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LAW OFFICES OF JEFFREY H. KIM Jeffrey H. Kim (SBN 218305) 800 West Sixth Street, Suite 1020 Los Angeles, CA 90017 Tel: (213) 627-5200 Fax: (213) 627-5209 Attorney for Plaintiff SAMUEL ANGULO

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES NORTHWEST DISTRICT ) SAMUEL ANGULO, an individual, ) ) Plaintiffs, ) ) ) vs. ) ) ) JUDITH MOCKLER, ET AL. ) ) Defendants. ) ) ) ) ) ) ) ) ) ) AND ALL CROSS-ACTIONS ) Case No.: LC074074 ASSIGNED FOR ALL PURPOSES TO HONORABLE JUDGE JAMES A. KADDO Department NW-I STIPULATION TO CONSOLIDATE RELATED CASES; [PROPOSED] ORDER TO CONSOLIDATE RELATED CASES COMPLAINT FILED: January 9, 2006 TRIAL DATE: None set

TO THE COURT, AND ALL PARTIES AND THEIR ATTORNEYS OF RECORD: WHEREAS, the parties want to maintain judicial economy; WHEREAS, the parties want to engage in meaningful settlement negotiations;
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IT IS HEREBY STIPULATED AND AGREED BY COUNSEL FOR THE UNDERSIGNED PARTIES THAT:
1.

The

limited

jurisdiction

matter

entitled

JORBY

RUIZ

V.

JUDTIH MOCKLER, SAMUEL ANGULO, and DOES 1 to 10, Inclusive, Case No. 06E01826, filed in County of Los Angeles, Northwest District, is related to the above-captioned case in unlimited jurisdiction entitled actions, SAMUEL Case ANGULO V. JUDITH filed MOCKLER, in and related Los cross-

No.

LC074074,

County

of

Angeles,

Northwest District.
2.

The two related cases, with the courts permission, shall

be consolidated for all purposes to serve judicial economy and to prevent the potential for inconsistent judgments or rulings

arising out of these two cases.

3.

Because the limited case is consolidated with an unlimited

case, the lead case shall be the unlimited case entitled SAMUEL ANGULO V. JUDITH MOCKLER, and related cross-actions, Case No.

LC074074, filed in County of Los Angeles, Northwest District.

4.

This Stipulation may be executed in sub-part, and facsimile

signatures shall have the same effect as the original. IT IS SO STIPULATED. DATED: _______, 2006 LAW OFFICES OF JEFFREY H. KIM, A P.C.

By: _________________________________ JEFFREY H. KIM, Esq. Attorneys for Plaintiff, SAMUEL ANGULO
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DATED:

_______, 2006

LAW OFFICES OF BEVERLY MILLS

By: _________________________________ BEVERLY MILLS, Esq. Attorney for Defendant and CrossComplainant JUDITH MOCKLER DATED: _______, 2006 LAW OFFICES OF ABRAMS, TOFER & REGHABI

By: _________________________________ O. ALEX TOFER, Esq. Attorney for Plaintiff in Limited Case, JORBY RUIZ DATED: _______, 2006 GLAZER & BLINDER

By: _________________________________ DAVID M.S. TAAM, Esq. Attorney for Defendant in Limited Case, SAMUEL ANGULO

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ORDER This matter having come before this Court by Stipulation of the Parties to Consolidate the Related Cases, the Court having reviewed the Stipulation, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED:

The matter entitled JORBY RUIZ V. JUDTIH MOCKLER, SAMUEL

ANGULO, and DOES 1 to 10, Inclusive, Case No. 06E01826, filed in County of Los Angeles, Northwest District, is consolidated to the above-captioned case entitled SAMUEL ANGULO V. JUDITH MOCKLER, and related cross-actions, Case No. LC074074, filed in County of Los Angeles, Northwest District. 2. The lead case shall be the case entitled SAMUEL ANGULO V. JUDITH MOCKLER, and related cross-actions, Case No. LC074074, filed in County of Los Angeles, Northwest District. DATED:_____________, 20006

__________________________ Judge of the Superior Court

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ___ BY MAIL STATE OF CALIFORNIA COUNTY OF LOS ANGELES

PROOF OF SERVICE ) ) )

ss:

I am employed in the County of Los Angeles, State of California. I am over the age of 18 years and am not a party to the within action. My business address is 800 West Sixth Street, Suite 1020, Los Angeles, CA 90017. On August 9, 2006, I served the foregoing documents described as STIPULATION TO CONSOLIDATE RELATED CASES; [PROPOSED] ORDER TO CONSOLIDATE RELATED CASES on the interested parties in this action by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Beverly I. Mills, Esq. Law Offices of Beverly I. Mills 6400 Canoga Avenue, Suite 203-D Woodland Hills, CA 91367 Fax: (818) 884-3435 O. Alex Tofer, Esq. Law Offices of Abrams, Tofer & Reghabi 315 South Beverly Dr., Suite 404 Beverly Hills, CA 90212 Fax: (310) 277-2888 David M.S. Taam, Esq. Glazer & Blinder 23945 Calabasas Road, Suite 200 Calabasas, CA 91302 Fax: (818) 591-7523

I deposited such envelope into the Firms office mail at Los Angeles, California. I am readily familiar with the Firms practice of collection and processing correspondence for mailing. Under that practice, in the ordinary course of business, the mail is affixed with postage thereon fully prepaid and deposited with the U.S. Postal Service in Los Angeles, California on the same day. I am aware that on motion of a party served, service is presumed invalid if the postal cancellation date or the

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postage meter date is more than one (1) day after the date of deposit for mailing in this affidavit. ___ BY PERSONAL SERVICE

I hand delivered such envelope to the offices of the addressee(s) listed above. ___ BY FACSIMILE

I sent such documents named above by facsimile to the offices of the addressee(s) listed above. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed August 9, 2006 at Los Angeles, California. _____________________________ Angela J. Kim

__________ Stipulation to Consolidate Related Cases