wittenberg vs beachwalk: aka as homeowners vs hoa industry
TRANSCRIPT
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8212545
IN TESUPREME COUT OF CALFON
PAUL ITTNBRG, et al.,Rsondnts,
v.
BACHWALK HOMRS ASSOCIATION,Ptitionrs.
TER A DEISION BY THE COURT OF PEL, OURTH PELLATE DISTRIT DIVISIO HREE
CASE No G046891
REPLY TO ASWER TO ETTON FOR REVEW
ADAMS KSSLR PLCDRIN J.DMS (B N 168678)
Y E. GRM (BAR N 168972)2566 OVRAD STE. 730L GEE, CAIFRNIA 905
(800) 4642817 F (310) 9450281
[email protected]@davissirlingcom
ATTORNEYS FOR PETITIONER
ACHWALK HOMONRS ASSOCIATION
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TL OF CONTNTS
Pag
TABLE OF AUTHORITIES ........................................ ........ ....... .... iii
INTRODUCTION ............. ................... ............. ...... ......................... 1
LEGAL DISCUSSION .......................................................... ........ ... 3
I. WITTENERG FAILS TO REBUT BEACWALKSSHOWIN THAT THE STATUTORYINTRPRETAION ISSUE MERITS REVIEW . ... .. ... .. ... .. .. 3
A. The tie the ici cuie nd the Cout oAel hve ll ecognized tht homeowne
ocition electo nd the inteettion oection 133.03()() e vitlly imotnt tomillion of Clionin............................................... 3
B. The mici lete nd ittenbeg' nwedemontte th the deciion h cuedconuion nd uncetinty to how noncndidte election on community iue my beonducted . ......... .......... ............. .............. ........ ........ .......
C. Wittenbeg doe not diectly dde mny o theey iue ied by Behwlk . . 8
II. WITTENBERG AND ICUS CURIAE CCHALRAISE ADDITIONAL QUESTIONS WARRANTINGREVIEW 1 1
A. The conuion egding the coe o cout'dicetion to uhold election eult when ccevioltion e inubtntil wnt eiew..... . .. . .. 1 1
B. The iue id by Wittenbeg egding whethe the Cout of Ael hould hveinvlidted the election the thn leving thteciion to the til cout' dicetion lodemontte the need o eview. ............................ 14
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CONCLUSION 16
CERTIFICATE OF WORD COUNT . 17
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TABLE OF AUTHORITIES
Page(s)
Cases
Denham v. Superior Court( 1970) 2 Cal3d 5 .. . .. . 1 1
Grner v. Sperior Court( 1986) 182 CalApp3d 335 . ......... 14
Richrds, Wtson & Gershon v. King( 1995) 39 Cal.App4th 1 16 . . . 14
Smith v. Fetterhoff( 1956) 140 CalApp.2d 4 1.................... 14
Stnson v. Mtt( 1976) 17 Cal3d 209.. ..._ .. ... .. ..... . .... . . . . .... ...9
Statutes
. 1363.03subd. (a)(1) ............. 1 2, 3
subd (a)() .................. 2
136304 10
136309 subd (a) ..................... 1 1 12
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IN THE
SUPEE COUT OF CALFONA
PAUL WITTENERG e lRsondnts
v
EACWK HOMOWNERS ASSOITIONPtitionr
REL TO ASER TOETTO FOR REE
INTRODUCTION
As demonstated by the answe to petton o evew and the
amus cuae lettes on le eveyone agees that the pope
constucton o secton 136303 subdvson (a)(1) 1 s an mpotant
ssue that wll have sgncant mpact on mllons o Calona
condomnum ownes.
The aguets asseted by Wttenbeg and the amc lettes
establsh that the decson by the Cout o Appeal has njectedseous conuson and uncetanty nto the pocess o conductng
1 Unless othewse ndcated all statutoy eeences n ths beae to the Calona Cv Code
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homeowne assocaton electons It s cucal to te unctonng o
Calona assocatons that the boads know they can povde
gudance to membes wheneve impotant issues ae up o electon
wthout subjectng the membeshp to ltgaton o causng unduecosts n conductng the electon The mpotance o ths ssue, and
the conuson and seous ham aced by Calona homeowne
assocatons waants evew
Wttenbeg an amcus cuae also ase addtonal gounds
o ths Cout t gant evew They seek gudnce on the scope o a
cout's dsceton to uphold electon esults when access volatons
unde secton 136303 subdvson (a)() o (a)(2) have occued
Ths Cout should gant evew and conm that when the access
volatons ae nsgncant the tal cout has the dsceton to and
ndeed should) uphol the electon esults despte the alleged
volatons
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LEGAL DISCUSSION
I ITTENBERG FAILS TO REBUT BEACHWALK'S
SHOG THAT THE STATUTORYINTERPRETATION ISSUE MERITS REVIEW
A The paries, h amici curia, and he Cour of ppal
have all recognize ha homeowner assoiaion
elecions an h inerpreaion of scion 136303(a)()
are vially imporan o millions of Californians
Wttenbeg gees tht the ntepetton o the equl ccess
povson o secton 136303 subdvson ()() wl hve wdesped
mpct coss the stte (Answe to Petton o Revew (APFR) p. 5
[Pettone nd Respondent gee tht the ssue wll ect mllns
o homeownes (nd) . my hve wdesped mpct on mllons o
Clon esdents]) Howeve e contends tht becuse theCout o Appel coectly constued the sttute thee s no need to
gnt evew (APFR pp. 56) In othe wods becuse he beleves
he would wn on the mets ths Cout should declne to nlyze the
decson nd ech ts own concluson. Wttenbeg s mstken
bout the mets o hs cse And ths ssue s too mpotnt nd
the esultn hm s too sevee to llow ths decson to become the
lw n Clon
In n mcus lette ugng ths Cout o nt Bechwlk's
petton twenty lw ms epesentng lge numbe o
hoeowne ssoctons toughout Clon emhszed the
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importance of the case (See letter from Laura Snoke, Esq to
Supreme Court on behalf of wenty amicus curia Davis-Stirling Act
Comon Interest eelopment Law Firms (ugust 23, 203)
(Snoke Letter) p [There are nearly 50,000 ommon interestdevelopments in the state housing approximately 5 million
Californians (8% of the state's population)"], p. [Each year
aociations conduct annual elections as well as a variety of special
elections oerseen by 50,000 boards of directors"], p. 3 [To restore
stability to common interest developments, reduce the ris of future
litigation, and provide important election guidelines to the ndustry,
we ask that this Court grant review of ittnbrg v Bachwak
"])
The amicus letter by the Center for California Homeowner
ssociation Law (CCHAL), while submitted in support of
Wittenberg, also acknowledges the importance of homeowner
association elections and the important issue of first impression
that this case presents. (See letter from Marjorie Murray toSupreme Court on behalf of Center for California Homeowner
Association Law (August 9, 203) (CCHAL letter) p 2 [association
elections [are] an issue of continuing pulic inteest"], p 3 [theLegislature apparently believes fair electons are as vital to the
governance of associations as they are to local governments"], p
[The Wittenberg opinion addresses for the rst time a critical issue
in association elections, namely: if an association permits any
candidate or member to advocate a point of iw using association
media must the association give members with opposing views
eual access to the same media"])
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h rcn rvisins t th Davis-Stirling Act als amplify h
urgncy that this dcisin b rviwd and apprpriat guidlins
b stablishd fr this industry As ntd by Wittnbrg,
Bachwalk urgd this Curt t rviw and rvrs th dcisin inpart bcaus th nw burdns impsd n assciatin bards wuld
mak it mch mr difficult and xpnsiv fr assciatins t btain
urt apprval f andmnts t CC&Rs undr sctin 135 f th
Civil Cd (APFR pp01 1) Amicus CCHAL cnfirms that th
abilty t amnd gvrning dcumnts is f vital intrst all
Califrnia assciatins and nts that tis intrst is hightnd
bcaus th rvisins t th DavisStirling Act, which ar ffctiv
in 2014 will rquir widsprad amndmns t gvrning
dcumnts acrss th stat (CCHAL lttr, p 3 [Amnding
vrning dcumntsth ky issu in Wittnbrgwill b f
pramunt imprtanc in 2014, whn AB805/Trrs taks ffct
This lgislatin vrhauls DavisStrling th bdy laws
gvrning assciatins. Bars ar alrady bing tld that ty willhav t rvis thi gvrning dumnts t ak thm cnfrm t
AB805 Amnding Cnditins Cvnnts and Rstrictins (CC&Rs)
is a critical issu fr hmwnrs"])
Th Curt f Appal itslf dd its dcisin a sigicant
n by crtiing it fr publicatin Th plicy issus raisd b th
dcisin ar imprtant and th industry it impacts is larg
Accrdingly, this Curts rviw is warrantd
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B The amici leers an Wienberg's answer
emonsrae ha he ecision has cause confusion
an uncerain as o how "non-caniae elecions
on communi issues ma be onuce
ttenbergs contenton that revew s not warrante because
the law s not unsettle" an th ecson nterrete the statute n
a clear manner s mstaken (PFR p 5 Ts s a case of frst
mpresson nterpretng a statute n whch the tral court an
appellate court came to opposte conclusons as to the plan meanng
of ts rovson
he tenty law frms that jone as amc n urgng revew
have emphasze the confusn an srupton the ecson has
cause (Snoke Letter p [s mngovernments the states
assocatons now lack clear polces for how boars partcpate n
those electons thereby makng them vulnerable to ltgaton that
ultmately s harmful to all assocaton members"] p 2 [Instea ofbrngng clarty the appellate ecson n ittnbrg has create
confuson].
CHL also notes the confuson an uncertanty surrounng
associationelections and the invalidation ofelection results based
o eual access volatons (CHL letter p. 1 [there seem to be no
uniformstandards used by California Courts for determining what
crcumstances o sets of facts lea to nalaton"] p. 1
[Homeowner plantffs allegng smlar volatns of the statute
e.g that they were ene equal access to assocaton mea or were
refuse a ballot - get wely varyng results ncourt"], p. 4 [there
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ae o stadas to gude lowe couts te execse o te
dsceto to alat a eecto"].)
Wttebeg's agumets oosg eew also demostate te
couso ad lack o claty suoudg te decso Fo exameWttebeg agues tat te decso oes ot madate tat
assocatos must ubs uedated, ueted statemets of al o
ts membes' (Ctato)" (APFR 6) Yet secto 136303,
subdso (a)() exessly odes tat a assocato may ot
edt o edact ay membes submsso
Wttebeg agues tat tee s otg te statute tat
obts a assocato m eactg easoable wod lmts" o
ote easoable submsso gudeles" tat comly wt
subsecto (a)() ad boas ae ee to moto wat t cosdes to
be ammatoy o deamtoy staces o mebe adocacy"
(APFR 78) uggestg tat assocatos may get aou te
o edactg a o edtg" maate by eactg o estats
o te accetable legt ad cotet o membe's submssos as acodt o ublcato (essetally e-edtg ad e-eactg
tem) oly ggts te couso suoudg te Cout o
Aeal's ecso a te mossble osto wc t as ace
assocatos attemtg to coduct electos Ts demostates te
eed o eew ad clacato by ts Cout
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ienberg oes no irec aress man of he ke
issues raise b Beachak.
Wittenberg asserts that the widesread negativeconsequences enunciated by Beachwalk will not occur dismissing
hem as hyerbolic doomsday contentions that do not suport
granting review (APFR 6.) He simly assumes that ublishing
unredacted unedited commentary rom all members who wish to be
hear during elections will not cause any roblems and will not
imede an association rom using its media to communicate
recommendations about election issues t its members Based on
that assumtion he concludes the decision creates no imediment
to associations ulilling their duciary duties related to elections
no undue diiculty in obtaining necessary amendments to CC&Rs
ursuant to section 1356 when aced with voter aathy and no
intererence with the duties o disclosure and care mandated by
various rovsions o the Daistirling Act (APFR 68, 1013.)Wittenbergs assumtionis mistaken. Beachwalk'sassertion
that onerous,unpredictable consequenceswill resultif thedecision
is not revrsed is suorted not only by commonsense, butalsoby
the amici common nterest develoment law irms, who have
conirmed that the decisionwillintererewith boards ulllingtheir
dutes relatedtoelections and otentially exosethemembers to
unreasonable litigation expenses. (Snoke Letter, p 3 ["if the
aellate court's decision is not overturned 50,000 homeowner
ssociationboardswill annually face potential litigationevery time
they send out election materials], p. 3 ["They will be afraid to
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povide important infomation to thei membeshi for fea of
subjecting thei associations to costly and contentios cout
battles"] p. 3 [To estoe stability to common interest
deveopments, educe the risk of futue litigation and povideimportant electionguidelines to theindustry, we askthat this Cout
grant reviewof Wittenbergv. Beachwalk HOA"].)
Wittenbeg does notdiectly addressBeachwak's argument
tatte decision confictswith settled lawregardingthe separate
entitystatus of acorporation,despite the fact that it isundisputed
thatthemedia" communications at issue inthis case were made by
the board in its official capcityon beha of the copoate entity.
Wittenberg argues there is n cnict because eua access can y
be triggeed when a candidate r member" advcates a pint f
view abut an eectin and the assciatin is nt ne f the acts
subect t the statute . . " (AFR p 9) Thus he agues ecause
te decisn igned the rpate stats f the auth f the medi
cmmunicatins here can be n cnict with crprate aw. Thiscnvuted circua argument aises frm the refusa t accept the
bvius that an assciatin" is nt a ember" f an assciatin
whse advcacy can trigge eua access unde the statute
Wittenberg cmpletey ignesBeachwaks cntentin that
the decision advances a policy of discouraging elected bad
mebers frm advising thei cnstituents n imprtant eectin
issues whichis cntaryt piciesunderyingthisCurt'sdecisin
in Stanson v. Mott ( 1976) 1 7 Ca.3d 209 and its prgeny (See
etionforReview (PFR pp.32-35.)
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Wittenberg also fails to address Beachwalk's argument that
the decision cannot be haronizedwith sction 1363.04ofthe Civil
Cde. This section precludes associations from using funds t
campaign in support of favored candidates during board elections,
but provides that associationsay prperlyuse fundsfor campaign
prposes during non-candidate elections to the extent necessary t
comply with the association's legal duties (See PFR pp. 30-32)
!he pvisions of this section demonstrate that different interests
and policies ae implicated depending on the type of election being
coducted They evidene a recogntion by the Legislature that
communications by associations about ssues will often be necessary
uring non-candidate elections in order to comply with duties owed
to te mmbersip. Both ittenberg and the Court of Appeal fail to
recognize thatprecldingelected leaders from offering guidance to
members aboutimportntelectionissues is contrary totheterms of
section 1363.04 and the underlying policies concernng non-
candidat elections reected in its provisions.Wittenberg has failed to rebut Beachwalk's showing that
reviewof the decisionis warranted.
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II WIEBERG AD MICUS CURIAE CCHAL RAISE
ADDIIO QUESIOS WARRAIG REVIEW
A he confusion regring he scope of coursiscreion o uphol elecion resuls hen ccess
violions re insusnil wrrns revie
Te anwer bmitted by Wittenberg and CCHL amic
letter bt argue tat review i neceary t clear p qetin
abut te extent a crt' dicretin t pld electin reult
prunt t eci 1363.09 bdiviin (a te Calirnia Civil
Cde wen acce vilatin ave ccurred (PFR pp. 2 31
CHAL letter pp. 14.) Te Curt ppeal ater ndng tattry
vilatin ccrred let it t te icrtin te trial crt t
determine wat eect tat uld ave n Beacwalk' electin
relt. Te anwer argue tat ti dipitin raied a matter
rt imprei" cncerning te invalidatin electin relt bytrial crt and crt appeal (PFR p 2) Wittenberg aer
te curt ppeal let pen ti crucial ie ie weter r nt
te electin reult ld ave been invalidated a a relt e
inding vilatin under 136303(a)(1) and (a)(2)." (PFR p 2)
He cntend ti warant ti crt cnideratin a t
prvide guidance t Calirnia crt w truggle wit te
applcatin tee recent tatty enactment" (PFR p 2)
Beacwalkaert tat Califrnialawi clear tat te curt
retain a reat eal f dicretin wic i diturbed nly en a
clea micariage fjtie a ccurred. (Denham v. Suprior Court
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(970) 2 Ca 3d 7, ) Winbrg acnowldgs his in his
answr, and nos ha scion 3309 subdivision (a) provids
ha a cour ay" void lcion rsuls i violaions hav occurrd
APFR pp. 3) Howvr, h argus ha h policy o librallyconsrung rdial saus qus a cour o invalida lcion
rsuls whnvr a violaio occurs unlss h cour is orbidn by
sau o do so PF pp ) This argun donsras
so conusion abou h xn o whic rial cour hav
discrion o uphold lcion rsuls whn insignican qual accss
violaions hav occurrd
Th CCL lr also rquss rviw o h unsld"
issu rarding h scop o a cour's discrion o invalida
lcion rsuls, noing h conusion in h couniy rgarding
whhr invalidaio undr scion 3309 is auoaic (CCL
lr, pp 1, 4 [ny hoownrs liv ha a violaion o h
saus lads auoaically o an invalidaion o a lcion")
CCL nos ha h dra languag o scion 33.09iniially providd ha cion rsuls shall" invalid i an
accss violaion occurrd, bu ha andaory languag was
changd by h raing coi o a prissiv ay" b voidd
o addrss cncrns o drars ha iigaion woud b gnrad
or insgnican accss violaions (CL lr, p. 4 [brs o
h worng grop wr concrnd a hoownrs would bring
suisand lcions would hav o b rconvndor wha wr
prcivd s inor inracions o h sau")
Bachwalk connds ha cours possss broad discrion o
uphold lcion rsuls whn h violaions o lcion accss ruls
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ar isubstatial his cas prsts a particularly good vhicl to
addrss this issu h trial court oud o violatios o sctio
6303 subdivisio (a)(2) rgardig r accss to commo aras
durig th August 20 ctio h Court o Appal rvrsdidig two violatios that wr xtrmly attuatd rom th
August lctio ad particularly isubstatial (p 67)
pciically, th court poitd to () th maagmt compay
mistaly chargig a mmbr $90 or us o a clubhous acility
durig a lctio i Dcmbr 200 (ad vidtly ailig to
rud th ) ad (2) th dial o a rqust to us a grblt
basd o a icomplt orm submittd by th mmbr durig a
lctio i April 20 p 6-7)
Bachwalk agrs with Wittbrg that this Cour should
grat rviw to clari that such isubstatial violatios costitut
a propr circumstac i which th trial court should xrcis its
discrtio ad uphold th lctio rsults
ordr to addrss th qustio raisd by Wittbrg thisCourt must grat rviw ad trtai briig o th issu his
is cosistt with Bachwal's ptitio also urgig this Court to
grat rviw ad brig clarity t th Davistirlig statutory
schm with rspct to how associatio boards ca ulill thir
dutis as lctd ladrs to advis thir commuitis whil
coductig o-cadidat lctios o issus i, whr masurs
ar put o th ballot or mmbrship approval suc as spcial
assssmts or proposd amdmts to th CC&Rs
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B The issue aise b Wienbeg egaing whehe he
Cou of Appea shou have invaiae he eecion
ahe han eaving ha ecision o he ia cou's
isceion aso eonsaes he nee fo eview
Witteberg also asks this Court to grat reviw to determie
wether the Court of Aeal should have ivalidated the electio
results based uo its fidig of violatios of sectio 3303,
sudivisio (a)() (equal access to media) ad subdivisio (a)(2)
(equal access to commo areas) (APFR 2.)
Beachwalk asserts that the trial court's discretio is broad,
a where it has discretio bt has ot exercised it the roer
aellate remedy is to reverse the judgmet wth directios to the
trial court to exercise its discretio (Richrds, Wtson Gershon
v King (995) 39 CalA4th 7 8 [til court icorrectly
believed that a attorey's lawsuit agaist a cliet must be
dismissed; judgmet reversed with directios to te trial court toexercise its discretio i cosiderig the cliet's motio to dismiss;
Grdner v Superior Court (98) 82 CalA3d 335 34 [trial
court icorrectly believed it was requred to grat the defedat's
motio for relief from a default judgmet case remaded to allow
trial court to to exercise ifored discretio i decidig this
matter"; Smith v Fetterhoff (95) 40 CalA2d 47 473
where as i the istat case the trial court refused to cosider ad
weigh evidece uo the erroeous teory that it could ot e
cosidere a aellate court is ot justifid i afrmig the
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judgment upon the ground that the evidence supports the
judgment"])
Wittenbergs argument that the Court of Appeal should have
invalidated the election results evidences a level of confusion aboutthe appropriate role of the appellate court in invalidating election
results after t has rersed a trial court's finding that no electio
violation had ocurred, and the need for review to clari this issue.
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CONCLUSION
So as to establish proper election policies for a large and
growing industry we rspectfully request this Court grantBeachwalk's petition
September 3, 2013 ADAMS KESSLER PLCADRIAN J. ADAMSMARY E. GR
MARY E GRAMAttorneys for PetitionerBEACHWALK HOMEONERS
ASSOCIATION
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CERIFICAE OF WORD COUNT
(al. Rules of Court, rule 8504(d)().)
The text of this petition consistsof 3,066 words as counted y
te Microsoft Word version 2010 word processing program used to
generate the etition.
Dated: Septeber 3, 203
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PROOF OF SERVICE
STATE OF CALIFRNIA, COUNTY OF LS ANGELES
At the time of service, I was over 18 years o age and not a party to this action I
am employed in the County of Los Angeles State of California My busines address is15760 Ventra Bolevard 18th Floor, Encino Calfornia 91436-3000.
On September 3 2013 I served true copies of the following document(s)described as REPLY TO ANSER T PETITION FOR REVIEW on the interested
parties in this action as follows:
SEE ATTCHED SERVICE IST
BY MIL: I enclosed the document(s) in a sealed envelope or packageaddressed to the persons at the addresses listed in the Service List and placed the
envelope for collection and mailing following our ordinary business practices. I amreadily familiar with Horvitz & evy LLP's practice for collecting and processingcorrespondence for mailing On the same day that the correspondence is placed forcollction and mailing it is deposited in the ordinary corse of business with theUnited States Postal Service in a sealed envelope with postage flly prepaid
I declare under penalty of perjuy under the laws of the State of California thatthe fregoing is tre and corect
Executed on September 3 2013 a Encino California
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SERVICE LISTWittenberg v. Beachwalk HOA
Court of Appeal Cse No. G046891Superior Court Cse No 30-201100507078
William L. BuusSchier & Buus APC3070 Bristol St Ste 530Costa Mesa CA 92626
California Court of Apeal Fourth Appellate District, Div 3
601 W Santa Ana Blvd.Santa Ana CA 92701
Hon Thierry Patrick Colaw
Orange County Superior Court700 Civic Center Drive Westept 25Santa Ana CA 92701
Attorneys for Plaintiffs and AppellantsPaul Wittenberg Raymond Dqkellis
Court of Appeal Case No G046891
Case No 30-201100507078