On March 12, 2021 a
Party Discovery
was filed
involving a dispute between
Kamali Rima,
and
David G. Davtyan M.D.,
for Wrongful Termination (General Jurisdiction)
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 03/17/2023 10:11 PM David W. Slayton, Executive Officer/Clerk of Court, by Y. Tarasyuk,Deputy Clerk
1 CHARLES H. JUNG (217909)
ANDREW R. KISLIK (118772)
2 NASSIRI & JUNG LLP
707 Wilshire Blvd., 46th Floor
3 Los Angeles, California 90017
Telephone: (213) 626-6200
4 Facsimile: (213) 284-3900
5 Attorneys for Defendant
David G. Davtyan, M.D.,
6 A Professional Medical Corporation
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF LOS ANGELES
10
11 RIMA KAMALI, an individual, Case No. 21STCV09820
12 Plaintiff, (Assigned for all purposes to Hon. Kristin S.
13 Escalante, Dept. 24)
vs.
14 DECLARATION OF CHARLES H. JUNG
IN SUPPORT OF DEFENDANT’S
DAVID G. DAVTYAN, M.D. A OPPOSITION TO PLAINTIFF’S EX
15 Professional Medical Corporation; and PARTE APPLICATION
DOES 1 through 25, inclusive, FOR AN ORDER STAYING
16
DEPOSITIONS UNTIL A MOTION FOR A
Defendants. PROTECTIVE ORDER MAY BE HEARD
17
18
19
20
I, Charles H. Jung, declare as follows:
21
1. I am an attorney admitted to practice in all of the courts of this state, and an attorney
22
at Nassiri & Jung LLP, counsel herein for Defendant David G. Davtyan, M.D. A Professional
23
Medical Corporation.
24
2. I requested contact information regarding Plaintiff’s employers in emails dated
25
January 12, 19 and 23, 2023, but Plaintiff’s attorney did not respond to these emails until January
26
25, 2023, when she told me that she would not provide the subsequent employers’ contact
27
information.
28
-1-
DECLARATION OF CHARLES H. JUNG ISO OPPOSITION TO PLAINTIFF’S EX PARTE APPLICATION
Document Filed Date
March 17, 2023
Case Filing Date
March 12, 2021
Category
Wrongful Termination (General Jurisdiction)
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Electronically FILED by Superior Court of California, County of Los Angeles on 03/17/2023 10:11 PM David W. Slayton, Executive Officer/Clerk of Court, by Y. Tarasyuk,Deputy Clerk 1 CHARLES H. JUNG (217909) ANDREW R. KISLIK (118772) 2 NASSIRI & JUNG LLP 707 Wilshire Blvd., 46th Floor 3 Los Angeles, California 90017 Telephone: (213) 626-6200 4 Facsimile: (213) 284-3900 5 Attorneys for Defendant David G. Davtyan, M.D., 6 A Professional Medical Corporation 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES 10 11 RIMA KAMALI, an individual, Case No. 21STCV09820 12 Plaintiff, (Assigned for all purposes to Hon. Kristin S. 13 Escalante, Dept. 24) vs. 14 DECLARATION OF CHARLES H. JUNG IN SUPPORT OF DEFENDANT’S DAVID G. DAVTYAN, M.D. A OPPOSITION TO PLAINTIFF’S EX 15 Professional Medical Corporation; and PARTE APPLICATION DOES 1 through 25, inclusive, FOR AN ORDER STAYING 16 DEPOSITIONS UNTIL A MOTION FOR A Defendants. PROTECTIVE ORDER MAY BE HEARD 17 18 19 20 I, Charles H. Jung, declare as follows: 21 1. I am an attorney admitted to practice in all of the courts of this state, and an attorney 22 at Nassiri & Jung LLP, counsel herein for Defendant David G. Davtyan, M.D. A Professional 23 Medical Corporation. 24 2. I requested contact information regarding Plaintiff’s employers in emails dated 25 January 12, 19 and 23, 2023, but Plaintiff’s attorney did not respond to these emails until January 26 25, 2023, when she told me that she would not provide the subsequent employers’ contact 27 information. 28 -1- DECLARATION OF CHARLES H. JUNG ISO OPPOSITION TO PLAINTIFF’S EX PARTE APPLICATION