SUPPLEMENT To 10-16-17 Req To Review FINAL Sent 12-11-17.compressed

Nancy Duffy McCarron, CBN 164780
950 Roble Lane

Santa Barbara, CA 93103
nancyduffysb@yahoo.com
805-450-0450
December 11, 2017
PERSONAL AND CONFIDENTIAL RE: Supplement to Request to Review

Steven J. Moawad
The State Bar of California 10-16-17 Request to Review Conclusions in Case 16-0-16202
Complaint Review Unit Respondent: Richard Nahigian, Robert Williamson
Office of the General Counsel Aggravating Factors: 2 Public Reproval Cases (Nahigian)
180 Howard Street 1 Private Reproval Case (Nahigian)
San Francisco, CA 94105-1617 Conclusions of State Bar Investigator Lita Abella
I represent Martin Jacinto and wife Carolina Ramirez – complainants in this Case No. 16-0-16202,
in Stubblefield v. Jacinto (CIVDS1208547) and Martin Jacinto v. Richard Nahigian (CIVDS1604759).
On July 21, 2016 Jacinto filed a bar complaint against Richard Nahigian and Robert Williamson related
to collusion in CIVDS1208547 resulting in $190,499.00 in fees against Jacinto on a $10,000 mobile home.
As you know on 9-28-17 Lita Abella sent a letter to Jacinto notifying him that she had closed the case.
On 10-16-17 we filed a Request to Review not only Ms. Abella’s conclusions but also her inherent conflicts.
Jacinto provided a significant amount of detailed evidence showing why Ms. Abella’s conclusions were not
supported by the overwhelming evidence Jacinto presented in his California State Bar attorney complaint.
Since July 21, 2016 I have discovered significant additional evidence. I obtained certified copies of
additional court records and transcripts attached to this supplement. Also attached is Jacinto’s brief
entitled “Opposition to Motion to Dismiss Appeal” filed at 4/2 DCA on 11/22/17. [Exh. 1 filed separately].
Stubblefield moved to dismiss Jacinto’s appeal of denial of a motion to set aside the $190,499.00 fee award
obtained by fraud on the court and Jacinto. Disposition of the motion to dismiss the appeal is pending.
We ask you to review Ms. Abella’s conclusion that there was no evidence against Robert Williamson.
Jacinto’s Statement of Facts in the attached “Opposition to Motion to Dismiss Appeal” provides compelling
evidence showing Nahigian colluded with Williamson to make sure he got the extortionate $190,499.00 fee
award by failing to file an opposition and failing to appear at oral argument. Nahigian intentionally failed
to file a CCP §473 motion to set it aside until 9/28/15---after the 6-month deadline to file it had expired.
Nahigian violated a fiduciary duty to Jacinto by initiating a conference call between Jacinto’s hard
money lender Bruno Ehlert, Williamson, Stubblefield, and Jacintos [Exh. 2] for Ehlert to disclose all of
Jacinto’s assets for Williamson to decide which property to arrange a 12% hard $ loan to get $$63,106.40
to pay Stubblefield’s judgment in full with 10% interest [Exh. 3]. This was without deducting $31,846.00
for removal costs---despite the court’s order to deduct removal costs from the awarded judgment.[Exh. 4];
and without deducting $5,000 to refund Jacinto’s deposit posted before removing the mobile home [Exh. 5].
Nahigian then summoned Jacinto’s son Chris Martinez to lend Jacinto $15,000 to create a cashier’s check
payable to Robert Williamson, Jr. personally for the “privilege” of negotiating a “settlement.” [Exh. 6].
Williamson actually netted $51,846 in fees ($31,846 not credited+$5,000 not credited+$15,000 cold cash).
This was 126% of the $41,168.0 4/8/14 judgment despite that Williamson was not entitled to any fees.
Page 1
Bottom line: Nahigian did everything to help Williamson and Stubblefield extort money from Jacinto,
and nothing to help Jacinto settle the fees with Williamson, set aside the extortionate $190,499 judgment,
or obtain two credits Jacinto was entitled to against Stubblefield’s judgment. [$31,846.00 + $5,000.00].
Nahigian facilitated nothing except benefits to Williamson & Stubblefield and cash detriments to Jacinto.
This was after collecting a $25,000 retainer+$3,000 for an intern to prosecute a bogus appeal he dismissed.
2/7/16 Nahigian paid for appeal documents with a $199.00 check drawn on from his personal bank account
proving he commingled client funds in his personal account. Ms. Abella missed this misconduct. [Exh. 7 ]
We ask you to review what happened in CIVDS1604759 - Martin Jacinto v. Richard Nahigian and
investigate Jacinto’s former attorney Kent Sharp and Nahigian’s attorney Chris Overton for collusion.
In 2016 Jacinto hired Chris Lockwood (an honest attorney they met through church) to sue Nahigian.
Chris diligently investigated facts, gathered documents, and filed a malpractice case against Mr. Nahigian.
Chris Overton served the malpractice lawsuit on Nahigian in early 2016. While waiting for Nahigian to
answer the complaint Jacinto’s hard money lender Bruno Ehlert advised Jacinto to hire attorney Kent
Sharp to litigate the malpractice case. Jacinto set up a meeting with Kent Sharp at his San Diego office.
During that consultation Kent Sharp advised Jacinto to fire Chris Overton and solicited Jacinto to sign
a substitution of attorney form. Jacinto signed it. Kent Sharp took over the malpractice case that day and
also took over Stubblefield’s case against Jacinto CIVDS1208547. Kent Sharp never moved to set aside the
extortionate $190,499.00 judgment obtained by fraud on the court and Jacinto. [see Exhibit 1–Opposition]
Kent Sharp simply advised Jacintos to refinance another property with a 12% interest hard $ loan to pay
Stubblefield $190,499.00 plus interest and to pay additional attorney fees to Robert Williamson.
Kent Sharp amended Jacinto’s malpractice complaint to include punitive damages for breach of duty,
served it on Nahigian, and then took his default 31 days later. This was 9 days too early because the
process server did not serve Nahigian personally but rather served it on Nahigian’s receptionist at his
Pasadena office. Rather than stipulate to set aside the default and accept Nahigian answer Kent Sharp
spent the next 10 months litigating the issue while billing Jacinto $20,000. (Exh. 8]. This was an egregious
violation of duty to the client. Sharp knew Judge Pacheco would set aside Nahigian’s default because
courts must set aside a default judgment if the party submits an attorney’s affidavit admitting fault.
After oral arguments on 6/13/17 Judge Pacheco set aside Nahigian’s default on 6/14/17. I attended
oral arguments on 6/13/17 to represent third party Bonnie Shipley concerning a new lien she had against
Stubblefield’s lien in Nahigian’s case as he had not fully paid Shipley’s judgment in CIVDS1204130.
Before the morning calendar on 6/13/17 Judge Pacheco’s clerk distributed a tentative ruling on the motion
to Jacinto’s attorney [Kent Sharp], Nahigian’s attorney [Chris Overton] and me for Ms. Shipley. [Exh. 9]
The tentative order showed the court would set aside the default but deny $10,000 in attorney fees Kent
Sharp had requested. Kent Sharp had a duty to argue against fee denial as he knew Jacinto paid $20,000.
Yet, the 6/13/17 transcript shows Kent Sharp never argued against denying Jacinto attorney fees. [Exh. 10]
Secondly, Kent Sharp never shared the tentative ruling with Mrs. Jacinto when she arrived at the hearing.
Nahigian only asked the court to set aside default and enter his proposed answer. The moving papers never
asked the court to quash Jacinto’s recorded $734,000 judgment, including $500,000 in punitive damages.
There was nothing in Sharp’s opposition or Nahigian’s reply on quashing Jacinto’s judgment abstract.
The 6/13/17 transcript [Exh. 10] shows quashing Jacinto’s abstract of judgment was never argued in court.
Quashing the abstract prejudiced Jacinto as Nahigian was trying to sell his $6,000,000.00 Los Angeles estate
and he would not have been able to close escrow unless Jacinto’s recorded judgment abstract was quashed.
Chris Overton inserted “abstract is quashed” into the proposed order he delivered to chambers on 6/13/17.
Overton failed to comply with Rule 3.1312 by first giving the proposed order to Kent Sharp, and waiting 5
days for Kent Sharp’s objections to the form of the order before delivering it to chambers for signature.
Page 2
The order shows it was signed 6/14/17 (a day after 6/13/17 oral arguments) with no objections from Sharp.
Overton violated his duties as a court officer by inserting “quash abstract” into the proposed order,
knowing he never sought such relief in moving papers or during oral arguments on 6/13/17. He willfully
violated Rule 3.1312. If he gave the proposed order to Kent Sharp on 6/13/17 then Kent Sharp violated
his duties to Jacinto by not protecting Jacinto’s right to seek an attachment order to attach sale proceeds,
since Judge Pacheco awarded $500,000 in punitive damages after reviewing default evidence presented.
On 6/14/17 a set aside default order, quashing the $734,000 judgment abstract was entered. (Exh 11].
On 8/8/17 Nahigian’s sale escrow closed. Nahigian received $1,146,336.99 in net proceeds. [Exh. 12].
We ask you to prosecute Nahigian for his egregious violations of Rules of Professional Conduct and fraud.
We ask you to compel restitution to Jacinto for all damages caused by Nahigian’s egregious misconduct.
We ask you to investigate Robert Williamson, Chris Overton, and Kent Sharp for their roles in colluding
with each other to enrich their clients to the severe financial detriment of Jacinto who has been straddled
with insurmountable debt for which they can never repay in a lifetime of working overtime to survive.
English is Jacintos’ second language. They have worked double shifts and overtime to comply with the
court’s 4/18/14 order to remove the mobile home from Stubblefield’s park, to make payments on the 12%
hard money loan on their property to pay off $63,106.40. Jacinto’s son committed suicide right before the
trial in CIVDS1208547 from extreme stress in the family household resulting from an endless nightmare
generated by a $10,000.00 purchase of a mobile home to relocate their elderly, failing mother from Mexico.
They have suffered enough. They lost a son. This nightmare has cost Jacinto $200,000 already. [Exh. 13].
Stubblefield got the mobile home removed from his park and received $63,106.40 to satisfy the judgment.
Jacinto never received a $31,846.00 credit from the judgment as the court had ordered. Jacinto never
received a $5,000 refund on a deposit Stubblefield took from him before he would approve the removal.
Williamson netted $51,846 in fees ($31,846 not credited for removal costs+$5,000 not credited for refund of
Jacinto’s $5,000 deposit +$15,000 cold cash paid by Chris Martinez on behalf of his parents (the Jacintos).
This was 126% of the $41,168.0 4/8/14 judgment---despite that Williamson was not entitled to any fees
under federal and state law. [Exh. 14] Nahigian received $1,146,336.99 net proceeds by selling his home.
Nahigian received $28,000.00 from Jacinto. Kent Sharp received over $20,000 from Jacinto and is still
harassing them with monthly invoices despite doing nothing to help them and everything to their prejudice.
Nahigian did nothing to help Jacintos and everything to their prejudice. It is time for justice to prevail!
We urge you not to let any of the greedy scoundrels get away with abusing innocent victims who can barely
speak English but work diligently to contribute to our community. Martin Jacinto runs an appliance repair
business and his wife Carolina runs a janitorial business to keep our schools and local businesses sanitary.
Their only mistake was to try to relocate a mom from Mexico into Stubblefield’s senior mobile home park.
No good deed ever goes unpunished! For this good deed they have endured a financial nightmare since 2012.
This nightmare must end! It is time for the State Bar to protect victims – not scoundrels with a bar license!
This is the fourth time Nahigian extorted a significant cash retainer without performing the legal services.
[see Exh. 15] The Bar imposed a private reproval on Nahigian for 2 public reprovals against Nahigian.
We await your decision upon full review of CIVDS1208547, CIVDS1604759, Ms. Lila Abella’s conflicts,
Richard Nahigian, Robert Williamson, Chris Overton and Kent Sharp.
12/11/17
Page 3
DECLARATION OF IUCHARD NAHIGIAN 2
I, Richard E. Nahigian ,declare as follows:
1. I am an attorney at law licensed to practice in the State of California and have
been so licensed since January 1970.
2. I am the attorney for defendant Martin J. Jacinto in the case herein.
3. During the pendency of the original complaint, Mr. Jacinto retained h4oises A.
Aviles to represent him. Mr. Aviles was the driving force behind the cross complaint
being filed on behalf of Mr. Jacinto. It as in this cross complaint that attorney's fees were
fist addressed by either party.
4. After the conclusion of trial, Mr. Jacinto fired Mr. Aviles as his representative for
his failure to properly advise Mr. Jacinto of the possible consequences that could result
from losing at trial.
5. On July 16,2014, Mr. Aviles forwarded Plaintiffs Notice of Motion and Motion
for Attorney's Fees to Mr. Jacinto.
6. On September 11,2014, Mr. Jacinto retained my services to represent him in this
matter. I contacted attorney Robert G. Williamson from King1 Hart to start negotiating
the terms of the "punch list" and settlement of the jury verdict. The jury verdict ordered
Mr. Jacinto to remove the mobile home fiom the Mountain Shadows Mobilehome
Community under the strict provisions outlined by Plaintiff, Thomas Parrish, the Senior
Vice President of Stubblefield Properties in a Removal Letter dated April 17,2013.
7. Staring in October 2014, Mr. Jacinto received numerous bids to perform he
mobile home removal fkom Shadow Hills.
8. In mid October, 2014, Robert G. Williamson received Mr. Jacinto's contract with
Palma ~onstruction,a cashier's check, %Certificateof Liability Insurance with *
Mountain Shadows as a certificate holder and a copy of the April 17,20 13 Removal
Letter. Palma Construction was retained to start the punch list requirements and remove
the mobile home fiom the space.
9. In November 2014, the punch list items were started, and the mobile home was
removed fiom the site. There was additional work to be completed by a separate
I- .-
contractor for the concrete and grading work.
lo. In early November 2014, Mr. Jacinto made a settlement offer to Plaintiff for
Page 4
11. This offer was again made in writing on November 8,2014.
12. During the course of the next few months, there were numerous attempts by Mr.
Jacinto and myself to clear up the punch card items with Mr. Parrish, such as filling in
the depression fiom the concrete removal and grading the property.
13. On February 5,2015, Robert G. Williamson asked me to clarify my client's
proposal for settlement, which I did on the same date.
is . On February 16,20 15, I contacted Robert G. Williamson to confirm a meeting
with Mr. Parrish at Mountain Shadows for a site visit. I also informed him that I had to
be in San Diego in the afternoon on February 17,2015 for a federal criminal matter.
r5 . On February 17,2015, I met with Mr. Parrish and his assistant, Eva, at Mountain
Shadows were we went over all items remaining on the punch list and trying to
accomplish an acceptable manner to complete the items.
16. On February 17,2015, I attended the United States District Court criminal
matter, which went over to February 18,2015. I immediately advised Robert G.
Williamson of the fact that the federal criminal matter mandated my appearance and I
would need to postpone the Attorney's Fees Hearing. The Motion had previously been
postponed in order to allow the defendant to complete the punch list requirements.
17. Early on February 18,2015, I contacted Robert G. Williamson at 8:15am and
reminded him that I was in federal court and all remaining punch list items were
scheduled to be completed shortly.
18. Robert G. Williamson responded within three minutes and asked if I would
assume the costs of the court reporter and interpreter if the matter were postponed, to
which I agreed.
19. At 10:38am, Robert G. Williamson informed me that the Court would not
continue the hearing and a bench warrant was issued for Mr. Jacinto for his fail&e to
appear at the Judgment Debtor Hearing.
I
20. I directed Mr. Jacinto to appear in Department 35 that afternoon and drove
directly fiom the United States District Court in San Diego to San Bernardino to
surrender Mr. Jacinto to the court and the bench warrant was recalled.
21. The court suggested I file a Motion for Reconsideration for the Attomey's Fees.
- _-
22. On February 19,2015, Robert G. Williamson represented that we would talk
settlement after the site work had been completed per the Removal Letter.
31 On Fehninrv 75 7n15 the Order Grnntina A t t n r n ~ v ' cFPPCin the nmniint nf Page 5
was rejected for lack of original signature, failure to reserve a date with the court prior to
filing and because the fee waiver on file for Mr. Jacinto had expired and the* fee
submitted in the amount of $465 for this hearing.
2s. On March 15,2015, Robert G. Williamson and I agreed to put a hold on the
attomey's fees in hopes that we would be able to resolve the issue through settlement
negotiations. I
26. On April 10,2015, Robert G. Williamson informed me that Mr. Parrish intended
to cancel Mr. Jacinto's Debtor Hearing and we set up a meeting with all parties to
discuss Mr. Jacinto's assets in order to reach a settlement.
27. On April 20,201 5, Robert G. Williamson, Mr. Parrish, his assistant, Eva, Mr.
Jacinto, his wife. Yolanda and I met. During this meeting, we ----------
Georg Bruno Ehlert. Mr. Ehlert is a loan coordinator for the Jacinto's and has detailed
F,
knowledge regarding the investments1properties of the Jacinto's.

28. During this conference, we went over all assets and properties belonging to Mr.
Jacinto or his wife Yolanda, in an attempt to structure a settlement agreement acceptable
to Mr. Parrish.
29. In May or June 2015, Mr. Jacinto made a $15,000.00 nonrekndable deposit in
the Hartl King trust account to cover additional attomey's fees incurred to negotiate a
final settlement.
30. On July 17,2015, Robert G. Williamson rejected the settlement offer of $65,000
cash and $30,000 at 8% on a secured note payable at the rate of $450 per month. The
counter offer, which was for the full amount, was $70,000 cash and $178,387.00 on a
secured note at 8% payable at $500 per month.
31. When 'the only counter offer made by Plaintiff was for the full amount 6f
judgment, it became abundantly clear that there was no good faith by Plaintiff to resolve
this matter for anyullng short of the entire order for attomey's fees.
32. I expressed my desire to file a Motion for Reconsideration and we agreed on
September 17,2015 as a mutually acceptable date.
33. After a thorough review of all the facts in this case, I believe a Motion to Set
- _-
Aside the Judgment is more appropriate for this scenario since the failure on my part to
attend the Motion for Attorney's Fees due to a mandatory appearance in Federal Coua in
another county was excusable neglect. Page 6
35. Had the Motion for Attorney's Fees been argued and heard on its merits, I
believe there would have been a substantially different outcome based on the possible
defenses of due process, notice and general equitable principles.
36. I did not file a written opposition but was prepared to orally oppose and argue the
Motion on its merits.
37. I would have contested the overall amount on the equitable principle of
unreasonable attomey's fees. The judgment in the trial awarded to Plaintiff was
approximately $40,000. The attorney's fees are almost 5 times that amount at $190,000.
As represented by Robert G. Williamson, he asked the manager of Shadow Hills Mobile
Home Community 2 questions (although I have no direct personal knowledge of this)
regarding the civil rights violation of racial discrimination. These were questions
directly related to the large population of Hispanic clients living at the Mountain
shadows community.
38. I would have contested the amount of attomey's fees billed from March 2012 to
June 20 13. The total amount for these billable hours was $18,740, with the last 40 of
those hours being billed at the discounted rate of $275.00, not the $350.00. Nowhere in
the Community Guidelines of Mountain Shadows Mobile Home Community are there
any provisions for the award of attorney's fees. Additionally, in the original complaint,
Plaintiff did not request any attomey's fees. Therefore, there was no notice to Mr.
Jacinto regarding these particular fees and holding him accountable for such fees
violates his due process rights. It was not until the cross-compliant was filed that
attorney's fees were contemplated by the parties.
39. By the request of Plaintiff, $15,000 was deposited to cover additional attomey's
fees that would incur over the continued negotiations to settle the total debt to Plaintiff.
Although Mr. ~acintomade numerous offers, there was never any counter offer made by
Plaintiff until July 2015. Mr. Jacinto continued to attempt to meet the demands of
Plaintiff and fulfill the judgment of the punch list items all in good faith and reliance
there would be an acceptable settlement.
40. During the majority of the settlement negotiations, unbeknownst to Mr. Jacinto,
and me a lien was placed on property owned by Mr. Jacinto on February 25,201 5. The
---- -..
very same day the court signed the order awarding attorney's fees. This demonstrates the
bad faith of Plaintiff and the pattern of incurring attorney's fees that are not reasonable.
A1 The hillahl~hnllrc have h ~ inflnt~rl
~ n 2nd are nnt reslcnnahle fnr the amnnnt nf Page 7
billing rate of $350.00, but then turns around and bills for the legal research that one
who had such specialization would be assume to already know.
4 2. The billable hours for the Motion for Attorney's Fees alone in unreasonable at
the expense of $4,809.00 not including expenditures.
43. As recent as August 17,20 15, Georg Bruno Ehlert wrote a payment demand to
9
Robert G. Williamson for fhetdaf amount of the original judgment (including the tax
penalty) in order for Mr. Jacinto to make full payment and has yet to receive any,word
back. Mr. Ehlert followed up with Robert G. Williamson again the next day with no
response. (See Exhibit A,) This is only further demonstrative evidence of the Plaintiffs
continual efforts to make this process as challenging and difficult as possible for Mr.
Jacinto.
I declare under penalty of pejury under the laws of the State of California that the
foregoing is true and correct.
Executed on August 21,20 15, at Pasadena, California.
Richard E. R a h i g i w
Page 8
3
August 25,2015
Ronald M. Fernando Sr.

Senlor Title Offacer
Lawyers Title
1675.5Von Karman Avenue #I00
Iwine, CA 92606
Dear Mr. Femndo:
Pursuant toyour request, demand is hereby made for payoff of the judgment and the post judgment
order in ClYl?S12?8547 on behalf of Stubblefield Properties, dba, Mountain Shadows ~ o b i l eHome
Community entered on October 1,2014, recorded as instrument number 2014-Wl8050 and on
-'February25,2015 recorded 2s instrument number 2015-30100,respectively, as follows:
Instrument No-: 2014-9418050
Date off udgmnt

Date of Order
Amount o f Judgment
Amount of Order
Interest Rate
Date of Demand
Daily Interest Amount
Interest Owedthru
Date of Demand
Total Amount Owed

As of Date of Demand $63,090.54
i!
$499,945.66
- \
$- iSf6 12
Very truly yours,

Stubbtefiefd Properties
On behalf of Mountain Shadows Mobileho.rneCommunity
Kathrine Faulise, Office Manager
c : \ u s e r s \ k a t h y W ~ e n t s ~ s m hcurrent
c projects\spc 120 demand.docx
Page 9
4
et Legal Support (951 )779-01 00 00/00/2-
First Legal Support (951 )779-01 00 00/00/2013
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~ 9 COUNTY OF SAN BERNARDINO- CIVIL DIVISION
10 STUBBLEFIELD PROPERTIES, a Case No. CTVDS 1208547

Califontia general partnersrnp, dba
11
MOUNTAIN SHADOWS MOBILE
12 HOME COMMUN1TY, f~J JUDGlVillNT IN FAVOR
OF PLAINTIFF STUBBLEFIELD
13 Plruntiff, PROPERTIES, A CALIFORNlA
GENERAL PARTNERSHIP DBA
14 v.
MOUNT.AIN SHADO\VS MOBILE
HOM:E COJVTIVJUNITY, AND AGAINST ·
15 DEFENDANT MARTIN C. JACINTO
MARTIN C. JACINTO, AFTER JURY TRIAL.
16
17
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19
Defendant.
l
The court having directed a verclict in favor Plaintiff and Cross Defendant
20 Stubblefield Properties, a California general partnership dba Mountain Shadows Mobile
21 Home Community and Cross Defendant Thomas Panisb, sued as Mr. Panish, against
22 Defendant and Cross Complainant Martin C. Jacinto on tbe issue of liability and having
23 dismissed the Cross Complaint on March 17, 2014;
24. On March 18, 2014, tbe jury on a special verclict found that Defendant Martin C.
25 Jacinto's wrongful conduct caused hann to Plaintiff Stubblefield Properties entitling Plaintiff
26 to damages for past and fllture rental value lost and cost of removal of tbe mobilehome from
27 space l 20 and restoration of mobilehome site, and the Court Clerk having recorded and filed
28 the special verdict, JT IS HEREBY ORDERED, ADruDGED AND DECREED, ·
Page 10
J 6568.050/,1852-SB I0-6521 v. l
{P/10/'0SED) JUDG~I£1/T
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A>t Legal Support (9512779-01 00 00/00/2-
Legal Support (951),79-0100 00/00/20 W
Judgment in favor of Plaintiff Stubblefield Properties, a Cahfonua general partnerslup
2 dba Mountain Shadows Mobile Home Cornmun.ity and against Defendant Martin C. Jacinto
3 in the sum of$41,166.58;

4 Tbat Defendant Martin C. Jacinto has no interest in or possessory right or rigbts to
s space 120 in Mountain Shadows Mobilehome Community, 4040 E. Piedmont Drjve,
6 Highland, CA; and
7 That Defendant Martin C. Jacinto shall be and hereby is ordered to ·· remove ills
8 mobilehome from Mountain Shadows Mobilehome Community in accordance with
9 Plaintiffs requirements set forth in Mountain Shadows Mobilehome Cmmnun.ity's move out
10 letter dated April 17, 2013. Defendant's removal of his mobilebome shall be partial
11 satisfaction of this judgment to tl1e extent of Ius verified costs incurred for said removal.
12 Plaintiff to recover its costs.
13 The Comt Clerk shall forthwith enter this judgment.
14 IT IS SO ORDERED.
15
16 Dated:QL!- (j b , 2014
17 l-Ion. Bryan F. Foster, Judge, Supe1ior
Court
18
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J656S.OS0/4851-881 0-6521 v.I
{PROPOSED} JUDGM£/'IT
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RICHARD E NAHIGIAN 2656607199
2656 ABERDEEN AVE
LOS ANGELES, CA 90027-1222
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SUPERIOR COURT OF CALIFORNI A, COUNTY OF SAN BERNARDINO
8303 N. Haven Avenue, 1" Floor, Ranch o Cucamonga, CA 91730-3848
PLArNTIFF(S) AND RESPONDENT FOR COU RTU¥i ~Ne I!; 10

STUBBLEFIELD PROPERTIES SUPERIOR C OURT 01' CALIFORN IA
COUi'ITV OF SAN BERNARDINO"
RANCHO CUCilMONGA DJSTRIC I
DEFENDANT (S) AND APPELLANT FEB 3 ,U16
QCL'-QL~"'0- V'JD.-n \..e:L.

MARTIN J . JACINTO
.",-;:....
CAS E l\'lJMBER C IVDS1208547

NOTIFICATION OF ESTIMATE OF COST OF TRANSCRIPTS
(8.122(c)(3), 8.130(b)(1), 8.147(a)(2). 8.155, 8.832(a) , 8.834(b)(2)(a)) APPELLATE NO E065006
TO:
RICHARD NA HIGIAN, ESQ. ROBERT G. WILLIAMSON. ESQ .
ATTORNEY F O R APPELLANT ATTORNEY FOR RESPONDENT
You are hereby noti fied, pursuant to th e California Rules of Court, that you r estimated costs to prepare the tran script on appeal in the amount li sted
below are as follows:
[8J An Original and one copy on appeal (If a cross-appeal has been filed, the initial expense of preparin g the record on appeal shall be bo rne
equally by the parties appealing.)
o Augmentation of the record as ordered by the Court of Appeals
DUE DATE: FEBRUARY 13, 2016

(Your notice(s) designating preparation oftl-ansnipts s ha ll not be effe ctive unless com pliance with t hese rules have been met by the due
date.)
CLERK'S TRANSCRIPT:
@ PELLANT - ORIG INAL AND ONE COpy - $ 187.00 - 100.00 paid ~ $87.00 Estimate Du e
IZJ RESPONDENT - (if d esired) - ONE COPY $93.50 Estimate Due
REPORTER'S TRANSCRIPT:
~PELLANT - ORIG INAL AND
l.:/6j..m copy IN $62.00
IZJ PAPER $50.00 Non-refu ndab le Trust Fee - DUE
o COMP UTER-READABLE FORMAT $ 112.00 Estimate Due
IZJ RESPONDENT - (if desired)

ONE COPY IN: $26.00
IZJ PAPER $ 5 0.00 Non-refundable Trust Fee - DUE
o COMPUTER-READABLE FORlVlAT $76.00 Estimate Due
NOTE: Please return a copy of this notice with you r payment to the address listed above.
MAKE nmCK PAY ABLE TO "CLERK OF THE SUPERIOR COURT"
ATTN: CA ROLYN DANIELS
Dated: February 3, 2016

Deputy
N TE OF COSTS OF TRANSCRIPTS
Page 15
Page 16
Page 17
LA JOLLA LAW GROUP
8
August 4,2016
Martin C. Jacinto
3420 Broadmoore Blvd.
San Bernardino, CA 92404
Carolina S. Ramirez
3420 BroadmooreBlvd.
San Bernardino, CA 92404
ATTORNEY/CLIENT
FEE AGREEMENT
Re: M3rtinC. Jacinto v. Rich",rdNabigian;

San Bernardino Superior Court Case No. CIVDS1604759
Dear Mr. Jacinto and Ms. Ramirez:
This letter will confinn La Jolla Law Group's willingness and appreciation for the
opportunity to represent you in this matter, and along with the fee agreement enclosed herewith,
sets forth the terms and conditions which will apply.
Please understand that in order for us to represent you, we will need you to submit a
retainer fee in the amount of $10,000.00. La Jolla Law Group does not accept cases on a pay as
you go basis because we want to avoid any possible conflict of interest with our clients, which
we believe forced bill collectioll, entails. Pursuant to our agreement, the initial deposit of
$5,000.00 towards the total retainer will be provided to La Jolla Law Group today at the time of
executing the enclosed Attorney-Client Fee Agreement, with the remaining $5,000.00 of the total
retainer due within 30 days, i.e., no later than September 3, 2016.
Please make the retainer check payable to:
La Jolla Law Group Trust Account
9404 Genesee Avenue, Suite 300, La Jolla, California 92037

Telephone (858) 202-] 321 • Facsimile (858) 202-1308 Page 18
Martin C. Jacinto
Carolina S. Ramirez
August 4, 2016
Page 2
Enclosed, please find the Attorney - Client Fee Agreement. Please sign and date where
indicated, make a copy for your files, and return the original executed Fee Agreement in the
envelope provided. Should you wish to make the retainer payment via credit card, please contact
our office to provide the necessary information to do so. La Jolla Law Group is under no
obligation to perform legal services prior to receiving an initial retainer and a signed
agreement.
We will perform legal services called for under this Agreement, respond promptly to your
inquiries and communications, and keep you informed of the status of your matter. We
encourage you to keep us apprised of facts pertinent to our representation, return our calls on a
timely basis, and review and comment to us in regard to documents we may periodically send to
you.
Thank you in advance for your anticipated courtesy and cooperation to the foregoing,
Should you have any questions or concerns regarding the above, please do not hesitate to contact
the undersigned at your convenience.
Very truly yours,

LA JOLLA LAW GROUP
KENT L. SHARP, ESQ.
KLS:slr
Enclosure
Page 19
04/03/2017 MON 15:46 FAX r41001
*********************
*** FAX TX REPORT ***
*********************
TRANSMISSION OK
JOB NO. 3400

DESTINATION ADDRESS 19098837327
SUBADDRESS
DESTINATION ID
ST. TIME 04/03 15:44
TX/RX TIME 01' 53
PGS. 6
RESULT OK
LA JOLLA LAW GROUP
9404 Genesee Avenue, Suite 300
La Jol1a, California 92037
Telephone: (858) 202-1321
Facsimile: (858) 202-1308
F'A C S I MIL E
April 3, 2017 No. of Pages (including eover):
Name Phone Number Fax Number
TO: CAROLINA RAMIREZ (909) 883-7327
CC:
FROM: Stacie L. Rammolsberg
RE: Request for Doeuments
Message:
Pursuant to your request, attached to this facsimile cover sheet please find the Fee
Agreement with Richard Nabigian and a summary of the legal fees paid to our office in
2016.
Page 20
3/2/2017 LA JOLLA LAW GROUP
9:12 AM AIR Transaction Listing Page 1
Selection Criteria
NR.Transaction Date 10/1/2013 - 31212017

NR.Transaction Type Payment
NR.Classification, Open
Clie.Selection Include: Jacinto, Martin
'B' for Billed. 'PI for Posted.
10 TypeClient
.......-________
Oate...... Invoice #
;..=;C:..:..;h..;;.ec;:;;.:.k..:....:N:..;;;.u=.;m:..;;.:;::..;be=.;r_--.;.,._ _ _ _ _ _ _~;;,.;;,.;,;.;;.~______=___......__ _ T.:. .;:o: ;. :;ta: ;.1
____<. .........................- - . ._ _
7101 PAY B Jacinto, Martin (1200.00)

8/4/2016 G:14202 1183
Retainer Payment - Thank You. Paid by Lucky Buy Appliances Check No. 1183

8/4/2016 G:14202
Retainer Payment - Thank You. Cash ..

1017/2016 G:14273
Cash Payment - Thank You.

10/7/2016 G:14273 R107515873
Payment - Thank You. Paid by Moneygram Money Order number R107515873113

10/7/2016 G:14273 R107515873
Payment - Thank You. Paid by Moneygram Money Order number R1075158731 02.

12/16/2016 G:14338 284 . .
Payment - Thank You. Paid by KJ Fisher Trust Check No. 284.
Grand Total
Payment. (20000.00)
Page 21
/
1 KENT L. SHARP, ESQ.: SBN179468

Email: kent@IajolIalawgroup.com
2 BRIEN J. O'MEARA, ESQ.: SBN188261
Email: brien@lajollalawgroup.com
3 LA JOLLA LAW GROUP
9404 Genesee Ave., Ste. 300
4 La Jolla, CA 92037
Telephone No.: (858) 202-1321
5 Facsimile No.: (858) 202-1308
6
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF SAN BERNARDINO - SAN BERNARDINO DISTRICT
10 MARTIN C. JACINTO, an individual, CASE NO. CIVDS1604759
11 Plaintiff, NOTICE OF ATTORNEY LIEN BY

0
LA JOLLA LAW GROUP
0
M 12 v.
2
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13 RICHARD NAHIGIAN, an individual; Assigned for all purposes to:
~ v~ ~ ~
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and DOES 1-10, inclusive, Honorable John M. Pacheco
~ ~ ~ g 14 Department S-31
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Defendants.
.....,. v ..
t'd ..:: tI:I r 15 Complaint Filed: April 1, 2016
.....:lc3.....:l Trial Date: None Set
o::T
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17
18
19 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

20 NOTICE IS HEREBY GIVEN THAT LA JOLLA LAW GROUP located at 9404
21 Genesee Avenue, Suite 300, City of San Diego, County of San Diego, State of California, claims
22 a lien for services rendered to PLAINTIFF MARTIN C. JACINTO ("JACINTO") who resides at
23 3420 Broadmoore Boulevard, San Bernardino, California 92404, on any judgment rendered in the
24 case or any settlement proceeds obtained by JACINTO. The instant lien arose in connection with
25 LA JOLLA LAW GROUP'S representation of JACINTO in the matter of Martin C. Jacinto v.
26 Richard Nahigian, San Bernardino County Superior Court Case No. CIVDS1604759. The
27 recovery to which LA JOLLA LAW GROUP'S lien attaches is based on contractual obligations,
28 services rendered, and hard costs incurred in the sum of $12,372.60. To date, JACINTO has
Notice of Attorney Lien by La Jolla Law Group Page 22

1 failed to pay the entire sum owed of $12,372.60 to LA JOLLA LAW GROUP.
2 RESPECTFULLY SlTBMITTED:
3 DATED: August .l-Z- ,2017 LA JOLLA LAW GROUP
BY:~
5
7
i<ENTCSHA YsQ.
8
10 VERIFICATION
11
0
0
C""l 12 I, Kent L. Sharp, am the principal of LA JOLLA LAW GROlTP named above. I have
6~
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8 ~ 0 f'I 13 read the attached notice and am familiar with its contents. At all times relevant to the Notice, I
oQ)f'lC""l
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ro ;> U 0 14 was and have been licensed to practice law in the State of California. To the best of my
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By:
17
KENT L. SHARP, ESQ.
18
19
20
21
22
23
24
25
26
27
28
2
Notice of Attorney Lien by La Jolla Law Group Page 23
Serrano, Suzanne
From: Pacheco, Hon. John

Sent: Monday, June 12, 2017 4:49 PM
To: Serrano, Suzanne
Cc:
Subject:
Pacheco, Hon. John
Jacinto CIVDS1q04759
9
Court's Tentative Ruling:
1. The court will deny Defendant's Opposition
2. The court will GRANT Defendant Richard Nahigian's motion for relief from the default
and default judgment and deem the proposed answer filed and served; and
3. The court will DENY Plaintiff's request for attorney's fees and costs.
1
Page 24
1 SUPERIOR COURT OF CALIFORNIA
2 COUNTY OF SAN BERNARDINO

10
3
5 MARTIN C. JACINTO, )
)
6 Plaintiff, )
vs. ) CASE NO. CIVDS1604759
7 )
RICHARD NAHIGIAN, )
8 )
)
9 Defendant. )
10
REPORTER'S TRANSCRIPT OF ORAL PROCEEDINGS
11
Before Hon. John M. Pacheco, Judge
12
Department S-31
13 San Bernardino, California
14 Tuesday, June 13, 2017
15
APPEARANCES:
16
For the Plaintiff: KENT L. SHARP
17 Attorney at Law
18 For the Defendant: CHRISTOPHER W. P. OVERTON

Attorney at Law
19
For the Claimant: NANCY DUFFY-MCCARRON
20
Reported by: ROCIO GONZALEZ
21 Official Court Reporter
C.S.R. No. 10911
22
23
24
25
26
Page 25
1
1 SAN BERNARDINO, CALIFORNIA; TUESDAY, JUNE 13, 2017
2 A.M. SESSION
3 DEPARTMENT S-31 HON. JOHN M. PACHECO, JUDGE
4 APPEARANCES:
5 The Plaintiff, MARTIN C. JACINTO,
6 represented by counsel, KENT L. SHARP,
7 Attorney at Law; the Defendant,
8 RICHARD NAHIGIAN, represented by
9 counsel, CHRISTOPHER W. P. OVERTON,
10 Attorney at Law; the Claimant,
11 BONNIE SHIPLEY, represented by counsel,
12 NANCY DUFFY MCCARRON, Attorney at Law.
13 (Rocio Gonzalez, Official Reporter, C-10911.)
14 -oOo-
15
16 THE COURT: Number 7 is Jacinto versus Nahigian.
17 MR. SHARP: Good morning, your Honor. Kent Sharp on
18 behalf of Plaintiffs.
19 MR. OVERTON: Good morning, your Honor. Christopher
20 Overton on behalf of Defendants.
21 THE COURT: The Court issued -- oh, I'm sorry.
22 MS. DUFFY MCCARRON: Good morning -- excuse me, sorry.
23 Good morning, your Honor. I'm Nancy Duffy McCarron. I'm
24 representing Bonnie Shipley, the lien claimant in this. And
25 I'm not here for these arguments, your Honor. I am just here
26 because I wanted you to know that we had filed the liens,
ROCIO GONZALEZ, CSR NO. 10911

Page 26
2
1 because you know how papers get lost in the shuffle.
2 I wanted both counsel to know and you to know, and I
3 put a lien against Mr. Williamson's lien because Mr. Williamson
4 who represents Stubblefield put a lien basically saying that if
5 Jacinto recovers money from Nahigian, they want their 200,000
6 judgment against Jacinto. They want you to take that out and
7 pay them. Okay. But we have a judgment against them that's
8 much older. And we also have a lien in the other Jacinto case.
9 So I put a lien against this lien. So in other words,
10 if we get to the point where you ever take any money, if
11 they're successful and you take any money out of Mr. Nahigian
12 to pay Jacinto, and then you're going to decide to pay Jacinto
13 and pay Stubblefield on the prior judgment in the other case,
14 we want our money first out of that. It's about 38,000 right
15 now they still owe.
16 THE COURT: Well, it's good to know you don't have a
17 dog in this fight.
18 MS. DUFFY MCCARRON: I don't but -- except that if
19 there's money we want our 38,000 rather than them get their 200
20 total.
21 THE COURT: Anything else?
22 MS. DUFFY MCCARRON: That's it.
23 THE COURT: Okay.
24 MS. DUFFY MCCARRON: Thank you, your Honor.
25 THE COURT: All right. So counsel wish to be heard on
26 the tentative?

Page 27
3
1 MR. SHARP: Yes, your Honor. I've read the tentative.
2 Couple of clarifications. You're denying the opposition I'm
3 assuming because former counsel was served, not Mr. Overton,
4 who's the current counsel, that's the reason?
5 THE COURT: No. There was opposition and I did take
6 that into consideration.
7 MR. SHARP: Okay. So we filed that on the 31st. We
8 also received a reply. We request that the Court deny this
9 motion. We deny this motion based upon the credibility of
10 Mr. Travis Kaspar. And I cited in my own declaration in the
11 papers regarding the false statements of Mr. Kaspar. And those
12 false statements go to the very issue that is here. And the
13 issue is, why didn't he file an answer timely. That is the
14 issue. The Court is to consider that credibility.
15 Throughout Mr. Kaspar's declaration there are numerous
16 false statements, and false statements that go directly to the
17 very issue of when he allegedly tried to file it and who tried
18 to file it. Specifically, your Honor, I'd just like to go
19 through a couple, probably around ten of the false statements.
20 There's no -- this is not a credible declaration of Mr. Kaspar
21 by any stretch of the imagination.
22 Mr. Kaspar first states in Paragraph 3 of this
23 declaration that he was assisting Mr. Nahigian with his
24 California State Bar. I've actually spoken to the California
25 State Bar, and the California State Bar has inquired with
26 regard to this action against Mr. Nahigian. They have no

Page 28
4
1 record of Mr. Kaspar ever having any contact with the
2 California State Bar. So his statement in Paragraph 3 that he
3 was assisting in the filing of an answer for Mr. Nahigian for
4 the California State Bar complaint is absolutely false.
5 More importantly, he states in his declaration that in
6 October 2016 he was assisting at the time the answer was due,
7 which was on October 3rd, that he was assisting that answer.
8 Mr. Nahigian, not Mr. Kaspar, had already requested an
9 extension of time to file the answer with the California State
10 Bar complaint. That extension was granted on September 28th to
11 October 14th. So there would have been no delay, and that
12 statement by Mr. Kaspar is utterly false.
13 Now, I'm working with the California State Bar because
14 they've asked for our files in this case against Mr. Nahigian.
15 That's why I had that phone call with the California State Bar.
16 Next false statement, Paragraph 4 of Mr. Kaspar's
17 declaration, he requested an extension of time to file an
18 answer. That's on October 3rd. We had supplied all of the
19 e-mails that we have with Mr. Kaspar. And Mr. Kaspar isn't new
20 to this case, by the way. He actually represented Mr. Nahigian
21 earlier. A default was previously entered, and he failed to
22 answer Mr. Lockwood, my former counsel in this case, had those
23 discussions with Mr. Kaspar. When are you going to file an
24 answer? When are you going to file an answer? He never does.
25 He filed as a default. Mr. Kaspar says, I want to go
26 ahead and set aside that default. Mr. Lockwood says, give me

Page 29
5
1 your papers. Let me see what your request is. Why? What's
2 the excuse? He never gives it to him. In fact, when I come
3 into the case in August, Mr. Kaspar asked me to set aside the
4 default. I said, give me your papers. He gives me his papers.
5 We decided to amend the complaint to add a breach of fiduciary
6 duty in the fraud cause of action against Mr. Nahigian.
7 Mr. Kaspar never requested extension of time. There
8 was never rejection of any extension. In fact, even looking at
9 the e-mail on October 3rd, clearly, he's not requesting an
10 extension of time. Another false statement.
11 But now, we're going to get to the exact issue. What
12 is the excuse of Mr. Kaspar not filing an answer? He sets
13 forth in Paragraph 7, he said that Mr. Papadakis is to file an
14 answer on October 14. And then he neglected to send a check,
15 and somehow he assumed it was filed. Well, I actually spoke to
16 Mr. Papadocus. Mr. Papadocus was informed by Mr. Kaspar not to
17 file the answer on October 14th. That's what he tells me on
18 the phone.
19 Moreover, if Mr. Kaspar was -- that was really true,
20 Mr. Kaspar would have filed and he would have served an answer.
21 No answer was ever served in our office. If he really assumed
22 that some answer was filed in court you would expect him,
23 pursuant to the code, to have served us with an answer. No
24 answer was ever served on our office. Another false statement
25 by Mr. Kaspar.
26 Now, never personally served by mail this answer or an

Page 30
6
1 e-mail or any answer at all. There's no evidence that, in
2 fact, the answer was ever attempted to be filed on October 14.
3 We don't have a declaration of Mr. Papadocus. It's clear
4 hearsay. In fact, he was alerted, and we'll get to why that's
5 also false, that Mr. Papadocus actually tried to file an answer
6 October 14, but it was rejected or it wasn't filed because he
7 didn't have a check. There's no declaration of evidence
8 supporting that. If he learned that, Mr. Kaspar had came from
9 Mr. Papadocus, that is clear hearsay. That's lack of
10 foundation.
11 We filed objections to Mr. Kaspar's declaration on
12 that very point, but we don't see a declaration of
13 Mr. Papadocus. And we would expect to see one.
14 Paragraph 8, he says his answer was rejected for lack
15 of filing. Again, no evidence of that. Hearsay. No
16 declaration of Mr. Papadocus.
17 He had never told me, when I finally talked to Mr. --
18 Mr. Kaspar that, in fact, he tried to file it on October 14.
19 That's a false statement. And in fact, we get into Paragraph
20 9, that I never gave him a follow-up communication regarding an
21 answer was due. We were here in court on October 4th, your
22 Honor, in the trial setting conference. He tells the Court,
23 which I provided the transcript from that proceeding, he tells
24 the Court, I'm going to file it right now. I'm going to file
25 it immediately. Fine. We expect that.
26 By that Friday, on October 7th, I'm reminding him,

Page 31
7
1 Mr. Kaspar, where is your answer? Where is your answer? I
2 feel like I'm repeating Mr. Lockwood from six months ago.
3 Where is your answer? I get no response. I say, if we don't
4 have your answer by Monday the 10th, we are going to go ahead
5 and default you. No response at all.
6 I then call him on October 14 to ask him again, where
7 is your answer? I leave a voicemail for him. I get no
8 response on October 14. So his statement that there was no
9 further communication regarding his answer is also false. It's
10 right there in our October 7th e-mail. Clearly, his statements
11 are false.
12 Further, he also says, which is outrageous, that he
13 was never served a copy of the entry of default, a default that
14 was filed and served on October 20th.
15 Paragraph 9 is where he states this, right in that
16 document, not only did we serve Mr. Kaspar, we served
17 Mr. Nahigian, the defendant. We served them both. We served
18 them at 714 West Olympic Boulevard, Suite 450, L.A. That is
19 his address. That's on the State Bar website. That is the
20 address that he has. Clearly, that's another false statement
21 by Mr. Kaspar that he was never provided notice of the entry of
22 default.
23 Now, we're going to get to the real crux of where his
24 lies are.
25 He says that I realize the answer that he attempted to
26 file was rejected on 10/22. Well, who does he learn this from,

Page 32
8
1 10/22? He says he makes a second attempt to file on 10/22 by a
2 process server, which was an online process server. Now, the
3 problem about his online process server, it's another false
4 statement, because he actually says in an e-mail on October
5 7th, and this is the very telling e-mail, which is attached to
6 my declaration, he states on -- excuse me, on November 7th,
7 your Honor, "I just got a message from my process server that
8 the answer he thought was filed was actually rejected due to
9 the default being filed just before he got it in."
10 So his statement in his declaration that he says it
11 was a process server that attempted to file that answer and it
12 was not filed because it was rejected because of a default, is
13 false. Because I asked him in these e-mails, who is your
14 process server? What company is it? He goes, it's a friend.
15 He does the filing. Mr. Papadocus. Not this legal online
16 service. Another telling false statement.
17 This goes to the very false statement that he's
18 claiming he should have relief on. And that is that the entry
19 of default, he tried to file an answer before October 20th, on
20 October 14th, using Mr. Papadocus. We never saw that. We
21 never heard that, ever. In fact, this is the first time in
22 these papers that we ever see that. And we know it's false
23 because the reality is Mr. Papadocus only attempted to file it
24 one time, and that was after the entry of default.
25 THE COURT: So that November 8, 2016, is that where he
26 says he doesn't work for a company, he does filing and odd jobs

Page 33
9
1 for me while he works on his documentary film?
2 MR. SHARP: Correct. That's directly contrary to the
3 statement that he makes in his declaration, that is, I'm using
4 an online process server. Absolutely false on the very issue.
5 And the reason is because Mr. Papadocus never tried to file
6 that answer on October 14th. Mr. Papadocus, as I put in my
7 declaration, I didn't believe him. I didn't believe
8 Mr. Kaspar. I go, I want to talk to your process server
9 (unintelligible). He goes, he gave me the answer to file the
10 14th, doesn't mention anything about payments, nonpayments. He
11 says, he calls me up and says, don't file it.
12 He tells me later to file it on or around 10/25, which
13 is exactly when we see the attempt to file, the notice by the
14 Court this is being rejected because of the entry of default.
15 Clearly, Mr. Papadocus attempted to file it only once. He
16 invents this 10/14 and it's contrary to his actual statements
17 in his declaration. There's absolutely no credibility in this
18 declaration of Mr. Kaspar at all with regard to what his
19 attempts are to file an answer. I've outlined this as much as
20 I can in our opposition.
21 He also says, now we take a look at his ex parte
22 papers. He calls me up in my office two days before
23 Christmas -- three days, 12/22. Mr. Sharp, I'm going to go ex
24 parte to set aside this entry of default. I go, you can't do
25 that ex parte. You've got to file a motion. He goes, oh, I'm
26 going to get a hearing date. I go, get a hearing date. I'm

Page 34
10
1 out but my office is there and I have another attorney. He can
2 go there. We never hear from him.
3 In fact, my secretary sends him an e-mail on December
4 27th, hey, you going ex parte or not? He tells us the court is
5 dark. Of course the court is dark. It should be dark that
6 week. He never goes ex parte. He doesn't do what he actually
7 says. But if we look at his ex parte papers there is no
8 mention, no mention in those ex parte papers that he ever
9 attempted to file that answer on October 14th. In fact, the
10 only time he's ever filed the answer or attempted to was on
11 October 25th.
12 We were here in court on October 4th, your Honor, and
13 you even said, are you going to file an answer? I'll be filing
14 it immediately. Clearly, he had been warned, we had been on
15 him to try to get this answer filed in the court. Now, he
16 wants to come in, what, that was on October 4th, he's almost
17 six months after the entry of default. Yeah, he's within his
18 six months, but the credibility of his declaration is
19 absolutely false. It has no merit.
20 And in fact, in reading even the reply of counsel, we
21 don't see him saying, no, that's a really true statement. And
22 the reason is because it's false. And it's false on the very
23 issue that he wants to say, I should have relief, because I
24 didn't give my file clerk a check to file an answer on October
25 14th. We know that's not true by his own e-mails and by his
26 subsequent declaration in his ex parte notice, your Honor.

Page 35
11
1 So we strongly urge this Court to deny this motion and
2 the credibility related to Mr. Kaspar regarding this actual
3 declaration.
4 I have also submitted the declaration, and this was --
5 excuse me -- requested by the California State Bar as to
6 Mr. Kaspar's declaration related to all this. That has now
7 also been served or sent to the investigator for the California
8 State Bar.
9 Thank you.
10 THE COURT: Thank you.
11 Counsel?
12 MR. OVERTON: Thank you, your Honor.
13 Counsel has just spent about the better part of 10
14 minutes berating Mr. Kaspar. In essence, that really makes our
15 argument for us, because Mr. Kaspar was the problem here.
16 Mr. Kaspar didn't get the answer filed. He was retained to do
17 that and get the case going. And counsel's own opposition
18 brief makes clear that the standard here is not simply saying,
19 well, I disagree with this attorney affidavit at fault, which
20 by the way, is not legally required to state grounds for it.
21 We went beyond what the law requires us to do, but to
22 affirmatively establish that there is no causation by the
23 attorney and that the fault rests indeed with the client
24 himself.
25 He hasn't uttered a word about anything Mr. Nahigian
26 did or didn't do that caused this problem. Mr. Kaspar was the

Page 36
12
1 problem. We can get ourselves lost in details, such as whether
2 or not he's acting as attorney or counselor for the State Bar
3 in preparation of an answer, as opposed to affirmatively
4 representing him in the State Bar action, for example. But I'm
5 not going to jump at shadows here. The bottom line is, this is
6 a very powerful remedy that's reserved for attorney affidavits
7 at fault.
8 Now, if I wanted to get lost in the details, perhaps I
9 might have done another declaration for Mr. Kaspar addressing
10 these things. I was denied that opportunity because ironically
11 enough in this situation the opposition wasn't served on me.
12 It was served on Mr. Kaspar. So the delinquent Mr. Kaspar
13 turned out to be a more reliable source of the opposition for
14 me than the counsel who is railing against him.
15 The bottom line is this: This case deserves to be
16 tried on its merits, and there are meritorious defenses to be
17 asserted. And however much we want to castigate Mr. Kaspar in
18 this situation, both of us are doing it, it doesn't change that
19 fact.
20 So we request that we have the default set aside, the
21 motion granted and be allowed to file an answer and litigate
22 this case.
23 THE COURT: Mr. Sharp?
24 MR. SHARP: Your Honor, the devil is in the detail.
25 They don't want to talk about the detail of Mr. Kaspar's
26 declaration. The case law is very clear, when counsel starts

Page 37
13
1 submitting declarations that are not credible based upon proven
2 false testimony, the Court can disregard that declaration. And
3 that's exactly what we're requesting this Court to do.
4 Mr. Kaspar has shown in his own e-mails, in his own ex parte
5 declaration, that, in fact, his declaration is false, and false
6 to a very high level. We're talking about declarations to this
7 Court. There's not a question why it's false.
8 He had actually -- we can show that his declaration, I
9 tried to file an answer, that is utterly false. And without
10 that one little area, Mr. Kaspar has no neglect. He just does
11 not do. In fact, my statement and my declaration, where I'm
12 actually talking to Mr. Papadocus, he tells him not to file the
13 answer. And I asked him why? And he says, I don't know why.
14 THE COURT: Anything else?
15 MR. OVERTON: No, I'll submit on this.
16 THE COURT: All right. I'll take the matter under
17 consideration, give you a more thorough ruling. Appreciate the
18 arguments, Counsel.
19 MR. SHARP: Thank you, your Honor.
20 MR. OVERTON: Thank you, your Honor.
21 (End of proceedings.)
22
23
24
25
26

Page 38
1 SUPERIOR COURT OF CALIFORNIA
3 DEPARTMENT S-31 HON. JOHN M. PACHECO, JUDGE
5 MARTIN C. JACINTO, )
)
6 Plaintiff, )
vs. ) CASE NO. CIVDS1604759
7 )
RICHARD NAHIGIAN, )
8 )
) REPORTER'S
9 Defendant. ) CERTIFICATE
10
STATE OF CALIFORNIA )
11 ) ss.
COUNTY OF SAN BERNARDINO )
12
13 I, ROCIO GONZALEZ, Official Reporter of the Superior
14 Court of California, County of San Bernardino, do hereby
15 certify that the foregoing pages, 1 through 13, to the best of
16 my knowledge and belief, comprise a full, true and correct
17 computer-aided transcript of the proceedings taken in the
18 matter of the above-mentioned cause held on Tuesday, June 13,
19 2017.
20 Dated this 20th day of November, 2017.
21
22 ___________________________________
Official Reporter, C.S.R. No. 10911
23
24
25
26
Page 39
•
Christopher W. P. Overton (SBN 196823)
Law Office of Christopher W. P. Overton
•,,".lfA~'J.~~ED
- 2 84 N. Wilson Ave., #106
Pasadena, CA 91106
SAN BERNARDINO DISTRICT
JUN 1 4 2017
3 Tel (213 ) 926-1119
"
4 Attorneys for Defendant, RICHARD NAHIGIAN BY ~",~Ld
SUZAN SEM. AND, DEPUTY
5

8
9 MARTIN C. JACINTO, CASE NO. CIVDS 1604759

10 Plaintiff,
~ ORDER GRANTING
11 vs. RICHARD NAHlGIAN'S MOTION FOR
RELIEF FROM DEFAULT JUDGMENT &
12 RICHARD NAHIGlAN, QUASHJNG ABSTRACT OF JUDGMENT
13 Defendant. Date: June ]3, 2017
Time: 8:30 p.m.
14 Dept: S31
15 Action Filed: April 1,2016
16
17
18
19 The Court, having considered the briefs, evidence and arguments submitted by the
20 parties, rules as follows :
21 1) The motion is granted;
22 2) The judgment against Richard Nahigian, in favor of Martin C. Jacinto, which.was ·
23 entered in the above entitled action on or about January 6, 2017, is vacated;
24 3) All abstracts of judgment based upon that judgment, including but not necessarily
25 limited to those issued on January 6, 2017 and February 6, 2017, are ordered
26 expunged and stricken;
27 4) Defendant Richard Nahigian is granted relief from default;
28 11
ORDER GRANTING RELIEF FROM DEFAULT JUDGMENT
Page 40
I
•
1
• •
5) The court shall deem the proposed Answer to Complaint lodged by Richard
2 Nahigian on or about May 16, 2017 to be as filed as of this date;
3 6) The court shall deem the proposed Cross-Complaint lodged by Richard Nahigian
4 on or about May 16, 2017 to be as filed as of this date;
5 7)
6
7
8
9
10
11 9.
12
13
14
15
16
17
18
19
20
21
22
23 . . ..:. --'4-...........,~~-----------------------
- ~. . ) ,
24 . ,' ,I 'I ',
25
26
Hon. John M. Pacheco,
- ""27- Judge of the Superior Court
ORDER GRANTING RELIEF FROM DEFAULT JUDGMENT

Page 41
"
THE DOCUMENT TO WHICH THIS CERTIFICATION

IS ATIACHED, CONSISTING OF Z. PAGE(S), IS A
FULL, TRUE AND CORRECT COPYOF THE ORIGINAL
ON FILE AND OF RECORD IN MYOFFICE.
ATIEST NANCY CS EBERHARDT
Clerk of the Superior Court of the State of Califomia,
in and for the County of San Bernardino.
NOV 032017
Date ~
B~DePUty
Met LtClncl~
Page 42
DAVIS & DAVIS LAW GROUP, APe
12
ATTORNEYS AT LAW
1900 AVENUE OF THE STARS. SUITe 960
M. STEPHEN DAYIS Tel: (310) 277-2323
MArrHEW S. DAYIS LOS ANGELES. CALIFORNIA 90067 fax: (310) 556-2308
OF COUNSEL MILTON DAVIS

JOHN D. WILSON 11907-19881
Writer's E·Mall:
dlalOddesq.cam
November 9, 2017
VIA GSO OVERNIGHT
Nancy Duffy McCarron

950 Roble Lane
Santa Barbara, CA 93103
Re: Jacinto v Nahigian; SBSC Case No. CIVDS1604759

Deposition Subpoena for Production ofBusiness Records
Dear Deposition Officer:
In satisfaction of the Deposition Subpoena for Production ofBusiness Records issued October 6,
2017, enclosed are the documents requested, per agreement of counsel, regarding American Trust
Escrow File No. 021030-SA identified by Bates Numbers 00001 to ATE 00006, together with a
Declaration of Custodian of Records.
If you should have any questions in regards to the above, please do not hesitate to contact me.
Very truly yours,
DAVIS & DAVIS LAW GROUP,APC
D~
MSD:sr
Enclosures
c: American Trust Escrow
Page 43
I 1
5
6
7
9 COUNTY OF SAN BERNARDINO - mSTICE CENTER
10
11 MARTIN JACINTO, CASE NO. CIVDS1604759
12 Plaintiff, DECLARATION OF CUSTODIAN
13 v. OF RECORDS OF AMERICAN
TRUST ESCROW, INC. PURSUANT
14 RICHARD NAHIGIAN, TO CALIFORNIA EVIDENCE CODE
Defendant. SECTIONS 1560-1561
15
16
17 I, CONNIE SCIDRTZ, declare:
18 I am an employee ofAmerican Trust Escrow, Inc. and a duly authori;z:ed Custodian
19 ofthe records ofAmerican Trust Escrow, Inc., a California corporation. I have authority
20 to certify said records.
21 I received a Deposition Subpoena for Production ofBusiness Records, issued on
22 October 6,2017, out ofthe above-entitled Court in the above-entitled action calling for the
23 escrow file and documents therein of Escrow No. 021030-SA.
24 The acconlpanying copies are true copies ·of the records described in said subpoena
25 that are in my possession as Custodian of Records of American Trust Escrow, Inc., as
26 limited in scope by agreement of counsel. Said records were prepared by persoIUlel of

27 American Trust Escrow, Inc. and other persons acting under the control of said persoIUlel
28
1
DECLARA TION OF CUSTODIAN OF RECORDS OF AMERICAN TRUST ESCROW, INC. PURSUANT
TO CALIFORNIA EVIDENCE CODE SECTIONS 1560-1561
Page 44
I
~
1
in the ordinary course of business at or near the time ofthe acts, conditions or events
j
~
2
recorded therein.
I 3
Exec~ted on November ~ 20.17.
5 I declare under penalty of perjury under the laws of the State of California that the
4
'j»
5
foregoing is true and correct.
6
10
11
12
13
14
I<
15
16
17
18
19
I
20
I
~
21
22
I
23
24
It

25
26
27
28
i
2
J DECLARATION OF CUSTODIAN OF RECORDS OF AMERICAN TRUST ESCROW, INC. PURSUANT
!I
!
TO CAUFORNIA EVIDENCE CODE SECfIONS 1560-1561
tI
Page 45
I
1662 Hlllhurti Avenue
AMLHICl~N L~ Angele., CA 90027
! i ! >'
Phone: (3U) 671,,2255
Fax: (323) 328.1790
SELLER'S FINAL SETTLEMENT ,STATEMENT

PROPERTY: 2656 Aberdeen Avenue DATE~ August 8.2017
los Angeles. CA 90021
CLOSING DATE; A~U&t8, 2017
SELLER; Richard Nahigian and Eileen Nahigian ESCROW NO.: 021030-SA
DEBITS CREQtTS
FINANCIAL CONSIDERATION
Totsl COt'ltIlderation 4,865.0®.0()
~Gfedit Buyer Closing eo.~ 8,000.00
PAYOFF CHARGES· Chase (1St Payoff)
[Totat Payoff $2,632.041."1
PrincipaJ Balance , 2,526,080.21
Interest on Principal Bahit1Qe at $142.0900lday trom03l011201~ to 61.501,94
0810712017
Interest on Principal Balancest $14.2.0900Iday from 0010712011 if) 284.18
0810812017
Recor:ding Fee 36,00
Escrow Advance Balaime 45,604.77
Suspense -2.027.71
Late Cttarges 562.60
PAYOFf CHARGES "MandarichlaYi Group-LtC
[Tota'Payoffl',11t..a$l
PrlncfpalBalarlee 9,060.14
IntefestonPrinclpaJ Balance at $1.58001dayfrom 0110112011 to 08I00I2'011 5:.t72
PAYOFFCHARGES-Intemal Revenue Service
[Total Payoff $"8~m.10]
TOTAL BALANCE DUE THRQUGH 81B12017
PAYOFF CHARGES .. Franch'" Tax Soard
rrotaIPayoff $97.812.83]
TOTAl AMOUNT DUE GOOD THROUGH 9/1512017 91.•852.53
PRORAll0N8IADJUSTYENTS
Property Taxes at $ 14,488,86t"m1.,.nnually fmrn.07/0112017 to 0810812017 2,978.27
Property Taxes at$6,499.84IsemkmnuaUy fr<m'107l01/2017 to 08lO8I2017 1,336.08
COMMISSION CHARGES
Safhebys.fntemational Reafty 121,625.00
Sothebys Intematlonal Realty ;"21,625.00
OTHER DEBITS/CREDITS
PrDP8rty 10 for Natural Hazan1iOlsQlosures 114.00
American Trust Escrow for Reimbursement for Upfront 98 report 142.96
Los Angeles Department ofW8ter>&nd Power'forFiUng Water Certificate of 15.00
Compliance
Title ~ American Trust Escrow Reimbursement forCourier/Overnight Handling 25.00
BetviceFee
8IueCJoud Exterminators for Rell'OfittinO Work. 1,510.00
Ftd_ity Natlona1 Home Warra~ for Home Warranty PolICy 265.00
Fidelity National Home WarramyfotHome Warranty Policy 185:00
Af~Opatk-Oemp$eyfor NoIaiY: Fee *mnt 30.00
TITt.ElTAXES/RECORDING C:HARGES - EquIV mle Company
TIfe - Owners TItle Po1lcy . . 5,&16.00
TiUer-lnspection Fee 121.00
T.itfe- Original Overnight Mail 12.:&0
Tilfe,. Sub Escrow Fee 62.50
TItte-WJre Fee 2$."00
Raeording IRS 6 $19;00 EACH 114.00
Recording S1eteot Califomlae~o $19.CJOE.ACH 95:~
Reeordlng.SEdisfaction 22.00
Documentary TransferTax 5,351.50
CIlYTr~tT. 21,892,_
U,..CUre<t.Taxe& Item· 05/40102828 2,19~;;56
unsecured Taxe.$1t$mO.6l40255830 2,200.11
Unsectired Ta~$_ 05140350417 156.49
ESCRDWOKARGIS .. American Trultl.cfOw
rifle • EeerowFee 6..065.00
Titte ~. t::»cument Preparation Fee 500.00
NetProCHR 1.146..336.99
TOTAL $ 4.865.000.00 $ 4~B&5,OOO,OO
:SAVETHIS STATEMENT FOttlNCOME TAX PURPOSeS
ATE 00001 Page 46

Closing Dis.closure
Dosing Information Transaction Information
Date Issued 8/4/2017 Borrowet
OOsingDate 8/6/2017
OJsburse.rnent Date 8/B/2017

Settlement Agent AmericanT rust Escrow Se'ler Rith.atd Nahigl.~n
Eileen Nahlgian
file" 021030~SA 26Sf) Abe(deen Avenue
LOS Angeles, CA9QD27
Property 2656 Atlerdeen Avenue
. ~osAngeles~ CA. 90027
Sate Price $4,865,000
Address j 1801 N. HUlhurst Avenue
;los Angeles, CA 90027
SEllER'S TRANSACTION
CA License 10
.. .. "'...., .... .......
~ ;."
.00899496
Contact
Con!!~!~.lkense 10
Emait
to
American 1 rusthcfOW
I.....
11662 Hillhurst Avenue
_·_l~8!~~~::,.g~.~~!.~ . . ~
"'i~~:::36 ~~i
CA liCenSe ID
Contact Alison
"~_'~"""A" ."",,,,,,,.,--, ~, .. """""""~~",~~,~,,,,,
$!:!!~~t,.~. .~~!!~e 10
Email
Phone
QueItIonsllfyou have questions about the

loan terms orCQStio»&nis.fQm\ usethft(Onta(t
InformatiC)ftoeloW.TOgIt~""oWnati'Qn
ormafce.:acomplalnt, contact the Consumer
f i nJnClII Protect1on Bur.....t
www.consumefftnence.goyl.....p-dOflng
CLOSING DISCLOSURE PAGE 1 of2
ATE 00002 Page 47

Closing Cost Details
OS
06
07
08
00
07
08
01 ritle - Docoment~repar~tiOOFee to Americ:an TrustEscrow

02 ntle£Sfro\\iF~w ... to A~iC~.I1JrW'~ EScrow
03 Title II1Sf)e!:;tlo,!Fee .
'W to Equity Titfe~mpaoy
Title - Sub Escrow Fee toE~ity Title Company
Titl~. - WireF~ tofquity Titl~ Company
01 Filinll WiJter·cer;tifi(;atef;lf{:omplian~~~_~. " and:J>ower

02 H~me""a!ran~y t~~"t:Pr~t~~"__,
03 Natural HalaFd ,Disclosures to
04 Real Estate ComfriiSSioflto_~~l:)y'~~I!~~r~t~~(JI~1!Y .•.
05 Real"E$tatf;!(:o'!lmi~sl?!1_ ........ __wto~!~~Y::sl~~~J!~~~BajReCJity
OO~~I'r'il:>IJ~~lI!~~,!or COurier/~!1!i~~t~i\tflCUi~~ lO Jjt~.=i\~ef1~!l Trust Escrewy
Reim~I:I(~~~~forlJpfront ~a l'erwft.w to American Trust Escrow
Ret~()fj~fl~~f)!k' ~() rJflJ.e CIC>lfC.l~t.erminat()rs
09 Title,~,g~~.!i~~~olicy to, E9:~ity n~I.E?~~pany
l0Ir~~I!"" N~j)ryService to Title - niltdPS,I!:lyNotary
11 _J.l~~lJ~(j.!a.~sl~em.#6 to~~;ItYn!:!i~~)' .
1.2 .JJtt~~~!~'Ta~sltemll7 .t!J ~tltty
Tit~~~mpany
13 Un~uredTaxes Item #.8 to Squav Title Company
CLOSING DISCLOSURE PAGE 2 of2
ATE 00003 Page 48

DocuSign Envelope 10: 7DA1ADF3-EC7C-445Q..833C~6A21MB7A8C1
1662 Hillhurst Avenue

Los Angeles, CA 90027
Phone: (323) 611 ~2255

Fax: (323) 328...1 790
Susan Opalk and Alison Opalk Date: July 11.2017
Escrow OffiCers Escrow No.: 021030..SA
Property Address: 2658 Aberdeen Avenue, Los Angeles, CA90027
INSTRUCTIONS TO PAY COMMISSION

REVISBD(J111f/2017
At the clof;e of your above..numnered escrow.~ou are authori%eda~ lnltructed topsy the following:
Pay Commission to Sothebtslntemational R,eslty $121.625.00
1801 N: Hillhurst Avenue
Los Ang"es, CA ;90027
Agent .Konstantine Valisssrskos
Charles Clad<
Pay Commission to Sothebyts IntemafionalRealty $121,625,00
1801 ~.Hitlhurst Avenue
Los Angetes,CA 90027
Agent: PatriCia Ruben
TOTAL COMMt.SSION $243,250.00
This instruction irrevocabtyusignsthe above slatedeommission toJ"e'sbove named Broker(.}. This instruction may not
be amended or revoked without the written consent of the Broker(~ bereinabove ,named.
Escrow Holder will notbeabla to Issueanycommlsalonchecks. _maul proof of a valid CA

. Bureau of Real Estahncanse.
SELLERS:
Richard Nahigian
Eileen Nahig:lan
SothEl"~~_tipnat Realty sothebY'~aI: Realty

~ bt""~'P By; ~~
~JJ!4&"'AuthoriZed Signature
Ucense # 00899496 U~#~.~~ •

'.~,9~~·~.~~ ____~~______
~~~----------~-----
ATE 00004
Page 49
A MeR I C,--,,'..,
...... AN
,~.~"-.--~ '~--""""'-----'""
CHECKko:
1fS..160611220
'086136
trust eSCROW
PAY
TO THE
'ORDER GF Sotheby's In"!maU"lat
HiUhU~~~~~i~e
1801 N,
los AngelesrCA 90027
DATE: August 8, 2017 ESCROWNQ,c(.121nS0..sA CHECKNO~ 086136

OFFICER: Susan Opalkand Alison OP~lk .A,MOUNt$** 1Ic21.980,43
Property: 2656 Aberdeen Avenu~~ L()$Anseles~ CA 90027
Saller: Richam Nahigian and. Eileen Nahigian
Agent: KonstanUne Valissarak

Commission 121,625·00.
Konstantine vanssarakos ~511384~27
LL Caddis. Inc, -48,.260.30
$otbeby'stntemstionat Realty
180'1 N. Hitlhurst AvenUe
086136
DATE: August 8, 2017
PAY TWENTY-ONE THOUSAND NINE HUNDREOEIGHTYANO 431100 :OOLLARS _____,...~ ____.._____-;.._4 _____;....._.
TO THE
ORDER OF Sotheby'stnt~roationaJ Realty
180'1 N. HlUhu(stAvenue
Los Angeles. CA90027
Issued By: Alison Opafk

FILE COpy
ATE 00005
Page 50
THiS CHECK IS PR/f.,lfED ON CHEMIt.Al R[ACT!VE PAPER WHICH CONIA1NS A WATEHMARK HOLD UF TO {\ liGHT 10 vIEW
AM e R leAN ,CHECK NO: ':08613S

16-160611220
trust ESCROW
TO THE
OROEROF
1801 N. HUIA~it..~rntie
10 Vm!FY THE AUTtIl:riTIClTV OF THIS CHE CK RUS on BREATHE ON fHE OVAl, COLOR Will DlSAPf'EAR, lHE~, HEi\PPEAH
DATE: August 8. 2017 ESCROW NO.021030-SA CHECK NO, 086139

OFFICER: Susan 0pantsnd Alison Opalk '; AMOUNT' $.... ·18~5a.46
Property: 2656 Aberdeen Avenue. LC1S Angetei. CAOO027
Seller: Richard' Nahigian and Eiteen Nahigian
Agent PatrielE. Ruben

Commls,$fon t21~6Z5,OO
Patricia Ruben -102,768.54
Sotheby's International Realty
1801 N. HiUhurst Avenue
lQs AngelesJ CA 90027
CHECK NO:
ATE
086139
1-0$ ~1~ Couruy
eSCROW NO. 021030"SA DATE: Augll$t8, 2017
PAY EIGHTEEN THOUSAND EIGHT HUNORED FIFTY-SIX ANO 46/100 OOLLARS -'~-~-.,,.---.------------~--,.-.......
TO THE
ORDER OF Sotheby's Internatiomrl·Rea1ty
1801 N. HiUhuf$t Avenue
los Angeles CA9QQ27
1
Issued By: Alison Opalk

FILE COpy
ATE 00006 Page 51

INDEX of KEY DOCUMENTS Stubblefield v. Martin Jacinto CIVDS1208547 Removal COSTS related to: Martin Jacinto v. Richard Nahigian SBSC Case: CIVDS1604759
REMOVAL
Item Exh PAGES DATE DOCUMENT COSTS
GRAND TOTAL COMMENTS COMMENTS
alleged Jacinto paid rent 6/1/11-12/1/11 ( 7 mo); 1/12/12
Stubblefield's Complaint 3 TORT claims: served 3-day notice to pay/perform or quit; and served 60-
1 A 1-8 8/16/2012 Ejectment; Nuisance; and Trespass; named
Martin Jacinto (husband) only
Space 120
13 day notice to terminate possession; plaintiff did not allege
attorney fees as damages; plaintiff did not pray for fees; no
MRL allegations
asserts D stopped pymts Dec 2011; damaged home; 2-3
2 B 9-15 3/6/2013 Case Management Statement Justis Britt
days trial estimate; M&C w/Jacinto (not true)
3 C 17-21 4/17/2013 Parrish ltr to Jacinto--removal of home to Jacinto mailed to Jacinto's home address in SanBernardino
Docket shows no answer to Jacinto's cross- cross-complaint discrimination state law:Civil 51 Govt
4 D 22- 3/12/2014 trial set 3/12/14
complaint was filed; no "at issue" 12955;42 USC 1981,1985(3),3604(a);3605
Williamson never issued a partial satisfaction for the

Jacinto ordered to remove home; **costs to verified costs to remove the mobilehome despite being
Court directed verdict on liability and $41,166.58 judgmt
5 E 23-24 4/8/2014 remove shall be credit to partial satisfaction provided with copies of removal costs; no attorney who
dismissed Jacinto's cross-complaint entered on 4/8/14
of judgment represented Jacinto ever showed Jacintos a copy of the
judgment or explained removal costs were to be credited
6 F 25-30 5/8/2014 Notice of Entry Judgment 4/8/14 served to attorney Mosies Avila
Eva Stubblefield Hazard sent 4/17/13
Williamson encouraged Eva Stubblefield to
7 G 31- 5/14/2014 removal letter directly to Jacinto at his home -
talk to Jacinto (circumventing Avila)
not sent to his attorney Avila
Jacinto fired atty Avila; copy sent to Robert
$57,888.50 jgmt Aware Jacinto fired Avila on 5/20/14
Williamson with attached notice authorizing
8 H 32-33 5/20/2014 abstract recorded San Williamson served/mailed Costs memo to
Bruno Ehlert to "work with Williamson" to
Bernardino Cty Avila - knowing Jacinto had fired him
settle judgment
Fraudulent Costs Memo includes items
p.34: $1,484 copies; p.39: $3,115.95 pvt investigator; p.39:
Williamson filed fraudulent Costs Memo expressly excluded under CCP 1033.5 (b) and
$16,721.92 "costs" $3,497 online legal research; $320 court call; $1,277.93
including several line items expressly Ladas case as not recoverable; Williams v.
9 I 34-41 5/20/2014 added to $41,166.58 delivery svs; $509.32 travel; $85 fed ex; P served memo to
excluded under the costs statute. see CCP Chino Firt Dept (Christianson) precludes
jgmt atty Avila, despite knowing Jacinto fired Avila; Avila never
§1033.5(b) awarding costs or fees to Def. unless finding of
told Martin Jacinto he could challenge costs
frivolous
paid $5k deposit to demanded $5,000 deposit to start work Eva suggested that Jacinto "work through your atty"; Eva
10 J 42-43 5/23/2014 Eva sent letter directly to Jacinto home
remove home @ 120 (included in 11K below) knew Jacinto was not represented by atty
Civil §798.85 (MRL); Govt §12965(b) served motion on atty Avila despite knowing Jacinto fired
Motion-$190,449 atty fees p. 49; Williamson
11 K 44-52 7/3/2014 (discrimination); 42 USC §1981; Avila, who never notified Jacinto about the motion or ever
set hearing 11/19/14
§1985(3);§3604(a);§3505 federal disc mailed it to Jacinto
Signed $19,850 new contract to remove 4 contractors showed up to bid from May
home; Pacific returned $5,000 deposit check 2014 to Oct 2014; after each prospective
12 L 53-54 8/11/2014 paid Pacific $5,000 check was returned to Jacinto uncashed
as he could not work with CEO Thomas contrctor met w/CEO Tom Parrish they told
Parrish Jacinto they refuse to work w/Tom
Def agreed to pay
Fee Agreement-Richard Nahigian $10,000 p.59 cashier's check for $15,000 plus paid $10,000 cash on 9/30/14 as Nahigian would not sign
Nahigian $25K cash
13 M 55-59 9/11/2014 cash deposit; $25,000 retainer to oppose atty $25,000.00 Nahigian's note in red acknowledging Jacinto substitution of atty without partial payment; see Item 13
retainer to oppose
motion and negotiated removal of home had paid $10,000 cash initial deposit "M" p.59 $15,000 cashier chk 11/12/14
fees/costs
14 N 60-61 9/30/2014 Substitution of Atty - Nahigian paid Nahigian 2-pymt 3,000.00 would not sign substitution w/out pay paid $28,000 total to Nahigian to negotiate settlemt
Minute Order Granting Motion to amend amended judgment
Minute Order recited Richard Nahigian was
15 O 62-64 10/1/2014 judgment to add $16,721.92 fraudulent costs $57,888.50 - applied for
present during the hearing
to $41,166.58 jdgmt abstract that day
16 P 65-75 10/14/2014 $11,000 removal punch list-storage paid Hart/King $11,000.00 $11,000.00 work on punch list; storage, etc. RGW 8/11/17 aff.¶6:1-9 (5K dep;6K rent 4/1-oct-2014)
paid Palma Const. $2,500.00 $2,500.00 down pymt on contract to remove home see p. 71 paid Palma $2,500 deposit 10/14/14
despite just receiving $11,000 check from Jacinto and
1 Q 76- 10/17/2014 Order to Appear for Examination to Martin Jacinto Williamson applied for order 10/15/17
Nahigian purportedly working to settle the case
2 R 77- 11/8/2014 Nahigian settlement offer to P $53,000 lump sum
3 S 78- 11/8/2014 $57,888.50 Abstract Jgmt recorded Page
recorded abstract despite lump sum settlement offer 52
Williamson appeard by phone; asked for
4 T 79- 11/13/2014 Debtor Jacinto appeared for exam no appearance by Nahigian
continuance; crt continued to 11/19/14
Williamson "advised court parties are trying to
5 U 80- 11/19/2014 2nd Appearance by debtor Jacinto no appearance by Nahigian
settle" continue to 12/17/14
6 V 81- 11/19/2014 Motion for $190,449 atty fees continued to 12/17/14 no appearance by Nahigian
$4k progress pymt to
7 W 82- 11/23/2014 Palma Construction Invoice $4,000.00 $4,000.00 partial payment to Palma Construction
Palma Construct.
8 X 83- 11/24/2014 Jacinto Mot-be relieved as counsel off-calendar subsitution of attorney filed 10/9/14 Nahigian filed substitution of attorney 10/9/14
paid Palma $15K total
9 Y 84- 12/15/2014 Palma Construction Invoice for removal $8,500.00 $8,500.00 final removal costs to Palma 15K Palma Construction Removal Total $15,000.00
($2.5K+$4K+$8.5K)
10 Z 85- 12/17/2014 3rd Appearance by debtor Jacinto continued by Williamson by court call
11 AA 86- 12/17/2014 Continued Motion for Atty Fees continued by Williamson by court call
paid MTZ Creative Demolish wall and haul away existing concrete
12 BB 87- 12/30/2014 Contract-demolition and haul away $3,400.00 $3,400.00 MTZ Concrete Removal Cost $3,400
Concrete, inc. with pregrade after
13 CC 88-89 1/7/2015 email to Nahigian re: punch list
14 DD 90-91 2/4/2015 email to Williamson 4 contractors setl offer: 5K+15K fees+65K +45K+25K
in fed ct 2/18/15; please postpone hearings on
email: re: 2/17/15 mtg set up w/Tom Parrish
15 EE 92- 2/17/2015 atty fees and Jacinto debtor exam both set for
re:punch list to do
2/18/15
16 FF 93- 2/18/2015 court grants 190,499 atty fees no opposition; no appearance
atty must file affidavit Nahigian told Jacinto no need to appear because he would
17 GG 94-95 2/18/2015 4th hearing Jacinto debtor exam bench warrant issued for Jacinto arrest
w/sheriff to arrest appear and get a 4th continuance
18 HH 96-97 2/24/2015 Jacinto filed permit at HCD Department $196.00 $196.00 determine conformance w/codes $196 Permit Fee to HCD inspector
19 II 98- 2/25/2015 MTZ Creative Concrete Invoice paid MTZ Concrete $2,250.00 $2,250.00 concrete work demand by Tom Parrish $2,500 compact dirt w/tractor & water every ft at fill
20 JJ 99-102 2/25/2015 Fee Award $190, 499.00 recorded abstract of judgment
Jacinto debtor exam; testified; ordered to
21 KK 103- 2/27/2015
return on 3/19/15
22 LL 104- 3/9/2015 HCD inspected utility pedestal found no code violaitons; approved
M Jacinto debtor exam; testified; ordered to
23 105- 3/19/2015
M return on 4/16/15
24 NN 106- 4/16/2015 Jacinto debtor exam; off calendar by request of moving party
Jacinto believed Nahigian had settled with his "long-time
Jacintos paid $15K cash to atty Robert
setl offer:$5K+$15k fees;$65K in 27 friend" Williamson to accept cash settlement; Jacinto
25 OO 107-108 5/21/2015 Williamson, Jr. and took hard $ loan to pay
days;$45K in 27 days;25K @ $450/mo thought paying 15K fees+45K fees+25Kfees was accepted
$63,106.40 to satisfy 1st judgment
by Williamson to settle the case
paid to: Robert Nahigian told Jacinto's they were paying a fee to
26 PP 109- 6/2/2015 $12K+$3K cash: Robert Williamson, Jr. $15,000.00 $15,000.00 2 checks to: RGW, Jr ($12K+$3K)
Williamson, Jr. Williamson for "privilege to negotiate settlemt"
$41,166.58 jgmt + Nahigian did not require Williamson to provide an
Demand: $57,888.50+$5,202.04+15.86
27 QQ 110- 8/25/2015 $16,721.92 costs + no acknowledgement of judgmt provided acknowledgement of full satisfaction of judgment which is
($5,217.90 interest)+jdmt= $63,106.40
$5,217.90 interest standard procedure at an escrow closing
Nahigian never sought credit for removal costs despite that
28 RR 111- 8/26/2015 Belle Vista Escrow paid $63,106.40 paid Stubblefield $63,106.40 no credits for removal costs deducted
4/8/14 judgment expressly ordered it
1.4 yrs later ackknowledgment demand is Williamson sent unnotarized acknowledgment not
29 SS 112- 11/22/2016 Kent Sharp demands acknowledgment
finally served on Williamson complying with duty to notarize his signature
30 TT 113- 12/7/2016 Unnotarized acknowledgements sent Atty forced to request notarized docs Williamson receives ltr and resends new docs
atty sent to D&B Williamson resent notarized docs to Kent
31 UU 114- 1/9/2017 Notarized Acknowledgments re-sent No credit was ever issued for removal costs
escrow company Sharp; trying to retrieve acknowl.
32 hired Chris Lockwood to sue Nahigian retainer paid Apr '16 $5,000 had to hire Chris Lockwood sue Nahigian to recover damages
33 VV 115- 3/2/2017 hired Kent Sharp to work on 2 cases Paid to Kent Sharp $20,000.00 invoices to end of 2016 - invoice 3/27/17 paid Kent Sharp to prosecute default judgment
34 Total Removal Cost► $46,846.00 $162,952.40 ◄ Sub-total Post-Litigation Costs no credit despite order to issue credit 4/8/14
35 minus $ Williamson -$15,000.00 ADDED Costs Pre-Litigation Costs Mobilehome @ 120
36 $31,846.00 $11,000.00 purchase mobilehome approx April 2011
$10,000 remodel costs recommended by Tom
37 $10,000.00
Parrish and Mgr Marvin Freeman
38 $7,000.00 rent paid from June 2011-Dec 2011
39 $28,000.00 Sub-total Pre-Litigation Costs
40 $190,952.40 ◄GRAND TOTAL ALL COSTS ◄ doesn't include 12% interest on 2015 hard $ loanPage 53
Williams v. Chino Valley Indep. Fire Dist., S213100 (Cal. May 04, 2015)
SUPREME COURT OF CALIFORNIA
Williams v. Chino Valley Indep. Fire Dist.

S213100 (Cal. May 04, 2015)
Cal. Gov. Code, § 12900 et seq.) The trial court granted

summary judgment for the District and, in a separate
SUPREME COURT OF CALIFORNIA order, awarded the District its court costs. Williams
appealed from the latter order, contending that in the
S213100 absence of a finding his action was frivolous, unrea-
sonable or groundless, defendant should not have
05-04-2015
been awarded its costs.
LORING WINN WILLIAMS, Plaintiff and The issues presented are these: Is a defendant prevail-
Appellant, v. CHINO VALLEY ing in a FEHA action entitled to its ordinary court
INDEPENDENT FIRE DISTRICT, costs as a matter of right pursuant to Code of Civil
Defendant and Respondent.
Procedure section 1032, or only in the discretion of
the trial court pursuant to Government Code section
Counsel: Loring Winn Williams, in pro. per.; Hamil-
12965, a provision of FEHA itself? And, if the trial
ton & McInnis, Donald E. McInnis, Ben-Thomas
court does have discretion, must that discretion be ex-
Hamilton; The deRubertis Law Firm, David M. deRu-
ercised according to the rule *2 applicable to attorney
bertis, Helen U. Kim; Pine & Pine and Norman Pine
fee awards in certain federal civil rights actions under
for Plaintiff and Appellant. Liebert Cassidy Whit-
Christiansburg Garment Co. v. EEOC (1978) 434 U.S. 412
more, Peter J. Brown and Judith S. Islas for Defendant
(Christiansburg), according to which a prevailing de-
and Respondent. Kira L. Klatchko for League of Cali-
fornia Cities, California Association of Counties, Cal- fendant receives its attorney fees only if the plaintiff's
ifornia Special Districts Association, California Asso- action was objectively groundless?
ciation of Sanitation Agencies, Fire Districts Associa-
We conclude Government Code section 12965, sub-
tion of California and Association of California Water
division (b), governs cost awards in FEHA actions, al-
Agencies as Amici Curiae on behalf of Defendant and
lowing trial courts discretion in awards of both attor-
Respondent.
ney fees and costs to prevailing FEHA parties. We fur-
ther conclude that in awarding attorney fees and costs,
the trial court's discretion is bounded by the rule of
WERDEGAR, J.
Christiansburg; an unsuccessful FEHA plaintiff should
Ct.App. 4/2 E055755San Bernardino County Super. not be ordered to pay the defendant's fees or costs un-
Ct. No. CIVRS801732 less the plaintiff brought or continued litigating the
action without an objective basis for believing it had
Plaintiff Loring Winn Williams sued defendant Chi- potential merit.
no Valley Independent Fire District (the District) for
employment discrimination in violation of the Cal-
ifornia Fair Employment and Housing Act. (FEHA; 14
casetext.com/case/williams-v-chino-valley... 1 of 13
Page 54
ORI(;INAL
(Do not write above this line.)
State Bar Court of California kwiktag ~ 018 038 659

Hearing Department
Los Angeles
REPROVAL
Counsel For The State Bar Case Number(s): For Court use only
10-O-02178
Cindy McCaughey, DTC 10-O-03701
Office of Chief Trial Counsel
1149 South Hill Street
213/765-1491
FILED .....
Bar # 222126 FEB i0 2011
In Pro Per Respondent STATE BAR COURT
CLERK’S OFFICE
Richard Nahigian LOS ANGELES
1122 E. Green Street
Pasadena, CA 91106
626/683-3991
Submitted to: Settlement Judge
Bar # 45675 STIPULATION RE FACTS, CONCLUSIONS OF LAW AND

DISPOSITION AND ORDER APPROVING
In the Matter of:
Richard Elia Nahigian
PUBLIC REPROVAL
[] PREVIOUS STIPULATION REJECTED

Bar # 45675
A Member of the State Bar of California

(Respondent)
Note: All information required by this form and any additional information which cannot be provided in the
space provided, must be set forth in an attachment to this stipulation under specific headings, e.go, "Facts,"
"Dismissals," "Conclusions of Law," "Supporting Authority," etc.
A. Parties’ Acknowledgments:
(1) Respondent is a member of the State Bar of California, admitted Jonuory 15, ] 970.
(2) The parties agree to be bound by the factual stipulations contained herein even if conclusions of law or
disposition are rejected or changed by the Supreme Court.
(3) All investigations or proceedings listed by case number in the caption of this stipulation are entirely resolved by
this stipulation and are deemed consolidated. Dismissed charge(s)/count(s) are listed under "Dismissals." The
stipulation consists of 15 pages, not including the order.
(4) A statement of acts or omissions acknowledged by Respondent as cause or causes for discipline is included
under "Facts."
(Effective January 1,2011)
Reproval
15 Page 55
(5) Conclusions of law, drawn from and specifically referring to the facts are also included under "Conclusions of
Law".
(6) The parties must include supporting authority for the recommended level of discipline under the heading
"Supporting Authority."
(7) No more than 30 days prior to the filing of this stipulation, Respondent has been advised in writing of any
pending investigation/proceeding not resolved by this stipulation, except for criminal investigations.
(8) Payment of Disciplinary CostsnRespondent acknowledges the provisions of Bus. & Prof. Code §§6086.10 &
6140.7. (Check one option only):
[] Costs are added to membership fee for calendar year following effective date of discipline (public
reproval).
[] Case ineligible for costs (private reproval).
[] Costs are to be paid in equal amounts prior to February 1 for the following membership years:
(Hardship, special circumstances or other good cause per rule 5.132, Rules of Procedure.) If
Respondent fails to pay any installment as described above, or as may be modified by the State Bar
Court, the remaining balance is due and payable immediately.
[] Costs are waived in part as set forth in a separate attachment entitled "Partial Waiver Qf Costs".
[] Costs are entirely waived.
(9) The parties understand that:
(a) [] A private reproval imposed on a respondent as a result of a stipulation approved by the Court prior to
initiation of a State Bar Court proceeding is part of the respondent’s official State Bar membership
records, but is not disclosed in response to public inquiries and is not reported on the State Bar’s web
page. The record of the proceeding in which such a private reproval was imposed is not available to
the public except as part of the record of any subsequent proceeding in which it is introduced as
evidence of a prior record of discipline under the Rules of Procedure of the State Bar.
(b) A private reproval imposed on a respondent after initiation of a State Bar Court proceeding is part of
the respondent’s official State Bar membership records, is disclosed in response to public inquiries
and is reported as a record of public discipline on the State Bar’s web page.
(c) [] A public reproval imposed on a respondent is publicly available as part of the respondent’s official
State Bar membership records, is disclosed in response to public inquiries and is reported as a record
of public discipline on the State Bar’s web page.
B. Aggravating Circumstances [for definition, see Standards for Attorney Sanctions for
Professional Misconduct, standard 1.2(b)]. Facts supporting aggravating circumstances
are required.
(1) [] Prior record of discipline [see standard 1.2(f)]
(a) [] State Bar Court case # of prior case 05-O-3460
(b) [] Date prior discipline effective December ! ], 2007
(c) [] Rules of Professional Conduct/State Bar Act violations: 60~8(b) Bus. & Prof.
(d) [] Degree of prior discipline Private Reproval

Reproval
2
Page 56
(e) [] If Respondent has two or more incidents of prior discipline, use space provided below or a separate
attachment entitled "Prior Discipline.
(2) [] Dishonesty: Respondent’s misconduct was surrounded by or followed by bad faith, dishonesty,
concealment, overreaching or other violations of the State Bar Act or Rules of Professional Conduct.
(3) [] Trust Violation: Trust funds or property were involved and Respondent refused or was unable to account
to the client or person who was the object of the misconduct for improper conduct toward said funds or
property.
(4) [] Harm: Respondent’s misconduct harmed significantly a client, the public or the administration of justice.
(5) [] Indifference: Respondent demonstrated indifference toward rectification of or atonement for the
consequences of his or her misconduct.
(6) [] Lack of Cooperation: Respondent displayed a lack of candor and cooperation to victims of his/her
misconduct or to the State Bar during disciplinary investigation or proceedings.
(7) [] Multiple/Pattern of Misconduct: Respondent’s current misconduct evidences multiple acts of wrongdoing
or demonstrates a pattern of misconduct.
(8) [] No aggravating circumstances are involved.
Additional aggravating circumstances:
C. Mitigating Circumstances [see standard 1.2(e)]. Facts supporting mitigating

circumstances are required.
[] No Prior Discipline: Respondent has no prior record of discipline over many years of practice coupled
with present misconduct which is not deemed serious.
(2) [] No Harm: Respondent did not harm the client or person who was the object of the misconduct.
(3) [] Candor/Cooperation: Respondent displayed spontaneous candor and cooperation with the victims of
his/her misconduct and to the State Bar during disciplinary investigation and proceedings.
(4) [] Remorse: Respondent promptly took objective steps spontaneously demonstrating remorse and
recognition of the wrongdoing, which steps were designed to timely atone for any consequences of his/her
misconduct.
(5) [] Restitution: Respondent paid $ on in restitution to without the threat or force of

disciplinary, civil or criminal proceedings.
(6) [] Delay: These disciplinary proceedings were excessively delayed. The delay is not attributable to
Respondent and the delay prejudiced him/her.
(7) [] Good Faith: Respondent acted in good faith.

(8) [] Emotional/Physical Difficulties: At the time of the stipulated act or acts of professional misconduct
Respondent suffered extreme emotional difficulties or physical disabilities which expert testimony would
establish was directly responsible for the misconduct. The difficulties or disabilities were not the product of
Reproval
Page 57
any illegal conduct by the member, such as illegal drug or substance abuse, and Respondent no longer
suffers from such difficulties or disabilities.
(9) [] Severe Financial Stress: At the time of the misconduct, Respondent suffered from severe financial stress
which resulted from circumstances not reasonably foreseeable or which were beyond his/her control and
which were directly responsible for the misconduct.
(10) [] Family Problems: At the time of the misconduct, Respondent suffered extreme difficulties in his/her
personal life which were other than emotional or physical in nature.
(11) [] Good Character: Respondent’s good character is attested to by a wide range of references in the legal
and general communities who are aware of the full extent of his/her misconduct.
(12) [] Rehabilitation: Considerable time has passed since the acts of professional misconduct occurred
followed by convincing proof of subsequent rehabilitation.
(13) [] No mitigating circumstances are involved.
Additional mitigating circumstances:
See attached
D. Discipline:
(1) [] Private reproval (check applicable conditions, if any, below)
(a) [] Approved by the Court prior to initiation of the State Bar Court proceedings (no public disclosure).
(b) [] Approved by the Court after initiation of the State Bar Court proceedings (public disclosure).
o../r
(2) [] Public reproval (Check applicable conditions, if any, below)
E. Conditions Attached to Reproval:
(1) [] Respondent must comply with the conditions attached to the reproval for a period of one year.
(2) [] During the condition period attached to the reproval, Respondent must comply with the provisions of the
State Bar Act and Rules of Professional Conduct.
(3) [] Within ten (10) days of any change, Respondent must report to the Membership Records Office of the
State Bar and to the Office of Probation of the State Bar of California ("Office of Probation"), all changes of
information, including current office address and telephone number, or other address for State Bar
purposes, as prescribed by section 6002.1 of the Business and Professions Code.
(4) Within thirty (30) days from the effective date of discipline, Respondent must contact the Office of Probation
and schedule a meeting with Respondent’s assigned probation deputy to discuss these terms and
conditions of probation. Upon the direction of the Office of Probation, Respondent must meet with the
probation deputy either in-person or by telephone. During the period of probation, Respondent must
promptly meet with the probation deputy as directed and upon request.
(5) [] Respondent must submit written quarterly reports to the Office of Probation on each January 10, April 10,
July 10, and October 10 of the condition period attached to the reproval. Under penalty of perjury,
Respondent must state whether Respondent has complied with the State Bar Act, the Rules of
Professional Conduct, and all conditions of the reproval during the preceding calendar quarter. Respondent
(Effective January 1,2011 )
Reproval
4
Page 58
must also state in each report whether there are any proceedings pending against him or her in the State
Bar Court and if so, the case number and current status of that proceeding. If the first report would cover
less than 30 (thirty) days, that report must be submitted on the next following quarter date, and cover the
extended period.
In addition to all quarterly reports, a final report, containing the same information, is due no earlier than
twenty (20) days before the last day of the condition period and no later than the last day of the condition
period.
(6) Respondent must be assigned a probation monitor. Respondent must promptly review the terms and
conditions of probation with the probation monitor to establish a manner and schedule of compliance.
During the period of probation, Respondent must furnish such reports as may be requested, in addition to
the quarterly reports required to be submitted to the Office of Probation. Respondent must cooperate fully
with the monitor.
(7) Subject to assertion of applicable privileges, Respondent must answer fully, promptly and truthfully any
inquiries of the Office of Probation and any probation monitor assigned under these conditions which are
directed to Respondent personally or in writing relating to whether Respondent is complying or has
complied with the conditions attached to the reproval.
(8) Within one (1) year of the effective date of the discipline herein, Respondent must provide to the Office of
Probation satisfactory proof of attendance at a session of the Ethics School, and passage of the test given
at the end of that session.
[] No Ethics School recommended. Reason:
(9) , Respondent must comply with all conditions of probation imposed in the underlying criminal matter and
must so declare under penalty of perjury in conjunction with any quarterly report to be filed with the Office
of Probation.
(10) [] Respondent must provide proof of passage of the Multistate Professional Responsibility Examination
("MPRE"), administered by the National Conference of Bar Examiners, to the Office of Probation within one
year of the effective date of the reproval.
[] No MPRE recommended. Reason:
(11) [] The following conditions are attached hereto and incorporated:
[] Substance Abuse Conditions [] Law Office Management Conditions
[] Medical Conditions [] Financial Conditions
F. Other Conditions Negotiated by the Parties:

Reproval
5
Page 59
In the Matter of: Case Number(s):

Richard Elia Nahigian 10-O-02178
10-O-03701
Financial Conditions
a. Restitution
Respondent must pay restitution (including the principal amount, plus interest of 10% per annum) to the
payee(s) listed below. If the Client Security Fund ("CSF") has reimbursed one or more of the payee(s) for all
or any portion of the principal amount(s) listed below, Respondent must also pay restitution to CSF in the
amount(s) paid, plus applicable interest and costs.
Payee Principal Amount Interest Accrues From

State Bar of Califomia, $6,500.00 March 13, 2007
Client Security Fund, on
behalf of Nicomedes Estrada
State Bar of California, $10,000.00 August3,2007
Client Security Fund, on
behalf of Henry West, IV
[] Respondent must pay above-referenced restitution and provide satisfactory proof of payment to the Office of
Probation not later than May 3 l, 2011.
b. Installment Restitution Payments
Respondent must pay the above-referenced restitution on the payment schedule set forth below. Respondent
must provide satisfactory proof of payment to the Office of Probation with each quarterly probation report, or
as otherwise directed by the Office of Probation. No later than 30 days prior to the expiration of the period of
probation (or period of reproval), Respondent must make any necessary final payment(s) in order to complete
the payment of restitution, including interest, in full.
Payee/CSF (as applicable) Minimum Payment Amount Payment Frequency
[] If Respondent fails to pay any installment as described above, or as may be modified by the State Bar Court,
the remaining balance is due and payable immediately.
c. Client Funds Certificate
[] 1. If Respondent possesses client funds at any time during the period covered by a required quarterly
report, Respondent must file with each required report a certificate from Respondent and/or a certified
public accountant or other financial professional approved by the Office of Probation, certifying that:

Page
Page 60
(Do not write above this line,)
Respondent has maintained a bank account in a bank authorized to do business in the State of
California, at a branch located within the State of California, and that such account is designated
as a "Trust Account" or "Clients’ Funds Account";
(Effective January 1,2011 )

Page 61
b. Respondent has kept and maintained the following:
A written ledger for each client on whose behalf funds are held that sets forth:
1. the name of such client;
2. the date, amount and source of all funds received on behalf of such client;
3. the date, amount, payee and purpose of each disbursement made on behalf of such
client; and,
4. the current balance for such client.
ii. a written journal for each client trust fund account that sets forth:
1. the name of such account;
2. the date, amount and client affected by each debit and credit; and,
3. the current balance in such account.
iii. all bank statements and cancelled checks for each client trust account; and,
each monthly reconciliation (balancing) of (i), (ii), and (iii), above, and if there are any
differences between the monthly total balances reflected in (i), (ii), and (iii), above, the
reasons for the differences.
Respondent has maintained a written journal of securities or other properties held for clients that
specifies:
i. each item of security and property held;
ii. the person on whose behalf the security or property is held;
iii. the date of receipt of the security or property;
iv. the date of distribution of the security or property; and,
v. the person to whom the security or property was distributed.
If Respondent does not possess any client funds, property or securities during the entire period
covered by a report, Respondent must so state under penalty of perjury in the report filed with the
Office of Probation for that reporting period. In this circumstance, Respondent need not file the
accountant’s certificate described above.
3. The requirements of this condition are in addition to those set forth in rule 4-100, Rules of
Professional Conduct.
d. Client Trust Accounting School
[] Within one (1) year of the effective date of the discipline herein, Respondent must supply to the Office of
Probation satisfactory proof of attendance at a session of the Ethics School Client Trust Accounting School,
within the same period of time, and passage of the test given at the end of that session.

Page_~
Page 62
ATTACHMENT TO
STIPULATION RE FACTS, CONCLUSIONS OF LAW AND DISPOSITION
In the Matter of: Richard Elia Nahigian

Case Number(s): 10-O-02178 and 10-O-03701
PENDING PROCEEDINGS
The disclosure date referred to on page two, paragraph (A)(7) is not applicable.
FACTS:
Respondent admits that the following facts are true and that he is culpable of violations of the
specified Rules of Professional Conduct and Business & Professions Code sections as follows:
Case #10-O-02178 (The Estrada Matter)
In or about April 2007, Martha Moto ("Moto") hired Respondent to represent her brother,
Nicomedes Estrada ("Estrada") at sentencing following his conviction for attempt murder
in Los Angeles County Superior Court case number VA072145 ("Estrada matter") and to
file a motion for a new trial. Estrada was over the age of 18.
’ 2. Moto paid Respondent $6,500.00 in advanced fees for his services.
3. Respondent did not obtain Estrada’s informed written consent before accepting
compensation from Moto to represent Estrada.
On or about April 13, 2007 Respondent appeared on behalf of Estrada for sentencing and
informed the court that he intended to file a motion for a new trial. Sentencing was
continued to June 8, 2007 with the Motion for New Trial calendared for May 30, 2007.
5. Respondent sought and the court granted a continuance of the motion and sentencing
until June 27, 2007.
6. At no time prior to June 27, 2007, did Respondent file a Motion for New Trial on
Estrada’s behalf.
7. On or about June 27, 2007, Estrada was sentenced to life in prison plus 25 years to life.
At no time did Respondent contact Estrada and inform him that he would not file a
Motion for New Trial, or explain to Estrada the reasons why he did not file the motion.
Respondent took no further actions to inform Estrada of his legal options. Respondent
conveyed the information only to Moto.
9. Respondent did not refund any portion of the fee.
Nahigian Stip Attachment
Page 63
CONCLUSIONS OF LAW:
By not informing Estrada in advance that he would not file a Motion for New Trial,
Respondent failed to keep a client reasonably informed of significant developments in a
matter in which he agreed to provide legal services in willful violation of Business and
Professions Code, section 6068(m).
By not obtaining Estrada’s informed written consent before accepting compensation from
Moto to perform services for Estrada, Respondent willfully violated Rules of Professional
Conduct, Rule 3-310(F).
By failing to refund the $6,500 to Estrada, Respondent failed to promptly refund any part
of a fee paid in advance that has not been earned in willful violation of Rules of
Professional Conduct, Rule 3-700(D)(2).
FACTS:
Respondent admits that the following facts are true and that he is culpable of violations of the
specified Rules of Professional Conduct and Business & Professions Code sections as follows:
Case #10-O-03701 (The West Matter)
In or about May 2007, respondent was hired by Henry Clay West ("West") to represent
him in Los Angeles County Superior Court case numbers PA 059029 and PA 054907.
Case number PA 054907 was a violation of probation matter, with a three year suspended
prison term as a condition of probation. On or about May 15, 2007, West paid
Respondent $10,000 in advance legal fees for all legal services leading up to trial.
2. On or about August 3, 2007, West paid Respondent an additional $10,000 in advanced

fees to represent him through jury trial.
On August 27, 2007, case number PA 059029 was trailing day 8 of 10 for trial when
West entered a plea of nolo contendre to certain charges in exchange for a total sentence
of four years in state prison to run concurrently with PA 054907.
In or about August, 2008, West wrote Respondent requesting a refund of the $10,000 in
advanced fees to represent West at trial. Respondent did not refund any portion of the
fee.
CONCLUSIONS OF LAW:
By failing to refund the $10,000 to West, Respondent failed to promptly refund any part
of a fee paid in advance that has not been earned in willful violation of Rules of
Professional Conduct, Rule 3-700(D)(2).
10
Page 64
WAIVER OF VARIANCE BETWEEN NOTICE OF DISCIPLINARY CHARGES AND
STIPULATED FACTS AND CULPABILITY
The parties waive any variance between the Notice of Disciplinary Charges filed on
December 2, 2010, and the facts and/or conclusions of law contained in this stipulation.
Additionally, the parties waive the issuance of an amended Notice of Disciplinary Charges. The
parties further waive the right to a formal hearing on any charge not included in the pending
Notice of Disciplinary Charges.
DISMISSALS
The parties respectfully request that the Court dismiss the following alleged violations in
the interest of justice:
Case No. 10-O-02178 Count One Rules of Professional Conduct, Rule 3-110(A)
Case No. 10-O-02178 Count Four Rules of Professional Conduct, Rule 4-100(B)(3)
ADDITIONAL MITIGATING CIRCUMSTANCES
¯ Respondent acted in good faith by communicating through Moto, with the expectation all
information would be conveyed to Estrada.
Respondent has demonstrated remorse and has attempted to refund the fee in full in both
matters, however, because both Estrada and West are currently incarcerated in the
California Department of Corrections and Rehabilitation, both Respondent and the State
Bar have experienced certain difficulties in ascertaining an appropriate repository for the
funds.
¯ Respondent has been a member for 40 years with one prior minor incident of misconduct,
which, as discussed below should have little weight in aggravation.
AUTHORITIES SUPPORTING DISCIPLINE
STANDARDS FOR ATTORNEY SANCTIONS
To determine the appropriate level of discipline, the standards provide guidance. Drociak
v. State Bar (1991) 52 Cal.3d 1085; In the Matter of Sampson, 3 Cal. State Bar Ct. Rptr. 119. A
disciplinary recommendation must be consistent with the discipline in similar proceedings. See
Snyder v. State Bar (1990) 49 Cal.3d 1302. Moreover, the recommended discipline must rest
upon a balanced consideration of relevant factors. In the Matter of Sampson, 3 Cal. State Bar Ct.
Rptr. 119.
Pursuant to Standard 1.3 of the Standards for Attorney Sanctions for Professional
Misconduct:
11
Page 65
The primary purposes of disciplinary proceedings conducted by the State Bar
of California and of sanctions imposed upon a finding or acknowledgment of
a member’s professional misconduct are the protection of the public, the
courts and the legal profession; the maintenance of high professional
standards by attorneys and the preservation of public confidence in the legal
profession. Rehabilitation of a member is a permissible object of a sanction
imposed upon the member but only if the imposition of rehabilitative
sanctions is consistent with the above-stated primary purposes of sanctions
for professional misconduct.
Misconduct:
Reasonable duties or conditions fairly related to the acts of professional

misconduct and surrounding circumstances found or acknowledged by the
member may be added to a recommendation or suspension or; pursuant to
rule 9.19, California Rules of Court, to a reproval. Said duties may include,
but are not limited to, any of the following:
1.5(b): a requirement that the member takes and passes an examination in

professional responsibility;
1.5(d): a requirement that the member undertake educational or rehabilitative

work at his or her own expense regarding one or more fields of substantive
law or law office management;
1.5(f): any other duty or condition consistent with the purposes of imposing a
sanction for professional misconduct as set forth in standard 1.3.
Misconduct:
Culpability of a member of willfully failing to perform services in an individual

matter or matters not demonstrating a pattern of misconduct or culpability of a
member of willfully failing to communicate with a client shall result in reproval
or suspension depending upon the extent of the misconduct and the degree of
harm to the client.
Misconduct:
Culpability of a member of a violation of any of the following provisions of the

Business and Professions Code shall result in disbarment or suspension depending
on the gravity of the offense or the harm, if any, to the victim, with due regard to
the purposes of imposing discipline set forth in Standard 1.3: ... (a) Sections 6067
and 6068 ....
12
Page 66
Misconduct:
Culpability of a member of a violation of any provision of the Business and

Professions Code not specified in these standards or a willful violation of any
Rule of Professional Conduct not specified in these standards shall result in
reproval or suspension according to the gravity of the offense or the harm, if any,
to the victim, with due regard to the purposes of imposing discipline set forth in
Standard 1.3.
Pursuant to Standard 1.7(a) of the Standards for Attorney Sanctions for

Professional Misconduct:
If a member is found culpable of professional misconduct in any proceeding in

which discipline may be imposed and the member has a record of one prior
imposition of discipline as defined by standard 1.2(0, the degree of discipline
imposed in the current proceeding shall be greater than that imposed in the prior
proceeding unless the prior discipline imposed was so~ remote in time to the
current proceeding and the offense for which it was imposed was so minimal in
severity that imposing greater discipline in the current proceeding would be
manifestly unjust.
Reproval is the appropriate sanction in this matter. First, the parties submit a
deviation from Standard 2.6 is appropriate in this case based upon the factors enumerated
in mitigation in Section "C" above. The parties agree that while Respondent failed to
communicate directly with Mr. Estrada about Respondent’s reasons for declining to file a
Motion for New Trial, Respondent did communicate this information to Moto
maintaining a good faith, albeit mistaken, belief it would be sufficient for Moto to
communicate to Mr. Estrada.
Moreover, Respondent has been willing to make restitution by refunding the fees
in full to both Estrada and West without regard to any portion which might have actually
been earned. The parties submit that because both West and Estrada have been
incarcerated in facilities throughout the Department of Corrections and Rehabilitation,
difficulties in locating an appropriate repository for these funds precluded Respondent
from acting earlier to refund these fees.
Furthermore, the conduct may be considered isolated when weighed against

Respondent’s 40 years as a member, although the parties acknowledge Respondent has
one prior incident of discipline.
Additionally, Respondent has demonstrated a level of remorse and cooperation

which reflects that he does not pose a significant future threat to the public or his clients.
13
Page 67
The parties further submit that the intent and goals of Standard 1.3 are met in this
matter with the imposition of a Public Reproval with those probationary conditions
articulated herein.
COSTS OF DISCIPLINARY PROCEEDINGS:
Respondent acknowledges that the Office of the Chief Trial Counsel has informed
Respondent that as of February 9, 2011, the prosecution costs in this matter are $2,925.00.
Respondent further acknowledges that should this stipulation be rejected or should relief from
the stipulation be granted, the costs in this matter may increase due to the cost of further
proceedings.
14
Page 68
In the Matter of Case number(s):
Richard Nahigian 10-O-02178 and 10-O-O3701
SIGNATURE OF THE PARTIES
By their signatures below, the parties and their counsel, as applicable, signify their agreement with
each of the recitations and each of the terms and conditions of this Stipulation Re Fact,
Conclusions of Law and Disposition.
Date Respondent’s Signature ti Print Name
Date Print Name
Date D~puty Trial C~unsel’~.~ignatur~ Print Name
(Stipulation form approved by SBC Executive Committee 10/16/00. Revised 12/16/2004; 12/13/2006.) Signature Page
Page 69
In the Matter of: Case Number(s):

Richard Nahigian 10-O-02178
10-O-03701
REPROVAL ORDER
Finding that the stipulation protects the public and that the interests of Respondent will be served by any conditions
attached to the reproval, IT IS ORDERED that the requested dismissal of counts/charges, if any, is GRANTED without
prejudice, and:
The stipulated facts and disposition are APPROVED AND THE REPROVAL IMPOSED.
[] The stipulated facts and disposition are APPROVED AS MODIFIED as set forth below, and the
REPROVAL IMPOSED.
[] All court dates in the Hearing Department are vacated.
The parties are bound by the stipulation as approved unless: 1) a motion to withdraw or modify the stipulation, filed
within 15 days after service of this order, is granted; or 2) this court modifies or further modifies the approved
stipulation. (See rule 5.58(E) & (F), Rules of Procedure.) Otherwise the stipulation shall be effective 15 days after
service of this order.
Failure to comply with any conditions attached to this reproval may constitute cause for a separate
proceeding for willful breach of rule 1-110, Rules of Professional Conduct.
Date Judge of the State Bar Court

Reproval Order
Page
Page 70
CERTIFICATE OF SERVICE
[Rules Proc. of State Bar; Rule 5.27(B); Code Civ. Proc., § 1013a(4)]
I am a Case Administrator of the State Bar Court of California. I am over the age of eighteen
and not a party to the within proceeding. Pursuant to standard court practice, in the City and
County of Los Angeles, on February 10, 2011, I deposited a true copy of the following
document(s):
STIPULATION RE FACTS, CONCLUSIONS OF LAW AND DISPOSITION AND

ORDER APPROVING
in a sealed envelope for collection and mailing on that date as follows:
by first-class mail, with postage thereon fully prepaid, through the United States Postal
Service at Los Angeles, California, addressed as follows:
RICHARD ELlA NAHIGIAN

1122 E GREEN ST
PASADENA, CA 91106- 2516
by interoffice mail through a facility regularly maintained by the State Bar of California
addressed as follows:
CYNTHIA MCCAUGHEY, Enforcement, Los Angeles
I hereby certify that the foregoing is true and correct. Executed in Los Angeles, California, on
February 10, 2011. ................... .-..
Rose Luthi
Case Administrator
State Bar Court
Page 71

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Nancy Duffy McCarron, CBN 164780

950 Roble Lane

December 11, 2017

PERSONAL AND CONFIDENTIAL RE: Supplement to Request to Review

knowledge regarding the investments1properties of the Jacinto's.

Ronald M. Fernando Sr.

Dear Mr. Femndo:

Instrument No-: 2014-9418050

Date off udgmnt

Total Amount Owed

Very truly yours,

Kathrine Faulise, Office Manager

10 STUBBLEFIELD PROPERTIES, a Case No. CTVDS 1208547

23 dismissed the Cross Complaint on March 17, 2014;

Judgment in favor of Plaintiff Stubblefield Properties, a Cahfonua general partnerslup

3 in the sum of$41,166.58;

s space 120 in Mountain Shadows Mobilehome Community, 4040 E. Piedmont Drjve,

6 Highland, CA; and

8 mobilehome from Mountain Shadows Mobilehome Community in accordance with

12 Plaintiff to recover its costs.

13 The Comt Clerk shall forthwith enter this judgment.

Rat&e?. *jiy?.ifi ?,:m n*.~~> -,.'. . 1-877-461-SBOC

2 The ROBERT G WILLIAMSON JR

Pay to the C. It- t?i= f Y1f A '/(.,(1 'tJ/vwr--- \JY',]

i .... ;":'-'- Co {, 5'0 6 ~ ____ __dd-~------

PLArNTIFF(S) AND RESPONDENT FOR COU RTU¥i ~Ne I!; 10

DEFENDANT (S) AND APPELLANT FEB 3 ,U16

QCL'-QL~"'0- V'JD.-n \..e:L.

CAS E l\'lJMBER C IVDS1208547

o Augmentation of the record as ordered by the Court of Appeals

DUE DATE: FEBRUARY 13, 2016

IZJ RESPONDENT - (if d esired) - ONE COPY $93.50 Estimate Due

IZJ RESPONDENT - (if desired)

Dated: February 3, 2016

Re: M3rtinC. Jacinto v. Rich",rdNabigian;

Dear Mr. Jacinto and Ms. Ramirez:

Please make the retainer check payable to:

La Jolla Law Group Trust Account

9404 Genesee Avenue, Suite 300, La Jolla, California 92037

Very truly yours,

KENT L. SHARP, ESQ.

JOB NO. 3400

LA JOLLA LAW GROUP

9404 Genesee Avenue, Suite 300

La Jol1a, California 92037

Telephone: (858) 202-1321

Facsimile: (858) 202-1308

Name Phone Number Fax Number

TO: CAROLINA RAMIREZ (909) 883-7327

FROM: Stacie L. Rammolsberg

RE: Request for Doeuments

NR.Transaction Date 10/1/2013 - 31212017

'B' for Billed. 'PI for Posted.

7101 PAY B Jacinto, Martin (1200.00)

7111 PAY B Jacinto, Martin (3800.00)

7200 PAY B Jacinto, Martin (4400.00)

7201 PAY B Jacinto, Martin (100.00)

7202 PAY B Jacinto, Martin (500.00)

7333 PAY B Jacinto, Martin (10000.00)

1 KENT L. SHARP, ESQ.: SBN179468

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

9 FOR THE COUNTY OF SAN BERNARDINO - SAN BERNARDINO DISTRICT

10 MARTIN C. JACINTO, an individual, CASE NO. CIVDS1604759

Rat&e?. jiy?.ifi ?,:m n.~~> -,.'. . 1-877-461-SBOC

i .... ;":'-'- Co {, 5'0 6 ~ __ dd-~------