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1 DUANE WILLIAMS
4195 Chino Hills Parkway #478-Chino Hills, CA 91709
2 951-505-2503
monicaguilleimin@gmail.com
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4 MONICA R. GUILLEMIN WILLIAMS, J.D., AND
DUANE WILLIAMS, IN PRO PER
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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MONICA R. GUILLEMIN WILLIAMS, J. D., ) Case No.: BC 607338
11 DUANE WILLIAMS
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Plaintiff(s),
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) Judge: Hon. Mel Red Recana
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vs.
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14 BILL WINSTON, SL HARE CAPITAL
) Dept.: 45
INVESTMENT BANKERS, INC, MANSIONS ) Room: 529
15 ON STOCKER LLC
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) MOTION TO AMEND
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) COMPLAINT
JOHN MCDONALD, JOHN MCDONALD,
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17 DBA, JOHN MCDONALD, INC. JOHN
WILLIAMS V WINSTON et. al
MCDONALD FAMILY TRUST, IMPERIAL ))
18 PROMENADE, LLC, IMPERIAL CENTURY )
PARTNERS, LLC, J.W.M. INVESTMENT,
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19 INC., ANGELES FIELD, DBA, and
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SYNGON L HARE, SL HARE CAPITAL
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21 INVESTMENT BANKERS, INC., MANSIONS )
ON STOCKER LLC
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DOES 1-50, INCLUSIVE
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)))
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TO:
26 PLEASE TAKE NOTICE that on January 19, 2016 at Los Angeles Superior Court, Central
27 Judicial District 111 North Hill Street, Los Angeles, CA 90012, Stanley Mosk Courthouse in
28 Department 45, Room 529 Plaintiffs Monica R. Guillemin and Duane Williams will and
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PLAINTIFF MONICA R. GUILLEMIN, J.D., AND DUANE WILLIAMS MOTION TO AMEND COMPLAINT
1 hereby does move the Court file an amended Complaint in this action. Motion to court to
2 allow Plaintiff to exercise first right to amend complaint filed January 14, 2016
This motion is made pursuant to California Code of Civil Procedure 473 (a) and
4 575 on the grounds of court to allow Plaintiff to exercise first right to amend complaint
5 filed January 14, 2016 to correct an inadvertent misstatements of facts, and to add
6 additional damages for prayers of relief, and add injunction relief to original complaint and
7 the established policy in California liberally permitting amendments at any stage of the
8 proceeding.
This motion is based upon this notice, the attached Declaration of Duane Williams
10 and Exhibits thereto, the records and files of this action, and upon such oral and
11 documentary evidence as may be presented upon the hearing of the motion.
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A.
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B.
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C.
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A.
The misstatement of fact in the original pleading proposed to be corrected are facts
regarding the agreement with Ricard, starting on page 15 line 15, paragraph number 60
21 and 61 ending on line 23, page 15.
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23 The original complaint states:
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60. April, 2011, Winston recommended Williams provide Andrea Ricard (Ricard),
Winstons neighbor and long-time friend, the information on the IPP. Pursuit to
Winstons recommendation and under Winstons direction, Williams provided
the investment package to Ricard, and McDonald also executed a Promissory
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PLAINTIFF MONICA R. GUILLEMIN, J.D., AND DUANE WILLIAMS MOTION TO AMEND COMPLAINT
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Partners, LLC also described in the Investors Package. Under the terms of
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Ricard.
Allegation proposed to be amended and therefore added to the Williams v
9 Winston First Amended Complaint start on page 15, line 15 paragraph number 60,
10 61, 62, 63, 64, 65, 66 thereby increasing the First Amended Complaint by 5 new paragraph
11 which now end on page 16 line 11 and are:
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60. April, 2011, Winston recommended Williams provide Andrea Ricard (Ricard),
Winstons neighbor and long-time friend, the information on the IPP. Pursuit to
Winstons recommendation and under Winstons direction, Williams provided
the investment package to Ricard.
61. At McDonald & Winston direction, Williams typed the document for
Defendants.
62. McDonald & Winston maintained there was an urgency for Ricards monetary
contribution towards the IPP project and claimed McDonald was out of town
and unable to provide McDonalds signature.
63. Defendants insisted Williams proceed as a messenger on Winston and
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64. Williams collected a $30,000 check from Ricard with Defendants oral promise
of remitting $45,000 back to Williams for Ricard pending success and
financing on the IPP. (Exhibit 10).
65. In the document McDonald also represented himself as a member and partner
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of Imperial Partners, LLC also described in the Investors Package. Under the
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7 The original damages for prayers of relief on page 37 line 19 and starting at line i pray for:
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10 Total: 222,510 (two hundred twenty-two thousand, five hundred ten dollars)
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22 Censorship of Syngon Hare and Bill Winston.
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24 The new proposed prayers for relief to be added to the Williams v Winston
First Amended Complaint starts on page 37, line 25, letter j, and reflects an additional
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$300,000 for damages resulting from loss of time for employment due to pain and
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suffering, and requests the court to issue permanent injunctions on Defendants
27 participation in development or redevelopment projects as specified in complaint.
28 Furthermore Plaintiffs pray the court order each defendant to disclose current and future
PLAINTIFF MONICA R. GUILLEMIN, J.D., AND DUANE WILLIAMS MOTION TO AMEND COMPLAINT
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5 Total: 522,510 (five hundred twenty-two thousand, five hundred ten dollars)
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to punish and deter these Defendants and others from similar malicious,
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court current and future pending public or private commercial real estate
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projects.
c. Order each defendant to disclose, disseminate, and make available to the
United States Department of Justice Real Estate Commission for purposes
of reporting fraud.
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PLAINTIFF MONICA R. GUILLEMIN, J.D., AND DUANE WILLIAMS MOTION TO AMEND COMPLAINT
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Respectably Submitted
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18 Dated: January 19, 2016
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___________________________________
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___________________________________
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DUANE WILLIAMS
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Declaration attached
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PLAINTIFF MONICA R. GUILLEMIN, J.D., AND DUANE WILLIAMS MOTION TO AMEND COMPLAINT
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PLAINTIFF MONICA R. GUILLEMIN, J.D., AND DUANE WILLIAMS MOTION TO AMEND COMPLAINT