982. Renumbered as Rule 560, eff. July 1,1998.)
RULE 570 RECORDS UNDER SEAL

The Court may direct the Clerk of the Superior Court to place under seal any sexually
Court to unseal the material.
explicit material filed with the Court pending a further order of
This rule shall not preclude the rights of the parties to access any material not shall it modify
their otherwise applicable discovery obligations.
(Eff. January 1,2013.)
RULE 591 ORDERS ANDJUDGMENTS
Rule 591.1 Minute Orders
Unless otherwise provided by statute or Rule of Court, the minute order granting,
denying, sustaining, overruling, or ordering off calendar, will be all that is required and no signed
order is necessary. (Former Rule 592, eff. May 27, 1982. Amended eff. July 1, 1991.
Renumbered as Rule 59 1.1 and amended, eff. July 1, 1998.)
Proposed orders shall be submitted to Judicial Assistant at the time of the hearing. If no
hearing is scheduled, the party may submit the proposed order to the clerk's office in the court
district where the matter is pending.
(EE January 1,2013.)
Rule 591.3Judgment Forms
Counsel must prepare, serve, and present to the Court forms for all orders and judgments,
which require the Court's signature. If no objection is forthcoming within ten days, the order or
judgment may be signed as presented. Complaints in intervention under the Labor Code do not
require supporting documentation.
(Former Rule 592.2, eff. May 27, 1982. Amended eff. July 1, 1991 and renumbered as Rule
591 2, eff. July 1, 1998. Renumbered as Rule 59 1 -3 and amended, eff. January 1,2013.)
%
RULE 593 CAPTIONS

Captions on orders, decrees, and judgments must refer to all matters covered by the order,
decree or judgment, and shall affirmatively state the result or relief. (Former Rule 594, eff. May
27, 1998. Renumbered as Rule 593, eff. JuIy 1, 1998.)
CIVDS_____________________
IMMEDIATE STAY REQUESTED

APPELLATE DIVISION
BONNIE SHIPLEY,
Petitioner,
v.
SUPERIOR COURT
Respondent;
Suppo
________________________________
with pr
Community, Real Party in Interest.
UDDS1204130 S-33: Michael A. Sachs
Case No. ____ _______________

(Trial Court UDDS1204130)
WRIT PETITION
[COMPLAINT]
supporting ORDER TO SHOW CAUSE
against Honorable Michael A. Sachs for
failure to comply with Writ of Mandate
entered by Appellate Division on 7/22/13;
with Proposed Order to Show Cause and
Request for Judicial Notice and Order
IMMEDIATE STAY REQUESTED

Urgency: Hearing set for April 9, 2015 - Judge Sachs will Expunge a
Lis Pendens destroying lien priority on inchoate judgment for attorney fees
950 Roble Lane
nancyduffysb@yahoo.com
805-450-0450 fax 805-965-3492
TABLE OF CONTENTS
CERTIFICATE OF INTERESTED ENTITIES OR PERSONS.............. first
1-2
WRIT ISSUES PRESENTED
Is Judge Michael Sachs guilty of contempt for failing to comply with a writ of mandate?
Can a judge use Star Chamber proceedings to convert an appellate loser into a winner?
STATEWIDE URGENCY
The moment an appellate court condones Star Chamber proceedings our judicial system
is rendered illusory---a mere travesty of justice. Petitioner prays to hold Michael Sachs
in contempt of court and refer Judge Sachs to the Committee on Judicial Performance.
PETITION .
AUTHENTICITY OF EXHIBITS ...
BENEFICIAL INTEREST OF PETITIONER, CAPACITIES OF PARTIES ........
URGENCY TO PETITIONER..
CHRONOLOGY OF PERTINENT EVENTS ..
NO ADEQUATE REMEDY AT LAW.....
18
PRAYER FOR RELIEF......
19
VERIFICATIONS ..............
20
POINTS & AUTHORITIES
21
1. Sachs was Aware of a Mandate, Had Ability to Comply and Failed to Comply.
21
2. Sachs Abused Process and Ran Star Court Proceedings for an Improper Motive ..
23
3. A Judge Must Be Disqualified When Bias is Shown in the Proceedings
25
CONCLUSION ..
26
CERTIFICATE OF WORD COUNT.
27
ii
7 0 BE FILED IN THE COURT OF APPEAL

-
I--
COURT OF APPEAL.
- -
SanBcrnsrdin A w a u r E D I S ~ R ~DM;SOI~; .
~ppel~ate~iv
~ u p o ~ r ~ o u r t ~nber:
~ose
Du@ McCarron 164780

-Nancy
950 Roble Lane
TELEPHOM
FAX No.
maJ:
805-965-3492
Michael Sachs, Stubblefield Properties
CERTIFICATE OF INTERESTED ENTITIES OR PERSONS
m INIT~ALCERTIFICATE
one):
u<
FOR COURTUSE ONLY
Bonnie Shipley
RESPONDENTIREAL PARTY IN INTEREST:
f'Cd
UDDS1204130
NO.: 805-450-0450
APPEUNT~ITIONER:
~ppell~DiV
1_, f i b
ATTORNEY OR PARTY WHO^ A ~ R N E (

Y~m
siele
, BW nmw,end amma):
APPdM
CwrtdAppeslCersNumb~
O SUPPLEMENTAL CERTIFICATE
II
Notice: Please read rules 8.208 and 8.488 before completing thk form. You may use this form for the inltiai
certificate in an appeal when you file your brief or a prebriefing motlon, application, or opposltlon to such a
motion or application in the Court of Appeal, and when you file a petitton for an extraordinary writ. You may
also use this form as a supplemental certificate when you learn of changed or additional information that m u d
be disclosed.
I. This form ISbang submitted on behalf ofthe following party (name): Petitioner
2. a.
b.
There are no hterested entities or persons h a t must be llsted in this certificate under rule 8.208.
Interested enlities or persons r e q u i ~ dto be listed under rule 8.208 are as foilows:
Full name af interested
entity or person
MicAae! ~5'~
Nature of interest
(Explain):
-
(I)
Stubblefield Ptoperties, Partners
Business BankcorpICA; see more- SEC filing Attachment 2
(2)
Stubblefield Quail Point Company
D.William Bader; Neal Baker;William Cozzo, Alan d Lane
(3) Eva Stubblefield Hazard, partner
John E. Duckworth; John Riddell; Robert L Nottingharn;
(4)
Arnold H Stubblefield, Gen Partner
John L Ridell; James W Andrews; Ruth E Adell
(5)
Thomas Parrish, General Partner
Neil Dcrry,SB Cty Supr race; Bill Postrnus;Dale Stubblefield
Continued on attachment 2.
The undersigned certifies that the above-llsted persons or entities (corporations, partnership, fims, or any other
association, but not includlna government entitles or thelr agencies) have either (1)an ownenshlp interest of 10 percent or
more In the party if It Is an entlty; or (2) a financial a other interest In the outcome of the proceeding that the justlces
should consider in detennlnlng whether to dlsqudlfy themselves, as defined i n rule 8.208(9)(2).
Date:
4-1-14
Nancy OuEfy McCarron 1 64780

(TYPE IX1 PRIM NAME)
Paga 1d l
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A P P m pev.Wrwq 1 , 2 t q
CERTIFICATE OF INTERESTED ENTITIES OR PERSONS
w.RIMS
m ~ o c nnaes
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111
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S b w L e ~ e a - e dand
* ( m y > Lode: f o r h s : & (&, 1 (or); for Ta: 1&WJ&WJ$ "(&In
beer).
Statement of Change inBeneficial Ownenhip of Securiiies

lWng Table of Coatents
. Form4
fllrRf Ss an NDGAR X1).a Document ronderl
FORM 4
UNITED STATES SECURfflES AND EXCHANGE COMMISSIQN

Wasillnghn, D.G. 20549
STATEMENT OF CHANGES IN BENEFlClAL OWNERSHIP
c - t ~ or1 n n k n g * s W
madm#.Fa+dPm 6
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humm~bnl(bk
Rlbd purmnt to B d o n lO(a}ol Ra S a s u ~ ~ w w t g eef 1934,

~ d eoalan 17C)dIbe Public
UUllty
Holdlag Company M af I835 orSefllm 30D)dlha InieQmenl Company Act of 1040
1. w
e wd Addfemaf Rcmfinu Permn*
a. lsver Name and TI*
6. Relotlowhipd RPpbflng Pmanb) to h e r

(Checkdl appllceble)
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or Tadlng Symbol
B-AN
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4. It Amendment Dete ofmnIrul Filed IMontWbayPTeer)
1 B. IndMdualor ~dntmrmpRung (M&
App(lab~8Line)
X k r m fllod by OM kporling P e m
Form filed by Morr man One Repdna
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CALIFORhTIA CASES
Arthur v. Supr Court (1965) 62 Cal.2d 404, 408. ................................................................ 2 1
Briggs v. Superior Court (193 1) 21 1 Cal. 619, 627 ............................................................. 23
In re Liu (1969) 273 C.A. 2d 135, 140 ................................................................................ 21
In re Morris (1924) 194 Cal. 63, 67 .................................................................................... 21
Ketscher v. Superior Court (1970) 9 C.A. 3d 601, 604-605 ................................................ 21
Koehler v. Superior Court (2010) 181 CA.4th 1153, 1170 ................................................. 2 1
Morelli v. Superior Court (1969) 1 Cal. 3d 328, 333. ......................................................... 2 1
Phillips v. Superior Court of Kern County (1943) 22 Cal. 2d 256, 258 .............................. 21
Vanderstok v. Bank of America (1 972) 29 C.A. 3d 73 1, 734 .............................................. 21
Weisenburg v. Molina (1976) 58 C.A. 3d 478, 489 ........................................................... 23
UNITED STATES CASES

Hicks v. Feiock (1988) 485 U.S. 624, 638 .......................................................................... 21
Offutt v. Unitedstates (1954) 348 U.S. 11,1617 ................................................................. 25
CALIFORNIA STATUTES:
Civil Code 5663 ............................................................................................................... 7, 23
Civil Code 5798.12 ........................................................................................................... 15
Civil Code $798.55 ................................................................................................. 3, 4, 5, 15
Civil Code $798.56 ........................................................................................ 15, 2 1,17, 22,26
Civil Code $798.75[c] ................................................................................................ 5, 22, 26
Code of Civil Procedure 5 1005................................................................................ 8, 23, 26
IS SUES PRESENTED IN PETITION [COMPLAINT]

FOR ORDER TO SHOW CAUSE IN RE CONTEMPT
Is Judge Michael Sachs guilty of contempt for failing to comply with a writ of mandate?
Can a judge use Star ~hamber'proceedings to convert an appellate loser into a winner?
STATEWIDE URGENCY
"Our legal system is based on the principle that an independent, fair and competent
judiciary will interpret and apply the laws that govern-us. The role of the judiciary is
central to American concepts of justice and the rule of law. Intrinsic to this code
are the precepts that j udges, individually and collectively, must respect and honor the
judicial office as a public trust and strive to enhance and maintain confidence in our
legal system. The judge is an arbiter of facts and law for the resolution of disputes and
a highly visible inember of government under the rule of law." Code of Judicial Ethics,
Preamble revised, effective January 1, 20 13
"A public office is a public trust." from Public &orruption-~aximizin~
~emedies
by Michael Sachs, Esq. Chief Deputy County Counsel and Leonard Gumport, E S ~ . ~
With 7 years as a Judge and 13 year as County Counsel Sachs knew he could not run a
Stur Chamber court, disregarding codes, rules and due process. Sachs knew he could not
thumb his nose at this court's Writ of Mandate or revise a statute by proclamation---through
interjecting the words or resident into Civil 798.56(d) to carve a new way for Stubblefield
to summarily evict residents [Shipley] under a code applying only to mobile home owners.
Star Chamber Court [l 5thcentury] was permitted to inflict any punishment except death. without
being bound by normal court rules or procedures. Laws were enacted by proclamation. It evolved
into a political weapon, symbol of abuse---instrument of oppression rather than justice. In 1641
Long Parliament abolished the Star Chamher Court in the Habeas Corpus Act of 1640. "Modernly,
it is used metaphorically to describe a runaway court, where a judge disregards codes, civil
procedures, rules of court, or attempts to revise statutes by proclamation."
http://en. wikipedja.org/wiki/Star-Chamber
presented by Michael Sachs on 9/14/05 at County Counsels' 2005 Annual Meeting in Los Ciatos
These ukra vires acts violated Separation of Powers, CA Constitution, Article 111 3.3
Evidence presented in petitioner's verified complaint will show that Department S-33 is
a runaway court where Michael Sachs disregards codes, civil procedures, rules of court,
waives statutory deadlines, and revises statutes by proclamation as the advocate for a party.
The moment an appellate court condones Star Chamber proceedings our judicial
system is rendered illusory---a mere travesty ofjustice. Petitioner prays to hold Sachs in
contempt of court and refer Judge Sachs to the Committee on Judicial Performance. 4
Sachs violated the Code of Judicial Ethics and his oath of office with serial improprieties.
"All members of the judiciary must comply with the code. Compliance is required
to preserve the integrity of the bench and to ensure the confidence of the public." CJE
"Candidate for judicial office" is a person seeking election to or retention of iudicial
office. CJE Sachs fears billionaire developer Stubblefield will fund an opponent during
his next 6-year election campaign. Sachs put retention of iudicial office above the law.
Sachs invited real party to compose an order to convert its loss into a win by paraphrasing
findings of fact and legal conclusions from the trial court and appellate division orders.
Sachs vacated Judge Alvarez's 10/2 1/ 13 order without any pending motion, having no
jurisdiction to vacate after 60 days. Judge Sachs revised Civil 798.56(d) by adding the
word resident to carve out a new eviction remedy for Stubblefield to use against Shipley.
Sachs deprived Shipley of her right as prevailing party to submit the proposed judgment.
Sachs entered judgment 3/20/14--a day after real par@ delivered it exparte to chambers.
Sachs refused to accept objections when Shipley tried to file them the next day--3/21/14.
Thc powers of state government are legislative, executive, and judicial. Persons charged with the
exercise of one power may not exercise either of the others except as permitted by this Constitution.
"Whether disciplinary action is appropriate, and the degree of discipline to be imposed

requires a reasoned application of the text and consideration of such factors as seriousness of the
transgression, whether there is a pattern of improper activity, and the effect of the improper
activity on others or on the judicial system." CJE, page 3, Improprietv includes conduct that
violates the law, court rules, or provisions of this code, and conduct that undermines
a judge's independence, integrity, or impartiality. Canons 2,2A Comment,2B, 2C
PETITION (COMPLAINT) FOR OSC IN RE CONTEMPT

AUTHENTICITY OF EXHIBITS
1.
All exhibits under separate cover accompanying this verified petition are true
and correct copies of original documents on file in respondent court or are transcripts.
The cited Ohio Supreme Court case [State Ex Rel Cincinnati Enquirer] is submitted
by way of a Request for Judicial Notice and Proposed Order pursuant to Rule 8.809.
BENEFICIAL INTEREST OF PETITIONER;
CAPACITIES OF RESPOIVDENT AND REAL PARTY I
N INTEREST
2.
Petitioner is defendant in an action in respondent court [Dept. S-331 entitled,
Stubblefield a California General Partnership v. Bonnie Shipley

UDDS 1204130, a summary eviction. Real Party in Interest is plaintiff below.
Respondent is Michael Sachs, Judge in S-33 presiding over petitioner's case and
is the alleged contemnor. San Bernardino Superior court is the respondent court.
URGENCY TO PETITIONER
3.
Absent intervention by this court Shipley will be subjected to yet another wrongful
eviction by Stubblefield, after having been rescued from one last year by this Division
when it granted her petition on 5/6/13. Exhibit 1
Shipley will also be subjected to
Star Court proceedings in which she will be deprived of any due process right to object
to orders before they are entered, to have rules of court and codes of procedure applied,
and to unbiased rulings. Shipley seeks an immediate STAY of all proceedings below
because on April 9,20 14 Judge Sachs will sign an order to expunge her lis pendens and
award $6,500 in fees against her to appease Stubblefield. Shipley will lose her priority
[first to record] as to her anticipated money judgment against Stubblefield for attorney
fees she is entitled to as prevailing party under Civil $798.85. Sachs carved out a new
remedy for Stubblefield to summarily evict any resident by interjecting the words
"or resident" into subsection [dl of Civil $798.56----a statutory remedy which can only
be used to evict homeowners until Sachs expanded [dl to be used against any resident.
CHRONOLOGY OF PERTINENT EVENTS
4.
On 8/1/12 petitioner moved in as co-resident of a mobile home owner at Space 333

in real party's park. The owner had a series of co-residents who shared the home since
she bought it in 2005. The next day owner delivered petitioner's signed co-resident
application package which she picked up the day before. It was the same co-resident
package owner had used to register all prior co-residents since 2005. Later that day,
while owner was away, the park's manager tried to orally evict petitioner by threatening
to lock her out of the park if she did not move out the next day. He told petitioner if she
wanted to reside in the park she had to find and move in with a "sugar daddy over 55."
5.
On 811 1/12 a 5-day Notice to Surrender Possession was nailed to the mobilehome,
citing Civil Code 798.75[c] as the basis for a summary eviction. It was invalid as [c]
applied only to apurchaser or transferee who occupied a home without first executing
a park lease. Despite written warning to counsel of the invalidity he served a sham
forcible detainer complaint 8/27/12. A demurrer for invalidity was denied by the court.
6.
After enduring 6 months of scorched earth litigation tactics, defendant petitioned

the Appellate Division to reverse denial of summary Judgment on a wrongfbl eviction.
On 516113 her petition was granted. Exhibit 1 The Division found Civil $798.75[c] did
not apply as petitioner was not an owner or transferee and not an "unlawful occupant."
" T h trial
murf nlisintefpl-eted CWIICrnde sectloo 79A 75'
This fa:&^.
applies onEy ta a pursl-raw.r oor traqsf@weof a m~bilrhomeunit that w u p i e s the

paMs
spom withaut firat exe~tatinga wrrnen lease
~ s e e r n ~ wdR
n l the pa&.
Peetltloner ks not a ybr~haserar transt"eme d the subject mobabhme. Therefore,
the -Day Natioe ta Surrender n mvafief bemuse k rs based upon an snappir&le

statute. Aa suck, the @vietien of Pet~timerby Stlahblcfi@ldunder @iwi Code
secfran 79B.75
15not
authorired.
4 Exh.1, p.1.9
The 5/6/13 order recited, "As the sublessee of a mobile home owner petitioner does
not fall within the category of an unlawful occupant." Exhibit 1, page 1.7
7. Division found Stubblefield could not evict Shipley directly absent privity of contract.
ID
adddmn te, the above Stubhiefield
cannot clrrecfly
slrrct Petitioner
bemuse there ts ma pprivbty btv?wnStubbCf~eidand Petltnaner-4 e StukBefreM
is not the legal owner d t f i ~rnobtlehme u n t in which Pet~%im@r

rs an wctjpa&.
4~
~ 1, h 1.8.
8. Because Stubblefield argued in opposition to Shipley's writ that he had no other way to
evict Shipley, the Division opined that Stubblefield was not without an MRL remedy.
Sliltablefreid's r m ~ d yurader the Msbiiehemo Resirns~tcyL:IW is to prated
against the b m a w n e r in a@crsrdancE w"%h Cwil Gode sa.etba0 798 $6,
subdrvis~on(d) b
r "kfrtl5ure of tine hsmm8ter or res~der-itto c ~ m p l ywitk a
reasonable rbie or regufatwn of the park that a pa& af the rental agreement
or
any arnend~nerttthereto."
4Exh. 1, p. 1.9
The Division expressed no opinion as to the reasonableness of Stubblefield's rules.
'we eYpre$s
00 opin on re~sdslrgtPe rsascrrrabieness of $twbblehdEbsrules or r@jiulaaonr,as

s%h a delernkratraa 8s no[ rekvani of naciesB,y b al,r W X U S l w 7
4 p. 1.9 fn2
More importantly the Division never held Shipley was an unlawful occupant.
To the contrary, it expressly found that Shipley did not fall within such definition.
mohilethome pursusni to tkrs chapter" As a sublessee 0%a mahilehome owner,
Pet~tronerd w s not dalii within t h definition
~
caf an **un~eu&lmx-upant"
9.
4Exh. 1, p. 1.7
The Division recited verbatim the trial court's erroneous finding as follows:
"
Rather the court found that Section 798.75, subdivision [c]

'is not limited in its application , only in the escrow, sale or tran~fer
of a mobile home. It applies when an occupant'of a mobile home has
no right of tenancy and is not otherwise entitled to occupy the mobile
Exhibit 1, p. 1.5
home pursuant to this chapter.' "
Most importantly the trial court never held Shipley was an unlawful occupant either.
On 2/14/13 the trial court denied real party's summary judgment motion based on arguing
petitioner was an unlawful occupant subject to summary eviction. If the trial court had
found petitioner
an unlawful occupant the court would have granted Stubblefield's
motion for summary judgment. The court denied Stubblefield's motion, to let a jury
decide if Shipley's occupancy was unlawful for violating a reasonable rule.
10.
On 7/22/13 the Appellate Division issued a Writ of Mandate directing the trial court
to vacate its order denying summary judgment and enter a new order granting summary
judgment and judgment for Shipley on the merits with costs. Exhibit 2, p. 2.1-2.1
1 1.
Due to real party's appeal of the Writ to the Second District Court of Appeal and the
California Supreme Court, it took the trial court until October 2 1, 20 13 to comply with the
Writ of Mandate by entering a minute order vacating denial of Shipley's MSJ and granting
summary judgment. Exh. 3.1 The S-32 clerk served the court's order on all parties by
mail the next day on 10/22/12 Exh. 3, pg. 3.3 This service triggered the clock on real
party's window to appeal [60 days under CRC 8.1041 or to move to vacate the order under
Civil 663(a)(2). [I5 days from service by court clerk]. Real party failed to appeal or
move to vacate or set aside the 10/21/13 order. Subsection (b) of Civil Code $663 recites,
"thepower of the court to rule on a motion to set aside and vacate a judgment
shall expire 60 daysfrom the mailing of notice of entry of judgment by the clerk."
The trial court's power to vacate the order expired on 12/23/13. No judge had the
power to waive a legislatively imposed statute of limitations for any party---not even the
almighty Stubblefield--even if it served to bolster the security of his own judicial office.
No judge we have encountered since this case commenced seems to have the courage to
I
sign an order against Stubblefield, unless helshe is ordered to do so by an appellate panel.

12.
Moreover, no judge may grant an order to vacate another judge's order, even if the
statute of limitations had not yet expired. unless moving party served notice of motion
under CCP 5 1005 on his opponent, reciting statutory grounds for relief. CRC 3.1 10.
CRC 3.1300. Under CRC 3.20 local rules cannot preempt California's Rules of Court.
13.
Two weeks after the S-32 clerk mailed notice of Judge Alvarez' order on parties,
reciting DEFENDANTMOVING PARTY to prepare JUDGMENT," on Nov. 4,201 3

Shipley submitted a proposed JUDGMENT to Alvarez with real party's objections and its
alternate proposed judgment. Exhibit 4 Judge Alvarez never signed any order presented,
and never colnposed his own judgment to comply with the writ of mandate.
14.
On 1/7/14 Shipley's Fee Motion, originally set 7/2/13 finally came on for hearing
six months after it was originally set. McCarron asked Judge Alvarez to recuse himself as
a presumption of bias arises when a Judge is reversed. Shipley was afraid Alvarez would
significantly cut her attorney fees as he had done in otherpro bono cases, forcing appeals.
Alvarez voluntarily recused himself and self-assigned his own replacement; i.e. Michael
Sachs in S-33---right next door to his S-32 court. It was continued to 2110i14. Exhibit 5
Shipley was surprised as she thought the presiding judge re-assigned judges, as required
under Local Rule 530 Exhibit 19.1 [presiding judge re-assigns all judges].
This was the
first hint that "something was rotten in Denmark." Why did he assign a buddy next door?
Why wasn't re-assignment presented to the presiding judge as required in Local Rule 530?
On 2110i14 McCarron appeared with 3 JUDGMENTS in the same format as submitted
to Judge Alvarez on 1114113---except the words prevailingparty had been deleted as real
party objected to it in November. "Donald Alvarez" was replaced with "Judge of the San
Bernardino Superior Court." Exhibit 6.1 Sachs refused to sign any of them. Exhibit 7.1
The Minute Order recited, "counsel for plainlift0 submit proposed judgnzent to the court."
Sachs continued it to 2119114---9 days later. Prevailing party is to propose all orders.
CRC 3.1312. Sachs ignored this rule of court.
15.
Sachs runs Star Court proceedings.
On 2- 19-14 McCarron objected to Sachs' revisiting summary judgment 5 months later.

Exh.8,8.5 McCarron notifjed Judge Sachs that he had no jurisdiction to amend an order
as real party's time to appeal or vacate Judge Alvarez's entry of summary judgment order
had expired 3 months earlier and that he could not rewrite findings made by either Judge
Alvarez at the trial court or Appellate Division's findings. Exh. 8,8.5: 16; p.8.6:9
McCarron suggested Sachs merely recite the Division's two-sentence directives and attach
the Appellate Division order with its Writ as Exhibits 1 and 2 for clarity. Exhibit 8,8.7: 1.
McCarron told Sachs again he had no jurisdiction to paraphrase or add findings not recited
in the trial court or Division's orders. Exhibit 8,8.11:22. Sachs replied, "I don't want to
reargue what we just did." Exhibit 8,8.7:10.
16.
Sachs runs Star Court proceedings.
The 2119/14 Minute Order recited, "counselfor plaintzflto prepare judgment as
proposed by court" by 3/5/14. Objections shall be due no later than 3/12/14. Sachs
insisted that plaintiffs counsel compose the judgment violating CRC 3.13 12 --reciting
"prevailing party to prepare." Who ever heard of a Judge asking the loser to compose the
final judgment? No unbiased judge does this. Sachs runs Star Court proceedings.
17.
On 3/4/14 real party submitted its proposed judgment, artfully paraphrasing the trial
court and Division's findings to fabricate the appearance that both courts found Shipley
was an unlawful occupant. Neither court made such finding. Exh. 10, p. 10.2
18.
On 3/4/14 petitioner filed objections, highlighting in TKFI'H) real party insertion of the
words such as defendant in its artfully paraphrased version of the 2114/13 transcript.
Exh. 11.1. The words such as defendant did not appear in the 2114113 court transcript.
Real party artfully paraphrased Division's findings to create a pretext that it found Shipley
was a sublessee of the mobilehome which was not its finding. The Division found
"As a sublessee of the mobilehome owner Petitioner does not fall within the definition
of an ''unlawful occupant."
mobilehome pursuant to this chapter.- As a sublessee of a mobilehome owner.
Petrtioner does not faif within the definition of an "un!avrful occupant."
4Exh. 1, p. 1.7
McCarron submitted an alternate order to ~ a c h accurately

s
reciting trial court and Division
findings by quoting verbatim fiom a transcript and Appellate Division's orders. Exh. 11.5
Sachs refused to even consider or discuss petitioner's proposed order. Sachs would only
consider plaintiff's &lly
paraphrased versions. Sachs runs Star Court proceedings.
19. March 17,20 14 McCarron appeared a third time for more Star Court proceedings.
Transcript shows bias to Mrs. McCarron and deference to Mr. Williamson. Exhibit 17
Throughout Star Chamber Proceedings Sachs addressed Mr. Williamson as Counsel
yet addressed McCarron as "ma 'am " in a loud, misogynist, condescending tone of voic,e.
not !tic case ~ t B>"nle
h
?- pley. 3oflnlr S ~ I @ I
+
s tlul a
juZ3sw
tsir ~nobilzhome, mrr**se *nay be I. s&djlrsrcc st
Q*
hlsl-ic~t";La,2'(C'
-Wvc, -ss %h&t

phone'~ -ou need Pu I S & ~
T32L60,Vs
.s gulng 10 go off
t c - n ~ r%$pley 5 s aubiess;.e of
PcL%?PL?, zrxr awnel iqho 15 tgi a vdlld lea?%u, 111 $hepat *.
the cou2:aan1ur
33:i-e
"IS. Pd~ni7pC;'d
a %blessee ;leal y 'd<e ol?z?ie 7 . 2 A thal
but Ye 5
-- thac -' xor15&ues31~eP..:he raue ,a: -~ r C eC Y W -
~2~~
r-e cC;m-,
about.
let 1710 '&I%*,
{DU
%q~a'ain:
tka,
%=CBRPO'1'
W 5
*@*atwe
n8aDrlr hame as.; @,atr.'Cca;ta:~
WILI do
932jl11
15
we
k.:! C r Q S
PO,t
lier+*
I Ihtfl- that IS
art&& ,&at vou i u SC'C

~ ;r7?
"14 YctA1<4L%. Than&+a., eot*e:t.
kip, i%":L:L'JfMCn3N:
iV&
--
?I%a%&dalke 4 to rav that so the*
y5.W:i.R.'~v?d
can ~s;;I? apaew eva:yb;",f
elsf, Zee what they *at*< 3 b%
hets, the+ 10% a t e RP,, WOL-IUltkr
-.
%E C'~-*L~RT
EuCus& ine, 9-?aa?'
V5 '+X'rhP"CSi
(,nay
t
T-E
r~m-:
What a d .ou
w!L,:~J~~~PJ:
T%-L you, ,aut
T;(% @$a$
($2 codat
na%?'osav7
- t s l r
Itndir?;
T1'E CXdri-. :an>asng ,?PGr tfie wu:t tindl~',, I atr

raadiPy :as ae have t #-;'it R e # e
'4%. KLL;P@7%3FI: irk \ri% B %bl&sW 01 ?he *3*SLze
horna ahat%%as
awned bd '%j
:*c::a.<urr
,
and thar uar the erto'e
brs~sop he, scrupsncf @ ' p r PIC^??^ "zemah8
te'r co~i8tt e ~ h d
Ihal r*?eappellare d r&sn t ~ ~ thar

r ~ r de *si3n'c r.anl'%l W
r h/an-E
af 6??3 a
,:'
T ~ E % , ~ T '~z-rece
t*d:L;b.I.I5TN.
M:
a
:
$
:'.Ki
GB
Of
7Sic dldrl r a;c
a put ;hasor of the mobile hnt'lre +t
i' trg ?f-
I 3-mea.a,MI,'.; a transrelee, beng a sublessee Bf
rrho U&T,,i the 1%),?3rlB

hQlT,6? h a 15 lllO4WlnQ%Tsr: ZO 5 1 % ~
the1 e. t-we pvasuo pati w'ae &nd#lr+oii Pa:.
su&+ssw. a
* B 3 B 5-3
she .s
s'u&rfi&-ct3 ~^~C;U;V lne flrobtlr hulna eve " Pi?
ssae
T-E ;D.,W
?:ooi??a,:hat's
(1%
T@&8s nhat I alrr g&ng to Jo. >&!ftaaflr
pur:ti55e$ 01
it-anefrrse
o t ?e sub:&:t
,was not a
malo! hc+w prlK.4.

-ha$ ir what 18-eapkellat* c-s,it deter %?*;.rn; hpprllale
C O UF
~ ee
;*-,
4 counselv. rnu'unz Exh. 12, pg. 12.3, 12.4
Disparate treatment of female attorneys does not comport with Code of Judicial Ethics.
20. The transcript shows when McCarron tried to object to Williamson's paraphrasing of
Division findings Sachs interrupted to suppress recording her objection on a transcript.
I-IS. 14cCARRON: They would B~kert to say t h a t so they
wr? use it a g a ~ n s teverybody else. See what they want t o d o

ket-e, they lost and t h e y ~voutdlrke - -
THE COURT: Exctrse mil, rna'arn.

MS. I4cCARRON: Okay
4
THE COURT: W h a t did yacr w a r ~ to
t say?
LIR. baJiiLIAId%Se3N:Thank you, your- Honor.
4 Exh. 12. pg. 12.4
Sachs actively facilitated Williamson's distortion of Division findings on the record.

That was the coun finding.
THE CDLJRT: 1 arm gsslng off .af t h e court finding, I an7

reading it as we have it right here.
MR. WILLIAMSON: S h e was a sublessee of t h e mobile
home that was 0 ~ 1 7 e dby &Is. IvtcLarron and that was t h e whale
bass d her omispancy *sf the. ~ i o b ~nome
le
and the caul%found
that, the appellate diwsion found that she wasn't transferee
of the ~nobitelaorne.
THE LDURT: Correct
MR. WILLIAMSON: Or a purchaser of tlse mob~tehame

vdhy the 798. J S ( c ) didn't apply to laer-.
is
I mean,. being a transferee, being a sublessee af

MeCar-ran ~ h owns
o
the mobile
hanie that is alla~uingher to stay
there, there was ns~paiticutaz- finding on that. S h e is a

sublessee, a subtenant to occupy the mob~lehame even ~fshe
was a sublessee
THE COURT: Counsel, that's fine.
This i s what I a m going to do: Defendant was not a

purchaser or a transferee of the subject motor home period.
That 1s what the appellate court determined, our appellate
corrrt here,
4 distortion, Exh.12, 12.
Williamson intentionally lied when he said "there was no particular finding on that."
2 1. Williamson & Sachs knew there
a particular finding on the issue; i.e. Division held
Shipley was a sublessee or subtenant of McCarron----not of the mobile home itself:

8;rp in
her name and she p ~ y far

s them Thus, Petitiooefo evidence establishes
that she is, in effect, a sublsssee or sub%enar?tof McGarron and that McCarran is
the owner of the m&ilaR~r~e
locatd at spa- 833 d SPrlbblefieEel's mubikharne
gak pursuant to a Ie8w agreement between McGarron and StubbkeB~ld,
22.
4Exh. 1 , 1.4
Williamson and Sachs knew Division found Shipley was not an unlawful occupant:
tenanq
Thus, this "unlawful occupant" @.a pu~~haser

without a has@
agrtwantsq a an occupant that
"IS
nat o!bwAse sn:k21&
to @M;klgy tale
mobilehome purswanl b ih%s~tssptsr'" As a sublessee af a rnobriehome orwner,
23.
Sachs rebuffed McCarron's demand that quotes of findings inust recite entire sentences.
'af vlle are going to quare, let's quo:e the whole
se17tence.
THE COURT: LVe don't need t o q ~ o t e
because t h e whole
decisrr~nis tncorporatea by reference so we don'tneed to

quote.
MS. MeCARFZQNr Tt~ankyou, your Hanor. I just
want n7.g win t o be turned inta a wrn for them, that
don't
$5 what
they are t r y n g 5~ do.

THE COURT: Well -MS, b l l r U R R O N :
They tost. They can't try to turnil-
into a win by having you paraphrase --
26
THE COURT: E x u s e me, ma'am, we are not talking
6
" 1 h o u t that. We are tqting to get this j:~dgrnent finalrrecl.
24.
4 Exh. 12, 12.5
Sachs facilitated Williamson's distortion of Judge Alvarez' findings by refusing to

cross out the words, "such as defendant" in Williamson's paraphrasing of his findings
to create a pretext that Judge Alvarez had found that Shipley was an unlawful occupant.
Judge Alvarez never made any such finding. He set trial for a jury to decide the factual
issue of whether or not McCarron "regularly occupied'' the mobile home under the rule.
25. Division quoted Alvarez' finding verbatim. Exh.l.5 There is no "such as defendant" in it:
At kt-@
Rearitq on Petit~oner'smotion fm wrstmapy judgment, the crsufl
found, srnong &her thngs, that G k ~Code

l
S
~ I O R
788.79
citcurnslanceo where owrsrer?ghi@rs transfewd

Section 328 7%.swilrisrsn (c)
ssxdw, $are sr transfer of
does not appb only to
Rather, tba
COU& found that
not lmrled in its applrcation. only ria t k
"IS
a rnobde home. It
agpiles wf~enan uccupant a[ a
mobile h m e bas tla srght of tenancy and a not btherwrse e&rt$ad to occupy th@
rn~btleAame pursuant
Msrs c)l&pl$a
-hFit's C~vllCode 798.75(~). ThLs chapter
as defendant not in here
The 2/14/13 transcript of Judge Alvarez's ruling recites exactly the language quoted above.
26. When McCarron pointed out this distortion Sachs flat out denied there was a distortion.
MS. McCdRRON: Okay. LVhaP about he first thr-ee
sentences whei-e they parapt'irassd ~tand they added :he word
such as Defendant':
W E COURT: It
IS
~rr~levant.
MS. McCARROPi: Why 1s
I?
THE COURT: Becavse that
lrreleirant:
was 3uclge A1~are.z'declsaon
~.ihrchwas. in fact, oberturnetl hy t h e court so wt~ater/erthat

says
I;
is realiy ~r-relevant.
MS. McCARW0E.I: Eut vdhgr have something Ln there :ha:
wasn't sale? That rs n o t nct-it

THE COURT: I 4e:le.e tr
27.
15 accurate.
4 Exh. 12.6 Sachs left in such as defendant
Sachs facilitated Williamson's distortion of Judge Alvarez' and the Division's findings
by approving Willia~nson'sparaphrasing of both courts' findings to create a pretext both
courts found Shipley was an "unlawful occupant" not entitled to reside under park rules.
Sachs asked his Deputy to copy the notes he made on his working copy of the proposed
order Williamson delivered to his chambers previously. Exhibit 13. On page 13.2: line 13
Sachs cleverly inserted the words "or resident" to carve a new summary eviction remedy
into a statute for Stubblefield that even his attorney Williamson did not think of inserting:
BY SUCH CONTRIVANCE SACHS STEPPED OUT OF A ROLE AS INDEPENDENT

JUDGE AND 1vTO THE ROLE OF ADVOCATE FOR PLAINTIFF STUBBLEFIELD.
I
By such contrivance, Sachs judicially authorized Stubblefield to proceed directly

against any resident under Civil 798.56[d] - a statute only applying to homeowners.
I
5798.56. keasons for termination of tenancy; written notice; cure of default

A tenanc3 shall be terminated by the management only for one or more
of the folllowingreasons:
~~.
(d) Failure of the homeowner or resident to comply with a reasonable rule or

regulation of the park that is part of the rental agreement or any amendment thereto.
9798.12. Tenancy
Tenancy is the right of a homeowner to the use of a site within a mobilehome park on
which to locate, maintain, and occupy a mobilehome, site improvements, and accessory
structures for human habitation, including the use of the services and facilities of the park.
Civil $798.55 and $798.56 apply only to homeowner tenancies and expressly refers to
termination of tenancy --- not occupancy. Stubblefield cannot directly evict a resident
who is not a homeowner because there is no privity of contract where she is not his tenant.
Such eviction is an illegal nullity as explained by the Division in its Writ of Mandate:
In addrtmn ta #e above Stubblefil$eld cannot drrecw @wdPetittoner
b&ause there xa
lp0
pr~wttybetween StubblefieM and PetRsner-4 e . StuStPbT@&
is not Vle legal ovmer of the rnob~lehasunit in which Pelibwlef is an occupant.
28.
4 E*.
1, .8
Sachs' carving out a new summary eviction remedy for Stubblefield violated not only
his Judicial Oath to be impartial, but also Article 3, $3 of our Constitution---Separation of
Powers Clause. Sachs had no power to revise $798.56 by a naked proclamation, or convert
Stubblefield's loss to a win by authorizing a way to evict Shipley directly. To guarantee his
gift was entered on the docket before Shipley could object Sachs orchestrated the following:
I
On 3/17/14 Sachs made a bizarre journal entry "jiles retained in department"
Exh. 17.1
Sachs could exercise exclusive control over what documents were accepted for filing.
I
Williamson hired "First Legal Support" to deliver the order exparte. Exhibits 15.4 & 18.4
He could thdn shift the blame for violating CRC 3.1 13,3.1201 & Local Rule 591.3 to FLS.
FLS delivered a judgment exparte on 3/20/14. Sachs signed it immediately. Exh. 18.4
29.
Williamson knew if he tried to file a proposed final judgment at the filing window it
may be rejected because it failed to comply with CRC 3.1 13, 3.120 1 and Local Rule 59 1.3.
McCarron did not receive Williamson's proposed Judgment until Friday morning 3/21/14.
McCarron immediately composed objections and emailed them to Shipley to print out and
deliver to the court. Shipley was unable to file objections at the filing window because of
Sachs' bizarre 3/17/14 journal entry; i.e. all files would be kept in S-33---not downstairs.
Shipley took her objections up to S-33. A clerk told her she had to wait outside the court
while she checked with Judge Sachs; the clerk returned to tell Shipley she could not accept
- Sachs signedlentered the order the day before on 3120114.
her obiections for filing as Judge
Because the S-33 clerk refused to accept objections for filing Shipley delivered objections
to Appellate Division by dropping them in a drop box as the Division had closed at 3:OO.
Sachs' refusal to accept Shipley's objections for filing, only pne day after he accepted
Williamson's proposed Judgment exparte in his chambers, violated CRC 3.130 (d):
(d) Filing of late papers No paper may be rejected for filing on the ground
that it was untimely submitted for filing. If the court, in its discretion, refuses
to consider a late filed paper, the minutes or order must so indicate
If objections were late Sachs was still required to accept them for filing. Objections were
not late because under Local Rule 591.3 Sachs was required to wait at least 10 days before
entering a final judgment. Exhibit 19.3 Sachs runs Star Court proceedings.
30.
On Friday 3/21/14 McCarron printed Shipley's online case docket. Exhibit 17.1
There was no journal entry reciting that on 3/20/14 a judgment had been entered.
On Monday, 3124114 there was still no journal entry reciting a 3120114 entry of a judgment.
McCarron called Marsha Lenihan, Legal Processing Supervisor, right before 4:00 p.m. to
ask why there was no-journal entry by 3124114 on a judgment purportedly entered 3120/14.
The next day (Tuesday) Marsha Lenihan notified McCarron a journal entry would appear
on the docket showing entry of Judgment on 3120114 and would be available that evening.
As of 412114 there was still no camera image icon to click on to download the document.
Finally, on Friday McCarron received plaintiffs "Notice of Ruling" by mail. Exhibit 18
On 412114 Shipley drove over to court to obtain a copy of the judgment signed on 3120114.
31.
The clerk at the filing window said she could not provide a copy of any document in her file
because Sachs' ordered her files to be maintained upstairs in Department S-33. Shipley went
upstairs to S-33. The clerk in S-33 told Shipley she had to go downstairs to get documents.
Shipley told the S-33 clerk she had already been downstairs and they had sent her upstairs.
The S-33 clerk said to come back the next day. When Shipley came back to S-33 the next
day the S-33 clerk told Shipley she could download the judgment at the court's website.
Shipley told her there was no camera image icon to click on as the judgment had not been
scanned into the case docket. The clerk told Shipley she had to return the next day again.
On Friday April 5.2014 Shipley returned to S-33. The S-33 clerk told her she did not have
the document. After having made 3 ROUND TRIPS to court, Shipley was unable to get a
copy of a final judgment where she is prevailing party. Sachs runs Star Court proceedings.
32.
On 4/1/14 plaintiffs counsel served McCarron with Notice of Ruling by mail. Exhibit 17
Williamson caught on to Sachs' cue to carve out a new remedy for his client Stubblefield to
evict Shipley directly. Williamson had not yet conjured up such a sneaky trick but Judge
Sachs didn't miss his opportunity to curry favor with the billionaire developer by artfully
inserting the words "orresident" into his judge notes given to both attorneys Exh. 13.2
33.
After 7 years as judge and 13 years as Chief Deputy of County Counsel's litigation team
Sachs knew the limits of his power and that he could not revise a statute by proclamation,
and he could not advocate for a party by inserting words into a statute to carve a remedy.
Sachs knew his power to vacate Judge Alvarez's order expired 60 days after it was entered
and that it violated a judicial oath he signed to uphold the law, court rules & civil procedures.
Sachs runs Star Court proceedings. Plaintiff added the words Sachs inserted, "Plaintiff
may proceed directly against the homeowner
resident under Civil Code section 798.56.. ."
mohilebun?t. PfainlifT'rnay picce~drliieectly against al:c hanrc;\~voerur wsroeot ~radcrCluil
rcplatim of ~ J I Epark ?hat is p.& d'ttie r r d d i a$recimes~t. ~any

t &rnm?~~s%iglent
thereto " A & q > y
9f
th- Opkwn Rfed Mby 6, '1013
I:erer:~1:y fl)ls 4 k t ~ ~ c .
jb
ilt?achc~hew16 i ~ e r k ~kx?!kit
d
"1.' ;.:?d i n l a ~ ~ r s t e d
4 Exhibit 18.5
34.
Shipley was the prevailing party under the Writ of Mandate. Yet, in his Star proceedings
Sachs carved a new summary eviction remedy [applying only to homeowners] to be used
directly against any resident deemed to be an "unlawful resident" for "violating a rule."
Petitioner is now subject to another summary eviction by Stubblefield under a statute that
clearly does not apply as she is not a homeowner but was expressly authorized by Sachs.
Sachs artfblly converted LOSER Stubblefield into a WINNER because he got exactly
what he set out to get when he first filed a sham complaint against Shipley; i.e. carving out
a new remedy to summarily evict any resident by labeling her as an "unlawful occupant."
Stubblefield now has a 3-page order signed by a Judicial Officer reciting that Judge
Alvarez found Shipley an "unlawful resident" and the Division authorized summary
eviction directly against a resident by yet another code section which does not apply.
35.
Shipley and her counsel fought like gladiators through two years of scorched earth
litigation tactics, and prevailed through all levels of the appellate process, just to have her
win converted to a loss because Sachs gave the green light to Stubbletield to evict her.
THIS IS A TRAVESTY OF JUSTICE BEGGING FOR CONTEMPT CHARGES.

NO ADEQUATE REMEDY AT LAW
36.
Petitioner has no adequate remedy at law for the relief sought in this Petition other than
an Order to Show Cause in re Contempt to compel compliance with the Division's Writ of
Mandate issued nearly a year ago on 516113 by ordering Sachs to vacate the judgment he
entered on 3120114 [Exhibit 18.41 in violation of the Separation of Powers Clause of the
California Constitution, Article 3, $3 as well as Rules of Court, Codes of Civil Procedure,
statutes of limitations and due process. Absent relief by the Appellate Division Shipley
will be subjected to Star Court Proceedings in a runaway court where the Judge acts as
advocate for the opposing party disregarding the law, rules, procedures and due process.
Unless this Division orders an IMMEDIATE STAY on all proceedings, on April 9,2014
Judge Sachs will order Shipley's lispendens expunged and award $6,500 in attorney fees
to Stubblefield. Shipley will lose priority on an inchoate judgment for her attorney fees.
PRAYER FOR REI,IEF

WHEREFORT,, petitioner [complainant] prays for this Court to:
1.
ISSUE AN IMMEDIATE STAY of all proceedings below pending resolution of the
petition (complaint) for Order to Show Cause in re contempt of Judge Michael A. Sachs.
2.
ISSUE AN ORDER TO SHOW CAUSE IN RE CONTEMPT commanding Michael
Sachs to appear before the Appellate Division to Show Cause why he should not be held in
Contempt of the Divisiol~for failing to comply with Writ of Mandate issued July 22, 201 3
pursuant to a Decision the Appellate Division entered on May 6, 20 13 and to consider the
petition (complaint) also an appeal of a Judgment Sachs entered below on March 20,2014.
3.
DIRECT Respondent Court [Michael A. Sachs] to vacate its order entered on 3/20/14
in violation of this Court's Writ of Mandate issued July 22, 20 13, in violation of Rules of
Court, Codes of Civil Procedure, Statutes of 1,imitations. and which exceeds jurisdiction
under Separation of Powers Clause of the California Constitution, Article 3. $3.
4. DIRECT Respondent Court [Michael A, Sachs] to enter Judgment on the merits as
presented by prevailing party on 2110114 at the first hearing in S-33 included as Exhibit 6.1.
5.
DIRECT Responderlt Court [Michael A. Sachs] to enter. in a new order, an award for
petitioner's attorney Sees as prevailing party in all proceeding below, including appeals
and writ proceedings, in an amount to be determined by separate motion at a later date.
6. DIRECT Respondent Court [Michael A. Sachs] to cnter, in a new order, an award for
petitioner's costs incurred as prevailing party in all proceedings below, including appeals
and ~vritproceedings, in an amount to be determined by filing a memorandum of costs.
7. DIRECT Michael A. Saclls to recuse liiinself and transfer all volumes he currently
holds in cliambers downstairs to the filing room. for public access pursuant to government
code, and ask presidingjudge to re-assign a retired judge as required under Local Rule 530.
8. DIRECT any additional relief the Appellate Division deems equitable and just.
Kespcctfully submitted
VERTFTCATION OF COUNSEL FOR PETITIONER

1. NANCY D MC.CARKON, declare:
1 am counsel for petitioner in this proceeding. I have read the foregoing
Petition for Order to Show Cause. and know the contents; the same is true of my
own personal knowledge, except as to those matters which are stated upon my
information or belief and as to those matters I believe them to be true. J declare
under penalty of perjury and California law the foregoing is true and correct and this
verification was executed on April 7, 2014 at Santa Barbara. California.
~ A N C ~ D . M C C A R R OAttorney
N,
for Petitioner
VERlFlCATlON OF PETITIONER
I. RONNIE SfUPLEY, declare:
J am petitioner in this proceeding. 1 have read the foregoing Petition for Order
-<
I
a
to Show Cause and know the contents theriot. the same is ttue of my own personal
5
knowledge, except as to those matters which are stated upon my information or
belief, and as to mose mO$rs 1 believe them to k true. I declare under penalty of
perjury and California taw the foregoing is true and correct and this verification was
executed on April 7,2O 14 at W ighlancl. California.
..
'c
+
.I:,
tfi
-,,-
2,
I . Hd
,/,.-,
BONNIE I. SHIPLE?. ~eritione;[complainant]
MEMORANDUM OF POINTS AND AUTHORlTIES

1.) Michael Sacbs was Aware of a Mandate, Had Ability to Comply & Failed to Comply
An Order to Show Cause is the appropriate remedy to bring a contemnor in to show
why he failed to complied with a directive. Arthur v. Supr Court (1965) 62 C.2d 404,408.
The purpose of a contempt proceeding is to protect the rights of litigants or vindicate
the dignity or authority of a court. Morelli v. Superior Court (1969) 1 Cal. 3d 328. 333.
A contempt proceeding is civil when it is remedial and coercive in nature, and the parties
are individual litigants whose private rights and remedies are to be protected or enforced.
In re Morris (1924) 194 Cal. 63, 67. Specific intent is an element only in criminal cases. Id
Petitioner inust show the order was entered on the docket. Ketscher v. Superior Court
(1970) 9 C.A. 3d 601, 604-605 Exhibits 1 & 18 show entry on the docket. Petitioner must
show the contemnor knew about a court's writ of mandate. Phillips v. Superior Court of
Kern County (1943) 22 Cal. 2d 256, 258. In transcripts Sachs admits he read the Appellate
Division's writ of mandate. Transcript 1 (2/19/14) Exhibit 8, 8.4: 1 & Transcript 2 (3117114)
Exhibit 12, page 12.14:20 & page 12.5: 1.
Petitioner must show contemnor had present ability to comply with the writ of mandate.
Koehler v. Superior Court (2010) 181 CA.4th 1153, 1170; Hicks v. Feiock (1988) 485 U.S.
624,638; In re Liu ( 1 969) 273 CA. 2d 135, 140. Exh. 6.1 shows Shipley presented 3
Judgments to Judge Sachs 2/10/14. He refused to sign them.
Petitioner must show contemnor failed to comply with an order. In re Rose ( 1 949) 90
CA. 2d 299, 304. Pretending to act under the authority of an order constitutes a contempt.
CCP 1209(a)(4). Disobedience of a lawful order is contempt. Ketscher v. Superior Cowt
(1970) 9 CA. 3d 601.604; Vanderstok v. Bank ofAmerica (1972) 29 C.A. 3d 731,734.
Although Sachs technically complied by entering Judgment for Shipley he rendered the
relief sought [protection from arbitrary eviction] illusory because in the same order Sachs
carved out a new remedy for Stubblefield to arbitrarily evict her, or any other resident under
an alternate statute (Civil 798.56[d]) which does not apply to her.
Civil $798.56[dj provides an kviction remedy only against a homeowner or tenant in

privity of contract with a park owner under a lease. Shipley filed a Request for Judicial
Notice of a similar contempt case in the Ohio Supreme Court.
Judge Hunter's evicted
Cincinnati Enquirer reporters from the court. The Appellate Court issued a Writ of Mandate
directing her to revoke her offending orders and grant unconditional entry to the court.
Hunter vacated her offending order, but issued a new order allowing entry but conditioned
upon non-publication of names. The Ohio Supreme Court affirmed the Appellate Court's
entry of contempt holding Hunter's interpretation of the Writ rendered it meaningless,
because although she allowed entry as ordered, she conditioned such entry upon the same
publishing prohibition. The High Court held that, "the alternative writ wouldprovide the
Enquirer only the illusion of relie$" Id, at page 9.

Here, Judge Sachs did exactly what Judge T~acieHunter did in the Ohio contempt case.
Sachs technically complied with a mandate by entering judgment for Shipley on the merits,
but provided only an illusion of relief. The Appellate Division held that Stubblefield could
not evict Shipley directly under Civil fj798.75rcI as that statute applied only to purchasers
and transferees---not s sublessee of an owner holding a valid lease with the park owner.
In the judgment Sachs carved out a new remedy for Stubblefield to summarily evict any
resident under an alternate code (Civil 798.56[d]) which also does not apply to Shipley as
she is not a tenant in privity of contract with Stubblefield under a valid tenancy lease.
Sachs' judgment authorizes her eviction through judicial proclamation, clearly violating the
Separation of Powers Clause, CA Constitution, Article 3, $3 and Article 6, 53 1 (Judicial)
Judge Sachs rendered the relief Shipley fought like a gladiator to obtain meaningless.
Just like an athlete who works diligently for four years to win an Olympic gold medal, only
to have her gold medal stripped and given to a loser, Sachs stripped Shipley of her victory.
Sachs gave the green light to Stubblefield to evict Shipley under by judicial proclamation.
Ohio Ex Rel. Cincinnati Enquirer v. Honorable Tracie M Hunter, Judge, Hamilton

County Court of Common Pleas. [Appellate C- 1301831. see Request for Judicial Notice
2.) Sachs Abused Process and Ran Star Court Proceedings for an Improper Motive
While a Legislature cannot exercise judicial functions or deprive the courts of judicial
powers, it may regulate procedures and place reasonable restrictions on judicial functions.
Briggs v. Superior Court (193 1) 2 11 Cal. 6 19, 627. Our California Legislature enacted
codes of procedures and rules of court to limit jurisdiction of the courts and to provide
due process to all litigants to comport with United States and California constitutions.
Abuse of process or proceedings of the court constitutes contempt. CCPS 1209(a)(4)
Sachs runs Star Court Proceedings. The essential elements of abuse of process are an
ulterior purpose and a willful act in the use of the process not proper in the regular conduct
of the proceeding. Weisenburg v. Molina (1976) 58 C.A. 3d 478,489. Sachs had a clear
ulterior purpose; i.e. he wanted to curry favor with billionaire developer Stubblefield to
ensure that Stubblefield does not run a candidate against Sachs in recurring 6-year elections.
Sachs willfully abused court processes and ran Star Court Proceedings to carve out a new
remedy for Stubblefield to summarily evict residents by labeling them unlawful occupants
for purportedly violating a purportedly reasonable park rule. Sachs improperly conducted
bizarre proceedings as described in Chronology of Events, including but not limited to:
1. 2110/14 Bolation of CRC 3.13 12 (prevailing party to prepare orders &judgments)

Sachs refixed to sign a judgment prevailing party presented for entry at the hearing;
instead he invited nun-prevailing party's attorney to prepare a proposed judgment.
2. 2/19/14 Violation of Civil 5663(b) (court power to vacate order expires in 60 days)
McCarron objected to revisiting Alvarez 10121113 order granting summary judgment.
McCarron told Sachs his jurisdiction to vacate or modify Alvarez' order had expired.
2/19/14 ViolationofCRC3.1103; 3.112; 3.1113. CCP 61005 (nonoticeoflnotion
timely filed per CCP 1005; no motion citing basis for relief or points & authorities.
2119114 Violation of CRC 3.13 12 (prevailing party to prepare orders and judgments)
The 2119114 Minute Order recites "Counsel for Plaintiff to Prepare Judgment" [bias]
3/17/14 Violation of Judicial Oath to Apply Constitution- violation of due process

Sachs suppressed McCarron from recording objections on the transcript depriving
Shipley of an opportunity to be heard, disparate treatment-calling counsel "ma'am"
3/17/14 Violation of Judicial Oath to Apply Constitution- violation of due process
Sachs actively advocated for a party by distorting prior
of two courts by
authorizing real party to paraphrase them to change the
those findings
3/17/14 N a t i o n of Judicial Oath to Apply Constitutio-n- violation of due process

Sachs advocated for Stubblefield by inserting the words "or resident" into his notes,
and then giving them to counsel for real party to insert tnem into the proposed order
(a contrivance so sneaky even real party's average attorney had not even conjured up).
This violated petitioner's right to due process under
US and CA's constitution.
The court is a stacked deck against Shipley when
is her opponent's advocate.

violation of due process
to enable him to take
or rejected for case filing.
exclusive control over what documents will be accept

Sachs then refused to accept Shipley's objections on
one day after real party
submitted its proposed judgment exparte directly to J dge Sachs' chambers on 3120114
VIOLATED LOCAL RULE 591.3 (Judge not to e ter judgment for 10 days)
Rule 59 1.3 was amended January 1, 20 13 to provide pposing party a chance to object
3/17/14 Violation of Judicial Oath to Applv ~onstithtion-violation of due process
Sachs then precluded Shipley from obtaining a copy f the judgment Sachs entered
immediately after real party had delivered it to his c ambers exparte on 3120114.
Shipley drove over to court 3 consecutive days to obtain a copy of the judgment
because it was not scanned into the online court docket, and each time she was told to
come back .the next day by Judge Sachs clerk in S-3 who had exclusive control over it.
Sachs runs Star Court Proceedings.
3.) A Judge Must Be Disqualified When Bias is Shown in the Proceedings.

Statements and mannerisms indicating hostility is sufficient to find bias. Offutt v. United
States (1954) 348 U.S. 1 I , 1 6 17. Throughout the proceedings on March 17,20 14 Michael
Sachs addressed real party's attorney Mr. Williamson as "counsel" while he addressed
Shipley's attorney McCarron as "ma'am" in a misogynist, condescending tone of voice.
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Judge Sachs must be disqualified under Ofit as his hostility for counsel shows clear bias.
CONCLUSION
Contempt Elements Satisfied [knowledge of order, ability to comply, failure to comply]
Two transcripts show Judge Sachs read .the Appellate Division's order entered on 5/6/13
and the Writ of Mandate entered on 7/22/13. Transcript 1 (2/19/14) Exhibit 8, 8.4: 1 and
Transcript 2 (3/17/14) Exhibit 12, page 12.14:20 and page 12.5:l. Sachs had the ability to
comply as counsel presented 3 judgments for signature on 2/10/14. Exhibit 6, 6.1, 6.2, 6.3.
Judge Sachs failed to comply with a 7/22/13 Writ of Mandate as explained in a detailed
10-page Decision entered 5/6/13. Judge Sachs technically complied by entering Judgment
on the merits for Shipley, but Sachs rendered the writ relief Shipley requested illusory.
The gravamen of the Appellate Court's reversal was that Stubblefield's 5-day Notice to
Surrender Possession was invalid as it was based on Civil 798.75[c] which did not apply.
Civil 5798.75 applied only to purchasers and transferees who became "unlawful occupants"
when they occupied a mobile home without first executing a park lease; and that Shipley did
not fit the description of "unlawful occupant" because she was not a purchaser or transferee.
Division found Stubblefield could not evict her directly as there was no privity of contract.
Sachs willfully conducted Star Court proceedings whereby he disregarded Rules of Court,
Procedural Mandates, Statutes of Limitations on vacating a 5-month old order, and the
Separation of Powers in Constitution Article 3 $3 by revising a statute by proclamation.
Sachs exceeded express Constitutional Limitations of Judicial Power in Article 6, $13.
The exparte judgment Sachs entered carved a new remedy for Stubblefield to proceed
directly against Shipley or any resident via Civil 798.56[d] applicable only to homeowners.
Sachs rendered the relief Shipley obtained [protection from arbitrary eviction] meaningless
as he gave Stubblefield .the green light to evict her under yet another inapplicable statute.
Sachs deprived Shipley of any opportunity to oppose this gratuitous gift because he donated
it sua sponte, without requiring Stubblefield to request such extraordinary relief by way of a
noticed motion in compliance with CRC Rule 3.1 103- 3.1 112 and CCP $1005 with Points
and Authorities citing the court's jurisdictional authority to grant such extraordinary relief.
Sachs gift exceeded his jurisdiction and was donated in bizarre Star Court proceedings.
Sachs must be held in contempt of court for failing to comply with a Writ of
Mandate just like Judge Hunter was held in contempt of court for failing to comply with a
writ of mandate by entering an order which rendered writ relief illusory and meaningless.
Sachs must be disqualified as he demonstrated clear bias, not only by conducting Star Court
Proceedings to enter an exparte order, but also by disparate treatment of Shipley's counsel,
shown in a distinct pattern of addressing real party's attorney as "counsel" while addressing
Shipley's attorney as "ma'am" in a loud, misogynist, condescending tone of voice.
Dated: 4/7114
An Order to Show Cause is filed with verified petition (complaint) in re Contempt
against Michael A. Sachs, supported by Evidentiary Exhibits 1- 19 under separate cover,

and a Request for Judicial Notice under separate cover, with a Proposed order for RJN.
Certificate of Interested Parties is filed and a Cover Sheet for the Appellate Division.
CERTIFICATE OF WORDCOLJNT
This petition contains 7,285 words [excluding tables] in roman typeface 13 font.
I relied on word count generated by MS Word 20 10 as recited in the status bar.
.
Dated: 4-7- 14
7
CHRONOLOGICAL LIST OF EXHIBITS

NO.
DOCUMENT
PAGES
FILED
1. Appellate Division Order Reversing Denial of MSJ, Judgment for Defendant
1.1-1.11
5/6/13
2. Writ of Mandate Directing Lower Court to Vacate Denial of MSJ & to grant MSJ
2.1-2.3
7/22/13
3. Minute Order 10121113 Alvarez' vacates 2114113 Denial MSJ; Grants Shipley MSJ 3.1-3.3
10-21- 13
4. Proposed Judgment Submitted by McCarron after plaintiff filed objections
4.1-4.8
1114.113
5. Minute Order 1/7/14-Alvarez Recusal-Move Atty Fee Motion to S-33 for 2110114
5.1-5.2
1/7/14
6. First Judgment Hearing S-33 McCarron submitted 3 Judgments for Sachs to sign
6.1-6.4
2110114
7. Minute Order-2/10/14 set Judgment Hearing; plaintiff to prepare proposed iudgment 7.1
2/10/14
8. TRANSCRIPT - 2ndJudgment Hearing-McCarron Objects to Strange Procedures
8.1-8.14
2119114
9. Minute Order-2-19- 14-Court directs plaintiff prepare proposed HYBRID ORDER
9.1
2/19/14
10. Proposed Order Plaintiffs Counsel Williamson submitted to Attorney McCarron
10.1-10.4
314114
11. Shiplev's Obiections to P's Proposed Order with Shipley's Alternate Order
11.1-11.6 3/4/14
12. TRANSCRIPT- 3rd Judgment Hearing-McCarron objects to Strange Procedures
12.1-12.16 3117/14
13. Michael Sachs' notes on p's Proposed Order adding "resident" page. 2: 13
13.1-13.3 3/17/14
14. Minute Order 3/17/14 plaintiff to prepare Judgment---"noteswgiven to counsel
14.1-14.2 3/17/14
15. P's EX PARTE Letter to Judne Sachs Letting Him know he did not miss the cue
15.1-15.4 3/19/14
16. D's Obiections to 2"* Proposed Order reiected in S-33 "judge already signed 3/20"
16.1-16.18 3/21/14
17. Dockets: 3/21/14-Friday; 3124114-Monday; 3125114-Tuesday; 412114-Wednesday
17.1-17.4 4/2/14
18. Notice of Entrv of Order Sachs signed 3120114; Plaintiff served by mail 4/2/14
18.1- 18.26 4/2/14
19. LOCAL Rule 530 (judge assignments); Rule 591.3 must hold judgments 10 days
19.1-19.3 4/1/14
'
I
ALPHABETICAL LIST OF EXHIBITS

DOCUMENT
PAGES
Appellate Division Order Reversing Denial of MSJ, Judgment for Defendant
1.1-1.11
D's Obiections to 2ndProposed Order rejected in S-33 "judge already signed 3/20"
16.1-16.1 8 3/21114
Dockets: 3/21/t 4-Friday; 3/24/14-Monday; 3/25/14-Tuesday; 4/2/14-Wednesday
17.1- 17.4
First Judgment Hearing, S-33 McCarron submitted 3 Judgments for Sachs to sign
6.1-6.4
LOCAL Rule 530 (judge assignments); Rule 591.3 must hold judgments 10 days
19.1-19.3
4/1/24
Michael Sachs' notes on p's Proposed Order adding "resident" page. 2: 13
13.1-13.3
3/17/14
Minute Order 10121113 Alvarez' vacates 2114113 Denial MSJ; Grants Shipley MSJ 3.1-3.3
Minute Order 1/7/ 14-Alvarez Recusal-Move Atty Fee Motion to S-33 for 2110114
5.1-5.2
FILED
516113
412114
2/10/14
10-21-13
1/7/14
Minute Order-2110114 set Judgment Hearing; plaintiff to prepare proposed iudment 7.1
2/10/14
Minute Order-2- 19-14-Court directs plaintiff prepare proposed HYBRID ORDER
9.1
2/19/14
Minute Order 3/17/14 plaintiff to prepare Judgment---"notesv given to counsel
14.1-14.2
3/17/14
Notice of Entrv of Order Sachs signed 3/20/14; Plaintiff sewed by mail 4/2/14
18.1-18.26 4/2/14
P's EX PARTE Letter to Judge Sachs Letting Him know he did not miss the cue
15.1-15.4 3/19/14
Proposed Judgment Submitted by McCarron after plaintiff filed objections
4.1-4.8
Proposed Order Plaintiffs Counsel Williamson submitted to Attorney McCarron
10.1- 10.4
3/44 4
Shplev's Objections to P's Proposed Order with Shipley's Alternate Order
11.1-11.6
3/4/14
TRANSCRIPT - 2ndJudgment Hearing-McCarron Objects to Strange Procedures
8.1-8.14
2119114
TRANSCRIPT- 3rd Judgment Hearing-McCarron objects to Strange Procedures
12.1-12.16 3117/14
Writ of Mandate Directing Lower Court to Vacate Denial of MSJ & to grant MSJ
2.1-2.3
4
.
11/4/13
7122113
VERTFTCATlON OF C O U ~ S E LFOR PETJTIONER

I
1. NANCY D MCCARKON, declare:
1 arn counsel for petitioner in this
I have read the foregoing
Petition for Qrder to Show Cause. and kndw the contents: the same is true of my
I
own personal knowledge. except as to thofie matters which are stated upon my
information or belief and as to those mattdrs I believe them to be true. I declare
under penalty of perjury and California lab the foregoing is true and correct and this
verification was executed on April 7. 201k at Santa Barbara. California.
(NANC~%.MC~CARRON. Attorney for Petitioner

VERIFIC ATIOP~ OF PETITIONER
I. BONNIE SFUPLEV, declare:
I am petitioner in this proceeding. I dave read the foregoing Petition for Order
C
-c
to Show Cause and know the contents t$erbof;.the same is true of m i own personal
3
knowledge. except as to those matters wlhich are stated upon my information or
belief. and as to mose mat[ers I believe ihem to he true. I declare under penalty of
I
perjury aid California law the foregoind is true and correct and this verification was
I
executed on April 7,10L 4 ai W ighland. kalifornia.
Nancy DufQ McCarron, CBN 164780

950 Roble Lane
Ph/fax 805-965-3492 cell 805-450-0450
nancyduffysb@,~ahoo.com
Attorney for Petitioner Bonnie Shipley
SAN BERNARDMO COUNTY SUPERIOR COURT

APPELLATE DIVISION
BONNIE SHIPLEY,
Petitioner,
,
Case No.
1403933
(Trial Court No. UDDS 1204 130)
V.
MICHAELA.
FO-
S A N BERNARDINO COUNTY
SUPERIOR C O m T
Respondent;
WRIT PETITION;
(Verified Complaint) with Exhibits 1 19;
REQUEST-FORJUDICIAL NOTICE;
Proposed'ORDER: OSC in re CONTEMPT;
Proposed Order re: RJN
40 1 North Arrowhead Avenue

San Bernardino, California 924.15
The undersigned counsel for Petitioner certifies the above recited documents filed in
Appellate Division on 4-7- 14, per directions from Appellate Ckrk by telephone today to
'(
serve parties by mail, were served by 2-day priody mail to respondent and real party at:
Hon. Michael A Sackrs S-33
San Bernardino' $<perior~surt
303 W. 'Fhird Street
San Bernardino, CA 924 15-0210
Robert Wfiliamson, Attorney for Real Party

HartKing 714-432-8700 fax 714-546-7457
4 Hutton Drive, Suite 900
Santa Ana, CA92707
The undersigned served real party by email to: rwilliamson@hartkinelaw.com and
declares this true under penalty of perjury and was executed in Santa Barbara on 4/17/14.
~ a n 8 buw
y
MCC~GOK,
Attorney for Petitioner
SUPER~ORCOURT OF THE STATE OF CALIF

APPELLATE DIVISION
401 N. Arrowhead Ave., San Bernardino, CA 92415-006
(909) 5213574
DATE: April 81 201
CASE NO.: CIVDS1403933 1 UDDS1204130 (San Bernardino)
BONNIE SHIPLEY,
Petitioner,
v.
ORDER DENYING REQUEST FOR

IMMEDIATE STAY

CALIFORNIA, COUNTY OF SAN BERNARDINO, -Respondent, ,
STUBBLEFIELD PROPERl'IES,
Petitioner has filed a petition for writ of mandate accompanied by a request for an immediGe
stay of the trial court proceedings pending our ruling on the petition.
The request for an immediate stay is DENIED.
. .
a&
--
. .->
- .,
-4.
.. ..
._
__
DAVID COHN
:Assistant Judge of the Appellate Division
.
cc: San Bernardino Courthouse
I certify that copies of the above Order were mailed to courlsel of record as indicated on
Court Clerk
_....
euperior Qourt atate of Qatifornia

Qnuntp of &an @ernarbinn
Appellate Division
DECLARATION OF SERVICE BY MAIL
STATE OF CALIFORNIA
)
)
Writ # ClVDS 403933 ,-.

Trial C o ~ j r tUDDS
i
1204130
The undersigned hereby declares: I am a citizen of the United States of America, over the
age of eighteen years, a resident of the above-named State, and not a party to nor interested
in the proceedings named in the title of the annexed document. I am a Deputy Appellate
Clerk of said County. I am readily familiar with the business practice for collection and
processing of correspondence for mailing with the United States Postal Service.
Correspondence would be deposited with the United States Postal Service that same day in
the ordinary course of business. On the date-of mailing shown below, I placed for collection
and mailing fol4owing ordinary business practices, at the request and under the direction of
the Superior Coud in and for the State of California and County above-named, whose ofice
is at the Courthouse, San Bernardino, California, a sealed envelope which contained a true
copy of each annexed document, and which envelope was addressed to the addressee, as
follows:
NANCY DUFFY MCCARRON, ESQ
950 ROBLE LANE

4 HUTTON CENTRE DRIVE
SUITE 900
SANTA ANA, CA 92707
SAN BERNARDINO CIVIL DIVISION

HONORABLE MICHAEL A. SACHS
Date and Place of Mailing: April 8, 2014, San Bernardino, California.
Document Mailed:. ORDER.ON PETfTION FOR WRIT.O.F.MANDATE
I declare under penalty of perjury that the foregoing is true and correct.
' Executed on ~ p r i l 82014,
,
at San Bernardino, Californ'
Deputy Clerk
#+:, #
&
&&
NPERCCR cam7
SUPERIOR COURT OF THE STATE OF CALIFORNIAOUNY?~~.."".Y.~

,.
.,
.
&Lcl(q
APPELLATE' DIVISION
401 N. Arrowhead Ave., San Bernardino, CA 824154063 BY&,&bc
.a. >?h
,.
-.
,i
:.$,;
~AROWN~OLBERG,
DEW
(909) 521-3574
CASE NO.: CIVDS1403933 1 UDDS1204130 (San Bemardino)
..
DATE: May 6;2014
BONNIE SHIPLEY,
Petitioner,
SUPERIOR COLIRT OF THE STATE OF
CALIFORNIA, COUNTY OF SANRmO; - -.Respondent,
ORDER
- . . ..
On March 20, 2014, judgment was entered in the underlying case.
On April 7, 2014, petitioner filed the instant petition for order to show cause re contempt
accompanied by a petition for writ of mandate requesting that the Appellate.Division Court issue an
order vacating the judgment, among other relief.
To appeal from a judgment or an appealable order in a limited civil case, the defendant must
file'a notice of appeal in the trial court that issued the judgment or order being appealed. (Cal. Rules
of Court,i.cule8.821 (a)(l).) A notice of appeal in a limited civil case must be filed within 30 days after
the rendition of the judgment or the making of the order being appealed. (Cal. Rules of Court, rule
8.822(a).)
We note that petifionsi; has filed a timely notice of appeal from the judgment.
extraordinary writ is inappropriate in this case. The petition is hereby DENIED.
Relief by
The Hon. Katrina West and the Hon. R. Glenn Yabuno concur.
I
istant Presiding Judge of the Appellate Division

cc: San Bernardino Courthouse
I certify that copies of the above Order were mailed to counsel of record as indicated on
-,
34
Court plerk
'
Superior &ourt &ate of California

Countp of S a n sernarbino
Appellate Division
1
1
1
STATE OF CALIFORNIA
Writ # ClVDS 1403933

Trial CouM UDDS 1204130
age of eighteen years, a resident of the above-named State, and 'not a party to nor interested
Clerk of said County. I am readily familiar with the business practice for collection and
processing of correspondence for mailing with the United States Postal Service.
-Correspsndemawauld.bedepasBed&b LheUn~~~Sbjes~PosfiServi~
that same-day -in - - - .
the ordinary course of business. On the date of mailing shown below, I placed for collection
and mailing following ordinary business practices, at the request and under the direction of
the Supeiior Court in and for the State of Califomia and County above-named, whose office
copy of each annexed document, and which envelope w22 addressed to the addressee, as
follows:
LAW OFFICE OF NANCY DUFFY MCCARRON HART KING & COLOREN

950 ROBLE LANE
4 HUTTON CENTRE DRIVE, STE 900
SANTA ANA, CA 92707
't
AN BERNARDINO COURTHOUSE
Date and Place of Mailing: May 6,2014, San Bernardino, Califomia.

Document Mailed: ORDER DENYING PETITION FOR tt'3iT OF MANDATE
... .... .
-.
.-*.
..
-.
.-
-.
---
I dedare under penalty of p&,ury that the foregoing is trug'2tlbaorred.
Executed on Ma
..
.- - - .
San Bernardino, California.
c c ~ a b- f psot
CAROLYN SOLBERG
Deputy Clerk
.F.-
-..--
- -.
I&4&&mhmYL*%1
YOHIAND, CALIFORNU 913111 PHONE (909) a82-2400

4 4 0 E. PIEDMONT DRm,SPACS
2258 BRADFORD AVENUE m HIGHLAND, CALlFORNlA 92346 PHONE (909) 8641522
May 9,2014
Dear Resident:
J
1
of speaositiondin~and coming sto-a f
within our cornmbnitv.
!
A potential progrim may be within our grasp and ifso it is entlrely due t o the efforts of your HOA Board of
Directors and an hnreifish group of 9 community minded residents. This gmup has come together under the
COMMITTEE", In order t o implement the program it will require the
name of the UTR4FFlCSAPETY
,
cooperation of eTery resident within the community as well as a commitment from your Park Management.
!
We, the parkV~ahagement,
are committed t o the following:
I. Modify the speed bumps where needed.

2. Agree t o bestripe all streets and walkways not less than every two years and not more than three
years. ;
3. ont ti nu$ t o enforce all trafflc rules wlthin our cornmunlty equally and fairly, BUT MORE
VIGORO~JSLY.
4. continu$ t o treat all offenders impartially, promptly and equally.
Management has committed to the above provided the residents are willing to accept their responsibility for
good safe driving habits within the community. That consists of the resident and guest commitment t o the
following:
i
'
'
1. Not t o ekceed the 15 MPH maximumspeed limit

2. Full and!cornplete stop a t all stop signs and intersections whether marked or not.
3. ~ ot ot @ the vehicle in front of you unless it comes t o a fuN stop.
4. To diligently comply with a l l aspects o f the traffic guidelines within our c&munity.
t
n
h
&
i
v
s be necessary t o have 10003 cooperation from each resideat and the

l
e
d
a
e
m
e
n
t
f
f
i
by
c June
e 13,2014.
ff we can all wqrk together on this program we commit t o you t o modify the speed bumps where needed, and
continue t o enqorce the traffic rules within our community, which we have all previously agreed t o in writing.
I
This will go a ldng way i n helping t o continue maintaining a very happy and safe community with an extra eye
out for our more senior residents that enjoy walking and bike riding.
~ loflthe abov; is very achievable, and will require an effort on the part of &resident
sign and return the Acknowledgement page.
.u
Eva 5. ~ a z a r d(
Community ~ $ n a ~ '-:
er
t o read. understand,
sfmi mi:
~ a 9,28
y I 14
i
Dear
We can , I agree that Mountain Shadows is a great place to live. Even when living
there can be irritating issues. One of &use issues that has
and MAhTAGEMENTfor a long time is the matter of
In an effblt to solve the problem, additional speed bumps were installed in many
places d t h i n the park. Unfortunately, most of us have found that this "solution"
has not been as effective' as we hoped, and may have caused disruption and even
hacishid to some of our residents. In response to our pleas for relief, management
has ask& the home owners to come up with a plan to address the problem, while
still achieving the main goal, ''Trmc Safety". Our committee has been meeting,
and is ricommending the following plan.
This Ieqer is the first part of our plan. We h o w that the majority of our residents
are d o u s to make our park a very safe place to live, and this includes residents
stopping at all stop signs and driving within the speed limit. We commend them for
this cooperation. However, there is an entrenched minority that for whatever
reasod, habitually ignore these safety requirements. There is also a small group of
deliverb people, sub-contractors, outside guests and even children of some of our
reside&. This letter is a special appeal to those people to live within the
restticdons that make our park such a nice place to live. If this earnest appeal goes
unheeded, we must find other ways to reach the offendeis with methods that will
meet obr goals*
In supbort of this objective, we would encourage all residents who witness obvious
vio~atibns,to report them to the park office. Emphasis should be on license
numb&, type and color of vehicle and the date, time and location the violation
occur&d.
We asjsume that some of the offenses are inadvertent and we may not be aware we
are spkeding. Our first action would be a documented verbal waning, The ncxt
step would be to send the first written notiee, then a second, followed by a fmal
I
de
notice.
find notice states that continuke of non-compliance may r e d in a
review o residency status in Mountain Shadows.
1.I
I
~alifbmikCivil Code provides for this remedy. It states in Article 6, Section

798.56..+~
tenancy s h d be terminated by the management for one or more of the
f o l l o d reasons.. (d)Fajlure of the homeowner or resident to tocomply with a
reasonabfe rule or regulation ofthe park that is part of the rental agreement or any
thereto."Further, the Memorandum of Understanding dated March 1,
7(A) (1) describes the consequences of Non-compliance with
Management hirs agreed to d o r c e Section 11B of the Comtnuaity Guidelines

&ted ~ h 1,20
h 1 0. The Guidelines clearly stat6 that residents and resident's
gueits &st obey aII posted traffic c.ontrolsigns. This includes coming to a full
and complete stop at all stop signs. This is for the good of our community as a
whole. &anagemat has assured us that if we are successful in obtaining ..
compliqce with the trafsc regulations they will adjust or lower the most oEensive
speed bpmps. Please work with us to achieve this goal.
Your T
~Safety
C Committee
Barbara Smith, Chairman
Committee Members:
John Robert
Jim Cbenoski
I Jim Cline
Arlind Hackett
~ian~~urph~
~ s Regis
y
Charles Romer
Steve Sutherland
COURT OF APPEAL -- STATE OF CALIFORNJA

FOURTH DISTRICT
MVISION TWO
ORDER
COURT OF APPE4L FOURTH DISTRIV
BONNIE SHIPLEY,
Petitioner,
E06 1182
(Super-Ct-Nos.CIVDS1403933,
ACIAS 1400026 &
UDDS 1204130)
THE SUPERIOR COURT OF SAN

BERNARDINO COUNTY,
Responderit;
The County of San Bernardino
MICHAEL A. SACHS et al.

Real Parties in Interest.
THE COURT
The petition for writ of review and request for immediate stay are DENIED.
Acting P. J.
cc:
See attached list
Court of Appeal, Fourth Appellate District, Division Two No. E061182

5219373
'
IN Tl3E SUPREME COURT OF CALIFORNIA
BONNIE SHIPLEY, Petitioner,
. . SUPERIOR COURT OF S A N BERNARDINO COUNTY, Respondent;
Ml[CHABL A. SACHS et al., Real Parties in Interest.

.'
The petition
for review and applidori far stay are denied.
.
.
SUPREME COURT
F.1LED
FrankA W i r e Clerk
*
Deputy
CANTIL-SAKAWE
Chief Justice

APPELLATE DIVISION
BONNIE SHIPLEY,
Petitioner,
v.
SUPERIOR COURT
Respondent;
STUi3BLEFIELD PROPERTIES,
Communitv. Real Partv in Interest.
LIDDS 1204130 S-33: Michael A. Sachs 1
PETITIONER'S APPLICATION TO CERTIFY

APPELLATE DIVISION APPEAL
TO FOURTH APPELLATE DISTRICT - DIVISION 2
California Rules of Court, Rule 8.1005
950 Roble Lane
nancvduffysb~,vahoo.corn
805-450-0450 fax 805-965-3492
Certification to Court of Appeal is Warranted to Conserve Resources
A.
Under California Rules of Court, Rule 8.1005, a party may apply to an Appellate
Division to certify a pending appeal to the Court of Appeals to secure uniformity
of decision or to settle an important question of law. The issues in this case
directly impact judicial and support staff resources, not only in this Appellate Division
but also in all Appellate Divisions, Courts of Appeal and even the Supreme Court.
There is currently no guidance in reported decisions in California on issues presented.
Forcing a-prevailingappellant to file a second a p ~ e ato
l enforce her first
appellate victory is a licentious perversion of justice. Forcing second appeals
Gposes an impermissible burden on Appellate Courts and the Supreme Court.

Once judgment for defendant is ordered by Writ of Mandate, and a plaintiff has
exhausted appeals up to the Supreme Court, the burden to defend should be over.
Because the Presiding Panel of this Appellate Division refused to enforce the
Writ of Mandate issued last year by issuing an OSC to hold Judge Michael A. Sachs
in contempt petitioner was forced to file an appeal to eschew a tainted order from
ripening into an un-appealable final judgment for want of a timely Notice of Appeal.
There can be no finality of decision if Appellate Divisions refuse to discharge their
duty to enforce their own Writs of Mandate.
The Ohio Supreme Court provides guidance on what Appellate Courts should do
to enforce Writs of Mandate; i.e they should hold the offending judge in contempt.
'
The Court held "a person guilty of the disobedience of, or resistance to, 'a lawful
process, order rule, judgment or command of a court' may be punished for contempt.. .
Ohio Ex Re1 Cincinnati Enquirer v. Honorable Tracie M. Hunter, Judge. Hamilton County Court of Common Pleas. [Appellate C-130183
:
-< ST\,
- =-. _\
.\
A court's contempt power is employed to ensure the effective administration

of justice, to secure the dignity of the court, and to affirm the supremacy of the law.
A civil contempt sanction is imposed to coerce a party in violation of the corn's

orders- the contemnor- to comply and to remedy the harm caused to other parties
by its disobedience." Proof of purposeful, willful, or intentional violation of a court's
order is not a prerequisite to a finding of civil contempt.. .The fact that a contemnor
acted innocently and not in intentional disregard of a court's order is not a defense to a
charge of civil contempt. Id, p. 2
The Ohio Supreme Court held that Judge Hunter's interpretation of the Writ
rendered it meaningless, because although she allowed entry as ordered, she conditioned
entry upon the same publishing prohibitions which led to the court's writ of mandate.
Judge Hunter could "comply" with the writ by granting entry but revoking it if
Enquirer published juvenile defendants' names. Thus, the "alternutive writ would
provide the Enquirer only the illusion of relief:" Id, page 9. The High Court held:
"A party cannot avoid contempt for violating an order that is plain
on its face based on the contemnor's subjective misunderstanding of
the order. {cites.. .)"the primary interest involved in a contempt
proceeding is the authority and proper fimctioning of the court, [and
thereforelgreat reliance should be placed upon the discretion of the
[court]." Judgment affirmed. Id, page 9.
Petitioner asks the court to review the Request for Judicial Notice filed
in this court on 4/7/14 and their own copy of Writ of Review served 5/19/14 .
,
In the interest of uniformity and conservation of appellate resources this court

should transfer the pending appeal to the Fourth District Court of Appeal.
Dated:. 5115/14
PROOF OF SERVICE
STATE OF CALIFOWLA,
Bonnie Shiolev v. A~mllateDivision of San Bemard'mo Superior Coud Case
Bonnie S h i ~ k v.
v M'lchae1 A. Sachs
i f -Q
CWDS1403933
Stubble&ld Pro~ertiesv. Bonnie Shipley UDDS1204130
The undersigned is counsel for Bonnie Shipley, who is the petitioner in this case,
petitioner in CIVDS1403933 (Appellate Division) and defendant in UDDS12W130
950 Roble Lane, Santa Barbara, California, 93 103 nancvduffvsb@vahoo.mm
cellular phone: 805-450-0450 fax and phone: 805-965-3492
On the date recited below the undersigned served the below document as indicated:
WRIT OF R E n W , Exhibits A-E, Certificate of Interested parties @xh.A-3" pg)

Motion To Transfer Appeal To Fourth District, Division 2
(2-day Mail) $1013a, 92015.5 CCP. Documents in pre-paid stamped envelope to:
Fourth District Court Appeal (orig+4)

Division Two
3389 Twelfth Street
Riverside, CA 92501
tel 951-782-2500 fax: 95 1-248-0235
Presiding Panel Appellate Division (1 copy)

401 Arrowhead Avenue
San Bernardino, CA 92415
te1909-52 1-3574 fax 909-521-3563
Respondent Michael A Sachs S-33 (1 copy)

San Bemardin0 Superior Court
303 W. Third Street
909-708-8699 f
a 909-708-8586
Robert W~lliamson,Esq. Real Party (1 copy + exh.)

HartKing
4 Hutton Drive, Suite 900
Santa Ana, CA92707
td 714-432-8700 f a 714546-7457
I am familiar with mail collection in Santa Barbara. I deposited the envelopes in the
mail at Santa Barbara, CA. I am aware on a motion of the party served, service is
presumed invalid if postal cancellation date i s more than one day after deposit date
on affidavit. Copies were sent by 2-day mail to track and ensure speedy delivery.
M(By Electronic) to email addresses below; copy to nancyduffysb@yaha.com

-w.com
[X] (STATE) I declare under penalty of perjury and laws of California that the
above is true. Executed in Santa Barbara CA on the date recited below.
F3LCI:E
COUH r OF GALIFOR
SUPERIOR COURT OF THE STATE OF CALIFORM%ERlCR
UNTY OF SAN BERNARCIY
64N BERNARDlNO DlSTRlCl
APPELLATE DIVISION
JlUN 0 i u t 4
247 West Third Street, San Bernardino, CA ' 92415-0063

(909) 521-3574
CASE NO.: CIVDS1403933 1 UDDS1204130 (San Bernardino)
cRb
DATE: June 9,2014
BONNIE SHIPLEY,
Petitioner,
v.
BERNARDINO,
- , . .
.Resp~.ndeclt,.
--.-
--
I
------
---
ORDER
---
--
---
This court has read and considered petitioner's application for certification and transfer. The
application is DENIED.
The Hon. R. Glenn Yabuno concurs.
%@nig
Presiding Judge of the Appellate Division
cc: $an Bernardino Courthouse
I certify that copies of the above Order were mailed to counsel of record as indicated on
JEN - 9 --.
7nqn
.
Cb4
.nvl
sw&
~ 6 u rClerk
t
Gfi.ROLW S O L B ~ W G
Superior &ourt %ate of EaIifornia

Countp of S a n Pernarbino
Appellate Division
STATE OF CALIFORNIA
1
1
1
Writ # ClVDS .I
403933
Trial Court# UDDS 1204130
age of eighteen years, a resident of the above-named State, ,and not a party.to nor interested
Clerk
----- of said Coun-Q. I am readily familiar with the business'practice for collection and
p r o c e s s i n g ~ r e s p o n d e r i &for m a i l i ~ ' w ~ n i S t a tPoStBISemi-=
e s
-Corresponden~~would
be deposited.with the United States Postal Service that same day in
the ordinary course of business. On the date of mailing shown below, I placed for collection
and mailing following ordinary business practices, at the request and under the direction of
the Superior'Court'in and for the State of California and County above-named, whose ofice
copy of each annexed document, and which envelope was addressed to the addressee, as
follows:
---..----
-.
LAW OFFICE OF NANCY DU.FFY MCCARRON HART KING & COLDREN

950 ROBLE LANE
4 HUlTON CENTRE DRIVE, S'rE 900
SANTA ANA, CA 92707
'
SAN BERNARDINO COURTHOUSE

Date and Place of Mailing: June 9,2014, San Bernardino, California.
Document Mailed: ORDER DENYING PETITIONER'S APPLICATION FOR TRANSFER
. - ....
.
,'
I declare under penalty of perjury that the foregoing is true and correct.
Executed on June 9, 2014, at San Bernardino, California.
June 9,2014
We are enclosing in this mailing two (2) letters, one from Park Management and
one from your HOA Board's new Traffic Safety Committee with an
AcknowIedgement page and this instruction sheet.
Please retain both letters for your records, sign and return the Acknowledgment
page toi the Park Office. BE CERTAIN THAT EVERYONE IN YOUR HOUSEHOLD
WHO IS/ONTHE LEASE HAS SIGNED THE ACKNOWLEDGMENT.
i
In order: to achieve the goals of your Traftic Safety Committee it is necessary to

read, understand, agree and return your signed copy of the enclosed
~cknodledgmentpage of the Traffic Safety Committee letter dated June 9,2014
to the Park Office by: June 13,2014.
Remember, with your complete and total cooperation, your Traffic Safety
Committee, your resident's Homeowners Association and Park Management will
be able t o move forward!
Thank you in advance for your cooperation.
Dear Resident:
We may now be In a ~ositionto better focus on the issues of speeding and coming to a full stop at stop s i
within our comdnftv.
A potential pmgrAm may be within our grasp and if so it is entirely due to the efforts of your HOA Board of
Directors and an hnselfish group of 9 community minded residents. This Broup has come together under the
name of the "TRAFFICSAFETY COMMITTEE". In order to implement the program it will require the
cooperation of eiery resident within the community as well as a commnment from your Park Management.
I
We, the Park Mahagement, are committed to the following:

I
1. Modify the speed bumps where needed.

2. Agree to testripe all streets and walkways not less than every two years and not more than three
years.
3. Continue to enforce all traffic rules within our community equally and fairly, BUT MORE
VIGOROUSLY.
4. ~ontinud
t o treat all offenders impartially, promptly and equally.
Management has committed to the above provided the residents are willing to accept their responsibility for
good safe drivink habits within the community. That consists of the resident and guest commitment to the
following:
1. Not t o ebceed the 15 MPH maximumspeed limit

2. Full andkomplete stop at all stop signs and intersections whether marked or not.
3. Not t o q s s the vehicle i n front of you unless it comes t o a full stop.
4. To diligently comply with a l l aspects of the traffic guidelines wJthirr our;ommunity.
In order to accdm~lishthis goal it will be necessary t o have 100% cooperation from each resident and the
attached ~ckndwledgementpage signed bv each residentand returned to the Park Office by June 13,2014
J
lfwe can all wotk together on this program we commit to you t o modify the speed bumps where needed, an
continue t o enlorce the traffic rules within our community, which we have al! previously agreed to in writing.
This will go a 18ng way in helping to contin& maintaining a very happy and safe community with an extra eyf
out for our more senior residents that enjoy walking and bike riding.
~ lof lthe abov; is very achievable, and will require an effort on the part of e ~ e s i d e nt o
t read. understan!
;
Yours T r u k J
r
Eva 5. Hazard, 1
Community $nager
May 9,28
I 14
Dear R ~ Sdent:
/
We can
agree that Mountain Shadows is a great place to live. Even when living
there can be irritating issues. One of those issues that has
and MAhTAGEMENTfor a long time is the matter of
In an effprt to solve the problem, additional speed bumps were installed in many
places 4 t h the park. Unfortunately, most of us have found that this c'soIution"
has not been as effective as we hoped, and may have caw& disruption md even
hardshid to some of our residents. In response to our pleas for relief, management
has ask4 the home owners to come up with a plan to address the problem, while
still achieving the main goal, '"Traf5c Safety". Our committee has been meeting,
and is r&ommending the follqwing plan.
This leqer is the first part of our p h . We know that the majority of ow residents
are anxious to make our park a very safe place to live, and this includes residents
stopping at all stop signs and driving within the speed limit. We commend them for
this cGPeration. However, there is an entrenched minority that for whatever
reason$, habitually ignore these safety requirements. There is also a small group of
delivery people, sub-contractors, outside guests and even children of some of our
reside&s. This letter is a special appeal to those people to live within the
restric$ons that make our park such a nice place to live. If this eapest appeal goes
unhee*, we must find other ways to reach the offenders with methods that will
meet our gods.
I
In sukort of this objective, we would encourage all residents who witness obvious
violatibns, to report them to the park office. Emphasis should be on license
numb&, type and color of vehicle and the date, time and location the violation
occu<cd.
We q u m e that some of the offenses are inadvertent and we may not be aware we
ate spteding. Out first action would be a documented verbal warning. The next
step would be to send the first written notice, then a second, followed by a final
d e fmd notice states that cont&u&e

I
of non-compliance may result

residency status in Mountain Shadows.
Aa
~aliforniaCivil Code provides for this remedy. It states in Article 6, Section

798.56.. j ' tenancy
~
shall be terminated by the management for one or more of the
followink m o n s... (d)Failure of the homeowner or resident to comply with s
reasonable tule or regulation df thc park that is part of the rental agreement or any
amendmht thereto." Further, the Memorandum of Understanding dated March 1,
2010, ~ebtion7(A) (1) describes the consequences of Non-c?mpliance with
~orn&y Guidelines.
~ a n a ~ e m ehas
n t agreed to enforce Section 11B of the Community Guidelines
dated M L C ~1,2010. The Guidelines clearly state that residents and resident's
&ests must obcy all posted t r a c control signs. This includes coming to a full
and codplete stop at all stop signs. This is for the good of our community as a
whole. hanagement has assured us that if we are successful in obtaining
compliqce with the traffic regulations they will adjust or lower the most offensive
speed bps. Please work with us to achieve this goal.
Your ~fafficSafety Committee
Barbara Smith, Chairman
Committee Members:
:
John Robert
Jim Chenoski
! Jim Cline
i
Arlind Hackett
RayF-Regis
,
Charles Romer
Steve Sutherland
Acknowledgment
01thd HOA Board's TrafEc Safety CommitteeManagement letters dated
1
In order \o move f o m d with this proposal, aclmowledgement of receipt and

willss to comply is required. ALL SIGNATORIES TO T m LEASE
ARE ASKEDvTO PLEASE SIGN AND DATE BELOW.
k
I
I
Space Number:
Name (Signature)
Date
Name (Signature)
Date
Name (Signat;re)
Date
Name (Signature)
Date

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EXHIBIT LIST

SUPERlOR COlJRT OF"'fHE STATE QF ClALIFOKtdlA

PEOPLE OF THE ST-4TE OF CALIFORNIA,

Ylaint;f*f, DECLARATIOIL' IN S-EPPORT OF

NETLAND KENNETH DERRV,

TilE UNDBRSlGNED HERWY IIECLARFS. UPON RJFORhlATlON AND BEI.lEF:

participated in numerous crlrn~nalinvestrgations I hold

advanced ccmficate issued by the

criminal investigations tat~ghlby cxpericnced investiptions and proseculing attorneys. Which r

Advanced officer training in oncer-involvcd shootings,

UETAILS OF THE INVESTIGATIUN

Arnold "A.ll," Siubblclield is a Sar~Bernardino properly owner and dcveloper. Stubblcfield hw

William Postmus. Stubblcficld intendcd to make a eontribu~ion10 the supcrvisor~alcampaign

PAC and he had no knowledge of the lnland h p r e PAC

remembers eithrr rna~l~np

who controllcd it. Stubblcfi~ld

l l c ~ s ytold invesligalors tho1 he con~wtedStubbIclield during thc campaign seeking a

who he knew cnntlpllccl the lnland bmpirv PAC

Drrry admined his canlpargn llacr received

Stuhblcfield I'unds were l o suppofl his campaign

want to receive (and hc required to r ~ p o nthcuc

pay nu1 that amount

his campaign, and so

Polilical Ilcfor~nha ('.I'R,4")

rcpurts and bank records of thc Inland Empire PA(' reflect

n a s dep(1sitec1il~tcrthe Dcrr) campaign accnunl on July 11; 20U7.

Fair Polllical Practices Commission ("FPPC") F o m 460 under pcnaltp o f "

l>rclmlton in Suppun ol COlIIp

[ 0ms)(ing N w a ( PE.uun- Pres....

NeU Dertysoughtb modify his plobation

Attorney Rajan Maline appemd on behalf of

denbs Denypmbeson Fhengea I Bnrsldng News IPE.corn- Pm...

and charged hlm with twP felonies and a

t!.e as s e n t e n d to three years pmbation.

The charges stemmed from e $5,000

Home > Local t i e >~ Riverside County 7 &met-San

Jacinta > Hemet-San Lac~ntoHeadlines

SAN JACINTO: Work

SRN JACINTO. Cwncil to consider

o enough bowg Jnne La p m n l

InIan2 Southsm Cal#hma7

No. Regardless d cost. wz need

Yes. Mlinons d d d l a n haw

0 Pemaps. sure, we can spend

mare and boy more salety.

Dale SlubbWela Jr.PIead GuiW

JAL;INTO: WO* release fw Mansperger, Shlbblef~ldI Breaking News I PE.com P - ~ n t e r p " ~ ~

chargep in the ease.

in the San JBcinto m m o t i w

Meanuhle, jail a d vxlR m o d s Friday shrur James Ayrss, m e

He ha4 receibd a oneyea sentence Aug. 12. A y w urar ordered

me case ~ I o h kind Ncwnbw2WB uhen e 155enunt

Council members at Uw the.

The indictment a l l 4 a ysan-lma

De$ndanb, pmsecutom said, bypassed C a l i l a campaign

Elibery took place when Sheuli bougld Ayme' hcuse fw tens of

b s t i g e b sald d & a p Stephen Holgate &as Ihe source d

hew been sentmeed

Menspcger, who nsle e f e m i I y U n a a 6 tow s&e and

The Judgeeald she b e E d Msnsperger hed taken UI

Manspergetend 6tuWdWd &a were A t m i $2,000each and

Two buslnsssmen tled to the ~

90 deys kameceleoss custady with an