On February 28, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Verb Technology Company Inc.,
and
Johnson Stuart,
Success Partners Inc.,
for Other Commercial/Business Tort (not fraud/ breach of contract) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 05/06/2022 05:31 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk
1 BUCHALTER
A Professional Corporation
2 ERIC KENNEDY (SBN: 228393)
LAUREN S. JACOBS (SBN: 335265)
3 1000 Wilshire Boulevard, Suite 1500
Los Angeles, CA 90017-1730
4 Telephone: 213.891.0700
Fax: 213.896.0400
5 ekennedy@buchalter.com
ljacobs@buchalter.com
6
7 Attorneys for Specially Appearing Defendants
STUART JOHNSON AND SUCCESS PARTNERS, INC.
8
9
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
COUNTY OF LOS ANGELES
11
VERB TECHNOLOGY COMPANY, INC., a CASE NO. 22STCV07251
12 Nevada corporation,
Hon. Michelle Williams Court
13 Plaintiff,
SPECIALLY APPEARING
14 vs. DEFENDANTS STUART JOHNSON
AND SUCCESS PARTNERS, INC.’S
15 STUART JOHNSON, an individual; SUCCESS NOTICE OF MOTION AND MOTION
PARTNERS, INC., a Texas corporation; and FOR FORUM NON CONVENIENS;
16 DOES 1 through 20, inclusive, MEMORANDUM OF POINTS AND
AUTHORITIES
17 Defendants.
[RESERVATION NO. 991857274448]
18
Date: January 17, 2023
19 Time: 8:30 a.m.
Dept: 74
20
[Concurrently filed with the Declarations of
21 Stuart Johnson and [Proposed] Order]
22
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
23
PLEASE TAKE NOTICE THAT on January 17, 2023 at 8:30 a.m., or as soon thereafter
24
as counsel may be heard in Department 74 of the above-entitled Court, located at 111 North Hill
25
Street, Los Angeles, California, Defendants Stuart Johnson and Success Partners, Inc. (collectively
26
“Defendants”) will, and hereby do, move this Court for an order dismissing, or in the alternative
27
staying, this action based on the doctrine of forum non conveniens.
28
BUCHALTER
A P R O F E S S I ON A L C OR P OR A T I O N 1
L O S A N G E LE S
MOTION TO DISMISS OR STAY FOR FORUM NON CONVENIENS
Document Filed Date
May 06, 2022
Case Filing Date
February 28, 2022
Category
Other Commercial/Business Tort (not fraud/ breach of contract) (General Jurisdiction)
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 05/06/2022 05:31 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk 1 BUCHALTER A Professional Corporation 2 ERIC KENNEDY (SBN: 228393) LAUREN S. JACOBS (SBN: 335265) 3 1000 Wilshire Boulevard, Suite 1500 Los Angeles, CA 90017-1730 4 Telephone: 213.891.0700 Fax: 213.896.0400 5 ekennedy@buchalter.com ljacobs@buchalter.com 6 7 Attorneys for Specially Appearing Defendants STUART JOHNSON AND SUCCESS PARTNERS, INC. 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF LOS ANGELES 11 VERB TECHNOLOGY COMPANY, INC., a CASE NO. 22STCV07251 12 Nevada corporation, Hon. Michelle Williams Court 13 Plaintiff, SPECIALLY APPEARING 14 vs. DEFENDANTS STUART JOHNSON AND SUCCESS PARTNERS, INC.’S 15 STUART JOHNSON, an individual; SUCCESS NOTICE OF MOTION AND MOTION PARTNERS, INC., a Texas corporation; and FOR FORUM NON CONVENIENS; 16 DOES 1 through 20, inclusive, MEMORANDUM OF POINTS AND AUTHORITIES 17 Defendants. [RESERVATION NO. 991857274448] 18 Date: January 17, 2023 19 Time: 8:30 a.m. Dept: 74 20 [Concurrently filed with the Declarations of 21 Stuart Johnson and [Proposed] Order] 22 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 23 PLEASE TAKE NOTICE THAT on January 17, 2023 at 8:30 a.m., or as soon thereafter 24 as counsel may be heard in Department 74 of the above-entitled Court, located at 111 North Hill 25 Street, Los Angeles, California, Defendants Stuart Johnson and Success Partners, Inc. (collectively 26 “Defendants”) will, and hereby do, move this Court for an order dismissing, or in the alternative 27 staying, this action based on the doctrine of forum non conveniens. 28 BUCHALTER A P R O F E S S I ON A L C OR P OR A T I O N 1 L O S A N G E LE S MOTION TO DISMISS OR STAY FOR FORUM NON CONVENIENS