Motion To Deem Rfas Admitted

Motion

Cal. Super. - 2nd Dist.November 16, 2018

Electronically FILED by Supe] a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 or Court of California, County of Los Angeles on 02/05/2019 12:30 PM Sherri R. Carter, Executive Officer/Clerk of Court, by C. Aquino,Deputy Clerk Aidin D. Ghavimi, Esq. (State Bar No. 305808) Paymon J. Vafa, Esq. (State Bar No. 306059) STARPOINT, LC 1801 Century Park East, 24™ Floor Los Angeles, California 90067 T: (310) 556-9627 F: (424) 255-4035 info@starpointlaw.com Attorneys for Plaintiff, Arad Goudarzi SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES - CENTRAL DISTRICT CASE NO. 18STCV05510 [Assigned to Hon. Christopher Lui ARAD GOUDARZI, an individual Plaintiff, NOTICE OF MOTION AND MOTION TO DEEM THE TRUTH OF MATTERS AND GENUINENESS OF DOCUMENTS SPECIFIED IN REQUESTS FOR ADMISSION SET ONE, ADMITTED AND CONCLUSIVELY] ESTABLISHED; REQUEST FOR ORDER AWARD MONETRY SANCTIONS AGAINST DEFENDANT AND DEFENDANT’S COUNSEL OF RECORD. VS. LESLIE PETTIS; MATTHEW PETTIS; and DOES 1 through 100, inclusive, Defendants. Res. ID: 525308123770 Date: ~~ April 8, 2019 Time: 1:30 PM Dept: 4A Complaint Filed: 11/16/18 Trial Date: 5/15/2018 N r N a N a N a N a N a N a N a N a N a N a N a N a N a N e N a SN N a N a N a N a N e N e TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN PLEASE TAKE NOTICE that on April 8, 2019 at 1:30 a.m. in Department 4A of the Los Angeles Superior Court - Central District located, Spring Street Court, at 312 N. Spring Street, Los Angeles, CA 90012, or as soon thereafter as the matter may be heard, Plaintiff ARAD GOUDARZI (“Plaintiff”) will and hereby moves the Court for an order deeming the truth of all matters specified in 1 PLAINTIFF’S MOTION TO DEEM ADMITTED, REQUEST FOR ADMISSIONS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Request for Admissions, Set One, against defendant MATTHEW PETTIS (“Defendant”), which Plaintiff propounded on December 27, 2018. This motion is made pursuant to C.C.P. § 2033.280 on the grounds that the responding party has failed to timely serve responses to these admissions requests. Notice is additionally given that Plaintiff will request that the Court award monetary sanctions against Defendant and/or Defendant’s counsel of record, and in favor of Plaintiff in the sum of $2,184 pursuant to C.C.P. §§ 2023.010 et seq., and C.C.P. § 2033.280(c). This motion is further based upon this notice; the attached Memorandum of Points and Authorities; the Declaration of Paymon J. Vafa, filed herewith; upon the records and files in this action; and upon such further evidence and argument as may be presented prior to or at the time of hearing on the motion. DATED: February 5, 2019 STARPOINT, LC / AIDIN GHAVIMI, ESQ. PAYMON J. VAFA, ESQ. Attorneys for Plaintiff, ARAD GOUDARZI 2 PLAINTIFF’S MOTION TO DEEM ADMITTED, REQUEST FOR ADMISSIONS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MEMORANDUM OF POINTS AND AUTHORITIES L INTRODUCTION On December 27, 2018, Plaintiff served Requests for Admissions, Set No. One, on defendant MATTHEW PETTIS (“Defendant”) pursuant to C.C.P. §§ 2033.010 et seq. These admissions requests comprised request Nos. 1 through 5, (Exhibit “4” to the Declaration of Paymon J. Vafa served and filed herewith. Responses to these requests for admissions were due on or before January 31, 2019, pursuant to C.C.P. § 2033.250(a), 30 days after service, extended for service by mail, overnight delivery or fax under C.C.P. § 1013. Despite Plaintift’s best efforts in inquiring as to whether Defendant’s counsel of record requires an extension, to Plaintiff’s written discovery responses, Defendant nor his counsel of record failed to respond to Plaintiff’s correspondences in regards to said written discovery. Plaintiff attempted to resolve discovery issue with Defendant to avoid judicial intervention by attempting to meet and confer with Defendant’s counsel. Despite Plaintiff’s efforts, Defendant continues to refuse to provide responses to propounded discovery, forcing Plaintiff to bring this Motion. IL STATEMENT OF FACTS This case involves a simple rear end collision, wherein Defendant Matthew Pettis suddenly and unexpectedly collided with Plaintiff Arad Goudarzi. After several failed attempted to settle the case, Plaintiff was forced to file this instant action. ( See Declaration of Paymon J. Vafa, § 2). Plaintiff propounded basic form interrogatories and special interrogatories, concurrently with requests for production of documents and Requests for Admission, on December 27, 2018. (Vafa Decl., § 3, Exh. 1.) Plaintiff contacted" Defendant’s counsel of record in in order to inquire whether Defendant required an extension or a courtesy copy of interrogatories. Due to failure of Defendant’s !' Plaintiff also contacted Defendant’s insurance carrier, Mercury Insurance Group, on multiple occasions since Defendant was in default by failing to timely file an answer to Plaintiffs Complaint. (Vafa Decl. 2). After multiple correspondences sent to the carrier, Defendant’s counsel of record requests an extension to answer Plaintiff’s complaint. (Vafa Decl. 2.) 3 PLAINTIFF’S MOTION TO DEEM ADMITTED, REQUEST FOR ADMISSIONS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 response to Plaintiff’s courtesy, Defendant refuses to provide any responses forcing Plaintiff to bring this instant motion. (See Vafa Decl., 9 4-6, Exhs. 2-4.) As a result of responding party’s willful refusal to serve answers to these requests for admissions, plaintiff is unable to proceed with meaningful discovery. The information requested is necessary in order to proceed with depositions, and to effectively prosecute/defend this action and prepare for trial in that Plaintiff will not be able to conduct his investigation as to liability and causation for his injuries created by Defendant’s negligence. III. THE COURT IS AUTHORIZED TO ORDER THAT THE TRUTH OF MATTERS SPECIFIED A. General Authority For Motion. “If a party to whom requests for admission have been directed fails to serve a timely response...[t]he requesting party may move for an order that the genuineness of any documents and the truth of any matters specified in the requests be deemed admitted, as well as for a monetary sanction under Chapter 7 (commencing with Section 2023.010).” C.C.P. § 2033.280(b). As a result of plaintiff’s/defendant’s failure to serve a timely response to Requests for Admissions, Set One, plaintiff is entitled to an order that the truth of the matters specified in the requests be deemed admitted. B. Later-Served Responses In Substantial Compliance. “The court shall make this order, unless it finds that the party to whom the requests for admission have been directed has served, before the hearing on the motion, a proposed response to the requests for admission that is in substantial compliance with Section 2033.220. C.C.P. § 2033.280(c). If no responses are served prior to the hearing on this motion, the court has no discretion but to grant this motion and deem the truth of the matters specified admitted. Demyer v. Costa Mesa Mobile Home Estates, 36 Cal. App. 4th 393, 395-96, 42 Cal. Rptr. 2d 260 (4th Dist. 1995) (disapproved on other grounds in Wilcox v. Birtwhistle, 21 Cal. 4th 973, 983, 90 Cal. Rptr. 2d 260, 4 PLAINTIFF’S MOTION TO DEEM ADMITTED, REQUEST FOR ADMISSIONS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 987 P.2d 727 (1999) A deemed admitted order establishes, by judicial fiat, that a nonresponding party has responded to the requests by admitting the truth of all matters contained therein. Wilcox v. Birtwhistle, 21 Cal. 4th 973, 979, 90 Cal. Rptr. 2d 260, 987 P.2d 727 (1999). Any matter admitted in response to a request for admission is conclusively established against the party making the admission in the pending action, unless the court has permitted withdrawal or amendment of that admission under C.C.P. § 2033.300. (See C.C.P. § 2033.410.) C. Defendant Has Waived The Right To Object To The Requests. “The party who fails to serve a timely response “(a)...waives any objection to the requests, including one based on privilege or on the protection for work product under Chapter 4 (commencing with Section 2018.010).” C.C.P. § 2033.280(a). Regardless of whether defendant serves responses in substantial compliance with C.C.P. § 2033.220 prior to the hearing on this motion, he has waived any right to object to these admissions requests. B. PLAINITFF HAS MADE SEVERAL ATTEMPTS TO AVOID THIS MOTION Although no warning or attempts at an informal resolution are required prior to making a motion to deem matters admitted where no responses are received ( Demyer v. Costa Mesa Mobile Home Estates, 36 Cal. App. 4th 393, 395, 42 Cal. Rptr. 2d 260 (4th Dist. 1995) (disapproved on other grounds in, Wilcox v. Birtwhistle, 21 Cal. 4th 973, 90 Cal. Rptr. 2d 260, 987 P.2d 727 (1999)); Leach v. Superior Court, 111 Cal. App. 3d 902, 906, 169 Cal. Rptr. 42 (3d Dist. 1980)), Plaintiff has nevertheless made good faith attempts to avoid this motion. (Vafa Decl., qq 3-6, and Exhs. 2-3 thereto). C. MONETARY SANCTIONS ARE MANDATORY AGAINST DEFENDANT FOR NECESSITATING THIS MOTION “It is mandatory that the court impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) on the party or attorney, or both, whose failure to serve a timely response to 5 PLAINTIFF’S MOTION TO DEEM ADMITTED, REQUEST FOR ADMISSIONS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 requests for admission necessitated this motion.” C.C.P. §2033.280(c). ”Misuses of the discovery process include, but are not limited to...(d) Failing to respond or to submit to an authorized method of discovery...” C.C.P. § 2023.010. “To the extent authorized by the chapter governing any particular discovery method or any other provision of this title, the court, after notice to any affected party, person or attorney, and after opportunity for hearing may impose. ..sanctions against anyone engaging in conduct that is a misuse of the discovery process...” C.C.P. § 2023.030. Regardless of whether defendant serves responses in substantial compliance with C.C.P. § 2033.220 after filing of the motion but prior to hearing on the motion, the court must award monetary sanctions against the responding party for necessitating the motion. (C.C.P. § 2033.280(c).) Said monetary sanctions are requested in the form of costs and reasonable attorney’s fees incurred in making the instant motion. (See Vafa. Decl. § 8.) Pursuant to C.C.P. § 2023.010, C.C.P. § 2023.030, and C.C.P. § 2033.280(c), monetary sanctions should properly be awarded to Plaintiff, and against Defendant, and his counsel of record in the amount of $2,184, as reflected in the Declaration of Paymon J. Vafa, (C.C.P. § 2023.040 requires a declaration setting forth facts supporting the amount of sanctions.) Plaintiff has made numerous good faith attempts to informally resolve the issues presented in this motion, but to date Defendant has failed and refused to provide any responses. (Vafa Decl., 9 3-6). Defendant’s repeated and willful refusal to cooperate amounts to bad faith and abuse of the discovery process to Plaintiff’s detriment. Plaintiff is entitled to discover Defendants policy information and liability information, and cannot effectively mount its case or negotiate settlement without such information. Further, Plaintiff intends to depose Defendant and will be hard-pressed without Defendant’s verified discovery responses. Defendant cannot provide substantial justification for its failure to cooperate, as required by Section 2023. Accordingly, Plaintiff requests sanctions 6 PLAINTIFF’S MOTION TO DEEM ADMITTED, REQUEST FOR ADMISSIONS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 against Defendant and her attorney of record Raffalow, Bretoi , Lutz & Stele, jointly and severally, for the reasonable attorney fees and costs of bringing this Motion in the amount of $2,184 . (Vafa Decl., 47.) D. CONCLUSION For the foregoing reasons, Plaintiff respectfully requests that the Court grant this Motion and issue an order establishing the truth of the matters specified in Plaintiff’s Requests For Admissions, Set No. One. Additionally, Plaintiff respectfully requests monetary sanctions be awarded in the amount of $2,184, against Defendant and in favor of Plaintiff under C.C.P. § 2033.280(c¢). DATED: 2/5/19 STARPOINT, L.C. By: MON J. VAFA- AIDIN D. GHAVIMI Attorneys for Plaintiff, ARAD GOUDARZI 7 PLAINTIFF’S MOTION TO DEEM ADMITTED, REQUEST FOR ADMISSIONS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF PAYMON J. VAFA I, John Vafa, hereby declare: 1. I am an attorney admitted to practice in the State of California. I am a Partner with the law firm of Starpoint, L.C., counsel of record for Defendant ARAD GOUDARZI (“Plaintiff”) in this lawsuit. The following facts and circumstances are personally known to me, and if called upon to do so, I could and would competently testify as to them. 2, Plaintiff filed his lawsuit against Defendant Matthew Pettis (“Defendant”) on November 16, 2018. Defendant failed to file a responsive pleading against Plaintiff’s complaint and was in default. In lieu of moving for default against Defendant, I sent multiple meet and confer correspondences to Defendant’s carrier, Mercury Insurance Group (“Mercury”) so that Defendant can file his responsive pleading. 3 On December 27, 2018, I served Defendant MATTHEW PETTIS (“Defendant”), by mail, Form Interrogatories, Special Interrogatories, Requests for Admissions, Set One, Set One, and Requests for Production of Documents, Set One (collectively “Discovery Set One”) . Attached hereto as Exhibit 1 is a true and correct copies of proofs of service of Discovery Set One, which I served Defendant. 4, On January 19, 2019, I contacted Defendant’s counsel, Raffalow, Bretoi , Lutz & Stele, in regards to Defendant’s amongst other things, whether Defendant requires a courtesy copy of Discovery Set One or whether an extension would be required. Attached hereto as Exhibit 2 is a true and correct copy of said correspondence with Defendant’s counsel of record. 5. On January 23, 2019, After not receiving a response from Defendant’s counsel of record, I followed up with another email asking whether Defendant requires an extension to Discovery Set One, in which Defendant did not responds to Plaintift’s inquiry. In addition, I reminded Defendant that his responses were due on January 31, 2019. Attached hereto as Exhibit 3 is a true and correct copy of said correspondence with Defendant’s counsel of record. 6. On February 1, 2019, After Defendant missed his deadline and I again contacted Defendant and inquired as to the status of Defendant’s written discovery responses to Discovery Set 8 PLAINTIFF’S MOTION TO DEEM ADMITTED, REQUEST FOR ADMISSIONS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 One. Again, I received no response and waited until February 5, 2019, as a courtesy to Defendant, to file this motion. Ts My regular attorney’s fees are $200 per hour. My law firm regularly handle client matters on an hourly basis. 8. I spent six (6) hours drafting three motions for: motion to compel interrogatories, Requests for Production, Set One, and motion to deem admitted, Plaintiff's Requests for Admission, Set One. I anticipate spending two (2) hours to draft Replies for each motion, if Defendant seeks to oppose Plaintiff’s moving papers. 1 anticipate spending one (2) hours, driving roundtrip from Woodland Hills to Spring Street Courthouse. I paid approximately $184 for filing costs for all motions relating to Written Discovery Set One. With the reasonable hourly rate of $200 per hour at ten hours and filing fees, I therefore request sanctions in the total amount of $2,184 against Defendant, and counsel of record Raffalow, Bretoi , Lutz & Stele, jointly and severally, to compensate my firm and Plaintiff for the needless time wasted in bringing this motion as a result of Defendant’s refusal to participate. 9. Attached hereto as Exhibit 4, is a true and correct copy of Plaintiff Request for Admissions, Set One. I declare under the penalty of perjury under the laws of the State of California that the foregoing is true and correct. This Declaration was executed on February 5, 2019, at Los Angeles, (oo ZJOHN VAFA, ESQ. California. 9 PLAINTIFF’S MOTION TO DEEM ADMITTED, REQUEST FOR ADMISSIONS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXHIBIT 1 10 PLAINTIFF’S MOTION TO DEEM ADMITTED, REQUEST FOR ADMISSIONS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE (CCP §§ 1013(a) and 2015.5; FRCP 5) STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is: 1801 Century Park East, 24" Floor, Los Angeles, CA 90067. On December 27, 2018, I served the foregoing documents described as: PLAINTIFF’S REQUESTS FOR ADMISSION TO DEFENDANT MATTHEW PETTIS, SET ONE, on the interested parties in this matter of Goudarzi v. Pettis et al. ., by placing the () original (XX) copies thereof enclosed in sealed envelopes addressed as follows: Matthew Pettis Mercury Insurance Group 4252 Silverado Drive Fax: 866-268-8494 Thousand Oaks, CA 91360-6854 Claims Adjuster for Matthew Pettis In pro per (XX) BY U.S. MAIL: I deposited such envelope(s) in the mail at LOS ANGELES, California. The envelopes were mailed with postage thereon fully prepaid. I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with U.S. Postal Service on the same day in the ordinary course of business. I am aware on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after the date of deposit for mailing in affidavit. (XX) COURTESY COPY VIA FACSIMILE: I faxed the documents to the persons at the numbers listed in the above service list. No error was reported by the fax system that [ used. A copy of the record of the fax transmission, which I printed out, is attached. () EMAIL/ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the parties to accept service by email or electronic transmission, I caused the documents to be sent to the person at the email addressed listed in the SERVICE LIST. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. ( XX) STATE - I declare under penalty of perjury under the laws of the State of California that the above is true and correct. EXECUTED on December 27, 2018, in Los Angeles, California. Do 7 #Paymon J. Vafa, Esq. 3 PLAINTIFF ARAD GOUDARZI’S REQUESTS FOR ADMISSIONTO DEFENDANT MATTHEW PETTIS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE (CCP §§ 1013(a) and 2015.5; FRCP 5) STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is: 1801 Century Park East, 24" Floor, Los Angeles, CA 90067. On December 27, 2018, I served the foregoing documents described as: PLAINTIFF'S FORM INTERROGATORIES TO DEFENDANT MATTHEW PETTIS, SET ONE on the interested parties in this matter of Goudarzi v. Pettis et al. ., by placing the () original (XX) copies thereof enclosed in sealed envelopes addressed as follows: Matthew Pettis Mercury Insurance Group 4252 Silverado Drive Fax: 866-268-8494 Thousand Oaks, CA 91360-6854 Claims Adjuster for Matthew Pettis In pro per= (XX) BY U.S. MAIL: I deposited such envelope(s) in the mail at LOS ANGELES, California. The envelopes were mailed with postage thereon fully prepaid. I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with U.S. Postal Service on the same day in the ordinary course of business. I am aware on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after the date of deposit for mailing in affidavit. (XX) COURTESY COPY VIA FACSIMILE: I faxed the documents to the persons at the numbers listed in the above service list. No error was reported by the fax system that [ used. A copy of the record of the fax transmission, which I printed out, is attached. () EMAIL/ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the parties to accept service by email or electronic transmission, I caused the documents to be sent to the person at the email addressed listed in the SERVICE LIST. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. ( XX) STATE - I declare under penalty of perjury under the laws of the State of California that the above is true and correct. EXECUTED on December 27, 2018, in Los Angeles, California. Do 7 #Paymon J. Vafa, Esq. a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE (CCP §§ 1013(a) and 2015.5; FRCP 5) STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is: 1801 Century Park East, 24" Floor, Los Angeles, CA 90067. On December 27, 2018, I served the foregoing documents described as: PLAINTIFF’S REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANT MATTHEW PETTIS, SET ONE, on the interested parties in this matter of Goudarzi v. Pettis et al. ., by placing the () original (XX) copies thereof enclosed in sealed envelopes addressed as follows: Matthew Pettis Mercury Insurance Group 4252 Silverado Drive Fax: 866-268-8494 Thousand Oaks, CA 91360-6854 Claims Adjuster for Matthew Pettis In pro per (XX) BY U.S. MAIL: I deposited such envelope(s) in the mail at LOS ANGELES, California. The envelopes were mailed with postage thereon fully prepaid. I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with U.S. Postal Service on the same day in the ordinary course of business. I am aware on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after the date of deposit for mailing in affidavit. (XX) COURTESY COPY VIA FACSIMILE: I faxed the documents to the persons at the numbers listed in the above service list. No error was reported by the fax system that [ used. A copy of the record of the fax transmission, which I printed out, is attached. () EMAIL/ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the parties to accept service by email or electronic transmission, I caused the documents to be sent to the person at the email addressed listed in the SERVICE LIST. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. ( XX) STATE - I declare under penalty of perjury under the laws of the State of California that the above is true and correct. EXECUTED on December 27, 2018, in Los Angeles, California. Do 7 #Paymon J. Vafa, Esq. 11 PLAINTIFF ARAD GOUDARZI’S RQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANT MATTHEW PETTIS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE (CCP §§ 1013(a) and 2015.5; FRCP 5) STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is: 1801 Century Park East, 24" Floor, Los Angeles, CA 90067. On December 27, 2018, I served the foregoing documents described as: PLAINTIFF'S SPECIAL ITNERROGATORIES TO DEFENDANT MATTHEW PETTIS, SET ONE on the interested parties in this matter of Goudarzi v. Pettis et al. ., by placing the () original (XX) copies thereof enclosed in sealed envelopes addressed as follows: Matthew Pettis Mercury Insurance Group 4252 Silverado Drive Fax: 866-268-8494 Thousand Oaks, CA 91360-6854 Claims Adjuster for Matthew Pettis In pro per (XX) BY U.S. MAIL: I deposited such envelope(s) in the mail at LOS ANGELES, California. The envelopes were mailed with postage thereon fully prepaid. I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with U.S. Postal Service on the same day in the ordinary course of business. I am aware on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after the date of deposit for mailing in affidavit. (XX) COURTESY COPY VIA FACSIMILE: I faxed the documents to the persons at the numbers listed in the above service list. No error was reported by the fax system that [ used. A copy of the record of the fax transmission, which I printed out, is attached. () EMAIL/ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the parties to accept service by email or electronic transmission, I caused the documents to be sent to the person at the email addressed listed in the SERVICE LIST. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. ( XX) STATE - I declare under penalty of perjury under the laws of the State of California that the above is true and correct. EXECUTED on December 27, 2018, in Los Angeles, California. Do 7 #Paymon J. Vafa, Esq. a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXHIBIT 2 11 PLAINTIFF’S MOTION TO DEEM ADMITTED, REQUEST FOR ADMISSIONS, SET ONE From: Subject: Date: To: Denyse Greer DGreer@mercuryinsurance.com @ RE: GOUDARZI V. PETTIS ET AL. January 19, 2019 at 2:52 PM John Vafa john@starpointlaw.com 866-436-7287 X 20585 From: John Vafa [mailto:john@starpointlaw.com] Sent: Saturday, January 19, 2019 2:51 PM To: Denyse Greer Subject: Re: GOUDARZI V. PETTIS ET AL. what number? John Vafa, Esq. STAR INTLc ATTORNEYS AT L AW T 310.556.9627 F 424.255.4035 John @starpointlaw.com 1801 Century Park East, 24th Floor Los Angeles, California 90067 PRIVILEGE AND CONFIDENTIALITY NOTICE This electronic message transmission is intended for the named recipient(s) only and contains information from the Starpoint, a Law Corporation, which may be confidential, protected by the attorney-client privilege, and/or the work product doctrine. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the content of this information is prohibited. If you have received this communication in error, please notify us immediately by e-mail, or by calling (310) 556-9627 and delete the original message and any attachments without reading or saving in any manner. On Jan 19, 2019, at 2:49 PM, Denyse Greer wrote: Yes. From: John Vafa [mailto:john@starpointlaw.com] Sent: Saturday, January 19, 2019 2:47 PM To: John Vafa ; Denyse Greer Cc: Aidin Ghavimi Subject: RE: GOUDARZI V. PETTIS ET AL. Are you available for a brief phone call? On Jan 19, 2019, 1:17 PM -0800, Denyse Greer , wrote: Hi John: The same to you. | will have to check into what happened with the transmission and appreciate the notice. | have a little more $$$ if you want to wrap this up now. R. Denyse Greer Raffalow, Bretoi , Lutz & Stele 14724 Ventura Blvd. Suite 905 Sherman Oaks, CA 91403 Tel: 866-436-7287 Fax: 877-389-1093 From: John Vafa [mailto:john@starpointlaw.com] Sent: Saturday, January 19, 2019 1:08 PM To: Denyse Greer Cc: Aidin Ghavimi ; Aidin Ghavimi Subject: GOUDARZI V. PETTIS ET AL. Hi Denyse, Happy belated new year! Yesterday we received your correspondence with Defendant’s answer, request for statement of damages, and Defendant’s written discovery propounded to Plaintiff. However the mail we received from your office incomplete. We only received partial pages from the Answer and the Deposition Notice with Production of Documents. Also your signature is not on Defendant’s deposition notice. Attached is the mail we received. Can we please receive a courtesy copy via email or fax with the completed version of the documents? In addition, Plaintiff has propounded written discovery to Matthew Pettis and served a statement of damages as well. Would you like a courtesy copy from our office? I assume you will need an extension to respond to said written discovery as well. Have a great long weekend. Best, John Vafa, Esq. This e-mail message, including any attachments, is for the sole use of the intended recipient, and may contain material that is privileged or confidential and legally protected from disclosure. If you are not the intended recipient or have received this message in error, you are not authorized to copy, distribute, or otherwise use this message or its attachments. Please notify the sender immediately by return e-mail and permanently delete this message and any attachments. a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXHIBIT 3 12 PLAINTIFF’S MOTION TO DEEM ADMITTED, REQUEST FOR ADMISSIONS, SET ONE From: John Vafa john @starpointlaw.com @ Subject: Re: GOUDARZIV. PETTIS ET AL. Date: February 1, 2019 at 4:57 PM To: John Vafa john @starpointlaw.com Cc: Denyse Greer DGreer@mercuryinsurance.com, Aidin Ghavimi aidin@starpointlaw.com, Aidin Ghavimi info @starpointlaw.com Denyse, Following up on my email. Defendant’s Discovery responses were due yesterday. What is the status on this? Also | have yet to receive Defendants’ full answer to the complaint and yet to received a courtesy copy of the incomplete discovery propounded to Plaintiff. John Vafa, Esq. STAR INT LC ATTORNEYS AW T 310.556.9627 F 424.255.4035 John@starpointlaw.com 1801 Century Park East, 24th Floor Los Angeles, California 90067 PRIVILEGE AND CONFIDENTIALITY NOTICE This electronic message transmission is intended for the named recipient(s) only and contains information from the Starpoint, a Law Corporation, which may be confidential, protected by the attorney-client privilege, and/or the work product doctrine. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the content of this information is prohibited. If you have received this communication in error, please notify us immediately by e-mail, or by calling (310) 556-9627 and delete the original message and any attachments without reading or saving in any manner. On Jan 283, 2019, at 12:57 PM, John Vafa wrote: Hi Denyse, Following up on my email from Saturday regarding Defendant’s Answer and discovery propounded. We only have the incomplete documents. When said documents are sent to us, would you be agreeable to stipulate that Plaintiff's responses are due 30 days from Plaintiff's receipt of new copies of Defendant’s propounded written discovery? Also as mentioned on our phone call we propounded written discovery to your client. Has he passed along these documents over to you? Please advise if not so that | can send over a courtesy copy. | also want to point out that Defendant’s responses to written discovery are due on 1/31/19. | assume you will require an extension to respond. Final point as to written discovery, are you willing to stipulate to email service for discovery? Seems easier since mail gets a little sloppy/labor intensive (Also we should be environmentally friendly). A final note is in regards to our discussion about Plaintiff’s deposition that was unilaterally set. Can you confirm that the deposition is off calendar? | am obtaining dates from my client where he can sit for deposition. Would you like to have someone from your office reach out and send 4 or 5 dates and | can check with Plaintiff. Best, John Vafa, Esq. T 310.556.9627 F 424.255.4035 John @starpointlaw.com 1801 Century Park East, 24th Floor Los Angeles, California 90067 PRIVILEGE AND CONFIDENTIALITY NOTICE This elertranic mecaane tranamiccinn ig intended far tha named recinieant(c) nnlv and rantaing infarmatinn THU CIVIL UT IU TH IV UUM NY MM IU THUD IU HILT IMIS TU LE IAT TIM TUITE EY SA TM UE IRATE EU 1 TE As from the Starpoint, a Law Corporation, which may be confidential, protected by the attorney-client privilege, and/or the work product doctrine. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the content of this information is prohibited. If you have received this communication in error, please notify us immediately by e-mail, or by calling (310) 556-9627 and delete the original message and any attachments without reading or saving in any manner. On Jan 19, 2019, at 2:55 PM, John Vafa wrote: Will call in a few minutes. On Jan 19, 2019, 2:52 PM -0800, Denyse Greer , wrote: 866-436-7287 X 20585 From: John Vafa [mailto:john@starpointlaw.com] Sent: Saturday, January 19, 2019 2:51 PM To: Denyse Greer Subject: Re: GOUDARZI V. PETTIS ET AL. what number? John Vafa, Esq. T 310.556.9627 F 424.255.4035 John@starpointlaw.com 1801 Century Park East, 24th Floor Los Angeles, California 90067 PRIVILEGE AND CONFIDENTIALITY NOTICE This electronic message transmission is intended for the named recipient(s) only and contains information from the Starpoint, a Law Corporation, which may be confidential, protected by the attorney- client privilege, and/or the work product doctrine. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the content of this information is prohibited. If you have received this communication in error, please notify us immediately by e-mail, or by calling (310) 556- 9627 and delete the original message and any attachments without reading or saving in any manner. On Jan 19, 2019, at 2:49 PM, Denyse Greer wrote: Yes. From: John Vafa [mailto:john@starpointlaw.com] Sent: Saturday, January 19, 2019 2:47 PM To: John Vafa ; Denyse Greer NR vAArfMrmArAi inna iranAan AAPA~ SNSLUITCTOI\IilIcivulyiliouil al ive.uul li 1.2 Cc: Aidin Ghavimi Subject: RE: GOUDARZI V. PETTIS ET AL. Are you available for a brief phone call? On Jan 19, 2019, 1:17 PM -0800, Denyse Greer , wrote: Hi John: The same to you. | will have to check into what happened with the transmission and appreciate the notice. | have a little more $$$ if you want to wrap this up now. R. Denyse Greer Raffalow, Bretoi , Lutz & Stele 14724 Ventura Blvd. Suite 905 Sherman Oaks, CA 91403 Tel: 866-436-7287 Fax: 877-389-1093 From: John Vafa [mailto:john @starpointlaw.com] Sent: Saturday, January 19, 2019 1:08 PM To: Denyse Greer Cc: Aidin Ghavimi ; Aidin Ghavimi Subject: GOUDARZI V. PETTIS ET AL. Hi Denyse, Happy belated new year! Yesterday we received your correspondence with Defendant’s answer, request for statement of damages, and Defendant's written discovery propounded to Plaintiff. However the mail we received from your office incomplete. Wa Anht rarnaiviad nartial nanac fram tha Ancwnar an A tha Nanncitinn Nlatina with Dradiinrtinn af Naniimante Alen VVG Vly IGUGIVEU pal ludl Pays HUI LIT ALIDWTT Alu UIT UGPUDILUIL INULILG WILT 1 TUUULUULT Ul LULUTTIGT ID. MIDY your signature is not on Defendant's deposition notice. Attached is the mail we received. Can we please receive a courtesy copy via email or fax with the completed version of the documents? In addition, Plaintiff has propounded written discovery to Matthew Pettis and served a statement of damages as well. Would you like a courtesy copy from our office? | assume you will need an extension to respond to said written discovery as well. Have a great long weekend. Best, John Vafa, Esq. This e-mail message, including any attachments, is for the sole use of the intended recipient, and may contain material that is privileged or confidential and legally protected from disclosure. If you are not the intended recipient or have received this message in error, you are not authorized to copy, distribute, or otherwise use this message or its attachments. Please notify the sender immediately by return e-mail and permanently delete this message and any attachments. From: Subject: Date: To: Cc: John Vafa john @starpointlaw.com @ Re: GOUDARZI V. PETTIS ET AL. January 23, 2019 at 12:57 PM Denyse Greer DGreer@mercuryinsurance.com Aidin Ghavimi aidin@starpointlaw.com, Aidin Ghavimi info @starpointlaw.com Hi Denyse, Following up on my email from Saturday regarding Defendant’s Answer and discovery propounded. We only have the incomplete documents. When said documents are sent to us, would you be agreeable to stipulate that Plaintiff's responses are due 30 days from Plaintiff's receipt of new copies of Defendant’s propounded written discovery? Also as mentioned on our phone call we propounded written discovery to your client. Has he passed along these documents over to you? Please advise if not so that | can send over a courtesy copy. | also want to point out that Defendants responses to written discovery are due on 1/31/19. | assume you will require an extension to respond. Final point as to written discovery, are you willing to stipulate to email service for discovery? Seems easier since mail gets a little sloppy/labor intensive (Also we should be environmentally friendly). A final note is in regards to our discussion about Plaintiff’s deposition that was unilaterally set. Can you confirm that the deposition is off calendar? | am obtaining dates from my client where he can sit for deposition. Would you like to have someone from your office reach out and send 4 or 5 dates and | can check with Plaintiff. Best, John Vafa, Esq. STARPOINT.c ATTORNEYS AT LAW T 310.556.9627 F 424.255.4035 John @starpointlaw.com 1801 Century Park East, 24th Floor Los Angeles, California 90067 PRIVILEGE AND CONFIDENTIALITY NOTICE This electronic message transmission is intended for the named recipient(s) only and contains information from the Starpoint, a Law Corporation, which may be confidential, protected by the attorney-client privilege, and/or the work product doctrine. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the content of this information is prohibited. If you have received this communication in error, please notify us immediately by e-mail, or by calling (310) 556-9627 and delete the original message and any attachments without reading or saving in any manner. On Jan 19, 2019, at 2:55 PM, John Vafa wrote: Will call in a few minutes. On Jan 19, 2019, 2:52 PM -0800, Denyse Greer , wrote: 866-436-7287 X 20585 From: John Vafa [mailto:john @starpointlaw.com] Sent: Saturday, January 19, 2019 2:51 PM To: Denyse Greer Subject: Re: GOUDARZI V. PETTIS ET AL. what number? John Vafa, Esq. T 310.556.9627 F 424.255.4035 John@starpointlaw.com 1801 Century Park East, 24th Floor Los Angeles, California 90067 PRIVILEGE AND CONFIDENTIALITY NOTICE This electronic message transmission is intended for the named recipient(s) only and contains information from the Starpoint, a Law Corporation, which may be confidential, protected by the attorney-client privilege, and/or the work product doctrine. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the content of this information is prohibited. If you have received this communication in error, please notify us immediately by e-mail, or by calling (310) 556-9627 and delete the original message and any attachments without reading or saving in any manner. On Jan 19, 2019, at 2:49 PM, Denyse Greer wrote: Yes. From: John Vafa [mailto:john @starpointlaw.com] Sent: Saturday, January 19, 2019 2:47 PM To: John Vafa ; Denyse Greer Cc: Aidin Ghavimi Subject: RE: GOUDARZI V. PETTIS ET AL. Are you available for a brief phone call? On Jan 19, 2019, 1:17 PM -0800, Denyse Greer Cc: Aidin Ghavimi ; Aidin Ghavimi Subject: GOUDARZI V. PETTIS ET AL. Hi Denyse, Happy belated new year! Yesterday we received your correspondence with Defendant’s answer, request for statement of damages, and Defendant’s written discovery propounded to Plaintiff. However the mail we received from your office incomplete. We only received partial pages from the Answer and the Deposition Notice with Production of Documents. Also your signature is not on Defendant’s deposition notice. Attached is the mail we received. Can we please receive a courtesy copy via email or fax with the completed version of the documents? In addition, Plaintiff has propounded written discovery to Matthew Pettis and served a statement of damages as well. Would you like a courtesy copy from our office? | assume you will need an extension to respond to said written discovery as well. Have a great long weekend. Best, John Vafa, Esq. This e-mail message, including any attachments, is for the sole use of the intended recipient, and may contain material that is privileged or confidential and legally protected from disclosure. If you are not the intended recipient or have received this message in error, you are not authorized to copy, distribute, or otherwise use this message or its attachments. Please notify the sender immediately by return e-mail and permanently delete this message and any attachments. a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXHIBIT 4 13 PLAINTIFF’S MOTION TO DEEM ADMITTED, REQUEST FOR ADMISSIONS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Aidin D. Ghavimi, Esq. (State Bar No. 305808) Paymon J. Vafa, Esq. (State Bar No. 306059) STARPOINT, LC 1801 Century Park East, 24™ Floor Los Angeles, California 90067 T: (310) 556-9627 F: (424) 255-4035 info@starpointlaw.com Attorneys for Plaintiff, Arad Goudarzi SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES - CENTRAL DISTRICT CASE NO. 18STCV05510 [Assigned to Hon. Christopher Lui ARAD GOUDARZI, an individual Plaintiff, VS. PLAINTIFF ARAD GOUDARZI’S REQUESTS FOR ADMISSION TO DEFENDANT LESLIE PETTIS; MATTHEW PETTIS; and MATTHEW PETTIS, SET ONE DOES 1 through 100, inclusive, Complaint Filed: 11/16/18 Defendants. Trial Date: 5/15/2018 N r N r N a N a N e N a SN N e N a N a N a N e N e PROPOUNDING PARTY: Plaintiff, ARAD GOUDARZI RESPONDING PARTY: Defendant, MATTHEW PETTIS SET NUMBER: One PLEASE TAKE NOTICE Pursuant to Code of Civil Procedure § 2033.010 through 2033.080, et seq., Plaintiff ARAD GOUDARZI(*“Plaintiff” or “Propounding Party’) hereby requests that Defendant MATTHEW PETTIS(“Defendant” or “Responding Party”) admit or deny the following requests for admission, under oath, within thirty days of service of these requests. i 1 PLAINTIFF ARAD GOUDARZI’S REQUESTS FOR ADMISSIONTO DEFENDANT MATTHEW PETTIS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DEFINITIONS I. INCIDENT or COLLISION refer to the alleged automobile collision giving rise to this action or proceeding. 2. YOU and/or YOUR refers to and includes ELENA JIMENEZ CASTELLANOS, his agents, insurance adjusters, employees, and anyone else acting on his behalf or their behalf. 3. As used herein, the singular shall be interchangeable with the plural; the masculine, feminine and neuter shall all be interchangeable, and the conjunctions "and" and "or" shall be both conjunctive and disjunctive. REQUESTS FOR ADMISSIONS REQUESTS FOR ADMISSION NO. 1: Admit that YOU collided with the vehicle in which Plaintiff was operating at the time of the INCIDENT. REQUESTS FOR ADMISSION NO. 2: Admit that YOU collided with the rear of Plaintiff’s vehicle. REQUESTS FOR ADMISSION NO. 3: Admit that YOU are 100% at fault for the INCIDENT. REQUESTS FOR ADMISSION NO. 5: Admit that YOU did not utilize YOUR vehicle’s left turn signal immediately prior to colliding with Plaintiff. DATED: December 27, 2018 STARPOINT, LC “AIDIN GHAVIMLI, ESQ. PAYMON J. VAFA, ESQ. Attorneys for Plaintiff, ARAD GOUDARZI 2 PLAINTIFF ARAD GOUDARZI’S REQUESTS FOR ADMISSIONTO DEFENDANT MATTHEW PETTIS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE (CCP §§ 1013(a) and 2015.5; FRCP 5) STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is: 1801 Century Park East, 24" Floor, Los Angeles, CA 90067. On December 27, 2018, I served the foregoing documents described as: PLAINTIFF’S REQUESTS FOR ADMISSION TO DEFENDANT MATTHEW PETTIS, SET ONE, on the interested parties in this matter of Goudarzi v. Pettis et al. ., by placing the () original (XX) copies thereof enclosed in sealed envelopes addressed as follows: Matthew Pettis Mercury Insurance Group 4252 Silverado Drive Fax: 866-268-8494 Thousand Oaks, CA 91360-6854 Claims Adjuster for Matthew Pettis In pro per (XX) BY U.S. MAIL: I deposited such envelope(s) in the mail at LOS ANGELES, California. The envelopes were mailed with postage thereon fully prepaid. I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with U.S. Postal Service on the same day in the ordinary course of business. I am aware on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after the date of deposit for mailing in affidavit. (XX) COURTESY COPY VIA FACSIMILE: I faxed the documents to the persons at the numbers listed in the above service list. No error was reported by the fax system that [ used. A copy of the record of the fax transmission, which I printed out, is attached. () EMAIL/ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the parties to accept service by email or electronic transmission, I caused the documents to be sent to the person at the email addressed listed in the SERVICE LIST. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. ( XX) STATE - I declare under penalty of perjury under the laws of the State of California that the above is true and correct. EXECUTED on December 27, 2018, in Los Angeles, California. Do 7 #Paymon J. Vafa, Esq. 3 PLAINTIFF ARAD GOUDARZI’S REQUESTS FOR ADMISSIONTO DEFENDANT MATTHEW PETTIS, SET ONE a WwW oe 0 9 S N Wh 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE (CCP §§ 1013(a) and 2015.5; FRCP 5) STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is: 1801 Century Park East, 24" Floor, Los Angeles, CA 90067. On February 5, 2019, I served the foregoing documents described as: PLAINITFF ARAD GOUDARZI’S MOTION TO DEEM ADMITTED REQUEST FOR ADMISSIONS, SET ONE, on the interested parties in this matter of Goudarzi v. Pettis et al., by placing the () original (XX) copies thereof enclosed in sealed envelopes addressed as follows: Denyse Greer Raffalow, Bretoi , Lut; & Stele 14724 Ventura Blvd. Suite 905 Sherman Oaks, CA 91403 Tel: 866-436-7287 Fax: 877-389-1093 Email: DGreerv@mercuryinsurance.com SEE SERVICE LIST (XX) BY U.S. MAIL: I deposited such envelope(s) in the mail at LOS ANGELES, California. The envelopes were mailed with postage thereon fully prepaid. I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with U.S. Postal Service on the same day in the ordinary course of business. I am aware on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after the date of deposit for mailing in affidavit. (XX) COURTESY COPY VIA FACSIMILE: I faxed the documents to the persons at the numbers listed in the above service list. No error was reported by the fax system that [ used. A copy of the record of the fax transmission, which I printed out, is attached. (XX) EMAIL/ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the parties to accept service by email or electronic transmission, I caused the documents to be sent to the person at the email addressed listed in the above SERVICE LIST. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. ( XX) STATE - I declare under penalty of perjury under the laws of the State of California that the above is true and correct. EXECUTED on February 5, 2019, in Los Angeles, California. Do 7 #Paymon J. Vafa, Esq. 14 PLAINTIFF’S MOTION TO DEEM ADMITTED, REQUEST FOR ADMISSIONS, SET ONE Make a Reservation | Journal Technologies Court Portal 2/5/19, 8:50 AM os Journal Technologies Court Portal Make a Reservation ARAD GOUDARZI| vs LESLIE PETTIS, et al. Case Number: 18STCV05510 Case Type: Civil Unlimited Category: Motor Vehicle - Personal Injury/Property [ Date Filed: 2018-11-16 Location: Spring Street Courthouse - Department 4A Reservation Case Name: Case Number: ARAD GOUDARZI vs LESLIE PETTIS, et al. 18STCV05510 Type: Status: Motion to Deem RFAs Admitted RESERVED Filing Party: Location: Arad Goudarzi (Plaintiff) Spring Street Courtho Date/Time: Number of Motions: 04/08/2019 1:30 PM 1 Reservation ID: Confirmation Code: 525308123770 CR-MFZWARGKN6Q Fees Description Motion to Deem RFAs Admitted Credit Card Percentage Fee (2.75%) TOTAL Payment Amount: Type: $61.65 Visa Account Number: Authorization: https://edelivery.lasc.journaltech.com/public-portal/?g=calendar/reserve Page 1 of 2 Make a Reservation | Journal Technologies Court Portal 2/5/19, 8:50 AM AXXXRZ263Y uL641G = Print Receipt = Reserve Another Hearing 4 View My Reservations Copyright © Journal Technologies, USA. 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