Document for ANTHONY FUSCHILLO, ET AL. VS. JAMES B. ROWLAND III, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 07/30/2019 04:23 PM Sherri R. Carter, Executive Officer/Clerk of Court, by N. Chambers,Deputy Clerk




                      1     Michael D. Finley, Esq. #169195
                            Law Offices of Michael D. Finley
                      2     28212 Kelly Johnson Parkway, Suite 195
                            Valencia, CA 91355-5088
                      3     661.964.0444

                      4     Attorney for Plaintiffs Anthony Fuschillo and Alicia Fuschillo

                      5

                      6                                                 SUPERIOR COURT OF CALIFORNIA

                      7                                                        COUNTY OF LOS ANGELES

                      8

                      9     ANTHONY FUSCHILLO, et al.,                                                  Case No.: PC058794

                    10                                                    Plaintiffs                    PLAINTIFFS' MOTION FOR LEAVE TO
                                                                                                        AMEND COMPLAINT
                    11                                   VS.
                                                                                                        DATE:                 10/18/2019
                    12      JAMES 8. ROWLAND Ill, et al.,                                               TIME:                 8:30 A.M.
                                                                                                        DEPT:                F47
                    13                                                    Defendants

                    14      AND RELATED CROSS-ACTION                                                    RESERVATION ID # 668249536387

                    15      TO THE HONORABLE COURT, TO ALL PARTIES HEREIN, AND TO THEIR COUNSEL
                    16      OF RECORD:
                    17                  PLEASE TAKE NOTICE that on October 18, 2019, at 8:30 a.in. in Department F-47 o
                    18      the Superior Court located at 9425 Pen field Avenue, Chatsworth, CA 91311, Plaintiffs Anthon
                    19      Fuschillo and Alicia Fuschillo will move this court for leave to amend their Complaint (originall
                    20      filed 9/20/2018) on the following grounds:
                    21                  1.          Plaintiffs' counsel recently determined that the initial description of the area oflan
                    22      in question for the original first, second, and third causes of action was not accurately described,
                    23      and that an amendment was necessary in order to clarify the area of land in question, which in th
                    24      new proposed first amended complaint is done by attaching and incorporating by reference
                    25
                            professional survey. New incidents have recently occurred between the plaintiffs and th
                    26      defendants herein, in which the defendants have violated this court's injunctions and cause
                    27      considerable damage to the plaintiffs' property, as outlined in the proposed first amende
                    28      complaint. In addition, plaintiffs have discovered that the defendants have committed additiona

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                                                  PLAINTIFFS' MOTION FOR LEAVE TO AMEND COMPLAINT