1-800-Battery, Inc. vs. George E. Kalo, Trustee of The George E. Kalo And Rimonda Kalo Revocable Living Trust

Demurrer to Amended Complaint

Cal. Super. - 4th Dist.October 5, 2016

Oo 00 J A N Ln BA W N = ND N N N N N N ND mm e m em e m e m e m e m e m ; Cc:Gus Tabor ; Carrie Ruiz ; Importance: High Mr Ferrucci: This will summarize our telephone call today. In response to me reaching out to meet and confer about my clients’ pending demurrer to your client's amended complaint, you started your end of the conversation by saying “f*** you” and calling me an “a**hole,” in response to my request for an extension. Before hanging up the phone, you stated, “do you want me to come over there and kick you're a**”? | do not take physical threats lightly, and as | stated before, will not allow that kind of contact against me or any of my staff. You will be hearing about this. Marc Y. Lazo Managing Partner — Irvine, CA Chair — Commercial Litigation WILSON KEADIJIAN w BROWNDORF 1900 Main Street, Ste. 600 Irvine, CA 92614 Office: (949) 333-0178 Fax: (949) 234-6254 Email: mlazo@wkbllp.com Website: www.wkbllp.com This email transmission, including any attachments, may contain material that is confidential, privileged and/or attorney work product for the sole use of the intended recipient. Any review, reliance, dissemination or distribution by anyone other than the named addressee, or forwarding without the express permission of the sender, is strictly prohibited. If you are not the intended recipient, please contact the sender by reply e-mail or telephone, delete this message, and destroy all copies of the message immediately. Thank you in advance for your cooperation. To ensure compliance with Internal Revenue Service Circular 230, we inform you that any U.S. Federal Tax advice contained in this communication is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any tax-related matter(s) addressed herein. https://mail.plutossama.com/owa/#viewmodel=ReadMessageltem <em ID =AAMKAGUyYjRmMzNiLWEzN2EtN GZjMiOSNmVm LW JIZjhkOW JiNDdINwWBGA... 17 \O oo J aN Wn E a Ww \) — ND N N N N N N ND mm e m em e m e m e m e m e m 3 aN Wn INN Ww No —_ La m \O oo BY aN Wn ~~ Ww No —_ oo 28 Wilson Keadjian Browndorf LLP Attorneys at Law Irvine. CA PROOF OF SERVICE (C.C.P. Section 1013a and Section 2015.5) I am employed in the County of Orange, State of California; I am over the age of eighteen years and not a party to the within action; my business address is 1900 Main Street, 6" Floor, Irvine, California 92614. On June 1, 2017, I served the within NOTICE OF HEARING ON DEMURRER AND DEMURRER OF DEFENDANTS MARC Y. LAZO, JACQUES HATTOUNI, AND H&L HOLDINGS LLCTO PLAINTIFF’SFIRST AMENDED VERIFIED COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIESIN SUPPORT on the interested parties in baid action, by placing a true copy thereof in an envelope addressed as shown below by the following means of service: Joseph A. Ferrucci, Esq. Michael G. King, Esq. FERRUCCI LAW GROUP, APC Thomas H. Case, Esq. 24361 El Toro Rd., Suite 220 HENNELLY & GROSSFELD Laguna Woods, CA 92637 4640 Admiralty Way #850 Tel: 949-600-5370 / Fax: 949-600-5371 Marina Del Rey, CA 90292 mking@hgla.com ; tcase @hgla.com nsnyder@hgla.com; kborysiak@hgla.com Terry J. Kent, Esq. Stephen C. Chuck, Esq. SUMMIT LA, A Professional Law Corporation Victoria J. Tsoong, Esq. 1800 Century Park East, Ste. 600 CHUCK & TSOONG. LLP Los Angeles, CA 90067 tkent @ summitlaw la 700 N. Brand Blvd., Suite 440 Glendale, CA 91203 (626) 689-4000 / Fax (626) 689-4011 schuck @cbtlegal.com [XX] BY MAIL: I placed a true copy in a sealed envelope addressed as indicated above, on the above mentioned date. I am familiar with the firm’s practice of collection and processing correspondence for mailing. It is deposited within the U.S. Postal Service on that same day in the ordinary course of business. I am aware that on mention of party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit of mailing in affidavit. I declare under penalty of perjury under the law of the State of California that the foregoing is true and correct. CARRIERUIZ _ "J Executed on June 1, 2017, at Irvine, California. -17- DEMURRER TO PLAINTIFF'S FIRST AMENDED VERIFIED COMPLAINT