Stephanie Clifford v. Donald J. Trump et al
Filing
1
NOTICE OF REMOVAL from Los Angeles Superior Court, case number BC696568 Receipt No: 0973-21427334 - Fee: $400, filed by Defendant Essential Consultants, LLC. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3) (Attorney Brent H Blakely added to party Essential Consultants, LLC(pty:dft))(Blakely, Brent)
Case 2:18-cv-02217 Document 1-2 Filed 03/16/18 Page 1 of 10 Page ID #:41
EXHIBIT 2
(Page 30
Case 2:18-cv-02217 Document 1-2 Filed 03/16/18 Page 2 of 10 Page ID #:42
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35)
CM-Q10
ATTORNtiYOR PARTY Wl
Micha&i J. A venara,
FOR COURTUSEONLY
r number, and address):
Mam, £
AVENATTI & ASSOCIATES, APC
520 Newport Center Drive, Suite 1400
FILED
Newport Beach, CA 92660
Superior Court of California
County of Los Angeles
fax no.: 949-706-7050
TELEPHONE NO.: 949"706"7000
ATTORNEY FOR (Name): Plaintiff
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
MAR 06 2018
street address: \ 1 \ North Hill Street
MAILING ADDRESS:
She ri R. Cerier, Executive Offieer/Ckrk of Court
city and zip code: Los Angeles. CA 90012
BRANCH NAME:
Stanley Mosk Courthouse
CASE NAME:
GlorteTta Robinson
CLIFFORD v. TRUMP, et al.
CIVIL CASE COVER SHEET
I / I Unlimited
I
I Limited
I
(Amount
(Amount
demanded
demanded is
$25,000 or less)
exceeds $25,000)
CASE NUM8ER:
Complex Case Designation
I Counter
I
-
^
^
^
^
BC6 9 6 5 6 8
I Joinder
Filed with first appearance by defendant
(Cal. Rules of Court, rule 3.402)
JUDGE:
DEPT:
Items 1-6 below must be completed (see instructions on page 2).
1 . Check one box below for the case type that best describes this case:
Contract
Auto Tort
I
Auto (22)
I
(Cal. Rules of Court, rules 3.400-3.403)
Other PI/PD/WD (Personal injury/Property
Damage/Wrongful Death) Tort
I
I
I Asbestos (04)
I Product liability (24)
I
I
I Medical malpractice (45)
I Other PI/PD/WD (23)
I I Rule 3.740 collections (09)
L_J Other collections (09)
I . ..I Insurance coverage (18)
I
j
I
I
I Uninsured motorist (46)
L_J Securities litigation (28)
I Other contract (37)
Real Property
I
I Eminent domain/Inverse
I
I
condemnation (14)
I
I
Non-PI/PD/WD (Other) Tort
I
I
Provisionally Complex Civil Litigation
I Breach of contract/warranty (OS)
I Environmental/Toxic tort (30)
I Insurance coverage claims arising from the
above listed provisionally complex case
I Wrongful eviction (33)
I Other real property (26)
j Business tort/unfair business practice (07)
Unlawful Detainer
I Civil rights (08)
types (41)
Enforcement of Judgment
I,.,, I Enforcement of judgment (20)
Commercial (31)
L_j Defamation (13)
I Antitrust/Trade regulation (03)
I Construction defect (10)
1 Mass tort (40)
Miscellaneous Civil Complaint
U3 Fraud (16)
CZ! Residential (32)
Z^| Rico (27)
t_J Intellectual property (1 9)
I
I Professional negligence (25)
I
I / I Other complaint (not specified above) (42)
Judicial Review
Miscellaneous Civil Petition
L_J
LJ
I
|
I
I
I
Other non-PI/PD/WD tort (35)
Employment
I'"" 1 Wrongful termination (36)
I
I Other employment (15)
2. This case
I
I is
I / I is not
1 Drugs (38)
Asset forfeiture (05)
Petition re: arbitration award (11)
Writ of mandate (02)
Other judicial review (39)
I Partnership and corporate governance (21)
Other petition (not spec/ffed above) (43)
complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the
factors requiring exceptional judicial management:
a. I
I Large number of separately represented parties
d. I
I Large number of witnesses
b. I
I Extensive motion practice raising difficult or novel
e. I
I Coordination with related actions pending in one or more courts
f. I
I Substantial postjudgment judicial supervision
issues that will be time-consuming to resolve
c. I
3.
I Substantial amount of documentary evidence
Remedies sought (check all that apply): a.l
i monetary
in other counties, states, or countries, or in a federal court
b. I / I nonmonetary: declaratory or injunctive relief
c. I
I punitive
4^ Number of causes of action (specify): 1 Declaratory Relief
5'J ^This case" I
I is
I / I is not
a class action suit.
6^-i If there are any known related cases, file and serve a notice of related case. (You may use form CM-015.)
Date: March 6, 2018
Michael J. Avenatti
^ ^^(sLdATUREOFPARTYORATTORNEYFORPARTY)
(TYPE OR PRINT NAME)
NOTICE
• Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed
under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
in sanctions.
• File this cover sheet in addition to any cover sheet required by local court rule.
• If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all
other parties to the action or proceeding.
• Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only.
Page 1 of 2
Form Adopted for Mandatory Use
Judicial Council of California
CM-010 [Rev. July 1, 2007]
CIVIL CASE COVER SHEET
Cal. Rules of Court, rules 2.30, 3.220, 3.400-3.403, 3.740;
Cal. Standards of Judicial Administration, sid. 3.10
www.coudinfo.ca.gov
(Page
31
Case 2:18-cv-02217 Document 1-2 Filed 03/16/18 Page 3 of 10 Page ID #:43
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35)
CM-010
i
INSTR
IONS ON HOW TO COMPLETE THE Ci
R SHEET
To Plaintiffs and Others Filing First Papers. If you are filing a first paper (for example, a complaint) in a civil case, you must
complete and file, along with your first paper, the Civil Case Cover Sheet contained on page 1 . This information will be used to compile
statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1 , you must check
one box for the case type that best describes the case. If the case fits both a general and a more specific type of case listed in item 1 ,
check the more specific one. If the case has multiple causes of action, check the box that best indicates the primary cause of action.
To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 are provided below. A cover
sheet must be filed only with your initial paper. Failure to file a cover sheet with the first paper filed in a civil case may subject a party,
its counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court.
To Parties in Rule 3.740 Collections Cases. A "collections case" under rule 3.740 is defined as an action for recovery of money
owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in
which property, services, or money was acquired on credit. A collections case does not include an action seeking the following: (1) tort
damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of
attachment. The identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general
time-for-service requirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections
case will be subject to the requirements for service and obtaining a judgment in rule 3.740.
To Parties in Complex Cases. In complex cases only, parties must also use the Civil Case Cover Sheet to designate whether the
case is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by
completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover sheet must be served with the
complaint on all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in the
plaintiffs designation, a counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation that
the case is complex.
CASE TYPES AND EXAMPLES
Breach of Contract/Warranty (06)
Auto (22)-Personal Injury/Property
Breach of Rental/Lease
Damage/Wrongful Death
Contract (not unlawful detainer
Uninsured Motorist (46) (if the
case involves an uninsured
motorist ciaim subject to
arbitration, check this item
instead ofAuto)
Other Pl/PD/WD (Personal Injury/
Property Damage/Wrongful Death)
Tort
Asbestos (04)
Asbestos Property Damage
Asbestos Personal Injury/
Wrongful Death
Product Liability (not asbestos or
toxic/environmental) (24)
Medical Malpractice (45)
Medical MalpracticePhysicians & Surgeons
Other Professional Health Care
Malpractice
Other Pl/PD/WD (23)
Premises Liability (e.g., slip
and fall)
Intentional Bodily Injury/PD/WD
(e.g., assault, vandalism)
Intentional Infliction of
Emotional Distress
Negligent infliction of
Emotional Distress
Other Pl/PD/WD
Non-Pt/PD/WD (Other) Tort
Business Tort/Unfair Business
Practice (07)
,£.Civil Rights (e.g., discrimination,
ivy
^
false arrest) (not civil
harassment) (08)
-K
Provisionally Complex Civil Litigation (Cal.
Contract
Auto Tort
'^Defamation (e.g., slander, libel)
§
Construction Defect (1 0)
S
3
Q.
Claims Involving Mass Tort
(40)
E
o
Securities litigation (28)
o
*
<2
Toxic Tort
.2
Environmental (30)
.2
§
Insurance Coverage Claims
£
from Complex Case (41 )
E
2 f
2,9
A6140 AdministrativeAgency Award (not unpaidtaxes)
2.8
A6114
Enforcement
of Judgment (20)
2,6
A6107 Confession of Judgment (non-domestic relations)
•E c
rSJ
I-.---
LACIV 109 (Rev 2/16)
CIVIL CASE COVER SHEET ADDENDUM
LASC Approved 03-04
AND STATEMENT OF LOCATION
Local Rule 2.3
Page 4 of 4
Case 2:18-cv-02217 Document 1-2 Filed 03/16/18 Page 8 of 10 Page ID #:48
NAME. ADDRESS; AND TELEPHONE NUMBER OF ATTORNEY OR PARTY WITHOUT ATTORNEY'
Michael J. Avenatti, Esq.
AVENATTI & ASSOCIATES, APC
,
520 Newport Center Drive, Suite
STATE OAR NUMBER:
Reserved for Clerk's File Stamp
206929
1400
Supr-v
Newport* Beach, CA 92660
(949)
r.
706-7000
FILED
'
Ot C'-I'f
V-rt >t •
ATTORNEY FOR (Name): Plaintiff
i
A .
'
•'irnja
STEPHANIE CLIFFORD
WAR G 9 2218
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
COURTHOUSE ADDRESS:
111
North Hill
Street,
Los Angeles,
CA
SherriR
90012
PLAINTIFF/PETITIONER:
STEPHANIE
^
!ji, uci/ClsrK
By.
CLIFFORD
DEFENDANT/RESPONDENT:
DONALD J.
TRUMP
PEREMPTORY CHALLENGE TO JUDICIAL OFFICER
CASE NUMBER:
(Code Civ. Proc., § 170.6)
BC 6 96568
Name of Judicial Officer: (PRINT)
Dept. Number:
Elizabeth,J.
39
BY FAX
Feifer
Si Judge
Commissioner
Referee
I am a party (or attorney for a party) to this action or special proceeding. The judicial officer named
above, before whom the trial of, or a hearing in, this case is pending, or to whom it has been
assigned, is prejudiced against the party (or his or her attorney) or the interest of the party (or his or
her attorney), so that declarant cannot, or believes that he or she cannot, have a fair and impartial
trial or hearing before the judicial officer.
DECLARATION
I
declare under penalty of perjury, under the laws
information entered on this form is true and correct.
Filed on behalf of:
Stephanie Clifford
Name of Party
of the State of California, that the
0 Plaintiff/Petitioner
Defendant/Respondent
Cross Complainant
Cross Defendant
Other:
35
Dated:
March 9, 2018
Signature of Declarant
Michael
25
J.
Avenatti
Printed Name
/
CD
CC
o
LACIV 015 (Rev. 12-14)
LASC Approved 04-04
For Optional Use
PEREMPTORY CHALLENGE TO JUDICIAL OFFICER
(Code Civ. Proc., § 170.6)
Code Civ. Proc., § 170.6
Case 2:18-cv-02217 Document 1-2 Filed 03/16/18 Page 9 of 10 Page ID #:49
(Page 1
of
1)
,
A
. FILED
Superior Court of California
FILE STAMpU"Ir 0f Los Anee'es
NOTICE SENT TO:
Avenatti
520
& Associates,
Newport
Newport Beach
MR 1 3 20 18
APC
Center Drive,
CA
Suite
1400
Sherri R-Carter, Executive Offi
92660
cer/Clerk
Bv
I
Christy Saltaba
i Deputy
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
STEPHANIE
CASE NUMBER
CLIFFORD ET AL
Ptaintiff(s),
BC696568
VS.
DONALD
J
TRUMP
ET AL
NOTICE OF CASE
MANAGEMENT CONFERENCE
Defendant^).
TO THE PLAINTlFF(S)/ATTORNEY(S) FOR PLAINTIFF(S) OF RECORD:
You are ordered to serve this notice of hearing on all parlies/attorneys of record forthwith, and meet and confer with all parties/
attorneys of record about the matters to be discussed no later than 30 days before the Case Management Conference.
Your Case Management Conference has been scheduled for July 12, 2018 at
at 111 North Hill Street, Los Angeles, California 90012.
NOTICE TO DEFENDANT:
8:30 am in Dept. 53
-
THE SETTING OF THE CASE MANAGEMENT CONFERENCE DOES NOT EXEMPT THE
DEFENDANT FROM FILING A RESPONSIVE PLEADING AS REQUIRED BY LAW.
Pursuant to California Rules of Court, rules 3.720-3.730, a completed Case Management Statement {Judicial Council form ft
CM-110) must be filed at least 15 calendar days prior to the Case Management Conference. The Case Management Statement
may be filed Jointly by all parties/attorneys of record or individually by each party/attorney of record. You must be familiar with (he
case and be fully prepared to participate effectively In the Case Management Conference.
At the Case Management Conference, the Court may make pretrial orders including the following, but not limited to, an order
establishing a discovery schedule: an order referring the case to Alternative Dispute Resolution (ADR); an order reclassifying the
case; an order setting subsequent conference and the trial date; or olher orders to achieve the goals of the Trial Court Delay
Reduction Act (Gov. Code, section 6B600 et seq.)
Notice is hereby given that if you do not file the Case Management Statement or appearand effectively participate at the Case
Management Conference, the Court may Impose sanctions pursuant to LASC Local Rule 3.37, Code of Civil Procedure sections
177.5, 575.2, 583.150, 583.360 and 583.1110. Government Code Section 68608 (b),
Date: March 13. 2018
2 2 et seq"
H0WAS£iU«*«r
CERTIFICATE OF SERVICE
1, the below named Executive Officer/Ctork of the above-entitled court, do hereby certify that I am not a party to the cause herein,
and Itefon this date I served the Notice of Case Management Conference upon each party or counsel named abovo:
I
depositing In the Unitod Slates mail at the courthouse in Los Angeles, California, one copy of tho original filed herein in a
separate sealed envelope to each address as shown above with postage thereon fully prepaid.
ji
[ ] by personally giving the party notice upon filing the complaint.
Shcrri R. Carter, Executive Officer/Clerk
Date: March 13. 2013
by
., Deputy Clerk
LACIV 132 (Rev 07/13)
Cal. Rules dr Court, nie 3.720-3 730
LASC Approved 10-03
LASC Local Rules. Chapter Three
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Case 2:18-cv-02217 Document 1-2 Filed 03/16/18 Page 10 of 10 Page ID #:50
FILED
Superior Courl of California
Counly of Los Angeles
FILE STAMP
NOTICE SENT TO:
MAR. 1 3 2018
Avenatti & Associates,
APC
520 Newport Center Drive,
CA
Newport Beach
Sherri R^Carter, Executive Officer/Clerk
Suite 1400
92660
Dfputy
By.
Christy Sahaba
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
CASE NUMBER
STEPHANIE
ET AL
CLIFFORD
BC696568
Plaintiff(s),
VS.
ORDER TO SHOW CAUSE HEARING
DONALD J TRUMP ET AL
Defendants).
To the party/attorney of record:_
.
.
You are ordered to appear for an Order to Show Cause Hearing on July 12. 2Q18 at 8:30 am in Dept. 53 of this
court, Central District, 111 North Hill Street, Los Angeles, California 90012, and show cause why sanctions should not be imposed for:
Failure to file Proof or Service of [ ] Petition M^Summotis and [j/ftfomplalnt [ ] Cross-Complaint pursuant to California
Rules of Court, rule 3.110(b) and (c) as to: _
rule 2.30,
Failure to comply or appear may result in sanctions, pursuant to one or more of the following: California Rules of Court,
and
and rule 3.1340; Code of Civil Procedure sections 177.5, 575.2, 583.150, 583.310, 583.360, 583.410, 583.420, 583.430;
Government Code section 68608.
I ] To avoid a mandatory appearance all required documents must be filed in [ ] this Dept [ ] Clerk's Office, Room
at least 5 court days prior to the date of the bearing.
case is not
[ ] The Court may infer from your failure to appear that possession of the premises is no longer at issue, and that your
en(itt£i to preference in setting pursuant to Code of Civil Procedure section 1179a.
[Vf You are ordered to give notice of said hearing forthwith to any party served with summons and complaint prior to OSC Hearing
and file a Proof of Service in this department or Clerk's Office at least 5 court days prior to the date of the bearing.
Dated: March 13. 2018
CERTIFICATE OF MAILING
and that on this date
I, ihe below fumed Executive OHiceNCIerlc of the ibove-entiiled court, do hereby certify thai I am not a party to the cause herein,
I served the §der lo Show Cause Hearing upon each party or counsel named above by depositing in the United States mail at the courthouse in Los Angeles
with the postage thereon fully
California, one copy of the original filed/entered herein In a sepante sealed envelope to each address as shown above
prepaid.
•"""
yi
\
Date: March 13, 2018
Sherri R. Cmt^^^rTWEOFFl^R/CLERK
>29
wa
Oo
By.
., Deputy Clerk
1
i
ORDER TO SHOW CAUSE HEARING
1
LACIV 166-1 (Rev. 09/08)
LASC Approved 06-04
LASC Local Rules, Chapter 7
Cal. Rules of Court, rule 2.30
:
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