Case 2:18-cv-02217-SJO-FFM Document 20 Filed 04/02/18 Page 1 of 2 Page ID #:224

1 BLAKELY LAW GROUP

BRENT H. BLAKELY (CA Bar No. 157292)
1334 Parkview Avenue, Suite 280
3 Manhattan Beach, California 90266
Telephone: (310) 546-7400
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Facsimile: (310) 546-7401
5 Email:
BBlakely@BlakelyLawGroup.com
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Attorneys for Defendant
7 ESSENTIAL CONSULTANTS, LLC
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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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11 STEPHANIE CLIFFORD a.k.a.
12 STORMY DANIELS a.k.a. PEGGY

PETERSON, an individual,

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Plaintiff,

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15

v.

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DONALD J. TRUMP a.k.a. DAVID
17 DENNISON, an individual,
18 ESSENTIAL CONSULTANTS, LLC, a
Delaware Limited Liability Company,
19 and DOES 1 through 10, inclusive,
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Defendants.

Case No. 2:18-CV-02217-SJO-FFM
DEFENDANT ESSENTIAL
CONSULTANT, LLC’S
NOTICE OF MOTION AND
MOTION TO COMPEL
ARBITRATION
Assigned for All Purposes to the
Hon. S. James Otero
Date:
April 30, 2018
Time:
10:00 a.m.
Location: 350 West 1st Street
Courtroom 10C, 10th Floor
Los Angeles, CA 90012
Action Filed: March 6, 2018

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NOTICE OF MOTION AND MOTION TO COMPEL ARBITRATION

 Case 2:18-cv-02217-SJO-FFM Document 20 Filed 04/02/18 Page 2 of 2 Page ID #:225

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TO THE COURT, ALL PARTIES AND COUNSEL OF RECORD:

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PLEASE TAKE NOTICE that on April 30, 2018, at 10:00 a.m. or as soon

3 thereafter as the matter may be heard in Courtroom 10C, located at the United States
4 District Court, 350 West 1st Street, Los Angeles, California 90012, the Honorable S.
5 James Otero presiding, Defendant Essential Consultants, LLC (“EC”) will move and
6 hereby does move for an order compelling Plaintiff Stephanie Clifford a.k.a. Stormy
7 Daniels a.k.a. Peggy Peterson (“Clifford” or “Plaintiff”) to arbitrate any and all
8 disputes arising under the written Confidential Settlement Agreement and Mutual
9 Release entered into by EC and Clifford on or about October 28, 2016 (the
10 “Settlement Agreement”), including but not limited to the first cause of action pleaded
11 in Plaintiff’s First Amended Complaint (“FAC”) in this action. Such arbitration
12 should be ordered to occur in the currently pending arbitration between the parties
13 with ADR Services, Inc. (“ADRS”) in Los Angeles, California, pursuant to the written
14 agreements of the parties. EC will also move and hereby does move for an order
15 staying the first cause of action in the FAC pending the outcome of the arbitration.
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This motion will be and is based on this Notice, the accompanying

17 Memorandum of Points and Authorities, the accompanying Declarations of Michael
18 D. Cohen and Brent H. Blakely (with exhibits), the anticipated reply papers, all other
19 papers on file in this action, all materials that may be properly considered in
20 connection with this motion, and oral argument at the hearing. This motion is made
21 following the conference of counsel pursuant to L.R. 7-3, which took place on March
22 21, 2018.
23 Dated: April 2, 2018

BLAKELY LAW GROUP

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By: /s/ Brent H. Blakely
BRENT H. BLAKELY
Attorneys for Defendant ESSENTIAL
CONSULTANTS, LLC

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-2NOTICE OF MOTION AND MOTION TO COMPEL ARBITRATION