Motion-Secondary: SONNY BENUDIZ VS WILLIAM A. SOROKY

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 09/15/2022 04:48 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Gonzalez,Deputy Clerk




                         1     RONALD P. SLATES, State Bar #43712
                               KEVIN A. HOANG, State Bar #277132
                         2     RONALD P. SLATES, A PROFESSIONAL CORPORATION
                               500 South Grand Avenue, Biltmore Tower Suite 2010
                         3     Los Angeles, California 90071
                               (213) 624-1515 / FAX (213) 624-7536
                         4     rslates2@rslateslaw.com

                         5     Attorneys for Defendant William A. Soroky

                         6

                         7

                         8                                    SUPERIOR COURT OF THE STATE OF CALIFORNIA

                         9         COUNTY OF LOS ANGELES CENTRAL DISTRICT - STANLEY MOSK COURTHOUSE

                       10

                       11      SONNY BENUDIZ,                      )                                         CASE NO. 21STCV29661
                                                                   )
                       12                 Plaintiff,               )                                         Assigned for all purposes to the Hon. Upinder S.
                                                                   )                                         Kalra, Judge - Dept 51
                       13           vs.                            )
                                                                   )                                         DECLARATION OF RONALD P. SLATES,
                       14      SOROKY A. WILLIAM AND DOES 1 TO 10, )                                         ESQUIRE IN SUPPORT OF
                               INCLUSIVE,                          )                                         DEFENDANT’S OPPOSITION TO
                       15                                          )                                         PLAINTIFF’S MOTION TO DISQUALIFY
                                          Defendant.               )                                         RONALD P. SLATES, A PROFESSIONAL
                       16                                          )                                         CORPORATION AND RONALD P.
                                                                                                             SLATES, ESQUIRE AS COUNSEL
                       17
                                                                                                             Date: September 29, 2022
                       18                                                                                    Time: 8:30 AM
                                                                                                             Dept.: 51
                       19
                                                                                                             Complaint filed: August 11, 2021
                       20                                                                                    Trial Date:      October 1, 2023

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                       22                 I, RONALD P. SLATES, do hereby declare and state as follows:

                       23                 1.          I am an attorney duly licensed to practice law before all of the Courts of the State of

                       24      California, the United States District Court of California, the 9th Circuit Court of Appeal and the

                       25      United States Supreme Court, and I have over 44 years’ experience in commercial debt collection and

                       26      enforcement of judgments. I am the sole shareholder and President of Ronald P. Slates, A Professional

                       27      Corporation (the “Firm”), which represents Defendant William A. Soroky in the within matter.

                       28                 2.          I am making this Declaration in support of Defendant’s Opposition to Plaintiff’s
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                                          Declaration of Ronald P. Slates ISO Opposition to Motion to Disqualify RPS and RPSPC as Counsel for Soroky