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JAN-28-2017 @9:35A FROM:CAL AUTO BROKERS 18668219323 TO: 18668219323 Pal www aw an ‘ Merele D. Chapman, Esq., Bat No: 170724 ‘\ DEC sa am Law Office of Merele D. Chapman 1717, Vista Chino A7486 : Palm Springs, California 92262 “ (760) 320-3656 2 Attomey for Defendants: Think Vast Conservancy Trust David Lamb in his Capcity as Trustee of Think Vast at Conservangy Trt st; T-B.A. Entity; David Lamb in his Capacityas Manager of T.B.A. Entity SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO RICHARD PURVIS, CASENO: CIVDS 1620118 Plaintiff, ANSWER O! DEFENDANT. ‘S THINK VAST vs. poe TRUST; DAVID LAMB IN HIS CAPACITY AS TRUSTEE OF STEPHEN HURT, AN INDIVIDUAL; THR VAST Sea acne THINK VAST CONSERVANCY TRUST erroneously sued as THINK VEST een ICY TRUST; DAVID /AMB IN HIS CAPACITY AS TRUSTEE oF THINK VAST CONSERVANCY ‘TRUST erroneously sued as LAMB,IN HIS CAPACITY. aS TRUSTEE ol ‘TRUST; T.B.A. ENTITY; DAVID LAMB IN HIS CAPACITY AS NANAGER OF T.B.A. ENTITY TO THE COMPLAINT OF RICHARD PURVIS MANAGER OF T.B.A. ENTITY; and DOES 1-100, INCLUSIVE, Defendant } ‘THINK VAST CONSERVANCY TRUST; DAVID LAMB IN HIS CAPACITY AS TRUSTEE OF THINK VAST CONSERVANCY TRUST; T.B.A. ENTITY; DAVID LAMB IN HIS CAPACITY AS MANAGER OF T.B.A. ENTITY, answer the Verified Complaint as follows: 1. Answering Paragraph one of Plaintiff's Complaint these defendants based on information and belief admit the allegations contained therein based on that information and belief. 2. Answering Paragraph two of Plaintiff's Complaint these defendants based on information and belicf admit the allegations contained therein based on that information and belief. 1 ANSWER OF DEFENDANTS THINK VAST CONSERVANCY TRUST; DAVID LAMB IN HIS CAPACITY AS. ‘TRUSTEE OF THINK VAST CONSERVANCY TRUST; T.B.A. ENTITY; DAVID LAMB IN HIS CAPACITY ‘AS MANAGER OF T.B.A. ENTITY JON-28-2017 @9:35A FROM:CAL AUTO BROKERS = 18668219323 TO: 19668219323 Pe ee yaw sewn 10 u 2 13 14 15 16 7 18 19 20 2 2 2B 24 25 26 27 28 Answering Paragraph three of Plaintiff's Complaint these defendants admit the allegations contained therein that THINK VAST CONSERVANCY TRUST, is a trust organized and existing under the laws of the State of California. However, itis considered a Business Trust under Internal Revenue Service and therefore, is considered a Business Trust under the laws of the State of California. Answering Paragraph four of Plaintiff's Complaint these defendants allege that David Lamb is the Trustee of the THINK VAST CONSERVANCY TRUST. Defendants admit that ‘THINK VAST CONSERVANCY TRUST is doing business in Riverside County, CA.. Answering Paragraph five of Plaintiff's Complaint these defendants admit that T.B.A. Entity is aholding entity doing business in Riverside County, CA.. Answering Paragraph six of Plaintiff's Complaint these defendants admit the allegations contained therein.. 7. Answering Paragraph seven of the Plaintiff's Complaint these defendants have no information or belief sufficient to enable them to admit the allegations of Paragraph seven of ‘the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. 8. Answering Paragraph eight of the Plaintiff's Complaint these defendants have no information or belief sufficient to enable them to admit the allegations of Paragraph eight of the ‘Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. 9 Answering Paragraph nine of the Plaintiff's Complaint these answering defendants specifically deny that they conspired with anyone to injure Plaintiff. As to the remaining allegations contained therein these defendants have no information or belief sufficient to enable them to admit the allegations of Paragraph nine of the Complaint herein, and placing. their denial on that ground, denies each and every allegation thereof. 2 ANSWER OF DEFENDANTS THINK VAST CONSERVANCY TRUST; DAVID LAMB IN HIS CAPACITY AS "TRUSTEE OF THINK VAST CONSERVANCY TRUST; T.B.A. ENTITY; DAVID LAMB IN HIS CAPACITY ‘AS MANAGER OF T.B.A. ENTITY JAN-28-2017 @9:35A FROM:CAL AUTO BROKERS 18668219323 TO: 18668219323 PS 10. 12, AS TO THE ALLEGATIONS CONTAINED IN THE FIRST CAUSE OF ACTION: ‘THIS CAUSE OF ACTION ONLY NAMES STEPHEN HURT AND, THEREFORE, THESE ANSWERING DEFENDANTS INCUR NO LIABILITY FROM THIS CAUSE OF ACTION. ‘Answering Paragraph ten of the Plaintiff's Complaint these answering defendants incorporate by reference as though fully set forth the answers set forth in paragraphs 1-9 inclusive. ‘Answering Paragraph eleven of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph eleven of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. ‘Answering Paragraph twelve of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph twelve of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. ‘Answering Paragraph thirteen of Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph thirteen of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. “Answering Paragraph fourteen of the Plaintiff's Complaint these answering defendants admit that the Plaintiff and Defendnat Stephen Hurt entered into a land sale contract for the purchase of the subject property as evidenced by Exhibit B contained in the complaint. As to all other allegations contained in Paragraph fourteen these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph thirteen of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. “These answering Defendants admit to the allegations contained in paragraph fifteen of the Plaintiff's complaint. ‘Answering Paragraph sixteen of the Plaintiff's Complaint these defendants lack sufficient 3 ANSWER OF DEFENDANTS THINK VAST CONSERVANCY TRUST; DAVID LAMB IN HIS CAPACITY AS: "TRUSTEE OF THINK VAST CONSERVANCY TRUST; T.B.A. ENTITY; DAVID LAMB IN HIS CAPACITY ‘AS MANAGER OF T.B.A. ENTITY JAN-28-2017 @9:36A FROM:CAL AUTO BROKERS 18668219323 20. 21 Pe TO: 18668219323 Pd information to enable them to admit or deny the allogations of Paragraph sixteen of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. ‘Answering Paragraph seventeen of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph seventeen of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. “Answering Paragraph eighteen of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph eighteen of the ‘Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. ‘Answering Paragraph nineteen of the Plaintiff’s Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph nineteen of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof, ‘Answering Paragraph twenty of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph twenty of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. “Answering Paragraph twenty-one of the Plaintif's Complaint these defendants lack sufficient {information to enable them to admit or deny the allegations of Paragraph twenty-one of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. ‘Answering Paragraph twenty-two ofthe Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph twenty-two of the Complaint heein, and placing their denial on that ground, denies each and every allegation thereof. 4 ANSWER OF DEFENDANTS THINK VAST CONSERVANCY TRUST; DAVID LAMB IN HIS CAPACITY AS TRUSTEE OF THINK VAST CONSERVANCY TRUST; T.B.A. ENTITY; DAVID LAMB IN HIS CAPACITY ENTITY ‘AS MANAGER OF T. JON-28-2017 @9:37A FROM:CAL AUTO BROKERS = 18668219323 een eee ee TO: 19668219323 PS ‘AS TO THE ALLEGATIONS CONTAINED IN THE SECOND CAUSE OF ACTION: ‘THIS CAUSE OF ACTION ONLY NAMES STEPHEN HURT AND, THEREFORE, THESE ANSWERING DEFENDANTS INCUR NO LIABILITY FROM THIS CAUSE OF ACTION. 23 Answering Paragraph twenty-three of the Plaintiff's Complaint these answering defendants incorporate by reference as though fully set forth the answers set forth in paragraphs 1-22 inclusive. 24. Answering Paragraph twenty-four of the Plaintif's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph twenty- four of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. 25. Answering Paragraph twenty-five of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph twenty- five of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. 26. Answering Paragraph twenty-six of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph twenty-six of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. AS TO THE ALLEGATIONS CONTAINED IN THE THIRD CAUSE OF ACTION: ‘THIS CAUSE OF ACTION ONLY NAMES STEPHEN HURT AND, THEREFORE, THESE ANSWERING DEFENDANTS INCUR NO LIABILITY FROM THIS CAUSE OF ACTION. 27. Answering Paragraph twenty-seven of the Plaintiff's Complaint these answering defendants incorporate by reference as though fully set forth the answers set forth in paragraphs 1-26 inclusive, 28. Answering Paragraph twenty-eight of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph twenty- eight of the Complaint herein, and placing their denial on that ground, denies each and every 5 ANSWER OF DEFENDANTS THINK VAST CONSERVANCY TRUST; DAVID LAMB IN HIS CAPACITY AS TRUSTEE OF THINK VAST CONSERVANCY TRUST; T.B.A, ENTITY; DAVID LAMB IN HIS CAPACITY ‘AS MANAGER OF TBA. ENTITY JAN-28-2017 @9:37A FROM:CAL AUTO BROKERS 18668219323 TO: 18668219323 P.6 29. 30. at i allegation thereof. Answering Paragraph twenty-nine of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph twenty- nine of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. Answering Paragraph thirty of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph thirty of the Complaint herein, and placing their denial on that ground, denies cach and every allegation thereof. Answering Paragraph thirty-one of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph thirty-one of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. AS TO THE ALLEGATIONS CONTAINED IN THE FOURTH CAUSE OF ACTION: ‘THIS CAUSE OF ACTION ONLY NAMES STEPHEN HURT AND, THEREFORE, THESE ANSWERING DEFENDANTS INCUR NO LIABILITY FROM THIS CAUSE OF ACTION. 32. 33, 34, 35. Answering Paragraph thirty-two of the Plaintiff's Complaint these answering defendants incorporate by reference as though fully set forth the answers set forth in paragraphs 1-31 inclusive. Answering Paragraph 33 of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph33 of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof, Answering Paragraph 34 of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph 34 of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. Answering Paragraph 35 of the Plaintiff's Complaint these defendants lack sufficient 6 ANSWER OF DEFENDANTS THINK VAST CONSERVANCY TRUST; DAVID LAMB IN HIS CAPACITY AS ‘TRUSTEE OF THINK VAST CONSERVANCY TRUST; T.B.A. ENTITY; DAVID LAMB IN HIS CAPACITY AS MANAGER OF T.B.A. ENTITY JAN-28-2017 @9:38A FROM: 36. L AUTO BROKERS ==: 18668219323 TO: 18668219323 Pe information to enable them to admit or deny the allegations of Paragraph 35 of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. ‘Answering Paragraph 36 of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph 36 of the ‘Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. AS TO THE ALLEGATIONS CONTAINED IN THE FIFTH CAUSE OF ACTION: THIS CAUSE OF ACTION ONLY NAMES STEPHEN HURT AND, THEREFORE, THESE ANSWERING DEFENDANTS INCUR NO LIABILITY FROM THIS CAUSE OF ACTION. 37. 38. 39, 40. 4. Answering Paragraph 37 of the Plaintiff's Complaint these answering defendants incorporate by reference as though fully set forth the answers set forth in paragraphs 1-36 inclusive. Answering Paragraph 38 of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph 38 of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. Answering Paragraph 39 of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph 39 of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. Answering Paragraph 40 of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph 40 of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. Answering Paragraph 41 of the Plaintif's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph 41 of the Complaint herein, and placing their denial on that ground, denies each and every allegation 7 (OF DEFENDANTS THINK VAST CONSERVANCY TRUST; DAVID LAMB IN HIS CAPACITY AS ANSWER | ‘TRUSTEE OF THINK VAST CONSERVANCY TRUST; T.B.A. ENTITY; DAVID LAMB IN HIS CAPACITY ‘AS MANAGER OF T.B.A. ENTITY JAN-28-2017 @9:39R FROM:CAL AUTO BROKERS 18668219323 TO: 18668219323 Ps 1 thereof, 42. Answering Paragraph 42 of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph 42 of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. 43. Answering Paragraph 43 of the Plaintiff's Complaint these defendants lack sufficient information to enable them to admit or deny the allegations of Paragraph 43 of the Complaint herein, and placing their denial on that ground, denies each and every allegation thereof. wey awaeun 10] AS TO THE ALLEGATIONS CONTAINED IN THE SIXTH CAUSE OF ACTION 11] 44. Answering Paragraph 44 of the Plaintiff's Complaint these answering defendants incorporate 12 by reference as though fully set forth the answers set forth in paragraphs 1-43 inclusive. 13] 45. Answering Paragraph 45 of the Plaintiff's Complaint these defendants lack sufficient 4 information to enable them to admit or deny the allegations of Paragraph 45 of the 15 Complaint herein, and placing their denial on that ground, denies each and every allegation 16 thereof. 17] 46. Answering Paragraph 47 of the Plaintiff's Complaint these defendants lack sufficient 18 information to enable them to admit or deny the allegations of Paragraph 46 of the 19 Complaint herein, and placing their denial on that ground, denies each and every allegation 20 thereof. 21] 47. Answering Paragraph 47 of the Plaintiff's Complaint these defendants lack sufficient 2 information to enable them to admit or deny the allegations of Paragraph 47 of the 2B Complaint herein, and placing their denial on that ground, denies each and every allegation 24 thereof. 25|| 48, _Asto paragraph 48 these answering defendants allege that there is no dispute between these 26 answering defendants and the plaintiff. These answering defendants allege that the equitable 27 ‘ownership of the land is as stated in the land sale contract. ‘The plaintiff and defendant 28 ANSWER OF DEFENDANTS THINK VAST CONSERVANCY TRUST; DAVID LAMB IN HIS CAPACITY AS ‘TRUSTEE OF THINK VAST CONSERVANCY TRUST; T.B.A. ENTITY; DAVID LAMB IN HIS CAPACITY AS MANAGER OF T.B.A. ENTITY. JON-28-2017 89:39 FROM:CAL AUTO BROKERS = 18668219323 TO: 19668219323 Po ee ee 10 ul 12 B 14 45 16 7 18 19 20 2 22 23 25 26 27 28 Stephen Hurt are partners in the land purchase. AFFIRMATIVE DEFENSE NUMBER ONE: THINK VAST CONSERVANCY TRUST IS AN INTERNAL REVENUE ACT RETIREMENT FUND AND AS SUCH IS NOT SUBJECT TO CREDITORS. California Code of Civ. Proc. §704.115, subds (b), (4) treat funds held in a private retirement plans as fully exempt from collection by creditors. Think Vast Conservancy Trust as a Business ‘Trust under the Internal Revenue Code is a private retirement plan fully protected from creditors by CCP 704.115. AFFIRMATIVE DEFENSE NUMBER TWO: DEFENDANT THINK VAST CONSERVANCY TRUST HAS A SECURED INTEREST IN THE LAND. T.B.A. ENTITY had an equitable interest in the subject property with the Hallecks holding legal title. T.B.A. Entity then sold its equitable interest to Plaintiff and Stephen Hurt as partners subject to its secured interest pursuant to the Land Contract of Sale. . T.B.A Entity then assigned the Land Contract David Lamb, Trustee of the VAST CONSERVANCY TRUST and instructed Hallecks to transfer the legal title to David Lamb, Trustee of the VAST CONSERVANCY TRUST which Hallecks then did. As of this date, Plaintiff and Stephen Hurt are partners as purchasers of the subject real property. Upon fully paying the land contract the legal title to the property shall be transferred to Richard Purvis and Stephen Hurt as partners. There remains unpaid on the land contract of sale the amount of $36,889.38, Attached to this answer as Exhibit A is complete payment history for the Land Contract of Sale. WHEREFORE, Defendants pray: 1. That Plaintifft be granted no relief against these defendants; 2. For costs herein incurred; and 9 ANSWER OF DEFENDANTS THINK VAST CONSERVANCY TRUST; DAVID LAMB IN HIS CAPACITY AS ‘TRUSTEE OF THINK VAST CONSERVANCY TRUST; T.B.A, ENTITY; DAVID LAMB IN HIS CAPACITY AS MANAGER OF T.B.A. ENTITY JAN-28-2017 @9:40A FROM:CAL AUTO BROKERS 18668219323 TO: 18668219323 P.1a 1] 3. For such other and further relief as the court may deem proper Dated: December 29, 2016 emu awe wn 10 nN 12 13 4 15 16 7 18 19 20 21 2 24 25 26 27 28 10 ANSWER OF DEFENDANTS THINK VAST CONSERVANCY TRUST; DAVID LAMB IN HIS CAPACITY AS ‘TRUSTEE OF THINK VAST CONSERVANCY TRUST; T.B.A. ENTITY; DAVID LAMB IN HIS CAPACITY AS MANAGER OF T.BA. ENTITY. % 3 Peat JON-28-2017 @9:4@A FROM:CAL AUTO BROKERS = 18668219323 TO: 1966821932: VERIFICATION |, DAVID LAMB, am the trustees for the THINK VAST CONSERVANCY TRUST, one of the DEFENDANTS in the sbove-entitled action. I have read the foregoing petition and know the contents thereof. The same is true of my own knowledge, except as to those matters which are therein stated on information and belief, and as to those matters, I believe ivthem to be true, Tdeclare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Y December 29, 2016 wma aH aw 3 DAVID LAMB, Declarant x y x ah Sees eee BSRRREUOSLS ssa ncaeas Verification JON-28-2017 @9:4@A FROM:CAL AUTO BROKERS = 18668219323 TO: 19668219323 P.12 EXHIBIT A e Pils JAN-28-2017 @9:41A FROM:CAL AUTO BROKERS 18668219323 TO: 18668219323 Think Vast Conservancy Trust Payment History 39600 Eina Way Cathedral City, CA 92234 Reference (Dave: 760-275-8717 Purvis YMCMPNLA -RC TV desertram!@aol.com Printed: 12/27/16 Period: 01/01/15 - 12/31/16 Additional information Mr, Richard Purvis 1647 A Beaver Creek Beaumont, CA 92223-7389 W: 760-393-1944 Regular ome: 1000.00 ntrater Tato Orig ar a0 Esarow pt 0.09 inteate: Fired Origdste: oats Service fea: 200 Pmttype:—_UsRule 385% arr: eran Tota pt: 1000.00 NSF ow: 25.00 OrdDaynFee: 28 100.00 Teal iat: +1000 Pay Date Duertype Amount _AzgliedRat interest Principal nce See Ta ae ost 1000 00 00 66000.00 e000 0.00 oarous P e009 600000 0.00 sognan = sonon.00 0.00 ao a7076 OME R 100000 s00000 © 309.17 == gaaes = (gona 17 2.00 000 Botntees ovaaé wows R 1000.00 100000 «s0480©=eoess0aetgor 00 on cr) Botata47 ewoss ome R soo0.00 100000 © s0060 = gan.dn.=aotaar 00 000 000 Boratast Mss tomtns R — toone0 —t00n00 28627 ona. = arotags a0 00 00 Botatas foraor's wos R $0000 00000 asta 0802.88 ooo on 00 otasasa ‘2O1NS 12H R — 1000.00 100000 ere = r1248 a0 00 op 000 Botat452 “annual Tota 79000.00 ead) aab080 300 wan a0 Escrow Paid Out ao Gious ovoine 100000 10000 —aeaste—TH888 agave v0 a00 300 otras fase ooWNs R 100000 s00000 «aro ang0 | aassa.28 00 oo 00 Bosatasa sours oaowre R 190000 000.00 z7a28 rare asaznap 00 00 000 Borarasz owonts wore R 400000 100000 asare = ra028 = aza88.26 ooo 00 00 Boratas owsons oserne R 7524 Taare aztenas cao oo a0 asrine oewrte R 400000 00000 e070 ayant 200000 0.00 BotAters ornare o7mine R 100000 © 100000 258.13 «tang? asad eco 0 oan Botae7s ornare ommine R 100000 00090 astgs Tuna? nn.nn oo oo aco Botats77 oH0316 ovOHHe R 400000 100000 ma. 80 ser7e74 00 og 000 Pala 323 TO: 18668219323 JON-28-2017 @9:41A FROM:CAL AUTO BROKERS = 18668219: Think Vast Conservancy Trust Paymont History 39600 Ena Way Cathedral City, CA 92234 Bema a a . Dave: 760-275-8717 Purvis YMCMPNLA -RC Ww Page 2 ‘desertramt@zoleom Printed: 12/27/16 Period: 01/01/15 - 12/3116 FatQete Duefype Amount Aopedet wrest Pencil Balance “Beerour ? =P Bgance — ‘eee tomtna R“seonaoiemnae sense Faye 00 en 000 Borataat er cre ee te eee il semsot et aaraalh tees tana 200 040 90 Botatanz Taane tapie R —tc0000 Y00000 asage 38000.28 oon ano Boatees Aan Taar "2000.80 soa Escrow Pakd Out: JON-28-2017 @9:42A FROM#CAL AUTO BROKERS = 18668219323 P.as POS-030 ‘ATTORNEY OR FATT WITHOUT ATIOWNY fm Sam Bm, dana ft FomcouRT sem MERELE D. CHAPMAN ‘SBN: 170724 ‘MERELE D CHAPMAN 1717 £. VISTA CHINO A7-486 PALM SPRINGS, CA 92262 TELEPHONE HO: 760-320-3656, ‘Eaue AooRGES (Open: merelechapman@ymail,com __FAXNO. trina 760-406-5010 ‘Arromwe¥ FOR my: DAVID LAMB, THINK VAST CONSERVANCY TRUST, TBA. ‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO ‘meet aponess 247 West Third Street sau aconess. 247 West Third Street ‘env ao ze coot: San Bernardino, 92415-0210 eves nave San Bernardino District - Civil Division PETITIONERVPLAINTIFF: RICHARD PURVIS ‘RESPONDENTIDEFENDANT: STEPHEN HURT ET AL PROOF OF SERVICE BY FIRST-CLASS MAIL—CIVIL CIV Ds 1620118 (Do not use this Proot of Service to show service af a Summons and Complain) |. 1am ove: 18 years of age and not a party to this action. | am a resident ot or employed Inthe county where the maling took place, 2 My residence or business address is: 1717 E. VISTA CHINO A7-486, PALM SPRINGS, CA 92262 3 On (oate):12/2972016 | mailed trom (oly and state):PALM SPRINGS, CA the folowing documents (specity): ANSWER TO COMPLAINT [1 The documents are sted in the Attachment to Proat of Service by First-Class MalhChi, (Documents Served) (orm POS.030(0)) 4. |! served the documents by enclosing them in an envelope and (cheek one): 2. C2) depositing he sealed envelope withthe United States Postal Service wih the postage fuly propa. ». (1 placing the envelope for collection and maling folowing our ordinary business practices. |am ‘readily familar with this ‘business's practice for collacting and processing correspondence for mailing. On the same day that correspondence is laced for collection and malig, it's doposited inthe ordinary course of business with the United Slates Postal Service in ‘a sealed envelope with postage fly prepaid. 5. The envelope was addressed and mailed as follows: ‘Name of person served:RICHARD PURVIS b. Address of person served: 28 MOONLIGHT, IRVINE, CA 92603 1) The name and address of each person to whom | mall the documents is listed In the Attachment to Proof of: ‘Service by First-Class Mail~Civi (Parsons Served) (POS-030()). "coclare under penalty of perury under the laws ofthe tate of Caforna thatthe foregoing is true and correct. ae:22972016 {_ » MERELED CHAPMAN {HWP Eom PATNA OF Penson GOUPLETWG THS FOR (BGR OF pRGoN Cowra THE FOR eageeetacae PROOF OF SERVICE BY FIRST-CLASS MAIL—CIVIL ‘Coie Ci Promina 85 013, ose PSS oni ny 0) (Proot of Service) Wnt Oot Po soe

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