On March 08, 2019 a
Hearing
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)
ED/E eSED
FALAKASSA LAW, P.C. AUG 1 0 2022
2 1901 Avenue ofthe Stars Suite # 450
3 Los Angeles, Califomia 90067 By:. p. Vue
Tel.: (818) 456-6168; Fax: (888) 505-0868 Deputy Clerk
4 Email: josh@falakassalaw.com
5. ARASH S. KHOSROWSHAHI (SBN: 293246)
6 L I B E R T Y MAN LAW, P.C.
1010 F Street, Ste. 300
7 Sacramento, Califomia 95814
Tel.: (916) 573-0469; Fax: (866) 700-0787
8 Email: ash@libertymanlaw.com
9
Attomeys for Plaintiff,
10 SAJIDAZAMAN
11 SUPERIOR COURT OF CALIFORNIA
BY FAX
12 COUNTY OF SACRAMENTO
13
SAJIDA ZAMAN, CASE NO.: 34-2019-00252121
14
Plaintifif, NOTICE OF EX PARTE
15
APPLICATION FOR ORDER (1)
vs.
16 SPECIALLY SETTING HEARINGS ON
LIQUI-BOX CORPORATION, and DOES DISCOVERY MOTIONS; OR
17 through 20, inclusive. ALTERNATIVELY (2) SEEKING
HEARINGS ON DISCOVERY
18 Defendants.
MOTIONS ON SHORTENED TIME.
19 Date: August 11, 2022
Time: 9:15am
20
Dept.: 53
21 Trial Date: September 12, 2022
22
TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD:
23
NOTICE IS HEREBY GIVEN that on August 11, 2022 at 9:15a.m., or as soon thereafter
24
as the matter may be heard, in Department 53 this court, located at the Hall of Justice, 813 6th
25
Street, Sacramento, Califomia 95814, Plaintiff Sajida Zaman ("Plaintiff') will, and hereby does,
26
apply to the Court ex parte for an order (1) specially setting hearings for Plaintiffs discovery
27
motions set on September 1, 2022 to August 25, 2022, or August 26, 2022; or in the altemative
28
NOTICE OF EX PARTE APPLICATION FOR ORDER (1) SPECIALLY SETTING HEARINGS ON
DISCOVERY MOTIONS; OR ALTERNATIVELY (2) SEEKING HEARINGS ON DISCOVERY MOTIONS ON
SHORTENED TIME.
1 of 2
(2) set hearings for Plaintiffs discovery motions on shortened time, with Defendant Liqui-Box
2 Corporation's ("Defendant") opposifion papers to be filed and served five court days and
3 Plaintiffs reply papers to be filed and served two court days prior to the Court's chosen hearing
4 date per Local Rule 2.35(B).
5 This application for relief is made on the grounds that Plaintifif faces irreparable harm il
6 she is not afforded the opportunity to argue these remaining discovery motions, which go to the
7 heart of relevant and material evidence. Without this discovery, she faces an incomplete record as
8 trial fast approaches, which would jeopardize her ability to present her case fully on the merits
9 (Califomia Rules of Court, Rule 3.1202; Chavez v. 24 Hour Fitness USA, Inc. (2015) 238
10 Cal.App.4th 632.)
11 The application will be based on this Notice, Declaration of Arash S. Khosrowshahi, the
12 Memorandum of Points and Authorities, the Request for Judicial Notice in Support, on the records
13 and file herein, and on such evidence as may be presented at the hearing of the motion
14 Pursuant to Local Rule 1.06 (A), the court will make a tentative mling on the merits of this
15 matter by 2:00 p.m., the court day before the hearing. The complete text of the tentative mlings
16 for the department may be downloaded off the court's website. If the party does not have online
17 access, they may call the dedicated phone number for the department as referenced in the local
18 telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the
19 hearing and receive the tentative mling. If you do not call the court and the opposing party by 4:00
20 p.m. the court day before the hearing, no hearing will be held.
21 Dated: August 10, 2022 LIBERTY MAN LAW, P.C.
FALAKASSA LAW, P.C.
22
23
24 Arash S. Khosrowshahi
25 Joshua S. Falakassa
Attomeys for Plainfiff Sajida Zaman
26
27
28
NOTICE OF EX PARTE APPLICATION FOR ORDER (1) SPECIALLY SETTING HEARINGS ON
DISCOVERY MOTIONS; OR ALTERNATIVELY (2) SEEKING HEARINGS ON DISCOVERY MOTIONS ON
SHORTENED TIME.
2 of 2
Document Filed Date
August 10, 2022
Case Filing Date
March 08, 2019
Category
(Wrongful Termination)
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1JOSHUA S. FALAKASSA (SBN: 295045) ED/E eSED FALAKASSA LAW, P.C. AUG 1 0 2022 2 1901 Avenue ofthe Stars Suite # 450 3 Los Angeles, Califomia 90067 By:. p. Vue Tel.: (818) 456-6168; Fax: (888) 505-0868 Deputy Clerk 4 Email: josh@falakassalaw.com 5. ARASH S. KHOSROWSHAHI (SBN: 293246) 6 L I B E R T Y MAN LAW, P.C. 1010 F Street, Ste. 300 7 Sacramento, Califomia 95814 Tel.: (916) 573-0469; Fax: (866) 700-0787 8 Email: ash@libertymanlaw.com 9 Attomeys for Plaintiff, 10 SAJIDAZAMAN 11 SUPERIOR COURT OF CALIFORNIA BY FAX 12 COUNTY OF SACRAMENTO 13 SAJIDA ZAMAN, CASE NO.: 34-2019-00252121 14 Plaintifif, NOTICE OF EX PARTE 15 APPLICATION FOR ORDER (1) vs. 16 SPECIALLY SETTING HEARINGS ON LIQUI-BOX CORPORATION, and DOES DISCOVERY MOTIONS; OR 17 through 20, inclusive. ALTERNATIVELY (2) SEEKING HEARINGS ON DISCOVERY 18 Defendants. MOTIONS ON SHORTENED TIME. 19 Date: August 11, 2022 Time: 9:15am 20 Dept.: 53 21 Trial Date: September 12, 2022 22 TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD: 23 NOTICE IS HEREBY GIVEN that on August 11, 2022 at 9:15a.m., or as soon thereafter 24 as the matter may be heard, in Department 53 this court, located at the Hall of Justice, 813 6th 25 Street, Sacramento, Califomia 95814, Plaintiff Sajida Zaman ("Plaintiff') will, and hereby does, 26 apply to the Court ex parte for an order (1) specially setting hearings for Plaintiffs discovery 27 motions set on September 1, 2022 to August 25, 2022, or August 26, 2022; or in the altemative 28 NOTICE OF EX PARTE APPLICATION FOR ORDER (1) SPECIALLY SETTING HEARINGS ON DISCOVERY MOTIONS; OR ALTERNATIVELY (2) SEEKING HEARINGS ON DISCOVERY MOTIONS ON SHORTENED TIME. 1 of 2 (2) set hearings for Plaintiffs discovery motions on shortened time, with Defendant Liqui-Box 2 Corporation's ("Defendant") opposifion papers to be filed and served five court days and 3 Plaintiffs reply papers to be filed and served two court days prior to the Court's chosen hearing 4 date per Local Rule 2.35(B). 5 This application for relief is made on the grounds that Plaintifif faces irreparable harm il 6 she is not afforded the opportunity to argue these remaining discovery motions, which go to the 7 heart of relevant and material evidence. Without this discovery, she faces an incomplete record as 8 trial fast approaches, which would jeopardize her ability to present her case fully on the merits 9 (Califomia Rules of Court, Rule 3.1202; Chavez v. 24 Hour Fitness USA, Inc. (2015) 238 10 Cal.App.4th 632.) 11 The application will be based on this Notice, Declaration of Arash S. Khosrowshahi, the 12 Memorandum of Points and Authorities, the Request for Judicial Notice in Support, on the records 13 and file herein, and on such evidence as may be presented at the hearing of the motion 14 Pursuant to Local Rule 1.06 (A), the court will make a tentative mling on the merits of this 15 matter by 2:00 p.m., the court day before the hearing. The complete text of the tentative mlings 16 for the department may be downloaded off the court's website. If the party does not have online 17 access, they may call the dedicated phone number for the department as referenced in the local 18 telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the 19 hearing and receive the tentative mling. If you do not call the court and the opposing party by 4:00 20 p.m. the court day before the hearing, no hearing will be held. 21 Dated: August 10, 2022 LIBERTY MAN LAW, P.C. FALAKASSA LAW, P.C. 22 23 24 Arash S. Khosrowshahi 25 Joshua S. Falakassa Attomeys for Plainfiff Sajida Zaman 26 27 28 NOTICE OF EX PARTE APPLICATION FOR ORDER (1) SPECIALLY SETTING HEARINGS ON DISCOVERY MOTIONS; OR ALTERNATIVELY (2) SEEKING HEARINGS ON DISCOVERY MOTIONS ON SHORTENED TIME. 2 of 2