Preview
I Murray Tragish. Esq., CSB ¹80759
LAW OFFICEiS OF MURRAY TRAGISH
1
5330 Office Center Court, Suite 72
Bakersiield. Calil'ornia 93309
3 Tel: (661) 324-2648
F.,-Mail: murray murraytragish.com
Craii* M. Lynch, Esq.i State Bar No. 105998
3
LYNCH k, LYNCH
10913 Craigton Court
Bakersfield, Califoniia 93311
7 Mailing:
P.O. Box 13515
s
Bakersfield, California 93389-3515
9 Tel: (661) 322-8396
E-Mail: clvnchlu~II nchandlvnchlaw.corn
lp
II Attorneys I'r PiaintiffiCross-Defendant: Aldar lvlini Storage, L.P., a
California Limited Partnership RIMl
l2 Cross-Defendant: Derrel Ridenour
13
SUPERIOR COURT OF TI-IE STATE OF CALIFORNIA
IN AND FOR Tl-IE COUNTY Ol" KERN, METROPOLITAN DISTRICT. CIVIL DIVISION
I6 ALDAR MINI STORAGf., L.P., a Calil'ornia Case No. BCV-20-101265-BCB
lilllited pal'tllershlp,
l7 NOTICE OF NON-OPPOSITION TO
AI,IDAR MINI STORAGF., I.,P.'S AND
ls Plaintiff. DERREL RIDENOURiS MOTION FOR
vs. CONTINUANCE OF MANDATORY
SETTLEMENT CONFERENCE, FINAL
'!
TIIV ENTERPRISES. a California CASE MANAGEMENT AND TRIAL
p
corporation; THV I-IAYKNARIK, LLC, a
California limited liability company; WORLD [Rule 3.1332 of the CRC]
21
OF P ENTECOS'f, INC.i a California non-
profit religious corporation, also known as Date of I-learing: November 14, 2022
22 Time of Hearing: 8:30 a.m.
WORLD OF PENTECOST-LIFE CI-IURCH; Division: H
13 KHACHATUR GHASABYAN, an individual,
also known as CHRIS GHASABYAN, Assigned to the Honorable Bernard C. Barmann
2$ TIGRAN ARUTYUNYAN, an individual; and
DOES Ithrough 500, inclusive. Action Filed: June 1,2020
13 Second Amended Complaint Filed: Dec. 21 2020
De I'endants. First Amended Cross-Complaint: May 24, 2021
16 Trial Date: March 20, 2023
27
WORLD OF PENTECOST, INC., a
Cross-Complainant,
NO I'ICE OF NONOPPOSITION 'lo Al DAR NIINI STORACir. I..l'.'S AND DERRFI. RIDENOUR'S NIOTION IiOR CONTINUANCE OF
NIANDATORV SE'I I'LEMlliNT CONIilllil NCE. IiINAI. CASE ivIANAOEiNILINT AND TRIAI.
I
vs.
ALDAR MINI STORAGE, L.P., a
California limited partnership, DERRELL
RIDENOUR, an individual, HEIDI NELSON,
an individual, THV ENTERPRISES, a
4
California corpoi'ation; THV HAYKNARIK,
6 LLC, a California limited liability company;
ALDAR MINI STORAGE, L.P., a California
limited partnership, KHACHATUR
GHASABYAN, an individual, also known as
CHRIS GHASABYAN; TIGRAN
s ARUTYUNYAN, All Person Unknown,
Claiming any Legal or Equitable Right, Title,
Estate, Lien, or Interest in the Property
lp
Described in the Complaint or Cross-
Complaint Adverse to Cross-Complainant's
Title Thereto, and DOES I through 500,
inclusive,
12
13 fCrossl-Defendants.
14 TO THE ABOVE-ENTITLED COURT„AND TO ALL PARTIES AND THEIR
ATTORNEYS OF RECORD:
16
The hearing on Plaintiff/Cross-Defendant: ALDAR MINI STORAGE, L.P., a California
17
limited partnership, and Cross-Defendant: Derrel Ridenour (hereinafter collectively referred to as
IS
"Movants") Motion for Continuance of the currently scheduled Mandatory Settlement Conference
of February 17, 2023, and Final Case Management and Trial Date of March 20, 2023 (hereinaiteI
21
referred to as the "Motion" ), is set for November 14, 2022, at 8:30 a.m., in Division H in the
22
above-entitled Court, before the Honorable Bernard C. Bannann, Jr.
23
Pursuant to California Code of Civil Procedure section 1005(b)(c), an opposition to the
2s Motion was required to be filed on October 31, 2022, which is nine (9) court days prior to the
hearing on November 14, 2022 and was required to be served in a manner reasonably calculated
27
to ensure delivery on Movants and their counsel of any such opposition.
2S
NOTICE OF NONOPPOSITION TO ALDAR MINI STORAGE, LP.'S AND DERREL RIDENOUR'S MOTION FOR CONTINUANCE OF
MANDATORY SETTLEMENT CONFERENCE, FINAL CASE MANAGEMENT AND TRIAL
2
Movants hereby g&ives notice that as of November 4, 2022, their counsel has not yet received
any opposition to the Motion, nor does the Court docket indicate any Opposition filed. Because
Movants'ounsel has nol,received any opposition to the above-I'eferenced lvlotion, Movants
respectfully requests that the Court grant the requested Order to continue the currently scheduled
3
Mandatory Settlement Conl'erence ol'ebruaiy 17, 2023. and Final Case lvtanagement and Trial
7 Date of March 20, 2023 for a 4-month continuance, to July 2023, or such date asset by the instant
CouiT, and reject any loiThcoining Papers or arguments by Del'endants, Cross-Complainant oi
()
Cross-Defendants and/or other any other party as untimely.
10
Dated: November 4, 2022 LAW
12 LY
13
Iai
17
Ia
20
21
77
i3
25
26
27
2R
NOTICE OF NON OPI'OSITION TO Al Ii alt iNIINI STORAGE. I ..I'FA NI& 17ERRI I. R1131 NOII II 5 MOTION Folt CON I'IN IIANCII OF
MAiNOATOIiV SE I'Tl.l MENT CONFIllifINCIE IiINAI. CAR Ii MANAGI!iMI N I'ND TRIA I.
3
PROOF OF SERVICE
zildar Mini Storage, L.P. vs. THV Enterprises, Inc,, et al.
Eern County Superior Court; Case No. BCV-20-101265-BCB
STATE OF CALIFORNIA, COUNTY OF KERN
I am a citizen of the United States and employed in the County of Kern, State of California and my
business address is 5330 OAice Center Court, Suite 72, Bakersfield, California 93309: I tun over the age of
eighteen and not a party to the within entitled action.
On November 4, 2022, I served the following document(s) described as: NOTICE OF NON-
OPPOSITION TO ALDAR MINI STORAGE. L.P.'S AND DERREL RIDKNOUR'S MOTION
FOR CONTINUANCE OF MANDATORY SKTTLEMKNT CONFERENCE. FINAL CASE
MANAGEMENT AND TRIAL, 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 nue copy thereof, enclosed in a sealed envelope with postage thereon fully
prepaid, for collection and mailing on that date following ordinaiy business practices, in the United
States Mail at the Law Offices of Murray Tragish, Bakersfield, Californi, addressed as shown
below. I am readily familiar with this business'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 saine day itwas placed for
collection and processing.
~Attorne for Defendant/Cross-Defendant, Khachtutur Ghasabvan aka Chris Ghasabyan
Ronald D. Dessy, Esq.
Dessy 62 Dessy APC
1301 "L" Street
Bakersfield, California 93301
Attornev for Defendants/Cross-Defendants: THV Enternrises. TI IV Flavknarik I.LC and
Tiaran Arutvunvan
G. Andrew Sister, Esq.
Quail Cardot, LLP
205 East River Park Circle, Suite 110
Fresno, Ca! ifornia 93720
Attornevs for Defendant/Cross-Comolainant: on behalf of World of Pentecost. Inc. aka
World of Pentecost Life-Church. and Limited Renresentation Attomev 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 Offices
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 $ 1010.6, caused each
such document(s) to be electronically served from 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 i of 2
Rond1952@aol.corn Ronald D. Dessy, Esq.
alexanderslaw@gmail.corn Thomas Alexanders, Jr., Esq.
aslaterta quallcardot.corn G. 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 November 4, 2022, at Bakersfield f Kem.
Page 2 of 2
Preview
I Murray Tragish. Esq., CSB ¹80759 LAW OFFICEiS OF MURRAY TRAGISH 1 5330 Office Center Court, Suite 72 Bakersiield. Calil'ornia 93309 3 Tel: (661) 324-2648 F.,-Mail: murray murraytragish.com Craii* M. Lynch, Esq.i State Bar No. 105998 3 LYNCH k, LYNCH 10913 Craigton Court Bakersfield, Califoniia 93311 7 Mailing: P.O. Box 13515 s Bakersfield, California 93389-3515 9 Tel: (661) 322-8396 E-Mail: clvnchlu~II nchandlvnchlaw.corn lp II Attorneys I'r PiaintiffiCross-Defendant: Aldar lvlini Storage, L.P., a California Limited Partnership RIMl l2 Cross-Defendant: Derrel Ridenour 13 SUPERIOR COURT OF TI-IE STATE OF CALIFORNIA IN AND FOR Tl-IE COUNTY Ol" KERN, METROPOLITAN DISTRICT. CIVIL DIVISION I6 ALDAR MINI STORAGf., L.P., a Calil'ornia Case No. BCV-20-101265-BCB lilllited pal'tllershlp, l7 NOTICE OF NON-OPPOSITION TO AI,IDAR MINI STORAGF., I.,P.'S AND ls Plaintiff. DERREL RIDENOURiS MOTION FOR vs. CONTINUANCE OF MANDATORY SETTLEMENT CONFERENCE, FINAL '! TIIV ENTERPRISES. a California CASE MANAGEMENT AND TRIAL p corporation; THV I-IAYKNARIK, LLC, a California limited liability company; WORLD [Rule 3.1332 of the CRC] 21 OF P ENTECOS'f, INC.i a California non- profit religious corporation, also known as Date of I-learing: November 14, 2022 22 Time of Hearing: 8:30 a.m. WORLD OF PENTECOST-LIFE CI-IURCH; Division: H 13 KHACHATUR GHASABYAN, an individual, also known as CHRIS GHASABYAN, Assigned to the Honorable Bernard C. Barmann 2$ TIGRAN ARUTYUNYAN, an individual; and DOES Ithrough 500, inclusive. Action Filed: June 1,2020 13 Second Amended Complaint Filed: Dec. 21 2020 De I'endants. First Amended Cross-Complaint: May 24, 2021 16 Trial Date: March 20, 2023 27 WORLD OF PENTECOST, INC., a Cross-Complainant, NO I'ICE OF NONOPPOSITION 'lo Al DAR NIINI STORACir. I..l'.'S AND DERRFI. RIDENOUR'S NIOTION IiOR CONTINUANCE OF NIANDATORV SE'I I'LEMlliNT CONIilllil NCE. IiINAI. CASE ivIANAOEiNILINT AND TRIAI. I vs. ALDAR MINI STORAGE, L.P., a California limited partnership, DERRELL RIDENOUR, an individual, HEIDI NELSON, an individual, THV ENTERPRISES, a 4 California corpoi'ation; THV HAYKNARIK, 6 LLC, a California limited liability company; ALDAR MINI STORAGE, L.P., a California limited partnership, KHACHATUR GHASABYAN, an individual, also known as CHRIS GHASABYAN; TIGRAN s ARUTYUNYAN, All Person Unknown, Claiming any Legal or Equitable Right, Title, Estate, Lien, or Interest in the Property lp Described in the Complaint or Cross- Complaint Adverse to Cross-Complainant's Title Thereto, and DOES I through 500, inclusive, 12 13 fCrossl-Defendants. 14 TO THE ABOVE-ENTITLED COURT„AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 16 The hearing on Plaintiff/Cross-Defendant: ALDAR MINI STORAGE, L.P., a California 17 limited partnership, and Cross-Defendant: Derrel Ridenour (hereinafter collectively referred to as IS "Movants") Motion for Continuance of the currently scheduled Mandatory Settlement Conference of February 17, 2023, and Final Case Management and Trial Date of March 20, 2023 (hereinaiteI 21 referred to as the "Motion" ), is set for November 14, 2022, at 8:30 a.m., in Division H in the 22 above-entitled Court, before the Honorable Bernard C. Bannann, Jr. 23 Pursuant to California Code of Civil Procedure section 1005(b)(c), an opposition to the 2s Motion was required to be filed on October 31, 2022, which is nine (9) court days prior to the hearing on November 14, 2022 and was required to be served in a manner reasonably calculated 27 to ensure delivery on Movants and their counsel of any such opposition. 2S NOTICE OF NONOPPOSITION TO ALDAR MINI STORAGE, LP.'S AND DERREL RIDENOUR'S MOTION FOR CONTINUANCE OF MANDATORY SETTLEMENT CONFERENCE, FINAL CASE MANAGEMENT AND TRIAL 2 Movants hereby g&ives notice that as of November 4, 2022, their counsel has not yet received any opposition to the Motion, nor does the Court docket indicate any Opposition filed. Because Movants'ounsel has nol,received any opposition to the above-I'eferenced lvlotion, Movants respectfully requests that the Court grant the requested Order to continue the currently scheduled 3 Mandatory Settlement Conl'erence ol'ebruaiy 17, 2023. and Final Case lvtanagement and Trial 7 Date of March 20, 2023 for a 4-month continuance, to July 2023, or such date asset by the instant CouiT, and reject any loiThcoining Papers or arguments by Del'endants, Cross-Complainant oi () Cross-Defendants and/or other any other party as untimely. 10 Dated: November 4, 2022 LAW 12 LY 13 Iai 17 Ia 20 21 77 i3 25 26 27 2R NOTICE OF NON OPI'OSITION TO Al Ii alt iNIINI STORAGE. I ..I'FA NI& 17ERRI I. R1131 NOII II 5 MOTION Folt CON I'IN IIANCII OF MAiNOATOIiV SE I'Tl.l MENT CONFIllifINCIE IiINAI. CAR Ii MANAGI!iMI N I'ND TRIA I. 3 PROOF OF SERVICE zildar Mini Storage, L.P. vs. THV Enterprises, Inc,, et al. Eern County Superior Court; Case No. BCV-20-101265-BCB STATE OF CALIFORNIA, COUNTY OF KERN I am a citizen of the United States and employed in the County of Kern, State of California and my business address is 5330 OAice Center Court, Suite 72, Bakersfield, California 93309: I tun over the age of eighteen and not a party to the within entitled action. On November 4, 2022, I served the following document(s) described as: NOTICE OF NON- OPPOSITION TO ALDAR MINI STORAGE. L.P.'S AND DERREL RIDKNOUR'S MOTION FOR CONTINUANCE OF MANDATORY SKTTLEMKNT CONFERENCE. FINAL CASE MANAGEMENT AND TRIAL, 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 nue copy thereof, enclosed in a sealed envelope with postage thereon fully prepaid, for collection and mailing on that date following ordinaiy business practices, in the United States Mail at the Law Offices of Murray Tragish, Bakersfield, Californi, addressed as shown below. I am readily familiar with this business'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 saine day itwas placed for collection and processing. ~Attorne for Defendant/Cross-Defendant, Khachtutur Ghasabvan aka Chris Ghasabyan Ronald D. Dessy, Esq. Dessy 62 Dessy APC 1301 "L" Street Bakersfield, California 93301 Attornev for Defendants/Cross-Defendants: THV Enternrises. TI IV Flavknarik I.LC and Tiaran Arutvunvan G. Andrew Sister, Esq. Quail Cardot, LLP 205 East River Park Circle, Suite 110 Fresno, Ca! ifornia 93720 Attornevs for Defendant/Cross-Comolainant: on behalf of World of Pentecost. Inc. aka World of Pentecost Life-Church. and Limited Renresentation Attomev 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 Offices 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 $ 1010.6, caused each such document(s) to be electronically served from 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 i of 2 Rond1952@aol.corn Ronald D. Dessy, Esq. alexanderslaw@gmail.corn Thomas Alexanders, Jr., Esq. aslaterta quallcardot.corn G. 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 November 4, 2022, at Bakersfield f Kem. Page 2 of 2