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No. 2839 OPPOSITION Declaration of Mireille Mouren-Laurens In Support of Mouren-Laurens Parties Response ...

Document REV 973 LLC v. John Mouren-Laurens, et al, 2:98-cv-10690, No. 2839 (C.D.Cal. Dec. 21, 2018)
In my individual capacity, I am a Defendant, Counter-Claimant, Cross- Claimant, Cross-Defendant and Third-Party Plaintiff in the lawsuit entitled Rev 973, LLC v. John Mouren-Laurens et al., Case No. CV 98-10690 DSF (Ex) (“REV 973 Lawsuit”).
After Michel informed The Mouren-Laurens Parties that Michel could no longer represent us, we approached Tim Cronin, with whom we have had a 20 plus years relationship and asked his firm to represent us in the case going forward.
Mr. Cronin agreed to our request and represent The Mouren-Laurens Parties explaining that it is the right thing to do under the circumstances and also makes practical sense.
Tim Cronin’s 20 years of institutional knowledge of the case makes him acutely familiar with the relevant facts and issues in the case, including those relating to The Mouren-Laurens Parties’ defenses and claims.
The Mouren-Laurens Parties believe that no counsel is better prepared to represent The Mouren-Laurens Parties than Cronin and transitioning representation to Cronin is an obvious, natural and seamless way to ensure that The Mouren-Laurens Parties’ interests, claims and defenses in the action are not compromised.
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No. 2838 OPPOSITION Declaration of C.D. Michel In Support of Mouren-Laurens Parties Response To Improper ...

Document REV 973 LLC v. John Mouren-Laurens, et al, 2:98-cv-10690, No. 2838 (C.D.Cal. Dec. 21, 2018)
A proposed global settlement agreement (“Settlement Agreement”) in this case was filed with the Court in 2016, on behalf of all Mouren-Lauren entities, in connection with all Mouren-Laurens entities’ Motion for Good Faith Determination.
My communications with Fraley focused on negotiating indemnification provisions and monetary terms of a revised Settlement Agreement that would satisfy all Mouren-Laurens entities, and specifically including the concerns of my clients the Mouren-Laurens Parties.
A draft revised proposed Settlement Agreement including renegotiated financial and indemnification terms pertaining to the Mouren-Laurens entities and specifically addressing the concerns of my clients the Mouren-Lauren Parties was prepared pursuant to my settlement discussions with Fraley, and copies were provided to both Cronin and Artiano for review as parties and signatories -- without objection from Fraley.
I have no recollection of Fraley making any specific new disclosures during our settlement discussions regarding Rev 973’s litigation strategies and case weaknesses that differed from those made by Fraley during mediation sessions conducted at Mr. Gallagher’s office or during status conferences with the Special Master, Judge Carl West, when Cronin and/or Alan R. Johnston, an attorney with
I have been authorized by The Mouren-Laurens Parties to disclose this information for the limited purpose of explaining their reasons for seeking to substitute Cronin into the case as their counsel / / / / / / / / / / / / / / / /
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No. 2840 OPPOSITION Declaration of W. Lee Smith In Support Of Mouren-Laurens Parties Response To Improper ...

Document REV 973 LLC v. John Mouren-Laurens, et al, 2:98-cv-10690, No. 2840 (C.D.Cal. Dec. 21, 2018)
Fraley and I never participated in separate mediation discussions for the purpose of reaching a settlement solely with our clients, The Mouren-Laurens Parties.
The purpose of my settlement discussions with Fraley, referenced in Fraley’s Declaration, was to attempt to renegotiate, on behalf of all Mouren-Laurens entities, the terms of the global settlement agreement (“Settlement Agreement”) that was filed with the Court in 2016, on behalf of all Mouren-Laurens entities, in connection with all Mouren-Laurens entities’ Motion for Good Faith Determination, which the Court denied in August 2016.
Accordingly, I did not communicate any litigation strategies or case weaknesses referenced by Fraley in his Declaration to either The Mouren-Laurens Parties, Cronin or Artiano.
discussions referenced in Fraley’s Declaration to withhold anything specific from 4 Cronin including Rev 973’s litigation strategies and case weaknesses.
2$ SMITH DECLARATION ISO MOUREN-LAURENS PARTIES’ RESPONSE TO IMPROPER “NEW MArFER” RAISED TN REV 973, LLC’S REPLY; REQUEST FOR APPROVAL OF SUBSTITUTION OF AEfORNEYS AND
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No. 2837

Document REV 973 LLC v. John Mouren-Laurens, et al, 2:98-cv-10690, No. 2837 (C.D.Cal. Dec. 21, 2018)

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No. 2836

Document REV 973 LLC v. John Mouren-Laurens, et al, 2:98-cv-10690, No. 2836 (C.D.Cal. Dec. 21, 2018)

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No. 11-27-2018-1758525719-Minute_Order

Document OLD REPUBLIC INSURANCE COMPANY VS. BISRAT KIFLEZGHIE, ET AL., SC126422, Minute Order (Los Angeles Sup. Ct Nov. 27, 2018)
November 27, 2018 8:30 AM Judge: Honorable Craig D. Karlan Judicial Assistant: Manny Mabunga Courtroom Assistant: Sandra Mixon CSR: None ERM: None Deputy Sheriff: None APPEARANCES: For Plaintiff(s): Steven Alfred Booska ...
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No. 2828

Document REV 973 LLC v. John Mouren-Laurens, et al, 2:98-cv-10690, No. 2828 (C.D.Cal. Oct. 25, 2018)

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NIAGARA RESTORATION INC VS MARQUIS, VALERIE

Docket 09A04927, California State, Los Angeles County, Superior Court (July 9, 2009)

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Ex Parte 1-Ex_Parte_PLTFFS_EX_PARTE_APPLICATION_FOR_AN_ORDER_DIR...

Document JOANNE SPANGLER VS ISAAC'S RELOCATION SER ET AL, CIV505326, Ex Parte 1-Ex_Parte_PLTFFS_EX_PARTE_APPLICATION_FOR_AN_ORDER_DIRECTING_SEIZURE_OF_PERSONA...

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Order 1-ORDER_PLAINTIFFS_AFFIDAVIT_OF_IDENTITY__ORDER_SIGNED_BY...

Document JOANNE SPANGLER VS ISAAC'S RELOCATION SER ET AL, CIV505326, Order 1-ORDER_PLAINTIFFS_AFFIDAVIT_OF_IDENTITY__ORDER_SIGNED_BY_JOSEPH_SCOTT_ON_053116_F...

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Adobe Systems Incorporated v. Galvez

Docket 5:09-cv-01081, California Northern District Court (March 11, 2009)
Hon. Ronald M. Whyte, presiding, Magistrate Judge Howard R. Lloyd
Copyright

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Minute Order MINUTE ORDER

Document IMRAN CHAUDHRY VS. LUIS CRUZ, EC066317, Minute Order MINUTE ORDER (Los Angeles Sup. Ct Apr. 23, 2018)

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No. 05984337

Document LVNV FUNDING LLC VS. ROGER TRAVIS, CGC-06-457052, No. 05984337 (California State, San Francisco County, Superior Court Aug. 14, 2017)

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Minute Order MINUTE ORDER

Document IMRAN CHAUDHRY VS. LUIS CRUZ, EC066317, Minute Order MINUTE ORDER (Los Angeles Sup. Ct Apr. 17, 2018)

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AMERICAN EXPRESS TRAVEL REL. SERV. INC VS. VIRGINIA MOMJIAN

Docket EC048352, California State, Los Angeles County, Superior Court (Nov. 5, 2008)
Charles W. Stoll, presiding.

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