Preview
Murray Tragish, Esq., CSB ¹80759
LAW OFFICES OF MURRAY TRAGISH
5330 Once Center Court, Suite 72
1405 Commercial Way, Suite 130
Bakersfield, California 93309
Tel: (661) 324-2648
E-Mail: Murray Murraytragish.corn
Ray T. Mullen, Esq., CSB ¹111852
LAW OFFICE OF RAY T. MULLKN
5330 Office Center Court, Suite 32
Bakersfield, California 93309
Tel: (661) 631-1531
E-Mail: Ray Raymuilen.corn
9
Attorneys for PlaintifFCross-Defendant: Aldar Mini Storage, L.P., a
California limited partnership and
10
Cross-Defendant: Derrel Ridenour
12 SUPERIOR COURT OF THE STATE OF CALIFORNIA
13 IN AND FOR THE COUNTY OF KERN, METROPOLITAN DISTRICT, CIVIL DIVISION
14
15
ALDAR MINI STORAGE, L,P., a California Case No. BCV-20-101265-BCB
limited partnership,
16
NOTICE OF NON-OPPOSITION TO
PLAINTIFF'S MOTION FOR AN ORDER
PlaintifF, COMPELI.ING DEFENDANT/CROSS-
17
vs. COMPLAINANT: WORLD OF
18
PENTECOST, INC. AKA WORLD OF
THV ENTERPRISES, a California PENTECOST-LIFE CHURCH
19 corporation; THV HAYKNARJK, LLC, a TO PROVIDE COURT-ORDERED
California limited liability company; WORLD FURTHER ANSWERS TO
20 OF PENTECOST, INC., a California non- SPECIAL INTERROGATOIUES, SET ONE,
profit religious corporation, also known as AND FOR THE PAYMENT OF
PREVIOUSLY ORDERED SANC11ONS,
21 WORLD OF PENTECOST-LIFE CHURCH; AND THE IMPOSITION OF
KHACHATUR GHASABYAN, an individual, FURTHER SANCTIONS FOR FAILIRE TO
22 also known as CHRIS GHASABYAN; OBEY COURT ORDER
TIGRAN ARUTYUNYAN, an individual; and [CCP t1'2030.300(a)(1)(3)(e), CCP
23 DOES Ithrough 500, inclusive, t'12030.290(b)(c), CCP $ 2023.010(d)(g); CCP
122023 030(d)(I)(3)(4)l
24
Defendants.
Date of Hearing: August 2, 2022
25
Time of Hearing: 8:30 a,m.
Division: T-2 (Metropolitan Traffic Division)
26 3131 Arrow Street, Bakersfield, CA 93308
27
WORLD OF PENTECOST, INC., a Assigned to the Honorable Bernard C. Barmann
28
Action Filed: June I, 2020
First Amended Cross-Complaint: May 24, 2021
NOTICE OF NON-OFPOSITION TO PLAINTIFF'S MOTION FOR AN ORDER COMPELLING DEFENDANT/CROSSCOMPLAINANT;
WORLD OF PENTECOST-LIFE CHURCH TO PROVIDE COURTNRDERED FURTHER ANSWERS TO SPECIAL INTERROGATORIES,
SET ONE, AND FOR THE PAYMENT OF PREVIOUSLY ORDERED SANCTIONS. AND THE IMPOSITION OF FURTHER SANCTIONS
FOR FAILURE TO OBEY COURT ORDER
I
Cross-Complainant, Trial Date: March 20, 2023
vs.
3 ALDAR MINI STORAGE, L.P., a
California limited partnership, DERRELL
4
RIDENOUR, an individual, HEIDI NELSON,
5 an individual, THV ENTERPRISES, a
California corporation; THV HAYKNARIK,
6 LLC, a California limited liability company;
7
ALDAR MINI STORAGE, L.P„a California
limited partnership, KHACHATUR
8 GHASABYAN, an individual, also known as
CHRIS GHASABYAN; TIGRAN
9
ARUTYUNYAN, All Person Unknown,
10
Claiming any Legal or Equitable Right, Title,
Estate, Lien, or Interest in the Property
11 Described in the Complaint or Cross-
Complaint Adverse to Cross-Complainant's
12
Title Thereto, and DOES I through 500,
13
inclusive,
14 fCross)-Defendants.
15
TO THE ABOVE-ENTITLED COURT, AND TO ALL PARTIES AND THEIR
16
ATTORNEYS OF RECORD:
17
The hearing on Plaintiff/Cross-Defendant: ALDAR MINI STORAGE, L.P., a California
18
!9 limited partnership (" Movant" ), Motion for an Order Compelling Court-Ordered Further Answers
20 to Special Interrogatories, Set One, and For the Payment of Court-Ordered Monetary Sanctions, and
21
Imposition of Sanctions, including for Failure to Obey Court Order, against Defendant/Cross-
22
Complainant: World of Pentecost-Life Church, Inc. aka World of Pentecost-Life Church
23
24
(hereinafter referred to as "WOP"), and to dismiss WOP's Answer to Complaint and WOP's Cross-
25 Complaint filed in these proceedings, (hereinafter referred to as the "Motion") is set for hearing on
26
August 2, 2022, at g:30 a,m. in Deparlment T-2 of the above-entitled Court, located at 3131 Arrow
27
Street, Bakersfield, California 93308, before the Honorable Bernard C. Barmann, Jr.
28
NOTICE OF NON.OFFOSITION TO PLAINTIFF'8 MOTION FOR AN ORDER COMPELLING DEFENDANTICROSS~MPLAINANT:
WORLD OF PENTECOST-MFE CHURCH TO PROVIDE COURT-ORDERED FURTHER ANSWERS TO SPECIAI. INTERROGATORIES,
SET ONE, AND FOR THE PAYMENT OF PREVIOUSLY ORDERED SANCTIONS, AND THE IMPOSITION OF FURTHER SANCTIONS
FOR FAILURE TO OBEY COURT ORDER
2
I
Pursuant to California Code of Civil Procedure section 1005(b)(c), an opposition to the
Motion was required to be filed not less than nine (9) court days prior to the hearing on Julv 20.
2022 and was required to be served in a manner reasonably calculated to ensure delivery on
Movant and its counsel of any such opposition.
5
Movant hereby gives notice that as of July 21, 21}21, its counsel has not yet received any
6
opposition to the Motion, nor does the Court docket indicate any Opposition filed. Because
Movant's counsel has not received any opposition to the above-referenced Motion, Movant
respectfully requests that the Court grant the requested Order Compelling Court-Ordered Furthei
10
Answers to Special interrogatories, Set One, and For the Payment of Court-Ordered Monetary
ll
Sanctions, and Imposition of Sanctions, including lbr Failure to Obey Court Order, against WOP
12
13 and to dismiss WOP's Answer to Complaint and WOP's Cross-Complaint filed in these
14 proceedings, and reject any forthcoming papers or arguments by WOP and/or other any other
party as untimely,
16
17
Dated: July 21, 2022 L R.RA
18 L T
19
by;
Murray Tragis Attorney for Plaintiff/
Cross-Defenil: Aldar Mini Storage, L ., a
CaliTornia limite rtnerslup and Cros
Defendant: Derrel RI
23
NOTICII'OF NON-OPPOSITION TO PI.AINTIFP'S MOTION POR AN ORDER COMPELLING 13EFENDANT/CROSS-COMPLAINANT;
WORI D Ol'ENTECOSTLIPE Ci IURCII TO I'ltOVIDE COUItTORDERED FURTI IER ANSWERS TO SPECIAL INTERROGATORIES,
SET ON E, AND POR Tl I E PAYMENT Ol'REVIOUSLY ORDERED SANCTIONS, AND TIIE I MI'OS ITION OP FURTk! E R SANCTIONS
FOR FAILURE TO OBEY COURT ORDER
3
PROOF OF SERVICE
zlldar Mini Storage, L.P. vs. THV Enterprises, Inc., et al.
Kern County Superior Court; Case No. BCV-20-/0/265-BCB
STATE OF CALIFORNIA, COUNTY OF KERN
I am a citizen of the United States and employed in the County of Kem, State of California and my
business address is 5330 Office Center Court, Suite 72, Bakersfield, California 93309; I am over the age of
eighteen and not a party to the within entitled action.
On July 21, 2022, I served the following document(s) described as: NOTICE OF NOLN-OPPOSITION
TO PLAINTIFF'S MOTION FOR AN ORDER COMPELLING DEFENDANT/CROSS-
COMPLAINANT: WORLD OF PENTECOST-LIFE CHURCH TO PROVIDE COURT-
ORDERED FURTHER ANSWERS TO SPECIAL INTERROGATORIES. SKT ONK. AND FOR
THE PAYMENT OF PREVIOUSLY ORDERED SANCTIONS. AND THK IMPOSITION OF
FURTHER SANCTIONS FOR FAILURE TO OBEY COURT ORDER, on the interested parties to
said action or through their attorneys of record, by placing a true copy thereof in a sealed envelope,
addressed as shown below, by the following means:
XX (By Mail) By placing a true copy thereof, enclosed in a sealed envelope with postage thereon fully
prepaid, for collection and mailing on that date following ordinary business practices, in the United
States Mail at the Law Offices of Murray Tragish, Bakersfield, California, addressed as shown
below. I am readily familiar with this busuiess's practice for collection and processing of
correspondence for mailing with the U.S. Postal Service, and in the ordinary course of business
correspondence would be deposited with the U.S. Postal Service the same day it was placed for
collection and processing.
Attornev for Defendant/Cross-Defendant: Khachartur Ghasabvan aka Chris Ghasabvan
Ronald D. Dessy, Esq.
Dessy & Dessy APC
1301 "L" Street
Bakersfield, California 93301
Att f Df d t/C -Df d t:YHVat t 't'H~VH k 'kLLC d
Ti m an Arutvunvan
Andrew Sister, Fsq.
Fennemore Dowling Aaron
8080 North Palm Avenue, Third Floor
Fresno, California 93711
Attornevs for Defendant/Cross-Comnlainant: on behalf of World of Pentecost. Inc. aka
World of Pentecost Life-Church. and Limited Renresentation Attornev for World of
Pentecost Church aka World of Pentecost Life Church
Thomas M. Alexander, Jr. Esq. Thomas M. Alexander, Jr, Esq.
Alexander Law Offices Thomas Alexander Law Ofiices
468 N. Camden Drive, Suite 200 226 East Sixth Street
Beverly Hills, California 90210 Beaumont, California 92223
XX (By Electronic Service) Complying with California Code of Civil Procedure ss1010.6, caused each
such document(s) to be electronically served I'rom amy@murraytragish.corn to each addressee
below. The file transmission was reported as complete and a copy of the receipt will be maintained
with the original document(s) in our office.
Page 1Df2
Rond1952@aokcom Ronald D. Dessy, Esq.
alexanderslaw gmaibcom Thomas Alexanders, Jr., Esq.
aslater@fennemorelaw.corn Andrew Sister, Esq.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and
correct, and that I am employed in the office of a member of the Bar of this Court at whose direction the
service was made. Executed on July 21, 2022, at Bake
Am Belye
Page 2 of 2
Preview
Murray Tragish, Esq., CSB ¹80759 LAW OFFICES OF MURRAY TRAGISH 5330 Once Center Court, Suite 72 1405 Commercial Way, Suite 130 Bakersfield, California 93309 Tel: (661) 324-2648 E-Mail: Murray Murraytragish.corn Ray T. Mullen, Esq., CSB ¹111852 LAW OFFICE OF RAY T. MULLKN 5330 Office Center Court, Suite 32 Bakersfield, California 93309 Tel: (661) 631-1531 E-Mail: Ray Raymuilen.corn 9 Attorneys for PlaintifFCross-Defendant: Aldar Mini Storage, L.P., a California limited partnership and 10 Cross-Defendant: Derrel Ridenour 12 SUPERIOR COURT OF THE STATE OF CALIFORNIA 13 IN AND FOR THE COUNTY OF KERN, METROPOLITAN DISTRICT, CIVIL DIVISION 14 15 ALDAR MINI STORAGE, L,P., a California Case No. BCV-20-101265-BCB limited partnership, 16 NOTICE OF NON-OPPOSITION TO PLAINTIFF'S MOTION FOR AN ORDER PlaintifF, COMPELI.ING DEFENDANT/CROSS- 17 vs. COMPLAINANT: WORLD OF 18 PENTECOST, INC. AKA WORLD OF THV ENTERPRISES, a California PENTECOST-LIFE CHURCH 19 corporation; THV HAYKNARJK, LLC, a TO PROVIDE COURT-ORDERED California limited liability company; WORLD FURTHER ANSWERS TO 20 OF PENTECOST, INC., a California non- SPECIAL INTERROGATOIUES, SET ONE, profit religious corporation, also known as AND FOR THE PAYMENT OF PREVIOUSLY ORDERED SANC11ONS, 21 WORLD OF PENTECOST-LIFE CHURCH; AND THE IMPOSITION OF KHACHATUR GHASABYAN, an individual, FURTHER SANCTIONS FOR FAILIRE TO 22 also known as CHRIS GHASABYAN; OBEY COURT ORDER TIGRAN ARUTYUNYAN, an individual; and [CCP t1'2030.300(a)(1)(3)(e), CCP 23 DOES Ithrough 500, inclusive, t'12030.290(b)(c), CCP $ 2023.010(d)(g); CCP 122023 030(d)(I)(3)(4)l 24 Defendants. Date of Hearing: August 2, 2022 25 Time of Hearing: 8:30 a,m. Division: T-2 (Metropolitan Traffic Division) 26 3131 Arrow Street, Bakersfield, CA 93308 27 WORLD OF PENTECOST, INC., a Assigned to the Honorable Bernard C. Barmann 28 Action Filed: June I, 2020 First Amended Cross-Complaint: May 24, 2021 NOTICE OF NON-OFPOSITION TO PLAINTIFF'S MOTION FOR AN ORDER COMPELLING DEFENDANT/CROSSCOMPLAINANT; WORLD OF PENTECOST-LIFE CHURCH TO PROVIDE COURTNRDERED FURTHER ANSWERS TO SPECIAL INTERROGATORIES, SET ONE, AND FOR THE PAYMENT OF PREVIOUSLY ORDERED SANCTIONS. AND THE IMPOSITION OF FURTHER SANCTIONS FOR FAILURE TO OBEY COURT ORDER I Cross-Complainant, Trial Date: March 20, 2023 vs. 3 ALDAR MINI STORAGE, L.P., a California limited partnership, DERRELL 4 RIDENOUR, an individual, HEIDI NELSON, 5 an individual, THV ENTERPRISES, a California corporation; THV HAYKNARIK, 6 LLC, a California limited liability company; 7 ALDAR MINI STORAGE, L.P„a California limited partnership, KHACHATUR 8 GHASABYAN, an individual, also known as CHRIS GHASABYAN; TIGRAN 9 ARUTYUNYAN, All Person Unknown, 10 Claiming any Legal or Equitable Right, Title, Estate, Lien, or Interest in the Property 11 Described in the Complaint or Cross- Complaint Adverse to Cross-Complainant's 12 Title Thereto, and DOES I through 500, 13 inclusive, 14 fCross)-Defendants. 15 TO THE ABOVE-ENTITLED COURT, AND TO ALL PARTIES AND THEIR 16 ATTORNEYS OF RECORD: 17 The hearing on Plaintiff/Cross-Defendant: ALDAR MINI STORAGE, L.P., a California 18 !9 limited partnership (" Movant" ), Motion for an Order Compelling Court-Ordered Further Answers 20 to Special Interrogatories, Set One, and For the Payment of Court-Ordered Monetary Sanctions, and 21 Imposition of Sanctions, including for Failure to Obey Court Order, against Defendant/Cross- 22 Complainant: World of Pentecost-Life Church, Inc. aka World of Pentecost-Life Church 23 24 (hereinafter referred to as "WOP"), and to dismiss WOP's Answer to Complaint and WOP's Cross- 25 Complaint filed in these proceedings, (hereinafter referred to as the "Motion") is set for hearing on 26 August 2, 2022, at g:30 a,m. in Deparlment T-2 of the above-entitled Court, located at 3131 Arrow 27 Street, Bakersfield, California 93308, before the Honorable Bernard C. Barmann, Jr. 28 NOTICE OF NON.OFFOSITION TO PLAINTIFF'8 MOTION FOR AN ORDER COMPELLING DEFENDANTICROSS~MPLAINANT: WORLD OF PENTECOST-MFE CHURCH TO PROVIDE COURT-ORDERED FURTHER ANSWERS TO SPECIAI. INTERROGATORIES, SET ONE, AND FOR THE PAYMENT OF PREVIOUSLY ORDERED SANCTIONS, AND THE IMPOSITION OF FURTHER SANCTIONS FOR FAILURE TO OBEY COURT ORDER 2 I Pursuant to California Code of Civil Procedure section 1005(b)(c), an opposition to the Motion was required to be filed not less than nine (9) court days prior to the hearing on Julv 20. 2022 and was required to be served in a manner reasonably calculated to ensure delivery on Movant and its counsel of any such opposition. 5 Movant hereby gives notice that as of July 21, 21}21, its counsel has not yet received any 6 opposition to the Motion, nor does the Court docket indicate any Opposition filed. Because Movant's counsel has not received any opposition to the above-referenced Motion, Movant respectfully requests that the Court grant the requested Order Compelling Court-Ordered Furthei 10 Answers to Special interrogatories, Set One, and For the Payment of Court-Ordered Monetary ll Sanctions, and Imposition of Sanctions, including lbr Failure to Obey Court Order, against WOP 12 13 and to dismiss WOP's Answer to Complaint and WOP's Cross-Complaint filed in these 14 proceedings, and reject any forthcoming papers or arguments by WOP and/or other any other party as untimely, 16 17 Dated: July 21, 2022 L R.RA 18 L T 19 by; Murray Tragis Attorney for Plaintiff/ Cross-Defenil: Aldar Mini Storage, L ., a CaliTornia limite rtnerslup and Cros Defendant: Derrel RI 23 NOTICII'OF NON-OPPOSITION TO PI.AINTIFP'S MOTION POR AN ORDER COMPELLING 13EFENDANT/CROSS-COMPLAINANT; WORI D Ol'ENTECOSTLIPE Ci IURCII TO I'ltOVIDE COUItTORDERED FURTI IER ANSWERS TO SPECIAL INTERROGATORIES, SET ON E, AND POR Tl I E PAYMENT Ol'REVIOUSLY ORDERED SANCTIONS, AND TIIE I MI'OS ITION OP FURTk! E R SANCTIONS FOR FAILURE TO OBEY COURT ORDER 3 PROOF OF SERVICE zlldar Mini Storage, L.P. vs. THV Enterprises, Inc., et al. Kern County Superior Court; Case No. BCV-20-/0/265-BCB STATE OF CALIFORNIA, COUNTY OF KERN I am a citizen of the United States and employed in the County of Kem, State of California and my business address is 5330 Office Center Court, Suite 72, Bakersfield, California 93309; I am over the age of eighteen and not a party to the within entitled action. On July 21, 2022, I served the following document(s) described as: NOTICE OF NOLN-OPPOSITION TO PLAINTIFF'S MOTION FOR AN ORDER COMPELLING DEFENDANT/CROSS- COMPLAINANT: WORLD OF PENTECOST-LIFE CHURCH TO PROVIDE COURT- ORDERED FURTHER ANSWERS TO SPECIAL INTERROGATORIES. SKT ONK. AND FOR THE PAYMENT OF PREVIOUSLY ORDERED SANCTIONS. AND THK IMPOSITION OF FURTHER SANCTIONS FOR FAILURE TO OBEY COURT ORDER, on the interested parties to said action or through their attorneys of record, by placing a true copy thereof in a sealed envelope, addressed as shown below, by the following means: XX (By Mail) By placing a true copy thereof, enclosed in a sealed envelope with postage thereon fully prepaid, for collection and mailing on that date following ordinary business practices, in the United States Mail at the Law Offices of Murray Tragish, Bakersfield, California, addressed as shown below. I am readily familiar with this busuiess's practice for collection and processing of correspondence for mailing with the U.S. Postal Service, and in the ordinary course of business correspondence would be deposited with the U.S. Postal Service the same day it was placed for collection and processing. Attornev for Defendant/Cross-Defendant: Khachartur Ghasabvan aka Chris Ghasabvan Ronald D. Dessy, Esq. Dessy & Dessy APC 1301 "L" Street Bakersfield, California 93301 Att f Df d t/C -Df d t:YHVat t 't'H~VH k 'kLLC d Ti m an Arutvunvan Andrew Sister, Fsq. Fennemore Dowling Aaron 8080 North Palm Avenue, Third Floor Fresno, California 93711 Attornevs for Defendant/Cross-Comnlainant: on behalf of World of Pentecost. Inc. aka World of Pentecost Life-Church. and Limited Renresentation Attornev for World of Pentecost Church aka World of Pentecost Life Church Thomas M. Alexander, Jr. Esq. Thomas M. Alexander, Jr, Esq. Alexander Law Offices Thomas Alexander Law Ofiices 468 N. Camden Drive, Suite 200 226 East Sixth Street Beverly Hills, California 90210 Beaumont, California 92223 XX (By Electronic Service) Complying with California Code of Civil Procedure ss1010.6, caused each such document(s) to be electronically served I'rom amy@murraytragish.corn to each addressee below. The file transmission was reported as complete and a copy of the receipt will be maintained with the original document(s) in our office. Page 1Df2 Rond1952@aokcom Ronald D. Dessy, Esq. alexanderslaw gmaibcom Thomas Alexanders, Jr., Esq. aslater@fennemorelaw.corn Andrew Sister, Esq. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that I am employed in the office of a member of the Bar of this Court at whose direction the service was made. Executed on July 21, 2022, at Bake Am Belye Page 2 of 2