Jaime Davies vs. Natasha KafaipourMotion for Summary JudgmentAdjudicationCal. Super. - 4th Dist.February 17, 20172 wn S e l m a n B r e i t m a n Li p A T T O R N E Y S A T L A W 126358.2 1541.42672 ELECTRONICALLY FILED Superior Court of California, County of Orange 06/11/2018 at 12:20:00 Fi Paul E. B Clerk of the Superior Court i alan ton” By Marlene Orellana, Deputy Clerk Ryan M. Sellers (SBN CA 270374) rsellers@selmanlaw.com Cindy Q. Tran (SBN CA 293820) ctran@selmanlaw.com SELMAN BREITMAN LLP 6 Hutton Centre Drive, Suite 1100 Santa Ana, CA 92707-5755 Telephone: 714.647.9700 Facsimile: 714.647.9200 Attorneys for Defendant JOSEPH ANTHONY MARINI SUPERIOR COURT OF CALIFORNIA COUNTY OF ORANGE JAMIE DAVIES, Case No. 30-2017-00904112-CU-PA-CJC Plaintiff, DEFENDANT JOSEPH ANTHONY MARINI'S NOTICE OF MOTION AND V. MOTION FOR SUMMARY JUDGMENT; MEMORANDUM OF POINTS AND NATASHA KAFAIPOUR, DONNA LOUISE | AUTHORITIES IN SUPPORT THEREOF HOOYEN, JOSEPH ANTHONY MARINI, EAN HOLDINGS LLC and DOES 1 to 25, Date: August 27,2018 Time: 10:30 a.m. Defendants. Dept.: C26 Judge: Hon. Gregory H. Lewis RESERVATION NO: 72782208 [Filed concurrently with Separate Statement of Undisputed Material Facts, Declaration of Paul E. Stephan, Declaration of Joseph Anthony Marini and [Proposed] Order] Complaint Filed: February 17, 2017 Trial: October 9, 2018 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on August 27, 2018, at 10:30 a.m., or as soon thereafter as the matter may be heard in Department C26 of the Orange County Superior Court located at 700 Civic Center Drive West, Santa Ana, California, 92701, defendant JOSEPH ANTHONY MARINI ("Mr. Marini") will move the court for summary judgment in its favor and against plaintiff JAMIE DAVIES ("plaintiff") pursuant to Cal. Code of Civil Procedure section 437c. ] NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT EN N O N Wn 10 11 12 13 14 15 16 17 S e l m a n B r e i t m a n LL p A T T O R N E Y S A T L A W 18 19 20 2) 22 23 24 25 26 27 28 126358.2 1541.42672 Summary judgment should be granted because the undisputed material facts establish that Mr. Marini was not negligent as he breached no duty owed to plaintiff and was not the legal cause of the subject accident, Specifically, there were four (4) vehicles involved in the subject accident, which occurred northbound on Interstate 405 in the number one lane, north of Bristol Street in Costa Mesa, California. The first vehicle in front was the red Ford Explorer operated by plaintiff Jamie Davies, followed by Mr. Marini operating a 2015 gray Hyundai Azera, followed by Defendant Donna Loiuise Hooyen ("Ms. Hooyen") operating a 2005 gray Hyundai Elantra, and the last vehicle was a 2014 white Mazda operated by Defendant Natasha Kafaipour ("Ms. Kafaipour"). Prior to the time of impact, Mr. Marini was completely stopped behind Plaintiff's red Ford Explorer with a license plate number of 7GEV236. Ms. Kafaipour ran into Ms. Hooyen s vehicle, which then ran into Mr. Marini's vehicle, which was pushed into Plaintiff's vehicle. The impact to the rear of Mr. Marini’s vehicle by Ms. Hooyen’s vehicle was the sole cause of his vehicle being pushed into the red Ford Explorer operated by plaintiff. Plaintiff has no admissible evidence to refute that (1) Mr. Marini was completely stopped before he was pushed into Plaintiff's vehicle or that (2) Ms. Kafaipour started and caused the chain- collision between the four vehicles. Therefore, this Court should grant summary judgment in favor of Mr. Marini. This motion is made pursuant to Code of Civil Procedure section 437¢, and is based upon this Notice, the attached Memorandum of Points and Authorities, the concurrently filed Separate Statement of Undisputed Material Facts, the concurrently filed Declaration of Paul E. Stephan, the concurrently filed Declaration of Joseph Anthony Marini, and the exhibits attached hereto, the Proposed Order, the records and files in this action, and upon such other oral and documentary evidence as may be presented at the hearing of this matter. DATED: June |, 2018 SELM.y IS4REITMAN LLP By: PAUL E. STEPHAN RYAN M. SELLERS CINDY Q. TRAN Attorneys for Defendant JOSEPH ANTHONY MARINI 2 NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT a © eo 3 O N Wn 10 11 12 13 14 15 16 17 S e l m a n B r e i t m a n LL P A T T O R N E Y S A T L A W 18 19 20 21 22 23 24 25 26 27 28 126358.2 1541.42672 II. HI. IV. Table of Contents INTRODUCTION (iremsnospsrssammsrnonssnensnismenstsnmssmemsssamssmmssnssnss samen snowemesssnoness nila isi isd 3 STATEMENT OF UNDISPUTED MATERIAL FACTS. .....ccormesuosussnmmpesssnssnes 5 LEGAL ARGUMENT. ...ooovemmiseomesononnqsasvs nen ssmsiok do is 455 55555555 608mm ois $600 mi we 7 A; The Court Has Authority to Dispose of a Cause of Action by Way of Summary Judgment or Summary Adjudication. ...........coceevvrviviiiiiiniinn 7 B. Plaintiff's Complaint Fails As A Matter Of Law As To Mr. Marini As No Triable Issue Of Fact Exists That (1) Mr. Marini Breached Any Duty Owed To Plaintiff Or That (2) Mr. Marini Was The Proximate Cause Of The Subject Accident. ......c..coovvveivreriiniincninnnnin, 8 CONCLUSION 3 NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT S e l m a n B r e i t m a n rr p A T T O R N E Y S A T L A W 126358.2 1541.42672 TABLE OF AUTHORITIES Cases Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 854 .......ccovivnnemnirniinnciiniiiiinninen, 7 Biles v, Richter (1988) 206 Cal APp.3d B25 unnssssssmuunes 55 suns sansa 55 55 pesssemsasmissnsmmmmsivensnd Chaknova v. Wilbur-Ellis Co. (1999) 69 Cal. App.4th 962.......cc.coovviivininiiiiiiii ees 7 Federico v. Superior Court (Jenry G.) (1997) 59 Cal. App.4th 1207, 1214.........coveirenininnen, 8 Hernandez v. Superior Court (2003) 112 Cal. App.4th 285 .....oooiiiiiiiiiiis 10 | J. Lv. Children's Institute, Inc. (2009) 177 Cal.App.4th388......ccccoviviiiiiiiiiiiiinn, 5,8 McGonnel v. Kaiser Gypsum Co., Inc. (2002) 98 Cal. App. 4th 1098......ccoiviriiniininiiieiinn 7 Osborn v. Hertz Corp. (1988) 205 Cal. APP. 3d 703... viiiriiiicie ccc Statutes C1vil Code seetion] 1 FLAC. .. voune vss 5s sss 1a sass 5 nesses os s sameness 13 yaGosins vss ss symwsn sy 350 61 5 Code Civil Procedure section 437C(N)(1) .ceevveererreisniseessesseisesressnisnssiesiisinssssassssssssnssssasessassssssenes 7 Code of Civil Procediite SECiON 43 TE(H ws snsusususrssssnasasimpissss stomps arises sass agei m» 7 Code of Civil Procedure Section A37C(PI2) user srersnssssaranesanconsnsisssssessssassnsanssssssibionesins an a sass sssnes 7 4 NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT S e l m a n B r e i t m a n LL p A T T O R N E Y S A T L A W 126358.2 1541.42672 MEMORANDUM OF POINTS AND AUTHORITIES I; INTRODUCTION This is an action seeking damages for personal injuries allegedly sustained by plaintiff as a result of a motor vehicle accident that occurred on February 20, 2015 on Interstate 405 in Costa Mesa, California. As set forth more fully below, the accident occurred when defendant Natasha Kafaipour ("Ms. Kafaipour") collided with another vehicle causing a multi-vehicle motor vehicle accident. Defendant JOSEPH ANTHONY MARINI ("Mr. Marini") is entitled to summary judgment because plaintiff JAMIE DAVIES ("plaintiff") cannot establish that Mr. Marini was negligent. ! To prevail in a negligence action, a plaintiff must show that the defendant owed a legal duty, the defendant breached that duty and the breach proximately caused injury to the plaintiff. (J.L v. Children's Institute, Inc. (2009) 177 Cal.App.4th 388, 396; Civil Code § 1714(a).) Here, plaintiff cannot establish that Mr. Marini breached any duty or proximately caused injury to the plaintiff. Indeed, as set forth in Mr. Marini's Separate Statement filed concurrently herewith, the undisputed material facts and supporting evidence establish that, prior to the time of impact, Mr. Marini was completely stopped behind Plaintiff's red Ford Explorer and that the chain collision started by Ms. Kafaipour was the sole cause of Mr. Marini's vehicle being pushed into the red Ford Explorer operated by plaintiff. Plaintiff has no admissible evidence to refute that (1) Mr. Marini was completely stopped before he was pushed into Plaintiff's vehicle or that (2) Ms. Kafaipour started and caused the chain-collision between the four vehicles. Therefore, this Court should grant summary judgment in favor of Mr. Marini. IL STATEMENT OF UNDISPUTED MATERIAL FACTS. Plaintiff filed this instant Complaint on February 17, 2017, alleging a multi-party motor 1 As set forth in the Traffic Collision Report generated by California Highway Patrol Officer R. Routs, Defendant Natasha Kafaipour ("Ms. Kafaipour") caused this collision by traveling at an unsafe speed for the traffic conditions, a violation of Vehicle Code section 22350, which caused her 2014 white Mazda to strike the rear of a 2005 gray Hyundai Elantra operated by defendant Defendant Donna Louise Hooyen ("Ms. Hooyen"), which then struck the rear of a 2015 gray Hyundai Azera operated by Mr. Marini, which then struck the rear of plaintiffs vehicle. (See Declaration of Paul E. Stephan , 4, Exhibit B). 5 NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT 11 12 13 14 15 16 17 S e l m a n B r e i t m a n LL p A T T O R N E Y S A T L A W 18 19 20 21 22 23 24 25 26 27 28 126358.2 1541.42672 vehicle accident on February 20, 2015 (the "subject accident"). (Separate Statement of Undisputed Material Facts ("SSUMF ") No. 1). There were four (4) vehicles involved in the subject accident, which occurred northbound on Interstate 405 in the number one lane, north of Bristol Street in Costa Mesa, California. (SSUMF No. 2). The first vehicle in front was the red Ford Explorer operated by plaintiff Jamie Davies, followed by Mr. Marini operating a 2015 gray Hyundai Azera, followed by Donna Loiuise Hooyen operating a 2005 gray Hyundai Elantra, and the last vehicle was a 2014 white Mazda operated by Defendant Natasha Kafaipour. (SSUMF No. 3). Ms. Kafaipour was the first person that made contact with any of the four vehicles at the time of the subject accident, (SSUMF No. 4). Ms. Kafaipour ran into Ms. Hooyen’s vehicle, who then ran into Mr. Marini's vehicle, which was pushed into Plaintiff's vehicle. (SSUMF No. 5). Ms. Kafaipour told the police officer who responded to the scene of the accident that she "looked away for a split second and then [she] couldn’t stop [her] car in time.” (SSUMF No. 6). There was only one impact to Plaintiff's vehicle at the time of the subject accident. (SSUMF No. 7). The sole impact to Plaintiff's vehicle at the time of the subject accident was the result of Mr. Marini's vehicle being pushed into Plaintiff's vehicle. (SSUMF No. 8). Prior to the time of impact, Mr. Marini was completely stopped behind Plaintiff's red Ford Explorer with a license plate number of 7GEV236. (SSUMF No. 9). Mr. Marini felt an impact to the rear of his vehicle as a result of a gray Hyundai Elantra operated by Ms. Hooyen hitting his vehicle. (SSUMF No. 10). Due to the impact from the rear of Mr. Marini's vehicle by the gray Hyundai Elantra operated by Ms. Hooyen, he was pushed into the rear of the red Ford Explorer operated by plaintiff. (SSUMF No. 11). The impact to the rear of Mr. Marini’s vehicle by Ms. Hooyen’s vehicle was the sole cause of his vehicle being pushed into the red Ford Explorer operated by plaintiff. (SSUMF No. 12). But for the impact to the rear of Mr. Marini’s vehicle, he would not have collided with the rear of the plaintiff's vehicle. (SSUMF No. 13). Plaintiff admits that Ms. Kafaipour caused her alleged injuries. (SSUMF No. 14). Plaintiff has no facts to refute that (1) Mr. Marini was completely stopped before he was pushed 6 NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT S e l m a n B r e i t m a n Li p A T T O R N E Y S A T L A W 126358.2 1541.42672 into Plaintiff's vehicle or that (2) Ms. Kafaipour started and caused the chain-collision between the four vehicles. (SSUMF No. 15). III. LEGAL ARGUMENT. A. The Court Has Authority to Dispose of a Cause of Action by Way of Summary Judgment or Summary Adjudication. A party may move for summary judgment in any action where it contends that the action has no merit. (Code of Civil Procedure §437c(a).) Summary judgment must be granted where a defendant can "show that the plaintiff cannot establish at least one element of the cause of action..." (Code Civil Procedure section §437c(n)(1); Aguilar v. Atlantic Richfield Co. (2001) 25 Cal 4th 826, 854 ("Aguilar").) Once a defendant has demonstrated that the plaintiff does not possess and cannot reasonably obtain evidence to establish an element of the plaintiff's cause of action, the burden shifts to the plaintiff to present admissible evidence to show that there exists a triable issue of material fact as to the cause of action. (Code of Civil Procedure §437c(p)(2), Aguilar at 853-56.) In response to a motion for summary judgment, the plaintiff may not rely on mere allegations or denials in the pleadings, rather, the plaintiff must set forth specific facts backed up by admissible evidence that show that a triable issue of material fact exists as to that cause of action. (Id) "It is not enough to produce just some evidence." (McGonnel v. Kaiser Gypsum Co., Inc. (2002) 98 Cal. App. 4th 1098, 1105.) "The evidence must be of sufficient quality to allow the trier of fact to find the underlying fact in favor of the party opposing the motion for summary judgment." (Aguilar at 850.) "If plaintiff fails to make the showing, summary judgment shall be granted." (Chaknova v. Wilbur-Ellis Co. (1999) 69 Cal. App.4th 962, 974-975.) As stated by the California Supreme Court: Summary judgment law in this state [no] longer require[s] a defendant moving for summary judgment to conclusively negate an element of the plaintiff's cause of action [...] All that the defendant need do is to "show [...] that one or more elements of the cause of action [...] cannot be established by the plaintiff. [Citation.] In other words, all that the defendant needs to do is to show that plaintiff cannot establish at least one element of the cause of action - for example, that the plaintiff cannot prove element X. Although he remains free to do so, the defendant need not himself conclusively negate any such element - for example, 7 NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT A 1 yore] «= 12 © Z = 13 == Ly 14 mz 15 gf < 16 = O 17 wn 18 19 20 21 22 23 24 25 26 27 28 126358.2 1541.42672 himself prove not X. [Fn.] (Aguilar at 853 - 854.) Here, plaintiff alleges that defendants Ms. Kafaipour, Ms. Hooyen, and Mr. Marini negligently operated their motor vehicles. However, as demonstrated in this motion, Ms. Kafaipour is solely responsible for the accident at issue. Mr. Marini breached no duty owed to plaintiff and was not negligent, thus negating plaintiff's complaint based upon motor vehicle negligence and general negligence against Mr. Marini. No triable issue of material fact exists as to the nature of the occurrence of the accident and the lack of negligence on behalf of Mr. Marini. Accordingly, Mr. Marini is entitled to summary judgment as a matter of law. B. Plaintiff's Complaint Fails As A Matter Of Law As To Mr. Marini As No Triable Issue Of Fact Exists That (1) Mr. Marini Breached Any Duty Owed To Plaintiff Or That (2) Mr. Marini Was The Proximate Cause Of The Subject Accident. To prevail in a negligence action, a plaintiff must show that the defendant owed a legal duty, the defendant breached that duty and the breach proximately caused injury to the plaintiff. (J.L v. Children's Institute, Inc. (2009) 177 Cal. App.4th 388, 396.) The existence of the duty in the first place is a question of law for the court. (/d.) The existence and scope of any duty depends on the foreseeability of the harm, which is also a legal issue for the court. (/d.) Absent a legal duty, any injury [no matter how severe or sympathetic] is just an injury without actionable wrong. (/d.) Duty, being a question of law, is particularly amenable to resolution by summary judgment. Id If there is no duty, there can be no liability. (/d.) Generally, whether a defendant was negligent constitutes a question of fact for the jury. (Biles v. Richter (1988) 206 Cal.App.3d 325, 332; Osborn v. Hertz Corp. (1988) 205 Cal. App.3d 703, 712-713 ("Osborn").) However, where reasonable jurors could draw only one conclusion from the evidence presented, lack of negligence may be determined as a matter of law and summary judgment granted. (Osborn, supra at 712-713; Federico v. Superior Court (Jenry G.) (1997) 59 Cal.App.4th 1207, 1214, as modified on denial of reh'g.) Here, the undisputed 8 NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT 2 3 4 5 6 7 8 9 10 & 11 - c 12 © 2 = 13 Cum” 0 14 = AZ 1s = < 16 E QO 17 7 18 19 20 21 22 23 24 25 26 27 28 126358.2 1541.42672 material facts demonstrate that Mr, Marini was not negligent as he breached no duty owed to plaintiff and that he was not the proximate cause of her alleged injuries. Here, plaintiff, Mr. Marini, and Ms. Kafaipour all agree to the facts of the accident on February 20, 2018. There were four vehicles all driving in the number one lane northbound on Interstate 405 in Costa Mesa, California. Ms. Kafaipour testified that she looked away for a second and collided into Ms. Hooyen’s vehicle. Ms. Hooyen’s vehicle then collided into Mr Marini’s vehicle. Due to the impact of Ms. Hooyen’s vehicle, Mr, Marini’s vehicle was then pushed into plaintiffs vehicle. But for the impact to the rear of Mr. Marini’s vehicle, he would not have collided with the rear of the red Ford Explorer operated by plaintiff as Mr. Marini’s vehicle was stopped prior to the impact from Ms. Kafaipour’s vehicle. Ms. Kafaipour’s rear- ender with Ms. Hooyen’s vehicle was what caused the chain reaction damage to the three vehicles in front of Ms. Kafaipour’s vehicle. There are no triable issues of fact as to the cause of the accident at issue. Mr. Marini was traveling at a speed and at a distance that allowed him to come to a complete stop behind plaintiff's vehicle ahead of him when there was a stoppage on the freeway. Ms. Kafaipour then rear-ended Ms. Hooyen, pushing her vehicle into the rear of Mr. Marini's vehicle, causing Mr Marini's vehicle to be pushed into the rear of plaintiff's vehicle. (See SSUMF Nos. 9-13.) Plaintiff experienced only one impact from behind, not two or three. Mr. Marini did not strike the plaintiff's vehicle and then strike it again when he was hit from the rear by Ms. Hooyen (who was initially hit from the rear by Ms. Kafaipour.) Ms. Marini was not negligent, and breached no duty owed to plaintiff. (See SSUMF Nos. 7-8.) The undisputed material facts demonstrate that Ms. Kafaipour was the sole cause of the subject accident, because she "looked away for a split second and then [she] couldn’t stop [her] car in time,” which caused the chain-collision resulting in the impact to plaintiff's vehicle. (See SSUMF Nos. 4-6, 14.) Plaintiff has no facts to refute that (1) Mr. Marini was completely stopped before he was pushed into Plaintiff's vehicle or that (2) Ms. Kafaipour started and caused the chain-collision between the four vehicles. (See SSUMF No. 15). 9 NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT S e l m a n B r e i t m a n LL p A T T O R N E Y S A T L A W 126358.2 1541.42672 Summary judgment provides the court and parties with a vehicle to weed the judicial system of an unmeritorious case which otherwise would consume scarce judicial resources and burden the parties with the economic and emotional costs of protracted litigation because the lack of merit is not apparent from the face of the complaint or the answer. (Hernandez v. Superior Court (2003) 112 Cal. App.4th 285.) The Court should weed Mr. Marini from this matter, to simplify this case down to the true necessary parties and save the Court time and resources which would be expended in trying an unmeritorious case against this defendant. Mr. Marini should not be burdened with the economic and emotional costs of a litigation which lacks any merit against him. Accordingly, the Court should grant Mr, Marini's instant motion for summary judgment. IV. CONCLUSION For the foregoing reasons, Mr, Marini's motion for summary judgment should be granted. DATED: June iia 2018 SELMAN J ETFRAN LLP oo” st By: pent PAUL E. STEPHAN RYAN M. SELLERS CINDY Q. TRAN Attorneys for Defendant JOSEPH ANTHONY MARINI 10 NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT S e l m a n B r e i t m a n LL P A T T O R N E Y S AT L A W H O WLW OO © 3 Oo Wn 10 11 i 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 120483. PROOF OF SERVICE Davies v. Kafaipour, et al. Orange County Superior Court Case No. 30-2017-00904112-CU-PA-CJC STATE OF CALIFORNIA, COUNTY OF ORANGE I am employed in the County of Orange, State of California. I am over the age of 18 years and am not a party to the within action; my business address is 6 Hutton Centre Drive, Suite 1100, Santa Ana, CA, 92707-5755. On June 11, 2018, I served the following document(s) described as DEFENDANT JOSEPH ANTHONY MARINI'S NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF the interested parties in this action as follows: Please See Service List Attached 0 BY MAIL: By placing a true copy thereof in a sealed envelope addressed as above, and placing it for collection and mailing following ordinary business practices. I am readily familiar with the firm’s practice of collection and processing correspondence, pleadings, and other matters for mailing with the United States Postal service on that same day with postage thereon fully prepaid at Santa Ana, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if the postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. J] BY OVERNIGHT COURIER: I caused the above-referenced document(s) to be delivered to for delivery to the addressee(s). O BY E-MAIL: I transmitted a copy of the foregoing document(s) via e-mail to the addressee(s). Ol BY FAX: In addition to U.S. Mail, I transmitted a copy of the foregoing document(s) via telecopier to the facsimile numbers of the addressee(s), and the transmission was reported as complete and without error. 1% BY PERSONAL SERVICE: I personally delivered such envelope by hand to the offices of the addressee(s) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on June 11, 2018, at Santa Ana, California. \ Elizabeth K. Jdmes 1541.42672 S e l m a n B r e i t m a n LL p A T T O R N E Y S AT L A W O e 3 1 11 12 13 14 13 16 17 18 19 20 21 22 23 24 23 26 27 28 120483. SERVICE LIST Davies v. Kafaipour, et al. Orange County Superior Court Case No. 30-2017-00904112-CU-PA-CJC Michael Shemtoub, Esq. BEVERLY LAW 4929 Wilshire Boulevard, Suite 915 Los Angeles, CA 90010 Larry D. Peterson, Esq. PETERSON, OLIVER & POLL 915 West Imperial Highway Suite 150 Brea, CA 92821 Normand A. Ayotte, Esq. JONES & AYOTTE 221 East Walnut Street Suite 238 Pasadena, CA 91101 1541.42672 Attorneys for Plaintiff, JAMIE DAVIES Telephone: (310) 552-6959 Facsimile: (323) 421-9397 Email: Attorneys for Defendant, NATASHA KAFAIPOUR Telephone: (714) 871-3191 Facsimile: (714) 871-3193 Email: Lpeterson@poplaw.Biz Attorneys for Defendant/Cross-Defendant/ Cross-Complainant, DONNA LOUISE HOOYEN Telephone: (626) 792-9741 Facsimile: (626) 792-9683 Email:
