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SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN BERNARDINO


APPELLATE DIVISION

STUBBLEFIELD PROPERTIES, et al

Appellate Division: ASIAS1500049

Plaintiff/Respondent

SBSC: UDDS1204130

v.
BONNIE SHIPLEY,
Defendant/Appellant

APPEAL FROM AN ORDER in San Bernardino Superior Court, Dept. S-29


Staying Enforcement of Attorney Fee Judgment Without Posting a Bond
Hon. Janet M. Frangie
_________________________________________________

APPELLANTS REPLY BRIEF


________________________________________________
Nancy Duffy McCarron #164780
950 Roble Lane
Santa Barbara, CA 93103
805-450-0450 fax 805-965-3492
nancyduffysb@yahoo.com
Attorney for Appellant, Bonnie Shipley

TABLE OF CONTENTS
TABLE OF AUTHORITIES ......................................................................................... 3-4
INTRODUCTION ..................................................................................................................5
ARGUMENT ..........................................................................................................................6
I. Order is Not Presumed Correct When it Ignores Supreme Court Mandate .....................6
II. Sanction Request is Procedurally Deficient and Factually Unwarranted ............................12
Global Effect of Enjoining Enforcement Without a Bond .............................................14
CONCLUSION .....................................................................................................................14
CERTIFICATE OF COMPLIANCE ..................................................................................15
Filed Under Separate Cover; i.e. Request to take Judicial Notice
RJN A-Unanimous Jury Verdict for McCarron on Second Frivolous Eviction
after losing First Frivolous Eviction against Bonnie Shipley via MSJ
RJN B-Fraudulent Request for Judicial Notice Filed in typical Fraudulent Eviction

PROOF OF SERVICE .....................................................................................................Last

TABLE OF AUTHORITIES
CASES
Auto Equity Sales, Inc. v. Superior Court (1962) 57 Cal.2d 450, 455 .................................... 6, 9
Bank of San Pedro v. Superior Court (1992) 3 Cal.4th. 797 .......................................... 5, passim
Behniwal v. Mix (2007)147 Cal.App.4th 62, 624 ..................................................................... 10
Bono v Clark (2002, 6th Dist) 103 CA 4th 1409 ...................................................................... 12
Chamberlin v. Dale's R.V. Rentals, Inc. (1986) 188 Cal.App.3d 356 ........................................ 6
Chapala Management Corp. v. Stanton (2010) 186 Cal.App.4th. 337 .................................. 6
Grant v. Superior Court (1990) 25 C.A.3d 929, 934................................................................ 14
Leung v. Verdugo Hills Hospital (2008) 168 Cal.App.4th 205, 211212 ................................ 14
Nielsen v. Stumbos (1990) 226 Cal.App.3d 301 ......................................................................... 6
OGrady v. Superior Court (1994) 21 Cal.App.4th 1021 .......................................................... 12
Pecsok v. Black (1992) 7 Cal.App.4th 456, 461 ....................................................................... 11
Simon v Bemis Bros. Bag Co. (1955, 2nd Dist) 131 CA. 2d 378 ............................................. 12
Vadas v. Sosnowski (1989) 210 Cal.App.3d 471, 473 ................................................................ 7
Webster v. Superior Court (1988) 46 Cal.3d 338, 344 ............................................................... 8

STATUTES
CCP 916 ......................................................................................................................... 6, 9, 11
CCP 917.1 .................................................................................................................... 6, passim
CCP 1033.5 ........................................................................................................................ 6, 11
Penal Codes 132 and 134 ...................................................................................................... 13
OTHER AUTHORITIES
AB 58 ................................................................................................................................ 8, 9, 11

INTRODUCTION
Respondents Brief is riddled with misrepresentations of the facts and the law.
It woefully fails to address the sole issue recited in Appellants Opening Brief:
Did the court err by ignoring a Supreme Court directive to
distinguish attorney fees as a non-routine cost--requiring
an undertaking to stay enforcement pending appeal?
There is no case, code or appellate rule authorizing a respondent to paraphrase
or intentionally distort the issue presented in an Appellants Opening Brief as follows:
Did the Trial Court err in finding that an Order solely awarding
attorneys fees as costs, unaccompanied by a money judgment,
is automatically stayed on appeal under Code of Civil Procedure
section 917.1(d) without the necessity of posting a bond.
Stubblefield employs his regular, unfair litigation tactic of paraphrasing to lead
this Panel down a primrose path to error---just as he did with Judge Sachs in 2014.
Respondent inserted the words or resident into the original judgment in this case,
delivered the tweaked judgment directly to chambers, without serving it on counsel,
to hoodwink Judge Sachs into signing a judgment authorizing Stubblefield to directly
evict Shipley--contrary to a clear directive in a previously issued writ of mandate.
Shipley had to appeal her own victory to invoke a Panel to correct the judgment.
Respondents unfair tactic resulted in a 2-year delay in awarding Shipley attorney fees.
Respondent filed a frivolous appeal of the same fee award solely to delay paying it.
Then respondent led the trial court below down the same primrose path to clear error,
by misrepresenting facts and artfully omitting controlling Supreme Court authority. 1

Bank of San Pedro v. Superior Court (1992) 3 Cal.4th. 797


5

I. Order is Not Presumed Correct When it Ignores Supreme Court Mandates


Respondents paraphrasing of the issue on appeal bypasses the entire point!
It is not whether attorney fees are recoverable under CCP 1033.5 as a routine cost
[stayed on appeal by CCP 916] -- but whether those fees are an extraordinary cost
[not stayed on appeal by CCP 916 unless the losing party posts a security bond].
AOB explained how our Supreme Court resolved appellate conflicts by hearing
Bank of San Pedro in 1992; how our legislators amended CCP 917.1 to codify it;
and how subsequent conflicts arose after Chapala Management Corp. v. Stanton
(2010) 186 Cal.App.4th. 337 refused to apply Bank of San Pedro to attorney fees.
There are no published cases following Chapala Managements contrary findings.
The trial court breached a duty to apply Bank of San Pedros controlling authority. 2
The High Court found an attorney fee award is an extraordinary cost --- and was
not a routine cost as defined in CCP 1033.5 -- automatically stayed by CCP 916.
It expressly approved Chamberlins finding that an attorney fee award is an order
for the payment of money as defined in CCP 917.1 (a)(1) --- exempt from the
automatic stay in CCP 916 and expressly disapproved contrary holdings:
In Chamberlin v. Dale's R.V. Rentals, Inc. (1986) 188 Cal.App.3d 356,
. court concluded the then-existing rule that costs were not included
for such purpose did not extend to the award of attorney fees. Unlike the
costs involved in the early cases, such attorney fees are in the nature of
a directly litigated issue rather than merely incidental to the
judgment. Further, attorney fees are not the type of costs involved in
virtually every case. Attorney fees are awarded only in limited
situations....A different Court of Appeal, however, subsequently held that
where a party recovers no money damages but only a judgment for costs,
including an award of attorney fees under Civil Code section 1717, no
undertaking is required for a stay of judgment on appeal. (Nielsen v.
Stumbos (1990) 226 Cal.App.3d 301) San Pedro @ 801-802
2

Auto Equity Sales, Inc. v. Superior Court (1962) 57 Cal.2d 450, 455
6

...The Court of Appeal in this case, however, held that Vadas,


supra, 210 Cal.App.3d 471, which involved only routine costs, is
distinguishable from the present case. The Court of Appeal relied
instead on Chamberlin v. Dale's R.V. Rentals, Inc., supra, 188
Cal.App.3d 356, for the principle that non-routine costs must be
treated differently from routine costs. The Court of Appeal further
concluded that expert witness fees awarded under section 998,
subdivision (c) are not routine costs We agree with both conclusions
San Pedro @ 802
"The perfecting of an appeal shall not stay enforcement of the
judgment or order in the trial court if the judgment or order is for
money or directs the payment of money, whether consisting of a
special fund or not, and whether payable by the appellant or another
party to the action, unless an undertaking is given."The question
in this case is whether the order awarding expert witness fees under
section 998, subdivision (c) is an order that "directs the payment of
money" within the meaning of section 917.1, subdivision (a).
[1a] On its face the order directs the payment of money-$116,184.05-by
plaintiff to defendant, and is therefore within the literal language of
section 917.1, subdivision (a).
Bank of San Pedro @ 800

. "A judgment for costs is not the judgment directing the payment of
money contemplated by section 942. If such were the fact, a stay bond
would be required in almost every conceivable case
The exception in section 917.1 to the automatic stay provision of
section 916 would cease to be an exception; it would subsume the
general rule. Such a result could not have been consistent with the
Legislature's intent.
Bank of San Pedro @ 801
. We therefore have held that a judgment for costs alone was
not a judgment directing the payment of money within the
meaning of former section 942 (now section 917.1, subdivision (a))
and was therefore stayed without the need for an undertaking
[cites] This rule has become well established. (See, e.g.,Vadas
v. Sosnowski (1989) 210 Cal.App.3d 471, 473.
San Pedro @ 801
7

The Court of Appeal in this case correctly explained that, "Expert witness
fees, like attorneys' fees, are not ordinarily a part of costs awarded at
trial. Further, the award of expert witness fees (1) is not the type of cost
included in virtually every case and (2) was a directly litigated issue, as
opposed to being an incidental matter. Specifically, the record reflects that
two separate hearings were conducted, involving two motions. Id @ 803
We must not lose sight of the fact that we are dealing with a statutory
question and that we must attempt to reach a result comporting with the
Legislature's intent. (Webster v. Superior Court (1988) 46 Cal.3d 338, 344
[250 Cal.Rptr. 268) The Court of Appeal's decision in this case achieves
this goal in several respects. Bank of San Pedro @ 803-804
Bank of San Pedro (1992) was codified 1993 legislative sessions as follows:
Documents associated with AB 58 in the Session Status

612 bytes

History-2529 bytes
Chaptered-09/27/93
Enrolled-08/27/93
Introduced-12/22/92
ASSEMBLY FLOOR: VOTES-ROLL CALL MEASURE:
AB58
AUTHOR: Peace
TOPIC: Actions and proceedings.
DATE: 09/02/93 LOCATION: ASM. FLOOR MOTION:
AB58
PEACE SPEC. CONSENT CALENDAR SECOND DAY
CONCURRENCE
(AYES 77. NOES 0.) (PASS)
Senate Floor: VOTES - ROLL CALL MEASURE:
AB58
AUTHOR: Peace
TOPIC: Actions and proceedings.
DATE: 08/27/93
LOCATION: SEN. FLOOR MOTION:
CONSENT CALENDAR
(AYES 37. NOES 0.) (PASS)
BILL ANALYSIS
CONSENT AB 58 Peace (D)
5/28/93
SUBJECT: Civil procedure

8/16//93 in Senate 21 67-0, p. 2110,


(Passed Assembly on Consent)
SOURCE: State Bar

Existing law specifies the circumstances under which an undertaking


is required in order to stay the enforcement of a judgment or order on
appeal. This bill would codify case law and require an undertaking or a
bond to be filed for a stay of enforcement of an order for extraordinary
costs awarded pursuant to specified Code of Civil Procedure sections.
It would also grant the court discretion to condition a stay of an award
of costs in other cases upon the filing of an undertaking.
RJG:ctl 8/19/93 Senate Floor Analyses
8

BILL ANALYSIS
SENATE COMMITTEE ON JUDICIARY
Bill Lockyer, Chairman
1993-94 Regular Session AB 58 (Peace)
As amended: August 16
Hearing date: August 17, 1993
Code of Civil Procedure
GWW:RF CIVIL PROCEDURE HISTORY
Source: Irwin Nowick; State Bar Prior Legislation:
AB 2616 (1992) - Chaptered)
Support: California Judges Association
Opposition: No known
Assembly Floor vote: Ayes 67 - Noes 0
SHOULD AN UNDERTAKING OR BOND BE REQUIRED TO STAY
ON APPEAL THE ENFORCEMENT OF AN ORDER FOR
EXTRAORDINARY COSTS?
The Supreme Court in Bank of San Pedro v. Superior Court, (1992)
3 Cal.4th 797, held that costs which have been awarded pursuant to
C.C.P. 998 (failure of a party to accept fair compromise offer) or C.C.P.
1141.21 (a judgment in a trial de novo that is less favorable then the
arbitration award) are extraordinary costs. Thus, a bond or undertaking
must be filed in order to stay enforcement of those orders.
AB 58 would codify the San Pedro case. It would also give to trial courts
the discretion to condition a stay of an award of cost in all other cases
upon the filing of a sufficient bond or undertaking.
http://www.leginfo.ca.gov/cgibin/postquery?bill_number=ab_58&sess=
9394&house=B&author=assembly_member_peace
The High Court held an award for extraordinary costs (such as attorney fees and
expert witness fees) must be distinguished from routine costs stayed by CCP 916.
It held orders directing the payment of money are excepted under 917.1(a)(1).
Inferior courts must follow Supreme Court mandates.3 The Chapala Management
v. Stanton Panel erred by failing to follow mandates recited in Bank of San Pedro.
In 6 years no published cases have ever followed Chapala Management (2010).
At http://www.calattorneysfees.com/cases_undertaking an attorney fees web author noted:

BLOG UNDERVIEW--The fees only undertaking issue is not as clean


as one might think. See the reasoning of the Fourth District, Division 3 in
Behniwal v. Mix, also discussed in our August 1, 2010 post on Chapala
Management, which seems to go the other way on this issue.
3

Auto Equity Sales, Inc. v. Superior Court (1962) 57 Cal.2d 450, 455
9

In Behniwal v. Mix, the Panel cited Bank of San Pedro, supra as follows:
[1] After canvassing the relevant authorities, particularly
Isaac, supra, 66 Cal.App.4th 586 and Bank of San Pedro v.
Superior Court (1992) 3 Cal.4th 797 [attorney fees awarded
pursuant to contract are not truly "incidental" to judgment]
Behniwal v. Mix (2007)147 Cal.App.4th 62, 624
Nor can, as we soon show, such an award be characterized as an
"incident" of the specific performance judgment on the theory that
the attorney fee provision is a mere "cost" authorized by statute.
The logic for such a result goes like this: Attorney fees recoverable
under contract are deemed "costs" under Civil Code section 1717
and Code of Civil Procedure section 1033.5; Dennis shows that
"costs" awarded in a suit may be offset against the purchase price
in a specific performance decree; ergo, attorney fees awarded
under contract may be deducted from the purchase price in a
specific performance decree.
Behniwal v. Mix @ 624
The logic breaks down because, as we will soon show, under Bank
of San Pedro, supra, 3 Cal.4th 797, contractual attorney fee awards
really aren't the sort of "routine" costs that the Dennis court dealt
with in passing. Rather, they are a separately litigated issue. Id
However, the Supreme Court held otherwise, making three points
that, as it turns out, are applicable to the case before us now. First,
the court said expert witness fees -- and in the process lumped
attorney fees into the same category -- are not "routine" costs.
They are a directly litigated issue. fn. 8 Second, expert witness
fees (and surely, we can add, attorney fees) are always a matter
of trial court discretion, even if awarded as a matter of right.
fn. 9 .
We recognize, of course, that the present case is not about
whether a bond is required for an attorney fee award included in a
judgment, but the Supreme Court's resolution of the expert fee
matter in Bank of San Pedro renders the buyers' logic here
untenable: In light of Bank of San Pedro, they cannot claim that
their attorney fee award is merely a "routine cost" included in the
judgment, deductible from the purchase price the same way that
the costs of duplication of reply briefs were deductible in Dennis.
Behniwal v. Mix @ 633-634
10

We need only add that, in distinguishing directly litigated issues


(like expert witness fees and attorney fees) from "routine"
costs, the Bank of San Pedro decision validated a distinction
impliedly drawn by the Kamper v. Mark Hopkins, Inc., supra, 78
Cal.App.2d 885 decision.
Behniwal v. Mix @ 635
It cannot be disputed that our Supreme Court in Bank of San Pedro, supra
expressly held attorney fee and expert witness fee awards, are not routine costs
automatically stayed under CCP 916, but are directly litigated issues--classified
as extraordinary costs excepted from stay by CCP 917.1(a)(1).
It cannot be disputed that our legislators codified Bank of San Pedro in AB58,
which expressly recited their specific intent to codify Bank of San Pedro, supra.
It cannot be disputed that trial courts are not authorized to ignore controlling
authority simply because they disagree with it. Auto Equity, supra.
It cannot be disputed the trial court below erred as a matter of law--not only by
misinterpreting CCP 916 and 917.1, but also by following an inferior courts
erroneous holding [which no other published case has followed in 6 years] instead
of following Supreme Court controlling authority as required in Auto Equity, supra.
Finally, and most importantly, the High Court in Bank of San Pedro, supra
expressly overruled Pecsok v. Black (1992) 7 Cal.App.4th 456 in fn 4 as follows:
FN 4. In Pecsok v. Black (1992) 7 Cal.App.4th 456, 461,
the Court of Appeal noted our grant of review in the present
case but rejected any distinction between routine and
nonroutine costs. We disapprove Pecsok to the extent it is
contrary to our decision in the present case.
It cannot be disputed the High Court in Bank of San Pedro disapproved of
any court who rejected its distinction between routine and non-routine costs.
Shipley filed 3 Memoranda of Costs (under CCP 1033.5) within 15 days of
prevailing on the writ of mandate, and respondents two appeals of the writ.
Those were the routine costs incident to judgment recited in CCP 1033.5.
Attorney fee award was our extraordinary cost which must be distinguished.
11

Appellants reliance on OGrady v. Superior Court (1994) 21 Cal.App.4th 1021


was not prohibited. Appellants AOB disclosed, at footnote 10 [page 10], that a
rehearing was granted, but then cancelled due to subsequent settlement of the case.
The case was never ordered depublished. After the case settled counsel never
followed up to correct the heading reciting a rehearing had been scheduled, which
never occurred due to the settlement.

The OGrady panel provided an extensive

analysis of the rationale used by our Supreme Court in Bank of San Pedro, supra.
II. Sanctions Request is Procedurally Deficient and Factually Unwarranted
Respondents Sanctions Request is procedurally deficient as Stubblefield failed
to request sanctions by a separate motion as required under CRC, Rule 8.276 (e):
Party required to defend a civil action on appeal failed to properly
request sanctions against plaintiff for bringing a frivolous appeal;
defendant failed to make its request by separate motion, as required by
former Cal. Rules of Court, Rule 26(e) (see now Cal. Rules of Court,
Rules 27 and 29.7). Bono v Clark (2002, 6th Dist) 103 CA 4th 1409
Even if respondent had complied with the prerequisite of filing a separate motion
prior to seeking sanctions, there is no basis in fact to request sanctions in this case.
An appeal is not frivolous where proof introduced by appellant is substantial and
persuasive, and is presented in a courteous and gracious manner. Simon v Bemis Bros.
Bag Co. (1955, 2nd Dist) 131 CA. 2d 378. Each appeal must be evaluated on its merits.
Respondent continues to hark back to a comment about Judge Sachs in a 2014 appeal,
which was resolved in Shipleys favor in 2014. Appellants opening brief here was
professional and did not make one disparaging remark about the court or respondent.
AOB recited a professional outline of conflicts in the Appellate Districts prior to 1992,
analyzed the Supreme Courts 1992 holdings in Bank of San Pedro; analyzed the 1993
legislative revisions to CCP 917.1 codifying Bank of San Pedro; and lastly explained
how the Chapala Management case generated further appellate conflicts.
12

The only party deserving sanctions is respondent. Despite a unanimous jury verdict
for McCarron, after a 4-week trial on a second frivolous eviction [see RJN Exh. A],
judgment for Shipley on the first frivolous eviction, a mysterious fire at space 333,
the Hart\King firm continues a campaign of frivolous evictions to filch mobilehomes.
[see RJN Exh. B] which is Hart\Kings filing in an Anaheim-Orange County Court.
It asks the court to take Judicial Notice of a fraudulent legislative intent purporting to
support a 5-day Notice to Surrender Possession as a valid instrument to evict occupants.
The firm continues to use the fraudulent instrument to filch homes from occupants who
are not purchasers or transferees and are not in privity of contract with the parkowner.
The Hart\King firm was served with a writ of mandate from this court explaining
how the notice could not be used to evict persons who are not purchasers or transferees
and who are not in privity of contract with the park owner. The firm appealed the order
and lost at the Fourth District Court of Appeal, Div. 4 and California Supreme Court.
The firm lost both appeals. Accordingly the firm knows the instrument they continue
to use to filch homes on behalf of greedy park owners is invalid and totally fraudulent.
Not only is the firms continued use of the invalid 5-day notice to steal mobilehomes
a violation of Penal Codes 132 and 134 (knowingly filing fraudulent documents in
court for an illegal purpose) but also constitutes a conspiracy to commit grand theft of
personal property whose value exceeds $5,000. Shipley asks this court to notify the
Anaheim Court Judge, and all other state Judges of this firms racketeering enterprise
and its unethical attorneys who prosecute fraudulent evictions to steal mobilehomes.
(see RJN Exh. B).
The court should not allow Hart|King to continue filching homes from poor, elderly
and disabled residents---to enrich wealthy park owners who pay their legal fees to filch
homes via fraudulent evictions based on invalid 5-day Notices to Surrender Possession.

13

GLOBAL EFFECT OF ENJOINING ENRCEMENT WITHOUT A BOND


Enjoining enforcement without requiring a bond will result in a tsunami of appeals.
There is no incentive not to roll the dice on appeal, where appellant is given an entire
year, or several years in protracted appeals, to liquidate assets and transfer funds out of
the country to avoid satisfying a judgment. It is an abuse of discretion for a court to
leave a prevailing party unprotected and without security pending the losers appeal.
Shipley asks the Panel to direct the trial court to reverse its ruling authorizing the
losers appeal without posting a bond---as required under CCP 917.1(a)(1) and
controlling Supreme Court authority in Bank of San Pedro, supra. Shipley asks
this Panel to award all costs and attorney fees she is entitled to under the law.
CONCLUSION
The purpose of the undertaking requirement is to protect the judgment won
in the trial court from becoming uncollectible while the judgment is subjected to
appellate review. A successful litigant will have an assured source of funds to meet
the amount of the money judgment, costs and post-judgment interest after postponing
enjoyment of a trial court victory. Grant v. Superior Court (1990) 25 C.A.3d 929, 934
In implementing this purpose, section 917.1 does not tailor the amount of the
undertaking to the peculiarities of the judgment. To the contrary, it is rigidly
formulaic: The undertaking shall be for double the amount of the judgment or order
unless given by an admitted surety insurer in which event it shall be for one and onehalf times the amount of the judgment or order. ( 917.1, subd. (b) . . . .).
Leung v. Verdugo Hills Hospital (2008) 168 Cal.App.4th 205, 211212.
A trial court lacks power to stay enforcement of the money judgment pending
appeal without the undertaking required by section 917.1, unless the statutory
exception applies. (See Sharifpour v. Le (2014) 223 Cal.App.4th 730, 733
[section 917.1, subdivision (a)(1) requires the giving of an undertaking to stay
enforcement of a money judgment.].)
14

Nor does it appear that the court had discretion to order an amount less than that set
forth in the statute, absent the exception. Leung, supra, 168 Cal.App.4th at p. 212.
Stubblefield failed to provide a scintilla of evidence to show irreparable harm would
occur if he had to post a bond pending appeal. Stubblefield is a wealthy developer who
can afford a bond for $197,857.50. Stubblefield could have written off the cost of a
bond as a regular business expense. The court did not even consider the irreparable harm
to Shipley in denying her security to collect a fee award. Stubblefield has many months
to transfer assets and money into any one of his sham entities to avoid paying his debt
[$197,857.50 +lo% interest when a mandatory attorney fee award is affirmed on appeal]
A court is required to weigh the benefits and burdens before issuing an injunction.

There are no burdens to Stubblefield and severe burdens to Shipley as there is no


security to collect her award. There are only benefits to Stubblefield in that he can delay
paying the judgment and transfer assets over the next year to avoid paying. Shipley has
no bond to cover risks of a potentially significant loss. There are no benefits to Shipley.
The trial court clearly erred in failing to apply stare decisis (Bank of San Pedro),
following an inferior court's erroneous decision, and in failing to balance equities
between the parties, as required before issuing an injunction.

Respectfully submitted 2127116

CERTIFICATE OF COMPLIANCE
The undersigned certifies Appellant's REPLY Brief consists of 4,307 words as shown
in Microsoft Word 2010 used to produce the brief in Times Roman Font, 13 points y
i
t
J
the TOC and TOA. The undersigned certifiwhis is true under penalty of perjury.
Executed on 2127116.
~ a n m u f f y ' f v l c ~ a r r oAttorney
n,
for Shipley

PROOF OF SERVICE
STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
Stubblefield v. Shipley ASIAS 1500049 UDFS 1204130

Undersigned is counsel for Bonnie Shipley: 950 Roble Ln, Santa Barbara, CA 93 103
cell 805-450-0450 tellfax 805-965-3492
The undersigned served respondent plaintiff with the following documents:
APPELLANT'S REPLY BRIEF- Appeal Issue STAY without a BOND
[ ] (By Personal Delivery)
[ ] (By Fax) The fax machine used complied with Rule 2003(3) and no error was
reported by machine, pursuant to Rule CRC, 2008 [c](4) I caused the machine to
maintain a record of same.
[ ] (By Electronic) to address below (agreement) & nancydufQsb@yahoo.com

rwilliamson@hartkinglaw.com
[XI(By US Mail) $ 1013a, $20 15.5 CCP. I deposited documents in a pre-paid
stamped envelope to:
Robert G. Williamson, Attorney for AppelleePlaintiff
HART\KING
4 Hutton Center Drive, Suite 900
Santa Ana, CA 92707
I am familiar with mail collection in [ ] San Bernardino [XI Santa Barbara.
I deposited the envelope in a US mailbox located in [ ] San Bernardino [x] Santa
Barbara, 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.
[XI (STATE) I declare under penalty of perjury and California law the above is true.
Executed in Santa Barbara, CA on the date indicated below.

V
&w
~ a n ~bu f~f $ h c ~ a r r o nAttorney
,
for Appellant