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Exhibit M: Superior Court of CA, County of Santa Clara, 18CV338308 (Case 5:24-cr-00292-PCP, Document 44-13)

Summary

This is Exhibit M, a complaint by Spieker Companies, Inc. in the Superior Court of the State of California, County of Santa Clara, Case No. 18CV338308, e-filed 11/19/2018. The defendants are Rosswood Properties, LLC, Cassie Will-Darnall, and Laura Menicucci, with Does 1 through 50. The complaint alleges that Spieker Companies is the management agent for the owners of the real property at issue and that Will-Darnall is a principal of Rosswood Properties. It alleges that Rosswood did not perform as promised and breached each of the Lease Agreements when it prematurely vacated and abandoned each of the subject units.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Exhibit M: Superior Court of CA, County of Santa Clara, 18CV338308 (Case 5:24-cr-00292-PCP, Document 44-13).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-44-13-d4e5d9d1ae/, SHA-256 0d8bd364d96b2657163c27ae19576928269f277a1ae8da9ad478539657b7351f.

Full text

Case 5:24-cr-00292-PCP   Document 44-13   Filed 04/09/25   Page 1 of 11




                 EXHIBIT M
                          Case 5:24-cr-00292-PCP             Document 44-13                Filed 04/09/25     Page 2 of 11

                                                                                                       E-FILED
                                                                                                       11/19/20184:19 PM
                                                                                                       Clerk of Court
                     1 PNIL&McCAY                                                                      Superior Court of CA,
                           A Professional Law Corporation                                              County of Santa Clara
                     2     Stephen D. Pahl, Esq. (State lla,No.95900)                                  18CV338308            ·
                           Eric J. Stephenson, Esq, (sm1e llfir N$, 282305)
                     3     225 West Santa Clara Street           •                                     Reviewed By: Y Pulido!
                           Suite 1500
                     4     San Jose, Califm:ni11 .95113-1752
                           Telephone:      (408) 286•5100
                     5     Facsimile:      (408) 286-5722
                           Email: spahl@pahl-mccay.com .
                     6             estephensort@plihl-mccay,qom

                     7     Attorney~ for Pfaintiff
                           SPIEKER COMPANIES, INC.
                     8
                                                SUPERIOR COURT OF THE STATE OF CALIFORNIA
                     9
                                                                 COUNTY OF SANTA CLARA
                     10
                           SPIEKER COMPANIES, INC., a (µllifornia                 ~        Case No. 18CV338308

                     ~:    Corporation,             Plaintiff,                    S~       [U11limited - Exceeds $25,000}      I'
                                                                                                                  t
                           v.                                                              COMPLAINT FORBREACU OF L
                     13                                                                    AND PROMISE WITHOUT INTE.
                           ROSSWOOD PROPERTIES, LLG, a                            )        PERFORM
                     14    California Limited Liability Company;                  )
                           CASSIE WILL.DARNALL, an individual;                    )
                     15    LAURA MENICUCCI, an individual, and                    )
                           DOES 1 through 50, inclusive,    •                     )
                     16                                                           ~)       Action Filed:
                                                    Defendants..                           Trial Date: TBA
                     17 1 - - - - - - - - - - - + - - - -
                     18            Comes now Plaintiff SPIEKER COMPANIES, INC., and complains as follows:
                                                                  ,           -                                                I
                     19             1.      PlaintiffSPlElKER COMPANIES,
                                                              '        ' INC.,. is and was the managementagentif r
                     20     the owners of the real property at issue herein at 11H times relevant to this matter. Plaintiff i a
                                                                                                                               }

                     21                                                                                                '
                            California corporntion, and has fulfilled all applicable requirements to conduct business ah
                                                                                                                               1
                     22     does business in the State of Cal ifo.rnia. .
                     23             2.      Plaintiff is. infom1eq and believes and thereon alleges that Defendant             ,
Pahl & ~l<Oy z4                                                    '                                                           i
Al'n)bu:Jrpf('mg,           ROSSWOOD PROPERTIES, LLC, is a California limited liability company with a princ!p
ll'S W.SlntaOMa                                               •                                                      I
Sult.e 1SOO           _
                     25
                                                              .                                                      '
:stnki:w,C.A9Slt.1
(400)1&,.,SIOO
                            place of business in Santa Clara qounty, California, and who entered into a contract where II
                                                                                                                               f
• 1526/001 •         26     payment and perfonnance was to be made in the County of Santa Clara, State of California
00652359.DOCX. !
                                                            .                                                     1
                     27           3.    Plaintiff is informed and believes and thereon alleges that Defendant CAS~I
                                                                                                                               t
                     28     WILL-DARNALL is a principal Qf ROSSWOOD PROPERTIES, LLC who entered into 11
                                                                                       1                                       ~
                           COMPLAINT FORBREACH oi, LEASE!..                                                                  (C..e o.   )
                                                                                                                               '


                                                                                                                             US-0001669

                                                                                                                  US-0001669
                                Case 5:24-cr-00292-PCP            Document 44-13         Filed 04/09/25       Page 3 of 11




                            1     contract where all payment and performance was to be made in the County of Santa Clar~, State
                            2     of California.
                            3             4.       Plaintiff is infonnecl and believes and thereon alleges that Defendant L4-Uf
                                                                        .                                                     '
                            4     MENICUCCI was a principal .of ROSSWOOD PROPERTIES, LLC at all times material\t the
                                                                                                                          ' ce
                        5         allegations in this Complaint, who entered into a contract where all payment and perfomim
                                                                       '                                                         .
                            6     was to be made in the County of Santa Clara, State of California.
                            7             S.       Plaintiff does not 1910w the true names or capacities, whether individual,
                                                                                                                                 ;
                            8     corporate, associate, or otherwise of Defendants sued herein as DOES 1 through 50, ind❖s ve.
                            9     Plaintiff sues said Defendants by su~h fictitious names and prays leave to amend this Co~ laint
                      10          when the true names and capacities of said Defendants have been ascertained. Plaintiff i§
                                                                       :                                                         !t
                      11          informed and believes and thereon alleges that said Defendants conducted, participated i?, r
                                                                                                                                 t
                      12          are responsible for the acts set forth herein, and Plaintiff is further infonned and believesla d
                                                                                                                                 '
                      13
                                                                                                                                 .
                                  thereon alleges that some or all of the said DOE Defendants are in combination, agency, pr joint
                                                                       .
                      14          venture relationships with the nari1ed Defendants.
                      15                  6.       Plaintiff is informed and believes and thereon alleges that at nil times herein
                                                                       '.                                                        1
                                                                                                                                 !
                      16          mentioned, each Defendant was t~e agent, servant, joint venturer, partner, and/or employ~ of
                                                                                                                                 i
                      17          each and every one of the other Qefendants, and was acting within the course and scope ~f 1is
                                                                   •                                                         '
                      18          authority, and each Defendant ratified, authorized, and approved of the acts o.f each otheJ
                                                                                                                                 !
                      19          Defendant. Any acts or omission~ attributed herein to a corporation or other business en1t
                      20          were authorized acts, performed by an authorized representative of s·aid entity, acting withi the
                                                                   •                                                         I

                      21                                                                                                       ' of
                                  course and scope of his agency or,. authority, and were ratified by• reasonable representati~e
                                                                                                                               '
                                                                                                                                 i
                      22          the entity.
                      23                  7.    The amount in controversy exceeds $25,000 and this matter is thus properly
                                                                                                                                 I
                                                                                                                         I
Pahl&McC.'ty ,
                            4     designated as a case of general jurisdiction.                                          !
A Pmfi:Mii.ma! O:;p. ...,
225 W, Santa Cl.lm
Sllilt: l;\011
SuiJ~.CA9:'ilt3       25                                             GENERAL ALLEGATIONS
(40!1) 2$6.~100

•ts2MX\l-             26                  8.  In March 2018, Plaintiff and Defendants entered into negotiations regardin~
00552359.00CX. l
                                                                                                                        I
                      27          Defendant ROSSWOOD's intention to lease apartment units al various properties in the f y
                                                                       •                                                         I

                      28          Area owned and managed by Plaintiff.                                                           !
                                                                                     2
                                  COMPLAil'<'T FOR BREACH OF LEASE.~.




                                                                                                                                US-0001670

                                                                                                                  US-0001670
                                    Case 5:24-cr-00292-PCP           Document 44-13          Filed 04/09/25        Page 4 of 11




                                1             9.     During these negotiations, Don Naugle, representative for Plaintiff, spoke;, "th
                                2      Defendant WILL-DARNALL, Pi'esident
                                                                 .        of Defendant ROSSWOOD. Defendant WILL- 1                    .
                                                                                                                                      i
                                3      DARNALL stated to Plaintiff du(ing a telephone call that Defendant ROSSWOOD need~
                                                                                                                                      /-
                                4      short-term, five-month lease agre~ments for these units, ending in September 2018. Defcp ant
                                                                                                                                      i
                                5      WILL-DARNALL reiterated in an e-mail correspondence to Mr. Naugle that she would ji e to
                                6      rent units from Plaintiff on a "five-month trial basis."                                       '
                                7             10.     Plaintiff responded that such a short lease term was not acceptable, as the fa I
                                8                                                                                                 ' ore-
                                       season generally brings a down-t11rn in the rental market and Plaintiff did not wish to ha~e
                                9                                                                                                     '
                                       rent multiple units at that time. In'stead, Plaintiff insisted that each lease must run througli
                                                                                                                                      i

                               10      February 28, 2019 at the earliest.,
                                                                                                                                      I
                               11             11.    Defendants WILL-DARNALL and MENICUCCI represented on behalf o,i;
                                                                          .                                                           I
                               12      Defendant ROSSWOOD that the'February 28, 2019 end lease term was acceptable, and i;in the
                                                                          •                                                           i


                               13      basis of that representation Plaintiff agreed to enter into written lease agreements with
                                                                                                                                 '

                               14      Defendant ROSSWOOD for a total of fifty (50) units, with eaeh lease term expiring on
                                                                          .                                                           l
                               15      February 28, 2019. A true and correct copy of orte.o.f the Lease Agreements is attached her to
                                                                         •                                                      !
                               16      as Exhibit A. A chart with the re1haining Lease Agreements' property addresses, start date., and
                                                                          '                                                           i



                               17                                                                                               '
                                       rental rates, is attached as Exhibi( B. The material terms of each of the Lease Agrccrncn~ e
                                                                                                                                      ;

                               18      other substantially similar and therefore full copies of each of the remaining Lease Agred
                                                                         ,                                                       I
                               19      have not been attached.                                                                   I
                                                                          .                                                           I
                               20              12.    Under the terms and conditions of the Lease Agreements, Defendant agreeb o
                                                                          •                                                           t
                               21      undertake obligations including, but not limited to, the payment of monthly installments b rent
                                                                          '                                                           i
                               22      until the end of the each respective lease tern1 on February 28, 2019, in accordance with th

                                23      terms of said Lease Agreement                                                                 !
                                                                                                                                      't
      Pahl & McCay ?4
      A P'm!C:iltirlMi (J:'q1.. ...,           13.    Section 48 of each of the Lease Agreements provides, in pertinent part, tha't •f
      llS\V,SMtaChr:t                                                                                                                 }
      5'.tik l:fOO
                               25                                                                                            '
.
$
      S.:tnJtK::-,C:A95l1'.I
      (408} U/4-.'HOO
                                       Defendant ROSSWOOD vacatesithe subject units prior to the expiration of the lease terrµ,
                                                                                                                                      f
      '1S:lllft)()J.           26      ROSSWOOD would continue to ·be liable for payment of rent through the expiration of th
~y,   00652359,DOCX.l

t;,                            27      lease term, or until a new tenant is secured for the unit in question.                         !
,4                                                                                                                                    •
                                                                                                                                      t
                               2S              14.    Section 53 of each :Of the Lease Agreements provides, in pertinent part, that
                                                                                                                                      f
                                                                                         3
                                       COMPLAINT FOR BREACH 01'" LEASE".




                                                                                                                                    US-0001671

                                                                                                                       US-0001671
                          Case 5:24-cr-00292-PCP           Document 44-13           Filed 04/09/25       Page 5 of 11




                      1      Defendant ROSSWOOD would be
                                                       i
                                                         considered in default of the Lease Agreements if they!;
                      2      vacated or abandoned the subject;units before the expiration of the lease terms.
                                                                                                                              l
                      3             15.    In viola.ti.on of the J;..ease Agreements, on July 31, 2018, Defendant WILL-!
                      4      DARNALL gave notice to Plaintiff that Defendant ROSSWOOD would be vacating ea4 f the
                      5      subject units by August 31, 2018; Defendants thereafter vacated and abandoned each of jh
                                                                                                                              '
                                                                                                                              !

                      6      subject units between August 31 and September 28, 2018, well before the end of the lease erms
                                                                '
                                                                                                                    ;          j


                      7      under the applicable Lease Agreements.
                                                                '                                                              £

                                                                                                                         •    i
                      8             16.    Pursuant to the terms of the Lease Agreements, Defendants are respons1bltl ~ r
                                                                                                                               f
                      9      payment of rent for the subject ut\its. Plaintiff has demanded from Defendanl,;; the paymfn of
                     10      damages resulting from Defendant's breach of each of the Lease Agreements, but no payn nt
                     11      of any kind has been made by ne;rendants.
                                                                                                                  I
                                                                                                                              !
                     12              17.                  '
                                           Defendant ROSSWOOD                                                     ' me
                                                              has also failed to return possession to Plaintiff of,s
                                                                                                                              ''
                     13      of the subject units, following the notice that they would be prematurely vacating and
                                                                                                                               i
                     14      abandoning those units on August 31, 2018. As a result, Plaintiff instituted unlawful deta.i          r
                                                                .                                                              I
                     15      proceedi.ngs against Defendant ROSSWOOD in order to recover possession of these units.
                                                                •                                                              I

                     16      Ultimately, Defendant ROSS\VO'OD relinquished possession during the pcndcncy of the~e
                 17          proceedings, Plaintiff recovered possession of all subject units by September 28, 2018, ap the
                                                                :                                                              f
                     18      unlawful detainer actions wen:: dismissed.                                                       ;
                     19             18.    As a direct and protmate result of Defendants' breach of the lease agreeJe1 ts,
                                                                •                                                              I

                     20      Plaintiff stood to incur damages qf no less than $902,500, totaling the amount of rent ow~ for
                                                                                                                               l
                     21                                                                                                  ' · te
                             each unit through the end of eachj lease term. Plaintiff, however, was able to partially mitjg
                                                                •                                                              I
                     22      these damages by recovering pos~ession of the subject unil~ as soon as possible, and adver ising
                     23      the units at a .reduced rental rate ih
                                                                  ;
                                                                    order to attract renters during a rental housing marketlj
                                                                                                                         ' intiff
                             downturn. To date, Plaintiff has tieen able to re-rent some of the subject units, although lfl·
                                                                                                                         f
                             was forced to re-rent many ofth~se units at a rental rate much lower than the rate agreed)! by
                                                                '                                                             !
•1 '2MIOJ •          26      Defendants.
00652359..DQC,!;,J

                     27             19.    Plaintiff's total damages resulting from Defendants' breach of the Lease
                                                                                                                               t
                     28      Agreements, less the amount of Illaintiff's mitigation efforts as described above, is no le'F han
                                                                               4                                    -------.-,-1----
                            COMPLAINT FOR BREACH 01'' LF..ASEi...                                                              . No .
                                                                                                                             (C.S,,




                                                                                                                             US-0001672

                                                                                                             US-0001672
                    Case 5:24-cr-00292-PCP             Document 44-13             Filed 04/09/25   Page 6 of 11




                    1    Four Hundred Seventy-Four Th~usand One Hundred Forty-One Dollars and 22/100
                    2    ($474,141.22).

                    3                   FIRST CAUSE OF ACTION FOR BREACH OF CONTRACT                                 I
                                                            l   .                       _                            f
                    4              (Against Defendant ROSSWOOD PROPERTIES, LLC, and DOES 1-50) t
                   5             20.
                                                                                                                     '
                                        Plaintiff hereby in¢orporates and re-alleges each and every foregoing para~ ph
                    6    of tliis Complaint us tho11gh full); set forth herein.
                    7            21.    Each of the Lease Agreements constitutes a valid, fully executed contract
                    8    between Plaintiff and Defendant'ROSSWOOD.
                    9            22.    Plaintiff has duly performed all of the terms, covenants and conditions of
                   10    Lease Agreement to be performC:d on. its part.
                   11            23.    Defendant has bre'1ched each of the Lease Agreemenls by prematurely va1a ing
                                                                                                                     i
                   12    and abandoning each and. every one of the units subject to the Lease Agreements, befor~ I e
                                                            •                                                        .'
                   13    expiration of the respective lease, terms. Defendant vacated each of the subject units bel\te n
                                                            i                                                        /

                   14    August 31, 2018 and September ;28, 2018.
                                                                                                                     l
                   15            24.    As a proximate result of Iiefendant's breaches, Plaintiff has been damagedI i that
                                                                                                                     !
                                                          •

                   16    rent charges, including additional rent, have accrued and are unpaid on the Premises in
                   17                                                                                           ' and
                         accordance with the Lease Agre~ment. Plaintiff has also incurred further turnover chargfs
                                                                                                                     I

                   18    foes to institute unlawful detainer actions against Defendant following their failure lo re~ n
                                                                                                                     I
                   19    possession of some of the units. fa total, Plaintiff has incurred damages of no less than F,o r
                                                           •                                                        I

               20        Hundred Seventy-Four Thousan~ One Hundred Forty-One Dollars and 22/100 ($474,14?· 2),
               21        less any amounts Plaintiff is able! to successfully mitigate. Based upon the breaches by ;'
                                                            '                                                        i
                                                                                                                     I
               22        Defendant of the Lease Agreem~nts, Plaintiff is entitled to judgment in said amount.
                                                            .                                                        I
               23              WHEREFORE, Plaintiff SPJEKER COMPANIES, INC., prays for judgment again t
                                                            •                                                        I

                         Defendant ROSSWOOD PROPERTIES, LLC, and DOES 1 through 50, inclusive, and ~a h of
                                                                                                                     ~
                         them, jointly and severally, as st~!ed in the Prayer for Relief below.
•,,,.,,.,, ·   26       Ill
00652359.00CX.,J

               27       Ill
               28       Ill
                                                                            5
                        COMPLAINT FOR BREACH O}' LEASE-




                                                                                                                  US-0001673

                                                                                                      US-0001673
                              Case 5:24-cr-00292-PCP          Document 44-13           Filed 04/09/25     Page 7 of 11




                          1                            SECOND~CAUSE OF ACTION FOR FRAUD
                          2      (Against Defendants CASSIE WILL-DARNALL and LAURA MENICUCCI, and ll ES
                                                                  •                                                         I
                          3                                                   1-50)
                                                                                                                            l
                          4             25.    Plaintiff hereby incorporates and re-alleges each and every foregoing paragr, ph
                          5     of this Complaint as though fully set forth herein.
                          6             26.    Defendants CASSIE
                                                               (
                                                                 WILL-DARNALL and LAURA MENlCUCCI, as aget ts
                                                                                                                            •
                          7      and representatives of Defendant iROSSWOOD, made promises to Plaintiff before enterip into
                          8                                                                                       "
                                 each of the Le.ase Agreements that' Defendant ROSSWOOD would remain in possessionlo
                                                                                                                            I
                         .9     each of the fifty (50) subject unil~; and pay monthly rent and additional
                                                                                                •
                                                                                                          rent accordingly th
                                                                                                                            1
                                                                                                                              ugh
                         10      the end of each lease term on Feb'rnary 28, 2019.
                                                                  .                                                         I
                         11             27.    During the negotiations for the rental of the subject units, Defendants WTL/'.,
                         12     DARNALL and MENICUCC[ hrid stated to Plaintiff that they wanted the Lease Agreem61 ts'
                                                                                                                            I
                         13      end date lo be in September 2018,
                         14             28.    When Plaintiff refused to enter into the Lease Agreements with such a shtirt lease
                                                                                                                            I
                         15      term which would end in arental'market
                                                                 •
                                                                        downturn, Defendants agreed to the February 28,
                                                                                                                     I
                                                                                                                        019
                         16      end date. Plaintiff is informed and believes and hereon alleges that Defendants WILL-      !
                                                                                                                            \'

                         17     DARNALL and MENlCUCCJ, a~ representatives of Defendant ROSSWOOD, made !hi~'
                                                                  '                                                         1
                         18      representation for the purpose of inducing Plaintiff to enter into the Lease Agreements, drs ite
                         19.     never intending to perform according to this promise, Plaintiff is informed and believes ~n
                                                                 •                                                         I

                         20      theron alleges that Defendants WlLL-DARNALL and MENICUCCI always intended to~. cate
                                                                                                                            \'
                         21      each of the fifty (50) units by September 2018,
                         22             29.    Plaintiff, when entering into each of the Lease Agreements, reasonably reUe
                         23      upon Defendants WILL-DARNALL and LAURA MENICUCCI's representation that                     I
fi'.aht & MeCay
A l'rofil.ui.w\ Cutp..   24      Defendant ROSSWOOD would not vacate the subject units until February 28, 2019.
215 W, Sann C!ru\l
Suit~_J!(KI
SanJoi.c, CA!l51U
(4ml) ;m!i,SJOO
                         25             30.    Defendant ROSSWOOD did not perform as promised by Defendanl~ WILJ:.,
                                                                                                                            i
•t526i001 •       26             DARNALL and MENICUCCI, as they breached each of the Lease Agreements when they
00652.159.00CX-.1

                         27
                                                                  :                                                  ~
                                 prematurely vacated and abandoned each of the subject units between August 31 and Sept mber
                         28      28, 2018, and refused to pay any turther rental amounts owed thereafter.
                                                                                   6
                                COMPLAINT FOR BREACH OF LEASE ...




                                                                                                                          US-0001674

                                                                                                              US-0001674
                              Case 5:24-cr-00292-PCP           Document 44-13             Filed 04/09/25    Page 8 of 11



                                                                                                                               '
                         1                31.   Plaintiff's reliance on the false promises made by Defendants WILL-DARh LL
                         2      and MENICUCCI was a substantial factor in causing Plaintiff's damages.
                        3
                                                                                                                               '
                                                                                                                               !
                                          32.   Plaintiff has been damaged in that Defendants owe no Jess than Four Hund)-e
                                                                    :                                                          l
                        4       Seventy-Four Thousand One Hundred Forty-One Dollars and 22/100 ($474,141.22), less1a y
                         5
                                                                                                                               '
                                amounts Plaintiff is able to successfully mitigate.
                         6                                                                                  '
                                       WHEREFORE, Plaintiff SPIEKER COMPANTES, INC., prays for judgment agai?s
                         7      Defendants CASSIE WILL-DARNALL and LAURA MENICUCCI, and DOES 1 througi 0,
                                                                                                                               I
                         8      inclusive, and each ofthern,jointly and severally, as staled in the Prayer for Relief below.\
                                                                                                                               I
                         9                                              PRAYER FOR RELIEF
                       10              WHEREFORE, Plaintiff SPIEKER COMPANIES, INC., prays for judgment agairis
                                                                    :                                                          j
                       11       Defendants ROSSWOOD PROPERTIES, LLC; CASSIB WILL-DARNALL; LAURA                                I
                       12       MENICUCCI; and DOES 1 throJgh 50, inclusive, and each of them, jointly and severauL s
                                                                                                                               i
                       13       follows
                       14                 1.    For damages for breach of the Lease Agreements in an amount to be proven t trial,
                       15
                                                                                                                               I
                                but no less than Four Hundred Seventy-Four Thousand One Hundred Forty-One Dollars                    d
                                                                                                                               I
                                                                    •                                                          !
                       16       22/100 ($474,141.22), less any amounts Plaintiff is able to successfully mitigate;             (
                       17                 2.    For costs of suit incurred herein; and,                                        '
                                                                                                                               ,'
                                                                                                                               !
                       18                 3.    For such other and further relief as this Coutt may deem just and proper.      1

                       19       DATED: November 19, 2018                       PAHL&McCAY
                                                                               A Professional Corporation
                       20
                       21
                       22                                                      By~
                                                                               StephenD.Pahl
                       23
Pahl & M,Cay
/\~lll'~lCrufl,        24"'
225 W, SM:lii Cl:Jra
Sui!c1;5()(J             _
SllnJl)!'4D\9!i113     25
{4-0!!) 2S6-~100

"1526/(Xll •           26
00652J59.DQCX, 1
                                                                                      Attorneys for Plaintiff SPIEKER COMPi NIES,
                       27                                                             INC.                                ;
                       28

                                COMPLAINT FOR BREACH OF LEASE;..
                                                                                  7                                  ------. ~ •    ---------
                                                                                                                            (C-isc. o.




                                                                                                                            US-0001675

                                                                                                               US-0001675
Case 5:24-cr-00292-PCP   Document 44-13   Filed 04/09/25   Page 9 of 11




                            ·EXHIBIT A

                                                                          US-0001676

                                                              US-0001676
               Case 5:24-cr-00292-PCP                              Document 44-13              Filed 04/09/25        Page 10 of 11
                                                                         EJ-100
ATTORNEY OR PARTYWlTI-lOUT ATTORNEY (Name, adc!res'$, anc{Sfete BfJJ' /'lu("ber,1:
Aner recording, return to:
  Stephen D. Pahl 95900
  PAHL & MCCAY
  225 W, Santa Clara Street, Suite 1500
  San Jose, CA 95113
     4 08 -286- 5100 FAX NO (op,oo,1)· 4 08-286'-5722
TEL NO.,
 E-MAILAD □RE.SS (Op!!OM•J):    spa.h1.6lpahl-mccay. com
 IX) ATTORNEY
        FOR
                             IX) JUDGMENT
                                 CREDITOR
                                                  D OF
                                                    ASSIGNEE
                                                       RECORD
SUPERIOR COURT OF CALIFORNIA, COUNTI OF SANTA                   CLARA
     srnEETAooRsss.191 North First Street
    MAIUNGADossss 191 North First Street
   c1rvANoz1Pcooe, San Jose, CA 95113
       BRANCHNAME: San Jose Civil Branch         FORRtcoROER'saRsECRETARYoFsrATE'SUSEONLY
  PLAINTIFF: SPIEKER COMPANIES, INC., a California     c,srnuMBER:
 corporation                                          18CV338308
 DEFENDANT: ROSSWOOD PROPERTIES, LLC a
 California limited liability company 1 _ et al.
         ACKNOWLEDGMENT OF SATISFACTION OF JUDGMENT                                                                  FOB.COURT.USE 0/ill.Y
                                                                                                                      t:1ectronica11y 1-ued
        [Z) FULL                 O PARTIAL                 O MATURED INSTALLMENT                                      by Superior Court of C~,
1. Satisfaction of the judgment is acknowledged as follows:                                                           County of Santa Clara.~
   a.   W  Full satisfaction                                                                                          on 10/7/2022 12:40 PM
                                                                                                                      Reviewed By:C. Romafl
      (1)     DJudgment is satisfied in full.                                                                         Case #18CV338308        •
      (2)     WThe judgment creditor has accepted payment or performance                                              Env #10165534
               other than that specified in the judgment i,\ full satisfaction of the
               judgment.
   b.   D  Partial satisfaction
           The amount received in partial
           satisfaction of the judgment is $
   c.   D  Matured installment
           All matured installments under the installmentjudgment have been satisfied as of (date):
2. Full name and address of judgment creditor:•
   Spieker Companies, Inc.
   1020 Corporation Way, Suite 100, Palo Alto, CA 94303
3. Full name and address of assignee of record, if any:



4. Full name and address of judgment debtor being fully'or partially released:'
   Cassie Will-Darnall                                                Laura Menici.;.cci
   111 Belwood Gateway, Los Gatos, CA 95032                                              105 Bluebonnet Lane, #13, Scotts Valley, CA s;so 5
5. a. Judgmentenleredon {dafe):April 29, 2022
   b.   D Renewal entered on (date):
                                                                                                                                              !
                                                                                                                                              1
6. (XJ An   W abstract of judgment                         D      certified copy of the judgment has been recorded as 1ollows/comp/efe all !
                                                                  information for each county where recorded)                              1  '
                                COUNTY                                               DATE OF RECORDING                  INSTRUMENT NUMB.E
Santa Cruz                                                                 June 8, 2022                       2022-0017567                    '
Santa Clara                                                                yune 8, 2022                       25317008
Riverside                                                                  June 8, 2022                       2022-0261355
7. □ A notice of judgment lien has been filed in the office of the Secretary of State as file number (specify):                               !
                                                                                                                                              t
                                                                                                                                              I
                                                                                                                             to be recordedlin each
                                                                                                                             ice of the Secret   of




                                                                                                           1526.009




                                                                                                                                             US-0001677

                                                                                                                           US-0001677
   Case 5:24-cr-00292-PCP                               Document 44-13                   Filed 04/09/25                 Page 11 of 11




 CALIFORNIA ACKNOWLEDGMENT                                                                                                  CIVIL CODE§ 11l\!9
                 l. U E J                           MM                                                 lffi@:.W      e::::e □ : □ 2J1emge4;s
                                                              ,                                                                                      I
   A notary public or other officer completing this cer\ificate verifies only the Identity oi the individual who signed the documen~
   to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.                         '

State of California                                                    }
Countyof         &n~ Cliinl
On O:,hii?ev 'I{ '].f}"l,Z,.                        before ;ne,       '/vQr,.ne, J1,,t leer,, /\Jr/tl,v1/ Pi,.._/:,1 ic,,.
               Date                               r,.         .          C'   Here Insert Name and Title ht the Officer
personally appeared _ _ ______,,Ul=.,_±b-'-"'e.-:"--'µ(l<:e,=--",2)-=-,c,h'--.lllo,,,1'.r).tl,!..l.>ll:>ch:....u.Yl.,__gp='-'~=--'-"""W\.:....,__ _ __,_,
                                                                 Name{s) of Signer{s)


who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribe;ci
to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their             \
authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity                                      !
upon behalf of which the person(s) acted, executed the instrument.                                                                                   I

                        neeeeeer
                          YVOIIHE M. LEON
                       Nowy FUblk • Calfforni.l
                                                    f
                                                    f
                                                                           I certify under PENALTY OF PERJURY under the
                                                                           laws of the State of California that the foregoing
                                                                                                                                                     I
                                                                                                                                                     'I
                         Santa. Clara: County       I                      paragraph is true and correct.
                         Commlulcn I 2J3Sl6!        ~
                    My Comm, Expire, Ot< 6, 202!                           WITNESS my hand and official seal.



                                                                           Signature       hv,,;, 1 D a .¢t;i
          Pface Notary Seyal and/or Stamp Above                               ~ a t u r e of Notary Public
                                                                  OPTIONAL - - - - - - - - - - - - - - - + ;
                          Completing this information can deter alteration of the document or
                           fraudulent reattachment of this form to on unintended document.
  Description of Attached Document
  Title or Type of D o c u m e n t - - - - - ~ - - - - - - - - - - - - - - - - - - - - -
  DocumentDate: _ _ _ _ _ _ _ _ _~___________ Numberof Pages: _ _ __
  Signer(s) Other Than Named A b o v e ; - ~ - - - - - - - - - - - - - - - - - - - -
  Capacity(ies) Cl.aimed f;)y Slgner{s)
  Signer's Name: _ _ _ _ _ _ _ _ _ _ __                                     Signer's Name: _ _ _ _ _ _ _ _ _ _ __
  □ Corporate Officer - Title(s): -------,----                              □ Corporate Officer - Title(s): _ _ _ _ _ __
  □ Partner - □ limited □ General                                           D Partner - □ limited □ General
  □ Individual            □ Attorney in Fact                                □ Individual            □ Attorney in Fact
  □ Trustee               □ Guardian or Cons.ervator                        □ Trustee               □ Guardian or Conservator
  D Other. - - - - - - - - - - - ~ - -                                      □ Other: _ _ _ _ _ _ _ _ _ _ _ _ __
  Signer is Representing: _ _ _ _ _ _ _ _ __                                Signer is Representing: _ _ _ _ _ _ _ _ __



©2019 National Notary Association




                                                                                                                                                  US-0001678

                                                                                                                               US-0001678


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