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REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION TO AMEND JUDGMENT TO ADD JUDMENT
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MILLER|LLP
Pursuant to California Evidence Code Sections 452(d) and (h), judgment creditors Knapp,
Petersen and Clarke, Stephen Ray Garcia, Stephen Harris, and Andre Jardini (collectively referred
to as “KPC”), respectfully ask this Court to take judicial notice of the following records:
1. All pleadings, files, trial transcripts, and any other evidence filed with the Court of Appeal
in Gaggero v. Knapp, Petersen & Clarke, et al, (2010), California Court of Appeal, Second
Appellate District, Division Eight, (Appeal Case No. B207567).
Attached as Exhibit A-2 is a true and correct copy of excerpts from the Appellate
Court’s Decision affirming this Court’s ruling in Gaggero v. Knapp, Petersen &
Clarke, et al, Los Angeles Superior Court (Case No. BC286925).
2. All pleadings, files, trial transcripts, and any other evidence filed or in connection with the
underlying action, Gaggero v. Knapp, Petersen & Clarke, et al, Los Angeles Superior Court,
(Case No. BC286925).
Attached as Exhibit A is a true and correct copy of Statement of Decision issued
by this Court in Gaggero v. Knapp, Petersen & Clarke, et al, Los Angeles
Superior Court (Case No. BC286925).
Attached as Exhibit B is a true and correct copy of the Amended Judgment filed in
the Gaggero v. Knapp, Petersen & Clarke, et al, Los Angeles Superior Court
(Case No. BC286925).
Attached as Exhibit K is a true and correct copy of excerpts and Reporter’s
Certificate from the Reporter’s Daily Transcript taken on August 2, 2007 in the
Gaggero v. Knapp, Petersen & Clarke, et al, Los Angeles Superior Court (Case
No. BC286925).
Attached as Exhibit L is a true and correct copy of excerpts and the Reporter’s
Certificate from the Reporter’s Daily Transcript on August 7, 2007 in the Gaggero
v. Knapp, Petersen & Clarke, et al, Los Angeles Superior Court (Case No.
BC286925).
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REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION TO AMEND JUDGMENT TO ADD JUDMENT
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MILLER|LLP
Attached as Exhibit N is a true and correct copy this Court’s transcript for the
October 5, 2011 hearing on the KPC’s motion to compel further responses to post-
judgment special interrogatories in the present case Gaggero v. Knapp, Petersen &
Clarke, et al, Los Angeles Superior Court (Case No. BC286925).
Attached as Exhibit S is true and correct copy of excerpts from Joseph Praske’s
Third Party Debtor Exam taken on June 9, 2009 and the Reporter’s Certificate of
the transcript.
3. All pleadings, files, trial transcripts, and any other evidence in connection with Gaggero v.
Yura, Los Angeles Superior Court (Case No. BC239810).
Attached as Exhibit M is a true and correct copy of the Declarations of Stephen M.
Gaggero and Joseph Praske in support of a Motion for Reconsideration filed the
Gaggero v. Yura, Los Angeles Superior Court (Case No. BC239810).
4. All pleadings, files, trial transcripts, and any other evidence filed with the Court of Appeal
from the appeal in Gaggero v. Yura (2008), California Court of Appeal, Second Appellate District,
Division Five, (Appeal Case No. B203780).
5. Attached as Exhibits C-I are true and correct copies of excerpts from the Reporters
Transcript on Appeal filed in Gaggero v. Yura (2008), California Court of Appeal, Second
Appellate District, Division Five (Appeal Case No. B203780). Exhibit J is a true and correct copy
of the Reporter’s Certificate for the Transcripts on Appeal.
Attached as Exhibits C is a true and correct copy of excerpts from the Reporter’s
Daily Transcript of Stephen Gaggero’s Direct Examination on June 27, 2005 from
the appeal of Gaggero v. Yura, et al, Los Angeles Superior Court (Case No.
BC239810).
Attached as Exhibits D is a true and correct copy of excerpts from the Reporter’s
Daily Transcript of Stephen Gaggero’s Direct Examination on June 28, 2005 from
the appeal of Gaggero v. Yura, et al, Los Angeles Superior Court (Case No.
BC239810).
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REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION TO AMEND JUDGMENT TO ADD JUDMENT
DEBTORS
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MILLER|LLP
Attached as Exhibits E is a true and correct copy of excerpts from the Reporter’s
Daily Transcript of Stephen Gaggero’s Direct Examination on June 29, 2005 from
the appeal of Gaggero v. Yura, et al, Los Angeles Superior Court (Case No.
BC239810).
Attached as Exhibits F is a true and correct copy of excerpts from the Reporter’s
Daily Transcript of Joseph Praske Direct Examination on June 30, 2005 from the
appeal of Gaggero v. Yura, et al, Los Angeles Superior Court (Case No.
BC239810).
Attached as Exhibits G is a true and correct copy of excerpts from the Reporter’s
Daily Transcript of Joseph Praske Cross Examination on June 30, 2005 from the
appeal of Gaggero v. Yura, et al, Los Angeles Superior Court (Case No.
BC239810).
Attached as Exhibits H is a true and correct copy of excerpts from the Reporter’s
Daily Transcript of Stephen Gaggero’s Re-Direct Examination on July 15, 2005
from the appeal of Gaggero v. Yura, et al, Los Angeles Superior Court (Case No.
BC239810).
Attached as Exhibits I is a true and correct copy of excerpts from the Reporter’s
Daily Transcript of Stephen Gaggero’s Re-Direct Examination on July 15, 2005
from the appeal of the Gaggero v. Yura, et al, Los Angeles Superior Court (Case
No. BC239810).
Attached as Exhibit J is a true and copy of the Reporter’s Certificate on Appeal
relating to the excerpts in Exhibits C-I above.
6. All documents publicly available on the Secretary of State of Nevada website
http://nvsos.gov/sosentitysearch relating to Pacific Coast Management and related entities.
Attached as Exhibit O are documents obtained from the website of the Secretary of State of
Nevada.
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1 7. All documents publicly available on the Secretary of State of California website
2 http://kepler.sos.ca.govrelatingto 511 OFW, LP, Gingerbread Court, LP, Malibu Broadbeach, LP,
3 Marina Glencoe, LP, Blu House, LLC, Boardwalk Sunset, LLC, and related entities. Attached as
4 Exhibit P are documents obtained from the website ofthe Secretary of State ofCalifornia.
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Dated: April 10, 2012 MILLERLLP
. By: tL-b.- CiVaI,..~R_ANDALL A. MJ:LLER, ESQ.
AUSTA WAKlLY, ESQ.
Attorneys for Defendants, KNAPP, PETERSEN &
CLARKE, STEPHEN RAY GARCIA, STEPHEN M.
HARRIS and ANDRE JARDINI
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REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION TO AMEND JUDGMENT TO ADD JUDMENT
DEBTORS