HomeMy WebLinkAbout20260310_Declaration of Attorney Sean Morrissey ISO Application- City_City v Smith
DECLARATION OF ATTORNEY SEAN E. MORRISSEY
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J. CHRISTINE DIETRICK, SBN 206539
City Attorney, City of San Luis Obispo
MATTHEW R. SILVER, SBN 245528
MSilver@CivicaLaw.com
SEAN E. MORRISSEY, SBN 297371
SMorrissey@CivicaLaw.com
NICHOLAS GARCÉS, SBN 273277
NGarces@CivicaLaw.com
CIVICA LAW GROUP APC
4000 Barranca Parkway, Suite 250, PMB #782
Irvine, California 92604
Phone: 949-592-0165
Fax: 949-335-1701
Attorneys for Plaintiffs
City of San Luis Obispo, and
People of the State of California
Exempt from filing fees pursuant to
Government Code section 6103.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN LUIS OBISPO
THE PEOPLE OF THE STATE OF
CALIFORNIA, EX REL, J. CHRISTINE
DIETRICK, CITY ATTORNEY OF THE CITY
OF SAN LUIS OBISPO; and,
THE CITY OF SAN LUIS OBISPO, a California
municipal corporation,
Plaintiff,
v.
LAUREL CREEK, LP, a California Limited
Partnership;
LAUREL CREEK, II, L.P., a Delaware limited
partnership;
1160 LAUREL LANE, LLC, a California limited
liability company;
PATRICK N. SMITH a/k/a PATRICK SMITH,
an individual;
SMITH AND COMPANY, A REAL ESTATE
INVESTMENT DEVELOPMENT
CORPORATION, a California corporation;
PATRICK N. SMITH a/k/a PATRICK SMITH,
AS TRUSTEE OF THE PATRICK N SMITH
2004 LIVING TRUST;
Case Number: 25CV-0667
Action Filed: October 16, 2025
Judge: Hon. Tana L. Coates
Dept.: 4
DECLARATION OF ATTORNEY SEAN E.
MORRISSEY IN SUPPORT OF PLAINTIFF
CITY OF SAN LUIS OBISPO’S EX PARTE
APPLICATION FOR APPOINTMENT OF
RECEIVER, OR ALTERNATIVELY, FOR
AN ORDER SHORTENING TIME
Filed concurrently with:
1. Ex Parte Receivership Application;
2. Memorandum of Points and Authorities;
3. Declaration of Code Enforcement Supervisor
John Mezzapesa;
4. Declaration of Supervising Building
Inspector Trevor Nelson;
5. Declaration of Fire Marshal Josh Daniel
6. Declaration of Proposed Receiver Kevin A.
Singer;
7. Request for Judicial Notice;
8. Appendix of Exhibits;
9. [Proposed] Receivership Order;
10. Proof of Service.
ELECTRONICALLY FILED3/10/2026 9:29 AM
DECLARATION OF ATTORNEY SEAN E. MORRISSEY
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CPIF CALIFORNIA LLC, a California limited
liability company;
CPIF LAUREL CREEK, LLC, a Washington
limited liability company;
ALL WALL SYSTEMS, INC., a Delaware
corporation;
AMERICAN RIVIERA BANK, a California
corporation;
ARNOLD BUILDERS, INC., a California
corporation;
B & B CONSTRUCTION CLEANUP INC., a
California corporation;
BLUE STEEL CONCRETE, LLC, a California
limited liability company;
COAST ENGINEERING & DESIGN INC., a
California corporation;
CONSOLIDATED ELECTRICAL
DISTRIBUTORS, INC., d/b/a CALIFORNIA
ELECTRICAL SUPPLY, a Delaware corporation;
CULBERT PLUMBING INC., F/K/A CULBERT
CONSTRUCTION AND PLUMBING, INC., a
California stock corporation;
EMPIRE ELECTRICAL SOLUTIONS, INC., a
California corporation;
FAMCON PIPE & SUPPLY, INC., a California
corporation;
G W SURFACES, a California corporation;
HOMER T. HAYWARD LUMBER CO ., a
California corporation;
KIRK CONSTRUCTION, a California
corporation;
LC LENDERS, LLC, a Delaware limited liability
company;
LW CONSTRUCTION, INC., a California
corporation;
MAHOGANY CONSTRUCTION, INC., a
California corporation;
NOLAN CHURCH DOING BUSINESS AS
COLORTRENDS PAINTING & DECORATING,
a California sole ownership or proprietor business;
SCHINDLER ELEVATOR CORPORATION, a
Delaware corporation;
THE SHERWIN-WILLIAMS COMPANY, an
Ohio corporation;
UNITED RENTALS (NORTH AMERICA) INC.,
a Delaware corporation;
US AIR CONDITIONING DISTRIBUTORS,
LLC, a Delaware limited liability company; and,
DOES 1 through 50, inclusive,
Defendants.
Hearing:
Date: March 12, 2026
Time: 8:30 a.m.
Dept: 4
Trial: None Set
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DECLARATION OF ATTORNEY SEAN E. MORRISSEY
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DECLARATION OF ATTORNEY SEAN E. MORRISSEY IN SUPPORT OF PLAINTIFF
CITY OF SAN CLEMENTE’S EX PARTE APPLICATION FOR APPOINTMENT OF
RECEIVER, OR ALTERNATIVELY, FOR AN ORDER SHORTENING TIME
I, Sean E. Morrissey, declare as follows:
1. I am a competent adult over the age of 18 years and have personal knowledge of the
following facts which I could and would testify to if called as a witness. I am an attorney licensed to
practice law in the State of California. I am an attorney with the law firm of Civica Law Group, APC
(“Civica”), and I represent Plaintiff City of San Luis Obispo (“City”) in its Verified Complaint for
Violation of Health & Safety Code and Receivership (“Complaint”) regarding the parcel of real property
located at 1150 Laurel Lane, San Luis Obispo, California, 93401, Assessor’s Parcel Numbers 004-962-
036, 004-962-037, and 004-962-042 (“Subject Property”), in the Superior Court of California, County
of San Luis Obispo, case number 25CV-0667 (“Receivership Action”). I submit this declaration in
support of the City’s Ex Parte Application for Appointment of Receiver, or Alternatively, for an Order
Shortening Time (“Receivership Application”).
Title Information for Subject Property
2. The record title owners of the Subject Property are Defendant Laurel Creek L.P. (“Defendant
Laurel Creek LP”) and Defendant Laurel Creek II, L.P. (“Defendant Laurel Creek II LP”) (collectively,
“Defendant Owners” or “Owners”), pursuant to a Grant Deed recorded June 24, 2020, in the San Luis
Obispo County Record’s Office (“SLO Official Records”), with record number 2020031255 (“Grant
Deed 1”), and a Grant Deed recorded on April 1, 2021, in SLO Official Records, with record number
2021024686 (“Grant Deed 2”), respectively (collectively “Grant Deeds”). True and correct copies of
the Grant Deeds are attached as Exhibit 1 to the Appendix of Exhibits and are incorporated herein.
3. Based on information and belief, Defendant 1160 Laurel Lane, LLC (“Defendant 1160
Laurel Lane”) is and at all relevant times herein was a general partner of and took actions in its
representative capacity as an agent for both Defendant Laurel Creek LP and Defendant Laurel Creek II
LP in relation to the Subject Property.
4. Based on information and belief, Defendant Patrick N. Smith, also known as Patrick Smith
(“Defendant P. Smith”) is responsible for Defendant Owners’ actions leading to the violations and
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conditions at issue in this action and this application.
5. Aside from title records conferring ownership, the Subject Property contains many other
documents recorded on title, which largely include liens from some money lenders securing their loans
on title, some which lent money on construction projects, and many mechanic’s liens from contractors
who performed work at the Subject Property for Defendant Owners, or as subcontractors. The remainder
of this “Title Information for Subject Property” section of my declaration describes the recorded interests
for each of the named parties who have appeared in this Action and have not been dismissed or have had
default entered against them.
6. Based on information and belief, Defendant Smith and Company, a Real Estate Investment
Development Corporation (“Defendant Smith and Co.”), holds some recorded interest in the Subject
Property including but not limited to, a “Claim of Mechanics Lien” recorded February 6, 2024, with
document number 2024-003206, and “Amended Claim of Mechanics Lien” recorded September 12,
2024, with instrument number 2024025742, of SLO Official Records.
7. Based on information and belief, Defendant Patrick N. Smith a/k/a Patrick Smith, as Trustee
of the Patrick N. Smith 2004 Living Trust (“Defendant P. Smith 2004 Trust”), through its trustee Patrick
N. Smith (“Trustee Patrick N. Smith”), holds some recorded interest in the Subject Property including
but not limited to, a “Memorandum of Loan Modification Agreement,” as a pledgor to an agreement to
modify terms of a deed of trust, recorded July 5, 2022, with document number 2022-027658, of SLO
Official Records.
8. Based on information and belief, Defendant CPIF California, LLC (“Defendant CPIF CA”),
holds a recorded interest in the Subject Property pursuant to a Deed of Trust, Assignment of Leases,
Security Agreement And Fixture Filing, dated March 31, 2021, and recorded April 1, 2021, in the SLO
Official Records with document number 2021-024690; a Deed of Trust, Assignment of Leases, Security
Agreement And Fixture Filing, recorded April 1, 2021, in the SLO Official Records with document
number 2021-0244687; a “UCC-1 Financing Statement” as recorded on April 1, 2021, with document
number 2021-024688; a “UCC-1 Financing Statement” as recorded on April 1, 2021, with document
number 2021-024691; a UCC Financing Statement” as recorded on July 5, 2022, with document number
2022-027659; a “Memorandum of Loan Modification Agreement,” recorded July 5, 2022, with
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DECLARATION OF ATTORNEY SEAN E. MORRISSEY
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document number 2022-027658; and, a “Modification of Deed of Trust, Substitution of Trustee, and
Deed of Partial Reconveyance,” recorded August 08, 2023, with document number 2023023592.
9. Based on information and belief, Defendant CPIF Laurel Creek, LLC (“Defendant CPIF
LC”), holds a recorded interest in the Subject Property pursuant to a Deed of Trust, Assignment of
Leases, Security Agreement And Fixture Filing recorded August 22, 2024, in the SLO Official Records
with document number 2024-023608; Deed of Trust, Assignment of Leases, Security Agreement And
Fixture Filing recorded August 22, 2024, in the SLO Official Records with document number 2024-
023609; a “Memorandum of Loan Modification Agreement,” recorded July 5, 2022, with document
number 2022-027658; a “UCC-3 Financing Statement Amendment” recorded August 22, 2024, with
document number 2024023610, and a “UCC-3 Financing Statement Amendment” recorded August 22,
2024, with document number 2024023611.
10. Defendant CPIF CA and Defendant CPIF LC, lenders who secured their loans on the Subject
Property through various recorded instruments on title, shall collectively hereafter be referred to as
“CPIF Defendants” or “Lender Defendants”).
11. Based on my review of litigation guarantees and title records for the Subject Property,
Arnold Builders, Inc. (“Defendant Arnold Builders”) holds some recorded interest in the Subject
Property including but not limited to a “Claim of Mechanics Lien” recorded October 11, 2023, with
document number 2023-029784, of SLO Official Records.
12. Based on information and belief, Defendant B & B Construction Cleanup Inc., (“Defendant
B&B Construction”), holds some recorded interest in the Subject Property including but not limited to a
claim of mechanics lien recorded July 26, 2023, with document number 2023021574, and a “Notice of
Pendency of Action” recorded December 8, 2023, with document number 2023-036584, of SLO Official
Records.
13. Based on information and belief, Defendant Homer T. Hayward Lumber Co. (“Defendant
Hayward Lumber”), holds a recorded interest in the Subject Property including but not limited to a
“Mechanics Lien” and “Claim Lein” each recorded October 10, 2023, with document number 2023-
029756 and 2023-029757, respectively, and two Amended Mechanics Liens each recorded October 10,
2023, with document numbers 2023-029897 and 2023-0299916, of SLO Official Records.
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DECLARATION OF ATTORNEY SEAN E. MORRISSEY
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14. Based on information and belief, Defendant LC Lenders, LLC (“Defendant LC Lenders”),
holds some recorded interest in the Subject Property including but not limited to an “Assignment of Deed
of Trust and Security Instruments” from Defendant American Riviera Bank, recorded January 13, 2025,
with document number 2025-000942, of SLO Official Records.
15. Based on my review of litigation guarantees and title records for the Subject Property,
Defendant Nolan Church doing business as Colortrends Painting & Decorating (“Defendant N.
Church/Colortrends”), holds some recorded interest in the Subject Property including but not limited to
a “Claim of Mechanics Lien” recorded November 21, 2023, with document number 2023-035119, of
SLO Official Records.
City’s Satisfaction of Procedural Prerequisites for Relief Sought in Receivership Action
16. Pursuant to Health and Safety Code (“HSC”) sections 17980 and 17980.6, on September 2,
2025, the City issued a Notice and Order to Repair or Abate (“N&O”) to Defendant Owners and all
interested parties with a recorded interest in the Subject Property (and additional potentially interested
parties) citing 274 violations of law on the Subject Property and ordering all violations on the Subject
Property to be corrected or abated within 30 days, which was October 2, 2025 (“Compliance Deadline”).
17. The N&O detailed all identified violations, described the dangers attendant to each violation,
and indicated what steps needed to be taken to correct each violation. The N&O also noted that failure
to comply prior to the Compliance Deadline would potentially result in further legal action, including
the appointment of a court receiver.
18. The N&O was mailed to the Defendant Owners and all interested parties with a recorded
interest in the Subject Property via first class mail and certified mail, return receipt requested, and also
posted on the Subject Property on September 2, 2025.
19. On September 8, 2025, the City recorded the N&O on title to the Subject Property via a
Notice of Pendency of Nuisance Abatement Action (“NoP”) to give further notice to all interested parties
of the City’s enforcement efforts regarding the Subject Property, as well as the violations present thereon.
A true and correct copy of the NoP with the N&O is attached as Exhibit 11 to the Appendix of Exhibits
and is incorporated herein.
20. After Defendant Owners and all other interested parties failed to comply with the N&O, the
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DECLARATION OF ATTORNEY SEAN E. MORRISSEY
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City filed its Complaint on October 16, 2025, seeking, among other relief, an order appointing a court
receiver to take possession and control of the Subject Property to abate the substantially dangerous and
substandard conditions present thereon pursuant to HSC section 17980.7, subdivision (c).
21. Prior to filing the Action, the City provided Defendant Owners and other interested parties
the required three days’ advanced notice (“3-Day Notice”) of the City’s intent to file this Action.
Pursuant to the HSC section 17980.7, subdivision (c), on October 3, 2025, the City served the 3-Day
Notice by first class mail and by posting it on the Subject Property. True and correct copies of photos
of the posting the 3-Day Notice at the Subject Property are attached as Exhibit 12 with the photos taken
of the Subject Property on that day to the Appendix of Exhibits and are incorporated herein. True and
correct copies of the 3-Day Notice and Proofs of Service are attached as Exhibit 13 to the Appendix of
Exhibits and are incorporated herein.
22. Despite having been provided more than a reasonable time and adequate opportunity to
rehabilitate the Subject Property––over 185 days since the N&O was issued and well over four years
since code enforcement efforts began––Defendant Owners and any other interested party have failed
to fully rehabilitate the Subject Property and bring it into compliance with State and local laws.
23. As such, the City has no other viable option and is therefore forced to seek receivership relief
to halt the substantial dangers on the Subject Property as detailed in the concurrently filed Declarations
of Code Enforcement Supervisor John Mezzapesa, Building Inspector Trevor Nelson, and Fire Marshall
Josh Daniel.
24. The City has complied with the procedural prerequisites for the appointment of a receiver
over the Subject Property. Defendant Owners were issued the N&O in accordance with HSC section
17980.6, and the City afforded Defendant Owners reasonable time to rehabilitate the Subject Property
pursuant to HSC section 17980, subdivision (a), and 17980.7.
Defaulted Defendants
25. The following Defendants failed to file a response to the City’s Complaint and Default has
been entered against them: All Wall Systems, Inc; Blue Steel Concrete, LLC; Empire Electrical
Solutions, Inc.; G W Surfaces; LW Construction, Inc.; the Sherwin-Williams Company; and, United
Rentals (North America) Inc. (collectively “Defaulted Defendants”). True and correct copies of the
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Entries of Defaults are attached as Exhibit 17 to the Appendix of Exhibits and are incorporated herein.
Dismissed Defendants
26. The following Defendants have been dismissed from the action: American Riviera Bank;
Coast Engineering and Design Inc.; Consolidated Electrical Distributors, Inc., d/b/a California Electrical
Supply; Culbert Plumbing Inc., f/k/a Culbert Construction and Plumbing Inc. f/k/a Culbert Construction
and Plumbing, Inc.; Famcon Pipe and Supply , Inc.; Kirk Construction; Mahogany Construction, Inc.;
and, US Air Conditioning Distributors, LLC (collectively, “Dismissed Defendants”). True and correct
copies of the Entries of Dismissal are attached as Exhibit 18 to the Appendix of Exhibits and are
incorporated herein.
Ex Parte Notice
27. On March 9, 2026, I provided notice of the City’s Ex Parte Receivership Application hearing
(“Notice of Hearing”) via email to all Defendants who have not had default entered against them or who
have not been dismissed at 2:11 p.m., in advance to the hearing set for March 12, 2026. The Notice of
Hearing provided with specificity the nature of the relief to be requested and the date, time, and place
for the presentation of the City’s Ex Parte Receivership Application and also sought to determine
whether any Defendants will appear and/or oppose the Ex Parte Receivership Application pursuant to
California Rules of Court, rule 3.1204(a). Although, as of my signing of this Declaration, I am unaware
which, if any, Defendants will appear or contest the matter. A true and correct copy of the March 9,
2026, Ex Parte Notice is attached as Exhibit 16 to the Appendix of Exhibits and is incorporated herein.
28. No notice is required or has been given to the Dismissed Defendants: American Riviera
Bank (dismissed 12/10/2026); Coast Engineering and Design Inc. (dismissed 12/10/2026); Consolidated
Electrical Distributors, Inc., d/b/a California Electrical Supply (dismissed 12/10/2026); Culbert
Plumbing Inc., f/k/a Culbert Construction and Plumbing Inc. f/k/a Culbert Construction and Plumbing,
Inc. (dismissed 2/24/2026); Famcon Pipe and Supply , Inc. (dismissed 12/10/2026); Kirk Construction
(dismissed 2/18/2026); Mahogany Construction, Inc. (dismissed 3/2/2026); and, US Air Conditioning
Distributors, LLC (dismissed 12/10/2026).
29. No notice is required or has been given to the Defaulted Defendants: All Wall Systems,
Inc. (on 2/26/2026); Blue Steel Concrete, LLC (on 1/9/2026); Empire Electrical Solutions, Inc. (on
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1/9/2026); G W Surfaces (on 2/26/2026); LW Construction, Inc. (on 1/9/2026); the Sherwin-Williams
Company (on 1/9/2026), United Rentals (North America) Inc. (on 1/9/2026).
Ex Parte Urgency to Support Receivership Application and Notice
30. Before filing the present Receivership Application, our offices confirmed with the San Luis
Obispo County Superior Court that Department 4 is currently setting hearings in August 2026 for
regularly noticed motions, which is over four (4) months away. Given the immediate dangers to the
community, including neighbors and first responders, that the Subject Property poses as detailed
extensively in the concurrently filed declarations of Code Enforcement Supervisor John Mezzapesa and
Building Inspector Trevor Nelson, the City and its community stand to suffer immediate and irreparable
risk of danger from the red tagged and condemned Subject Property with incomplete or lacking fire
safety requirements, systems, and safeguards, and many dangerous, substandard, and hazardous
conditions caused by Defendant Owners’ pattern of unpermitted construction, unauthorized occupancy,
and building activity that compromises public safety.
31. The City provided more than two days’ notice of this Receivership Application in an
abundance of caution as detailed below.
32. The known contact information for each of the Defendants is:
a. Defendant Laurel Creek LP. Their last known addresses are 505 Bath Street, Santa
Barbara, California 93101; c/o 1160 Laurel Lane, LLC, 505 Bath Street, Santa Barbara,
California 93101; c/o Capital Corporate Services, Inc., 455 Mall 217, Sacramento,
California 95814; and through their attorneys Foley Bezek Behle & Curtis, LLP, Attn:
Robert A. Curtis, Kevin D. Gamarnik, Jordan A. Liebman, 15 W. Carrillo Street, Santa
Barbara, CA 93101; Phone#: 805-962-9495, and emails: rcurtis@foleybezek.com,
kgamarnik@foleybezek.com, and liebman@foleybezek.com.
b. Defendants Laurel Creek II LP. Their last known addresses are 505 Bath Street, Santa
Barbara, California 93101; c/o 1160 Laurel Lane, LLC, 505 Bath Street, Santa Barbara,
California 93101; c/o Capital Corporate Services, Inc., 455 Mall 217, Sacramento,
California 95814; and through their attorneys Foley Bezek Behle & Curtis, LLP, Attn:
Robert A. Curtis, Kevin D. Gamarnik, Jordan A. Liebman, 15 W. Carrillo Street, Santa
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Barbara, CA 93101; Phone#: 805-962-9495, and emails: rcurtis@foleybezek.com,
kgamarnik@foleybezek.com, and liebman@foleybezek.com.
c. Defendant 1160 Laurel Lane LLC. Its last known address is c/o Patrick N. Smith 505
Bath Street, Santa Barbara, California 93101; and through their attorneys Foley Bezek
Behle & Curtis, LLP, Attn: Robert A. Curtis, Kevin D. Gamarnik, Jordan A. Liebman,
15 W. Carrillo Street, Santa Barbara, CA 93101; Phone#: 805-962-9495, and emails:
rcurtis@foleybezek.com, kgamarnik@foleybezek.com, and liebman@foleybezek.com.
d. Patrick N. Smith a/k/a Patrick Smith. His last known address is 505 Bath Street, Santa
Barbara, California 93101; and through his attorneys Foley Bezek Behle & Curtis, LLP,
Attn: Robert A. Curtis, Kevin D. Gamarnik, Jordan A. Liebman, 15 W. Carrillo Street,
Santa Barbara, CA 93101; Phone#: 805-962-9495, and emails: rcurtis@foleybezek.com,
kgamarnik@foleybezek.com, and liebman@foleybezek.com.
e. Patrick N. Smith, as trustee of the Patrick N. Smith 2004 Living Trust. His last known
address is 505 Bath Street, Santa Barbara, California 93101; and through his attorneys
Foley Bezek Behle & Curtis, LLP, Attn: Robert A. Curtis, Kevin D. Gamarnik, Jordan
A. Liebman, 15 W. Carrillo Street, Santa Barbara, CA 93101; Phone#: 805-962-9495,
and emails: rcurtis@foleybezek.com, kgamarnik@foleybezek.com, and
liebman@foleybezek.com.
f. Smith and Company, A Real estate Investment Development Corporation. Its last known
address is c/o Patrick N. Smith 505 Bath Street, Santa Barbara, California 93101; and
through their attorneys Price, Postel & Parma LLP, Attn: Todd A. Amspoker, Christopher
E. Haskell, and Jeff F. Tchakarov, 200 East. Carrillo Street, Fourth Floor, Santa Barbara,
CA 93101; Phone#: 805-962-0011, and emails: taa@ppplaw.com, ceh@ppplaw.com, and
jft@ppplaw.com.
g. CPIF California LLC. Its last known address is through their attorneys at Duane Morris
LLP, Attn: Meagen E. Leary and Marcus O. Colabianchi, Spear Tower, One Market
Plaza, Suite 2200, San Francisco, CA 94105-1127, Phone#: 415-957-3000, and emails:
MELeary@duanemorris.com, MColabianchi@duanemorris.com.
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h. CPIF Laurel Creek, LLC. Its last known address is through their attorneys at Duane
Morris LLP, Attn: Meagen E. Leary and Marcus O. Colabianchi, Spear Tower, One
Market Plaza, Suite 2200, San Francisco, CA 94105-1127, Phone#: 415-957-3000, and
emails: MELeary@duanemorris.com, MColabianchi@duanemorris.com.
i. Arnold Builders, Inc. Its last known address is 1239 11st Los Osos, CA 93402-1330, and
through its attorneys at The Bailey Law Firm, Attn: Jonas Bailey and Tom Nanney, 1405
Garden Street, Suite 2, San Luis Obispo, CA 93401, Phone#: 805-232-4577, and email
jbailey@jonasbailey.com, tnanney@jonasbailey.com.
j. B&B Construction Cleanup Inc. Its last known address is 2290 Hutton Rd., Nipomo, CA
93444-9448, and through its attorneys at Twitchell and Rice, LLP, Attn: Vincent T.
Martinez, 215 North Lincoln Street, P.O. Box 520, Santa Maria, CA 93456, Phone#: 805-
925-2611, and email vmartinez@twitchellandrice.com, llimone@twitchellandrice.com.
k. Homer T. Hayward Lumber Co. Its last known address is through its attorneys at Noland,
Hamerly, Etienne & Hoss, Attn: Heidi A. Quinn and Anne K. Secker, 333 Salinas Street,
P.O. Box 2510, Salinas, CA 93902-2510, Phone#: 831-424-1414, and email:
HQuinn@nheh.com, ASecker@nheh.com.
l. LC Lenders, LLC. Default was entered against LC Lenders, LLC on 1/15/2026.
Thereafter, a stipulation to set aside default was filed, which the Court granted 2/9/2026,
and LC Lenders, LLC later answered on 02/10/2026. As such its last known address is
c/o Patrick N. Smith 505 Bath Street, Santa Barbara, California 93101; and through their
attorneys Price, Postel & Parma LLP, Attn: Todd A. Amspoker, Christopher E. Haskell,
and Jeff F. Tchakarov, 200 East. Carrillo Street, Fourth Floor, Santa Barbara, CA 93101;
Phone#: 805-962-0011, and emails: taa@ppplaw.com, ceh@ppplaw.com, and
jft@ppplaw.com.
m. Nolan Church doing business as Colortrends Painting and Decorating. His last known
address is 200 S. Dolliver St Spc 1, Pismo Beach, CA 93449-4947 and through his
attorneys at Law Offices of Stephen G. Geihs, Attn: Stephen G. Geihs, 314 Pomeroy
Avenue, Post Office Box 155, Pismo Beach, CA 93448, Phone#: 805-773-4601, and
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n.Defendants Unknown/Doe Defendants are fictitious individuals,so the People and the
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City do not have contact information for Defendants Unknown//Doe Defendants3
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33.Immediate relief is needed.The next available hearing for a regularly noticed motion
6 hearing is not until August,and further harm is likely to occur between now and then.
I declare under penalty of perjury under the laws of the State of California that the foregoing is
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8 true and correct.
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10 Dated:March 9,2026
CITy OF SAN LUIS OBISPO
SEA
Attorney for ainti
PEOPLE OF T STATE OF CALIFORNIA
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DECLARATION OF ATTORNEY SEAN E.MORRISSEY