Party Discovery: SONNY BENUDIZ VS WILLIAM A. SOROKY

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 09/06/2022 04:08 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Miro,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, )                                          ESQ. ISO MEMORANDUM OF POINTS
                         INCLUSIVE,                          )                                          AND AUTHORITIES TO PLAINTIFF’S
                 15                                          )                                          MOTION TO COMPEL THE DEPOSITION
                                    Defendant.               )                                          OF WILLIAM A. SOROKY AND
                 16                                          )                                          PRODUCTION OF DOCUMENTS

                 17

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

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

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

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

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

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

                 24                  2.         I am making this Declaration in support of Defendant’s Memorandum of Points and

                 25      Authorities to Plaintiff’s Motion to Compel Deposition.

                 26                  3.         I am the principal attorney involved in every aspect of this matter. All other attorneys

                 27      and para-professionals at the Firm work under my direction and supervision in this matter. I have

                 28      carefully reviewed the file and generally know the contents therein.
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                                                                    DECLARATION OF RONALD P. SLATES, ESQ.