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I Murray Tragish, Eso., CSB it 80759
LAW OFFICES 05'URRAY TRAGISH
2 5330 Oflice Center Court, Suite 72
Bakersfield, California 93309
3 Tel: (661) 324-2648
E-Mail:murray murraytragish.corn
4
Craig M. Lynch, Esq., State Bar No. 105998
5
LYNCH //4 LYNCH
6 10913 Craigton Court
Bakersfield, California 93311
7 Mailing:
P.O. Box 13515
8
Bakersfield, California 93389-3515
9 Tel: (661) 322-8396
E-Mail:clvnch&lvnchandlvnchlaw.corn
California
10
Attorneys for Plaintiff/Cross-Defendant: Alder Mini Storage, L.P., a
ll limited partnership and
Cross-Defendant: Derrel Ridenour
12
SUPERIOR COURT OF THE STATE OF CALIFORNIA
14 IN AND FOR THE COUNTY OF KERN, METROPOLITAN DISTRICT, CIVIL DIVISION
IS
ALDAR MINI STORAGE, L.P., a California I
Case No. BCV-20-101265-BCB
16
limited partnership,
NOTICE OF CONTINUANCE OF
17 PLAINTIFF'S MOTION FOR AN ORDER
Plaintiff, COMPELLING DEFENDANT/CROSS-
18 vs. COMPLAINANT: WORLD OF
PENTECOST, INC. AKA
19
THV ENTERPRISES, a California WORLD OF PENTECOST-LIFE CHURCH
corporation; THV HAYKNARJK, LLC, a TO PROVIDE WRITTEN RESPONSES
20
Cahfornia limited liability company; WORLD AND DOCUMENTS TO DEMAND FOR
OF PENTECOST, INC., a California non- PRODUCTION OF DOCUMENTS SET
21
profit religious corporation, also known as TWO, AND FOR PREVIOUSLY IMPOSED
SANCTIONS AND THE IMPOSITION OF
22 WORLD OF PENTECOST-LIFE CHURCH; FURTHER MONETARY SANCTIONS FOR
KHACHATUR GHASABYAN, an individual, FAILURE TO OBEY COURT ORDERS
23 also known as CHRIS GHASABYAN; [CCP ii2023.010(d)(g), CCP $ 2031.300(a)(b);
TIGRAN ARUTYUNYAN, an individual; and and CRC Rule 3.1345(b)(I);
24 DOES Ithrough 500, inclusive, CCP ti2023.030(a)]
25 Defendants. Date of Hearing; November 21, 2022
Time of Hearing: 8:30 a.m.
26 Division: H
27 Assigned to the Honorable Bernard C,
WORLD OF PENTECOST, INC., a Barmann
28
Cross-Complainant,
NOTICE OF CONTINUANCE OF PLAINTIFF'S MOTION FOR AN ORDER COMPEI.LING DEFENDANTICROSSCOMPLAINANT:
WORLD OF PENTECOST-LIFE CHURCH TO PROVIDE WRITTEN RESPONSES AND DOCUMENTS TO DEMAND FOR
PRODUCTION OF DOCUMENTS, SET TWO, AND FOR PREVIOUSLY IMPOSED SANCTIONS AND THE IMPOSITION OF FURTHER
MONETARY SANCTIONS FOR FAILURE TO OEERY COURT ORDERS - I
vs. Action Filed: June I, 2020
ALDAR MINI STORAGE, L.P., a First Amended Complaint: July 13, 2020
Second Amended Complaint: Dec. 21, 2020
California limited partnership, DERRELL Cross-Complaint: February 26, 2021
RIDENOUR, an individual, HEIDI NELSON, First Amended Cross-Complaint: May 24, 2021
an individuai, THV ENTERPRISES, a Trial Date: October 30, 2023
4
California corporation; THV HAYKNARIK,
LLC, a California limited liability company;
ALDAR MINI STORAGE, L.P., a California
limited partnership, KHACHATUR
GHASABYAN, an individual, also known as
CHRIS GHASAB YAN; TIGRAN
8 ARUTYUNYAN, All Person Unknown,
Claiming any Legal or Equitable Right, Title,
Estate, Lien, or Interest in the Property
Described in the Complaint or Cross-
Complaint Adverse to Cross-Complainant's
Title Thereto, and DOES I through 500,
inclusive,
l2
13 fCrossl-Defendants
I4 TO ALL PARTIES AND THEIR RESPECTIVE COUNSEL OF RECORD:
California
NOTICE IS HEREBY GIVEN that the Court has continued the hearing on Plaintiff/Cross.
Is
Defendant: ALDAR MINI STORAGE, L.P., a limited partnership, and Cross.
17
Defendant: Derrel Ridenour (hereinafter collectively referred to as "Movants") Motion tc
18
I9 Compel Written Responses and Documents to Demand for Production of Documents, Set Two, and
for Previously Imposed Sanctions and the Imposition of Further Monetary Sanctions for Failure tc
21
Obey Court Orders, against Defendant/Cross-Complainant: World of Pentecost-Life Church, Inc,
22
aka World of Pentecost-Life Church (hereinafter referred to as "WOP") (hereinafter referred to as
23
the "Motion'*), which shall now be heard on November 21. 2022, at 8:30 a.m., in Division H of the
25 above-entitled Court, before the Honorable Bernard C. Barmatut, Jr.
27
28
NOTICE OF CONTINUANCE OF PI.AINTIFF'S MOTION FOR AN ORDER COMPELLINO DEFENDANT/CROSS-COMPLAINANT:
WORLD OF PENTECOST-LIFE CHURCH TO PROVIDE WRITTEN RESPONSES AND DOCUMENTS TO DEMAND FOR
PRODUCTION OF DOCUMENTS, SET TWO, AND FOR PREVIOUSLY IMPOSED SANCTIONS AND THE IMPOSITION OF FURTHER
MONETARY SANCTIONS FOR FAILURE TO OBERY COURT ORDERS -2
Dated: November 15, 2022 L
L
by:
Murray Tr ish, Attorneys for Plaintiff
Cross-Defe ant: Aldtn Mini Storage, .P., a
Californialim dpaltnershipandCr s-
Defendant: Derre 'our
10
12
13
10)
17
IS
20
21
72
76
27
NOTICI OF CONTINUANC!.'F PI.AINTII'I'*S MOTION FOR AN ORDER Coivll'EI.I.INO DEI'l(NDANT/CRF).'ili-COMPI.AINAN)&
WOR! D OF I'l)/I I COST LIFE CIIURCII TO I'ROVII&E 'IVRITTEN RL'SPONSES AND DOCUNff NTS TO I&ESIAND
I OR
I'RODUCOON Ol'OCUMIlNTS. '.in/I'WO, AND N&R I'RIIVIOUiil Y IMPOSED SANCTIONS AND Tf il1'ls ll'OSITION
OF I'URTI III R
MDNI'TARY sANcTIQNs I'oa I'AII URE To ouERY co(IR'I'()RI)nas -3
PROOF OF SERVICE
Aldar Mini Storage, L.P. vs. THV Enterprises, Inc., et af
Kern 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 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 November 15, 2022, I served the following document(s) described as: NOTICE OF
CONTINUANCE OF PLAINTIFF'S MOTION FOR AN ORDER COMPELLING
DEFENDANT/CROSS-COMPLAINANT: WORLD OF PENTECOST-LIFE CHURCH TO
PROVIDE WRITTEN RESPONSES AND DOCUMENTS TO DEME&% FOR PRODUCTION OF
DOCUMENTS. SKT TWO. AND FOR PREVIOUSLY IMPOSED SANCTIONS AaND THE
IMPOSITION OF FURTHER MONETARY SANCTIONS FOR FAILURE TO OBKRY COURT
ORDERS, 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 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 same day itwas placed for
collection and processing.
Attomev for Defendant/Cross-Defendant: Khachartur Ghasabvan aka Chris (ihasabvan
P.ona!d D. Dessy, Esq.
Dessy k Dessy APC
1301 "L" Street
Bakersfield, California 93301
Attomev for Defendants/Cross-Defendants: TI-1V Enterorises. Tl IV kjavknarik. LLC and
Tiaran Arutvunvan
G. Andrew Sister, Esq.
Quail Cardot, LLP
205 East River Park Circle, Suite 110
Fresno, California 93720
Attomevs for Defendant/Cross-Comnlainant: on behalf of World of Pentecost. Inc, aka
World of Pentecost Life-Church. and Limited Representation 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 Offices
468 N. Camden Drive, Suite 200 226 East Sixth Street
Beverly Hills, California 90210 Beauinont, California 92223
Courtesv coov:
Stratton S. Barbee, Esq.
Law Offices of Stratton S. Barbee
6700 Freeport Boulevard, Suite 203-A
Sacramento, California 95822
Page i of 2
X (By Electronic Service) Complying with California Code of Civil Procedure tj1010.6, 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.
Rond1952@aokcom Ronald D. Dessy, Esq.
alexanderslaw@gmail.corn Thomas Alexanders, Jr., Esq.
aslater quallcardot.corn G. Andrew Slater, Esq.
strattonbarbee@hotmail.corn Stratton S. Barbee, Esq. (courtesy copy)
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 15, 2022, at Bak f ld C 1'f '
nty of Kem.
Page 2 of 2
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I Murray Tragish, Eso., CSB it 80759 LAW OFFICES 05'URRAY TRAGISH 2 5330 Oflice Center Court, Suite 72 Bakersfield, California 93309 3 Tel: (661) 324-2648 E-Mail:murray murraytragish.corn 4 Craig M. Lynch, Esq., State Bar No. 105998 5 LYNCH //4 LYNCH 6 10913 Craigton Court Bakersfield, California 93311 7 Mailing: P.O. Box 13515 8 Bakersfield, California 93389-3515 9 Tel: (661) 322-8396 E-Mail:clvnch&lvnchandlvnchlaw.corn California 10 Attorneys for Plaintiff/Cross-Defendant: Alder Mini Storage, L.P., a ll limited partnership and Cross-Defendant: Derrel Ridenour 12 SUPERIOR COURT OF THE STATE OF CALIFORNIA 14 IN AND FOR THE COUNTY OF KERN, METROPOLITAN DISTRICT, CIVIL DIVISION IS ALDAR MINI STORAGE, L.P., a California I Case No. BCV-20-101265-BCB 16 limited partnership, NOTICE OF CONTINUANCE OF 17 PLAINTIFF'S MOTION FOR AN ORDER Plaintiff, COMPELLING DEFENDANT/CROSS- 18 vs. COMPLAINANT: WORLD OF PENTECOST, INC. AKA 19 THV ENTERPRISES, a California WORLD OF PENTECOST-LIFE CHURCH corporation; THV HAYKNARJK, LLC, a TO PROVIDE WRITTEN RESPONSES 20 Cahfornia limited liability company; WORLD AND DOCUMENTS TO DEMAND FOR OF PENTECOST, INC., a California non- PRODUCTION OF DOCUMENTS SET 21 profit religious corporation, also known as TWO, AND FOR PREVIOUSLY IMPOSED SANCTIONS AND THE IMPOSITION OF 22 WORLD OF PENTECOST-LIFE CHURCH; FURTHER MONETARY SANCTIONS FOR KHACHATUR GHASABYAN, an individual, FAILURE TO OBEY COURT ORDERS 23 also known as CHRIS GHASABYAN; [CCP ii2023.010(d)(g), CCP $ 2031.300(a)(b); TIGRAN ARUTYUNYAN, an individual; and and CRC Rule 3.1345(b)(I); 24 DOES Ithrough 500, inclusive, CCP ti2023.030(a)] 25 Defendants. Date of Hearing; November 21, 2022 Time of Hearing: 8:30 a.m. 26 Division: H 27 Assigned to the Honorable Bernard C, WORLD OF PENTECOST, INC., a Barmann 28 Cross-Complainant, NOTICE OF CONTINUANCE OF PLAINTIFF'S MOTION FOR AN ORDER COMPEI.LING DEFENDANTICROSSCOMPLAINANT: WORLD OF PENTECOST-LIFE CHURCH TO PROVIDE WRITTEN RESPONSES AND DOCUMENTS TO DEMAND FOR PRODUCTION OF DOCUMENTS, SET TWO, AND FOR PREVIOUSLY IMPOSED SANCTIONS AND THE IMPOSITION OF FURTHER MONETARY SANCTIONS FOR FAILURE TO OEERY COURT ORDERS - I vs. Action Filed: June I, 2020 ALDAR MINI STORAGE, L.P., a First Amended Complaint: July 13, 2020 Second Amended Complaint: Dec. 21, 2020 California limited partnership, DERRELL Cross-Complaint: February 26, 2021 RIDENOUR, an individual, HEIDI NELSON, First Amended Cross-Complaint: May 24, 2021 an individuai, THV ENTERPRISES, a Trial Date: October 30, 2023 4 California corporation; THV HAYKNARIK, LLC, a California limited liability company; ALDAR MINI STORAGE, L.P., a California limited partnership, KHACHATUR GHASABYAN, an individual, also known as CHRIS GHASAB YAN; TIGRAN 8 ARUTYUNYAN, All Person Unknown, Claiming any Legal or Equitable Right, Title, Estate, Lien, or Interest in the Property Described in the Complaint or Cross- Complaint Adverse to Cross-Complainant's Title Thereto, and DOES I through 500, inclusive, l2 13 fCrossl-Defendants I4 TO ALL PARTIES AND THEIR RESPECTIVE COUNSEL OF RECORD: California NOTICE IS HEREBY GIVEN that the Court has continued the hearing on Plaintiff/Cross. Is Defendant: ALDAR MINI STORAGE, L.P., a limited partnership, and Cross. 17 Defendant: Derrel Ridenour (hereinafter collectively referred to as "Movants") Motion tc 18 I9 Compel Written Responses and Documents to Demand for Production of Documents, Set Two, and for Previously Imposed Sanctions and the Imposition of Further Monetary Sanctions for Failure tc 21 Obey Court Orders, against Defendant/Cross-Complainant: World of Pentecost-Life Church, Inc, 22 aka World of Pentecost-Life Church (hereinafter referred to as "WOP") (hereinafter referred to as 23 the "Motion'*), which shall now be heard on November 21. 2022, at 8:30 a.m., in Division H of the 25 above-entitled Court, before the Honorable Bernard C. Barmatut, Jr. 27 28 NOTICE OF CONTINUANCE OF PI.AINTIFF'S MOTION FOR AN ORDER COMPELLINO DEFENDANT/CROSS-COMPLAINANT: WORLD OF PENTECOST-LIFE CHURCH TO PROVIDE WRITTEN RESPONSES AND DOCUMENTS TO DEMAND FOR PRODUCTION OF DOCUMENTS, SET TWO, AND FOR PREVIOUSLY IMPOSED SANCTIONS AND THE IMPOSITION OF FURTHER MONETARY SANCTIONS FOR FAILURE TO OBERY COURT ORDERS -2 Dated: November 15, 2022 L L by: Murray Tr ish, Attorneys for Plaintiff Cross-Defe ant: Aldtn Mini Storage, .P., a Californialim dpaltnershipandCr s- Defendant: Derre 'our 10 12 13 10) 17 IS 20 21 72 76 27 NOTICI OF CONTINUANC!.'F PI.AINTII'I'*S MOTION FOR AN ORDER Coivll'EI.I.INO DEI'l(NDANT/CRF).'ili-COMPI.AINAN)& WOR! D OF I'l)/I I COST LIFE CIIURCII TO I'ROVII&E 'IVRITTEN RL'SPONSES AND DOCUNff NTS TO I&ESIAND I OR I'RODUCOON Ol'OCUMIlNTS. '.in/I'WO, AND N&R I'RIIVIOUiil Y IMPOSED SANCTIONS AND Tf il1'ls ll'OSITION OF I'URTI III R MDNI'TARY sANcTIQNs I'oa I'AII URE To ouERY co(IR'I'()RI)nas -3 PROOF OF SERVICE Aldar Mini Storage, L.P. vs. THV Enterprises, Inc., et af Kern 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 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 November 15, 2022, I served the following document(s) described as: NOTICE OF CONTINUANCE OF PLAINTIFF'S MOTION FOR AN ORDER COMPELLING DEFENDANT/CROSS-COMPLAINANT: WORLD OF PENTECOST-LIFE CHURCH TO PROVIDE WRITTEN RESPONSES AND DOCUMENTS TO DEME&% FOR PRODUCTION OF DOCUMENTS. SKT TWO. AND FOR PREVIOUSLY IMPOSED SANCTIONS AaND THE IMPOSITION OF FURTHER MONETARY SANCTIONS FOR FAILURE TO OBKRY COURT ORDERS, 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 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 same day itwas placed for collection and processing. Attomev for Defendant/Cross-Defendant: Khachartur Ghasabvan aka Chris (ihasabvan P.ona!d D. Dessy, Esq. Dessy k Dessy APC 1301 "L" Street Bakersfield, California 93301 Attomev for Defendants/Cross-Defendants: TI-1V Enterorises. Tl IV kjavknarik. LLC and Tiaran Arutvunvan G. Andrew Sister, Esq. Quail Cardot, LLP 205 East River Park Circle, Suite 110 Fresno, California 93720 Attomevs for Defendant/Cross-Comnlainant: on behalf of World of Pentecost. Inc, aka World of Pentecost Life-Church. and Limited Representation 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 Offices 468 N. Camden Drive, Suite 200 226 East Sixth Street Beverly Hills, California 90210 Beauinont, California 92223 Courtesv coov: Stratton S. Barbee, Esq. Law Offices of Stratton S. Barbee 6700 Freeport Boulevard, Suite 203-A Sacramento, California 95822 Page i of 2 X (By Electronic Service) Complying with California Code of Civil Procedure tj1010.6, 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. Rond1952@aokcom Ronald D. Dessy, Esq. alexanderslaw@gmail.corn Thomas Alexanders, Jr., Esq. aslater quallcardot.corn G. Andrew Slater, Esq. strattonbarbee@hotmail.corn Stratton S. Barbee, Esq. (courtesy copy) 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 15, 2022, at Bak f ld C 1'f ' nty of Kem. Page 2 of 2