On July 12, 2019 a
Party Statement
was filed
involving a dispute between
Deninger, Paul Francis,
Lemasters, Mary Elizabeth,
and
Deninger, Paul Francis,
Does 1-10,
for (06) Unlimited Breach of Contract/Warranty
in the District Court of San Mateo County.
Preview
1
SUNENA SABHARWAL, SBN 148237
2 SABHARWAL LAW OFFICES
1816 5th Street
3 Berkeley, CA 94710
Phone: (510) 665-8777
4
Fax: (510) 665-8778
5
Attorney for plaintiff
6
7 RANDY RABIDOUX, SBN 293166
ALEXANDER T. JONES, SBN 266082
8 SOUND LAW GROUP, LLP
201 Spear Street, Suite 1100
9 San Francisco, CA 94105
Telephone: (415) 495-4499
10 Facsimile: (415) 495-3202
Email: rrabidoux@soundlawsf.com
11 ajones@soundlawsf.com
12
Attorneys for Defendant,
13
Paul Francis Deninger
14
SUPERIOR COURT OF THE STATE OF CALIFORNIA
15 COUNTY OF SAN MATEO – CIVIL DIVISION
16
17 In re Matter of: Case No. 19-CIV-03974
18
MARY ELIZABETH LEMASTERS,
19 PROPOSED STATEMENT OF THE
Plaintiff, CASE
20
v.
21 Judge: Hon. Nancy L. Fineman
PAUL FRANCIS DENINGER,
22 Department: 4
Defendant,
23
24 PROPOSED STATEMENT OF THE CASE
25
In this case, Ms. LeMasters contends that Mr. Deninger and she were in a loving, committed
26
relationship when he asked her to leave her employment and live with him, and in exchange he would
27
cover all of her living expenses, share in the increase in value of his assets, and buy a house in Carmel
28
1
JOINT STATEMENT OF THE CASE
1 and condominium on the Peninsula, which they would own jointly. Mr. Deninger contends that no such
2 offers were ever made to Ms. LeMasters. Mr. Deninger contends that he told Ms. LeMasters that he
3 would provide financial support to Ms. LeMasters to enable her to complete a professionally produced
4 music album.
5 Ms. LeMasters and Mr. Deninger met in 2005 at their place of employment: Broadview
6 International. Later Broadview merged with Jeffries and Company and both parties continued to work
7 there until 2010. In addition to her job at Jeffries, Ms. LeMasters worked as a singer who performed at
8 local venues starting in or around 1995. Ms. LeMasters and Mr. Deninger continued their romantic
9 relationship until 2017.
10 Ms. LeMasters contends that the parties’ contract was stated orally, that there are writings which
11 corroborate it, and that their contract was also implied by the parties’ conduct. Mr. Deninger contends
12 that the parties never contemplated a contract and that the financial support he provided Ms. LeMasters
13 came in the form of gifts.
14 Ms. LeMasters contends that both parties lived in California and in Massachusetts during their
15 relationship. Mr. Deninger contends that he has been a resident of Massachusetts his entire life and that
16 he primarily saw Ms. LeMasters when he travelled to California.
17 In November of 2010 Ms. LeMasters left her job at Jefferies. Ms. LeMasters alleges that her
18 decision to resign from her position at Jefferies was because Mr. Deninger wanted her to leave her
19 position and did not want her to work. Mr. Deninger contends that he and Ms. LeMasters never entered
20 into a contract that induced her to leave her job at Jeffries. Mr. Deninger contends that he told Ms.
21 LeMasters that he would provide financial support to Ms. LeMasters to enable her to complete a
22 professionally produced music album.
23 Between February 2011 and 2018, Mr. Deninger rented various homes in the Bay Area at which
they both stayed.
24
From 2011 through March of 2019, Mr. Deninger paid for Ms. LeMasters’ living expenses and
25
all costs associated with the production and promotion of her music, which he contends averaged
26
between $6,000 – $7,000 per month. Ms. LeMasters contends that Mr. Deninger paid on average
27
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2
JOINT STATEMENT OF THE CASE
1 approximately $15,000 per month for all of her expenses and additional money for her artistic
2 endeavors.
3 Ms. LeMasters contends that Mr. Deninger breached their contract when he stopped paying her
4 expenses. Mr. Deninger contends that he followed through on the gifts to Ms. LeMasters so she could
5 finish her music album.
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3
JOINT STATEMENT OF THE CASE
Document Filed Date
November 30, 2022
Case Filing Date
July 12, 2019
Category
(06) Unlimited Breach of Contract/Warranty
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1 SUNENA SABHARWAL, SBN 148237 2 SABHARWAL LAW OFFICES 1816 5th Street 3 Berkeley, CA 94710 Phone: (510) 665-8777 4 Fax: (510) 665-8778 5 Attorney for plaintiff 6 7 RANDY RABIDOUX, SBN 293166 ALEXANDER T. JONES, SBN 266082 8 SOUND LAW GROUP, LLP 201 Spear Street, Suite 1100 9 San Francisco, CA 94105 Telephone: (415) 495-4499 10 Facsimile: (415) 495-3202 Email: rrabidoux@soundlawsf.com 11 ajones@soundlawsf.com 12 Attorneys for Defendant, 13 Paul Francis Deninger 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 COUNTY OF SAN MATEO – CIVIL DIVISION 16 17 In re Matter of: Case No. 19-CIV-03974 18 MARY ELIZABETH LEMASTERS, 19 PROPOSED STATEMENT OF THE Plaintiff, CASE 20 v. 21 Judge: Hon. Nancy L. Fineman PAUL FRANCIS DENINGER, 22 Department: 4 Defendant, 23 24 PROPOSED STATEMENT OF THE CASE 25 In this case, Ms. LeMasters contends that Mr. Deninger and she were in a loving, committed 26 relationship when he asked her to leave her employment and live with him, and in exchange he would 27 cover all of her living expenses, share in the increase in value of his assets, and buy a house in Carmel 28 1 JOINT STATEMENT OF THE CASE 1 and condominium on the Peninsula, which they would own jointly. Mr. Deninger contends that no such 2 offers were ever made to Ms. LeMasters. Mr. Deninger contends that he told Ms. LeMasters that he 3 would provide financial support to Ms. LeMasters to enable her to complete a professionally produced 4 music album. 5 Ms. LeMasters and Mr. Deninger met in 2005 at their place of employment: Broadview 6 International. Later Broadview merged with Jeffries and Company and both parties continued to work 7 there until 2010. In addition to her job at Jeffries, Ms. LeMasters worked as a singer who performed at 8 local venues starting in or around 1995. Ms. LeMasters and Mr. Deninger continued their romantic 9 relationship until 2017. 10 Ms. LeMasters contends that the parties’ contract was stated orally, that there are writings which 11 corroborate it, and that their contract was also implied by the parties’ conduct. Mr. Deninger contends 12 that the parties never contemplated a contract and that the financial support he provided Ms. LeMasters 13 came in the form of gifts. 14 Ms. LeMasters contends that both parties lived in California and in Massachusetts during their 15 relationship. Mr. Deninger contends that he has been a resident of Massachusetts his entire life and that 16 he primarily saw Ms. LeMasters when he travelled to California. 17 In November of 2010 Ms. LeMasters left her job at Jefferies. Ms. LeMasters alleges that her 18 decision to resign from her position at Jefferies was because Mr. Deninger wanted her to leave her 19 position and did not want her to work. Mr. Deninger contends that he and Ms. LeMasters never entered 20 into a contract that induced her to leave her job at Jeffries. Mr. Deninger contends that he told Ms. 21 LeMasters that he would provide financial support to Ms. LeMasters to enable her to complete a 22 professionally produced music album. 23 Between February 2011 and 2018, Mr. Deninger rented various homes in the Bay Area at which they both stayed. 24 From 2011 through March of 2019, Mr. Deninger paid for Ms. LeMasters’ living expenses and 25 all costs associated with the production and promotion of her music, which he contends averaged 26 between $6,000 – $7,000 per month. Ms. LeMasters contends that Mr. Deninger paid on average 27 28 2 JOINT STATEMENT OF THE CASE 1 approximately $15,000 per month for all of her expenses and additional money for her artistic 2 endeavors. 3 Ms. LeMasters contends that Mr. Deninger breached their contract when he stopped paying her 4 expenses. Mr. Deninger contends that he followed through on the gifts to Ms. LeMasters so she could 5 finish her music album. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 JOINT STATEMENT OF THE CASE