On February 23, 2021 a
Motion-Secondary
was filed
involving a dispute between
Grewal Cargo Inc.,
Silchuk Logistics, Llc,
Singh, Charanjeet,
Singh, Tajinder,
and
California Department Of Health Care Services,
Darrisha Raquel Wheeler,
Fage Usa Dairy Industry, Inc,
Grewal Cargo Inc.,
Grewel Logistics,
Silchuk Logistics, Llc,
Singh, Charanjeet,
Singh, Tajinder,
for Unlimited Civil Auto Tort
in the District Court of San Joaquin County.
Preview
Electronically Filed
1 TOREM & ASSOCIATES Superior Court of California
ATTORNEYS AT LAW County of San Joaquin
2 9100 Wilshire Boulevard 2021-05-14 16:41:23
Suite 820 East
Clerk: Natalie Bashaw
3 Beverly Hills, California 90212
Telephone: (310) 276-7878
4 Facsimile: (310) 276-8818
RON TOREM, ESQ.
5 YIGAL TOREM, ESQ.
DANIEL A. TOREM, ESQ.
6 State Bar Nos. 134280/110015/325346
7 Attorneys for Plaintiff, JOE EDWIN TAYLOR III, an incompetent adult, BY AND THROUGH
HIS GUARDIAN AD LITEM TELISHA L. MOORE
8
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN JOAQUIN
10
11 JOE EDWIN TAYLOR III, an incompetent CASE NO.
adult, BY AND THROUGH HIS STK-CV-UAT-2021-0001576
12 GUARDIAN AD LITEM TELISHA L. Hon. Judge Robert T. Waters
MOORE
13
14 SUPPLEMENTAL DECLARATION
Plaintiff, OF DANIEL A. TOREM IN
15 vs. SUPPORT OF PLAINTIFF’S
OPPOSITION TO MOTION TO
16 STRIKE
GREWAL CARGO INC.; CHARANJEET
SINGH; and DOES 1 through 150, inclusive,
17 Date: May 25, 2021
18 Defendants. Time: 9:00 a.m.
Dept. : 11
19
20 Filing Date: 02/23/2021
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22
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TO DEFENDANT GREWAL CARGO INC. AND ITS COUNSEL OF RECORD:
24
25 ///
26 ///
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1
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SUPPLEMENTAL DECLARATION OF DANIEL A. TOREM IN SUPPORT OF PLAINTIFF’S
OPPOSITION TO MOTION TO STRIKE
1 DECLARATION OF DANIEL A, TOREM , ESQ.
2 I, DANIEL A, TOREM , ESQ. DO DECLARE AS FOLLOWS:
3
1. I am an attorney at law duly licensed to practice law before all the courts of this state.
4
2. I am trial counsel at Torem & Associates, counsel of record for Plaintiff and I make this
5
declaration of my own personal knowledge and if called upon to testify, I would and could
6
competently testify thereto.
7
8 3. Attached as Exhibit 1 is a Minute Order ordering warrant regarding case no. STK-CR-
9 MDUI-2021-0002489 quashed.
10 4. Attached as Exhibit 2 is a Minute Order ordering warrant regarding case No. STK-TR-MI-
11 2019-00050949 recalled.
12 I declare under penalty of perjury that the foregoing is true and correct this 14th day of May, 2021
13 at Los Angeles, California.
14
15
16
17 ____________________________________________
18 DANIEL A, TOREM
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SUPPLEMENTAL DECLARATION OF DANIEL A. TOREM IN SUPPORT OF PLAINTIFF’S
OPPOSITION TO MOTION TO STRIKE
EXHIBIT 1
Superior Court of California, County of San Joaquin
MINUTE ORDER
Date: 05/12/2021 08:30 AM Case Number: STK-CR-MDUI-2021-0002489
People of the State of California vs. Joe
Edwin Taylor III 07/11/1981
Event Type: Arraignment Department: 5C
Appearances: Presiding Judicial Officer: Richard Vlavianos, Judge. Prosecution appears by
Prosecution Attorney, Melanie Eiges. Attorney Kiarash Feyzjou appears for Defendant, Joe Edwin
Taylor III. Defendant not required to appear. Also attending: rgrant Court Clerk.
Warrant ordered held to this date quashed.
Kiarash Feyzjou present for defense via phone.
Attorney Kiarash Feyzjou retained
Copy of pleading provided to defendant/counsel for defendant.
Formal arraignment waived.
Future Court Dates:
Wednesday May 19, 2021 at 10:00 AM in Department 5C for Further Arraignment;
Defendant ordered present on next court date, unless attorney present.
C.R. release reinstated.
Minute Order
EXHIBIT 2
Superior Court of California, County of San Joaquin
MINUTE ORDER
Date: 05/12/2021 08:30 AM Case Number: STK-TR-MI-2019-0050949
People of the State of California vs. Joe
Edwin Taylor III 07/11/1981
Event Type: Further Arraignment for Driver's Department: 5C
License
Appearances: Presiding Judicial Officer: Richard Vlavianos, Judge. Prosecution appears by
Prosecution Attorney, Melanie Eiges. Attorney Kiarash Feyzjou appears for Defendant, Joe Edwin
Taylor III. Defendant not required to appear. Also attending: rgrant Court Clerk.
Warrant ordered recalled.
Court orders DMV hold released.
Attorney Kiarash Feyzjou retained
Future Court Dates:
Wednesday May 19, 2021 at 10:00 AM in Department 5C for Further Arraignment;
Defendant ordered present on next court date, unless attorney present.
C.R. release reinstated.
Minute Order
1 PROOF OF SERVICE
2 Code of Civil Procedure §§ 1011, 1013, 1013a, 2015.5
3
I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not
4 a party to the within action; my business address is 1607 Pontius Avenue, Los Angeles, California 90025.
5 On the date listed below, I served the foregoing document described as SUPPLEMENTAL
DECLARATION OF DANIEL A. TOREM IN SUPPORT OF PLAINTIFF’S OPPOSITION
6 TO MOTION TO STRIKE on interested parties in this action by placing a true copy thereof enclosed
in a sealed envelope, addressed as follows:
7
8 SEE ATTACHED SERVICE LIST
9
# EMAIL/ELECTRONIC TRANSMISSION: I caused the documents to be sent to the
10 persons at the email addresses listed on the attached service list. I did not receive, within
a reasonable time after the submission, any electronic message or other indication that the
11 transmission was unsuccessful.
12 9 BY PERSONAL SERVICE: I served said document by personally serving the above-
named at ____________________________________.
13
14 EXECUTED on May 14, 2021, at Los Angeles, California.
15
X I declare under penalty of perjury, under the laws of the State of California that the above
16 is true and correct.
17
18
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______________________________
20
Daniel A. Torem
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3
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SUPPLEMENTAL DECLARATION OF DANIEL A. TOREM IN SUPPORT OF PLAINTIFF’S
OPPOSITION TO MOTION TO STRIKE
1
2
3
4
5
6 ATTACHED SERVICE LIST
7
8 Steven B. Health, Esq.
Steven W. Yuen, Esq.
9
Lucy K. Galek, Esq.
10 HEATH & YUEN
11 268 Bush Street, Suite 3006
San Francisco, CA 94104
12 Telephone: (415) 622-7004
13 Facsimile: (415) 373-3957
Email: sheath@heathandyuen.com; syuen@heathandyuen.com; lgalek@heathandyuen.com;
14 wyang@heathandyuen.com; kgorostieta@heathandyuen.com
15
Attorneys for Defendant, GREWAL CARGO, INC. And Charanjeet Singh
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4
28
SUPPLEMENTAL DECLARATION OF DANIEL A. TOREM IN SUPPORT OF PLAINTIFF’S
OPPOSITION TO MOTION TO STRIKE
Preview
Electronically Filed 1 TOREM & ASSOCIATES Superior Court of California ATTORNEYS AT LAW County of San Joaquin 2 9100 Wilshire Boulevard 2021-05-14 16:41:23 Suite 820 East Clerk: Natalie Bashaw 3 Beverly Hills, California 90212 Telephone: (310) 276-7878 4 Facsimile: (310) 276-8818 RON TOREM, ESQ. 5 YIGAL TOREM, ESQ. DANIEL A. TOREM, ESQ. 6 State Bar Nos. 134280/110015/325346 7 Attorneys for Plaintiff, JOE EDWIN TAYLOR III, an incompetent adult, BY AND THROUGH HIS GUARDIAN AD LITEM TELISHA L. MOORE 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN JOAQUIN 10 11 JOE EDWIN TAYLOR III, an incompetent CASE NO. adult, BY AND THROUGH HIS STK-CV-UAT-2021-0001576 12 GUARDIAN AD LITEM TELISHA L. Hon. Judge Robert T. Waters MOORE 13 14 SUPPLEMENTAL DECLARATION Plaintiff, OF DANIEL A. TOREM IN 15 vs. SUPPORT OF PLAINTIFF’S OPPOSITION TO MOTION TO 16 STRIKE GREWAL CARGO INC.; CHARANJEET SINGH; and DOES 1 through 150, inclusive, 17 Date: May 25, 2021 18 Defendants. Time: 9:00 a.m. Dept. : 11 19 20 Filing Date: 02/23/2021 21 22 23 TO DEFENDANT GREWAL CARGO INC. AND ITS COUNSEL OF RECORD: 24 25 /// 26 /// 27 1 28 SUPPLEMENTAL DECLARATION OF DANIEL A. TOREM IN SUPPORT OF PLAINTIFF’S OPPOSITION TO MOTION TO STRIKE 1 DECLARATION OF DANIEL A, TOREM , ESQ. 2 I, DANIEL A, TOREM , ESQ. DO DECLARE AS FOLLOWS: 3 1. I am an attorney at law duly licensed to practice law before all the courts of this state. 4 2. I am trial counsel at Torem & Associates, counsel of record for Plaintiff and I make this 5 declaration of my own personal knowledge and if called upon to testify, I would and could 6 competently testify thereto. 7 8 3. Attached as Exhibit 1 is a Minute Order ordering warrant regarding case no. STK-CR- 9 MDUI-2021-0002489 quashed. 10 4. Attached as Exhibit 2 is a Minute Order ordering warrant regarding case No. STK-TR-MI- 11 2019-00050949 recalled. 12 I declare under penalty of perjury that the foregoing is true and correct this 14th day of May, 2021 13 at Los Angeles, California. 14 15 16 17 ____________________________________________ 18 DANIEL A, TOREM 19 20 21 22 23 24 25 26 27 2 28 SUPPLEMENTAL DECLARATION OF DANIEL A. TOREM IN SUPPORT OF PLAINTIFF’S OPPOSITION TO MOTION TO STRIKE EXHIBIT 1 Superior Court of California, County of San Joaquin MINUTE ORDER Date: 05/12/2021 08:30 AM Case Number: STK-CR-MDUI-2021-0002489 People of the State of California vs. Joe Edwin Taylor III 07/11/1981 Event Type: Arraignment Department: 5C Appearances: Presiding Judicial Officer: Richard Vlavianos, Judge. Prosecution appears by Prosecution Attorney, Melanie Eiges. Attorney Kiarash Feyzjou appears for Defendant, Joe Edwin Taylor III. Defendant not required to appear. Also attending: rgrant Court Clerk. Warrant ordered held to this date quashed. Kiarash Feyzjou present for defense via phone. Attorney Kiarash Feyzjou retained Copy of pleading provided to defendant/counsel for defendant. Formal arraignment waived. Future Court Dates: Wednesday May 19, 2021 at 10:00 AM in Department 5C for Further Arraignment; Defendant ordered present on next court date, unless attorney present. C.R. release reinstated. Minute Order EXHIBIT 2 Superior Court of California, County of San Joaquin MINUTE ORDER Date: 05/12/2021 08:30 AM Case Number: STK-TR-MI-2019-0050949 People of the State of California vs. Joe Edwin Taylor III 07/11/1981 Event Type: Further Arraignment for Driver's Department: 5C License Appearances: Presiding Judicial Officer: Richard Vlavianos, Judge. Prosecution appears by Prosecution Attorney, Melanie Eiges. Attorney Kiarash Feyzjou appears for Defendant, Joe Edwin Taylor III. Defendant not required to appear. Also attending: rgrant Court Clerk. Warrant ordered recalled. Court orders DMV hold released. Attorney Kiarash Feyzjou retained Future Court Dates: Wednesday May 19, 2021 at 10:00 AM in Department 5C for Further Arraignment; Defendant ordered present on next court date, unless attorney present. C.R. release reinstated. Minute Order 1 PROOF OF SERVICE 2 Code of Civil Procedure §§ 1011, 1013, 1013a, 2015.5 3 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not 4 a party to the within action; my business address is 1607 Pontius Avenue, Los Angeles, California 90025. 5 On the date listed below, I served the foregoing document described as SUPPLEMENTAL DECLARATION OF DANIEL A. TOREM IN SUPPORT OF PLAINTIFF’S OPPOSITION 6 TO MOTION TO STRIKE on interested parties in this action by placing a true copy thereof enclosed in a sealed envelope, addressed as follows: 7 8 SEE ATTACHED SERVICE LIST 9 # EMAIL/ELECTRONIC TRANSMISSION: I caused the documents to be sent to the 10 persons at the email addresses listed on the attached service list. I did not receive, within a reasonable time after the submission, any electronic message or other indication that the 11 transmission was unsuccessful. 12 9 BY PERSONAL SERVICE: I served said document by personally serving the above- named at ____________________________________. 13 14 EXECUTED on May 14, 2021, at Los Angeles, California. 15 X I declare under penalty of perjury, under the laws of the State of California that the above 16 is true and correct. 17 18 19 ______________________________ 20 Daniel A. Torem 21 22 23 24 25 26 27 3 28 SUPPLEMENTAL DECLARATION OF DANIEL A. TOREM IN SUPPORT OF PLAINTIFF’S OPPOSITION TO MOTION TO STRIKE 1 2 3 4 5 6 ATTACHED SERVICE LIST 7 8 Steven B. Health, Esq. Steven W. Yuen, Esq. 9 Lucy K. Galek, Esq. 10 HEATH & YUEN 11 268 Bush Street, Suite 3006 San Francisco, CA 94104 12 Telephone: (415) 622-7004 13 Facsimile: (415) 373-3957 Email: sheath@heathandyuen.com; syuen@heathandyuen.com; lgalek@heathandyuen.com; 14 wyang@heathandyuen.com; kgorostieta@heathandyuen.com 15 Attorneys for Defendant, GREWAL CARGO, INC. And Charanjeet Singh 16 17 18 19 20 21 22 23 24 25 26 27 4 28 SUPPLEMENTAL DECLARATION OF DANIEL A. TOREM IN SUPPORT OF PLAINTIFF’S OPPOSITION TO MOTION TO STRIKE