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1 LEWIS BRISBOIS BISGAARD & SMITH LLP
JOSEPH R. LORDAN, SB# 265610
2 E-Mail: Joseph.Lordan@lewisbrisbois.com ELECTRONICALLY
ALLISON L. CARDENAS, SB# 272924
3 E-Mail: Allison.Cardenas@lewisbrisbois.com F I L E D
Superior Court of California,
KAA BAO YANG, SB# 302155 County of San Francisco
4 E-Mail: KaaBao.Yang@lewisbrisbois.com
CIARA M. DINEEN, SB# 319913 05/27/2022
Clerk of the Court
5 E-Mail: Ciara.Dineen@lewisbrisbois.com BY: EDNALEEN ALEGRE
333 Bush Street, Suite 1100 Deputy Clerk
6 San Francisco, California 94104-2872
Telephone: 415.362.2580
7 Facsimile: 415.434.0882
8 Attorneys for Defendants
EUROMOTORS, INC. DBA MERCEDES-
9 BENZ OF SAN FRANCISCO, a California
corporation; and DARIN SPARROW, an
10 individual
11 SUPERIOR COURT OF THE STATE OF CALIFORNIA
12 COUNTY OF SAN FRANCISCO
13
14 LUKMAN DOTSON; ADEAJAI DOTSON; Case No. CGC-20-587463
and ALI HABIBVAND,
15 DECLARATION OF JOSEPH R.
Plaintiffs, LORDAN IN SUPPORT OF
16 DEFENDANTS’ MOTION TO CONTINUE
vs. TRIAL AND RELATED PRE-TRIAL
17 DATES
EUROMOTORS, INC. DBA MERCEDES-
18 BENZ OF SAN FRANCISCO, a California Judge: Hon. Samuel K. Feng
corporation; DARIN SPARROW, an Date: June 28, 2022
19 individual; AND DOES 1-20, Time: 9:30 a.m.
Dept.: 206
20 Defendants.
Action File: November 3, 2020
21 Trial Date: September 7, 2022
22
23 I, Joseph R. Lordan, declare:
24 1. I am an attorney licensed to practice law in the State of California and I am a
25 Partner at Lewis, Brisbois, Bisgaard & Smith, LLP. I represent Defendants EUROMOTORS,
26 INC. DBA MERCEDES-BENZ OF SAN FRANCISCO and DARIN SPARROW in the above-
27 referenced lawsuit. The facts set forth herein are of my own personal knowledge, and if sworn I
28 could and would competently testify thereto.
LEWIS
B RISBOIS 4865-8669-7248.2 1
B ISGAARD
& SMITHLLP DECLARATION OF JOSEPH R LORDAN ISO DEFENDANTS’ MOTION TO CONTINUE TRIAL AND
ATTORNEYS AT LAW RELATED PRE-TRIAL DATES
1 2. On May 12, 2022 at approximately 11:30 a.m., I spoke with Plaintiffs’ counsel
2 Hunter Pyle and Bree Ullman regarding scheduling a mediation with two proposed mediators
3 since our previously scheduled mediation with Jeff Ross for December 8, 2022 falls after the trial
4 date.
5 3. I am currently engaged in efforts to secure an agreeable mediator with availability
6 in July or early August of 2022.
7 I declare under penalty of perjury under the laws of the State of California that the
8 foregoing is true and correct and that this declaration was executed on this 27 day of May, 2022, at
9 San Francisco, California.
10 DATED: May 27, 2022
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Joseph R. Lordan, Esq.
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LEWIS
B RISBOIS 4865-8669-7248.2 2
B ISGAARD
& SMITHLLP DECLARATION OF JOSEPH R LORDAN ISO DEFENDANTS’ MOTION TO CONTINUE TRIAL AND
ATTORNEYS AT LAW RELATED PRE-TRIAL DATES
1 CALIFORNIA STATE COURT PROOF OF SERVICE
Lukman Dotson, et al. v. Euromotors, Inc., et al.
2 San Francisco County Superior Court, Case No. CGC-20-587463
3 STATE OF CALIFORNIA, COUNTY OF ALAMEDA
4 At the time of service, I was over 18 years of age and not a party to this action. My
business address is 333 Bush Street, Suite 1100, San Francisco, CA 94104 -2872.
5
On May 27, 2022, I served true copies of the following document(s): DECLARATION
6 OF JOSEPH R. LORDAN IN SUPPORT OF DEFENDANTS’ MOTION TO CONTINUE
TRIAL AND RELATED PRE-TRIAL DATES
7
I served the documents on the following persons at the following addresses (including fax
8 numbers and e-mail addresses, if applicable):
9 Bree A. Ullman Hunter Pyle
LAW OFFICE OF BREE A. ULLMAN John J. Darin
10 1054 Keith Avenue HUNTER PYLE LAW
Berkeley, California 94708 428 Thirteenth Street, 11th Floor
11 Telephone: (425) 318-0708 Oakland, California 94612
Email: bree.esq@gmail.com Telephone: (510) 444-4400
12 Facsimile: (510) 444-4410
Attorneys for Plaintiffs Email:
13 LUKMAN DOTSON hunter@hunterpylelaw.com
ADEAJAI DOTSON jdarin@hunterpylelaw.com
14 ALI HABIBVAND Tanya Tambling –
ttambling@hunterpylelaw.com
15
Attorneys for Plaintiffs
16 LUKMAN DOTSON
ADEAJAI DOTSON
17 ALI HABIBVAND
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The documents were served by the following means:
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 (BY ELECTRONIC TRANSMISSION ONLY) Only by e-mailing the document(s) to the
20 persons at the e-mail address(es) listed above based on notice provided on March 16, 2020
that, during the Coronavirus (COVID-19) pandemic, this office will be working remotely,
21 not able to send physical mail as usual, and is therefore using only electronic mail. No
electronic message or other indication that the transmission was unsuccessful was received
22 within a reasonable time after the transmission.
23 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
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Executed on May 27, 2022, at Alameda, California.
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27 Monica B. Pena
28
LEWIS
B RISBOIS
B ISGAARD 4865-8669-7248.2
& SMITHLLP
ATTORNEYS AT LAW PROOF OF SERVICE
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1 LEWIS BRISBOIS BISGAARD & SMITH LLP JOSEPH R. LORDAN, SB# 265610 2 E-Mail: Joseph.Lordan@lewisbrisbois.com ELECTRONICALLY ALLISON L. CARDENAS, SB# 272924 3 E-Mail: Allison.Cardenas@lewisbrisbois.com F I L E D Superior Court of California, KAA BAO YANG, SB# 302155 County of San Francisco 4 E-Mail: KaaBao.Yang@lewisbrisbois.com CIARA M. DINEEN, SB# 319913 05/27/2022 Clerk of the Court 5 E-Mail: Ciara.Dineen@lewisbrisbois.com BY: EDNALEEN ALEGRE 333 Bush Street, Suite 1100 Deputy Clerk 6 San Francisco, California 94104-2872 Telephone: 415.362.2580 7 Facsimile: 415.434.0882 8 Attorneys for Defendants EUROMOTORS, INC. DBA MERCEDES- 9 BENZ OF SAN FRANCISCO, a California corporation; and DARIN SPARROW, an 10 individual 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 COUNTY OF SAN FRANCISCO 13 14 LUKMAN DOTSON; ADEAJAI DOTSON; Case No. CGC-20-587463 and ALI HABIBVAND, 15 DECLARATION OF JOSEPH R. Plaintiffs, LORDAN IN SUPPORT OF 16 DEFENDANTS’ MOTION TO CONTINUE vs. TRIAL AND RELATED PRE-TRIAL 17 DATES EUROMOTORS, INC. DBA MERCEDES- 18 BENZ OF SAN FRANCISCO, a California Judge: Hon. Samuel K. Feng corporation; DARIN SPARROW, an Date: June 28, 2022 19 individual; AND DOES 1-20, Time: 9:30 a.m. Dept.: 206 20 Defendants. Action File: November 3, 2020 21 Trial Date: September 7, 2022 22 23 I, Joseph R. Lordan, declare: 24 1. I am an attorney licensed to practice law in the State of California and I am a 25 Partner at Lewis, Brisbois, Bisgaard & Smith, LLP. I represent Defendants EUROMOTORS, 26 INC. DBA MERCEDES-BENZ OF SAN FRANCISCO and DARIN SPARROW in the above- 27 referenced lawsuit. The facts set forth herein are of my own personal knowledge, and if sworn I 28 could and would competently testify thereto. LEWIS B RISBOIS 4865-8669-7248.2 1 B ISGAARD & SMITHLLP DECLARATION OF JOSEPH R LORDAN ISO DEFENDANTS’ MOTION TO CONTINUE TRIAL AND ATTORNEYS AT LAW RELATED PRE-TRIAL DATES 1 2. On May 12, 2022 at approximately 11:30 a.m., I spoke with Plaintiffs’ counsel 2 Hunter Pyle and Bree Ullman regarding scheduling a mediation with two proposed mediators 3 since our previously scheduled mediation with Jeff Ross for December 8, 2022 falls after the trial 4 date. 5 3. I am currently engaged in efforts to secure an agreeable mediator with availability 6 in July or early August of 2022. 7 I declare under penalty of perjury under the laws of the State of California that the 8 foregoing is true and correct and that this declaration was executed on this 27 day of May, 2022, at 9 San Francisco, California. 10 DATED: May 27, 2022 11 12 Joseph R. Lordan, Esq. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LEWIS B RISBOIS 4865-8669-7248.2 2 B ISGAARD & SMITHLLP DECLARATION OF JOSEPH R LORDAN ISO DEFENDANTS’ MOTION TO CONTINUE TRIAL AND ATTORNEYS AT LAW RELATED PRE-TRIAL DATES 1 CALIFORNIA STATE COURT PROOF OF SERVICE Lukman Dotson, et al. v. Euromotors, Inc., et al. 2 San Francisco County Superior Court, Case No. CGC-20-587463 3 STATE OF CALIFORNIA, COUNTY OF ALAMEDA 4 At the time of service, I was over 18 years of age and not a party to this action. My business address is 333 Bush Street, Suite 1100, San Francisco, CA 94104 -2872. 5 On May 27, 2022, I served true copies of the following document(s): DECLARATION 6 OF JOSEPH R. LORDAN IN SUPPORT OF DEFENDANTS’ MOTION TO CONTINUE TRIAL AND RELATED PRE-TRIAL DATES 7 I served the documents on the following persons at the following addresses (including fax 8 numbers and e-mail addresses, if applicable): 9 Bree A. Ullman Hunter Pyle LAW OFFICE OF BREE A. ULLMAN John J. Darin 10 1054 Keith Avenue HUNTER PYLE LAW Berkeley, California 94708 428 Thirteenth Street, 11th Floor 11 Telephone: (425) 318-0708 Oakland, California 94612 Email: bree.esq@gmail.com Telephone: (510) 444-4400 12 Facsimile: (510) 444-4410 Attorneys for Plaintiffs Email: 13 LUKMAN DOTSON hunter@hunterpylelaw.com ADEAJAI DOTSON jdarin@hunterpylelaw.com 14 ALI HABIBVAND Tanya Tambling – ttambling@hunterpylelaw.com 15 Attorneys for Plaintiffs 16 LUKMAN DOTSON ADEAJAI DOTSON 17 ALI HABIBVAND 18 The documents were served by the following means: 19  (BY ELECTRONIC TRANSMISSION ONLY) Only by e-mailing the document(s) to the 20 persons at the e-mail address(es) listed above based on notice provided on March 16, 2020 that, during the Coronavirus (COVID-19) pandemic, this office will be working remotely, 21 not able to send physical mail as usual, and is therefore using only electronic mail. No electronic message or other indication that the transmission was unsuccessful was received 22 within a reasonable time after the transmission. 23 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 24 Executed on May 27, 2022, at Alameda, California. 25 26 27 Monica B. Pena 28 LEWIS B RISBOIS B ISGAARD 4865-8669-7248.2 & SMITHLLP ATTORNEYS AT LAW PROOF OF SERVICE