Opposition ObjectionsCal. Super. - 6th Dist.December 4, 2020MICHAEL A. MAZZOCONE, State Bar ¹183209 MICHAEL A. MAZZOCONE ATTORNEY AT LAW 601 Montgomery Street, Suite 850 San Francisco, California 94111 Telephone: (415) 399-0800 Facsimile: (415) 399-0900 Attorney for Defendant PG CAPITAL, LLC, A SERIES OF RAPJR INVESTMENTS, LLC, a Nevada Limited Liability Company 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA UNLIMITED JURISDICTION 12 13 14 15 16 17 18 19 20 21 22 23 24 1999 STONE LLC, ) ) Plaintiff, ) ) vs. ) ) PG CAPITAL, LLC A SERIES OF REPJR ) INVESTMENTS, LLC, a Nevada Limited) Liability Company; FRANCES LAVINIA) PAPAPIETRO, TRUSTEE OF THE) FRANCES LAVINIA PAPAPIETRO) SEPARATE PROPERTY TRUST DATED) AUGUST 27, 2018, PLM LOAN) MANAGEMENT SERVICES, INC., DOES) ONE through TWENTY FIVE, inclusive, ) ) Defendants. ) ) ) ) ) ) CASE NO. 20CV373828 Complaint filed: December 4, 2020 Trial date: TBD DATE: TIME: PLACE: TBD 8:15 a.m. TBD JOINDER OF DEFENDANT PG CAPITAL, LLC& A SERIES OF RAPJR INVESTMENTSi LLC TO OPPOSITION OF INTERESTED PARTY PRIVATE CAPITAL INVESTMENTS TO PLAINTIFF'S EX PARTE APPLICATION FOR ORDER TO SHOW CAUSE AND FOR TEMPORARY RETRAINING ORDER 25 26 27 28 Defendant PG CAPITAL, LLC, A SERIES OF RAPJR INVESTMENTS, LLC ("Defendant") hereby submits this Joinder to Interested Party Private Capital Investments'pposition to Plaintiff s Ex Parte Application for Order to Show Cause and for Temporary Retraining Order (the "Opposition") as follows: Joinder to Opposition to Ex Parte Application Electronically Filed by Superior Court of CA, County of Santa Clara, on 12/7/2020 4:51 PM Reviewed By: R. Burciaga Case #20CV373828 Envelope: 5425843 20CV373828 Santa Clara - Civil R. Burciaga Defendant hereby joins the Opposition, the arguments set forth therein, and the relief sought thereby. Dated: December 7, 2020 MICHAEL MAZZOCONE, ATTORNEY AT LAW By: Mich el A. zzocone, Esq. PG APIT, LLC, A SERI OF RPPJ VESTMENTS, LL, a Ne ada Limited Liabi tyCopany'0 12 13 14 15 16 17 19 20 21 22 23 24 25 26 27 28 Joinder to Opposition to Ex Parte Application PROOF OF SERVICE Case Name: 1999 Stone LLC vs PG CAPITAL, LLC, A SERIES OF RAPJR INVESTMENTS, LLC, a Nevada Limited Liability Company, et al. Court and Case No.: Sant Clara Superior Court, Case No: 20CV373828 I, the undersigned, declare that I am employed in the City and County of San Francisco, California. I am over the age of eighteen years and not a party to the within action. My electronic notification address is Michaei@Mazzlaw.corn. On December 7, 2020, I served the following documents: JOINDER OF DEFENDANT PG CAPITAL, LLC, A SERIES OF RAPJR INVESTMENTS, LLC TO OPPOSITION OF INTERESTED PARTY PRIVATE CAPITAL INVESTMENTS TO PLAINTIFF'S EX PARTE APPLICATION FOR ORDER TO SHOW CAUSE AND FOR TEMPORARY RETRAINING ORDER 8 9 10 11 12 13 14 15 16 on the part[y/ies] addressed as follows: Henry Chuang, Esq. Diemer & Wei, 55 South Market Street, Suite1420 San Jose, CA 95113-2365 hchuang@diemerwei.corn James Roberts, Esq. Roberts ~ Elliott Law Corporation 1798 Technology Drive, Suite 292 San Jose, CA 95110-1309 j roberts@robertselliott.corn Counsel for Interested Party Private Capital Investments Counsel for Plaintiff 1999 Stone LLC 17 19 ~o jp 21 22 23 24 BY MAIL by placing a true copy of each document listed above in a sealed envelope addressed to the parties listed above and/or on the attachment hereto and placing it for collection in my office for deposit in the United States Postal Service. I am readily familiar with the regular business practices of my office and attest that envelopes so placed for collection are deposited on the same business day with the United States Postal Service. BY ELECTRONIC SERVICE The document listed above was served electronically through One Legal and the transmission was reported as complete and without error. BY HAND I caused each such envelope to be delivered by had to the addressee(s) listed above and/or on the attachment hereto via messenger. BY ELECTRONIC MAIL The document(s) listed above was(were) served electronically to the electronic mail address(es) listed above and the transmission was reported as complete and without error. 25 26 0 BY FACSIMILE I caused a true copy to be transmitted via facsimile to the addressee(s) listed above and/or on the attachment hereto at the FAX number(s) noted aller the party's[ies'] address[es]. 27 28 I declare under penalty ofperjury under the laws of the State of California that the foregoing is true and correct. Executed on November 17, 2020, at San Francisco, California. Page I