On March 08, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Zaman, Sajida,
and
Does 1-20,
Liqui-Box Corporation,
for (Wrongful Termination)
in the District Court of Sacramento County.
Preview
1JOSHUA S. FALAKASSA (SBN: 295045)
FALAKASSA LAW, P.C.
2 1901 Avenue of the Stars Suite # 450
3 Los Angeles, California 90067
Tel.: (818) 456-6168; Fax: (888) 505-0868
4 Email: josh@falakassalaw.coni
5 ARASH S. KHOSROWSHAHI (SBN: 293246)
LIBERTY MAN LAW, P.C.
6 1010 F Street, Ste. 300
Sacramento, California 95814
7 Tel.: (916) 573-0469; Fax: (866) 700-0787
Email: ash@libertymanlaw.com
8
Attorneys for Plaintiff,
9 SAJIDA ZAMAN
10 SUPERIOR COURT OF CALIFORNIA
11 COUNTY OF SACRAMENTO
12 SAJIDA ZAMAN, CASE NO.: 34-2019-00252121
13 RESERVATION ID: 2656706
Plaintiff, AMENDED NOTICE OF MOTION
14 vs. AND MOTION TO COMPEL
DISCOVERY RESPONSES AS TO
15 LIQUI-BOX CORPORATION, and DOES 1 FORM INTERROGATORIES-
GENERAL, SET TWO (2), AND
through 20, inclusive, MONETARY SANCTIONS
16
Defendants. BY FAX
17 Date: August 25, 2022
18 Time: 1:30pm
Dept.: 53
19 Trial Date: September 12, 2022
20 TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD:
21 NOTICE IS HEREBY GIVEN that on August 25, 2022 at 1:30p.m., or as soon thereafter
22 as the matter may be heard, in Department 53 this court, located at the Hall of Justice, 813 6th
23 Street, Sacramento, California 95814, Plaintiff Sajida Zaman ("Plaintiff) will, and hereby does
24 move for an order (1) waiving Defendant Liqui-Box Corporation's ("Defendant") right to object
25 to Plaintiffs Form Interrogatories—General, Set Two, No. 17.1; (2) compelling a response to
26 Form Interrogatory No. 17.1 therein; and (3) sanctioning Defendant $810.00, on the grounds that
27 Plaintiff served on Defendant the Form Interrogatories electronically on May 27, 2022, but
28
AMENDED NOTICE OF MOTION AND MOTION TO COMPEL DISCOVERY RESPONSES AS TO FORM
INTERROGATORIES-GENERAL, SET TWO (2), AND MONETARY SANCTIONS
1 of 2
1 Defendant did not respond by the June 28, 2022 deadline. (Code Civ. Proc. §§ 1010.6(a)(4)(B);
2 2023.010(d), 2030.290.)
3 The motion will be based on this Notice, Declaration of Arash S. Khosrowshahi, the
4 Memorandum of Points and Authorities, on the records and file herein, and on such evidence as
5 may be presented at the hearing of the motion.
6 Dated: August 11, 2022 LIBERTY MAN LAW, P.C.
FALAKASSA LAW, P.C.
7
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By:
9 Arash S. Khosrowshahi
Joshua S. Falakassa
10
Attorneys for Plaintiff Sajida Zaman
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AMENDED NOTICE OF MOTION AND MOTION TO COMPEL DISCOVERY RESPONSES AS TO FORM
INTERROGATORIES-GENERAL, SET TWO (2), AND MONETARY SANCTIONS
2 of 2
Document Filed Date
August 11, 2022
Case Filing Date
March 08, 2019
Category
(Wrongful Termination)
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