Order_proposed_motion_in_limine_number_10MotionCal. Super. - 2nd Dist.December 3, 201210 11 El ec tr on ic al ly Re ce iv ed 02 /0 8/ 20 19 04 :4 8 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 EARLY 28 BE | SULLIVAN WRIGHT GIZER & W&M MCRAE LLP 252794.1 | ATTORNEYS AT LAW Scott E. Gizer, State Bar Number 221962 sgizer@earlysullivan.com Diane M. Luczon, State Bar Number 235059 dluczon@earlysullivan.com Padideh Zargari, State Bar Number 307409 pzargari@earlysullivan.com EARLY SULLIVAN WRIGHT GIZER & McRAE LLP 6420 Wilshire Boulevard, 17® Floor Los Angeles, California 90048 Telephone: (323) 301-4660 Facsimile: (323) 301-4676 Attorneys for Defendant and Cross-Complainant ATAOLLAH AMINPOUR SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - WEST DISTRICT GREAT AMERICAN CHICKEN CORP, INC., a California corporation and U.S. FOOD CORP, INC., a California corporation, Plaintiffs, VS. ATAOLLAH AMINPOUR and DOES 1 through 10, inclusive, Defendants. AND RELATED CROSS-ACTION Case No.: SC119261 [Related Case Nos. SC120155 & SC120466] [The Honorable Craig D. Karlan] [PROPOSED] ORDER RE: DEFENDANT AND CROSS-COMPLAINANT ATAOLLAH AMINPOUR’S NOTICE OF MOTION AND MOTION IN LIMINE NUMBER 10 TO EXCLUDE EVIDENCE, ARGUMENT, OR TESTIMONY REGARDING AMINPOUR’S PRIOR FELONY PLEA TO MAKING A FALSE STATEMENT TO A FINANCIAL INSTITUTION Date: February 25, 2019 Time: 8:30 a.m. Dept.: N [Filed Concurrently with Motion in limine No. 10; Declaration of Diane Myint Luczon] Date Filed: Trial Date: December 3, 2012 February 25, 2019 [PROPOSED] ORDER MIL NO. 10 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 EARLY 28 BE | SULLIVAN WRIGHT GIZER & W&M MCRAE LLP 252794.1 | ATTORNEYS AT LAW [PROPOSED ORDER] The Court, having heard and considered Defendant and Cross-Complainant Ataollah Aminpour’s (“Aminpour”) Motion in [imine No. 10 to preclude all parties and their counsel from offering any evidence, argument, or testimony at trial regarding Aminpour’s November 10, 2017, plea of guilty to making a false statement to a financial institution in violation of 18 U.S.C. § 1014 (“2017 conviction”), any opposition thereto, and all argument by counsel at the hearing, finds that good cause exists to order the following: IT IS HEREBY ORDERED that Aminpour’s Motion in Limine No. 10 precluding all parties and their counsel from offering any evidence, argument, or testimony at trial regarding Aminpour’s November 10, 2017, plea of guilty to making a false statement to a financial institution in violation of 18 U.S.C. § 1014 (“2017 conviction”), is GRANTED. IT IS ORDERED DATED: Judge of the Superior Court Craig D. Karlan 1 [PROPOSED] ORDER MIL NO. 10 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 EARLY 28 BE | SULLIVAN ey |ZER & W&M MCRAE LLP 252794.1 | ATTORNEYS AT LAW PROOF OF SERVICE 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 6420 Wilshire Boulevard, 17th Floor, Los Angeles, California 90048. On February 8, 2019, I served the foregoing document(s) described as: [PROPOSED] RDER RE: DEFENDANT AND CROSS-COMPLAINANT ATAOLLAH AMINPOUR’S OTICE OF MOTION AND MOTION IN LIMINE NUMBER 10 TO EXCLUDE VIDENCE, ARGUMENT, OR TESTIMONY REGARDING AMINPOUR’S PRIOR ELONY PLEA TO MAKING A FALSE STATEMENT TO A FINANCIAL INSTITUTION pn the interested parties to this action by placing a copy thereof enclosed in a sealed envelope addressed as follows: SEE SERVICE LIST BY MAIL: Iam readily familiar with the business practice for collection and processing of correspondence for mailing with the United States Postal Service. I served the following document(s) by enclosing them in an envelope and placing the envelope for collection and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business at our Firm’s office address in Los Angeles, California within the United States Postal Service in a sealed envelope with postage fully prepaid. Service made pursuant to this paragraph, upon motion of a party served, shall be presumed invalid if the postal cancellation date of postage meter date on the envelope is more than one day after the date of deposit for mailing contained in this affidavit. BY PERSONAL DELIVERY: I caused such envelope to be delivered by hand to the offices of the above named addressee(s). BY OVERNIGHT DELIVERY: [served the foregoing document by Federal Express, an express service carrier which provides overnight delivery, as follows. I placed true copies of the foregoing document in sealed envelopes or packages designated by the express service carrier, addressed to each interested party as set forth above, with fees for overnight delivery paid or provided for. BY E-MAIL: I caused to be e-mailed a true copy to the e-mail addresses listed above. Executed on February 8, 2019, at Los Angeles, California. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. /s/ D’Metria Bolden D’METRIA BOLDEN 2 [PROPOSED] ORDER MIL NO. 10 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 EARLY 28 BE | SULLIVAN WRIGHT GIZER & W&M MCRAE LLP 252794.1 | ATTORNEYS AT LAW SERVICE LIST Bruce David Abel, Esq. ABEL LAW OFFICES 77711 Flora Road, Suite 310 Palm Desert, CA 92211 T: 310-498-9374; Geoffrey M. Gold, Esq. Eric W. Cheung, Esq. ERVIN COHEN & JESSUP 9401 Wilshire Blvd., 9th Floor Beverly Hills, CA 90212 T: 310-273-6333; F: 310-859-2325 ggold@ecjlaw.com Paul D. Murphy, Esq. Mark J. Nagle, Esq. MURPHY ROSEN MEYLAN & DAVITT 100 Wilshire Blvd., Suite 1300 Santa Monica, CA 90401 T: 310-899-3300; F: 310-399-97201 pmurphy @murphyrosen.com mnagle @murphyrosen.com 3 Attorneys for Defendants Karoosh Zaghi, Little Rock Management, Inc., and David and Delila Management, Inc. Attorneys for Plaintiffs Great American Chicken Corp., Inc. and U.S. Food Corp, Inc. Attorneys for Defendants Shaoul Levy, Aryeh Aslan, and Sharam Elyaszadeh [PROPOSED] ORDER MIL NO. 10
